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.com

Page 2 of 49
General Shale Brick, Inc.

ICR Test Report

Table of Contents

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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

Page 3 of 49
Introduction

Page 4 of 49
Generals 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

Page 5 of 49
Summary of Results

Page 6 of 49
General 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 % O2 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

Page 7 of 49
Testing Methodology

Page 8 of 49
General 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 (O2/CO2) 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 O2/CO2/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 H2SO4, 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.

Page 9 of 49
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 H2SO4) 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.

Page 10 of 49
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

Page 11 of 49
Introduction

Page 12 of 49
Generals 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

Page 13 of 49
Summary of Results

Page 14 of 49
General 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 % O2 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

Page 15 of 49
Testing Methodology

Page 16 of 49
General 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 (O2/CO2) 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 O2/CO2/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 H2SO4, 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.

Page 17 of 49
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 H2SO4) 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.

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Appendix A 

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Appendix B 

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Appendix C 

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Appendix D 

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Appendix E 

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Appendix F 

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THIS IS THE LAST

PAGE OF THIS

REPORT

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