EPA Applicability Determinations Index 

## U.S. Environmental Protection Agency Applicability Determination Index

Control Number: M090023

Category: MACT EPA Office: Region 5 Date: 10/24/2006 Title: Alternative Monitoring Method and Performance Test Waiver Recipient: Carrier, Jerry Author: Czerniak, George Comments:

Part 63, A General Provisions JJJJJ

Abstract:

Q1: The Glen-Gery Marseilles Facility (Glen-Gery) in Marseilles, Illinois, operates two identical natural gas fired tunnel kilns subject to 40 CFR part 63, subpart JJJJJ. May Glen-Gery use an alternative monitoring procedure whereby exhaust flow to the dry limestone absorber (DLA) will be verified by continuously monitoring the bypass stack damper position at least once every fifteen minutes during normal kiln operation, and any period in which the bypass damper is opened allowing the kiln exhaust gas to bypass the DLA would be considered a MACT-related event triggering corrective actions pursuant to the facilities startup, shutdown, and malfunction plan? A1: Yes. EPA approves this alternative monitoring request under MACT subpart JJJJJ. As explained in 68 FR 26704, the pressure drop across the DLA is only intended to demonstrate that kiln exhaust flow is being directed through the DLA, and is not bypassing the control device. Q2: Will EPA approve a performance test waiver for Glen-Gery seeking approval to conduct performance testing while Kiln A and B are operating at maximum production rates, but with different limestone extraction screw settings, and then apply the lower DLA limestone extraction screw setting to demonstrate ongoing compliance with both kilns under 40 CFR part 63, subpart JJJJJ? A2: No. EPA denies Glen-Gery's performance test waiver request. Although both units may be identical in design and operation, there is an insufficient body of compliant performance test data demonstrating that the kilns have a low variability in emissions, and that the emissions profiles of the kilns are the same under MACT subpart JJJJJ.

Letter:

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, IL 60604-3590

REPLY TO THE ATTENTION OF: AE-17JEPA Applicability Determinations Index

OCT 24 2006 Jerry Carrier Technical Services Manager Glen-Gery Corporation Technical Services/Research Route #61 Box 340 Shoemakersville, PA 19555 Re: Request for Alternative Monitoring Method and Performance Test Waiver for Glen-Gery Corporation's Marseilles Facility Dear Sir, In your letter dated August 29, 2006, you requested an alternative monitoring method and performance test waiver pursuant to 40 CFR Part 63 Subpart A - General Provisions, and Subpart JJJJJ - National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Brick and Structural Clay Products Manufacturing (Brick MACT) for the affected kilns and associated control devices located at the Marseilles Facility in Marseilles, Illinois. The Glen-Gery Marseilles Facility operates two identical natural gas fired tunnel kilns. Each kiln is equipped with identical dry limestone absorber (DLA) systems to control hazardous air pollutants (HAP). To demonstrate ongoing compliance, the Brick MACT requires Glen-Gery to monitor parameters related to the operation of the DLA, such as minimum pressure drop across the DLA, minimum limestone extraction screw setting, verification of adequate limestone for the DLA systems, and verification that the same grade and source of limestone used during the performance test continues to be used in the DLA. The DLA systems must be operated such that the monitored parameters reflect the operation scenario used to demonstrate compliance with Brick MACT emission standards during initial performance testing. U.S. EPA requires that performance testing take place while the affected unit is operating at the maximum production level to ensure that the conditions represent maximum HAP loading to the DLA systems. In your letter, you point out that the minimum pressure drop across the DLA set while testing under maximum production conditions is unobtainable when the kiln operates at a lower production level, or when the manufacture of specific products require that the variable speed fan located downstream of the DLA is operated at a setting lower than what was used during the stack test. You also note that the kilns at the Marseilles facility are each equipped with dampers that are not used to regulate flow through the kilns, and are designed to only be in the open or closed positions. Glen-Gery proposes an alternative monitoring procedure where exhaust flow to the DLA will be verified by continuously monitoring the bypass stack damper position at least once every fifteen minutes during normal kiln operation. Any period in which the bypass damper is opened allowing the kiln exhaust gas to bypass the DLA would be considered a MACT-related event triggering corrective actions pursuant to the facilities startup, shutdown, and malfunction plan. Based on the information supplied by your letter, U.S. EPA hereby approves your alternative monitoring request. As stated in your letter, U.S. EPA has acknowledged in 68 FR 26704 that the pressure drop across the DLA is only intended to demonstrate that kiln exhaust flow is being directed through the DLA, and is not bypassing the control device. This approval does not in any way waive your responsibility to comply with all other applicable requirements of the Brick MACT, or all other applicable Federal or State requirements. Glen-Gery also requested a performance test waiver seeking approval to conduct performance testing while Kiln A and B are operating at maximum production rates, but with different limestone extraction screw settings. Should the results successfully demonstrate that the kilns have met the emission limitations of the Brick MACT, you propose that the lower DLA limestone extraction screw setting be applied to demonstrate ongoing compliance with both kilns. You state that this approach would allow Glen-Gery the flexibility to conduct performance tests at more than one limestone extraction screw setting during a single mobilization of the emission stack testing firm, resulting in considerable savings. Based on the information supplied by your letter and the compliance history of the kilns at the Marseilles facility, U.S. EPA denies your performance test waiver request. While both units may beEPA Applicability Determinations Index identical in design and operation, there is an insufficient body of compliant performance test data demonstrating that the kilns have a low variability in emissions, and that the emissions profiles of the kilns are the same. Within the past five years, performance testing of the same pollutants covered in the waiver request has indicated non-compliance. This contributed to the lack of performance test data available for review. If Glen-Gery wishes to operate its DLA systems at a lower limestone extraction screw setting, performance testing on each individual kiln should be carried out. If you have any questions regarding this approval, please contact Joseph Ulfig, of my staff, at 312-353­ 8205. Sincerely yours, George t. Czerniak, Chief Air Enforcement and Compliance Assurance Branch

cc: Don Sutton, Manager Permits Section Bureau of Air Illinois EPA Julie Armitage, Manager Compliance and Enforcement Section Bureau of Air Illinois EPA