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-17J 
EPA 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 be 
EPA 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