DAQ-2025-000486

1
DAQC-047-25
Site ID 10423 (B1)

MEMORANDUM

TO: FILE – INTERSTATE BRICK COMPANY (ISB)

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Robert Haynes, Environmental Scientist

DATE: January 16, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Salt Lake County,
FRS# UT0000004903500200

INSPECTION DATE: January 9, 2025

SOURCE LOCATION: 9780 South 5200 West
West Jordan, UT 84081

MAILING ADDRESS: 9780 South 5200 West
West Jordan, UT 84081

SOURCE CONTACT: Brittany Barney, EHS Coordinator
Cell: 801-436-4051
Email: [e-mail]

Jorge Mendoza, Regional EHS Manager
Office: 801-280-5223, Cell: 385-235-4339
Email: [e-mail]

Gregory Stevenson - Environmental Manager/Consultant (Basalite
Building Products LLC): 916-343-2108
Email Address: [e-mail]

OPERATING STATUS: Operating. Line #3 was shut down on July 19, 2023, due to economic
conditions.

PROCESS DESCRIPTION:

Brick and Structural Clay Manufacturing Facility:

Material Processing: Clays are trucked to the facility from Utah Lake, Southern Utah, and Wyoming.
(FEL’s) mix different clay types from the storage piles and transfer the material either to the primary
crusher or to a covered storage pile area. Cracked or damaged bricks from the end of the manufacturing
process are also added to most blends in small quantities known as “grog.”

2
All raw materials pass through the primary crusher before being conveyed to the screening building.
Next, the material passes through one of four grinders located in the screening building. The fine ground
material is then screened to a suitable size for brick formation. Screened material is transferred to one of 3
operating brick lines by being conveyed to the reclaiming building. Line #1 has not been used since 1982,
and will not be used until the scrubber is replaced. Line #2 is permanently shut down. Lines #3 and #4 are
fed from their respective reclaimers. Line #5 which was a specialty line, has been permanently shut down.
The material is then pushed by a reclaimer onto conveyors that lead to the appropriate brick line. Brick Line Processing: Additives such as manganese, barium carbonate and iron chromate are blended to the conveyed material to prevent leaching. The material drops into a pug mill that mixes the materials and adds water to form thick clay. Next, the blended material is discharged through a vacuum chamber that removes air. The material is then extruded through a die, where the clay is formed into the appropriate shape and is cut to size, creating “green” bricks. Finally, the green bricks are placed onto kiln cars that transport the bricks to the appropriate brick line holding room. Brick Line #3 (Residential Line) Processing: The holding room of line #3 pre-dries the bricks prior to entering the tunnel dryer which further dries the bricks. The holding room and tunnel dryer use waste heat from the tunnel kiln’s cooling zone. Next, the bricks enter the firing zone (~2200 °F) of the tunnel kiln. The waste heat and combustion exhaust are vented outside the building. Finally, the bricks enter the cooling zone and are cooled to ambient temperature before leaving the tunnel kiln. Brick Line #4 (Architectural Line) Processing: This line is used primarily for commercial work and is equipped with 2 extruders. A small extruder is used to make accessory bricks. The accessory bricks are dried in the shapes dryer. This dryer utilizes natural gas for combustion, with exhaust vented outside the building. Bricks from the main extruder are loaded onto pallets to be individually dried in the pallet dryer. The pallet dryer uses waste heat from the cooling zone of the tunnel kiln to dry the bricks prior to entering the holding room. The waste heat used in the pallet dryer is vented outside the building. After leaving either the shapes dryer or pallet dryer, the bricks enter the preheater. The preheater uses waste heat from the cooling zone of the tunnel kiln to heat the bricks to ~500 °F. The bricks then move on to the firing zone (~2200 °F) of the kiln. The waste heat and combustion exhaust are currently vented outside the building. Finally, the bricks are cooled in the cooling zone, to ambient temperature, before leaving the tunnel kiln.
Shipping Finished Product: Finished bricks are packaged into cubes or are palletized. The cubes or
pallets of brick are staged before being loaded onto trucks or rail cars for shipment. This company has a
maximum production capacity of 18-cars/day/tunnel kiln.

APPLICABLE REGULATIONS: Title V Permit #3500200002, Aug 22, 2023. Rev. Feb 19, 2024.
Approval Order (AO) Modification DAQE-AN104230018-24,
Dec 03, 2024.
40 CFR Part 63 Subpart A-General Provision
40 CFR Part 63 Subpart CCCCCC-Gasoline Dispensing
Facilities

3
SOURCE EVALUATION:
SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990
(CAA) except those terms and conditions that are specifically designated as "State
Requirements". (R307-415-6b)

Status: This is a statement of fact and not an inspection item.
I.B Permitted Activity(ies).
Except as provided in R307-415-7b(1), the permittee may not operate except in compliance with this permit. (See also Provision I.E, Application Shield)
Status: This is a statement of fact and not an inspection item.

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of the following: enforcement action; permit termination; revocation and reissuance;
modification; or denial of a permit renewal application. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that the Director may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit or to determine compliance with this permit. Upon request, the permittee shall also furnish to the Director copies of records required to be kept by this permit or, for information claimed to be confidential, the permittee may furnish such records directly to the EPA along with a claim of confidentiality. (R307-415-6a(6)(e))

I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance shall not stay any permit condition, except as provided under R307-415-7f(1) for minor permit modifications. (R307-415-6a(6)(c))

Status: This is a statement of fact and not an inspection item.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

4
I.D.2 Application for renewal of this permit is due on or before the date shown under
"Enforceable Dates and Timelines" at the front of this permit. An application may be
submitted early for any reason. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be accepted for processing, but shall not be considered a timely application and shall not relieve the permittee of any enforcement actions resulting from submitting a late application. (R307-415-5a(5))

I.D.4 Permit expiration terminates the permittee’s right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and (R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: The new permit expires on August 22, 2028. Application for renewal is due February
22, 2028.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's
failure to have an operating permit will not be a violation of R307-415, until the Director
takes final action on the permit renewal application. In such case, the terms and conditions
of this permit shall remain in force until permit renewal or denial. This protection shall
cease to apply if, subsequent to the completeness determination required pursuant to R307-
415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by the deadline
specified in writing by the Director any additional information identified as being needed to
process the application. (R307-415-7b(2))

Status: Application for renewal is due February 22, 2028. See status of condition I.D.

I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is
held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))

Status: This is a statement of fact and not an inspection item.

I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9.
(R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

Status: In compliance – The annual emission fee invoice was sent electronically on September
30, 2024, with a due date of October 3, 2024. No outstanding fees have been noted.

5
I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

Status: This is a statement of fact and not an inspection item.

I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes for changes that are
provided for in this permit. (R307-415-6a(8))

Status: This is a statement of fact and not an inspection item.

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow the Director or an authorized representative to perform any of the
following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related
activity is conducted, or where records are kept under the conditions of this permit.
(R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practice, or operation regulated or required under this
permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of
assuring compliance with this permit or applicable requirements.
(R307-415-6c(2)(d))

I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall
be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

Status: In compliance – Source access was granted. No statements of confidentially were made
at time of the inspection.

6
I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit
shall contain certification as to its truth, accuracy, and completeness, by a responsible
official as defined in R307-415-3. This certification shall state that, based on information
and belief formed after reasonable inquiry, the statements and information in the document
are true, accurate, and complete. (R307-415-5d)

Status: In compliance – Reports and certifications submitted by Interstate Brick Company,
appeared to have certification statements and were signed by responsible officials.

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. This certification shall be submitted no later than
the date shown under "Enforceable Dates and Timelines" at the front of this permit, and that
date each year following until this permit expires. The certification shall include all the
following (permittee may cross-reference this permit or previous reports):
(R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the
certification;

I.L.1.b The identification of the methods or other means used by the permittee for
determining the compliance status with each term and condition during the
certification period. Such methods and other means shall include, at a minimum, the
monitoring and related recordkeeping and reporting requirements in this permit. If
necessary, the permittee also shall identify any other material information that must
be included in the certification to comply with section 113(c)(2) of the Act, which
prohibits knowingly making a false certification or omitting material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period
covered by the certification, including whether compliance during the period was
continuous or intermittent. The certification shall be based on the method or means
designated in Provision I.L.1.b. The certification shall identify each deviation and
take it into account in the compliance certification. The certification shall also
identify as possible exceptions to compliance any periods during which compliance
is required and in which an excursion or exceedance as defined under 40 CFR Part
64 occurred; and

I.L.1.d Such other facts as the Director may require to determine the compliance status.

7
I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the Director:
(R307-415-6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: In compliance – The initial annual compliance certification, dated September 23, 2024,
was received on October 9, 2024, with a due date of October 10, 2024. The annual
compliance addressed the 6-month monitoring reports submitted on March 22 and
October 2, 2024. For more information, see Compliance Assistance.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any
applicable requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this
permit, or (R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and listed
in this permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section
19-2-112, and the provisions of the CAA Section 303. (R307-415-6f(3)(a))
I.M.2.b The liability of the owner or operator of the source for any violation of applicable
requirements under Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110
prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA
Section 408(a). (R307-415-6f(3)(c))

I.M.2.d The ability of the Director to obtain information from the source under Utah Code
Ann. Section 19-2-120, and the ability of the EPA to obtain information from the
source under the CAA Section 114. (R307-415-6f(3)(d))

Status: N/A – See section III of this permit.

I.N Reserved.

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

8
I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.

Status: These are statements of fact and not inspection items (I.O through I.R).

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be
retained by the permittee for a period of at least five years from the date of the
monitoring sample, measurement, report, or application. Support information
includes all calibration and maintenance records, all original strip-charts or
appropriate recordings for continuous monitoring instrumentation, and copies of all
reports required by this permit. (R307-415-6a(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the
source shall record the following information, where applicable:
(R307-415-6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or
measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or
measurement.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special
Provisions.

Status: In compliance – All required records were provided at time of the inspection.

9
I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more frequently if specified in Section II. All instances of deviation from permit requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a
responsible official in accordance with Provision I.K of this permit. (R307-415-6a(3)(c)(i)

I.S.2.c The Director shall be notified promptly of any deviations from permit requirements including those attributable to upset conditions as defined in this permit, the probable cause of such deviations, and any corrective actions or preventative measures taken. Prompt, as used in this condition, shall be defined as written notification within the number of days shown under "Enforceable Dates and Timelines" at the front of this permit. Deviations from permit requirements due to breakdowns shall be reported in accordance with the provisions of R307-107. (R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be submitted to the Director are to be sent to the following address or to such other address as may be required by the Director: Utah Division of Air Quality P.O. Box 144820 Salt Lake City, UT 84114-4820 Phone: [phone]

I.S.3.b All reports, notifications or other submissions required by this permit to be submitted to the EPA should be sent to one of the following addresses or to such other address as may be required by the Director: For annual compliance certifications: Environmental Protection Agency, Region VIII Office of Enforcement, Compliance and Environmental Justice (mail code 8ENF) 1595 Wynkoop Street Denver, CO 80202-1129 For reports, notifications, or other correspondence related to permit modifications, applications, etc.: Environmental Protection Agency, Region VIII Office of Partnerships and Regulatory Assistance Air and Radiation Program (mail code 8P-AR) 1595 Wynkoop Street Denver, CO 80202-1129 Phone: [phone]

Status: In compliance – The most recent six-month monitoring report was received on October 9, 2024, for the report period of March 23, 2024 – September 23, 2024. The previous six-month monitoring report for the report period of September 23, 2023 – March 22, 2024, was received on March 22, 2024. This report contained a deviation that occurred on March 20, 2024.
10
I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a
remaining permit term of three or more years. No such reopening is required if the
effective date of the requirement is later than the date on which this permit is due to
expire, unless the terms and conditions of this permit have been extended pursuant
to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b The Director or EPA determines that this permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other
terms or conditions of this permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Director determines that this permit must be revised or revoked to
assure compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal date
of this permit and are in conflict with existing permit conditions.
(R307-415-7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to a
Title IV affected source under the Acid Rain Program. Upon approval by EPA, excess
emissions offset plans shall be deemed to be incorporated into this permit.
(R307-415-7g(1)(b))

I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial
permit issuance and shall affect only those parts of this permit for which cause to reopen
exists. (R307-415-7g(2))

Status: This is a statement of fact and not an inspection item.

I.U Inventory Requirements.

An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission Inventories. (R307-150)

Status: In compliance – The 2023 annual emission inventory was submitted on April 5, 2024.
The 2024 emission inventory will be due on or before April 15, 2025. See the SLEIS
database.

I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of
regulations promulgated under Title IV of the Act, Acid Deposition Control, both
provisions shall be incorporated into this permit. (R307-415-6a(1)(b))

Status: This is a statement of fact and not an inspection item.

11
SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

II.A.2 Line #1
Tunnel Kiln #1. Listed for identification purposes only. Not approved for operation.

II.A.3 Line #3
Includes: Line #3 kiln, packed tower scrubber (60,000 ACFM) with mist eliminator, and
baghouse (MikroPul).

II.A.4 Line #4
Includes: Line #4 kiln
Wet scrubber (89,800 ACFM) with mist eliminator, vacuum cleaner, shapes dryer, and baghouse
(MikroPul).

II.A.5 Grizzly Hopper
Pre- August 31, 1983.

II.A.6 Primary and Secondary Crushers Pre-40 CFR Part 60, Subpart OOO facilities: (A) Primary crusher (100 ton/hr) with pulse jet baghouse. Primary crusher replaced after the NSPS effective date with equipment of equal or smaller size. Exempted from Subpart OOO by provision 40 CFR 60.670(d)(1). (B) Secondary crusher/grinding. Pre-August 31,1983. (C) Screens. Pre-August 31,1983.

II.A.7 Silos Two lime silos.

II.A.8 Clay Storage Piles Storage for raw materials.

II.A.9 Gasoline Storage Tank- 40 CFR 63 Subpart CCCCCC Above ground gasoline storage tank for fueling vehicles. Capacity approximately 1,000 gallons. Throughput less than 10,000 gallons per month.

II.A.10 Diesel Storage Tanks
Above-ground diesel storage tank for fueling vehicles. Capacity approximately 2,000 gallons.

II.A.11 Degreasers
Four parts washers.

Status: In compliance – No unapproved equipment was noted at time of the inspections. One of the
previous lime silos (Item II.A.7) was taken offline, and a new silo has been added but is not
currently in use. (At the time of inspection, it was not known when the new silo is going to be
brought online).

12
II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted facility
as indicated:

II.B.1 Permitted Source (Source wide)

II.B.1.a Condition:

Plant wide production/consumption shall not exceed:

1) 2,880 tons raw clay consumption per rolling 24-hour period.

2) 393,236 tons of brick produced in Line #3 and Line #4 combined per
rolling 12-month period.

3) 512,582 tons of brick produced plant-wide per rolling 12-month
period.

[Authority granted under R307-401-8(1)(a)[BACT]; condition originated in DAQE-AN104230017-16].

II.B.1.a.1 Monitoring:

Recordkeeping requirements for this permit condition shall serve as monitoring.

II.B.1.a.2 Recordkeeping:
To demonstrate compliance with a rolling 12-month total, a new 12-month total shall be calculated by the twentieth day of each month using data from the previous 12 months. To demonstrate compliance with a rolling 24-hour total, a new 24-hour total shall be calculated after each hour of operation using data from the previous 24 hours. Production/consumption records shall be kept on a daily basis and maintained in accordance with provision I.S.1 of his permit.

II.B.1.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – Plant wide production/consumption:

Material Limits Consumption/Production
Raw Clay Consumption 2,880 tons per rolling 24-hour period 871 Tons
(24-hour period)
Brick Produced
(Lines 3 and 4 Combined)
393,236 tons per rolling 12-month
period
111,164 Tons
(Jan 2024 through Dec 2024)
Brick Produced Plant Wide 512,582 tons per rolling 12-month
period
111,164 Tons
(Jan 2024 through Dec 2024)

13
II.B.1.b Condition:

Visible emissions from the following emission points shall not exceed the following values:

(1) All screens - 10% opacity.

(2) All conveyor transfer points - 10% opacity.

(3) All baghouses - 10% opacity.

(4) All buildings enclosing crushers - 10% opacity.

(5) All crushers - 15% opacity.

(6) All other points onsite- 20% opacity.

[Authority granted under R307-401-8(1)(a)[BACT]; condition originated in DAQE-AN104230017-16].

II.B.1.b.1 Monitoring:

If an affected emission unit is operated during a calendar quarter, an opacity observation of the emission unit shall be performed in the calendar quarter that the emission unit was operated. The
opacity observation can be conducted at any time during the quarter. The opacity observation
shall be conducted by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9, while the emission unit is operating. If visible emissions other than
condensed water vapor are observed from the emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial visual emission observation. The opacity determination shall be performed in accordance with 40 CFR
60, Appendix A, Method 9.

II.B.1.b.2 Recordkeeping:
The permittee shall keep a log which includes the location and description of each affected
emission unit. For each calendar quarter for each affected emission unit, the log shall include either the date of the opacity observation and if visual emission other than condensed water vapor were observed or a note that the emission unit was not operated. For each observed visual
emission other than condensed water vapor the permittee shall record: date and time of visual emission observation, emission unit location and description, time and date of opacity determination, and percent opacity. The records required by this provision and all data required
by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The opacity observers have been EPA Method 9 Certified since the last
inspection. The hardcopy quarterly opacity observation records (Visible Emission
Observations (VEOs)), indicated that there were no opacity exceedances of the opacity limits
mentioned above.

14
II.B.1.c Condition:

The moisture content of the clay shall be maintained at an average of no less than 4.0% by
weight. [Authority granted under R307-401-8(1)(a)[BACT]; condition originated in
DAQE-AN104230017-16].

II.B.1.c.1 Monitoring:

Clay moisture content shall be monitored using a moisture meter. The moisture meter shall be
calibrated biannually according to manufacturer specifications and procedures.

II.B.1.c.2 Recordkeeping:

Clay moisture content shall be recorded once a calendar week. Records of moisture meter
calibrations shall be maintained. A copy of manufacturer specifications for moisture meter
operation, maintenance, and calibration shall be kept on site. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.1.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status:

In compliance – Weekly Clay Moisture Content Records indicated that the clay moisture was above
4.0% by weight for all entries. When the moisture content is less than 4.0% by weight, the clay is
watered until the moisture content is above 4.0% by weight. The clay is monitored at the belt with a
moisture meter that is not required by the manufacturer to be calibrated. Testing has not been
directed by the DAQ.
II.B.1.d Condition:

The plant-wide emissions of VOCs from the brick manufacturing plant and associated operations shall
not exceed 14.87 tons per rolling 12-month period for VOCs. [Authority granted under
R307-401-8(1)(a)[BACT]; condition originated in DAQE-AN104230017-16].

II.B.1.d.1 Monitoring: Compliance with the limitation shall be demonstrated on a rolling 12-month total. Based on the twentieth day of each month, a new 12-month total shall be calculated using data from the previous 12 months. The VOC emissions shall be determined by maintaining a record of VOC-emitting materials used each month. The record shall include the following data for each material used: A. Name of the VOC-emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc. B. Density of each material used (pounds per gallon).
C. Percent by weight of all VOC in each material used.

D. Gallons of each VOC-emitting material used.

15
E. The amount of VOC emitted monthly by each material used shall be calculated by the following procedure:

VOC = % VOC by Weight x [ Density ( lb )] x Gal Consumed x 1 ton (100) (gal) 2000 lb

F. The amount of VOC emitted monthly from all materials used.
G. The amount of VOCs reclaimed for the month shall be similarly quantified and
subtracted from the quantities calculated above to provide the monthly total VOC emissions.

II.B.1.d.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – Plant wide VOC emissions for the rolling 12-month period January 2024 –
December 2024:

Pollutant Limit (Tons) Actual Emissions (Tons)
Plant Wide VOCs 14.87 2.41

II.B.1.e Condition:

The plant-wide emissions of HAPs from the brick manufacturing plant and associated
operations shall not exceed:

7.2 tons per rolling 12-month period for HCl

6.7 tons per rolling 12-month period for HF

7.0 tons per rolling 12-month period for miscellaneous HAPs

18.2 tons per rolling 12-month period for all HAPs combined.

[Authority granted under R307-401-8(1)(a)[BACT]; condition originated in DAQE-AN104230017-16].

II.B.1.e.1 Monitoring:

Compliance with the limitation shall be demonstrated on a rolling 12-month total. Based on the
twentieth day of each month, a new 12-month total shall be calculated using data from the
previous 12 months.

Compliance with HF and HCl limitations listed above shall be demonstrated using the mass
balance plan approved by the Director, submitted by ISB on October 22, 2009
(See AO DAQE-AN104230017-16, Appendices A-C).

16
If ISB submits any additional revised mass balance methods for determining annual emissions to
the Director for approval, the plan shall include, at a minimum, the following:

A. Proposed test methods and test frequency for determining the weight of the elemental
fluorine contained in the clays used to manufacture brick.

B. Proposed test methods and test frequency for determining the weight of the elemental
fluorine contained in the finished product.

C. Calculation method of determining emissions of HCL and HF which will demonstrate
compliance with the HCl and HF emission limitations listed above. The miscellaneous
HAP emissions shall be determined by maintaining a record of HAP-emitting materials
used each month. The record shall include the following data for each material used:

1. Name of the HAP-emitting material, such as: paint, adhesive, solvent, thinner,
reducers, chemical compounds, toxics, isocyanates, etc.
2. Density of each material used (pounds per gallon).

3. Percent by weight of all HAP in each material used.
4. Gallons of each HAP-emitting material used.
5. The amount of HAP emitted monthly by each material used shall be calculated by
the following procedure:
HAP = % HAP by Weight x [Density ( lb ) ] x Gal Consumed x 1 ton
(100) (gal) 2000 lb
6. The amount of HAPs emitted monthly from all materials used.

7. The amount of HAPs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC
emissions.

II.B.1.e.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.e.3

Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – Plant wide HAP emissions for the rolling 12-month period January 2024 -
December 2024:

Pollutant Limit (Tons) Actual Emissions (Tons)
HCl 7.2 0.47
HF 6.7 0.58
Miscellaneous HAPs 7.0 0.22
Combined HAPs 18.2 1.27

17
II.B.1.f Condition:

Fugitive Dust:

(1) The permittee shall submit and abide by a fugitive dust control plan acceptable to the Director for
control of dust. [Origin: DAQE-AN104230017-16].

The fugitive dust control plan must include contact information, site address, total area of
disturbance, expected start and completion dates, identification of dust suppressant and plan
certification by signature of a responsible person. [Origin: R307-309-6(5)]

(2) Opacity caused by fugitive dust shall not exceed 10% at the property boundary, and 20% on site.
[Origin: R307-309-5(1)]

(3) State Only Requirements: The above opacity requirements shall not apply when the wind speed
exceeds 25 miles per hour if the owner or operator has implemented, and continues to implement,
the accepted fugitive dust control plan and administers one or more of the following contingency
measures:

(a) Pre-event watering;

(b) Hourly watering;

(c) Additional chemical stabilization;

(d) Cease or reduce fugitive dust producing operations to the extent practicable.

[Origin: R307-309-5(3)]

(4) The permittee shall limit vehicle speeds on haul roads as follows:

(a) 15 mph within the plant and in the vicinity of the crusher; and

(b) 25 mph between the plant and the paved highway. Speed limit signs shall be posted at the
entrance to the active haul road area.

[Origin: DAQE-AN104230017-16].

(5) All roads and other operational areas that are used by mobile equipment shall be sprayed with
water to control fugitive dust. Treatment shall be applied of sufficient frequency and quantity to
maintain the surface material in a condition such that fugitive emissions are minimized, unless the
ambient temperature could result in freezing conditions.

[Authority granted under R307-401-8(1)(a)[BACT]; condition originated in DAQE-AN104230017-16].

(6) The storage piles shall be watered to minimize generation of fugitive dusts as dry conditions
warrant or as determined necessary by the Director.

[Authority granted under R307-401-8(1)(a)[BACT]; condition originated in DAQE-AN104230017-16].

18
II.B.1.f.1 Monitoring:

(1) For paragraph (1) of the above condition: recordkeeping shall serve as monitoring for the
most recently approved fugitive dust control plan.

(2) For paragraph (2) of the above condition: adherence to the most recently approved fugitive
dust control plan shall be monitored to demonstrate that appropriate measures are being
implemented to control fugitive dust in lieu of monitoring via visible emissions observations.

(3) For paragraph (3) of the above condition: wind speed shall be measured by an anemometer to
identify periods when velocity exceeds 25 mph. [Origin: R307-309-5(4); State Only
Requirement]

(4) For paragraph (4) of the above condition: vehicle/equipment speed shall be observed at a
minimum of once each year. Additionally, at least once each year, all speed limit signs shall
be inspected to assure they are still present.

(5) For paragraph (5) of the above condition: recordkeeping shall serve as monitoring (fugitive
dust control requirements that apply to roads).

(6) For paragraph (6) of the above condition: recordkeeping shall serve as monitoring (fugitive
dust control requirements that apply to storage piles).

II.B.1.f.2 Recordkeeping:

The following records shall be maintained in accordance with Provision I.S.1 of this permit:

(1) The most recently approved fugitive dust control plan. Records required by the most recently
approved fugitive dust control plan shall be maintained in accordance with the plan.

(2) Measures taken to control fugitive dust.

(3) If wind speeds are measured to establish an exception from the visible emissions limits,
records of the administered contingency measures and the wind speed measurements shall be
maintained. [State Only Requirement]

(4) Observations of the vehicle/equipment speed, and inspections of speed limit signs.

(5) Records of water treatment to suppress fugitive dust from roads. In addition to the
requirements of Provision I.S.1 of this permit, records shall include the following items:

A. Number of treatments made;

B. Dilution ratio of treatments;

C. Quantity applied;

D. Rainfall received, if any, approximate amount; and

E. Time of day treatments were made.
19
[Origin: DAQE-AN104230017-16]

(6) Records of water treatment to suppress fugitive dust from storage piles. In addition to the
requirements of Provision I.S.1 of this permit, records shall include the following items:

A. Number of treatments made;

B. Dilution ratio of treatments;

C. Quantity applied;

D. Rainfall received, if any, approximate amount; and

E. Time of day treatments were made.

[Origin: DAQE-AN104230017-16].

(7) Records shall be maintained in accordance with section I.S.1 of this permit.

II.B.1.f.3

Status:
Reporting:

There are no reporting requirements for this provision except those specified in Section I of this permit.

In compliance – Interstate Brick Company is currently using a FDCP dated March 6, 2012. A
dedicated water truck is used to control fugitive dust from haul roads, operational areas, and
storage piles. Water records are maintained. It was recommended that the hardcopy records
be electronically kept. Finally, haul road speed limit signs are posted on-site. See Compliance
Assistance.

II.B.2 Line #3

II.B.2.a Condition:

All exhaust air from Kiln #3 process streams shall be routed through the wet scrubber before being vented
to the atmosphere. [Authority granted under R307-401-8(1)(a)[BACT]; condition originated in
DAQE-AN104230017-16].

II.B.2.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.2.a.2 Recordkeeping:

Records shall be kept for all periods when the scrubber is not in use during line #3 operation.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

20
II.B.2.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Not inspected. Line #3 was shut down in July 2023, and remains offline to date.

II.B.2.b Condition:

Emissions from the Kiln #3 Scrubber Tunnel shall not exceed:

Total PM2.5* .....8.66 lb/hr (1-hr average).

PM10 ......8.66 lb/hr (1-hr average).

NOx...... 5.07 lb/hr (1-hr average)

SO2 ...... 8.09 lb/hr (1-hr average).

Total Fluorides...... 1.77 lb/hr (1-hr average).

* Including front half and back half condensable.

[Authority granted under R307-401-8(1)(a)[BACT]; condition originated in DAQE-AN104230017-16].

II.B.2.b.1 Monitoring:

Stack testing shall be performed as specified below:

(1) Frequency

Kiln #3 Scrubber Tunnel emissions shall be tested as follows:
PM10 and PM 2.5......every three calendar years.
NOx...................... every three calendar years*.
SO2...................... every calendar year.
Total Fluorides........ every five years based on the date of the last test.

Additional tests may also be required at the direction of the Director.

* If production exceeds 294,927 tons of brick produced per rolling 12-month period then testing
will be conducted each calendar year and within 90 days of exceeding the 294,927-ton limit.

(2) Notification
At least 30 days before the test, the source shall notify the Director of the date, time, and place of
testing and provide a copy of the test protocol. The source shall attend a pretest conference if
determined necessary by the Director.

21
(3) Methods

(a) Sample Location
The emission point shall conform to the requirements of 40 CFR 60, Appendix A,
Method 1, and Occupational Safety and Health Administration (OSHA) or Mine Safety
and Health Administration (MSHA) approved access shall be provided to the test
location.

(b) Emissions tests:
(1) PM10 and PM 2.5:
(i) 40 CFR 51, Appendix M, Method 201a and Method 202, or
(ii) 40 CFR 60, Appendix A, Method 5 and 40 CFR 51, Appendix M,
Method 202.

(2) NOx: 40 CFR 60, Appendix A, Method 7E.

(3) SO2: 40 CFR 60, Appendix A, Method 6C.

(4) Total Fluorides: 40 CFR 60, Appendix A, Method 13B.

(c) 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow
rate.

(d) Or other EPA approved testing methods acceptable to the Director.

(4) Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director to give the results in the specified units of the
emission limitation.

(5) Production Rate During Testing
For a source/emission point, the production rate during compliance testing shall be no less than
90% of the maximum allowable production rate (17.92 tons of product per hour). If the maximum
allowable production rate cannot be achieved at the time of the test, the following procedure shall
be followed:

(a) Testing shall be at no less than 90% of the anticipated annual production rate.

(b) If the test demonstrates compliance with the limits listed above, the maximum
allowable production rate shall be 110% of the rate achieved during the latest test.

(c) If a higher production rate is necessary, upon notification to the Director, ISB may
increase production to 110% of the highest tested rate that demonstrates compliance with
the limits limited in this condition.

II.B.2.b.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

22
II.B.2.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Not inspected. Line #3 was shut down in July 2023, and remains offline to date.

II.B.2.c Condition:

Emissions from the Line #3 Baghouse shall not exceed:

(1) Total PM2.5* ..........0.18 lb/hr and 0.016 grains/dscf (1-hr average); and

(2) PM10**.......................... 0.18 lb/hr and 0.016 grains/dscf (1-hr average).

*(dry filterable particulate only), including front half and back half condensables.

**(dry filterable particulate only)

[Authority granted under R307-401-8(1)(a)[BACT]; condition originated in DAQE-AN104230017-16].

II.B.2.c.1 Monitoring:

Stack testing shall be performed as specified below:

(1) Frequency: every three calendar years.

Additional tests may also be required at the direction of the Director.

(2) Notification

At least 30 days before the test, the source shall notify the Director of the date, time, and
place of testing and provide a copy of the test protocol. The source shall attend a pretest
conference if determined necessary by the Director.

(3) Methods

(a) Sample Location

The emission point shall conform to the requirements of 40 CFR 60, Appendix A,
Method 1, and Occupational Safety and Health Administration (OSHA) or Mine
Safety and Health Administration (MSHA) approved access shall be provided to the
test location.

(b) Emissions tests for PM10 and PM 2.5:
1. 40 CFR 51, Appendix M, Method 201a (Method 202, dry impinger not
required), or

2. 40 CFR 60, Appendix A, Method 5 (40 CFR 51, Appendix M, Method
202, dry impinger not required).

23
(c) 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow
rate.

(d) Or other EPA approved testing methods acceptable to the Director.

(4) Calculations

To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by
the appropriate methods above shall be multiplied by the volumetric flow rate and any
necessary conversion factors determined by the Director to give the results in the specified
units of the emission limitation.

(5) Production Rate During Testing

For a source/emission point, the production rate during compliance testing shall be no less
than 90% of the maximum allowable production rate (17.92 tons of product per hour). If the
maximum allowable production rate cannot be achieved at the time of the test, the following
procedure shall be followed:

(a) Testing shall be at no less than 90% of the anticipated annual production rate.

(b) If the test demonstrates compliance with the limits listed above, the maximum
allowable production rate shall be 110% of the rate achieved during the latest test.

(c) If a higher production rate is necessary, upon notification to the Director, ISB may
increase production to 110% of the highest tested rate that demonstrates compliance
with the limits limited in this condition.

II.B.2.c.2 Recordkeeping:

Results of stack testing shall be maintained in accordance with Provision I.S.1 of this permit.

The permittee shall maintain records of the occurrence and duration of any startup, shutdown, or
malfunction in the operation of Line#3; and any malfunction of the air pollution control
equipment.

II.B.2.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Not inspected. Line #3 was shut down in July 2023, and remains offline to date.

II.B.2.d Condition:

Line #3 tunnel kiln production shall not exceed 17.92 tons of product per hour.
[Authority granted under R307-401-8(1)(a)[BACT]; condition originated in DAQE-AN104230017-16].

24
II.B.2.d.1 Monitoring:

Production calculations shall be based on tons of product per hour averaged over a rolling 24-
hour period. A new 24-hour average shall be calculated after each hour of operation using data
from the previous 24 hours.

II.B.2.d.2 Recordkeeping:

Production/consumption records shall be kept on a daily basis and kept for all periods when the
plant is in operation. Records shall be maintained in accordance with provision I.S.1 of his
permit.

II.B.2.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Not inspected. Line #3 was shut down in July 2023, and remains offline to date.

II.B.2.e Condition:

Clay Prep for Line #3 shall not exceed 6,240 hours of operation per rolling 12-month period (does not
Include Kiln # 3 operating hours)
[Authority granted under R307-401-8; condition originated in DAQE-AN104230017-16].

II.B.2.e.1 Monitoring:

Hours of operation shall be calculated based on a rolling 12-month period, a new 12-month total
shall be calculated by the twentieth day of each month using data from the previous 12 months.

II.B.2.e.2 Recordkeeping:

Records shall be kept on a daily basis and kept for all periods when the plant is in operation.
Records shall be maintained in accordance with provision I.S.1 of his permit.

II.B.2.e.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Not inspected. Line #3 was shut down in July 2023, and remains offline to date.

II.B.2.f Condition:

Natural gas shall be used for fuel in Kiln #3 with propane as a backup.
[Authority granted under R307-401-8; condition originated in DAQE-AN104230017-16].

II.B.2.f.1 Monitoring:

Records required for this permit condition will serve as monitoring.

25
II.B.2.f.2 Recordkeeping:

To demonstrate compliance, fuel records shall be kept for all periods when the facility is in
operation indicating purchase of natural gas or propane.

II.B.2.f.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Not inspected. Line #3 was shut down in July 2023, and remains offline to date.

II.B.2.g Condition:

The minimum pressure drop for the Line #3 scrubber shall be 0.1 inches/w.g.

The above limit does not apply during start-up and shut-down of the scrubber. Pressure gauges shall be
located such that an inspector/operator can safely read the indicator at any time.

[Authority granted under R307-401-8; condition originated in DAQE-AN104230017-16].

II.B.2.g.1 Monitoring:

Pressure drop shall be measured once per operating day to demonstrate compliance with the
limitation.

Pressure gauges must be certified by the manufacturer to be accurate within plus or minus five
percent of the w.g. design. Pressure gauges must be calibrated on an annual basis in accordance
with the manufacturer's instructions.

II.B.2.g.2 Recordkeeping:

Pressure drop monitoring results shall be recorded on a daily basis.

Records shall be kept onsite for pressure gauges and shall include: manufacturer certifications,
calibrations, and operating instructions.

Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.g.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Not inspected. Line #3 was shut down in July 2023, and remains offline to date.

26
II.B.2.h Condition:

Line #3 scrubber fluid shall be maintained between 5-9 pH.

When the scrubber is in operation, the pH shall be within the range specified above, except during start-
up and shutdown of the scrubber.
[Authority granted under R307-401-8; condition originated in DAQE-AN104230017-16].

II.B.2.h.1 Monitoring:

A monitoring device for the continuous measurement of scrubbing solution pH shall be installed,
calibrated, maintained, and operated.
The monitoring device shall be certified by the manufacturer to be accurate within plus or minus five percent of the design pH and must be calibrated on an annual basis in accordance with the manufacturer's instructions. The pH monitoring device shall be located such that an inspector/operator can safely read the indicator at any time.

II.B.2.h.2 Recordkeeping:

The pH shall be recorded once per operating day. Continuous recording is not required. Records
shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.h.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Not inspected. Line #3 was shut down in July 2023, and remains offline to date.

II.B.2.i

Condition:

The minimum flow rate of Line #3 scrubber fluid shall be 200 gallons per minute. When the scrubber is in operation, the minimum flow rate shall be as specified above, except during start-up and shutdown of the scrubber. [Authority granted under R307-401-8(1)(a)[BACT]; condition originated in DAQE-AN104230017-16].
II.B.2.i.1 Monitoring:
A monitoring device for the continuous measurement of flow rate shall be installed, calibrated, maintained, and operated. The monitoring device shall be certified by the manufacturer to be accurate within plus or minus five percent of the design flow rate and must be calibrated on an annual basis in accordance with the manufacturer's instructions. The flow rate monitoring device shall be located such that an inspector/operator can safely read the indicator at any time.

27
II.B.2.i.2 Recordkeeping:
The scrubber flow rate shall be recorded once per operating day. Continuous recording is not
required.

II.B.2.i.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit.
Status: Not inspected. Line #3 was shut down in July 2023, and remains offline to date.

II.B.3 Line #4

II.B.3.a Condition:

All exhaust air from Kiln #4 process streams shall be routed through the wet scrubber before being vented
to the atmosphere. [Authority granted under R307-401-8]; condition originated in
DAQE-AN104230017-16].

II.B.3.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.3.a.2 Recordkeeping:

Records shall be kept for all periods when the scrubber is not in use during line #4 operation.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.3.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – All exhaust air from Kiln #4 is normally routed through the wet scrubber
before being vented to the atmosphere, apart from uncontrolled emissions during 6-month
maintenance. This is subject to change due to permit updating. Refer to compliance assistance
for more information.

II.B.3.b Condition:

Emissions from the Kiln #4 Scrubber Tunnel shall not exceed:

Total PM2.5* .....3.97 lb/hr (1-hr average).

PM10 ......3.97 lb/hr (1-hr average).

NOx ..... 10.52 lb/hr (1-hr average).

SO2 .......5.87 lb/hr (1-hr average).

28
Total Fluorides ........3.25 lb/hr (1-hr average).

*including front half and back half condensables.

[Authority granted under R307-401-8; condition originated in DAQE-AN104230017-16].

II.B.3.b.1 Monitoring:

Stack testing shall be performed as specified below:

(1) Frequency

Kiln #4 Scrubber Tunnel emissions shall be tested as follows:

PM10 and PM 2.5......every three calendar years.

NOx...........................every three calendar years*.

SO2...........................every calendar year.

Total Fluorides.........every five years based on the date of the last stack test.

Additional tests may also be required at the direction of the Director.

* If production exceeds 294,927 tons of brick produced per rolling 12-month period then testing
will be conducted each calendar year and within 90 days of exceeding the 294,927 ton limit.

(2) Notification

At least 30 days before the test, the source shall notify the Director of the date, time, and place of
testing and provide a copy of the test protocol. The source shall attend a pretest conference if
determined necessary by the Director.

(3) Methods

(a) Sample Location

The emission point shall conform to the requirements of 40 CFR 60, Appendix A,
Method 1, and Occupational Safety and Health Administration (OSHA) or Mine Safety
and Health Administration (MSHA) approved access shall be provided to the test
location.

(b) Emissions tests:

(1) PM10 and PM 2.5:

(i) 40 CFR 51, Appendix M, Method 201a and Method 202, or

(ii) 40 CFR 60, Appendix A, Method 5 and 40 CFR 51, Appendix M,
Method 202.

29
(2) NOx: 40 CFR 60, Appendix A, Method 7E.

(3) SO2: 40 CFR 60, Appendix A, Method 6C.

(4) Total Fluorides: 40 CFR 60, Appendix A, Method 13B.

(c) 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow
rate.

(d) Or other EPA approved testing methods acceptable to the Director.

(4) Calculations

To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director to give the results in the specified units of the
emission limitation.

(5) Production Rate During Testing

For a source/emission point, the production rate during compliance testing shall be no less than
90% of the maximum allowable production rate (26.97 tons of product per hour). If the maximum
allowable production rate cannot be achieved at the time of the test, the following procedure shall
be followed:

(a) Testing shall be at no less than 90% of the anticipated annual production rate.

(b) If the test demonstrates compliance with the limits listed above, the maximum
allowable production rate shall be 110% of the rate achieved during the latest test.

(c) If a higher production rate is necessary, upon notification to the Director, ISB may
increase production to 110% of the highest tested rate that demonstrates compliance with
the limits limited in this condition.

II.B.3.b.2 Recordkeeping:

Results of stack testing shall be kept for all periods when the scrubber is not in use during line #4
operation. Records shall be maintained in accordance with Provision I.S.1 of this permit.

The permittee shall maintain records of the occurrence and duration of any startup, shutdown, or
malfunction in the operation of Line #4; and any malfunction of the air pollution control
equipment.

30
II.B.3.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The most current Kiln #4 scrubber stack test results are shown below. The
next stack testing will occur in 2025. Testing has not yet been scheduled.

Test Date Pollutant Limit (lb/hr) Results (lb/hr)
08/08/2022 PM10/2.5 3.97 1.20
07/28-29/2021 NOx 10.52 2.50
07/20/2023 SO2 5.87 0.11
07/14/2020 TF 3.25 0.07

II.B.3.c Condition:

Emissions from the Line #4 Baghouse shall not exceed:

Total PM2.5* ... 0.34 lb/hr and 0.016 grains/dscf (1-hr average).

PM10 ...............0.34 lb/hr (dry filterable particulate only), and 0.016 grains/dscf (1-hr average).

*(dry filterable particulate only), including front half and back half condensable

[Authority granted under R307-401-8; condition originated in DAQE-AN104230017-16].

II.B.3.c.1 Monitoring:

Stack testing shall be performed as specified below:

(1) Frequency: every three calendar years.

Additional tests may also be required at the direction of the Director.

(2) Notification

At least 30 days before the test, the source shall notify the Director of the date, time, and place of
testing and provide a copy of the test protocol. The source shall attend a pretest conference if
determined necessary by the Director.

(3) Methods

(a) Sample Location

The emission point shall conform to the requirements of 40 CFR 60, Appendix A,
Method 1, and Occupational Safety and Health Administration (OSHA) or Mine Safety
and Health Administration (MSHA) approved access shall be provided to the test
location.

31
(b) Emissions tests for PM10 and PM 2.5:

(1) 40 CFR 51, Appendix M, Method 201a (Method 202 not required), or

(2) 40 CFR 60, Appendix A, Method 5 and 40 CFR 51 (Method 202 not
required).

(c) 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow
rate.

(d) Or other EPA approved testing methods acceptable to the Director.

(4) Calculations

To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director to give the results in the specified units of the
emission limitation.

(5) Production Rate During Testing
For a source/emission point, the production rate during compliance testing shall be no less than
90% of the maximum allowable production rate (26.97 tons of product per hour). If the maximum
allowable production rate cannot be achieved at the time of the test, the following procedure shall
be followed:

(a) Testing shall be at no less than 90% of the anticipated annual production rate.

(b) If the test demonstrates compliance with the limits listed above, the maximum
allowable production rate shall be 110% of the rate achieved during the latest test.

(c) If a higher production rate is necessary, upon notification to the Director, ISB may
increase production to 110% of the highest tested rate that demonstrates compliance
with the limits limited in this condition.

II.B.3.c.2 Recordkeeping:

Results of stack testing shall be kept for all periods when the scrubber is not in use during line #4
operation. Records shall be maintained in accordance with Provision I.S.1 of this permit.

The permittee shall maintain records of the occurrence and duration of any startup, shutdown, or
malfunction in the operation of Line #4; and any malfunction of the air pollution control
equipment.

32
II.B.3.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The most current Kiln #4 baghouse stack test results are shown below. The next
testing is to be scheduled in 2025.

Test Date Pollutant Limits (lb/hr) Results (lb/hr)
08/08/2022 PM10/2.5 0.34 0.017

II.B.3.d Condition:

Line #4 tunnel kiln production shall not exceed 26.97 tons of product per hour averaged over a rolling 24-
hour period. [Authority granted under R307-401-8; condition originated in DAQE-AN104230017-16].

II.B.3.d.1 Monitoring:

Production calculations shall be based on tons of product per hour averaged over a rolling 24-
hour period. A new 24-hour average shall be calculated after each hour of operation using data
from the previous 24 hours.

II.B.3.d.2 Recordkeeping:

Production/consumption records shall be kept on a daily basis and kept for all periods when the
plant is in operation. Records shall be maintained in accordance with provision I.S.1 of his
permit.

II.B.3.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The line #4 kiln produced 10.80 tph of product in a 24-hour period. Daily
records are kept.

II.B.3.e Condition:

Clay Prep for Line # 4 shall not exceed 6,240 hours of operation per rolling 12-month period (does not
Include Kiln # 4 operating hours) [Authority granted under R307-401-8; condition originated in
DAQE-AN104230017-16].

II.B.3.e.1 Monitoring:

Hours of operation shall be calculated based on a rolling 12-month period, a new 12-month total
shall be calculated by the twentieth day of each month using data from the previous 12 months.

33
II.B.3.e.2 Recordkeeping:

Records shall be kept on a daily basis and kept for all periods when the plant is in operation.
Records shall be maintained in accordance with provision I.S.1 of his permit.

II.B.3.e.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The clay prep for line #4 operated for 4,612 hours in the 12-month period
January 2024 – December 2024. Daily records are kept.

II.B.3.f Condition:

Natural gas shall be used for fuel in Kiln #4 with propane as a backup. [Authority granted under
R307-401-8; condition originated in DAQE-AN104230017-16].

II.B.3.f.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.3.f.2 Recordkeeping:

To demonstrate compliance, fuel records shall be kept for all periods when the facility is in
operation indicating purchase of natural gas or propane.

II.B.3.f.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – Kiln #4 is only fueled by natural gas. There are leased propane tanks on-site,
however they are not connected to the kiln.

II.B.3.g Condition:

The minimum pressure drop for the Line #4 scrubber shall be 2.0 inches/w.g.

The above limit does not apply during start-up and shut-down of the scrubber.

Pressure gauges shall be located such that an inspector/operator can safely read the indicator at any time.
[Authority granted under R307-401-8; condition originated in DAQE-AN104230017-16].

II.B.3.g.1 Monitoring:

Pressure drop shall be measured once per operating day to demonstrate compliance with the
limitation.

34
Pressure gauges must be certified by the manufacturer to be accurate within plus or minus five
percent of the w.g. design. Pressure gauges must be calibrated on an annual basis in accordance
with the manufacturer's instructions.

II.B.3.g.2 Recordkeeping:

Pressure drop monitoring results shall be recorded on a daily basis.

Records shall be kept onsite for pressure gauges and shall include: manufacturer certifications,
calibrations, and operating instructions.

Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.3.g.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The line #4 scrubber’s pressure drop is recorded once per day. The recorded
pressure drop, at time of the inspection, was 8.90 inches /w.g. Gauges are calibrated annually,
by WSC, and are located for easy access.

II.B.3.h Condition:

Line #4 scrubber fluid shall be maintained between 5-9 pH.

When the scrubber is in operation, the pH shall be within the range specified above, except during
start-up and shutdown of the scrubber. [Authority granted under R307-401-8; condition originated in
DAQE-AN104230017-16].

II.B.3.h.1 Monitoring:

A monitoring device for the continuous measurement of scrubbing solution pH shall be installed,
calibrated, maintained, and operated.

The monitoring device shall be certified by the manufacturer to be accurate within plus or minus
five percent of the design pH and must be calibrated on an annual basis in accordance with the
manufacturer's instructions.

The pH monitoring device shall be located such that an inspector/operator can safely read the
indicator at any time.

II.B.3.h.2 Recordkeeping:

The pH shall be recorded once per operating day. Continuous recording is not required.

35
II.B.3.h.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The line #4 scrubber’s pH is recorded once per day. The recorded pH at time
of the inspection, was 7.0. Gauges are calibrated annually by WSC, and are located for easy
access.

II.B.3.i Condition:

The minimum flow rate of Line #4 scrubber fluid shall be 600 gallons per minute.

When the scrubber is in operation, the minimum flow rate shall be as specified above, except during
start-up and shutdown of the scrubber. [Authority granted under R307-401-8; condition originated in
DAQE-AN104230017-16].

II.B.3.i.1 Monitoring:

A monitoring device for the continuous measurement of flow rate shall be installed, calibrated, maintained, and operated. The monitoring device shall be certified by the manufacturer to be accurate within plus or minus five percent of the design flow rate and must be calibrated on an annual basis in accordance with the manufacturer's instructions. The flow rate monitoring device shall be located such that an inspector/operator can safely read the indicator at any time.

II.B.3.i.2 Recordkeeping:

The scrubber flow rate shall be recorded once per operating day. Continuous recording is not
required.

II.B.3.i.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The line #4 scrubber’s fluid flow rate is recorded once per day. The recorded flow rate, at time of the inspection, was 721 gpm. The flow meters are calibrated annually by WSC, and are located for easy access.
II.B.4 Primary and Secondary Crushers

II.B.4.a Condition:

All exhaust air from the Primary Crusher Building shall be routed through the Primary Crusher Baghouse
before being vented to the atmosphere. [Authority granted under R307-401-8(1)(a)[BACT]; condition
originated in DAQE-AN104230017-16].

36
II.B.4.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.4.a.2 Recordkeeping:

Records shall be kept for all periods when the Primary Crusher Baghouse is not in use during
crusher operation. Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.4.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The primary crusher baghouse is installed and appears to control emissions
from the building to the atmosphere.

II.B.4.b Condition:

Emissions from the Primary Crusher Baghouse Vent shall not exceed: Total PM2.5* ........ 0.56 lb/hr and 0.010 grains/dscf (1-hr average). PM10........................0.56 lb/hr (dry filterable particulate only), and 0.010 grains/dscf (1-hr average). *(dry filterable particulate only), including front half and back half condensables. [Authority granted under R307-401-8; condition originated in DAQE-AN104230017-16].

II.B.4.b.1 Monitoring:

Stack testing shall be performed as specified below:

(1) Frequency: every three calendar years.

Additional tests may also be required at the direction of the Director.

(2) Notification

At least 30 days before the test, the source shall notify the Director of the date, time, and place of
testing and provide a copy of the test protocol. The source shall attend a pretest conference if
determined necessary by the Director.

(3) Methods

(a) Sample Location

The emission point shall conform to the requirements of 40 CFR 60, Appendix A,
Method 1, and Occupational Safety and Health Administration (OSHA) or Mine Safety
and Health Administration (MSHA) approved access shall be provided to the test
location.

37
(b) Emissions tests for PM10 and PM 2.5:
(1) 40 CFR 51, Appendix M, Method 201a (Method 202, not
required), or

(2) 40 CFR 60, Appendix A, Method 5 (40 CFR 51, (Method 202 not required).

(c) 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow
rate.

(d) Or other EPA approved testing methods acceptable to the Director.

(4) Calculations

To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director to give the results in the specified units of the
emission limitation.

(5) Production Rate During Testing

For a source/emission point, the production rate during compliance testing shall be no less than
90% of the maximum allowable production rate (crusher rating 100 tons/hr). If the maximum
allowable production rate cannot be achieved at the time of the test, the following procedure shall
be followed:

(a) Testing shall be at no less than 90% of the anticipated annual production rate.

(b) If the test demonstrates compliance with the limits listed above, the maximum
allowable production rate shall be 110% of the rate achieved during the latest test.

(c) If a higher production rate is necessary, upon notification to the Director, ISB may
increase production to 110% of the highest tested rate that demonstrates compliance
with the limits limited in this condition.

II.B.4.b.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.4.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The latest primary crusher baghouse stack test results are shown below. Next stack
test is to be scheduled in 2025.

Test Date Pollutant Limit (lb/hr) Results (lb/hr)
08/08/2022 PM10/2.5 0.56 0.035

38
II.B.4.c Condition:

The minimum pressure drop for the Primary Crusher Baghouse shall be:

(A) 2.0 in inches/w.g. when using polyester felt; or

(B) 0.4 in inches/w.g. when using PTFE membrane

The above limits do not apply during a period of ten crusher operating days following filter media
replacement.

Pressure gauges shall be located such that an inspector/operator can safely read them at any time.

[Authority granted under R307-401-8; condition originated in DAQE-AN104230017-16].

II.B.4.c.1 Monitoring:

Pressure drop shall be measured once per operating day to demonstrate compliance with the
above limitation.

Pressure gauges must be certified by the manufacturer to be accurate within plus or minus five
percent of the w.g. design. Pressure gauges must be calibrated on an annual basis in accordance
with the manufacturer's instructions.

II.B.4.c.2 Recordkeeping:

Pressure drop monitoring results shall be recorded on a daily basis.
Records shall be kept onsite for pressure gauges and shall include: manufacturer certifications,
calibrations, and operating instructions.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.4.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – According to Interstate Brick Company the primary crusher baghouse
pressure drop averages 2.0 – 2.5 inches/w.g. The pressure drop is recorded once per day. The
gauges are calibrated annually by WSC, and are located for easy access. The gauges were last
calibrated on April 26, 2024.

II.B.5 Gasoline Storage Tank- 40 CFR 63 Subpart CCCCCC

II.B.5.a Condition:

For each gasoline storage tank with a throughput less than 10,000 gallons per month the permittee shall
allow gasoline to be handled in a manner that would not result in vapor releases to the atmosphere for
extended periods of time. Measures to be taken include, but are not limited to, the following:

39
(1) Minimize gasoline spills;
(2) Clean up spills as expeditiously as practicable;
(3) Cover all open gasoline containers and all gasoline storage tank fill-pipes with a gasketed seal
when not in use;
(4) Minimize gasoline sent to open waste collection systems that collect and transport gasoline to
reclamation and recycling devices, such as oil/water separators.

The permittee shall also, at all times, operate and maintain any affected source, including
associated air pollution control equipment and monitoring equipment, in a manner consistent with
safety and good air pollution control practices for minimizing emissions. Determination of
whether such operation and maintenance procedures are being used will be based on information
available to the Administrator which may include, but is not limited to, monitoring results, review
of operation and maintenance procedures, review of operation and maintenance records, and
inspection of the source. [Authority granted under: 40 CFR 63 Subpart CCCCCC40]; condition
originated in 40 CFR 63.11116 and 63.11115].

II.B.5.a.1 Monitoring:

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 3 of 40 CFR 63 Subpart CCCCCC. [40 CFR 63.11130]

Records required for this permit condition will serve as monitoring.

II.B.5.a.2 Recordkeeping:

The permittee shall, upon request of the Director, demonstrate their monthly throughput is less
than 10,000 gallons within 24 hours of the request. Records shall be maintained in accordance
with Provision I.S.1 of this permit. A log shall be maintained to document records in accordance
with 40 CFR 63.11125. [40 CFR 63.11111(e) and 63.11116(b)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 3 of 40 CFR 63 Subpart CCCCCC. [40 CFR 63.11130].

II.B.5.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The highest gasoline throughput since the last inspection was 989 gallons (in
the period of January through December 2024). All of the above measures used to minimize
gas vapors are used by Interstate Brick Company, except for item 4. Item 4 is considered
nonapplicable.

40
II.B.6 Degreasers

II.B.6.a Condition:

The permittee shall ensure that the following conditions are met:

(1) Each solvent degreaser is equipped with a cover which shall remain closed except during actual
loading, unloading or handling of parts in cleaner. The cover shall be designed so that it can be
easily operated with one hand if:

(a) the volatility of the solvent is greater than 2 kPa (15 mm Hg or 0.3 psi) measured at
38 degrees C (100 degrees F),

(b) the solvent is agitated, or

(c) the solvent is heated.

(2) An internal draining rack for cleaned parts shall be installed on which parts shall be drained until
all dripping ceases. If the volatility of the solvent is greater than 4.3 kPa (32 mm Hg at 38
degrees C (100 degrees F)), the drainage facility must be internal, so that parts are enclosed under
the cover while draining. The drainage facility may be external for applications where an internal
type cannot fit into the cleaning system.

(3) Waste or used solvent shall be stored in covered containers.

(4) Tanks, containers and all associated equipment shall be maintained in good operating condition
and leaks shall be repaired immediately or the degreaser shall be shutdown.

(5) Written procedures for the operation and maintenance of the degreasing or solvent cleaning
equipment shall be permanently posted in an accessible and conspicuous location near the
equipment.

(6) If the solvent volatility is greater than 4.3 kPa (33 mm Hg or 0.6 psi) measured at 38 degrees C
(100 degrees F), or if solvent is heated above 50 degrees C (120 degrees F), then one of the
following control devices shall be used:

(a) freeboard that gives a freeboard ratio greater than 0.7;

(b) water cover if the solvent is insoluble in and heavier than water;

(c) other systems of equivalent control, such as a refrigerated chiller or carbon
absorption.

(7) If used, the solvent spray shall be a solid fluid stream at a pressure which does not cause
excessive splashing and may not be a fine, atomized or shower type spray.

[Authority granted under R307-335-4; condition originated in R307-335-4].

41
II.B.6.a.1 Monitoring:

A visual observation shall be conducted each calendar month for all equipment and applicable
work practices.

II.B.6.a.2 Recordkeeping:

Results of monthly inspections and the volatility of the solvent(s) being used shall be recorded
and maintained as described in Provision I.S.1 of this permit.

II.B.6.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – There are two parts washers on-site. The parts washers are covered when not
in use. Operational instructions are posted on the lids and can be seen when the lids are
closed. Monthly visual inspections are conducted and are logged. Safety-Kleen is used to
maintain the degreasers.

II.C Emissions Trading
(R307-415-6a(10))

Not applicable to this source.

II.D Alternative Operating Scenarios.
(R307-415-6a(9))

Not applicable to this source.

II.E Source-specific Definitions.

There are no source specific definitions for this permit.

SECTION III: PERMIT SHIELD

A permit shield was not granted for any specific requirements.

SECTION IV: ACID RAIN PROVISIONS

IV.A This source is not subject to Section IV.

Additional conditions for compliance regarding Approval Order DAQE-AN104230018-24 of
December 3, 2024:

Project Description This modification includes:

1. The addition of emissions from crushing and screening as a result of baghouse vent reconfiguration.
Previously, on-site baghouses vented internally, causing hazardous indoor conditions. As a remediation to
internal dust issues, the baghouses will now vent out of the building. This change will result in an
increase in PM10 and PM2.5 emissions.
42
2. A reduction in NOx emissions. Reductions are based on 20+ years of emission testing on Kiln #3 and
Kiln #4. The new kiln lb/hr limits will be added (4.70 lb/hr for Kiln #3 and 6.40 lb/hr for Kiln #4). This
reduction will remove IBS from SIP consideration; testing for these kilns will be increased from every
five years to every year.

3. Site-wide conditions were updated to comply with administrative standards and updates. There were no
changes to requirements as a result of these updates beyond the reduced NOx rates and increased NOx-
based stack testing frequency. Speed-related requirements were removed as emissions for hauling are
limited by the 20% opacity requirements for fugitive emissions.

4. ISB submitted a second notification for the inclusion of a replacement soda ash silo and controlling bin
vent. This project will be consolidated into the permit modification. The replacement silo and bin vent
will not increase total soda ash usage or expected emissions. The silos were labeled as "lime silos"
(II.A.7) in the existing AO. This label will be updated.

Status: Kiln #3 and Kiln #4 NOX emission changes have been used in new testing if applicable. None
of the new equipment changes have been completed as of this inspection. Not evaluated.

EMISSION INVENTORY: The 2023 Emissions Inventory received April 05, 2024:

Pollutants Total Tons/Year
PM10 24.20
PM2.5 11.26
SO2 7.10
NOx 26.72
VOC 2.49
CO 42.12
HF 0.61
HCl 0.99

PREVIOUS ENFORCEMENT
ACTIONS: 1) November 17, 2020 (C-1456-20) – Warning Letter
2) April 21, 2022 (C-522-22) – Warning Letter
3) July 25, 2023 (C-629-23) – Settlement Agreement

COMPLIANCE STATUS &
RECOMMENDATIONS: In compliance with conditions of the Operating Permit
#3500200002, dated August 22, 2023, and revised A.O.
February 19, 2024, at time of the inspection.

HPV STATUS: Not applicable.

43
COMPLIANCE ASSISTANCE: 1) Discussed revising Excess Emission report, Six Month
Monitoring report, Deviation report and current Compliance
Certification. Regarding the deviation of condition II.B.3.b.

2) Discussed putting water records into an electronic filing
system. See condition II.B.1.f.

3) Interstate Brick is recommended to update permit regarding
excess emissions during Scrubber #4 maintenance. ISB has
bypassed the scrubber and emitted emissions uncontrolled
during its six-month maintenance and submitted deviation
reports when this occurred (March 22, 2024, and October 16,
2024). Aside from these two instances, ISB is in compliance
of this condition (See I.S.2).

RECOMMENDATION FOR
NEXT INSPECTION: Verify that all required reports have been submitted on time.
Facility partially shuts down during December. Joe Eck is no
longer the point of contact - going forward, please contact
Brittany Barney or Jorge Mendoza. Inspect as usual.

ATTACHMENTS: VEO Form