From: Schimmel, Terry (Bricks

- Phenix City) <Terry.Schimmel@boral.com>
Sent: Wed nesday

, October 31

, 2012 10:55 AM
To: Telander.Jeff@epamail.epa.gov
Cc: Keith Barnett <barnett.keith@epa.gov>; Ray mond, Gabrielle <graymond@rti.org>; Marinshaw, Richard <rjmarinshaw@rti.org>; Holloway, Thomas C. (Tom) <tcholloway@rti.org>; Sroka, Kristin <ksroka@rti.org>; Susan Miller <SMiller@bia.org>; Keon, Mary Ann (Industries

- Atlanta) MaryAnn.Keon@boral.com Subject: If RE: Clarification of Production During Testing at Bessemer, AL

Jeff, Sorry for the confusion and I thought we had the reports corrected but apparently not. The configuration of our DIFF and the reporting criteria of the ERT plus some of the learning curve on the testers part in reporting the data has been a challenge for all. Anyways here are the answers that hopefully will clear things up:

1. All of the dryer data is correctly reported at an approximate 12TPH throughput. We have 4 tunnel dryers that are paired into two exhaust duc ts. We tested only one as the sources are identical. Each pair of dryers feeds one of the two tunnel kilns.

2. All the DIFF data is outlet and represents a throughput of approximately 24 TPH. There is only one DIFF outlet stack and all of the flow from the tw o kilns exits via the scrubber and through that stack. Both kilns were operational and at the 12 TPH/each capacity during the

test.
3. The confusion on the reagent feed rate originates from the fact that there are separate
inlets to the DIFF from each individ ual kiln. Each inlet has a reagent feed system and at the time of the test each was feeding 72#/hr or a combined feed rate of 144#/hr. That said if it matters the 72# feed rate equates to a 12 TPH throughput of product.

Please let me know if this addresse s your questions.

TERRY SCHIMMEL V.P. Technical Services Boral Bricks Inc.

Office: (334) 480

- 2488 Mobile: (706) 575

- 6213 Fax: (334) 291

- 9627 Email: Terry.Schimmel@boral.com

100 Brickyard Road Phenix City Alabama 36869 http://www.boralbricks.com http://www.boralbuildingproducts.comF rom: Telander.Jeff@epamail.epa.gov [ mailto:Telander.Jeff@epamail.epa.gov ]
Sent: Tuesday, October 30, 2012 8:47 AM
To: Schimmel, Terry (Bricks

- Phenix City)
Cc: Keith Barnett; graymond@rti.org ; rjmarinshaw@rt i.org ; tcholloway@rti.org ; Sroka, Kristin Subject: Clarification of Production During Testing at Bessemer, AL

Hi Terry,

While reviewing the files submitted by Boral Bricks Bessemer, AL (BORA

- 5) Plant 6, we notice d a potential discrepancy that needs clarification. The 114 information request specified that Boral Bricks test the Bessemer, AL Plant 6 DIFF Stack, which controls emissions from two kilns (003 and 004). However, upon review of the test report and ERT f ile from the July 13

- 15, 2010 test, it is unclear whether one or both of the kilns that are ducted to the DIFF were actually operating during the testing.

We initially assumed that both kilns were operating during the testing because they both are ducte d to the DIFF and the test report does not indicate that only one kiln was operating. (In the process description section, there is only a statement that the process description was not provided (for some reason this page is only in the hard copy and was left out of the PDF).) The test report provides the production rate for each run in several places (summary tables in the hard copy, also page 68 of the PDF), but it never specifies if that is the total for both kilns or just one kiln, so we assumed that both kilns were operating at about 50% capacity. The production rates in the test report are listed below:

Run 1 = 11.99 ton of Fired Brick

Run 2 = 12.40 ton of Fired Brick

Run 3 = 12.40 ton of Fired Brick

When we compared the test report with the ERT file, we noticed a few things that made us question our original assumption. Although the ERT does not clearly state if both kilns were operating or if only one was operating, the ERT file includes this description of the source on page 2:

“Two Swin dell Dressler tunnel kilns controlled by an E.I. Tec Dry Injection Fabric Filter which uses hydrated lime as the reagent. The feed rate at the time of testing was 72 lbs of lime per hour. The throughput rate of the kilns is 24 tons/hr, which equates to 1 2 tons/hr per kilns.”

The production rate fields in the ERT were left blank (p. 18), so we do not know if this is a general description of the capacity of both kilns, or a description of the actual throughput during the test. Also,
the feed rate of lime is about half of the rate provided in the ICR response for this APCD, which could be consistent with either both kilns operating at about half capacity or one kiln operating while the other
was shut down.

Both reports are attached for your convenien ce. Note that the “Boral Bessemer July 2010 Test Report.pdf” does not include all the same pages as the hard copy version.I would appreciate it if you would clarify whether one or both of the kilns were operating during the July 2010 Brick MACT ICR testing. If both kilns were operating, please confirm that the production rate is for
the sum of the two kilns. We want to make sure we have the correct number of kilns correlating with the reported emiss ions and production rates in the test report.

Thanks,

Jeff

Jeff Telander Sector Policies and Programs Division Office of Air Quality Planning and Standards (D243

- 02)
RTP, NC 27711

919

- 541

- 5427

919

- 541

- 5450 (FAX)

Overnight mail address:

US EPA
Mail Code D243

- 02
109 TW Alexander Drive RTP, NC 27709

2 attachments (See attached file: Boral

- Bessemer,AL

- ERT

- Final Test Report.pdf) (See attached file: Boral Bessemer July 2010 Test Report.pdf)