## 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 em ission standards for hazardous air pollutants (NESHAP) on May 16, 2003, for the brick and struct ural clay products (B SCP) 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 manu facturing 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 standard s for BSCP manufacturing, including limits for HF, HCl, chlorine (Cl 2 

## ), mercury (Hg), and non-Hg metals (or PM surrogate). The EPA provided a 90-day public comment period fo llowing proposal of the BSCP Manufacturing NESHAP, during which all affected parties we re given the opportunity to comment on the proposed rule. The EPA has considered the comm ents received and, as appropriate, incorporated them into the final rule. The purpose of this memo randum 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 assura nce/quality control (QA/QC) checks performed on the data.

II. Sources of Data

The main sources of test da ta 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 Associati on (BIA) sent to the EPA to provide test data for facilities not covere d by the section 114 surveys, and data received following the publication of the propos ed rule. Copies of all the te st 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 author ity 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 C o., General Shale Brick, Inc., Glen-Gery Corp., Hanson Building Products America, Morin Brick C o., 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 k ilns at those nine companies. Although the 2008 survey did not require any new testing to be performed, the “For m D - Test Data” worksheet in the survey asked for information on emission tests previously perf ormed on kilns at the facilities and asked each facility to submit complete copies of the repo rts for these emission tests. The test reports received contained results for HF, HCl, Cl 2 

## , 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 Ha nson Building Products America) and required testing of HF, HCl, Cl 2 

## , PM filterable, HAP metals including Hg, and dioxin/furan emissions from tunnel kilns and testing of dioxin/furan emi ssions from dryers (Tsirigotis, 2010a-c). Phase II of the survey was sent out to six companie s (Acme Brick, General Shale Brick, Inc., GlenGery Corp., Interstate Brick, Jenkins Brick and Tile Company, and Tayl or Clay Products, Inc.) and required testing of HF, HCl, Cl 2 

## , PM filterable, and HAP metals emissions from tunnel kilns (Tsirigotis, 2010d-i). Instead of performing new stack tests, Inte rstate Brick and Jenkins Brick requested permission to submit hist orical results of test s previously conducted at the facilities (Gunning, 2011; Sims, 2011), and the EPA gr anted 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 Calculatio ns 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 t ons per hour (tph)

 Flow rate, in actual cubi c 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 microgr ams per dry standard cubic meter (μg/dscm)

 Corrected reported concentra tions to 17 percent oxygen (% O 2 

## ) using the following equation: 

#    

2 2 

## O % Tested 20.9 17 9

. 20 μ g/dscm O % μ g/dscm@17

 

  

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

Note that at proposal, the reported con centrations were corrected to 7% O 2 

## . However, during the public comment period, several commente rs stated that the concentration limits for PM and Hg should not be corrected to 7 % O 2 

## because BSCP tunnel kilns operate with a higher oxygen content. The EPA evaluated the oxygen cont ent 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 % O 2 

## , with an average of 16.8 and a mode of 17 % O 2 

## when evaluating the run-by-run O 2 

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

19.5 % O 2 

## , with an average of 17.2 and a mode of 17 % O 2 

## when evaluating the run-by-run O 2 

## values rounded to whole numbers. The EPA conc luded that correcting c oncentration data to 17

% O 2 

## rather than 7 % O 2 

## , as proposed, provides more representa tive values of kilns’ operating

conditions and would not artificia lly inflate the values. Theref ore, the EPA recalculated the oxygen-corrected PM and Hg test ru ns to be corrected to 17 % O 2 

## instead of 7 % O 2



## .

In addition, the commenters noted that fo r kilns that did not report a tested oxygen content, the calculation of the oxygen-corrected PM concentration values incorrectly assumed a

0 % O 2 

## value. Thus, for the final run-by-run PM da taset, for kilns that did not report a tested oxygen content value, the EPA did not correct PM concentration to 17 % O 2 

## and did not use the data from those kilns in calculating the concentr ation MACT floors. See Appendix A for the list of kilns without an oxygen-correct ed 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 unacceptabl e 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 spr eadsheet after the QA/QC checks. See Appendix B for the run-by-run test data that were used in th e calculation of MACT

floors.

A. BIA QA/QC

The BIA provided their first round of comment s 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 samp ling and analysis approach used in the stack tests to the approach required by the reference method, as well as in sights 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 documen ted issues with the test methodology or

results.

 Tests that warranted additional review due to concerns that proper procedures were not followed, either during the testi ng 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 te mperature 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 ga s testing methodology did not affect the PM results. The data for any tests that were rejected by the local or state ag ency were also removed fr om 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 addr essed in the first round of comments, as well as to present BIA’s comments on the EPA’s conc lusions 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. Simila r 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 te mperature per the test me thod instructions (the PM data were retained). For PM tests where th e 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 va lues, 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 repr esentative 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 availabl e 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 re view 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 sin ce the industry’s section 114 survey submittals, including acquisitions, closures , and new test data. The BI A provided two acquisition updates and a table listing demolished and/or decommissione d kilns. The BIA also revisited a few test reports from the June 5, 2009 memorandum (K uo et al., 2009a) and provided updated information regarding facility status, control technology, and emission factors.

The third memorandum from BIA was review ed 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 stat us, 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 classi fication 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 th e test data, inconsistencies were found between the Hg and individual non-Hg HAP metal valu es reported in the summary page s of certain test reports and the values reported in the laborator y sections of the test reports. Therefore, the Hg and non-Hg

HAP metal values were reviewed for correctne ss, 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 re porting limit if MDLs we re not available.

 Front Half (Hg & non-Hg HAP metal), Fracti on 1: Container 1 Filter, Container 2 Acetone Probe Rinse, Container 3 Acid Probe Rinse

 Back Half (Hg & non-Hg HAP meta l), Fraction 2B: Container 4 HNO 3 

## /H 2 

## O 2 

## (Nitric Acid/ Hydrogen Peroxide) Impingers

 Back Half (Hg Only), Fract ion 3A: Container 5A HNO 3



##  Back Half (Hg Only), Fract ion 3B: Container 5B KMnO 4 

## /H 2 

## SO 4 

## (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 recalc ulated 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 in cluded 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 (M n) being contaminated from the permanganate used in Fraction 3B for Hg sampling. To check fo r Mn contamination, the ratio of the back half

Mn mass to the front half Mn mass was calculate d. 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 te st run from a particular test for a source was not contaminated, the entire test wa s removed. The following table indi cates 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 te st 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 (Wes tlin and Merrill, 2011).

For test runs with less than 1 mg collected, the 1 mg RDL va lue 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 product ton mg 453.59237 lb 1

hr 1 min 60

min dscf

dscf dscm 0.02831685

dscm

mg 1

product ton lb        

   





## 4. PM Evaluation for Probe and Filter Temperatures

The EPA examined the PM test data and f ound 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 ma intained at 248 ± 25 degrees Fahrenheit (°F) ( i.e.

, between 223 and 273 °F). Test runs with temperat ures outside that range were removed from the data set; see Appendix A.

## 7 5. Dioxins/Furans

To calculate emissions of total dioxins/fura ns, the mass values for each of the homologue group totals reported in the laborat ory analysis of the test repo rt 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 c ongener 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 Orga nization (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 contai ns a sample calculation showing how the total dioxin/furan and total TEQ values were calculat ed from the reported laboratory masses to the final run by run values pr esented 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 te st runs are comprised of individual fractions. For any te st 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, emissi on 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 a bove 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 ma sses 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 emission s 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) Fl oor Analysis for Bri ck 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 anothe r test was conducted on the same source in a similar time frame, the produc tion 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 f acility, the production rate was set equal to 83 percent of the kiln capacity. The 83 percent capacity utiliza tion was a conservative estimated developed from the available produ ction data and design capacitie s reported in the BIA survey data (Schimmel, 2008).

8. Kiln Configurations

In some cases, multiple kilns are ducted togeth er 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 valu es 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 Structur al Clay Products Manufacturing Final Rule

.

V. References

EPA (U.S. Environmental Protection Agency). 2010. Recommended Toxicity Equivalence Factors (TEFs) for Human Health Risk Assessm ents 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 fr om testing requireme nts 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 Pr oducts Manufacturing Final Rule . Memorandum from Thomas Holloway and Kristin Sroka, RTI Internati onal, 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, EP A/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 Indu stry 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 A ssociation, 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 a nd 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 Bri ck and Structural Clay Products . Memorandum from Gabrielle Raymond and Kristin Sroka, RTI Internationa l, to Sharon Nizich, EPA/OAQPS/SPPD. September 24, 2015.

Schimmel, T. 2008. “Brick Industry Associ ation MACT data colle ction.” E-mail and attachments from Terry Schimmel, Brick I ndustry Association, to Jeff Telander, U.S. Environmental Protection Agency. Oct ober 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 Br ick and Tile Co.” Letter from Brian Sims, Jenkins Brick and Tile Co., to Jeff Telander, U.S. Environm ental 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 In terstate Brick.” E-mail from Jeff Telander, U.S. Environmental Protection Agency, to Ge rald 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 Je nkins 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 collect ion request to selected brick and structural clay products facilities.” Lette r and attachments from Peter Ts irigotis, U.S. Environmental Protection Agency, to Terry Schimmel, Bo ral Bricks, Inc., transmitting section 114 information collection request asking for inform ation on brick and structural clay products processes, emissions, and controls. Identical letters sent to other addressees listed (The Belden Brick Co., Boral Bricks, Inc., Carolin a 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. Do cket Item No. EPA-HQ-OAR-2013-0291-0506.

Tsirigotis, P. 2010a. “Section 114 information co llection 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., tr ansmitting section 114 information collection request asking for information on startup a nd 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 colle ction request to Boral Bricks, Inc.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Terry Schimmel, Boral Bricks Inc., transmitting se ction 114 information collection request asking for information on startup and shutdown even ts and emission data for specified emission points. June 11, 2010. Docket It em No. EPA-HQ-OAR-2013-0291-0496.

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

America.” Letter and attachments from Pete r Tsirigotis, U.S. Environmental Protection Agency, to J. David McKeown, Hanson Buildin g Products America, transmitting section 114 information collection request asking for info rmation 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 co llection request to Acme Brick Co.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Dennis Knautz, Acme Brick Co., transmitting section 11 4 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 co llection request to General Shale Brick, Inc.” Letter and attachments from Peter Tsirigotis , U.S. Environmental Protection Agency, to Dave McNees, General Shale Brick, Inc., tr ansmitting section 114 in formation collection request asking for information on startup a nd 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 co llection request to Glen -Gery Corp.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Steve Matsick, Glen-Gery Corp., transmitting section 1 14 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 colle ction request to Inters tate 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 collec tion 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 a nd 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 colle ction 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 a nd 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 UsedA-1Table A-1. Tunnel Kiln Test Data Removed from Database after QA/QC, Not Used in MACT Floor AnalysesFacilityIDFacilityCityStateTest DateSourceKiln IDExplanation Why Data ExcludedACME-5Acme BrickCompanyDenton TX 2/8/20112010survey503Removed Non-Hg HAP Metal results due to only onetest run from this test was not Mn contaminatedACME-6Acme BrickCompanyCastle Rock CO 7/2/1998Docket A-99-30506Removed PM Run 1 due to probe and filter tempsoutside M5 rangeACME-6Acme BrickCompanyCastle Rock CO 7/10/1998Docket A-99-30506Removed PM Runs 1 and 2 due to probe and filtertemps outside M5 range, removed PM Run 3 sinceonly one valid run leftACME-8Acme BrickCompanyElgin TX 3/15/20072008survey508Removed PM Run 1 due to probe and filter tempsoutside M5 rangeACME-15Acme BrickCompanyMcQueeney TX 10/14/20032008surveyLocated at true area source facilityACME-16Acme BrickCompanyOklahomaCityOK 3/15/20022008surveyLocated at true area source facilityACME-17Acme BrickCompanyMalvern AR 3/27/20072008survey514Removed PM Run 1 due to probe and filter tempsoutside M5 rangeACME-19Acme BrickCompanySealy TX 4/12/20062008survey517Removed PM Runs 1 and 2 due to probe and filtertemps outside M5 range, removed PM Run 3 sinceonly one valid run leftACME-19Acme BrickCompanySealy TX 6/18/1991Docket A-99-30517Removed PM Runs 1, 2, and 3 due to probe and filtertemps outside M5 rangeBELD-1Belden BrickCompanySugarcreekPlant 3OH 7/25/20112010survey527 Rejected by Ohio EPABELD-1Belden BrickCompanySugarcreekPlant 6OH 5/30/20072008survey528, 529, 530 Rejected by Ohio EPABELD-1Belden BrickCompanySugarcreekPlant 8OH 5/3/20012008survey532Test conducted prior to current control deviceinstallationBELD-1Belden BrickCompanySugarcreekPlant 8OH 8/26/20032008survey531, 532, 533 Rejected by Ohio EPABELD-1Belden BrickCompanySugarcreekPlant 8OH 1/20/20062008survey531, 532, 533 No HAP data; only SO2dataBELD-1Belden BrickCompanySugarcreekPlant 9OH 5/31/20072008survey534, 535 Rejected by Ohio EPAA-2FacilityIDFacilityCityStateTest DateSourceKiln IDExplanation Why Data ExcludedBORA-1Boral BricksInc.Smyrna GA 11/2/20042008survey537, 538Test conducted prior to current control deviceinstallationBORA-1Boral BricksInc.Smyrna GA 2/8/20052008survey537, 538Test conducted prior to current control deviceinstallationBORA-1Boral BricksInc.Smyrna GA 10/17/20062008survey537, 538 Removed PM results due to ripped filterBORA-1Boral BricksInc.Smyrna GA 3/28/20072008survey538 Removed PM Run 2 results due to ripped filterBORA-3Boral BricksInc.AugustaPlant 6GA 9/10/1991Docket A-99-30542 Kiln demolished and/or decommissionedBORA-3Boral BricksInc.AugustaPlant 5GA 9/14/20102010Survey543Removed Non-Hg HAP Metal Run 2 results due to MncontaminationBORA-5Boral BricksInc.Bessemer AL 5/15/20072008survey547, 548Removed HF and HCl results due to low probe andfilter temperatures; retained PM resultsBORA-5Boral BricksInc.Bessemer AL7/13-14/20102010survey547, 548Removed Non-Hg HAP Metal results due to only onetest run from this test was not Mn contaminated;removed PM Runs 2 and 3 due to probe and filtertemps outside M5 range; removed PM Run 1 sinceonly one valid run leftBORA-7Boral BricksInc.Henderson TX6/29-30/1995Docket A-99-30551, 552Removed PM Run 3 due to probe and filter tempsoutside M5 rangeBORA-7Boral BricksInc.Henderson TX 2/15/1996Docket A-99-30551, 552Removed PM Run 1 due to probe and filter tempsoutside M5 rangeBORA-7Boral BricksInc.Henderson TX 8/1/20012008survey551, 552No reported oxygen content, could not correct PMconcentration to 17 % O2BORA-9Boral BricksInc.Lexington SC 1/23/1997Docket A-99-30553 Kiln demolished and/or decommissionedBORA-11Boral BricksInc.Macon MS 4/22/19992008survey555 Kiln demolished and/or decommissionedBORA-12Boral BricksInc.Marshall TX 6/1/1986Docket A-99-30557 Kiln demolished and/or decommissionedBORA-12Boral BricksInc.Marshall TX 3/12/20022008survey557 Kiln demolished and/or decommissionedA-3FacilityIDFacilityCityStateTest DateSourceKiln IDExplanation Why Data ExcludedBORA-13Boral BricksInc.Muskogee OK 12/13/20052008survey558Test conducted prior to current control deviceinstallationBORA-13Boral BricksInc.Muskogee OK 2/7/20062008survey558Test conducted prior to current control deviceinstallationBORA-17Boral BricksInc.Salisbury NC 9/8/20052008survey565 Kiln demolished and/or decommissionedBORA-17Boral BricksInc.Salisbury NC 9/21/20102010survey566 Removed Cl2Run 1 results as outlierBORA-17Boral BricksInc.Salisbury NC 9/21/20102010survey566Removed Non-Hg HAP Metal Run 3 results due to MncontaminationBORA-19Boral BricksInc.Union City OK 5/25/20062008survey568Removed HF and HCl results due to low probe andfilter temperatures; removed PM Runs 1, 2, and 3 dueto probe and filter temps outside M5 rangeBORA-19Boral BricksInc.Union City OK 3/14/20072008survey568Removed HCl results due to low probe and filtertemperaturesBORA-19Boral BricksInc.Union City OK 11/17/20102010survey568Removed Non-Hg HAP Metal Run 3 results due to MncontaminationBORA-20Boral BricksInc.Corona CA 12/2/19992008surveyLocated at true area source facilityBORA-21Boral BricksInc.Van Wyck SC 5/14/1997Docket A-99-30569, 570 Kiln demolished and/or decommissionedBIA-120BowerstonShale CoBowerston OH 9/27/2007 BIA 571 Located at true area source facilityBIA-120BowerstonShale CoBowerston OH 11/16/2000 BIA 571 Located at true area source facilityCARO-1CarolinaCeramicsColumbia SC 12/12/20002008survey573No reported oxygen content, could not correct PMconcentration to 17 % O2BIA-093CherokeeBrick and TileMacon GA 5/15/2006 BIA 577, 578Removed PM Run 1 due to probe and filter tempsoutside M5 rangeBIA-093CherokeeBrick and TileMacon GA 4/19/2007 BIA 577, 578Removed PM Run 1 due to probe and filter tempsoutside M5 rangeBIA-037ColumbusBrickCompanyColumbus MS 3/31/2006 BIA 583No reported oxygen content, could not correct PMconcentration to 17 % O2A-4FacilityIDFacilityCityStateTest DateSourceKiln IDExplanation Why Data ExcludedGENE-2GeneralShale Brick,Inc.JohnsonCityTN 7/27/19932008survey601 Kiln demolished and/or decommissionedGENE-4GeneralShale Brick,Inc.Fairsdale KY 9/21/20012008survey603Removed HF results due to glass fiber filter; retainedPM resultsGENE-4GeneralShale Brick,Inc.Fairsdale KY 12/18/20012008survey603 No HAP data; only SO2dataGENE-4GeneralShale Brick,Inc.Fairsdale KY 12/15/20052008survey604Removed HF and HCl results due to glass fiber filter;retained PM resultsGENE-5GeneralShale Brick,Inc.Coosa GA 3/17/20052008survey606 No HAP data; only SO2dataGENE-5GeneralShale Brick,Inc.Coosa GA 1/18/20112010survey606Removed Non-Hg HAP Metal Run 3 results due to MncontaminationGENE-5GeneralShale Brick,Inc.Coosa GA 6/24/20082008survey605 No HAP data; only SO2dataGENE-5GeneralShale Brick,Inc.Coosa GA 1/18/20112010survey606 Removed HF results, kiln retested 7/11/11GENE-7GeneralShale Brick,Inc.Mooresville IN 11/2/20062008survey609 Kiln demolished and/or decommissionedGENE-7GeneralShale Brick,Inc.Mooresville IN 11/3/20062008survey610Removed HF and HCl results due to low probe andfilter temperatures; removed PM Run 1 due to probeand filter temps outside M5 rangeGENE-7GeneralShale Brick,Inc.Mooresville IN 2/1/20122010survey611Discarded entire test report per Steffan Johnson, EPA(Johnson, 2013)GENE-8GeneralShale Brick,Inc.Blue Ridge(Roanoke)VA 2/23/20052008survey612, 613Removed HF Run 1 results due to low probe and filtertemperatures; retained other acid gas and PM resultsA-5FacilityIDFacilityCityStateTest DateSourceKiln IDExplanation Why Data ExcludedGENE-11GeneralShale Brick,Inc.Moncure NC 2/20/20062008survey625Reported oxygen content as 20.9 % O2, could notcorrect PM concentration to 17 % O2GLEN-2 Glen Gery Caledonia OH 5/1/20072008survey639, 638 No HAP data; only SO2dataGLEN-6 Glen Gery Summerville PA 4/26/20052008survey643Removed HCl results due to questionable masscollectionHANS5Hanson BrickEast, LLCElgin TX 10/21/20072008survey653Removed PM Run 3 due to probe and filter tempsoutside M5 rangeHANS5Hanson BrickEast, LLCElgin TX 1/27/20112010survey653Removed Non-Hg HAP Metal Run 1 results due to MncontaminationHANS6Hanson BrickEast, LLCCorunna MI 6/7/1995Docket A-99-30655 Removed fluorides results, used 2010 HF dataHANS9Hanson BrickEast, LLCNinety-Six SC 3/7/1997Docket A-99-30663 Kiln demolished and/or decommissionedHANS9Hanson BrickEast, LLCNinety-Six SC 7/11/1997Docket A-99-30665 Kiln demolished and/or decommissionedHANS10Hanson BrickEast, LLCPleasantGardenNC 5/10/20062008survey666 Kiln demolished and/or decommissionedHANS12Hanson BrickEast, LLCStanton KY 12/1/20042008survey669No reported oxygen content, could not correct PMconcentration to 17 % O2HANS12Hanson BrickEast, LLCStanton KY 12/1/20042008survey670 Kiln demolished and/or decommissionedHANS14Hanson BrickEast, LLCColumbia SC 10/5/20062008survey673, 674No reported oxygen content, could not correct PMconcentration to 17 % O2HANS14Hanson BrickEast, LLCColumbia SC 10/11/20062008survey673, 674No reported oxygen content, could not correct PMconcentration to 17 % O2HANS15Hanson BrickEast, LLCMineralWellsTX 8/17/20102010survey676Removed Non-Hg HAP Metal Run 5 results due to MncontaminationBIA-013Jenkins BrickCompanyMontgomery AL 6/5/2007 BIA 686, 687Removed PM Runs 1, 2, and 3 due to probe and filtertemps outside M5 rangeBIA-202Jenkins BrickCompanyBrompton AL 2/21/2008 BIA 688Removed PM Run 1 due to probe and filter tempsoutside M5 rangeA-6FacilityIDFacilityCityStateTest DateSourceKiln IDExplanation Why Data ExcludedBIA-092Brick and TileCorporationofLawrencevilleLawrencevilleAL 10/20/2006 BIA 691No reported oxygen content, could not correct PMconcentration to 17 % O2BIA-055Lee Brick andTile Co.Sanford NC 3/29/20052008survey695 Removed PM Run 1 due to bad isokineticsBIA-055Lee Brick andTile Co.Sanford NC 4/25/2007 BIA 696No reported oxygen content, could not correct PMconcentration to 17 % O2MetropolitanCeramicsCanton OH 3/30/1994Docket A-99-30704, 705, 706No reported oxygen content, could not correct PMconcentration to 17 % O2MetropolitanCeramicsCanton OH11/17-18/1993Docket A-99-30706No reported oxygen content, could not correct PMconcentration to 17 % O28(BIA-099)RedlandRocky RidgePlantRocky Ridge MD 8/5/1998 BIA 741 Incomplete test report, no run by run data availableBIA-014Redland-Cushwa PlantWilliamsport MD5/10-11/2006BIA 736No reported oxygen content, could not correct PMconcentration to 17 % O266(BIA-015)RedlandHarmar PlantCheswick PA 3/5/2002 BIA 738Removed HF, HCl, PM results due to "extreme feed"issue66(BIA-015)RedlandHarmar PlantCheswick PA 3/11/2002 BIA 738Removed HF and HCl results due to low probe andfilter temperatures; retained PM results; No reportedoxygen content, could not correct PM concentration to17 % O266(BIA-015)RedlandHarmar PlantCheswick PA 4/22/2005 BIA 738Removed HF and HCl results due to low probe andfilter temperatures; retained PM results; No reportedoxygen content, could not correct PM concentration to17 % O266(BIA-015)RedlandHarmar PlantCheswick PA 10/26/2006 BIA 738Removed HF and HCl results due to low probe andfilter temperatures; removed HF, HCl, PM results dueto "extreme feed" issue141(BIA-114)StarkCeramics,Inc.East Canton OH 9/16/1993Docket A-99-30752 Kiln demolished and/or decommissioned149(BIA-014)RedlandCushwa PlantWilliamsport MD 5/10/2006 BIA 736Removed HF and HCl results due to low probe andfilter temperatures; retained PM resultsA-7FacilityIDFacilityCityStateTest DateSourceKiln IDExplanation Why Data ExcludedBIA-183VermontBrick Mfg, LPHighgate VT10/1-3/2002Facility Located at true area source facilityBIA-206Pine HallBrick Co Inc.Fairmount GA 6/22/2005 BIA 725Removed HF and HCl results due to glass fiber filter;retained PM resultsBIA-206Pine HallBrick Co Inc.Fairmont GA 2/3/2004 BIA 724Removed HF and HCl results due to glass fiber filter;retained PM resultsBIA-048Triangle BrickCompanyMerry Oaks NC 4/20/2006 BIA 766, 767No reported oxygen content, could not correct PMconcentration to 17 % O2BIA-048Triangle BrickCompanyMerry Oaks NC 8/10/2006 BIA 766, 767No reported oxygen content, could not correct PMconcentration to 17 % O2

## Appendix B

Final Run-by-Run Values

## B-1 The final run-by-run values for HF, HCl, Cl 2 

## , PM, Hg, individual non-Hg metal HAP,

and dioxin/furan runs for tunnel kilns and dioxi n/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 Sa mple Calculations

## C-1 A sample calculation of run by run reported laboratory masse s converted into final total dioxin/furan and total TEQ run-by-run values is provided in the corresponding Appendix C

Microsoft Excel® file.