Glen-Gery Corporation 

Technical Services/Research 

433 South Pottsville Pike 

Shoemakersville, PA 19555 

610/562-3076 

Fax: 610/562-2084 

Fittp://www.glengerybrick.com 

August 13, 2008 lm;tr 

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 thus 
emission 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