Date: September 2 4 , 2015

To: Sharon Nizich , EPA /OAQPS/SPPD

From: Gabrielle Raymond , RTI International
Subject: Test Data Used in C lay C eramics Manufacturing Final 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 industr y, specifically 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 chloride (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 issues associated with the methodology used to determine the minimum regulatory “floors” for new and existing units. 1 Therefore, on December 18, 2014, the EPA propos ed 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 EPA provided a 90

- day public comment period following proposal of the BSCP M anufacturing NESHAP, during which all affected parties were given the opportunity to comme nt on the proposed rule. The EPA has considered the comments received and, as appropriate, incorporated them into the final rule

. 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 (sanitaryware 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 sources ( 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 NESHA P

. The purpose of this
memo randum is to describe the sources of test data obtained and considered in the c lay c eramics

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

.2 rulemaking and describe the quality assurance/quality control ( QA / QC ) checks performed o n the data

. 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

- 2013

- 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 and 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 req uired clay ceramics facilities to conduct 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.

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).3 The c eramic t ile facilities 3 were required 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 d ioxin / f uran from roller kilns ;

• Dioxin / f uran fro m 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

. During the public comment period, the Tile Council of North America (TCNA) (EPA

HQ

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- 2013

- 0290

- 0246) identified a production rate transcription error in the master run

- by

run spreadsheet for the May 2010 stack test performed on R oller K iln ID 77 (RK

- 2L) at Monarch Ceramic Tile’s ceramic floor tile facility in Florence, AL . The EPA has corrected this valu e and recalculated emissions for that source as such.
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 volume, in dry standard cubic meter (dscm)

• Stack mois ture, 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 meter (mg/dscm), grains per dry standard cubic foot (g r/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 spreadsheet :

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

• Calculated emissions in nanograms per kilogram (ng/kg) using emission rate (kg/hr) and converted production rate (tph) to kg/hr

• Calculated emissions in pounds per ton (lb/ton) using emission rate (lb/hr) and producti on rate (tph)

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 ( Gilberg , 2010).4 During the public comment period, several commenters suggested a mass

- based production

- related standard for the dioxin/furan emission limits for ceramic tile manufacturing and sanitaryware manufacturing rather than the propose d concentration format

. As such , the dioxin/furan limits provided in the final rule for clay ceramics are in units of ng TEQ/kg of throughput fired or processed.

I V. Q uality A ssurance / Q uality Control Checks
After the test data had been compiled and calcula ted 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 included 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.
A. Industry QA / QC
The TCNA conducted two reviews on the test data , one in November 2012 ( Gilberg , 2012) and one in March 2013 ( Hartman , 2013)

. The TCNA revie w 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 specifi ed

• 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 maintained 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 r esults 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 provided, t he HF and HCl data for RK

- 1 were removed from the test data set.5 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 mismatched 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 r epresent 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 M etal 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 Hg fractions and two non

- Hg HAP metal fra ctions (see list below) , the blank fractions, and the
m ethod detection limits (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 Aci d 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 erm anganate/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 non

- 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 t esting using EPA Method 29. There is a possibility of the back half fraction (Fraction 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 u e 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 r ate , and emission factor for that run

. In these cases , the emission factor was calculated 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         × × × ×

=7 4. PM Evaluation for Probe and Filter Temperatures
The EPA examined the PM test data and found that a number of the EPA Method 5 test runs had probe or filter temperatures outside of the range of acceptable values. EPA Method 5 specifies that the temperature should be maintained at 248 ± 25 degrees Fahren heit (°F) ( i.e. , between 223 and 273 °F). Test runs with temperatures outside that range were removed from the data set , see Appendix A

. 5

. D ioxin s /

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

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 (T EF) (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 labor atory masses to the final run by run v alues presented in Appendix B.8 Table 3

. Dioxin/Furan Toxic ity 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

6

. 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 detection 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 w as 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 frac tion/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 (Raymon d and Sroka , 2014).9 7

. Source C onfigurations
In some cases, multiple sources are ducted to the outlet stack being tested. For most emission types , e ach source operating during the time of testing was assumed to have the same concentration and emission fac tor 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 g laze 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 Specialist. Test Dates: August 10

- 17, 2010. Docket Item No. EPA

- HQ

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- 0069

. EPA (U.S. Environmental Protection Agency)

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

- Tetrachlorodibenzo

- p
- dioxin and Dioxin

- Like Compounds

. Publication No. EPA/100/R

– 10/005

. December 2010. Docket Item No. EPA

- HQ

- OAR

- 2013

- 0290

- 0169

. Florim

. 2013. Major Source MACT: Ceramic Tile Industry

– Request for Exclusion Florim USA May 2010 Kiln HF and HCl Data

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

. August 1, 2013. Docket Item No. EPA

- HQ

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- 2013

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- 012 7

. Gilberg, H

. 2010. “Tile Industry ICR's.” E

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

. April 23, 2010. Docket Item No. EPA

- HQ

- OAR

- 2013

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- 0117

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

. Confidential Memorandum from Howard Gil berg, Guida, Slavich & Flores, to Jeff Telander, EPA/OAQPS/SPPD, November 13, 2012. Hartman, M. 2013. Memorandum: CONFIDENTIAL

- Updated Test Reports

. Confidential Memorandum from Michael Hartman, Air

- Tech Environmental, LLC, to Howard Gilberg, Guida, S lavich & 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. Docket Item No. EPA

- HQ

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- 2013

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- 0220

.10 Raymond, G. , and K. Sroka. 201 5

. Final Maximum Achievable Control Technology (MACT) Floor Analysis for Clay Ceramic s . Memorandum from Gabrielle Raymond and Kristin Sroka, RTI International, to Sharon Nizich , EPA/OAQPS/SPPD. September 24 , 2015

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

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

. May 4, 2010. Docket Item No. EPA

- HQ

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- 2013

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- 0167

. Tsirigotis, P. 2008a. “ Section 114 informa tion 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 informati on on brick and structural clay products processes, emissions, and controls. Identical letters sent to other addressees listed ( Florida Tile Industries, Inc., Florim USA, Interceramic, Marazzi Tile, Inc., and StonePeak Ceramics )

. June 23, 2008. Docket I tem No. EPA

- HQ

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- 2013

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- 0009

. 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 LL C , transmitting section 114 information collection request asking for information on brick and structural clay products processes, emissions, and controls. July 7, 2008. Docket Item No. EPA

- HQ

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. 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 a sking for information on brick and structural clay products processes, emissions, and controls. July 10, 2008. Docket Item No. EPA

- HQ

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- 2013

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- 0013

. Tsirigotis , P. 2009 . “ Section 114 information collection request to selected clay ceramics facilit ies. ” 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. Docket Item No. EPA

- HQ

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- 2013

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- 001 5. Tsirigotis, P. 2010a. “Section 114 information collection request to Dal

- Tile Corp.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protecti on 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. Docket Item No. EPA

- HQ

- OAR

- 2013

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- 0023

. Tsirigotis, P. 2010b. “Section 114 information collection request to Florim USA. ” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Connie O'Neal, Florim USA, transmitting section 114 information collection req uest asking for information on startup and shutdown events and emission data for specified emission points. March 9, 2010. Docket Item No. EPA

- HQ

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- 2013

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- 002 4.11 Tsirigotis , P. 2010c. “Section 114 information collection request to Kohler Co.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Michael Cassidy, Kohler Co., transmitting section 114 information collection request asking for information on startup and shutdown events and emission data for specified emission points. March 9, 2010. Docket Item No. EPA

- HQ

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- 2013

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- 002 5. 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. Docket Item No. EPA

- HQ

- OAR

- 2013

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- 002 6. Tsirigotis, P. 2010e. “Section 114 information collection request to Monarch Ceramic Tile, Inc.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Age ncy, to Gianni Mattioli, Monarch Ceramic 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. Docket Item No. EPA

- HQ

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- 2013

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- 002 7. Westlin, P. and Merrill, R. 2011. Data and procedure for handling below detection level data in analyzing various pollutant emissions databases for MACT and RTR emissions limits

. Memorandum from Peter Westlin, SPPD/MPG and Raymond Merril l, AQAD/MTG, to SPPD management and MACT rule writers. December 13, 2011. Docket Item No. EPA

HQ

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.Appendix A
Test Data N ot U sedA

- 1 Table A
- 1 Test Data Removed from Database after QA/QC, Not Used in MACT Floor Analyses2 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 ; Removed PM Run 1 due to p robe and filter temp s outside M5 range
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 temperatures3 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 5/3 /2006 Roller Kiln 2008 Survey 59, 60 RK

- 1, RK

- 2 Removed PM Run 1 due to p robe and filter temp s outside M5 range
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 ; Removed PM Runs 1, 2, and 3 due to p robe and filter temp s outside M5 range

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 ; Removed PM Runs 1, 2, and 3 due to p robe and filter temp s outside M5 range

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
FLOR

- 1 Florim USA Clarksville TN 5/2 4 /2010 Glazing 2010 Survey 7 3, 74, 75 GL

- 3, 4, 5 Removed PM Run 1 due to p robe and filter temp s outside M5 range4 Facility ID Facility City State Test Date Unit Type Source RTI ID Source ID Explanation Why Data Excluded

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

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

- 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

KOHL

- SC Kohler Co. Spartanburg SC 8/16/2010 Manual glaze application 2010 Survey 2 LBM Removed PM Run 1 due to p robe and filter temp s outside M5 rangeAppendix B
Final R un - by

- R un ValuesB

- 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 CalculationsC

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

- by

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