.%

POLLUTANT EMISSION

TESTING

OF ONE SCRUBBER CONTROLLING KILN EMISSIONS BRICK AND

TILE

CORPORATION OF LAWRENCEVILLE Lawrenceville,

Virginia

Prepared for: Brick and Tile Corporation

of Lawreneeville P.O. Box 45 Lawrenceville, VA 23868 Project No. 30-04004.00 September 13, 2004

Clayton Group Services 104. Towerview

Court Cary, NC 27513

COVER

PAGE SUPPLEMENTPlant

Name & Location: Brick and Tile Corporation

of Lawrenceville 16024 Governor

Harrison

Parkway

(US Hwy 58) Lawrenceville, VA 23868 Units Tested at Source:

• Tunnel Kiln 4 (ES-4-K)

and associated

Scrubber

(ES-4-SCRB). The inlet and exhaust of the scrubber

was tested for SO2 and I-IF using USEPA Methods

6C & 26 respectively.

The exhaust of the scrubber

was tested for HC1 using USEPA

Method

26.
Tester Name, Address

& Report Date: Clayton Group Services 104 Towerview

Court Cary, NC 27513 September 13, 2004

111Claytori

CONTENTS Section 1.0

INTRODUCTION

............................................................. 11 2.0 SUMMARY

OF RESULTS

................................................................................. 2.1 ES-4-SCRB

SULFUR

DIOXIDE

CONTROL

EFFICIENCY 2 2.2 ES-4-SCRB

HYDROGEN

FLUORIDE

CONTROL

EFFICIENCY 2

,• • v¢_a_¢c,uu

vlvI•Rt3CI•I,t•RIC

ACID EMISSIONS 2

4.0 SAMPLING

AND ANALYTICAL

PROCEDURES 3 4.1 EXHAUST

GAS COMPOSITION

AND FLOWRATE 3 4.2 SULFUR

DIOXIDE

EMISSIONS

............................................... 4 4.3 HYDROCHLORIC

ACID/HYDROGEN FLUORIDE

EMISSIONS 4 Limitations .................................................................................................. 5 Tables 123 Scrubber

SO2 Control Efficiency

and Emissions Scrubber HF Control Efficiency

and Emissions Scrubber HC1 Emissions Figures 1 Scrubber

Inlet and Outlet Sampling

Locations 2 USEPA

Methods

6C/10 Sampling

Train 3 USEPA

Method

26 Sampling

Train Graphs 1 Kiln Scrubber

SO2 Inlet/Outlet

Emissions

Compliance

Testing Run 1 2 Kiln Scrubber

SO2 Inlet/Outlet

Emissions

Compliance

Testing Run 2 3 Kiln Scrubber

SO2 Inlet/Outlet

Emissions

Compliance

Testing Run 3

V•'•Claytoff

1.0 INTRODUCTION Brick and Tile Corporation

of Lawrenceville

(Brick & Tile Corp.) retained

Clayton

Group Services (Clayton)

to conduct

the following

testing at its facility in Lawrenceville,

VA: 1. Testing of Kiln 4 (ES-4-K)

and its scrubber

(ES 4-SCRB)

consisting

of:

a. control efficiency

(CE) testing for sulfur dioxide

(SO2) and hydrogen fluoride (HF) based on control device inlet and outlet testing; and b. emissions

testing of sulfur dioxide

(SO2), hydrogen

fluoride

(HF), and hydrochloric acid (HC1).

be submitted

to the Commonwealth

of Virginia

Department

of Environmental

Quality (CVDEQ) to determine

compliance

with conditions

of Air Permit Registration

No. 30872. Messrs.

Mark R. Grigereit,

Manager;

Barry Boulianne,

Project Manager;

Thomas Schmelter, Environmental

Consultant;

and Fred Meinecke,

Environmental

Technician

[[ with Clayton,

performed

the testing on August 11 and September

2-3, 2004 United States Environmental

Protection

Agency

(USEPA)

Methods

1-4, 6C, and 26 from the Code of Federal

Regulations,

Title 40, Part 60, Appendix

A (40 CFR 60, Appendix A) were utilized for the completion

of this project.

Mr. Dale Overcash,

P.E., Director, Air Quality Services

with Clayton's

Raleigh

Regional

Office, provided

technical assistance for this study. Messrs.

Leon F. Williams,

llI, Senior Vice President Production, and Darren Talbert,

Mining Engineer,

both with Brick & Tile Corp., provided technical and process

operation

assistance

for this study. Mr. Denis Schmidt, Environmental Compliance

Specialist,

Sr., with CVDEQ

Piedmont

Regional

Office, observed the testing. The above testing was conducted

to supplement

the testing that was conducted

on June 15 and 16, 2004. During the June testing, the dry hydrated

baghouse

experienced

a malfunction that had a direct affect on the HF and HC1 test results and which might have possibly affected

the SO2 test results.

The results of the June test and the malfunction were discussed

in a meeting

with CVDEQ

staff in a meeting

at the CVDEQ

offices on July 27, 2004. The above referenced

testing completes

all permit testing requirements.

2.0 SUMMARY

OF RESULTS Brick & Tile Corp. has installed

a dry hydrated

baghouse

(i.e., referred

to herein as the scrubber, ES-4-SCRB)

to control HF emissions

from one runnel kiln (ES-4-K).

Due to its design, some minimal

SOz removal

is also expected

from the scrubber. The emissions

testing conducted

at the Lawrenceville

facility was performed

on emission source ES-4-K

(and its control device ES-4-SCRB)

utilizing

United States Environmental Protection Agency

(USEPA)

Methods

1-4, 6C, and 26. It is important

to note thatClaytor emission rate calculations

have been adjusted

to account

for damper valve closures

that occur in the kiln approximately

every 24 minutes

and for a duration

of approximately

five (5) minutes.

Additionally,

the HF and HC1 testing performed

on August 11, 2004 was considered void due to laboratory

analytical

errors. The results of that testing are not included in this report; however,

the field and computer

generated

data sheets can be found in Appendix

B. Example

calculations

are located in Appendix

A. Refer to Appendix D for the Brick and Tile Corporation

Raw Production

Data. The following

table provides

a summary

of the results of the emissions

testing completed and allowable

emission

limits as outlined

in the Brick and Tile Corporation

of Lawrenceville permit registration

number

30872: Emission Unit ID # ES-4-SCRB Parameter Allowable

Emissions Test Results SO: Control Efficiency 30% 29.6% SO2 Emission

Rate 6.9 lbs/hr 2.56 lbs/hr I-IF Control Efficiency 90% 99.1% HF Emission

Rate 1.2 lbs/hr 0.106 lbs/hr HCL Emission

Rate

0.83 lbs/hr 0.024 lbs/hr HCL Emission

Rate

0.056 lb/tons fired brick

0.0019 lb/ton fired brick 2.1 ES-4-SCRB

SULFUR

DIOXIDE

CONTROL

EFFICIENCY

AND EMISSION RATE The scrubber

was tested for SO2 control efficiency

and outlet emissions.

The SO2 results for the three tests performed

on August 11, 2004, reported

an average

control efficiency of 29.6% and an emission

rate of 2.56 pounds per hour (lb/hr) (see Table 1 for individual test results). S02 run graphs associated

with the USEPA

Method

6C testing can be viewed in the attached graph section of this report. The kiln damper cycle data is available

in Appendix D. Calibration

data and graphs associated

with the USEPA

Method

6C testing can be viewed in Appendix

E. 2.2 ES-4-SCRB

HYDROGEN

FLUORIDE

CONTROL

EFFICIENCY

AND EMISSION RATE The scrubber

was tested for HF control efficiency

and outlet emissions.

The HF control efficiency test results averaged

99.1% for the three tests performed

on September

2-3, 2004. The average HF emission

rate was 0.106 pounds per hour (see Table 2 for individual test results).Claytori The I-IF field and computer-calculated data sheets for the USEPA

Method

26 testing conducted at the Lawrenceville

facility are presented

in Appendix

B. The USEPA Method 26 laboratory

results are presented

in Appendix

C. Calibration

data sheets associated with the USEPA

Method

26 testing can be viewed in Appendix

E. 2.3 ES-4-SCRB

HYDROCHLORIC ACID EMISSIONS The tunnel kiln (and scrubber)

was tested for HC1 emissions.

The HC1 emission

test results averaged

0.024 lbs/hr (and 0.0019 lb HC1/ton

of fired brick) for the three tests performed on September

2-3, 2004 (see Table 3 for individual

test results).

Inlet testing, which was not part of the CVDEQ

requirements,

was performed

and the inlet emission rates were 0.391 lb/hr (and 0.031 Ib HC1/ton

of fired brick).

conducted at the Lawrenceville

facility are presented

in Appendix

B. The USEPA Method 26 laboratory

results are presented

in Appendix

C. Calibration

data sheets associated with the USEPA

Method

26 testing can be viewed in Appendix

E.

3.0 SITE DESCRIPTION Brick & Tile Corporation

of Lawrenceville

is a brick manufacturing

facility.

The testing

was performed

on the new tunnel kiln at Plant 4. The kiln production

rate was 12.77 tons of fired brick per hour.

4.0 SAMPLING

AND ANALYTICAL

PROCEDURES 4.1 EXHAUST

GAS COMPOSITION

AND FLOWRATE USEPA Methods

1 and 2, from the Code of Federal

Regulations,

Title 40, Part 60, Appendix A (40 CFR 60, Appendix

A), were used to determine

the number

of traverse points and to perform

velocity

profile measurements.

See Figure 1 for a presentation

of the test port and traverse/sampling

point locations

for the inlet and outlet of the Kiln Scrubber. An S-type pitot ® tube and thermocouple

assembly,

calibrated

in accordance with USEPA

Method

2, Section 4.1.1, was used to measure

exhaust gas velocity pressures and temperatures

during testing.

Because

the dimensions

outlined

in Sections 2-6 through

2-8 were within the specified

limits, the baseline

pitot ® tube coefficient

of 0.84 (dimensionless)

was assigned. Molecular weight determinations

were evaluated

according

to USEPA

Method

3, "Gas Analysis for the Determination

of Dry Molecular

Weight."

The equipment

used for this evaluation consisted

of (1) a stainless-steel

probe of sufficient

length to reach the centroid of the duct, (2) a one-way

squeeze

bulb with connecting

tubing, and (3) a set of Fyrite ® combustion gas analyzers.

Carbon dioxide

and oxygen content were analyzed

using the Fyrite ® procedure

at the scrubber

inlet and outlet.•Claytor• During

the preliminary

traverse,

moisture

content was approximated

using thewetbulb/dry-bulb method described

in USEPA

Method 4, "Determination

of Moisture Content in Stack Gases."

Actual moisture

contents

were derived from each Run 1-3 through USEPA

Method

4 analysis

in conjunction

with inlet/outlet

USEPA

Method

26 performance. Raw field and computer

generated

data sheets are available

in Appendix

B. 4.2 SULFUR

DIOXIDE

EMISSIONS The sulfur dioxide content of the scrubber

inlet and outlet gas streams were evaluated according to procedures

outlined

in USEPA

Method

6C, "Determination

of Sulfur Dioxide Emissions

from Stationary

Sources

(Instrumental

Analyzer

Procedure)." The SO2 content of the gas stream was measured

using a Western

Research

SO2 gas analyzer (see Figure 2 for a schematic

of the sampling

train). A sample of the gas stream was drawn through

an insulated

stainle•-steel

probe with an in-line glass fib•er filter to remove any particulate,

a heated Teflon • sample line, through

a cold Tefion

impinger train with a peristaltic

pump to remove the moisture

from the sample before it entered the analyzer. Data was recorded

at 4-second

intervals

on a Dell PC equipped

with Labview

® data acquisition

software.

Triplicate,

1-hour tests were performed

on the scrubber

inlet and outlet at the normal high load. Prior to each test run, the analyzer

was calibrated

using known concentrations

of calibration gases, prepared

in accordance

with USEPA

Protocol

1 procedures.

Athreepoint (zero, mid, and high) calibration

check was performed

on the SO2 analyzer. Calibration drift checks were performed

at the completion

of each run. Calibration

data and graphs can be viewed in Appendix

E. Analyzer system bias and response

times were conducted

at the beginning

of each test. A sample of the high-range

calibration

gas was sent directly from the gas cylinder

to the probe tip and allowed

to past through

the sample system.

The time required

for the system to respond

to the calibration

gas was monitored.

System bias was also recorded

at this time. The bias for the system met the limit of + 5% of the calibration

gas value. 4.3 HYDROCHLORIC ACID/HYDROGEN FLUORIDE

EMISSIONS The HC1 and HF content of the scrubber

inlet and outlet gas stream was evaluated according to procedures

outlined

in USEPA

Method

26, "Determination

of Hydrogen Halide and Halogen

Emissions

from Stationary

Sources

(non-isokinetic

method)

(see Figure 3 for a schematic

of the sampling

train). The Method

26 sampling

train consists

of: (1) a borosilicate

or quartz glass probe liner; (2) a borosilicate

or quartz glass filter holder containing

a 110-mm

diameter

washed quartz filter with Teflon filter support;

(3) a set of five Greenburg-Smith

(GS) impingers with the first and second standard

GS impingers

each containing

100 ml of 0.1 Normality Sulfuric Acid (0.1 N H2SO4),

the third and fourth impingers

each contain 100 ml of 0.1 Normality Sodium Hydroxide

(NaOH),

and a fifth modified

GS impinger

containing

a

4,Claytori known weight of silica gel desiccant;

(4) a length of sample line, and (5) a Nutech control case equipped

with a pump, dry gas meter, and calibrated

orifice.

Prior to assembly

of the inlet Method

26 train, an impinger

was found to be broken.

The inlet Method

26 train was modified

and set up with the first two impingers

containing

I00 ml of the H2SO4 solution, the third contained

200 ml of the NaOH solution

and the fourth contained

silica gel desiccant.

The modified

inlet Method

26 train was approved

by Mr. Denis Schmidt, Environmental Compliance

Specialist,

St., with CVDEQ

Piedmont

Regional

Office. After completion

of the final leak test for each test run, the impinger

train was carefully disassembled. The liquid volume of each impinger

was measured

in a graduated

cylinder and any volume increase

was noted on field sheets. The impinger

catch solution

was then transferred to pre-cleaned

sample containers.

The first two impingers

were then triple rinsed with deionized

water (DI H20), and the rinses were added to the H2SO4 sample •^-'•: "'^ ":-• tripi •1• uu,u •uu .,.uu•u.• xmpmgers

were then

e rinsed with Di H20 and the rinses were added to the NaOH sample container.

Sodium

thiosulfate

is added to the NaOH sample containers

to ensure reaction

with the hypohalous

acid to form a second halide ion such that 2 halide ions are formed for each molecule

of halogen

gas. The containers were labeled with the test number,

test location,

test date, and the level of liquid was marked on the outside of each container.

Immediately

after recovery,

the sample containers

were placed in a sealed cooler for storage.

All samples

were transported by Clayton personnel

to Clayton's

Novi, Michigan

laboratory

and all analyses were performed

by Clayton's

Novi, laboratory.

Laboratory

analytical

data can be found in Appendix C.Claytor/

Table 1 Scrubber SO2 Control Efficiency

and Emissions USEPA Method 6C Results Brick & Tile Corporation

of Lawrenceville Lawrenceville, Virginia Clayton Project No. 30-04004.003 Sampling Date: August 11, 2004

Normal Load Parameter Run 1 Sampling Start Time Molecular Weight (SO2) Inlet Flowrate (dscfm) Average Inlet SO 2 Concentration

(ppmv) Average Inlet SO 2 Concentration

(ppmv, corrected)

2 Inlet SO2 Mass Emission

Rate (lb/hr) Outlet Flowrate (dscfm) Average Outlet SO2 Concentration

(ppmv) Average Outlet SO2 Concentration

(ppmv, corrected) Outlet SO2 Mass Emission

Rate (lb/hr) SO2 Control Efficiency

(%) 11:35-12:35 64.07 23,930 14.014.23.37 20,384 11.811.72.3729.7

Run 2
12:53-13:53 64.07 23,315 14.214.13.27 20,809 11.911.72.4325.8

Run 3
14:11-15:31" 64.07 24,545 17.617.84.34 20,448 14.214.22.8933.2 Average

64.07 23,930 15.315.33.66 20,547 12.612.62.5629.6

Run inlet flowrate was taken at time of dumper adjusting (I 5,875dscf) therefore, the flow average of runs 2 and 3 was used. corrected for analyzer drift as per USEPA Method 6C testing was halted fi'om 14:25-14:45

due to down impinger peristalic pump SO2 sulfur dioxide ppmv parts per million on a volume-to-volume

basis dsefm dry standard cubic feet per minute lb/hr pounds per hour equations:lb/hr dscfm*ppmv*(molecular

weight/24.14)'0.000003746 control efficiency % (inlet lb/hr outlet lb/hr) inlet lb/hr * 100Table 2 Scrubber HF Control Efficiency

and Emissions USEPA Method 26 Results Brick & Tile Corporation

of Lawrenceville La.wrenceville, Virginia Clayton Project No. 30-04004.003 Sampling Date: September

2-3, 2004 Claytori

Test Number HF-

HF-2

HF-3

Average Sampling Date Sampling Time Damper Valve Closed During Test (min) Inlet Flowrate (dscfm) Inlet Sample Volume (Vm-Std ft3) Inlet HF weight (mg) Inlet HF concentration

(mg/dsct) Inlet HF mass emissions rate (lb/hr) Actual Inlet HF mass emission rate (lb/hr) Outlet Flowrate (dscfm) Sept. 2, 2004 16:48-17:48 1018,988 42.925O5.830 14.64 12.20 20,740

Sept. 2,2004 19:21-20:21 1019,528 41.82505.979 15.44 12.87 19,528

Sept. 3,2004 7:45-8:45 1219,509 43.12505.797 14.96 11.97 19,509

19,342 42.62505.869 15.014 12.345 19,926 Outlet Sample Volume (Vm-Std ft3) Outlet HF weight (mg) ;Outlet HF concentration

(mg/dscf) Outlet HF mass emissions rate (lb/hr) Actual Outlet HF mass emission rate (lb/hr) HF Control Efficiency

(%) 42.91.70 0.040 0.109 0.09199.3

41.82.30 0.055 0.142 0.11899.1

43.12.30.053 0.138 0.11099.1

42.62.10.049 0.129 0.106 Average Control Efficiency

(%) actual emission value is calculation

based on actual time emissions are occuring equation: actual emissions

mass emission rate (lb/hr) * (60 min damper closed time in min) 60 min dsefm dry standard cubic feet per minute mg/dscf milligram per dry standard cubic feet lb/hr pound per hour HF hydrogen fluoride 99.1

Equations lb/hr (mg/scf) / 1000 * 15.43 * (scfrn* 60/7000) Efficiency [(lbs/hr inlet Ibs/hr outlet)/lbs/hr

inlet] * 100Table 3 Scrubber HCI Emissions USEPA Method 26 Results Brick & Tile Corporation

of Lawrenceville Lawrenceville, Virginia Clayton Project No. 30-04004.00 Sampling Dates: September

2-3, 2004 . . Claytori

Test Number Sampling Date Sampling Time Damper Valve Closed During Test (rain) Inlet Flowrate (dscfm) Inlet Sample Volume (Vm-Std fL3) Inlet HCL weight (mg) Inlet HCL concentration

(mg/dsc0 Inlet HCL mass emissions rate (lb/hr) Actual Inlet HC1 mass emission rate (lb/hr) Outlet Flowrate (dscfm) Outlet Sample Volume (Vm-Std ft3) Outlet HCI weight (mg) Outlet HCI concentration

(mg/dscf) Outlet HCI mass emission rate (Ib/hr) Actual Outlet HCI mass emission rate (lb/hr)

HCI-I Sept. 2,2004 16:48-17:48 I018,988 4297.800.182 0.457 0.381 20,740 41.7 <0.44

HCI-2 Sept. 2,2004 19:21-20:21 1019,528
417.60 0.182 0.469 0.391 20,827 44.1 <0.44

HCL Control Efficiency

(%) 0.011 0.029 0.024 93.7

0.010 0.028 0.02394.1

HCI-3 Sept. 3, 2004 7:45-8:45 1219,509
438.40 0.195 0.503 0.402 23,267 44.6 <0.44 0.010 0.030 0.02494.0 Average Mass Emission Rate (Ib/hr) Average Actual Mass Emission Rate (Ib/hr) actual emission value is calculation

based on actual time emissions are occuring equation: actual emissions

mass emission rate (lb/hr) * (60 min damper closed time in min) 60 min dscfm dry standard cubic feet per minute mg/dscf= milligram per dry standard cubic feet lb/hr pound per hour HCI hydrochloric

acid CE control efficiency Equations lb/hr (mg/scf)/1000

* 15.43 * (scfm* 60/7000) CE% (inlet lb/hr-outlet

lb/hr)/inlet lb/hr*100 Average

19,342
47 fi 7.93 0.186 0.476 0.391 21,611 43.5<0.44 0.010 0.029 0.02493.9 0.029 0.024Stack Walll

h su •ted Stainless Steel Probe

Air 2-Way Valve

Sample Conditioner

4-Way Valve /

Low Mid Hi Calibration Gases Exhaust Sample • SO2.Analyzer

Data Acquisition

System w/Labview Sol'tware

Method 6C Sampling Brick and Tile Corporation of Lawrence[ Lawrence, Virginia

Brick and Tile Corporation

of Lawrence Lawrence, Virginia Project No. 30-04004.00

I L•t Revision SeplemberV•

USPEA

Method 26 Sampling Train

,•_.__-• GROUP SERVIC•ZS

I ]• Brick and Tile Corporation

of 15riCK an(] llle II Corporation of LawrencelV• Lawrence, Viruinia

•

4 4 0 Lasl Revision Project No 30 0 00 012:35:43

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13:27:39 13:25:39 13:23:39 13:21:39 13:19:39 13:17:39 13:15:39 13:13:39 13:11:39 13:09:39 13:07:39 13:05:39 13:03:39 13:01:39 12:59:39 12:57:39 12:55:39 12:53:39Amdd •ol•n 0 puu •OlUI ZOS

15:31:07 15:29:07 15:27:07 15:25:07 15:23:07 15:21:07 15:19:07 15:17:07 15:15:07 15:13:07 15:11:07
15:07:07 15:05:07 15:03:07 15:01:07 14:59:07 14:57:07 14:55:07 ._• 14:53:07 • 14:51:07 • 14:49:07 • 14:47:07 14:45:07 14:43:07 14:41:07 14:39:07 14:37:07 1.4:35:07 14:33:07 14:31:07 14:29:07 14:27:07 14:25:07 14:23:07 14:21:07 14:19:07 14:17:07 14:15:07 14:13:07 14:11:07APPENDIX D RAW PRODUCTION

DATA