... . •-. "-: : . Poilution.-Control

SystemEvaluations.. arid.Boiler

Performance

.Testing

- . F•hone. (205) .491.6676

Fax (205)-491-6614

-.-Entec Services,

Inc. 16 D Commerce

Avenue Hueytown, Alabama

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

3, 2004 Compliance Emissions

Testing

for the Tunnel Kiln -located

at the Fairmount Facility located in Fairmount,

Georgia Georgia Department

of Natural

Resources Permit No. 3251-064-0073.S-01-0 Submitted

to: Pine Hall Brick

Company,

inc. P.O. Box 836 Madison, North Carolina

27025

Entec Project

No. 23159 Completed By:-
..Attention: Mr. Harold Newman Report Submitted:

Februar•

25, 2004 R•viewed. By: Tommy Lotz, Jr. Project Manager Glen Corley General ManagerREPORT CERTIFICATION The sampling and analysis performed

for this report were carded out under my direction and hereby certify that the test report is authentic and accurate to the best of my knowledge. Date: Signature: l.alan Kirby Project Manager have reviewed the testing details and results of this report, and hereby certify that the test report is authentic and accurate to the best of my knowledge.

Glen Codey General Manager SOURCE OWNER: Pine Hall Brick Company OPERATOR'S LOC•ATION: SE)UR/CE(S),NAME(S): .SOUR(•E•S) C•)NDITION: SOURCE(S) SHAPE: Falrmount,

Georgia Tunnel Kiln Outlet Compliance Olmuiar PROBE WASH CHEMICAL: Acetone SOURCE PERMIT NUMBER: 3251-064-0073-S-01.0 TESTS PERFORMED: Emissions Testing REFERENCE METHOD TESTS:

Sample Location Volumetrio Flow Moie•ular Weight Moisture Content Suffur Dioxide Carbon Dioxide Particulate Hydrochlodo Acid Hydmfloudc A•d

EPA Method EPA Method

2 EPA Method

3A EPA Method

4 EPA Method

6C EPA Method

10 EPA Method

26A .•PA Method

26A EPA Method

26A TEST SUPERVISOR: l.alan Kirby OWNER'S REPRESENTATIVE: Harold Newman RULING AGENCY REPRESENTATIVE: DeAnna Oser DATES TESTS CONDUCTED: 02/03/04 ENTEC PROJECT NUMBER: 23159Pine Hall Brick

Company,

inc. Table of Contents

Section Page # Executive Summary Detailed TestResultsControl Room Production

Data Sampling ProcedureS /• isokinetic

Field Data Sheets Test Run 1 Test Run 2 Test Run 3 Instrumental Field Data Sheets Test Run t Test Run 2 Test Run 3 Location of Test Ports _Cyclonic Flow Test -_Quality Control

I Quality

Assurance

Procedures Laboratory Analysis Equipment Calibration Instrumentation Calibrations Test Calculations

and Nomenclature t479171822630313539

475063779499Executive Summary Entec Services,

Inc. was retained

by Pine Hall Brick Company,

inc. to perform emissions testing,

on the Tunnel

Kiln at the Fairmount

facility

located

in Fairmount, Georgia. Mr. Tommy

Lotz, Jr., Mr. Lalan Kirby, Mr. Joseph

Lotz, and Mr. Tom Lotz, Sr. conducted the testing

on February

3, 2004.

Representing

Pine Hall Brick Company was Mr. Harold

Newman

who coordinated

testing

with the control

room production activity. Ms. DeAnna

G. Oser representing

Georgia

Department

of Natural

Resources observed the testing. Emissions were perf.ormed

in accordance

with EPA CFR .40 Part 60 Appendix

"A" methods 1, 2, 3A, .4,,. 6C, 10, and 26A. Three,

sixty (60) minutes

test runs were performed o/n th,e source

with the Kiln operations

at approximately

85 percent

load. Prior • the first test run a preliminary

velocity

measurement

of the exhaust

gas was dete•.rrn•'ned to verify the absence

of cyclonic

flow in the gas stream

and to allow the selection of the appropriate

nozzle diameter

for isokinetic

sample

withdrawal.

A Nutech Model 2010 sampling

train which meets the specifications

in the above-cited

reference methods, was used to isokinetically

extract the particulate,

hydrogen

chloride

(HCI), and hydrogen fluoride

(HF) samples

by means

of a heated

glass lined steel probe and heated filter compartment. Testing was conducted

from two test ports oriented

at 90 degree

on the exhaust

stack. The test ports were located

10.85-duct

diameters

downstream

and 2.89 duct diarneters upstream from the nearest

disturbance.

A 12-point

traverse

was used to determine

the exhaust gas volumetric

flow and to coilecta

representative

sample

of the particulate, HCI,oand.HF emissions.

Each traverse

point was sampled

for.five

(5) minutes

for a total sampling time of Sixty (60) minutes

for each test run. No difficulties

were encountered

in the field collection

of the samples

or in the laboratory analysis

of the samples

by Entec Services,

Inc. Testing

was conducted

in accordance with the applicable

CFR 40 Part 60 Appendix

"A" test procedures.On

the basis of these facts and a complete

review of the data and results,

it is our -opinion that the results

reported

herein are accurate

and closely

reflect the actual values, which existed

at the time the testing was conducted. The particulate

emissions

test summary

on the following

page gives a detailed sumrnar•- •f each tes• Fun compared

to the-maximum

emission

limits set forth by the Georgia Department

of Natural

Resources.

Tests. results

indicate

the emissions comply with the Georgia

Department

of Natural

Resources

Permit

No..3251-064- -0073-S-01-0Test ItsENTEC Services,

inc. 16-D Commerce

Ave. Hueytown,

Alabama

35023 EMISSIONS CALCULATIONS

Client: Pine Hall Brick Company Job No.:

23159 Source: Tunnel Kiln Outlet

INPUT DATA Data Input By: Tommy Lotz, Jr.

Run Number Test Date Time Began-Ended Sampling Time, Minutes/ Stack Area, Square Feet Barometric, Pressure, Inches of mercury Stack static Pressure, Inches of water Pitot Tube Correction

factor Meter Correction

Factor Meter Delta H • Nozzle Diameter, Inches Meter Volume, Cubic feet Me•er Temperature,

Degrees F Avg: Orifice Delta H,.Inche•-of

Water Highest Vaccum Achieved During Run, in. H 9 Volume H20 Collected,

ml .C.O2 Concentration,

Percent 02 Concentration,

Percent Avg. Sq. Rt of Delta P, Inches of Water Stack Temperature,

Degrees F ,Total Hydrogen Chloride collected, mg Total Hydrogen Fluodde coll.ected, m 9 Total particulate

collected, mg 02/03/04 1000-1121 6012.048 29,36 -0,19

0.993 1.531 0.322

02103104 1205-1310 6O12.048 29,36

0.993 1.531

42.504 43,243 81.3 86.1 1.31.2.592.93.315.5 0.474 1.364,090,6

302/03/O4 1380-1455 80 12.048 29,36 -0.200.840.993 1.531 0.322 44,784 85.51.482.388.1 3.2 3.4 15.5 17.1 0.483 0.504 393.0 393.5 5.56 5.16 1,95 2,02

392.7

2.0335.7

AVERAGE

29.36 -0,20

43.5t0 84.31.38

90.53.316.0 0.487 393.15.352.0027.7 22.8 24,5 -#ENTEC Services,

inc. 16-D Commerce

Ave. Hueytown,

Alabama

35023 EMISSIONS CALCULATIONS

Client: Pine Hall Brick Company Job No.: 23159

Source: Tunnel Kiln Outlet Data Input By: T, Lotz, Jr,

CALCULATED DATA

Run Number 2

3

AvERAGE Test Date Time Began-Ended 1. Stack Pressure, Inches of mercury 2. Meter Pres•sure,•l•ches

of meroury 3. Standard Meter v•Ium•, Cubic Feet Standard Water Volume, Cubic. Feet 5. Moisture Fraction 9. Molecular Weight Of Stack Gas, dry basis !10. Molecular Weight Of Stack Gas, wet basis ! 1. Average Stack Gas Velocity, Feet/Second 12. Stack Gas Flow (• Stack Conditions,

ACFM 13. Stack Gas Flow @ Standard Conditions,

DSCFM 14a. Particulate concentration

@ Std.Cond.,Grains/Cu.Ft. 14b. Hydrogen Chiodde concentration

(• Std.Cond.,Grains/Cu.Ft. 14c. Hydrogen Fluoride concentration

@ Std.Cond.,GrainslCu.Ft. 15a. Particulate*emissions,

Ibs per hour

-'. 15b. Hydrogen Chlodde emissions,

Ibs per hour 15c. Hydrogen Fluoride emissions,

Ibs per hour 16. Volume collected through nozzle, ACF 17. Isokinetic Sampling Rate, Percent

!Post Mater Orifice Cal. (EMC ALT-009 Yqa) !% Difference,

(must be within 5% of odgional Y-factor) 0•0•04 1000-1121 29.35 29.46 40.513 4.373 0.097 29.142 28.057 34.625 25,030 13,710

02103104

02/03/04 1205-1310 1350-1455 29.35 29.35 29.46 40.863 4.265 0.094 29.128 28.077 35.273 25,498 14,003 0.0093 29.47

0.25 0.23

0.24

0.24 0.09 0.09

0.09

0.09 73.963 74.408

76.637

75.003 104.93 103.62

102.42

103.66

0.9972 1.0026

1.0098

1.0032 -1.03% 1.02 0.0021 0.0020 0.0020 0.0007 0.0008

0.0008

0.0008 36.754 26,569 14,692 -0.0136 0.0020

1.71 42.378 4.147 •261 0.089 0.094 29.223 29.165 28.222 28.119 29.46 41.251

35.551 25,699 14,135 0.0105

1.28 0.0087. 29.35Co.•u•trol Room

Production DataControl Room

Data The feed rate in terms of tons of brick per hour was taken by Mr. Harold Newman

of Pine Hall Brick Company,

inc. and was averaged

for the testing performed

on February 3, 2004. The results are located

on the emissions

summary

page, Mr. Harold Newman took readings

for the lime bed dry scrubber

control

device.

The readings

were for pressure drop across

the lime bed in units bf mill bars (mm) and for lime discharge (lbs/hr). The data is located

on th$ following

page.SamplingProcedures The

emission

rates were determined

using EPA Methods

1, 2, 3A, 4, 6C, 10, 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

II! Stationary

Source-Specific Methods were followed

throughout

the duration

of the field and laboratory

testing. The most current

revision

revised

as of. July 1, 2001, of each method

(as described

in the Federal

Register)

was used. Stack Gas Volumetri,

c Flow The veio•city-,of

the gas stream

was determined

according

to EPA Reference

Method

I / and 2"by reading

the instantaneous

velocity

head with an inclined

manometer

at each sam•iirrgl•oint 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. .•, calibrated

pyrometer

was used to measure

stack temperature

at each sampling

point. The stack was tested for cyclonic

flow according

to EPA Reference

Method

1. Stack Gas-Molecular

Weight The carbon

dioxide

concentrations

were determined

using EPA Reference

Method

3A. The molecular

weight of the gas was calculated

using the moisture,

oxygen

and carbon dioxide content

and the measured

stack gas temperature. Moisture Co•tent The moisture

content

used for ,calculating

the gas stream

flow rate was determined-by weighing the amount

of condensed

moisturecollected in the "•mpingers

of the sampling train as described

in EPA Reference

Method

4.Particulate, Hydrogen

Chloride,

and Hydrogen

Fluoride 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_

•nrl =f•r •h= •,•÷ ,,o•,,•., micrometer.and was also recorded

on the data sheets. The sampling

probe was placed at each sampling

point to provide

a total sampling

time of 60 minutes.

The gases were drawn through

a glass nozzle

attached

to a heated glass lined probe.

Tfie probe was maintained

at the proper

setting

to obtain an exit temperature pf 248 _+ 25 0 F, The gases then proceeded

through

borosilicate

glass filter holder, with a" Teflon frit filter support

through

a glass fiber filter to remove

particulate ; matter. The filter wasmaintained

at a temperature

of 248 + 25 0 F. Thesetemperatures were recorded

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

through

a series of four impingers

to capture

hydrogen halides• and halogens

and moisture.

(The optional

first impinger

for a knockout

for moisture was not used.)

The first and second

impingers

contained

approximately

100 ml of a 0.1N H2SO4 solution

and the third and fourth, impinger

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 pass through

the impinger

series in an ice bath to maintain

a maximum

•:exit temperature

of 68 0 F. This temperature

was also recorded on the data sheets.

The clear• and cool-gases

then entered

the meter box where ths gas flow and temperature

were measured. After the completion

of the test the sampling

train and the probe nozzle assembly

was transferred to the cleanup

area making

sure no particulate

was lost. The cleanup

data was recorded.Particulate catches

were placed

in sealed petri dishes.

Each acetone

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

and placed

in a sealed container.

For the group of tests an acetone

blank of approximately

200 milliliters

was placed in a sealed container. The first and second

impinger

contents

were transferred

to its tared container, weighed

and the rinsing

from the glassware

were added to this container. The third and fourth impinger

was transferred

to its respective

tared container,

weighed and the rinsing from the glassware

was added to this container.

The. silica ge! from the fifth impinger

was transferred

to its respective

tared container

and weighed.

A blank of the sulfuric

acid solution,

sodium

hydroxide,

distilled

water and acetone

was taken. All containers were clearly marked,

logged in, and shipped,

to a State of Georgia

approved certified laboratory,

for analysis. Oxy_qen- ./ Ti•e 0•'ygen..content

in the flue gas was determined

using a Siemens

Ultramat

23 ox'y•ed analyzer.

The Ultramat

23 uses an electrochemical

cell that consumes

oxygen from the atmosphere

surrounding

the cell. The consumption

of the oxygen,

generates

a proportional electrical

current.

This current

is then amplified

and provides-

a signal output of 4-20ma

signals,

which corresponds

to a full-scale

range of 0-25% oxygen. Carbon Dioxide Carbon dioxide

concentrations

were continuously

measured

with a Siemens

Ultramat 23 non-dispersive

infrared

(NDIR)analyzer.

The theory of operation

for this analyzer

is based on the principle

that CO2 has a unique

absorption

line spectrum

in the infrared region. The instrument

consist•

of an irtfrared

light.source,

a chopper,

a measurement cell, and a d•tector.

The infrared

light beam emitted

by the source

.passes

through

the mea•sur!,ng cell, which is filled .with a continuously

flowing

.gas..sample.

The light beam is partially absorbed

or attenuated

by the gas species

ot interest

in this cell before reaching the front chamber

of the detector.

Both the front and rear chambers

of the sealed detector

are filled with a reference

gas. The difference

in the amount

of light absorbed between

the front and rear chambers

are dependent

on the concentration

of the gas species

of interest

within the sample

measurement

cell; a pressure

differentialis

thus created

between

the two chambers.

This pressure

difference

is then observed as gas flow by the micro-flow

sensor

located

in a channel

connecting

the two chambers. The resulting

AC signal from the micro-flow

sensor

is rectified,

amplified

and iinearized into a 4-20ma

signal for output that corresponds

to a full-scale

0-25% measurement range. Sulfur Dioxide A Western

Research

Model 721M SO2 analyzer

provided

continuous

analysis

of SO2 in the gas stream.

The basic analytical

principle

involves

quantitative

measurement

of the absorption of UV radiation

by •SO2 molecules.

The analyzer

uses a single light source, which emits an appropriate

wavelength,

illuminating

the sample

cell throughwhich

the sample is continuously

passed.

Narrow-band

optical

filters are rotated

through

the beam, and tr)e ra, diation

passed

through

the optical filters and sample

cell !s detected by a single photo,detector.

The signal pulses from the photo-detector

are separatedby

a multiplexor

into a measuring

channel

and-a reference

Channel.

A log ratio ampiifier. computes the logarithm

of the input signal ration, producing

a signal that is' proportional to the SO2 concentration.

The duat-range

analyzer

has a digital readout,

as well as 0- 10.0 V DC output •erminals.

The full scale of the instrument

was setat 100 ppm Carbon Monoxide The CO •vas measured

using a Siemens

Ultramat

23 .analyzer.

T-his monitor

is a selective non-dispersive

infrared

radiation

(NDIR)

gas analyzer

that operates-,

on the infrared doubi•beam

alternating,

light .principle.

The full-range

for the CO component

of this instrument

throughout

the test period Was t000 ppm. Sampling System :. '.... Samples were extracted

from the gas stream

by a heated

stainless

steel-probe• maintained at a set temperature

of 250 degrees

Fahrenheit,

through

a ten (10) foot heated sample

line that was heated

to a temperature

between

225 and 250 degrees, through a chilled sample

conditioner

to remove

the moisture

in the.gas

stream

and transported to the test trailer through

unheated

teflon sample

lines to the analyzers.Da•

Aca.uisition Concentrations

were collected

at each fifteen-second,

interval

and averaged

at each -ten-second and sixty-second

intervals

with a Parametrics

data acquisition

system. During all testing,

the unit was operating

within normal operating

parameters;

at a range appropriate in accordance

with applicable

permits.