EXAMPLE CALCULATIONS FOR THE REFRACTORY PRODUCTS NESHAP

**Introduction**

The national emissions standards for hazardous air pollutants (NESHAP)
for manufacturers of refractory products were finalized on April 16,
2003 (Federal Register Volume 68, Number 73, pages 18730 to 18785). To
determine if you are subject to these standards, you must determine if
you are a major source of hazardous air pollutants (HAP) emissions. If
you are subject to these standards, you must meet the testing
requirements included in the rule. Determining the applicability of the
standards to your facility and following the testing procedures in the
rule requires that you perform complex calculations. To assist you in
these calculations, we have developed example calculations that you may
use as guidance.

The example calculations in this document are presented in three
sections. Section I provides example calculations that demonstrate how
to determine whether your source is a major source of HAP and therefore
subject to the rule. Section II provides example calculations for
demonstrating compliance and establishing operating limits using
performance test data for facilities manufacturing refractory products
containing organic HAP. Section III provides example calculations for
demonstrating compliance and establishing operating limits using
performance test data for facilities manufacturing clay refractory
products. Both Sections II and III also include example calculations
that are specific to the testing of batch processes.

I.  **Example Calculations for Determining Total HAP Emissions**

If you emit, or have the potential to emit, 10 tons per year (tons/yr)
of any one HAP or 25 tons/yr of any combination of HAP then you will be
subject to the emission limits and work practice standards included in
the rule. Determining the total HAP emissions for your facility is the
first step in determining whether or not you will be subject to the
standard. For this purpose, we have provided some example calculations
for manufacturers of refractory products containing organic HAP and clay
refractory products. Although it is not possible to provide example
calculations that cover every possible scenario, we have tried to
provide several examples that we believe cover the most common
situations that exist within the industry.

In developing the NESHAP for the refractory products manufacturing
industry, EPA collected test data from refractory products manufacturing
facilities. EPA used these test data to develop uncontrolled HAP
emission factors for the industry. These emission factors, presented in
Table 1, represent EPA's best estimate based on the data available to
them. However, differences in the types of products manufactured, the
additives used in those products, and process parameters such as curing
time and temperature can all impact the amount of HAP emitted from a
particular facility. Therefore, to determine the most representative
estimates of HAP emissions from your facility, you should use the
results of emission tests performed on your sources. In the absence of
such site-specific test data, the uncontrolled HAP emission factors
contained in Table 1 can be used in calculating your actual and
potential emissions.

These emission factors reflect the amount of a particular pollutant that
is actually emitted as a factor of the amount of the pollutant that is
used or processed. For example, the emission factor for phenol for the
curing and firing of resin-bonded products is 290 pounds per ton
(lbs/ton) of phenol. This means that for every ton of phenol that is
processed or used, 290 pounds is actually emitted.

**Table 1. Summary of Uncontrolled HAP Emission Factors for**

**Refractory Products Manufacturing Sources**

  ------------------------------------------------------------------------------------
  Product type        Process/source^a^   Pollutant       Emission   Units
                                                          factor     
  ------------------- ------------------- --------------- ---------- -----------------
  Resin-bonded        Curing and          Phenol          290        lbs/ton of phenol
                      firing^b^                                      

                                          Formaldehyde    790        lbs/ton of
                                                                     formaldehyde

                                          Methanol        2,000      lbs/ton of
                                                                     methanol

                                          Ethylene glycol 280        lbs/ton of
                                                                     ethylene glycol

  Pitch-impregnated   Coking oven         POM             860        lbs/ton of pitch

                      Defumer             POM             2.3        lbs/ton of pitch

                      Working tank        POM             0.25       lbs/ton of pitch

                      Main pitch storage  POM             0.030      lbs/ton of pitch
                      tank                                           

                      Shape preheater     POM             0.33       lbs/ton of pitch

  Pitch-bonded        Entire process line POM             860        lbs/ton of pitch

                      Heated mixer        POM             3.9        lbs/ton of pitch

                      Main pitch storage  POM             0.030      lbs/ton of pitch
                      tank                                           

  Other products that Dryer               Phenol          290        lbs/ton of phenol
  contain organic HAP                                                

                                          Formaldehyde    790        lbs/ton of
                                                                     formaldehyde

                                          Methanol        2,000      lbs/ton of
                                                                     methanol

                                          Ethylene glycol 280        lbs/ton of
                                                                     ethylene glycol

  Chromium            Kiln^c^             Chromium        0.21       lbs Cr~2~O~3~/ton
                                          compounds as               Cr~2~O~3~
                                          Cr~2~O~3~                  

                                          Cr^+6^          0.0090     lbs Cr^+6^/ton
                                                                     Cr~2~O~3~

  Clay                Kiln                HF              0.38       lbs/ton clay

                                          HCl             0.26       lbs/ton clay

                      Calciner            HF              0.19       lbs/ton clay

                                          HCl             0.13       lbs/ton clay

                      Calciner (with      HF              0.0019     lbs/ton clay
                      venturi scrubber)                              

                                          HCl             0.0013     lbs/ton clay
  ------------------------------------------------------------------------------------

^a^ Emission factors are for uncontrolled emissions unless noted.

^b^ Factors apply to entire process line, including those which consist
of curing only and those which consist of curing and firing.

^c^ Emission factors are in units of pounds of pollutant per tons of
chromium oxide (Cr~2~O~3~); Cr^+6^ = hexavalent chromium.

Part A of this section includes a general discussion concerning actual
and potential emissions. Example calculations for facilities
manufacturing refractory products containing organic HAP are presented
in Part B. Examples for facilities manufacturing clay refractory
products are presented in Part C.

## Actual Emissions Versus Potential Emissions

The first step in determining if your facility is a major source of HAP,
and is therefore subject to the standard, is to calculate your actual
emissions. Calculating your facility's actual emissions is a relatively
straightforward process. Actual emissions from a facility manufacturing
refractory products containing organic HAP are a function of the HAP
content of the refractory products and the production rate of those
products. For clay refractory products, HAP emissions are a function of
the percentage of uncalcined clay in the refractory products and the
production rate of those products. The example calculations presented in
Parts B and C of this section provide guidelines for determining your
actual emissions.

If the actual HAP emissions for your facility are greater than 25
tons/yr (or 10 tons/yr of any one HAP), then you will be subject to the
standard. However, even if your actual emissions are less than 10/25
tons/yr, you may still be subject to the standard if your potential
emissions are greater than 10/25 tons/yr. Therefore, the second step for
facilities with actual emissions less than 10/25 tons/yr is to determine
your potential emissions to evaluate whether or not you are subject to
the standard.

The definition of potential to emit is as follows:

*"[Potential to emit]{.underline} means the maximum capacity of a
stationary source to emit a pollutant under its physical and operational
design. Any physical or operational limitation on the capacity of the
stationary source to emit a pollutant, including air pollution control
equipment and restrictions on hours of operation or on the type or
amount of material combusted, stored, or processed, shall be treated as
part of its design if the limitation or the effect it would have on
emissions is federally enforceable."*

If your facility manufactures refractory products containing organic
HAP, your potential emissions would be based on the maximum production
rate for the facility at 8,760 hours/yr (24 hours/day x 365 days/yr),
unless there is some physical or operational limit on the design or
operation of your facility that prevents you from operating that many
hours. For example, you may not be able to operate a kiln or other piece
of equipment over that many hours because it would have to undergo
maintenance a few weeks a year in order to operate properly. In that
case, your maximum production could be based on something less than
8,760 hours/yr.

You would also have to assume that you were manufacturing the refractory
product with the highest organic HAP processing rate for that 8,760
hours. If your facility manufactures clay refractory products, your
potential emissions would be based on the maximum production rate for
the facility at 8,760 hours/yr. You would also have to assume that you
were manufacturing the product with the highest percentage of uncalcined
clay for those 8,760 hours.

However, you can limit your potential to emit by agreeing to Federally
enforceable limitations on your operations. Typically, these limitations
would be included in your permit. For example, your facility may only
operate 5,000 hours/yr. If you agree to limit your facility's annual
operating time to 5,000 hours in your permit, your emissions would be
based on your production at 5,000 hours/yr. On the other hand, if you
only manufacture limited quantities of your highest emitting refractory
product because there is no market for larger quantities, you could
agree in your permit to limit your production of that product. In that
case, your potential to emit would be based on that production limit.

There are a number of options for facilities that have actual emissions
less than 10/25 tons/yr and potential emissions greater than 10/25
tons/yr. The examples presented in Parts B and C of this section attempt
to address some of these options.

## Example Emissions Calculations for Facilities Manufacturing Products Containing Organic HAP

This part presents example calculations that facilities manufacturing
products containing organic HAP may find useful in determining their
major source status with respect to HAP emissions.

######### Example 1: Calculation of Actual HAP Emissions from Resin-Bonded Refractory Production

The facility manufactures three types of resin-bonded products. The
composition and production rate for each of these products is described
below.

-   Resin-bonded product 1: The resin used in this product contains 10
    percent phenol and the product mix contains 8 percent resin. The
    facility manufactures 6,000 tons of the product per year.

-   Resin-bonded product 2: The resin used in this product contains 9
    percent phenol, 20 percent ethylene glycol, and 5 percent methanol.
    The product mix contains 6 percent resin. The facility manufactures
    11,000 tons of the product per year.

-   Resin-bonded product 3: The resin used in this product contains 6
    percent phenol. The product mix contains 5 percent resin. The
    facility manufactures 3,000 tons of the product per year.

The first step in calculating actual emissions is to determine the
annual organic HAP processing rate for each individual HAP in each
product. Although the annual organic HAP processing rate only represents
the amount of that HAP used or the amount of that HAP contained in the
products manufactured during the year, the facility's actual emissions
of that HAP are based on that value.

[Resin-bonded product 1]{.underline}

The only HAP in this product is phenol. The annual organic HAP
processing rate for phenol is:

6,000 tons x 10/100 x 8/100 = 48 tons phenol/yr

[Resin-bonded product 2]{.underline}

This product contains phenol, ethylene glycol and methanol. The annual
organic HAP processing rates are as follows:

11,000 x 9/100 x 6/100 = 59.4 tons phenol/yr

11,000 x 20/100 x 6/100 = 132 tons ethylene glycol/yr

11,000 x 5/100 x 6/100 = 33 tons methanol/yr

[Resin-bonded product 3]{.underline}

This product also contains only phenol. The annual organic HAP
processing rate for phenol is:

3,000 tons x 6/100 x 5/100 = 9 tons phenol/yr

Only a percentage of the HAP that is processed by the facility is
actually emitted. As shown in Table 1, EPA developed emission factors
for the industry to use in calculating actual HAP emissions. The
emission factors for phenol, ethylene glycol, and methanol used in
resin-bonded products are as follows:

-   Phenol -- 290 lbs/ton of phenol = 14.5 percent of phenol emitted

-   Ethylene glycol -- 280 lbs/ton of ethylene glycol = 14 percent of
    ethylene glycol emitted

-   Methanol -- 2,000 lbs/ton of methanol = 100 percent of methanol
    emitted

Using the annual organic HAP processing rates calculated above and the
emission factors from Table 1, we can calculate total actual emissions
of each HAP.

[Phenol]{.underline}

(48 tons + 59.4 tons + 9 tons) x 14.5/100 = 16.9 tons of phenol

[Ethylene glycol]{.underline}

132 tons x 14/100 = 18.5 tons of ethylene glycol

[Methanol]{.underline}

33 tons x 100/100 = 33 tons of methanol

Total HAP emissions = 68.4 tons

Because the facility's actual HAP emissions are greater than 10/25
tons/yr, there is no need to calculate the facility's potential
emissions. The facility is a major source of HAP based on its actual
emissions and therefore will be subject to the standard.

######### Example 2: Calculation of Actual HAP Emissions from Pitch-Bonded Refractory Production

The facility manufactures two types of pitch-bonded products. The
composition and production rate for both of these products are described
below.

-   Pitch-bonded product 1: The product mix contains 8 percent pitch.
    The facility manufactures 15,000 tons of the product per year.

-   Pitch-bonded product 2: The product mix contains 7 percent pitch.
    The facility manufactures 10,000 tons of the product per year.

The first step in calculating actual emissions is to determine the
annual organic HAP processing rate for polycyclic organic matter (POM)
for each product. Pitch is considered to be 100 percent POM.

[Pitch-bonded product 1]{.underline}

15,000 tons x 8/100 = 1,200 tons of POM

[Pitch-bonded product 2]{.underline}

10,000 tons x 7/100 = 700 tons of POM

Based on EPA's emission factors, 860 pounds of POM are emitted for every
2,000 pounds that are processed, that is, 43 percent of the POM is
emitted. Therefore, total POM emissions for the facility can be
calculated as follows:

(1,200 tons + 700 tons) x 43/100 = 817 tons of POM

> Because the facility's actual POM emissions are more than 10 tons/yr,
> the facility does not have to determine its potential emissions. The
> facility is a major source based on its actual emissions and is
> therefore subject to the standard.

######### Example 3: Calculation of Actual HAP Emissions from Pitch-Impregnated Refractory Production

The facility manufactures 1 type of pitch-impregnated product. The
product contains 10 percent pitch. The facility produces 23,000 tons of
the product per year. The annual organic HAP processing rate for POM for
the product is:

23,000 tons x 10/100 = 2,300 tons of POM

Based on the emission factors developed by EPA, the coking oven is the
primary source of POM emissions for the manufacture of pitch-impregnated
products. The emission factor for the coking oven is 860 lbs of POM
emitted per ton of pitch used. Therefore, 43 percent of the POM used is
emitted in the coking oven.

2,300 tons x 43/100 = 989 tons POM

POM is also emitted in small quantities from the defumer, working tank,
main pitch storage tank, and shape preheater. However, based on EPA's
emission factors, these sources represent less than 1 percent of the
total emissions. For example, emissions from the defumer and shape
preheater are 2.3 and 0.33 lbs POM/ton of pitch, respectively. For this
example, POM emissions from these sources would be negligible.

2.3/2,000 = 0.12 percent of pitch is emitted from the defumer

0.33/2,000 = 0.017 percent of pitch is emitted from the shape preheater

Total emissions from the defumer and preheater are as follows:

2,300 tons x 0.12/100 = 2.8 tons POM from the defumer

2,300 tons x 0.017/100 = 0.4 tons POM from the preheater

Emissions from the working tank and main pitch storage tank are based on
the amount of pitch filled or added to the tank. EPA's emission factor
for the working tank is 0.25 lb POM/ton of pitch (0.013 percent). The
emission factor for the main pitch storage tank is 0.03 lb POM/ton of
pitch (0.0015 percent). Assuming for this example that the amount filled
or added to these tanks is equivalent to the annual processing rate,
that is, 2,300 tons, POM emissions from these tanks can be calculated as
follows:

2,300 x 0.013/100 = 0.3 tons POM from the working tank

2,300 x 0.0015/100 = 0.03 tons POM from the main storage tank

Total POM emissions from the coking oven, defumer, preheater, working
tank, and main storage tank are:

989 tons + 2.8 tons + 0.4 tons + 0.3 tons + 0.03 tons = 992.5 tons

It is obvious from this example that if you are only interested in
calculating your actual emissions to determine if you are a major
source, it may well be sufficient to only calculate the emissions from
the coking oven. However, you may be required to calculate your
emissions from the other smaller emission sources for your permit so we
have included those calculations here as an example.

######### Example 4: Calculation of Potential HAP Emissions from Resin-Bonded Refractory Production

The facility manufactures 1 type of resin-bonded product. The resin
contains 12 percent phenol and the refractory product mix contains 6
percent resin. The facility manufactures 6,000 tons of product per year.

The annual organic HAP processing rate for phenol can be calculated as
follows:

6,000 tons x 12/100 x 6/100 = 43.2 tons of phenol

The EPA emission factor for phenol is 290 pounds/ton of phenol
processed, or 14.5 percent. Therefore, total emissions of phenol are:

43.2 tons x 14.5/100 = 6.3 tons of phenol

The facility's actual emissions of phenol are less than 10 tons/yr and
the facility does not emit any other HAP. However, the facility may
still be a major source based on its potential emissions. The facility
only operates 4,500 hours/yr, although the facility's potential
emissions are based on 8,760 hours/yr. Therefore, the facility's
potential emissions can be calculated as follows:

6.3 tons x 8,760/4,500 = 12.3 tons phenol/yr

In this case, the facility has two options. The facility may choose to
include a limit on its operating hours in its permit that will restrict
its potential emissions to less than 10 tons/year of phenol. Or the
facility may determine that it does not want to agree to a limit on its
operating hours because it would like to increase production in the near
future. In that case, the facility would be considered a major source
and would be subject to the requirements of the standard.

######### Example 5: Calculation of Potential HAP Emissions from Resin-Bonded Refractory Production

The facility manufactures both a resin-bonded refractory product and
another type of refractory product that contains no organic HAP. Both
products are manufactured using the same equipment. When operating 8,760
hours/yr, the facility manufactures 5,000 tons of the resin-bonded
product per year and 20,000 tons of the refractory product that contains
no organic HAP.

The resin used in the resin-bonded product contains 8 percent phenol and
the refractory product mix contains 5 percent resin. The annual organic
HAP processing rate for phenol is:

5,000 tons x 8/100 x 5/100 = 20 tons of phenol

The EPA emission factor for phenol for resin-bonded products is 290
lbs/ton of phenol or 14.5 percent. Therefore, total actual phenol
emissions are:

20 tons x 14.5/100 = 2.9 tons of phenol/yr

This is well below the major source emission rate of 10 tons/yr, but
because the facility uses the same equipment to manufacture both types
of refractory products, and the production rate is the same for both
types of products, the facility's potential emissions are based on the
total production of 25,000 tons/yr of the resin-bonded product. At this
production rate, the annual organic HAP processing rate for phenol is:

25,000 tons x 8/100 x 5/100 = 100 tons of phenol

Total potential phenol emissions are:

100 tons x 14.5/100 = 14.5 tons of phenol/yr

In this case, the facility's potential emissions of phenol are greater
than 10 tons/yr, so the facility could be considered a major source.

However, the resin-bonded product is a specialty product that has a
limited market. The facility would never make 25,000 tons of the
specialty resin-bonded product because there is no market for that much
product.

Because the facility will never need to produce 25,000 tons of the
specialty resin-bonded product, its best option to avoid being subject
to the standard is to agree to a production limit for the resin-bonded
specialty product. The production limit on the resin-bonded product will
ensure that phenol emissions from the facility never exceed 10
tons/year.

######### Example 6: Calculation of Actual HAP Emissions from Pitch-Bonded Refractory Production

The facility has two processing lines. Both lines are used to
manufacture pitch-bonded refractory products. Line 1 is an older line
that is uncontrolled. However, when the facility installed the second
line the permitting authority required the facility to install a thermal
oxidizer to control emissions from that line. The facility must
calculate the total emissions for the facility based on the emissions
from both lines.

*[Line 1 (no control)]{.underline}*

On this line, the facility manufactures a pitch-bonded product that
contains 8 percent pitch. Total production for the product is 10,000
tons/yr. The annual organic HAP processing rate for POM can be
calculated as follows:

10,000 x 8/100 = 800 tons of POM

The EPA emission factor for POM for pitch-bonded products is 860 lbs/ton
of pitch or 43 percent. Therefore, total POM emissions for Line 1 are:

800 tons x 43/100 = 344 tons POM/yr

*[Line 2 (with thermal oxidizer)]{.underline}*

On this line, the facility manufactures a pitch-bonded product that
contains 5 percent pitch. Total production is 8,000 tons/yr. The annual
organic HAP processing rate for POM can be calculated as follows:

8,000 x 5/100 = 400 tons of POM

The EPA emission factor for POM for pitch-bonded products is 860 lbs/ton
of pitch or 43 percent. Therefore, total uncontrolled emissions for Line
2 are:

400 tons x 43/100 = 172 tons of POM

The facility has conducted performance tests on the thermal oxidizer
controlling Line 2 and determined that the oxidizer achieves 95 percent
control efficiency. Total emissions after control for Line 2 are:

172 -- (172 x 0.95) = 8.6 tons POM/yr

Even though the total POM emissions from Line 2 are less than 10 tons of
POM/yr, the facility is still a major source of HAP because emissions
from Line 1 are uncontrolled and total POM emissions for the facility
are 352.6 tons/yr. Therefore, the facility will be subject to the
standard.

######### Example 7: Calculation of Potential HAP Emissions from Resin-Bonded Refractory Production -- Batch Process Sources

The facility manufactures 1 type of resin-bonded refractory product
using a batch process. Total production is 5,500 tons/yr while operating
3,750 hours. The refractory product contains 7.6 percent resin and the
resin contains 6.9 percent phenol. The annual organic HAP processing
rate for phenol is:

5,500 tons x 7.6/100 x 6.9/100 = 28.8 tons phenol/yr

Based on EPA's emission factors, only 14.5 percent of the phenol that is
processed is actually emitted. Therefore, actual emissions for the
facility are:

28.8 x 14.5/100 = 4.2 tons phenol/yr

If the facility operated 8,760 hours/yr, it could potentially produce
12,848 tons of refractory product per year. However, the capacity of
each of the facility's two ovens is only 12 tons and the cycle time for
each oven is 21 hours. Therefore, the maximum number of cycles for each
oven is 417 cycles/yr (8,760/21). At a capacity of 12 tons/cycle, the
annual capacity for each oven is only 5,004 tons/yr or a total capacity
for the two ovens of 10,008 tons/yr.

Because of both the operational and physical design limits associated
with the oven cycle time and capacity, the facility's maximum production
is only 10,008 tons/yr. Therefore, the facility's potential emissions
are based on a production of 10,008 tons/yr, not 12,844 tons/yr.

The potential annual organic HAP processing rate for phenol is:

10,008 tons x 7.6/100 x 6.9/100 = 52.5 tons phenol/yr

The facility's potential emissions are:

52.5 x 14.5/100 = 7.6 tons phenol/yr

Both the facility's actual and potential emissions are less than 10/25
tons/yr so the facility is not a major source and not subject to the
standard.

## Example Calculations for Facilities Manufacturing Clay Refractory Products

This part contains example emissions calculations for facilities
manufacturing clay refractory products. The examples should be useful to
clay refractory products manufacturers performing emissions calculations
to determine the applicability of the standard to their operations.

######### Example 1: Calculation of Actual HAP Emissions from Clay Refractory Production

The facility manufactures two types of clay refractory products. Clay
refractory product 1 contains 80 percent uncalcined clay and clay
refractory product 2 contains 70 percent uncalcined clay. The facility
manufactures 50,000 tons of clay refractory product 1 and 40,000 tons of
clay refractory product 2.

The first step in calculating the facility's emissions is to calculate
the annual processing rate of uncalcined clay for each product. For
product 1, the uncalcined clay annual processing rate can be calculated
as follows:

50,000 tons x 80/100 = 40,000 tons of uncalcined clay/yr

For product 2, the annual processing rate for uncalcined clay is:

40,000 tons x 70/100 = 28,000 tons of uncalcined clay/yr

The facility total annual processing rate for uncalcined clay is:

40,000 + 28,000 = 68,000 tons of uncalcined clay/yr

In developing the NESHAP requirements for clay refractory manufacturers,
EPA developed emission factors for HF and HCl. These emission factors
are based on the amount of uncalcined clay processed. The emission
factor for HF is 0.38 lbs/ton of uncalcined clay processed and the
emission factor for HCl is 0.26 lbs/ton of uncalcined clay processed.
The second step in calculating total HAP emissions is to apply these
emission factors to the results from step 1 above. Therefore, total HF
and HCl emissions can be calculated as follows:

0.38 lbs HF/ton x 68,000 tons = 25,840 lbs HF = 12.9 tons

0.26 lbs HF/ton x 68,000 tons = 17,680 lbs HCl = 8.84 tons

The facility emits more than 10 tons of HF annually so it is a major
source of HAP and therefore subject to the standard.

######### Example 2: Calculation of Potential HAP Emissions from Clay Refractory Production with On‑Site Calciner

The facility manufactures three types of clay refractory products. The
facility manufactures 40,000 tons of product 1, which contains 85
percent uncalcined clay. The facility manufactures 35,000 tons of
product 2, which contains 20 percent uncalcined clay. The facility also
manufactures 25,000 tons of product 3, which contains 40 percent
calcined clay. Because product 3 contains only calcined clay, the firing
of that product does not contribute to the facility's HF and HCl
emissions. However, the facility does have a calciner onsite to process
the clay used in product 3, and the calciner is a source of HF and HCl
emissions.

All HAP emitting sources at a facility must be included when determining
the major source status of the facility, not just those sources covered
by the refractory products rule. Therefore, the facility must include
emissions from the calciner in determining its total emissions.

The facility's actual emissions from the kilns are calculated based on
the uncalcined clay annual processing rate as follows:

Product 1: 40,000 tons x 85/100 = 34,000 tons of uncalcined clay/yr

Product 2: 35,000 tons x 20/100 = 7,000 tons of uncalcined clay/yr

The total uncalcined clay annual processing rate is:

34,000 tons + 7,000 tons = 41,000 tons uncalcined clay/yr

Total actual HF and HCl emissions from the kilns can be calculated as
follows:

0.38 lbs HF/ton x 41,000 = 15,580 lbs HF = 7.8 tons

0.26 lbs HCl/ton x 41,000 = 10,660 lbs HCl = 5.3 tons

In addition to the kiln emissions from the manufacturing of the clay
refractory products 1 and 2, the facility must also calculate emissions
from the calciner. The calciner processes 10,000 tons of clay per year.
Using the emission factors developed by EPA and shown in Table 1, actual
emissions from the calciner can be calculated as follows:

0.19 lbs HF x 10,000 tons of clay = 1,900 lbs HF = 0.95 tons HF

0.13 lbs HCl x 10,000 tons of clay = 1,300 lbs HCl = 0.65 tons HCl

Total HF emissions from the kiln and the calciner are 8.8 tons. Total
HCl emissions from the kiln and the calciner are 5.95 tons. Based on its
actual emissions, the facility is not a major source. HF and HCl
emissions are both less than 10 tons/yr and total emissions for the
pollutants combined are less than 25 tons/yr.

Although actual emissions are less than 10/25 tons/yr, the facility
needs to calculate its potential emissions to determine if it may be a
major source. Because emissions are dependent upon the amount of
uncalcined clay the facility processes, the facility's potential
emissions are based on the production of the product with the highest
percentage of uncalcined clay. The production rates for products 1, 2
and 3 are the same, therefore the facility can potentially produce
100,000 tons of product 1 (40,000 tons + 35,000 tons + 25,000 tons). The
facility must calculate its potential emissions based on the production
of 100,000 tons of product 1, which contains 85 percent uncalcined clay.
The facility's potential uncalcined clay processing rate is:

100,000 tons x 85/100 = 85,000 tons of uncalcined clay

Total potential HF and HCl emissions from the kiln are calculated as
follows:

0.38 lbs HF/ton x 85,000 tons = 32,300 lbs HF = 16.2 tons

0.26 lbs HCl/ton x 85,000 tons = 22,100 lbs HCl = 11.1 tons

If the facility is manufacturing 100,000 tons of product 1, it cannot
manufacture any of product 3. Therefore, the calciner is not operating
under this scenario and the only source of emissions is the kiln. Total
potential HF emissions are 16.2 tons and total potential HCl emissions
are 11.1 tons.

Based on its potential emissions, the facility is a major source and
would therefore be subject to the standard. However, the facility can
avoid being subject to the rule if it agrees to permit limits that
ensure its potential emissions are also less than 10/25 tons/year. For
example, the facility may agree to a limit on the production of product
1 to ensure that its HF emissions are less than 10 tons/yr.

######### Example 3: Calculation of Potential HAP Emissions from Clay Refractory Production

The facility manufactures one type of clay refractory product. This
product contains 75 percent uncalcined clay. The facility manufactures
32,000 tons of the product while operating 3,000 hours/yr. The
facility's actual emissions are based on the production of 32,000 tons
of product with an uncalcined clay content of 75 percent. The annual
uncalcined clay processing rate is:

32,000 tons x 75/100 = 24,000 tons of uncalcined clay

Actual HF and HCl emissions are:

0.38 lb HF/ton x 24,000 tons = 9,120 lbs = 4.6 tons

0.26 lbs HCl/ton x 24,000 tons = 6,240 lbs = 3.1 tons

The facility's actual emissions are less than 10/25 tons/yr, but its
potential emissions are based on 8,760 hours/yr. Therefore, the
potential production is:

32,000 x 8,760/3,000 = 93,440 tons

The potential annual uncalcined clay processing rate is:

93,440 tons x 75/100 = 70,080 tons uncalcined clay

Potential HF and HCl emissions are:

0.38 lbs HF/ton x 70,080 = 26,630 lbs = 13.3 tons HF

0.26 lbs HCl/ton x 70,080 = 18,221 lbs = 9.1 tons HCl

The facility's potential emissions of HF are greater than 10 tons/yr so
the facility is a major source and subject to the requirements of the
standard. However, the facility may agree to limit its operating hours
in its permit to ensure that HF emissions are less than 10 tons/yr. In
that case, the facility would not be subject to the requirements of the
standard.

######### Example 4: Calculation of Potential HAP Emissions from Clay Refractory Production with Limiting Process

The facility manufactures 50,000 tons/yr of one type of clay refractory
product. The product contains 85 percent uncalcined clay. The annual
uncalcined clay processing rate is:

50,000 x 85/100 = 42,500 tons uncalcined clay/yr

The facility's actual emissions are:

0.38 lbs HF x 42,500 tons = 16,150 lbs/yr = 8.1 tons HF/yr

0.26 lbs HCl x 42,500 tons = 11,050 lbs/yr = 5.5 tons HCl/yr

The facility currently operates 6,200 hours/yr so it could potentially
produce 70,645 tons in 8,760 hours/yr. However, the maximum design
capacity of the presses that are used for forming operations is only 6.5
tons/hr or 56,940 tons/yr for 8,760 hours/year. All of the other process
units have sufficient design capacity to produce at least 70,645
tons/yr, but the physical design of the press limits the facility's
production to 56,940 tons/yr.

The capacity of the equipment can limit the facility's potential to
emit. Therefore, the facility's potential emissions are based on 56,940
tons/yr, not 70,645 tons/yr.

The potential uncalcined clay processing rate is:

56,940 tons/yr x 85/00 = 48,399 tons uncalcined clay/yr

The facility's potential emissions are:

0.38 lbs HF x 48,399 tons = 18,392 lbs/yr = 9.2 tons HF/yr

0.26 lbs HCl x 48,399 tons = 12,584 lbs/yr = 6.3 tons HCl/yr

The facility's actual and potential emissions are both less than 10/25
tons/yr so the facility is not a major source and is not subject to the
standard.

II. **Example Compliance Calculations for Facilities Manufacturing
    Products Containing Organic HAP**

This section provides example calculations for facilities manufacturing
the following products:

-   Resin-bonded refractory products

-   Pitch-bonded refractory products

-   Pitch-impregnated refractory products

-   Other formed products that use additives that contain or form
    organic HAP

The calculations are applicable to the following emission sources:

-   Shape dryers

-   Curing ovens

-   Kilns

-   Coking ovens

-   Defumers

-   New shape preheaters

The example calculations presented in this section are primarily related
to demonstrating compliance with emission limits and developing
operating limits using data collected during performance tests.

The compliance calculations vary depending upon whether the facility
manufactures products using a continuous or batch process. These
differences are due primarily to the differences in testing requirements
for continuous and batch processes.

Part A of this section provides example calculations for facilities
using a continuous process, and Part B provides example calculations for
facilities using a batch process.

## Continuous Process Compliance Options and Associated Calculations for Facilities Manufacturing Products Containing Organic HAP 

1.  *Example calculations for demonstrating compliance with the emission
    limits.* The rule provides two different compliance options for
    facilities manufacturing products containing organic HAP using a
    continuous process. These two different options are meeting a THC
    concentration limit or meeting a THC percentage reduction limit.
    Different calculations are used for each of the two compliance
    options. Following are example calculations for demonstrating
    compliance for each of these options using performance test data.

Example 1: Demonstrating Compliance with the THC Concentration Limits
for a Continuous Process Using the Performance Test Data

Table 1 provides data for an example test run for a facility equipped
with a thermal oxidizer. The data include both the THC concentrations
and the oxygen concentrations for each minute of the 1-hour test run.

Using the data presented in Table 1, calculate the average THC
concentration for the 1-hour run. Then calculate the average oxygen
concentration for the 1-hour test run. Using Equation 1 of 63.9800(g)(1)
of the rule, then calculate the hourly average THC concentration
corrected to 18 percent oxygen.

In the example test run presented in Table 1, the hourly average THC
concentration is 14.9 ppmvd and the hourly average oxygen concentration
is 18.6. Therefore, the corrected THC concentration for the test run is:

Corrected THC = (2.9 x 14.9)/(20.9-18.6) = 18.8 ppmvd

For a continuous process, the THC concentration for the performance test
is based on the average of the corrected concentrations for each test
run. Therefore, if the corrected THC concentrations for the other two
test runs are 15.2 ppmvd and 17.8 ppmvd, the average corrected THC
concentration for the three test runs is:

(18.8 + 15.2 + 17.8)/3 = 17.3 ppmvd

Therefore, the results of the performance test indicate the facility is
in compliance with the emission limit of 20 ppmvd, corrected to 18
percent oxygen.

**Table 1. Example THC and Oxygen Concentration Data for 1-Hour
Performance Test**

+-----------------+-------------------------+-------------------------+
| Time            | THC Concentration       | Oxygen Concentration    |
|                 | (ppmvd)                 |                         |
|                 |                         | (percent)               |
+-----------------+-------------------------+-------------------------+
| 1510            | 15                      | 18.1                    |
+-----------------+-------------------------+-------------------------+
| 1511            | 16                      | 19.2                    |
+-----------------+-------------------------+-------------------------+
| 1512            | 12                      | 18.7                    |
+-----------------+-------------------------+-------------------------+
| 1513            | 18                      | 17.9                    |
+-----------------+-------------------------+-------------------------+
| 1514            | 19                      | 19.1                    |
+-----------------+-------------------------+-------------------------+
| 1515            | 20                      | 17.8                    |
+-----------------+-------------------------+-------------------------+
| 1516            | 22                      | 18.4                    |
+-----------------+-------------------------+-------------------------+
| 1517            | 21                      | 18.4                    |
+-----------------+-------------------------+-------------------------+
| 1518            | 21                      | 18.5                    |
+-----------------+-------------------------+-------------------------+
| 1519            | 22                      | 19.1                    |
+-----------------+-------------------------+-------------------------+
| 1520            | 23                      | 17.5                    |
+-----------------+-------------------------+-------------------------+
| 1521            | 20                      | 17.6                    |
+-----------------+-------------------------+-------------------------+
| 1522            | 18                      | 17.7                    |
+-----------------+-------------------------+-------------------------+
| 1523            | 17                      | 17.8                    |
+-----------------+-------------------------+-------------------------+
| 1524            | 17                      | 17.9                    |
+-----------------+-------------------------+-------------------------+
| 1525            | 16                      | 19.1                    |
+-----------------+-------------------------+-------------------------+
| 1526            | 14                      | 19.2                    |
+-----------------+-------------------------+-------------------------+
| 1527            | 14                      | 20.1                    |
+-----------------+-------------------------+-------------------------+
| 1528            | 13                      | 20.2                    |
+-----------------+-------------------------+-------------------------+
| 1529            | 10                      | 19.9                    |
+-----------------+-------------------------+-------------------------+
| 1530            | 12                      | 19.8                    |
+-----------------+-------------------------+-------------------------+
| 1531            | 12                      | 18.1                    |
+-----------------+-------------------------+-------------------------+
| 1532            | 12                      | 18.1                    |
+-----------------+-------------------------+-------------------------+
| 1533            | 12                      | 18.1                    |
+-----------------+-------------------------+-------------------------+
| 1534            | 14                      | 18.9                    |
+-----------------+-------------------------+-------------------------+
| 1535            | 14                      | 17.8                    |
+-----------------+-------------------------+-------------------------+
| 1536            | 12                      | 17.5                    |
+-----------------+-------------------------+-------------------------+
| 1537            | 9.3                     | 17.7                    |
+-----------------+-------------------------+-------------------------+
| 1538            | 8.5                     | 18.2                    |
+-----------------+-------------------------+-------------------------+
| 1539            | 8.3                     | 19.1                    |
+-----------------+-------------------------+-------------------------+
| 1540            | 10                      | 19.1                    |
+-----------------+-------------------------+-------------------------+
| 1541            | 12                      | 19.1                    |
+-----------------+-------------------------+-------------------------+
| 1542            | 14                      | 19.9                    |
+-----------------+-------------------------+-------------------------+
| 1543            | 15                      | 19.5                    |
+-----------------+-------------------------+-------------------------+
| 1544            | 15                      | 19.5                    |
+-----------------+-------------------------+-------------------------+
| 1545            | 17                      | 18.8                    |
+-----------------+-------------------------+-------------------------+
| 1546            | 20                      | 18.9                    |
+-----------------+-------------------------+-------------------------+
| 1547            | 21                      | 19.1                    |
+-----------------+-------------------------+-------------------------+
| 1548            | 19                      | 19.0                    |
+-----------------+-------------------------+-------------------------+
| 1549            | 18                      | 19.1                    |
+-----------------+-------------------------+-------------------------+
| 1550            | 18                      | 19.1                    |
+-----------------+-------------------------+-------------------------+
| 1551            | 16                      | 19.2                    |
+-----------------+-------------------------+-------------------------+
| 1552            | 15                      | 18.3                    |
+-----------------+-------------------------+-------------------------+
| 1553            | 15                      | 17.9                    |
+-----------------+-------------------------+-------------------------+
| 1554            | 15                      | 17.8                    |
+-----------------+-------------------------+-------------------------+
| 1555            | 14                      | 17.9                    |
+-----------------+-------------------------+-------------------------+
| 1556            | 14                      | 18.4                    |
+-----------------+-------------------------+-------------------------+
| 1557            | 13                      | 18.1                    |
+-----------------+-------------------------+-------------------------+
| 1558            | 12                      | 18.5                    |
+-----------------+-------------------------+-------------------------+
| 1559            | 12                      | 18.6                    |
+-----------------+-------------------------+-------------------------+
| 1600            | 12                      | 18.8                    |
+-----------------+-------------------------+-------------------------+
| 1601            | 11                      | 19.2                    |
+-----------------+-------------------------+-------------------------+
| 1602            | 13                      | 18.9                    |
+-----------------+-------------------------+-------------------------+
| 1603            | 13                      | 17.9                    |
+-----------------+-------------------------+-------------------------+
| 1604            | 15                      | 18.2                    |
+-----------------+-------------------------+-------------------------+
| 1605            | 15                      | 19.1                    |
+-----------------+-------------------------+-------------------------+
| 1606            | 14                      | 18.3                    |
+-----------------+-------------------------+-------------------------+
| 1607            | 12                      | 18.2                    |
+-----------------+-------------------------+-------------------------+
| 1608            | 11                      | 19.0                    |
+-----------------+-------------------------+-------------------------+
| 1609            | 10                      | 17.8                    |
+-----------------+-------------------------+-------------------------+
| Average         | 14.9                    | 18.6                    |
+-----------------+-------------------------+-------------------------+

Example 2: Demonstrating Compliance with the THC Percentage Reduction
Limit for a Continuous Process

You may choose to meet the emission limits in the rule by meeting the
THC percentage reduction requirement of 95 percent. If you choose this
option, measure the THC concentration at both the inlet and outlet of
the control device. Using the 1-minute THC measurements for the test run
and the volumetric flow rate values, calculate the pounds of THC emitted
per hour for each hour of the test run at both the inlet and outlet of
the control device. Using the inlet and outlet mass emission rates, then
calculate the percentage reduction achieved by the control device using
Equation 2 of Section 63.9800(g)(2) of the rule, which is as follows:

PR = (ER~i~ -- ER~o~)/ER~i~ x 100

Where:

PR = percentage reduction, percent

ER~i~ = THC mass emission rate entering the control device (lbs/hr)

ER~o~ = THC mass emission rate exiting the control device (lbs/hr)

Using the data for the example test runs presented below, we have
calculated the percentage reduction for the control device.

*[Run 1]{.underline}*

THC emission rate at inlet = 20 lbs/hr

THC emission rate at outlet = 1 lbs/hr

Percentage reduction for Run 1 = (20 -- 1)/20 = 95 percent reduction

*[Run 2]{.underline}*

THC emission rate at inlet = 17.5 lbs/hr

THC emission rate at outlet = 0.7 lbs/hr

Percentage reduction for Run 2 = (17.5-0.7)/17.5 = 96 percent reduction

*[Run 3]{.underline}*

THC emission rate at inlet = 18.8 lbs/hr

THC emission rate at outlet = 0.8 lbs/hr

Percentage reduction for Run 3 = (18.8 -- 0.8)/18.8 = 95.7 percent
reduction

The average for the three test runs is:

(95 + 96 + 95.7)/3 = 95.6 percent reduction

This is greater than the required reduction of 95 percent so the results
from the performance test demonstrate the facility is in compliance with
the THC percentage reduction emission limit.

Example 3: Performance Test Data Indicate Non-Compliance with the THC
Percentage Reduction Requirements for a Continuous Process

In this example, the facility is also trying to demonstrate compliance
with the THC percentage reduction limit of 95 percent. The facility is
using a continuous process to manufacture refractory products containing
organic HAP. To demonstrate compliance with the THC percentage reduction
limit, the facility measures the THC concentration at both the inlet and
outlet of the control device. Using the 1-minute THC measurements and
the flow rate measurements, the facility calculates the THC mass
emission rate at both the inlet and outlet of the control device. Using
Equation 2 of Section 63.9800(g)(2), the facility calculates the THC
percentage reduction for each test run.

Using the example data presented below for each test run, we have
calculated the percentage reduction for each test run.

*[Run 1]{.underline}*

THC Emission Rate at Inlet = 15.3 lbs/hour

THC Emission Rate at Outlet = 1.5 lbs/hour

Percentage reduction for Run 1 = (15.3 -- 1.5)/15.3 = 90.2 percent

*[Run 2]{.underline}*

THC Emission Rate at Inlet = 16.1 lbs/hour

THC Emission Rate at Outlet = 1.9 lbs/hour

Percentage reduction for Run 2 = (16.1-1.9)/16.1 = 88.2 percent

*[Run 3]{.underline}*

THC Emission Rate at Inlet = 16.2 lbs/hour

THC Emission Rate at Outlet = 1.8 lbs/hour

Percentage reduction for Run 3 = (16.2-1.8)/16.2 = 88.9 percent

The average percentage reduction for the three test runs is:

(90.2 + 88.2 + 88.9)/3 = 89.1 percent

In this case, the results from the performance test indicate that the
facility is not achieving the THC percentage reduction limit of 95
percent. The facility should notify its permitting authority immediately
upon determining that it has failed the compliance test. The permitting
authority will address failed compliance tests on a case-by-case basis.

2.  *Example calculations for establishing operating limits.* Facilities
    manufacturing refractory products containing organic HAP using a
    continuous process must establish operating limits for the maximum
    allowable organic HAP processing rate and the oxidizer temperature
    for each source subject to the standard. The operating limit for the
    oxidizer temperature is the minimum temperature that you must
    maintain for your oxidizer while manufacturing products containing
    organic HAP. For facilities equipped with a thermal oxidizer, the
    oxidizer temperature is based on the combustion chamber temperature.
    For facilities equipped with a catalytic oxidizer, the oxidizer
    temperature is based on the temperature at the inlet to the catalyst
    bed. The following example calculations demonstrate how to establish
    operating limits for the maximum allowable organic HAP processing
    rate and the oxidizer temperature.

######### Example 4: Calculating the Operating Limit for the Maximum Allowable Organic HAP Processing Rate

The maximum allowable organic HAP processing rate is based on the
organic HAP content of any resins, binders or additives in the
refractory product, the percentage of those resins, binders or additives
in the refractory product mix, and the production rate for the
refractory product during the compliance test.

In all cases, the compliance test should be conducted while
manufacturing the product with the highest organic HAP processing rate.
In this example, the product with the highest organic HAP processing
rate is a resin-bonded product. The resin contains 10 percent phenol and
the refractory product contains 8 percent resin. The production rate is
approximately 8,000 lbs/hr, but it varies slightly for each test run.

## *[Run 1]{.underline}* {#run-1 .unnumbered}

Production rate is 8,100 lbs/hr

Organic HAP processing rate = 8,100 x 10/100 x 8/100 = 64.8 lbs/hr

## *[Run 2]{.underline}* {#run-2 .unnumbered}

Production rate is 7,800 lbs/hr

Organic HAP processing rate = 7,800 x 10/100 x 8/100 = 62.4 lbs/hr

## *[Run 3]{.underline}* {#run-3 .unnumbered}

Production rate is 8,250 lbs/hr

Organic HAP processing rate = 8,250 x 10/100 x 8/100 = 66 lbs/hr

The operating limit for the maximum allowable organic HAP processing
rate is the average organic HAP processing rate for the three test runs
plus 10 percent. The average for the three test runs is 64.4 lbs/hour,
so the operating limit is 64.4 + (0.1 x 64.4) = 70.8 lbs/hour.

######### Example 5: Calculating the Operating Limit for the Oxidizer Temperature

As discussed earlier, the operating limit for the oxidizer temperature
is based on the combustion chamber temperature if you have a thermal
oxidizer, and the temperature at the inlet to the catalyst bed if you
have a catalytic oxidizer. However, the procedure for calculating the
operating limit for the oxidizer temperature is the same regardless of
the type of oxidizer that you have.

During each test run, you need to measure the oxidizer temperature every
15 minutes. Then calculate the average oxidizer temperature for each
hour of the test run. The operating limit is based on the average
temperature for the three test runs. Following is an example calculation
for a facility equipped with a thermal oxidizer.

*[Run 1]{.underline}*

During the 1-hour test run, the facility measured the combustion chamber
temperature 4 times. The combustion chamber temperatures were as
follows:

1530F

1538F

1541F

1542F

The average combustion chamber temperature for Run 1 is:

(1530 + 1538 + 1541 + 1542)/4 = 1538F

*[Run 2]{.underline}*

During Run 2, the combustion chamber temperatures were:

1545F

1550F

1543F

1547F

The average combustion chamber temperature for Run 2 is:

(1545 + 1550 + 1543 + 1547)/4 = 1546F

*[Run 3]{.underline}*

During Run 3, the combustion chamber temperatures were:

1551F

1543F

1544F

1538F

The average combustion chamber temperature for Run 3 is:

(1551 + 1543 + 1544 + 1538)/4 = 1544F

The average combustion chamber temperature for the three test runs is:

(1538 + 1546 + 1544)/3 = 1543F

The operating limit for the oxidizer temperature is the average for the
three test runs minus 25F or:

1543 -- 25 = 1518F

For the facility to be in continuous compliance with the operating limit
for oxidizer temperature, the rolling average for each 3-hour period of
operation must be at least 1518F.

## Example Compliance Calculations for Facilities Manufacturing Products Containing Organic HAP Using a Batch Process

> 1\. *Example Calculations for Developing an Emissions Profile.*
> Testing batch processes is typically more complicated than testing
> continuous processes. Because many of the batch processes associated
> with the manufacturing of refractory products containing organic HAP
> are very long, lasting 12 hours or more, the rule contains a provision
> that allows facilities to limit testing to the peak emissions period.
> To do this, the facility must first develop an emissions profile.
> Developing an emissions profile can simplify the testing process.
> Example 6 provides an example calculation for determining the peak
> emissions period and developing an emissions profile.

######### Example 6: Calculation for Determining the Peak Emissions Period and Developing an Emissions Profile

The rule contains options for reducing the total testing time for
facilities using a batch process to manufacture products containing
organic HAP. One option is to develop an emissions profile. The goal of
developing an emissions profile is to determine the peak emissions
period, that is, the period of 3 consecutive hours during the batch when
emissions are at their highest. The data from the example test run
presented in Table 2 will be used to demonstrate how to develop an
emissions profile.

As shown in the right-hand column of Table 2, to develop an emissions
profile you have to calculate the total emission rate at the control
device inlet for each consecutive 3-hour period of the batch. In this
case, the value represents the total emission rate for the 3-hour period
ending at that hour. For example, the total emission rate for hours 1
through 3 is:

3.2 + 5.1 + 5.5 = 13.8

As shown in the table, the highest total emission rate at the control
device inlet for any consecutive 3-hour period for this example test run
is 53.8. This total emission rate occurs between hours 9 and 11 of the
test. This represents the peak emissions period for this source.

**Table 2. Example Test Data for Developing an Emissions Profile**

  ---------------------- ------------------------ ------------------------
  Hour                   THC Emission Rate at     Total Emission Rate for
                         Inlet (lbs/hr)           3-Hour Period

  1                      3.2                      

  2                      5.1                      

  3                      5.5                      13.8

  4                      6.5                      17.1

  5                      8.5                      20.5

  6                      10.7                     25.7

  7                      12.7                     31.9

  8                      16.8                     40.2

  9                      17.9                     47.4

  10                     18.4                     53.1

  11                     17.5                     53.8

  12                     16.2                     52.1

  13                     16.1                     49.8

  14                     15.1                     47.4

  15                     14.0                     45.2

  16                     11.2                     40.3

  17                     11.1                     36.3

  18                     9.4                      31.7

  19                     8.8                      29.3

  20                     5.9                      24.1

  21                     4.2                      18.9

  22                     3.5                      13.6

  23                     2.1                      9.8

  24                     1.2                      6.8

  25                     1.5                      4.8
  ---------------------- ------------------------ ------------------------

Unless you begin to manufacture a product with a maximum allowable
organic HAP processing rate that is greater than the operating limit you
have established, then for all future testing of this emission source
you only have to conduct testing during this peak emissions period, that
is, during hours 9 through 11 of the batch. If you wish to establish a
new operating limit for the maximum allowable organic HAP processing
rate, you must also develop a new emissions profile. In addition, the
provision to limit testing to the peak emissions period does not apply
if you wish to cut off or reduce the temperature of the thermal
oxidizer, as discussed in item 8.a.i(4) of Table 4 of the rule.

1.  *Example Calculations for Demonstrating Compliance with the Emission
    Limits.* The rule provides two options for demonstrating compliance
    with the emission limits. The first option is to meet a THC
    concentration limit. The second option is to meet a THC percentage
    reduction requirement. Example calculations for each of these
    options are presented below.

######### Example 7: Calculation for Demonstrating Compliance with the THC Concentration Limit (Compliance Option 1) for a Batch Process

To demonstrate compliance with the THC concentration limit, you must
perform the following calculations for each test run:

1.  Calculate the average THC concentration for each hour of the
    performance test using the 1‑minute measurements.

2.  Calculate the average oxygen content for each hour of the
    performance test using the 1‑minute measurements.

3.  Using the hourly averages calculated for steps (1) and (2) above,
    calculate the average hourly THC concentration corrected to 18
    percent oxygen using Equation 1 of 63.9800(g)(6). For example, if
    the average hourly concentration is 11 ppmvd and the average oxygen
    concentration for that same hour is 19.0, the corrected THC
    concentration is as follows:

Corrected THC = 2.9 x 11/(20.9 -- 19) = 16.8 ppmvd

4.  Determine the period of 3 consecutive hours over which the sum of
    the hourly average corrected THC concentrations calculated in
    step (3) is greater than the sum for any other period of 3
    consecutive hours during the test run as shown in the right-hand
    column of Table 3 below.

5.  Calculate the average of the hourly average corrected THC
    concentrations for the 3-hour period identified in step (4).

6.  Calculate the average peak THC concentration for the two test runs.

Table 3 provides an example test run for a batch that demonstrates how
to determine compliance with the THC concentration limit using the
performance test data. Note that the right-hand column of the table
represents the total corrected THC concentration for the 3-hour period
ending at that hour.

Table 3. Example Test Run for Demonstrating Compliance with the

THC Concentration Limit for a Batch Process

+-------+-------------+---------------+---------------+--------------+
| Hour  | Average THC | Average       | Average THC   | Total        |
|       | Co          | Oxygen        | Concentration | Corrected    |
|       | ncentration | Concentration | Corrected to  | THC          |
|       | (ppmvd)     |               | 18% Oxygen    | C            |
|       |             | (percent)     |               | oncentration |
|       |             |               |               | for 3-Hour   |
|       |             |               |               | Period       |
+-------+-------------+---------------+---------------+--------------+
| 1     | 10          | 18.5          | 12.1          |              |
+-------+-------------+---------------+---------------+--------------+
| 2     | 9           | 18.6          | 11.3          |              |
+-------+-------------+---------------+---------------+--------------+
| 3     | 8           | 19            | 12.2          | 35.6         |
+-------+-------------+---------------+---------------+--------------+
| 4     | 11          | 19.2          | 18.8          | 42.3         |
+-------+-------------+---------------+---------------+--------------+
| 5     | 12          | 19.1          | 19.3          | 50.3         |
+-------+-------------+---------------+---------------+--------------+
| 6     | 9           | 19.5          | 18.6          | 56.7         |
+-------+-------------+---------------+---------------+--------------+
| 7     | 8           | 19.4          | 15.5          | 53.4         |
+-------+-------------+---------------+---------------+--------------+
| 8     | 6           | 19.3          | 10.9          | 45.0         |
+-------+-------------+---------------+---------------+--------------+
| 9     | 5           | 19.3          | 9.1           | 35.5         |
+-------+-------------+---------------+---------------+--------------+
| 10    | 3           | 18.8          | 4.1           | 24.1         |
+-------+-------------+---------------+---------------+--------------+
| 11    | 2           | 18.5          | 2.4           | 15.6         |
+-------+-------------+---------------+---------------+--------------+
| 12    | 2           | 18.6          | 2.5           | 9.0          |
+-------+-------------+---------------+---------------+--------------+

Based on the results from the example test run in Table 3, the 3-hour
peak occurred between hours 4 and 6, with a total corrected THC
concentration of 56.7. The average hourly-corrected THC concentrations
for those three hours are 18.8, 19.3, and 18.6. The average THC
concentration for the peak period for the test run is 18.9 ppmvd
((18.8 + 19.3 + 18.6)/3), corrected to 18 percent oxygen.

For a batch process, you are required to conduct two test runs. Assuming
that the average corrected THC concentration for the peak period for the
second test run is 16.5 ppmvd, the average for the performance test
would be 17.7 ppmvd ((18.9 + 16.5)/2). This is less than the limit of 20
ppmvd, so the calculations demonstrate the facility is in compliance
with the THC concentration limits.

Example 8: Performance Test Data Indicate Non-Compliance with the THC
Concentration Limits for a Batch Process

In this example, the facility is also attempting to demonstrate
compliance with the THC concentration limits for a batch process. Table
4 presents data for an example test run. Using the data presented in
Table 4, the facility followed steps 1-6 as presented in Example 7. As
shown in the right-hand column of Table 4, the peak emissions period
occurs between hours 6 and 8 of the test run. The average corrected THC
concentrations for hours 6, 7, and 8 are 39.2 ppm, 39.8 ppm, and 53.8
ppm. Therefore, the corrected THC concentration for the test run is 44.3
ppm (39.2 + 39.8 + 53.8/3).

For batch sources, the facility is required to conduct two test runs.
Assuming that the average corrected THC concentration for the peak
emissions period is 34.1 ppm, the average for the performance test is
39.2 ppm. This is greater than the THC concentration limit of 20 ppm,
corrected to 18 percent oxygen. Therefore, the facility is not in
compliance with the rule.

In this case, the facility should contact its permitting authority
immediately upon determining that the performance test indicates the
facility is not in compliance with the standard. The permitting
authority will address all failed compliance tests on a case-by-case
basis.

Table 4. Example Test Run for Demonstrating Compliance with the THC
Concentration Limits for a Batch Process

  -------------- --------------- --------------- --------------- ---------------
  Hour           Average THC     Average Oxygen  Average THC     Total Corrected
                 Concentration   Concentration   Concentration   THC
                 (ppm)           (percent)       Corrected to    Concentration
                                                 18% Oxygen      for 3-Hour
                                                 (ppm)           Period

  1              8.2             19.2            13.4            

  2              8.5             19.4            16.4            

  3              9.6             18.9            13.9            43.7

  4              13.4            19.1            21.6            51.9

  5              16.3            19.0            24.9            60.4

  6              18.9            19.5            39.2            85.7

  7              19.2            19.5            39.8            103.9

  8              20.4            19.8            53.8            132.8

  9              18.8            19.4            36.3            129.9

  10             18.2            19.5            37.7            127.8

  11             17.5            18.9            25.4            99.4

  12             14.2            19.0            21.7            84.8

  13             13.1            19.1            21.2            68.3

  14             12.7            18.7            16.7            59.6
  -------------- --------------- --------------- --------------- ---------------

Example 9: Calculation for Demonstrating Compliance with the THC
Percentage Reduction Limit (Compliance Option 2) for a Batch Process

To demonstrate compliance with the THC percentage reduction limit, you
must perform the following calculations:

1.  Calculate the hourly THC mass emission rate (lbs THC/hr) at both the
    inlet and outlet of the control device for each hour of the test
    run.

2.  Using the hourly THC mass emission rates for the control device
    inlet calculated in step (1), calculate the total THC mass emission
    rate for each period of 3 consecutive hours as shown in Table 5.

3.  Using the 3-hour total mass emission rates calculated in step (2),
    determine the period of 3 consecutive hours when the sum of the
    inlet mass emission rates is greater than any other 3‑hour period.

4.  Calculate the average THC percentage reduction for that 3-hour
    period for each test run using Equation 2 of 63.9800(g)(2):

PR = (ER~i~ -- ER~o~)/ER~i~ x 100

Where:

PR = Percentage reduction, percent

ER~i~ = mass emission rate of THC at the inlet to the control device,
lbs/hr

ER~o~= mass emission rate of THC at the outlet of the control device,
lbs/hr

For example, in Table 5 below, the inlet THC mass emission rate for the
first hour of the test run is 5.0 lbs/hr. The outlet rate for that hour
is 0.21 lbs/hr. Therefore, the percentage reduction may be calculated as
follows:

PR = (5.0 -- 0.21)/5.0 x 100 = 95.8 percent reduction

5.  Calculate the average percentage reduction for both test runs.

Table 5 presents data from an example test run that demonstrates how to
show compliance with the percentage reduction requirement for a batch
process.

Table 5. Example Test Run for Demonstrating Compliance with the

Percentage Reduction Requirement for a Batch Process

  -------------- -------------- -------------- -------------- --------------
  Hour           THC Mass       3-Hour Total   THC Mass       Percentage
                 Emission Rate, Mass Emission  Emission Rate, Reduction
                 Inlet (lbs/hr) Rate, Inlet    Outlet         
                                               (lbs/hr)       

  1              5.0                           0.21           95.8

  2              6.1                           0.30           95.1

  3              8.6            19.7           0.35           95.9

  4              9.2            23.9           0.43           95.3

  5              12             29.8           0.56           95.3

  6              11             32.2           0.40           96.4

  7              7.9            30.9           0.37           95.3

  8              6.8            25.7           0.31           95.4

  9              5.5            20.2           0.25           95.5

  10             3.8            16.1           0.17           95.5

  11             3.2            12.5           0.13           95.9
  -------------- -------------- -------------- -------------- --------------

The highest 3-hour total for this example test run occurs between hours
4 and 6, with a total mass emission rate during that period of 32.2. The
percentage reductions for hours 4, 5, and 6 are 95.3, 95.3, and 96.4
percent respectively. Therefore the average percentage reduction for
this test run is:

(95.3 + 95.3 + 96.4)/3 = 95.7 percent

Assuming that the average reduction for the second test run is 96.4
percent, the average percentage reduction for the performance test is
96.1 percent. Therefore, the results of the performance test demonstrate
the facility is in compliance with the rule.

> 3\. *Example calculations for establishing operating limits.*
> Facilities manufacturing refractory products containing organic HAP
> using a batch process must establish operating limits for the maximum
> allowable organic HAP processing rate and the oxidizer temperature.
> For facilities equipped with a thermal oxidizer, the oxidizer
> temperature is based on the combustion chamber temperature. For
> facilities equipped with a catalytic oxidizer, the oxidizer
> temperature is based on the temperature at the inlet to the catalyst
> bed. The following example calculations demonstrate how to establish
> operating limits for the maximum allowable organic HAP processing rate
> and the oxidizer temperature.

######### Example 10: Calculation for Establishing the Operating Limit for the Maximum Allowable Organic HAP Processing Rate for a Batch Process

The organic HAP processing rate for a batch process is a function of the
HAP content of any binders, resins, or additives used in the refractory
product, the percentage of the HAP containing constituent in the
refractory product, and the amount of product produced during the batch.

The operating limit for the maximum allowable organic HAP processing
rate is based on the organic HAP processing rate for the products
manufactured during the performance test.

All performance tests should be conducted while manufacturing the
product with the highest organic HAP processing rate.

For this example, the product with the highest organic HAP processing
rate is a pitch-bonded product. The pitch contains 100 percent POM and
the refractory product mix contains 8 percent pitch. The production for
each batch varies slightly. The organic HAP processing rate for each
test run is calculated as follows:

*[Run 1]{.underline}*

Total production for the batch is 17,250 lbs. Therefore, the organic HAP
processing rate for Run 1 is:

17,250 lbs/batch x 8/100 = 1,380 lbs POM/ batch

*[Run 2]{.underline}*

During the second run, the total production for the batch is 16,900 lbs.
The organic HAP processing rate for Run 2 is:

16,900 lbs/batch x 8/100 = 1,352 lbs POM/batch

The operating limit for the maximum allowable organic HAP processing
rate is based on the average of the two test runs plus 10 percent. The
average for the two test runs in this example is 1,366 lbs POM/batch.
Therefore, the operating limit for the maximum allowable organic HAP
processing rate is:

1,366 + (0.1 x 1,366) = 1,503 lbs/batch

######### Example 11: Calculation for Establishing the Operating Limit for Oxidizer Temperature for a Batch Process

As discussed earlier, the operating limit for oxidizer temperature is
based on the combustion chamber temperature if the source is controlled
by a thermal oxidizer. If the source is controlled by a catalytic
oxidizer, the operating limit is based on the temperature at the inlet
to the catalyst bed. However, the calculations for establishing the
operating limit for oxidizer temperature are the same regardless of the
type of oxidizer.

During the performance test, monitor and record the oxidizer temperature
every 15 minutes. For batch operations, the operating limit is based on
the temperature of the oxidizer during the peak 3-hour emissions period.
For a source choosing to comply with the THC concentration limits, the
peak 3-hour emissions period is the period of 3 consecutive hours during
which the total corrected THC concentration at the outlet of the control
device or in the stack is greater than the total corrected THC
concentration for any other consecutive 3-hour period (see Example
Calculation 7). For facilities choosing to comply with the THC
percentage reduction limit, the peak 3-hour emissions period is the
period of 3 consecutive hours during the test during which mass emission
rates at the control device inlet are greater than any other 3-hour
period (see Example Calculations 6 and 9). For each test run, calculate
the average hourly oxidizer temperature for each hour of the peak 3-hour
period. Then calculate the average temperature for that 3-hour period
based on the hourly averages. The operating limit is based on the
average for the two test runs.

In this example, the facility is using a thermal oxidizer to control
emissions. Therefore, they are required to measure and record the
combustion chamber temperature during each test run.

*[Run 1]{.underline}*

The peak 3-hour emissions period for the batch occurs between the
beginning of hour 4 and the end of hour 6. The average combustion
chamber temperature for each hour is provided below:

Hour 4 -- 1575EF

Hour 5 -- 1560EF

Hour 6 -- 1565EF

The average combustion chamber temperature for the peak 3-hour period
for the test run is:

(1575 + 1560 + 1565)/3 = 1567EF

*[Run 2]{.underline}*

Again, the peak emissions period is between hour 4 and 6 of the batch.
The average combustion chamber temperature for each hour is:

Hour 4 -- 1550EF

Hour 5 -- 1565EF

Hour 6 -- 1570EF

The average combustion chamber temperature for Run 2 during the peak
3-hour period is:

(1550 + 1565 + 1570)/3 = 1562EF

The average combustion chamber temperature for the two test runs is
1565EF. The operating limit for the oxidizer combustion chamber
temperature is the average for the two test runs, 1565EF, minus 25EF, or
1540EF.

III. **Example Compliance Calculations for Facilities Manufacturing Clay
     Refractory Products**

These example calculations apply to new kilns used to manufacture clay
refractory products using uncalcined clay. Because the testing
requirements vary depending upon whether the clay refractories are
manufactured using a continuous process or a batch process, the
calculations also vary depending upon the manufacturing process.
Therefore, this section presents example calculations for facilities
using a continuous process, and calculations for facilities using a
batch process.

## Example Compliance Calculations for Facilities Manufacturing Clay Refractory Products Using a Continuous Process

> 1\. *Example Calculations for Demonstrating Compliance with the
> Emission Limits.*

The rule contains two compliance options for facilities manufacturing
clay refractory products using a continuous process. Facilities may meet
production-based emission limits for HF and HCl or they may meet
percentage reduction requirements for HF and HCl.

Example calculations for both options are presented below.

######### Example 1: Calculations for Demonstrating Compliance with the HF and HCl Production-Based Emission Limits

To demonstrate compliance with the HF and HCl production-based emission
limits, you must perform the following calculations:

1.  Using the production data and product formulation data, calculate
    the average rate at which you processed uncalcined clay (tons/hr)
    during each test run.

2.  Calculate the HF and HCl mass emission rates for each test run.

3.  Calculate the hourly production-based emission rate for HF and HCl
    using the following equation, which is Equation 3 of section
    63.9798(g)(3) of the rule:

MP = ER/P

Where:

MP = mass per unit of production (lbs/ton) of uncalcined clay processed

ER = mass emission rate of HF or HCl during each performance test
(lbs/hr)

> P = average uncalcined clay processing rate for the performance test,
> tons of uncalcined clay processed per hour

4.  Calculate the 3-hour block average of the emission rate for each
    pollutant as the average emission rate for the three test runs.

Following is the calculation procedure using data from an example
performance test.

The uncalcined clay processing rate is a function of the production rate
and the fraction of uncalcined clay in the refractory product. During
the first test run, the production rate for the example facility is 4
tons/hr. The refractory product manufactured during the test run has an
uncalcined clay fraction of 50 percent. The processing rate for the
uncalcined clay can be calculated as follows:

4 tons/hr x 0.5 = 2 tons of uncalcined clay per hour

The facility used Method 26A to measure HF and HCl. Based on the results
from Method 26A, the mass emission rate for HF during the first test run
was 0.070 lbs/hr. The mass emission rate for HCl was 0.34 lbs/hr. Using
the uncalcined clay processing rate of 2 tons/hr, the production-based
emission rates for HF and HCL can be calculated as follows:

(0.070 lbs HF/hr)/(2 tons/hr) = 0.035 lbs HF/ton of uncalcined clay

(0.34 lbs HCl/hr)/(2tons/hr) = 0.17 lbs HCl/ton of uncalcined clay

Following the same procedure, the facility determined the
production-based emission rates for HF and HCl for Runs 2 and 3. For HF,
the emission rate was 0.036 for Run 2 and 0.038 for Run 3. Therefore,
the 3-hour block average for HF was:

(0.035 + 0.036 + 0.038)/3 = 0.036 lbs HF/ton of uncalcined clay

This production-based mass emission rate is less than the HF emission
limit of 0.038 lbs HF/ton of uncalcined clay, so the source is in
compliance for HF.

For HCl, the emission rate was 0.16 for Run 2 and 0.15 for Run 3. The
3-hour block average for HCl was:

(0.17 + 0.16 + 0.15)/3 = 0.16 lbs HCl/ton of uncalcined clay

This production-based mass emission rate is less than the HCl emission
limit of 0.18 lbs HCl/ton of uncalcined clay, so the source is in
compliance for HCl.

Example 2: Calculation for Demonstrating Compliance with the Percentage
Reduction Requirements for HF and HCl for a Continuous Process

To demonstrate compliance with the percentage reduction requirements for
HF and HCl, you must perform the following calculations:

1.  Determine the mass emission rates for HF and HCl in lbs/hr at both
    the inlet and outlet of the control device.

2.  Calculate the hourly HF and HCl percentage reductions using the
    following equation, which is Equation 2 of section 63.9800(g)(2) of
    the rule:

PR = (ER~i~ -- ER~o~)/ER~i~ x 100

Where:

PR = percentage reduction, percent

ER~i~ = mass emission rate of HF or HCl entering the control device
(lbs/hr)

ER~o~ = mass emission rate of HF or HCl exiting the control device
(lbs/hr)

3.  Calculate the 3-hour block average as the average of the percentage
    reductions for each test run.

The data from an example performance test can be used to illustrate
these calculation procedures.

*[Run 1]{.underline}*

Using Method 26A, the facility determines the mass emission rates for HF
and HCl as follows:

HF inlet emission rate = 0.83 lbs/hr

HF outlet emission rate = 0.040 lbs/hr

HCl inlet emission rate = 0.46 lbs/hr

HCl outlet emission rate = 0.22 lbs/hr

The percentage reduction for HF for Run 1 can be calculated as follows:

(0.83 -- 0.040)/0.83 x 100 = 95.2 percent

The percentage reduction for HCl is:

(0.46 -- 0.22)/0.46 = 52.2 percent

The facility conducted two additional test runs and, using the same
procedures, determined that the HF percentage reduction for Run 2 was
91.5 percent and the reduction for Run 3 was 92.3 percent. The 3-hour
block average for the performance test was

(95.2 + 91.5 + 92.3)/3 = 93.0 percent

For HCl, the reduction for Run 2 was 41.2 percent and the reduction for
Run 3 was 45.4 percent. The 3-hour block average for the performance
test was:

(52.2 + 41.2 + 45.4)/3= 46.3 percent

The rule requires facilities to reduce HF emissions by 90 percent and
HCl emissions by 30 percent, so in this example the results from the
performance test indicate that the facility is in compliance with the
rule.

## Example Compliance Calculations for Facilities Manufacturing Clay Refractory Products Using a Batch Process

> 1\. *Example Calculation for Determining the Peak HF Emissions Period
> and Developing an Emissions Profile*

Batch cycle times for clay refractory kilns may be 12 hours or more.
Therefore, the rule contains provisions that allow the facility to only
test during the peak HF emissions period if the facility first develops
an emissions profile. The peak HF emissions period is the period of 3
consecutive hours during the batch during which the total HF mass
emission rate at the control device inlet is greater than during any
other 3-hour period of the batch.

Example 3: Calculation for Determining the Peak HF Emissions Period and
Developing an Emissions Profile

Table 6 presents data from an example test run that can be used to
demonstrate how to determine the peak HF emissions period and develop an
emissions profile.

**Table 6. Example Test Data for Developing an Emissions Profile for a**

Clay Refractory Kiln

  ------------------ -------------------------- --------------------------
  Hour               HF Mass Emission Rate at   Total Mass Emission Rate
                     Control Device Inlet       for 3‑Hour Period
                     (lbs/hr)                   

  1                  0.40                       

  2                  0.50                       

  3                  0.65                       1.55

  4                  0.82                       1.97

  5                  0.96                       2.43

  6                  1.25                       3.03

  7                  1.08                       3.29

  8                  0.87                       3.20

  9                  0.78                       2.73

  10                 0.63                       2.28

  11                 0.51                       1.92

  12                 0.42                       1.56

  13                 0.37                       1.30

  14                 0.29                       1.08

  15                 0.15                       0.81

  16                 0.11                       0.55

  17                 0.07                       0.32

  18                 0.04                       0.22
  ------------------ -------------------------- --------------------------

As shown in the right-hand column of Table 6, to develop an emissions
profile you have to calculate the total emission rate for each
consecutive 3-hour period of the batch. In this case, the value
represents the total emission rate for the 3-hour period ending at that
hour. For example, the total emission rate for hours 1 through 3 is:

0.40 + 0.50 + 0.65 = 1.55

For the example test run presented in Table 6, the highest total is
3.29. This peak emissions period occurs between hours 5 and 7. Because
this is the peak emissions period for this particular source, you will
only have to conduct testing during hours 5 through 7 of the batch for
all future testing of this kiln. You must begin testing at the beginning
of hour 5 and you may end testing at the end of hour 7.

> 2\. *Example Calculations for Demonstrating Compliance with the
> Emission Limits*

The emission limits for clay refractory kilns using a batch process are
based on a percentage reduction requirement. Facilities must achieve a
90 percent reduction in HF emissions and a 30 percent reduction in HCl
emissions. Example 4 presents the calculation procedures for
demonstrating compliance with the percentage reduction requirement.

Example 4: Calculations for Demonstrating Compliance with the Percentage
Reduction Requirements for a Batch Process

You should follow these steps to demonstrate compliance with the
percentage reduction requirements in the rule.

1.  Determine the hourly HF and HCl mass emission rates (lbs/hr) at the
    inlet and outlet of the control device using one of the approved
    test methods.

2.  Identify the period of 3 consecutive hours during the test run when
    the sum of the hourly HF emission rates at the inlet to the control
    device is greater than any other period of 3 consecutive hours. This
    3-hour period is referred to as the peak HF emissions period.

3.  Calculate the HF and HCl percentage reduction for each hour of the
    peak emissions period using Equation 2 of 63.9800(g)(2). For
    example, in Table 7 below, the percentage reduction for HF for Hour
    1 is calculated as follows:

(0.50 -- 0.050)/0.50 x 100 = 90 percent

4.  For each test run, calculate the average percentage reduction for HF
    and HCl for the 3-hour peak HF emissions period.

5.  Calculate the average HF and HCl percentage reduction for the two
    test runs. This is the percentage reduction for the performance
    test.

Table 7 presents data from an example test run that can be used to
demonstrate the procedure for showing compliance with the percentage
reduction requirements.

**Table 7. Example Test Run For Demonstrating Compliance with the**

**Percentage Reduction Requirements for a Clay Refractory Batch
Process**

+----+--------+-------+--------+---------+--------+--------+---------+
| Ho | HF     | 3     | HF     | HF      | HCl    | HCl    | HCl     |
| ur | Em     | -Hour | Em     | Per     | Em     | Em     | Per     |
|    | ission | Total | ission | centage | ission | ission | centage |
|    | Rate,  | HF    | Rate,  | Re      | Rate,  | Rate,  | Re      |
|    | Inlet  | Emi   | Outlet | duction | Inlet  | Outlet | duction |
|    | (l     | ssion | (l     |         | (l     |        |         |
|    | bs/hr) | Rate, | bs/hr) |         | bs/hr) | (l     |         |
|    |        | Inlet |        |         |        | bs/hr) |         |
+----+--------+-------+--------+---------+--------+--------+---------+
| 1  | 0.50   |       | 0.050  | 90      | 0.11   | 0.070  | 36.4    |
+----+--------+-------+--------+---------+--------+--------+---------+
| 2  | 0.60   |       | 0.054  | 91      | 0.13   | 0.090  | 30.8    |
+----+--------+-------+--------+---------+--------+--------+---------+
| 3  | 0.92   | 2.02  | 0.072  | 92.2    | 0.21   | 0.14   | 33.3    |
+----+--------+-------+--------+---------+--------+--------+---------+
| 4  | 1.03   | 2.55  | 0.075  | 92.7    | 0.32   | 0.22   | 31.3    |
+----+--------+-------+--------+---------+--------+--------+---------+
| 5  | 1.16   | 3.11  | 0.078  | 93.3    | 0.35   | 0.23   | 34.3    |
+----+--------+-------+--------+---------+--------+--------+---------+
| 6  | 1.23   | 3.42  | 0.083  | 93.3    | 0.38   | 0.25   | 34.2    |
+----+--------+-------+--------+---------+--------+--------+---------+
| 7  | 1.09   | 3.48  | 0.077  | 92.9    | 0.38   | 0.26   | 31.6    |
+----+--------+-------+--------+---------+--------+--------+---------+
| 8  | 0.87   | 3.19  | 0.073  | 91.6    | 0.31   | 0.21   | 32.3    |
+----+--------+-------+--------+---------+--------+--------+---------+
| 9  | 0.63   | 2.59  | 0.055  | 91.3    | 0.19   | 0.13   | 31.6    |
+----+--------+-------+--------+---------+--------+--------+---------+
| 10 | 0.48   | 1.98  | 0.043  | 91.0    | 0.12   | 0.08   | 33.3    |
+----+--------+-------+--------+---------+--------+--------+---------+
| 11 | 0.28   | 1.39  | 0.027  | 90.4    | 0.08   | 0.05   | 37.5    |
+----+--------+-------+--------+---------+--------+--------+---------+

The peak HF emissions period for this example test run occurs between
hours 5 and 7. Therefore, following step (4) above, you must determine
the average reduction for both HF and HCl during that 3-hour period.

For HF, the percentage reductions for hours 5, 6, and 7 are 93.3, 93.3
and 92.9, respectively. Therefore, the average percentage reduction for
HF for this test run is 93.2 percent.

For HCl, the percentage reduction for hours 5, 6 and 7 are 34.3, 34.2
and 31.6, respectively. Therefore, the average percentage reduction for
HCl for this test run is 33.4 percent.

Following step (5), next calculate the average reduction for the two
test runs. Assuming that the average percentage reduction for HF for the
peak emissions period for the second test run was 91.8, the average
percentage reduction for HF for the performance test is:

(93.2 + 91.8)/2 = 92.4

For HCl, the average percentage reduction for the peak emissions period
for the second test run was 31.8. Therefore, the average for the two
test runs was 32.6 percent.

The rule requires at least 90 percent reduction for HF and at least 30
percent reduction for HCl, therefore the results of the performance test
indicate the facility is in compliance with the rule.