# From: Telander, Jeff <Telander.Jeff@epa.gov>

Sent: Wednesday, October 01, 2014 10:05 AM

To: Frey, Nathan J.

Cc: Barnett, Keith

Subject: RE: Briefing for OMB on Brick and Structural Clay and Clay Ceramics Package

Nathan,

I’ve attached the slides we will use in our discussion tomorrow.

Jeff T.

<< Slides for 10-2 OMB briefing.pptx >>

From: Frey, Nathan J. <Nathan_J._Frey@omb.eop.gov>

Sent: Tuesday, September 30, 2014 4:04 PM

To: Barnett, Keith

Cc: Telander, Jeff

Subject: RE: Briefing for OMB on Brick and Structural Clay and Clay Ceramics Package

Perfect, thanks!

From: Barnett, Keith <Barnett.Keith@epa.gov>

Sent: Tuesday, September 30, 2014 4:01 PM

To: Frey, Nathan J.

Cc: Telander, Jeff

Subject: RE: Briefing for OMB on Brick and Structural Clay and Clay Ceramics Package

Working on them now – Paula Van Lahr (OP) is already invited.

Keith Barnett

Minerals and Manufacturing Group Leader

919-541-5605

# From: Frey, Nathan J. <Nathan_J._Frey@omb.eop.gov>

Sent: Tuesday, September 30, 2014 3:58 PM

To: Barnett, Keith; Telander, Jeff; VanLare, Paula; Jordan, Scott

Cc: Walton, Tom; Palma, Ted; Rimer, Kelly

Subject: RE: Briefing for OMB on Brick and Structural Clay and Clay Ceramics Package

Thanks Keith. If you have any materials (PP slides etc.) available in advance of Thursday please

pass along when ready.

Also, if you could invite the relevant EPA OP person(s) to the briefing that would be great.

Best,

Nathan

-----Original Appointment-----

From: Barnett, Keith <Barnett.Keith@epa.gov>

Sent: Tuesday, September 30, 2014 3:52 PM

To: Telander, Jeff; Frey, Nathan J.; VanLare, Paula; Jordan, Scott

Cc: Walton, Tom; Palma, Ted; Rimer, Kelly

Subject: Briefing for OMB on Brick and Structural Clay and Clay Ceramics Package

When: Thursday, October 02, 2014 2:00 PM-3:00 PM (UTC-05:00) Eastern Time (US &

Canada).

Where: D231B and Phone Line 919-541-4332Brick and Structural Clay Products & ClayCeramics Manufacturing NESHAPBriefing for OMBOctober 2, 2014Deliberative- Do not Cite or QuoteBrick and Structural Clay ProductsBackground►Brick industry (major sources)►44 companies (8 large and 36 small)►Tunnel kilns – 172 kilns nationwide; 75 at small businesses►120 of 172 kilns are uncontrolled►Pollutants emitted from source category include:►Hydrogen fluoride (HF)►Hydrogen chloride (HCl)►Chlorine (Cl2)►HAP metals►Mercury (Hg)►Dioxins►Particulate matter (PM)►Compared to other source categories, emissions are low►Brick industry is economically stressed►Rule being developed under tier 2 rulemaking process►Per consent decree, proposal signature on November 20, 2014, and finalsignature on September 24, 20152Deliberative- Do not Cite or QuoteBrick and Structural Clay ProductsHealth-Based Standards►We are proposing a single numerical limit that results in hazardindex (HI)≤1 for all facilities►Modeling of all facilities indicates annual emission limit of ~250 tpy(HCl-equivalent) would result in HI≤1►All but one brick plant estimated to have HCl-equivalent emissionsbelow 250 tpy►We believe facts presented in previous rulemakingsthat rejectedhealth-based standards are not present here►Co-benefits of MACT floor are low compared to cement and boilers►We have data on facility locations and stack parameters needed toaddress both chronic and acute exposure►Brick does not have co-location issues that were identifiedin boilers►Health-based standards for brick will not present significant or widespreadecological effects►Industry strongly supports health-based standard3Deliberative- Do not Cite or QuoteBrick and Structural Clay ProductsRegulatory Options Currently Under Consideration►All options in the preamble include health-based standards for acidgases►Proposed Option: Health-based standards for acid gases; PM andmetals in various alternative formats (lb/ton concentration, lb/hr)►PM floor based on dry injection fabric filter (DIFF) as best performing sources►Alternative Option : Same as proposed option exceptPM floor is notbased on DIFF controls; instead, based on 12% of available PMdata; we are soliciting comment on the alternativeoption►Based on recommendations of Small Business AdvocacyReviewPanel, we are also taking comment on work practicesfor metals togive industry opportunity to provide input and information►Work practices under section 112(h) are justified only incases whereapplication of measurement methodology to particular class of sources is notpracticable due to technological and economic limitations4Deliberative- Do not Cite or QuoteClay Ceramics ManufacturingBackground►Clay ceramics manufacturing source category is comprised of 3subcategories: wall tile, floor tile and sanitary ware manufacturing►Tile manufacturing had 5 major sources, but all have reportedlybecome area sources►No emission reductions or cost impacts►Sanitary ware manufacturing has 3 major sources, all of which areowned by Kohler; remaining facilities are area sources►Pollutants emitted from clay ceramics manufacturingare:►Acid gases (HF and HCl)►HAP metals (PM as surrogate)►Mercury (Hg)►Dioxins and furans (D/F)►As with brick source category, total HAP emissionsare low (only onetenth of total emissions compared to brick category)►No small businesses in clay ceramics manufacturingsourcecategory5Deliberative- Do not Cite or QuoteClay Ceramics Manufacturing►We are proposing emission limits for three subcategories: walltile, floor tile and sanitary ware►We are proposing health-based standards for acid gases fromclay ceramics manufacturing►Floor Tile and Wall Tile manufacturers have requested that wedo not set standards for floor or wall tile manufacturing sincethere are currently no major sources left in thosesubcategories►Sanitary Ware:►We anticipate no significant impacts for sanitary ware facilities►All three major source facilities are expected to remain majorsources6