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. 
Our careful review has found no production records that correspond specifically with Run 2, which occurred between 11:36 am and 12:37 pm. Further, the production problems that were noted in Run 3 and reported earlier to EPA preclude a definitive extrapolation of the production that occurred in Run 2. The total mechanical breakdown of the conveyor feeding tile to the kiln that eventually failed entirely during Run 3 did not occur precise.ly at the start of 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 response for the kiln unloading problems was to reduce feed to the kiln, and/or to create gaps in production where no tile is fed 

to the kiln. The available production records show that audible alarms went off throughout the entire shift that included all 3 runs of the stack test. In short, ''commotion" was the common production theme on this day for this kiln. Production staff was focused on attempting to maintain production by concentrating on the 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 to the extent possible using the information available. We have examined the meager production department records for the shift, which are broken down by production time segments. The relevant segment for Run 2 covers the period from 9:00 am until 1 :59 pm. It shows that a maximum 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 x 299 minutes). Design ·capacity is bas~d on the size of the tile being produced and the speed of the kiln, described as the 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 am until 1 :59 pm, 159 minutes of production at any production rate were noted. lnis leaves 140 minutes of actual downtime, meaning in this context that no tile was fired 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, a valid stack test for permit compliance purposes requires a production rate representative of.normal operating conditions as close to de~gn capacity as possible, but in no event not less than 90 percent of the design rate. Among the long-recognized reasons for this requirement is that the conditions \\<i.thin the source, here the kiln, vary in important ways that 

can and do impact the evolution of air pollutants and ultimately measured emission rates. 
evolution from the green clay body of the tile as it is heated, were extraordinari

y 

w 

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 be nondetect 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 October 
Very truly yours, 

cc: Howard L Gilberg, Esq. 

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