# Brick and Structural Clay Products ICR Test Report

Test Location General Shale Brick, Inc.

241 Hoyal Lane Spring City, TN 37381 

### Test Dates May 5, 2011



### Source Tested Kiln/Predryer Consisting of One

coal/Natural Gas Fired Brick Tunnel Kiln with Dry Injection Fabric Filter Control and One Predryer Using Waste Heat from the Kiln

Emission Source Reference No. (ESRN) 72-0116-04
Tunnel Kiln (EU ID: tk-1) Dry Sorbent Injection/fabric filter (Control/Stack ID: diff-1)



### Report Prepared by Alliance Source Testing, LLC 214 Central Circle SW Decatur, Alabama 35603 

### Project Number 2011-0126



### Report Submittal Date June 9, 2011General Shale Brick, Inc. ICR Test Report Certification Statement

c:\\Projects\General Shale\Spring City, TN\2011-0126\ICR Test Report Page i Certification Statement

Alliance Source Testing, LLC (AST) of Decatur, AL has completed the source testing as described in this report. Results apply only to the source(s) tested and operating condition(s) for the specific test date(s) and time(s) identified within this report. All results are intended to be considered in their entirety, and AST is not responsible for use of less than the complete test report without written consent. This report shall not be reproduced in full or in part without written approval from the customer. To the best of my knowledge and abilities, all information, facts and test data are correct. Data presented in this report has been checked for completeness and is accurate, error-free and legible. Onsite testing was conducted in accordance with approved internal Standard Operating Procedures. Any deviations or problems are detailed in the relevant sections on the test report.

June 9, 2011 

### Jeremy Hutchens, QSTI Project Manager Alliance Source Testing, LLC Date

This document was prepared in portable document format (.pdf) and contains pages as identified in the bottom footer of this document.

Questions or comments regarding this report should be directed to the persons identified below. Facility Contact Test Firm Contact

Martha West General Shale Brick, Inc. P.O. Box 3547 Johnson City, TN 37602 (423) 952-4240 martha.west@generalshale.com Jeremy Hutchens Alliance Source Testing, LLC 214 Central Circle SW Decatur, AL 35603 (256) 260-3974 jeremy.hutchens@stacktest.com www.alliancesourcetesting.comGeneral Shale Brick, Inc. ICR Test Report Table of Contents

c:\\Projects\General Shale\Spring City, TN\2011-0126\ICR Test Report Page ii TABLE OF CONTENTS

Certification Statement ...................................................................................................................................................i 1.0 Introduction .................................................................................................................................................. 1-1 1.1 Source and Control System Descriptions................................................................................................. 1-1 1.2 Project Team ............................................................................................................................................ 1-1 1.3 Test Notification ...................................................................................................................................... 1-1 2.0 Summary of Results ..................................................................................................................................... 2-1 3.0 Testing Methodology.................................................................................................................................... 3-1 3.1 U.S. EPA Reference Test Methods 1 & 2 – Volumetric Flow Rate......................................................... 3-1 3.2 U.S. EPA Reference Test Methods 3 & 3A – Oxygen/Carbon Dioxide .................................................. 3-1 3.3 U.S. EPA Reference Test Method 4 – Moisture Content......................................................................... 3-1 3.4 U.S. EPA Reference Test Methods 5 & 29 – Particulate Matter, Mercury & Metals .............................. 3-1 3.5 U.S. EPA Reference Test Method 26A – Hydrogen Chloride/Chlorine/Hydrogen Fluoride................... 3-2 3.6 Quality Assurance/Quality Control – U. S. EPA Reference Test Method 3A ......................................... 3-3

LIST OF TABLES Table 1-1 Project Team........................................................................................................................................ 1-1 Table 2-1 Summary of Process & Production Data ............................................................................................. 2-1 Table 2-2 Summary of Emission Testing Results – HCl, Cl 2 & HF .................................................................... 2-1 Table 2-3 Summary of Emission Testing Results – PM and HAP Metals........................................................... 2-2 Table 3-1 Source Testing Methodology............................................................................................................... 3-1

APPENDICES Appendix A Sample Calculations Appendix B Field Data Appendix C Laboratory Data Appendix D Quality Assurance/Quality Control Data Appendix E Process Operating/Control System Data Appendix F Laboratory Reporting Limits

# IntroductionGenerals Shale Brick, Inc. ICR Test Report Introduction

c:\\Projects\General Shale\Spring City, TN\2011-0126\ICR Test Report Page 1-1 1.0 Introduction Alliance Source Testing, LLC (AST) was retained by General Shale Brick, Inc. (General Shale) to conduct Brick and Structural Clay Products Information Collection Request (ICR) testing at the Spring City, TN facility. General Shale is subject to provisions of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Brick and Structural Clay Products facilities as detailed in 40 CFR 63, Subpart JJJJJ and Tennessee Department of Environment and Conservation (TDEC) issued Permit 964000P.
The United States Environmental Protection Agency (U.S. EPA) requested in a Section 114 letter dated November 17, 2010, pursuant to its authority under section 114 of the Clean Air Act, emissions data for certain pollutants. U.S. EPA’s specific request included a determination of filterable particulate matter (PM), hydrogen chloride (HCl), chlorine (Cl 2 ), hydrogen fluoride (HF) and multiple metals - antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel and selenium (Sb, Ar, Be, Cd, Cr, Co, Pb, Mn, Hg, Ni & Se) emissions. Testing was conducted to determine the aforementioned target pollutant emissions from one (1) tunnel kiln with dry sorbent injection filter/fabric filter (baghouse). All testing in this report was conducted under normal process operations.

1.1 Source and Control System Descriptions Brick exterior building material is manufactured at this facility. Shale and clay are mined, crushed and sent through a screening process prior to brick forming by extrusion. Once the brick is extruded, it is dried in a tunnel Kiln at temperatures exceeding 1,900 °F. After being fired, the brick is cooled, packaged and shipped to various locations. The emissions are controlled with a baghouse.

1.2 Project Team Personnel involved in this project are identified in the following table.

Table 1-1 Project Team AST Personnel Facility Personnel Jeremy Hutchens – Project Manager Brandy Hughes – Report Coordinator Stacey Cunningham – Technician Kenny Boyd – Technician Chris Landtroop – Technician Adam Towe – Technician Martha West
Regulatory Personnel Johnathan Bradley - TDEC

1.3 Test Notification Testing was conducted in accordance with the Test Protocol submitted to Mr. Jeryl Stewart of the Tennessee Department of Environment and Conservation on April 21, 2011.

# Summary of ResultsGeneral Shale Brick, Inc. ICR Test Report Summary of Results

c:\\Projects\General Shale\Spring City, TN\2011-0126\ICR Test Report Page 2-1 2.0 Summary of Results AST conducted Brick and Structural Clay ICR testing on a tunnel kiln at the General Shale facility in Spring City, TN. Testing was conducted May 5, 2011 and consisted of three (3) test runs for PM, HCl, Cl 2 , HF and multiple metals (Sb, Ar, Be, Cd, Cr, Co, Pb, Mn, Hg, Ni & Se). Table 2-1 provides a summary of the process operating and control system data collected during the performance test. Tables 2-2 through 2-3 provide a summary of the emission testing results. Any difference between the summary results listed in the following tables and the detailed results contained in Appendix B is due to rounding for presentation.
Emissions data presented in the format “[< Value]” indicates that the value or values used in emission calculations was reported from the analytical laboratory as “non-detect” or “below detection limit”. Therefore, the Reporting Detection Limit (RDL) was used as the “real” value for emissions calculations. Additionally, data reported as “an estimate between the EDL and the RDL” from the analytical laboratory has the notation of “J” beside the emission calculations. Appendix C provides the full analytical laboratory reports. Table 2-1 Summary of Process & Production Data

Parameter Average during Runs 1-3 Test Date 5/5/11 Brick Production 12 tph/ 10.9 Mg/hr Coal Usage 1,416 lb/hr Gas Usage 636 scf DLA Differential Pressure 6.5 in. w.c. Limestone Feed 65 lb/hr

Table 2-2 Summary of Emission Testing Results – HCl, Cl 2 & HF

Parameter Run 1 Run 2 Run 3 Average Test Date 5/5/11 5/5/11 5/5/11

-- Hydrogen Chloride Data Concentration, ppmvd @ 7 % O 2 49.8 34.0 23.2 35.7 Emission Rate, kg/hr 0.65 0.44 0.27 0.45 Emission Factor, kg/Mg 0.060 0.041 0.024 0.042 Chlorine Data Concentration, ppmvd @ 7 % O 2 1.1 J 0.5 J 0.6 J 0.7 Emission Rate, kg/hr 0.03 J 0.01 J 0.01 J 0.02 Emission Factor, kg/Mg 0.002 J 0.001 J 0.001 J 0.002 Hydrogen Fluoride Concentration, ppmvd @ 7 % O 2 15.4 5.3 3.5 8.1 Emission Rate, kg/hr 0.11 0.04 0.02 0.06 Emission Factor, kg/Mg 0.010 0.003 0.002 0.005General Shale Brick, Inc. ICR Test Report Summary of Results

c:\\Projects\General Shale\Spring City, TN\2011-0126\ICR Test Report Page 2-2 Table 2-3 Summary of Emission Testing Results – PM and HAP Metals

Parameter Run 1 Run 2 Run 3 Average Test Date 5/5/11 5/5/11 5/5/11

-- Filterable Particulate Matter Data Concentration, mg/dscm @ 7 % O 2 [<19.1] [<12.4] [<32.9] 21.4 Emission Rate, kg/hr [<0.16] [<0.11] [<0.25] 0.17 Emission Factor, kg/Mg [<0.015] [<0.010] [<0.023] 0.016 Antimony Data Concentration, mg/dscm @ 7 % O 2 [<2.4E-03] [<4.6E-03] [<2.8E-03] 3.3E-03 Emission Rate, kg/hr [<2.11E-05] [<3.91E-05] [<2.10E-05] 2.71E-05 Emission Factor, kg/Mg [<1.94E-06] [<3.59E-06] [<1.93E-06] 2.49E-06 Arsenic Data Concentration, mg/dscm @ 7 % O 2 [<4.2E-03] [<3.8E-03] [<7.5E-03] 5.1E-03 Emission Rate, kg/hr [<3.58E-05] [<3.24E-05] [<5.66E-05] 4.16E-05 Emission Factor, kg/Mg [<3.29E-06] [<2.98E-06] [<5.20E-06] 3.82E-06 Beryllium Data Concentration, mg/dscm @ 7 % O 2 [<6.1E-04] [<6.1E-04] [<7.0E-04] 6.4E-04 Emission Rate, kg/hr [<5.27E-06] [<5.20E-06] [<5.26E-06] 5.24E-06 Emission Factor, kg/Mg [<4.84E-07] [<4.77E-07] [<4.83E-07] 4.82E-07 Cadmium Data Concentration, mg/dscm @ 7 % O 2 [<6.1E-04] [<6.1E-04] [<7.0E-04] 6.4E-04 Emission Rate, kg/hr [<5.27E-06] [<5.20E-06] [<5.26E-06] 5.24E-06 Emission Factor, kg/Mg [<4.84E-07] [<4.77E-07] [<4.83E-07] 4.82E-07 Chromium Data Concentration, mg/dscm @ 7 % O 2 1.3E-02 2.2E-02 2.0E-02 1.8E-02 Emission Rate, kg/hr 1.11E-04 1.86E-04 1.54E-04 1.50E-04 Emission Factor, kg/Mg 1.02E-05 1.71E-05 1.41E-05 1.38E-05 Cobalt Data Concentration, mg/dscm @ 7 % O 2 1.5E-03 1.2E-03 2.4E-03 1.7E-03 Emission Rate, kg/hr 1.33E-05 1.07E-05 1.80E-05 1.40E-05 Emission Factor, kg/Mg 1.22E-06 9.86E-07 1.65E-06 1.28E-06 Lead Data Concentration, mg/dscm @ 7 % O 2 1.0E-02 6.6E-03 6.8E-03 7.9E-03 Emission Rate, kg/hr 8.96E-05 5.70E-05 5.11E-05 6.59E-05 Emission Factor, kg/Mg 8.23E-06 5.23E-06 4.70E-06 6.05E-06General Shale Brick, Inc. ICR Test Report Summary of Results

c:\\Projects\General Shale\Spring City, TN\2011-0126\ICR Test Report Page 2-3 Table 2-3 (Continued) Summary of Emission Testing Results – PM and HAP Metals

Parameter Run 1 Run 2 Run 3 Average Test Date 5/5/11 5/5/11 5/5/11

-- Manganese Data Concentration, mg/dscm @ 7 % O 2 2.0E-02 1.4E-02 3.0E-02 2.1E-02 Emission Rate, kg/hr 1.76E-04 1.17E-04 2.29E-04 1.74E-04 Emission Factor, kg/Mg 1.62E-05 1.07E-05 2.10E-05 1.60E-05 Nickel Data Concentration, mg/dscm @ 7 % O 2 1.9E-02 2.1E-02 3.8E-02 2.6E-02 Emission Rate, kg/hr 1.64E-04 1.82E-04 2.87E-04 2.11E-04 Emission Factor, kg/Mg 1.51E-05 1.67E-05 2.63E-05 1.94E-05 Selenium Data Concentration, mg/dscm @ 7 % O 2 [<1.2E-02] [<1.6E-02] 1.4E-02 1.4E-02 Emission Rate, kg/hr [<1.07E-04] [<1.38E-04] 1.09E-04 1.18E-04 Emission Factor, kg/Mg [<9.80E-06] [<1.26E-05] 9.99E-06 1.08E-05 Mercury Data Concentration, mg/dscm @ 7 % O 2 6.6E-02 6.4E-02 6.1E-02 6.4E-02 Emission Rate, kg/hr 5.65E-04 5.47E-04 4.62E-04 5.25E-04 Emission Factor, kg/Mg 5.19E-05 5.03E-05 4.24E-05 4.82E-05

# Testing MethodologyGeneral Shale Brick, Inc. ICR Test Report Testing Methodology

c:\\Projects\General Shale\Spring City, TN\2011-0126\ICR Test Report Page 3-1 3.0 Testing Methodology The emission testing program was conducted in accordance with the test methods listed in Table 3-1. Method descriptions are provided below while quality assurance/quality control data is provided in Appendix D.

Table 3-1 Source Testing Methodology

Parameter Test Methods Notes/Remarks Volumetric Flow Rate (VFR) U.S. EPA Reference Test Methods 1 & 2 Full Velocity Traverses Oxygen/Carbon Dioxide (O 2 /CO 2 ) U.S. EPA Reference Test Method 3/3A Integrated Bag/ Instrumental Analysis Moisture Content (BWS) U.S. EPA Reference Test Method 4 Volumetric /Gravimetric Analysis Particulate Matter (PM) U.S. EPA Reference Test Method 5 Isokinetic Sampling Hydrogen Chloride//Chlorine/ Hydrogen Fluoride/ (HCl/Cl 2 /HF) U.S. EPA Reference Test Method 26A Isokinetic Sampling Multiple Metals (Sb, Ar, Be, Cd, Cr, Co, Pb, Mn, Hg, Se & Ni) U.S. EPA Reference Test Method 29 Isokinetic Sampling

3.1 U.S. EPA Reference Test Methods 1 & 2 – Volumetric Flow Rate The sampling location and number of traverse (sampling) points were selected in accordance with U.S. EPA Reference Test Method 1. A full velocity traverse was conducted in accordance with U.S. EPA Reference Test Method 2 to determine the average stack gas velocity pressure, static pressure and temperature. The velocity and static pressure measurement system consisted of an S-type pitot tube and inclined manometer while the stack gas temperature was measured with a K-type thermocouple and pyrometer.

3.2 U.S. EPA Reference Test Methods 3 & 3A – Oxygen/Carbon Dioxide The oxygen and carbon dioxide concentrations were determined in accordance with U.S. EPA Reference Test Methods 3/3A. One (1) integrated Tedlar bag sample was collected during each test run. The bag samples were analyzed on site with a California Analytical Instruments Model 300P O 2 /CO 2 /CO analyzer. The remaining stack gas constituent was assumed to be nitrogen for the stack gas molecular weight determination. The quality control measures are described in Section 3.6.

3.3 U.S. EPA Reference Test Method 4 – Moisture Content The stack gas moisture content was determined in accordance with U.S. EPA Reference Test Method 4. The gas conditioning train consisted of a series of chilled impingers. The impinger contents were pre and post-measured to determine the amount of moisture condensed during each test run.

3.4 U.S. EPA Reference Test Methods 5 & 29 – Particulate Matter, Mercury & Metals The particulate matter, mercury and metals testing was conducted in accordance with U.S. EPA Reference TestMethods 5 and 29. The complete sampling system consisted of a glass nozzle, heated glass-lined probe, preweighed glass-fiber filter, gas conditioning system, pump and calibrated dry gas meter. The gas conditioning train consisted of seven (7) chilled impingers. The first and second impingers contained 100 milliliters (mL) ofGeneral Shale Brick, Inc. ICR Test Report Testing Methodology

c:\\Projects\General Shale\Spring City, TN\2011-0126\ICR Test Report Page 3-2 HNO 3 /H 2 O 2 , the third and fourth were empty, the fifth and sixth contained 100 mL of acidic KMnO 4 and the seventh contained approximately 200 grams of silica gel.
Pretest sample train cleaning procedures consisted of rinsing all glassware with hot tap water and then in hot soapy water. The glassware was then triple-rinsed with tap water, followed by three additional rinses with de-ionized (DI) water. Next the glassware was soaked in a 10% HNO 3 for a minimum of four (4) hours, rinsed three (3) times with DI water, a single acetone rinse and then air-dried. All glassware open-ends were covered with Teflon tape until the sample train was ready for onsite assembly.
Following the completion of each test run, the sample train was leak checked at a vacuum pressure equal to or greater than the highest vacuum pressure observed during the run. The alternative post-test calibration procedure outlined in Alternative Method 5 Post-Test Calibration (Y qa ) was used for the in-field post test calibration check.
The filter was placed into a labeled Petri dish (Container 1). The nozzle, probe liner and front-half of the filter holder were cleaned with a non-metallic probe brush and triple-rinsed with Acetone. These rinses were recovered in Container 2. The nozzle, probe liner and front-half of the filter holder were cleaned again with a non-metallic probe brush and triple-rinsed with 0.1 HNO 3 . These rinses were recovered in Container 3. The contents of impingers 1 and 2 were placed in Container 4. Impingers 1 and 2 along with the filter support, back half of the filter holder and all connecting glassware were triple-rinsed with 0.1 N HNO 3 . These rinses were recovered in Container 4. The contents of impinger 3 were placed in Container 5. The impinger and connecting glassware were triple-rinsed with HNO 3 , and this rinse was added to Container 5. The contents of impingers 4, 5 and 6 were placed in Container 6. The impingers and all connecting glassware were triple-rinsed with acidified KMNO 4 and then with DI water. These rinses were added to Container 6. If needed, impingers 4, 5 and 6 were rinsed with 25 mL of 8N HCl. This rinse was added to the 200 mL of DI water in Container 7. All samples were sealed, clearly labeled and shipped to Maxxam Analytics, Inc. in Mississauga, Ontario, Canada via an overnight courier.

3.5 U.S. EPA Reference Test Method 26A – Hydrogen Chloride/Chlorine/Hydrogen Fluoride The hydrogen chloride, chlorine and hydrogen fluoride concentrations were determined in accordance with U.S. EPA Reference Test Method 26A. The complete sampling system consisted of a glass nozzle, heated glass-lined probe, Teflon filter, gas conditioning train, pump and calibrated dry gas meter. The gas conditioning train consisted of five (5) impingers contained in an ice/water bath. The first and second impingers contained 100 mL of 0.1 N H 2 SO 4 , the third and fourth impinger contained 100 mL of 0.1 NaOH and the last impinger contained approximately 200 grams of silica gel. The probe and filter box temperatures were maintained above 250 o F, and the impinger temperature was maintained below 68 o F throughout the testing.
Following the completion of the test run, the sampling train was leak checked at a vacuum pressure greater than or equal to the highest vacuum pressure observed during the run. The alternative post-test calibration procedure outlined in Alternative Method 5 Post-Test Calibration (Y qa ) was used for the in-field post test calibration check.
After determining the amount of condensed moisture in each impinger, the acidic absorbing solution (0.1 N H 2 SO 4 ) from the first and second impingers was placed into a sample container and the alkaline absorbing solution (0.1 N NaOH) from the third and fourth impinger was placed into a sample container. The back-half of the filter holder, first and second impingers and all glassware leading to the outlet of the second impinger were triple-rinsed with DIGeneral Shale Brick, Inc. ICR Test Report Testing Methodology

c:\\Projects\General Shale\Spring City, TN\2011-0126\ICR Test Report Page 3-3 water and placed in the appropriate sample container. The samples were sealed, labeled and liquid levels marked for transport to Maxxam Analytics, Inc. of Mississauga, Ontario, Canada.

3.6 Quality Assurance/Quality Control – U. S. EPA Reference Test Method 3A Cylinder calibration gases were supplied by AirGas – South or NexAir which met Protocol 1 (+/- 2%) standards.
Low Level gases were introduced directly to analyzer. After adjusting the analyzer to the Low Level gas concentration and once the analyzer reading was stable, the analyzer reading was recorded. This process was repeated for the High Level gas. Next, Mid Level gases were introduced directly to analyzer and reading was recorded. All recording readings were within +/- 2 percent of the Calibration Span.
All data was reviewed by the Field Team Leader before leaving the facility. Once arriving at AST’s office, all written and electronic data was relinquished to the report coordinator and then a final review was performed by the Project Manager.

# Appendix A

# Appendix B

# Appendix C

# Appendix D

# Appendix E

# Appendix F

# THIS IS THE LAST PAGE OF THIS REPORT