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 present the review of the second round of 

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

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

all test reports for 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 standards for the brick industry. This 

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

primary concerns in using certain test reports. BIA identified three overall groups of 

concern: 

Group 1: Tests that should be removed 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 additional review by EPA prior to consideration for 

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

methodology. 

Group 3: Tests that were incorrectly interpreted 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 reports were suspect, including 16 Group 1 

sources that should be immediately removed from the database. EPA reported an 

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

attached (Attachment 1). In general, BIA 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 discrepancy is provided in Attachment 1. 

BIA continues to support the exclusion of this report. 

The test reports for the remaining 42 sources 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 removed. Also of primary concern are the 

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

emissions. In the second round of review outlined below, BIA 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 focused 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 reports 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 identified 17 additional sources whose test 

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

(i.e. Group 1). These errors include the use 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 should be rejected due to inappropriate testing 

equipment and/or procedures include: 

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

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

degrees F 

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

filter temperatures 

 General Shale, Kiln 612, Test Date 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 Date 3/11/05 – Low probe and filter 

temperatures. 

o Test Date 10/25/05 – Glass 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 H2SO4 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 additional sources whose emission factors are based on nondetectable emissions. For PM, it is a generally accepted practice to collect a 

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

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

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

EPA to review these test reports, along with the 15 sources cited in the preliminary 

review document. 

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

include (please see June 5 memorandum 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 resulting in non-detectable levels. 

Group 3 

The emission factors for three sources were 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 misinterpreted as having two tests for one 

stack instead of simultaneous results from two 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 configuration of kiln 
Table 1. Round 2- Review Comments on Test Reports Used to Generate Emission Factors for HF, HCl, 

Parent_

Co FacName ST 

Maj_Ar

ea KilnID APCD_Type 

Test Report 

Used to 

Generate Em 

Factor 

Notes on Em Factor No

Boral Bricks Inc. 

BoralAtlanta Plant 

GA Major 

Source 

EU01 Dry 

Injection/Fabric Filter (DIFF) 

10/17/2006 EPA divided the results for two kilns PM is at detect

ripped filte

Boral Bricks Inc. 

BoralAtlanta Plant 

GA Major 

Source 

EU02 Dry 

Injection/Fabric Filter (DIFF) 

10/17/06, 

3/28/07, 2/15/07 

EPA used the per kiln result for 537 and averaged with two later tests. Used average production during tests. Without 2/15 report, factors are not significantly different, except HCl=.019 lb/ton 

3/28 test appea

MACT complia

received rip

REJECTED. Qu

should be used f

On 10/17 test, P

Correction: T

Boral Bricks Inc. 

BoralBessemer Plant #6 

AL Major 

Source 

003 Dry 

Injection/Fabric Filter (DIFF) 5/15/2007 

Straight from test 

report. Averaged 

between 2 kilns for 

one stack 

Test should be re

filter exit tempe

degrees 

Boral Bricks Inc. 

BoralBessemer Plant #6 

AL Major 

Source 

004 Dry 

Injection/Fabric Filter (DIFF) 

Test should be re

filter exit tempe

degrees 

Boral Bricks Inc. 

BoralGleason Plant 

TN Major 

Source 

ES02 Uncontrolled 

11/4/1998 Straight from test report. N

Boral Bricks Inc. 

BoralSalisbury Plant 

NC Major 

Source 

6BK Dry 

Injection/Fabric Filter (DIFF) 2/13/07 & 

7/20/07 Plant 6 

EPA averaged the two tests, but cannot confirm HCl. BIA data suggests HCl=.046 lb/ton. Plant 6 

For the 7/20/07 

detection l
Table 1. Round 2- Review Comments on Test Reports Used to Generate Emission Factors for HF, HCl, 

Parent_

Co FacName ST 

Maj_Ar

ea KilnID APCD_Type 

Test Report 

Used to 

Generate Em 

Factor 

Notes on Em Factor No

Boral Bricks Inc. 

BoralUnion City Plant 

OK Area 

Source (synthetic) 

EU02 Dry 

Injection/Fabric Filter (DIFF) 8/8/06, 5/24/06, 

3/14/07 

EPA averaged where possible. 

8/24 test shows N

Analytical data wa

cause of ND. EP

low probe tempe

showd low p

Cunningham Brick Company, Inc 

CunninghamThomasville 

NC Major 

Source 

tk-1 Uncontrolled 

4/22/97 tk-1 

Production rate during testing reported at 7.34 tons/hr. Lb/hr #s confirmed 

General Shale Brick, Inc 

General Shale BrickPlants 35 & 36 

VA Major 

Source 

tk-1 Dry Limestone 

Adsorber (DLA) 2/23/2005 Unit #5 EPA divided the results for two kilns. HF results from R

temperatures. E

General Shale Brick, Inc 

General ShaleMoncure Facility 

NC Major 

Source 

ES-K4 Dry Limestone 

Adsorber (DLA) 2/10/06 Kiln 4 Straight from test report 

Glen Gery 

Glen-Gery Corporation-Hanley 

PA Area 

Source (synthetic) 

SID - 113 

Wet Scrubber 

4/26/2005 Cannot confirm HCl . 

Teflon filter us

controlled. No a

revie

Lee Brick and Tile Co 

Lee Brick Sanford Facility 

NC Major 

Source 

ES-K2 Uncontrolled 

4/18/1997 Kiln 2 

Data was averaged and should have been added together since this kiln has two stacks. Resulting in HF emission of 0.96lb/ton. 

 Inappropriately us

HF (9/8/99 pre-

looks ok though 

available and 

Lee Brick and Tile Co 

Lee Brick Sanford Facility 

NC Major 

Source 

ES-K3 Other 

3/29/2005 Kiln 3 Straight from test report All runs were non

weight. Minim
Table 1. Round 2- Review Comments on Test Reports Used to Generate Emission Factors for HF, HCl, 

Parent_

Co FacName ST 

Maj_Ar

ea KilnID APCD_Type 

Test Report 

Used to 

Generate Em 

Factor 

Notes on Em Factor No

Lee Brick and Tile Co 

Lee Brick Sanford Facility 

NC Major 

Source 

ES-K4 Dry Limestone 

Adsorber (DLA) 4/25/2007 Kiln 4 Straight from test report Run 1 was 1.1 m

on PM is 6.0 mg (

mg. Without 3 v

Pine Hall Brick Co Inc 

Pine Hall Brick Co Inc 

GA Area 

Source (synthetic) 

tk-61 Dry Limestone 

Adsorber (DLA) 2/3/2004 Straight from test report Test results for HF 

us

Pine Hall Brick Co Inc 

Pine Hall Brick Co Inc 

GA Area 

Source (synthetic) 

tk-62 Dry Limestone 

Adsorber (DLA) 6/22/2005 

Straight from test report (Prod rate is slightly diff, but not significant) 

Test results for HF 

us

Pine Hall Brick Co, Inc 

Pine HallMadison Plant tk41 

NC Major 

Source 

tk-41 Dry Limestone 

Adsorber (DLA) 

11/1/2006 

Averaged between 

one run for two kilns 

and one run for one 

kiln to get lb/hr per 

kiln. When divided 

by per kiln tph em 

factors should be 

HF=.02lb/ton, 

HCl=.014, PM=.138. 

EPA divided by 2 

again. 

Needs more a

Preliminary not

incorrectly in te

higher than Kiln 1

11/3: HF error on 

should be .012 no

Pine Hall Brick Co, Inc 

Pine HallMadison Plant tk42 

NC Major 

Source 

tk-42 Dry Limestone 

Adsorber (DLA) 

Averaged between 

one run for two kilns 

and one run for one 

kiln to get lb/hr per 

kiln. When divided 

by per kiln tph em 

factors should be 

HF=.02lb/ton, 

HCl=.014, PM=.138. 

EPA divided by 2 

again. 
Table 1. Round 2- Review Comments on Test Reports Used to Generate Emission Factors for HF, HCl, 

Parent_

Co FacName ST 

Maj_Ar

ea KilnID APCD_Type 

Test Report 

Used to 

Generate Em 

Factor 

Notes on Em Factor No

Redland (Belden) Brick Company 

RedlandCushwa Plant Steel kiln 

MD 

Major Source 

tk-1- Steel kiln 

Dry Limestone Adsorber (DLA) 

5/10/2006 tk-1 

steel kiln 

Straight from test report. 

Confirmed prope

also suspect sin

degree F. Data m

Redland (Belden) Brick Company 

RedlandHarmar Plant 

PA Area 

Source (synthetic) 

NEW -Harmer 

Dry Injection/Fabric Filter (DIFF) 

3/5/02, 3/11/02, 

4/22/05 & 

10/25/05 

Averaged from test reports. Based on conversation with B. Miller at the plant, only the shale runs should be considered. Other runs were run at extreme feed conditions and are not indicative of normal operating cnditions. 

Did not review 3

normal operations

report from 3/11

probe and filter te

on all data, how

detectable amou

reportable limit wa

data from 10/25/0

operating proce

probe and filter te

J. L. Anderson Co., Inc 

Palmetto Brick 

SC Area 

Source (synthetic)-no survey 

tk-1 Dry Limestone 

Adsorber (DLA) 3/4/1999 EPA divided test result by two These results are 

HCl in H2S

J. L. Anderson Co., Inc 

Palmetto Brick 

SC Area 

Source (synthetic)-no survey 

tk-2 Dry Limestone 

Adsorber (DLA) EPA divided test result by two These results are 

HCl in H2S

Acme Brick Company 

AcmePerla Plant (PEP/PWP) 

AR Major 

Source 

tk-2 Uncontrolled 

10/12/1993 

Straight from test report. Used Fluorides as HF. Need to confirm production rate during test. 

Need full test repo

fluorides emiss

pro

Boral Bricks Inc. 

BoralMacon, MS Plant 

MS 

Major Source 

AA-001 Uncontrolled 

4/22/1999 

Straight from test report. Fluorides as HF. No 

Need full test repo

fluorides emiss

pro
Table 1. Round 2- Review Comments on Test Reports Used to Generate Emission Factors for HF, HCl, 

Parent_

Co FacName ST 

Maj_Ar

ea KilnID APCD_Type 

Test Report 

Used to 

Generate Em 

Factor 

Notes on Em Factor No

differentiation between total PM or front half. 

Acme Brick Company 

AcmeEureka Plant (EBP) 

AR Major 

Source 

tk-5 Uncontrolled 

3/4/1996 

EPA took the average of two tests performed on the same day and used capacity of 4.98 instead of 3.67tph as reported. 

Calc'd average u

13B provides no 

should not be con

to EPA) N

Hanson Brick East, LLC 

Hanson - Michigan 

MI Area 

Source (synthetic) 

tk-2 Dry 

Injection/Fabric Filter (DIFF) 6/7/1995 

EPA used an average based on two runs one of which was ND. Used fluoride emissions as HF 

Filter type not sp

Non-detects 

Inappropriately us

HF (9/8/99 

General Shale Brick, Inc 

General Shale BrickPlants 20, 32 & 43 

IN Major 

Source 

tk-1 Dry 

Injection/Fabric Filter (DIFF) 

11/1/2006 Kiln 

20 

EPA averaged 4 test runs. Plant excluded run 1 from reported avg. Avg from 3 runs HF=.00038, HCl=.146, and PM=.022. PM changed more because 1 run of the 4 reported 0 emissions. 

Filter type not spe

this kil

General Shale Brick, Inc 

General Shale BrickPlants 20, 32 & 43 

IN Major 

Source 

tk-2 Dry 

Injection/Fabric Filter (DIFF) 11/2/06 & 1/24/07 Kiln 32 

EPA averaged the two tests. EPA did not use production rate to calc lb/ton 

11/2/06 test shou

SO2 and proces

test conditions 

HCl=.0
Table 1. Round 2- Review Comments on Test Reports Used to Generate Emission Factors for HF, HCl, 

Parent_

Co FacName ST 

Maj_Ar

ea KilnID APCD_Type 

Test Report 

Used to 

Generate Em 

Factor 

Notes on Em Factor No

Hanson Brick East, LLC 

Hanson Mineral Wells 

TX Area 

Source (synthetic) 

tk-1 Dry 

Injection/Fabric Filter (DIFF) 

6/29/1993 Kiln 1 

Typo for PM for Kiln 

2. Should be 3.425 

lb/hr and 0.03lb/ton. 

Full design capacity 

was used by EPA. 

Test report suggests 

tests were at 76% 

capacity (13/17 cars) 

which only slightly 

changes numbers to 

HF=.000469 and 

PM=.59 for Kiln 1 

and HF=.00049 and 

PM=0.39 for Kiln 2 

Need an

Hanson Brick East, LLC 

Hanson Mineral Wells 

TX Area 

Source (synthetic) 

tk-2 Dry 

Injection/Fabric Filter (DIFF) 

6/29/1993 Kiln 2 

Typo for PM for Kiln 

2. Should be 3.425 

lb/hr and 0.03lb/ton. 

Full design capacity 

was used by EPA. 

Test report suggests 

tests were at 76% 

capacity (13/17 cars) 

which only slightly 

changes numbers to 

HF=.000469 and 

PM=.59 for Kiln 1 

and HF=.00049 and 

PM=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 report indicates that a quartz fiber 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 stack gas temperature never exceeded 280°F. 

Therefore, there is justification to remove the test results from 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 than 120°C (248°F)." The field data sheets (pages 60 to 62 of 

test report) indicate the "Box Temp" dropped below 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 results of the HF test should not be used. 

However, the above-noted problems should 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 from 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 referencing. The entry for this kiln in Table 1 of the 

BIA memo indicates for this test that the problems were "Non-detects present and high 

moisture." 

Page 23 of the test report indicates moisture 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 sampling 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 justification for disallowing the 

results of this test. 

EPA Action Taken

None. 

BIA Response

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

should be noted that this test report is still considered questionable 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 250°F" or there is not "sufficient QA/QC data 

to support the average temperature readings." 

EPA Response

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

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

the appendices show no entries for the "Filter Temp." 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) results 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 the database because the test data were rejected 

by the State of Ohio due to improper sampling point location. 

EPA Response

A review of the sampling location diagram indicates 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 flow disturbance, we concur that the test 

results should not be used. However, the results had not been used in developing the 

Lookup Table for the MACT Floor ranking because 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-rejected 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 original 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 the database because the test data were rejected 

by the State of Ohio due to improper sampling point location. 

EPA Response

A review of the sampling location diagram indicates 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 flow disturbance, we concur that the test 

results should not be used. 

EPA Action Taken

The HF and HCl emission factors for this kiln 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 revised PM emission factor was calculated after 

removing the results of this test. 

BIA Response

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

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

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

point since EPA is agreeing to remove 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/ton, 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 the database because the test data were rejected 

by the State of Ohio due because the proper filter 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. However, 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 there 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 determining that Run 1 failed the leak check. The 

Field Data Sheet for Run 1 shows hand-written 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 leakage 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 recommendation, then we disagree with their 

assessment. 

EPA Action Taken

None 

BIA Response

BIA concurs with the recalculated leak check values. 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 3mg 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 there 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 the other two runs (both of which were below 

the detection limit). 

EPA Response

The emission factor in the Lookup Table is the average of all 3 runs; the results from Run 1 

were not excluded, as claimed by BIA. In addition, 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, the ICR response from Acme states that the 

production rates for each of the kilns 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 excluded due to scrubber upset (see p A0009). 

Production rate of 8.84 came in a separate correspondence to BIA from Jason Pence (see 
insert labeled confidential). This production rate is not readily available in test report. It 

should be noted that data is still considered suspect due to non-detection limits. 
Attachment 2. Review of Test Reports Used to Generate Emission Factors for 

Cumulative 

Kiln 

No BIA_ID FacName City 

Sta

te 

Test Report Used to Generate Em Factor 

BIA Notes on Em Factor 

Generated by EPA 

604 BIA-070 General Shale Brick-Plant 38 Fairsdale KY 12/15/05 Kiln 38B Straight from test report 765 BIA-148 Taylor Clay Salisbury NC 

11/1/2007 ESK4 Straight from test report 

603 BIA-070 General Shale Brick-Plant 38 Fairsdale KY 

9/21/2001 Straight from test report 

567 BIA-208 Boral- Terre Haute Plant Terre Haute IN 8/919/08 Straight from test report. 558 BIA-104 Boral- Muskogee Plant Muskogee OK 

7/25/2007 

Straight from test report. 7/11 tewas engineering test, while 7/25 permit compliance. Both were submitted. HF would not changaveraged, but HCl would be .01 lb/ton and PM would be .089 lb/

675 BIA-019 Hanson Mineral Wells Mineral Wells TX 

6/29/1993 Kiln 1 

Typo for PM for Kiln 2. Should 

3.425 lb/hr and 0.03lb/ton. F

design capacity was used by E

Test report suggests tests wer

76% capacity (13/17 cars) wh

only slightly changes numbers 

HF=.000469 and PM=.59 for K

and HF=.00049 and PM=0.39 

Kiln 2 
Attachment 2. Review of Test Reports Used to Generate Emission Factors for 

Cumulative 

Kiln 

No BIA_ID FacName City 

Sta

te 

Test Report Used to Generate Em Factor 

BIA Notes on Em Factor 

Generated by EPA 

676 BIA-019 Hanson Mineral Wells Mineral Wells TX 6/29/1993 Kiln 2 609 BIA-072 General Shale Brick-Plants 

20, 32 & 43 

Mooresville IN 

11/1/2006 Kiln 20 

EPA averaged 4 test runs. Planexcluded run 1 from reported avAvg from 3 runs HF=.00038, HCl=.146, and PM=.022. PM changed more because 1 run of 4 reported 0 emissions. 

531 BIA-005 Belden- Plant #8 Sugarcreek Sugarcreek OH 

8/26/2003 (&8/23/05 

for PM) 

For HF and HCl, EPA took 8/2

result and divided for 3 kilns. 

PM, they added 8/26/03 and 8/2

results and divided by 6. With

8/26, PM would be 1.26 lb/hr a

using their prod rate 0.182 lb/t

EPA did not use engineering 

from 9/27/01 

532 BIA-005 Belden- Plant #8 Sugarcreek Sugarcreek OH 533 BIA-005 Belden- Plant #8 Sugarcreek Sugarcreek OH 653 BIA-018 Hanson – Elgin Elgin TX 

10/21/2007 tk-2 Straight from test report 

547 BIA-111 Boral- Bessemer Plant #6 Bessemer AL 5/15/2007 Straight from test report. Avera

between 2 kilns for one stac

548 BIA-111 Boral- Bessemer Plant #6 Bessemer AL 
Attachment 2. Review of Test Reports Used to Generate Emission Factors for 

Cumulative 

Kiln 

No BIA_ID FacName City 

Sta

te 

Test Report Used to Generate Em Factor 

BIA Notes on Em Factor 

Generated by EPA 

666 BIA-045 Hanson - Pleasant Garden Pleasant 

Garden 

NC 5/10/2006 straight from test report 

655 BIA-095 Hanson - Michigan Corunna MI 

6/7/1995 

EPA used an average based on runs one of which was ND. Usefluoride emissions as HF 

568 BIA-207 Boral- Union City Plant Union City OK 

8/8/06, 5/24/06, 

3/14/07 EPA averaged where possible. 

721 BIA-128 Pacific Coast-West Jordan West Jordan UT 10/31/1995 Straight from test report 502 BIA-077 Acme- Bennett Tunnel Plant 

(BTP) 

Millsap TX 

10/5/2005 & 6/5/97? 

EPA used average for HF and HNeed to confirm PM and producrate. Looks like EPA may have Front half PM emissions from 6/report instead of total. 

662 BIA-044 Hanson - Monroe Monroe NC 12/1/2006 Straight from test report 738 BIA-015 Redland- Harmar Plant Cheswick PA 

3/5/02, 3/11/02, 

4/22/05 & 10/25/05 Averaged from test reports 
Attachment 2. Review of Test Reports Used to Generate Emission Factors for 

Cumulative 

Kiln 

No BIA_ID FacName City 

Sta

te 

Test Report Used to Generate Em Factor 

BIA Notes on Em Factor 

Generated by EPA 

503 BIA-078 Acme- Denton Plant (DTP) Denton TX 

11/9/2005 

EPA used capacity of 9.98 wh

average throughput during test 

8.84tph. BIA estimates are 0.

lbHF/ton and .014 lbHCl/ton 

504 BIA-078 Acme- Denton Plant (DTP) Denton TX 505 BIA-078 Acme- Denton Plant (DTP) Denton TX 625 BIA-038 General Shale- Moncure 

Facility 

Moncure NC 2/10/06 Kiln 4 Straight from test report 

687 BIA-013 Jenkins- Montgomery Plant Montgomery AL 

6/5/2007 tk-2 

Straight from test report. Need confirm if DIFF is controlling two kilns to be able to consider 8/3 report. 8/3 report has suspect dfor HF, potentially usable data fHCl, but no PM or production da

696 BIA-055 Lee Brick Sanford Facility Sanford NC 

4/25/2007 Kiln 4 Straight from test report 

508 BIA-080 Acme- Elgin Plant 

(ELP/ENP) 

Elgin TX 3/15/2007 Straight from test report 

766 BIA-048 Triangle Brick- Merry Oaks 

Plant 

Merry Oaks NC 

4/20/06 & 8/10/06 

EPA average two tests and div

by 2 for Kiln 1 and Kiln 2 (com

DLA/stack) 

767 BIA-048 Triangle Brick- Merry Oaks 

Plant 

Merry Oaks NC 

768 BIA-048 Triangle Brick- Merry Oaks 

Plant 

Merry Oaks NC 5/4/2006 kiln 3 Straight from test report 
Attachment 2. Review of Test Reports Used to Generate Emission Factors for 

Cumulative 

Kiln 

No BIA_ID FacName City 

Sta

te 

Test Report Used to Generate Em Factor 

BIA Notes on Em Factor 

Generated by EPA 

612 BIA-073 General Shale Brick-Plants 

35 & 36 

Blue Ridge (Roanoke) 

VA 2/23/2005 Unit #5 EPA divided the results for two 

613 BIA-073 General Shale Brick-Plants 

35 & 36 

Blue Ridge (Roanoke) 

VA 

770 BIA-203 Triangle Brick- Wadesboro 

Plant 

Wadesboro NC 

3/1/2005 

Straight from test report. Need confirm if lb/ton numbers reporteand production rate to back into lb/hr. EPA and BIA lb/hr #'s maby this method, but then EPA ditruncated number by production and got slightly lower em factor. significant. 

769 BIA-203 Triangle Brick- Wadesboro 

Plant 

Wadesboro NC 3/14/2006 Straight from test report 

736 BIA-014 Redland- Cushwa Plant Steel 

kiln 

Williamsport MD 5/10/2006 tk-1 steel 

kiln Straight from test report. 

566 BIA-103 Boral- Salisbury Plant Salisbury NC 2/13/07 & 7/20/07 

Plant 6 

EPA averaged the two tests, bucannot confirm HCl. BIA data suggests HCl=.046 lb/ton. Plan

724 BIA-206 Pine Hall Brick Co Inc Fairmont GA 2/3/2004 Straight from test report 644 BIA-042 Glen-Gery CorporationMarseilles Marseilles IL 11/8/2006 Kiln A Straight from test report 692 BIA-092 Lawrenceville- Plant III Lawrenceville VA 9/2/2004 Kiln 4 Straight from test report 
Attachment 2. Review of Test Reports Used to Generate Emission Factors for 

Cumulative 

Kiln 

No BIA_ID FacName City 

Sta

te 

Test Report Used to Generate Em Factor 

BIA Notes on Em Factor 

Generated by EPA 

643 BIA-180 Glen-Gery CorporationHanley Summerville PA 4/26/2005 Cannot confirm HCl . 606 BIA-204 General Shale Brick-Plant 40 Coosa GA 7/18/2007 Straight from test report 506 BIA-163 Acme- Denver Plant (DVP) Castle Rock CO 

7/1998 & 8/13/03 

EPA averaged three tests for HF HCL. One run for HF and HCL 7/10 reported 0 values. Cannot confirm PM, but close. 

722 BIA-035 Palmetto Brick Wallace SC 3/4/1999 EPA divided test result by tw723 BIA-035 Palmetto Brick Wallace SC 729 BIA-011 Pine Hall- Madison Plant tk41 Madison NC 

11/1/2006 

Averaged between one run for 

kilns and one run for one kiln to 

lb/hr per kiln. When divided by 

kiln tph em factors should b

HF=.02lb/ton, HCl=.014, PM=.

EPA divided by 2 again. Em fawould not change significantly u

Eng report. HF=.017, HCl=.01

PM=.174. If use variability o

averages then UCL would b

HF=.058, HCl=.0323, PM=.30

730 BIA-011 Pine Hall- Madison Plant tk42 Madison NC 725 BIA-206 Pine Hall Brick Co Inc Fairmont GA 6/22/2005 Straight from test report (Prod r

is slightly diff, but not significant
Attachment 2. Review of Test Reports Used to Generate Emission Factors for 

Cumulative 

Kiln 

No BIA_ID FacName City 

Sta

te 

Test Report Used to Generate Em Factor 

BIA Notes on Em Factor 

Generated by EPA 

645 BIA-042 Glen-Gery CorporationMarseilles Marseilles IL 11/8/06 & 5/9/07 EPA averaged the two tests 691 BIA-092 Lawrenceville- Plant III Lawrenceville VA 10/20/06 Kiln 3 Straight from test report. PM fro

front half (filterable) 

647 BIA-179 Glen-Gery Corporation-Mid 

Atlantic 

Shoemakersville 

PA 10/10/07 - Harrop Straight from test report 

518 BIA-026 Acme- Texas Clay Plant 

(TCP) 

Malakoff TX 

3/26/2002 

HF and HCl lb/hr straight from tereport. Need to confirm productrate. PM is from front half only. 

514 BIA-085 Acme- Ouachita Plant (OEP) Malvern AR 3/27/2007 Straight from test report 542 BIA-096 Boral- Augusta Plants 3, 4, & 

5 

Augusta GA ? Cannot confirm em factors 

543 BIA-096 Boral- Augusta Plants 3, 4, & 

5 

Augusta GA 11/1/2006 Straight from test for Plant #5 

573 BIA-056 Carolina Ceramics Columbia SC 10/18/05 & 

12/12/2000 Kiln 3 

EPA averaged for HF, but HCl aPM only available on 12/12 test 

574 BIA-056 Carolina Ceramics Columbia SC 11/30/2005 Kiln 4 Straight from test report 610 BIA-072 General Shale Brick-Plants 

20, 32 & 43 

Mooresville IN 

11/2/06 & 1/24/07 

Kiln 32 

EPA averaged the two tests. EPdid not use production rate to calb/ton 

646 BIA-179 Glen-Gery Corporation-Mid 

Atlantic 

Shoemakersville 

PA 10/10/07 - Bickley Straight from test report 

527 BIA-002 Belden- Plant #3 Sugarcreek Sugarcreek OH 

8/24/05 & 5/1/01 

EPA used average from the two reports and capacity rather than production during test. Not 
Attachment 2. Review of Test Reports Used to Generate Emission Factors for 

Cumulative 

Kiln 

No BIA_ID FacName City 

Sta

te 

Test Report Used to Generate Em Factor 

BIA Notes on Em Factor 

Generated by EPA 

significant. 

641 BIA-177 Glen-Gery Corporation – 

Iberia 

Iberia OH 4/26/2006 Straight from test report 

673 BIA-009 Hanson Columbia - Plant 4 Columbia SC 

10/5/2006 

HF is straight from test repo

Cannot confirm HCl & PM exa

but it's very close. 

674 BIA-009 Hanson Columbia - Plant 4 Columbia SC 517 BIA-088 Acme- San Felipe (SFP) Sealy TX 

4/12/2006 

HCL is straight from test report. Cannot confirm HF or PM. Test report: HF=.076lb/ton and PM=.103lb/ton. EPA table lists 20.14 as prod rate, but calcs loolike the actual production rate of 21.08 tph was used. 

583 BIA-037 Columbus Brick Company Columbus MS 3/23/06 - kiln 3 Straight from test report 605 BIA-204 General Shale Brick-Plant 40 Coosa GA 7/19/07 & 2/26/08 EPA averaged the two tests. Ki526 BIA-188 Belden- Plant #2 Sugarcreek 

(P102) 

Sugarcreek OH 

1/17/06 &4/30/2001 

& 8/24/2005 (PM) 

HF & HCl lb/hr is average from an 4/30 test reports. PM is averfrom 4/30 and8/24. Cannot conproduction rate, though probably close. 

649 BIA-181 Glen-Gery Corporation-York York PA 10/09/07 - Kiln 2 Straight from test report 537 BIA-097 Boral- Atlanta Plant Smyrna GA 10/17/2006 EPA divided the results for two 
Attachment 2. Review of Test Reports Used to Generate Emission Factors for 

Cumulative 

Kiln 

No BIA_ID FacName City 

Sta

te 

Test Report Used to Generate Em Factor 

BIA Notes on Em Factor 

Generated by EPA 

740 BIA-016 Redland- KF Plant South Windsor CT ? 6 tests available. Cannot confir688 BIA-202 Jenkins-Jordan Plant Jordan AL 

4/18/08 & 2/21/08 

EPA averaged the two tests. Caconfirm production rate. EPA us26.46 and BIA shows avg of 32.

544 BIA-096 Boral- Augusta Plants 3, 4, & 

5 

Augusta GA ? Cannot confirm em factors 

577 BIA-093 Cherokee Brick & Tile Macon GA 

5/16/06, 12/13/06, 

2/28/07, 4/19/07 

Average of 4 test reports divide

2. PM and production rate aver

these 4 tests with 5/8/07 tes

578 BIA-093 Cherokee Brick & Tile Macon GA 812 BIA-081 Acme- Fort Smith Plant 

(FSP) 

Fort Smith AR 

12/10/2003 

Based on total emissions for baas extrapolated from run data divided by batch capacity 

741 BIA-099 Redland- Rocky Ridge Plant Rocky Ridge MD Aug-98 Straight from test report 622 BIA-038 General Shale- Moncure 

Facility 

Moncure NC 

? Cannot confirm em factors 

623 BIA-038 General Shale- Moncure 

Facility 

Moncure NC 

? 

614 BIA-073 General Shale Brick-Plants 

35 & 36 

Blue Ridge (Roanoke) 

VA 11/29/06, 5/20/08, 

8/22/07, 3/14/07 & 

7/15/08 

EPA averaged 5 test reports 
Attachment 2. Review of Test Reports Used to Generate Emission Factors for 

Cumulative 

Kiln 

No BIA_ID FacName City 

Sta

te 

Test Report Used to Generate Em Factor 

BIA Notes on Em Factor 

Generated by EPA 

601 BIA-067 General Shale Brick-Plant 10 Johnson City TN 

7/27/1993 

USEPA Test report. Straight frotest report. PM taken from Kiln Combustion Exhaust Multiple Mand Total Particulate Emissions

551 BIA-113 Boral- Henderson Facility Henderson TX 

3/02/95, 6/29/05, 2/14/96, 8/03/99, 8/01/01, 3/13/03, 

5/25/04 

Cannot confirm PM Em Facto

Checked front half numbers, bu

cannot confirm. EPA used ave

for HF from all tests and 8/01 

3/13/02 for HCL then divided b

First two tests are not listed a

having been submitted. 

552 BIA-113 Boral- Henderson Facility Henderson TX 538 BIA-097 Boral- Atlanta Plant Smyrna GA 

10/17/06, 3/28/07, 

2/15/07 

EPA used the per kiln result for and averaged with two later testUsed average production during tests. Without 2/15 report, factoare not significantly different, exHCl=.019lb/ton 

720 BIA-128 Pacific Coast-West Jordan West Jordan UT 12/5/1994 Straight from test report 598 BIA-116 Endicott Clay Products Fairbury NE 7/6/1993 Straight from test report 763 BIA-148 Taylor Clay Salisbury NC 7/11/2000 Straight from test report for lb/h

Cannot confirm production ra

764 BIA-148 Taylor Clay Salisbury NC 753 BIA-031 Statesville Brick Statesville NC 5/15/1997 Straight from test report 
Attachment 2. Review of Test Reports Used to Generate Emission Factors for 

Cumulative 

Kiln 

No BIA_ID FacName City 

Sta

te 

Test Report Used to Generate Em Factor 

BIA Notes on Em Factor 

Generated by EPA 

516 BIA-087 Acme- Perla Plant 

(PEP/PWP) 

Malvern AR 

10/12/1993 

Straight from test report. Used Fluorides as HF. Need to confirproduction rate during test. 

539 BIA-102 Boral- Augusta Plant 6 Augusta GA 

1991 

Straight from test report, but neeconfirm production rate during testing. 

571 BIA-120 Bowerston- Bowerston Plant Bowerston OH 11/16/2000 & 9/27/07 

(HF) 

EPA averaged two tests for HF used single data from 11/16 for Cannot confirm production rate. 

555 BIA-110 Boral- Macon, MS Plant Macon MS 

4/22/1999 

Straight from test report. Fluoridas HF. No differentiation betwtotal PM or front half. 

569 BIA-108 Boral- Van Wyck Plants Van Wyck SC 

1997 

Straight from test but need 

confirmation on capacity vers

production. Need to confirm P

B=tk-1 and Kiln #3=tk2 

731 BIA-011 Pine Hall- Madison Plant tk51 Madison NC 3/3/98 & 3/6/98 Average from two test report804 BIA-075 Acme- Bennett Plant (BEP) Millsap TX 2/12/2003 Cannot confirm, but can get clos591 BIA-053 Cunningham- Thomasville Thomasville NC 4/22/97 tk-1 Need to confirm capacity versus production rate. Lb/hr #s confirm565 BIA-103 Boral- Salisbury Plant Salisbury NC 9/8/2005 Plant 5 EPA used kiln exhaust data and excluded SD dryer. 694 BIA-055 Lee Brick Sanford Facility Sanford NC 

4/18/1997 Kiln 2 Straight from test report 
Attachment 2. Review of Test Reports Used to Generate Emission Factors for 

Cumulative 

Kiln 

No BIA_ID FacName City 

Sta

te 

Test Report Used to Generate Em Factor 

BIA Notes on Em Factor 

Generated by EPA 

665 BIA-010 Hanson - Ninety Six Ninety-Six SC 7/11/1997 tk-3 Cannot confirm production rate. Lb/hr numbers are confirmed 704 Metropolitan Ceramics, Inc. Canton OH 3/30/94 & 11/18/93? Cannot confirm but can get clos

HF. BIA has no PM data 

705 Metropolitan Ceramics, Inc. Canton OH 706 Metropolitan Ceramics, Inc. Canton OH 650 BIA-152 Hanson - Athens Athens TX 663 BIA-010 Hanson - Ninety Six Ninety-Six SC 3/7/1997 tk-1 Straight from test report 570 BIA-108 Boral- Van Wyck Plants Van Wyck SC 695 BIA-055 Lee Brick Sanford Facility Sanford NC 3/29/2005 Kiln 3 Straight from test report 557 BIA-098 Boral- Marshall Plant Marshall TX 

1986 & 3/29/02 

HF is from average of the two teHCl was only available from 02 Need to confirm capacity versus production rate during test. 

530 BIA-004 Belden- Plant #6 Sugarcreek Sugarcreek OH 

11/93, 5/94, for HF, 

HCl and added in 

5/07 for PM 

EPA used average of first two tefor HF and HCl, and averaged athree for PM. Ohio EPA rejecte5/07 test report due to port locatWithout this, PM=4.06 lb/hr or 1lb/ton. EPA used the production rates from first two tests only annot consider that 5/07 results wefor three kilns. 

549 BIA-112 Boral- Gleason Plant Gleason TN 11/4/1998 Straight from test report. 
Attachment 2. Review of Test Reports Used to Generate Emission Factors for 

Cumulative 

Kiln 

No BIA_ID FacName City 

Sta

te 

Test Report Used to Generate Em Factor 

BIA Notes on Em Factor 

Generated by EPA 

559 BIA-106 Boral- Phenix City-Plant 3 Phenix City AL 

? 

Need to identify test report. We have 10/03/07 and 10/04/07 for and No. 2 kilns (not sure of planbut only unctrld PM. Need to re

808 BIA-076 Acme- Bridgeport Plant 

(BPP) 

Bridgeport TX 

5/21/2003 

Based on total emissions for baas extrapolated from run data divided by batch capacity 

553 BIA-101 Boral- Lexington Plant Lexington SC 1/23/1997 Straight from test report. 510 BIA-138 Acme- Eureka Plant (EBP) Clarksville AR 

3/4/1996 

EPA took the average of two tesperformed on the same day and used capacity of 4.98 instead of 3.67tph as reported. 

535 BIA-006 Belden- Plant #9 Sugarcreek Sugarcreek OH 

5/4/01 & 5/94 & 

5/07(PM) 

EPA used average of first two tefor HF and HCl, and averaged athree for PM. Ohio EPA rejecte5/07 test report due to port locatWithout this, PM=2.03 lb/hr or .8lb/ton. EPA used the production rates from first two tests only annot consider that 5/07 results wefor two kilns 

670 BIA-021 Hanson - Stanton Stanton KY 12/1/2004 straight from test report 669 BIA-021 Hanson - Stanton Stanton KY 12/1/2004 straight from test report 710 BIA-143 Mutual Materials-Newcastle Renton WA 4/22/1994 Cannot confirm production rate. Lb/hr numbers are confirmed 
Attachment 2. Review of Test Reports Used to Generate Emission Factors for 

Cumulative 

Kiln 

No BIA_ID FacName City 

Sta

te 

Test Report Used to Generate Em Factor 

BIA Notes on Em Factor 

Generated by EPA 

529 BIA-004 Belden- Plant #6 Sugarcreek Sugarcreek OH 

5/94 &5/01Kiln 2 

EPA used average of two test reports, but production rate from 5/94. Average would be 3.63 so numbers would be very close. 

737 BIA-014 Redland- Cushwa Plant Brick 

Kiln 

Williamsport MD 4/05 & 11/12/96 tk2 

brick unctrld Average from two test reports. 

521 BIA-089 Acme- Tulsa Plant (TUP) Tulsa OK 

9/6/2002 

HF and HCl lb/hr straight from tereport. Need to confirm productrate. PM is from front half only. 

515 BIA-087 Acme- Perla Plant 

(PEP/PWP) 

Malvern AR 9/3/1996 Straight from test report. Need 

confirm production rate during te

528 BIA-004 Belden- Plant #6 Sugarcreek Sugarcreek OH 

5/30/2007 

Straight from test report. EPA divided lb/hr number by 3. Need confirm production rate during te

534 BIA-006 Belden- Plant #9 Sugarcreek Sugarcreek OH 5/31/2007 Divided test lb/hr by two for P10

and P102. Production number o

616 BIA-071 General Shale Brick-Plants 6 

& 28 

Atkins (Marion) VA ? 

617 BIA-071 General Shale Brick-Plants 6 

& 28 

Atkins (Marion) VA ? 

775 BIA-201 Whitacre Greer Alliance OH 

5/9/06 P004 Straight from test report 

776 BIA-201 Whitacre Greer Alliance OH