### BY EMAIL 

### M$. Sharon Nizich U.S. Environmental Protection Agency Sector Policies and Programs Division August

1, 2013 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 Florim USA May 2010 Kiln HF and HCl Data Dear Ms. Nizich: This letter is written
to renew our request
to excJude the Florim USA May 2010 stack test in its entirety from the MACT Floor data set. It is written in follow up to discussions with Mr. Barnett, Mr. Telaqder and RTI ("EPA") on March 28 

### in which

a presentation requesting this e.xclusion was submitted **base~** on problems during Run 3.

1 In that March 28 meeting, EPA stated that even 

### if. it agreed that Run
3 should be excluded,

it had that authority

to rely on, and use two runs from this stack **t~ting** event. We disagreed then and respectfully,
we continue
to disagree.

.. The premise of this letter is that we have subsequently learned that there were production and equipment problems during Run
2 of this stack testing event, which should lead EPA to exclude those data from MACT Floor data set and with only one successful run, must result in exclusion of the entire May 2010 stack test data set from the MACT Floor. In our meeting on March 28, EPA, RTI specifically and voluntarily questioned whether we had examined the validity ofthe Run
2 data. It was pointed out that data from Run
2 were as aberrational

as the 

### data from Run 3. Since our focus had been on the kiln operaJing conditions during Run 3, we cmdd only concur at that time with this description
of the Run
2 data and agree to examine

it more closely. 1 Following that meeting, you advised TCNA counsel that that EPA determined

to discard the Run
3 data, based on our presentation.Ms. Sharon Nizich U.S. Environmental Protection Agency August

1, 2013 Page2 We have nowscrutinized Run
2 carefully. We started with the production information for Run
2 reported by Entec under

aclaim of Confidential Business Information

by within its response
tothe EPA March 2010 Information Collection Request (''ICR"). Regrettably,
wehave learned that the production information
we provided
toEntec wasthe theoretical rateand not reflective of actual production during Run 2 .. Our careful review has found no production records that correspond specifically with Run 2, which occurred between 11:36 amand 12:37 pm. Further, the production problems that were noted in Run
3 and reported earlier toEPA preclude

adefinitive extrapolation

of the production that occurred
in Run 2. The total mechanical breakdown
of the conveyor feeding tile tothe kiln that eventually failed entirely during Run
3 did notoccur precise.ly

atthe startof Run 3: signs of the breakdown were emerging earlier in the day. In **additio~**problems with the kiln unloading system were occurring earlier in the day. Tbe only informed responsefor the kiln unloading problems wasto reduce feed tothe kiln, and/or tocreate gapsin production where notile is fed tothe kiln. The available production records show that audible alarms wentoff throughout the entire shift that included
all 3 runsof the stack test.In short, ''commotion" wasthe common production theme onthis day for this kiln. Production staff wasfocused on attempting

to maintain production
by concentrating

onthe emerging equipment problems; keeping accurate production records associated with Run 2 apparently was secondary. We have made an attempt
to reconstruct production during Run
2 tothe extent possible using the information available. We have examined the meager production department records for the shift, which arebroken down by production time segments. The relevant segment for Run
2 coversthe period from 9:00 amuntil

1 :59 pm.It shows that
amaximum
of 4,084 pieces of tile were**prod~.bd**

**.**during this 299 minute period. The design production capacity for the .specific tile in production during this time period was 7,894 pieces (26.4 pieces/minutes

x299 minutes). Design ·capacity

is **bas~d**onthe size of the tile being produced and the speed of the kiln, described

asthe kiln firing cycle. The actual production
of only 4,084 pieces calculates out to only 51.?% of production capacity. I We further attempted

to extrapolate production during Run
2 by considering minutes of production. During the 299 minute period from 9:00 amuntil

1 :59 pm,159 minutes of production

at any production ratewerenoted. lnis leaves 140 minutes of actual downtime, meaning

in this context that notile wasfired 2.33 hours of the time. This 159:299 ratio for production compares very closely with the 51.7% production capacity described

in the preceding paragraph. Again, this shows that Run
2 was unrepresentative
and emissions results from it are therefore unusable. As you know,

avalid stack testfor permit compliance purposes requires

a production rate representative of.normal operating conditions

asclose to **de~gn**capacity
as possible, but in no eventnotless than 90 percent of the design rate. Among the long-recognized reasonsfor this requirement

is that the conditions \\<i.thin the source,here the kiln, varyin important waysthat canand do impact the evolution
of air pollutants and ultimately measured emission rates.Ms. Sharon Nizich U.S. Environmental Protection Agency August

1, 2013 Page3 Specifically, when

a fast fire tile roller kiln is operated

at very low production rates and/or in "fits and starts" relative
to its capacity, the tile residence time, the kiln firing temperature curve and the air flow (each of which are designed for

a 

### full kiln production)
are each substantially different, and synergistically, create wholly unrepresentative
kiln conditions and emissions. We are comfortable with the conclusion that HF and HCl emissions, the only source of which are evolution from the green clay body of the tile as it is heated, were extraordinarily low and/or non-detect during periods throughout Runs


### 2 and 

### 3 because
as time went on, production became more and more sporadic. As described above, commotion was the common production theme on this day for this kiln. Mechanical issues at the tile feed entrance
to the tile kiln prec1uded tile from entering the kiln for firing and the additional mechanical problems

at the end of the kiln encouraged production personnel

to introduce gaps between and among the tile entering the kiln, both of which resulted
in reduced production. The combination

of the two created the considerable downtime. Our bottom line is that there is no credible way for Florim or EPA to use the spotty production data to calculate valid/representative production-based emissions rates for the period of Run 

### 2. Despite the best of intentions
by Florim, and including the payment of considerable stack testing expepses, this problem

is incurable.
As previously and separately described

to EPA in connection with the Run
3 problems, Florim was so concerned with the situation that it retested this kiln for 

### HF and HCl emissions

in October 2010 to assure compliance with the EPA ICR.


### It had no expectation that EPA would consider the results from the May

, 2010 test to be credible. We believe that
a decision by EPA to use any of the May 2010 test results for 

### HF and HCl emissions woUJ(fbe completely arbitrary and without merit. ., .... We also find incompte1ensible
that either HF or HCl emission results could benondetect during any run of any kiln stack test. The chloride and fluoride loadings
in the materials entering the kiln do not vary significantly
are way too high for non-detect results to occur given the fact 

### that no coritrol device
is 100% efficient. Moreover, since it is well documented

by EPA and the industry that chlorides and fluorides are naturally occurring
in the raw materials and since loading
is relatively consistent,

it is technically inconceivable that the emission result for one of these pollutants would be non-detect and the other would be in a reasonably predictable and typically measured range. This is exactly the situation presented by Entec the May 201 0 test report. In conclusion.

a valid stack test requires the averaging
of three representative
one hour runs. In some very unusual circumstances
not present here,
it might be possible
to exclude one run and base results on the average of only two runs. However, since the May 20
l 0 did not have two valid and representative runs, none of the results are useable. Florim complied with the lCR by submitting representative data from the test performed

in October 2010. We had, and still have the full expectation that the results of May 2010 test would, in recognition
of the above, be discarded
by EPA as unrepresentative

and completely unusable.
Since EPA has the OctoberMs. Sharon Nizich U.S. Environmental Protection Agency August

1, 2013 Page4 201 0 results for this source, there is no compelling need for EPA to use the May 2010 HF and HCl **result~**for this kiln. They should be discarded; not to do so would be completely arbitrary. Thank you for your consideration

of this request. Very truly yours, cc: Howard

L Gilberg, Esq. 35404

.v2

""
. **~.**