August 9, 2013

Note:

To: Jeff Telander, OAQPS SPPD MMG

From: Steffan Johnson, OAQPS SPPD MPG

Re: Source test report review

– General Shale Brick, Inc, Mooresville, IN, Feb. 1, 2012

Jeff,

I have reviewed the source test report “Determination of HCl/HF/CL2 & HAPS Emissions” submitted by General Shale Brick, Inc., Mooresville, Indiana, dated February 1, 2012, and have found several major discrepancies in the report. It is my professional opinion that data from this report should not be used
in MAC T floor analysis or calculation. The following is a synopsis of my findings.

HCl / HF:

Run 1 of the HCl tests showed extremely high results in lab analysis, and the reported value of 154.7 lb/hr was not used in the final average. Instead, runs 2 and 3 we re averaged (2.4 and 0.35 lb/hr respectively). The tester provided no discussion of the se results in their report nor did they offer explanation in their report as to why the first test run was discarded. Sample volumes, moisture catch results, and flow rate measurements during Run 1 are similar to Runs 2 and 3, and isokinetic calculations demonstrate that the collected sample volume was appropriate for the nozzle size and flow velocity in
the stack. This leads me to believe that the test procedure was d one appropriately or at least consistently with the other two test runs. No other significant difference is notable between the f irst test and the following two, and the laboratory notes indicate no concerns with the sample handling in
transit or Ion Chro matographic analysis. Failing to find significant differences between the three tests, or any issues with the lab analysis, I conclude that the most likely cause of the extremely high value from
Run 1 and subsequently lower results during Run s 2 and 3 are indicative of contamination from sampling gear that was not clean on arrival at the plant site. While this is not absolutely clear from the report, it is clear that the tester themselves questioned the results of the first test enough to consider it inva lid as they did not include those results in their reported averages . As such, I can see no reason to hold the other two tests runs as valid; for if indeed the first run was contaminated it is clear that the second test was likewise affected to some degre e, and possibly the third to an unknown extent . This, naturally,
overflows to the HF data that result from the same test runs as contamination may exist to an unknown degree with that data as well . The sampling gear and reagent is the same for these two analytes, and where data is invalid for one (HCl) it is invalid for the other (HF). It is my conclusion that n one of the Method 26A data from this emission test report should be used for emissions calculations.Multi Metals and Mercury:

The Method 29 tes t results are invalid, top to bottom, for all reported values. A review of the lab data shows appropriate analytical technique, however the samples were not correctly analyzed for their respective analytes. The chain of custody clearly indicates that inc orrect analyses were requested for the majority of samples submitted. Of five analytical fractions that should have been submitted for analysis of Hg from each test run , only 1 fraction from each test run (potassium permanganate impinger solution) was ana lyzed for Hg. This biases the results for mercury low for every test run, and to an unknown extent (but possibly very significant ). Multiple metals analyses were done on 2 analytical
fractions that are stipulated only for mercury analysis by the test met hod; analysis for multi

- metals is never conducted on any portion of the sample train following the nitric/peroxide impinger solution. In other words, samples labeled 5A, 5B, and 5C should not have been analyzed for any metal other than Hg and, in this cas e, both 5A and 5C were analyzed for all metals other than Hg (and not for Hg).
Furthermore , the lab should have received and digested a Method 29 filter ( container 1), and an acetone rinse residue fraction (container 2) for each test run to be analyzed fo r all metals including Hg. There is no record of such samples being submitted to the lab, nor are there lab analyses of these fractions anywhere in the emissions test report.

In summation, all the reported mercury data are biased low to an unknown extent and this data should not be used for any emission calculations. All the reported multi

- metals may be biased high (due to the inclusion of values from sample 5C which will add significant amounts of manganese and other metals contaminants) but without a p robe and filter digestion a significant amount of these metals remains unaccounted for in the final values. Again, these data should not be used in any emissions calculations.

Please let me know if you have any questions regarding my findings; I am happy to discuss these with you further.

Respectfully submitted,

Steffan Johnson

OAQPS/SPPD/MPG