Glen-Gery Corporation 

Technical Services I Research 

433 South Pottsville Pike 

Shoemakersville, PA 19555 

(610) 562-3076 

Fax: (61 0) 562-2084 

httpJ/www.glengerybrick.com 

DELIVERED VIA EMAIL- February 25, 2011 

Jeffery Telander 

Telander.jeff@epa.gov 

US EPA Mailroom (D243-02) 

US Environmental Protection Agency 

Office of Air Quality and Standards 

109. T.W. Alexander Drive 

Research Triangle Park, NC 27711 

RE: Requirement to provide information according to Title 42 of the United States Code, Chapter 85, 

Subchapter I, Part A, section 7414 (42 U.S.C 7414) 

Dear M r. Telander, 

Per the United States Environmental Protection Agency letter dated November 17, 2010, The Glen-Gery 

Corporation is submitting the requested information per Title 42 of the United States Code, Chapter 85, 

Subchapter I, Part A, section 7414 (42 U.S.C 7414). 

The first part of this request, startup and shutdown events at all Glen-Gery Corporation structural clay 

products manufacturing facilities, can be found attached. The Glen-Gery Corporation understands and 

appreciates that t he second part of this request, Emissions of hydrogen fl uoride, hydrochloric acid, 

chlorine, metals, and particulate matter from our Summerville, PA plant, was waived per your email 

dated January 11, 2011. 

If you have any questions regarding this response, please contact me at 

mike.krzyzanowski@oldcastleapg.com or (610) 562-3076. 

Sincerely, 

Glen,lrporation 

T~chnical 

t.t~ Services Manager 

cc: Steve Matsick 

George Robinson 
Startup/Shutdown Survey: 

Question #1: Facility Information 

A B c D E 

Facility 

ID Facility Name Physical Address Mailing Address Latitude Longitude 

Glen-Gery Bigler 24 Pine Top Road PO Box 338 

GLEN-1 Plant Bigler PA 16825 Bigler PA 16825~338 40.981583 -78.30986 

Glen-Gery 5692 Rinker Rd. PO Box 398 

GLEN-2 Caledonia Plant Caledonia 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 

Glen-Gery Hanley 12637 Harrison 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 Broadway St. PO Box 306 

GLEN-6 Marseilles Plant Marseilles IL 61341 Marseilles IL 61341 41.32175 -88.68576 

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 Redfield 1519 Old Highway #6 1520 Old Highway #6 

GLEN-8 Plant Redfield lA S0233-8032 Redfield 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) facilities detailed above all operate under individual State Required Tit le V Operating 

Permits. None of the individual Title V Operating Permits for the facilities above include any permit 

condition(s) or applicable limits specific for startup or shutdown events. Therefore, no startup or 

shutdown events in the past three (3) years can be listed as resulting in the exceedance of any permit 

condition or limit. Glen-Gery would like to add that just because no limits or conditions exist within the 

existing operating permits does not imply that emissions during normal kiln startup or shutdown events 

can be accurately depicted by stack emission testing. Not listing an exceedance within this survey does 

not indicate Glen-Gery's facilities would automatically meet a standard based solely on stack testing 

data. It is our belief that certain situations and events during the normal operation of a brick 

manufacturing facility exist where stack test emission data would not accurately represent kiln 

emissions all of the time. For example, uncontrolled bypassing of air pollution control devices (APCD) 

must occur for certain routine maintenance tasks. Glen-Gery operates six (6) Dry limestone Absorbers 

(DLA) at four (4) of its nine (9) facilities as well as one (1) wet scrubber at its Summerville, PA facility. 

DLA Routine control device maintenance exceptions were requested by Glen-Gery and granted by the 

state environmental agencies in Pennsylvania for just this reason. The routine control device 

maintenance exceptions allow our facilities to bypass DLA control devices and continue operating while 

routine maintenance is performed on the control device as long as the bypass time does not exceed 4% 

of the annual operating time for each affected ki ln DLA. The routine control device maintenance 

exception also allows our wet scrubber facility (Summerville, PA), which is currently a synthetic 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 of time 

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 of the 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.