From: Ron Myers/RTP/USEPA/US

To: "James Rickun" <jrickun@chorus.net>

Cc: armst@ix.netcom.com, David.McKeown@hanson.biz, Jeff

T elander/RTP/USEPA/US@EPA, paul.anderson@hanson.com, PTBAKER@mactec.com, Barrett Parker/RTP/USEPA/US@EPA, Peter Westlin/RTP/USEPA/US@EPA, Tom Driscoll@EPA, Rachel Agnew/RTP/USEPA/US@EPA

Date: 10/06/2010 09:30 AM Subject: Re: Hanson Brick MACT Test Information
Attachments: HansenBrickMine ral.xxx

James: I looked at the file HansenBrickMineral.aaa and thought it might be the mdb file that was blocked. I was able to open this file in the ERT but there are several problems with the information entered into the file
and as a result the emissions information is incorrect or can not be calculated. I do not know to what extent information that was not interfering with the calculation of the emissions needs revision. Here

are the issues that prevent the proper calculation of an emission s concentration or emissions rate.

1) Uncorrected emissions concentrations are not selected. As a result corrected emissions
concentrations can not be calculated. 2) The Mid point dry gas meter checks have the wrong values in the data block. The v alues that are to
be inserted in the two Mid point InitDGM and FinalDGM are the initial and final dry gas meter reading(s)
for the leak check (if there was one) conducted during port changes. The difference of these two values

is subtracted from the dr y gas volume measured for the total test. The values you have in those two blocks exceeds the total volume sampled. If no leak check was performed during port changes, then a "0" should be placed in both blocks.

In addition, there are three runs wh ich did not meet the method required isokinetic sampling rate. Runs

2 and 3 for Method 23 show an isokinetic rate of 78.2% and 78.9%. Run 2 of Method 29 shows an isokinetic rate of 88.9%. These are all outside the allowable range of 90 to 110%. This may be a problem with a missing or incorrect meter volume entry in the Point Data table for these three runs,

There are entries on all the Lab Data tables that do not make sense or are questionable. 1) For Method 23, the Comments field contains text "Below Detect", "less than" and "0.032504 ng/dscm @ 7% O2". The two detection descriptors should be placed in the Flag column using the acronym "BDL" for Below Detection Limits, "DLL" for Detection Lim it Limited (which in Method 23 should only be used for Total Dioxins, Total Furans or TEQ) or "ADL" for Above Detection Limit. It is not
clear what "less than" means. Is that an EMPC value supplied by the lab, or something else? The values
in Total Di oxins and Total Furans do not equal the sums of the listed dioxin and furans congeners and
are lower than I would think that the total dioxins and furans would be given the values for the individual congeners. The Mass for the Total Dioxins and Total F urans is the same as the values presented in the comments column when the calculated ng/dscm @ 7% O2 for those masses would be

0.0351

2) For Method 26A, there are comments of either < or a value with concentrations of ppm @7% O2. The

concentrations presented in the comment field do not agree with the ERT calculated concentrations corrected to 7% O2. The lab reports mass and not corrected stack concentrations. The detection limitsshould be reported in the same units reported by the lab. In addit ion, a short summary of how the laboratory determined the detection limit should be included in the comments column.

3) For Method 29, the comments column has the term "less than" without an indication of what this

term means. There should be an ind ication in the Flag column on whether this is a sample where all
fractions were BDL or only some fractions were below detection limit (use the Flag "DLL") or whether all
fractions were above the detection limit (use the Flag "ADL"). The comment column should then have
the individual fraction masses reported by the lab. In the comment field, fractions below detection limit should be bracketed with a < symbol before the value. Also, like with Method 26A, the comment field should include a short phras e indicating how the lab established the detection limit. While the
corrected concentrations presented in the comments field don't agree exactly with the values calculated by the ERT, they are close given the uncertainty of the point data and the header data entries.

I also noted that the Process Data show values of 0 for Brick Produced and Hydrate Lime Feed Rate for all nine runs. Also, there is no indication of which process run goes with which test method run. The comments field is the place that the test method and run number can be identified.

I assume that all the attachments were in the file that our e

- mail system stripped from your message. That includes the meter box calibrations, nozzle measurements or calibrations, pitot calibrations or measurements, diagram of the sampling location, field data sheets, lab report(s), chain of custody forms and a project narrative (since it is not included in any of the text fields)

I am returning a corrected copy of the file HansenBrickMineral.xxx which includes my corrections to the file so that the emissions are calculated by the ERT. I made the assumption that there was no leak check during port changes and I added the calculation of an uncorrected concentrat ion for all three test
methods.

_________________________________ Ron Myers U.S. Environmental Protection Agency Office of Air Quality Planning and Standards Sector Policy and Programs Division Monitoring Policy Group, D243

- 05

RTP NC 27711

Te l. 919.541.5407

Fax 919.541.1039

E

- mail myers.ron@epa.govFrom: "James Rickun" <jrickun@chorus.net>

To: Jeff Telander/RTP/USEPA/US@EPA

Cc: <David.McKeown@hanson.biz>, <paul.anderson@hanson.com>, Ron Myers/RTP/USEPA/US@EPA, <armst@ix.netcom.com>

Date: 10/05/2010 07:51 PM Subject: Hanson Brick MACT Test Information

Mr. Telander:

On behalf of Hanson Brick

– Mineral Wells, Texas, please find attached the information solicited by Peter Tsirigotis in a June 16, 2010 letter addressed to Mr. J. David McKeown the Regional Environmental Manager of Hanson Building Products America. Please review my cover letter first as it explains the difficulties we encountered in using the ERT Program. If you have any questions or need any additional information please e

- mail me.

Thank you

Jim

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