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 919-541-4332 
Brick and Structural Clay Products & 

Ceramics Manufacturing NESHA

Briefing for OMB

October 2, 2014
Deliberative- Do not Cite or Quote 

Brick 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, 201

signature on September 24, 2015
Deliberative- Do not Cite or Quote 

Brick and Structural Clay ProductsHealth-Based Standards

► We are proposing a single numerical limit that results in 

index (HI) ≤ 1 for all facilities

► Modeling of all facilities indicates annual emission limit o

(HCl-equivalent) would result in HI ≤ 1

► All but one brick plant estimated to have HCl-equivalent 

below 250 tpy

► We believe facts presented in previous rulemakings that 

health-based standards are not present here

► Co-benefits of MACT floor are low compared to cement and bo► We have data on facility locations and stack parameters neede

address both chronic and acute exposure 

► Brick does not have co-location issues that were identified in bo► Health-based standards for brick will not present significant or w

ecological effects

► Industry strongly supports health-based standard 
Deliberative- Do not Cite or Quote 

Brick and Structural Clay Products Regulatory Options Currently Under Conside

► All options in the preamble include health-based standar

gases

► Proposed Option: Health-based standards for acid gases; 

metals in various alternative formats (lb/ton concentration, 

► PM floor based on dry injection fabric filter (DIFF) as best perform

► Alternative Option : Same as proposed option except PM 

based on DIFF controls; instead, based on 12% of availadata; we are soliciting comment on the alternative option 

► Based on recommendations of Small Business Advocac

Panel, we are also taking comment on work practices fogive industry opportunity to provide input and information

► Work practices under section 112(h) are justified only in cases 

application of measurement methodology to particular class opracticable due to technological and economic limitations
Deliberative- Do not Cite or Quote 

Clay Ceramics Manufacturing Background

► Clay ceramics manufacturing source category is compris

subcategories: wall tile, floor tile and sanitary ware manu

► Tile manufacturing had 5 major sources, but all have rep

become area sources

► No emission reductions or cost impacts

► Sanitary ware manufacturing has 3 major sources, all of 

owned by Kohler; remaining facilities are area sources

► Pollutants emitted from clay ceramics manufacturing are

► Acid gases (HF and HCl)► HAP metals (PM as surrogate)► Mercury (Hg) ► Dioxins and furans (D/F)

► As with brick source category, total HAP emissions are lo

tenth of total emissions compared to brick category)

► No small businesses in clay ceramics manufacturing sou

category
Deliberative- Do not Cite or Quote 

Clay Ceramics Manufacturing 

► We are proposing emission limits for three subcatego

tile, floor tile and sanitary ware

► We are proposing health-based standards for acid ga

clay ceramics manufacturing

► Floor Tile and Wall Tile manufacturers have requested 

do not set standards for floor or wall tile manufacturinthere are currently no major sources left in those subc

► Sanitary Ware:

► We anticipate no significant impacts for sanitary ware fa► All three major source facilities are expected to remain 

sources