# MEMORANDUM

Date: September 4, 2009

To: Jeff Telander, EPA/SSPD

From: Irene Kuo and Susan Miller, Brick Industry Association

Michael Hartman, Air-Tech Environmental, LLC

Subject: Subsequent review of test reports and BIA comments on EPA actions

on preliminary review of test reports

The purpose of this memorandum is to pres ent the review of the second round of

test reports, as well as to present co mments on EPA’s conclusions on our first

memorandum (June 5, 2009). The table included with this memorandum includes

all test reports fo r completeness.

BIA Comments on EPA Actions

On June 5, 2009, BIA submitted a preliminary review of stack test reports currently

being used to establish the emissions st andards for the brick industry. This

previous memo outlined our approach to t he review process and identified the

primary concerns in using certain test repor ts. BIA identified thr ee overall groups of

concern:

Group 1: Tests that should be remo ved from the database due to

inappropriate testing including use of the wrong equipment, test conditions

outside method specifications, use of methods other than Method 26A,

insufficient number of test runs, and calibration errors.

Group 2: Tests that warrant addi tional review by EPA prior to consideration for

developing the standard wit h primary focus on the reporting use of nondetectable emissions and insufficient information to satisfy appropriate

methodology.

Group 3: Tests that were incorrectly interp reted by EPA in their draft summary

table including use of capacity over production during testing, typographical and

calculation errors, and data collected under conditions that do not reflect normal

operating conditions.

# BIA identified 51 sources whose test r eports were suspect, including 16 Group 1

sources that should be immediately remo ved from the databas e. EPA reported an

evaluation of 9 of these 16 kilns. A summa ry of BIA’s comments on these actions is

attached (Attachment 1). In general, BI A concurred with EPA’s actions, with the

exception of the discrepancy of whether a regional EPA -rejected test was used for

kiln 530. A detailed assessment of this di screpancy is provided in Attachment 1.

BIA continues to support the exclusion of this report.

The test reports for the remaining 42 sour ces identified by BIA in the preliminary

review are still of major concern, especially those of the seven additional sources in

Group 1, which should be immediately remov ed. Also of primary concern are the

15 sources in the first review whose emi ssion factors are based on non-detectable

emissions. In the second round of revi ew outlined below, BI A has identified 4

additional sources with non-detectable emissions. While we contend that no nondetects should be used in standard setting , at a minimum, any use of data

derived from non-detectable results should be standardized across all test reports

and follow sound science. In doing so, demonstration of compliance will be

consistent with the procedures used during testing to set the emission limit. We will

be submitting a separate memorandum focu sed on our growing concern about the

use of non-detects in the next two weeks.

Test Report Review Update

A second round of review of the test r eports used to create the EPA’s emissions

database is summarized in Table 1. For a complete updated listing of review

comments on all test reports, see Attachment 2. Using the same method of review

outlined in the June 5, 2009 memo, BIA i dentified 17 additional sources whose test

reports should not be included in the em issions database due to test method error

(i.e. Group 1). These errors include the us e of glass fiber filters and low probe

temperatures which both bias HF and HCl results and the use of incorrect

impingers. Also presented are three test reports that used Method 13B instead of

Method 26A. In EPAs action memo, one test report was removed from the

database for using Method 13B; however, these three were not addressed.

The additional test reports that shoul d be rejected due to inappropriate testing

equipment and/or pr ocedures include:

 Boral Bricks, Kilns 537 & 538, Test Date 10/17/06 - Lab cites ripped filter

 Boral Bricks, Kilns 547 & 548, Test Da te 5/15/07 – Filter temperatures <248

degrees F

 Boral Bricks, Kiln 568, Test dat es 5/24/06 & 3/14/ 07 – Low probe and

filter temperatures

 General Shale, Kiln 612, Test Da te 2/23/05 – Run 1 should be rejected

due to low temperatures.

#  Pine Hall Brick, Kilns 724, Test Date 2/3/04 – Glass fiber filter used instead

of Teflon or quartz.

 Pine Hall Brick, Kiln 725, Test Date 6/22/05 – Glass fiber filter used instead

of Teflon or quartz.

 Redland Brick, Kiln 736, Test Date 5/10/06 – Discrepancy over the type of

filter used since report cites both glass and Teflon. Stack temperatures were

~230 degrees F.

 Redland Brick, Kiln 738, Test Da te 3/11/05 – Low probe and filter

temperatures.

o Test Date 10/25/05 – Gla ss fiber filter and not

indicative of normal operations.

o Test Date 4/22/05 – Low probe and filter

temperatures.

 J.L. Anderson Co., Kilns 722 &723, Test Date 3/4/99 - These results are for

chlorine in NaOH impingers not HCl in H 2 

# SO 4 

# impingers.

 Acme Brick, Kiln 516, Test Date 10/12/93 – Method 13B instead of 26A

 Boral Brick, Kiln 555, Test Date 4/22/99 – Method 13B instead of 26A

 Acme Brick, Kiln 510, Test Date 3/4/96 – Method 13B instead of 26 A and

used capacity instead of production during test.

 Belden Brick, Kiln 530, Test Date 5/30/07 – Local EPA rejected test.

Group 2

BIA identified four additiona l sources whose emission factors are based on nondetectable emissions. For PM, it is a gener ally accepted practice to collect a

minimum weight of 6.0mg according to the National Council for Air and Stream

Improvement (NCASI). Insufficient collect ion of the sample leads to non-detectable

emissions being reported in a non-standardized way. BIA strongly encourages

EPA to review these test r eports, along with the 15 source s cited in the preliminary

review document.

Additional test reports t hat require further analysis due to non-detectable emissions

include (please see June 5 memor andum for other 15 sources):

 Boral Brick, Kiln 549, Test Date 11/4/98 – Non detects reported for PM

 Boral Brick, Kiln 566, Test Date 7/ 20/07 – Analytical detection limits reported

 Glen Gery, Kiln 643, Test Date 4/26/ 05 – HCl emissions are reported as 0.

 Lee Brick, Kilns 695 & 696, Test Dates 3/29/05 & 4/25/07 – Insufficient

collection of PM sample resu lting in non-detectable levels.

Group 3

The emission factors for three sources we re derived based on calculation error.

These sources were presented in the preliminary memo and are repeated here

# since the corrections were not made in EPA’s updated emissions database dated

7/20/09. One source at Lee Brick was mi sinterpreted as having two tests for one

stack instead of simultaneous results from tw o stacks from the source. Test reports

that we believe were misinterpreted are:

 Pine Hall Brick, Kilns 729 & 730, Test Date 11/1/06 – Emissions calculation

error

 General Shale, Kiln 609, Test Date 11/1/06 – Calculation error

 Hanson Brick, Kilns 675 & 676, Test Date 6/29/93 – Typographical error

resulting in calculation error.

 Lee Brick, Kiln 694, Test Date 4/ 18/97 – Stack results should be added not

averaged due to confi guration of kilnTable 1. Round 2- Review Comments on Test Reports Used to Generate Emission Factors for HF, HCl, and PM for the Brick IndustryParent_CoFacNameSTMaj_AreaKilnIDAPCD_TypeTest ReportUsed toGenerate EmFactorNotes on Em FactorNotes on Test ReportBoralBricksInc.BoralAtlantaPlantGA MajorSourceEU01 DryInjection/FabricFilter (DIFF)10/17/2006EPA divided theresults for two kilnsPM is at detection limit (<3mg capture) Lab citesripped filter. Test should be rejected.BoralBricksInc.BoralAtlantaPlantGA MajorSourceEU02 DryInjection/FabricFilter (DIFF)10/17/06,3/28/07, 2/15/07EPA used the per kilnresult for 537 andaveraged with twolater tests. Usedaverage productionduring tests. Without2/15 report, factorsare not significantlydifferent, exceptHCl=.019 lb/ton3/28 test appears to be a re-do since 2/15 failedMACT compliance. The 3/28 test cites that labreceived ripped filter, thus data should beREJECTED. Question whether other pollutant datashould be used from 2/15 test since it failed for HF.On 10/17 test, PM collection below 3mg standard.Correction: The 10/17 test cites ripped filter.BoralBricksInc.BoralBessemerPlant #6ALMajorSource003DryInjection/FabricFilter (DIFF)5/15/2007Straight from testreport. Averagedbetween 2 kilns forone stackTest should be rejected due to low filter temps. Mostfilter exit temperatures on all 3 runs were <248degrees causing a low bias for HF.BoralBricksInc.BoralBessemerPlant #6ALMajorSource004DryInjection/FabricFilter (DIFF)Test should be rejected due to low filter temps. Mostfilter exit temperatures on all 3 runs were <248degrees causing a low bias for HF.BoralBricksInc.BoralGleasonPlantTN MajorSourceES02 Uncontrolled11/4/1998Straight from testreport.Non-detects for PMBoralBricksInc.BoralSalisburyPlantNC MajorSource6BK DryInjection/FabricFilter (DIFF) 2/13/07 &7/20/07 Plant 6EPA averaged thetwo tests, but cannotconfirm HCl. BIAdata suggestsHCl=.046 lb/ton.Plant 6For the 7/20/07 test, HF and HCl used analyticaldetection limits to calculate emissions.Table 1. Round 2- Review Comments on Test Reports Used to Generate Emission Factors for HF, HCl, and PM for the Brick IndustryParent_CoFacNameSTMaj_AreaKilnIDAPCD_TypeTest ReportUsed toGenerate EmFactorNotes on Em FactorNotes on Test ReportBoralBricksInc.BoralUnion CityPlantOK AreaSource(synthetic)EU02 DryInjection/FabricFilter (DIFF)8/8/06, 5/24/06,3/14/07EPA averaged wherepossible.8/24 test shows ND for HF leaving only 2 viable runs.Analytical data was insufficient to determine possiblecause of ND. EPA should reject 5/24/06 test due tolow probe temperatures.. Test report 3/14/07 alsoshowd low probe and filter temperatures.Cunningham BrickCompany, IncCunninghamThomasvilleNC MajorSourcetk-1 Uncontrolled4/22/97 tk-1Production rateduring testingreported at 7.34tons/hr. Lb/hr #sconfirmedOK to use.GeneralShaleBrick, IncGeneralShaleBrickPlants 35& 36VA MajorSourcetk-1 Dry LimestoneAdsorber(DLA)2/23/2005 Unit#5EPA divided theresults for two kilns.HF results from Run 1 should be excluded due to lowtemperatures. Entire test should be rejected due toonly 2 viable runsGeneralShaleBrick, IncGeneralShaleMoncureFacilityNC MajorSourceES-K4 Dry LimestoneAdsorber(DLA)2/10/06 Kiln 4Straight from testreportOk to useGlenGeryGlen-GeryCorporation-HanleyPA AreaSource(synthetic)SID -113Wet Scrubber4/26/2005Cannot confirm HCl .Teflon filter used. HCl number reported as 0controlled. No analytical data available for furtherreview. PM gained weight.Lee Brickand TileCoLee BrickSanfordFacilityNC MajorSourceES-K2 Uncontrolled4/18/1997 Kiln 2Data was averagedand should havebeen added togethersince this kiln has twostacks. Resulting inHF emission of0.96lb/ton.Inappropriately used fluorides emissions to representHF (9/8/99 pre-proposal letter to EPA) 26A datalooks ok though no probe temperature data wasavailable and some filter temps looked low.Lee Brickand TileCoLee BrickSanfordFacilityNC MajorSourceES-K3 Other3/29/2005 Kiln 3Straight from testreportAll runs were non-detects averaging only 1.5mg totalweight. Minimum weight is 6.0 mg per NCASI.Table 1. Round 2- Review Comments on Test Reports Used to Generate Emission Factors for HF, HCl, and PM for the Brick IndustryParent_CoFacNameSTMaj_AreaKilnIDAPCD_TypeTest ReportUsed toGenerate EmFactorNotes on Em FactorNotes on Test ReportLee Brickand TileCoLee BrickSanfordFacilityNC MajorSourceES-K4 Dry LimestoneAdsorber(DLA)4/25/2007 Kiln 4Straight from testreportRun 1 was 1.1 mg total weight. Minimum detectionon PM is 6.0 mg (NCASI). Runs 2 and 3 average 6.0mg. Without 3 viable runs, test should be rejected.Pine HallBrick CoIncPine HallBrick CoIncGA AreaSource(synthetic)tk-61 Dry LimestoneAdsorber(DLA)2/3/2004Straight from testreportTest results for HF and HCl should be rejected due touse of glass fiber filter.Pine HallBrick CoIncPine HallBrick CoIncGA AreaSource(synthetic)tk-62 Dry LimestoneAdsorber(DLA)6/22/2005Straight from testreport (Prod rate isslightly diff, but notsignificant)Test results for HF and HCl should be rejected due touse of glass fiber filter.Pine HallBrick Co,IncPine HallMadisonPlant tk41NC MajorSourcetk-41 Dry LimestoneAdsorber(DLA)11/1/2006Averaged betweenone run for two kilnsand one run for onekiln to get lb/hr perkiln. When dividedby per kiln tph emfactors should beHF=.02lb/ton,HCl=.014, PM=.138.EPA divided by 2again.Needs more analytical data for further review.Preliminary notes: Average emissions reportedincorrectly in test report.Kiln 2 flowrate is 60%higher than Kiln 1. (For tests performed on 11/2 and11/3: HF error on meter volume on Run 3. Averageshould be .012 not .009.)We are in discussions withtesting firm.Pine HallBrick Co,IncPine HallMadisonPlant tk42NC MajorSourcetk-42 Dry LimestoneAdsorber(DLA)Averaged betweenone run for two kilnsand one run for onekiln to get lb/hr perkiln. When dividedby per kiln tph emfactors should beHF=.02lb/ton,HCl=.014, PM=.138.EPA divided by 2again.Table 1. Round 2- Review Comments on Test Reports Used to Generate Emission Factors for HF, HCl, and PM for the Brick IndustryParent_CoFacNameSTMaj_AreaKilnIDAPCD_TypeTest ReportUsed toGenerate EmFactorNotes on Em FactorNotes on Test ReportRedland(Belden)BrickCompanyRedlandCushwaPlantSteel kilnMDMajorSourcetk-1-SteelkilnDry LimestoneAdsorber(DLA)5/10/2006 tk-1steel kilnStraight from testreport.Confirmed proper filter with test company. Data isalso suspect since stack temperatures were ~230degree F. Data may not berepresentative of normaloperations.Redland(Belden)BrickCompanyRedlandHarmarPlantPA AreaSource(synthetic)NEW -HarmerDryInjection/FabricFilter (DIFF)3/5/02, 3/11/02,4/22/05 &10/25/05Averaged from testreports. Based onconversation with B.Miller at the plant,only the shale runsshould beconsidered. Otherruns were run atextreme feedconditions and arenot indicative ofnormal operatingcnditions.Did not review 3/5/02 report since not indicative ofnormal operations. Should not include this test. Testreport from 3/11/05 should be rejected due to lowprobe and filter temperatures. Non detect limits usedon all data, however the analytical data states "nodetectable amount". There is concern over how thereportable limit was devised. Should not include testdata from 10/25/05 since it is not indicative of normaloperating procedures. The 4/22/05 test had lowprobe and filter temperatures and should be rejected.J. L.AndersonCo., IncPalmettoBrickSC AreaSource(synthetic)-nosurveytk-1 Dry LimestoneAdsorber(DLA) 3/4/1999EPA divided testresult by twoThese results are for chlorine in NaOH impingers notHCl in H2SO4impingers. DO NOT USEJ. L.AndersonCo., IncPalmettoBrickSC AreaSource(synthetic)-nosurveytk-2 Dry LimestoneAdsorber(DLA)EPA divided testresult by twoThese results are for chlorine in NaOH impingers notHCl in H2SO4impingers. DO NOT USEAcmeBrickCompanyAcmePerlaPlant(PEP/PWP)AR MajorSourcetk-2 Uncontrolled10/12/1993Straight from testreport. UsedFluorides as HF.Need to confirmproduction rateduring test.Need full test report for review. Inappropriately usedfluorides emissions to represent HF (9/8/99 preproposal letter to EPA)BoralBricksInc.BoralMacon,MS PlantMSMajorSourceAA-001 Uncontrolled4/22/1999Straight from testreport. Fluorides asHF. NoNeed full test report for review. Inappropriately usedfluorides emissions to represent HF (9/8/99 preproposal letter to EPA)Table 1. Round 2- Review Comments on Test Reports Used to Generate Emission Factors for HF, HCl, and PM for the Brick IndustryParent_CoFacNameSTMaj_AreaKilnIDAPCD_TypeTest ReportUsed toGenerate EmFactorNotes on Em FactorNotes on Test Reportdifferentiationbetween total PM orfront half.AcmeBrickCompanyAcmeEurekaPlant(EBP)AR MajorSourcetk-5 Uncontrolled3/4/1996EPA took theaverage of two testsperformed on thesame day and usedcapacity of 4.98instead of 3.67tph asreported.Calc'd average using fluorides (13B) and HF(26A).13B provides no speciation of gaseous fluoride andshould not be considered. (9/8/99 pre-proposal letterto EPA) Need full test report to reviewHansonBrickEast,LLCHanson -MichiganMI AreaSource(synthetic)tk-2 DryInjection/FabricFilter (DIFF)6/7/1995EPA used anaverage based ontwo runs one of whichwas ND. Usedfluoride emissions asHFFilter type not specified. Filter temp reported as 0.Non-detects present. No analytical data.Inappropriately used fluoridesemissions to representHF (9/8/99 pre-proposal letter to EPA)GeneralShaleBrick, IncGeneralShaleBrickPlants 20,32 & 43INMajorSourcetk-1DryInjection/FabricFilter (DIFF)11/1/2006 Kiln20EPA averaged 4 testruns. Plant excludedrun 1 from reportedavg. Avg from 3 runsHF=.00038,HCl=.146, andPM=.022. PMchanged morebecause 1 run of the4 reported 0emissions.Filter type not specified. Non-detects present. (Note:this kiln has not run since test)GeneralShaleBrick, IncGeneralShaleBrickPlants 20,32 & 43IN MajorSourcetk-2 DryInjection/FabricFilter (DIFF)11/2/06 &1/24/07 Kiln 32EPA averaged thetwo tests. EPA didnot use productionrate to calc lb/ton11/2/06 test should be rejected. This test failed forSO2 and process was changed permanently to thetest conditions of 1/24/07 test. HF=.045lb/ton,HCl=.006 lb/ton, PM=.03 lb/tonTable 1. Round 2- Review Comments on Test Reports Used to Generate Emission Factors for HF, HCl, and PM for the Brick IndustryParent_CoFacNameSTMaj_AreaKilnIDAPCD_TypeTest ReportUsed toGenerate EmFactorNotes on Em FactorNotes on Test ReportHansonBrickEast,LLCHansonMineralWellsTXAreaSource(synthetic)tk-1DryInjection/FabricFilter (DIFF)6/29/1993 Kiln 1Typo for PM for Kiln2. Should be 3.425lb/hr and 0.03lb/ton.Full design capacitywas used by EPA.Test report suggeststests were at 76%capacity (13/17 cars)which only slightlychanges numbers toHF=.000469 andPM=.59 for Kiln 1and HF=.00049 andPM=0.39 for Kiln 2Need analytical data for full reviewHansonBrickEast,LLCHansonMineralWellsTXAreaSource(synthetic)tk-2DryInjection/FabricFilter (DIFF)6/29/1993 Kiln 2Typo for PM for Kiln2. Should be 3.425lb/hr and 0.03lb/ton.Full design capacitywas used by EPA.Test report suggeststests were at 76%capacity (13/17 cars)which only slightlychanges numbers toHF=.000469 andPM=.59 for Kiln 1and HF=.00049 andPM=0.39 for Kiln 2

# Attachment 1

Emission Test Results Reviewed by BIA

EPA Response and Action Taken

BIA Position on EPA Action

BIA Comments on EPA’s response and action noted in red.

1. General Shale -- Kiln 603, Test Date 9/21/01

BIA Recommendation

Results of this test should be removed from the database because a glass fiber filter was

used.

EPA Response

The test report includes a specifications sheet on glass fiber filters in the appendices (page

110), but page 41 of the test re port indicates that a quartz fibe r filter was used, not a glass

fiber filter as indicated by BIA. Section 7.1.1 of Method 26A requires a Teflon mat filter,

but allows use of a quartz fiber filter when the stack gas temperature exceeds 410°F. In this

test, a quartz fiber filter was used, but the st ack gas temperature never exceeded 280°F.

Therefore, there is justificati on to remove the test results fr om the MACT floor analysis.

Also, Section 8.1.5 of Method 26A requires a temperature "around the probe, filter (and

cyclone, if used), of greater th an 120°C (248°F)." The field da ta sheets (pages 60 to 62 of

test report) indicate the "Box Temp" dropped belo w 248°F for a few of the traverse points (1

point during Runs 1 and 3, and 6 points during Run 2). So, there is also an additional

argument for disallowing the results of this test.

In conclusion, we agree with BIA that the re sults of the HF test should not be used.

However, the above-noted problems s hould not affect PM test results.

EPA Action Taken

HF results removed from lookup table; PM data retained.

BIA Response

BIA concurs.

2. General Shale -- Kiln 604, Test Date: 12/15/05

BIA Recommendation

Results of this test should be removed from the database because a glass fiber filter was

used.

EPA Response

Page 9 of the test report indicates that a glass fiber filter was used. Therefore, we agree with

the BIA's recommendation for disallowing the test results.

# EPA Action Taken

HF and HCl results removed from lookup table; PM data retained.

BIA Response

BIA concurs.

3. Acme Brick -- Kiln 508, Test Date: 3/15/97

BIA Recommendation

Results of this test should be removed fr om the database because of high moisture.

EPA Response

The only test report we have for this kiln is for a test conducted on March 15, 2007. We

assume that this is the test BIA was referenci ng. The entry for this k iln in Table 1 of the

BIA memo indicates for this test that the pr oblems were "Non-detec ts present and high

moisture."

Page 23 of the test report indicates moistu re readings ranged from 14.32 to 18.26 percent for

the Method 5 sampling train. However, HF and HCl were measured using a separate

Method 320 sampling train, which included a sa mpling line that was maintained at a

temperature above 340°F. Therefore, moisture interference should not be a concern for the

HF and HCl results, and we do not believe there is sufficient justificat ion for disallowing the

results of this test.

EPA Action Taken

None.

BIA Response

BIA concurs with evaluaton of the moisture leve ls and its effect on HF and HCl results. It

should be noted that this test report is still considered questio nable due to non-detect values

for PM.

4. Hanson Brick -- Kiln 655, Test Date: 6/7/95

BIA Recommendation

Results of this test should be removed from the database because either the probe and filter

temperature were not maintained "at or above 25 0°F" or there is not "sufficient QA/QC data

to support the average te mperature readings."

EPA Response

The "Summary of Particulate Train Paramete rs" for the fluoride test (Method 13B) in the

report indicates "0" as the average filter temper ature. The "Sampling Train Data" sheets in

the appendices show no entries for the "Filter Te mp." Based on this, it appears that filter

temperatures were not measured.

# In conclusion, we agree with BIA that the data from this test should be disallowed.

EPA Action Taken

HF (fluoride - Method 13B) resu lts removed from lookup table.

BIA Response

BIA concurs. However, action on Method 13B data has not been decided by EPA in this

document.

5. Belden Brick -- Kiln 530, Test Date: 5/30/07

BIA Recommendation

Results of this test should be removed from th e database because the te st data were rejected

by the State of Ohio due to im proper sampling point location.

EPA Response

A review of the sampling location diagram indi cates that the sampling point was located 1.2

duct diameters downstream of the nearest flow disturbance. Since Method 1 requires a

minimum of two duct diameters downstream of a fl ow disturbance, we concur that the test

results should not be used. However, the re sults had not been us ed in developing the

Lookup Table for the MACT Floor ranking b ecause the test was conducted on a stack

exhausting three kilns and there were other test data on emissions of Kiln 530 alone.

EPA Action Taken

None

BIA Response

Kiln 530 is one of 3 uncontrolled tunnel kilns in Plant #6. The test data available for this

kiln are:

Test Date HF (lb/hr) HCl (lb/hr) PM (lb/hr)

11/93 1.00 0.06 1.40

5/94 2.94 1.8 6.72

Averages 1.97 0.93 4.06

EPA data 1.97 0.9315 2.7025

If you include rejected 5/07 data for PM at 1.388 lb/hr, you get an overall average of

2.702lb/hr. Therefore, it appears that EPA did use the state-re jected test report in their

original Lookup Table for MACT Floor ranking and should adjust the PM number to 4.06

lb/hr or 1.236 lb/ton. (EPA’s origin al factor for PM was 0.823 lb/ton)

6. Belden Brick -- Kiln 535, Test Date: 5/31/07

# BIA Recommendation

Results of this test should be removed from th e database because the te st data were rejected

by the State of Ohio due to im proper sampling point location.

EPA Response

A review of the sampling location diagram indi cates that the sampling point was located 1.3

duct diameters downstream of the nearest flow disturbance. Since Method 1 requires a

minimum of two duct diameters downstream of a fl ow disturbance, we concur that the test

results should not be used.

EPA Action Taken

The HF and HCl emission factors for this ki ln in the Lookup Table were based on two other

tests and not this test. However, the PM emission factor in the Lookup Table was based on

this test and the other two tests. A revi sed PM emission factor was calculated after

removing the results of this test.

BIA Response

Kiln 535 is one of 2 uncontrolled kilns in Plan t #9. Revised PM emission factor should be

0.812 lb/ton after removal of rejected te st. Previous factor wa 2.28 lb/ton.

(Upon re-examination, the original PM emission f actor cannot be duplicated. This is a moot

point since EPA is agreeing to re move the rejected data. Possible discrepancy could be use

of front half data, but cannot be confirmed with test reports as written. Note if EPA’s

revised emission factor is not 0.812 lb/t on, this will need to be revisited.)

7. Belden Brick -- Kiln 531, Test Date: 8/26/03

BIA Recommendation

Results of this test should be removed from th e database because the te st data were rejected

by the State of Ohio due because the proper filt er temperatures were not maintained during

the test.

EPA Response

The file copy of the test report for this kiln is incomplete and does not include the

appendices showing filter temperatures. Howe ver, we have no reason to question the

assessment by the Ohio EPA.

EPA Action Taken

Results of test removed from lookup table.

BIA Response

Acceptable action.

# 8. Acme Brick -- Kiln 514, Test Date: 3/27/07

BIA Recommendation

Results of this test should be removed from the database because th ere were only two valid

test runs. In the BIA memo, the Table 1 entry for this test indicates Run 1 failed the leak

check, so the results for that test run are invalid.

EPA Response

It is unclear what the basis is for BIA dete rmining that Run 1 failed the leak check. The

Field Data Sheet for Run 1 shows hand-writte n entries for the pre- and post-run meter

readings for leak checks and net leakage rates. The entries indicate that the net leakage rates

to be 0.04 to 0.09 cubic feet per minute (cfm). However, those values were not calculated

correctly. The correct leakag e rates should be 0.004 to 0.009 cfm, all of which meet the

criterion of less than 0.02 cfm. Therefore, it appears that the leak checks all passed. If the

Field Data sheet is the basis for BIA's r ecommendation, then we disagree with their

assessment.

EPA Action Taken

None

BIA Response

BIA concurs with the recalculated leak check va lues. It should be noted, however, that the

PM captures were all less than 3mg (from 0.7 – 3.0 mg) which are considered non-detects

by NCASI and SES. Captures less than 3m g warrant test runs longer than 1 hour.

9. Acme Brick -- Kiln 503, Test Date: 11/9/05

BIA Recommendation

Results of this test should be removed from the database because th ere were only two valid

test runs. In the BIA memo, the Table 1 entry for this test indicates Run 1 HF results were

excluded because they were much higher than th e other two runs (both of which were below

the detection limit).

EPA Response

The emission factor in the Lookup Table is the av erage of all 3 runs; th e results from Run 1

were not excluded, as claimed by BIA. In addi tion, the BIA memo states that each of the

three kilns tested had a production rate of 8.84 tons/hr and that the 9.98 tons/hr production

rate used by RTI was incorrect. However, th e ICR response from Acme states that the

production rates for each of the kiln s during the test was 9.98 tons/hr.

EPA Action Taken

None

BIA Response

11/9/05 test ran a total of 4 runs, the first excl uded due to scrubber upset (see p A0009).

Production rate of 8.84 came in a separate co rrespondence to BIA from Jason Pence (see

# insert labeled confidential). This production rate is not readily availabl e in test report. It

should be noted that data is still consid ered suspect due to non-detection limits.Attachment 2. Review of Test Reports Used to GenerateEmission Factors for HF, HCl, and PM for the Brick IndustryCumulativeKilnNoBIA_IDFacNameCityStateTest Report Used toGenerate Em FactorBIA Notes on Em FactorGenerated by EPANotes on Test Reports Used to Generate Emission Factor604BIA-070General Shale Brick-Plant 38FairsdaleKY12/15/05 Kiln 38B Straight from test reportUsed glass fiber filter and HF data was non-detect (EPA removed HF andHCl and retained PM)765BIA-148Taylor ClaySalisburyNC11/1/2007 ESK4 Straight from test reportFurther QA/QC data needed for furtherreview. HCl concentrations weredetectable for two runs while HF ws not detected in any of the outletsamples. One-half the detection limit was used for this report. Noinformation on filter type available.603BIA-070General Shale Brick-Plant 38FairsdaleKY9/21/2001 Straight from test reportQuartz fiber filter listed in description but glass fiber listed in Appendix.Conflicting values of HF reported 3 orders of magnitude apart. Nondetects listed for 2 of 3 runs in both cases. Data is suspect. (EPAremoved HF and HCl and retained PM)567BIA-208Boral- Terre Haute PlantTerre HauteIN8/919/08 Straight from test report.No filter type specified. All HF are non detects. Lower flow rates thanother kilns. Fluoride calibration data is missing.558BIA-104Boral- Muskogee PlantMuskogeeOK7/25/2007Straight from test report. 7/11 testwas engineering test, while 7/25 waspermit compliance. Both weresubmitted. HF would not change ifaveraged, but HCl would be .01lb/ton and PM would be .089 lb/ton.All HF is below detection limits.675BIA-019Hanson Mineral WellsMineral WellsTX6/29/1993 Kiln 1Typo for PM for Kiln 2. Should be3.425 lb/hr and 0.03lb/ton. Fulldesign capacity was used by EPA.Test report suggests tests were at76% capacity (13/17 cars) whichonly slightly changes numbers toHF=.000469 and PM=.59 for Kiln 1and HF=.00049 and PM=0.39 forKiln 2Need analytical data for full reviewAttachment 2. Review of Test Reports Used to GenerateEmission Factors for HF, HCl, and PM for the Brick IndustryCumulativeKilnNoBIA_IDFacNameCityStateTest Report Used toGenerate Em FactorBIA Notes on Em FactorGenerated by EPANotes on Test Reports Used to Generate Emission Factor676BIA-019Hanson Mineral WellsMineral WellsTX6/29/1993 Kiln 2 0609BIA-072General Shale Brick-Plants20, 32 & 43MooresvilleIN11/1/2006 Kiln 20EPA averaged 4 test runs. Plantexcluded run 1 from reported avg.Avg from 3 runs HF=.00038,HCl=.146, and PM=.022. PMchanged more because 1 run of the4 reported 0 emissions.Filter type not specified. Non-detectspresent. (Note: this kiln has notrun since test)531BIA-005Belden- Plant #8 SugarcreekSugarcreekOH8/26/2003 (&8/23/05for PM)For HF and HCl, EPA took 8/26/03result and divided for 3 kilns. ForPM, they added 8/26/03 and 8/23/05results and divided by 6. Without8/26, PM would be 1.26 lb/hr andusing their prod rate 0.182 lb/ton.EPA did not use engineering testfrom 9/27/01Should not include 8/26/03test since it was rejected by Ohio EPA forImproper test method. (Letter dated 11/7/03 from S. Clay to J. Johnson)532BIA-005Belden- Plant #8 SugarcreekSugarcreekOH0533BIA-005Belden- Plant #8 SugarcreekSugarcreekOH0653BIA-018Hanson – ElginElginTX10/21/2007 tk-2 Straight from test reportData collected is 2 orders of magnitude below the lowest calibration. Noconfirmation of filter type for tk-2.Low volume of gas collected (15 cubicfeet).547BIA-111Boral- Bessemer Plant #6BessemerAL5/15/2007Straight from test report. Averagedbetween 2 kilns for one stackTest should be rejected due to low filter temps. Most filter exittemperatures on all 3 runs were <248 degrees causing a low bias for HF.548BIA-111Boral- Bessemer Plant #6BessemerALTest should be rejected due to low filter temps. Most filter exittemperatures on all 3 runs were <248 degrees causing a low bias for HF.Attachment 2. Review of Test Reports Used to GenerateEmission Factors for HF, HCl, and PM for the Brick IndustryCumulativeKilnNoBIA_IDFacNameCityStateTest Report Used toGenerate Em FactorBIA Notes on Em FactorGenerated by EPANotes on Test Reports Used to Generate Emission Factor666BIA-045Hanson - Pleasant GardenPleasantGardenNC5/10/2006 straight from test report OKto use, though HCl looks suspicious.655 BIA-095 Hanson - Michigan Corunna MI6/7/1995EPA used an average based on tworuns one of which was ND. Usedfluoride emissions as HFFilter type not specified. Filter temp reported as 0. Non-detects present.No analytical data. Inappropriately used fluorides emissions to representHF (9/8/99 pre-proposal letter to EPA) (EPA removed HF)568 BIA-207 Boral- Union City Plant Union City OK8/8/06, 5/24/06,3/14/07EPA averaged where possible.8/24 test shows ND for HF leaving only2 viable runs. Analytical data wasinsufficient to determine possible cause of ND. EPA should reject 5/24/06test due to low probe temperatures.. Test report 3/14/07 also showd lowprobe and filter temperatures.721 BIA-128 Pacific Coast-West Jordan West Jordan UT10/31/1995 Straight from test report Needs full review502 BIA-077 Acme- Bennett Tunnel Plant(BTP)Millsap TX10/5/2005 & 6/5/97?EPA used average for HF and HCl.Need to confirm PM and productionrate. Looks like EPA may have usedFront half PM emissions from 6/97report instead of total.Analytical error: diluted sample but reported no dilution resulting in nondetects for 6/5/97 HF. No QA/QC data for 10/5/05 report. Non-detectsalso present on 10/05/05 report.662 BIA-044 Hanson - Monroe Monroe NC12/1/2006 Straight from test report Needs full review738BIA-015Redland- Harmar PlantCheswick PA3/5/02, 3/11/02,4/22/05 & 10/25/05Averaged from test reportsDid not review 3/5/02 report since not indicative of normal operations.Should not include this test. Test report from 3/11/05 should be rejecteddue to low probe and filter temperatures. Non detect limites used on alldata, however the analyticaldata states "no detectable amount". There isconcern over how the reportable limit was devised. Should not includetest data from 10/25/05 since it used aglass fiber filter and because is notindicative of normal operating procedures. The 4/22/05 test had lowprobe and filter temperatures and should be rejected.Attachment 2. Review of Test Reports Used to GenerateEmission Factors for HF, HCl, and PM for the Brick IndustryCumulativeKilnNoBIA_IDFacNameCityStateTest Report Used toGenerate Em FactorBIA Notes on Em FactorGenerated by EPANotes on Test Reports Used to Generate Emission Factor503 BIA-078 Acme- Denton Plant (DTP) Denton TX11/9/2005EPA used capacity of 9.98 whenaverage throughput during test was8.84tph. BIA estimates are 0.003lbHF/ton and .014 lbHCl/tonBIA summary cites 9/9/05 perhaps typo. Run 1 was excluded for noreason other than high HF #'s. No QA/QC on sampling temperatures orfilter type. Two numbers used are non-detects. Insufficient QA/QC data.504 BIA-078 Acme- Denton Plant (DTP) Denton TX0505 BIA-078 Acme- Denton Plant (DTP) Denton TX0625 BIA-038 General Shale- MoncureFacilityMoncure NC2/10/06 Kiln 4 Straight from test report Ok to use687BIA-013Jenkins- Montgomery PlantMontgomery AL6/5/2007 tk-2Straight from test report. Need toconfirm if DIFF iscontrolling twokilns to be able to consider 8/3report. 8/3 report has suspect datafor HF, potentially usable data forHCl, but no PM or production data.Non-detects present with PM collection below 3mg standard detectionlimit.696BIA-055Lee Brick Sanford FacilitySanford NC4/25/2007 Kiln 4 Straight from test reportRun 1 was 1.1 mg total weight. Minimum detection on PM is 6.0 mg(NCASI). Runs 2 and 3 average 6.0 mg. Without 3 viable runs, testshould be rejected.508BIA-080Acme- Elgin Plant(ELP/ENP)Elgin TX3/15/2007 Straight from test report Non-detects present and high moisture766 BIA-048 TriangleBrick- Merry OaksPlantMerry Oaks NC4/20/06 & 8/10/06EPA average two tests and dividedby 2 for Kiln 1 and Kiln 2 (commonDLA/stack)Needs full review767 BIA-048 TriangleBrick- Merry OaksPlantMerry Oaks NCNeeds full review768 BIA-048 TriangleBrick- Merry OaksPlantMerry Oaks NC5/4/2006 kiln 3 Straight from test report Needs full reviewAttachment 2. Review of Test Reports Used to GenerateEmission Factors for HF, HCl, and PM for the Brick IndustryCumulativeKilnNoBIA_IDFacNameCityStateTest Report Used toGenerate Em FactorBIA Notes on Em FactorGenerated by EPANotes on Test Reports Used to Generate Emission Factor612 BIA-073 General Shale Brick-Plants35 & 36Blue Ridge(Roanoke)VA2/23/2005 Unit #5 EPA divided theresults for two kilns.HF results from Run 1 should be excluded due to low temperatures.Entire test should be rejected due to only 2 viable runs613 BIA-073 General Shale Brick-Plants35 & 36Blue Ridge(Roanoke)VANeeds full review770 BIA-203 Triangle Brick- WadesboroPlantWadesboro NC3/1/2005Straight from test report. Need toconfirm if lb/ton numbers reportedand production rate to back intolb/hr. EPA and BIA lb/hr #'s matchby this method, but then EPA dividedtruncated number by production rateand got slightly lower em factor. Notsignificant.Needs full review769 BIA-203 Triangle Brick- WadesboroPlantWadesboro NC3/14/2006 Straight from test report Needs full review736 BIA-014 Redland- Cushwa Plant SteelkilnWilliamsport MD5/10/2006 tk-1 steelkilnStraight from test report.Discrepancy in reported use of glass fiberfilter versus teflon. Data is alsosuspect since stack temperatures were ~230 degree F. Data may not berepresentative of normal operations.566 BIA-103 Boral- Salisbury Plant Salisbury NC2/13/07 & 7/20/07Plant 6EPA averaged the two tests, butcannot confirm HCl. BIA datasuggests HCl=.046 lb/ton. Plant 6For the 7/20/07 test, HF and HCl used analytical detection limits tocalculate emissions.724 BIA-206 Pine Hall Brick Co Inc Fairmont GA2/3/2004 Straight from test reportTest results for HF and HCl should be rejected due to use of glass fiberfilter.644 BIA-042 Glen-Gery CorporationMarseillesMarseilles IL11/8/2006 Kiln A Straight from test report Needs full review692BIA-092Lawrenceville- Plant IIILawrenceville VA9/2/2004 Kiln 4 Straight from test reportNeed to confirm which test used teflon filter. QA/QC data needed toreview non-detects.Attachment 2. Review of Test Reports Used to GenerateEmission Factors for HF, HCl, and PM for the Brick IndustryCumulativeKilnNoBIA_IDFacNameCityStateTest Report Used toGenerate Em FactorBIA Notes on Em FactorGenerated by EPANotes on Test Reports Used to Generate Emission Factor643 BIA-180 Glen-Gery CorporationHanleySummerville PA4/26/2005 Cannot confirm HCl .Teflon filter used. HCl number reported as 0 controlled. No analyticaldata available for further review. PM gained weight.606 BIA-204 General Shale Brick-Plant 40 Coosa GA7/18/2007 Straight from test report Teflon filter used. No lab data available.506BIA-163Acme- Denver Plant (DVP)Castle Rock CO7/1998 & 8/13/03EPA averaged three tests for HF andHCL. One run for HF and HCL data7/10 reported 0 values. Cannotconfirm PM, but close.Filter material not specified. Suspect glass filter because PM and HF inone train. Non-detects present for HF and HCl.722BIA-035Palmetto BrickWallace SC3/4/1999 EPA divided test result by twoThese results are for chlorine in NaOH impingers not HCl in H2SO4impingers. DO NOT USE723BIA-035Palmetto BrickWallace SCThese results are for chlorine in NaOH impingers not HCl in H2SO4impingers. DO NOT USE729 BIA-011 Pine Hall- Madison Plant tk41Madison NC11/1/2006Averaged between one run for twokilns and one run for one kiln to getlb/hr per kiln. When divided by perkiln tph em factors should beHF=.02lb/ton, HCl=.014, PM=.138.EPA divided by 2 again. Em factorswould not change significantly usingEng report. HF=.017, HCl=.01534,PM=.174. If use variability ofaverages then UCL would beHF=.058, HCl=.0323, PM=.3095Needs more analytical data for further review. Preliminary notes:Average emissions reported incorrectly in test report. Kiln 2 flowrate is60% higher than Kiln 1. (For tests performed on 11/2 and 11/3: HFerror on meter volum on Run 3. Average should be .012 not .009.)730 BIA-011 Pine Hall- Madison Plant tk42Madison NC0725 BIA-206 Pine Hall Brick Co Inc Fairmont GA6/22/2005Straight from test report (Prod rateis slightly diff, but not significant)Test results for HF and HCl should be rejected due to use of glass fiberfilter.Attachment 2. Review of Test Reports Used to GenerateEmission Factors for HF, HCl, and PM for the Brick IndustryCumulativeKilnNoBIA_IDFacNameCityStateTest Report Used toGenerate Em FactorBIA Notes on Em FactorGenerated by EPANotes on Test Reports Used to Generate Emission Factor645 BIA-042 Glen-Gery CorporationMarseillesMarseilles IL11/8/06 & 5/9/07 EPA averaged the two testsNeed to review. HCL numbers reported negative efficiency. Test on5/9/07 was for limestone change. Need to determine if this is indicative ofprocess as normally run.691 BIA-092 Lawrenceville- Plant III Lawrenceville VA10/20/06 Kiln 3Straight from test report. PM fromfront half (filterable)Teflon filter used. Test report ok.647 BIA-179 Glen-Gery Corporation-MidAtlanticShoemakersvillePA10/10/07 - Harrop Straight from test report Needs full review518 BIA-026 Acme- Texas Clay Plant(TCP)Malakoff TX3/26/2002HF and HCl lb/hr straight from testreport. Need to confirm productionrate. PM is from front half only.Need full test report to review. PMfrom front half only. Need to review514BIA-085Acme- Ouachita Plant (OEP)Malvern AR3/27/2007 Straight from test report Run 1should be excluded for failed leak check.542 BIA-096 Boral- Augusta Plants 3, 4, &5Augusta GA? Cannot confirm em factors Identify tests and review543 BIA-096 Boral- Augusta Plants 3, 4, &5Augusta GA11/1/2006 Straight from test for Plant #5 Needs full review573 BIA-056 Carolina Ceramics Columbia SC10/18/05 &12/12/2000 Kiln 3EPA averaged for HF, but HCl andPM only available on 12/12 testNeeds full review574 BIA-056 Carolina Ceramics Columbia SC11/30/2005 Kiln 4 Straight from test report Needs full review610 BIA-072 General Shale Brick-Plants20, 32 & 43Mooresville IN11/2/06 & 1/24/07Kiln 32EPA averaged the two tests. EPAdid not use production rate to calclb/ton11/2/06 test should be rejected. This test failed for SO2 and process waschanged permanently to the test conditions of 1/24/07 test.HF=.045lb/ton, HCl=.006 lb/ton, PM=.03 lb/ton646 BIA-179 Glen-Gery Corporation-MidAtlanticShoemakersvillePA10/10/07 - Bickley Straight fromtest report Needs full review527BIA-002Belden- Plant #3 SugarcreekSugarcreek OH8/24/05 & 5/1/01EPA used average from the two testreports and capacity rather thanproduction during test. Not8/24/05 test is RATA.Attachment 2. Review of Test Reports Used to GenerateEmission Factors for HF, HCl, and PM for the Brick IndustryCumulativeKilnNoBIA_IDFacNameCityStateTest Report Used toGenerate Em FactorBIA Notes on Em FactorGenerated by EPANotes on Test Reports Used to Generate Emission Factorsignificant.641 BIA-177 Glen-Gery Corporation –IberiaIberia OH4/26/2006 Straight from test report Needs full review673 BIA-009 Hanson Columbia - Plant 4 Columbia SC10/5/2006HF is straight from test report.Cannot confirm HCl & PM exactly,but it's very close.Needs full review674 BIA-009 Hanson Columbia - Plant 4 Columbia SC0517 BIA-088 Acme- San Felipe (SFP) Sealy TX4/12/2006HCL is straight from test report.Cannot confirm HF or PM. Testreport: HF=.076lb/ton andPM=.103lb/ton. EPA table lists20.14 as prod rate, but calcs looklike the actual production rate of21.08 tph was used.OK to use583 BIA-037 Columbus Brick Company Columbus MS3/23/06 - kiln 3 Straight from test report Needs full review605 BIA-204 General Shale Brick-Plant 40 Coosa GA7/19/07 & 2/26/08 EPA averaged the two tests.Kiln A QA/QC data neededfor further review.526 BIA-188 Belden- Plant #2 Sugarcreek(P102)Sugarcreek OH1/17/06 &4/30/2001& 8/24/2005 (PM)HF & HCl lb/hr is average from 1/06an 4/30 test reports. PM is averagefrom 4/30 and8/24. Cannot confirmproduction rate, though probablyclose.Need full test report to review649 BIA-181 Glen-Gery Corporation-York York PA10/09/07 - Kiln 2 Straight from test report Needs full review537BIA-097Boral- Atlanta PlantSmyrna GA10/17/2006 EPA divided theresults for two kilnsPM is at detection limit (<3mg capture)Lab cites ripped filter. Test shouldbe rejected.Attachment 2. Review of Test Reports Used to GenerateEmission Factors for HF, HCl, and PM for the Brick IndustryCumulativeKilnNoBIA_IDFacNameCityStateTest Report Used toGenerate Em FactorBIA Notes on Em FactorGenerated by EPANotes on Test Reports Used to Generate Emission Factor740 BIA-016 Redland- KF Plant South Windsor CT? 6 tests available. Cannotconfirm. Needs full review688 BIA-202 Jenkins-Jordan Plant Jordan AL4/18/08 & 2/21/08EPA averaged the two tests. Cannotconfirm production rate. EPA used26.46 and BIA shows avg of 32.5Needs full review544 BIA-096 Boral- Augusta Plants 3, 4, &5Augusta GA? Cannot confirm em factors Identify tests and review577 BIA-093 Cherokee Brick & Tile Macon GA5/16/06, 12/13/06,2/28/07, 4/19/07Average of 4 test reports divided by2. PM and production rate averagedthese 4 tests with 5/8/07 testNeeds full review578 BIA-093 Cherokee Brick & Tile Macon GANeeds full review812 BIA-081 Acme- Fort Smith Plant(FSP)Fort Smith AR12/10/2003Based on total emissions for batchas extrapolated from run datadivided by batch capacityNeeds full review741 BIA-099 Redland- Rocky Ridge Plant Rocky Ridge MDAug-98 Straight from test report Needs full review622 BIA-038 General Shale- MoncureFacilityMoncure NC? Cannot confirm em factors Needs full review623 BIA-038 General Shale- MoncureFacilityMoncure NC? 0614 BIA-073 General Shale Brick-Plants35 & 36Blue Ridge(Roanoke)VA 11/29/06, 5/20/08,8/22/07, 3/14/07 &7/15/08EPA averaged 5 test reports Need s full review (7/15 full report avail on pdf)Attachment 2. Review of Test Reports Used to GenerateEmission Factors for HF, HCl, and PM for the Brick IndustryCumulativeKilnNoBIA_IDFacNameCityStateTest Report Used toGenerate Em FactorBIA Notes on Em FactorGenerated by EPANotes on Test Reports Used to Generate Emission Factor601 BIA-067 General Shale Brick-Plant 10 Johnson City TN7/27/1993USEPA Test report. Straight fromtest report. PM taken from KilnCombustion Exhaust Multiple Metalsand Total Particulate Emissions.Appears to have used both front and back half for PM.551 BIA-113 Boral- Henderson Facility Henderson TX3/02/95, 6/29/05,2/14/96, 8/03/99,8/01/01, 3/13/03,5/25/04Cannot confirm PM Em Factors.Checked front half numbers, but stillcannot confirm. EPA used averagefor HF from all tests and 8/01 and3/13/02 for HCL then divided by 2.First two tests are not listed ashaving been submitted.Needs full review552 BIA-113 Boral- Henderson Facility Henderson TX0538BIA-097Boral- Atlanta PlantSmyrna GA10/17/06, 3/28/07,2/15/07EPA used the per kiln result for 537and averaged with two later tests.Used average production duringtests. Without 2/15 report, factorsare not significantly different, exceptHCl=.019lb/ton3/28 test appears to be a re-do since 2/15 failed MACT compliance. The3/28 test cites that lab receivedripped filter, thus data should beREJECTED. Question whether other pollutant data should be used from2/15 test since it failed for HF. On 10/17 test, PM collection below 3mgstandard. Correction: The10/17 test cites ripped filter.720 BIA-128 Pacific Coast-West Jordan West Jordan UT12/5/1994 Straight from test report Needs full review598 BIA-116 Endicott Clay Products Fairbury NE7/6/1993 Straight from test report Needs full review763 BIA-148 Taylor Clay Salisbury NC7/11/2000Straight from test report for lb/hr HF.Cannot confirm production rate.Needs full review764 BIA-148 Taylor Clay Salisbury NCNeeds full review753 BIA-031 StatesvilleBrick Statesville NC5/15/1997 Straight from test report Needs full reviewAttachment 2. Review of Test Reports Used to GenerateEmission Factors for HF, HCl, and PM for the Brick IndustryCumulativeKilnNoBIA_IDFacNameCityStateTest Report Used toGenerate Em FactorBIA Notes on Em FactorGenerated by EPANotes on Test Reports Used to Generate Emission Factor516 BIA-087 Acme- Perla Plant(PEP/PWP)Malvern AR10/12/1993Straight from test report. UsedFluorides as HF. Need to confirmproduction rate during test.Need full test report for review. Inappropriately used fluorides emissionsto represent HF (9/8/99pre-proposal letter to EPA)539 BIA-102 Boral- Augusta Plant 6 Augusta GA1991Straight from test report, but need toconfirm production rate duringtesting.Needs full review571 BIA-120 Bowerston- Bowerston Plant Bowerston OH11/16/2000 & 9/27/07(HF)EPA averaged two tests for HF andused single data from 11/16 for PM.Cannot confirm production rate.Needs full review555 BIA-110 Boral- Macon, MS Plant Macon MS4/22/1999Straight from test report. Fluoridesas HF. No differentiation betweentotal PM or front half.Need full test report for review. Inappropriately used fluorides emissionsto represent HF (9/8/99pre-proposal letter to EPA)569 BIA-108 Boral- Van Wyck Plants Van Wyck SC1997Straight from test but needconfirmation on capacity versusproduction. Need to confirm PlantB=tk-1 and Kiln #3=tk2Needs full review731 BIA-011 Pine Hall- Madison Plant tk51Madison NC3/3/98 & 3/6/98 Average from two test reports. Need analytical data for full review804 BIA-075 Acme- BennettPlant (BEP) Millsap TX2/12/2003 Cannot confirm, but can get close Needs full review591 BIA-053 Cunningham- Thomasville Thomasville NC4/22/97 tk-1Need to confirm capacity versusproduction rate. Lb/hr #s confirmedOK to use.565 BIA-103 Boral- Salisbury Plant Salisbury NC9/8/2005 Plant 5EPA used kiln exhaust data andexcluded SD dryer.Needs full review694 BIA-055 Lee Brick Sanford Facility Sanford NC4/18/1997 Kiln 2 Straight from test reportInappropriately used fluorides emissions to represent HF (9/8/99 preproposal letter to EPA) 26A data looks ok though no probe temperaturedata was available and some filter temps looked low.Attachment 2. Review of Test Reports Used to GenerateEmission Factors for HF, HCl, and PM for the Brick IndustryCumulativeKilnNoBIA_IDFacNameCityStateTest Report Used toGenerate Em FactorBIA Notes on Em FactorGenerated by EPANotes on Test Reports Used to Generate Emission Factor665 BIA-010 Hanson - Ninety Six Ninety-Six SC7/11/1997 tk-3Cannot confirm production rate.Lb/hr numbers are confirmedNeeds full review704 Metropolitan Ceramics, Inc. Canton OH3/30/94 & 11/18/93?Cannot confirm but can get close onHF. BIA has no PM dataNeeds full review705 Metropolitan Ceramics, Inc. Canton OH0706 Metropolitan Ceramics, Inc. Canton OH0650 BIA-152 Hanson - Athens Athens TX0663 BIA-010 Hanson - Ninety Six Ninety-Six SC3/7/1997 tk-1 Straight from test report Needs full review570 BIA-108 Boral- Van Wyck Plants Van Wyck SC0695BIA-055Lee Brick Sanford FacilitySanford NC3/29/2005 Kiln 3 Straight from test reportAll runs were non-detects averaging only 1.5mg total weight. Minimumweight is 6.0 mg per NCASI.557 BIA-098 Boral- Marshall Plant Marshall TX1986 & 3/29/02HF is from average of the two tests.HCl was only available from 02 test.Need to confirm capacity versusproduction rate during test.Need full test to review530 BIA-004 Belden- Plant#6 Sugarcreek Sugarcreek OH11/93, 5/94, for HF,HCl and added in5/07 for PMEPA used average of first two testsfor HF and HCl, and averaged allthree for PM. Ohio EPA rejected5/07 test report due to port location.Without this, PM=4.06 lb/hr or 1.24lb/ton. EPA used the productionrates from first two tests only and didnot consider that 5/07 results werefor three kilns.Ohio EPA rejected test report dated 5/07 due to port location.549BIA-112Boral- Gleason PlantGleason TN11/4/1998 Straight from test report. Non-detects for PMAttachment 2. Review of Test Reports Used to GenerateEmission Factors for HF, HCl, and PM for the Brick IndustryCumulativeKilnNoBIA_IDFacNameCityStateTest Report Used toGenerate Em FactorBIA Notes on Em FactorGenerated by EPANotes on Test Reports Used to Generate Emission Factor559 BIA-106 Boral- Phenix City-Plant 3 Phenix City AL?Need to identify test report. Wehave 10/03/07 and 10/04/07 for No.1and No. 2 kilns (not sure of plant id)but only unctrld PM. Need to review.Need full test report to review808 BIA-076 Acme- Bridgeport Plant(BPP)Bridgeport TX5/21/2003Based on total emissions for batchas extrapolated from run datadivided by batch capacityNeed to review (Periodic)553 BIA-101 Boral- Lexington Plant Lexington SC1/23/1997 Straight from test report. Needs full review510 BIA-138 Acme- Eureka Plant (EBP) Clarksville AR3/4/1996EPA took the average of two testsperformed on the same day andused capacity of 4.98 instead of3.67tph as reported.Calc'd average using fluorides (13B) and HF(26A). 13B provides nospeciation of gaseous fluoride and should not be considered. (9/8/99 preproposal letter to EPA) Needfull test report to review535 BIA-006 Belden- Plant#9 Sugarcreek Sugarcreek OH5/4/01 & 5/94 &5/07(PM)EPA used average of first two testsfor HF and HCl, and averaged allthree for PM. Ohio EPA rejected5/07 test report due to port location.Without this, PM=2.03 lb/hr or .812lb/ton. EPA used the productionrates from first two tests only and didnot consider that 5/07 results werefor two kilnsOhio EPA rejected test report dated 5/07 due to port location. (EPArevised PM emission factor)670 BIA-021 Hanson - Stanton Stanton KY12/1/2004 straight from test report Needs full review669 BIA-021 Hanson - Stanton Stanton KY12/1/2004 straight from test report Needs full review710 BIA-143 Mutual Materials-Newcastle Renton WA4/22/1994Cannot confirm production rate.Lb/hr numbers are confirmedNeeds full reviewAttachment 2. Review of Test Reports Used to GenerateEmission Factors for HF, HCl, and PM for the Brick IndustryCumulativeKilnNoBIA_IDFacNameCityStateTest Report Used toGenerate Em FactorBIA Notes on Em FactorGenerated by EPANotes on Test Reports Used to Generate Emission Factor529 BIA-004 Belden- Plant#6 Sugarcreek Sugarcreek OH5/94 &5/01Kiln 2EPA used average of two testreports, but production rate from5/94. Average would be 3.63 sonumbers would be very close.Needs full review737 BIA-014 Redland- Cushwa Plant BrickKilnWilliamsport MD4/05 & 11/12/96 tk2brick unctrldAverage from two test reports. Needs full review521 BIA-089 Acme- Tulsa Plant (TUP) Tulsa OK9/6/2002HF and HCl lb/hr straight from testreport. Need to confirm productionrate. PM is from front half only.Teflon filter used. PM from front half only.515 BIA-087 Acme- Perla Plant(PEP/PWP)Malvern AR9/3/1996Straight from test report. Need toconfirm production rate during testNeeds full review528 BIA-004 Belden- Plant#6 Sugarcreek Sugarcreek OH5/30/2007Straight from test report. EPAdivided lb/hr number by 3. Need toconfirm production rate during testNeeds full review534 BIA-006 Belden- Plant#9 Sugarcreek Sugarcreek OH5/31/2007Divided test lb/hr by two for P101and P102. Production number okNeeds full review616BIA-071General Shale Brick-Plants 6& 28Atkins (Marion) VA?0617 BIA-071 General Shale Brick-Plants 6& 28Atkins (Marion) VA?0775 BIA-201 Whitacre Greer Alliance OH5/9/06 P004 Straight from test report Needs full review776 BIA-201 Whitacre Greer Alliance OH0