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 MACT 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 were averaged (2.4 and 0.35 lb/hr 

respectively). The tester provided no discussion of these 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 done appropriately or at least 

consistently with the other two test runs. No other significant difference is notable between the first 

test and the following two, and the laboratory notes indicate no concerns with the sample handling in 

transit or Ion Chromatographic 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 Runs 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 invalid 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 degree, 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 none of the 

Method 26A data from this emission test report should be used for emissions calculations.
Multi Metals and Mercury:

The Method 29 test 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 incorrect 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 analyzed 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 method; 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 case, 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 for 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 probe 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