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` arun. 

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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