# Brick and Structural Clay Products ICR Test Report

Test Location General Shale Brick, Inc.

121 Turners Bend SW Rome, GA 30165 

### Test Dates July 12, 2011



### Source Tested Tunnel Kiln (EU ID: tk-2)

Dry Sorbent Injection/fabric filter (Control/Stack ID: diff-2)



### Report Prepared by Alliance Source Testing, LLC 214 Central Circle SW Decatur, Alabama 35603 

### Project Number 2011-0172R1



### Report Submittal Date August 16, 2011 September 26, 2011 (revised)General Shale Brick, Inc. ICR Test Report Certification Statement

c:\\Projects\General Shale\Rome, GA\2011-0172R1\ICR Test Report Page i Certification Statement
Alliance Source Testing, LLC (AST) of Decatur, AL has completed the source testing as described in this report. Results apply only to the source(s) tested and operating condition(s) for the specific test date(s) and time(s) identified within this report. All results are intended to be considered in their entirety, and AST is not responsible for use of less than the complete test report without written consent. This report shall not be reproduced in full or in part without written approval from the customer. To the best of my knowledge and abilities, all information, facts and test data are correct. Data presented in this report has been checked for completeness and is accurate, error-free and legible. Onsite testing was conducted in accordance with approved internal Standard Operating Procedures. Any deviations or problems are detailed in the relevant sections on the test report.

9/26/2011 

### Jeremy Hutchens, QSTI Project Manager Alliance Source Testing, LLC Date

This document was prepared in portable document format (.pdf) and contains pages as identified in the bottom footer of this document.

Questions or comments regarding this report should be directed to the persons identified below. Facility Contact Test Firm Contact
Martha West General Shale Brick, Inc. P.O. Box 3547 Johnson City, TN 37602 (423) 952-4240 martha.west@generalshale.com Jeremy Hutchens Alliance Source Testing, LLC 214 Central Circle SW Decatur, AL 35603 (256) 260-3974 jeremy.hutchens@stacktest.com www.alliancesourcetesting.comGeneral Shale Brick, Inc. ICR Test Report Table of Contents

c:\\Projects\General Shale\Rome, GA\2011-0172R1\ICR Test Report Page ii TABLE OF CONTENTS
Certification Statement ...................................................................................................................................................i 1.0 Introduction .................................................................................................................................................. 1-1 1.1 Source and Control System Descriptions................................................................................................. 1-1 1.2 Project Team ............................................................................................................................................ 1-1 2.0 Summary of Results ..................................................................................................................................... 2-1 3.0 Testing Methodology.................................................................................................................................... 3-1 3.1 U.S. EPA Reference Test Methods 1 & 2 – Volumetric Flow Rate......................................................... 3-1 3.2 U.S. EPA Reference Test Methods 3 & 3A – Oxygen/Carbon Dioxide .................................................. 3-1 3.3 U.S. EPA Reference Test Method 4 – Moisture Content......................................................................... 3-1 3.4 U.S. EPA Reference Test Method 26 – Hydrogen Fluoride .................................................................... 3-1 3.5 Quality Assurance/Quality Control – U. S. EPA Reference Test Method 3A ......................................... 3-2

LIST OF TABLES Table 1-1 Project Team........................................................................................................................................ 1-1 Table 2-1 Summary of Process & Production Data ............................................................................................. 2-1 Table 2-2 Summary of Emission Testing Results ................................................................................................ 2-1 Table 3-1 Source Testing Methodology............................................................................................................... 3-1

APPENDICES Appendix A Sample Calculations Appendix B Field Data Appendix C Laboratory Data Appendix D Quality Assurance/Quality Control Data Appendix E Process Operating/Control System Data Appendix F Laboratory Reporting Limits

# IntroductionGenerals Shale Brick, Inc. ICR Test Report Introduction

c:\\Projects\General Shale\Rome, GA\2011-0172R1\ICR Test Report Page 1-1 1.0 Introduction Alliance Source Testing, LLC (AST) was retained by General Shale Brick, Inc. (General Shale) to conduct Brick and Structural Clay Products Information Collection Request (ICR) testing at the Rome, GA facility. General Shale is subject to provisions of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Brick and Structural Clay Products facilities as detailed in 40 CFR 63, Subpart JJJJJ and the Georgia Department of Natural Resources issued permit. The United States Environmental Protection Agency (U.S. EPA) requested in a Section 114 letter, pursuant to its authority under section 114 of the Clean Air Act, emissions data for certain pollutants. U.S. EPA’s specific request included a determination of hydrogen fluoride (HF) emissions. Testing was conducted to determine the aforementioned target pollutant emissions from one (1) tunnel kiln with dry sorbent injection filter/fabric filter (baghouse). All testing in this report was conducted under normal process operations.

1.1 Source and Control System Descriptions Brick exterior building material is manufactured at this facility. Shale and clay are mined, crushed and sent through a screening process prior to brick forming by extrusion. Once the brick is extruded, it is dried in a tunnel Kiln at temperatures exceeding 1,900 °F. After being fired, the brick is cooled, packaged and shipped to various locations. The emissions are controlled with a baghouse. Only the B-Kiln was operating during testing.

1.2 Project Team Personnel involved in this project are identified in the following table.

Table 1-1 Project Team AST Personnel Facility Personnel Jeremy Hutchens – Project Manager Brandy Hughes – Report Coordinator Andy Roth – Onsite Team Leader Kenny Boyd – Technician Anthony Tebben – Technician Simon Gregg – Technician Martha West

# Summary of ResultsGeneral Shale Brick, Inc. ICR Test Report Summary of Results

c:\\Projects\General Shale\Rome, GA\2011-0172R1\ICR Test Report Page 2-1 2.0 Summary of Results AST conducted Brick and Structural Clay ICR testing on a tunnel kiln at the General Shale facility in Rome, GA. Testing was conducted July 12, 2011 and consisted of three (3) test runs for HF. Table 2-1 provides a summary of the process operating and control system data collected during the performance test. Table 2-2 provides a summary of the emission testing results. Any difference between the summary results listed in the following tables and the detailed results contained in Appendix B is due to rounding for presentation.

Table 2-1 Summary of Process & Production Data

Parameter Average during Runs 1-3 Test Date 7/12/11 Brick Production 18.55 tph/ 16.84 Mg/hr (10,305 brick/hr) Coal Usage 1,250 lb/hr Bi-Carb Feedrate 150 lb/hr
Table 2-2 Summary of Emission Testing Results

Parameter Run 1 Run 2 Run 3 Average Test Date 7/12/11 7/12/11 7/12/11
-- Outlet Hydrogen Fluoride Data Concentration, ppmvd @ 7 % O 2 231.2 277.3 271.3 259.9 Emission Rate, kg/hr 2.0 2.6 2.5 2.4 Emission Factor, kg/MG 0.12 0.16 0.15 0.14

# Testing MethodologyGeneral Shale Brick, Inc. ICR Test Report Testing Methodology

c:\\Projects\General Shale\Rome, GA\2011-0172R1\ICR Test Report Page 3-1 3.0 Testing Methodology The emission testing program was conducted in accordance with the test methods listed in Table 3-1. Method descriptions are provided below while quality assurance/quality control data is provided in Appendix D.
Table 3-1 Source Testing Methodology

Parameter Test Methods Notes/Remarks Volumetric Flow Rate (VFR) U.S. EPA Reference Test Methods 1 & 2 Full Velocity Traverses Oxygen/Carbon Dioxide (O 2 /CO 2 ) U.S. EPA Reference Test Method 3/3A Integrated Bag/ Instrumental Analysis Moisture Content (BWS) U.S. EPA Reference Test Method 4 Volumetric /Gravimetric Analysis Hydrogen Fluoride (HF) U.S. EPA Reference Test Method 26 Isokinetic Sampling

3.1 U.S. EPA Reference Test Methods 1 & 2 – Volumetric Flow Rate The sampling location and number of traverse (sampling) points were selected in accordance with U.S. EPA Reference Test Method 1. A full velocity traverse was conducted in accordance with U.S. EPA Reference Test Method 2 to determine the average stack gas velocity pressure, static pressure and temperature. The velocity and static pressure measurement system consisted of an S-type pitot tube and inclined manometer while the stack gas temperature was measured with a K-type thermocouple and pyrometer.

3.2 U.S. EPA Reference Test Methods 3 & 3A – Oxygen/Carbon Dioxide The oxygen and carbon dioxide concentrations were determined in accordance with U.S. EPA Reference Test Methods 3/3A. One (1) integrated Tedlar bag sample was collected during each test run. The bag samples were analyzed on site with a California Analytical Instruments Model 300P O 2 /CO 2 /CO analyzer. The remaining stack gas constituent was assumed to be nitrogen for the stack gas molecular weight determination. The quality control measures are described in Section 3.5.
3.3 U.S. EPA Reference Test Method 4 – Moisture Content The stack gas moisture content was determined in accordance with U.S. EPA Reference Test Method 4. The gas conditioning train consisted of a series of chilled impingers. The impinger contents were pre and post-measured to determine the amount of moisture condensed during each test run.
3.4 U.S. EPA Reference Test Method 26 – Hydrogen Fluoride The hydrogen fluoride concentration was determined in accordance with U.S. EPA Reference Test Method 26. The complete sampling system consisted of a heated glass-lined probe, Teflon filter, gas conditioning train, pump and calibrated dry gas meter. The gas conditioning train consisted of four (4) impingers contained in an ice/water bath. The first and second impingers contained 0.1 N H 2 SO 4 , the third was initially empty and the fourth impinger contained silica gel. The probe and filter box temperatures were maintained above 250°F, and the impinger exit gas temperature were maintained below 68°F throughout the testing.General Shale Brick, Inc. ICR Test Report Testing Methodology

c:\\Projects\General Shale\Rome, GA\2011-0172R1\ICR Test Report Page 3-2 Following the completion of each test run, the sampling train was leak checked at a vacuum pressure greater than or equal to the highest vacuum pressure observed during the run. The absorbing solution (0.1 N H 2 SO 4 ) from the first and second impingers was placed into sample Container 1. The back-half of the filter holder, first, second and third impingers and all glassware leading to the outlet of the third impinger were triple-rinsed with DI water. These rinses were also placed in Container 1. The samples were sealed, labeled and liquid levels marked for transport to Maxxam Analytics, Inc. of Mississauga, Ontario, Canada.

3.5 Quality Assurance/Quality Control – U. S. EPA Reference Test Method 3A Cylinder calibration gases were supplied by AirGas – South or NexAir which met Protocol 1 (+/- 2%) standards. Low Level gases were introduced directly to analyzer. After adjusting the analyzer to the Low Level gas concentration and once the analyzer reading was stable, the analyzer reading was recorded. This process was repeated for the High Level gas. Next, Mid Level gases were introduced directly to analyzer and reading was recorded. All recording readings were within +/- 2 percent of the Calibration Span. All data was reviewed by the Field Team Leader before leaving the facility. Once arriving at AST’s office, all written and electronic data was relinquished to the report coordinator and then a final review was performed by the Project Manager.General Shale Brick, Inc. ICR Test Report Table of Contents

c:\\Projects\General Shale\Rome, GA\2011-0172R1\ICR Test Report Page ii TABLE OF CONTENTS
Certification Statement ...................................................................................................................................................i 1.0 Introduction .................................................................................................................................................. 1-1 1.1 Source and Control System Descriptions................................................................................................. 1-1 1.2 Project Team ............................................................................................................................................ 1-1 2.0 Summary of Results ..................................................................................................................................... 2-1 3.0 Testing Methodology.................................................................................................................................... 3-1 3.1 U.S. EPA Reference Test Methods 1 & 2 – Volumetric Flow Rate......................................................... 3-1 3.2 U.S. EPA Reference Test Methods 3 & 3A – Oxygen/Carbon Dioxide .................................................. 3-1 3.3 U.S. EPA Reference Test Method 4 – Moisture Content......................................................................... 3-1 3.4 U.S. EPA Reference Test Method 26 – Hydrogen Fluoride .................................................................... 3-1 3.5 Quality Assurance/Quality Control – U. S. EPA Reference Test Method 3A ......................................... 3-2

LIST OF TABLES Table 1-1 Project Team........................................................................................................................................ 1-1 Table 2-1 Summary of Process & Production Data ............................................................................................. 2-1 Table 2-2 Summary of Emission Testing Results ................................................................................................ 2-1 Table 3-1 Source Testing Methodology............................................................................................................... 3-1

APPENDICES Appendix A Sample Calculations Appendix B Field Data Appendix C Laboratory Data Appendix D Quality Assurance/Quality Control Data Appendix E Process Operating/Control System Data Appendix F Laboratory Reporting Limits

# IntroductionGenerals Shale Brick, Inc. ICR Test Report Introduction

c:\\Projects\General Shale\Rome, GA\2011-0172R1\ICR Test Report Page 1-1 1.0 Introduction Alliance Source Testing, LLC (AST) was retained by General Shale Brick, Inc. (General Shale) to conduct Brick and Structural Clay Products Information Collection Request (ICR) testing at the Rome, GA facility. General Shale is subject to provisions of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Brick and Structural Clay Products facilities as detailed in 40 CFR 63, Subpart JJJJJ and the Georgia Department of Natural Resources issued permit. The United States Environmental Protection Agency (U.S. EPA) requested in a Section 114 letter, pursuant to its authority under section 114 of the Clean Air Act, emissions data for certain pollutants. U.S. EPA’s specific request included a determination of hydrogen fluoride (HF) emissions. Testing was conducted to determine the aforementioned target pollutant emissions from one (1) tunnel kiln with dry sorbent injection filter/fabric filter (baghouse). All testing in this report was conducted under normal process operations.

1.1 Source and Control System Descriptions Brick exterior building material is manufactured at this facility. Shale and clay are mined, crushed and sent through a screening process prior to brick forming by extrusion. Once the brick is extruded, it is dried in a tunnel Kiln at temperatures exceeding 1,900 °F. After being fired, the brick is cooled, packaged and shipped to various locations. The emissions are controlled with a baghouse. Only the B-Kiln was operating during testing.

1.2 Project Team Personnel involved in this project are identified in the following table.

Table 1-1 Project Team AST Personnel Facility Personnel Jeremy Hutchens – Project Manager Brandy Hughes – Report Coordinator Andy Roth – Onsite Team Leader Kenny Boyd – Technician Anthony Tebben – Technician Simon Gregg – Technician Martha West

# Summary of ResultsGeneral Shale Brick, Inc. ICR Test Report Summary of Results

c:\\Projects\General Shale\Rome, GA\2011-0172R1\ICR Test Report Page 2-1 2.0 Summary of Results AST conducted Brick and Structural Clay ICR testing on a tunnel kiln at the General Shale facility in Rome, GA. Testing was conducted July 12, 2011 and consisted of three (3) test runs for HF. Table 2-1 provides a summary of the process operating and control system data collected during the performance test. Table 2-2 provides a summary of the emission testing results. Any difference between the summary results listed in the following tables and the detailed results contained in Appendix B is due to rounding for presentation.

Table 2-1 Summary of Process & Production Data

Parameter Average during Runs 1-3 Test Date 7/12/11 Brick Production 18.55 tph/ 16.84 Mg/hr (10,305 brick/hr) Coal Usage 1,250 lb/hr Bi-Carb Feedrate 150 lb/hr
Table 2-2 Summary of Emission Testing Results

Parameter Run 1 Run 2 Run 3 Average Test Date 7/12/11 7/12/11 7/12/11
-- Outlet Hydrogen Fluoride Data Concentration, ppmvd @ 7 % O 2 231.2 277.3 271.3 259.9 Emission Rate, kg/hr 2.0 2.6 2.5 2.4 Emission Factor, kg/MG 0.12 0.16 0.15 0.14

# Testing MethodologyGeneral Shale Brick, Inc. ICR Test Report Testing Methodology

c:\\Projects\General Shale\Rome, GA\2011-0172R1\ICR Test Report Page 3-1 3.0 Testing Methodology The emission testing program was conducted in accordance with the test methods listed in Table 3-1. Method descriptions are provided below while quality assurance/quality control data is provided in Appendix D.
Table 3-1 Source Testing Methodology

Parameter Test Methods Notes/Remarks Volumetric Flow Rate (VFR) U.S. EPA Reference Test Methods 1 & 2 Full Velocity Traverses Oxygen/Carbon Dioxide (O 2 /CO 2 ) U.S. EPA Reference Test Method 3/3A Integrated Bag/ Instrumental Analysis Moisture Content (BWS) U.S. EPA Reference Test Method 4 Volumetric /Gravimetric Analysis Hydrogen Fluoride (HF) U.S. EPA Reference Test Method 26 Isokinetic Sampling

3.1 U.S. EPA Reference Test Methods 1 & 2 – Volumetric Flow Rate The sampling location and number of traverse (sampling) points were selected in accordance with U.S. EPA Reference Test Method 1. A full velocity traverse was conducted in accordance with U.S. EPA Reference Test Method 2 to determine the average stack gas velocity pressure, static pressure and temperature. The velocity and static pressure measurement system consisted of an S-type pitot tube and inclined manometer while the stack gas temperature was measured with a K-type thermocouple and pyrometer.

3.2 U.S. EPA Reference Test Methods 3 & 3A – Oxygen/Carbon Dioxide The oxygen and carbon dioxide concentrations were determined in accordance with U.S. EPA Reference Test Methods 3/3A. One (1) integrated Tedlar bag sample was collected during each test run. The bag samples were analyzed on site with a California Analytical Instruments Model 300P O 2 /CO 2 /CO analyzer. The remaining stack gas constituent was assumed to be nitrogen for the stack gas molecular weight determination. The quality control measures are described in Section 3.5.
3.3 U.S. EPA Reference Test Method 4 – Moisture Content The stack gas moisture content was determined in accordance with U.S. EPA Reference Test Method 4. The gas conditioning train consisted of a series of chilled impingers. The impinger contents were pre and post-measured to determine the amount of moisture condensed during each test run.
3.4 U.S. EPA Reference Test Method 26 – Hydrogen Fluoride The hydrogen fluoride concentration was determined in accordance with U.S. EPA Reference Test Method 26. The complete sampling system consisted of a heated glass-lined probe, Teflon filter, gas conditioning train, pump and calibrated dry gas meter. The gas conditioning train consisted of four (4) impingers contained in an ice/water bath. The first and second impingers contained 0.1 N H 2 SO 4 , the third was initially empty and the fourth impinger contained silica gel. The probe and filter box temperatures were maintained above 250°F, and the impinger exit gas temperature were maintained below 68°F throughout the testing.General Shale Brick, Inc. ICR Test Report Testing Methodology

c:\\Projects\General Shale\Rome, GA\2011-0172R1\ICR Test Report Page 3-2 Following the completion of each test run, the sampling train was leak checked at a vacuum pressure greater than or equal to the highest vacuum pressure observed during the run. The absorbing solution (0.1 N H 2 SO 4 ) from the first and second impingers was placed into sample Container 1. The back-half of the filter holder, first, second and third impingers and all glassware leading to the outlet of the third impinger were triple-rinsed with DI water. These rinses were also placed in Container 1. The samples were sealed, labeled and liquid levels marked for transport to Maxxam Analytics, Inc. of Mississauga, Ontario, Canada.

3.5 Quality Assurance/Quality Control – U. S. EPA Reference Test Method 3A Cylinder calibration gases were supplied by AirGas – South or NexAir which met Protocol 1 (+/- 2%) standards. Low Level gases were introduced directly to analyzer. After adjusting the analyzer to the Low Level gas concentration and once the analyzer reading was stable, the analyzer reading was recorded. This process was repeated for the High Level gas. Next, Mid Level gases were introduced directly to analyzer and reading was recorded. All recording readings were within +/- 2 percent of the Calibration Span. All data was reviewed by the Field Team Leader before leaving the facility. Once arriving at AST’s office, all written and electronic data was relinquished to the report coordinator and then a final review was performed by the Project Manager.

# Appendix A

# Appendix B

# Appendix C

# Appendix D

# Appendix E

# Appendix F

# THIS IS THE LAST PAGE OF THIS REPORT