Date: November 6 , 2014

To: Jeff Telander, EPA/OAQPS/SPPD

From: Gabrielle Raymond and Kristin Sroka

, RTI International

Subject: Determination of “Non

- Detect” Test Data for the BSCP Proposed Rule

I. I ntroduction

In accordance with section 112 of the Clean Air Act (CAA), the U.S. Environmental Protection Agency (EPA) established national emission standards for hazardous air pollutants (NESHAP) on May 16, 2003, for the brick and structural clay products (BSCP) manufacturing industry. The NESHAP regulated emissions of hydrogen fluoride (HF)

, hydrogen chloride (HCl), and particulate matter (PM)

— a surrogate for hazardous air pollutant (HAP) metals

— from tunnel kilns located at BSCP facilities

. On March 13, 2007, the D.C. Circuit Court vac ated the emission standards for BSCP manufacturing due to issues associated with the methodology used to determine the minimum regulatory “floors” for new and existing units. 1 Therefore, the EPA is proposing new standards for BSCP manufacturing, including standards for HF, HCl, chlorine (Cl 2 ), mercury (Hg), and non

- Hg HAP metals (or PM surrogate)

. The objective of this

memo randum is to describe the determination of “non

- detect” EPA Method 29 (multi

- metals) and EPA Method 23 (dioxin/furan) test data for ev aluation in the setting of numeric MACT floor standard s versus establishing work practice standard s for the BSCP p roposed r ule.

II. Sources and Pollutants Evaluated

For BSCP tunnel kilns

, the run flags for each HAP metal

, including Hg

, and each dioxin/furan toxic equivalent (TEQ) 2 test run w ere evaluated to determine the “non

- detect ” status of the run

. In addition, f or BSCP dryers

, each dioxin/furan run flag was evaluated to determine the “non

- detect” status of the run

. The guidelines from EPA’s memo randum Determination of “non

- detect” from EPA Method 29 (multi

- metals) and EPA Method 23 (dioxin/furan) test data when evaluating the setting of MACT floors versus estab lishing work practice standards (Johnson

, 2014) were followed for each evaluation

.

1 Sierra Club v. EPA , 479 F.3d 875 (D.C. Cir. 2007).
2 For these runs, d ioxin/furan emissions are expressed in terms of 2,3,7,8

- tetrachlorodibenzo

- p

- dioxin ( TCDD ) toxic equivalents ( TEQ )

.2 III. Definitions from Guidance Memo randum (Johnson , 2014)

The following definitions appear in the Johnson guidance memorandum (2014) and also apply to this memorandum:

ADL (Above Detection Limit) : R esults from the lab sh ow measured values above the MDL. (Be sure to distinguish reported values as being above the MDL versus above the RL or other lab ‘confidence’ level).

BDL (Below Detection Limit) : A laboratory result where detectable amounts of an individual pollutant or congener are not found. Again, evaluate the data to ensure BDL means “below MDL” and not “below RL” or some other ‘confidence’ level.

DLL (Detection Limit Limited) : A test result where some fractions of the analysis return detectable amounts of a pollut ant or congener (above MDL), while other fractions are BDL.

EDL (Estimated Detection Limit) : For Dioxin/Furan tests, a commonly reported estimate of the concentration where a given analyte would have to be present to produce a signal with a peak height of at least 2.5x the background noise signal level. The EDL determination is done for each sample set at the time of analysis. This is specific to the analytical technique and is affected by factors such as sample size, dilution, etc., commonly reported for non

- detected analytes instead of other values such as PQL, RL, QL, etc. It is important to note that EDL and MDL are not the same, but EDL is a standard benchmark for determining detection from an isotope dilution analysis, common to dioxin/furan emissio n testing.

MDL (Method Detection Limit) : Syn onymous with the term LOD (Level of Detection) the MDL is defined as the lowest quantity of a substance that can be distinguished from the absence of that substance (i.e. a blank value) with a stated level of co nfidence. For the purposes of this document, the process of identifying the MDL of a given substance is defined in EPA Method 301, Section 15.

RDL (Representative Detection Limit) : S ometimes referred to as the Representative Method Detection Limit (RMDL ) this is the mean MDL value of a specific analyte determined by an MTG review of l lab analyses represented by labs who provided data for best performing sources, thereby creating a representative value by which to assess detection such that the best perf orming lab handing any particular analytical sample does not drive all detection limit discussion and decision making. By establishing this value as the mean of several labs we allow for the selection of local and cost effective analysis of environmental samples while maintaining a balance of quality analyses. The Westlin/Merrill memo randum defines RDL for dioxin/furans as EDL x 2 (Westlin and Merrill, 2011)

.

IV. Run Flags

Run flags are determined by the facility/analytical laboratory for each run. They compare each analytical fraction mass to the MDL or other detection limit values ( e.g

. , Reporting Limit) as available. Mercury runs have five analytical fractions and the other HAP metals have two analytical fractions. The run flag is BDL if all of the fr action masses are below the MDL

, DLL if3 one or more of fraction masses are below the MDL

, and ADL if all of the fraction masses are above the MDL. Similarly

, for dioxin/furan testing

, there are multiple congeners for each TEQ run. The run flag is BDL if all of the congener masses are below the MDL; DLL if one or more congeners are below the MDL; and ADL if all the congeners are above the MDL. For each fraction/congener mass that is b elow the MDL, the MDL mass is used for the fraction/congener mass and subsequent emissions calculations.

V. Mercury

For each tunnel kiln with Hg test data, each run flag was evaluated to determine the “non

detect” status of the run, according to Johnson (2 014). I f the run flag was ADL or DLL, the run was considered ADL. If the run flag was BDL, the run mass (sum of five fraction masses, as available) was evaluated and compared to the RDL value provided in the guidance document Data and procedure for handl ing below detection level data in analyzing various pollutant emissions databases for MACT and RTR emissions limits (Westlin and Merrill , 2011) for Hg analyzed by Cold Vapor AA, 0.56 μg . If the run mass was less than the RDL, the run was considered BDL. If the run mass was greater than the RDL and was based on MDL values, the run was considered BDL. If the run mass was greater than the RDL and was based on other detection limit values ( e.g. , Reporting Limit), the data was set aside and not used for the a nalysis. ( Note that data set aside for this analysis were not set aside for actual MACT floor rankings and floor calculations. ) The following figure displays the steps in determining the “non

- detect” status of a run for this analysis based on the guidanc e provided by Johnson (2014)

.4 Figure 1

. Steps in determining the “non

- detect” status of test run data for setting MACT floors.

Table 1 displays the percent age of ADL and BDL runs for Hg from BSCP tunnel kilns. The run

- by

- run data used to calculate the percent ADL and BDL for Hg from BSCP tunnel kilns can be found in Appendix A.

Table 1. Percent ADL and BDL for Hg from BSCP Tunnel Kilns
Hg
Total Runs 55
No. Set Aside 6
No. Use d 49
No. BDL 0
No. ADL 49
% BDL 0
% ADL 1005 The percent BDL for BSCP tunnel k ilns was 0 percent; as such , the EPA is proposing a MACT floor standard for Hg for BSCP tunnel kilns.

VI. Non

- Hg H AP Metals

For each tunnel kiln with non

- Hg HAP metals test data, each run flag was evaluated to determine the “non

- detect” status of the run, according to Johnson (2014). If the run flag was ADL or DLL, the run was considered ADL. If the run flag was BDL, the run mass (sum of each fraction mass) was evaluated and compared to the RDL value provided in the guidance document ( Westlin and Merrill , 2011) for each individual non

- Hg HAP metal analyzed by either Inductively Coupled Plasma/Mass Spectrometry or Graphite Furnace Atomic Absorption Analysis [ICP/MS or GFAAA] or Inductively Coupled Atomic Emissio n Spectroscopy or Atomic Absorption Analysis [ICP/AES or AA]. Table 2 presents the RDL values for each non

Hg HAP met al for each analytical method.

Table 2

. RDL values for each Non

- Hg HAP Metal per Analytical Method ( Westlin and Merrill , 2011)

Method 29 Non

- Hg HAP Metals ICP/AES or AA RDL ( μg ) ICP/MS or GFAA RDL ( μg ) Antimony 1.2E+01 1.1E+00
Arsenic 1.9E+01 4.0E

- 01 Beryllium 1.1E

- 01 8.0E

- 02
Cadmium 1.5E+00 3.0E

- 02
Chromium 2.5E+00 3.0E

- 01
Cobalt 2.5E+00 3.0E

- 01
Lead 1.5E+01 3.0E

- 01 Manganese 7.0E

- 01 3.0E

- 01
Nickel 5.4E+00 5.4E+00
Selenium 2.7E+01 8.0E

- 01

If the run mass was less than the RDL, the run was considered BDL. If the run mass was greater than the RDL and was based on MDL values, the run was considered BDL. If the run

mass was greater than the RDL and was based on other detection limit values ( e.g

. , Reporting Limit), the data was set aside and not used for the analysis. ( Note that data set aside for this analysis were not set aside for actual MACT floor rankings and floor calculations. ) Table 3 displays the percent age of ADL and BDL runs for each non

- Hg HAP metal from BSCP tunnel kilns. The run

- by

- run data used to calculate the percent ADL and BDL for each non

- Hg HAP metal from BSCP tunnel kilns can be found in Appendix B.6 Table 3

. Percent ADL and BDL for Each Non

- Hg HAP Metal from BSCP Tunnel Kilns a

Sb As Be Cd Cr Co Pb Mn Ni Se Total Non

- Hg

HAP Metals
Total Runs 52 52 52 52 52 52 52 41 52 52 509
No. Set Aside 24 24 3 6 18 0 19 6 0 1 14 139
No. Use d 28 28 1 6 34 52 33 46 41 51 38 370
No. BDL 12 6 1 6 1 0 11 11 0 0 0 60
No. ADL 16 22 0 33 52 22 35 41 51 38 310
% BDL 43 21 100 3 0 33 24 0 0 0 16
% ADL 57 79 0 97 100 67 76 100 100 100 84

a Sb = antimony; As = arsenic; Be = beryllium; Cd = cadmium; Cr = chromium; Co = cobalt; Pb = lead; Mn =

manganese; Ni = nickel; Se = selenium.

The majority of the individual non

- Hg HAP metals had a high percentage of runs above detection level, thus not m eeting the criteria for a work practice standard. As a result , the EPA is proposing MACT floor standards for PM as a surrogate for non

- Hg HAP metals for BSCP tunnel kilns.

VII. Dioxin/Furan ( TEQ )

Seventeen specific dioxin/furan congeners are considered in the calculation of TEQ values

. For the 17 specific dioxin/furan congeners

, the mass reported in the laboratory analysis of the test report was multiplied by the 2005 World Health Organization (WHO) toxic equivalent factors (TEF) to calculate the TEQ valu e for each run

. If the mass for the congener was flagged as BDL , then a value of zero was used as the mass. The mass of each of the 17 calculated TEQ values were summed together to get a total TEQ mass for each run

. The total TEQ mass for each run was c o mpared to the Utilities TEQ EDL

, 0.018 ng (Westlin and Merrill , 2011)

. I f the total TEQ mass was greater than the EDL, the run was considered ADL. If the total TEQ mass was less than the EDL, the run was considered BDL.

Table 4 summarize s the overall per cent age of ADL and BDL runs for BSCP tunnel kilns and dryers. The run

- by

- run data used to calculate the overall percent ADL and BDL for TEQ from BSCP tunnel kilns and dryers can be found in Appendix C.

Table 4

. Percent ADL and BDL for TEQ from BSCP Tunnel Kilns and Dryers

Source No. Runs % ADL % BDL
Overall for BSCP Tunnel Kilns 18 17 83 Overall for BSCP Dryers 12 0 1007 T he percent BDL for k ilns was 83 percent ; thus , the EPA is proposing a work practice standards for dioxin s/ furan s (TEQ) for BSCP tunnel kilns.

The percent BDL for dryers was 100 percent ; thus , the EPA is proposing no limit for dioxin s/furans (TEQ) for BSCP dryers.

VIII. References

Johnson, S. 2014. Determination of “non

- detect” from EPA Method 29 (multi

- metals) and EPA Method 23 ( dioxin/furan) test data when evaluating the setting of MACT floors versus establishing work practice standards

. Memorandum from Stef fan Johnson, SPPD, MPG

, to SPPD management and MACT rule writers

. June 5, 2014.

Westlin, P., and R. Merrill. 2011. Data and procedure for handling below detection level data in analyzing various pollutant emissions databases for MACT and RTR emissions limits

. Memorandum from Peter Westlin, SPPD, MPG and Raymond Merrill, AQAD, MTG

, to SPPD management and MACT rule writers

. December 13, 2011.Appendix A

BSCP Tunnel Kiln Hg DataA

- 1 The run

- by

- run data used to calculate the percent ADL and BDL for Hg from BSCP tunnel kilns are provided in the corresponding Appendix A Microsoft Excel® fileAppendix B

BSCP Tunnel Kiln Non

- Hg HAP Metal DataB

- 1 The run

- by

- run data used to calculate the percent ADL and BDL for non

- Hg HAP metals from BSCP tunnel kilns are provided in the corresponding Appendix B Microsoft Excel® file

.Appendix C

BSCP Tunnel Kiln and Dryer TEQ DataC

- 1 The run

- by

- run data used to calculate the percent ADL and BDL for TEQ from BSCP tunnel kilns and dryers are provided in the corresponding Appendix C Microsoft Excel® file

.