Date: September 24, 2015 

To: Sharon Nizich, EPA/OAQPS/SPPD 

From: Gabrielle Raymond, RTI International 

Subject: Test Data Used in BSCP Manufacturing Final Rule 

I. Introduction 

In accordance with section 112 of the Clean Air Act (CAA), the U.S. Environmental 

Protection Agency (EPA) established national emission standards for hazardous air pollutants 

(NESHAP) on May 16, 2003, for the brick and structural clay products (BSCP) manufacturing 

industry. The NESHAP regulated emissions of hydrogen fluoride (HF), hydrogen chloride 

(HCl), and particulate matter (PM)—a surrogate for hazardous air pollutant (HAP) metals—from 

tunnel kilns located at BSCP facilities. On March 13, 2007, the D.C. Circuit Court vacated the 

emission standards for BSCP manufacturing due to issues associated with the methodology used 

to determine the minimum regulatory “floors” for new and existing units.1 Therefore, on 

December 18, 2014, the EPA proposed new standards for BSCP manufacturing, including limits 

for HF, HCl, chlorine (Cl2), mercury (Hg), and non-Hg metals (or PM surrogate). The EPA 

provided a 90-day public comment period following proposal of the BSCP Manufacturing 

NESHAP, during which all affected parties were given the opportunity to comment on the 

proposed rule. The EPA has considered the comments received and, as appropriate, incorporated 

them into the final rule. The purpose of this memorandum is to describe the sources of test data 

obtained for BSCP tunnel kilns and dryers and considered in the BSCP rulemaking and to 

describe the quality assurance/quality control (QA/QC) checks performed on the data. 

II. Sources of Data 

The main sources of test data were responses to the 2008 and 2010 section 114 surveys to 

the BSCP industry (described in the remainder of this section), test data in the BSCP Legacy 

Docket A-99-30, test reports that the Brick Industry Association (BIA) sent to the EPA to 

provide test data for facilities not covered by the section 114 surveys, and data received 

following the publication of the proposed rule. Copies of all the test reports collected from these 

sources are included in Docket ID No. EPA-HQ-OAR-2013-0291. 

 

1 Sierra Club v. EPA, 479 F.3d 875 (D.C. Cir. 2007). 
2 

The EPA conducted two surveys under the authority of section 114 of the CAA. In June 

2008, the EPA sent out a survey to nine BSCP companies—Acme Brick, The Belden Brick Co., 

Boral Bricks, Inc., Carolina Ceramics Brick Co., General Shale Brick, Inc., Glen-Gery Corp., 

Hanson Building Products America, Morin Brick Co., and Taylor Clay Products, Inc. (Tsirigotis, 

2008). The survey was designed in the form of a Microsoft Excel® spreadsheet file that 

included seven different worksheets to complete. The main intention of the survey was to collect 

inventory information about the kilns at those nine companies. Although the 2008 survey did not 

require any new testing to be performed, the “Form D - Test Data” worksheet in the survey asked 

for information on emission tests previously performed on kilns at the facilities and asked each 

facility to submit complete copies of the reports for these emission tests. The test reports 

received contained results for HF, HCl, Cl2, and filterable PM. 

In 2010, the EPA sent out another section 114 survey to nine BSCP companies. The 

survey was sent out in two phases. Phase I of the survey was sent out to three companies (The 

Belden Brick Co., Boral Bricks, Inc., and Hanson Building Products America) and required 

testing of HF, HCl, Cl2, PM filterable, HAP metals including Hg, and dioxin/furan emissions 

from tunnel kilns and testing of dioxin/furan emissions from dryers (Tsirigotis, 2010a-c). Phase 

II of the survey was sent out to six companies (Acme Brick, General Shale Brick, Inc., GlenGery Corp., Interstate Brick, Jenkins Brick and Tile Company, and Taylor Clay Products, Inc.) 

and required testing of HF, HCl, Cl2, PM filterable, and HAP metals emissions from tunnel kilns 

(Tsirigotis, 2010d-i). Instead of performing new stack tests, Interstate Brick and Jenkins Brick 

requested permission to submit historical results of tests previously conducted at the facilities 

(Gunning, 2011; Sims, 2011), and the EPA granted the request (Telander, 2011a,b). 

Following the publication of the proposed rule, BIA provided three Glen-Gery stack tests 

for three individual kilns with HF, HCl, and PM test data. These data were incorporated into the 

individual run by run spreadsheets: Shoemakersville, PA Kiln ID 646, Shoemakersville, PA Kiln 

ID 647, and York, PA Kiln ID 649. 

III. Data Compiled and Calculations Conducted from Test Reports 

From each test report, the following parameters and emissions data for each test run were 

compiled into a master run-by-run spreadsheet: 

 Production rate, in tons per hour (tph) 

 Flow rate, in actual cubic feet per minute (acfm) 

 Flow rate, in dry standard cubic feet per minute (dscfm) 

 Sample volume, in dry standard cubic feet (dscf) 

 Sample volume, in dry standard cubic meter (dscm) 

 Stack moisture, in percent (%) 

 Stack gas temperature, in degrees Fahrenheit ( ̊F) 

 Oxygen content of stack gas, in percent (%) 

 Pollutant concentration, in parts per million (ppm), milligrams per dry standard cubic 

meter (mg/dscm), grains per dry standard cubic foot (gr/dscf), etc. 

 Pollutant emission rate, in kilograms per hour (kg/hr), pounds per hour (lb/hr), etc. 
3 

Once the data were compiled, the following calculations were conducted in the master 

run-by-run spreadsheet: 

 Converted reported concentrations to micrograms per dry standard cubic meter (μg/dscm) 

 Corrected reported concentrations to 17 percent oxygen (% O2) using the following 

equation:     2 Tested % O2 μg/dscm@17% O  μg/dscm 20.9 17  20.9 

 Calculated emissions in pounds per ton (lb/ton) using emission rate (lb/hr) and production 

rate (tph) 

Note that at proposal, the reported concentrations were corrected to 7% O2. However, 

during the public comment period, several commenters stated that the concentration limits for 

PM and Hg should not be corrected to 7 % O2 because BSCP tunnel kilns operate with a higher 

oxygen content. The EPA evaluated the oxygen content of the run-by-run datasets of PM and 

Hg for BSCP tunnel kilns and found that for the PM data set, the oxygen content ranged from 9.5 

to 20.5 % O2, with an average of 16.8 and a mode of 17 % O2 when evaluating the run-by-run O2

values rounded to whole numbers. For the Hg data set, the oxygen content ranged from 13.1 to 

19.5 % O2, with an average of 17.2 and a mode of 17 % O2 when evaluating the run-by-run O2

values rounded to whole numbers. The EPA concluded that correcting concentration data to 17 

% O2 rather than 7 % O2, as proposed, provides more representative values of kilns’ operating 

conditions and would not artificially inflate the values. Therefore, the EPA recalculated the 

oxygen-corrected PM and Hg test runs to be corrected to 17 % O2 instead of 7 % O2. 

In addition, the commenters noted that for kilns that did not report a tested oxygen 

content, the calculation of the oxygen-corrected PM concentration values incorrectly assumed a 

0 % O2 value. Thus, for the final run-by-run PM dataset, for kilns that did not report a tested 

oxygen content value, the EPA did not correct PM concentration to 17 % O2 and did not use the 

data from those kilns in calculating the concentration MACT floors. See Appendix A for the list 

of kilns without an oxygen-corrected PM concentration value. 

IV. Quality Assurance/Quality Control Checks 

After the test data had been compiled and calculated in the master run-by-run 

spreadsheet, there were three rounds of QA/QC with BIA and internal QA/QC from RTI and the 

EPA. Test data determined to be unacceptable after the QA/QC checks were removed from the 

run-by-run spreadsheet and were not included in the calculation of MACT floors. See Appendix 

A for the list of test data that were removed from the run-by-run spreadsheet after the QA/QC 

checks. See Appendix B for the run-by-run test data that were used in the calculation of MACT 

floors. 

A. BIA QA/QC 

The BIA provided their first round of comments on a subset of the test data in a 

memorandum dated June 5, 2009 (Kuo et al., 2009a). The BIA retained the services of Mr. Mike 

Hartman of Air-Tech Environmental, LLC to review the test reports submitted to the EPA. Mr. 

Hartman’s review included comparison of the sampling and analysis approach used in the stack 

tests to the approach required by the reference method, as well as insights from his experience as 

a stack tester. The review results were presented in three groups: 
4 

 Tests that BIA believed should be removed immediately from the EPA’s database used to 

establish a MACT standard due to documented issues with the test methodology or 

results. 

 Tests that warranted additional review due to concerns that proper procedures were not 

followed, either during the testing or the analytical process. 

 Tests that appeared to be incorrectly presented in the EPA’s summary table. 

The memorandum from BIA was reviewed with the corresponding test data, and 

revisions were made to the test data set. For acid gas tests where a glass fiber filter was used, the 

results were removed from the test data set. For acid gas tests where the probe and filter 

temperature were not maintained at the proper temperature per the test method instructions, the 

results were removed from the test data set. In both of the above cases, the PM data were 

retained, as errors in the acid gas testing methodology did not affect the PM results. The data for 

any tests that were rejected by the local or state agency were also removed from the test data set. 

The BIA provided a second round of review on the remaining test data in a memorandum 

dated September 4, 2009 (Kuo et al., 2009b). The purpose of the memorandum was to present 

the review of the remaining test reports not addressed in the first round of comments, as well as 

to present BIA’s comments on the EPA’s conclusions regarding BIA’s first memorandum (Kuo 

et al., 2009a). 

The second memorandum from BIA was reviewed with the corresponding test data, and 

revisions were made to the test data set. Similar to the review of the first memorandum, acid gas 

data were removed for tests where a glass fiber filter was used or where the probe and filter 

temperature were not maintained at the proper temperature per the test method instructions (the 

PM data were retained). For PM tests where the testing contractor or laboratory noted a ripped 

filter, the data were removed from the test data set. For tests where the testing contractor or 

laboratory indicated non-detect values, the data were not removed, but the run was flagged with 

a “<”. For tests that were run at “extreme feed type conditions,” defined as 100 percent fireclay 

raw material, the data were removed as not representative of normal operation. Results for total 

fluorides measured with EPA Method 13B were not removed from the test data set if they were 

the only results representative of HF available for that source. Other revisions included 

correcting calculation errors or misinterpreted test data that the BIA explained and revising 

production rates with values BIA provided. 

The BIA provided their third round of review in a memorandum dated December 12, 

2012 (Kuo and Miller, 2012). The purpose of the memorandum was to present specific changes 

and/or updates to the EPA’s BSCP Manufacturing MACT floor ranking database. Several 

changes had occurred in the BSCP industry since the industry’s section 114 survey submittals, 

including acquisitions, closures, and new test data. The BIA provided two acquisition updates 

and a table listing demolished and/or decommissioned kilns. The BIA also revisited a few test 

reports from the June 5, 2009 memorandum (Kuo et al., 2009a) and provided updated 

information regarding facility status, control technology, and emission factors. 

The third memorandum from BIA was reviewed with the corresponding test data, and 

revisions were made to the inventory and test data set. The BSCP tunnel kiln inventory was 

updated with the new acquisition, facility status, and control technology updates (Holloway, 
5 

2014). Test data from kilns identified as being demolished and/or decommissioned were 

removed. Any applicable data errors identified by the BIA were revised. For tests where the 

testing contractor or laboratory indicated non-detect values, the data were not removed, but the 

run was flagged with a “<”. The source classification for facilities that changed status (e.g., 

major source, synthetic area source) was also revised. 

B. Internal QA/QC 

1. Mercury and Non-Mercury HAP Metals 

In the internal QA/QC of the test data, inconsistencies were found between the Hg and 

individual non-Hg HAP metal values reported in the summary pages of certain test reports and 

the values reported in the laboratory sections of the test reports. Therefore, the Hg and non-Hg 

HAP metal values were reviewed for correctness, starting from the laboratory results. 

Specifically, the laboratory reports were reviewed to extract and compile the mass values for five 

Hg fractions and two non-Hg HAP metal fractions (see list below), the blank fractions, and the 

method detection limits (MDLs), or other reporting limit if MDLs were not available. 

 Front Half (Hg & non-Hg HAP metal), Fraction 1: Container 1 Filter, Container 2 

Acetone Probe Rinse, Container 3 Acid Probe Rinse 

 Back Half (Hg & non-Hg HAP metal), Fraction 2B: Container 4 HNO3/H2O2 (Nitric 

Acid/ Hydrogen Peroxide) Impingers 

 Back Half (Hg Only), Fraction 3A: Container 5A HNO3

 Back Half (Hg Only), Fraction 3B: Container 5B KMnO4/H2SO4 (Potassium 

Permanganate/Sulfuric Acid) Absorbing Solution 

 Back Half (Hg Only), Fraction 3C: Container 5C HCl Rinse and Dilution 

The Hg and other HAP metal values were recalculated from the laboratory data and blank 

corrected when necessary in accordance with EPA Method 29 guidelines. These are the values 

included in Appendix B for Hg and non-Hg HAP metals data. 

2. Manganese Contamination 

The 2010 section 114 survey test request included BSCP tunnel kiln Hg testing 

concurrent with non-Hg HAP metal testing using EPA Method 29. There is a possibility of the 

back half fraction (Fraction 2B) for manganese (Mn) being contaminated from the permanganate 

used in Fraction 3B for Hg sampling. To check for Mn contamination, the ratio of the back half 

Mn mass to the front half Mn mass was calculated. If the ratio was over 5, that test run was 

assumed to have Mn contamination. The test runs with Mn contamination were removed from 

the data set. If it was determined that only one test run from a particular test for a source was not 

contaminated, the entire test was removed. The following table indicates the test runs that were 

removed from the BSCP tunnel kiln data set due to Mn contamination. 
6 

Table 1. BSCP Tunnel Kiln Test Runs Removed Due to Mn Contamination 

RTI 

Inventory 

- Kiln No. Test Date 

Run 

No. Facility Name City 

Stat

e Kiln ID 

503 2/8/2011 2, 3 a Acme Brick Denton TX EPN 21 (Kiln A) 

543 9/17/2010 2 Boral Bricks, Inc. - Augusta 

Plant 5 Augusta GA EU05 

566 9/21/2010 3 Boral Bricks, Inc. - Salisbury 

Plant Salisbury NC BK6 

547/548 7/13-14/2010 1, 3 a Boral Bricks, Inc. - Bessemer 

Plant 6 Bessemer AL 003 & 004 (kiln 1&2) 

568 11/17/2010 1, 3 a Boral Bricks, Inc. - Union City 

Plant Union City OK EU02 

606 1/18/2011 3 General Shale Brick, Inc. Coosa 

(Rome) GA Kiln 40 Units K2 

(kiln B) 

653 1/27/2011 1 Hanson Brick Elgin TX tk-2 

676 8/17/2010 5 Hanson (formerly Jannock/US 

Brick) Mineral Wells TX tk-2 

a Entire test was removed because only one test run from this test was not contaminated. 

3. PM Correction for Test Runs Below 1 mg 

As part of the BSCP test data review, the mass (mg) collected for each PM test run was 

evaluated. In the EPA memorandum, Data and procedure for handling below detection level 

data in analyzing various pollutant emissions databases for MACT and RTR emissions limits, 

1 mg is given as the Representative Detection Level (RDL) for PM (Westlin and Merrill, 2011). 

For test runs with less than 1 mg collected, the 1 mg RDL value was used to calculate the 

concentration, emission rate, and emission factor for that run. In these cases, the emission factor 

was calculated as follows: 

hr

ton product

453.59237 mg

1lb

1hr

60 min

min

dscf

dscf

0.02831685dscm

dscm

1mg

ton product

lb 















   



4. PM Evaluation for Probe and Filter Temperatures 

The EPA examined the PM test data and found that a number of the EPA Method 5 test 

runs had probe or filter temperatures outside of the range of acceptable values. EPA Method 5 

specifies that the temperature should be maintained at 248 ± 25 degrees Fahrenheit (°F) (i.e., 

between 223 and 273 °F). Test runs with temperatures outside that range were removed from the 

data set; see Appendix A. 
7 

5. Dioxins/Furans 

To calculate emissions of total dioxins/furans, the mass values for each of the homologue 

group totals reported in the laboratory analysis of the test report were summed. The homologue 

groups are shown in Table 2. 

Table 2. Dioxin/Furan Homologue Group Totals 

Homologue Group Totals Short Hand 

Total Tetrachlorodibenzo-p-dioxins Total TCDD 

Total Pentachlorodibenzo-p-dioxin Total PeCDD 

Total Hexachlorodibenzo-p-dioxins Total HxCDD 

Total Heptachlorodibenzo-p-dioxins Total HpCDD 

Total Octachlorodibenzo-p-dioxin Total OCDD 

Total Tetrachlorodibenzofurans Total TCDF 

Total Pentachlorodibenzofurans Total PeCDF 

Total Hexachlorodibenzofurans Total HxCDF 

Total Heptachlorodibenzofurans Total HpCDF 

Total Octachlorodibenzofuran Total OCDF 

Next, 17 specific dioxin/furan congeners were considered separately from the homologue 

group totals. The 17 specific dioxin/furan congener mass values reported in the laboratory 

analysis of the test report were converted to 2,3,7,8-TCDD toxic equivalency (TEQ) values for 

each test run using the 2005 World Health Organization (WHO) toxicity equivalence factors 

(TEF) (EPA, 2010) in Table 3. The 17 converted TEQ values were then summed to calculate a 

total TEQ value for each run. Appendix C contains a sample calculation showing how the total 

dioxin/furan and total TEQ values were calculated from the reported laboratory masses to the 

final run by run values presented in Appendix B. 
8 

Table 3. Dioxin/Furan Toxicity Equivalence Factors 

Dioxin/furan congener Short Hand 

Toxicity equivalence 

factor 

2,3,7,8-tetrachlorodibenzo-p-dioxin 2,3,7,8-TCDD 1 

1,2,3,7,8-pentachlorodibenzo-p-dioxin 1,2,3,7,8-PeCDD 1 

1,2,3,4,7,8-hexachlorodibenzo-p-dioxin 1,2,3,4,7,8-HxCDD 0.1 

1,2,3,7,8,9-hexachlorodibenzo-p-dioxin 1,2,3,6,7,8-HxCDD 0.1 

1,2,3,6,7,8-hexachlorodibenzo-p-dioxin 1,2,3,7,8,9-HxCDD 0.1 

1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin 1,2,3,4,6,7,8-HpCDD 0.01 

Octachlorodibenzo-p-dioxin OCDD 0.0003 

2,3,7,8-tetrachlorodibenzofuran 2,3,7,8-TCDF 0.1 

1,2,3,7,8-pentachlorodibenzofuran 1,2,3,7,8-PeCDF 0.03 

2,3,4,7,8-pentachlorodibenzofuran 2,3,4,7,8-PeCDF 0.3 

1,2,3,4,7,8-hexachlorodibenzofuran 1,2,3,4,7,8-HxCDF 0.1 

1,2,3,6,7,8-hexachlorodibenzofuran 1,2,3,6,7,8-HxCDF 0.1 

2,3,4,6,7,8-hexachlorodibenzofuran 2,3,4,6,7,8-HxCDF 0.1 

1,2,3,7,8,9-hexachlorodibenzofuran 1,2,3,7,8,9-HxCDF 0.1 

1,2,3,4,6,7,8-heptachlorodibenzofuran 1,2,3,4,6,7,8-HpCDF 0.01 

1,2,3,4,7,8,9-heptachlorodibenzofuran 1,2,3,4,7,8,9-HpCDF 0.01 

Octachlorodibenzofuran OCDF 0.0003 

6. Non-Detects 

As mentioned in Section IV.B.1, Hg and non-Hg HAP metal test runs are comprised of 

individual fractions. For any test run fraction that had values flagged as being below detection 

limit (BDL), the MDL, or other reporting limit if an MDL was not available, was used as the 

mass for that fraction. The concentration, emission rate, and emission factor for the run were 

then calculated using the sum of the fractions for each test run. 

If all fractions for a run were flagged as BDL, then the run was considered BDL. If there 

was a mix of fractions flagged as BDL and above detection limit (ADL), then the run was 

considered detection level limited (DLL). If all fractions for a run were flagged as ADL, then 

the run was considered ADL. 

Similarly, for dioxin/furan testing, there are multiple congeners for each TEQ run. The 

run was flagged as BDL if all of the congener masses were below the MDL; DLL if one or more 

congeners were below the MDL; and ADL if all the congeners were above the MDL. For each 

fraction/congener mass that is below the MDL, the MDL mass was used for the 

fraction/congener mass and subsequent emissions calculations. For more information on how 

these data were treated for purposes of calculating MACT floors, see the memorandum Final

Maximum Achievable Control Technology (MACT) Floor Analysis for Brick and Structural Clay 

Products (Raymond and Sroka, 2015). 
9 

7. Production Rates 

For most of the test reports, the production rate (in tph) was provided within the test 

report. Some of the test reports did not provide a production rate. In some of those instances, 

the BIA was able to provide the production rate. Alternatively, if another test was conducted on 

the same source in a similar time frame, the production rate for that test was used. As a last 

resort, if the production rate used during the test was not provided in the test report or survey 

response, and it was not available from the facility, the production rate was set equal to 

83 percent of the kiln capacity. The 83 percent capacity utilization was a conservative estimated 

developed from the available production data and design capacities reported in the BIA survey 

data (Schimmel, 2008). 

8. Kiln Configurations 

In some cases, multiple kilns are ducted together to the outlet stack being tested. Each 

kiln operating during the time of testing was assumed to have the same concentration and 

emission factor value. Their emission rate values were calculated as a proportion of the outlet 

stack value, based on a ratio of production rates. If any of the kilns were not operating during 

the test, the emission values do not apply to those kilns. 

9. Kiln Status Change 

The BIA notified EPA of status changes of several facilities. The data from these 

facilities were removed from the datasets. For more information please see Updated Inventory 

Database and Documentation for Brick and Structural Clay Products Manufacturing Final Rule. 

V. References 

EPA (U.S. Environmental Protection Agency). 2010. Recommended Toxicity Equivalence 

Factors (TEFs) for Human Health Risk Assessments of 2,3,7,8-Tetrachlorodibenzo-p-dioxin 

and Dioxin-Like Compounds. Publication No. EPA/100/R–10/005. December 2010. Docket 

Item No. EPA-HQ-OAR-2013-0291-0054. 

Gunning, G. 2011. “Request for exemption from testing requirements of section 114 

information collection request for Interstate Brick.” Letter and attachment from Gerry 

Gunning, Interstate Brick, to Jeff Telander, U.S. Environmental Protection Agency. January 

4, 2011. Docket Item No. EPA-HQ-OAR-2013-0291-0488. 

Holloway, T., and K. Sroka. 2015. Updated BSCP Inventory Database and Documentation for 

Brick and Structural Clay Products Manufacturing Final Rule. Memorandum from Thomas 

Holloway and Kristin Sroka, RTI International, to Sharon Nizich, EPA/OAQPS/SPPD. 

September 24, 2015. 

Johnson, S. 2013. Source test report review – General Shale Brick, Inc, Mooresville, IN, Feb. 1, 

2012. Memorandum from Steffan Johnson, EPA/SPPD, to Jeff Telander, EPA/SPPD. 

August 9, 2013. Docket Item No. EPA-HQ-OAR-2013-0291-0324. 
10 

Kuo, I., S. Miller, and M. Hartman. 2009a. Preliminary review of test reports. Memorandum 

from Irene Kuo and Susan Miller, Brick Industry Association, and Michael Hartman, AirTech Environmental, LLC, to Jeff Telander, EPA/SPPD. June 5, 2009. Docket Item No. 

EPA-HQ-OAR-2013-0291-0213. 

Kuo, I., S. Miller, and M. Hartman. 2009b. Subsequent review of test reports and BIA 

comments on EPA actions on preliminary review of test reports. Memorandum from Irene 

Kuo and Susan Miller, Brick Industry Association, and Michael Hartman, Air-Tech 

Environmental, LLC, to Jeff Telander, EPA/SPPD. September 4, 2009. Docket Item No. 

EPA-HQ-OAR-2013-0291-0210. 

Kuo, I. and S. Miller. 2012. Review of EPA BSCP MACT Floor Ranking Database (Version 

dated 3/15/2010). Memorandum from Irene Kuo and Susan Miller, Brick Industry 

Association, to Jeff Telander, EPA/SPPD. December 12, 2012. Docket Item No. EPA-HQOAR-2013-0291-0207. 

Raymond, G. and K. Sroka. 2015. Final Maximum Achievable Control Technology (MACT) 

Floor Analysis for the Brick and Structural Clay Products. Memorandum from Gabrielle 

Raymond and Kristin Sroka, RTI International, to Sharon Nizich, EPA/OAQPS/SPPD. 

September 24, 2015. 

Schimmel, T. 2008. “Brick Industry Association MACT data collection.” E-mail and 

attachments from Terry Schimmel, Brick Industry Association, to Jeff Telander, U.S. 

Environmental Protection Agency. October 17, 2008. Docket Item No. EPA-HQ-OAR2013-0291-0216. 

Sims, B. 2011. “Request for exemption from testing requirements of section 114 information 

collection request for Jenkins Brick and Tile Co.” Letter from Brian Sims, Jenkins Brick and 

Tile Co., to Jeff Telander, U.S. Environmental Protection Agency. January 13, 2011. 

Docket Item No. EPA-HQ-OAR-2013-0291-0482. 

Telander, J. 2011a. “EPA approval of request for exemption from testing requirements of 

section 114 information collection request for Interstate Brick.” E-mail from Jeff Telander, 

U.S. Environmental Protection Agency, to Gerald Gunning, Interstate Brick. January 12, 

2011. Docket Item No. EPA-HQ-OAR-2013-0291-0483. 

Telander, J. 2011b. “EPA approval of request for exemption from testing requirements of 

section 114 information collection request for Jenkins Brick and Tile Co.” E-mail from Jeff 

Telander, U.S. Environmental Protection Agency, to Brian Sims, Jenkins Brick and Tile Co. 

February 15, 2011. Docket Item No. EPA-HQ-OAR-2013-0291-0480. 

Tsirigotis, P. 2008. “Section 114 information collection request to selected brick and structural 

clay products facilities.” Letter and attachments from Peter Tsirigotis, U.S. Environmental 

Protection Agency, to Terry Schimmel, Boral Bricks, Inc., transmitting section 114 

information collection request asking for information on brick and structural clay products 

processes, emissions, and controls. Identical letters sent to other addressees listed (The 

Belden Brick Co., Boral Bricks, Inc., Carolina Ceramics Brick Co., General Shale Brick, 
11 

Inc., Glen-Gery Corp., Hanson Building Products America, Morin Brick Co., and Taylor 

Clay Products, Inc.). June 4, 2008. Docket Item No. EPA-HQ-OAR-2013-0291-0506. 

Tsirigotis, P. 2010a. “Section 114 information collection request to The Belden Brick Co.” 

Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to 

William Belden, Jr., The Belden Brick Co., transmitting section 114 information collection 

request asking for information on startup and shutdown events and emission data for 

specified emission points. June 11, 2010. Docket Item No. EPA-HQ-OAR-2013-0291-0497. 

Tsirigotis, P. 2010b. “Section 114 information collection request to Boral Bricks, Inc.” Letter 

and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Terry 

Schimmel, Boral Bricks Inc., transmitting section 114 information collection request asking 

for information on startup and shutdown events and emission data for specified emission 

points. June 11, 2010. Docket Item No. EPA-HQ-OAR-2013-0291-0496. 

Tsirigotis, P. 2010c. “Section 114 information collection request to Hanson Building Products 

America.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection 

Agency, to J. David McKeown, Hanson Building Products America, transmitting section 114 

information collection request asking for information on startup and shutdown events and 

emission data for specified emission points. June 11, 2010. Docket Item No. EPA-HQOAR-2013-0291-0495. 

Tsirigotis, P. 2010d. “Section 114 information collection request to Acme Brick Co.” Letter 

and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Dennis 

Knautz, Acme Brick Co., transmitting section 114 information collection request asking for 

information on startup and shutdown events and emission data for specified emission points. 

November 17, 2010. Docket Item No. EPA-HQ-OAR-2013-0291-0494. 

Tsirigotis, P. 2010e. “Section 114 information collection request to General Shale Brick, Inc.” 

Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to 

Dave McNees, General Shale Brick, Inc., transmitting section 114 information collection 

request asking for information on startup and shutdown events and emission data for 

specified emission points. November 17, 2010. Docket Item No. EPA-HQ-OAR-2013-

0291-0493. 

Tsirigotis, P. 2010f. “Section 114 information collection request to Glen-Gery Corp.” Letter 

and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Steve 

Matsick, Glen-Gery Corp., transmitting section 114 information collection request asking for 

information on startup and shutdown events and emission data for specified emission points. 

November 17, 2010. Docket Item No. EPA-HQ-OAR-2013-0291-0492. 

Tsirigotis, P. 2010g. “Section 114 information collection request to Interstate Brick.” Letter 

and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Gerry 

Gunning, Interstate Brick, transmitting section 114 information collection request asking for 

information on startup and shutdown events and emission data for specified emission points. 

November 17, 2010. Docket Item No. EPA-HQ-OAR-2013-0291-0491. 
12 

Tsirigotis, P. 2010h. “Section 114 information collection request to Jenkins Brick and Tile Co.” 

Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to 

Mike Jenkins, Jenkins Brick and Tile Co., transmitting section 114 information collection 

request asking for information on startup and shutdown events and emission data for 

specified emission points. November 17, 2010. Docket Item No. EPA-HQ-OAR-2013-

0291-0490. 

Tsirigotis, P. 2010i. “Section 114 information collection request to Taylor Clay Products, Inc.” 

Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to 

Charles Taylor, Taylor Clay Products, Inc., transmitting section 114 information collection 

request asking for information on startup and shutdown events and emission data for 

specified emission points. November 17, 2010. Docket Item No. EPA-HQ-OAR-2013-

0291-0489. 

Westlin, P. and R. Merrill. 2011. Data and procedure for handling below detection level data in 

analyzing various pollutant emissions databases for MACT and RTR emissions limits. 

Memorandum from Peter Westlin, SPPD/MPG and Raymond Merrill, AQAD/MTG, to 

SPPD management and MACT rule writers. December 13, 2011. Docket Item No. EPAHQ-OAR-2013-0291-0133. 
Appendix A 

Test Data Not Used 
A-1 

Table A-1. Tunnel Kiln Test Data Removed from Database after QA/QC, Not Used in MACT Floo

Facility 

ID Facility City State Test Date Source Kiln ID Explanation Why D

ACME-5 Acme Brick Company Denton TX 2/8/2011 2010 survey 503 Removed Non-Hg HAP Metal r

test run from this test was not M

ACME-6 Acme Brick Company Castle Rock CO 7/2/1998 Docket A- 99-30 506 Removed PM Run 1 due to pro

outside M5 range 

ACME-6 Acme Brick Company Castle Rock CO 7/10/1998 Docket A- 99-30 506 Removed PM Runs 1 and 2 du

temps outside M5 range, remoonly one valid run left 

ACME-8 Acme Brick Company Elgin TX 3/15/2007 2008 survey 508 Removed PM Run 1 due to pro

outside M5 range 

ACME-15 Acme Brick Company McQueeney TX 10/14/2003 2008 survey Located at true area source facACME-16 Acme Brick Company Oklahoma City OK 3/15/2002 2008 survey Located at true area source facACME-17 Acme Brick Company Malvern AR 3/27/2007 2008 survey 514 Removed PM Run 1 due to pro

outside M5 range 

ACME-19 Acme Brick Company Sealy TX 4/12/2006 2008 survey 517 Removed PM Runs 1 and 2 du

temps outside M5 range, remoonly one valid run left 

ACME-19 Acme Brick Company Sealy TX 6/18/1991 Docket A- 99-30 517 Removed PM Runs 1, 2, and 3 

temps outside M5 range 

BELD-1 Belden Brick Company Sugarcreek Plant 3 OH 7/25/2011 2010 survey 527 Rejected by Ohio EPA BELD-1 Belden Brick Company Sugarcreek Plant 6 OH 5/30/2007 2008 survey 528, 529, 530 Rejected by Ohio EPA BELD-1 Belden Brick Company Sugarcreek Plant 8 OH 5/3/2001 2008 survey 532 Test conducted prior to current 

installation 

BELD-1 Belden Brick Company Sugarcreek Plant 8 OH 8/26/2003 2008 survey 531, 532, 533 Rejected by Ohio EPA BELD-1 Belden Brick Company Sugarcreek Plant 8 OH 1/20/2006 2008 survey 531, 532, 533 No HAP data; only SO2 data BELD-1 Belden Brick Company Sugarcreek Plant 9 OH 5/31/2007 2008 survey 534, 535 Rejected by Ohio EPA 
A-2 

Facility 

ID Facility City State Test Date Source Kiln ID Explanation Why D

BORA-1 Boral Bricks Inc. Smyrna GA 11/2/2004 2008 survey 537, 538 Test conducted prior to current 

installation 

BORA-1 Boral Bricks Inc. Smyrna GA 2/8/2005 2008 survey 537, 538 Test conducted prior to current 

installation 

BORA-1 Boral Bricks Inc. Smyrna GA 10/17/2006 2008 survey 537, 538 Removed PM results due to ripBORA-1 Boral Bricks Inc. Smyrna GA 3/28/2007 2008 survey 538 Removed PM Run 2 results duBORA-3 Boral Bricks Inc. Augusta Plant 6 GA 9/10/1991 Docket A- 99-30 542 Kiln demolished and/or decomBORA-3 Boral Bricks Inc. Augusta Plant 5 GA 9/14/2010 2010 Survey 543 Removed Non-Hg HAP Metal R

contamination 

BORA-5 Boral Bricks Inc. Bessemer AL 5/15/2007 2008 survey 547, 548 Removed HF and HCl results d

filter temperatures; retained PM 

BORA-5 Boral Bricks Inc. Bessemer AL 7/13- 14/2010 2010 survey 547, 548 

Removed Non-Hg HAP Metal rtest run from this test was not Mremoved PM Runs 2 and 3 due temps outside M5 range; remoonly one valid run left 

BORA-7 Boral Bricks Inc. Henderson TX 6/29- 30/1995 Docket A- 99-30 551, 552 Removed PM Run 3 due to pro

outside M5 range 

BORA-7 Boral Bricks Inc. Henderson TX 2/15/1996 Docket A- 99-30 551, 552 Removed PM Run 1 due to pro

outside M5 range 

BORA-7 Boral Bricks Inc. Henderson TX 8/1/2001 2008 survey 551, 552 No reported oxygen content, co

concentration to 17 % O2

BORA-9 Boral Bricks Inc. Lexington SC 1/23/1997 Docket A- 99-30 553 Kiln demolished and/or decomBORA-11 Boral Bricks Inc. Macon MS 4/22/1999 2008 survey 555 Kiln demolished and/or decomBORA-12 Boral Bricks Inc. Marshall TX 6/1/1986 Docket A- 99-30 557 Kiln demolished and/or decomBORA-12 Boral Bricks Inc. Marshall TX 3/12/2002 2008 survey 557 Kiln demolished and/or decom
A-3 

Facility 

ID Facility City State Test Date Source Kiln ID Explanation Why D

BORA-13 Boral Bricks Inc. Muskogee OK 12/13/2005 2008 survey 558 Test conducted prior to current 

installation 

BORA-13 Boral Bricks Inc. Muskogee OK 2/7/2006 2008 survey 558 Test conducted prior to current 

installation 

BORA-17 Boral Bricks Inc. Salisbury NC 9/8/2005 2008 survey 565 Kiln demolished and/or decomBORA-17 Boral Bricks Inc. Salisbury NC 9/21/2010 2010 survey 566 Removed Cl2 Run 1 results as BORA-17 Boral Bricks Inc. Salisbury NC 9/21/2010 2010 survey 566 Removed Non-Hg HAP Metal R

contamination 

BORA-19 Boral Bricks Inc. Union City OK 5/25/2006 2008 survey 568 Removed HF and HCl results d

filter temperatures; removed Pto probe and filter temps outsid

BORA-19 Boral Bricks Inc. Union City OK 3/14/2007 2008 survey 568 Removed HCl results due to lo

temperatures 

BORA-19 Boral Bricks Inc. Union City OK 11/17/2010 2010 survey 568 Removed Non-Hg HAP Metal R

contamination 

BORA-20 Boral Bricks Inc. Corona CA 12/2/1999 2008 survey Located at true area source facBORA-21 Boral Bricks Inc. Van Wyck SC 5/14/1997 Docket A- 99-30 569, 570 Kiln demolished and/or decomBIA-120 Bowerston Shale Co Bowerston OH 9/27/2007 BIA 571 Located at true area source facBIA-120 Bowerston Shale Co Bowerston OH 11/16/2000 BIA 571 Located at true area source facCARO-1 Carolina Ceramics Columbia SC 12/12/2000 2008 survey 573 No reported oxygen content, co

concentration to 17 % O2

BIA-093 Cherokee Brick and Tile Macon GA 5/15/2006 BIA 577, 578 Removed PM Run 1 due to pro

outside M5 range 

BIA-093 Cherokee Brick and Tile Macon GA 4/19/2007 BIA 577, 578 Removed PM Run 1 due to pro

outside M5 range 

BIA-037 

Columbus Brick Company 

Columbus MS 3/31/2006 BIA 583 No reported oxygen content, co

concentration to 17 % O2
A-4 

Facility 

ID Facility City State Test Date Source Kiln ID Explanation Why D

GENE-2 

General Shale Brick, Inc. 

Johnson City TN 7/27/1993 2008 survey 601 Kiln demolished and/or decom

GENE-4 

General Shale Brick, Inc. 

Fairsdale KY 9/21/2001 2008 

survey 

603 Removed HF results due to gla

PM results 

GENE-4 

General Shale Brick, Inc. 

Fairsdale KY 12/18/2001 2008 

survey 603 No HAP data; only SO2 data 

GENE-4 

General Shale Brick, Inc. 

Fairsdale KY 12/15/2005 2008 

survey 

604 Removed HF and HCl results d

retained PM results 

GENE-5 

General Shale Brick, Inc. 

Coosa GA 3/17/2005 2008 

survey 606 No HAP data; only SO2 data 

GENE-5 

General Shale Brick, Inc. 

Coosa GA 1/18/2011 2010 

survey 

606 Removed Non-Hg HAP Metal R

contamination 

GENE-5 

General Shale Brick, Inc. 

Coosa GA 6/24/2008 2008 

survey 605 No HAP data; only SO2 data 

GENE-5 

General Shale Brick, Inc. 

Coosa GA 1/18/2011 2010 

survey 606 Removed HF results, kiln retes

GENE-7 

General Shale Brick, Inc. 

Mooresville IN 11/2/2006 2008 

survey 

609 Kiln demolished and/or decom

GENE-7 

General Shale Brick, Inc. 

Mooresville IN 11/3/2006 2008 

survey 

610 

Removed HF and HCl results dfilter temperatures; removed Pand filter temps outside M5 ran

GENE-7 

General Shale Brick, Inc. 

Mooresville IN 2/1/2012 2010 

survey 

611 Discarded entire test report pe

(Johnson, 2013) 

GENE-8 

General Shale Brick, Inc. 

Blue Ridge (Roanoke) VA 2/23/2005 2008 survey 612, 613 Removed HF Run 1 results du

temperatures; retained other a
A-5 

Facility 

ID Facility City State Test Date Source Kiln ID Explanation Why D

GENE-11 

General Shale Brick, Inc. 

Moncure NC 2/20/2006 2008 

survey 

625 Reported oxygen content as 20

correct PM concentration to 17 

GLEN-2 Glen Gery Caledonia OH 5/1/2007 2008 survey 639, 638 No HAP data; only SO2 data GLEN-6 Glen Gery Summerville PA 4/26/2005 2008 survey 643 Removed HCl results due to qu

collection 

HANS5 Hanson Brick East, LLC Elgin TX 10/21/2007 2008 survey 653 Removed PM Run 3 due to pro

outside M5 range 

HANS5 Hanson Brick East, LLC Elgin TX 1/27/2011 2010 survey 653 Removed Non-Hg HAP Metal R

contamination 

HANS6 Hanson Brick East, LLC Corunna MI 6/7/1995 Docket A- 99-30 655 Removed fluorides results, useHANS9 Hanson Brick East, LLC Ninety-Six SC 3/7/1997 Docket A- 99-30 663 Kiln demolished and/or decomHANS9 Hanson Brick East, LLC Ninety-Six SC 7/11/1997 Docket A- 99-30 665 Kiln demolished and/or decomHANS10 Hanson Brick East, LLC Pleasant Garden NC 5/10/2006 2008 survey 666 Kiln demolished and/or decomHANS12 Hanson Brick East, LLC Stanton KY 12/1/2004 2008 survey 669 No reported oxygen content, co

concentration to 17 % O2

HANS12 Hanson Brick East, LLC Stanton KY 12/1/2004 2008 survey 670 Kiln demolished and/or decomHANS14 Hanson Brick East, LLC Columbia SC 10/5/2006 2008 survey 673, 674 No reported oxygen content, co

concentration to 17 % O2

HANS14 Hanson Brick East, LLC Columbia SC 10/11/2006 2008 survey 673, 674 No reported oxygen content, co

concentration to 17 % O2

HANS15 Hanson Brick East, LLC Mineral Wells TX 8/17/2010 2010 survey 676 Removed Non-Hg HAP Metal R

contamination 

BIA-013 Jenkins Brick Company Montgomery AL 6/5/2007 BIA 686, 687 Removed PM Runs 1, 2, and 3 

temps outside M5 range 

BIA-202 Jenkins Brick Company Brompton AL 2/21/2008 BIA 688 Removed PM Run 1 due to pro

outside M5 range 
A-6 

Facility 

ID Facility City State Test Date Source Kiln ID Explanation Why D

BIA-092 

Brick and Tile Corporation of Lawrenceville 

Lawrenceville 

AL 10/20/2006 BIA 691 No reported oxygen content, co

concentration to 17 % O2

BIA-055 Lee Brick and Tile Co. Sanford NC 3/29/2005 2008 survey 695 Removed PM Run 1 due to baBIA-055 Lee Brick and Tile Co. Sanford NC 4/25/2007 BIA 696 No reported oxygen content, co

concentration to 17 % O2

Metropolitan Ceramics Canton OH 3/30/1994 Docket A- 99-30 704, 705, 706 No reported oxygen content, co

concentration to 17 % O2

Metropolitan Ceramics Canton OH 11/17- 18/1993 Docket A- 99-30 706 No reported oxygen content, co

concentration to 17 % O2

8 (BIA-099) 

RedlandRocky Ridge Plant 

Rocky Ridge MD 8/5/1998 BIA 741 Incomplete test report, no run b

BIA-014 Redland- Cushwa Plant Williamsport MD 5/10- 11/2006 BIA 736 No reported oxygen content, co

concentration to 17 % O2

66 (BIA-015) 

RedlandHarmar Plant Cheswick PA 3/5/2002 BIA 738 Removed HF, HCl, PM results 

issue 

66 (BIA-015) 

RedlandHarmar Plant Cheswick PA 3/11/2002 BIA 738 

Removed HF and HCl results dfilter temperatures; retained PM oxygen content, could not corre17 % O2

66 (BIA-015) 

RedlandHarmar Plant Cheswick PA 4/22/2005 BIA 738 

Removed HF and HCl results dfilter temperatures; retained PM oxygen content, could not corre17 % O2

66 (BIA-015) 

RedlandHarmar Plant Cheswick PA 10/26/2006 BIA 738 Removed HF and HCl results d

filter temperatures; removed Hto "extreme feed" issue 

141 (BIA-114) 

Stark Ceramics, Inc. 

East Canton OH 9/16/1993 Docket A- 99-30 752 Kiln demolished and/or decom

149 (BIA-014) 

RedlandCushwa Plant Williamsport MD 5/10/2006 BIA 736 Removed HF and HCl results d

filter temperatures; retained PM 
A-7 

Facility 

ID Facility City State Test Date Source Kiln ID Explanation Why D

BIA-183 Vermont Brick Mfg, LP Highgate VT 10/1- 3/2002 Facility Located at true area source facBIA-206 Pine Hall Brick Co Inc. Fairmount GA 6/22/2005 BIA 725 Removed HF and HCl results d

retained PM results 

BIA-206 Pine Hall Brick Co Inc. Fairmont GA 2/3/2004 BIA 724 Removed HF and HCl results d

retained PM results 

BIA-048 Triangle Brick Company Merry Oaks NC 4/20/2006 BIA 766, 767 No reported oxygen content, co

concentration to 17 % O2

BIA-048 Triangle Brick Company Merry Oaks NC 8/10/2006 BIA 766, 767 No reported oxygen content, co

concentration to 17 % O2
Appendix B 

Final Run-by-Run Values 
B-1 

The final run-by-run values for HF, HCl, Cl2, PM, Hg, individual non-Hg metal HAP, 

and dioxin/furan runs for tunnel kilns and dioxin/furan runs for dryers are provided in the 

corresponding Appendix B Microsoft Excel® file. The file includes the parameters and emission 

data compiled from each test report and the calculations conducted on the data. 
Appendix C 

Dioxin/Furan and TEQ Sample Calculations 
C-1 

A sample calculation of run by run reported laboratory masses converted into final total 

dioxin/furan and total TEQ run-by-run values is provided in the corresponding Appendix C 

Microsoft Excel® file.