Date: November 6, 2014

To: Jeff Telander, EPA/OAQPS/SPPD

From: Gabrielle Raymond, RTI International

Subject: Test Data Used in BSCP Proposed Rule

I. Introduction

In accordance with section 112 of the Clean Air Act (CAA), the U.S. Environmental 

Protection Agency (EPA) established national emission standards for hazardous air pollutants 

(NESHAP) on May 16, 2003, for the brick and structural clay products (BSCP) manufacturing 

industry. The NESHAP regulated emissions of hydrogen fluoride (HF), hydrogen chloride 

(HCl), and particulate matter (PM)—a surrogate for hazardous air pollutant (HAP) metals—from 

tunnel kilns located at BSCP facilities. On March 13, 2007, the D.C. Circuit Court vacated the 

emission standards for BSCP manufacturing due to issues associated with the methodology used 

to determine the minimum regulatory “floors” for new and existing units.

1 Therefore, the EPA is 

proposing new standards for BSCP manufacturing, including limits for HF, HCl, chlorine (Cl2), 

mercury (Hg), and non-Hg metals (or PM surrogate). The purpose of this memorandum is to 

describe the sources of test data obtained for BSCP tunnel kilns and dryers and considered in the 

BSCP rulemaking and to describe the quality assurance/quality control (QA/QC) checks 

performed on the data.

II. Sources of Data

The main sources of test data were responses to the 2008 and 2010 section 114 surveys to 

the BSCP industry (described in the remainder of this section), test data in the BSCP Legacy 

Docket A-99-30, and test reports that the Brick Industry Association (BIA) sent to the EPA to 

provide test data for facilities not covered by the section 114 surveys. Copies of all the test 

reports collected from these sources are included in Docket ID No. EPA-HQ-OAR-2013-0291.

The EPA conducted two surveys under the authority of section 114 of the CAA. In June 

2008, the EPA sent out a survey to nine BSCP companies—Acme Brick, The Belden Brick Co., 

Boral Bricks, Inc., Carolina Ceramics Brick Co., General Shale Brick, Inc., Glen-Gery Corp., 

Hanson Building Products America, Morin Brick Co., and Taylor Clay Products, Inc. (Tsirigotis, 

2008). The survey was designed in the form of a Microsoft Excel® spreadsheet file that 

 1 Sierra Club v. EPA, 479 F.3d 875 (D.C. Cir. 2007).
2

included seven different worksheets to complete. The main intention of the survey was to collect 

inventory information about the kilns at those nine companies. Although the 2008 survey did not 

require any new testing to be performed, the “Form D - Test Data” worksheet in the survey asked 

for information on emission tests previously performed on kilns at the facilities and asked each

facility to submit complete copies of the reports for these emission tests. The test reports 

received contained results for HF, HCl, Cl2, and filterable PM.

In 2010, the EPA sent out another section 114 survey to nine BSCP companies. The 

survey was sent out in two phases. Phase I of the survey was sent out to three companies (The 

Belden Brick Co., Boral Bricks, Inc., and Hanson Building Products America) and required 

testing of HF, HCl, Cl2, PM filterable, HAP metals including Hg, and dioxin/furan emissions 

from tunnel kilns and testing of dioxin/furan emissions from dryers (Tsirigotis, 2010a-c). Phase 

II of the survey was sent out to six companies (Acme Brick, General Shale Brick, Inc., GlenGery Corp., Interstate Brick, Jenkins Brick and Tile Company, and Taylor Clay Products, Inc.) 

and required testing of HF, HCl, Cl2, PM filterable, and HAP metals emissions from tunnel kilns

(Tsirigotis, 2010d-i). Instead of performing new stack tests, Interstate Brick and Jenkins Brick 

requested permission to submit historical results of tests previously conducted at the facilities

(Gunning, 2011; Sims, 2011), and the EPA granted the request (Telander, 2011a,b).

III. Data Compiled and Calculations Conducted from Test Reports

From each test report, the following parameters and emissions data for each test run were 

compiled into a master run-by-run spreadsheet:

• Production rate, in tons per hour (tph)

• Flow rate, in actual cubic feet per minute (acfm)

• Flow rate, in dry standard cubic feet per minute (dscfm)

• Sample volume, in dry standard cubic feet (dscf)

• Sample volume, in dry standard cubic meter (dscm)

• Stack moisture, in percent (%)

• Stack gas temperature, in degrees Fahrenheit ( ̊F)

• Oxygen content of stack gas, in percent (%)

• Pollutant concentration, in parts per million (ppm), milligrams per dry standard cubic 

meter (mg/dscm), grains per dry standard cubic foot (gr/dscf), etc.

• Pollutant emission rate, in kilograms per hour (kg/hr), pounds per hour (lb/hr), etc.

Once the data were compiled, the following calculations were conducted in the master 

run-by-run spreadsheet:

• Converted reported concentrations to micrograms per dry standard cubic meter (μg/dscm)

• Corrected reported concentrations to 7 percent oxygen (% O2) using the following 

equation: ( ) 2 Tested % O2 μg/dscm@7% O = μg/dscm×13.9 ÷ 20.9 −

• Calculated emissions in pounds per ton (lb/ton) using emission rate (lb/hr) and production 

rate (tph)
3

IV. Quality Assurance/Quality Control Checks

After the test data had been compiled and calculated in the master run-by-run 

spreadsheet, there were three rounds of QA/QC with BIA and internal QA/QC from RTI and the

EPA. Test data determined to be unacceptable after the QA/QC checks were removed from the 

run-by-run spreadsheet and were not included in the calculation of MACT floors. See Appendix 

A for the list of test data that were removed from the run-by-run spreadsheet after the QA/QC 

checks. See Appendix B for the run-by-run test data that were used in the calculation of MACT 

floors.

A. BIA QA/QC

The BIA provided their first round of comments on a subset of the test data in a 

memorandum dated June 5, 2009 (Kuo et al., 2009a). The BIA retained the services of Mr. Mike 

Hartman of Air-Tech Environmental, LLC to review the test reports submitted to the EPA. Mr. 

Hartman’s review included comparison of the sampling and analysis approach used in the stack 

tests to the approach required by the reference method, as well as insights from his experience as 

a stack tester. The review results were presented in three groups:

• Tests that BIA believed should be removed immediately from the EPA’s database used to 

establish a MACT standard due to documented issues with the test methodology or 

results.

• Tests that warranted additional review due to concerns that proper procedures were not 

followed, either during the testing or the analytical process.

• Tests that appeared to be incorrectly presented in the EPA’s summary table.

The memorandum from BIA was reviewed with the corresponding test data, and 

revisions were made to the test data set. For acid gas tests where a glass fiber filter was used, the 

results were removed from the test data set. For acid gas tests where the probe and filter 

temperature were not maintained at the proper temperature per the test method instructions, the 

results were removed from the test data set. In both of the above cases, the PM data were 

retained, as errors in the acid gas testing methodology did not affect the PM results. The data for 

any tests that were rejected by the local or state agency were also removed from the test data set.

The BIA provided a second round of review on the remaining test data in a memorandum

dated September 4, 2009 (Kuo et al., 2009b). The purpose of the memorandum was to present 

the review of the remaining test reports not addressed in the first round of comments, as well as 

to present BIA’s comments on the EPA’s conclusions regarding BIA’s first memorandum (Kuo

et al., 2009a).

The second memorandum from BIA was reviewed with the corresponding test data, and 

revisions were made to the test data set. Similar to the review of the first memorandum, acid gas 

data were removed for tests where a glass fiber filter was used or where the probe and filter 

temperature were not maintained at the proper temperature per the test method instructions (the 

PM data were retained). For PM tests where the testing contractor or laboratory noted a ripped 

filter, the data were removed from the test data set. For tests where the testing contractor or 

laboratory indicated non-detect values, the data were not removed, but the run was flagged with 
4

a “<”. For tests that were run at “extreme feed type conditions,” defined as 100 percent fireclay 

raw material, the data were removed as not representative of normal operation. Results for total 

fluorides measured with EPA Method 13B were not removed from the test data set if they were 

the only results representative of HF available for that source. Other revisions included 

correcting calculation errors or misinterpreted test data that the BIA explained and revising

production rates with values BIA provided.

The BIA provided their third round of review in a memorandum dated December 12, 

2012 (Kuo and Miller, 2012). The purpose of the memorandum was to present specific changes 

and/or updates to the EPA’s BSCP MACT floor ranking database. Several changes had occurred 

in the BSCP industry since the industry’s section 114 survey submittals, including acquisitions, 

closures, and new test data. The BIA provided two acquisition updates and a table listing

demolished and/or decommissioned kilns. The BIA also revisited a few test reports from the 

June 5, 2009 memorandum (Kuo et al., 2009a) and provided updated information regarding 

facility status, control technology, and emission factors.

The third memorandum from BIA was reviewed with the corresponding test data, and 

revisions were made to the inventory and test data set. The BSCP kiln inventory was updated 

with the new acquisition, facility status, and control technology updates (Holloway, 2014). Test 

data from kilns identified as being demolished and/or decommissioned were removed. Any 

applicable data errors identified by the BIA were revised. For tests where the testing contractor 

or laboratory indicated non-detect values, the data were not removed, but the run was flagged 

with a “<”. The source classification for facilities that changed status (e.g., major source,

synthetic area source) was also revised.

B. Internal QA/QC

1. Mercury and Non-Mercury HAP Metals

In the internal QA/QC of the test data, inconsistencies were found between the Hg and 

individual non-Hg HAP metal values reported in the summary pages of certain test reports and 

the values reported in the laboratory sections of the test reports. Therefore, the Hg and non-Hg 

HAP metal values were reviewed for correctness, starting from the laboratory results. 

Specifically, the laboratory reports were reviewed to extract and compile the mass values for five 

Hg fractions and two non-Hg HAP metal fractions (see list below), the blank fractions, and the 

method detection limits (MDLs), or other reporting limit if MDLs were not available.

• Front Half (Hg & non-Hg HAP metal), Fraction 1: Container 1 Filter, Container 2 

Acetone Probe Rinse, Container 3 Acid Probe Rinse

• Back Half (Hg & non-Hg HAP metal), Fraction 2B: Container 4 HNO3/H2O2 (Nitric 

Acid/ Hydrogen Peroxide) Impingers

• Back Half (Hg Only), Fraction 3A: Container 5A HNO3

• Back Half (Hg Only), Fraction 3B: Container 5B KMnO4/H2SO4 (Potassium 

Permanganate/Sulfuric Acid) Absorbing Solution

• Back Half (Hg Only), Fraction 3C: Container 5C HCl Rinse and Dilution
5

The Hg and other HAP metal values were recalculated from the laboratory data and blank 

corrected when necessary in accordance with EPA Method 29 guidelines. These are the values 

included in Appendix B for Hg and non-Hg HAP metals data.

2. Manganese Contamination

The 2010 section 114 survey test request included BSCP tunnel kiln Hg testing 

concurrent with non-Hg HAP metal testing using EPA Method 29. There is a possibility of the 

back half fraction (Fraction 2B) for manganese (Mn) being contaminated from the permanganate 

used in Fraction 3B for Hg sampling. To check for Mn contamination, the ratio of the back half 

Mn mass to the front half Mn mass was calculated. If the ratio was over 5, that test run was 

assumed to have Mn contamination. The test runs with Mn contamination were removed from 

the data set. If it was determined that only one test run from a particular test for a source was not 

contaminated, the entire test was removed. The following table indicates the test runs that were 

removed from the BSCP tunnel kiln data set due to Mn contamination.

Table 1. BSCP Tunnel Kiln Test Runs Removed Due to Mn Contamination

RTI 

Inventory 

- Kiln No. Test Date

Run

No. Facility Name City State Kiln ID

503 2/8/2011 2, 3 a Acme Brick Denton TX EPN 21 (Kiln A)

543 9/17/2010 2 Boral Bricks, Inc. - Augusta 

Plant 5 Augusta GA EU05

566 9/21/2010 3 Boral Bricks, Inc. - Salisbury 

Plant Salisbury NC BK6

547/548 7/13-14/2010 1, 3 a Boral Bricks, Inc. - Bessemer 

Plant 6 Bessemer AL 003 & 004 (kiln 1&2)

568 11/17/2010 1, 3 a Boral Bricks, Inc. - Union City 

Plant Union City OK EU02

606 1/18/2011 3 General Shale Brick, Inc. Coosa 

(Rome) GA Kiln 40 Units K2 

(kiln B)

653 1/27/2011 1 Hanson Brick Elgin TX tk-2

676 8/17/2010 5 Hanson (formerly Jannock/US 

Brick) Mineral Wells TX tk-2

a Entire test was removed because only one test run from this test was not contaminated.

3. PM Correction for Test Runs Below 1 mg

As part of the BSCP test data review, the mass (mg) collected for each PM test run was 

evaluated. In the EPA memorandum, Data and procedure for handling below detection level 

data in analyzing various pollutant emissions databases for MACT and RTR emissions limits, 

1 mg is given as the Representative Detection Level (RDL) for PM (Westlin and Merrill, 2011).

For test runs with less than 1 mg collected, the 1 mg RDL value was used to calculate the 

concentration, emission rate, and emission factor for that run. In these cases, the emission factor 

was calculated as follows:
6

hr

ton product

453.59237 mg

1lb

1hr

60 min

min

dscf

dscf

0.02831685dscm

dscm

1mg

ton product

lb 















× × × ×

=

4. Dioxins/Furans

To calculate emissions of total dioxins/furans, the mass values for each of the homologue 

group totals reported in the laboratory analysis of the test report were summed. The homologue 

groups are shown in Table 2.

Table 2. Dioxin/Furan Homologue Group Totals

Homologue Group Totals Short Hand

Total Tetrachlorodibenzo-p-dioxins Total TCDD

Total Pentachlorodibenzo-p-dioxin Total PeCDD

Total Hexachlorodibenzo-p-dioxins Total HxCDD

Total Heptachlorodibenzo-p-dioxins Total HpCDD

Total Octachlorodibenzo-p-dioxin Total OCDD

Total Tetrachlorodibenzofurans Total TCDF

Total Pentachlorodibenzofurans Total PeCDF

Total Hexachlorodibenzofurans Total HxCDF

Total Heptachlorodibenzofurans Total HpCDF

Total Octachlorodibenzofuran Total OCDF

Next, 17 specific dioxin/furan congeners were considered separately from the homologue 

group totals. The 17 specific dioxin/furan congener mass values reported in the laboratory 

analysis of the test report were converted to 2,3,7,8-TCDD toxic equivalency (TEQ) values for 

each test run using the 2005 World Health Organization (WHO) toxicity equivalence factors 

(TEF) (EPA, 2010) in Table 3. The 17 converted TEQ values were then summed to calculate a 

total TEQ value for each run. Appendix C contains a sample calculation showing how the total 

dioxin/furan and total TEQ values were calculated from the reported laboratory masses to the 

final run by run values presented in Appendix B.
7

Table 3. Dioxin/Furan Toxicity Equivalence Factors

Dioxin/furan congener Short Hand

Toxicity equivalence 

factor

2,3,7,8-tetrachlorodibenzo-p-dioxin 2,3,7,8-TCDD 1

1,2,3,7,8-pentachlorodibenzo-p-dioxin 1,2,3,7,8-PeCDD 1

1,2,3,4,7,8-hexachlorodibenzo-p-dioxin 1,2,3,4,7,8-HxCDD 0.1

1,2,3,7,8,9-hexachlorodibenzo-p-dioxin 1,2,3,6,7,8-HxCDD 0.1

1,2,3,6,7,8-hexachlorodibenzo-p-dioxin 1,2,3,7,8,9-HxCDD 0.1

1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin 1,2,3,4,6,7,8-HpCDD 0.01

Octachlorodibenzo-p-dioxin OCDD 0.0003

2,3,7,8-tetrachlorodibenzofuran 2,3,7,8-TCDF 0.1

1,2,3,7,8-pentachlorodibenzofuran 1,2,3,7,8-PeCDF 0.03

2,3,4,7,8-pentachlorodibenzofuran 2,3,4,7,8-PeCDF 0.3

1,2,3,4,7,8-hexachlorodibenzofuran 1,2,3,4,7,8-HxCDF 0.1

1,2,3,6,7,8-hexachlorodibenzofuran 1,2,3,6,7,8-HxCDF 0.1

2,3,4,6,7,8-hexachlorodibenzofuran 2,3,4,6,7,8-HxCDF 0.1

1,2,3,7,8,9-hexachlorodibenzofuran 1,2,3,7,8,9-HxCDF 0.1

1,2,3,4,6,7,8-heptachlorodibenzofuran 1,2,3,4,6,7,8-HpCDF 0.01

1,2,3,4,7,8,9-heptachlorodibenzofuran 1,2,3,4,7,8,9-HpCDF 0.01

Octachlorodibenzofuran OCDF 0.0003

5. Non-Detects

As mentioned in Section IV.B.1, Hg and non-Hg HAP metal test runs are comprised of 

individual fractions. For any test run fraction that had values flagged as being below detection 

limit (BDL), the MDL, or other reporting limit if an MDL was not available, was used as the 

mass for that fraction. The concentration, emission rate, and emission factor for the run were 

then calculated using the sum of the fractions for each test run.

If all fractions for a run were flagged as BDL, then the run was considered BDL. If there 

was a mix of fractions flagged as BDL and above detection limit (ADL), then the run was 

considered detection level limited (DLL). If all fractions for a run were flagged as ADL, then 

the run was considered ADL.

Similarly, for dioxin/furan testing, there are multiple congeners for each TEQ run. The 

run was flagged as BDL if all of the congener masses were below the MDL; DLL if one or more 

congeners were below the MDL; and ADL if all the congeners were above the MDL. For each 

fraction/congener mass that is below the MDL, the MDL mass was used for the 

fraction/congener mass and subsequent emissions calculations. For more information on how 

these data were treated for purposes of calculating MACT floors, see the memorandum 

Maximum Achievable Control Technology (MACT) Floor Analysis for Brick and Structural Clay 

Products (Raymond and Sroka, 2014).
8

6. Production Rates

For most of the test reports, the production rate (in tph) was provided within the test 

report. Some of the test reports did not provide a production rate. In some of those instances,

the BIA was able to provide the production rate. Alternatively, if another test was conducted on 

the same source in a similar time frame, the production rate for that test was used. As a last 

resort, if the production rate used during the test was not provided in the test report or survey 

response, and it was not available from the facility, the production rate was set equal to

83 percent of the kiln capacity. The 83 percent capacity utilization was a conservative estimated 

developed from the available production data and design capacities reported in the BIA survey

data (Schimmel, 2008).

7. Kiln Configurations

In some cases, multiple kilns are ducted together to the outlet stack being tested. Each

kiln operating during the time of testing was assumed to have the same concentration and 

emission factor value. Their emission rate values were calculated as a proportion of the outlet 

stack value, based on a ratio of production rates. If any of the kilns were not operating during 

the test, the emission values do not apply to those kilns.

V. References

EPA (U.S. Environmental Protection Agency). 2010. Recommended Toxicity Equivalence 

Factors (TEFs) for Human Health Risk Assessments of 2,3,7,8-Tetrachlorodibenzo-p-dioxin 

and Dioxin-Like Compounds. Publication No. EPA/100/R–10/005. Available at: 

http://www.epa.gov/raf/files/tefs-for-dioxin-epa-00-r-10-005-final.pdf. December 2010.

Gunning, G. 2011. “Request for exemption from testing requirements of section 114 

information collection request for Interstate Brick.” Letter and attachment from Gerry 

Gunning, Interstate Brick, to Jeff Telander, U.S. Environmental Protection Agency. January 

4, 2011.

Holloway, K. 2014. Updated BSCP Inventory Database and Documentation. Memorandum 

from Thomas Holloway, RTI International, to Jeff Telander, EPA/OAQPS/SPPD. November 

6, 2014.

Johnson, S. 2013. Source test report review – General Shale Brick, Inc, Mooresville, IN, Feb. 1, 

2012. Memorandum from Steffan Johnson, EPA/SPPD, to Jeff Telander, EPA/SPPD. 

August 9, 2013.

Kuo, I., Miller, S., and Hartman, M. 2009a. Preliminary review of test reports. Memorandum 

from Irene Kuo and Susan Miller, Brick Industry Association, and Michael Hartman, AirTech Environmental, LLC, to Jeff Telander, EPA/SPPD. June 5, 2009.

Kuo, I., Miller, S., and Hartman, M. 2009b. Subsequent review of test reports and BIA 

comments on EPA actions on preliminary review of test reports. Memorandum from Irene 

Kuo and Susan Miller, Brick Industry Association, and Michael Hartman, Air-Tech 

Environmental, LLC, to Jeff Telander, EPA/SPPD. September 4, 2009.
9

Kuo, I. and Miller, S. 2012. Review of EPA BSCP MACT Floor Ranking Database (Version 

dated 3/15/2010). Memorandum from Irene Kuo and Susan Miller, Brick Industry 

Association, to Jeff Telander, EPA/SPPD. December 12, 2012.

Raymond, G. and Sroka, K. 2014. Maximum Achievable Control Technology (MACT) Floor 

Analysis for the Brick and Structural Clay Products Proposed Rule. Memorandum from 

Gabrielle Raymond and Kristin Sroka, RTI International, to Jeff Telander, 

EPA/OAQPS/SPPD. November 6, 2014.

Schimmel, T. 2008. “Brick Industry Association MACT data collection.” E-mail and 

attachments from Terry Schimmel, Brick Industry Association, to Jeff Telander, U.S. 

Environmental Protection Agency. October 17, 2008.

Sims, B. 2011. “Request for exemption from testing requirements of section 114 information 

collection request for Jenkins Brick and Tile Co.” Letter from Brian Sims, Jenkins Brick and 

Tile Co., to Jeff Telander, U.S. Environmental Protection Agency. January 13, 2011.

Telander, J. 2011a. “EPA approval of request for exemption from testing requirements of 

section 114 information collection request for Interstate Brick.” E-mail from Jeff Telander, 

U.S. Environmental Protection Agency, to Gerald Gunning, Interstate Brick. January 12, 

2011.

Telander, J. 2011b. “EPA approval of request for exemption from testing requirements of 

section 114 information collection request for Jenkins Brick and Tile Co.” E-mail from Jeff 

Telander, U.S. Environmental Protection Agency, to Brian Sims, Jenkins Brick and Tile Co.

February 15, 2011.

Tsirigotis, P. 2008. “Section 114 information collection request to selected brick and structural 

clay products facilities.” Letter and attachments from Peter Tsirigotis, U.S. Environmental 

Protection Agency, to Terry Schimmel, Boral Bricks, Inc., transmitting section 114 

information collection request asking for information on brick and structural clay products 

processes, emissions, and controls. Identical letters sent to other addressees listed (The 

Belden Brick Co., Boral Bricks, Inc., Carolina Ceramics Brick Co., General Shale Brick, 

Inc., Glen-Gery Corp., Hanson Building Products America, Morin Brick Co., and Taylor 

Clay Products, Inc.). June 4, 2008.

Tsirigotis, P. 2010a. “Section 114 information collection request to The Belden Brick Co.” 

Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to 

William Belden, Jr., The Belden Brick Co., transmitting section 114 information collection 

request asking for information on startup and shutdown events and emission data for 

specified emission points. June 11, 2010.

Tsirigotis, P. 2010b. “Section 114 information collection request to Boral Bricks, Inc.” Letter 

and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Terry 

Schimmel, Boral Bricks Inc., transmitting section 114 information collection request asking 

for information on startup and shutdown events and emission data for specified emission 

points. June 11, 2010.
10

Tsirigotis, P. 2010c. “Section 114 information collection request to Hanson Building Products 

America.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection 

Agency, to J. David McKeown, Hanson Building Products America, transmitting section 114 

information collection request asking for information on startup and shutdown events and 

emission data for specified emission points. June 11, 2010.

Tsirigotis, P. 2010d. “Section 114 information collection request to Acme Brick Co.” Letter 

and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Dennis 

Knautz, Acme Brick Co., transmitting section 114 information collection request asking for 

information on startup and shutdown events and emission data for specified emission points. 

November 17, 2010.

Tsirigotis, P. 2010e. “Section 114 information collection request to General Shale Brick, Inc.” 

Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to 

Dave McNees, General Shale Brick, Inc., transmitting section 114 information collection 

request asking for information on startup and shutdown events and emission data for 

specified emission points. November 17, 2010.

Tsirigotis, P. 2010f. “Section 114 information collection request to Glen-Gery Corp.” Letter 

and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Steve 

Matsick, Glen-Gery Corp., transmitting section 114 information collection request asking for 

information on startup and shutdown events and emission data for specified emission points. 

November 17, 2010.

Tsirigotis, P. 2010g. “Section 114 information collection request to Interstate Brick.” Letter 

and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Gerry 

Gunning, Interstate Brick, transmitting section 114 information collection request asking for 

information on startup and shutdown events and emission data for specified emission points. 

November 17, 2010.

Tsirigotis, P. 2010h. “Section 114 information collection request to Jenkins Brick and Tile Co.” 

Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to 

Mike Jenkins, Jenkins Brick and Tile Co., transmitting section 114 information collection 

request asking for information on startup and shutdown events and emission data for 

specified emission points. November 17, 2010.

Tsirigotis, P. 2010i. “Section 114 information collection request to Taylor Clay Products, Inc.” 

Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to 

Charles Taylor, Taylor Clay Products, Inc., transmitting section 114 information collection 

request asking for information on startup and shutdown events and emission data for 

specified emission points. November 17, 2010.

Westlin, P. and Merrill, R. 2011. Data and procedure for handling below detection level data in 

analyzing various pollutant emissions databases for MACT and RTR emissions limits. 

Memorandum from Peter Westlin, SPPD/MPG and Raymond Merrill, AQAD/MTG, to 

SPPD management and MACT rule writers. December 13, 2011.
Appendix A

Test Data Not Used
A-1

Table A-1. Tunnel Kiln Test Data Removed from Database after QA/QC, Not Used in MACT Floor Analyses

Facility ID Facility City State Test Date Source Kiln ID Explanation Why Data Excluded 

ACME-5 Acme Brick 

Company Denton TX 2/8/2011 2010 

survey

503 Removed Non-Hg HAP Metal results due to only one 

test run from this test was not Mn contaminated

ACME-15 Acme Brick 

Company McQueeney TX 10/14/2003 2008 survey

Located at true area source facility

ACME-16 Acme Brick 

Company

Oklahoma 

City OK 3/15/2002 2008 survey

Located at true area source facility

BELD-1 Belden Brick 

Company

Sugarcreek 

Plant 3 OH 7/25/2011 2010 

survey

527 Rejected by Ohio EPA

BELD-1 Belden Brick 

Company

Sugarcreek 

Plant 6 OH 5/30/2007 2008 survey 528, 529, 530 Rejected by Ohio EPA

BELD-1 Belden Brick 

Company

Sugarcreek 

Plant 8 OH 5/3/2001 2008 

survey

532 Test conducted prior to current control device 

installation

BELD-1 Belden Brick 

Company

Sugarcreek 

Plant 8 OH 8/26/2003 2008 

survey 531, 532, 533 Rejected by Ohio EPA

BELD-1 Belden Brick 

Company

Sugarcreek 

Plant 8 OH 1/20/2006 2008 survey 531, 532, 533 No HAP data; only SO2 data

BELD-1 Belden Brick 

Company

Sugarcreek 

Plant 9 OH 5/31/2007 2008 

survey 534, 535 Rejected by Ohio EPA

BORA-1 Boral Bricks 

Inc. Smyrna GA 11/2/2004 2008 survey 537, 538 Test conducted prior to current control device installation

BORA-1 Boral Bricks 

Inc. Smyrna GA 2/8/2005 2008 

survey 537, 538 Test conducted prior to current control device installation

BORA-1 Boral Bricks 

Inc. Smyrna GA 10/17/2006 2008 

survey 537, 538 Removed PM results due to ripped filter

BORA-1 Boral Bricks 

Inc. Smyrna GA 3/28/2007 2008 survey

538 Removed PM Run 2 results due to ripped filter

BORA-3 Boral Bricks 

Inc.

Augusta 

Plant 6 GA 9/10/1991 Docket A99-30 542 Kiln demolished and/or decommissioned 

BORA-3 Boral Bricks 

Inc.

Augusta 

Plant 5 GA 9/14/2010 2010 Survey 543 Removed Non-Hg HAP Metal Run 2 results due to Mn contamination

BORA-5 Boral Bricks 

Inc. Bessemer AL 5/15/2007 2008 

survey 547, 548 Removed HF and HCl results due to low probe and 

filter temperatures; retained PM results

BORA-5 Boral Bricks 

Inc. Bessemer AL 7/13-14/2010

2010 

survey 547, 548 Removed Non-Hg HAP Metal results due to only one test run from this test was not Mn contaminated
A-2

Facility ID Facility City State Test Date Source Kiln ID Explanation Why Data Excluded 

BORA-9 Boral Bricks 

Inc. Lexington SC 1/23/1997 Docket A99-30 553 Kiln demolished and/or decommissioned 

BORA-11 Boral Bricks 

Inc. Macon MS 4/22/1999 2008 

survey

555 Kiln demolished and/or decommissioned 

BORA-12 Boral Bricks 

Inc. Marshall TX 6/1/1986 Docket A99-30 557 Kiln demolished and/or decommissioned

BORA-12 Boral Bricks 

Inc. Marshall TX 3/12/2002 2008 survey

557 Kiln demolished and/or decommissioned

BORA-13 Boral Bricks 

Inc. Muskogee OK 12/13/2005 2008 

survey

558 Test conducted prior to current control device 

installation

BORA-13 Boral Bricks 

Inc. Muskogee OK 2/7/2006 2008 survey

558 Test conducted prior to current control device 

installation

BORA-17 Boral Bricks 

Inc. Salisbury NC 9/8/2005 2008 

survey

565 Kiln demolished and/or decommissioned

BORA-17 Boral Bricks 

Inc. Salisbury NC 9/21/2010 2010 

survey

566 Removed Cl2 Run 1 results as outlier

BORA-17 Boral Bricks 

Inc. Salisbury NC 9/21/2010 2010 survey

566 Removed Non-Hg HAP Metal Run 3 results due to Mn 

contamination

BORA-19 Boral Bricks 

Inc. Union City OK 5/25/2006 2008 

survey

568 Removed HF and HCl results due to low probe and 

filter temperatures; retained PM results

BORA-19 Boral Bricks 

Inc. Union City OK 3/14/2007 2008 survey

568 Removed HCl results due to low probe and filter 

temperatures

BORA-19 Boral Bricks 

Inc. Union City OK 11/17/2010 2010

survey

568 Removed Non-Hg HAP Metal Run 3 results due to Mn 

contamination

BORA-20 Boral Bricks 

Inc. Corona CA 12/2/1999 2008 survey

Located at true area source facility

BORA-21 Boral Bricks 

Inc. Van Wyck SC 5/14/1997 Docket A99-30 569, 570 Kiln demolished and/or decommissioned

BIA-120 Bowerston 

Shale Co Bowerston OH 9/27/2007 BIA 571 Run 1 HF results excluded by Ohio EPA

GENE-2

General 

Shale Brick, 

Inc.

Johnson City TN 7/27/1993 2008 

survey

601 Kiln demolished and/or decommissioned
A-3

Facility ID Facility City State Test Date Source Kiln ID Explanation Why Data Excluded 

GENE-4

General 

Shale Brick, 

Inc.

Fairsdale KY 9/21/2001 2008 

survey

603 Removed HF results due to glass fiber filter; retained

PM results

GENE-4

General 

Shale Brick, 

Inc.

Fairsdale KY 12/18/2001 2008 

survey

603 No HAP data; only SO2 data

GENE-4

General

Shale Brick, 

Inc.

Fairsdale KY 12/15/2005 2008 

survey

604 Removed HF and HCl results due to glass fiber filter; 

retained PM results

GENE-5

General 

Shale Brick, 

Inc.

Coosa GA 3/17/2005 2008 

survey

606 No HAP data; only SO2 data

GENE-5

General 

Shale Brick, 

Inc.

Coosa GA 1/18/2011 2010

survey

606 Removed Non-Hg HAP Metal Run 3 results due to Mn 

contamination

GENE-5

General 

Shale Brick, 

Inc.

Coosa GA 6/24/2008 2008 

survey

605 No HAP data; only SO2 data

GENE-5

General 

Shale Brick, 

Inc.

Coosa GA 1/18/2011 2010 

survey

606 Removed HF results, kiln retested 7/11/11

GENE-7

General 

Shale Brick, 

Inc.

Mooresville IN 11/2/2006 2008 

survey

609 Kiln demolished and/or decommissioned

GENE-7

General 

Shale Brick, 

Inc.

Mooresville IN 11/3/2006 2008 

survey

610 Removed HF and HCl results due to low probe and 

filter temperatures; retained PM results

GENE-7

General 

Shale Brick, 

Inc.

Mooresville IN 2/1/2012 2010 

survey

611 Discarded entire test report per Steffan Johnson, EPA

(Johnson, 2013)

GENE-8

General 

Shale Brick, 

Inc.

Blue Ridge 

(Roanoke) VA 2/23/2005 2008 survey 612, 613 Removed HF Run 1 results due to low probe and filter temperatures; retained other acid gas and PM results

GLEN-2 Glen Gery Caledonia OH 5/1/2007 2008 

survey 639, 638 No HAP data; only SO2 data
A-4

Facility ID Facility City State Test Date Source Kiln ID Explanation Why Data Excluded 

GLEN-6 Glen Gery Summerville PA 4/26/2005 2008 

survey

643 Removed HCl results due to questionable mass 

collection

HANS5 Hanson Brick 

East, LLC Elgin TX 1/27/2011 2010 

survey

653 Removed Non-Hg HAP Metal Run 1 results due to Mn 

contamination

HANS6 Hanson Brick 

East, LLC Corunna MI 6/7/1995 Docket A99-30 655 Removed fluorides results, used 2010 HF data

HANS10 Hanson Brick 

East, LLC

Pleasant 

Garden NC 5/10/2006 2008 survey

666 Kiln demolished and/or decommissioned

HANS12 Hanson Brick 

East, LLC Stanton KY 12/1/2004 2008 

survey

670 Kiln demolished and/or decommissioned

HANS15 Hanson Brick 

East, LLC

Mineral 

Wells TX 8/17/2010 2010 survey

676 Removed Non-Hg HAP Metal Run 5 results due to Mn 

contamination

8

(BIA-099)

RedlandRocky Ridge 

Plant

Rocky Ridge MD 8/5/1998 BIA 741 Incomplete test report, no run by run data available

66

(BIA-015)

RedlandHarmar Plant Cheswick PA 3/5/2002 BIA 738 Removed HF, HCl, PM results due to "extreme feed" 

issue

66

(BIA-015)

RedlandHarmar Plant Cheswick PA 3/11/2002 BIA 738 Removed HF and HCl results due to low probe and 

filter temperatures; retained PM results

66

(BIA-015)

RedlandHarmar Plant Cheswick PA 4/22/2005 BIA 738 Removed HF and HCl results due to low probe and 

filter temperatures; retained PM results

66

(BIA-015)

RedlandHarmar Plant Cheswick PA 10/26/2006 BIA 738

Removed HF and HCl results due to low probe and 

filter temperatures; removed HF, HCl, PM results due to 

"extreme feed" issue

141

(BIA-114)

Stark 

Ceramics, 

Inc.

East Canton OH 9/16/1993 Docket A99-30 752 Kiln demolished and/or decommissioned

149

(BIA-014)

RedlandCushwa Plant Williamsport MD 5/10/2006 BIA 736 Removed HF and HCl results due to low probe and 

filter temperatures; retained PM results

BIA-183 Vermont Brick 

Mfg, LP Highgate VT 10/1-

3/2002 Facility Located at true area source facility

BIA-206 Pine Hall 

Brick Co Inc. Fairmount GA 6/22/2005 BIA 725 Removed HF and HCl results due to glass fiber filter; retained PM results

BIA-206 Pine Hall 

Brick Co Inc. Fairmont GA 2/3/2004 BIA 724 Removed HF and HCl results due to glass fiber filter; retained PM results
Appendix B

Final Run-by-Run Values
B-1

The final run-by-run values for HF, HCl, Cl2, PM, Hg, individual non-Hg metal HAP, 

and dioxin/furan runs for tunnel kilns and dioxin/furan runs for dryers are provided in the 

corresponding Appendix B Microsoft Excel® file. The file includes the parameters and emission 

data compiled from each test report and the calculations conducted on the data.
Appendix C

Dioxin/Furan and TEQ Sample Calculations
C-1

A sample calculation of run by run reported laboratory masses converted into final total 

dioxin/furan and total TEQ run-by-run values is provided in the corresponding Appendix C

Microsoft Excel® file.