General Sha e Rome, Georgia

Compliance Emissions

Testing DES Baghouse

Stacks

K1 (Kiln A)

February 26, 2008 Entec Project

No.: 28127

16-D Commerce

Avenue

Hueytown,

Alabama

35023 Phone: (205) 491-6676

Fax (205) 491=6614 www.entecservices.comEntec Services, 16 D Commerce

Avenue Hueytown, Alabama

35023 Telephone: (205) 491-6676 Fax: (205) 491-6614 Results of the February

26, 2008 Compliance Emissions

Testing DLS Baghouse

Stacks

K1 (Kiln A) at the General Shale

Brick Company

located

in Rome, Georgia
Submitted to: General Shale

Brick

Company
P.O. Box 3547 Johnson City, Tennessee

37602 Attention: Ms. Martha

West
Entec Project

No. 28127 Completed By: Report Submitted

March 24, 2008 Reviewed By:

Project Leader Tom Lotz Technical Services

Manager

hereby certify to the best of my knowledge

all field sampling

and laboratory

analysis

performed

for this report is authentic

and accurate.

It has been checked

for completeness

and accuracy.Executive Sumrnarv
Entec Services,

Inc. was retained

by General

Shale Brick Co. to perform

compliance emissions testing

at the facility

located

in Rome,

Georgia.

Mr. Tommy

Lotz, Jr., Mr. Johnathan Cochran,

and Mr. Trent McMahan

of Entec Services,

Inc. conducted

the testing on February

27, 2008. Representing

General

Shale was Ms. IVlartha

West who coordinated testing with the control room production

activity.
Entec Services,

Inc. encountered

no difficulties

or problems

during the sampling

of this emissions source.

The emissions

test summaries

on the following

pages compared

each test run to the Georgia

Department

of Natural

Resources

(GDNR)

Permit No. 3251o115- 0105=V=02-0. The total combination

of HAPs per ton of brick processed

was 0.047 which is below the limit of 0.150.

The sulfur dioxide

emissions

were above the allowable

limit.o oDetailed Test

ResultsSOURCE

OWNER:
PLANT LOCATION: SOURCE(S) NAME(S): SOURCE(S) CONDITION: SOURCE(S) SHAPE:
SOURCE PERMIT

NUMBER:
TEST PERFORMED: REFERENCE METHOD

TESTS:

PROJECT MANAGER
ENVIRONMENTAL ANALYST

PROJECT

LEADER
ENVIRONMENTAL ANALYST

ASSISTANT
OWNER'S REPRESENTATIVE:
RULING AGENCY: Entec

Services, inc. SOURCE OVERVIEW

General Shale Brick Rome, Georgia
Kiln A Annual Compliance

Testing Circular 3251-115-0105-V-02-0
Gas with HCI and HF Sample Location Volumetric Flow Molecular Weight Moisture Content Sulfur Dioxide HCI HF EPA Method EPA Method EPA Method EPA Method EPA Method EPA Method
Mr. Tommy Lotz, Jr.
Mr. Art Otero
Mr. Trent McMahan
Mrs. Martha West Georgia Department

of Natural Resources

DATES TESTS CONDUCTED:
ENTEC PROJECT

NUMBER: 02/26/08
28127 2346C26AENTEC Services,

inc.
16-D Commerce Ave. Hue o•[g_•..• Alabama 35023 INPUT TEST DATA Client: Source: General Shale Brick Kiln A Field Data Run Number Test Date Symbol

Units

Job No.:

28127 Data Input By:

Art Otero Test Data

Time Test Run Began Ended Military Time Sampling Time e minutes Stack Area A,

Ft Barometric Pressure P•a,

in. Hg
in. H20 Stack Static Pressure Pitot Tube Correction

factor Meter Correction

Factor P•ICp

Y Meter Delta H @ /tH(•

in. H20 iNozzle Diameter o.

inches Meter Volume v,,

dcf Meter Temperature tm

°F Avg. Orifice Delta H ,•H

in. Hz0 Impingers Weight Gain (Moisture) w•mp

grams Silica Gel Impinger Weight Gain (Moisture)

w,•

grams 3xygen Concentration,

dry basis

o2

% •arbon Dioxide Concentration,

dry basis

co2

% ;ulfur Dioxide Concentration,

dry basis

so2

ppm •vg. Sq. Rt. of Delta P (sqrt AP)av. (in. H=0) ;tack Temperature t,

°F otal Hydrogen

Chloride collected,

mg otal Hydrogen

Fluoride collected,

mg

HCL
HF

mg
mg

02/26/08 0835-0939 6O 18.665

0.84 0.978 1.856 0.305

02/26/08 1034-1137 60 18.665

0.84 0.978 1.856 0.305

3 02/26/08 1201-1305 6O 18.665

0.84 0.978 1.856 0.305

AVERAGE

60

29.13 -0.27 0.84 0.978 1.856 0.305 41.333 40,327

41.709

41.123 73.5 74.0

80.2

75.9 1.53 1.51

1.67

1.57 52.7 54.2

49.1

52.0 8.9 7.9

9.1

8.6 16.5 16.5

16.5

16.5 4.5 5.0

4.0

415 110.8 119.8

t16.1

115.57 0.516 0.514

0.538

0.523 314.0 312.3

315.0

313.8 9.5 8.0

10.4

9.3 1.0 0.8

1.3

tnENTEC Services,

inc.
16-D Commerce Ave•lebama

35023 CALCULATED TEST DATA
Client: General Shale Brick Source: Kiln A Description Formulas

S•,mbol Run Number Test Date Time Began-Ended I. Stack Pressure P•, P,/13.6 2. Meter Pressure Pb• •'H 113.6 3, Standard Meter Volume 17.64" y* (VM"]'m)* tP•r &H 113.6 4a. Standard Volume of Water Vapor Condensed 4b. Standard Volume of Water Collected in Silica Gel =0,04706*W•mp =0.04715'W• 5. Moisture Fraction 9. Molecular Weight Of Stack Gas, dry basis 10, Molecular Weight Of Stack Gas, wet basis 11. Average Stack Gas Velocity 12. Stack Gas Flow @ Stack Conditions

=(v•stdl Vw•l)l(V•(=•dl

Vw•=,•I V,•=,•)) 0.32"(O=)+ 0.44"(c0=)+0.2e'(100-(o•).(c0=) M•*(1-B•)+lS.0*(B•) 85.49*Cp*(sqrt &p)=•I*SQRT((T,)

60*v=*A 13. Stack Gas Flow @ Standard Conditions 14. Stack Gas Flow @ Dry Standard Conditions 14b. Hydrogen Chlodde concentration @ Std.Cond.,GrainslCu.Ft. 14b. Hydrogen Fluoride concentration @ Std.Cond.,Grains/Cu.Ft. =(0.01543*HCL•)/Q•= =(0.01543*HFn•)/Q• 15b. Hydrogen Chlodde emissions Ibs per hour 15b. Hydrogen Fluodde emissions, Ibs per hour 16. Sulfur Dioxide (SO2) Gas Concentration =(60t7000)"HCLQ=d*Q=•d =(60/7000)*HFQ•d*Q =C•=* MW 1385.1 10' -•1. Sulfur Dioxide (SO2) Gas Concentration =Cso• !4. Isokinetic Sampling Rate, Percent 100"Vnl

'ost Meter Orifice Cal, (EMC ALT-009 Yqa) Difference. (Calibration must be within •1% of original Y-factor) Q=Q=

HCLcs
NFcs

HF -Ibs/hr

SO•lblhr Job No.:

28127 Data Input By: Art Otero Units Calculated Data 2 3 AVERAGE 02/26/08 Mllaary Tin'• in. Hg in. Hg dscf

fraction g/g-mole g/g-mole
f'ds

scfm dscfm grldscf grldscf Ibs/hr Ibs/hr

% 0835-0939 29.11 29.24 39.086 2.480 0.420 0,0691 29.380 28.594 36.73 40,020 26,554 24,720 0,004 9.000 0.79 0,08

02/26/0• 1034-1137 29.11 29.24 38.097 2.551 0.372 0.0713 29.460 28,643 35.50 39,761 26.436 24.552 0.003 0,000 0.68 0.07

02/26/08 1201-1305 29.11 29.25 38.965 2.311 0,429 0.0657 29.300 28.558 37.30 41,769 27,677 25,859 0.004

29.11 29.25 38,716 2.447 0.407 0,0687 29,380 28.598 36.178 40,517 26,889 25,043 0.004 0.001 0.000 0.91 0,80 0.11 1.84E-05 1.99E-05

1.93E-05 27.34 29,36

29.96 96.95 95.14

92.39

0,09 1.92E-05 28.89 94.83

1.0003 1.0178

1.0417

1.0199Procedures The emission

rates were determined

using EPA Methods

1, 2, 3, 4, 6C and 26A of the CFR Title 40, Part 60, Appendix

A and Part 63 Subpart

JJJJJ (Brick MACT).

The calibration and quality assurance

procedures

of EPA CFR 40 Part 60 Appendix

A for all methods, and the "Quality

Assurance

Handbook

for Air Pollution

Measurement

System" Volume III Stationary

Source-Specific

Methods

were followed

throughout

the duration

of the field and laboratory

testing.

The most current

version

for each method

(as described in the Federal

Register)

was used.
Stack Gas Volumetric

Flow Methods

1 and ? 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 previously tested for cyclonic

flow according

to EPA Reference

Method

1. Stack Gas Molecular

Weight-

Method

-• The carbon

dioxide

and oxygen

concentrations

were determined

using EPA Reference Method 3 (Fyrite 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

Method

4 The moisture

content

used for calculating

the gas stream

flow rate was determined

by measuring the amount

of condensed

moisture

in the impingers

in the sampling

train as described in EPA Reference

Method

4 at the completion

of each test. Ice is placed around the impingers

and the outlet temperature

of the impinger

is monitored

and recorded throughout the duration

of the testing to verify the temperature

is less than 680 F.Sulfur Dioxide

Method An Ametek

921 CE SO2 (Method

6C) analyzer

provided

continuous

analysis

of SO2 in the gas stream.

The basic analytical

principle

involves

quantitative

measurement

of the absorption of UV radiation

by SO2 molecules.

The analyzer

uses a single light source, which emits an appropriate

wavelength,

illuminating

the sample

cell through

which the sample is continuously

passed.

Narrow-band

optical

filters are rotated

through

the beam, and the radiation

passed

through

the optical filters and sample

cell is detected

by a single photo-detector.

The signal pulses from the photo-detector

are separated

by a multiplexor into a measuring

channel

and a reference

channel.

A log ratio amplifier computes the logarithm

of the input signal ration, producing

a signal that is proportional to the SO2 concentration.

The dual-range

analyzer

has a digital readout,

as well as 0- 10.0 V DC output terminals.

The full scale of the instrument

was set at 226.6 ppm. Hydrogen Chloride

/ Hydrogen

Fluoride

Method

26,•. Preliminary data was used to determine

stack temperature,

pressure,

and range of velocity heads,

moisture

content

and stack gas dry molecular

weight

prior to sampling. The meter box was leak checked

from the pump to the orifice.

Initial and final leak checks of the sampling

system

and pitot lines were performed

as outlined

in Method

5 and were recorded

on the data sheets.

The nozzle (glass with an angle of taper of 30 degrees and of button hook design)

was calibrated

before

and after the test using a micrometer and was recorded

on the field data sheets.
The sampling

probe was placed

at each sampling

point to provide

a total sampling

time of sixty (60) minutes.

The gases were drawn through

a glass nozzle

attached

to a heated glass lined probe.

The probe was maintained

at the proper settings

to obtain an exit temperature

of greater

than 248 o F during sampling.

The gases then proceeded through borosilicate

glass filter holder,

with a Teflon frit filter support

through

a Teflon filter to remove

particulate

matter.

The filter was maintained

at a temperature

of greater than 248 0 F. These temperatures

were recorded

at each point on the field data sheets. The gases were then scrubbed

through

a series of four pre-weighed

impingers

to capture hydrogen halides

and halogens

and moisture.

(The optional

first impinger

for a knockout for moisture

was not used.)

The first and second

impingers

contained

approximately

100 ml of a 0.1N H2SO,•

(acid) solution

and the third and fourth

impingers

contained 8approximately 100 ml of a 0.1 N NaOH (alkaline)

solution.

The fifth impinger

contained pre weighed

silica gel to remove

any remaining

moisture.

The gases pass through

the impinger series in an ice bath to maintain

a maximum

exit temperature

of 68 0 F. This temperature was also recorded

on the data sheets.

The clean and cool gases then entered the meter box where the gas flow and temperature

were measured. After the completion

of the test the sampling

train and the probe nozzle assembly

was transferred to the cleanup

area making

sure no particulate

was lost. The cleanup

data was recorded.
Each impinger

was first verified

for moisture,

then the first and second

impinger

contents were transferred

to its container,

weighed

and the rinsing from the glassware

were added to this container.

The third and fourth impinger

was transferred

to its respective container, and the rinsing from the glassware

was added to this container.

The silica gel from the fifth impinger

was transferred

to its respective

tared container

and weighed.

A blank of the sulfuric

acid solution

and sodium

hydroxide

were taken. These containers were clearly marked

and transported

to our office. The samples

were shipped

to Test America an approved

and certified

lab in Georgia. •g System The new test requirements

require

a stratification

test which was performed

and was determined that the gas stream

was unstratified.

The gas samples

were collected

from a single point that most closely

matches

the mean of the stratification

test data. Samples were extracted

from the gas stream

by a heated

stainless

steel probe maintained

at a set temperature of 250 degrees

Fahrenheit,

through

a hundred

(100) foot heated

sample

line that was heated

and maintained

at a temperature

between

225 and 250 degrees.

The gas is transported

to the test trailer then passed

through

a chilled sample

conditioner

to remove the moisture

in the gas stream

and then to the analyzers.
Data Acquisition Concentration

values

were collected

using a Baldwin

Environmental

RM Plus Parametrics data acquisition

system.

The data was recorded

every fifteen-seconds

and then averaged

for each sixty-second

interval.

Each minute

average

was then averagedfor the duration

of each test run. During all testing,

the unit was operating

within normal operating parameters,

at a range appropriate

in accordance

with applicable

permits.

10Entec Services,

Inc 16 D Commerce

Ave. Hueytown,

AL 35023 STACK DRAWING

& TRAVERSE

POINT LOCATION Client: General Shale Brick Job No. 28127 Source: Kiln A Input By: Art Otero Type of Traverse: Velocity (V) or Particulate

(P):

_p

Port Type

Nipple

Port Diameter

4.0" Stack Diameter, inches:

58.5 Stack Area, Ft2: 18.665 Stack Height, feet:

100 Number of Ports: 2 Stack Properties:

Inches

Duct Diameters

Length of Port, inches: 4.00 226.0 3.86

Total Number of Traverse Points:

20 300.0 5.13

Number of Points per diameter: 10 Upstream Disturbance: Downstream Disturbance: 58.5

•NCHES

NCHES Inside Stack

Outside Nipple Point No.

Inches Inches 1.5 5.5 2 4.8 8.8 3 8.5 12.5 4 13.2 17.2 5 20,0 24.0 6 38.5 42.5 7 45.3 49.3 8 50.0 54.0 9 53.7 57.7 10 57.0 61.0

Adjusted points diameter > 24" no point closer than 1.0 inch Adjusted points diameter < 24" no point closer than 0.5 inch Stack Diameters between 12-24 inches minimum points are 8 4 points per port if the 8 2 diameters downstream

and upstream criteria is met. ,.( INCHES

11Train EPA Methods

6C

Three Way Valve Calibration

Gas Line

Heated Teflon Line

Flow Control Panel

iication Lines

Acquisition System

OO0 Air Sampling Analyzers

Calibration Gases

12Method 26A

Sampling Train

Filter Z• %mperature

and

•[•

Temperature S•nSo•s np!ngi

npmg•

npmg• •3 #4 (}.IN D.1N bso •aO•-

•aO•

Impinger Exit Temperature (<680 F)

npmg, #5 •250 lica G

Temperature__]

13K1 (Kiln

A) Field Data

SheetsKI (Kiln

A) Run No.

1ENTEC Services,

inc. 16-D Commerce Ave. Hueytown, Alabama 35023
Client: General Shale Brick Test Date:

2/26/2008 Source: Kiln A Run Number:

1

PARTICULATE W/HYDROGEN

CHLORIDE

HYDROGEN

FLOURIDE

FIELD DATA, EPA METHOD

5/26A

Traverse Point 1-11-21-31-41-51-6

Delta P 0.23 0.31 0.28

Sq. Rt. Delta P

Delta H 0.4796 1.29 0.5568 1.75 0.5292 1.58 0,30 0.5477

1.69 0,24 0.4899

1.35 0.18 0.4243

1.01 1-7 0.21

0.4583

1.18 1-8 0.21

0.4583

1.18 1-9 O, 19

0.4359

1.07 1-10 0.14

0.3742

0.79 2-1 0,44 2-2 2-3 2-4 2-5 2-6 2-7 2-8 2-9 2-10 0.45 0.41 0,36 0.30 0,28 0,26 0.24 0.22 0.20

0.27 Stack Temp. (°F) Meter Temp. (°F 314 67 312 68 311 71 312 72 310 73 309 73 308 73

K-Factor 5.63 310

72 310 72 300 72 0.6633 2.48

320 0.6708 2,53

320 0.6403 2.31 0.6000 2.03 0.5477 1.69 0.5292 1.58 0.5099 1.46 0.4899 1.35 0.4690 1.24 0.4472 1.13

0.5161 1.53 7375 322 78 318 78 321 75 317 75 317 75 319 76 315 76 315 76

314.0 73.5General Shale

Brick Rome, GA Facility Kiln A

Run Number

Dat___•e

Tim____•e

SO•2

Run Number

Date

Time 2/26/2008 8:34:45 2/26/2008 8:35:45 212612008 8:36:45 2/26/2008 8:37:45 2/26/2008 8:38:45 2/26/2008 8:39:45 2/26/2008 8:40:45 2/26/2008 8:41:45 2/26/2008 8:42:45 2/26/2008 8:43:45 212612008 8:44:45 2/26/2008 8:45:45 2/26/2008 8:46:45 2/26/2008 8:47:45 2/26/2008 8:48:45 2/26/2008 8:49:45 2/26/2008 8:50:45 2/26/2008 8:51:45 2/26/2008 8:52:45 2/26/2008 8:53:45 2/26/2008 8:54:45 1 2/26/2008

8:55:45 2/26/2008 8:56:45 2/26/2008 8:57:45

SO2 56.0 104.3 105.3 102.8 109.0 115.1 117.9 100.4 110.8 110.8 112.5 117.9 122.7 107.9 116.9 105.9 70.4 129.9 114.0 104.7 114.9 113.3 120.1 123.2

182/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/2612008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 8:58:45 8:59:45 9:00:45 9:01:45 9:02:45 9:03:45 9:04:45 9:05:45 9:06:45 9:07:45 9:08:45 9:09:45 9:10:45 9:11:45 9:12:45 9:13:45 9:14:45 9:15:45 9:16:45 9:17:45 9:18:45 9:19:45 9:20:45 9:21:45 9:22:45 9:23:45 9:24:45 9:25:45 9:26:45 9:27:45 9:28:45 9:29:45 9:30:45 9:31:45 9:32:45 9:33:45 Average

120.0 111.0 116.9 124.2 138.6 136.6 123.8 112.2 72.6 126.2 111.0 101.4 110.7 112.8 117.4 111.5 99.2 110.9 113.4 120.2 126.8 112.6 121.4 109.9 70.3 119.2 92.6 101.9 111.0 115.2 115.4 106.2 109.3 120.8 121.5 126.2 111.3

19Average Emissions

Test Performed

For: General Shale Brick Rome, GA Facility Kiln A Compliance Testing Date:2/26/08 Test Performed

By: Entec Services,

Inc. Birmingham Division Test Trailer 904 Tommy Lotz, Jr. Run 1 Calibration Gas Value 0.0 ppm SO2 125.1 ppm SO 2

Initial Calibration 4.0 ppm 125.3 ppm

Final Calibration

Average 3.8 ppm

3.90 125.2 ppm

125.25 Mean Reference

Values: 111.3 ppm SO2 Corrected

Results: 110.8 ppm SO•

Basis: DRY

2OENTEC SERVICES,

•NC. SAMPLE RECOVERY

DATA SHEET Client / Location:

_General

Shale Brick Sampling

Date(s):_2-26=2008 Run No,: impingers Final Wt. Initial Wt. Net Weight

1

Recovery

Date: 1 2

3 715.7 725.3

732,3 694.8 702.0

723.8 20.9 23.3

8.5 Moisture imp.:

52.7

Grams Description of Impinger

Contents:

clear Description of Particulate

on Filter:

NIA Silica Gel Color: mixed Filter I.D. Number: N/A Probe Rinse Container

No.:

N/A Impinger Contents

Container

No.:

R-I Run No.:

2

Recovery

Date: Impingers 1

2

3 Final Wt.

731.9

695.5

739.2 Initial Wt.

702.1

678.0

732.3 Net Weight

29.8

17.5

6.9 Moisture Imp.:

54.2

Grams Description of Impinger

Contents:

clear Description of Particulate

on Filter:

NIA Silica Gel Color: mixed Filter I.D. Number: NIA Probe Rinse Container

No.:

N/A Impinger Contents

Container

No.:

R-2 Run No.:

3

Recovery

Date: Impingers 1

2

3 Final Wt.

722.4

707.6

710.5 Initial Wt.

693.t

692.6

705.7 Net Weight

29.3

15

4.8 Moisture Imp.:

49.1

Grams Description of Impinger

Contents:

clear Description of Particulate

on Filter:

N/A Silica Gel Color: mixed Filter I.D. Number: NIA Probe Rinse Container

No.:

N/A Impinger Contents

Container

No.:

R-3 BLANKS: Probe Rinse: 2/26/2008 Recovered

By:

AO 4 5

6

Si|ical Gel 714.5 •• 870.0 7tl.8 •

•

861.1
Moisture Gel,:

8.9 Grams Sealed: Y N Percent Spent:

15 % Filter Container

No,: N/A Liquid Level Marked/Sealed:

Y N Liquid Level Marked ISealed:

Y N 2/26/2008 4 719.1 714.5 4.6 Recovered

By: 5 6

AO Silical Gel 877.9 870.0
Moisture Gel.:

7.9 Grams Sealed: Y N Percent Spent:

20 % Filter Container

No.: NIA Liquid Level Marked/Sealed:

Y N Liquid Level Marked/Sealed:

Y N Recovered By:

AO 4 5

6

Silical Gel • 811.4
Moisture Gel.:

9.1

Grams 212612008
710.3 710.1

Sealed:

Y N Percent Spent:

10 % Filter Container

No.: N/A Liquid Level Marked ISealed:

Y N Liquid Level Marked ISealed:

Y N Impinger: X

Filter: Project No.:

28127 21K1 (Kiln

A) Run No.

2ENTEC Services,

inc.
16-D Commerce Ave. Hueytown, Alabama 35023
Client: General Shale Brick Test Date:

2/26/2008 Source: Kiln A Run Number:

2

PARTICULATE W/HYDROGEN

CHLORIDE

HYDROGEN

FLOURIDE

FIELD DATA, EPA METHOD

5/26A

Traverse Point 1-11-21-31-41-51-61-71-81-9 1-10 2-12-2 Delta H Delta P 0.28 0.26 0.20 0.29 0.32 0,25 0.21 0,15 0.13 0,19 0.37 0.32 2-3 0.34 2-4 0.40 2-5 2-6 2-72-82-9 2-10

K-Factor 5.63 0.37 0.30 0.24 0.21 0.30 0.25

0.27

Sq. Rt. Delta P 0.5292

1.58 0.5099 1.46 0.4472 1.13 0.5385 1.63 0.5657 1.80 0,5000 1.41 0.4583 1.18 0.3873 0.84 0.3606 0.73 0.4359 1.07 0.6083 2.08 0.5657 1.80 0.5831 1.91 0.6325 2.25 0.6083 2.08 0.5477 1.69 0.4899 1.35 0.4583 1.18 0.5477 1.69 0.5000 1,41

Stack Temp. (°F) Meter Temp. (°F 316 70 319 70 316 7O 317 71 317 71 318 72 313 72 310 72 307 73 301 73 314 74 315 74 315 75 313 76 311 77 307 77 310 78 309 78 313 78 305 79

312.3 74.0
23..(222222222222222222222222222222222222 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/2612008 2/2612008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008

10:33:45 10:34:45 10:35:45 10:36:45 10:37:45 10:38:45 10:39:45 10:40:45 10:41:45 10:42:45 10:43:45 10:44:45 10:45:45 10:46:45 10:47:45 10:48:45 10:49:45 10:50:45 i0:51:45 10:52:45 10:53:45 10:54:45 10:55:45 10:56:45 10:57:45 10:58:45 10:59:45 11:00:45 11:01:45 11:02:45 11:03:45 11:04:45 11:05:45 11:06:45 11:07:45 11:08:45

111.3 119.1 113.0 105.6 115.6 137.2 143.8 134.9 108.8 66.8 130.0 t22.5 117.8 117.3 125.9 130.5 132.6 125.7 113.7 122.9 136.2 149.2 146.1 131.3 119.5 77.7 137.1 115.6 113.1 124.2 135.8 141.8 135.2 124.8 135.1 140.1

25222222222222222222222222 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 212612008 2/26/2008 2/26/2008 212612008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008

11:09:45 11:10:45 11:11:45 11:12:45 11:13:45 11:14:45 11:15:45 11:16:45 11:17:45 11:18:45 11:19:45 11:20:45 11:21:45 11:22:45 11:23:45 11:24:45 11:25:45 11:26:45 11:27:45 11:28:45 11:29:45 11:30:45 11:31:45 11:32:45 Average

145.6 142.3 140.5 142.6 129.8 78.7 107.1 8O.7 82.5 85.7 85.1 76.7 81.2 109.1 123.0 124.5 124.5 126.0 135.9 146.6 125.2 68.8 126.1 121.9 119.5

26Average Emissions

Test Performed

For: General Shale Brick Rome, GA Facility Kiln A Compliance Testing Date:2/26/08 Test Performed

By: Entec Services,

Inc. Birmingham Division Test Trailer 904 Tommy Lotz, Jr. Run 2 Calibration Gas Value 0.0 ppm SO2 125.1 ppm SO2 Initial Calibration 3.8 ppm 125.2 ppm

Final Calibration 3.7 ppm 124.0 ppm

Average 3.75 124.59 i•lean Reference

Values: 119.5 ppm SO2 Corrected

Results: t19.8 ppm SO 2

Basis: DRY

27KI (Kiln

A) Run No.3

28LT__•ZENTEC Services,

inc.
16-D Commerce Ave. Hueytown, Alabama 35023

Client: General Shale Brick Test Date:

2/26/2008 Source: Kiln A Run Number:

3

PARTICULATE W/HYDROGEN

CHLORIDE

HYDROGEN

FLOURIDE

FIELD DATA, EPA METHOD 5/26A

Traverse Point

Delta P 1-1 0.21 1-2 0.29 1-31-41-51-6 1-71-81-9

Sq. Rt. Delta P 0.4583 0.5385 0.31 0.5568 0.31 0.5568 0.33 0,22 0.25 0.18 0.13 1-10 0.16 2-1 0,47 2-2 2-3 2-4

0.5745 0.4690 0.5000 0.4243 0.3606 0.4000 0.6856 0.43 0.6557 0.43 0.6557 0.40 2-5 0,34 2-6 0.33 2-7 2-8 2-9

0.6325 0.5831

2-10 0.5745 0.28 0.5292 0.31 0.5568 0.31 0.5568 0.24

K-Factor 5.63 0.30

0.4899

Delta H 1.18 1.63 1.75 1.75 1.86 1.24 1.41 1,01 0.73 0.90 2.65

Stack Temp. (°F) 321318

77 318 77 315 319 313 316 Meter Temp. (°F) 77

77787979 312 79 314 8O 314 80 316 8O 2.42 312

81 2.42 310

81 2.25 1,91 320

82 317 82 317 312 313 314 83838383 1.86 1.58 1.75 1.75 1.35

0.5379 1.67

308

83

315.0 80.2

3O333333333333333333333333333333333333 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008

11:33:45 12:01:30 12:02:30 12:03:30 12:04:30 12:05:30 12:06:30 12:07:30 12:08:30 12:09:30 12:10:30 12:11:30 12:12:30 12:13:30 12:14:30 12:15:30 12:16:30 12:17:30 12:18:30 12:19:30 12:20:30 12:21:30 12:22:30 12:23:30 12:24:30 12:25:30 12:26:30 12:27:30 12:28:30 12:29:30 12:30:30 12:31:30 12:32:30 12:33:30 12:34:30 12:35:30

141.4 125.6 69.1 121.9 127.7 125.3 115.4 121.8 126.4 130.0 129.7 118.9 123.3 131.7 147.7 148.2 134.3 132.5 72.3 127.2 121.7 108.4 119.1 126.6 128.5 127.3 115.3 122.8 127.0 130.9 138.4 128.1 136.7 134.3 72.5 100.8

31333333333333333333333333 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008 2/26/2008

12:36:30 12:37:30 12:38:30 12:39:30 12:40:30 12:41:30 12:42:30 12:43:30 12:44:30 12:45:30 12:46:30 12:47:30 12:48:30 12:49:30 12:50:30 12:51:30 12:52:30 12:53:30 12:54:30 12:55:30 12:56:30 12:57:30 12:58:30 12:59:30 Average

77.3 75.3 77.5 78.7 93.7 92.3 105.0 115.1 119.5 123.0 115.8 124.7 137.4 133.7 71.5 95.1 72.7 77.1 106.9 116.4 118.3 112.1 125.0 129.7 115.0

32Calculation of Average

Emissions

Test Performed

For: General Shale Brick Rome, GA Facility Kiln A Compliance Testing Date:2126Calibration Gas Value 0.0 ppm SO 2 125.1 ppm SO2 Mean Reference

Values: 115.0 ppm SO2 Test Performed

By: Entec Services,

Inc. Birmingham Division Test Trailer 904 Tommy Lotz, Jr. Run 3 Initial Calibration 3.7 ppm 124.0 ppm

Final Calibration

Average 3.5 ppm

3.60 123.4 ppm

123.69 Corrected Results: 116.1 ppm SO 2

Basis: DRY

33Control Room

Production Data

34Production Data The following

information

was received

by email from rvls. Martha

West of General

Shale Brick Company

for the testing

performed

at their facility in Rome, Georgia,

on February 26, 2008.

K1 (Kiln A) 02-26=2008 Brick Production

18.9 tonslhr Lime Feed Rate

74.3 Ibs/hr Pressure Drop Coal Usage Gas Usage

4.4 in ches 262.25 Ibs/hr 4,583 scf/hr

35Quality Assurance / Quality

Control Procedures

36QA / QC Procedures Specific quality assurance

/ quality control procedures

were adhered

to during this test project to provide

valid and scientifically

defensible

data. For any environmental

field and laboratory

measurement,

a degree

of uncertainty

exists in the data due to inherent limitations of the measurement

systems

employed.

The objective

of a QA/QC

program is to produce

data of known

precision,

accuracy,

representation,

completeness

and comparability. The objective

in this test project

was to determine

compliance

with applicable air permit

requirements.

The final data user in this project

will be the Georgia Department

of Natural

Resources.
The following

section

details

all QC procedures

followed

during the manual

sampling activities. Velocity / Volumetric

Flow Rate Methods

I and 2 Volumetric flow rates were determined

during each isokinetic

test run. The following QC steps were adhered

to during these tests: Reported duct dimensions

were checked

by physical

measurements

to determine cross-sectional duct area. Pitot tube coefficients

were determined

based on physical

measurement

techniques
as delineated

in Method

2 The Type-S

pitot tube was visually

inspected

before and after sampling. The pitot tube was installed

on the sampling

probe with the proper orientation

and spacing from the sampling

nozzle. Before each series of tests, thermocouple

readings

for the silica gel impinger

exit temperature were checked

against

an N.I.S.T.

traceable

thermometer. The oil manometer

was leveled

and zeroed before each test run. Both legs of the pitot tube were leak-checked

before and after sampling. Proper orientation

of the pitot tube was maintained

while making

measurements. The roll and pitch axis of the pitot tube was maintained

at 900 to the flow. An average

velocity

pressure

reading

was recorded

at each point instead

of recording extreme

high or low values. The pitot/manometer

umbilical

lines were inspected

before and after sampling

for moisture condensate.

Lines were cleared

if moisture

was found. 3?Molecular Weight

Determination

Method

3 The carbon

dioxide

and oxygen

concentrations

were determined

using EPA Reference Method 3. A sample

of the flue gas was extracted

from the gas stream during each test. The samples

were analyzed

with a Fyrite gas analyzer.

The following

QC steps were adhered to during these tests: The sampling

train was leak checked

before and after each samples

was taken. The samples

were run in triplicate

for accuracy. Standardization was performed

to audit the reagents

and the operators

technique. A known mixture

of CO2 and 02 was analyzed

and repeated

with 3 consecutive values ÷/- 0.5 percent

of the known value. Two NIST traceable

gas cylinders

were run against

the instrument

to audit the accuracy of the analyzer

and the analyzer

operator

technique.

One cylinder contained 2 to 4 percent

02 and 14 to 18 percent

CO2. The second

cylinder contained 2 to 4 percent

CO2 and about 15 percent

02. Moisture Determination

Method

4 Stack gas moisture

content

(Bws) was determined

by dividing

the mass of moisture collected by the impingers

or stainless

steel condenser

and silica gel impinger

by the standardized volume

of gas sampled.

The following

QC steps were adhered

to during these tests: The indicating

silica gel was fresh for the first run and periodically

inspected

and replaced during runs, if needed. The analytical

balance

was placed in a clean, motionless

environment

for weighing. The balance

was leveled

and zeroed

if necessary

before each weighing. Preliminary silica gel impinger

tare weights

and post-run

weights

were weighed

to the nearest

0.1 g. Before each series of tests, thermocouple

readings

for the silica gel impinger

exit temperature were checked

against

an N.I.S.T.

traceable

thermometer. The silica gel impinger

gas temperature

was maintained

below 68°F and recorded at every traverse

point. Each impinger

was wiped of surface

moisture

before post-run

weighing. The volume

of liquid captured

was measured

using a graduated

cylinder

with 1- milliliter increments.

38Sulfur Dioxide

Determination

Method

6C The sulfur dioxide

concentrations

were determined

using EPA Reference

Method

6C. A sample of the flue gas was extracted

from the gas stream

during each test. Moisture was removed

form the sample

and was analyzed

on a dry basis with an Instrumental gas analyzer.

The following

QC steps were adhered

to during these tests: Only analyzers

that have a resolution

or sensitivity

of at least < 2.0% of full-scale range are used. Upon the SO2 analyzers

initial use in the field, an interference

check was conducted. The reference

calibration

gases used in this test program

are certified

following EPA Protocol

Number

1 analysis.

Copies

of the calibration

gas certifications

are included in the instrument

calibration

section. The high level gas was equal to the calibration

span gas. The mid level gas was between

40 and 60 % of the calibration

span gas. The low level gas was < 20% of the calibration

span gas. In accordance

with EPA Method

6C a three-point

(i.e., zero, mid-, and high-range) analyzer calibration

error was conducted

on each reference

analyzer

prior to initiating the compliance

testing.

These

checks

were conducted

(after final calibration adjustments

were made) by injecting

the calibration

gases directly

into each gas analyzer

and recorded

the responses. The analyzer

calibration

error was less than _+ 2.0% or _+ 0.5 ppm of the calibration span gas for the zero, mid-range,

and high-range

calibration

gases. The probe material

was stainless

steel. The probe, filter and sample

line temperature

was maintained

above the dew point by heating,

prior to sample

conditioning. The sampling

system

bias was less than +_ 5.0 % or of the calibration

span gas for the zero and upscale

calibration

gases (_+ 0.5 ppm absolute

difference). The system

response

time was calculated

during the initial sampling

system

bias. The drift for either the low-level

and mid-level

or high-level

gases was less than _+ 3.0% or of the calibration

span gas (_+ 0.5 ppm absolute

difference). The sampling

system

was purged

> 2 times the system

response

time before each test run. Sample flow rate was maintained

within 10% during the entire test period. Data is recorded

at 1-minute

intervals.

39All data collected

was within the calibration

span gas.

procedures that were followed sampling system

were: HCI/HF Sampling

I•lethod

26A Accurate particulate

concentrations

are dependent

on the HCI/HF

concentrations

from the stack gas by the use of a series of specialized

reagents

in the impingers

and recovered after sampling,

and the standardized

gas sample

volume

measured.

QC
so that representative

data was collected

by the Only clean, well-maintained

sampling

equipment

was used. Sampling ports were inspected

and cleaned

prior to sampling. All equipment

was calibrated

according

to EPA standards.

The dry gas meter was fully calibrated

within the past 12 months

using a set of calibrated

orifices. The sampling

train components

exposed

to sample

gas were constructed

of glass
or Teflon. Accurate barometric

pressure

was recorded

at least once per day. The dry gas meter thermocouples

were compared

to ambient

temperature

prior to the test run as a check on operation. Pretest and post-test

leak-checks

were completed

(must be less than 0.02 cfm or 4% of the average

sampling

rate). Before each series of tests, thermocouple

readings

for meter temperature,

filter hotbox, probe,

and filter exit temperatures

were checked

against

an N.I.S.T. traceable thermometer. Readings of the dry gas meter,

meter orifice pressure

(AH), meter temperatures, filter hotbox

temperatures,

probe temperatures,

and filter exit temperatures

were taken at every traverse

point. Probe and filter temperatures

were monitored

and maintained

at greater

than 248 0 F. The filter exit temperature

was maintained

at greater

than 248 0 F. The gas meter was read to the thousandth

of a cubic foot for the initial and final readings. The sampling

velocity

through

the nozzle was maintained

within 10% of the stack gas velocity

(isokinetic

sampling

rate at 100+10%). All nozzle/probe

recovery

items were pre-cleaned

and kept in containers

when not being used. The 0.1 N H2SO4 capture

liquid in the first two impingers

was recovered

and placed 40into a container

for analysis

of HCI/HF. The 0.1 N NaOH capture

liquid in the last two impingers

was recovered

and placed into a container

for analysis

of CI/F (if needed). Each impinger

and connecting

glassware

was rinsed with distilled

water three times and added to the respective

container. The H2SO4 solution

was collected

for laboratory

analysis. Liquid levels were marked

on sample

containers

and sealed

for shipment

to the laboratory. Prior to the initial run a y-factor

check was performed

to ensure

that the meter was operating according

to the original

calibration

to within 3% of the original

y-factor. For the post-test

calibration

the alternative

Method

5 post-test

calibration procedures were used (Emission

Measurement

Center

Approved

Alternative Method ALT-009).ENTEC SERVICES, FIELD QA / QC CHECKLIST

PERMIT NUMBER:

O• TEST METHODS

USED: CONTROL AGENCY:

• •

ON SITE REPRESENTATIVE: PERMIT LIMITS:

• MODIFICATIONS TO METHOD:

YE_.=..=•S 1. Was Calibration

Data on site? (Methods

1-5 / CEMS CAL Gas) 2. Was Stack Diameter

I Area & Traverse

Points verified on field data sheets? 3. Was a 10-minute

Meter Orifice Check performed? Results of check 4. Were Temperatures

Verified wl NIST Traceable

Thermometer? 5. Was Preliminary

Traverse

wl Cyclonic

Flow verification

performed? 6. Was previous

test data on source used to determine

K factor? Was Probe & Hot Box Temperatures

maintained

at 248 ÷/•3 ° F? If not, explain 8. Was Filter Outlet Temperature

maintained

at 248 +/- 25 ° F?

_• If not, explain 9. Was Orsat or Fyrite leak checked and standardization

performed

as required? Ambient 02 Reading

•.,O,•

% Ambient

CO2 Readingj

% 10. Was Tedlar Gas Sampling

Bags used? If not, explain _• r'•z Were they leak-checked?

Y or N 11. Were Pitot Leak Checks performed

& recorded

on each field data sheet? Pitot inspected?

•or N Noted Visual Defects?

/•1•.¢.. 12. Was Meter Leak Checks performed

& recorded

on each field date sheet? 13. Was Nozzle Diameter

measured

& recorded

on each field data sheet? Nozzle inspected?

(£•or N Noted Visual Defects?.

/IJt>•.e_ 14. Was Silica Gel Verified,

and recorded

for each test run? Percentage Used during test- Run No.'s//l•

=•= 2: •3•> 3: • 15. Was Acetone

Lot Number

v•rded

on Field Data Sheet mature (Test Team Leader):__.•//•'//•_//L// Date: by: c,/•--•.

• As required:

Control room data supplied wa on-site, email, or fax. Revision 2 December

2005 DLB 4 2ENTEC SERVICES, iNC. METER ORiFiCE

AND

TEMPERATURE CHECKS

Meter Box Numbe•. Origina| AH@ -, /. •'•'• Lee=ion: Barometric

Pressure:

•

"Hg Original Y: Bi-Annual Calibration

Date:

Total Volume: Temperature,

Vm = Volume

of Dry Gas Meter Average:

Final
•7

Dry Gas •ete•' Ouffet

Initial

Average: "•'m = Average

Temperature

of Dry Gas Meter in degrees

Rankin

(+460) PBarm Barometric

Pressure Yc = 10NmX

•/{ 0.0319

X Tm/Paarm}

= 101( 7.&o•

)xV•0.0319x( /'a&

)/(•.37

)}

•s Y¢ < +/- 3% of Original

Y ? •6•

¢ The•ocouple Check

(all tem••s

am in o F) NIST Traceable Thermocouple• I I.D.

Probe I

Freer Exit Ambient

Temp.

Meter Outlet / •"- Impinger Ex• /
Field Checks Reference

Temp.

Acceptance

Range

+1- 7.5 o +/- 5.4 o +1-5.4 ° +1-2..0 o +/- 5.4 o +1-2.0 o +1o 5.4 o

Revision September

2005 DLB • 3,,•.:..--• Calibration ,•,.,•,,,b• •

ISO/tEC

t7025 ANO

•,•.- Ce•. No.: 4371.'1511•40

Instrument Identification: Model: 14-648-44

S/N: 72083397

Manufacturer Standards/Equipment: Des• Temperature Probe Thermialor Module Temperature Calibration Bath TC155 Temperature Probe 'rl•ermislor Module Temperalure Calibration Ball] TC191 Control Company
Serial Number

Due Date

•.$T Traceable

Reference 149 8/14/07

A6713030 A27129 7110/07

100020769,i 93139 157 11/14/07

A6B06053 A17118 8123/07

A6823089 A42238 Certificate Information: Technician: 68 Test Conditions:

23.0"C

39.0 %RH Calibration Data: (N• i•-strument) Unit(s) Nominal

As l':ound In Tol • Nominal •C N.A.

• 0.001 "C N.A,

99.999 Procedure: CAL-03 1028 mBar

Cal Date: 1/19/07

As Left In "rol

Cal Due: 1/18/09

Max ±uc [UR
99.6 Y

99.0

101 0 0 059 >4 This Instrument

was calibrated using Instruments

Traceable to National Institute of Standards and Technology.

Maintaining Accuracy:

Recalibration:

CONTROL COIVlPANY

4455 Rex Road Friendswood,

T× 77546 USA Phone 281 482-1714

Fax 281 482-9448

service@control3.com

www,control3,com

Comrol Compa=ty •s •O 9001 Quality Cetlil•ed by (DNV) Oel Nors•e Veritas. Ceddi,:ale No. CERT.01805.AQ.HOLIENTEC SERVICES, iNC. • ORSAT

STANDARDiZATiON

source: •','•,/1 Orsat / F•eak

Check: Date of Test: Date of Standardization:, Orsat / Fyrite ID #: Ca|ibrat•on Gases

Vendor Gas Tank

Concentration, (%) Carrier Gas Container Type Cylinder ID # Date of Expiration Tank 2
02 •02 /q. q7

3.002, •5

Tank 1 Actual Net

2 Actual Net / •.o •'.o

3 Actual Net /•,.O Average Net Volume

Value

Difference 0.0.•

Tank 1 2 Actual CO2O2

Net 3.0

2 Actual Net /•.o

3 Actual Net •.o/•'.o Average Net Volume

Value
/z/ 97'

Difference

45Certificate of Analysis

Date of Analysis: Customer Name: Grade of Product;

7/14/2005
PRIMARY

STANDARD

Reference

Number: Part NLlmber:

87•110858887-5 X03N!82P15AC226 C_C_ylinder Number CC214139

Component _•l.Ueste

d CARBON DIOXIDE

3.000 % OXYGEN 15.00 % NITROGEN Balance 3.002 14.97 Balance Notes: Relative Uncertainty

of Analytical

Value: +/- 1% of component

or +f- 0.02% of absolute, which ever is lower. Primary Standard

gas mixtures

are traceable

to N.I.S.T weights

and/or N.I.S.T gas mixture reference mat,.rials

.....

...... Approvnl Signalure

u-.'Certificate of Analysis

Date of Analysis: Customer Name, Grade of Prodclct:

7," 14/2005 PR}MARY

STANDARD

Reference

N umber: Part Number:

87-110858887-4 X03 N 181P 15AC225 _Cylinder Number CC214147

Component _•e_q u ested Concentration

Actual Concentration OXYGEN 3.000 %

2,993 % CARBON DIOXIDE

t6.00 %

15.97 % NITROGEN Balance. Balance Notes: Relative Uncertainty_o_f,,,An.•!y•.i£#! ,•alM#,; +1- 1% of component

or +/- 0,02% of absolute, which ever is lower. Primary Standard

gas mixtures

are traceable

to N.I.S.T weights

and/or N.I.S,T gas mixture reference materials, Ap.:.•ruval Sigr•ak•r•-'

.,/ k......• ':' •.,--./"'/

Page

47ENTEC Se ices,

Inc. 16 D Commerce

Ave, Hueytown, AL 35023 Preliminary Traverse

& Cyclonic

Flow Verification Client: General Shale Brick Source: Kiln A Test Date: 02/26/08 Run No.: Preliminary

Test
Traverse Point

Delta P 1-1 0.23 1-2 0,31 1-3 0.28 1-4 0.30 1-5 0,24 1-6 0.18 1-7 0,21 1-8 0.21 1-9 0.19 1-10 0.14 2-1 0.44 2-2 0.45 2-3 0,41 2-4 0.36 2-5 0,30 2-6 0,28 2-7 0.26 2-8 0.24 2-9 0.22 2-10 0.20

Average 0.27

Sq. Rt. Delta P 0,4796 0.5568 0.5292 0.5477 0.4899 0.4243 0.4583 0.4583 0.4359 0.3742 0.6633

5 0.6708 5 0.6403 0.6000 0.5477 O.5292 0.5099 0.4899 0.4690 0.4472

0.5161
Note: Based on the preliminary

traverse the flow is not considered

cyclonic

Null Reading (Angle)

o

Stack Temp. (°F) 314 0 312 311312 0 310 0 309 308 310

0.75 0

310 0 300 320 320 322 0 318 0 321 0 317 317 319 315 0 315

314.0

4849ENTEC SERVICES,

INC FIELD QA / QC CHECKLIST Method 6C Sulfur

Dioxide

TEST METHODS

USED: TYPE CONTROL

DEVICE: MODIFICATIONS TO METHOD:

Was valid Interference

Check (sum of responses

< 2.5 % of calibration

span) on site? 2 Was valid Certificate

of all Protocol t calibration

gases on site? 3 Was the High-level

gas equal to the calibration

span ? 4 Was the IVlid-level gas between 40 and 60 % to the calibration

span ? 5 Was the Low-level

gas < 20 % of the calibration

span ? 6 Was the sample kept above the dew point by heating prior to the sample conditioner

? 7 Was the Analyzer Calibration

Error within +/-2 % or +/- 0.5 ppm of the calibration

span for all calibration gases ? YE.=.•S

NO

8 Was the System Bias within +/-5 % of the calibration

span for the low-scale and upscale gases ? 9 Was the System Response

Time Calculated

during the initial sampling system bias check? What was the System Response

Time ?

| o•

Seconds 10 Was the Drift within +/-3 % or +/- 0.5 ppm of the calibration

span for the low-scale and upscale gases ? 11 Was the sampling system purged > 2 times the system response time before each test run? 12 Was the minimum

time at each sampling point > 2 times the system response time ? 13 Was the sample flow rate within 10 % of the flow rate established

during the system response time check for each run ?

Flow rate: • ¢•

liters/minute 14 Was a stratification

test performed

before the first run ? What were the results of the stratification

test? All points were: Within +/- 5 % or +/- 0.5 ppm of mean for 1-point sampling (unnstratified) Within +/- 10 % or +/- 1.0 ppm of mean for 3-point sampling (minimumally

stratified) Some points were > 10 % or 1.0 ppm of mean for 12-point sampling (stratified) 15 Was a Multi-point

or 3 point probe used ? 16 Was the flow rate from each point verified to be within 10 % of the mean flow rate for each run ? 17 Were all data points recorded in at least 1 minute averages?
18 Was the average concentration

fo•/•c•libration span? Signature (Test Team Leader): •

50Interference Response

Test
Date 10/1/2007 Analyzer Model

Ametek 921 CE Component Sulfur Dioxide Analyzer Serial No. AD-921-5141 Span 0-215 ppm Cylinder iD

Test Gas

Concentration

SG9120994 SG9120994 SG9120994 SG9120994 S02
CO

213

Analyzer

Response

215 495 CO2 9.76 O2 20.79

Total *Specification (EPA Method 20) Sum of interference

responses

must not exceed 2% of span Difference

% of Span
0.95

0.48

% of Span

Analyzer Response

X 100 Instrument Span 1.43

51Test Protocol

.52Pollution Control System Evaluation

and Source Emissions

Testing January 25,2008

Ms. DeAnna

Oser Air Branch

Georgia

Environmental

Protection

Division

Test Protocol

Reference

Letter for General

Shale

Rome GA K1 (Kiln A) DLS Baghouse

Stack

HC• / HF, & SO2 Entec Project

No.: 28127 Dear Ms. Oser, Please find attached

the test protocol

for General

Shale

Rome, Georgia

facility

K1 (Kiln A) Dry Lime Scrubber

(DLS) Baghouse

Stack.

The protocol

outlines

the test procedures, the QA/QC

requirements,

and example

calculations.

Testing

has been scheduled for Tuesday

February

26, 2008. Testing

will be conducted

during one day. It is understood

that modification

to the permitted

test requirements

has been approved
on previous

testing to use EPA Method

6C for the determination

of Sulfur Dioxide.

The facility will supply all operation

parameters

to meet permitting

requirements

under the MACT and will be included

in the final report.
If you should

have any additional

questions

about the protocol

please

call me at 205- 491-6676 or my cell at 205- 613-5473

and will make any changes

as required. Sincerely, Entec Services

inc. Lynn Beane Operations Manager

16-D Commerce

Avenue

Hueytown,

Alabama

35023

Phone: (205) 491-6676 6614 www.enl•cse

rvices, com Fax (205) 491-En ec Services, inc. 16-D Commerce

Avenue Hueytown, Alabama

35023 Telephone: (205) 491-6676 Fax: (205) 491-6614

Test Protocol

for the KI (Kiln A) DLS Baghouse

Stack (Dry Lime Scrubber

w/Fabric

Filter Baghouse) Emissions Testing

at the Genera• Shale

Company

facility

located

in Rome, Georgia

Submitted to:
General Shale P.O. Box 3547 Johnson City, Tennessee

37602 Attention: Ms. Martha

West CC: State of Georgia

Department

of Natural

Resources

Air Protection

Branch

Entec Project

No. 28127 Reviewed By: Protocol

Emailed:

January

25, 2008 Completed By:

Tom Lotz QA/QC Manager Lynn Beane Operations Manager

54Scope of Work Entec services

will conduct

testing per the requirements

of General

Shale

Rome, GA Facility Title V Operating

Permit

No. 3251=115-0105=V=02-0. Testing

will be conducted for hydrogen

chloride,

hydrogen

fluoride,

and Sulfur Dioxide

emissions

on the K1 (Kiln A) Baghouse

Stack per requirements

of Part 63 Subpart

JJJJJ

Brick MACT. The proposed

test program

will take one (1) day to complete.

Entec will perform the testing

during the week of February

18, 2008 upon approval

of this test protocol a final date will be set and updated

via email to GA-DNR

with an approximate start time of 9:00 am. Procedures Testing will follow EPA Test Methods

1-4 w/26A

& 6C of the CFR Title 40, Part 60, Appendix A and Part 63 Subpart

JJJJJ.

The calibration

and quality

assurance procedures of EPA CFR 40 Part 60 Appendix

A and Part 63 for test Methods

1-4 w/26A & 6C of the "Quality

Assurance

Handbook

for Air Pollution

Measurement

System" Volume III Stationary

Source-Specific

Methods

will be followed

throughout

the duration of the field testing

and laboratory

analysis.

The most current

CFR revision

of each method (July 1, 2006) will be used.
It is understood

that the State of Georgia

Department

of Natural

Resources

Air Protection Branch

may at their discretion

bring audit samples

to the test team for analysis in conjunction

with the other samples

as required.

The following

paragraphs summarize the methods

to be used, detailed

test procedures,

QA/QC

procedures,

and other documentation

to be used for this test program.
Stack Gas Volumetric

Flow The velocity

of the gas stream will be determined

according

to EPA Reference

Method 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

will be measured

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

pyrometer

will be used to measure

stack temperature

at each sampling point. The stack will be tested for cyclonic

flow according

to EPA Reference

Method

2.

55Stack Gas Molecular

Weight. The carbon dioxide

and oxygen

concentrations

will be determined

using EPA Reference Method 3. A grab sample

of the flue gas will be extracted

from the gas stream

during each particulate

test run and analyzed

using and Fyrite analyzer.

The molecular

weight of the gas will be calculated

using the moisture,

oxygen

and carbon dioxide

content

and the measured

stack gas temperature.

The Fyrite sampling

system

will be verified

to be leak free prior to the analysis. Moisture Content

(Combined

w/Method

26A} The moisture

content

used for calculating

the gas stream

flow rate is determined

by measuring the amount

of condensed

moisture

in the series of impingers

in the sampling train as described

in EPA Reference

Method

4 at the completion

of each test. The moisture content

will be conducted

in conjunction

with EPA Method

26A.
The moisture

collection

system

consists

of a series of impingers.

Ice is placed around the impingers

to maintain

a temperature

<680 F. The outlet temperature

of the impingers is monitored

and recorded

throughout

the duration

of the testing

to verify the temperature is below <680 F. Hydrogen Chloride

I Hydrogen

Fluoride Preliminary data will be used to determine

stack temperature,

pressure,

and range of velocity heads,

moisture

content

and stack gas dry molecular

weight prior to sampling. The meter box will be leak checked

from the pump to the orifice.

Initial and final leak checks of the sampling

system

and pitot lines will be performed

as outlined

in Method 26A and will be recorded

on the data sheets.

The nozzle

(glass or Teflon lined with an angle of taper of 30 degrees

and of button hook design)

will be calibrated

before and after the test using a micrometer

and will be also recorded

on the data sheets. The sampling

probe will be placed at each sampling

point to provide

a total sampling time of at least 60 minutes

and a volume

of at least 31.8 cubic feet. The gases will be drawn through

a glass nozzle attached

to a heated

glass lined probe.

The probe and filter will be maintained

at the proper setting to obtain a temperature

of greater

than 248 0 F. The gases then proceeded

through

borosilicate

glass filter holder,

with a Teflon frit filter support

through

a tarred Teflon or quartz fiber filter to remove

particulate

matter. The exit of the filter will be maintained

at a temperature

of greater

than 248 0 F. These temperatures will be recorded

at each poir•eon

the data sheets.The gases will be then scrubbed

through

a series of five impingers

(optional

impinger not included)

to capture

hydrogen

halides

and halogens

and moisture.

The optional

first irnpinger for a knockout

for moisture

will not be used since the source

it is a dry baghouse system.

The second

and third impingers

will contain

approximately

100 ml of
a 0.1N H2SO4 solution

and the fourth and fifth impingers

will contain

approximately

100 ml of a 0.1 N NaOH solution.

The sixth impinger

will contain

pre weighed

silica gel to remove any remaining

moisture.

The gases pass through

the impinger

series in an ice bath to maintain

a maximum

exit temperature

of 68 0 F. This temperature

will be also recorded on the data sheets.

The clean and cool gases then entered

the meter box where the gas flow and temperature

will be measured.
After the completion

of the test leak rate determinations

will be made. Then thesampling train and the probe nozzle assembly

will be transferred

to the cleanup

area making
sure no sample

will be lost. The cleanup

data will be recorded.
The first, second

and third impinger

contents

will be transferred

to its tarred container, weighed and the rinsing from the glassware

will be added to this container.

The fourth and fifth impinger

contents

will be transferred

to its respective

tarred container,

weighed and the rinsing from the glassware

will be added to this container.

The silica gel from the fifth impinger

will be transferred

to its respective

tarred container

and weighed.

A blank of the sulfuric

acid solution,

sodium

hydroxide,

distilled

water and acetone

will be taken. These containers

will be clearly marked

and transported

to the laboratory

for analysis.
A State of Georgia

approved

and accredited

laboratory

will perform

all of the laboratory analysis.
Sulfur Dioxide

Method

6C A Western

Research

(or equivalent)

SO2 Method

6C analyzer

(or comparable)

will provided continuous

analysis

of SO2 in the gas stream.

The basic analytical

principle involves quantitative

measurement

of the absorption

of UV radiation

by SO2 molecules. The analyzer

uses a single light source,

which emits an appropriate

wavelength, illuminating the sample

cell through

which the sample

is continuously

passed.

Narrowband optical filters are rotated

through

the beam, and the radiation

passed

through

the optical filters and sample

cell is detected

I• a single photo-detector.

The signal pulsesfrom the photo-detector

are separated

by a multiplexor

into a measuring

channel

and a reference channel.

A log ratio amplifier

computes

the logarithm

of the input signal ration, producing

a signal that is proportional

to the SO2 concentration.

The dual-range analyzer has a digital readout,

as well as 0-10.0 V DC output terminals.

The full scale of the instrument

will be set at high level calibration

gas ppm value as required.

58QA / QC Procedures Specific quality assurance

/ quality control procedures

will be adhered

to during this test project to provide

valid and scientifically

defensible

data. For any environmental

field and laboratory

measurement,

a degree

of uncertainty

exists in the data due to inherent limitations of the measurement

systems

employed.

The objective

of a QA/QC

program is to produce

data of known

precision,

accuracy,

representation,

completeness

and comparability. The objective

in this test project

is to determine

compliance

with applicable air permit requirements.

The final data user in this project will be the State of Georgia Department

of Environmental

Quality. The following

section

details all QC procedures

to be followed

during the sampling. Velocity / Volumetric

Flow Rate Volumetric flow rates will be determined

during each isokinetic

test run. The following QC steps will be adhered

to during these tests: Reported duct dimensions

will be checked

by physical

measurements

to determine cross-sectional duct area. Pitot tube coefficients

are determined

based on physical

measurement

techniques
as delineated

in Method

2 before and after each test. The Type-S

pitot tube are visually

inspected

before and after sampling. The pitot tube is installed

on the sampling

probe with the proper orientation

and spacing from the sampling

nozzle. Before each series of tests, thermocouple

readings

for the silica gel impinger

exit temperature are checked

against

an N.I.S.T.

traceable

thermometer. The oil manometer

is leveled

and zeroed before each test run. Both legs of the pitot tube are leak-checked

before and after sampling. Proper orientation

of the pitot tube is maintained

while making

measurements.

The roll and pitch axis of the pitot tube is maintained

at 90 o to the flow. An average

velocity

pressure

reading

is recorded

at each point instead

of recording extreme high or low values. The pitot/manometer

umbilical

lines are inspected

before and after sampling

for moisture condensate.

Lines are cleared

if moisture

is found.
Molecular Weight

Determination

Fyrite Analysis The carbon

dioxide

and oxygen

concentrations

are determined

using EPA Reference Method 3. A sample

of the flue gas is extracted

from the gas stream

during each test.The samples

are analyzed

with a Fyrite gas analyzer.

The following

QC steps are adhered to during these tests: The sampling

train is leak checked

before and after each sample

is taken. The samples

are run in triplicate

for accuracy. Standardization is performed

to audit the reagents

and the operators

technique.

A known mixture

of CO2 and 02 is analyzed

and repeated

with 3 consecutive

values +/- 0.5 percent

of the known value. Two NIST traceable

gas cylinders

are run against

the instrument

to audit the accuracy of the analyzer

and the analyzer

operator

technique.

One cylinder contains 2 to 4 percent

02 and 14 to 18 percent

CO2. The second

cylinder

contains 2 to 4 percent

CO2 and about 15 percent

02. Moisture Determination Stack gas moisture

content

(Bws) is determined

by dividing

the mass of moisture collected by the impingers

or stainless

steel condenser

and silica gel impinger

by the standardized volume

of gas sampled.

The following

QC steps are adhered

to during these tests: The indicating

silica gel is fresh for the first run and periodically

inspected

and replaced during runs, if needed. The analytical

balance

is placed in a clean, motionless

environment

for weighing. The balance

is leveled

and zeroed if necessary

before each weighing. Preliminary silica gel impinger

tare weights

and post-run

weights

are weighed

to the nearest 0.1 g. Before each series of tests, thermocouple

readings

for the silica gel impinger

exit temperature are checked

against

an N.I.S.T.

traceable

thermometer. The silica gel impinger

gas temperature

is maintained

below 68°F and recorded

at every traverse

point. Each impinger

is wiped of surface

moisture

before post-run

weighing. The volume

of liquid captured

is measured

using a graduated

cylinder

with 1- milliliter increments. Sulfur Dioxide

Determination The sulfur dioxide

concentrations

will be determined

using EPA Reference

Method

6C. A sample

of the flue gas was extracted

from the gas stream

during each test. Moisture will be removed

form the sample

and analyzed

on a dry basis with an Instrumental

gas analyzer. The following

QC steps were adl•ed

to during these tests:Only analyzers

that have a resolution

or sensitivity

of at least < 2.0% of full-scale range are used. Upon the SO2 analyzers

initial use in the field, an interference

check was conducted. The reference

calibration

gases used in this test program

are certified

following

EPA Protocol Number

1 analysis.

Copies

of the calibration

gas certifications

are included in the instrument

calibration

section. The high level gas was equal to the calibration

span gas. The mid level gas was between

40 and 60 % of the calibration

span gas. The low level gas was < 20% of the calibration

span gas. In accordance

with EPA Method

6C a three-point

(i.e., zero, mid-, and high-range) analyzer calibration

error was conducted

on each reference

analyzer

prior to initiating the compliance

testing.

These

checks

were conducted

(after final calibration adjustments

were made) by injecting

the calibration

gases directly

into each gas analyzer

and recorded

the responses. The analyzer

calibration

error was less than _+ 2.0% or + 0.5 ppm of the.calibration span gas for the zero, mid-range,

and high-range

calibration

gases. The probe material

was stainless

steel. The probe, filter and sample

line temperature

was maintained

above the dew point by heating,

prior to sample

conditioning. The sampling

system

bias was less than _+ 5.0 % or of the calibration

span gas for the zero and upscale

calibration

gases (_+ 0.5 ppm absolute

difference). The system

response

time was calculated

during the initial sampling

system

bias. The drift for either the low-level

and mid-level

or high-level

gases was less than + 3.0% or of the calibration

span gas (+ 0.5 ppm absolute

difference). The sampling

system

was purged

> 2 times the system

response

time before each test run. Sample flow rate was maintained

within 10% during the entire test period. Data is recorded

at 1-minute

intervals. All data collected

was within the calibration

span gas.TEST CALCULATIONS EQUATIONS 1. Ps = Pbar +(Pg/13.6)=( +

/13.6) 2. Pn• Pbar +(&H/13.6)=( + (

/13.6) 3. Vrnst,•=l 7.64 Vm Y (P,•/Tn•)=I

7.64*(

)*(

)*( 4. Vwst• 0.04707

V•0=0.04707"( )= 5. Bws Vwstd/(Vmstd

+ Vwstd)=(

)/(

+

)=

/ )=

For saturated

sources

(No. 6 8 only): If No. 6 is less than No. 5 source is considered

saturated 6. TBws (106.37. {2827/(ts.365)}/ps

10 6"37"{2827/(

+365)}/( 7. TVwstd Vr.std*( TBws/1-

TBws)=(

)*( 8. TV•c= TVwst•/0.04707

=(

) / ( 0.04707

)= 9.

12.13.14.15.16.

19.
20. )/( 1

M•= 0.44(%CO2)+0.32(%O2)+0.28((100-(%CO2+%O2)) =0.44(

)+0.32(

)+0.28(100-(

+ )= Ms M,• (1- Bws)+18

Bws=(

)*(1-

)+18( Vs 85.49 Cp* •/AP •/(Ts/(Ms*

Ps)) 85.49*(0.84)*( )*•/(

/((

)( Qa Vs As 60=(

)(

)(60)= Qs Qa (1- Bws) (528/Ts)*(P,J29.92)=( )(1- C&=0.01543* (Mn/Vmstd)=0.01543*( /

)= PMR= Cs* Qs (6017000)=( )*(

)*(60/7000)= Vn=Ts/Ps*{(0.002669) V=c+ (Vn• Y Pn•)/Trn)} =( /

)*{(0.002669)( )+(

)( •=Vnl00/(60*e*Vs*An)=( )100 / (60)(

)(

)*(528/

)))=
)*( /29.92)=

)( )/(

)}= )( )= %EA= 100%* {(%O•)-0.5*(%CO)}

/ {0.264(%N•)

(%02)+ 0.5*(%CO)} 100%*{( )-0.5(

)} / {0.264(

)-(

)+0.5( Cs @ 50% EA= Cs/1-[{1.5(%02)-0.133(%N2)-0.75(%CO)}/20.9] =(

/ 1-[{1.5(

)-0.133(

)-0.75( Ib/mmBtu= (Cs17000)*{(F,•*20.9)l(20.9-%0•)} =(

/7000)*{(

)'20.9)/(20.9-( )}=

)}/20.9]=

62NOMENCLATURE ASAnACFM BwsC•CaCpAH APdscf EAE/Btu FKpMdMsIPbarPgPinPMR PsPstdQ.QsTBw• TVlc TVwstd TinTstd 0VmV•Vins•d V•Vwstd Y Cross-sectional

area of stack, square feet Cross-sectional area of nozzle, square feet Actual cubic feet of gas per minute at stack conditions Proportion by volume of water vapor in gas stream Particulate concentration

in stack gas, gr/dscf Deionized water blank residue concentration,

mg/g Pitot tube coefficient Pressure drop across orifice meter, inches water Velocity head of stack gas, inches water Cubic feet of dry gas corrected

to standard conditions Excess Air Particulate Emission

Rate, pounds/mmBtu F-factor, 9640 dscf/MMBTU's

of heat input Constant (85.49) Total particulate

matter collected,

mg Molecular weight of stack gas; dry basis, Ib/lb-mole Molecular weight of stack gas; wet basis, Ib/Ib-mole Percent of isokinetic

sampling Barometric pressure,

inches mercury Stack static pressure,

inches of water Barometric pressure of dry gas meter, in. mercury Particulate mass rate, pounds/hour Absolute stack gas pressure,

inches mercury Barometric pressure,

standard conditions,

29.92 "Hg Volumetric flow rate, actual conditions,

ACF/min Volumetric flow rate, dry standard conditions,

dscf/min Theoretical water vapor in the gas stream based on saturated

stack conditions,

proportion by volume (dimensionless) Theoretical volume of water collected

based on saturated

stack conditions,

ml Theoretical volume of water vapor in the gas sample based on saturated

stack conditions, corrected to standard temperature

and pressure,

scf Absolute average dry gas meter temperature,

degree R (460) Absolute average stack gas temperature,

degree R (460) Absolute temperature

at standard conditions,

528 R Total sampling

time, minutes Total volume collected

in impingers

and silica gel, ml Volume of gas sampled through gas meter, cubic feet Volume collected

at stack conditions

through nozzle, ACF Stack gas volume sampled,

ACF Volume of gas sampled through gas meter, cubic feet Average stack gas velocity,

feet/sec Volume of water vapor in gas sampled,

standard

cubic feet Dry gas meter calibration

factor

63NOMENCLATURE FOR SULFUR

DiOXiDES

(Method

6C)

ACECAv• CDirCGas CoCMCMA

Cv
CSDSBSBfinal SB•MWSO2 Ibs/hr 385.1 x 106

Analyzer

calibration

error, percent of calibration

span.

= Average

unadjusted

gas concentration

indicated

by recorder

for the test run, ppmv. Measured concentration

of a calibration

gas (low, reed, high) when introduced in direct calibration

mode, ppmv

= Average

effluent gas concentration

adjusted

for bias, ppmv.

= Average

of initial and final system calibration

bias(or 2-point system calibration error) check responses

form the low level (zero) calibration

gas, ppmv. Average of initial and final system calibration

bias (or 2-point system calibration error) check responses

for the upscale

calibration

gas, ppmv. Actual concentration

of the upscale

calibration

gas, ppmv. Measured concentration

of a calibration

gas (low, mid, or high) when introduced in system calibration

mode, ppmv. Manufactured certified

concentration

of a calibration

gas (low, mid, or high), ppmv.

= Calibration

span, ppmv. Drift assessment,

percent of calibration

span. System bias, percent of calibration

span. Post-run system calibration

error, percent

of calibration

span. Pre-run system bias, percent calibration

span. Molecular weight of SO2, which is equal to 64.06 Sulfur Dioxide mass rate in pounds per hour Conversion factorACE (7E=1)

SB

D(7E=4) CDi__r Cv_ x 100 CS (

)/( Cs _.r X 100 CS ( SBfinal

SBil =

)/( )X 100=
)X 100=

CGas (7E=5) (CAvg

Co) X CMA/(CM

Co) ( )X(

)/(

16. SO2 Ibs/dscf

= Cgas X Me / 385.1 x 106 ( x (64.06)/(385.1

x 106)

17. SO2 Ibs/mmBTU=SO2

Ibs/dscf

x F-factor

x ((20.9/(20.9-O2)) ( ) x (

)x((20.9/20.9-( ))=
17. SO2 Ibs/mmBTU=SO2

Ibs/hr/Heat

Input mmBTU/hr ( )/( )
21. SO2 Ibs/hr = SO2 Ibs/dscf

x DSCFM

x 60

= ( )x(

) x (6o) =

65QSTI Certification Documentation

660 o•68• O

Z©N

©Laboratory AnalysisENTEC SERVICES, INC LABORATORY SAMPLES

QA/QC

CHECKLIST

METHOD(S): RECOVERY DATE: Description of Impinger

Contents: Test Run No.'s 1: ..• Impinger Contents

Container

Number: Test Run No.'s 1"_ ,/-•--/

2: /Z-- •

3: Samples Sealed and Stored in Secure Container?•r

N Liquid Level Marked?

•r N Filter ID Number: Test Run No.'s 1: ••

2: Description of Paniculate

on Filter: Test Run No.'s 1" Filter Container

Number: Test Run No.'s 1: Samples Sealed and S{ored in Secure Con{ainer?

Y or N Probe Rinse Con{ainer

Number: Tes{ Run No.'s 1" Samples Sealed and S{ored in Secure Con{ainer? Liquid Level Marked?

Y or N Probe Rinse Rea•en{: Labora{o• Blanks: Probe Rinse:

Impinger:

•

FiRer:

O{her: Were samples

anal•ed

by En{ec 8e•ices,

Inc.? Y or• If not, Laborato•

Peffo•ing

Analysi• YorN
Lot Number:

*** if using outside

I•)l•oratory

services

please fib out the following

chain of custody. ;•It•':: .:!i:.t!::;i•!• •,,. 'i!:i::,:i•iE•'•!::•.'i: S,gnature. • Date. •>•.. •10•

S,gnature:

E,;• • • rintName:_•. 0

Time(24hr):

/a :00

PrintName:

/•/4• Signature (Project Manager

or T@r): Date: •
Revision 2 September

2005 TLj 7 2FAX MESSAGE

Subject.'

This material is intended only for the use of tl•e individual(s)

or entity to whom it is addressed

and may contain information

that is l•vileged

and confidential

It iS our policy that fecsimile$

are Intended for and should be used for business purposes only, If you are not the intended recipient, or the employee or agent responsible

for delivering this material to the intended recipient, you are I•ereby notified that any die.ruination,

distribution

or copying of this fao•imile is strictly prohibited,

ff you have received this communication

in error, please no•fy the sender, Thank you for your professional

consideration

and cooperation,
900 Lakeside Drive

Mobile, AL 36693

tel 251,666.6633

fax 251,666,6696

www,testamet|cainc.com
73Sent: Thursday,

March 13, 2008 5:14 To: 'tomlotzsr@entercservices.com' Norris, Jim HiHere's a brief summary

of the data. Please let me know if you have any questions, Units= mg/L Lab ID

Sample ID R-1 Kiln A Sta•k R-2 Kiln A •l•,k 1 R-3 Kiln A Stack | 0.1N H2SO4 Blank 700-27653-1 700•27653• 700-27653-3 700-27653-4

HCL as chlodde 21ii 27Not detected HF as fluoride 2,22.03.3Not detected Thanks, CHARLES L. NEWTON Project Manager
TestAmerica

THE LEADERS IN ENVIRONMENTAL

TESTING

900 Lakeside

Drive Mobile, AL 36693 Tel 251.666.6633

Fax 251.666.6696

cell 251.89&3973

www. testa m e r_Lc.o•n c, co m

3/13/2008 ?4ENTEC SERVICES,

iNC. Chain of Custody

Client General Shale Brick Project No, _2•.127 Rome• GA Lab Name:

•o• NO• 20•9•=6676 Ent• Job No•

2/26/2008 2/26/2OO8 2F•/2008 2/27/2008 .=•mgl• COllected

by:

A. Otero • •u• •:

T. LO•, •r. Email R•u• To: • ;.0:•

•=• •.•, ,, •,,,: R-1 Kiln A •
R-3 Kilq A Stack 0.1 N H•804 Blank 28127

76Gas Analysis •nstrument Calibration DataAnalyzer Calibration Error

?8Analyzer Calibration Error

Test Performed

For: General Shale Brick Rome, GA Facility Kiln A Compliance Testing Date:2/26/08 Test Performed

By: Entec Services,

Inc. Birmingham Division Test Trailer 904 Tommy Lotz, Jr. Run Sulfur Dioxide

Monitor Full Scale:

226.6 ppm Cylinder Reference

Gas Number Concentration Method 6C Serial Number: WR900 SN AD-92-1-5 Analyzer Difference

Calibration Response Error (%) SG917038BAL/cg12 0.0 ppm

1.1 ppm

1.1 ppm

0.49 % CC178851/cgl 125.1 ppm

125.8 ppm

0.7 ppm

0.29 % XC025683B/cg2 226.6 ppm

226.5 ppm

-0.1 ppm

-0.04 %

?9System Bias

and

Drift

80Sampling Systen

Bias

and

Test Performed

For: General Shale Brick Rome, GA Facility Kiln A Compliance Testing Date:2/26/08 Test Performed

By: Entec Services,

Inc. Birmingham Division Test Trailer 904 Tommy Lotz, Jr. Run 1
Monitor Type Analyzer

Cal Response 1.1 ppm 125.8 ppm

Initial Cal Value 4.0 ppm 125.3 ppm

Pre Run Bias (%) 1.28 % -0.22 % Final Cal Value 3.8 ppm 125.2 ppm

Post Run Bias (%) 1.19% -0.26 % Total Run Drift (%) 0.09 % 0.04 %

81Sampling System

E ias

and

Drift

Test Performed

For: General Shale Brick Rome, GA Facility Kiln A Compliance Testing Date:2126 Test Performed

By: Entec Services,

Inc. Birmingham Division Test Trailer 904 Tommy Lotz, Jr. Run 2
Monitor Type SO2SO2 Analyzer

Cal Response 1.1 ppm 125.8 ppm

Initial Cal Value 3.8 ppm 125.2 ppm

Pre Run Bias (%) 1.19% -0.26 % Final Cal Value 3.7 ppm 124.0 ppm

Post Run Bias (%) 1.15% -0.79 % Total Run Drift (%) 0.04 % 0.53 %

82Test Performed

For: General Shale Brick Rome, GA Facility Kiln A Compliance Testing Date:2/26/08 Test Performed

By: Entec Services,

Inc. Birmingham Division Test Trailer 904 Tommy Lotz, Jr. Run 3
Monitor Type SO2 SO 2 Analyzer

Cal Response 1.1 ppm 125.8 ppm

Initial Cal Value 3.7 ppm 124.0 ppm

Pre Run Bias (%) 1.15% -0.79 % Final Cal Value 3.5 ppm 123.4 ppm

Post Run Bias (%) 1.06 % -1.06 % Total Run Drift (%) 0.09 % 0.26 %

83Calibration Gas

Certificates

I]4Equipment CalibrationsSAMPLING AND ANALYTICAL

EQUIPMENT

CALIBRATIONS All of the emission

testing equipment

used was calibrated

according

to the procedures outlined in the EPA CFR 40 Part 60 Appendix

"A" and the Quality Assurance

Handbook for Air Pollution

Measurement

System,•,

Volume

III, EPA-600/4-77-027b. Type-S Pitot tube Calibration• The pitot tubes used for flow velocity

measurement

were checked

for dimensions

to verify a pitot coefficient

Cp of 0.84. Documentation

of the calibration

and calibration check for dimensional

measurements

is provided. Samplin.• Nozzle

Calibration Sampling nozzles

were checked

visually

for nicks or damage

and for dimensional calibration prior to testing

by measuring

the nozzle diameter

in at least three planes using a Vernier

micrometer.

Measurements

must agree to within -+0.004-inches. Documentation is provided

on the individual

data sheets. Temperature Measuring

Device

Calibration-• Each temperature

sensor

(stack gas, dry gas meter,

and impinger

exit) and readout was calibrated

at a minimum

of two points over the anticipated

range of use against

a' NIST-traceable mercury-in-glass

thermometer.

All sensors/readouts

were calibrated prior to field sampling.

Stack gas thermocouples

must agree within 1.5% (expressed

in []R) of the reference

thermometer

through

out the entire calibration

range.

Dry gas meter thermocouples

must agree within _+5.4•:F

and impinger

exit thermocouples

must agree within _+2F. Documentation

is provided. Dry Gas Meter Calibration• Dry gas meters

were fully calibrated

against

a set of calibrated

orifices.

After assembly and leak checking,

the console's

pump is allowed

to run for 15-minutes

to warm up the dry gas meter and pump. For a pre-test

full calibration,

data are collected

at five (5) orifice manometer

(L•H) settings

of approximately:

0.32, 0.67, 1.2, 2.0, and 3.9 inches of H20. Gas volumes

of at least 5 ft3 are used at all the orifice settings

and critical vacuums were obtained

at all of the calibration

points.

The individual

gas meter correction factors

(Yi) are calculated

for each orifice setting and averaged.

The method requires that each of the individual

correction

factors

fall within +2% of the average 86correction factor, or the meter be cleaned,

adjusted

or repaired

and recalibrated.

The orifice pressure

differential

(AH@) that equates

to 0.75 cfm of air at 68°F and 29.92 inches Hg is calculated

and along with the average

correction

factor (y) is marked

on the meter console. For the post-test

calibration

the alternative

Method

5 post-test

calibration

procedures
were used (Emission

Measurement

Center

Approved

Alternative

Method

ALT-009). Prior to the initial run a y-factor

check was performed

to ensure

that the meter was operating according

to the original

calibration

to within 3% of the original

y-factor.0TYPE S PITOT

TUBE

iNSPECTiON

DATA

SHEET

LEVEL

"•: z

Distance Between Tube OD Parameter Assembl•/Level? Holes Damaged? Obstructed?

•2

A Z A sin 7 W A sin e PA

PA- PB DT Thermocouple Cal. Thermocouple Cal.

Value Yes

Allowable

Range Yes No No No No 0 -10 < cd < +10 0 -10 < 0•2 < +10 0 -5 < 131 < +5

9O90.98800.494 .494 _5 < < +5

for 1/4" OD, 0.526 to 0.750 for 3/8" OD, 0.788 to 1.125

W < 0.031" for 1/4" OD, 0.263 to 0.375 for 3/8" OD, 0.394 to 0.563 for 1/4" OD, 0.263 to 0.375 for 3/8" OD, 0.394 to 0.563 0 -0.063 to 0.063" .375 0.188 to 0.375" 67 Reference

temp. 67 Probe Thermocouple
Certification certify that the Type S pitot tube/probe

ID # ESP= 62B meets or exceeds

all specifications, criteria and/or applicable

design features

and is hereby

assigned

a pitot tube calibration factor Cp of 0.84

Certified and Calibrated

By: Date Certified: Lalan R. Kirby 12/21/2007 Annual Calibration

89ENTEC Services,

nc.
16-D Commerce Ave.Hue•own,

Alabama 35023 Calibration Date:

12/31/2007 Calibrated by:

Tom Lotz Annual Thermocouple

Calibrations Entec Serv=ces

Temperature

**Reference

Thermocouple

Difference

Within ID Number

Source

Temperature

Temperature

Degrees F

Tolerance 66 65 TC-1 TC-2 TC-3 TC-4 TC-6 TC-7 TC-8 TC-11 TC-12 TC-13 TC-14 TC-15 TC-16 ambient ambient

66 ambient 66 Yes 65 Yes 66 0 ambient 66

67 ambient 66

66 ambient 66 ambient 66

6565 ambient 66

65 ambient 66 ambient 66 ambient 66

666767 ambient 66

65 66 65 66 65 66 66 ambient TC-17 ambient TC-19 ambient ambient

66

65 ambient 66 ambient 66 ambient 66 ambient 66 ambient 66

6766656565 ambient 66

65 666666 TC-20 TC-21 TC-22 TC-23 TC-24 TCS TCS 2 TCS 3 TCS 4 TCS 5 TCS 7 TCS 8

ambient ambient ambient ambient ambient

6666 TCS 9

ambient

66 TCS- 10

ambient

66 TCS 11

ambient

66 ambient 6666 TCS 12 TCS- 13 TCS 14 TCS- 15 6666 ambient ambient ambient TCS 16 Fluke Hand Held Fluke Hand Held 2 Fluke Hand Field 3

ambient

66 ambient 66 ambient 6666 ambient

65676665656566656566656567666666 Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes o Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes emperature tolerance within +/- 2 F of acceptable ranges for all thermocouples. Note: NIST Traceable Digital Thermometer

Serial Number 72083241 was used as reference temperature 90Calibration Date: ENTEC

Services,

lnc,
16-D Commerce Ave.Hueytown,

Alabama 35023
1/2/2007 Calibrated by:

Tom Lotz
Annual Hot Box Thermocouple

Calibrations

Entec Services

Temperature

**Reference

Thermocouple

Difference

W•thin ID Number

Source

Temperature

Temperature

Degrees F

Tolerance HOTBOX ambient HOTBOX 2

ambient HOTBOX 3

ambient

66

67 66 67 66 66 HOTBOX 4

ambient

66 HOTBOX 5

ambient

66 HOTBOX 6

ambient 6567 Yes Yes Yes Yes Yes 66 67 Yes HOTBOX 7

ambient

66

66

0

Yes HOTBOX 8

ambient

66

66

0

Yes 66 65 Yes 66 65 Yes 66 67 Yes 66 ambient ambient ambient 67 66 65 Yes Yes HOTBOX 9 HOTBOX 10 HOTBOX 11 HOTBOX 12

ambient HOTBOX 13

ambient HOTBOX 14

ambient

66

67 Yes Temperature tolerance within +/- 2 F of acceptable ranges for all thermocouples. Note: NIST Traceable Digital Thermometer

Serial Number 221243179 was used as reference temperature

91ENTEC Services,

inc. t6-D Commerce Ave,Huey•own,

Alabama 35023 Calibration Date:

1/2/2007 Calibrated by:
Annual Gooseneck

Thermocouple

Calibrations

......

Tom Lotz

Entec Services

Temperature

**Reference

Thermocouple

Difference

Within ID Number

Source

Temperature

Temperature

Degrees F

Tolerance GN-1 ambient GN-2 ambient GN-3 GN-4 GN-5

6464 ambient 64 ambient 64 ambient ambient ambient ambient 04646464 ambient 64 ambient 64 ambient ambient ambient 646464 ambient 64 ambient 64 ambient ambient ambient ambient ambient ambient ambient 6464646464

64

65 Yes 65 Yes 65656463636365646565636364656364 0 65656565 GN-6 GN-7 GN-8 GN-9 GN-10 GN-11 GN-12 GN-13 GN-14

Yes

GN-15 (Mini GN-16 (Mini GN-17 Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes GN-18 (Mini GN-19 (Mini HB) GN-20 (Mini HB) GN-21 GN-22 (Mini HB) 'emperature tolerance within +1- 2 F of acceptable ranges for all thermocouples. Note: NIST Traceable Digital Thermometer

Serial Number 221243179 was used as reference temperature

92Safety Documentation

94Pollution Control System Evaluation

and Source Emissions

Testing

Required PPE: (Check

Required) Hard Hat Steel Toed Boots Safety Glasses Ear Plugs Gloves / Hot Gloves Safety Harness

or Fall Protection Special Clothing

(Blues / Greens

/ Tyvex) CO Personnel

Monitor Respirator (w/PM or Gas Cartridges) Long Sleeve Shirt Other Requirements;

(List as needed) Attendees: Name (Print)

4)5)6)7)8)9) Facility required

additional

safety training

prior to entering

site: Video Safety Class•

Literature Yes or No Training Class (MSHA)
Rev 3:-3-06 95Test Nomenclature and

CalculationsNOMENCLATURE
A8AnACFM BwsCaCpAH APdscf EAE/Btu FKpMn

PbarP•PrnPMR PstdQa )

QsQstdTB•s mVlc TVwstd TmTstdV•cVmVnVmaVmstd vsVwcstd Vwsgstd Wimp W,• Y

Cross-sectional

area of stack, square feet Cross-sectional area of nozzle, square feet Actual cubic feet of gas per minute at stack conditions Proportion by volume of water vapor in gas stream Particulate concentration

in stack gas, gr/dscf Particulate concentration

in stack gas, gdacf Pitot tube coefficient Pressure drop across odfice meter, inches water Velocity head of stack gas, inches water Cubic feet of dry gas corrected

to standard

conditions Excess Air Particulate Emission

Rate, pounds/mmBtu F-factor, 9640 dscf/MMBTU's

of heat input Constant (85.49) Total particulate

matter collected,

mg Molecular weight of stack gas; dry basis, Ib/Ib-mole Molecular weight of stack gas; wet basis, Ib/Ib-mole Percent of isokinetic

sampling Barometric pressure,

inches mercury Stack static pressure,

inches of water Barometric pressure

of dry gas meter, in. mercury Particulate mass rate, pounds/hour Absolute stack gas pressure,

inches mercury Barometric pressure,

standard

conditions,

29.92 inches Hg Volumetric flow rate, actual conditions,

ACF/min Volumetric flow rate, standard

conditions,

scf/min Volumetric flow rate, dry standard

conditions,

dscf/min Theoretical water vapor in the gas stream based on saturated

stack conditions,

proportion

by volume (dimensionless) Theoretical volume of water collected

based on saturated

stack conditions,

ml Theoretical volume

of water vapor in the gas sample

based on saturated

stack conditions, corrected to standard

temperature

and pressure,

scf Absolute average

dry gas meter temperature,

degree R (460) Absolute average

stack gas temperature,

degree R (460) Absolute temperature

at standard

conditions,

528 R Total sampling

time, minutes Total volume collected

in impingers

and silica gel, gr Volume of gas sampled

through

gas meter, cubic feet Volume collected

at stack conditions

through

nozzle, ACF Stack gas volume sampled,

ACF Volume of gas sampled

through

gas meter, cubic feet Average stack gas velocity,

feet/sec Volume of water vapor in gas sampled

from impingers,

standard

cubic feet Volume of water vapor in gas sampled

from silica gel, standard

cubic feet Total volume collected

in impingers,

gr Total volume collected

in silica gel, gr Dry gas meter calibration

factor

97EQUATIONS 1.

P.= Pbar +(Po/13.6) 2. Pm= Pbar +(&H/13.6) 3. Vr•st,: 17.64 Vm Y (PnJTrn) 4a. Vwc(std)

004706

Wimp 4b. Vwsg(st,•)

0.04715

Wso 5. Bws Vw,l•/(Vrn,td

+ Vw,td) For saturated

sources

(No. 6 8 only): TEST

CALCULATIONS Kiln A- Run 1

0.04706*( 0.04715*( Z.gqq •, )/(
6i TBw• (10 637- {2827/(ts+365)}/Ps

10637-{2827/( TVwsta Vm•ta*( TBws/1- TBws) • TV•c= TVwstd/0.04707 +a•..l•/( )*(

)/( 1

)=

Md 0.44(%CO2)+0.32(%O2)+0.28((100-(%CO2+%O2)) 0.44(

,,•.,,•

)+0.32(

|•,,,•

)+0.28(100-(

12.

14.15.

23.

)+18/

.(b(o'tl

)= "Z,£. •cl 5(0

Qa= V, As "60

3 l•,#'l •?a

)( I•. I8• S

)(60)= ))
Q,= Qa* (528/Ts)*(Ps/29.92) )*(528/

)*(

/29.92) Qst• Qa (1- Bws) (528/Ts)*(Ps/29.92)

=('•"b•)•"•,,)(1-

o• )*(528/ ""•'•4 ./-" Cs=0.01543*(Mn/Vm,t•) 0.01543*(

(•.,•

•flo{•(•

)= E/Btu= (Cs/7000)*{(F•*20.9)/(20.9-%O2)} /7000)*{( )'20.9)/(20.9-( )}= %EA= 100%* {(%O2)-0.5*(%CO)}

/ {0.264(%N2)

(%02)+ 0.5*(%CO)} 100%*{( )-0.5(

)} / {0.264(

)-( •"•P/JV•= C: Qs,, (60/7000) °•O-C0"•)*(

•,4'•

•

)+0.5( )*(60/7000) Vn=TJPs*{(0.002669) V,c+ (Vm Y Pm)/mm)} "=1'•f4 •,•,11•1)*{(0.002669)( •,"• Ca=0.01543 (Mn/V,•)

0.01543*( :11• )( z•l. z•ze, )/( 555.5)} )= I=Vol00/(60*e*V,*A,) (i,•.25&%•t.)100/(60)( 60 )( •5.q$'lZ

)( .tbO• 5t::r#•)=

C•.I•

/

98NOMENCLATURE FOR

SULFUR

D OXIDES

(Method

6C)

ACECAvg CDirCGas CoCMCMA

CvCSDSBSBfinal SB• MWSO2 Ibs/hr 385.1 x 106

Analyzer

calibration

error, percent

of calibration

span. Average unadjusted

gas concentration

indicated

by recorder

for the test run, ppmv.

= Measured

concentration

of a calibration

gas (low, reed, high) when introduced

in direct calibration

mode, ppmv Average effluent gas concentration

adjusted

for bias, ppmv. Average of initial and final system calibration

bias(or 2-point system calibration error) check responses

form the low level (zero) calibration

gas, ppmv. Average of initial and final system calibration

bias (or 2-point system calibration error) check responses

for the upscale

calibration

gas, ppmv. Actual concentration

of the upscale

calibration

gas, ppmv.

= Measured

concentration

of a calibration

gas (low, mid, or high) when introduced

in system calibration

mode, ppmv. Manufactured certified

concentration

of a calibration

gas (low, mid, or high), ppmv. Calibration span, ppmv. Drift assessment,

percent

of calibration

span. System bias, percent

of calibration

span. Post-run system calibration

error, percent of calibration

span. Pre-run system bias, percent

calibration

span. Molecular weight of SO2, which is equal to 64.06 Sulfur Dioxide mass rate in pounds per hour Conversion factor

99Kiln A- Run 1

ACE (7E-1)

SB(7E-2)

D(7E-4) CDir C_•_ X 100 CS CS_ CDir X 100 CS
SBfinal SBil

)/( 2,%•o •

)x lOO

CGas (7E-5) (CAvg Co)X CMA/(CM

Co)

16. SO2 Ibs/dscf

Cg•s x MW 385.1 x 10 e (64.06)/(385.1

x 106)

17. SO2 Ibs/mmBTU=SO2

Ibs/dscf x F-factor x 20.9 / (20.9-02))

x x (20.9 / 20.9

))=

17. SO2 Ibs/mmBTU=SO

2 Ibs/hr/Heat

Input mmBTU/hr )/(
21. SO2 Ibs/hr

SO2 Ibs/dscf x DSCFM x 60

x (60)

100