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 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 

Guaranteed. Testingt,nC. 

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. - 070504 
Compliance 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. EPA 

Method 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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Compliance Stack Emission Test Report Glen-Gerv Corporation - Marseilles Facility 

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. - 070504 
Compliance 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 

784.5" 

16.55 Equivalent 

Diameters Downstream 

from Disturbance 

I 

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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 

V47.3" x 47.4" I.D. ~ 

Elliptical Stack 

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 Oz, 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. - 070504 
Compliance 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 

(BrZ)] 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 Air Comptiance Testing, Inc. - 070504 
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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 Compliance Testing, Inc. - 070504 
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Compliance 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