# C ompliance Stack Emissio 

# n Te 

# st Repo 

# rt Determination of Total Filterable Particulate Matter, Hydrogen Chloride, and Hydrogen

Fluoride Emissions Natural Gas Fired Tunnel Kiln B(P002) EPA Methods 1, 2, 3, 4, 5, and 26A Glen-Gery Corporation - Marseilles Facility

Marseilles, Itlinois llate Conducted: May 9, 2007 Job Nwnber: 070504

Prepared by: 

# Air Compliance 

# ~ Testing, Inc.

. PO Box 41156 '. Cieveland OH 44141-0156 ' Phone: (800) EPA-AIR1 (372-2471) 

### Report Date: June 7, 2007

# SuperiorQuality A ~~ 

# ' C®mp,(an(;e

Emission Testing. Valid Results Testing t ,nC. Guaranteed. P.O. Box 41156 Cleveland, Ohio 44141 1-800-EPA-AIRI www.aircomp.com

testing@aircomp.com 

### June 7. 2007 Jerry Carrier EHS Manager Glen-Gery Corporation - Marseilles Facility 423 South Pottsville Pike Shoemakersville, Pennsylvania 19555 Dear Jerry: The following report provides the results of the complianee emission testing conducted on May 9, 2007. These results are a product of the application of the U.S. EPA Stationary Source Sampling Methods listed in 40 CFR Part 60 Appendix A that were in effect at the time of this test. 

### Please mail one copy of 8iis report along witli any other supportive process operating data collected during this test to your local EPA representative. You should also attach a cover letter (on cotnpany letterhead) stating the purpose and the outcome of this test. Additionally; you inay address, preferably in a timetable format, any obligations or implications that might be necessary to aehieve environmental compliance because of the result of this test. Please do not hesitate to call if you have any questions or concerns about these test results. On behalf of Air Compliance Testing, I would also like to personally thank you for the opportunity to work with you on this testing project and would enjoy the opportunity to work with you again on any additional future testing projects. Sincerely,



# ~~ ~ 

# ~~ Pfianee Yidra Uppalapati Reporli ; To



# ~ _'e' 

# ~~

` 

### Robert J. Lisy, Jr. Quality Assurance Officer

### Compiiance Stack Emission Test Report Glen-Gerv Corporation - Marseiiles FaciliN 

# Table of Contents Page 1.0 INTRODUCTION 2 1.I Summary of Test Program 2 1.2 Key Personnel 2 2.0 SUMMARY AND DISCUSSION OF TEST RESULTS 3 2.1 Objectives and Test Matrix 3 2.2 Field Test Changes and Problems 3 2.3 Presentation of Results 4 3.0 PLANT AND SAMPLING LOCATION DESCRIPTIONS 7 3.1 Process Description and Operation 7 3.2 Control Equipment Description 7 3.3 Flue Gas Sampling Locations 8 3.4 Process Sampling Location 8 4.0 SAMPLING AND ANALYTICAL PROCEDURES 12 4.1 Test Methods 12 4.2 Procedures for Obtaining Process Data 13 5.0 1NTERNAL QA/QC ACTIVITIES 16 5.1 QA Audits 16 5.2 QA/QC Problems 16 6.0 APPENDIX 19

Test Date: May 9, 2007 Page 1 Air 

### Compliance Testing, Inc. 

### - 070504Compliance Stack Emission Test Report Glen-Gery Corporation - Marseilles Facility

1 ~~ 

# . .. ~ ~ 

# ,. . . • . .,,,, 1.1 Summary of Test Progranr Glen-Gery Corporation - Marseilles Facility, (Facility ID: 099050AAK), located in Marseilles, Illinois contracted Air Compliance Testing, Inc. of Cleveland, Ohio to conduct compliance stack emission testing for their Natural Gas Fired Tunnel Kiln B(P002). Testing was performed to satisfy Glen-Gery Corporation - Marseilles Facility's emission testing requirements pursuant to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Brick and Structural Clay Products Manufacturing (40 CFR Part 63, Subpart JJJJJ). The testing was perforined on May 9, 2007. Sampling was performed at the P002 Dry Limestone Adsorber (DLA) Inlet Duct and at the P002 DLA Exhaust Stack to determine the rnass emission rate o£TICI and HF. Sampling was also perforined at the P002 DLA Exhaust Stack to determine the mass emission rate of total filterable particulate matter (PM). Testing was conducted while P002 operated at maximum production levels. Duruig this test, emissions from P002 were controlled by the DLA. The test metliods that were conducted during this test were EPA Methods 1, 2, 3, 4, 5, and 26A. 1.2 Key Personnel 

### The key personnel who coordinated this test program (and their phone numbers) were: Jerry Carrier, EHS Manager, Glen-Gery Corporation, 610-562-3076 Andy Reiter, Technieal Manager, Glen-Gery Corporation, 815-795-6922 Mike Krzyzanowslci, Glen-Gery Corporation, 610-562-3076 Philip J. Billick, President, Air Coinpliance Testing, Inc. 800-372-2471 Sin Hoi Chiew, Project Manager, Air Compliance Testing, Inc. 800-372-2471

Test Date: May 9, 2007 Page 2 Air Compliance Testing, Inc. - 070504

### Compliance Stack Emission Test Report Glen-Gerv Corporation - Marseilles Facilitv



## 2.0 SUMMARY AND DISCUSSION OF TEST RESULTS 2.1 Objectives and Test Matrix The purpose of this test was to determine the mass emission rates of HCI and HF at the P002 DLA Inlet Duct and at the P002 DLA Exhaust Stack and also deterinine the inass emission rate of total filterable PM at the P002 DLA Exhaust Stack while P002 operated at maxiinum production levels. Testing was performed to satisfy Glen-Geiy Corporation - Marseilles Facility's emission testing requirements pursuant to the NESHAP for Brick and Stractural Clay Products Manufacturing (40 CFR Part 63, Subpart JJJJJ). The specitc test oblectives for this test were to: 

### Measure the concentrations of HCl and HF at the P002 DLA Inlet Duct and the concentrations of HCI, HF, and total filterable PM at the P002 DLA Exhaust Stack while P002 operated at maximuin production levels. Measure the dry standard and actual volumetric flow rate of the stack gas at the P002 DLA Inlet Duct and at the P002 DLA Exhaust Stack while P002 operated at maximum production levels. Utilize the above variables to detennine the mass emission rates of HCI and HF at the P002 DLA Inlet Duet and the mass emission rate of HCI, HF, and total filterable PM at the P002 DLA Exhaust Stack while P002 operated at inaximum prodaction levels. Table 2.1 presents the sampling and analytical matrix log for this test. 2.2 Fleld Test Changes and Problems No field test changes or problems occurred during the performance of this test that would bias the accuracy of the results of this test.

Test Date: May 9, 2007 Page 3 Air Compliance Testing, Inc. - 070504

### Compliance Stack Emission Test Report Glen-Genr Corporation - Marseilles Facilitv



### 2.3 Presentation of Results A single sampling train was utilized at each run at each location to deterinine the mass emission rates of HCI and HF at the P002 DLA hilet Duct and at the P002 DLA Exhaust Stack and also deterinine the mass emission rate of total filterable PM at the P002 DLA Exhaust Stack while P002 operated at maximum production levels. These sampling trains measured the stack gas volumetric flow rate, dry molecular weight, moisture content, and concentrations of HCI, HF, and total front-lialf PM. Table 2.2 displays the mass emission rates of HCI and HF measured at the P002 DLA Inlet Duct and the mass emission rates of HCI, HF, and total filterable PM measared at the P002 DLA Exhaust Stack while P002 operated at maximum production levels. As displayed 'in Table 2.2, the HCl emissions from P002 were ineasured to be higher at the DLA outlet than at the DLA inlet. (Note that this phenomenon also occurred during the November 2006 test event at P001.) As with previous instanees, Air Cornpliance Testing, Inc. perfonned a review of the sampling equipment, field data recorded during the test runs, and analytical laboratory data to verify the HCI results. EPAMethod 26A notes that there are several compounds known to cause interferences witli HCI. However, GlenGery does not have data to either confirm or deny that these compounds were present in the kiln exhaust.
, After a thorough review of the available data, it is the opinion of Air Complacence Testing, Inc. that the HCI

results displayed in Table 2.2 are reported correctly.

Test Date: May 9, 2007 Page 4 Air Compliance Testing, Inc. - 070504

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## 3.0 PLANT AND SAMPLING LOCATION DESCRIPTIONS 3.1 Process Descrfption and Operation The Glen-Gety Corporation - Marseilles Facility operates two identical natural gas-fired tunnel kilns. Each kiln is 496 ft long, has a natural gas firing rate of approximately 32 MMBtu/hr ; and was designed by Ceric, Ine. The kilns can be used interchangeably to produce brick of various sizes and colors made from clay and shale obtained froin the same source. P002 was in operation during the perforinance test. Natural Gas Fired Tunnel Kiln B(P002) was operated during the performance test at maximum capacity (i.e., equal to or greater than 90% of the kihi's designed eapacity for the selected brick product). The selected brick product for the performance test was a modular briek containing 84% shale and 16% clay. This formulation is the most commonly used brick formulation at the Marseilles Facility. No lime was added to the forinulation since previous emission tests have shown that lime additives reduce HF emissions. This brick formulation has been used in recent DLA performance tests required by IEPA and was considered to be the bricic formulation that would yield representative HF emissions On October 24, 2006 US-EPA approved a request by Glen-Gery to monitor the bypass damper position in lieu of monitoring DLA pressure drop. The request for alternative monitoring was submitted with the written test plan at least 60 days prior to the performanee test. The DLA limestone extraction settings were established and set at least one week prior to testing as required by Table 3, Condition 3(b) of the Brick MACT. Please consult the Production & Process Data section of the Appendix for a detailed description of the process data. 

## 3.2 Control Eguipment Description Kiln B is equipped with a DLA system to control MACT-regulated hazardous air pollutants (HAPs). The DLA system manufactured by Hellmicli is comprised of double limestone cascade absorbers equipped with independent limestone silos atop each DLA and extraction systems to provide crushed limestone to each cascade absorber tower. Exhaust gases from the kiln are passed through each absorber perpendicular to the crushed limestone that is slowly extracted from the base of the absorbers. This DLA utilize the same grade of limestone obtained from the same source. A block flow diagram depicting kihi and DLA arrangeinents is provided in Figure 3.1.

Test Date: May 9, 2007 Page 7 Air 

## Compliance Testing, Inc. - 070504Compliance Stack Emission Test Report 

### Glen-Gerv Corporation - Marseilles Facility



## 3.3 Flue Gas 

## Satnpling Locations 3.11 P002 DLA Inlet Duct The P002 DLA Inlet Duct was elliptical in shape with ineasured inner diameters of 51.3-inches and 52.4- inches. The stack was oriented in the horizontal plane and wae accessed from ground. Two sampling ports one with 3.6-inches and other with 3.4-inches were located 90° apart from one another at a location that met EPA Method 1, Section 11.1.1 criteria. During emissions sampling, the duct was traversed for stack gas volumetric flow rate, dry molecular weight, moisture content, and HCI and HF concentration determination. 3.3.2 P002 DLA Ex1iaust Stack The P002 DLA Exliaust Stack was elliptical in shape with measured inner diameters of 47.3-inches and 47.4- inches. The stack was oriented in the vertical plane, and was accessed from a permanent platform. Two (2) 3.7-inch I.D. sampling ports were located 90° apart from one another at a loeation that met EPA Method 1, Section 11.1.1 criteria. During emission's sampling, the stack was traversed for stack gas volumetric flow rate, dry molecular weiglit, moisture content, and total filterable PM, HCI, and HF concentration deterinination. Figures 3.2 and 3.3 schematically illustrate the traverse point and sample port locations utilized. 3.4 

### Process 

## Sampling Location The EPA Reference Test Metl7ods performed did not specifically require that process samples were to be taken during the performance of this testing event. It is in the best knowledge of Air Compliance Testing that no process samples were obtained and therefore no process sampling location was identified in this report. See Glen-Gery Corporation - Marseilles Facility personnel for any process sampling locations which may have been utilized unknowingly to Air Compliance Testing, Ine. during this tesfing event.

Test Date: May 9, 2007 Page 8 Air Compliance Testing, Inc. - 070504

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101.3" 2.14 Equivalent Diameters Upstream from Disturbance Port 1 (2) 3.7" LD. Sampling Ports 

## Located 90°Apart

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## I 

# H --J 2.4° Port 2 Distance From Distance From Point % of Duct Depth Inside Wall (in.) Inside Wall (in.) Port 1 Port 2 1 4.4 2.1 2.1 2 14.6 6.9 6.9 3 29.6 14.0 14.0 4 70.4 33.3 33.4 5 65.4 40.4 40.5 6 95.6 45.2 45.3 

# V 47.3" x 47.4" I.D. ~

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## Figure 3.3 - P002 DLA Exhaust Stack Traverse Point Location llrawing

Test Date: May 9, 2007 Page 11 Air Compliance Testing, Inc. - 070504

### Compliance Stack Emission Test Report Glen-Gerv Corporation - Marseilles Facilitv



### 4,1 Test Methods 4.1.1 EPA Method 1: Sample and Velocity Traverses for Stationary Source Principle: To aid in the representative measurement of pollutant emissions and/or total volumetric flow rate from a stationary source, a measurement site where the effluent stream is flowing in a known direction is selected, and the cross-section of the stack is divided into a number of equal areas. A traverse point is then located within each of these equal axeas. This method was utilized in its entirety as per the procedures outlined in 40 CFR Part 60, Appendix A. 4.1.2 EPA Method 2: Determination of Stack Gas Velocity and Volumetric Flow Rate (Type S) Principle: The average gas velocity in a stack is determined from the gas density and from measurement of the average velocity head with a Type S(Stausscheibe or reverse type) pitot tube. This method was utilized in its entirety as per the procedures outlined in 40 CFR Part 60, Appendix A. 4.1.3 EPA Method 3: Gas Analysis for the Determination of Dry Molecular Weight Principle: A gas sample is extracted from a stack by one of the following methods: (1) single-point, grab sampling; (2) single-point, integrated sampling; or (3) multi-point, integrated sampling. The gas sample is analyzed for percent CO 2 , 

### percent O z , and if necessary, for percent CO. For dry molecular weight determination a Fyrite analyzer will be used for the analysis. This method was utilized in its entirety as per the procedures outlined in 40 CFR Part 60, Appendix A. 4.1.4 EPA Method 4: Determination of Moisture Content in Staek Gases Princip1e: A gas sainple is extracted at a constant rate from the source; moisture is removed froin the saanple stream and determined either volumetrically or gravimetrically. This method was utilized in its enfirety as per the procedures outlined in 40 CFR Part 60, Appendix A. 4.1.5 EPA Method 5: Determination of Particulate Emissions from Stationary Sources (Front-Half PM only) Principle: Particolate matter (PM) is withdrawn isokinetieally from the souree and collected on a glass fiber filter maintained at a temperature in the range of 120 f 

### 14°C (248 T 

### 25°F) or such other temperature as specified by an applicable subpart of the standards or approved by the Administrator, U.S. Environmental Protection Agency, for a particular application. The PM mass, which includes any material that condenses at or above the filtration temperature, is determined gravimetrically after removal of uncombined water. This inethod was utilized in its entirety as per the procedures outlined in 40 CFR Part 60, Appendix A.

Test Date: May 9, 2007 

### Page 12 

### AirCompliance Testing, Inc. 

### - 070504Compliance Stack Emission Test Reoort 

### Glen-Gerv Corporation - Marseilles Facilitv



### 4.1.6 EPA Method 26A: Determination of Hydrogen Halide and Halogen Emissions from Stationary SourcesIsokinetic Metliod Prineiple: This method is applicable for determining emissions of hydrogen halides (HX) [hydrogen chloride (HCI), hydrogen bromide (HBr), and hydrogen fluoride (HF)] and halogens (X Z ) [ 

### chlorine (CI Z ) 

### and bromine (Br Z )] from stationary sources. This method colleets the emission sample isokinetically and is tllerefore particularly suited for sampling at sources, sueh as those controlled by wet scrubbers, emitting acid particulate matter (e.g., hydrogen halides dissolved in water droplets). This method was utilized for HCI and HF determination as per the procedures outlined in 40 CFR Part 60, Appendix A. The sampling trains utilized during this testing project are depicted in Figures 4.1 and 4.2. 4.2 Procedures for Obtaining Process Data

, Process data was recorded by Glen-Gery Corporation - Marseilles Facility personnel utilizing their typical

record keeping procedures. Recorded process data was provided to Air Compliance Testing, Inc. personnel at ' the conclusion of this test event. The process data is located in the Appendix.

Test Date: May 9, 2007 Page 13 

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### Compiiance Stack Emission Test Report Glen-GerV Corporation - Marseilles Facilitv



## 5.0 INTERNAL QA/QC ACTIVITIES 5.1 QA Audits Tables 5.1 and 5.2 illustrate the QA audit activities that were performed during this test. All meter boxes and sainpling trains used during sarnpling performed within the requirements of their respeetive metliods as is shown in Tables 5.1 and 5.2. All pre-test and post-test leak checks were well below the applicable limit. Minimum metered volumes and percent isokinetics were also met where applicable. 

## 5.2 QA/QC 

## Problems No QA/QC problems occurred during this test event.

Test Date: May 9, 2007 Page 16 Air 

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### aCompliance Stack Emission Test Report Glen-Gery Corporation - Marseilles Facilitv

XI • 

### • • It Appendix attached.

Test Date: May 9, 2007 Page 19 Air Compliance Testing, lnc. 

### - 070504

# APPENDIX to Compliance Stack Emission Test Report Determination of Total Filterable Particulate Matter, Hydrogen Chloride, and Hydrogen Fluoride Emissions Natural Gas Fired Tunnel Kiln B(P002) EPA Methods 1, 2, 3, 4, 5, and 26A Glen-Gery Corporation - Marseilles Facilitv

Marseilles, illinois Date Conducted: May 9, 2007 Job Number: 070504

Prepared by: 

# Air Compliance Testing, Inc.

PO Box 41156 

### ' Cleveland OH 44141-0156 

### Phone:(800) EPA-AIR1(372-2471) 

### Repott Date: June 7, 2007

## Marseilles Plant Stack Test Data 9-May-07 Stack Test *Push Pieces Throughput Product 

### Location Date Rate (Min.) Per Car Weight (Tons/Hour) Type Size Color Kiln B I5/9/2007

~ 

### ' x,; 2A ~~:: ~ ~~ 

### ;10;080
~ 

### : 3$<'=. 15.96 Extruded Ttllodular < 117sh`cl

~ 

### me 20.00 cars per day

Marseilles Process Data for May 9, 2007 Stack test.xls