.% 

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 SUPPLEMENT 
Plant 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 

111 
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CONTENTS 

Section 

1.0 INTRODUCTION ............................................................. 

1 

1 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 

1 

2 

3 

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 that 
 Claytor 

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). 
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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 the wetbulb/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. A threepoint (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 •^-'•: "'^ 

•1• 

":-• 

uu,u •uu .,.uu•u.• xmpmgers were then tripi 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 

14.0 

14.2 

3.37 

20,384 

11.8 

11.7 

2.37 

29.7 

Run 2 

12:53-13:53 

64.07 

23,315 

14.2 

14.1 

3.27 

20,809 

11.9 

11.7 

2.43 

25.8 

Run 3 

14:11-15:31" 

64.07 

24,545 

17.6 

17.8 

4.34 

20,448 

14.2 

14.2 

2.89 

33.2 

Average 

64.07 

23,930 

15.3 

15.3 

3.66 

20,547 

12.6 

12.6 

2.56 

29.6 

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 * 100 
Table 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 

10 

18,988 

42.9 

25O 

5.830 

14.64 

12.20 

20,740 

Sept. 2,2004 

19:21-20:21 

10 

19,528 

41.8 

250 

5.979 

15.44 

12.87 

19,528 

Sept. 3,2004 

7:45-8:45 

12 

19,509 

43.1 

250 

5.797 

14.96 

11.97 

19,509 

19,342 

42.6 

250 

5.869 

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 (%) 

42.9 

1.70 

0.040 

0.109 

0.091 

99.3 

41.8 

2.30 

0.055 

0.142 

0.118 

99.1 

43.1 

2.3 

0.053 

0.138 

0.110 

99.1 

42.6 

2.1 

0.049 

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] * 100 
Table 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 

I0 

18,988 

429 

7.80 

0.182 

0.457 

0.381 

20,740 

41.7 

<0.44 

HCI-2 

Sept. 2,2004 

19:21-20:21 

10 

19,528 

41 

7.60 

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 

0.023 

94.1 

HCI-3 

Sept. 3, 2004 

7:45-8:45 

12 

19,509 

43 

8.40 

0.195 

0.503 

0.402 

23,267 

44.6 

<0.44 

0.010 

0.030 

0.024 

94.0 

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 

0.024 

93.9 

0.029 

0.024 

Stack 

Wall 

l 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 

Seplember 
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USPEA Method 26 Sampling 

Train ,•_.__-• GROUP SERVIC•ZS I 

]• Brick and Tile Corporation of 

15riCK an(] llle II 

Corporation of LawrencelV• Lawrence, Viruinia • 

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APPENDIX D 

RAW PRODUCTION DATA