From: "Reinbold, Kimbra" <Kimbra.Reinbold@epa.state.oh.us>

To: Jeff Telander/RTP/USEPA/US@EPA

Date: 10/05/2012 09:27 AM

Subject: Belden Brick testing information

Jeff:

Attached is the letter we sent to Belden that summarizes the results of the 7/11 and 11/11 stack testing. 

The 11/11 results are being forwarded shortly. Thanks!

Kim(See attached file: Belden_Brick_Stack Test Form Ltr Fail.klrcomments2.docx)

From: "Reinbold, Kimbra" <Kimbra.Reinbold@epa.state.oh.us>

To: Jeff Telander/RTP/USEPA/US@EPA

Date: 10/05/2012 09:28 AM

Subject: FW: Plant 3 Stack Test Results 1 of 2

Jeff:

1st of two files for Belden.

Kim

From: Belden, Bradley [mailto:Bradley.Belden@beldenbrick.com] 

Sent: Thursday, December 22, 2011 3:27 PM

To: Reinbold, Kimbra

Subject: Plant 3 Stack Test Results 1 of 2

Kim,

Please find the results from the Plant 3 stack test that was conducted on November 8, 2011. The 

summary results begin on page 12/147 in PDF part 1 of 2. We have been in contact with Opsis, the CEM 

manufacturer, to get their opinion on Method 26a and how that correlates to their CEM settings. We 

will be facilitating more discussions with them in light of these results. We will let you know the results 

of these discussions and any actions that may arise from them.

Please be aware that Plant 3 was shut down on November 23, 2011 due to weak economic demand.

Bradley H. Belden

Corporate Manager - Occupational & Regulatory Services

The Belden Brick Company

(330) 456-0031

(See attached file: 2011-11-08 Plt 3 Stack Test Results (1 of 2).pdf)
From: "Reinbold, Kimbra" <Kimbra.Reinbold@epa.state.oh.us>

To: Jeff Telander/RTP/USEPA/US@EPA

Date: 10/05/2012 09:29 AM

Subject: FW: Plant 3 Stack Test Results 2 of 2

Jeff:

2nd of two stack test files for Belden.

Thx!

Kim

From: Belden, Bradley [mailto:Bradley.Belden@beldenbrick.com] 

Sent: Thursday, December 22, 2011 3:34 PM

To: Reinbold, Kimbra

Subject: Plant 3 Stack Test Results 2 of 2

Happy Holidays to you too.

Bradley H. Belden

Corporate Manager - Occupational & Regulatory Services

The Belden Brick Company

(330) 456-0031

(See attached file: 2011-11-08 Plt 3 Stack Test Results (2 of 2).pdf)
February 22, 2012 RE: Tuscarawas County

The Belden Brick Company

Facility ID #:0679000118

EU #: P301

COMPLIANCE TEST

HPV-GC8 Notice of Violation 

CERTIFIED: 70101060000178963669

Mr. Bradley Belden

The Belden Brick Company

P.O. Box 430

Sugarcreek, OH 44681

Dear Mr. Belden:

On July 25, 2011, Blue Mountain Environmental performed a hydrogen halides 

emissions test at The Belden Brick Company, 475 Dover Rd, Sugarcreek, Ohio. The 

emissions test was performed on Emissions Unit (EU) P301, the Plant 3 Tunnel Kiln #1 

which is controlled with a dry injection fabric filter scrubber. The test was conducted at 

the request of U.S. EPA to assist with MACT development. The results of the test 

indicated that EU P301 was not in compliance with the applicable Ohio EPA regulations 

and permit terms and conditions for hydrogen fluoride (HF). The results of the test were 

reported to Ohio EPA on October 26, 2011. 

On November 8, 2011, Air/Compliance Consultants, Inc. performed another hydrogen 

halides emissions test on EU P301. The test was conducted as a follow-up test to 

demonstrate compliance with your permit terms and conditions. The results of the test 

were reported to Ohio EPA on December 22, 2011. This test consisted of two operating 

conditions, both using normal production while changing the rate of lime injection. Lime 

injection is used to control the HF emissions. 

The test reports have been reviewed and we have concluded that the tests were

conducted according to the procedures specified in 40 CFR Part 60, Appendix A, U.S. 

EPA Test Methods 1 through 4 and 26A. The results of the tests indicated that EU P301

was not in compliance with the applicable Ohio EPA regulations and facility permit 

terms and conditions for HF during the July 25, 2011 test and the November 8, 2011 

operating condition 1 test. However, compliance with the HF limit was demonstrated 

during the November 8, 2011 operating condition 2 test.
Mr. Bradley Belden

The Belden Brick Company

February 22, 2012

Page 2

2

Belden Brick permit requirements and 07/25/2011 test results for EU P301:

P301 – Kiln #1 HCl HF Cl2

Tested Emission Rate: 0.180 lb/hr 2.95 lbs/hr 0.054 lb/hr

Allowable Emission 

Rate:

1.2 lbs/hr 1.9 lbs/hr No limit in permit.

Source Operating 

Rate:

7.06 tons/hr

(13.78 tons/hr, 

maximum)

Test Lime Injection 

Rate:

67.5 lbs/hr

Test Sodium 

Bicarbonate Injection 

Rate:

66.5 lbs/hr

Test Fabric Filter

Differential Pressure 

Drop:

3.4 inches of 

water

Belden Brick permit requirements and 11/08/2011 test results for EU P301:

P301 – Kiln #1 

Operating Condition 1

HCl HF Cl2

Tested Emission Rate: 0.4 lb/hr 3.0 lbs/hr 0.029 lb/ton

Allowable Emission 

Rate:

1.2 lbs/hr 1.9 lbs/hr 0.026 lb/ton

Source Operating Rate: 7.08 tons/hr 

(13.78 tons/hr, 

maximum)

Test Lime Injection 

Rate:

4.1 lbs/hr

Test Sodium 

Bicarbonate Injection 

Rate:

Not reported

Test Fabric Filter

Differential Pressure 

Drop:

1.5 inches of 

water

 

Belden Brick permit requirements and 11/08/2011 test results for EU P301:

P301 – Kiln #1 

Operating Condition 2

HCl HF Cl2

Tested Emission Rate: 0.2 lb/hr 1.0 lb/hr 0.003 lb/ton

Allowable Emission 

Rate:

1.2 lbs/hr 1.9 lbs/hr 0.026 lb/ton

Source Operating Rate: 7.08 tons/hr 

(13.78 tons/hr, 

maximum)
Mr. Bradley Belden

The Belden Brick Company

February 22, 2012

Page 3

3

Test Lime Injection 

Rate:

37.0 lbs/hr

Test Sodium 

Bicarbonate Injection 

Rate:

Not reported

Test Fabric Filter

Differential Pressure 

Drop:

1.5 inches of 

water

 

After Belden Brick received the results of the July 25, 2011 test, the company began 

investigating the conflict between the Method 26A sampling data and the continuous 

emissions monitoring system (CEMS) data for HF that is used to control the lime feed to 

the fabric filter scrubber. The HF CEMS is not required to be certified, but the CEMS 

manufacturer, Opsis, was contacted for assistance, and a separate CEMS unit was 

brought in. The company ran its CEMS and the CEMS unit provided by the 

manufacturer concurrently, and both CEMS were reading approximately the same HF 

emission rates. The company then began investigating potential problems with the 

Method 26A test run in July, but no issues were discovered. During the test conducted 

on November, the HF emission rates again exceeded the permit limitation when the 

CEMS was set at the same HF rate of approximately 1.0 pound per hour (operating 

condition 1) that was established during the July test. However, when the CEMS was 

set at a lower rate (0.3-0.5 lb/hr), the Method 26A data confirmed compliance with the 

HF emission limit.

On December 22, 2011, you notified DAPC, SEDO that EU P301 had been shut down 

on November 23, 2011, due to economic conditions. As of that date, Belden Brick was 

continuing to work with Opsis to determine why the CEMS data and Method 26A data 

do not correlate.

Please submit to this office, within 30 days of receipt of this letter, a plan and schedule 

that details the company’s strategy to ensure compliance with the HF limits in Belden’s 

air permits for EU P301. Submit this plan to the attention of Kimbra Reinbold.

Acceptance by Ohio EPA of a compliance plan and schedule does not constitute a 

waiver of Ohio EPA’s authority to seek civil penalties as provided in Section 3704.06 of 

the Revised Code. The determination to pursue or to decline to pursue such penalties in 

this case will be made by Ohio EPA at a later date.

Please refer any questions concerning the above requirements to Kimbra Reinbold, 

Ohio EPA, Division of Air Pollution Control, Southeast District Office at (740) 380-5245.
Mr. Bradley Belden

The Belden Brick Company

February 22, 2012

Page 4

4

Thank you for your cooperation in this matter.

Sincerely,

Marco Deshaies

Environmental Specialist

Division of Air Pollution Control

Southeast District Office

MD/cs

cc: Kimbra Reinbold, (Emissions Unit File Copy)

Marco Deshaies, DAPC-SEDO 

Bruce Weinberg, DAPC-SEDO

Tom Kalman DAPC-CO

Mickey Jencius, U.S. EPA, Region V

Test Report File Copy