E•ncv- pi•÷

Z V_ihq P2,01 Entec Sewices, Inc. 16 D Commerce

Avenue Hueytown, Alabama

35023 Telephone: (205) 494-6676 Fax: (205) 491-6614 Results of the January

17 and 18, 2006 RATA/Compliance Testing

for Gaseous

Emissions

on the Brick Plant No. •2 Tunnel

Kiln located

in Sugarcreek, Ohio Facili• Permit

No. 06-79-00-0118,

tD No. P201
Submitted to: Belden Brick

Company 475 Dover Road Sugarcreek, Ohio 44681

Attention: Mr. John Jonson
Entec Project No. 26108

Report Submitted:

Februa•

18, 2006 C pleted, •y:

e )om£y

Lo Jr. Project Leader evlewed

By:

Tom Lotz Sr. QA/QC Manager/Project

Manager hereby certify to the best of my knowledge

all field sampling

and laboratory

anaiysts pe•rmed

for this report is authentic

and accurate.

It has been checked for completeness

and accuracy,Belden Brick

Company Table of Contents

SectionExecutive Summary Compliance Emissions

Summary Detailed Test Results Relative Accuracy

Test Results Sulfur Dioxide Nitrogen Oxides Carbon Monoxide Hydrogen Chloride Hydrogen Fluoride Sampling Procedures Location of Test Ports Diagram of Sampling

Train RATA RM and CEM's Field Data Volumetric Flow Field Data Production Data Quality Assurance/Quality Control

Procedures Preliminary Traverse

w/Cyclonic

Flow Analyzer Interference

Checks NOx Converter

Efficiency

Test FT-IR CTS Check Instrumental Analyzer

Calibrations Calibration Gas Certificates Flow Equipment

Calibrations Nomenclature and Te• Calc.utations Page No. 368141516171819
20252628t33156 159 166167173 175 176 196 207 210Executive Summary
Entec Services,

Inc. was retained

by Belden Brick Company

to perform

a RATA on the CEM unit and compliance

gaseous

emissions

testing on Brick Plant No. 2 Tunnel Kiln located in Sugarcreek,

Ohio. The control devices

for the kiln are a dry scrubber

and a baghouse. The Opsis CEM is composed

of two analyzers,

One analyzer

uses an infrared (IR) detector

and the other used an ultraviolet

(UV) detector,

The IR detector

analyzes

the gas stream

fo• NOx, CO and SO2. The UV detector

measures

HCl and HE Both analyzers shoot the IFL/UV across the stack to let the gas combine

with the projected

light
source. A detector

at the other side of the stack picks up the light source influenced

by the gas stream

and transmits

via fiber optic cable the signal to be processed

by a interferometer located with the signat processing

equipment

in the cabinet.

This "spectra" is then turned into a direct ppm measurement.
Mr. Erik Groth and Mr. Tommy

Lotz, Jr. of Entec Services,

lnc conducted

the testing on January 17 and 18, 2006. Mr. John Jensen

was present

from Belden

Brick and to coordinate testing with control room activities.

Mr. Todd Brown from the State of Ohio Environmental Protection

Agency

observed

these tests,
The first through

fourth RATA runs failed the spike and recovery

procedure

for the reactive gases (HC1 and HF) and were considered

invalid. The numbering

system for the reactive gases was then restarted.

The sixth reactive

gas run was also considered

invalid due to the failure of the spike and recovery

procedure.

The sixth run was restarted,

The restarted
runs one through

three of the HCI were valid but were not used in the calculations. Seventeen 30-minute

RATAs

were performed.

Due to the confusing

nature of the numbering system a chart has been constructed

to clarify the test program

and is included
on the following

pages. Entec Services,

tnc encountered

no other difficulties

in the field collection of the samples

or in the laboratory

analysis

of the samples.

The gaseous

emissions

test summary

on the following

page gives a detailed

summary

of each paired test run compared

to the maximum

emission

limits set forth by the State of Ohio Environmental

Protection

Agency.

Tests results

indicate

the average

gaseous emissions are below the limits set forth by the State of Ohio EPA for Facility

Permit No, 06-79-00-0118,

Facility

Source

Identification

No. P201.The RATA test summaries

on the following

pages give a summary,

of the. CEM's calculated emissions, reference

method

calculated

emissions

and the calculated

relative accuracy

for the CEM•s emissions,

Test results

indicate

that the RATA results are below the limits for $02, NOx, HF and HCl and above the limits for CO as set forth by the Code of Federal Regulations

(CFR) 40 Pad: 60, Appendix

B, and Performance

Spe¢ifl(•attons 2, 4, (•, and 1'5,Plant 2 CEMS HCI and HF Plant FT-IR Flow Notes HF/HCI Scratch Spike and Recovery

Bad: HFIHCI Scratch Sp!,ke and ReCOvery

Bad HF/HCI Soratch Spik e an,d Recovery

Bad •=tHCI S•ratoh Spike gnd ,Recovery

Ba,,d, HCI not used not; used

Run No. Run No, Start

Stop

Date

HCI not used Spike and ae•ve•

Bad

89t01112

t 0910 2 1020 3 t130!255 1442 6 1616 7 0650 0620
1109 1700
t912 2002 2055 2141 2228 45

89

111213141 ̧5

17

0940 1117/2006 1050 1/t 7/2006 ,!,•00 1t1712006 1325 111712006 1512 1/17/2006 t646 ,,!/!7/2006 0720 1/18/2006 0850 111812006 1030 1It 8t2006 1139 1f18/2006 1-•3,• 1/!8/2oo6 18•6 1:i18/2006 1942 t/t8•2006 2032 1/18/2006 2t25 1t18/2006 2211 1118/2006 2258 t118/2006

5CSOURCE

OWNER:
PLANT LOCATION: SOURCE(S) NAME(S): SOURCE(S) CONDITION: SOURCE(S) SHAPE: SOURCE PERMIT NUMBER: TEST PERFORMED: REFERENCE METHOD TESTS:

Entec

Sewices,

Inc. SOURCE OVERVIEW
Beiden Bdck Sugarc•eek, Ohio Bdck Plant Tunnel Kiln No. 2 Initial RATA/Compliance Circuit 0679.000-t18-P301 RATA T• Sample Location Volumetric Row Molecular Weight Sulfur Dioxide O•es of N•ogen •on Monoxide Hy(trogen •lodde Hydrogen F|uodde
PROJECT MANAGER ENVIRONMENTAL ANALYST

PROJECT

LEADER ENVIRONMENTAL ANALYST

ASSISTANT OWNEWS REPRESENTATWE: RULING AGENCY RULING AGENCY REPRESENTATIVE: DATES TESTS CONDUCTED: ENTEC PROJECT

NUMBER: Mr. Tom Lotz, St, Tommy •, Jr.
Mr. Edk Gro•.h
Mr. John Jensen O•oEPA Todd Brown 0tll 7t06 011t 8106 261O8

EPA Method EPA Met,hod EPA Met,hod EPA Method EPA Method EPA Method EPA Method EPA Method

i2/Spec 6 37EiS•Band2 10 / S•6 and 4 320 / Spec 6 and 15 320 / Spec 6 and 150E

0Procedures The relative

accuracy

test results and the emission

tests were determined

using EPA Methods 1, 2, 3A, 4 (by FT-IR), 6C, 7E, and 10 CFR Title 40, Part 60, Appendix

A; Method 320 CFR Title 40, Part 63, Appendix

A; Appendix

B performance

specification

2 for Sulfur Dioxide and Oxides

of Nitrogen,

performance

specification

4 for Carbon

Monoxide, performance specification

6 for flow rates, and performance

specification

15 for Hydrogen Chloride and Hydrogen

Fluoride.

The calibration

and quality assurance

procedures

of EPA CFR 40 Part 60 Appendix

A for all methods,

and the "Quatity

Assurance

Handbook for Air Pollution

Measurement

System"

Volume

lit Stationary

Source-Specific

Methods

were followed

throughout

the duration

of the field and laboratory

testing.
The most current revision

revised as of July 1, 2004, of each method

(as described

in the Federal Register)

was used.
To satis• the certification

requirements

for the CEMS data accuracy

assessment

of the applicable performance

specifications

in 40 CFR 60, Appendix

B, the relative

accuracy test must have a minimum

of nine test runs. If more than 9 test runs are performed

a maximum of three sets of the test results may be rejected

so long as the total number

of test results used to determine

the relative

accuracy

is greater

than or equal to nine. However, all data must be reported

including

the rejected

data. The relative

accuracy performance specification

of the CEM'S must be no greater

than 20 percent

of the mean value of the reference

data in units of the emission

or 10 percent

of the applicable standard, which ever is greater.

Each run was twenty-one

minutes

tong.
Stack Gas Volumetric

Flow The velocity

of the gas stream was determined

according

to EPA Reference

Method

1 and 2 by reading

the instantaneous

velocity

head with an inclined

manometer

at each sampling point with a calibrated

S-type pitot tube attached

adjacent

to the sample nozzle, The stack pressure

was measured

with the static side of an S-type pitot tube. A calibrated pyrometer was used to measure

stack temperature

at each sampling

point, The stack

was tested for cyclonic

flow according

to EPA Reference

Method

1.Stack Gas Molecular

Weight-Instrumental The carbon dioxide

concentrations

were determined

using EPA Reference

Method

3A. The molecular

weight of the gas was calculated

using the moisture,

oxygen

and carbon dioxide content and the measured

stack gas temperature.
Moisture Con•nt The moisture

content

used for calculating

the gas stream flow rate was determined

by measuring the amount

of moisture

using a Temet DX 4000 FT-IR analyzer. Oxv_clen The oxygen

content

in the flue gas was determined

using a Siemens

Oxymat

61 oxygen analyzer. The Oxymat

61 uses paramagnetic

analysis.

Oxygen

is attracted

into a strong magnetic field. Oxygen

molecules

in an inhomogeneous

magnetic

field are drawn in the direction of the increased

field strength

due to the paramagnetism

When two gases with different oxygen

concentrations

meet in a magnetic

field, a pressure

difference

is produced between

them. One of the gases is a reference

gas (N2), the other is the sample gas. The reference

gas is introduced

into the sample chamber

through

two channels.

One of these reference

gas streams

meets the sample gas within the area of a magnetic

field. Because the two channels

are connected,

the pressure,

which is proportional

to the oxygen concentration,

causes a flow. This flow is converted

into and electric

signal by a microflow sensor.

This current is then amplified

and provides

a signal output of 4-20ma signals, which corresponds

to a full-scale

range of 0-25% oxygen.
Carbon Dioxide Carbon dioxide

concentrations

were continuously

measured

with a Siemens

Ultramat

23 non-dispersive infrared

(NDIR) analyzer.

The theory of operation

for this ana•zer

is based on the principle

that CO2 has a unique absorption

line spectrum

in the infrared region. The instrument

consists

of an infrared

light source,

a chopper,

a measurement cell, and a detector.

The infrared

light beam emitted

by the source passes

through

the measuring cell, which is filled with a continuously

flowing gas sample.

The light beam is partially absorbed

or attenuated

by the gas species

of interest

in this cell before reaching the front chamber

of the detector,

Both the front and rear chambers

of the seaied detector

are filled with a reference

gas. The difference

in the amount

of light absorbed

between the front and rear chambers

are dependent

on the concentration

of the gas species

ofinterest wffhin the sample

measurement

cell; a pressure

differential

is thus created between the two chambers.

This pressure

difference

is then observed

as gas flow by the micro-flow sensor located

in a channel

connecting

the two chambers.

The resulting

AC signal from the micro-flow

sensor is rectified,

amplified

and linearized

into a 4-20ma

signal for output that corresponds

to a full-scale

0-25% measurement

range.
Sulfur Dioxide A Western

Research

Model 721-AT

SO2 analyzer

provided

continuous

analysis

of SO2 in the gas stream.

The basic analytical

principle

involves

quantitative

measurement

of the absorption of UV radiation

by SO2 molecules.

The analyzer

uses a single light source, which emits an appropriate

wavelength,

illuminating

the sample

all through

which the sample is continuously

passed.

Narrow-band

optical filters are rotated through

the beam, and the radiation

passed

through

the optical filters and sample cell is detected

by a single photo-detector. The signal pulses from the photo-detector

are separated

by a multi-plexor into a measuring

channel

and a reference

channel,

A log ratio amplifier

computes

the logarithm of the input signal ration, producing

a signal that is proportional

to the SO2 concentration. The duaI-range

analyzer

has a digital readout,

as well as 0-10.0 V DC output terminals.

The full scale of the instrument

was set at 200 ppm. Nitrogen Oxides An Advanced

Pollution

Instruments

(API) Model 200AH NO× analyzer,

which operates

on the basis of chemiluminescences, was used continuously

to determine

the NOx concentration in the effluent.

The sample

is initially routed through

a converter

where the NO2 iS dissociated

to form NO. The sample

is then passed

through

a reaction

chamber where the NO is quantitatively

converted

to NO2 by gas-phase

oxidation

with ozone produced within the analyzer.

In this reaction,

the NO2 molecules

are elevated

to an electronically excited

state and then immediately

revert to a non-excited

ground

state. This reversion

is accompanied

by emission

of photons

(luminescent

light), which impinge

on a photo-multiplier

detector

and generate

a low-level

direct current.

The NOx concentration measured

by the instrument

includes

the contributions

of both the NO in the effluent and the NO resulting

from the dissociation

of NO×. Instrument

outputs

include an analog readout

and 0-10 V DC output terminals.

Full-scale

response

of the analyzer

was set at 25 ppm throughout

the test period.Carbon Monoxide The CO emissions

were measured

using a Siemens

Ultramat

23 analyzer.

This monitor

is

a selective

non-dispersive

infrared

radiation

(NDIR) gas analyzer

that operates

on the infrared double-beam

alternating

light principle.

The full range for the CO component

of this instrument

throughout

the test period was 1000 ppm. Hydrogen Chloride

and Hvdroaen

Fluoride Emission measurements

for HCI and HF were performed

using the Temet DX 4000 FT-IR in accordance

with Performance

Specification

6 and 15. Twelve

30-minute

runs were performed for the RATA. Nine of these runs satisfied

the emissions

portion of the test as per Performance

Specification

6 and 15. Spike and recoveries

were performed

before and after each run to validate

the accuracy

of the analyzer

and sampling

system to correctly

measure reactive

compounds

(HCI, HF). This spike and recovery

technique

was performed as specified

in Method

321. A total of t0 three-minute

samples

were collected per each 30 minute run. The sampling

system turned over the cell volume

18 times per three-minute sample.

This flow rate satisfied

the measuring

time/rate

as set by performance specification

15. Samplin_• System Samples were extracted

from the gas stream by a heated titanium

probe maintained

at a set temperature

of 200 degrees

Celsius,

through

a one-hundred

(100) foot heated sample line that was heated to a temperature

of 200 degrees

Celsius,

then pulled through

theFTIR by a chi|led sample

conditioner

to remove

the moisture

in the gas stream and then delivered to the remainder

of the analyzers

on a dry basis.

Data Acquisition Concentration

values were collected

using a Baldwin

Environmental

RM Plus Parametrics data acquisition

system.

The data was recorded

every fifteen-seconds

and then averaged for each six,,second

interval.

Each minute average

was then averaged

for the duration

of each test run. During all testing, the unit was operating

within normal operating

parameters;

at a range appropriate in accordance

with applicable

permits.Entec Sewices,

Inc t6 D Commerce

Ave. HUe•rOWn,

AL 35023 STACK DRAWING

& TRAVERSE

POINT LOCATION
Client: Beiden Brick Job No. 26t08 SourcE: Bdck Plant Tunnel Kiln No. 2 input By: Tommy Lot• Jr. Type of Traverse Velocity (V) or Pa•culat• (P):

•

Port Ty•

•1• Po• Oiame•t

2.0" S•ck Dl•etet, •nc•s:

57• •¢k At•, F•: 18.033 S•ck H•tgh• •

6 HumOr • Po•: 2 Stack Pm•:

tnoh•

Duct O•metem

Leng• • P• Inch•: 7,•
t 74•0

3,03

To=I Num•r of Tmveme P•n•:

•2 Upstream Disturbance: Downstr_,_•__m D.L•.urbance: 57.5

INCHES

tI•CHES

432.0 FLOW Inelde •t•c;k

Ou•I•l• Nipple Point No,

inches Inches 2,$
3 17.0 24.5

Ft.ATA Probe 9,8

17.3
47.7 •5,2 Adjusted points dtertmte¢ > 24" no point c|o•ter than 1,0 inch Adjusted pCnts dtanmtsr_< 24" no point closet t•an 0.5 Inch

4 points per port if the 8 2 dlametem downstream

and ul•tteam crfteda is met,Instrument Sampling Train

00000

n

NOx COso•co=o=

Caltbra•on GasesFT-IR Sampling Train

Pro•

Commun|catlon

Lines ©©