## Email Communication with OAR

From: Jeff Telander To: William Swietlik Date: Wednesday, May 21, 2014 11:23 AM Subject: RE: Brick and Clay follow

- up

There are 3 wet scrubbers at 2 different brick facil ities (see list below). Both of these facilities are synthetic area sources that would not be subject to the BSCP rule.

Company Name Facility

Name Emission

Unit ID Kiln

Design Capacity Year

built Kiln Fuel Control Measure Description Yr

APCD Installed Class Entity Size

Pacific Coast Building Products Pacific Coast

West Jordan LINE 3 16.33 1977 Natural
gas Wet Scrubber 1996 Area Source (synthetic) Large

Entity

Pacific Coast Building Products Pacific Coast

West Jordan LINE 4 20.79 1982 Natural
gas Wet Scrubber 2000 Area Source (synthetic) Large

Entity

Glen Gery Glen

- Gery

Corporation

Hanley SID

- 113 14.70 2002 Natural
gas Wet Scrubber 2003 Area Source (synthetic) Large

Entity



### With regard to the Clay Ceramics source category

Sanitaryware has 2 wet scrubbers at major sources, one on a kiln, and one controlling two glaze spray booths. Each row represents a different wet scrubber; if multiple kilns or glaze lines are listed in the Kiln ID or Glaze ID column, that means they are vented together.

Kiln

Company Name Facility

Name City State Kiln ID Production rate, ton/hr APCD

ID / Stack ID Fuel APCD

Type Class Kohler Co. Kohler,

Spartanburg Plant Spartanb

urg SC 38

-

TK

10 0.735 POC,

RCE (2 stacks) Natu

ral Gas Wet Scrubber Major



### Glazing Company Name Facility Name City State Glaze ID APCD ID APCD

Type Class Kohler Co. Kohler, Wisconsin

Plant Kohler WI P16A

- Q04, P16B

- Q05 S16 Wet Scrubber Major



### Ceramic tile has four wet scrubbers controlling kilns at two facilities and five controlling glaze lines at two facilities, but since all the floor tile facilities became synthetic area, none of the wet scrubbers are at major sources. Each row represents a different wet scrubber; if multiple kilns or

### glaze lines are listed in the Kiln ID or Glaze ID column, that means they are vented togeth er.

Also, green font in the rows for Dal Italia and Florim indicates something that changed when they became synthetic area.

Kilns

Company Name Facility

Name City State Kiln ID APCD ID / Stack ID Fuel APCD

Type Class Subcategory Dal

- Tile Corp. Dal

Italia Muskogee OK RK

1, RK

- 5 EPN

20 Natural

Gas Wet

Scrubber Area

Source (synthetic) Floor Tile

Dal

- Tile Corp. Dal

Italia Muskogee OK RK

2, RK

3, RK

- 4 EPN

29 Natural

Gas Wet

Scrubber Area

Source (synthetic) Floor Tile

Mohawk Industries Dal

- Tile

Dallas Plant Dallas TX RK

99

- 1, RK

99

- 2 EPN

99 Natural

Gas Wet

Scrubber Area

Source (synthetic) Wall Tile

Mohawk Industries Dal

- Tile

Dallas Plant Dallas TX RK

100

- 2, RK

100

- 3 EPN

100 Natural Gas Wet

Scrubber Area

Source (synthetic) Wall Tile



### Glazing Company Name Facility

Name City State Glaze ID APCD ID APCD

Type Class Florim Ceramiche S.p.A Florim USA Clarksville TN GL

- 3, GL

4, GL

- 5 CD

- 2 Wet Scrubber Area Source

(synthetic)

Florim Ceramiche S.p.A Florim USA Clarksville TN GL

- 6, GL

7, GL

- 8 CD

- 3 Wet Scrubber Area Source

(synthetic)

Florim Ceramiche S.p.A Florim USA Clarksville TN GL

- 9, GL

10, GL

- 11 CD

- 4 Wet Scrubber Area Source

(synthetic)

Mohawk Industries Dal

- Tile

Dallas Plant Dallas TX GL

- 203, GL

- 204 EPN

- 20 Wet Scrubber Area Source

(synthetic) Mohawk Industries Dal

- Tile

Dallas Plant Dallas TX GL

- 301, GL

- 302, GL

- 303, GL

- 306 EPN

- 43 Wet Scrubber Area Source

(synthetic)



### Please let me know if you need anything else.

### From: William Swietlik

To: Jeff Telander Date: Tuesday , May 20 , 2014 11:14 AM Subject: RE: Brick and Clay follow

- up

Jeff: Got your phone call

— to clarify.....

I meant to say in the email below

-- Brick and Structural Clay Manufacturing, as that is what I was intending to talk about on the phone with you last week, but maybe wasn’t clear. Since we are going to close out our investigation of this industry as NOT needing wastewater discharge standards given there is little likelihood that scrubbers are being installed and generating a new water wastestreams (a possibility we were pursuing p rior to realizing the NESHAPS had been vacated), it would be good for us to have some documentation indicating how few of these types of facilities actually do use scrubbers.

Since you said there were less than 10 facilities using scrubbers, primarily for SO2 emissions, I thought maybe you could send us an inventory, a listing or something like that that we could refer to when making our conclusions that no new water regulation is necessary.

If you were considering only Brick manufacturing when we were ta lking last week, and not Structural Clay manufacturing, does that make any difference?

In your phone message you implied it does not. So documentation showing how few use scrubbers for both of these industries would be helpful for us.

_______________________________ William F. Swietlik US EPA, Office of Water Engineering and Analysis Division (4303T) 1200 Pennsylvania Ave., NW Washington, DC 20460 202

- 566

- 1129: phone 202

- 566

- 1053: Fax From: William Swietlik To: Jeff Telander Date: Wednesday, May 14, 2014 3:49 PM Subject: Brick and Clay follow

- up

Jeff:

Thanks for talking with me today.

In follow

- up to our conversation, is there any documentation you can send me on the Brick and Clay facilities that do use scrubbers for SO2 control??

### Since there are less than 10 such facilities, this most likely means we have no wastewater

discharge issues with the industry, but to make this conclusion in our annual report, it would be good to have supporting documentation.

___________________________ ____ William F. Swietlik US EPA, Office of Water Engineering and Analysis Division (4303T) 1200 Pennsylvania Ave., NW Washington, DC 20460 202

- 566

- 1129: phone 202

- 566

- 1053: Fax