Glen-Gery Corporation Technical Services/Research

433 South Pottsville Pike Shoemakersville, PA 19555 610/562-3076 Fax: 610/562-2084 Fittp://www.glengerybrick.com

l m ;t r August 13, 2008

CERTIFIED MAIL NO.:

Mr. Jeffery Telander U.S. EPA Mailroom (D243-02) U. S. Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park, NC 27711

RE: U.S.E.P.A Information Survey on the Hazardous Air Po11_utant (HAP) emission sources and controls in the BSCP industry — Glen-Gery Corporation.

Dear Mr. Telander,

The Glen-Gery Corporation is pleased to submit the information requested by the U.S. Environmental Protection Agency (EPA) per your letter dated June 9, 2008. It is our hope that thc information we are providing combined with the information from others within the Brick and Structural Clay Products industry will provide the basis you seek for developing new BSCP industry standards that are fair, reasonable, and obtainable.

We feel that the information we have provided fulfills your requests but would
like to include some additional comments:
Form A — General Information: • We have included our current HAP source classification, but intend on reviewing the
status of each of our facilities.
Form B — Kiln Information:

• Please note that we have included closed facilities as well as demolished kilns in our survey to assist you in updating your current database. • The throughput values that we have indicated are based on 12 month rolling averages, not instantaneous limits. • The operating hours included for our kilns represent 2007 data. Please note that these hours are far less than our typical yearly operating desire (8,760 hr/yr). The economy typically dictates our operating conditions. We ask that you consider the existing economic hardship that currently exists and what additional impacts could result from a"MACT on MACT" determination that would affect our facilities that already installed controls and continue to operate them in "good faith". • Facility GLEN-8 (Marseilles, Illinois), Kiln A installed a DLA in 2006, but did not operate at all in 2007 (and continues to be idle) due to economic conditions.Form C — APCD Information:

• Alternative to Pressure Drop Monitoring and Remote Visual Limestone Level Inspection - In order for our kilns equipped with DLA's to meet the initial MACT HF and HCl emission standards, the DLA's had to be sure limestone was present within the DLA, and the kiln exhaust gas had to be directed through the DLA. Glen-Gery currently ensures that the limestone is present in the DLA by verifying that sufftcient limestone is in each silo using a series of level indicators as described in 70 FR 69662 and continuously monitoring of the limestone extraction screw setting. - The initial Brick MACT required performance testing to be conducted "while operating at the maximum production level". It was Glen-Gery's understanding that USEPA's reasoning for conducting the initial performance testing at maximum production levels was to ensure the DLA could achieve the required pollutant control under conditions that represented maximum HAP loading from the kiln. However, the Delta P across the DLA is a direct result of a variable speed fan located downstream from the DLA and is designed to control the volume of air based on pressure within the kiln. The volumes of air as well as kiln pressure vary for each product and/or production level. Therefore, if the initial performance tests were performed "while operating at maximum production level" and establishes a minimum delta P threshold used to determine on-going compliance, as soon as the production level decreases, the variable speed fan will slow down, decreasing the delta P below the established level. Different products require different kiln operating temperatures and push rates (tons/hour of brick). In addition, the size of the brick, stacking pattern for the brick stacked on the kiln car, and whether the bricks are solid or cored will affect the airflow through the kiln, directly affecting the delta P across the DLA. During these periods of lower fan speeds caused by decreased production rate, product temperature requirements, and particular brick loading configuration, meeting the minimum delta P requirement established during the performance testing would not be feasible. Note that this condition is worsened by the initial MACT requirement that the delta P after the performance test remain above the "average" of the pressures during the test. It would be difficult if not impossible for any brick manufacturer to maintain pressure above an average delta P during a stack test that is run at maximum production. - EPA has acknowledged that Delta P across the DLA is intended primarily to demonstrate that the kiln exhaust flow is directed through the DLA, as noted in 68 FR 26704, and not bypassing the control device. Glen-Gery feels that kiln exhaust flow to the DLA is verified by simply monitoring the bypass stack damper position (e.g., verifying the damper position at least once every fifteen minutes while the kiln is in normal operations). It is important to note that the damper is designed to be in either the open (i.e., bypassing the DLA) or closed (i.e., directing gas through the DLA) position, not to regulate kiln exhaust flow. By monitoring the bypass damper position, Glen-Gery can ensure that the kiln exhaust gases are directed through the DLA and thusemission levels can be achieved. Any period in which the bypass damper is opened allowing the kiln exhaust gas to bypass the DLA would be considered an event triggering corrective actions pursuant to the plants Start-up, Shut Down, and Malfunction Plan (SSMP). • The Glen-Gery Marseilles, Illinois facility (GLEN-8) was granted approval for this alternative monitoring by the USEPA Region 5 in October 2006. • The Glen-Gery Mid-Atlantic (GLEN-9) and York (GLEN-10) facilities were granted approval for this alternative monitoring by the Pennsylvania Department of Environmental Protection in May 2007.

Form E— Monitoring — other Costs • We have included two Form E's. The first Form E contains the average cost to operate the DLA's at the four (4) facilities currently operating DLA's (GLEN-4, 8, 9, 10). • The second Form E contains the cost to operate the one (1) wet scrubber located at Glen-Gery's Hanley Plant (GLEN-6).

Additional Enclosures: - The following items will be included in a separate Certified Mailing:■ Form F— Economics — This item contains Confidential Business

Information not meant for public distribution. Data CD including: • Stack Testing Reports • Plant Flow Diagram — Pennsylvania facilities • Raw material mass balance testing results.

If you require any additional inforrnation or need clarification on the information provided within this correspondence please feel free to contact Mike Krzyzanowski, Glen-Gery's Environmental Manager at 610-562-6427.

Sinc y,

G obinson Vice President Production — Glen-Gery Corporation

GR/mk

Enclosures