Glen-Gery Corporation Techn ica l Services I Research 433 South Pottsv ille Pike Shoemakersville, PA 19555 (610) 562-3076 Fax: (61 0) 562-2084 httpJ/www.g lengerybrick.com

DELIVERED VIA EMAIL- February 25, 2011 J effery Telander Te lande r .jeff@epa.gov US EPA Mailroom (D243-02) US Environmental Protection Agency Office of Air Quality and Standards 109. T.W. Alexande r Drive Research Tri ang l e Park, NC 27711 RE: Requirement to provide information according to Title 42 of the United States Code, Chapter 85, Subchapter I , Part A, section 74 1 4 (42 U.S.C 7414) Dear M r. Te lander, Per th e United Stat es Environmental Protection Agency l etter dated November 17, 2010, Th e Glen-G ery Co rp orat ion is submittin g th e req u ested inf o rm at io n per Titl e 42 of the United States Code, Chapter 85, Subchapte r I, Part A, sect ion 7414 (42 U.S .C 7414). Th e first part of th is request , start up and shutdown events at all Glen-Gery Corporation structural clay products manufacturing faci lities, can be found attached. The Glen-Gery Corporation understands and appreciates that t he second part of th i s requ est , Emissio ns of hydrogen fl uoride, hydrochlo ric acid, ch lorine, metals, and particulate matter from our Summervill e, P A plant, was waived per your email dated January 11 , 2011. If you have any question s regarding this response, please contact m e at mike
. krzyzanowski@o ldcastl eapg.com or (610) 562-3076. Si n ce re ly, 

## Glen ,lrporation

# t.t~**T~chnical** Services Manager
cc: Steve Matsick George Rob in sonStartup/Shutdown Survey: Qu estion #1: F aci lity Inform ation 

### A B 

## c D E Facility

I D Facility Name Physica l Address Mailing Address Latitude Longitude Glen-Gery Bigler 24 Pine Top Road PO Box 338 GLEN- 1 Plant Bigler PA 16825 Big le r PA**16825~338** 40.981583 -78 .30986 Glen-Gery 5692 Rinker Rd
. PO Box 398 GLEN-2 Caledonia Pla nt Caledo nia OH 43314 Caledonia OH 43314-0398 40.635971 -82 .97554 Glen-Gery Capitol 9905 Godwin Drive PO Box 3410 GLEN -3 Plant Manassas VA 20110 Manassas VA 20108 38
.740976 -77
.503787 G len- Gery Hanley 12637 Harriso n St
. PO Box 68 GLEN-4 Plant Summerville PA 14864 Summerville PA 1S864-0068 41.119582 - 79.18829 Glen-Gery Iberia 3785 Cardington - Iberia Rd. PO Box 207 GLEN-S Plant Iberia OH 43325 Iberia OH 43325..n208 40.657462 - 85
.85964 Glen-Gery 1401 Broa dway St. PO Box 306 GLEN-6 Marseilles Plant Ma rsei ll es IL 61341 Ma rseilles IL 61341 41.32 175 -88.68 5 76 Glen-Gery Mid- 423 S
. Pottsville Pike 423 S
. Pottsville Pike GLEN-7 Atlantic Plant Shoemakersville PA 19555 Shoemakersville PA 19555 40.48693 -75. 96239 Glen -Gery Redfie ld 1519 Old Highway #6 1520 Old Highway #6 GLEN-8 Plant Redfield l A S0233-8032 Redfi e ld lA 50233-8032 41.59253 -94.1829 Glen-Gery York 1090 E
. Boundary Ave
. 1091 E. Boundary Ave. GLEN-9 Plant York PA 17403-2920 York PA 17403-2920 39.95683 -76
.70423 Question #2: Startup/Shutdown Events The nine (9) faci l ities deta i led above all operate under individual State Required Tit le V Operating Permits
. None of the individual Tit l e V Operating Permits for the facilities above include any permit condit io n(s) or applicable limits specific for sta rtup or shu td own events. Therefore, no startup o r shutdown events in the past three (3) years can be li sted as resulting in the exceedance of an y permit condition or limit. Glen-Gery wou ld like to add that ju st becau se no l im its or conditions exist within the exist ing operating permits does not imp ly that emissions during normal kiln startup or shutdown events can be accurately depicted by stack emission testing. Not li sting an exceedance within this survey does not indicate Glen-Gery's facilities would automatically m eet a standard based solely on stack testing data
. It is our belief that certain situations and events during the normal ope ration of a brick manufacturing facility exist w h e re stack test emissio n data wou ld not acc urate ly represent kiln emissions all of the tim e. F or example, uncontrolled bypassing of air pollution contro l dev ices (APCD) must occur for certain ro utin e maintenance tasks. G l en-Gery operates six (6) Dry limestone Absorbers (DLA) at four (4) of its nine (9) f acil ities as well as one (1) wet scrubber at its Summerville, PA facili ty . DLA Routine control device maintenance exceptions were requ ested by Glen -Gery and granted by the state environmental agencies in Pennsy lva ni a for just this reason. The ro utine control device mainten a nce except ion s allow ou r facilities to bypass DLA control devices and continue operating wh il e routine maintenance is performed on the contro l device as long as the bypass time does not exceed 4% of the annual ope rat ing time for eac h affected ki l n DLA
. Th e routin e contro l devi ce ma i ntenance exce pt io n also allows our wet sc rubber f aci l ity (Summ erville, PA), which is currently a syn thetic minor

### for HAPs, to bypass their control device and continue operating while routine maintenance is performed on the control device as long as the bypass time does not exceed 72 hours per year per consecutive 12-month period. Since brick kilns operate continuously for extensive periods oftime between shutdowns (i.e. often several years), routine maintenance helps to ensure that the control device is operating properly and will continue to operate in a manner that will achieve the greatest amount of emission control. These exceptions also allow for the option of deferring inspections/maintenance activities with the intention of minimizing the potential for system malfunctions. The bypass operation of any control device is by nature electro-mechanical and is by no means fool-proof. Although routine preventive maintenance is conducted on these devices, malfunctions to these devices as well as other functions ofthe control device do occur. For instance, power outages occur frequently and can cause the control device to automatically assume a bypass condition to maintain the integrity and safety of the device. Therefore, bypassing the control device for certain occurrences during normal operating conditions is a realistic requirement to ensure efficient emission control overall. Our existing permits do not apply specific limits to emissions during these particular events. And, since the kilns are not controlled during the time of such events, we would expect that emissions during those times would not meet limits established by stack test data obtained from a control device that is operating as expected. Question #3: Startup/Shutdown Plan None of Glen-Gery's Plants are required to maintain or develop a startup and shutdown plan. Question 

### #4: Recommendation for a Startup/Shutdown Standard Glen-Gery is aware that the Brick Industry Association (BIA) is in the process of developing information for a comprehensive discussion of this issue for submittal this summer (2011). At that time The GlenGery Corporation 

### will be a participant in providing information for such a submittal.