MACT Task Force

1 M E M O R A N D U M

Date: June 5, 2009

To: Jeff Telander, EPA/SSPD

From: Irene Kuo and Susan Miller, Brick Industry Association

Michael Hartman, Air

‐ Tech Environmental, LLC

Subject: Preliminary review of test reports

The purpose of this memorandum is to present a summary of our initial review of the

first batch of stack test reports for the brick industry. The Brick Industry Association

(BIA), and members of the brick industry, provided copies of all available compliance

test (i.e., stack test) reports. Some of these tests were required to be submitted under

Section 114 authority; other tests were submitted voluntarily. In both instances, the BIA

did not limit the test reports that were submitted based on some industry

‐ established

criteria. Rather, the intent was to provide the EPA with all available compliance tests

and then to jointly review their worthiness to be used to establish emission limitations

applicable to the industry. This memorandum is part of that process. We continue to

review additional test reports and will get those assessments to you as soon as possible.

Our intent in this memorandum is to lay out our approach for determining whether a

stack test is a viable candidate for use as a basis for a national rule. Since it is EPA’s

directive that testing procedures used in the development of emission limits be

consistent with the testing requirements for compliance

( http://www.epa.gov/ttn/emc/facts.html ), it is imperative that criteria be established at

this time for the use of specific test data that is based on scientific accuracy. We believe

that the accuracy and quality criteria of a test used for these purposes may be higher

than for a compliance test; at a minimum, the tests should follow all requirements and

recommendations that impact the accuracy of these tests. These tests must follow a

procedure that ensures that the results are accurate and repeatable or EPA cannot

ensure that the limits they establish have been achieved or are achievable.

Based on preliminary information provided by EPA, BIA determined the specific test

reports EPA used to develop emission levels for each source. Due to the large number

of test reports used, BIA prioritized the review process to address those test reports that

showed some of the lowest emission rates of HF, HCl, and PM since these tests wouldMACT Task Force

2 likely be included in an assessment of the lowest emitting units. Our focus also

included tests for kilns controlled with add

‐ on air pollution control devices in general.

Please note that the inclusion of test reports from synthetic minor sources in this

review in no way indicates our belief that they belong in the analysis. We continue to

assert that synthetic minor sources are not included in the source category and cannot

be used to establish a MACT floor for existing sources. We also assert that controls

that do not get a consistent HAP reduction (e.g., due to variable reagent flow

dependent on a non

‐ HAP pollutant) are not MACT controls and should be eliminated.

The remainder of this memorandum outlines specific issues we identified during the

course of our preliminary review that we believe cause specific tests to be deemed

questionable for use as a basis for a national rule. Please note that a test may appear

on more than one list. We look forward to discussing our approach with you and

working to ensure that the MACT levels of control required for our industry are based

on sound science.

BIA Preliminary Test Review Results

BIA has retained the services of Mr. Mike Hartman of Air

‐ Tech Environmental, LLC to

review the test reports submitted to EPA. Mr. Hartman is a recognized expert on stack

testing (resume available upon request). Mr. Hartman’s review includes comparison of

the approach for both sampling and analysis to the approach required by the reference

method, as well as insights from his extensive experience as a stack tester.

A complete list of all tests reviewed to date, including specific comments by Mr.

Hartman can be found in Appendix A. It should be noted that a comment such as

“Needs full review” or “Needs further review” indicates that the test report has only

been reviewed for issues related to #3 below or sufficient QA/QC data are not currently

available (we are requesting this information from each manufacturer and will provide a

full copy of the table in Appendix A in each review). The remaining document is

separated into three groups:

1) Tests that we believe should be removed immediately from EPA’s database used

to establish a MACT standard. These tests contain “fatal” issues that cannot be

addressed or corrected. There is no way to know, based on the information in

the specific test, that the facility represents one of the best performing sources

since the test was faulty.

2) Tests that warrant additional review due to concerns that proper procedures

were not followed, either during the testing or the analytical process. These

tests are questionable as to whether they are reasonable for use as the basis of aMACT Task Force

3 MACT standard. We have requested additional information for some of these

tests, which will enable a more complete review by BIA and/or Mr. Hartman.

3) Tests that appear to be incorrectly presented in EPA’s summary table. This could

be due to an apparent EPA error in interpreting the data or computation. Many

of these test reports have only been reviewed for basic issues at this time (e.g.,

proper process weight rates) and not been through the full review process by

BIA/or Mr. Hartman.

Each group is presented below.

1. Tests that should be removed from the database. BIA believes that the following

tests should not be included in the database used to establish a MACT standard.

a. Test reports rejected by state or regional agency

. Two tests reports were

rejected by Ohio EPA because the proper test procedure was not followed.

These tests should not be used by EPA. The letters from the Ohio EPA can be

provided, if requested.

i. Belden Brick

‐ Kiln 530 Test Date 5/07

ii. Belden Brick

– Kiln 531 Test Date 8/26/03

iii. Belden Brick

– Kiln 535 Test Date 5/07

b. Inappropriate testing equipment and/or conditions

‐ use of glass fiber

filters. As outlined in the EMC guidance document GD

‐ 034 (EMTIC

Workshop Background Paper for Method 26 and Method 26A), the use of

glass fiber filters is not allowed especially at low concentrations of HCl

because of the potential for reaction with the filter. Similarly, it has been Mr.

Hartman’s experience and is stated in Method 13B that hydrogen fluoride

(HF) reacts with the glass fiber filter and embeds in the filter causing a

negative bias. Method 26A requires the use of Quartz fiber or Teflon filters.

Any test report that states the use of a glass fiber filter should be eliminated.

(as discussed below, we suggest that any HF and/or HCl test report that does

not specify the type of filter used warrants further review. The following

tests should not be used to establish a MACT standard:

i. General Shale

– Kiln 603 Test Date 9/21/01

ii. General Shale

– Kiln 604 Test Date 12/15/05

c. Tests for fluorine that use Method 13b as opposed to Method 26 or FTIR

. While test reports based on Method 13 should be considered “available

information” and used for qualitative comparisons, the emission data

specifically used for establishing a MACT standard should be based on the

test method that will be used to demonstrate compliance. Method 13B

provides no speciation of gaseous fluoride and should not be considered.

The following tests should not be used to establish a MACT standard:

i. Acme Brick

– Kiln 510 Test Date 3/4/96

ii. Hanson Brick

– Kiln 655 Test Date 6/7/95MACT Task Force

4 iii. Lee Brick

– Kiln 694 Test Date 4/18/97

iv. Acme Brick

– Kiln 516 Test Date 10/21/93

v. Boral Brick

– Kiln 555 Test Date 4/22/99

d. Inappropriate test procedures: low temperature and/or high moisture.

Method 26A specifies sample collection at 250 o F to collect a dry sample. As

outlined in the EMC guidance document GD

‐ 034 (EMTIC Workshop

Background Paper for Method 26 and Method 26A), as little as one drop of

moisture is sufficient to cause a significant negative bias because of the

solubility of halides in water. This same concern would exist for tests using

Test Method 320 (FTIR). BIA recommends the exclusion of test reports that

do not maintain a probe and filter temperature at or above 250 or that do

not have sufficient analytical QA/QC data to support the average

temperature readings.

i. Acme Brick

– Kiln 508 Test Date 3/15/97

ii. Hanson Brick

– Kiln 655 Test Date 6/7/95

e. Inappropriate procedures

‐ only two viable test runs

. Compliance with any

future MACT standard will be based on conducting a test according to

established procedures in the reference test method. For Methods 26A, 5,

and 320, this requires a minimum of three test runs. Therefore, EPA should

only base MACT emission limitations on tests that include three viable runs.

In some instances, only two test runs were used from a three test run test.

In one case (name), there was a flaw in the filter that should have precluded

the test run from being used. In another case (name), the only apparent

reason for eliminating one run was that it was much higher than the other

two runs ‐ in this case, all three test runs could be used and then this test

could be considered to be a valid test (unless EPA identifies another issue or

justification for the elimination of the higher run). The following tests appear

to only use two test runs.

i. Acme Brick

– Kiln 514 Test Date 3/27/07

ii. Acme Brick

– Kiln 503 Test Date 11/9/05

f. Calibration and QA/QC Issues

. Several of the test reports reviewed had

extremely low emissions levels. In some instances, the reported values were

well below the calibration range of the sampling train. This is not proper

procedure and calls into question the viability and repeatability of the data.

With low reported emission levels, calibration limits and analytical data are

critical. Tests where proper calibration was not used and where QA/QC data

does not exist should not be used by EPA.MACT Task Force

5 i. Boral Brick

– Kiln 538 Test Dates 10/17/06 & 3/28/07

ii. Acme Brick

– Kiln 502 Test Date 6/5/97

iii. Hanson Brick

– Kiln 653 Test Date 10/21/07

2. Tests that warrant additional review prior to consideration for developing the

standard.

a. Appropriate use of “non

‐ detects” in establishing emission standards

. As

stated by EMC ( http://www.epa.gov/ttn/emc/facts.html ), if the data are

used to set emission limits, different procedures [regarding the use of non

‐ detects] may be used for different source categories. However, the

procedure used to determine compliance with the emission limit should be

consistent with the procedure used during testing to set the emission limit.

Any use of data derived from non

‐ detectable results should be standardized

across all test reports. In some reports submitted for the brick industry,

values were reported at the limit of detection, while others were reported at

the limit of quantification. In others, values were reported as zero or at one

half of the detection limit.

An overriding issue in using non

‐ detect emission rates from these test

reports is the limited duration of the tests and the resulting low volume

collected. It is generally recommended by the National Council for Air and

Stream Improvement (NCASI) that data containing non

‐ detect values be used

only if collected over a 4 hour or more test period.

EMC cites the example of when measuring dioxin/furan emissions from

municipal waste combustors, EPA substituted zero for BDL results during the

testing to gather data to support the emission limit. To be consistent, the

Agency allows testers to substitute zero for BDL results when determining

compliance with the municipal waste combustor dioxin/furan emission limit

provided the test run duration is four or more hours.

Without sufficient 4 hour test runs to compare to the non

‐ detect values

presented in these test results, it is difficult to determine the validity and the

repeatability of these results. Thus non

‐ detects pose the problem of

accuracy, standardization, and consistent test methodology.

The BIA believes that the use of “non detect” values in setting a standard

pose a significant enforceability issue. At a minimum, “non detect” test

reports should be reviewed carefully for any anomalies. EPA must ensure

that the approach for use of “non detects” is consistent across all tests. In noMACT Task Force

6 case, should anything lower than the detection limit be used for tests

reporting “non detects.”

Further review is required for these tests:

i. Acme Brick

– Kiln 502 Test Dates 6/5/97 & 10/05/05

ii. General Shale

– Kiln 603 Test Date 9/21/01

iii. General Shale

– Kiln 604 Test Date 12/15/05

iv. Acme Brick

– Kiln 503 Test Date 11/9/05

v. Acme Brick

– Kiln 506 Test Date 8/13/03

vi. Acme Brick

– Kiln 508 Test Date 3/15/07

vii. Boral Brick

– Kiln 537 Test Date 10/17/06

viii. Boral Brick

– Kiln 558 Test Date 7/25/07

ix. Boral Brick

– Kiln 567 Test Date 8/19/08

x. General Shale

– Kiln 609 Test Date 11/1/06

xi. Hanson Brick

– Kiln 653 Test Date 10/21/07

xii. Hanson Brick

– Kiln 655 Test Date 6/7/95

xiii. Jenkins Brick

– Kiln 687 Test Date 8/3/06

xiv. Taylor Clay

– Kiln 765 Test Date 1/1/07

xv. Glen Gery

– Kiln 645 Test Date 11/8/06 & 5/9/07

b. Questionable procedure

‐ Insufficient information on media type and QA/QC

.

In many test reports, the filter media is not specified and QA/QC data is absent

or insufficient. Some of the lowest emission rates have been identified in tests

where glass filters are known to have been used. Therefore, glass fiber filters are

suspected when a filter type is not specified since glass fiber is the standard (and

lowest cost) filter used by source samplers who may be unaware of the negative

bias for HF and HCl. We are currently requesting additional information from

these sources to better assess whether the correct filter media was used and

determine if their QA/QC procedures are acceptable.

i. Acme Brick

– Kiln 503 Test Date 11/9/05

ii. Acme Brick

– Kiln 516 Test Date 10/12/93

iii. Boral Brick

‐ Kiln 537 Test Date 10/17/06

iv. Boral Brick

– Kiln 555 Test Date 4/22/99

v. Boral Brick

– Kiln 567 Test Date 8/19/08

vi. General Shale

– Kiln 609 Test Date 11/1/06

vii. Hanson Brick

– Kiln 653 Test Date 10/21/07

viii. Hanson Brick

– Kiln 655 Test Date 6/7/95

ix. Lawrenceville Brick And Tile

– Kiln 692 Test Report 9/2/04

x. Lee Brick

– Kiln 694 Test 4/18/97

xi. Taylor Brick

– Kiln 765 Test 2007MACT Task Force

7 xii. Boral Brick

– Kiln 547 & 548 Test Date 5/15/07

xiii. Hanson Brick

– Kiln 675 Test Date 6/29/93

3. Tests incorrectly presented in draft EPA summary table

. Further review may be

required. In some instances, it appears that EPA may have combined information

from one test with another to establish a value for a facility

‐ or otherwise incorrectly

used a value from a test report.

a. Data from other tests and/or MACT survey

. Since “capacity” for a specific

kiln can change depending on the product being produced and other factors,

we strongly suggest that EPA not use information from another source in

combination with a stack test. This would include combining information

from multiple tests or using a capacity from a company’s MACT survey as the

capacity during a test. When the process weight rate for brick is missing

from a test, we are working to obtain that information from the facilities and

will forward it to you as soon as possible.

i. Acme Brick

– Kiln 502 Test Date 10/5/05

ii. Acme Brick

– Kiln 510 Test Date 3/4/96

iii. General Shale

– Kiln 610 Test Date 1/24/07

iv. Acme Brick

– Kiln 503 Test Date 11/9/05

v. Hanson Brick

– Kiln 675 Test Date 6/29/93

vi. Acme Brick

– Kiln 515 Test Date 9/31/96

vii. Acme Brick

– Kiln 516 Test Date 10/21/93

viii. Acme Brick

– Kiln 517 Test Date 4/12/06

ix. Acme Brick

– Kiln 518 Test Date 3/26/02

x. Acme Brick

– Kiln 521 Test Date 9/6/02

xi. Belden Brick

– Kiln 526 Test Date 5/30/07

xii. Boral Brick

– Kiln 557 Test Date 3/29/02

xiii. Boral Brick

– Kiln 569 Test Date 1997

xiv. Clay City Pipe

– Kiln 571 Test Date 11/16/00 & 9/27/07

xv. Cunningham Brick

– Kiln 591 Test Date 4/22/97

xvi. Hanson Brick

– Kiln 665 Test Date 7/11/93

xvii. Jenkins Brick

– Kiln 688 Test Date 4/18/08 & 2/21/08

xviii. Mutual Materials Co.

– Kiln 710 Test Date 4/22/94

xix. Taylor Clay

– Kilns 763 & 764 Test Date 8/19/97

b. Apparent errors. These include typographical errors and potential

computational errors:

i. Acme Brick

– Kiln 517 Test Date 4/12/06

ii. Boral Brick

– Kiln 551 Test Date Uncertain

iii. Boral Brick

– Kiln 566 Test Date 2/13/07 & 7/20/07MACT Task Force

8 iv. Hanson Brick

– Kiln 675 Test Date 6/29/93

c. Use of tests that represent previous operating scenarios. We believe that it

is important to properly characterize each kiln. If a kiln has two stack tests,

but each represents a different operating scenario, the two emission rates

should not be averaged. By averaging, EPA creates an unrealistic picture of

the emissions level for that kiln. This is most apparent when test data from

failed compliance tests are used. Such tests include:

i. General Shale

– Kiln 610 Test Date 11/02/06

ii. Boral Brick

– Kiln 538 Test Date 3/28/07

iii. Redland Brick

‐ Kiln 738 Test Date 3/02, 4/05, and 10/05

In conclusion, BIA recommends that a definitive list of criteria be established for

accepting/rejecting test data that can be reproduced for compliance. BIA recommends

automatically rejecting reports that have been rejected by a state or local agency and

those that blatantly failed to follow appropriate test methods. BIA recommends further

review of potentially acceptable test reports based on equipment, but lack appropriate

QA/QC data for procedural review.

We look forward to meeting with you to further discuss what appropriate criteria may

be for tests used to establish a national MACT emission limitation. We are prepared to

meet with you or your designees at your earliest convenience to discuss your review of

the test reports and to discuss the next steps in this critical review process.Table 1. Preliminary Review of Test Reports Used to Generate Emission Factors for HF, HCl, and PM for the Brick IndustryKiln NoBIA_ID FacName City StateTest Report Used toGenerate Em FactorBIA Notes on Em Factor Generated by EPANotes on Test Reports Used to Generate EmissionFactor604 BIA-070 General Shale Brick-Plant 38 Fairsdale KY 12/15/05 Kiln 38B Straight from test report Used glass fiber filter and HF datawas non-detect765 BIA-148 Taylor Clay Salisbury NC11/1/2007 ESK4 Straight from test reportFurther QA/QC data needed for further review. HClconcentrations were detectable for two runs while HF wsnot detected in any of the outlet samples. One-half thedetection limit was used for this report. No informationon filter type available.603 BIA-070 General Shale Brick-Plant 38 Fairsdale KY9/21/2001 Straight from test reportQuartz fiber filter listed in description but glass fiberlisted in Appendix. Conflicting values of HF reported 3orders of magnitude apart. Non-detects listed for 2 of 3runs in both cases. Data is suspect.567 BIA-208 Boral- Terre Haute Plant Terre Haute IN8/919/08 Straight from test report.No filter type specified. All HF are non detects. Lowerflow rates than other kilns. Fluoride calibration data ismissing.558 BIA-104 Boral- Muskogee Plant Muskogee OK7/25/2007Straight from test report. 7/11 test was engineering test, while 7/25 was permitcompliance. Both were submitted. HF would not change if averaged, but HCl wouldbe .01 lb/ton and PM would be .089 lb/ton.All HF is below detection limits.675 BIA-019 Hanson Mineral Wells Mineral Wells TX6/29/1993 Kiln 1Typo for PM for Kiln 2. Should be 3.425 lb/hr and 0.03lb/ton. Full design capacitywas used by EPA. Test report suggests tests were at 76% capacity (13/17 cars)which only slightly changes numbers to HF=.000469 and PM=.59 for Kiln 1 andHF=.00049 and PM=0.39 for Kiln 2Need analytical data for full review676 BIA-019 Hanson Mineral Wells Mineral Wells TX 6/29/1993 Kiln 2609 BIA-072 General Shale Brick-Plants 20, 32 & 43 Mooresville IN11/1/2006 Kiln 20EPA averaged 4 test runs. Plant excluded run 1 from reported avg. Avg from 3 runsHF=.00038, HCl=.146, and PM=.022. PM changed more because 1 run of the 4reported 0 emissions.Filter type not specified. Non-detects present. (Note:this kiln has not run since test)531 BIA-005 Belden- Plant #8 Sugarcreek Sugarcreek OH8/26/2003 (&8/23/05 for PM)For HF and HCl, EPA took 8/26/03 result and divided for 3 kilns. For PM, they added8/26/03 and 8/23/05 results and divided by 6. Without 8/26, PM would be 1.26 lb/hrand using their prod rate 0.182 lb/ton. EPA did not use engineering test from 9/27/01Should not include 8/26/03 test since it was rejected byOhio EPA for Improper test method. (Letter dated11/7/03 from S. Clay to J. Johnson)532 BIA-005 Belden- Plant #8 Sugarcreek Sugarcreek OH533 BIA-005 Belden- Plant #8 Sugarcreek Sugarcreek OH653 BIA-018 Hanson - Elgin Elgin TX10/21/2007 tk-2 Straight from test reportData collected is 2 orders of magnitude below thelowest calibration. No confirmation of filter type for tk-2.Low volume of gas collected (15 cubic feet).547 BIA-111 Boral- Bessemer Plant #6 Bessemer AL5/15/2007 Straight from test report. Averaged between 2 kilns for one stackQA/QC data needed for further review. Requested on5/11/09.548 BIA-111 Boral- Bessemer Plant #6 Bessemer AL666 BIA-045 Hanson - Pleasant Garden Pleasant Garden NC 5/10/2006 straight from test report OK to use, though HCl looks suspicious.655 BIA-095 Hanson - Michigan Corunna MI6/7/1995EPA used an average based on two runs one of which was ND. Used fluorideemissions as HFFilter type not specified. Filter temp reported as 0. Nondetects present. No analytical data. Inappropriatelyused fluorides emissions to represent HF (9/8/99 preproposal letter to EPA)568 BIA-207 Boral- Union City Plant Union City OK8/8/06, 5/24/06, 3/14/07 EPA averaged where possible.Needs full review721 BIA-128 Pacific Coast-West Jordan West Jordan UT 10/31/1995 Straight from test reportNeeds full reviewTable 1. Preliminary Review of Test Reports Used to Generate Emission Factors for HF, HCl, and PM for the Brick IndustryKiln NoBIA_ID FacName City StateTest Report Used toGenerate Em FactorBIA Notes on Em Factor Generated by EPANotes on Test Reports Used to Generate EmissionFactor502 BIA-077 Acme- Bennett Tunnel Plant (BTP) Millsap TX10/5/2005 & 6/5/97?EPA used average for HF and HCl. Need to confirm PM and production rate. Lookslike EPA may have used Front half PM emissions from 6/97 report instead of total.Analytical error: diluted sample but reported no dilutionresulting in non-detects for 6/5/97 HF. No QA/QC datafor 10/5/05 report. Non-detects also present on10/05/05 report.662 BIA-044 Hanson - Monroe Monroe NC 12/1/2006 Straight from test reportNeeds full review738 BIA-015 Redland- Harmar Plant Cheswick PA3/5/02, 3/11/02, 4/22/05 &10/25/05Averaged from test reportsThese tests were run at extreme feed conditions and arenot indicative of normal operating conditions. Needs fullreview503 BIA-078 Acme- Denton Plant (DTP) Denton TX11/9/2005EPA used capacity of 9.98 when average throughput during test was 8.84tph. BIAestimates are 0.003 lbHF/ton and .014 lbHCl/tonBIA summary cites 9/9/05 perhaps typo. Run 1 wasexcluded for no reason other than high HF #'s. NoQA/QC on sampling temperatures or filter type. Twonumbers used are non-detects. Insufficient QA/QCdata.504 BIA-078 Acme- Denton Plant (DTP) Denton TX505 BIA-078 Acme- Denton Plant (DTP) Denton TX625 BIA-038 General Shale- Moncure Facility Moncure NC 2/10/06 Kiln 4 Straight from test reportNeeds full review687 BIA-013 Jenkins- Montgomery Plant Montgomery AL6/5/2007 tk-2Straight from test report. Need to confirm if DIFF is controlling two kilns to be able toconsider 8/3 report. 8/3 report has suspect data for HF, potentially usable data forHCl, but no PM or production data.Non-detects present with PM collection below 3mgstandard detection limit.696 BIA-055 Lee Brick Sanford Facility Sanford NC 4/25/2007 Kiln 4 Straight from test reportNeeds full review508 BIA-080 Acme- Elgin Plant (ELP/ENP) Elgin TX 3/15/2007 Straight from test report Non-detects present and high moisture766 BIA-048 Triangle Brick- Merry Oaks Plant Merry Oaks NC4/20/06 & 8/10/06 EPA average two tests and divided by 2 for Kiln 1 and Kiln 2 (common DLA/stack) Needs full review767 BIA-048 Triangle Brick- Merry Oaks Plant Merry Oaks NCNeeds full review768 BIA-048 Triangle Brick- Merry Oaks Plant Merry Oaks NC 5/4/2006 kiln 3 Straight from test reportNeeds full review612 BIA-073 General Shale Brick-Plants 35 & 36 Blue Ridge (Roanoke) VA 2/23/2005 Unit #5 EPA divided the results for two kilns. Needs full review613 BIA-073 General Shale Brick-Plants 35 & 36 Blue Ridge (Roanoke) VANeeds full review770 BIA-203 Triangle Brick- Wadesboro Plant Wadesboro NC3/1/2005Straight from test report. Need to confirm if lb/ton numbers reported and productionrate to back into lb/hr. EPA and BIA lb/hr #'s match by this method, but then EPAdivided truncated number by production rate and got slightly lower em factor. Notsignificant.Needs full review769 BIA-203 Triangle Brick- Wadesboro Plant Wadesboro NC 3/14/2006 Straight from test reportNeeds full review736 BIA-014 Redland- Cushwa Plant Steel kiln Williamsport MD5/10/2006 tk-1 steel kiln Straight from test report.Needs full review566 BIA-103 Boral- Salisbury Plant Salisbury NC2/13/07 & 7/20/07 Plant 6EPA averaged the two tests, but cannot confirm HCl. BIA data suggests HCl=.046lb/ton. Plant 6Needs full review644 BIA-042 Glen-Gery Corporation-Marseilles Marseilles IL 11/8/2006 Kiln A Straight from test reportNeeds full review692 BIA-092 Lawrenceville- Plant III Lawrenceville VA9/2/2004 Kiln 4 Straight from test reportNeed to confirm which test used teflon filter. QA/QCdata needed to review non-detects.643 BIA-180 Glen-Gery Corporation-Hanley Summerville PA4/26/2005 Cannot confirm HCl .Teflon filter used. HCl number reported as 0 controlled.No analytical data available for further review. PMgained weight.606 BIA-204 General Shale Brick-Plant 40 Coosa GA 7/18/2007 Straight from test report Teflon filter used. No lab data available.506 BIA-163 Acme- Denver Plant (DVP) Castle Rock CO7/1998 & 8/13/03EPA averaged three tests for HF and HCL. One run for HF and HCL data 7/10reported 0 values. Cannot confirm PM, but close.Filter material not specified. Suspect glass filterbecause PM and HF in one train. Non-detects presentfor HF and HCl.Table 1. Preliminary Review of Test Reports Used to Generate Emission Factors for HF, HCl, and PM for the Brick IndustryKiln NoBIA_ID FacName City StateTest Report Used toGenerate Em FactorBIA Notes on Em Factor Generated by EPANotes on Test Reports Used to Generate EmissionFactor645 BIA-042 Glen-Gery Corporation-Marseilles Marseilles IL11/8/06 & 5/9/07 EPA averaged the two testsNeed to review. HCL numbers reported negativeefficiency. Test on 5/9/07 was for limestone change.Need to determine if this is indicative of process asnormally run.691 BIA-092 Lawrenceville- Plant III Lawrenceville VA 10/20/06 Kiln 3 Straight from test report. PM from front half (filterable) Teflon filter used. Test report ok.647 BIA-179 Glen-Gery Corporation-Mid Atlantic Shoemakersville PA 10/10/07 - Harrop Straight from test reportNeeds full review518 BIA-026 Acme- Texas Clay Plant (TCP) Malakoff TX3/26/2002HF and HCl lb/hr straight from test report. Need to confirm production rate. PM isfrom front half only.Need full test report to review. PM from front half only.Need to review514 BIA-085 Acme- Ouachita Plant (OEP) Malvern AR 3/27/2007 Straight from test report Run 1 should be excluded for failed leak check.542 BIA-096 Boral- Augusta Plants 3, 4, & 5 Augusta GA ? Cannot confirm em factorsIdentify tests and review543 BIA-096 Boral- Augusta Plants 3, 4, & 5 Augusta GA 11/1/2006 Straight from test for Plant #5Needs full review573 BIA-056 Carolina Ceramics Columbia SC 10/18/05 & 12/12/2000 Kiln 3 EPA averaged for HF, but HCl and PM only available on 12/12 test Needs full review574 BIA-056 Carolina Ceramics Columbia SC 11/30/2005 Kiln 4 Straight from test reportNeeds full review610 BIA-072 General Shale Brick-Plants 20, 32 & 43 Mooresville IN11/2/06 & 1/24/07 Kiln 32 EPA averaged the two tests. EPA did not use production rate to calc lb/ton11/2/06 test should be rejected. This test failed for SO2and process was changed permanently to the testconditions of 1/24/07 test. HF=.045lb/ton, HCl=.006lb/ton, PM=.03 lb/ton646 BIA-179 Glen-Gery Corporation-Mid Atlantic Shoemakersville PA 10/10/07 - Bickley Straight from test reportNeeds full review527 BIA-002 Belden- Plant #3 Sugarcreek Sugarcreek OH8/24/05 & 5/1/01EPA used average from the two test reports and capacity rather than productionduring test. Not significant.8/24/05 test is RATA.641 BIA-177 Glen-Gery Corporation - Iberia Iberia OH 4/26/2006 Straight from test reportNeeds full review673 BIA-009 Hanson Columbia - Plant 4 Columbia SC10/5/2006 HF is straight from test report. Cannot confirm HCl & PM exactly, but it's very close. Needs full review674 BIA-009 Hanson Columbia - Plant 4 Columbia SC517 BIA-088 Acme- San Felipe (SFP) Sealy TX4/12/2006HCL is straight from test report. Cannot confirm HF or PM. Test report:HF=.076lb/ton and PM=.103lb/ton. EPA table lists 20.14 as prod rate, but calcs looklike the actual production rate of 21.08 tph was used.OK to use583 BIA-037 Columbus Brick Company Columbus MS3/23/06 - kiln 3 Straight from test reportNeeds full review605 BIA-204 General Shale Brick-Plant 40 Coosa GA 7/19/07 & 2/26/08 EPA averaged the two tests. Kiln A QA/QC data needed for furtherreview.526 BIA-188 Belden- Plant #2 Sugarcreek (P102) Sugarcreek OH 1/17/06 &4/30/2001 &8/24/2005 (PM)HF & HCl lb/hr is average from 1/06 an 4/30 test reports. PM is average from 4/30and8/24. Cannot confirm production rate, though probably close.Need full test report to review649 BIA-181 Glen-Gery Corporation-York York PA 10/09/07 - Kiln 2 Straight from test reportNeeds full review537 BIA-097 Boral- Atlanta Plant Smyrna GA10/17/2006 EPA divided the results for two kilnsPM is at detection limit (<3mg capture) QA/QC dataneeded for further evaluation740 BIA-016 Redland- KF Plant South Windsor CT ? 6 tests available. Cannot confirm. Needs full review688 BIA-202 Jenkins-Jordan Plant Jordan AL4/18/08 & 2/21/08EPA averaged the two tests. Cannot confirm production rate. EPA used 26.46 andBIA shows avg of 32.5Needs full review544 BIA-096 Boral- Augusta Plants 3, 4, & 5 Augusta GA ? Cannot confirm em factorsIdentify tests and review577 BIA-093 Cherokee Brick & Tile Macon GA5/16/06, 12/13/06, 2/28/07,4/19/07Average of 4 test reports divided by 2. PM and production rate averaged these 4tests with 5/8/07 testNeeds full review578 BIA-093 Cherokee Brick & Tile Macon GANeeds full review812 BIA-081 Acme- Fort Smith Plant (FSP) Fort Smith AR12/10/2003Based on total emissions for batch as extrapolated from run data divided by batchcapacityNeeds full review741 BIA-099 Redland- Rocky Ridge Plant Rocky Ridge MD Aug-98 Straight from test reportNeeds full reviewTable 1. Preliminary Review of Test Reports Used to Generate Emission Factors for HF, HCl, and PM for the Brick IndustryKiln NoBIA_ID FacName City StateTest Report Used toGenerate Em FactorBIA Notes on Em Factor Generated by EPANotes on Test Reports Used to Generate EmissionFactor622 BIA-038 General Shale- Moncure Facility Moncure NC? Cannot confirm em factors Needs full review623 BIA-038 General Shale- Moncure Facility Moncure NC?614 BIA-073 General Shale Brick-Plants 35 & 36 Blue Ridge (Roanoke) VA 11/29/06, 5/20/08, 8/22/07,3/14/07 & 7/15/08EPA averaged 5 test reports Need s full review (7/15 full report avail on pdf)601 BIA-067 General Shale Brick-Plant 10 Johnson City TN7/27/1993USEPA Test report. Straight from test report. PM taken from Kiln CombustionExhaust Multiple Metals and Total Particulate Emissions.Appears to have used both front and back half for PM.551 BIA-113 Boral- Henderson Facility Henderson TX 3/02/95, 6/29/05, 2/14/96,8/03/99, 8/01/01, 3/13/03,5/25/04Cannot confirm PM Em Factors. Checked front half numbers, but still cannot confirm.EPA used average for HF from all tests and 8/01 and 3/13/02 for HCL then divided by2. First two tests are not listed as having been submitted.Needs full review552 BIA-113 Boral- Henderson Facility Henderson TX538 BIA-097 Boral- Atlanta Plant Smyrna GA10/17/06, 3/28/07, 2/15/07EPA used the per kiln result for 537 and averaged with two later tests. Used averageproduction during tests. Without 2/15 report, factors are not significantly different,except HCl=.019lb/ton3/28 test appears to be a re-do since 2/15 failed MACTcompliance. The 3/28 test cites that lab received rippedfilter, thus data should be REJECTED. Questionwhether other pollutant data should be used from 2/15test since it failed for HF. On 10/17 test, PM collectionbelow 3mg standard.720 BIA-128 Pacific Coast-West Jordan West Jordan UT 12/5/1994 Straight from test reportNeeds full review598 BIA-116 Endicott Clay Products Fairbury NE 7/6/1993 Straight from test reportNeeds full review763 BIA-148 Taylor Clay Salisbury NC 7/11/2000 Straight from test report for lb/hr HF. Cannot confirm production rate. Needs full review764 BIA-148 Taylor Clay Salisbury NCNeeds full review753 BIA-031 Statesville Brick Statesville NC5/15/1997 Straight from test reportNeeds full review516 BIA-087 Acme- Perla Plant (PEP/PWP) Malvern AR10/12/1993Straight from test report. Used Fluorides as HF. Need to confirm production rateduring test.Need full test report for review. Inappropriately usedfluorides emissions to represent HF (9/8/99 pre-proposal letter to EPA)539 BIA-102 Boral- Augusta Plant 6 Augusta GA 1991 Straight from test report, but need to confirm production rate during testing. Needs full review571 BIA-120 Bowerston- Bowerston Plant Bowerston OH11/16/2000 & 9/27/07 (HF)EPA averaged two tests for HF and used single data from 11/16 for PM. Cannotconfirm production rate.Needs full review555 BIA-110 Boral- Macon, MS Plant Macon MS4/22/1999Straight from test report. Fluorides as HF. No differentiation between total PM orfront half.Need full test report for review. Inappropriately usedfluorides emissions to represent HF (9/8/99 pre-proposal letter to EPA)569 BIA-108 Boral- Van Wyck Plants Van Wyck SC1997Straight from test but need confirmation on capacity versus production. Need toconfirm Plant B=tk-1 and Kiln #3=tk2Needs full review804 BIA-075 Acme- Bennett Plant (BEP) Millsap TX 2/12/2003 Cannot confirm, but can get closeNeeds full review591 BIA-053 Cunningham- Thomasville Thomasville NC 4/22/97 tk-1 Need to confirm capacity versus production rate. Lb/hr #s confirmedNeeds full review565 BIA-103 Boral- Salisbury Plant Salisbury NC9/8/2005 Plant 5 EPA used kiln exhaust data and excluded SD dryer. Needs full review694 BIA-055 Lee Brick Sanford Facility Sanford NC4/18/1997 Kiln 2 Straight from test reportNeed full test report for review. Inappropriately usedfluorides emissions to represent HF (9/8/99 preproposal letter to EPA)665 BIA-010 Hanson - Ninety Six Ninety-Six SC 7/11/1997 tk-3 Cannot confirm production rate. Lb/hr numbers are confirmed Needs full review704 Metropolitan Ceramics, Inc. Canton OH 3/30/94 & 11/18/93?Cannot confirm but can get close on HF. BIA has no PM dataNeeds full review705 Metropolitan Ceramics, Inc. Canton OHTable 1. Preliminary Review of Test Reports Used to Generate Emission Factors for HF, HCl, and PM for the Brick IndustryKiln NoBIA_ID FacName City StateTest Report Used toGenerate Em FactorBIA Notes on Em Factor Generated by EPANotes on Test Reports Used to Generate EmissionFactor706 Metropolitan Ceramics, Inc. Canton OH650 BIA-152 Hanson - Athens Athens TX663 BIA-010 Hanson - Ninety Six Ninety-Six SC 3/7/1997 tk-1 Straight from test reportNeeds full review570 BIA-108 Boral- Van Wyck Plants Van Wyck SC695 BIA-055 Lee Brick Sanford Facility Sanford NC3/29/2005 Kiln 3 Straight from test reportEngineering tests557 BIA-098 Boral- Marshall Plant Marshall TX1986 & 3/29/02HF is from average of the two tests. HCl was only available from 02 test. Need toconfirm capacity versus production rate during test.Need full test to review530 BIA-004 Belden- Plant #6 Sugarcreek Sugarcreek OH11/93, 5/94, for HF, HCl andadded in 5/07 for PMEPA used average of first two tests for HF and HCl, and averaged all three for PM.Ohio EPA rejected 5/07 test report due to port location. Without this, PM=4.06 lb/hr or1.24 lb/ton. EPA used the production rates from first two tests only and did notconsider that 5/07 results were for three kilns.Ohio EPA rejected test report dated 5/07 due to portlocation.549 BIA-112 Boral- Gleason Plant Gleason TN 11/4/1998 Straight from test report.Needs full review559 BIA-106 Boral- Phenix City-Plant 3 Phenix City AL?Need to identify test report. We have 10/03/07 and 10/04/07 for No.1 and No. 2 kilns(not sure of plant id) but only unctrld PM. Need to review.Need full test report to review808 BIA-076 Acme- Bridgeport Plant (BPP) Bridgeport TX5/21/2003Based on total emissions for batch as extrapolated from run data divided by batchcapacityNeed to review (Periodic)553 BIA-101 Boral- Lexington Plant Lexington SC 1/23/1997 Straight from test report.Needs full review510 BIA-138 Acme- Eureka Plant (EBP) Clarksville AR3/4/1996EPA took the average of two tests performed on the same day and used capacity of4.98 instead of 3.67tph as reported.Calc'd average using fluorides (13B) and HF(26A). 13Bprovides no speciation of gaseous fluoride and shouldnot be considered. (9/8/99 pre-proposal letter to EPA)Need full test report to review535 BIA-006 Belden- Plant #9 Sugarcreek Sugarcreek OH5/4/01 & 5/94 & 5/07(PM)EPA used average of first two tests for HF and HCl, and averaged all three for PM.Ohio EPA rejected 5/07 test report due to port location. Without this, PM=2.03 lb/hr or.812 lb/ton. EPA used the production rates from first two tests only and did notconsider that 5/07 results were for two kilnsOhio EPA rejected test report dated 5/07 due to portlocation.670 BIA-021 Hanson - Stanton Stanton KY 12/1/2004 straight from test reportNeeds full review669 BIA-021 Hanson - Stanton Stanton KY 12/1/2004 straight from test reportNeeds full review710 BIA-143 Mutual Materials-Newcastle Renton WA 4/22/1994 Cannot confirm production rate. Lb/hr numbers are confirmed Needs full review529 BIA-004 Belden- Plant #6 Sugarcreek Sugarcreek OH5/94 &5/01Kiln 2EPA used average of two test reports, but production rate from 5/94. Average wouldbe 3.63 so numbers would be very close.Needs full review737 BIA-014 Redland- Cushwa Plant Brick Kiln Williamsport MD4/05 & 11/12/96 tk2 brick unctrlAverage from two test reports.Needs full review521 BIA-089 Acme- Tulsa Plant (TUP) Tulsa OK9/6/2002HF and HCl lb/hr straight from test report. Need to confirm production rate. PM isfrom front half only.Teflon filter used. PM from front half only.515 BIA-087 Acme- Perla Plant (PEP/PWP) Malvern AR 9/3/1996 Straight from test report. Need to confirm production rate during test Needs full review528 BIA-004 Belden- Plant #6 Sugarcreek Sugarcreek OH5/30/2007Straight from test report. EPA divided lb/hr number by 3. Need to confirm productionrate during testNeeds full review534 BIA-006 Belden- Plant #9 Sugarcreek Sugarcreek OH 5/31/2007 Divided test lb/hr by two for P101 and P102. Production number ok Needs full review616 BIA-071 General Shale Brick-Plants 6 & 28 Atkins (Marion) VA ?BIA has no test reports for this facility617 BIA-071 General Shale Brick-Plants 6 & 28 Atkins (Marion) VA ?775 BIA-201 Whitacre Greer Alliance OH5/9/06 P004 Straight from test reportNeeds full review776 BIA-201 Whitacre Greer Alliance OH