### Air

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July 10, 2013

Howard L. Gilberg Guida, Slavich & Flores, P.C. 750 North St. Paul Street, Suite 200 Dallas, TX 75201

Re: Stonepea k Ceramics December 2005 Test Report

Dear Mr. Gilberg:

This letter concerns the review of the December 2005 test report of Stonepeak

Ceramics as referenced above. It supersedes my report dated March 2013. The testing company and analytical laboratory are both located in North Carolina. Our focus was

on the kil n HCI/HF results. The kiln was tested for HCI/HF by Method 26. Method 26A

, and not M ethod 26 with its mini

- impingers, is best for establishing standards, along with

Method 320.

Integrity conducted three sixty

- minute tests at the kiln main exhaust stack

. I have

reviewed numerous acid gas stack test s at clay ceramics plants during my lengthy

career

. I have conducted hundreds of HCl tests by Method 26 and Method 26A at Brick, Tile, Cement, Boilers and Industrial Furnaces. The report ed HF and HCl results at Stonepeak are impossibly low. Ceramic tile kilns process tens of thousands of pounds of tile at one time containing clay with high chloride and fluoride levels

. I cannot

recall ever have non

- detect results for HC l and HF

.

It is my professional judgment that t he HF and HCl results reported by Integrity reflect

conditions expected in the ambient atmosphere. The moistures of the sampling trains

are consistent with the sampling of ambient air. While leak checks were reportedly perfor med with success, there are a number of other opportunities that are not required

to be reported in a stack test that lead to the unexpected and unplanned measurement

of a mbient air, such as the probe not being placed in the proper loca tion in the stack. 

# A IR 

# T ECHHoward L. Gilberg Page 2 July 10 , 2013

These test results are not acceptable statistically ; they are statistical outliers not comparable to the HF and HCl results reported by major source floor tile plants in the industry to EPA. Those results, as recorded by EPA, are att ached to this presentation. The raw materials used and the production processes involved at Stonepeak are very similar to those found in floor tile plants whose results were reported to EPA , so I

discount this basis for explaining the reported results.

In a handwritten note on p age 60 of the Integrity report , it indicates that the stack testing was stopped and then restarted one hour and 13 minutes later (9:05 am to 10:18 am). This is a red flag. The report provides no explanation for this situation. We

q uestion the validity of a test run that is broken into a 20 minute segment followed by

over an hour’s delay before a final 40 minutes was run , especially with no explanation

for the situation

.

There are no production record field notes provided to support the emissions rates reported

. All we have are emails over two weeks after the testing was completed, which is inadequate. The stack test report does not provide records showing that operation of

the kiln was routine and being run at full capacity or was e mpty , or anything in between

. It is not uncommon for kilns with processing problems to be emptied of tile until

corrections are made

. A ceramic kiln not processing ceramic does not have fluorides or

chlorides in it to evolve as air emissions

. The repo rt does not indicate if a bypass stack was present . One explanation for HCl and HF measurements reflecting ambient air conditions is that a bypass stack might have inadvertently been in use . If it was, the Method 26 measurement equipment would have had no opportunity to come in contact with, or to measure the kiln exhaust gases during the stack testing. It would have been measuring ambient air present in the main exhaust stack.

There w as a probe and filter temperature abnormalit y in the testing and reportin g procedures , beginning on page 60 of the report . This field data sheet indicates that the desired probe and filter temperature was 250oF

, as required by the method, but there is

no indication on the data sheet itself as to whether this was achieved. In addition, there

is no documentation that t he probe and filter temperatures were maintained as required throughout the test ing runs. If the temperature was not maintained, then the results are invalidly biased lower than the actual emissions. This failure of the field technician to document the temperatures of the probe and the filter indicates, to me, that those temperatures were not maintained during the test. This conclusion is supported by the

low numbers in the test results. There also was no indic ation on the data sheet that the probe was in the stack. No stack temperature was recorded on the data sheet

.Howard L. Gilberg Page 3 July 10 , 2013

Maybe most critically, t here are no means to validate the HF results used because

t he re are no HF analytical results re ported by Element One, the laboratory. Results are provided for HCl and CL only on the M26

- A HF

- IC data sheets. Setting standards on assumed corrections of laboratory data would be inappropriate and arbitrary.

For all of these reasons, I c annot recommend this HF or HCl information be used for

any regulatory purpose

.

Sincerely,

Michael W. Hartman Managing Director/Principal Scientist (AT13

- 0 658

- GSF)