Compliance Stack Emission 

Test Report 

Determination of Total Front-Half Particulate 

Matter, Hydrogen Chloride, and Hydrogen 

Fluoride Emissions 

Natural Gas Fired Tunnel Kiln A(P001) and 

Natural Gas Fired Tunnel Kiln B(P002) 

EPA Methods l, 2, 3, 4, 5, and 26A 

Glen-Gerp Corporation - Marseilles Facility 

Marseiltes, Illinois 

Dates Conducted: November 8 and 9, 2006 

Job Number: 061109 

Prepared by: 

Air Compliance 

z

~ 

Testing, lnc. 

PO Box 41156 

Cieveland OH 44141-0156 

Phone: (800) EPA-AIR1 (372-2471) 

Report Date: December 23, 2006 
SuperiorQuality A'r C®/np,/a/](;e 

Emission Testing. „ p, - n„ p n . r 

Valid Results 

Guaranteed. ~ Tesfing'lnC. 

P.O. Box 41156 Cleveland, Ohio 44141 

1-800-EPA-AIR1 www.aircomp.com 

. testing@aircomp.com 

December 23, 2006 

Brett Chronister 

EHS Manager 

Glen-Gery Corporation 

423 South Pottsville Pike 

Shoemakersville, Pennsylvania 19555 

Dear Brett: 

The following report provides the results of the compliance emission testing conducted on 

November 8 and 9, 2006. These results are a product of the application of the U.S. EPA 

Stationary Source 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 letterhead) 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 eoncerns 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, 

L4 

Robert J. Lisy, Jr. 

Quality Assurance Officer 
Compliance Stack Emission Test Report Glen-Gerv Corgoration - Marseilles Facilitv 

Table of Contents 

Page 

1.0 INTRODUCTION 2 

1.1 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 

2.3 Presentation of Results 4 

3.0 PLANT AND SAMPLING LOCATION DESCRIPTIONS 8 

3.1 Process Description and Operation 8 

3.2 Control Equipment Description 8 

3.3 Flue Gas Sampling Locations 8 

3.4 Process Sarnpling Location 9 

4.0 SAMPLING AND ANALYTICAL PROCEDURES 15 

4.1 Test Methods 15 

4.2 Procedures for Obtaining Process Data 16 

5.0 INTERNAL QA/QC ACTIVITIES 19 

5.1 QA Audits 19 

5.2 QA/QC Problems 19 

6.0 APPENDIX 24 

Test Date: November 8 and 9, 2006 Page 1 Air Compliance Testing, Inc. - 061109 
Compliance Stack Emission Test Report Glen-Gerv Corporation - Marseilles Facilitv 

9.9 Summary of Test Pr®gram 

Glen-Gery Corporation contracted Air Compliarice Testing, Ine. of Cleveland, Ohio to conduct compliance 

stack emission testing for the Natural Gas Fired Tunnel Kiln A(P001) and Natural Gas Fired Tunnel Kiln B 

(P002) at their Marseilles Facility (Fac'rlity ID: 099050AAK) located in Marseilles, Illinois. Testing was 

performed to satisfy Glen-Gery Corporation - Marseilles Facility's emission testing requirements pursuant to 

the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Brick and Structural Clay 

Products Manufacturing (40 CFR Part 63, Subpart JJJJJ). The testing was performed on November 8 and 9, 

2006. 

Simultaneous sampling was performed at the P001 Dry Limestone Adsorber (DLA) Inlet Duct and at the 

, P001 DLA Exhaust Stack to determine the mass emission rate of hydrogen chloride (HCI) and hydrogen 

fluoride (HF). Sampling was also performed at the P001 DLA Exhaust Stack to determine the mass emission 

rate of total front-half particulate matter (PM). Testing was conducted during maximum production 

, operations and predetermined DLA limestone extraction settings. During this test, emissions from P001 were 

controlled by a DLA. 

Simultaneous sampling was performed at the P002 DLA Inlet Duct and at the P002 DLA Exhaust Stack to 

determine the mass emission rate of HCI and HF. Sampling was also performed at the P002 DLA Exhaust 

Stack to determine the mass ernission rate of total front-half particulate matter (PM). Testing was conducted 

during maximum production operations and predetermined DLA limestone extraction settings. During this 

test, emissions from P002 were controlled by a DLA. 

The test methods that were conducted at this test were EPA Methods 1, 2, 3, 4, 5, and 26A. 

1.2 Key Personnel 

The key personnel who coordinated this test program (and their phone numbers) were: 

Brett Chronister, EHS Manager, Glen-Gery Corporation, 610-562-3076 

Philip J. Billick, President, Air Compliance Testing, Inc. 800-372-2471 

Sin Hoi Chiew, Project Manager, Air Compliance Testing, Inc. 800-372-2471 

Test Date: November 8 and 9, 2006 Page 2 Air Compliance Testing, Inc. - 061109 
Compliance Stack Emission Test Report Glen-Gerv Corporation - Marseilles Facilitv 

2.1 Objectives and Test Matrix 

The purpose of this test was to determine the mass emission rate of HCI and HF at the P001 DLA Inlet Duct 

and the mass emission rate of HCI, HF, and total front-half PM at the P001 DLA Exhaust Stack. The purpose 

of this test was to also determine the mass emission rate of HCl and HF at the P002 DLA Inlet Duct and the 

mass emission rate of HCI, HF, and total front-half PM at the P002 DLA Exhaust Stack. AII sampling was 

conducted during maximum production operations and predetermined DLA lirnestone extraction set[ings. 

Testing was performed to satisfy Glen-Gery Corporation - Marseilles Facility's emission testing requirements 

pursuant to the NESHAP for Brick and Structural Clay Products Manufacturing (40 CFR Part 63, Subpart 

JJJJJ). 

The specific test objectives for this test were to: 

Simultaneously measure the concentrations of HCI and HF at the P001 DLA Inlet Duct and the 

concentrations of HCI, HF, and total front-half PM at the P001 DLA Exhaust Stack during rnaximum 

production operations and predetermined DLA limestone extraction settings. 

Simultaneously ineasure the dry standard and actual volumetric flow rate of the stack gas at the P001 DLA 

Inlet Duct and at the P001 DLA Exhaust Stack during rnaximum production operations and predetermined 

DLA limestone extraction sett'rngs. 

Utilize the above variables to determine the mass emission rate of HCI and HF at the P001 DLA Inlet Duct 

and the mass emission rate of HCI, HF, and total front-half PM at the P001 DLA Exhaust Stack during 

maximum production operations and predetermined DLA limestone extraction settings. 

Simultaneously measure the concentrations of HCl and HF at the P002 DLA Inlet Duct and the 

concentrations of HCI, HF, and total front-half PM at the P002 DLA Exhaust Stack during maximum 

production operations and predetermined DLA limestone extraction settings. 

Simultaneously measure the dry standard and actual volumetric flow rate of the stack gas at the P002 DLA 

Inlet Duct and at the P002 DLA Exhaust Stack during maximum production operations and predetermined 

DLA limestone extraction settings. 

Utilize the above variables to determine the mass emission rate of HCI and HF at the P002 DLA Inlet Duct 

and the mass emission rate of HCI, HF, and total front-half PM at the P002 DLA Exhaust Stack during 

maximum production operations and predetermined DLA limestone extraction settings. 

Table 2.1 presents the sampling and analytical matrix log for this test. 

2.2 Field Test Changes and Problems 

No field test changes or problems occurred at the performance of this test that would bias the accuracy of the 

results of this test. 

Test Date: November 8 and 9, 2006 Page 3 Air Compliance Testing, Inc. - 061109 
Compliance Stack Emission Test Report Glen-Gerv Cornoration - Marseilles Facilitv 

2.3 Presentation of Results 

A single sampling train was utilized at each run at each location to determine the mass emission rate of HCI 

and HF at the P001 DLA Inlet Duct, the maes emission rate of HCI, HF, and total front-half PM at the P001 

DLA Exhaust Stack, the mass emission rate of HCI and HF at the P002 DLA Inlet Duct, and the mass 

emission rate of HCI, FIF, and total front-half PM at the P002 DLA Exhaust Stack. These sarnpling trains 

measured the stack gas volumetric flow rate, dry molecular weight, moisture content, and concentrations of 

HCI, HF, and total front-half PM where applicable. 

Table 2.2.1 displays the mass emission rate of HCI and HF measured at the P001 DLA Inlet Duct and the 

mass emission rate of HCI, HF, and total front-half PM measured at the P001 DLA Exhaust Stack during 

maximum production operations and predetermined DLA limestone extraction settings. 

Table 2.2.2 displays the mass emission rate of HCl and HF measured at the P002 DLA Inlet Duct and the 

mass emission rate of HCI, HF, and total front-half PM measured at the P002 DLA Exhaust Stack during 

maximum production operations and predetermined DLA limestone extraction settings. 

Note that the concentrations of HF measured at the P001 DLA Exhaust Stack and at the P002 DLA Exhaust 

Stack were all below the rninimum detection limit (MDL) of applicable analytical method. Mass emission 

rates denoted with a"<" in Tables 2.2.1 and 2.2.2 were calculated utilizing the applicable MDL 

concentration value instead of the "as measured" concentration value. 

Test Date: November 8 and 9, 2006 Page 4 Air Compliance Testing, Inc. - 061109 
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Compliance Stack Emission Test Report Glen-Gerv Corporation - Marseilles Facilitv 

3.0 PLANT AND SAMPLING LOCATION DESCRIPTIONS 

3.1 Process Description and Operation 

Glen-Gery Corporation is a lead'rng manufacturer of molded bricks. The Marseilles facility operates Natural 

Gas Fired Tunnel Kiln A(P001) and Natural Gas Fired Tunnel Kiln B(P002). Each kiln is 496 ft long and has 

a natural gas firing rate of —32 MMBtu/hr. The kilns can be used interchangeably to produce brick of various 

sizes and colors made from clay and shale obtained from the same source. P001 and P002 were in operation 

during the performance of this test. 

Figure 3.1 depicts the process schematic. 

3.2 Contro/ Eguipment Description 

During this test, emissions from P001 and P002 were each controlled by a DLA. 

3.3 Flue Gas Sampling Locations 

3.3.1 P001 DLA Inlet Duct 

The POOI DLA Inlet Duct was elliptical in shape with measured inner diameters of 50.5-inches and 49.7- 

inches. The duct was oriented in the horizontal plane and was accessed from ground. Two (2) 3.5-inch I.D. 

sarnpling ports were located 90° apart from one another at a location that met EPA Method I, Section 1 I.1.1 

criteria. Prior to emissions sampling, the duct was traversed to verify the absence of cyclonic flow. An 

average yaw angle of 2.63° was measured. Therefore, the sampling location also met EPA Method l, Section 

11.4.2 criteria. During emissions sampling, the duct was traversed for stack gas volumetric flow rate, dry 

molecular weight, moisture content, and HCI and HF concentration determination. 

3.3.2 P001 DLA Exhaust Stack 

The P001 DLA Exhaust Stack had a measured inner diameter of 47.1-inches, was oriented in the vertical 

plane, and was accessed from a permanent platform. Two (2) 3.7-inch I.D. sampling ports were located 90 0 

apart from one another at a location that met EPA Method 1, Section I l.l.l criteria. Prior to emissions 

sampling, the stack was traversed to verify the absence of cyclonic flow. An average yaw angle of 6.59 0was 

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, and total front-half PM, HCI, and HF concentration determination. 

Test Date: November 8 and 9, 2006 Page 8 Air Compliance Testing, Inc. - 061109 
Compliance Stack Emission Test Report GIen-Gery Corporation - Marseilles Facilitv 

3.3.3 P002 DLA Inlet Duct 

The P002 DLA Inlet Duct was elliptical in shape with measured inner diameters of 51.3-inches and 52.4- 

inches. The stack was oriented in the horizonta) plane and was accessed from ground. Two sarnpling ports 

one with 3.6-inches and other with 3.4-inches were located 90° apart frorn one another at a location that met 

EPA Method 1, Section I 1.1.1 criteria. Prior to emissions sampling, the duct was traversed to verify the 

absence of cyclonic flow. An average yaw angle of 3.25° was measured. Therefore, the sampling location 

also met EPA Method 1, Section 11.4.2 criteria. During emissions sampling, the duct was traversed for stack 

gas volumetric flow rate, dry molecular weight, moisture content, and HCI and HF concentration 

determination. 

3.3.4 P002 DLA Exhaust Stack 

The P002 DLA Exhaust Stack was elliptical in shape with measured inner diameters of 47.3-inches and 47.4- 

inches. The stack was oriented in the vertical plane, and was accessed from a permanent platform. Two (2) 

3.7-inch I.D. sampling ports were located 90° apart from one another at a location that met EPA Method 1, 

Section 11.1.1 criteria. Prior to emissions sampling, the stack was traversed to verify the absence of cyclonic 

flow. An average yaw angle of 10.67° was measured. Therefore, the sainpling 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, and total front-half PM, HCI, and HF concentration 

determination. 

Figures 3.2 - 3.5 schematically illustrate the traverse point and sample port locations utilized. 

3.4 Process Sampling Location 

The EPA Reference Test Methods performed did not specifically require that process samples were to be taken 

during the performance of this testing event. It is in the best knowledge of Air Compliance Testing that no 

process samples were obtained and therefore no process sampling location was identified in this report. 

See Glen-Gery Corporation - Marseilles Facility personnel for any process sainpling locations which may have 

been utilized unknowingly to Air Compliance Testing, Inc. during this testing event. 

Test Date: November 8 and 9, 2006 Page 9 Air Complfance Testing, Inc. - 061109 
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Compliance Stack Emission Test Report Glen-Gerv Corporation - Marseilles Facilitv 

1" 

98" 

2.08 Equivalent Diameters 

Upstream from 

Disturbance 

Port 1 

~ I (2) 3.7' I.D. 

Sampling Ports 

~ Located 90°Apart 

787" 

16.7 Equivalent 

Diameters Downstream 

from Disturbance 

I 

Port 2 

Point % of Duct Depth Distance From Inside Wall (in.) 

1 4.4 2.1 

2 14.6 6.9 

3 29.6 13.9 

4 70.4 33.2 

5 85.4 40.2 

6 95.6 45.0 

~7.1" I.D. Stack 

Figure 3.3 - P001 DLA Exhaust Stack Traverse Point Location Drawing 

Test Date: November 8 and 9, 2006 Page 12 Afr Compliance Testing, Inc. - 061109 
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Compliance Stack Emission Test Report Glen-Gerv Corporation - Marseilles Facilitv 

L 

Port 2 

Distance From Distance From 

% of Duct Depth Inside Wall (in.) Inside Wall (in.) 

Port 1 Pnrf 2 

1 4.4 2.1 2.1 

2 14.6 6.9 6.9 

3 29.6 14.0 14.0 

4 70.4 33.3 33.4 

5 85.4 40.4 40.5 

6 95.6 45.2 45.3 

_47.3" x 47.4" I. D. 

Eilipticai Stack 

Figure 3.5 - P002 DLA Exhaust Stack Traverse Point Location Drawing 

—~ 

101.3" 

2.14 Equivalent Diameters 

Upstream from 

Disturbance 

Port 1 

(2) 3.7" LD. 

~ - t Sampling Ports 

Located 90°Apart 

784.5" 

16.55 Equivalent Point 

Diameters Downstream 

from Disturbance 

Test Date: November 8 and 9, 2006 Page 14 Air Compliance Testing, Inc. - 061109 
Compliance Stack Emission Test Report Glen-Gerv Corporation - Marseilles Facilitv 

4.0 SAMPLING AND ANALYTICAL PR®CEDURES 

4.1 Test Methods 

4.1.1 EPA Method 1: Sample and Velocity Traverses for Stationary Source 

Principle: To aid in the representative measurement of pollutant emissions 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: Determination 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 tube. 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 Weight 

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 forpercent CO2, percent 02, 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: Detennination of Particulate Emissions from Stationary Sources (Front-Half PM only) 

Principle: Particulate matter (PM) is withdrawn isokinetieally from the source and collected on a glass fiber 

filter maintained at a temperature in the range of 120 t 14°C (248 f 25°F) or such other temperature as 

specified 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 uncornbined water. This 

method was utilized in its entirety as per the procedures outlined in 40 CFR Part 60, Appendix A. 

Test Date: November 8 and 9, 2006 Page 15 Air Compliance Testing, Inc. - 061109 
Compliance Stack Emission Test Report Glen-Gerv Corporation - Marseilles Facilitv 

4.1.6 EPA Method 26A: Determination of Hydrogen Halide and Halogen Emissions from Stationary SourcesIsokinetic Method 

Principle: This method is applicable for determining emissions of hydrogen halides (HX) [hydrogen chloride 

(HCI), hydrogen bromide (HBr), and hydrogen fluoride (HF)] and halogens (X 2) [chlorine (Cl Z) and bromine 

(Br2)] 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 for HCI and HF 

determination as per the procedures outlined in 40 CFR Part 60, Appendix A. 

The sampling trains utilized during this testing project are depicted in Figure 4.1 and 4.2. 

4.2 Procedures for OBtaining Process Data 

Process data was recorded by Glen-Gery Corporation - Marseilles Facility personnel utilizing their typical 

record keeping procedures. Recorded process data was provided to Air Compliance Testing, Inc. personnel at 

the conclusion of this test event. The process data is located in the Appendix. 

Test Date: November 8 and 9, 2006 Page 16 Air Compliance Testing, lnc. - 061109 
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Compliance Stack Emission Test Report Glen-Gerv Corporation - Marseilles Facilitv 

5.0 INTERNAL QA/QC ACTIVITIES 

5.1 QA Audits 

Tables 5.1.1 - 5.2.2 illustrate the QA audit activities that were performed during this test. 

All meter boxes and sampling trains used during sampling performed within the requirements of their 

respective methods as is shown in Tables 5.1.1 - 5.2.2. All pre-test and post-test leak checks were well below 

the applicable limit. Minimum metered volumes and percent isokinetics were also met where applicable. 

5.2 QA/QC Problems 

No QA/QC problems occurred during this test event. 

Test Date: November 8 and 9, 2006 Page 19 Air Compliance Testing, lnc. - 061109 
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Compliance Stack Emission Test Report Glen-Gerv Corporation - Marseilies Pacilitv 

1 V340 ; . 

Appendix attached. 

Test Date: November 8 and 9, 2006 Page 24 Air Compliance Testing, Inc. - 061109 
/_1»=1ilk171:1 

to 

Compliance Stack Emission Test Report 

Determination of Total Front-Half 

Particulate Matter, Hydrogen Chloride, and 

Hydrogen Fluoride Emissions 

Natural Gas Fired Tunnel Kiln A(P001) and 

Natural Gas Fired Tunnel Kiln B(P002) 

EPA Methods 1, 2, 3, 4, 5, and 26A 

Glen-Gerv Corporation - Marseilles Facilitv 

Marseilles, Illinois 

Date Conducted: November 8 and 9, 2006 

Job Number: 061109 

Prepared by: 

Air Compliance Testing, Inc. 

PO Bo% 41156 

Cleveland OH 44141-0156 

Phone: (800) EPA-AIRt (372-2471) 

Report Date: December 23, 2006 
Kiln Throughput Calculations 

Marseilles Emissions Testing 

November 8 and 9, 2006 

Kiln Operating Parameters 

Kiln I Push Interval = 25 Min. 

Kiln 2 Push Interval = 24 Min. 

Weight of 1 brick = 3.7 Ibs. 

# Bricks per Car = 10080 Bricks 

# Bricks Per Push = 3360 Bricks (1/3 of Car) 

Kiln 1 Throughput Calculation 

3360 Bricks 3.71bs. 1 Ton 60 Min. 

-------------- * ----------- * ----------- * ----------- = 14.92 Tons of Brick per Hour 

25 Min. Brick 20001bs. 1 Hour 

Kiln 2 Throughput Calculation 

3360 Bricks 3.7 lbs. 1 Ton 60 Min. 

-------------- * ----------- * ----------- * ----------- — 15.54 Tons of Brick per Hour 

24 Min. Brick 2000 Ibs. I Hour