### March 28, 2013



### BY HAND DELIVERY Mr. Jeff Telander U.S. Enviroiirnental Protection Agency Sector Policies and Programs Division Office of Air Quality Planning and Standards Mail Code D243-02 109 TW Alexander Drive Research Triangle Park, NC 27709

Re: Major Source MACT: Ceramic Tile Industry Request for Exclusion of Florim May 2010 Kiln HF and HC1 Data

Dear Mr. Telander:

This letter is written to request the exclusion of the HF and HCl kiln emissions results from the Florim USA May 2010 stack test fi•om the MACT Floor data set. These test results are unrepresentative of this source or any other similar source because production during one of the three runs required by the test metllod 320 was at less than 20 percent of permitted tlu•oughput capacity. This productlon information was provided to EPA Lulder a claim of Confidential Business Information by the company as part of its response to the March 2010 Infor111atlon Collection Request ("ICR") (see attached).

This unrepresentatively low production rate occurred as a result of two factors that caused the feed of tile into the kiln to be stopped, creating what the industry refers to as a"gap" in production. The first factor was the need to introduce a 5 minute gap in the kiln feed to accommodate a change in the color of the tile being produced. This gap was created by stopping the feed conveyor at the entrance of the kiln. The second factor causing a gap occurred sllortly after the restart of the feed conveyor and was the result of a mechanical failure of the feed conveyor that lasted for the remainder of the tllird stack test run. Simply explained, HF and HC1 emissions, which evolve from the green clay body of the tile as it is heated, were extraordinarily low because as time went on during the stack test, nlore and more of the firing zone of the kiln emptied: no tile was being f red. The gap continued well after the stack test ended. Contemporaneous plant production data document this problem.

In fact, the actual relevant throughput was substantially lower than 20 percent of design capacity. The design capacity of this kiln for the product being produced during the stack test was set at 60.8 pieces per minute, or roughly 3650 pieces per hour. This design capacity is based

### Mr. Jeff Telander

U.S. Environmental Protection Agency March 26, 2013 Page 2



### in considerable part on the speed of the kiln, described as the kiln firing cycle. The HAP emissions-relevant throughput, when measured in pieces of tile, is the number of pieces of tile going through the firing zone of the kiln because this zone is the only one in which HAP emissions evolve to any meaningful degree. Plant records show that 730 pieces of tile exited the kiln during the problematic 3rd run, but that, of these 730 pieces, 608 pieces were not in the firing zone. Thus, the relevant throughput during this run was 122 pieces or 0.249 Mg. As demonstrated in the tables below, this artificially lowered the emission factor for the 3` a run.

Table 1 Production Calculations

Recorded Production Cooling Zone Setting Production Through Firing Zone Recorded Cooling Phase 10 Adjusted Pieces 122 Production 730 Length minutes ieces Weight per 2,04 Speed (Pieces/min) 60.8 Weight per piece 2.04 iece s s Total Total Weight 248.88 Weight 1,489.2 Total Pieces 608 (kgs) (kgs) Total Weight per piece Total Weight .24888 Weight 1.4892 (kgs) 2.04 (Mg) M Total Wei t s 1,240.32

Total Wei t M 1.24032



### Table 2 Emission Factor Comparison Calculations

Run 1 Run 3 as re orted Run 3 as Ad'usted Pollutant HF HCl HF HCl HF HCl Emission Rate .373 1.109 0.02 0.202 0.02 0.202 Throu ut M 5.68 5.68 1.48 1.48 0.24888 0.24888 Emission Factor k G) 0.0656 0.1952 0.0135 0.2989 0.0803 0.8116


### Note the wide disparity between the HF and HCl emissions during normal production conditions during run 1, and the HF and HCl emissions during run 3 as reported and run 3 as adjusted for the relevant throughput. One readily concludes that run 3's HF and HCl emissions were wholly unrepresentative. This problem was not encountered during any other stack test at this facility performed in response to the ICR.

As you know, a valid stack test for permit compliance purposes requires a production rate close to design capacity: 90 percent or higher. Among the long-recognized reasons for this requirement is that the conditions within the source, here the kiln, vary in important ways that can and do impact the evolution of air pollutants a.nd ultimately measured emission rates. Specifically, when a fast fire tile roller kiln is operated at very low production rates relative to its capacity, the tile residence time, the kiln firing temperature curve and the air flow (each of which

### Mr. Jeff Telander

U.S. Environmental Protection Agency March 26, 2013 Page 3



### are designed for a full kiln production) are each substantially different, and synergistically, create wholly uiu•epresentative kiln conditions and enlissions.

Method 320 requires the averaginb of tliree representative one llour runs. The May 2010 report provided two representative one hour runs. Since the May 2010 did not satisfy the requirements of Method 320, we ran the October 2010 kiln stack test for HF and HC1. We complied with the ICR by submitting representative data from the October 2010 test, witll the full expectation that these May results would, in recognition of the above, would be discarded by EPA.

Thank you for your consideration of this request.

Very truly yours,



# I

Enc.

cc: Howard L. Gilberg, Esq.

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