EMISSION TESTING REQUIREMENTS FOR THE

REFRACTORY PRODUCTS NESHAP

# Introduction

The national emission standards for hazardous air pollutants (NESHAP)
for refractory products manufacturers were finalized on April 16, 2003
(Federal Register Volume 68, Number 73, pages 18730--18785). The NESHAP
include detailed requirements for emission testing for facilities that
are subject to the standard. Because these requirements are complex, and
vary by the type of product manufactured and the manufacturing process
used for a particular product type, the U.S. Environmental Protection
Agency (EPA) has developed this guidance on emission testing.

The guidance in this document is presented in two sections. The first
section presents testing requirements for facilities that manufacture
products containing organic hazardous air pollutants (HAP). The second
section discusses testing requirements for facilities manufacturing clay
refractory products. Each of these sections is further divided by
manufacturing process. Both refractory products containing organic HAP
and clay refractory products may be manufactured using either a
continuous or batch process. Because the testing requirements vary
depending upon the manufacturing process, we have included guidance for
both continuous and batch processes. We have attempted to make each
section self-contained, so that you do not have to search through a
section that is not applicable to your operation for guidance. For
example, if your facility only manufactures clay refractory products
using a continuous process, all of the information you need should be
contained in Section III.A.

Guidance for testing requirements for each product type and
manufacturing process is presented in the form of a series of questions
and responses. We have also incorporated tables and examples into the
guidance. Where applicable, we have referenced the appropriate section
of the rule that addresses each question so that you may also refer to
the rule for additional information or clarification. Table 4 of the
rule also summarizes testing requirements, so you may find additional
guidance there.

It is important that before you begin any testing program that you
perform a thorough maintenance check of your control device to ensure
that it is operating correctly. You should also calibrate all monitoring
systems that will be used to collect data for the purposes of
establishing operating limits, such as temperature monitoring systems
for an oxidizer or pressure drop monitoring systems for a scrubber. The
performance test is critical for not only demonstrating compliance with
the appropriate emission standards but also for establishing operating
limits that you will use to demonstrate continuing compliance with the
emission limits. Establishing operating limits that do not accurately
reflect your operations may result in future violations of the standard.
It is a good idea to do a "dry run" to ensure everything is operating
correctly. This should help minimize problems when conducting the actual
performance test.

+-----------------------------------------------------------------------+
| **Tip for Meeting Your Reporting Requirements:**                      |
|                                                                       |
| The Office of Air Quality Planning and Standards is developing        |
| recommendations and options for electronic web-based reporting of     |
| environmental regulatory requirements and for direct reporting of     |
| data to EPA. As currently planned, CERTS will allow facilities to     |
| report NESHAP compliance requirements through EPA\'s Central Data     |
| Exchange (CDX) system. You can access more information on CERTS at    |
| the following website: <http://www.epa.gov/ttn/atw/certs/>            |
+-----------------------------------------------------------------------+

# Testing Requirements for Facilities Manufacturing Products Containing Organic HAP

Facilities that are subject to these testing requirements include those
manufacturing any of 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 new and existing emission sources that are subject to these
requirements include the following:

-   Shape dryers

-   Curing ovens

-   Kilns

-   Coking ovens

-   Defumers.

New shape preheaters will also be subject to the emission limits
presented in the rule and will therefore be subject to the same testing
requirements.

As discussed earlier, testing requirements vary by the type of process
used to manufacture the product. Testing procedures for facilities
manufacturing the products listed above using a continuous process are
presented in Section II.A. Facilities manufacturing products using a
batch process have several options they may choose between to meet the
testing requirements. Procedures and guidance for facilities
manufacturing products using a batch process are presented in Section
II.B.

## Guidance on Testing Requirements for Facilities Manufacturing Refractory Products Containing Organic HAP Using a Continuous Process

Section 63.9824 of the NESHAP defines a continuous process as follows:

"Continuous process means a process that operates continuously. In a
continuous process unit, the materials or shapes that are processed are
either continuously charged (fed) to and discharged from the process
unit, or are charged and discharged at regular time intervals without
the process unit being shut down. Continuous thermal process units, such
as tunnel kilns, generally include temperature zones that are maintained
at relatively constant temperature and through which the materials or
shapes being processed are conveyed continuously or at regular time
intervals."

Guidance on testing requirements for facilities manufacturing refractory
products containing organic HAP using a continuous process is presented
below.

### Under what conditions should the testing be conducted?

For all emission tests, you are required to conduct the tests under
conditions that result in the maximum organic HAP emissions. For
continuous processes, the organic HAP emissions are a function of both
the HAP content of the refractory product and the rate at which the
refractory product is manufactured. The HAP content of the product is a
function not only of the HAP content of the resin, binders, or other
additives, but also of the amount of those constituents in the
refractory mix. Following is an example calculation for a facility that
manufactures two types of refractory products containing organic HAP.

*[Example 1: Calculating the Organic HAP Processing Rate for a
Continuous Process]{.underline}*

The example facility manufactures two types of resin-bonded refractory
products. To determine which product they should manufacture during the
test, the facility must determine the organic HAP processing rate for
each product.

-   Resin-bonded product 1---The curing rate for this product is 8,000
    lbs/hr. The resin contains 10 percent phenol. The refractory mix
    contains 5 percent resin. Therefore, the total organic HAP
    processing rate is

> 8,000 lbs/hr x 5/100 x 10/100 = 40 lbs/hr

-   Resin-bonded product 2---The curing rate for this product is 2,000
    lbs/hr. The resin contains 5 percent phenol and 25 percent ethylene
    glycol. The refractory mix contains 3 percent resin. The organic HAP
    processing rate for phenol is

> 2,000 lbs/hr x 3/100 x 5/100 = 3 lbs/hr

-   The organic HAP processing rate for ethylene glycol is

> 2,000 lbs/hr x 3/100 x 25/100 = 15 lbs/hr
>
> Therefore, the total organic HAP processing rate for product 2 is 18
> lbs/hour.

Of the two products, resin-bonded refractory product 1 has the higher
organic HAP processing rate. Therefore, the facility should conduct all
performance tests while manufacturing resin-bonded product 1, which is
the product with the maximum organic HAP processing rate.

### When is testing required?

Sections 63.9796 and 63.9798 of the rule specify when testing is
required. If you own or operate an existing source, you must conduct
your first emission test, known as the initial performance test, by
October 14, 2006. New sources must conduct their initial performance
test within 180 days of startup.

If you do not make any substantive changes to the operating limits
established in your operation, maintenance, and monitoring plan; you are
only required to conduct subsequent performance tests every five years.
However, as a manufacturer of refractory products containing organic
HAP, you are required to establish operating limits for the organic HAP
processing rate and the control device operating parameters specified in
your operation, maintenance, and monitoring plan. For example, if your
affected source is controlled with a thermal oxidizer, you must
establish an operating limit for the operating temperature of the
thermal oxidizer combustion chamber; if your affected source is
controlled with a catalytic oxidizer, you must establish an operating
limit for the temperature at the inlet to the catalyst bed. If you
change any of these operating limits you may be required to conduct an
additional performance test.

If you begin to manufacture products with an organic HAP processing rate
that exceeds the rate for the product you manufactured during your most
recent performance test by more than 10 percent, you must conduct a new
performance test while manufacturing that product. For example, if the
example facility discussed above in Section II.A.1 begins manufacturing
a product with an organic HAP processing rate of more than 44 lbs/hr
(i.e., 40 x 1.1), then the facility would have to conduct a new
performance test with that product. The performance test would establish
a new operating limit for the maximum allowable organic HAP processing
rate. This performance test should be done before the facility begins
normal production of that product.

Other changes in operating limits may also trigger the need for a
performance test. For example, if you established an operating limit for
your thermal oxidizer of 1600F and you decided to decrease the set
point to 1500F, then you would be required to conduct a performance
test to ensure that you are still meeting the emission limits for that
source at the reduced combustion chamber temperature.

The only other time you are required to conduct a performance test is if
you have an uncontrolled kiln that is used to process products
containing organic HAP and you decrease the operating temperature of the
curing oven or shape dryer that precedes the kiln in the process line.
If you decrease the operating temperature of the curing oven or shape
dryer, fewer of the organics may be driven off or emitted from the oven
or shape dryer. This may result in more of the organics being driven off
in the kiln, thereby increasing kiln emissions. If the kiln is
uncontrolled, total hydrocarbon (THC) emissions from the kiln could
exceed 20 ppm. Therefore, you must retest the kiln to ensure you are
still meeting the emission limits. As is the case with all testing, you
should retest the kiln while manufacturing the product with the maximum
organic HAP processing rate. If the process changes to the curing oven
or shape dryer have increased the THC concentration from the kiln to
greater than 20 ppm, then you will have to add a control device to the
kiln or make additional process changes to ensure the kiln is meeting
the THC emission limit.

Table 1 summarizes the schedule for performance test requirements for
facilities manufacturing refractory products containing organic HAP.

Table 1. Performance Test Schedule For Facilities Manufacturing

Products Containing Organic HAP

+---------------+-------------------------+----------------------------+
| **Emission    | **Reason for testing**  | **Schedule**               |
| source**      |                         |                            |
+---------------+-------------------------+----------------------------+
| Each curing   | Initial performance     | For existing sources, must |
| oven, shape   | test to demonstrate     | be conducted by            |
| dryer, kiln,  | initial compliance with | October 14, 2006           |
| coking oven,  | standard                |                            |
| defumer, and  |                         | For new sources, must be   |
| new shape     |                         | conducted within 180 days  |
| preheater     |                         | of startup                 |
+---------------+-------------------------+----------------------------+
|               | Follow-up performance   | At least every 5 years     |
|               | test to demonstrate     | after initial performance  |
|               | continuing compliance   | test                       |
|               | with standard           |                            |
+---------------+-------------------------+----------------------------+
|               | Demonstrate compliance  | Upon increase in maximum   |
|               | after change in         | allowable organic HAP      |
|               | operating limits        | processing rate            |
+---------------+-------------------------+----------------------------+
|               | Demonstrate compliance  | Upon decrease in           |
|               | after change in         | combustion chamber         |
|               | operating limits        | temperature of thermal     |
|               |                         | oxidizer or catalyst bed   |
|               |                         | inlet temperature of       |
|               |                         | catalytic oxidizer         |
+---------------+-------------------------+----------------------------+
| Uncontrolled  | Demonstrate compliance  | Upon decrease in operating |
| kilns         | after change in process | temperature of curing oven |
| preceded by   | parameters              | or shape dryer that        |
| curing oven   |                         | precedes the kiln in the   |
| or shape      |                         | process line               |
| preheater in  |                         |                            |
| the process   |                         |                            |
| line          |                         |                            |
+---------------+-------------------------+----------------------------+

### What pollutants and exhaust gas characteristics am I required to measure during the performance test and what test methods should I use?

The only pollutant you are required to measure during the test is THC.
If you are planning to comply with the standard by meeting the THC
concentration limits in the rule, you are required to measure the THC
concentration only at the outlet of the control device or in the stack.
However, if you are planning to comply with the standard by meeting the
THC percentage reduction requirement in the rule, you must measure the
THC concentration and determine the THC mass emissions rate at both the
inlet and outlet of the control device.

During the test, you must also measure the gas velocity and volumetric
flow rate, the gas molecular weight, and the gas moisture content. If
you are demonstrating compliance with the THC concentration limits
included in the rule, you must also measure the oxygen content of the
exhaust gas. Table 2 presents the exhaust gas parameters that must be
monitored during each test, the test method for each parameter, and the
measurement frequency for each parameter.

###### Table 2. Test Methods for Sources that Emit Organic HAP {#table-2.-test-methods-for-sources-that-emit-organic-hap .unnumbered}

  ------------------------ ---------------------- -----------------------
  **Exhaust gas            **Test method**        **Frequency**
  parameter**                                     

  Total hydrocarbon        EPA Method 25A^a^      Each minute during the
  concentration or mass                           test run
  emissions rate                                  

  Gas velocity and         EPA Method 2, 2A, 2C,  Each hour during the
  volumetric flow rate     2D, 2F, or 2G^a^       test run

  Gas molecular weight     EPA Method 3, 3A, or   As specified in the
                           3B ^a^; or ASME PTC    applicable test method
                           19.10-1981-Part 10     

  Gas moisture content     EPA Method 4 ^a^       As specified in the
                                                  applicable test method

  Oxygen concentration ^b^ EPA Method 3A^a^       Each minute during the
                                                  test run
  ------------------------ ---------------------- -----------------------

> ^a^ Test methods can be found in 40 CFR part 60, appendix A.
>
> ^b^ Only required for facilities choosing to comply with the standard
> by meeting the THC
>
> concentration limits.

### How many test runs am I required to conduct?

For each performance test, you must conduct at least three test runs.
Each test run must be at least 1 hour in duration.

### What process parameters do I have to record for the test?

For each test run, you are required to record each of the following
process parameters:

-   The organic HAP content of all resins, binders, and additives used
    in the refractory product being manufactured using data from Method
    311, material safety data sheets (MSDS), or product labels;

-   The percentage by weight of each resin, binder, and additive in the
    refractory product being manufactured using data from MSDS or
    product labels;

-   The production rate (e.g., pounds per hour) for the product being
    manufactured; and

-   The operating temperature of the affected source (i.e., the oven,
    kiln, etc.) in the highest temperature zone using the thermocouple
    sensor of the affected source.

The organic HAP content of each constituent, the percentage of each
constituent in the refractory product, and the production rate are all
used to determine the organic HAP processing rate for the product being
tested. The organic HAP content and percentage by weight of each resin,
binder, and additive used in the refractory products to be processed
generally are known prior to the start of the performance test.
Therefore, you should record the value of these parameters prior to the
start of the performance test. The actual production rate and operating
temperatures of the affected source should be recorded during each test
run of the performance test.

### What control device parameters do I have to measure during each test? 

If the emission source is equipped with a thermal oxidizer, you must
measure and record the combustion chamber temperature of the oxidizer at
least once every 15 minutes. If the source is equipped with a catalytic
oxidizer, you must measure and record the temperature at the inlet of
the catalyst bed at least once every 15 minutes. Note that this
measurement must be performed at the inlet to the catalyst bed and not
at the inlet to the oxidizer itself. After passing through the inlet to
the oxidizer, the waste gases typically pass through a preheat zone,
which raises the temperature to the minimum required for catalytic
oxidization. You must monitor the catalyst bed inlet temperature between
this preheat zone and the inlet to the catalyst bed.

### How do I demonstrate compliance with the THC concentration limit using the data from the performance test?

To demonstrate compliance with the THC concentration limit using the
performance test data, follow these steps:

a.  Calculate the average THC concentration for each hour of the
    performance test using the THC concentration values measured with
    EPA Method 25A.

b.  Calculate the average oxygen concentration for each hour of the test
    run.

c.  Using the average THC concentration and the average oxygen
    concentration for each hour, calculate the average THC concentration
    corrected to 18 percent oxygen, using the following equation
    (Equation 1, Section 63.9800(g)(1)):

> C~THC-C~ = (2.9 x C~THC~)/(20.9 -- C~O2~)
>
> where
>
> C~THC-C~ = THC concentration, corrected to 18 percent oxygen (parts
> per million by volume, dry basis \[ppmvd\])

C~THC~ = THC concentration, uncorrected (ppmvd)

C~O2~ = oxygen concentration (percent)

Example 2 demonstrates the procedures you should follow using data from
an example test run.

*[Example 2: Demonstrating Compliance with the THC Concentration Limits
Using the Performance Test Data for a Continuous Process]{.underline}*

Table 3 provides data for an example test run for a facility equipped
with a thermal oxidizer. The data include the THC concentrations, the
oxygen concentrations, and the combustion chamber temperature of the
oxidizer during the 1-hour run.

Using the data presented in Table 3, calculate the hourly average THC
concentration corrected to 18 percent oxygen. The uncorrected average
THC concentration for the 1‑hour test run is 14.9 ppmvd. The average
oxygen concentration for the test run is 18.4 percent. Using Equation 1
provided in Section 63.9800(g)(1) of the rule, the corrected THC
concentration for the test run is

> C~THC-C~ = (2.9 x 14.9)/(20.9-18.4) = 17.3 ppmvd

Assuming the corrected THC concentrations for the other two runs are
15.2 ppmvd and 17.8 ppmvd, the average corrected THC concentration for
the three test runs is 16.8 ppmvd. Therefore, the test indicates that
the facility is in compliance with the emission limit of 20 ppmvd THC,
corrected to 18 percent oxygen.

**Table 3. Example Test Run for Demonstrating Compliance**

**With the THC Concentration Limits**

+------------+------------------+------------------+-----------------+
| **Time**   | **THC            | **Oxygen         | **Combustion    |
|            | concentration    | concentration**  | chamber**       |
|            | (ppmvd)**        |                  |                 |
|            |                  | **(percent)**    | **temperature   |
|            |                  |                  | (F)**          |
+============+==================+==================+=================+
| 15:10      | 15               | 18               | 1540            |
+------------+------------------+------------------+-----------------+
| 15:11      | 16               | 19               |                 |
+------------+------------------+------------------+-----------------+
| 15:12      | 12               | 18               |                 |
+------------+------------------+------------------+-----------------+
| 15:13      | 18               | 17               |                 |
+------------+------------------+------------------+-----------------+
| 15:14      | 19               | 19               |                 |
+------------+------------------+------------------+-----------------+
| 15:15      | 20               | 17               |                 |
+------------+------------------+------------------+-----------------+
| 15:16      | 22               | 18               |                 |
+------------+------------------+------------------+-----------------+
| 15:17      | 21               | 18               |                 |
+------------+------------------+------------------+-----------------+
| 15:18      | 21               | 18               |                 |
+------------+------------------+------------------+-----------------+
| 15:19      | 22               | 19               |                 |
+------------+------------------+------------------+-----------------+
| 15:20      | 23               | 17               |                 |
+------------+------------------+------------------+-----------------+
| 15:21      | 20               | 17               |                 |
+------------+------------------+------------------+-----------------+
| 15:22      | 18               | 17               |                 |
+------------+------------------+------------------+-----------------+
| 15:23      | 17               | 17               |                 |
+------------+------------------+------------------+-----------------+
| 15:24      | 17               | 17               |                 |
+------------+------------------+------------------+-----------------+
| 15:25      | 16               | 19               | 1528            |
+------------+------------------+------------------+-----------------+
| 15:26      | 14               | 19               |                 |
+------------+------------------+------------------+-----------------+
| 15:27      | 14               | 20               |                 |
+------------+------------------+------------------+-----------------+
| 15:28      | 13               | 20               |                 |
+------------+------------------+------------------+-----------------+
| 15:29      | 10               | 20               |                 |
+------------+------------------+------------------+-----------------+
| 15:30      | 12               | 20               |                 |
+------------+------------------+------------------+-----------------+
| 15:31      | 12               | 18               |                 |
+------------+------------------+------------------+-----------------+
| 15:32      | 12               | 18               |                 |
+------------+------------------+------------------+-----------------+
| 15:33      | 12               | 18               |                 |
+------------+------------------+------------------+-----------------+
| 15:34      | 14               | 19               |                 |
+------------+------------------+------------------+-----------------+
| 15:35      | 14               | 17               |                 |
+------------+------------------+------------------+-----------------+
| 15:36      | 12               | 17               |                 |
+------------+------------------+------------------+-----------------+
| 15:37      | 9                | 17               |                 |
+------------+------------------+------------------+-----------------+
| 15:38      | 8                | 18               |                 |
+------------+------------------+------------------+-----------------+
| 15:39      | 8                | 19               |                 |
+------------+------------------+------------------+-----------------+
| 15:40      | 10               | 19               | 1538            |
+------------+------------------+------------------+-----------------+
| 15:41      | 12               | 19               |                 |
+------------+------------------+------------------+-----------------+
| 15:42      | 14               | 20               |                 |
+------------+------------------+------------------+-----------------+
| 15:43      | 15               | 21               |                 |
+------------+------------------+------------------+-----------------+
| 15:44      | 15               | 21               |                 |
+------------+------------------+------------------+-----------------+
| 15:45      | 17               | 18               |                 |
+------------+------------------+------------------+-----------------+
| 15:46      | 20               | 18               |                 |
+------------+------------------+------------------+-----------------+
| 15:47      | 21               | 19               |                 |
+------------+------------------+------------------+-----------------+
| 15:48      | 19               | 19               |                 |
+------------+------------------+------------------+-----------------+
| 15:49      | 18               | 19               |                 |
+------------+------------------+------------------+-----------------+
| 15:50      | 18               | 19               |                 |
+------------+------------------+------------------+-----------------+
| 15:51      | 16               | 19               |                 |
+------------+------------------+------------------+-----------------+
| 15:52      | 15               | 18               |                 |
+------------+------------------+------------------+-----------------+
| 15:53      | 15               | 17               |                 |
+------------+------------------+------------------+-----------------+
| 15:54      | 15               | 17               |                 |
+------------+------------------+------------------+-----------------+
| 15:55      | 14               | 17               | 1554            |
+------------+------------------+------------------+-----------------+
| 15:56      | 14               | 18               |                 |
+------------+------------------+------------------+-----------------+
| 15:57      | 13               | 18               |                 |
+------------+------------------+------------------+-----------------+
| 15:58      | 12               | 20               |                 |
+------------+------------------+------------------+-----------------+
| 15:59      | 12               | 19               |                 |
+------------+------------------+------------------+-----------------+
| 16:00      | 12               | 19               |                 |
+------------+------------------+------------------+-----------------+
| 16:01      | 11               | 19               |                 |
+------------+------------------+------------------+-----------------+
| 16:02      | 13               | 18               |                 |
+------------+------------------+------------------+-----------------+
| 16:03      | 13               | 17               |                 |
+------------+------------------+------------------+-----------------+
| 16:04      | 15               | 17               |                 |
+------------+------------------+------------------+-----------------+
| 16:05      | 15               | 19               |                 |
+------------+------------------+------------------+-----------------+
| 16:06      | 14               | 18               |                 |
+------------+------------------+------------------+-----------------+
| 16:07      | 12               | 18               |                 |
+------------+------------------+------------------+-----------------+
| 16:08      | 11               | 19               |                 |
+------------+------------------+------------------+-----------------+
| 16:09      | 10               | 17               | 1550            |
+------------+------------------+------------------+-----------------+
| Average    | 14.9             | 18.4             | 1542            |
+------------+------------------+------------------+-----------------+

### How do I demonstrate compliance with the percentage reduction requirement in the rule using the data from the performance test?

If you choose to meet the emission limits included in the rule by
meeting the percentage reduction requirement of 95 percent, you must
measure the THC concentration at the inlet and outlet of the control
device. Using the 1-minute 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. Using
the inlet and outlet mass emission rates, calculate the percentage
reduction achieved by the control device using Equation 2 in Section
63.9800(g)(2). Following are two example calculations.

*[Example 3: Calculating the Percentage Reduction for the Control Device
for a Continuous Process]{.underline}*

*[Run 1]{.underline}*

THC emission rate at inlet = 8.2 lb/hr

THC emission rate at outlet = 0.27 lb/hr

Percentage reduction = (8.2- 0.27)/8.2 = 96.7 percent reduction

Assuming percentage reductions for Runs 2 and 3 of 95.2 and 96.1
respectively, the average percentage reduction for the three test runs
is 96 percent. Therefore, the results from the performance test
demonstrate the facility is in compliance with the rule.

> *[Example 4: Results from Compliance Test Indicate Noncompliance with
> the Percentage Reduction Limits for a Continuous Process]{.underline}*
>
> *[Run 1]{.underline}*
>
> THC emission rate at inlet = 4.5 lb/hr
>
> THC emission rate at outlet = 0.51 lb/hr
>
> Percentage reduction = (4.5 -- 0.51)/4.5 = 88.7 percent
>
> *[Run 2]{.underline}*
>
> THC emission rate at inlet = 4.9 lb/hr
>
> THC emission rate at outlet = 0.48 lb/hr
>
> Percentage reduction = (4.9 --0.48)/4.9 = 90.2 percent
>
> *[Run 3]{.underline}*
>
> THC emission rate at inlet = 5.3 lb/hr
>
> THC emission rate at outlet = 0.47 lb/hr
>
> Percentage reduction = (5.3 -- 0.47)/5.3 = 91.1 percent
>
> In this example, the average THC percentage reduction for the three
> test runs is only 90.0 percent. This is less than the required
> reduction of 95 percent, so the performance test indicates the
> facility is not in compliance with the standard. This example
> demonstrates the importance of conducting a "dry run" to ensure
> everything is operating correctly. For example, the facility may need
> to operate its oxidizer at a higher temperature to ensure that it is
> achieving the 95 percent reduction requirement.
>
> If the results of your performance test indicate that you are not
> complying with the emission limits, you should contact your permitting
> authority immediately. The permitting authority will address any
> failed compliance tests on a case-by-case basis.

### What operating limits do I have to establish using the data from the performance test?

To demonstrate continuing compliance with the standard you must
establish operating limits for the maximum organic HAP processing rate
and the control device operating parameters specified in your operation,
maintenance, and monitoring plan (OM&M plan). If your affected source is
controlled with a thermal oxidizer, you must establish an operating
limit for the operating temperature of the thermal oxidizer combustion
chamber; if your affected source is controlled with a catalytic
oxidizer, you must establish an operating limit for the temperature at
the inlet to the catalyst bed. These operating limits must be
established using the data collected during the performance test.

Section 63.9794 of the rule specifies what you should include in your
OM&M plan. In summary, the OM&M plan should include a list of each
affected source and its associated control device, monitoring system
specifications, monitoring schedule, operating limits established for
each parameter during the most recent performance test, maintenance
procedures for the control device and CPMS components, and calibration
procedures for the CPMS. The purpose of the OM&M plan is to establish
routine procedures for you to use that will help you anticipate problems
and identify problems quickly when they do arise. This should help you
avoid violations of the standard.

### How do I establish the operating limit for the maximum allowable organic HAP processing rate using the performance test data?

An example of how to calculate the organic HAP processing rate is
provided in Section II.A.1 (Example 1). For each test run conducted
during the performance test, you should calculate the organic HAP
processing rate using the formulation data for any resins, binders, or
additives used in the refractory product; the percentage of the HAP
containing constituent in the refractory product; and the process feed
rate (i.e., the pounds of product per hour). The maximum allowable
organic HAP processing rate is the average of the organic HAP processing
rates for the three test runs plus 10 percent. Following is an example
of how to calculate the maximum organic HAP processing rate.

*[Example 5: Calculating the Maximum Allowable Organic HAP Processing
Rate for a Continuous Process]{.underline}*

Following up on the example provided earlier in Section II.A.1 (Example
1), the refractory product manufactured by the example facility that has
the greatest potential HAP emission rate is resin-bonded refractory
product 1. Therefore, the facility conducts the performance test while
manufacturing this product. Although the concentration of phenol in the
resin and the concentration of resin in the product is the same for each
of the three test runs, the production rate varies slightly for each
run. The organic HAP processing rate for each run is calculated as
follows:

*[Run 1]{.underline}*

Production rate is 8,100 lbs/hr

Organic HAP processing rate = 8,100 x 5/100 x 10/100 = 40.5 lbs/hr

*[Run 2]{.underline}*

Production rate is 7,800 lbs/hr

Organic HAP processing rate = 7,800 x 5/100 x 10/100 = 39 lbs/hr

*[Run 3]{.underline}*

Production rate is 8,250 lbs/hr

Organic HAP processing rate = 8,250 x 5/100 x 10/100 = 41.3 lbs/hr

Based on the average from the three test runs, the maximum organic HAP
processing rate for the facility is 40.3 lbs/hr. Therefore, to
demonstrate continuing compliance with the rule, the 3-hour average for
the maximum allowable organic HAP processing rate must not exceed 44.3
lbs/hr. This is equivalent to the average for the three test runs, 40.3
lbs/hour, plus 10 percent (40.3 x 1.1). If you exceed the operating
limit for the maximum allowable organic HAP processing rate, you must
conduct another performance test to establish a new operating limit.

### How do I establish the operating limit for the oxidizer temperature?

As discussed earlier, you must monitor the oxidizer temperature during
each test run. If the emission source is controlled by a thermal
oxidizer, you must monitor the combustion chamber temperature. If the
emission source is controlled by a catalytic oxidizer, you must monitor
the temperature at the inlet to the catalyst bed. You must monitor and
record the temperature at least every 15 minutes during each test run.

The operating limit for the oxidizer temperature is based on the average
temperature for the three test runs. For example, Table 3 (in Example 2,
Section II.A.7) shows the combustion chamber temperatures for an example
test run. The average temperature for the test run (i.e., Run 1) is
1542F. If the average temperature for Run 2 is 1565F and the average
temperature for Run 3 is 1555F, the average for the three test runs is
1554F. The operating limit for the combustion chamber temperature is
1529F, or 1554F minus 25F. The 25F factor allows for minor
fluctuations in thermal oxidizer operating temperature without
triggering a violation of the operating limit. To demonstrate continuous
compliance with the standard, the average combustion chamber temperature
for any 3-hour rolling period must not be less than 1529F.

### My facility is planning to use either process changes or an alternative control device (i.e., not a thermal or catalytic oxidizer) to meet the emission limits. What are the testing requirements for my facility and how do I establish operating limits for my facility?

In general, the testing requirements for your facility are the same as
those for other continuous processes presented in this section. However,
the parameters for which you establish operating limits may be different
than those discussed above (maximum organic HAP processing rate and
oxidizer temperature). Section 63.9800(i)(2) of the rule addresses the
requirements for facilities that plan to use process changes or a
control device other than an oxidizer to meet the emission limits.

If you choose to use an alternative control device or you wish to
propose an alternative monitoring method, it is your responsibility to
develop a testing and continuous compliance plan. The test plan must
include provisions for an emission test that clearly demonstrates that
you are meeting the emission limits specified in the rule. If you
propose an alternative monitoring method, the method must allow you to
clearly demonstrate that you are in continuous compliance with the
emission limits specified in the rule.

If you are planning to use alternative methods to meet the emission
limits, you must submit a request for approval of alternative monitoring
methods to the Administrator. This request must include a list of the
operating parameters that will be monitored during the performance test
and a description of how you will establish operating limits using the
operating parameter data from the performance test. If you exceed those
operating limits, you will have to perform another performance test to
demonstrate that you are still in compliance with the emission limits.

## Guidance on Testing Requirements for Manufacturers of Products Containing Organic HAP Using a Batch Process

Section 63.9824 of the NESHAP defines a batch process as follows:

"Batch process means a process in which a set of refractory shapes is
acted upon as a single unit according to a predetermined schedule,
during which none of the refractory shapes being processed are added or
removed. A batch process does not operate continuously."

If you are manufacturing refractory products containing organic HAP
using a batch process, you may choose from several options in meeting
the performance test requirements of the rule. These options and other
guidance on testing requirements are presented below.

### Under what conditions should testing be conducted?

For all emission tests, you are required to conduct the tests under
conditions that will result in the maximum organic HAP emissions. For
batch processes, the organic HAP emissions are a function of the HAP
content of the refractory product, the amount of product produced during
the batch, the process temperature, and the batch cycle time. However,
in the rule, the only parameters that you must consider in determining
the organic HAP processing rate are the HAP content of the product and
the amount of product produced during the batch.

The HAP content of the refractory product is a function not only of the
HAP content of the resins, binders, or other additives but also of the
amount of those constituents in the refractory mix. Following is an
example calculation for a facility that manufactures two types of
refractory products containing organic HAP using a batch process.

*[Example 6: Calculating the Organic HAP Processing Rate for a Batch
Process]{.underline}*

The facility manufactures two types of pitch-bonded refractory products.
To determine which product it should manufacture during the test, the
facility must determine the organic HAP processing rate for each
product.

-   Pitch-bonded product 1---Each batch of pitch-bonded product 1 is 8.5
    tons or 17,000 lbs. The pitch is assumed to consist of 100 percent
    polycyclic organic matter (POM). The refractory mix contains 8
    percent pitch. The organic HAP processing rate for POM is

> 17,000 lbs/batch x 8/100 = 1,360 lbs/batch

-   Pitch-bonded product 2---Each batch of pitch-bonded product 2 is 12
    tons or 24,000 lbs. The pitch is assumed to consist of 100 percent
    POM. The refractory mix contains 5 percent pitch. Therefore, the
    total organic HAP processing rate is

> 24,000 lbs/batch x 5/100 = 1,200 lbs/batch
>
> Of the two pitch-bonded products, product 1 has the highest organic
> HAP processing rate. Therefore, the facility should conduct all
> performance tests while manufacturing pitch-bonded product 1, which is
> the product with the maximum organic HAP processing rate.

### When is testing required?

Sections 63.9796 and 63.9798 of the rule specify when testing is
required. If you own or operate an existing source, you must conduct
your first emission test, known as the initial performance test, by
October 14, 2006. New sources must conduct their initial performance
test within 180 days of startup.

If you do not make any substantive changes to the operating limits
established in your OM&M (see Section 63.9794 for details on what
information should be included in your OM&M plan), you are only required
to conduct subsequent performance tests every 5 years. However, as a
manufacturer of refractory products containing organic HAP, you are
required to establish operating limits for the maximum allowable organic
HAP processing rate and the control device operating parameters
specified in your operation, maintenance, and monitoring plan. For
example, if your affected source is controlled with a thermal oxidizer,
you must establish an operating limit for the operating temperature of
the thermal oxidizer combustion chamber; if your affected source is
controlled with a catalytic oxidizer, you must establish an operating
limit for the temperature at the inlet to the catalyst bed. If you
change any of these operating limits you will be required to conduct a
new performance test.

If you begin to manufacture a product with an organic HAP processing
rate that exceeds the rate for the product that you manufactured during
your most recent performance test by more than 10 percent, that is, the
organic HAP processing rate is greater than the maximum allowable
organic HAP processing rate, you must conduct a new performance test
while manufacturing that product. For example, if the example facility
discussed above in II.B.1 (Example 6) begins manufacturing a product
with an organic HAP processing rate that is 10 percent or more greater
than pitch-bonded product 1 (in this example, 1,360 x 1.1 or 1,496
lbs/batch) the facility would have to conduct a new performance test
with that product. The performance test would be used to establish a new
operating limit for the maximum allowable organic HAP processing rate.
The facility would have to conduct the performance test before they
begin normal production of the product.

Other changes in operating limits may also trigger the need for a new
performance test. For example, if you established an operating limit for
your thermal oxidizer of 1560F and you decided to decrease the set
point to 1475F, you would be required to conduct a new performance test
to ensure that you are still meeting the emission limits for that source
at the reduced combustion chamber temperature.

The only other time you are required to conduct a performance test is if
you have an uncontrolled kiln that is used to process refractory
products containing organic HAP and you decrease the operating
temperature or batch cycle time of the curing oven or shape dryer that
precedes the kiln in the process line. If you decrease the operating
temperature or batch cycle time of the curing oven or shape dryer, fewer
of the organics may be driven off or emitted from the oven or dryer.
This may result in more of the organics being driven off in the kiln,
thereby increasing kiln emissions. If the kiln is uncontrolled, the
total hydrocarbon (THC) concentration from the kiln could exceed 20 ppm.
Therefore, you must retest the kiln to ensure you are still meeting the
emission limits. As is the case with all testing, you should retest the
kiln while manufacturing the product with the maximum organic HAP
processing rate. If the process changes to the curing oven or shape
dryer have increased the THC concentration from the kiln to greater than
20 ppm, then you will have to add a control device to the kiln or make
additional process changes to ensure the kiln is meeting the THC
emission limit.

Table 4 summarizes the schedule for the performance test requirements
for facilities manufacturing refractory products containing organic HAP
using a batch process.

###### Table 4. Performance Test Schedule for Manufacturers of Products {#table-4.-performance-test-schedule-for-manufacturers-of-products .unnumbered}

**Containing Organic HAP**

+--------------------+--------------------+----------------------------+
| **Emission         | **Reason for       | **Schedule**               |
| source**           | testing**          |                            |
+--------------------+--------------------+----------------------------+
| Each curing oven,  | Initial            | For existing sources, must |
| shape dryer, kiln, | performance test   | be conducted by October    |
| coking oven,       | to demonstrate     | 14, 2006                   |
| defumer, and new   | initial compliance |                            |
| shape preheater    | with standard      | For new sources, must be   |
|                    |                    | conducted within 180 days  |
|                    |                    | of startup                 |
+--------------------+--------------------+----------------------------+
|                    | Follow-up          | At least every 5 years     |
|                    | performance test   | after initial performance  |
|                    | to demonstrate     | test                       |
|                    | continuing         |                            |
|                    | compliance with    |                            |
|                    | standard           |                            |
+--------------------+--------------------+----------------------------+
|                    | Demonstrate        | Upon increase in maximum   |
|                    | compliance after   | organic HAP processing     |
|                    | change in          | rate of more than 10       |
|                    | operating limits   | percent                    |
+--------------------+--------------------+----------------------------+
|                    | Demonstrate        | Upon decrease in           |
|                    | compliance after   | combustion chamber         |
|                    | change in          | temperature of thermal     |
|                    | operating limits   | oxidizer or catalyst bed   |
|                    |                    | inlet temperature of       |
|                    |                    | catalytic oxidizer         |
+--------------------+--------------------+----------------------------+
| Uncontrolled kilns | Demonstrate        | Upon decrease in operating |
| preceded by curing | compliance after   | temperature or batch cycle |
| oven or shape      | change in process  | of curing oven or shape    |
| preheater          | parameters         | dryer that precedes the    |
|                    |                    | kiln in the process line   |
+--------------------+--------------------+----------------------------+

### What pollutants and exhaust gas characteristics am I required to measure during the performance test, and what test methods should I use?

The only pollutant you are required to measure during the test is THC.
If you are planning to comply with the standard by meeting the THC
concentration limits in the rule (that is, 20 ppm corrected to 18
percent oxygen), you are required to measure the THC concentration only
at the outlet of the control device or in the stack. However, if you are
planning to develop an emissions profile (Section II.B.5, Example 7),
you will have to measure the THC mass emission rate at the inlet of the
control device during the run that is used to develop the emissions
profile.

If you are planning to comply with the standard by meeting the THC
percentage reduction requirement in the rule, you are required to
measure the THC concentration and determine the THC mass emissions rate
at both the inlet and outlet of the control device.

During the test, you must also measure the gas velocity and volumetric
flow rate, the gas molecular weight, and the gas moisture content. If
you are demonstrating compliance with the THC concentration limits
included in the rule, you must also measure the oxygen content of the
exhaust gas. Table 5 presents the exhaust gas parameters that must be
monitored during each test, the test method for each parameter, the
monitoring frequency for each parameter, and the sampling location for
each compliance option.

**Table 5. Test Methods for Sources that Emit Organic HAP**

  ----------------------- ----------------------- -----------------------
  **Test parameters**     **Compliance option**   

                          **THC concentration     **THC percentage
                          limit of 20 ppmvd       reduction limit of 95
                          corrected to 18 percent percent**
                          oxygen**                

  Testing location        Outlet of control       Inlet and outlet of
                          device only unless      control device
                          developing emissions    
                          profile; must test      
                          inlet and outlet if     
                          developing emissions    
                          profile                 

  THC Concentration       EPA Method 25A^a^ each  EPA Method 25A^a^ each
                          minute during the test  minute during the test
                          run.                    run

  Oxygen concentration    EPA Method 3A^a^ each   Not required
                          minute during the test  
                          run.                    

  Gas molecular weight    EPA Method 3, 3A, or    EPA Method 3, 3A, or
                          3B^a^ or ASME PTC       3B^a^ or ASME PTC
                          19.10-1981-Part 10      19.10-1981-Part 10

  Gas velocity and        EPA Method 2, 2A, 2C,   EPA Method 2, 2A, 2C,
  volumetric flow rate    2D, 2F or 2G^a^ each    2D, 2F, or 2G^a^ each
                          hour during the test    hour during the test
                          run                     run

  Gas moisture content    EPA Method 4^a^ as      EPA Method 4^a^ as
                          specified in the        specified in the
                          applicable test method  applicable test method
  ----------------------- ----------------------- -----------------------

^a^ Test methods can be found in 40 CFR part 60, appendix A

### How many test runs am I required to conduct?

You must conduct at least two test runs. In most cases, you must conduct
the two test runs over separate batch cycles. However, the rule includes
a provision (see Section 63.9800(f)(3)) that allows facilities to
conduct the two runs over the same batch cycle under certain conditions.

As discussed earlier, you are required to conduct each performance test
while manufacturing the product that will generate the highest HAP
emissions. In the example presented earlier in Section II.B.1 (Example
6), the facility must conduct the performance test while manufacturing
pitch-bonded product 1, because that product has the highest organic HAP
processing rate of the two products the facility manufactures. However,
assume in this case that the facility only manufactures pitch-bonded
product 1 on rare occasions, and it never manufactures consecutive batch
cycles of that product. Manufacturing two consecutive batches of the
product would disrupt the facility's production schedule to the point
that it could not meet its production goals for the other refractory
products. In this case, the facility may conduct the two test runs
simultaneously over the same batch. That is, the facility can set up two
separate sampling trains and collect two sets of data. Each data set is
considered a separate test run. If you are planning to follow this
approach (i.e., conduct the two test runs simultaneously), you must
include the request and explanation in your Notification of Performance
Test.

### Each batch cycle for my curing oven lasts 25 hours. Do I have to test over the entire 25 hours? What options are available for testing my batch process?

We recognize that some of the batch cycles for the emission sources
covered by this rule may last a day or more and that testing over the
entire batch cycle could be very expensive. However, emissions for a
batch operation also tend to be much more variable than for a continuous
operation. As shown in Figure 1, the emission rate for a batch operation
typically increases as the process temperature of the emission source,
for example, the curing oven, increases. As the oven reaches its maximum
temperature, the emission rate also reaches its maximum level. In the
rule, this period of maximum emissions is known as the peak emissions
period. Finally, the emission rate typically decreases as the curing
oven temperature is decreased.

![](media/image1.wmf)

In an attempt to balance the potential cost of testing an entire batch
against the need to ensure that the facility is meeting the emission
limits during periods of highest emissions, we have included three
options in the rule for facilities with batch operations. These options
are

-   Conduct testing over the entire batch

-   Develop an emissions profile

-   Meet specific conditions for terminating the test before the end of
    the batch cycle.

Each of these options is discussed in more detail below.

*[Option 1: Conduct testing over the entire batch.]{.underline}* You may
choose to conduct each of your two test runs over the entire batch
cycle. If you choose this option, testing must begin when the source's
burners are ignited and testing cannot end until the batch is ended
(i.e., when the product is removed from the curing oven).

*[Option 2: Develop an emissions profile.]{.underline}* If you choose to
develop an emissions profile, you must test one batch cycle from the
beginning of the batch until the end. As with all performance tests, the
emissions profile should be developed when you are manufacturing the
product with the highest organic HAP processing rate. The THC mass
emission rates for this batch will be used to establish the peak
emissions period for THC for that source. The peak emissions period is
the period of 3 consecutive hours over which the total THC emission rate
at the control device inlet is greater than any other 3 consecutive
hours of the batch.

Example 7 demonstrates how to develop an emissions profile using data
from an example test run.

*[Example 7: Developing an Emissions Profile for Facilities
Manufacturing Products Containing Organic HAP]{.underline}*

Table 6 presents the results of an example test run for a batch
operation. In the example, testing was conducted over the entire 25
hours of the batch. Note that the right-hand column in the table
represents the total emission rate for the 3-hour period ending at that
hour.

###### Table 6. Example Test Data for Developing an Emissions Profile {#table-6.-example-test-data-for-developing-an-emissions-profile .unnumbered}

  ---------------------- ------------------------- -----------------------
  **Hour**               **THC Emission Rate at    **Total Emission Rate
                         Control Device Inlet      for 3-Hour Period
                         (lb/hour)**               (lb)**

  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
  ---------------------- ------------------------- -----------------------

Using the data presented in Table 6, the highest total emission rate for
any 3-hour period of the test is 53.8 lb. This peak emission rate occurs
between hours 9 and 11 of the test. Therefore, the peak THC emissions
period for this emission source is hours 9 through 11.

As long as you do not begin to manufacture a product that exceeds the
operating limit established for the maximum allowable organic HAP
processing rate, you may limit all future testing of this emission
source to hours 9 through 11 of the batch. You must begin testing at the
beginning of hour 9 and you may end testing at the end of hour 11.
However, if you begin manufacturing a product with an organic HAP
processing rate that is greater than the operating limit established for
the maximum allowable organic HAP processing rate, you must develop a
new emissions profile for the source.

*[Option 3: Terminate testing before the end of the batch]{.underline}*.
If you decide that you do not want to develop an emissions profile, but
you would like to terminate testing before the end of the batch, there
are conditions under which you may do so. At a minimum, you must
continue the test run until the operating temperature of the emission
source has been at its maximum level for at least 3 hours. For example,
if the maximum operating temperature for your curing oven during a batch
is 650F and you reach that temperature 6 hours into the batch, then you
would have to test for a minimum of 9 hours.

At the end of the 9 hours, you can terminate testing under the following
conditions:

a.  The hourly average THC mass emission rate at the outlet of the
    control device or in the stack has not increased during that 3-hour
    period (i.e., in this example, the hourly average THC emission rate
    did not increase between hours 6 and 9), and one of the following
    two conditions is met:

-   The hourly THC concentration at the outlet of the control device has
    not exceeded 20 ppmvd, corrected to 18 percent oxygen, during the
    3-hour period (in this example, between hours 6 and 9); or

-   The hourly average THC percentage reduction during the 3-hour period
    has been at least 95 percent.

b.  If the emission source is equipped with a thermal or catalytic
    oxidizer, at least 1 hour must have passed since the oxidizer
    temperature was reduced (see Section II.B.6 below).

Example 8 demonstrates the conditions under which you may terminate
testing using an example test run.

*[Example 8: How to Terminate Testing Before the End of the
Batch]{.underline}*

Table 7 presents data from an example test run that will be used to
illustrate when the testing may be terminated.

**Table 7. Example Test Run for Terminating Batch Testing**

+-----+-------+--------------+--------------+------------+------------+
| **  | **    | **THC        | **THC        | **THC      | **Curing   |
| Num | Batch | emission     | emission     | percentage | oven       |
| ber | cycle | rate at      | rate at      | r          | t          |
| ra  | h     | control      | control      | eduction** | emperature |
| nge | our** | device       | device       |            | (F)**     |
| CHA |       | inlet**      | outlet**     | **(%)**    |            |
| PTE |       |              |              |            |            |
| RCl |       | **(lbs       | **(lbs       |            |            |
| ock |       | THC/hr)**    | THC/hr)**    |            |            |
| tim |       |              |              |            |            |
| e** |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 1   | 1     | 0.2          | 0.05         | 75.0       | 150        |
| 100 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 1   | 2     | 0.4          | 0.07         | 82.5       | 350        |
| 200 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 1   | 3     | 1.1          | 0.09         | 91.8       | 450        |
| 300 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 1   | 4     | 2.4          | 0.11         | 95.4       | 500        |
| 400 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 1   | 5     | 4.3          | 0.12         | 97.2       | 575        |
| 500 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 1   | 6     | 4.9          | 0.14         | 97.1       | 650        |
| 600 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 1   | 7     | 4.7          | 0.13         | 97.2       | 650        |
| 700 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 1   | 8     | 4.1          | 0.12         | 97.1       | 650        |
| 800 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 1   | 9     | 3.6          | 0.11         | 96.9       | 650        |
| 900 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 2   | 10    | NR ^a^       | NR ^a^       | NR ^a^     | 600        |
| 000 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 2   | 11    | NR           | NR           | NR         | 600        |
| 100 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 2   | 12    | NR           | NR           | NR         | 600        |
| 200 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 2   | 13    | NR           | NR           | NR         | 600        |
| 300 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 0   | 14    | NR           | NR           | NR         | 600        |
| 000 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 0   | 15    | NR           | NR           | NR         | 520        |
| 100 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 0   | 16    | NR           | NR           | NR         | 450        |
| 200 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 0   | 17    | NR           | NR           | NR         | 380        |
| 300 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 0   | 18    | NR           | NR           | NR         | 300        |
| 400 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+
| 0   | 19    | NR           | NR           | NR         | 250        |
| 500 |       |              |              |            |            |
+-----+-------+--------------+--------------+------------+------------+

^a^ Testing is not required for remainder of batch.

In this example, the batch lasts for 19 hours, from 1100 hours one day
to 0500 the following day. However, at 1600 hours, the curing oven
reaches its maximum temperature of 650F. Over the next 3 hours, the THC
emission rate at the outlet decreases from 0.14 lbs/hour to 0.06 lbs/hr,
and the average THC percentage reduction is at least 95 percent.
Therefore, the facility may terminate testing at 1900 hours. Note that,
although the THC percentage reduction was less than 95 percent during
the period between 1100 and 1300 hours, it would not be considered a
violation of the standard because that period is not the peak emissions
period. For this example, the peak emissions period occurs between hours
1500 and 1700.

For the example test run presented in Table 7, the facility could have
also terminated testing at 1900 hours if the THC concentration at the
control device outlet was no greater than 20 ppmvd, corrected to 18
percent oxygen.

### If I use a thermal or catalytic oxidizer to control emissions from my batch process source, do I have to maintain the oxidizer temperature at the same level for the entire test?

The rule includes provisions that allow you to reduce the temperature of
the oxidizer or even shut the oxidizer off at a certain point in the
test (see item 13 of Table 4 of the rule). However, you must meet
several conditions to do so. These conditions are as follows:

a.  You are not using an emissions profile to limit testing to the
    3-hour peak emissions period;

b.  It has been at least 3 hours since the source you are testing (kiln,
    defumer, etc.) reached the maximum operating temperature;

c.  During each of the three 1-hour periods that has passed since the
    source reached its maximum operating temperature, you have achieved
    the emission limits for that source (THC concentration no greater
    than 20 ppmvd or THC percentage reduction of at least 95 percent);

d.  The hourly average THC mass emissions rate did not increase during
    the 3-hour period; and

e.  During each of the four 15-minute periods following the reduction in
    the oxidizer temperature, you met the emission limits for that
    source (THC concentration no greater than 20 ppm or THC percentage
    reduction of at least 95 percent).

If the source did not meet condition (e), then you must return the
temperature of the oxidizer to its normal operating temperature as soon
as possible. You must then maintain the oxidizer at that temperature for
at least 1 hour. Following this 1-hour period, you should continue the
test run until condition (e) is met. This would be considered a
violation of the emission limit if you did not return the oxidizer to
the temperature at which the oxidizer was operating during the peak
emissions period when compliance with the emission limit was
demonstrated.

### What process parameters do I have to record for the test?

For each test, you are required to record each of the of following
process parameters:

-   The organic HAP content of all resins, binders, and additives used
    in the refractory product being manufactured using data from Method
    311, MSDS, or product labels;

-   The percentage by weight of each resin, binder, and additive in the
    refractory product being manufactured from MSDS or product labels;

-   The production rate, in pounds of product per batch, for the product
    being manufactured;

-   The batch time; and

-   The hourly operating temperature of the affected source (i.e., the
    oven, kiln, defumer, etc.) using the thermocouple sensor of the
    affected source.

The organic HAP content of each constituent, the percentage of each
constituent in the refractory product, and the production rate are all
used to determine the organic HAP processing rate for the product being
tested. The organic HAP content and percentage by weight of each resin,
binder, and additive used in the refractory products to be processed
generally are known prior to the start of the batch cycle. The
production rate (i.e., the weight of the batch) and the batch cycle time
also are determined before the start of the batch cycle. Therefore, you
should record the value of these parameters prior to the start of the
performance test. The hourly operating temperature of the affected batch
process source should be recorded during each hour of each test run of
the performance test.

### What control device parameters do I have to measure during each test?

If the emission source is equipped with a thermal oxidizer, you must
monitor and record the combustion chamber temperature of the oxidizer at
least once every 15 minutes. If the source is equipped with a catalytic
oxidizer, you must monitor and record the temperature at the inlet of
the catalyst bed at least once every 15 minutes. Note that this
measurement must be performed at the inlet to the catalyst bed and not
at the inlet to the oxidizer itself. After passing through the inlet to
the oxidizer, the waste gases typically pass through a preheat zone,
which raises the temperature to the minimum required for catalytic
oxidization. You must monitor the catalyst bed inlet temperature between
this preheat zone and the inlet to the catalyst bed.

### How do I demonstrate compliance with the THC concentration limit using the data from the performance test?

Follow these steps to demonstrate compliance with the THC concentration
limits:

a.  For each test run, calculate the average THC concentration for each
    hour of the performance test using the 1-minute measurements.

b.  For each test run, calculate the average oxygen content for each
    hour of the performance test using the 1-minute measurements.

c.  Calculate the average hourly THC concentration corrected to18
    percent oxygen using Equation 1 of Section 63.9800(g)(6).

> For example, if the average hourly THC concentration is 11 ppmvd and
> the average oxygen concentration for that same hour is 19, the
> corrected THC concentration is as follows:
>
> Corrected THC = 2.9 x 11/(20.9 --19) = 16.8 ppmvd

d.  Using the corrected average hourly THC concentrations, determine the
    period of 3 consecutive hours during which the sum of the corrected
    THC concentrations is greater than any other 3-hour period of the
    test run.

e.  Calculate the average corrected THC concentration for the peak
    3-hour period for each test run.

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

The following example demonstrates how you can show compliance with the
THC concentration limits using data from an example test run.

*[Example 9: Demonstrating Compliance with the THC Concentration Limits
for a Batch Process]{.underline}*

Table 8 presents data from an example test run for a batch process;
these data demonstrate how to determine compliance with the THC
concentration limits using the test data. Note that the right-hand
column of the table represents the total THC concentration for the
3‑hour period ending at that hour.

###### Table 8. Example Test Run for Demonstrating Compliance {#table-8.-example-test-run-for-demonstrating-compliance .unnumbered}

**with THC Concentration Limits for a Batch Process**

  ---------- --------------- --------------- ----------------- ------------------
  **Hour**   **Average THC   **Average       **Average THC     **3-hour total of
             concentration   oxygen          concentration     corrected THC
             (ppmvd)**       concentration   corrected to 18%  concentrations**
                             (percent)**     oxygen (ppmvd)**  

  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

  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
  ---------- --------------- --------------- ----------------- ------------------

Based on the results for the example test run in Table 8, the 3-hour
peak occurred between hours 4 and 6. The average hourly-corrected THC
concentrations for those three hours are 18.8, 19.3, and 18.6.
Therefore, the average THC concentration for the peak period for the
test run is 18.9 ppmvd, corrected to 18 percent oxygen.

Assuming that the average THC concentration for the peak period for the
second test run was 16.5 ppmvd, the average for the performance test is
17.7 ppmvd, corrected to 18 percent oxygen. This is less than the limit
of 20 ppmvd, so the results of the performance test indicate the
facility is in compliance with the standard.

### How do I demonstrate compliance with the percentage reduction requirement in the rule using the data from the performance test?

To demonstrate compliance with the percentage reduction requirements,
follow these steps:

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

b.  Using the hourly THC mass emission rates at the control device,
    determine the 3‑hour period during the test when the sum of the
    emission rates is greater than any other 3-hour period.

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

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

Note that you are not required to continuously measure the oxygen
concentration if you are meeting the percentage reduction limits
specified in the rule.

Following is an example demonstrating how you may show compliance with
the THC percentage reduction requirements using data from an example
test run.

*[Example 10: Demonstrating Compliance with the THC Percentage Reduction
Limits for a Batch Process]{.underline}*

Using the data in Table 9, we have provided an example for demonstrating
compliance with the 95 percent reduction requirement in the rule.

###### Table 9. Example Test Run for Demonstrating Compliance with {#table-9.-example-test-run-for-demonstrating-compliance-with .unnumbered}

**the Percentage Reduction Requirement for Batch Process**

  ----------- -------------- -------------- -------------- --------------
  **Hour**    **THC emission **3-hour total **THC emission **Percentage
              rate, inlet    emission rate, rate, outlet   reduction**
              (lbs/hr)**     inlet          (lbs/hr)**     
                             (lbs/hr)**                    

  1           5                             0.2            96

  2           6                             0.3            95

  3           8              19             0.35           95.6

  4           9              23             0.4            95.6

  5           12             29             0.5            95.8

  6           11             32             0.4            96.4

  7           7              30             0.3            95.7

  8           6              24             0.3            95

  9           5              18             0.2            96

  10          3              14             0.1            96.7

  11          3              11             0.1            96.7
  ----------- -------------- -------------- -------------- --------------

The highest 3-hour total for the example test run occurs between hours 4
and 6, with a total emission rate at the inlet of 32. The percentage
reductions for hours 4, 5, and 6 are 95.6, 95.8, and 96.4 percent,
respectively. Therefore, the average percentage reduction for the test
run is 95.9 percent.

Assuming the average percentage THC reduction for the second test run
was 96.4 percent, the average percentage THC reduction for the
performance test would be 96.2 percent. Therefore, the results of the
performance test demonstrate the facility is in compliance with the
rule.

### What operating limits am I required to establish using the data from the performance test?

To demonstrate continuing compliance with the standard you must
establish operating limits for the maximum allowable organic HAP
processing rate and the control device operating parameters specified in
your operation, maintenance, and monitoring plan. If your affected
source is controlled with a thermal oxidizer, you must establish an
operating limit for the operating temperature of the thermal oxidizer
combustion chamber; if your affected source is controlled with a
catalytic oxidizer, you must establish an operating limit for the
temperature at the inlet to the catalyst bed. These operating limits
must be established using the data collected during the most recent
performance test.

### How do I establish the operating limit for the maximum allowable organic HAP processing rate for my batch process?

Section II.B.1 provides an example (see Example 6) of how to calculate
the organic HAP processing rate for a batch operation. For each test run
conducted during the performance test, calculate the organic HAP
processing rate using the formulation data for any binders, resins, or
additives used in the refractory product; the percentage of the HAP
containing constituent in the refractory product; and the production
rate for the batch. The operating limit for the maximum allowable
organic HAP processing rate is the average of the organic HAP processing
rate for the two test runs plus 10 percent. Following is an example of
how to calculate the operating limit for the maximum allowable organic
HAP processing rate.

*[Example 11: Calculating the Maximum Allowable Organic HAP Processing
Rate for a Batch Process]{.underline}*

Following up on Example 6 provided in II.B.1, pitch-bonded product 1 is
the product manufactured by the facility that has the greatest potential
HAP emission rate. Therefore, the facility conducts the performance test
while manufacturing that product. Although the concentration of pitch in
the product is the same for each test run, the production for each batch
varies slightly. The organic HAP processing rate for each test run is
calculated as follows:

*[Run 1]{.underline}*

The pitch is 100 percent POM. The refractory product mix contains 8
percent pitch. The actual production during the test run is 17,250
lbs/batch.

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

Total organic HAP processing rate for Run 1 is 1,380 lbs/batch.

*[Run 2]{.underline}*

During this run, the production was only 16,900 lbs/batch.

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

Total organic HAP processing rate for Run 2 is 1,352 lbs/batch

The operating limit for the maximum allowable organic HAP processing
rate is the average of the two test runs (i.e., 1,366 lbs/batch), plus
10 percent . Therefore, the operating limit for the maximum allowable
organic HAP processing rate for this example is 1,503 lbs/batch. If the
facility plans to begin manufacturing a product with a higher organic
HAP processing rate than 1,503 lbs/batch, then the facility must conduct
another performance test to establish a new operating limit and to
demonstrate that it is still in compliance with the standard.

### How do I establish the operating limit for the oxidizer temperature?

As discussed earlier, you must monitor the oxidizer temperature during
each test run. If the source is controlled by a thermal oxidizer, you
must monitor the combustion chamber temperature. If the source is
controlled by a catalytic oxidizer, you must monitor the temperature at
the inlet to the catalyst bed. You must monitor and record the
temperature at least every 15 minutes during each test run.

For a batch operation, the operating limit for the oxidizer is based on
the temperature of the oxidizer during the peak 3-hour emissions period.
(See Sections II.B.9 and II.B.10, Examples 9 and 10, for information on
how to determine the peak emissions period). 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 using the hourly averages.

The operating limit is based on the average for the two test runs.
Following is an example demonstrating how to calculate the operating
limit for the oxidizer temperature for a batch process.

*[Example 12: Establishing the Operating Limit for Oxidizer
Temperature]{.underline}*

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 six. The average combustion
chamber temperature for each hour is

Hour 4 -- 1575F

Hour 5 -- 1560F

Hour 6 -- 1565F

The average combustion chamber temperature for the peak 3-hour period is
1567F.

*[Run 2]{.underline}*

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

Hour 4 -- 1550F

Hour 5 -- 1565F

Hour 6 -- 1570F

The average combustion chamber temperature for Run 2 during the peak
3-hour period is 1562F.

The average combustion chamber temperature for the two test runs is
1565F. The operating limit for the oxidizer combustion chamber
temperature is the average for the two test runs, 1565F, minus 25F, or
1540F. Therefore, the thermal oxidizer must be operated at a
temperature of at least 1540F. The facility is in continuous compliance
with the standard as long as they maintain the minimum temperature of
the thermal oxidizer at 1540F. If the temperature of the thermal
oxidizer falls below 1540F, it is a violation of the standard.

### My facility is planning to use either process changes or an alternative control device (i.e., not a thermal or catalytic oxidizer) to meet the emission limits. What are the testing requirements for my facility and how do I establish operating limits for my facility?

In general, the testing requirements for your facility are the same as
those for other batch processes that are presented in this section.
However, the parameters for which you establish operating limits may be
different than those discussed above (i.e., maximum organic HAP
processing rate and oxidizer temperature). Section 63.9800(I)(2) of the
rule addresses the requirements for facilities that plan to use process
changes or a control device other than an oxidizer to meet the emission
limits.

If you choose to use an alternative control device or you wish to
propose an alternative monitoring method, it is your responsibility to
develop a testing and continuous compliance plan. The test plan must
include provisions for an emission test that clearly demonstrates that
you are meeting the emission levels included in the rule. If you propose
an alternative monitoring method, the method must allow you to clearly
demonstrate that you are in continuous compliance with the emission
limits included in the rule.

If you are planning to use alternative methods to meet the emission
limits, you must submit a request for approval of alternative monitoring
methods to the Administrator. This request must include a list of the
operating parameters that will be monitored during the performance test
and a description of how you will establish operating limits using the
operating parameter data from the performance test to demonstrate
compliance with the emission limits. If you exceed those operating
limits, you will have to perform another performance test to demonstrate
that you are still in compliance with the emission limits.

# Testing Requirements for Facilities Manufacturing Clay Refractory Products

These testing requirements apply to new kilns used to manufacture clay
refractory products using uncalcined clay. If you have an existing kiln
that manufactures clay refractory products or you use only calcined
clay, then you are not subject to these testing requirements.

If you are an existing major source using uncalcined clay, you are still
subject to the rule and you must meet the notification, reporting, and
recordkeeping requirements and the requirement to use natural gas as the
kiln fuel, as specified in item 4 of Table 3 of the rule.

Section 63.9824 of the NESHAP defines a clay refractory product as
follows:

*"Clay refractory product means a refractory product that contains at
least 10 percent uncalcined clay by weight prior to firing in a kiln. In
this definition, the term 'clay' means any of the following six
classifications of clay defined by the U.S. Geologic Survey: ball clay,
bentonite, common clay and shale, fire clay, fuller's earth, and
kaolin."*

Testing requirements for kilns processing clay refractory products vary
by the type of process used to manufacture the product. Testing
procedures for facilities manufacturing clay refractory products using a
continuous process are presented in Section III.A. Procedures and
guidance for facilities manufacturing clay refractory products using a
batch process are presented in Section III.B.

## Guidance on Testing Requirements for Facilities Manufacturing Clay Refractory Products Using a Continuous Process

Section 63.9824 of the NESHAP defines a continuous process as follows:

*"Continuous process means a process that operates continuously. In a
continuous process unit, the materials or shapes that are processed are
either continuously charged (fed) to and discharged from the process
unit, or are charged and discharged at regular time intervals without
the process unit being shut down. Continuous thermal process units, such
as tunnel kilns, generally include temperature zones that are maintained
at relatively constant temperature and through which the materials or
shapes being processed are conveyed continuously or at regular time
intervals."*

Guidance on testing requirements for kilns used to manufacture clay
refractory products using a continuous process is presented below.

### Under what conditions should testing be conducted?

Sections 63.9796 and 63.9798 of the rule specify when testing is
required. For all emission tests, you are required to conduct the tests
under the conditions that will result in the maximum emissions of HF and
HCl. For facilities manufacturing clay refractory products using a
continuous process, this means you should conduct testing while the kiln
is operating at its maximum production rate and while you are
manufacturing the product with the highest percentage of uncalcined
clay.

### When is testing required?

You must conduct the initial performance test on your new kiln within
180 days of startup.

If you do not make any substantive changes to the operating limits
established in your operation, maintenance, and monitoring plan, you are
only required to conduct subsequent performance tests every five years.
The operating limits for facilities manufacturing clay refractory
products vary by the type of control device you are using to control
emissions. These limits are established during the performance test. If
you modify your process or control device in such a way that the
operating limits you have established are no longer valid, then you need
to conduct testing to establish new operating limits and to demonstrate
that you are still in compliance with the emission limits while using
the new operating limits.

Table 10 summarizes the schedule for performance test requirements for
kilns used to manufacture refractory clay products.

###### Table 10. Performance Test Schedule for Clay Refractory Products Kilns {#table-10.-performance-test-schedule-for-clay-refractory-products-kilns .unnumbered}

  --------------------- ------------- ------------- ------------- -------------------------- ---------- -------------- ------------- -------------------- -- -- -- --
  **Emission source**                 **Reason for                                                      **Schedule**                                               
                                      testing**                                                                                                                    

  Each new kiln                                     Initial                                                            Must be                                     
                                                    performance                                                        conducted                                   
                                                    test to                                                            within 180                                  
                                                    demonstrate                                                        days of                                     
                                                    initial                                                            startup of                                  
                                                    compliance                                                         kiln                                        
                                                    with the                                                                                                       
                                                    standard                                                                                                       

                                                    Follow-up                                                          Five years                                  
                                                    performance                                                        after initial                               
                                                    test to                                                            performance                                 
                                                    demonstrate                                                        test                                        
                                                    continuing                                                                                                     
                                                    compliance                                                                                                     
                                                    with the                                                                                                       
                                                    standard                                                                                                       

  Each kiln equipped    Demonstrate                                                          Upon                                                                  
  with a dry limestone  compliance                                                           decrease                                                              
  adsorber (DLA)        after change                                                         in                                                                    
                        in operating                                                         pressure                                                              
                        limits                                                               drop                                                                  
                                                                                             across DLA                                                            

                                                    Demonstrate                                                        Upon decrease                               
                                                    compliance                                                         in limestone                                
                                                    after change                                                       feeder rate                                 
                                                    in operating                                                                                                   
                                                    limits                                                                                                         

                                                    Demonstrate                                                        Upon change                                 
                                                    compliance                                                         in grade of                                 
                                                    after change                                                       limestone                                   
                                                    in operating                                                       used                                        
                                                    limits                                                                                                         

  Each kiln equipped                  Demonstrate                                                       Upon decrease                                              
  with a dry injection                compliance                                                        in lime feeder                                             
  fabric filter (DIFF)                after change                                                      setting                                                    
  or dry lime scrubber/               in operating                                                                                                                 
  fabric filter                       limits                                                                                                                       
  (DLS/FF)                                                                                                                                                         

  Each kiln equipped                                              Demonstrate compliance                                             Upon decrease in              
  with a wet scrubber                                             after change in operating                                          average pressure              
                                                                  limits                                                             drop across the               
                                                                                                                                     scrubber                      

                                                                  Demonstrate compliance                                             Upon decrease in pH           
                                                                  after change in operating                                          of scrubber liquid            
                                                                  limits                                                                                           

                                                                  Demonstrate compliance                                             Upon decrease in              
                                                                  after change in operating                                          liquid flow rate              
                                                                  limits                                                                                           

                                                                  Demonstrate compliance                                             Upon decrease in              
                                                                  after change in operating                                          chemical feed rate            
                                                                  limits                                                                                           
  --------------------- ------------- ------------- ------------- -------------------------- ---------- -------------- ------------- -------------------- -- -- -- --

### What pollutants am I required to measure during the performance test and what test methods should I use?

You must measure the mass emissions rates of both hydrogen fluoride (HF)
and hydrochloric acid (HCl) during the performance test. If you are
planning to comply with the standard by meeting the production-based
emission rates for HF and HCl included in the rule, you are required to
measure these pollutants only at the outlet of the control device.
However, if you are planning to comply with the HF and HCl percentage
reduction requirements in the standard, you must measure the mass
emissions rates of HF and HCl at both the inlet and outlet to the
control device.

EPA has developed three test methods for measuring HF and HCl. These
methods are

-   Method 26A of 40 CFR part 60, appendix A

-   Method 26 of 40 CFR part 60, appendix A

-   Method 320 of 40 CFR part 63, appendix A.

You can choose to use either Method 26A or Method 320. You may also use
Method 26, but only if no acid particulate matter (PM) (for example, HF
or HCl dissolved in water droplets emitted by sources controlled by a
wet scrubber) is present in the exhaust gas.

If you choose to use Method 320, you must follow the analyte spiking
procedures that are presented in Section 13 of that method, unless you
can demonstrate that the complete spiking procedure has been conducted
at a source similar to the kiln you are testing.

Number range CHAPTERDuring the test, you must also measure the gas
velocity and volumetric flow rate, the gas molecular weight, and the gas
moisture content. Table 11 presents the exhaust gas parameters that must
be monitored during each test, the test method for each parameter, and
the monitoring frequency for each parameter.

###### Table 11. Test Methods for Clay Refractory Products Kilns {#table-11.-test-methods-for-clay-refractory-products-kilns .unnumbered}

  ------------------------ ----------------------- -----------------------
  **Exhaust gas            **Test method ^a^**     **Frequency**
  parameter**                                      

  Mass emission rates of   EPA Method 26 or 26A,   Each hour during the
  HF and HCl               or                      test run

                           EPA Method 320          As specified in the
                                                   test method

  Gas velocity and         EPA Method 2, 2A, 2C,   Each hour during the
  volumetric flow rate     2D, 2F, or 2G           test run

  Gas molecular weight     EPA Method 3, 3A, or    As specified in the
                           3B; or ASME PTC         applicable test method
                           19.10-1981-Part 10      

  Gas moisture content     EPA Method 4            As specified in the
                                                   applicable test method
  ------------------------ ----------------------- -----------------------

^a^ All EPA test methods can be found in 40 CFR part 60, appendix A.

### How many test runs am I required to conduct?

For each performance test, you must conduct at least three test runs.
Each test run must be at least 1 hour in duration.

### What process parameters do I have to record for the test?

For each test, you are required to record each of the following process
parameters:

-   Production rate in tons per hour of fired product;

-   Formulation data that includes the mass fraction of uncalcined clay
    in the products that are manufactured during the performance test;
    and

-   The processing rate for uncalcined clay (tons per hour) based on the
    production rate and formulation data.

### What control device parameters do I have to measure during each test run?

The control device parameters that you are required to measure during
the test vary depending upon the type of control device you are using.
Following are the list of parameters presented by control device.

a.  DLA---If the kiln is equipped with a dry lime adsorber, you must
    measure and record the pressure drop across the DLA every 15 minutes
    during the test. At least one week prior to the test, you must also
    establish the limestone feeder setting. During that one-week period
    and during the performance test, you must record the feeder setting.
    During the test, you must inspect the feed hopper, silo, and DLA to
    ensure that the limestone is free-flowing at all times during the
    test.

b.  DIFF or DLS/FF---If the kiln is equipped with a dry injection fabric
    filter or a dry lime scrubber/fabric filter, you must record the
    lime feeder setting for each of the three test runs. You must also
    inspect the feed hopper and silo during the performance test to
    ensure that lime is free-flowing at all times.

c.  Wet scrubber---If the kiln is equipped with a wet scrubber, you must
    measure and record each of the following parameters at least once
    every 15 minutes during the test run:

    -   Pressure drop across the scrubber

    -   Scrubber liquid pH

    -   Scrubber liquid flow rate

    -   Scrubber chemical feed rate if you use a chemical, such as lime
        or sodium bicarbonate, in your wet scrubber.

### How do I demonstrate compliance with the production-based HF and HCl emission limits using the data from the performance test?

If you have chosen to demonstrate compliance with the standard by
meeting the production-based emission limits, follow these steps:

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

b.  Using the calculations presented in the applicable test method,
    calculate the HF and HCl mass emission rates for each test run.

c.  Calculate the hourly production-based emission rate for HF and HCl
    using the following equation

> MP = ER/P (Equation 3, Section 63.9798(g)(3))

where

> MP = mass per unit of production of uncalcined clay processed (lb/ton)
>
> ER = mass emission rate of HF or HCl during each performance test
> (lb/hr)
>
> P = average uncalcined clay processing rate for the performance test
> (tons of
>
> uncalcined clay processed/hr).

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

If the 3-hour block average for HCl does not exceed 0.18 lb/ton of
uncalcined clay processed, then you are in compliance with the HCl
emission limit. If the 3-hour block average for HF does not exceed 0.038
lb/ton of uncalcined clay processed, then you are in compliance with the
HF emission limit.

Example 13 illustrates the procedure for demonstrating compliance with
the HF and HCl emission limits using data from an example performance
test.

*[Example 13: Demonstrating Compliance with the Production-Based
Emission Limits for HF and HCl]{.underline}*

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 by weight. Therefore, the
processing rate for the uncalcined clay is 2 tons/hr.

The facility used Method 26A to measure HF and HCl. Based on the results
from Method 26A, the emission rate for HCl during the first test run was
0.052 lb/hr. The emission rate for HF during the first test run was
0.070 lb/hr. Therefore, the production-based emission rates for HCl and
HF can be calculated as follows:

> 0.070 lbs/hr/2 tons/hr = 0.035 lbs HF/ton of uncalcined clay
>
> 0.052 lbs/hr/2 tons/hr = 0.026 lbs HCl/ton of uncalcined clay

For HF, the production-based emission rate for Run 2 was 0.036 lbs/ton,
and the rate for Run 3 was 0.038 lbs/ton. Therefore, the 3-hour block
average for the performance test was 0.036 lbs HF/ton of uncalcined
clay. This is less than the standard of 0.038 lbs/ton, so the facility
is in compliance with the HF emission rate.

Assuming that the production-based emission rate for HCl was 0.040
lbs/ton for Run 2 and 0.035 lbs/ton for Run 3, the 3-hour block average
for the performance test is 0.034 lbs HCl/ton of uncalcined clay. This
is less than the standard of 0.18, so the facility is in compliance with
the HCl emission rate.

### How do I demonstrate compliance with the HF and HCl percentage reduction requirements using data from the performance test? 

If you have chosen to demonstrate compliance with the standard by
meeting the percentage reduction requirements, follow these steps:

a.  Determine the mass emission rates for HF and HCl at both the inlet
    and outlet of the control device by following the calculations
    included in the applicable test method.

b.  Calculate the hourly HF and HCl percentage reduction using the
    following equation (Equation 2, Section 63.9800(g)(2)):

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

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

Example 14 demonstrates how to show compliance with the percentage
reduction requirements for HF and HCl using data from an example test
run.

*[Example 14: Demonstrating Compliance with the HF and HCl Percentage
Reduction Requirements]{.underline}*

The facility conducts three test runs using Method 26A.

*[Run 1]{.underline}*

HF inlet emission rate = 0.80 lbs/hr

HF outlet emission rate = 0.040 lbs/hr

HCl inlet emission rate = 0.40 lbs/hr

HCl outlet emission rate = 0.080 lbs/hr

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

> (0.80 -- 0.04)/0.8 x 100 = 95 percent

The percentage reduction for HCl for Run 1 can be calculated using the
same equation:

> (0.4 -- 0.080/0.4) x 100 = 80 percent

For HF, the percentage reductions for Runs 2 and 3 were 91.5 and 92.3
percent, respectively. Therefore, the 3-hour block average for the
performance test was 92.9 percent. This is greater than the percentage
reduction requirement of 90 percent for HF, so the facility is in
compliance with the HF standard.

For HCl, the percentage reductions for Runs 2 and 3 were 72 percent and
84 percent, respectively. Therefore, the 3-hour block average for the
performance test was 78.7 percent. This is greater than the percentage
reduction requirement of 30 percent for HCl, so the facility is also in
compliance with the HCl standard.

Suppose you operate a kiln that is controlled with a DLA, and the
surface of the limestone needs to be abraded. However, you are unaware
of this condition, you conduct the performance test, and the test
indicates noncompliance with the emission limit. In this case, you must
repeat the performance test. This example illustrates the importance of
proper maintenance in avoiding violations of the standard. As explained
previously, you should consider performing a dry run of the performance
test to ensure that control devices are working properly and to help
recognize other potential problems that could result in a failed
compliance test.

### Emissions from the kiln at my facility are controlled by a DLA. How do I establish operating limits using the data from the performance test?

To demonstrate continuing compliance with the standard, you must
establish operating limits for pressure drop and limestone feeder
setting during the performance test. The procedures you need to follow
for each operating limit are presented below.

a.  *Establishing the operating limit for pressure drop across the DLA.*
    As discussed earlier, you are required to monitor and record the
    pressure drop across the DLA at least every 15 minutes during each
    test run. For each hour of the test run, calculate the average
    pressure drop. The operating limit for the pressure drop is based on
    the average of the hourly average pressure drops for the three test
    runs.

b.  *Establishing the operating limit for limestone feeder setting.* You
    are required to establish the limestone feeder setting one week
    before you begin the performance test. During this 1-week period
    preceding the test, you must record and maintain the limestone
    feeder setting. You must also maintain the feeder setting at the
    same rate during the performance test and ensure that the limestone
    in the feed hopper, silo, and DLA is free-flowing at all times
    during the test. The setting used during the performance test will
    represent the operating limit for the limestone feeder.

### How do I establish the operating limits if my kiln is equipped with a DIFF or DLS/FF?

To demonstrate continuous compliance with the standard if your facility
is equipped with a DIFF or DLS/FF, you must follow all EPA guidance and
specifications for bag leak detection systems. You must also establish
the operating limit for the lime feeder setting.

To establish the operating limit for the lime feeder setting, you must
record the setting for each of the three test runs. The operating limit
for the setting is the average feed rate for the three test runs.

### How do I establish the operating limits if my kiln is equipped with a wet scrubber?

If your kiln is equipped with a wet scrubber, you must establish
operating limits for

-   Minimum scrubber pressure drop

-   Minimum scrubber liquid pH

-   Minimum scrubber liquid flow rate

-   Minimum scrubber chemical feed rate if you use a chemical, such as
    lime or sodium bicarbonate, in your wet scrubber.

The procedure for establishing these operating limits is detailed below.
The procedure is the same for each parameter.

a.  Monitor and record each parameter at least once every 15 minutes
    during the test run.

b.  Calculate the hourly average for each parameter for each hour of the
    test run.

c.  Calculate the average of each of the hourly averages for each
    parameter. This is the operating limit for that parameter.

### What if I want to change the operating limits I have established due to changes in my process or changes in the operation of my control device?

As explained previously, if you wish to change the operating limit you
have established for a particular parameter, you must conduct a new
performance test. Even if you have made process changes, such as a
reduction in the production rate, that you believe justify lowering the
operating limit for a parameter, you must conduct a new performance test
to demonstrate that you are still in compliance with the standard at the
lower operating limit. For example, if your kiln is controlled by a wet
scrubber and you wish to operate at a lower liquid flow rate than the
minimum level established during the performance test, you must conduct
a new performance test to establish a new operating limit. If the
results from the new performance test indicate you are still in
compliance with the standard, then you may establish a new operating
limit for the liquid flow rate based on the data from that performance
test.

## Guidance on Testing Requirements for Clay Refractory Batch Processes

Section 63.9824 of the NESHAP defines a batch process as follows:

*"Batch process means a process in which a set of refractory shapes is
acted upon as a single unit according to a predetermined schedule,
during which none of the refractory shapes being processed are added or
removed. A batch process does not operate continuously."*

Guidance for facilities manufacturing clay refractory products using a
batch process is presented below.

### Under what conditions should testing be conducted?

For all emission tests, you are required to conduct the tests under the
conditions that will result in the maximum emissions of HF and HCl. For
facilities manufacturing clay refractory products using a batch process,
this means you should conduct testing while the kiln is operating at its
maximum production rate and while you are manufacturing the product with
the highest percentage of uncalcined clay.

### When is testing required?

Sections 63.9796 and 63.9798 of the rule specify when testing is
required. You must conduct the initial performance test on your new kiln
within 180 days of startup.

If you do not make any substantive changes to the operating limits
established in your operation, maintenance, and monitoring plan, you are
only required to conduct subsequent performance tests every five years.
The operating limits for facilities manufacturing clay refractory
products vary by the type of control device you are using to control
emissions. These limits are established during the performance test.

If you modify your process or control device in such a way that the
operating limits you have established are no longer valid, then you must
conduct testing to establish new operating limits and to demonstrate
that you are still in compliance with the emission limits while using
the new operating limits.

Table 12 summarizes the schedule for performance test requirements for
kilns used to manufacture refractory clay products.

###### Table 12. Performance Test Schedule for Clay Refractory Products Kilns {#table-12.-performance-test-schedule-for-clay-refractory-products-kilns .unnumbered}

  --------------------- -------------------- ----------------------------- --
  **Emission source**   **Reason for         **Schedule**                  
                        testing**                                          

  Each new kiln         Initial performance  Must be conducted within 180  
                        test to demonstrate  days of startup of kiln       
                        initial compliance                                 
                        with the standard                                  

                        Follow-up            Five years after initial      
                        performance test to  performance test              
                        demonstrate                                        
                        continuing                                         
                        compliance with the                                
                        standard                                           

  Each kiln equipped    Demonstrate          Upon decrease in pressure     
  with a dry limestone  compliance after     drop across DLA               
  adsorber (DLA)        change in operating                                
                        limits                                             

                        Demonstrate          Upon decrease in limestone    
                        compliance after     feeder rate                   
                        change in operating                                
                        limits                                             

                        Demonstrate          Upon change in grade of       
                        compliance after     limestone used                
                        change in operating                                
                        limits                                             

  Each kiln equipped    Demonstrate          Upon decrease in lime feeder  
  with a dry injection  compliance after     setting                       
  fabric filter (DIFF)  change in operating                                
  or dry lime           limits                                             
  scrubber/fabric                                                          
  filter (DLS/FF)                                                          

  Each kiln equipped    Demonstrate          Upon decrease in average      
  with a wet scrubber   compliance after     pressure drop across the      
                        change in operating  scrubber                      
                        limits                                             

                        Demonstrate          Upon decrease in pH of        
                        compliance after     scrubber liquid               
                        change in operating                                
                        limits                                             

                        Demonstrate          Upon decrease in liquid flow  
                        compliance after     rate                          
                        change in operating                                
                        limits                                             

                        Demonstrate          Upon decrease in chemical     
                        compliance after     feed rate if you use a        
                        change in operating  chemical, such as lime or     
                        limits               sodium bicarbonate, in your   
                                             wet scrubber                  
  --------------------- -------------------- ----------------------------- --

### What pollutants am I required to measure during the performance test and what test methods should I use?

You must measure both HF and HCl at both the inlet and outlet of the
control device during the performance test.

EPA has developed three test methods that may be used for measuring HF
and HCl. These methods are

-   Method 26A of 40 CFR part 60, appendix A

-   Method 26 of 40 CFR part 60, appendix A

-   Method 320 of 40 CFR part 63, appendix A.

You can choose to use either Method 26A or Method 320. You may also use
Method 26, but only if no acid particulate matter (PM) (for example, HF
or HCl dissolved in water droplets emitted by sources controlled by a
wet scrubber) is present in the exhaust gas.

If you choose to use Method 320, you must follow the analyte spiking
procedures that are presented in Section 13 of that method, unless you
can demonstrate that the complete spiking procedure has been conducted
at a source similar to the kiln you are testing.

Number range CHAPTERDuring the test, you must also measure the gas
velocity and volumetric flow rate, the gas molecular weight, and the gas
moisture content. Table 13 presents the exhaust gas parameters that must
be monitored during each test, the test method for each parameter, and
the monitoring frequency for each parameter.

###### Table 13. Test Methods for Clay Refractory Products Kilns {#table-13.-test-methods-for-clay-refractory-products-kilns .unnumbered}

  ------------------------- -------- --------------------- ----------- --------------------- --
  **Exhaust gas parameter**          **Test method ^a^**               **Frequency**         

  Mass emission rates of HF          EPA Method 26 or 26A,             Each hour during the  
  and HCl                            or                                test run              

                            EPA                            As                                
                            Method                         specified                         
                            320                            in the test                       
                                                           method                            

  Gas velocity and                   EPA Method 2, 2A, 2C,             Each hour during the  
  volumetric flow rate               2D, 2F, or 2G                     test run              

  Gas molecular weight               EPA Method 3, 3A, or              As specified in the   
                                     3B; or ASME PTC                   applicable test       
                                     19.10-1981-Part 10                method                

  Gas moisture content               EPA Method 4                      As specified in the   
                                                                       applicable test       
                                                                       method                
  ------------------------- -------- --------------------- ----------- --------------------- --

> ^a^All EPA test methods can be found in 40 CFR part 60, appendix A.

### How many test runs am I required to conduct?

You must conduct at least two test runs. In most cases, you must conduct
the two test runs over separate batch cycles. However, Section
63.9800(f)(3) and (4) contains a provision that allows facilities to
conduct the two runs over the same batch cycle under certain conditions.

As discussed earlier, you must conduct the performance test while the
kiln is operating at its maximum production rate. For example, the kiln
may operate at a rate of 4,000 tons/batch for most clay refractory
products, but the facility manufactures one product where the kiln
operates at 5,000 tons/batch. Therefore, the facility should conduct the
performance test while manufacturing the product with a production rate
of 5,000 tons/batch. However, the facility rarely manufactures the
product that is produced at a rate of 5,000 tons/batch and it never
manufactures consecutive batch cycles of the product. Manufacturing two
consecutive batches of that product would disrupt the facility's
production schedule. In this case, the facility may conduct the two test
runs simultaneously over the same batch. That is, the facility can set
up two separate sampling trains and collect two sets of data. Each data
set is considered a separate test run.

If you do wish to conduct the two test runs simultaneously over the same
batch, you must include the request and the rationale in your
Notification of Performance Test.

### Each batch cycle for my kiln lasts 15 hours. Do I have to test over the entire 15 hours? What options are available for testing my batch process?

We recognize that some of the batch cycles for clay refractory kilns may
be quite long and that testing over the entire batch cycle could be very
expensive. However, emissions for a batch operation also tend to be much
more variable than for a continuous operation.

For those facilities manufacturing clay refractories using a batch
process, we have included two options for testing in the rule. The first
option is to test over the entire batch cycle. If you choose this
option, you must conduct a series of 1-hour runs that begin with the
start of the batch cycle and continue until the end of the batch cycle.

The second option is to develop an emissions profile. The purpose of the
emissions profile is to identify the peak emissions period for the
batch. For clay refractories, this peak emissions period is based on the
hourly HF emission rates at the inlet of the control device.

If you elect to develop an emissions profile, you must test one batch
cycle from the beginning of the batch until the end with a series of
1-hour test runs. The data from this batch will be used to identify the
peak emissions period for HF. The peak emissions period is the period of
3 consecutive hours over which the total HF mass emission rate is
greater than any other 3 consecutive hours of the batch. Once you have
identified the peak HF emissions period, you only have to test during
that 3-hour period when conducting future tests.

Example 15 demonstrates the procedure for developing an emissions
profile using data from an example test run.

*[Example 15: Developing an Emissions Profile for a Clay Refractory
Kiln]{.underline}*

Table 14 presents the results of an example test run for a clay
refractory kiln that operates as a batch process. In the example,
testing was conducted over the entire 18 hours of the batch. Note that
the total emission rate in the right-hand column represents the total
emission rate for the 3-hour period ending at that hour.

###### Table 14. Example Test Data for Developing an Emissions Profile {#table-14.-example-test-data-for-developing-an-emissions-profile .unnumbered}

**for a Clay Refractory Kiln**

  --------------------- ------------------------ ------------------------
  **Hour**              **HF emission rate at    **Total emission rate
                        control device inlet     for 3‑hour period
                        (lbs/hour)**             (lbs)**

  1                     0.4                      

  2                     0.5                      

  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                     1.3

  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
  --------------------- ------------------------ ------------------------

Using the data presented in Table 14, the highest total emission rate
for any 3-hour period of the test run is 3.29. This peak emission rate
occurs between hours 5 and 7. Therefore, the peak HF emissions period
for this emission source is hours 5 through 7.

For all future testing of this kiln, you only have to conduct testing
during hours 5 through 7 of the batch. You must begin testing at the
beginning of hour 5 and you may end testing at the end of hour 7.

### What process parameters do I have to record for the test?

For batch operations, the only process parameters you must record for
the test is the production rate (tons/batch) for each test run and the
percentage of uncalcined clay in the product for each test run..

### What control device parameters do I have to monitor during each test?

The control device parameters that you are required to measure during
the test vary depending upon the type of control device you are using.
Following are the list of parameters presented by control device.

a.  DLA---If the kiln is equipped with a dry lime adsorber, you must
    measure and record the pressure drop across the DLA every 15 minutes
    during the test. At least one week prior to the test, you must also
    establish the limestone feeder setting. During that one-week period
    and during the performance test, you must record the feeder setting.
    During the test, you must inspect the feed hopper, silo, and DLA to
    ensure that the limestone is free-flowing at all times during the
    test.

b.  DIFF or DLS/FF---If the kiln is equipped with a dry injection fabric
    filter or a dry lime scrubber/fabric filter, you must record the
    lime feeder setting for each of the three test runs. You must also
    inspect the feed hopper and silo during the performance test to
    ensure that lime is free-flowing at all times.

c.  Wet scrubber---If the kiln is equipped with a wet scrubber, you must
    measure and record each of the following parameters at least once
    every 15 minutes during the test run:

    -   Pressure drop across the scrubber

    -   Scrubber liquid pH

    -   Scrubber liquid flow rate

    -   Scrubber chemical feed rate if you use a chemical, such as lime
        or sodium bicarbonate, in your wet scrubber.

### How do I demonstrate compliance with the HF and HCl percentage reduction requirements in the rule using the data from the performance test?

Follow these steps to demonstrate compliance with the percentage
reduction requirements in the rule.

a.  Determine the hourly HF and HCl mass emission rates (lbs/hr) at the
    inlet and outlet of the control device by following the calculations
    included in the applicable test method.

b.  Identify the period of 3 consecutive hours during the test run when
    the sum of the hourly HF mass 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.

c.  Calculate the HF and HCl percentage reduction for each hour of the
    peak emissions period using Equation 2 of 63.9800(g)(2).

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

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

Example 16 demonstrates how to show compliance with the percentage
reduction requirements for HF and HCL using data from an example test
run.

*[Example 16: Demonstrating Compliance with the Percentage Reduction
Requirements for a Clay Refractory Batch Process]{.underline}*

Table 15 presents data from an example test run that will be used to
show how to demonstrate compliance with the percentage reduction
requirements.

Table 15. Example Test Run for Demonstrating Compliance with the
Percentage Reduction Requirements for a Clay Refractory Batch Process

+-----+--------+--------+--------+--------+--------+--------+--------+
| **  | **HF   | **     | **HF   | **HF   | **HCl  | **HCl  | **HCl  |
| Hou | em     | 3-hour | em     | perc   | em     | em     | perc   |
| r** | ission | total  | ission | entage | ission | ission | entage |
|     | rate,  | HF     | rate,  | reduc  | rate,  | rate,  | reduc  |
|     | inlet  | em     | outlet | tion** | inlet  | ou     | tion** |
|     | (lbs/h | ission | (lbs   |        | (lbs   | tlet** |        |
|     | our)** | rate,  | /hr)** |        | /hr)** |        |        |
|     |        | inlet  |        |        |        | **(lbs |        |
|     |        | (lbs   |        |        |        | /hr)** |        |
|     |        | /hr)** |        |        |        |        |        |
+-----+--------+--------+--------+--------+--------+--------+--------+
| 1   | 0.5    |        | 0.05   | 90     | 0.11   | 0.07   | 36.4   |
+-----+--------+--------+--------+--------+--------+--------+--------+
| 2   | 0.6    |        | 0.054  | 91     | 0.13   | 0.09   | 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 the example test run presented in Table
15 occurs between hours 5 and 7. Therefore, 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 reductions 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.

Assuming that the average percentage reduction for HF for the second
test run was 91.8, the average for the performance test is 92.4. This is
greater than the required percentage reduction of 90 percent, so the
results from the performance test indicate the facility is in compliance
with the emission limit for HF.

Assuming that the average percentage reduction for HCl for the second
test run was 31.8 percent, the average for the performance test is 32.6
percent. This is greater than the required percentage reduction of 30
percent, so the results from the performance test indicate that the
facility is also in compliance with the emission limit for HCl.

### Emissions from the kiln at my facility are controlled by a DLA. How do I establish operating limits using the data from the performance test?

To demonstrate continuing compliance with the standard you must
establish operating limits for pressure drop and limestone feeder
setting during the performance test. The procedures you need to follow
for each operating limit are presented below.

a.  *Establishing the operating limit for pressure drop across the DLA*.
    As discussed earlier, you are required to monitor and record the
    pressure drop across the DLA at least every 15 minutes during each
    test run. For each hour of the test run, calculate the average
    pressure drop. The operating limit for the pressure drop is based on
    the average of the hourly average pressure drops for the two test
    runs.

b.  *Establishing the operating limit for limestone feeder setting*. You
    are required to establish the limestone feeder setting one week
    before you begin the performance test. During this 1-week period
    preceding the test, you must record and maintain the limestone
    feeder setting. You must also maintain the feeder setting at the
    same rate during the performance test and ensure that the limestone
    in the feed hopper, silo, and DLA is free-flowing at all times
    during the test. The setting used during the performance test will
    represent the operating limit for the limestone feeder.

### How do I establish the operating limits if my kiln is equipped with a DIFF or DLS/FF?

To demonstrate continuous compliance with the standard if your facility
is equipped with a DIFF or DLS/FF, you must follow all EPA guidance and
specifications for bag leak detection systems. You must also establish
the operating limit for the lime feeder setting.

To establish the operating limit for the lime feeder setting, you must
record the setting for each of the two test runs. The operating limit
for the setting is the average feed rate for the two test runs.

### How do I establish the operating limits if my kiln is equipped with a wet scrubber?

If your kiln is equipped with a wet scrubber, you must establish
operating limits for

-   Minimum scrubber pressure drop

-   Minimum scrubber liquid pH

-   Minimum scrubber liquid flow rate

-   Minimum scrubber chemical feed rate if you use a chemical, such as
    lime or sodium bicarbonate, in your wet scrubber.

The procedure for establishing each of these operating limits is
detailed below. The procedure is the same for each parameter:

a.  Monitor and record each parameter at least once every 15 minutes
    during the test run.

b.  Calculate the hourly average for each parameter for each hour of the
    test run.

c.  Calculate the average of each of the hourly averages for each
    parameter. This is the operating limit for that parameter.

### What if I want to change the operating limits I have established due to changes in my process or changes in the operation of my control device?

As stated previously, if you wish to change the operating limit you have
established for a particular parameter, you must conduct another
performance test. For example, if your kiln is controlled by a wet
scrubber and you wish to operate at a lower liquid flow rate than the
minimum level established during the performance test, you must conduct
a new performance test to establish a new operating limit. Your kiln may
be equipped with a DIFF and you believe can still achieve the emission
limits if you operate at a lower lime feeder setting. You would also
have to conduct a new performance test in this situation to establish a
new operating limit for the lime feeder setting and to ensure that you
are still meeting the emission limits at the lower setting. If the
results from the new performance test indicate you are still in
compliance with the standard, then you may establish a new operating
limit for the liquid flow rate or the lime feeder setting based on the
data from that performance test.