### Date: Novembe r 6 , 2014

To: Jeff Telander, EPA /OAQPS/SPPD

From: Gabrielle Raymond , RTI International

Subject: Test Data Used in C lay C eramics Proposed Rule

I. Introduction

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 clay ceramics manufacturing industry, specifical ly the sanitaryware and ceramic tile industry sectors. Sanitaryware includes plumbing and bathroom fixtures such as toilets and sinks

. Ceramic tile is used to cover floors and walls

. The NESHAP regulated emissions of hydrogen fluoride (HF), hydrogen chl oride (HCl), and particulate matter (PM)

— a surrogate for HAP metals

— from new and reconstructed kilns located at clay ceramics facilities

. On March 13, 2007, the D.C. Circuit Court vacated the emission standards for clay ceramics manufacturing due to issue s 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 clay ceramics manufacturing, including standards for HF, HCl, mercury (Hg), non

Hg HAP metals (specifically, the PM surrogate), and dioxins/furans

. The list of affected sources to be regulated has been expanded to include new and existing kilns, spray dryers (ceramic tile only), press dryers (floor tile only), and spray glaze operations (sanitaryw are and floor tile only)

. The facilities currently subject to the proposed NESHAP include three sanitaryware facilities. The ceramic tile facilities ( including floor tile and wall tile facilities) have taken the necessary steps to become synthetic area s ources ( i.e. , have obtained a federally enforceable limit reducing emissions below major source thresholds) and would not be subject to the major source clay ceramics NESHAP

. The purpose of this

memo randum is to describe the sources of test data obtained and considered in the c lay c eramics rulemaking and describe the quality assurance/quality control ( QA / QC ) checks performed o n the data

.

1 Sierra Club v. EPA , 479 F.3d 875 (D.C. Cir. 2007)

.

### 2 II. Sources of Data

The main sources of test data were responses to the 2008 and 2010 section 114 surveys to the clay ceramics industry (described in the remainder of this section) and the clay ceramics L egacy D ocket A

- 2000

- 48

. Copies of all the test reports collected from these sources are included in Docket ID No

. EPA

- HQ

- OAR

- 20 13

- 029 0.

The EPA conducted two surveys under the authority of section 114 of the CAA. In June 2008

, the EPA se n t out a survey to six clay ceramics companies

, including sanitaryware company Kohler Co. and seven ceramic tile companies : Dal

- Tile Corp. (including Dal Italia

, a joint venture between Dal

- Tile and Italy

- based tile maker EmilCeramica ), Florida Tile Industries, Inc., Florim USA, Interceramic, Marazzi Tile, Inc., StonePeak Ceramics (Tsirigotis, 2008a

- c ) , and Monarch Ceramic Tile, Inc. (letter sent in May 2009 ; Tsirigotis, 2009)

. The
survey was designed in the form of a Microsoft Excel ® spreadsheet file that included seven different worksheets to complete

. The main intention of the survey w as to collect inventory information about the kilns a nd glaze lines at those companies

. Although the 2008 survey did not require any new testing to be performed, t he “ Form D

- Test Data ” worksheet in the survey asked for information on emission tests previously performed on kilns at the facilities and asked each facility to submit complete copies of the reports for these emission test s

. The test reports received contained results for HF, HCl, Cl 2 

### , and filterable PM.

In 2010

, the EPA s ent out another section 114 survey to five clay ceramics companies

, including sanitaryware company Kohler Co. and four ceramic tile companies : Dal

- Tile Corp. (including Dal Italia) , Florim USA, Marazzi Tile, Inc., and Monarch Ceramic Tile, Inc

. (Tsirigotis, 2010a

- e )

. The survey required clay ceramics facilities to conduc t stack tests of their kilns, dryers, and spray glaze operations.

The sanitaryware facilities were required 2 

### to measure emissions of the following pollutants from their emission sources :

• HF, HCl, PM filterable, HAP metals ( including Hg )

, PM 2.5 

### filterable, PM 2.5 

### condensable

, and dioxin/furan from tunnel kilns;

• Dioxin/furan from ware dryers; and

• PM filterable, HAP metals ( including Hg )

, and PM 2.5 

### filterable, from glaze spray booths.

The c eramic t ile facilities 3 

### were required to measure emissions of the following pollutants from their emission sources :

2 After the survey letters were mailed out to the facilities, an agreement was reached between the sanitaryware industry and the EPA that removed the testing requirements of PM 2.5 filterable and PM 2.5 condensable from tunnel kiln testing and removed the tes ting requirements of PM 2.5 filterable and HAP metals, including Hg, from glaze spray booth testing (Telander, 2010 b )

. 3 After the survey letters were mailed out to the facilities, an agreement was reached between the ceramic tile industry and the EPA that removed the testing requirements of PM 2.5 filterable and PM 2.5 condensable from roller kiln testing; and removed the testing requirements of PM 2.5 filterable from glaze line testing (Telander, 2010a)

.

### 3 • HF, HCl, PM filterable , HAP metals ( including Hg )

, PM 2.5 

### filterable, PM 2.5 

### condensable

, and d ioxin / f uran from roller kilns ;

• Dioxin / f uran from spray dryers and press dryers ; and

• PM filterable, HAP metals ( including Hg )

, and PM 2.5 

### filterable from glaze lines that spray apply the glaze

.
III. Data Compiled and Calculations Conducted from Test Reports

From each test report, the following parameters and emissions data for each test run were compiled into a master run

- by

- run spreadsheet:

• Production rate, in tons per hour (tph)

• Flow rate, in actual cubic feet per minute (acfm)

• Flow rate, in dry standard cubic feet per minute (dscfm)

• Sample volume, in dry standard cubic feet (dscf)

• Sample v olume, in dry standard cubic meter (dscm)

• Stack moisture, in percent (%)

• Stack gas t emperature , in degrees Fahrenheit ( ̊F )

• Oxygen content of stack gas, in percent (%)

• Pollutant concentration, in parts per million (ppm), milligrams per dry standard cubic

me ter (mg/dscm), grains per dry standard cubic foot (gr/dscf), etc.

• Pollutant emission rate, in kilograms per hour (kg/hr), pounds per hour (lb/hr), etc.

Once the data were compiled

, the following calculations were conducted in the master

run

- by

- run spreadsh eet :

• Converted reported concentrations to micrograms per dry standard cubic meter ( μ g/dscm)

• Corrected reported concentrations to 7 percent oxygen (% O 2 

### ) using the following equation: 

## ( ) 2 2 

### O % Tested 20.9 13.9 μg/dscm O μg/dscm@7%

− ÷ × =

• Calculated emissions in pounds per ton (lb/ton) us ing emission rate (lb/hr) and production rate (tph)

I V. Q uality A ssurance / Q uality Control Checks

After the test data had been compiled and calculated in the master run

- by

- run spreadsheet, there were two rounds of QA / QC with the ceramic tile industry association ( Tile Coun cil of North America [TCNA])

, test report comments from Kohler Co., and internal QA / QC from RTI and EPA. Test data determined to be unacceptable after the QA/QC checks were removed from the run

- by

- run spreadsheet and were not include d in the calculation of MACT floors. See Appendix A for the list of test data that were removed from the run

- by

- run spreadsheet after the QA/QC checks

. See Appendix B for the run

- by

- run test data that were used in the calculation of MACT floors.

### 4 A. Indu stry QA / QC

The TCNA conducted two reviews on the test data

, one in November 2012 (TCNA, 2012) and one in March 2013 (TCNA

, 2013)

. The TCNA review indicated the following problems with some of the test data :

• Glass fiber filter used

• No record of filter temperature measurements

• Low probe and filter temperatures

• Lowest Method 26A calibration standard higher than the results

• Detection limit not specified

• Plant had been demolished

The reviews from TCNA were examined with the corresponding test data, and revisions were made to the test data

. For acid gas tests where a glass fiber filter was used, the results were removed from the test data set . For acid gas tests where the probe and filter temperature were not maint ained at the proper temperature per the test method instructions, the results were removed from the test data set

. Test results where the Method 26A calibration standard was higher than the results were removed from the test data set

. In the three above cases, the PM data were retained, as errors in the acid gas testing methodology did not affect the PM results. In cases where t he detection limit s were not specified , the results for that pollutant were removed from the test data set

. All t est data from kilns identified as being demolished and/or decommissioned were removed.

Florim USA also identified a problem with their HF and HCl results during 2010 testing due to production and equipment problems (Florim, 2013)

. After reviewing the information provid ed, t he HF and HCl data for RK

- 1 were removed from the test data set.

Kohler Co. also identified within their test report for the Spartanburg, SC plant that the re was a mix up during the sample preparation phase and filters and front

- half rinses were misma tched in the digestion vessel prior to analysis for the HAP m etals T K#10 POC and RCE stack s (ARI, 2010)

. As such

, th e s e data w ere flagged as compromised and do not represent the concentrations and emission rates that correspond to the affected sources for these specific sample runs. The HAP metals data for TK#10 POC and RCE stacks were removed from the test dat a set.

B. In ternal QA / QC

1. Mercury and Non

- Mercury HAP Metal s

In the internal QA/QC of the test data, inconsistencies were found between the Hg and individual non

- Hg HAP metal values reported in the summary pages of certain test reports and the values reported in the laboratory sections of the test reports. Therefore, the Hg and non

- Hg HAP metal values were reviewed for correctness

, starting from the laboratory results. Specifically, the lab oratory reports were reviewed to extract and compile the mass values for five

### 5 Hg fractions and two non

- Hg HAP metal fractions (see list below)

, the blank fractions, and the

m ethod detection limi ts (MDLs), or other reporting limit if MDL s were not available.

• Front Half (Hg & non

- Hg HAP metal), Fraction 1: Container 1 Filter, Container 2 Acetone Probe Rinse, Container 3 Acid Probe Rinse

• Back Half (Hg & non

- Hg HAP metal), Fraction 2B: Container 4 H NO 3 

### / H 2 

### O 2 

### (N itric A cid / H ydrogen P eroxide ) Impingers

• Back Half (Hg Only), Fraction 3A: Container 5A HNO 3



### • Back Half (Hg Only), Fraction 3B: Container 5B KMnO 4 

### /H 2 

### SO 4 

### (Potassium P ermanganate/Sulfuric A cid) A bsorbing Solution

• Back Half (Hg Only), Fraction 3C: Container 5C HCl Rinse and Dilution

The Hg and other HAP metal values were recalculated from the lab oratory data and blank
correct ed when necessary in accordance with EPA Method 29 guidelines

. These are the values included in Appendix B for Hg and no n

- Hg HAP metals data.

2. Manganese C ontamination
The 2010 section 114 survey test request included kiln and glaze spray booth Hg testing concurrent with non

- Hg HAP metal testing using EPA Method 29. There is a possibility of the back half fraction (Fracti on 2B) for manganese (Mn) being contaminated from the permanganate used in Fraction 3B for Hg sampling. To check for Mn contamination, the ratio of the back half Mn mass to the front half Mn mass was calculated. If the ratio was over 5, that test run was assumed to have Mn contamination. The test runs with Mn contamination were removed from the data set. If it was determined that only one test run from a particular test for a source was not contaminated, the entire test was removed. The following table indicates the test runs that were removed from the kiln and glaze spray booth data set s due to Mn contamination.

### 6 Table 1

. Kiln and Glaze Spray Booth Test Runs Removed D ue to M n Contamination

RTI Inventory

- Kiln No. Test Date Run No. Facility Name City State Kiln ID Source Type
41 5/25/2010 2, 3 a Florim USA Clarksville TN RK

- 1 Roller Kiln 60, 61, 62 5/13

- 15/2010 b Dal Italia Muskogee OK RK

- 2, RK

- 3, RK

- 4 Roller Kiln
77 5/4

- 5/10 1, 2 a Monarch Florence AL RK

- 2L Roller Kiln
36 12/6

- 7/2010 2 Marazzi Sunnyvale TX RK

- 4 Roller Kiln 64, 65, 68, 69 12/13

- 14/2010 1 Dal

- Tile El Paso TX RK

- 1, RK

- 2, RK

- 5, RK

- 6 Bisque Roller Kiln

70, 71, 74, 75 12/15

- 16/2010 2 Dal

- Tile El Paso TX RK

- 7, RK

- 8, RK

11, RK

- 12 Glost Roller Kiln

114; 116; 117; 119 5/13

- 15/2010 1, 2 a Dal Italia Muskogee OK GL 7

- 10 Glaze Line

71 5/26/2010 2 Florim USA Clarksville TN GL

- 1 Glaze Line

19 & 20 8/23

- 24/2010 2 Kohler Co. Brownwood TX TK #6/12 POC stack Tunnel Kiln

7 8/12

- 13/2010 2 Kohler Co. Spartanburg SC TK #8 POC stack Tunnel Kiln

a Entire test was removed because only one test run from this test was not contaminated.

b Entire test was removed because all test runs contaminated.



### 3. PM C orrection for Test Runs Below 1 mg

As part of the clay ceramics test data review

, the mass ( mg ) collected for each PM test

run was evaluated

. In the EPA memorandum, Data and procedure for handling below detection level data in analyzing various pollutant emissions databases for MACT and RTR emissions limits , 1 mg is given as the Representative Detection Level (R DL ) for PM (Westlin and Merrill, 2011)

. For test runs with less than 1 mg collected

, t he 1 mg RDL value was used to calculate the concentration, emission rate , and emission factor for that run

. In these cases , the emission factor

was ca lculated as follows:

hr product ton mg 453.59237 lb 1
hr 1 min 60
min dscf
dscf dscm 0.02831685
dscm

mg 1

product ton lb        

× × × ×

=



### 4. D ioxin s /

Furans

To calculate emissions of total dioxin s /furans, the mass values for each of the homologue group totals reported in the laboratory analysis of the test report were summed. The homologue
groups are shown in Table 2.

### 7 Table 2. Dioxin/Furan Homologue Group Totals Homologue Group Totals Short Hand
Total Tetrachlorodibenzo

- p

- dioxins Total TCDD
Total Pentachlorodibenzo

- p

- dioxin Total PeCDD
Total Hexachlorodibenzo

- p

- dioxins Total HxCDD
Total Heptachlorodibenzo

- p

- dioxins Total HpCDD
Total Octachlorodibenzo

- p

- dioxin Total OCDD
Total Tetrachlorodibenzofurans Total TCDF
Total Pentachlorodibenzofurans Total PeCDF
Total Hexachlorodibenzofurans Total HxCDF
Total Heptachlorodibenzofurans Total HpCDF
Total Octachlorodibenzofuran Total OCDF



### Next, 17 specific dioxin/furan congeners were considered separately from the homologue group totals. The 17 specific dioxin/furan congener mass values reported in the laboratory analysis of the test report were converted to 2,3,7,8

- TCDD toxic equivalency (TEQ) values for each test run using the 2005 World Health Organization (WHO) toxicity equivalence factors (TEF) (EPA, 2010) in Table 3

. The 17 converted TEQ values were then summed to calculate a total TEQ value for each run

. Appendix C contains a sample calculation showing how the total dioxin/furan and total TEQ values were calculated from the reported laboratory masses to the final run by run v alues presented in Appendix B.

### 8 Table 3

. Dioxin/Furan Toxic i ty Equivalence Factors

Dioxin/furan congener Short Hand Toxicity equivalence factor 2,3,7,8

- tetrachlorodibenzo

- p

- dioxin 2,3,7,8

- TCDD 1 1,2,3,7,8

- pentachlorodibenzo

- p

- dioxin 1,2,3,7,8

- PeCDD 1 1,2,3,4,7,8

- hexachlorodibenzo

- p

- dioxin 1,2,3,4,7,8

- HxCDD 0.1 1,2,3,7,8,9

- hexachlorodibenzo

- p

- dioxin 1,2,3,6,7,8

- HxCDD 0.1 1,2,3,6,7,8

- hexachlorodibenzo

- p

- dioxin 1,2,3,7,8,9

- HxCDD 0.1 1,2,3,4,6,7,8

- heptachlorodibenzo

- p

- dioxin 1,2,3,4,6,7,8

- HpCDD 0.01 Octachlorodibenzo

- p

- dioxin OCDD 0.0003 2,3,7,8

- tetrachlorodibenzofuran 2,3,7,8

- TCDF 0.1 1,2,3,7,8

- pentachlorodibenzofuran 1,2,3,7,8

- PeCDF 0.03 2,3,4,7,8

- pentachlorodibenzofuran 2,3,4,7,8

- PeCDF 0.3 1,2,3,4,7,8

- hexachlorodibenzofuran 1,2,3,4,7,8

- HxCDF 0.1 1,2,3,6,7,8

- hexachlorodibenzofuran 1,2,3,6,7,8

- HxCDF 0.1 2,3,4,6,7,8

- hexachlorodibenzofuran 2,3,4,6,7,8

- HxCDF 0.1 1,2,3,7,8,9

- hexachlorodibenzofuran 1,2,3,7,8,9

- HxCDF 0.1 1,2,3,4,6,7,8

- heptachlorodibenzofuran 1,2,3,4,6,7,8

- HpCDF 0.01 1,2,3,4,7,8,9

- heptachlorodibenzofuran 1,2,3,4,7,8,9

- HpCDF 0.01 Octachlorodibenzofuran OCDF 0.0003



### 5. Non

- Detects
As mentioned in Section IV.B.1, Hg and non

- Hg HAP metal test runs are comprised of individual fractions. For any test run fraction that had values flagged as being below detect ion limit (BDL), the MDL, or other reporting limit if an MDL was not available, was used as the mass for that fraction. The concentration, emission rate, and emission factor for the run were then calculated using the sum of the fractions for each test run

. If all fractions for a run were flagged as BDL, then the run was considered BDL. If there was a mix of fractions flagged as BDL and above detection limit (ADL), then the run was considered detection level limited (DLL). If all fractions for a run were flagged as ADL, the n the run was considered ADL.

Similarly for dioxin/furan testing there are multiple congeners for each TEQ run. The run was flagged as BDL if all of the congener masses were below the MDL; DLL if one or more
congeners were below the MDL ; and ADL if all the congeners were above the MDL. For each fraction/congener mass that is below the MDL, the MDL mass was used for the fraction/congener mass and subsequent emissions calculations

. For more information on how these data were treated for purposes of calculating MACT floors, see the memorandum Maximum Achievable Control Technology (MACT) Floor Analysis for Clay Ceramics (Raymond and Sroka , 2014).

### 9 6. Source C onfigurations

In some cases, multiple sources are ducted to the outlet stack being t ested. For most emission types , e ach source operating during the time of testing was assumed to have the same concentration and emission factor value. Their emission rate values were calculated as a proportion of the outlet stack value, based on a ratio of production rates. If any of the sources were not operating during the test, the emission values do not apply to those sources.

For tile glaze lines and wall tile roller kilns

, all of the units ducted to an outlet stack were considered one source (Raymond 2014).

In other cases, a single source ( e.g. , a kiln or dryer) that is being tested is ducted to multiple stacks

. The emissions from each stack are summed together to get one value for the

source.

V. References

ARI (ARI Environmental, Inc.). 2010. Emissions Test Program: Clay MACT ICR Data Gathering

– Kohler Company Vitreous Plant, Spartanburg, South Carolina. Prepared for Kohler Company, Attention: Michael J. Cassidy, EHS S pecialist. Test Dates: August 10

- 17, 2010.

EPA (U.S. Environmental Protection Agency)

. 2010. Recommended Toxicity Equivalence Factors (TEFs) for Human Health Risk Assessments of 2,3,7,8

- Tetrachlorodibenzo

- p

- dioxin and Dioxin

- Like Compounds

. Publication No. EPA/100/R

– 10/005

. Available at: http://www.epa.gov/raf/files/tefs

- for

- dioxin

- epa

- 00

- r

- 10

- 005

- final.pdf . December 2010.

Florim

. 2013. Memorandum: Major Source MA CT: Ceramic Tile Industry Request for Exclusion Florim USA May 2010 Kiln HF and HCl Data

. Memorandum from Connie O’Neal, Florim USA, to Sharon Nizich , EPA/OAQPS/SPPD

. August 1, 2013.

Gilberg, H. 2012. Challenge to Potential Use or Reliance on Selecte d HF and HCl Data

. Memorandum from Howard Gilberg, Guida, Slavich & Flores, to Jeff Telander, EPA/OAQPS/SPPD, November 13, 2012.

Hartman, M. 2013. Memorandum: CONFIDENTIAL

- Updated Test Reports

. Memorandum from Michael Hartman, Air

- Tech Environmental, LLC, to Howard Gilberg, Guida, Slavich & Flores

. March 25, 2013.

Raymond, G. 2014

. Updated Inventory Database and Documentation for CC Proposed Rule

. Memorandum from Gabrielle Raymond, RTI International to Jeff Telander, EPA/OAQPS/SPPD

. November 6, 2014.

Ray mond, G. and Sroka, K. 2014. Maximum Achievable Control Technology (MACT) Floor Analysis for Clay Ceramic s . Memorandum from Gabrielle Raymond and Kristin Sroka, RTI International, to Jeff Telander, EPA/OAQPS/SPPD. November 6, 2014.

### 10 Telander, J. 2010a. “Re: 114 letter and enclosures.” E

- mail from Jeff T elander, U.S. Environmental Protection Agency, to Howard Gilberg, Guida, Slavich & Flores

. April 23, 2010.

Telander, J. 2010b. “Tile Industry ICR's.” E

- mail from Jeff T elander, U.S. Environmental Protection A gency, to Mike Cassidy, Kohler Co

. May 4, 2010.

Tsirigotis, P. 2008a. “ Section 114 information collection request to selected clay ceramics facilities. ” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Robert Hurt, Dal

- Tile Corp. , transmitting section 114 information collection request asking for information on brick and structural clay products processes, emissions, and controls. Identical letters sent to other addressees listed ( Florida Tile Industries, Inc., Flo rim USA, Interceramic, Marazzi Tile, Inc., and StonePeak Ceramics )

. June 23, 2008.

Tsirigotis, P. 2008b. “ Section 114 information collection request to selected clay ceramics facilities. ” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Robert Hurt, Dal Italia LLC , transmitting section 114 information collection request asking for information on brick and structural clay products processes, emissions, and controls. July 7, 2008.

Tsirigotis, P. 2008c. “ Section 114 information collection request to selected clay ceramics facilities. ” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Michael Cassidy, Kohler Co. , transmitting section 114 information collection request asking for i nformation on brick and structural clay products processes, emissions, and controls. July 10, 2008.

Tsirigotis , P. 2009 . “ Section 114 information collection request to selected clay ceramics facilities. ” Letter and attachments from Peter Tsirigotis, U. S. Environmental Protection Agency, to Gianni Mattioli, Monarch Ceramic Tile, Inc. , transmitting section 114 information collection request asking for information on brick and structural clay products processes, emissions, and controls. May 19, 2009.

Tsir igotis, P. 2010a. “Section 114 information collection request to Dal

- Tile Corp.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Robert Hurt, Dal

- Tile Corp., transmitting section 114 information collection request asking for information on startup and shutdown events and emission data for specified emission points. March 9, 2010.

Tsirigotis, P. 2010b. “Section 114 information collection request to Florim USA. ” Letter and attachments from Peter Tsirigotis, U.S. E nvironmental Protection Agency, to Connie O'Neal, Florim USA, transmitting section 114 information collection request asking for information on startup and shutdown events and emission data for specified emission points. March 9, 2010.

Tsirigotis, P. 201 0c. “Section 114 information collection request to Kohler Co.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Michael

### 11 Cassidy, Kohler Co., transmitting section 114 information collection request asking for informat ion on startup and shutdown events and emission data for specified emission points. March 9, 2010.

Tsirigotis, P. 2010d. “Section 114 information collection request to Marazzi Tile, Inc.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Steven Wiederwax, Marazzi Tile, Inc., transmitting section 114 information collection request asking for information on startup and shutdown events and emission data for specified emission points. March 9, 2010.

Tsirigotis, P. 2010e. “Section 114 information collection request to Monarch Ceramic Tile, Inc.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Gianni Mattioli, Monarch Ceramic Tile, Inc., transmitting section 114 information col lection request asking for information on startup and shutdown events and emission data for specified emission points. March 9, 2010.

Westlin, P. and Merrill, R. 2011. Data and procedure for handling below detection level data in analyzing various pollu tant 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

Test Data N ot U sed

### A

- 1 Table A

- 1 Test Data Removed from Database after QA/QC, Not Used in MACT Floor Analyses

Facility ID Facility City State Test Date Unit Type Source RTI ID Source ID Explanation Why Data Excluded

MARR

- 1 Marazzi, Sunnyvale Facility Sunnyvale TX 4/ 14 /2005 Roller Kiln 2008 Survey 33 RK

- 1 Acid Gas Ceramic run

-- since only one run for this type of product

MARR

- 1 Marazzi, Sunnyvale Facility Sunnyvale TX 12/6

- 7/2010 Roller Kiln 2010 Survey 36 RK

- 4 Removed Non

- Hg HAP Metal Run 2 results due to Mn contamination

2100500008 Florida Tile Inc. Lawrenceburg KY 11/12/1996 Roller Kiln Legacy Docket A

- 2000

- 48 38 RK

- 2 Acid Gas results removed per further review from industry and EPA due to glass fiber filter used

2100500008 Florida Tile Inc. Lawrenceburg KY 1/15

- 16/2008 Roller Kiln 2008 Survey 40 RK

- 6 Acid Gas results removed per further review from industry and EPA due to inappropriate cooling vent sample location and no spike/recovery data

FLOR

- 1 Florim USA Clarksville TN 10/25/2007 Roller Kiln 2008 Survey 41 RK

- 1 Acid Gas results removed per further review from industry and EPA due to glass fiber filter used

FLOR

- 1 Florim USA Clarksville TN 11/18/2008 Roller Kiln 2008 Survey 41 RK

- 1 Acid Gas results removed per further review from industry and EPA due to lack of filter temperature measurement records

FLOR

- 1 Florim USA Clarksville TN 5/25/2010 Roller Kiln 2010 Survey 41 RK

- 1 Acid Gas results removed per further review from industry and EPA due to production and equipment problems during Run 2 and production shutdowns during Run 3 ; Removed Non

- Hg HAP Metal results due to only one test run from this test was not Mn contaminated

INTE

- 1 Interceramic Garland TX 8/22/1995 Roller Kiln 2008 Survey 46 RK

- 1 No run by run data, only average and potential to emit calculations, only one value per kiln

INTE

- 1 Interceramic Garland TX 8/22/1995 Roller Kiln 2008 Survey 47 RK

- 2 No run by run data, only average and potential to emit calculations, only one value per kiln

INTE

- 1 Interceramic Garland TX 8/22/1995 Roller Kiln 2008 Survey 48 RK

- 3 No run by run data, only average and potential to emit calculations, only one value per kiln

INTE

- 1 Interceramic Garland TX 8/22/1995 Roller Kiln 2008 Survey 49 RK

- 4 No run by run data, only average and potential to emit calculations, only one value per kiln

INTE

- 1 Interceramic Garland TX 8/22/1995 Roller Kiln 2008 Survey 50 RK

- 5 No run by run data, only average and potential to emit calculations, only one value per kiln

MOHA

- 1 Dal

- Tile Conroe Plant Conroe TX 8/23/2005 Roller Kiln 2008 Survey 51, 52, 53 RK

- 1, RK

- 2, RK

- 3 Plant shut down and dismantled

MOHA

- 2 Dal

- Tile Dallas Plant Dallas TX 5/22/2007 Roller Kiln 2008 Survey 54, 55 RK

- 99

- 1, RK

99

- 2 Acid Gas results removed per further review from industry and EPA due to high Method 26A calibration standards, detection limit not specified, and low probe and filter temperatures

### 2 Facility ID Facility City State Test Date Unit Type Source RTI ID Source ID Explanation Why Data Excluded

MOHA

- 2 Dal

- Tile Dallas Plant Dallas TX 5/23/2007 Roller Kiln 2008 Survey 56, 57 RK

- 100

- 2, RK

100

- 3 Acid Gas results removed per further review from industry and EPA due to high Method 26A calibration standards, detection limit not specified, and low probe and filter temperatures

DALT

- 1 Dal Italia Muskogee OK 12/7/2005 Roller Kiln 2008 Survey 59, 60 RK

- 1, RK

- 2 Acid Gas results removed per further review from industry and EPA due to high Method 26A calibration standards and detection limit not specified

DALT

- 1 Dal Italia Muskogee OK 4/12/2006 Roller Kiln 2008 Survey 59, 60 RK

- 1, RK

- 2 Acid Gas results removed per further review from industry and EPA due to high Method 26A calibration standards and detection limit not specified

DALT

- 1 Dal Italia Muskogee OK 5/14/2010 Roller Kiln 2010 Survey 60, 61, 62 RK

- 2, RK

- 3, RK

- 4 Removed Non

- Hg HAP Metal results due to all runs being Mn contaminated

DALT

- 1 Dal Italia Muskogee OK 11/2/2006 Roller Kiln 2008 Survey 61, 62 RK

- 3, RK

- 4 Acid Gas results removed per further review from industry and EPA due to detection limit not specified

DALT

- 1 Dal Italia Muskogee OK 12/8/2005 Roller Kiln 2008 Survey 63 RK

- 5 Acid Gas results removed per further review from industry and EPA due to high Method 26A calibration standards and detection limit not specified

DALT

- 1 Dal Italia Muskogee OK 4/13/2006 Roller Kiln 2008 Survey 63 RK

- 5 Acid Gas results removed per further review from industry and EPA due to high Method 26A calibration standards and detection limit not specified

MOHA

- 3 Dal

- Tile El Paso Plant El Paso TX 12/13

- 14/2010 Roller Kiln 2010 Survey 64, 65, 68, 69 RK

- 1, RK

- 2, RK

- 5, RK

- 6

Bisque Removed Non

- Hg HAP Metal Run 1 results due to Mn contamination

MOHA

- 3 Dal

- Tile El Paso Plant El Paso TX 12/15

- 16/2010 Roller Kiln 2010 Survey 70, 71, 74, 75 RK

- 7, RK

- 8, RK

- 11, RK

- 12 Glost Removed Non

- Hg HAP Metal Run 2 results due to Mn contamination

MARR

- 2 Monarch Ceramic Tile, Inc. Florence AL 5/4

- 5/2010 Roller Kiln 2010 Survey 77 RK

- 2L Removed Non

- Hg HAP Metal results due to only one test run from this test was not Mn contaminated

FLOR

- 1 Florim USA Clarksville TN 5/26/2010 Glazing 2010 Survey 71 GL

- 1 Removed Non

- Hg HAP Metal Run 2 results due to Mn contamination

DALT

- 1 Dal Italia Muskogee OK 10/30/2006 Glazing 2008 Survey 114; 116; 117; 119 GL

- 7 west, GL

8, GL

- 9 west, GL

- 10 PM no production in units of lb/ton glaze sprayed

### 3 Facility ID Facility City State Test Date Unit Type Source RTI ID Source ID Explanation Why Data Excluded

DALT

- 1 Dal Italia Muskogee OK 5/13

- 15/2010 Glazing 2010 Survey 114; 116; 117; 119 GL

- 7 west, GL

8, GL

- 9 west, GL

- 10 Removed Non

- Hg HAP Metal results due to only one test run from this test was not Mn contaminated

MARR

- 2 Monarch Ceramic Tile, Inc. Florence AL 3/23/2005 Glazing 2008 Survey 127, 128 GL

- 5; GL

- 6 PM no production in units of lb/ton glaze sprayed

KOHL

- SC Kohler Co. Spartanburg SC 8/13/2010 Tunnel Kiln 2010 Survey 9 TK #10 POC + RCE stacks Hg & HAP metals lab results were compromised

KOHL

- SC Kohler Co. Spartanburg SC 8/11/2010 Tunnel Kiln 2010 Survey 2 TK #2 POC + EE + FE stack DF/TEQ and PM concentration data removed as result of outlier testing

KOHL

- TX Kohler Co. Brownwood TX 8/23

- 24/2010 Tunnel Kiln 2010 Survey 19 & 20 TK #6/12 POC stack Removed Non

- Hg HAP Metal Run 2 results due to Mn contamination

KOHL

- TX Kohler Co. Brownwood TX 8/12

- 13/2010 Tunnel Kiln 2010 Survey 7 TK #8 POC stack Removed Non

- Hg HAP Metal Run 2 results due to Mn contamination

### Appendix B

Final R un - by

- R un Values

### B

- 1 The final run

- by

- run values for HF, HCl, PM, Hg, individual non

- Hg HAP metal

, and dioxin/furan runs for kilns; dioxin/furan runs for dryers; and PM, Hg, and non

- Hg HAP metal runs for glaze spray booths are provided in the corresponding Appendix B Microsoft Excel® file. The file includes the parameters and emission data compiled from each test report and the calculations conducted on the data.

### Appendix C

Dioxin/Furan and TEQ Sample Calculations

### C

- 1 A sample calculation of run by run reported laboratory masses converted into final total dioxin/furan and total TEQ run

- by

- r un values is provided in the corresponding Appendix C Microsoft Excel® file.