From: Ron Myers/RTP/USEPA/US 

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

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

Telander/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: HansenBrickMineral.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 emissions 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 values 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 dry 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 which 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 Limit 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 Dioxins 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 Furans 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 limits 
should be reported in the same units reported by the lab. In addition, 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 indication 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 phrase 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 concentration 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 

Tel. 919.541.5407 

Fax 919.541.1039 

E-mail myers.ron@epa.gov 
From: "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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