ENTEC Services Pollution Control System Evaluation

and Source El•issions

Testing Cherokee Brick

and

Tile

Compliance Emissions

Re-Testing No. 1 and No. 2Kilns

Dry lime Absorber

Stack

February 28, 2007 Entec Project

No.: 27125

16-D Commerce

Avenue

Hueytown,

Alabama

35023 Phone: (205) 491-6676

Fax (205) 491-6614 www. entecservices,

comEntec Services, Inc. 16-D Commerce

Avenue Hueytown, Alabama

35023 Telephone: (205) 491-6676 Fax: (205) 491-6614 Results of the February

28, 2007 Emissions Re-Testing

for Particulate

w/HCI

/ HF on No. 1 and Nn• _• Kilns Dry Lime Absorber

St•ck

•t the Cherokee Brick Facility

located

in Macon, Georgia
Submitted to: Cherokee Brick

and Tile Co. 3250 Waterville

Road Macon, Georgia

31206 Attention: Mr. Jim Owens
Entec Project

No. 27125 Completed By: Report Submitted"

March 6, 2007 Reviewed By:

•/, G Tommy

Lotz•Jr. Project Manager. Tom L•z• '•
Technical Services

Manager hereby certify to the best of my knowledge

all field sampling

and laboratory

analysis

performed for this report is authentic

and accurate.

It has been checked

for completeness

and accuracy.Cherokee Brick

and Tile Co. Table of Contents .Section Pa_ae No. Executive Summary Emissions

Summary Detailed Test Results Sampling Procedures Location of Test Ports Method 5/26A Sampling

Train No.1 No. 2 Kilns Dry Lime Absorber

Field Data Sheets Test Run 1 Test Run 2 Test Run 3 Control Room Data Quality Control

/ Quality Assurance

Procedures QA/QC Checklist Orifice Check and Temperature

Check Fyrite / Orsat Standardization Laboratory Analysis Equipment Calibrations Nomenclature and Test Calculations 371112131417202325303132375464Executive Summary Cherokee Brick located

in Macon,

Georgia,

retained

Entec Services,

inc. to perform emissions re-testing

on the No. 1 and No. 2 Kilns Dry Lime Absorber

Stack.

Mr. Tommy Lotz, Jr., and Mr. Jason English,

of Entec Services,

Inc. conducted

the testing
on February

28, 2007.

Representing

Cherokee

.Brick was Mr. Jim Owens

who coordinated testing

with the control

room production

activity.

Representing

the state from the Georgia

Department

of Natural

Resources

was Mr. Daniel McCain. Entec Services,

Inc. encountered

no difficulties

in the field collection

of the samples

or in the laboratory

analysis

of the samples
The emissions

test summary

on the following

page gives a detailed

summary

of each test run compared

to the maximum

emission

limits set forth by the Georgia

Department of Natural

Resources.

Test results

indicate

the emissions

results

were below the emissions standards

set forth by Permit

No. 3251-021-0167-V-02-0 ID No. PCD01, except for the Hydrogen

Fluoride

emissions

in Ibslton

of Fired Brick.Detailed TestSOURCE

OWNER: PLANT LOCATION: SOURCE(S) NAME(S): SOURCE(S) CONDITION: SOURCE(S) SHAPE:

Entec_.Services, Inc. SOURCE OVERVIEW
Cherokee

Brick and Tile Macon, GA Dry Lime Absorber

Stack Compliance Testing (New Feed Rate) Circular PROBE WASH CHEMICAL: SOURCE PERMIT

NUMBER: TEST PERFORMED: REFERENCE METHOD

TESTS:

PROJECT MANAGER ENVIRONMENTAL ANALYST

PROJECT

LEADER ENVIRONMENTAL ANALYST

ASSISTANT OWNER'S REPRESENTATIVE: RULING AGENCY: RULING AGENCY

REPRESENTATIVE: DATES TESTS CONDUCTED: ENTEC PROJECT

NUMBER: Acetone 3251-021-0167-V-02-0 ID No. PCD01 Lime MACT Subpart JJJJJ Sample Location

EPA Method Volumetric Flow

EPA Method Molecular Weight

EPA Method Moisture Content

EPA Method Particulate EPA Method Hydrogen Chloride

EPA Method Hydrogen Fluoride

EPA Method Mr. Tommy Lotz Jr. Mr. Tommy Lotz Jr. Mr. Jason English Mr. Jim Owens Georgia Department

of Natural Resources Mr. Daniel McCain 02/28/07 27125 1234526A 26AENTEC Services,

Inc. 16-D Commerce Ave. Hueytown, Alabama 35023 INPUT TEST DATA Client: Source: Cherokee

Brick and Tile Dry Lime Absorber

Stack Field Data Run Number Test Date Time Test Run Began Ended

,•=,,,•,,,,,• T;m• Stack Area Barometric Pressure Stack Static Pressure Pitot Tube Correction

factor Meter Correction

Factor Meter Delta H @ Nozzle Diameter Meter Volume Meter Temperature Avg. Orifice Delta H Impingers Weight Gain (Moisture) Silica Gel Impinger Weight Gain (Moisture) Oxygen Concentration,

dry basis Carbon Dioxide Concentration,

dry basis Avg. Sq. Rt. of Delta P Stack Temperature Total Hydrogen

Chloride collected,

mg Total Hydrogen

Fluoride collected,

mg ]'otal particulate

collected Symbol

P•CpY

Units
Military Time minutes Ft in. Hg in. H20

in. Hz0

Job No.: Data Input By:

02/28/07 0845-0948
22.166 29.75 0.15 0.84 1.004 1.800

27125 T. Lotz, Jr. Test Data 2 3 02/28/07 02/28/07 1107-1217 1254-1356
22.166 60

6O 22.166 29.75 30.02 0.13 0.84 1.004 1.800 0.13 0.84 1.004 1.800

AVERAGE

29.84 0.14 0.84 1.004 1.800 Dn inches

0.312

0.312

0.312

0.312 Vm dcf

45.677

45.924

45.373

45.658 tm °F

69.8

87.8 1.80 115.0 10.6 in. H20 grams grams

(in. H20) F AHWimpW=•O2COz (sqrt &P)avg 91.9

83.2 1.75 1.71

1.75 108.6 111.5

111.7 13.3 16.0 3.0 0.557 356.0 27.5 HCL HF
mn mgmgmg

16.0

80.0

7.616.0 4.0 0.550 357.7 27.6 85.5 58.8 5.0 0.566 358.8

69.9 10.5 16.0 4.0 0.558 357.5 27.5 82.3 59.1 27.5 81.4 48.5

5ENTEC Services,

Inc. 16-D Commerce Ave. Hueytown, Alabama 35023 CALCULATED TEST DATA
Client: Cherokee Brick and Tile Source: Dry Lime Absorber Stack Description

Formulas Run Number Test Date Time Began-Ended 1. Stack Pressure P• Pal 13.| 2. Meter Pressure P•,• Nrl 113.• 3. Standard Meter Volume 17.•4" Y* (V,dT=)* (P•,• +/•H 113.6] 4a. Standard Volume of Water Vapor Condensed =0,04706=W•

5. Moisture Fraction 9. Molecular Weight Of Slack Gas, dry basis 10. Molecular Weight Of Stack Gas, wet basis

=(V•.q=,=• V,,,•l)l(V•¢l=•

V•,,•.•) 0.32"(O.z}+ 0.44"(CO= )+0.28"( 100-(O•)-(COz)] M=='('I -B,•)+ 18.0*(B•= 11. Average Stack Gas Velocity 12. Stack Gas Flow (• Stack Conditions

85.49"Cp*(sqrt -•P)z,•'SQRT((T,)

(P,'M,)}

13. Stack Gas Flow @ Standard Conditions Q,'(T=•=rr,)'(P=/P=•} 14. Stack Gas Flow @ Dry Standard Conditions 14b. Hydrogen Chloride concentration @ Std.Cond.,Grains/Cu.Ft. 14b. Hydrogen Fluoride concentration @ Std.Cond.,Grains/Cu.Ft. :15. Particulate concentration @ Standard Conditions 15b. Hydrogen Chlodde emissions, Ibs per hour 15b. Hydrogen Fluodde emissions, los per hour 21. Particulate emissions 22. Volume collected through nozzle 24. Isokinetic Sampling Rate, Percent =(0.01543"HCL•)IQ• =(0.01543"HF,•)/Q.• =0.01543"m•/•dl =(60/7000)*HCLQ•*Q=t,• =(60/7000)'HFQ•*Q=t,• (60/7000)*c,*Q• :T=/P=*[0.002669"V•¢+ Vm*Y*Pm/'rm lO0*Vn (60*v,'A•*O)

Post Meter Orifice Cal. (EMC ALT-O09 Yqa) % Difference, (Calibration must be within 5% of original Y-factor) Job No.:

27125 Data Input BY: T. Lotz, Jr. Symbol Units

Calculated Data 2 3 AVERAGE 02/28107 02/28107

02/28/07 Military Time 0845-0948

1107-1217

1254-1356 P, in. Hg 29.76

29.76

30.03

29.85 p. in. Hg 29.88

29.88

30.15

29.97 v,,,• dscf 45.626

44.359

43.891

44.625 v,,•,,• sol 5.412

5.111

5.247

5.257 ;',,•,,.• • 0.•.•'00

0.627

0.358

0.495 B•= fraction

0.1147

0.1145

0.1133

0.1142 I• g/g-moin

29.440

29.120

29.280

29.280
• g•g-moin

28.128

27.846

28.003

27.992
v, rds 40.21

39.69

38.97

39.622 Q, acfm 53,474

52,783

51,831

52,696 Q, scfrn 34,284

33,957

33,578

33,940 Q.• dscfm 30,352

30,067

29,776

30,065 HCLcs gr/dscf

0.009

0.010

0.010

0.010 HFcs grldscf

0.028

0.028

0.030

0.028

cs grldscf 0.0164

0.0243

0.0207

0.0205 HC! 4bs/hr IbsJhr

2.42

2.47

2.48

2.45 HF -Ibs/hr Ibsrnr

7.16

7.17

7.67

7.33 PMR Iblhr 4.27

6.27

5.28

5.27 V. acf 80.387

77.873

76.405

78.222 % 104.60

102.66

102.57

103.28

0.9816 0.9827

0.9793

0.9812 2.27%SamplingProcedures The

particulate

and gas emission

rates were determined

using EPA Methods

1-5, and 26A, CFR Title 40, Part 60, Appendix

A. The calibration

and quality

assurance procedures of EPA CFR 40 Part 60 Appendix

A for all methods,

and the "Quality Assurance Handbook

for Air Pollution

Measurement

System"

Volume

III Stationary Source-Specific Methods

were followed

throughout

the duration

of the field and laboratory testing. The most current

revision

revised

as of July 1, 2004, of each method

(as described

in the Federal

Register)

was used. Stack Gas Volumetric

Flow The velocity

of the gas stream was determined

according

to EPA Reference

Method

1 and 2 by reading

the instantaneous

velocity

head with an inclined

manometer

at each sampling point with a calibrated

S-type

pitot tube attached

adjacent

to the sample nozzle. The stack pressure

was measured

with the static side of an S-type pitot tube. A calibrated

pyrometer

was used to measure

stack temperature

at each sampling

point. Stack Gas Molecular

Weight The carbon dioxide

and oxygen

concentrations

were determined

using EPA Reference Method 3 (Fyrite Method).

A sample

of the flue gas was extracted

from the gas stream during each test. These

samples

were analyzed

with a Fyrite gas analyzer.

The molecular weight

of the gas was calculated

using the moisture,

oxygen

and carbon dioxide content

and the measured

stack gas temperature. Moisture Content The moisture

content

used for calculating

the gas stream

flow rate was determined

by measuring the amount

of condensed

moisture

in the glass impinger

and silica gel impinger in the sampling

train as described

in EPA Reference

Method

4 at the completion of each test. The moisture

collection

system

consists

of a series of 4 impingers

connected

to a silica gel impinger

attached

to the outlet.

Ice is placed around

the impingers

to maintain

atemperature <680 F. The outlet temperature

of the impinger

is monitored

and recorded throughout the duration

of the testing to verify the temperature

is below <680 F. Hvdroqen Chloride

I Fluoride

with Particulate Preliminary data was used to determine

stack temperature,

pressure,

and range of velocity heads, moisture

content

and stack gas dry molecular

weight prior to sampling. The meter box was leak checked

from the pump to the orifice.

Initial and final leak checks of the sampling

system

and pitot lines were performed

as outlined

in Method

5 and were recorded

on the data sheets.

The nozzle (glass with an angle of taper of 30 degrees and of button hook design)

was calibrated

before and after the test using a micrometer and was also recorded

on the field data sheets. The sampling

probe was placed at each sampling

point to provide

a total sampling

time of at least 60 minutes

and a volume

of at least 31.8 cubic feet. The gases were drawn through a glass nozzle attached

to a heated

glass lined probe.

The probe wasmaintained at the proper

setting

to obtain a temperature

of > 248 0 F. The gases then proceeded through

borosilicate

glass filter holder, with a Teflon frit filter support

through
a tarred Teflon or quartz fiber filter to remove

particulate

matter.

The exit of the filter was maintained

at a temperature

of > 248 0 F. These temperatures

were recorded

at each point on the field data sheets. The gases were then scrubbed

through

a series of four impingers

to capture

hydrogen halides, and moisture.

The optional

moisture

knockout

impinger

was not used in the sample train. The first and second

impingers

contained

approximately

100 ml of a 0o 1N H2SO4 solution

and the third and fourth impingers

contained

approximately

100 ml of a 0.1 N NaOH solution.

The fifth impinger

contained

pre weighed

silica gel to remove

any remaining moisture.

The gases passed

through

the impinger

series in an ice bath to maintain a maximum

exit temperature

of 68 0 F. This temperature

will be also recorded on the field data sheets.

The clean and cool gases then entered

the meter box where the gas flow and temperature

were measured. After the completion

of each test run leak rate determinations

were made and recorded on the field data sheets.

Then the sampling

train and the probe nozzle assembly

weretransferred to the cleanup

area making

sure no particulate

was lost. The cleanup

data was also recorded

on the field data sheets and / or the laboratory

checklist

sheet. Particulate catches

were placed

in sealed

petri dishes.

Each acetone

rinse from the nozzle, probe, and filter holder were combined

and placed

in a sealed container.

The first, and second

impinger

contents

were transferred

to its tarred container,

weighed and the rinsing from the glassware

will be added to this container.

The third and fourth impinger contents

were weighed

for moisture

determination

calculations

but were not kept for analysis.

The silica gel from the fifth impinger

was transferred

to its respective

•,•u •u•,,•,•

ahd w•,g•eu.

For Lhe group of LesLs an acetone

biank, suifuric

acid solution, distilled

water and. acetone

of approximately

200 milliliters

were placed

in a sealed container.

These

containers

will be clearly

marked

and transported

to the laboratory for analysis. Enthalpy will perform

all of the laboratory

analysis

and is an approved

Louisiana accredited lab (Certification

Number

04010)

that meets all requirements

for the State of Georgia approved

and accredited

laboratory.

10Entec Services,

Inc 16 D Commerce

Ave. Hueytown,

AL 35023 STACK DRAWING

& TRAVERSE

POINT LOCATION Client: Cherokee

Brick and Tile Job No. 27125 Source: Dry Lime Absorber

Stack Input By: Jason English Type of Traverse: Velocity (V) or Particulate

(P): Stack Diameter, inches:

63.75 Stack Height, feet:

100

P

Port Type

Flange

Port Diameter

6.0" Stack Area, Ft2: 22.166 Number of Ports: 2 Stack Properties:

Inches

Duct Diameters Upstream Disturbance:

170.0 Downstream Disturbance:

684.0

2.67 10.73

Length of Port, inches: Total Number of Traverse Points: Number of Points per diameter: 8.25126 63.8 INCHES

170.0

NCHES

Point No.

Inside Stack

Outside Nipple Inches Inches 2.8 11•1 2 9.3 17.6 3 18.9 27.1 4 44.9 53.1 5 54.4 62.7 6 60.9 69.2

684.0 NCHES

Adjusted pointe diameter > 24" no point closer than 1.0 inch Adjusted points diameter < 24" no point closer than 0.5 inch Stack Diameters between 12-24 inches minimum points are 8 4 points per port if the 81 2 diameters downstream

and upstream criteria is met.Method 5/26A

Sampling Train

Filter Exit Temperature (>248 F)

48 F)•rature Sensors Impinger Exit Temperature (<68 F)

nplng #3O.1N qaOI Ice Bath

Exhaust oooo

• ol Temp. and Flow Controllers
Temperature

Manometer [Pressure[ FDry Gas Meter

12Field Data

Sheets No. 1 & No. 2 Kilns

Dry Lime

Absorber

Stack

13Run No.

1 Field Data

SheetsENTEC Services,

Inc. 16-D Commerce Ave. Hueytown, Alabama 35023
Client: Cherokee'Brick

and Tile Test Date:

2/2812007 Source: Dry Lime Absorber

Stack Run Number:

1

PARTICULATE Wl HYDROGEN

CHLORIDE

HYDROGEN

FLOURIDE

FIELD DATA, EPA METHOD 5126A

Traverse Point 1-11-21-31-41-5

2-12-22-32-42-5

0.41 2.29

357

60 0.42 0.6481

2.34

357

63 0.35 0.5916

1.95

359

66 0.32 0.5657

1.79

362

67 0.29 0.5385

1.62

360

69

1.80 0.19 0.4359

1.06 0.34 0.5831

1.90 0.31 0.5568

1.73 0.33 0.5745

1.84 0.35 0.5916

1.95 0.27 0.5196

1.51

356

70 360 69 358 71 358 73 359 75 360 76 360 79

358.8 2-6 0.30

0.5477

1.67

K-Factor 5.58 0.32

0.5661 69.8 15!!!Run No.

2 Field Data

SheetsENTEC Services,

Inc. 16-D Commerce Ave. Hue_ytown, Alabama 35023
Client: Cherokee

Brick and Tile Test Date:

2/28/2007 Source: Dry Lime Absorber

Stack Run Number:

2

PARTICULPARTICULATE Wl HYDROGEN

CHLORIDE

HYDROGEN

FLOURIDE

FIELD DATA, EPA METHOD

5126A

1-1 0.34 1-2 0.30 1-3 0.33 1-4 0.34 1-51-62-12-22-32-42-5

K-Factor 0,29

0.5831 0.5477

1.90 1.67

353355 0.5745 1.84

357

86 0.5831 1.90

357

87 0.5385 1,62

360

88 0.21 0.4583 0,40 0.6325 0.40 0.6325 0.39 0.6245 0.28 0.5292

1.17 2.23 2.23 2.18 1.56 0.5000 1.40 0,4796 1.28

0.5569 0.25

355

88 352 88 357358 362 356350 2-6 O.23

5.58 9091929089

1.75 356.0

87.8Run No.

3 Field Data

SheetsENTEC Services,

Inc. 16-D Commerce

Ave. Hueytown, Alabama 35023
Client: Cherokee

Brick and Tile Test Date:

2/2812007 Source: Dry Lime Absorber

Stack Run Number:

3

PARTICULATE W/HYDROGEN

CHLORIDE

HYDROGEN

FLOURIDE

FIELD DATA, EPA METHOD

5126A

T•verse Po.i.n.t

_he!t_= p

•q_ Rt De!f_• P

nelt•_ H

•P•el¢ T•np. (°F,• Meter T•m_rn• (°F) 1-1 0.39 1-2 0.40 1-3 0.33 1-4 0.27 1-5 0.22 1-6 0.20

0.6245

2.18

354

92 0.6325 2.23

358

88 0.5745 1.84

358

89 0.5196 1.51

359

91 0.4690 1.23

358

91 0.4472 1.12

356

91 2-1 0.33

0.5745

1.84

354

91 2-2 0.26

0.5099

1.45

359

93 2-3 0.32 2-4 0.29 2-5 0.35 2-6 0.31

0.5657

1.79

360

93 0.5385 1.62

359

94 0.5916 1.95

359

94 0.5568 1.73

358

96

K-Factor 5.58 0.31

0.5504

1.71

357.7

91.9o

EE EControl Room

Process

Data

 ̧23Production Data The following

information

was received

by email from Mr. Jim Owens

of Cherokee

Brick And Tile Company

for the testing

performed

at their, facility

in Macon,

Georgia,

on FebruarY 28, 2007. The brick being fired were queen size in both kilns. The production

data during

the test for the emission

rate was: Lingl Kiln No. 1 = 25 cars per day of Queen

Size brick for a rate of 16.56 tons/hour Lingl Kiln No. 2 = 25 cars per day of Queen

Size brick for a rate of 16.47 tons/hour
The limestone

usage was 175.5 pounds/hour.
The average

differential

pressure

was: 06:00 am 9:00 am

.79 09:00 am 12:00 noon

.80 12:00 noon-

03:00 pm

.77