Brier-... Pl•.hl- •- k.:ilh PSOI ENTEC Services Pollution Control System Evaluation

and Source Emissions

Testtng October 3, 2005
Mr. John Jensen Belden Brick Company 475 Dover Road Sugarcreek, OH 44681 Re: RATAJCompfiance

Testing

for Gaseous

Emissions Brick Plant No. 3 Tunnel

Kiln Sugarcreek, Ohio Entec Project No,: 25126
Dear Mr. Jensen, Please find the attached

three copies of the RATA/complance

emissions

testing for the Brick Plant No, 3 Tunnel Kiln performed

at your fact•y on August 24, 2005. VVe appreciate

the opportunity

to perform

this project

for you and hope to be of assistance to you in the future. If you have any questions

please cal 205/491-6676. Sincerely,Entec Services,

Inc.
Erik Groth ( Project Leader

Commerce

Avenue

Hueytown,

Alabama 35023 Phone: (205} 491,,6676

Fax (2•5) 49t-66'•4 •.entecserv|ces,com£NTEC Services Pollution Control System Evaluation

and Source Emissions

Testing October 21, 2005
Mr. John Jensen Belden Brick Company 475 Dover Road Sugarcreek, OH 44681 Re: Compliance

Testing

for Gaseous

Emissions Brick Plant No, 3 Tunnel

Kiln Sugarcreek, Ohio Entec Project No.: 25126
Dear Mr. Jensen, Please find the attached

copy of corrected

sheets.

Please insert them into your copy of the report, We appreciate

the opportunity

to perform

this project for you and hope to be of assistance to you in the future. If you have any questions

please call 2051491,6676. Sincerely,Entec Services,

Inc.
Efik Groth Project Leader

Commerce

Avenue

Hue•owr•,

Atabama 3502:• Phone: (205) 49t-6676

Fax (205) 49%6514 www.en•ecservtces,comEntec Sewic , Inc. 16 D Commerce

Avenue Hueytown; Alabama

35023 Telephone: (205) 491-6676 Fax: (205) 491•14 Results of the August

24, 2005 RATA/Compliance Testing

for Gaseous

Emissions

on the Brick Plant No. 3 Tunnel

Kiln located

in Sugaecreek, Ohio Facility Permit

No. 06-79-00-0118,

ID No. P301 Submitted to: Belden Brick

Company 475 Dover Road Sugarcreek, Ohio •681
Attention: Mr. John Jensen Entec Project No. 25126 Completed By: Er•Groth Project Leader Report Submitted:

October

3, 2005 Reviewed By:

Tom Lotz Sr. QNQC Manager
hereby certify to the best of my knowledge

all field sampling

and laboratory

ana•sis performed for this report Is authentic

and accurate.

It has been checked for completeness

and accuracy.Belden Brick

Company Table,of Conten•,,,

Executive Summary Compliance Emissions

Summary Relative Accuracy

Test Results Sulfur Dioxide Nitrogen Oxides Carbon Monoxide Hydrogen Chloride Hydrogen Fluoride RATA Emissions

Summary Detailed Test Results Sampling Procedures Location of Test Ports Diagram of Sampling

Train RATA RM with System

Drift and CEM's Field Data Volumetric Flow Field Data Quality Assurance

t Quali•

Control

Procedures QA I QC Checklist Orifice Check and Temperature

Check Fydte / Oreat Standardization Equipment Calibrations Nomenclature and Test Calculations Pa•e No.
35678910111216192O2193111115116117118131Executive Summary Entec Services,

Inc. was retained

by Belden Bdck Company

to perform

a RATA on the CEM unit and compliance

gaseous

emissions

testing on Brick Plant No. 3 Tunnel Kiln located in Sugarcreek,

Ohio. The control devices

for the kiln are a dry scrubber

and a baghouse. The Opsis CEM is composed

of two analyzers.

One analyzer

uses an infrared (IR) detector

and the other used an ultraviolet

(U• detector.

The IR detector analyzes the gas stream for NOx, CO and SO2. The UV detector

measures

HCt and HF. Both analyzers

shoot the IR/UV across the stack to let the gas combine

with the projected light source.

A detector

at the other side of the stack picks up the light source influenced by the gas stream

and transmits

via fiber optic cable the signal to be processed by a interferometer

located

with the signal processing

equipment

in the cabinet. This "spectra"

is then turned into a direct ppm measurement. Mr. Erik Groth and Mr. Tommy

Lotz, Jr. of Entec Services,

Inc conducted

the testing on August 24, 2005. Mr. John Jensen

was present

from Betden Brick and to coordinate testing with control

room activities.

Mr. Todd Brown from the State of Ohio Environmental Protection

Agency

observed

these tests. The fourth RATA run failed the spike and recovery

procedure

for the reactive

gases and was considered

invalid for the HCI and HF compounds.

Ten 30-minute

•TAs were performed. Due to the fourth RATA being incomplete,

RATAs

1-3, 5-7 were used for the compliance

tests. No other difficulties

were encountered

in the field collection

of the samples or in the laboratory

analysis

of the samples

by Entec Services,

Inc.
The gaseous

emissions

test summary

on the following

page gives a detailed

summary of each paired test run compared

to the maximum

emission

limits set forth by the State of Ohio Environmental

Protection

Agency.

Tests results

indicate

the average gaseous emissions

are below the limits set forth by the State of Ohio EPA for Facility Permit No. 06-79-00-01t8,

Facility

Source

Identification

No. P301.The RATA te• summaries

on the following

pages give a summaw

of the CEM's •tcUlated emissions,

referen•

method

•lculated

et•issions

and the cai•ulated relative ac•ura•

•or the CEils

emissions:

Tekt results

indicate

that ,the RATA results are below•e

ltmi• for so2, NOx, CO, HF & HCI assetfolloW

the Codeof Fede•| Regulations

(CFR)4OPa•

•0, AppendS:

B, and ;Perfo•anCe:

S•ciflcatlon 6 andThe RATA test summaries

on •e following

pages give a summary

of the GEM's calculated emissions,

reference

method

calculated

emissions

and •the calculated relative accuracy

for •the GEM's emissions,

Test. results

indicate

that the •-RATA resul• am •low the limi• for 802, •HF & HCi and above the limits for NO• CO as set forth by the. Code of Federal

Regulations

(CFR) 40 Part 60, Appendix

B, and Performance Specification

6 andm

"I:!Reletive Test

Ult•SOURCE OWNER: PLANT L•:X:ATION: SOURCe(S) SOURCF•S) CONDITION: 8OURCE{8) SHAPE: SOURCE PERMIT NLI•BER: TEST PERFOPJ•ED: REFERENCI• M•OD TESTS:

PROJECT MANAGER ENVIRONMENTAL Ahta•.¥ST *PROJECT

LEADER OWNER• REPRE•NTATIVE: RULJNG.AGENCY: RULING AGENCY REPRESENTATWE: DATES TESTS CON[IJCTED: ENTEC P•ECT NUMBER:

Entec

Services,

Inc. •URCE.OVERVIEW

•Plml,Tmne• • NO. 3

EPA Me•

F.PA Method

•6/15 EPA Me•od

• 6/15 EPA Method £•PA, MethodProcedures The relative

accuracy

test results and the emission

tests were determined

using EPA Methods 1-4 CFR Title 40, Part 60, Appendix

A; Method

320 CFR Title 40, Part 63, Appendix A; and CFR Title 40, Part 60, Appendix

B performance

specification

6 for flow rates, and performance

specification

15 for all gases.

The calibration

and quality
assurance procedures

of EPA CFR 40 Part 60 Appendix

A, Part 63 Appendix

A for all methods, and the "Quality Assurance

Handbook

for Air Pollution

Measurement

System" Volume II! Stationary

Source-Specific

Methods

were followed

throughout

the duration

of the field and laboratory

testing.
The most current revision

revised as of July 1, 2004, of each method

(as described

in the Federal

Register)

was used,
To satisfy the certification

requirements

for the CEMS data accuracy

assessment

of the applicable performance

specifications

in 40 CFR 60, Appendix

B, the relative accuracy test must have a minimum

of nine test runs. If more than 9 test runs are performed

a maximum of three sets of the test results may be rejected

so long as the total number of test results used to determine

the relative

accuracy

is greater than or equal to nine. However, all data must be reported

including

the rejected

data. The relative accuracy performance specification

of the CEM'S

must be no greater

than 20 percent

of the
mean value of the reference

data in units of the emission

or 10 percent

of the applicable standard,

which ever is greater. Stack Gas Volumetric

Flow The velocity

of the gas stream was determined

according

to EPA Reference

Method

1 and 2 by reading

the instantaneous

velocity

head with an inclined

manometer

at each sampling point with a calibrated

S-type pitot tube attached

adjacent

to the sample nozzle. The stack pressure

was measured

with the static side of an S-type pitot tube, A calibrated

pyrometer

was used to measure

stack temperature

at each sampling

point, The stack was tested for cyclonic

flow according

to EPA Reference

Method

1•Stack Gas Molecular

Weight The carbon dioxide and oxygen

concentrations

were determined

using EPA Reference Method 3 (Fydte Method).

A sample

of the flue gas was extracted

from the gas stream during each test. These samples

were analyzed

with a Fyrite gas analyzer.

The molecular weight of the gas was calculated

using the moisture,

oxygen

and carbon dioxide content and the measured

stack gas temperature. Moisture Content The moisture

content

used for calculating

the gas stream flow rate was determined

by measuring the amount

of condensed

moisture

in the stainless

steel condenser

and silica gel impinger

in the sampling

train as described

in EPA Reference

Method

4 at the completion of the first test. This was then compared

to the Temet DX 400 FT-IR to show the accuracy

of the measurement

of moisture

with FT-IR. Each test thereafter

the Temet DX 4000 FT-IR was used to measure

the moisture

content. Emissions Measurements Emission measurements

for NO×, SO2, CO HCI, and HF were performed

using the Temet DX 4000 FT-tR in accordance

with Performance

Specification

6 and 15. Ten 30- minute runs were performed

for the RATA. Nine of these runs satisfied

the emissions portion of the test as per Performance

Specification

6 and 15• Spike and recoveries
were performed

before and after each run to validate

the accuracy

of the analyzer

and sampling system to correctly

measure

reactive

compounds

(HCI, HF). This spike and recovery technique

was performed

as specified

in Method

320. In between

each run a known value of NO2 and NOx were sent up the sample line and measured

to insure the accuracy of the analyzer

to measure

NO× as per the request

of the OHIO EPA. A total of 10 three-minute

samples

were collected

per each 30 minute run. The sampling system turned over the cell volume

12 times per three-minute

sample.

This flow rate satisfied the measuring

time/rate

as set by performance

specification

15.Entec Services,

inc t6 D Commerce

Ave. Hueytown•

AL 35023 STACK O.AWING

& •RSE

POINT •CATION Client: Belden Brick Source: Bdck Plant Tunnel Kiln No. 3 Type of Traveme: VelOCity (V) or Particulate (P): Stack Diameter, tn•hes:

43 Stack Height, fee•

60 Star, k PropertY:

Inche• Job No." 25•26 input By: Tommy

Upstream Distudmmce:

120.0 Downstream Disturbance:

420.0

V

Port Type

Flange Port Diameter Sta•k Area. Ft•: Numbe• of Ports: Duct D|ameter•

Lmtgth of Po• 2.•0 To•l N•r •Tmv•e P•: 8.75 Num•r • P•n• •r dl•r:

4,0"
2

48.0 INCHES

120.C

•.CHES

420.( K•HES FLOW Inside Stack

Outside Nipple Po, ,n,t N¢•

inches Inche• IE 2.1 9.6 2 7,0 14,5
4 33.8 4t .3 5 41.0 •5 6 45•9 53,4
RATA 8.224.0 31,5 3•.8 47.3 AdjuM•l poin• diameter > 24" no point clout than 1.0 inch Adjusted points dtameiar <_ 24" no point clo•m" than 0,S inch Stack Dismetem between 12-24 inches minimum points am8 4 points per port if the 8 f 2 diameters downstream

and upetmam crif•da is met,FT-IR Sampling Train

He.ted •nium Heated '"'1 Teflon Coated Filter Box Heated CalibrationGae Line

Heated Teflon Line

SP-4000 HeatedPump Assembly

DataAcquisition

Communication Li•s

N•

Spike!