From: Schimmel, Terry (Bricks

- Phenix City) [ mailto:Terry.Schimmel@boral.com ] Sent: Thursday, June 11, 2015 9:58 AM
To: Nizich, Sharon Cc: Susan Miller Subject: Gleason Brick PM Test Values

Sharon, Please find the attached very brief memo I have put together for Gleason. If you have any further questions of need more please let me know. Thanks, Terry

TERRY SCHIMMEL Consultant Boral Bricks Inc.

Office: (334) 480

- 2488 Mobile: (706) 575

- 6213 Fax: (334) 291

- 3237 4 Digit Dial (Internal Use Only) : 2488 Email: Terry.Schimmel@boral.com

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100 Brickyard Road Phenix City Alabama 36869 http://www.boralbricks.com http://www.boralbuildingproducts.com1 June 11 , 2015

Subject: Boral comments with regard to PM results of Gleason 1998 stack testing

The below comments are submitted with respect to why the PM emissions may be lower than for some
other source tests in the current EPA database as well as whether similar testing done currently on the Gleason kiln would produce similarly low numbers.

1. The Gleason kilns were built by Harrop Industries around 1960 and were of a design dating back to the earliest tunnel kilns. These kilns were supplied with a lo w velocity naturally aspirated combustion system and were operated substantially unchanged until modifications were initiated starting in May 1997 but not fully completed until late in 1999. The modifications included the installation of a forced air high velocity combustion system, flame safety on preheat burners, the addition of high velocity preheat burners, crown high velocity burners and 4 zones of automatic temperature control. Additionally crown baffles and hearth narrowing partition walls were added to increase air velocities through the brick loads rather than around
them . An exact timetable of what was done when as it relates to the 1998 stack test in question
is unknown.
2. In 2008 a major project to install a producer gas system to both generate a combustible gas as well as combust it in the kilns was undertaken. Modifications included additional burner ports and various air baffling modifications. This trial was abandoned after several year of minimal success and the onset of lower natural gas prici ng. Much of the system has hence been removed
but some modifications remain.

Given bullet point 1 and 2 above it is suspected that the PM results achieved in the 1998 tests would not be achievable if tested today as further explained in the below bullet p oints.

1. As originally configured these kiln had very low product scrubbing air velocities relying more on radiation and conduction and less on convection to supply energy to the product. This was a result of both low velocity combustion systems as well as a lower area ratio of product cross section vs. tunnel cross section. The above mentioned modifications as well as the designs of modern kilns result in much higher air velocities around and through the product as well as
across the car decks etc. These h igher air velocities can be expected to stir and entrain more material that will be caught as PM in a stack test. Kilns with high velocity under deck firing
systems which Gleason is not could be expected to entrain even more PM.
2. The production rate in the 1998 test was 5.9 TPH vs. a design rate of 9.8 TPH. Operation at around 60% of capacity would have resulted in less combustion system velocities as well as lower exhaust volumes and subsequently a lesser potential of PM generation or entrainment from the product, kilns cars or other sources internal to the kiln. Operation at this lower capacity also results in a compression of the temperature curve with less input from the higher velocity preheat burners and recirculation systems located just upstream of th e exhaust takeoff ports.

In summary there are many reason s why the Gleason PM numbers may be lower than other test results
from both controlled and uncontrolled kilns as well as why a stack test done today would likely not2 return similarly low PM numbers

. Please let me know if you have questions or need further clarification of any of the above.

Terry Schimmel

- Consultant for Boral Bricks Inc.