General Shale Brick Co.
 
Title V Renewal Application Review General Shale Brick, Plant 30, TV-14414
 
Printed:  April 19, 2005  Page 1 of 12
  
 Facility Name: General Shale Brick, Plant 30
 City: Atlanta
 County: Fulton
 AIRS #: 04-13-121-00004
 
 Application #:  TV-14414
 Date Application Received: April 7, 2003
 Permit No: 3251-121-0004-V-02-0
 
Program Review Engineers Review Managers
SSPP Hamid Yavari Richard McDonald
ISMP Deanna Oser Larry Webber
SSCP Lewis Hays Douglas Waldron
Toxics Karen Hays Karen Hays
 
 
Introduction
 
This narrative is being provided to assist the reader in understanding the content of the attached draft Part 70
operating permit.   Complex issues and unusual items are explained herein simpler terms and/or greater detail
than is sometimes possible in the actual permit.  This permit is being issued pursuant to: (1) Georgia Air Quality
Act, O.C.G.A § 12-9-1, et seq. and (2) Georgia Rules for Air Quality Control, Chapter 391-3-1, and (3) Title V
of the Clean Air Act.  Section 391-3-1-.03(10) of the Georgia Rules for Air Quality Control incorporates
requirements of Part 70 of Title 40 of the Code of Federal Regulations promulgated pursuant to the Federal
Clean Air Act.  The primary purpose of this permit is to consolidate and identify existing state and federal air
requirements applicable to General Shale Brick, Plant 30 and to provide practical methods for determining
compliance with these requirements.  The following narrative is designed to accompany the draft permit and is
presented in the same general order as the permit.  It initially describes the facility receiving the permit, the
applicable requirements and their significance, and the methods for determining compliance with those
applicable requirements.  This narrative is intended as an adjunct for the reviewer and to provide information
only. It has no legal standing.  Any revisions made to the permit in response to comments received during the
public participation and EPA review process will be described in an addendum to this narrative.
Title V Renewal Application Review General Shale Brick, Plant 30, TV-14414
 
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I. Facility Description
A. Facility Identification
1. Facility Name: General Shale Brick, Plant 30
2. Parent/Holding Company Name  
The facility Parent/Holding Company Name was General Shale Products LLC.  On January 11, 2005 a request received by the Division for name change to General Shale Brick, Inc.  
3. Previous and/or Other Name(s)  
The facility was previously known as Chattahoochee Brick Company
4. Facility Location
3195 Brick Plant Road, NW
Atlanta, Georgia 30318
Fulton County  
5. Attainment, Non-attainment Area Location, or Contributing Area
The facility is located inside the Atlanta non-attainment area.  
6. Class I Area Impacts  
The facility is not near any Class 1 area  
B. Site Determination
There are no other facilities which could possibly be contiguous or adjacent and under common control.  
C. Existing Permits
Table 1 below lists all current Title V permits, all amendments, 502(b)(10) changes, and off- permit changes, issued to the facility, based on a comparative review of form A.6, Current Permits, of the Title V application and the "Permit" file(s) on the facility found in the Air Branch office.
Table 1:  List of Current Permits, Amendments, and Off-Permit Changes
Permit Number and/or Off-
Permit Change Date of Issuance/ Effectiveness  Purpose of Issuance  
3251-121-0004-V-01-0 July 13, 1999 Initial Title V Permit
 
Title V Renewal Application Review General Shale Brick, Plant 30, TV-14414  
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D. Process Description
 
1. SIC Codes(s)
3251
The SIC Code(s) identified above were assigned by EPD's Air Protection Branch for purposes pursuant to the Georgia Air Quality Act and related administrative purposes only and are not intended to be used for any other purpose.  Assignment of SIC Codes by EPD's Air Protection Branch for these purposes does not prohibit the facility from using these or different SIC Codes for other regulatory and non-regulatory purposes.
 
Should the reference(s) to SIC Code(s) in any narratives or narrative addendum previously issued for the Title V permit for this facility conflict with the revised language herein, the language herein shall control; provided, however, language in previously issued narratives that does not expressly reference SIC Code(s) shall not be affected.
 
2. Description of Product(s)
The facility manufactures clay bricks.
 
3. Overall Facility Process Description  
Raw clay material is surface mined and transported to the plant by dump truck or railcar and placed in the Raw Clay Storage shed.  The raw material is transported from the storage shed by conveyor belt to the Grinding and Screening building.  The Grinding and Screening building processes the raw material by grinding (384 Dry Pan Grinder and Steele Hammermill) and screening (Diester Screens), to produce an easier material to mix.  Ground and screened clay is transported by conveyor belt to the Ground Storage area and placed in storage bins or silos.
 
The ground and screened clay is combined with water and other additives and fed through an extrusion machine.  A column is produced from the extrusion machine and sand coated, textured, and cut into segments called, “green brick”.  “Green brick” are stacked on kiln cars and placed in either Predryer ‘A’ or Predryer ‘B’ where the moisture content is lowered slightly.  From Predryer ‘A’ or Predryer ‘B’, the kiln cars are moved to Dryer ‘A’ and Dryer ‘B’, respectfully for further moisture removal.  Predryer ‘A’, Predryer ‘B’, Dryer ‘A’, and Dryer ‘B’ are heated with hot air from the cooling section of the kiln.
 
Dried brick are moved from Dryer ‘A’ or Dryer ‘B’ to Tunnel Kiln ‘A’ (K30A) and Tunnel Kiln ‘B’ (K30B), respectfully.  Final evaporation of free water, dehydration, oxidation, vitrification, flashing, and cooling of bricks occurs in the Tunnel Kiln ‘A’ (K30A) and Tunnel Kiln ‘B’ (K30B).  After the finished product is allowed to cool, it is stored for resale.
 
The primary fuel for Tunnel Kiln ‘A’ (K30A) and Tunnel Kiln ‘B’ (K30B) is natural gas and coal.  Exhaust from the kiln exits the kiln and vents to one of two baghouses (BGH1 and BGH2) to control Particulate Matter (PM)emissions.
 
Title V Renewal Application Review General Shale Brick, Plant 30, TV-14414
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4. Overall Process Flow Diagram  
The facility provided a process flow diagram in their Title V permit application.  Copies of these diagrams are attached.
 
E. Regulatory Status
1. PSD/NSR
 
The facility is non-major under PSD and nonattainment NSR regulations.  Average actual NOx emissions are listed at 28 tons/yr, which will make the source major for nonattainment NSR under severe nonattainment classification.  Actual and potential VOC emissions will remain non-major under severe nonattainment classification.
 
2. Title V Major Source Status by Pollutant
  Table 2:  Title V Major Source Status
If emitted, what is the facility’s Title V status for the pollutant?
Pollutant Is the Pollutant
Emitted? Major Source Status Major Source
Requesting SM Status Non-Major Source Status
PM    
PM10  
SO2    
VOC    
NOx    
CO    
TRS    
H2S    
Individual
HAP    
Total HAPs  
 
3. MACT Standards
The source requested a production limit of less than 10 tons per hour for each kiln in order
to avoid the Brick and Structural Clay Products MACT (40 CFR 63 Subpart JJJJJ)
 
4. Program Applicability (AIRS Program Codes)
Program Code Applicable
(y/n)
Program Code 6 - PSD No
Program Code 8 – Part 61 NESHAP No
Program Code 9 - NSPS No
Program Code M – Part 63 NESHAP No
Program Code V – Title V Yes
Title V Renewal Application Review General Shale Brick, Plant 30, TV-14414
 
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Regulatory Analysis  
II. Facility Wide Requirements
A. Emission and Operating Caps:
 
The initial title V permit has an emission limit of less than 4.1 tons per month for Nitrogen Oxides (NOX) for avoiding Georgia Rule 391-3-1-.02(2)(yy) (NOX Reasonable Available Control Technology, RACT).  By limiting the amount of coal used for fuel, the facility will limit NOX emissions below 50 tons per year.  The facility will have to keep records of coal consumption to demonstrate compliance.
 
On January 1, 2004, the Atlanta ozone nonattainment area was redesignated from serious to severe for the 1-hour ozone standard, which, among other things, changed the VOC and NOX major source threshold from 50 tons per year (tpy) to 25 tpy.  General Shale must either accept a federally enforceable permit limit to keep NOX emissions less than 25 tons per year from its kilns or develop and submit a Reasonably Available Control Technology Analysis (RACT)
determination for the kilns.  General Shale has submitted a RACT analysis for NOX emissions from the combination coal and natural gas fired tunnel kilns on September 29, 2004.  EPD is processing the RACT plan and will inform General Shale of its decision on or before April 1, 2005.  To eliminate the possibility of NOX emissions increase from the current permit level, conditions 3.2.1 and 3.2.2 will remain unchanged in this Title V permit renewal.
 
The record keeping requirements, pertaining to coal sampling left out of the initial permit is now added and presented as New Conditions 6.2.6.
 
Brick production is limited to less than 10 tons per hour for each kiln to avoid 40 CFR 63 Subpart JJJJJ.  Consumption of coal is limited to 13,950 tons during any twelve consecutive month period to limit NOX emissions thereby, avoiding Rule (yy).  Additional specific record keeping and reporting requirements are added to this permit renewal and presented as conditions 6.2.2-6.2.5 for coal consumption and 6.2.7-6.2.9 for brick production.
 
B. Applicable Rules and Regulations  
None applicable.  
C. Compliance Status  
Not Applicable.
D. Operational Flexibility
None applicable.  
E. Permit Conditions
None Applicable
Title V Renewal Application Review General Shale Brick, Plant 30, TV-14414
 
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III. Regulated Equipment Requirements  
A. Brief Process Description
A process description is specified in the narrative for Title V Permit No. 3251-121-0004-V-01-0
(see section I.D.3 “Overall Facility Process Description” of that narrative.).
 
B. Equipment List for the Process  
Emission Units Specific Limitations/Requirements Air Pollution Control Devices
ID No. Description Applicable
Requirements/Standards Corresponding Permit Conditions ID No. Description
K30A Tunnel Kiln 391-3-1-.02(2)(b)
391-3-1-.02(2)(e)
391-3-1-.02(2)(g)
3.2.1, 3.2.2, 3.2.3, 3.4.1,
3.4.2, 3.4.3, 5.2.1, 5.2.2,
5.2.3, 5.2.4, 6.1.7, 6.2.2,
6.2.3, 6.2.4, 6.2.5, 6.2.6,
6.2.7, 6.2.8, 6.2.9
BGH1 Baghouse
K30B Tunnel Kiln 391-3-1-.02(2)(b)
391-3-1-.02(2)(e)
391-3-1-.02(2)(g)
3.2.1, 3.2.2, 3.2.3, 3.4.1,
3.4.2, 3.4.3, 5.2.1, 5.2.2,
5.2.3, 5.2.4, 6.1.7, 6.2.2,
6.2.3, 6.2.4, 6.2.5, 6.2.6,
6.2.7, 6.2.8, 6.2.9
BGH2 Baghouse
 
C. Equipment & Rule Applicability  
Equipment and Rule Applicability specified in Permit No. 3251-121-0004-V-01-0 is discussed in the initial Title V permit narrative for this permit.  Please refer to this narrative.
 
Emission and Operating Caps:  
Not applicable
 
Rules and Regulations Assessment:  
Both tunnel kilns are subject to Georgia Rule (e) (see narrative for initial permit).  They are also subject to Georgia Rule (b) for opacity.  Since the tunnel kilns burn fuel (natural gas and coal), they are subject to Georgia Rule (g) for sulfur dioxide.  Rule (g) was omitted from the original Title V permit.  It is added to this draft permit.  
 
The MACT standard for Brick and Structural Clay Products Manufacturing (40 CFR 63, Subpart JJJJJ) was promulgated May 16, 2003.  Under the promulgated rule, an existing affected source is any tunnel kiln constructed before July 22, 2002, that has a process weight rate (throughput) of at least 10 tons of fired brick per hour.  General Shale Brick submitted an initial notification for the Plant 30 and listed the process weight rate of each kiln as less than 10.0 tons/hr.  Thus both tunnel kilns are exempt from Subpart JJJJJ.  Conditions for record keeping and reporting of compliance with production rate of less than 10 tons per hour are added to this permit renewal.
Title V Renewal Application Review General Shale Brick, Plant 30, TV-14414
 
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D. Compliance Status  
General Shale Brick, Plant 30 did not report any non-compliance in their Title V application.  
This has been confirmed with SSCP.
  
E. Operational Flexibility  
None applicable.
 
F. Permit Conditions  
Conditions for 40 CFR 63 Subpart JJJJJ avoidance has been added to this permit (Conditions 3.2.3 and 6.2.7-6.2.9)  
Georgia Rules (e), (b), and (g) are contained in condition 3.4.1 through 3.4.3.  The Rule (e)
condition was rewritten for clarity.  Rules (b) and (g) conditions are new conditions.
.
Title V Renewal Application Review General Shale Brick, Plant 30, TV-14414  
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IV. Testing Requirements (with Associated Record Keeping and Reporting)  
A. General Testing Requirements
The permit includes a requirement that the Permittee conduct performance testing on any specified emission unit when directed by the Division.  Additionally, a written notification of any performance test(s) is required 30 days prior to the date of the test(s) and a test plan is required to be submitted with the test notification.  Test methods and procedures for determining compliance with applicable emission limitations are listed and test results are required to be submitted to the Division within 60 days of completion of the testing.
 
B. Specific Testing Requirements  
1. Individual Equipment  
None applicable.  
2. Equipment Groups (all subject to the same test requirements):  
None applicable.  
Title V Renewal Application Review General Shale Brick, Plant 30, TV-14414
 
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V. Monitoring Requirements  
 
A. General Monitoring Requirements  
Condition 5.1.1 requires that all continuous monitoring systems required by the Division be operated continuously except during monitoring system breakdowns and repairs.  Monitoring system response during quality assurance activities is required to be measured and recorded.  Maintenance or repair is required to be conducted in an expeditious manner.  
 
B. Specific Monitoring Requirements  
1. Individual Equipment:  
None applicable.  
 
2. Equipment Groups (all subject to the same monitoring requirements):  
Monitoring requirements specified in Permit No. 3251-121-0004-V-01-0 are discussed in the initial Title V permit narrative for this permit.  Please refer to this narrative.  Note that even though Georgia Rules (b) and (g) were not listed as applicable requirements for the Tunnel Kilns, the narrative did discuss monitoring for Rule (b).
 
The Tunnel Kilns are subject to the sulfur dioxide requirements of Georgia Rule (g).  Both of the kilns burn natural gas and coal.  Natural gas has inherently low sulfur.  Records will be required to track and assure sulfur content of coal remains less than 2.5% by weight.
 
C. Compliance Assurance Monitoring (CAM)  
Pre-control emissions from the baghouses on the kiln exhaust are less than the major threshhold level.  Therefore, the baghouses are exempt from the CAM rule.
 
Title V Renewal Application Review General Shale Brick, Plant 30, TV-14414  
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VI. Record Keeping and Reporting Requirements  
A. General Record Keeping and Reporting Requirements  
The Permit contains general requirements for the maintenance of all records for a period of five years following the date of entry and requires the prompt reporting of all information related to deviations from the applicable requirements.  Records, including identification of any excess emissions, exceedances, or excursions from the applicable monitoring triggers, the cause of such occurrence, and the corrective action taken, are required to be kept by the Permittee and reporting is required on a semiannual basis.
 
B. Specific Record Keeping and Reporting Requirements  
General Shale Brick submitted a request for a limit on the brick production of less than 10 tons per hour to avoid compliance with for 40 CFR 63 Subpart JJJJJ.  Conditions for record keeping and reporting of compliance with production rate of less than 10 tons per hour are updated and now presented as new conditions 6.2.7-6.2.9.
 
An exceedance is defined as any time during which coal is combusted in Kilns in excess of or equal to 13,950 tons during any 12 consecutive months and brick production is greater than or equal to 10 tons per hour.  In this renewal, condition 6.1.7 is amended.
 
An excursion is defined as (1) any time two required daily determinations of visible emissions requiring action by condition 5.2.2a. or b from the same source, (2) any time the temperature at the inlet of any baghouse exceeds the filter bag design temperature and (3) any time a shipment of coal is received that contains more than 2.5% sulfur by weight.  In this renewal, condition 6.1.7 is amended.
 
Conditions for record keeping and reporting of compliance with coal consumption of less than 13,950 tons during any 12 consecutive month are updated and now presented as new conditions 6.2.2-6.2.5.
 
The record keeping requirements, pertaining to coal sampling determination, was not required by initial permit (Permit No. 4911-321-0004-V-01-0).  In this renewal condition is added for coal sampling determination and presented as new condition 6.2.6.  Condition 6.1.7 will define an excursion as any time a shipment of coal is received containing more than 2.5% sulfur, by weight.
 
Title V Renewal Application Review General Shale Brick, Plant 30, TV-14414  
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VII. Specific Requirements  
A. Operational Flexibility  
No specific operational flexibility provisions are included in the Title V permit.  The applicant did not include any alternative operating scenarios in their Title V application.
B. Alternative Requirements  
There are no alternative requirements that need to be incorporated into the Title V permit.  
B. Insignificant Activities  
See Appendix B of the Title V permit.  
D. Temporary Sources
General Shale Brick has not made a request to operate any temporary sources.
E. Short-Term Activities  
General Shale Brick did not report any short-term activities.
F. Compliance Schedule/Progress Reports  
None
G. Emissions Trading
The facility is not involved in any emission trading program.
H. Acid Rain Requirements  
The facility is not subject to any Acid Rain requirements.  
I. Stratospheric Ozone Protection Requirements  
None  
J. Pollution Prevention  
There are no specific pollution prevention provisions in the Title V permit.
K. Specific Conditions
None
Title V Renewal Application Review General Shale Brick, Plant 30, TV-14414  
Printed:  April 19, 2005  Page 12 of 12
 
VIII. General Provisions  
Generic provisions have been included in this permit to address the requirements in 40 CFR Part 70 that apply to all Title V sources, and the requirements in Chapter 391-3-1 of the Georgia Rules for Air Quality Control that apply to all stationary sources of air pollution.Title V Application Review - Addendum General Shale Brick, Plant 30, TV-14414
Printed:  April 19, 2005  Addendum Page 1 of 1
Addendum to Narrative
 
EPD issued draft Title V Permit 3251-121-0004-V-02-0 for General Shale Brick, Plant 30 in Atlanta, Georgia on December 20, 2004.  The public notice for this permit was published in the Fulton County Daily Report on January 18, 2005.  The public comment period expired February 18, 2005.  No comments were received.
 
On January 11, 2005 EPD received a letter from the facility (dated January 6, 2005) and logged as application No. 15947 requesting a name change for the Parent/Holding Company from General Shale Products LLC to General Shale Brick, Inc.  The Parent/Holding Company name has been changed as requested.