# Cornpliance Stack E nission Test Report Determination of Total Filterable Particulate Matter, Hydrogen Chloride, Hydrogen Fluoride and Visible Emissions

Kiln No. 2 EPA Methods 1, 2, 3, 4, 5, 9 and 26A Glen-Gery Coruoration - York Facility

York, Pennsylvania Date Conducted: October 9, 2007 Job Number: 070918

Prepared by: 

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# ing, Inc.
PO Box 41156 Cleveland OH 44141-0156 Phone: (800) EPA-AIR7 (372-2471) 

### Report Date: November 7, 2007

### SuperiorQuality 

# Air Compliance

Emission Testing. Valid Results 

# Testing, Inc. Guaranteed. P.O. Box 41156 Cleveland, Ohio 44141 1-800-EPA-AIR1 www.aircomp.com

testing@aircomp.com 

### November 7, 2007 Jerry Carrier Director of Research/Development Glen-Gery Corporation - York Facility 433 South Pottsville Pike Shoemakersville, Pemisylvania 19555 Dear Jerry: The following report provides the results of the compliance emission testing conducted on October 9, 2007. These results are a product of the application of the U.S. EPA Stationary Soarce Sampling Methods listed in 40 CFR Part 60 Appendix A that were in effect at the time of this test. Please mail one copy of this report along with any other supportive process operating data collected during this test to your local EPA representative. You should also attach a cover letter (on company letterliead) stating the purpose and the outcome of this test. Additionally, you may address, preferably in a timetable format, any obligations or implications that might be necessary to achieve environmental compliance because of the result of this test. Please do not hesitate to call if you have any questions or concerns about these test results. On behalf of Air Compliance Testing, I would also like to personally thank you for the opportunity to work with you on this testing project and would enjoy the opportunity to work with you again on any additional future testing projects. 

## Sincerely, 

# v Phaneendra 

# G Uppalapati Air Quali Engineer

0 

# y~ Robert J. Lisy, . Quality Assurance Officer

### Compliance Stack Emission Test Report Glen-Gerv Corporation - York Facilitv 

# Table of Contents Page 1.0 INTRODUCTION 2 l.l Summary of Test Program 2 1.2 Key Personnel 2 2.0 SUMMARY AND DISCUSSION OF TEST RESULTS 3 2.1 Objectives and Test Matrix 3 2.2 Field Test Changes and Problems 3 23 Presentation of Results 4 3.0 PLANT AND SAMPLING LOCATION DESCRIPTIONS 7 3.1 Process Description and Operation 7 3.2 Control Equipment Description 7 3.3 Flue Gas Sampling Locations 7 3.4 Process Sampling Location 8 4.0 SAMPLING AND ANALYTICAL PROCEDURES 12 4.1 Test Methods 12 4.2 Procedures for Obtaining Process Data 13 5.0 INTERNAL QA/QC ACTIVITIES I S 5.1 QA Audits IS 5.2 QA/QC Problems 15 6.0 APPENDIX 19

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### Compliance Stack Emission Test Report Glen-Gerv Corporation - York Facilitv



## 1.0 INTRODUCTION 1.1 Summary 

## of Test Program Glen-Gery Corporation - York Facility, located in York, Pennsylvania contracted Air Compliance Testing, Ine. of Cleveland, Ohio to conduct compliance stack emission testing for their Kiln No. 2. Testing was performed to satisfy the emission testing requirements pursuant to Operating Permit No. 67-05045B. The testing was performed on October 9, 2007. Simultaneous sampling was perforined at the Kiln No. 2 Dry Limestone Adsorber (DLA) Inlet Duct and at the ICiln No. 2 DLA Exhaust Stack to determine the mass emission rate of hydrochloric acid (HCI) and hydrofluoric acid (HF). Sampling was also performed at the Kiln No. 2 DLA Exhaust Stack to deterinine the mass emission rate oftotal filterable particulate inatter (PM). Visible Emissions (VEs), measured as percent opacity were also determined at the Kiln No. 2 DLA Exriaust Stack. Testing was conducted while operating at maximum production level for the products listed in the appendix. During this test emissions from Kiln No. 2 were controlled by the DLA. The test methods that were conducted during this test were EPA Methods I, 2, 3, 4, 5, 9, and 26A. 1.2 Key Personnel The key personnel who coordinated this test program (and their phone numbers) were: Jerry Carrier, Director of Research/Development, Glen-Gery Corporation, 610-374-4011 Rick Millard, Pennsylvania Dept of Environmental Proteetion, 717-783-2300 Philip J. Billick, President, Air Compliance Testing, Inc. 800-372-2471 S'rn Hoi Chiew, Project Manager, Air Compliance Testing, Inc. 800-372-2471

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### Compliance Stack Emission Test Repo t Glen-Gerv Corporation - York Facilitv 

## 2.0 SUMMARY AND DISCUSSION OF TEST RESULTS 2.1 Objectives and Test Matrix 

## The purpose of this test was to determine the mass emission rate of HCl and HF at the Kiln No. 2 DLA Inlet Duct and at the Kiln No. 2 DLA Exhaust Stack and also to detennine the mass emission rate of total filterable PM at the Kiln No. 2 DLA Exhaust Stack while operating at maximum production levels for the products listed in the appendix at a predetennined limestone extraction setting. The purpose of this test was also to determine VEs (as %-opacity) at the Kiln No. 2 DLA Exhaust Stack while operating at maximum production levels for the products listed in the appendix at a predetermined limestone extraction setting. Testing was performed to prove compliance with the Plan Approval Requirements of Operating Permit No. 67-05045B. The specific test objectives for this test were to: 

## Measure the concentration of I-ICl and HF at the Kiln No. 2 DLA Inlet Duct and at the Kiln No. 2 DLA Exhaust Stack and also measure the concentration of total filterable PM at the Kiln No. 2 DLA Exhaust Stack while operating at maximum production levels for the products listed in the appendix at a predetermined limestone extraction setting. Measure the dry standard and actual volumetric flow rate of the stack gas at the Kiln No. 2 DLA Inlet Duct and at the Kiln No. 2 DLA Exhaust Stack while operating at maximum production levels for the products listed in the appendix at a predetermined limestone extraction setting. Utilize the above variables to determine the mass emission rate of HCl and HF at the Kiln No. 2 DLA Inlet Duct and at the Kiln No. 2 DLA Exhaust Stack and also determine the mass emission rate of total filterable PM at the Kiln No. 2 DLA Exhaust Stack while operating at maximum production levels for the products listed in the appendix at a predetermined limestone extraction setting. Deterinine VEs (as %-opacity) Kiln No. 2 DLA Exhaust Stack while operating at maximum production levels for the products listed in the appendix at a predetermined limestone extraction setting. Table 2.1 presents the sampling and analytical matrix log for this test. 2.2 Field Test Changes and Problems 

## No 6eld test changes or problems occurred during the performance of this test that would bias the accuracy of the results of this test.

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### Compliance Stack Emission Test Report Glen-Gerv Corporation
- York Facilitv



### 2.3 Presentation of Results A single sampling train was utilized during each run at each location to determine the mass emission rate of HCI and HF at the Kiln No. 2 DLA Inlet Duct and at the Kiln No. 2 DLA Exhaust Stack and also determine the mass emission rate of total filterable PM at the Kiln No. 2 DLA Exhaust Stack while operating at maximum production level for the products listed in the appendix at a predetermined limestone extraction setfing. A single sampling train at the Kiln No. 2 DLA Inlet Duct measured the stack gas volumetric flow rate, dry molecular weight, moisture content, and eoncentrations of HCI and HF. A single sampling train at the ICiln No. 2 DLA Exhaust Stack measured the stack gas volumetric flow rate, dry molecular weight, moisture content, and concentrations of total filterable PM, HCI, and HF. Table 2.2 displays the mass einission rate of HCI and HF measured at the Kiln No. 2 DLA Inlet Duct and at the Kiln No. 2 DLA Exhaust Stack and also displays the mass emission rate of total filterable PM measured at the Kiln No, 2 DLA Exhaust Stack while operating at maximum production levels for the products listed in the appendix at a predetermined limestone extraction setting. Table 2.2 also displays the maximum 6-minute average of opacity measured at the Kiln No. 2 DLA Exhaust Stack while operating at a maximum production level for the products listed in the appendix at a predetermined limestone extraction setting.

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## 3.0 PLANT AND 8AMPLING LOCATION DESCRIPTIONS 34 Process Description and Operation Glen-Gery Corporation - York facility operates two natural gas-fired tunnel kilns. The kilns produce brick of various sizes and colors. Kiln 2(Unit ID 102) has been fitted with a dry limestone absorber (DLA) system manufactured by Hellmich to control Hydrogen Fluoride and Hydrogen Chloride emissions. The Kiln No. 2 was in operation during the performance of this test event. Figure 3.1 depicts the process schematic. 

## 3.2 Control Equipment Description The DLA system is comprised of a liinestone cascade absorber equipped with a limestone silo located atop the DLA Exhaust gases froin the kihi pass through the absorber. The absorber is equipped with a peeling drum that mechanically removes the reacted layer from the crushed lunestone. The "peeled" limestone is pneuinatically conveyed from the peeling drum back to the limestone feed bin, located on top of the absorber. The reacted layer that has been peeled from the limestone is discharged via gravity to a hopper for disposal. During this test emissions from the Kiln No. 2 were controlled by the DLA and the bypass damper was closed.


## 3.3 Flue Gas Sampling Locations 3.3.1 - Kiln No. 2 DLA Inlet Duct 

### The Kiln No. 2 DLA Inlet Duct was elliptical in shape with measured inner diameters of 47.5-inches and 47.7- inches. The stack was oriented in the horizontal plane and was accessed from a perinanent platform. Two (2) 4.0-inch I.D. sampling ports were located 90 0 apart from one another at a location that met EPA Method 1, Section 1 1.1.1 criteria. On July 23, 2007, the stack was traversed to verify the absence of cyclonic flow. An average yaw angle of 6.83° was measured. Therefore, the sampling location also met EPA Method 1, Section 11.4.2 criteria. During emissions sampling, the stack was traversed for stack gas volumetric flow rate, dry molecular weight, moisture content, HCI, and HF concentration determination.

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### Compliance Stack Emission Test Report Glen-Gerv Corporation
- York Facility



### 33.2 - Kiln No. 2 DLA Exhaust Stack The Kiln No. 2 DLA Exhaust Stack was elliptical in shape with measured inner diameters of 47.5-inches and 47.0-inches. The stack was oriented in the vertical plane and was accessed from a permanent platform. Two (2) 4.0-inch I.D. sampling ports were located 90° apart from one another at a location that met EPA Method 1, Section 1 l.l .l criteria. On July 23, 2007, the stack was traversed to verify the absence of cyclonic flow. An average yaw angle of 3.42° was measured. Therefore, the sampling location also met EPA Method 1, Section 11.4.2 criteria. During emissions sampling, the stack was traversed for stack gas volumetric flow rate, dry molecular weight, moisture content, total filterable PM, HCI, and FTF concentration determination. Figures 3.2 and 3.3 schematically illustrate the traverse point and sample port locations utilized. 3.4 Process Sampling Location Proeess sampling was completed by Glen-Gery as part of their QA/QC program and included raw material sampling at the pug mill as well as Fire Check Key testing in the kiln. In addition, '/z brick was removed from cars after the drier/prior to kiln entry as well as at kiln exit for purposes of mass balance testing if results of the stack test did not indicate compliance. Results from the QA/QC testing were unavailable at the time of this report.

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Compliance Stack Emission Test Report Glen-Gerv Corporation - York Facilitv



## C~ 120.0"

2.53 Equivalent Diameters Upstream from Disturbance

(2) 4.0" I.D.

~ Sampling Ports

located 90°Apart

660.0" 13.89 Equivalent Diameters Downstream from Disturbance 

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Elliptical Stack Port 2


### Distance From Distance From Point % of Duct Depth Inside Wall (in.) Inside Wall (in.) Port 1 Pnrt 2 1 4.4 2.1 2.1 2 14.6 6.9 6.9 3 29.6 14.1 1319 4 70.4 33.4 33.1 5 85.4 40.6 40.1 6 95.6 45.4 44.9


## Figure 3.3 - Kiln No. 2 DLA Lxhaust Stack Traverse Point Location Drawing

Test Date: October 9, 2007 Page 11 Air Compliance Testing, Inc. - 070918Compliance Stack Emission Test Report Gien-Gerv Corporation - York Facility

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## 4.1.1 EPA Method 1: Sample and Velocity Traverses for Stationary Source Principle: To aid in the representative measurernent of pollutant emiesions and/or total volumetric flow rate from a stationary source, a measurement site where the effluent stream is flowing in a known direction is selected, and the cross-section of the stack is divided into a number of equal areas. A traverse point is then located within each of these equal areas. This method was utilized in its entirety as per the procedures outlined in 40 CFR Part 60, Appendix A. 4.1.2 EPA Method 2: Deterinination of Stack Gas Velocity and Volumetric Flow Rate (Type S) Principle: The average gas velocity in a stack is determined from the gas density and from measurement of the average velocity head with a Type S(Stausscheibe or reverse type) pitot tabe. This method was utilized in its entirety as per the procedures outlined in 40 CFR Part 60, Appendix A. 4.1.3 EPA Method 3: Gas Analysis for the Determination of Dry Molecular Weiglit Principle: A gas sample is extracted from a stack by one of the following methods: (1) single-point, grab sampling; (2) single-point, integrated sampling; or (3) multi-point, integrated sampling. The gas sample is analyzed for percent CO 2 , percent 0 2 , and if necessary, for percent CO. For dry molecular weight determination a Fyrite analyzer will be used for the analysis. This method was utilized in its entirety as per the procedures outlined in 40 CFR Part 60, Appendix A. 4.1.4 EPA Method 4: Determination of Moisture Content in Stack Gases Principle: A gas sample is extracted at a constant rate from the source; moisture is removed from the sample stream and determined either volumetrically or gravimetrically. This method was utilized in its entirety as per the procedures outlined in 40 CFR Part 60, Appendix A. 4.1.5 EPA Method 5: Determination of Particulate Emissions from Stationary Sources (Front-Half PM only) Principle: Particulate matter (PM) is withdrawn isokinetically from the source and collected on a glass fiber filter maintained at a temperature in the range of 120 ± 14°C (248 t 25°F) or such other temperature as speeified by an applicable subpart of the standards or approved by the Administrator, U.S. Environmental Protection Agency, for a particular application. The PM mass, which includes any material that condenses at or above the filtration temperature, is determined gravimetrically after removal of uncombined water. This method was utilized in its entirety as per the procedures outlined in 40 CFR Part 60, Appendix A. 4.1.6 EPA Method 9: Visual Determination of the Opacity of Emissions from Stationary Sources Principle: The opacity of emissions from stationary sources is deterinined visually by a qualified observer. This method was utilized in its entirety as per the procedures outlined in 40 CFR Part 60, Appendix A.

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### Compliance Stack Emission Test Report Glen-Gerv Corporation - York Facilitv



### 4.1.7 EPA Method 26A: Deterinination of Hydrogen Halide and Halogen Emissions from Stationary SourcesIsokinetic Method Principle: This method is applicable for determining emissions of hydrogen halides (HX) [hydrogen chloride (HCl), hydrogen bromide (HBr), and hydrogen fluoride (HF)] and halogens (X Z ) [ 

### chlorine (C1 2 ) 

### and bromine (Br Z )] from stationary sources. This method collects the emission sample isokinetically and is therefore particularly suited for sampling at sources, such as those controlled by wet scrubbers, emitting acid particulate matter (e.g., hydrogen halides dissolved in water droplets). This method was utilized in its entirety as per the procedures outlined in 40 CFR Part 60, Appendix A. The sampling train utilized during this testing project is depicted in Figure 4.1. 

## 4,2 Procedures for Obtaining Process 

## Data Process data was recorded by Glen-Gery Corporation - York Facility personnel utilizing their typical record keeping procedures. Recorded process data was provided to Air Compliance Testing, Ine, personnel at the conclusion of this test event. The process data is located in the Appendix and includes the following. Glen-Gery personnel recorded the following process data during the performance test: Kiln Throughput (Tons fired brick/hour) Type of Brick in Kiln during testing Bypass Damper Position Limestone extraction setting Source and Grade of Limestone

Test Date: October 9, 2007 Page 13 Air Compliance Testing, lne. - 070918

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## 5.0 INTERNAL QA/QC ACTIVITIES 5.1 

## QA Audits Tables 5.1 - 5.3 illustrate the QA audit activities that were performed during this test. All meter boxes and sampling trains used during sainpling performed within the requirements of their respective methods as is shown in Tables 5.1 and 5.2. Al) pre-test and post-test leak checks were well below the applicable limit. Minimum metered volumes and percent isokinetics were also inet where applicable. Table 5.3 displays the results of the EPA Metliod 26A Audit Sample analysis. The results were transmitted by e-mail to Mr. Rick Millard, Pennsylvania Dept of Environmental Protection. On October 30, 2007, Mr. Millard informed Air Compliance Testing, Inc. that the two (2) reported audit concentrations met EPA Method 26A, Section t 1.5.3 criteria. S}hawn Bodnar was certified on October 3, 2007 as a Visible Emissions Evaluator. The certification expires in six months from the issue date. Por quality assurance, the observer obtained a view of the einissions with the best available contrasting background and w'rth the sun oriented in the 140° sector to his back. Readings were taken every 15 seconds and made to the nearest 5% opacity. 5.2 QA/QC ProBlems No QA/QC problems occurred during this test event.

Test Date: October 9, 2007 Page 15 Air 

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## _•94, 1 G7/1 Appendix attached.

Test Date: October 9, 2007 Page 19 Air Compliance Testing, Inc. - 070918

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## Compliance Stack Emission Test Report 

# Determination of Total Falterable Particulate Matter, Hydrogen Chloride, Hydrogen Fluoride and Visible Emissions

Kiln No. 2 EPA Methods 1, 2, 3, 4, 5, 9 and 26A Glen-Gerv Corporation - York Facility

York, Pennsylvania Date Conducted: October 9, 2007 Job Number: 070918

Prepared by: 

## Air Compliance Testing, Inc.

PO Box 41156 Cleveland OH 44141-0156 Phone: (800) EPA-AIR1 (372-2471) 

### Report Date: November 7, 2007O

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