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, 2011
General Shale Brick, Inc.

ICR Test Report

Certification Statement

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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.com

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ICR Test Report

Table of Contents

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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, Cl2 & 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

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Introduction

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Generals Shale Brick, Inc.

ICR Test Report

Introduction

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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 (Cl2), 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.

Page 5 of 85
Summary of Results

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General Shale Brick, Inc.

ICR Test Report

Summary of Results

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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, Cl2, 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, Cl2 & 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 % O2 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 % O2 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 % O2 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 0.005

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Summary of Results

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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 % O2 [<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 % O2 [<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 % O2 [<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 % O2 [<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 % O2 [<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 % O2 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 % O2 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 % O2 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-06

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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 % O2 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 % O2 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 % O2 [<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 % O2 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

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Testing Methodology

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General Shale Brick, Inc.

ICR Test Report

Testing Methodology

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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 (O2/CO2) 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/Cl2/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 O2/CO2/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 Test

Methods 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) of

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HNO3/H2O2, the third and fourth were empty, the fifth and sixth contained 100 mL of acidic KMnO4 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% HNO3 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 (Yqa) 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 HNO3. 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 HNO3. 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

HNO3, 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 KMNO4 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 H2SO4, 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 250oF, and the impinger temperature was maintained

below 68oF 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 (Yqa) 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 H2SO4)

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 DI

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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.

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Appendix A 

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Appendix B 

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Appendix C 

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Appendix D 

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Appendix E 

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Appendix F 

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THIS IS THE LAST

PAGE OF THIS

REPORT

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