From: Susan Miller [mailto:SMiller@bia.org]
Sent: Monday, June 08, 2015 2:21 PM
To: Nizich, Sharon <Nizich.Sharon@epa.gov>
Cc: Raymond, Gabrielle <graymond@rti.org>; Sroka, Kristin <ksroka@rti.org>; Holloway, Thomas C. (Tom) <tcholloway@rti.org> Subject: RE: more information needed on kiln test reports for uncontrolled kilns

Yes- It is the “Ninety-Six” plant for Hanson. The plant has been demolished- no kilns exist there anymore. Yes, it should be removed from the inventory.

Susan Miller 919 380-2191 smiller@bia.org

When you talk, you are only repeating what you al ready know; but when you listen, you may learn something new. -Dalai Lama

From: Nizich, Sharon [mailto:Nizich.Sharon@epa.gov]
Sent: Monday, June 08, 2015 1:19 PM
To: Susan Miller
Cc: Barnett, Keith
Subject: FW: more information needed on kiln test reports for uncontrolled kilns

Susan – this is the data we have for this plant in Ninety-Six. So you are saying it should be removed since it was demolished?

From: Raymond, Gabrielle
Sent: Monday, June 08, 2015 1:02 PM
To: Nizich, Sharon
Cc: Sroka, Kristin; Holloway, Thomas C. (Tom)
Subject: RE: more information needed on kiln test reports for uncontrolled kilns

The company is still Hanson, the location should be Ninety-Six, SC not Columbia, SC.

Also there are 3 kilns at this location in our inventory.

663 HANS9 BIA-010 32 Hanson Brick East, LLC HansonNinety Six Ninety-Six SC tk-1664 HANS9 BIA-010 32 Hanson Brick East, LLC HansonNinety Six Ninety-Six SC tk-2

665 HANS9 BIA-010 32 Hanson Brick East, LLC HansonNinety Six Ninety-Six SC tk-3

Gabrielle Raymond RTI International 3040 Cornwallis Road P.O. Box 12194 Research Triangle Park, NC 27709 Phone: (919) 541-7015

From: Nizich, Sharon [mailto:Nizich.Sharon@epa.gov]
Sent: Monday, June 08, 2015 12:44 PM
To: Susan Miller
Cc: Raymond, Gabrielle; Sroka, Kristin; Holloway, Thomas C. (Tom)
Subject: RE: more information needed on kiln test reports for uncontrolled kilns

Ok thanks. I believe you are saying that the Hanson test below should have been labelled a kiln called the “Ninety-Six” kiln, and that labelling it the Hansen Brick company test is a mistake. If that is the case, I think you are saying that the “Ninety-Six” kiln was shut down and thus is not representative of current conditions. ?? Thanks.

Sharon Nizich US EPA Office of Air Quality Planning and Standards Sector Policies and Programs Division/SPPD RTP NC 27711 (919) 541 2825

From: Susan Miller [mailto:SMiller@bia.org]
Sent: Monday, June 08, 2015 12:29 PM
To: Nizich, Sharon Subject: RE: more information needed on kiln test reports for uncontrolled kilns

We did not have a copy of the test report for Hanson- FYI- It is actually the Ninety-Six plant that was tested on that date, not Columbia. When we searched the docket, the item labeled as this test is not this test – instead it is the original 1998 ICRs for Hanson.

The Ninety-Six plant has not operated in years and is currently an open field (all kilns are long gone). This plant was built in the 50s or so and did not survive the recent recession. Can the not be removed from the database since it no longer exists? Seems like it should not be in there.Thanks

sus

Susan Miller 919 380-2191 smiller@bia.org

When you talk, you are only repeating what you al ready know; but when you listen, you may learn something new. -Dalai Lama

From: Nizich, Sharon [mailto:Nizich.Sharon@epa.gov]
Sent: Monday, June 08, 2015 11:21 AM
To: Susan Miller; terry.schimmel@boral.com Subject: FW: more information needed on kiln test reports for uncontrolled kilns

Thanks!

Sharon Nizich US EPA Office of Air Quality Planning and Standards Sector Policies and Programs Division/SPPD RTP NC 27711 (919) 541 2825

From: Raymond, Gabrielle [mailto:graymond@rti.org]
Sent: Monday, June 08, 2015 11:17 AM
To: Nizich, Sharon; Sroka, Kristin; Holloway, Thomas C. (Tom) Subject: RE: more information needed on kiln test reports for uncontrolled kilns

RTI Inventory - Kiln No Company Plant Location

(City) Plant Location

State APCD Type QA1 Average PM for each kiln (lb/ton), corrected for

PM<1mg Test Date 695 Lee Brick and Tile Co S anford NC None 0.013 3/29/2005

549 Boral Bricks, Inc. - Gleason Plant Gleason TN None 0.020 11/4/1998

665 Hanson Brick (formally Jannock Limited) Columbia SC None 0.050037879 7/11/1997

Gabrielle RaymondRTI International 3040 Cornwallis Road P.O. Box 12194 Research Triangle Park, NC 27709 Phone: (919) 541-7015

From: Nizich, Sharon [mailto:Nizich.Sharon@epa.gov]
Sent: Monday, June 08, 2015 11:10 AM
To: Raymond, Gabrielle; Sroka, Kristin; Holloway, Thomas C. (Tom) Subject: FW: more information needed on kiln test reports for uncontrolled kilns

Gabrielle – do you have the dates for these runs below? Thanks.

Sharon Nizich US EPA Office of Air Quality Planning and Standards Sector Policies and Programs Division/SPPD RTP NC 27711 (919) 541 2825

From: Susan Miller [mailto:SMiller@bia.org]
Sent: Monday, June 08, 2015 11:02 AM
To: Nizich, Sharon; terry.schimmel@boral.com
Cc: Barnett, Keith Subject: RE: more information needed on kiln test reports for uncontrolled kilns

Can you give us the test dates? It will save me tracking them down... Terry has Gleason covered.

Susan Miller 919 380-2191 smiller@bia.org

When you talk, you are only repeating what you al ready know; but when you listen, you may learn something new. -Dalai Lama

From: Nizich, Sharon [mailto:Nizich.Sharon@epa.gov]
Sent: Monday, June 08, 2015 10:42 AM
To: 'terry.schimmel@boral.com'; 'Susan Miller'Cc: Barnett, Keith Subject: RE: more information needed on kiln test reports for uncontrolled kilns

Hello Terry/SusanI wanted to send you the emissions data for these 3 uncontrolled kilns with their associated low emission profiles generated from their tests, some dating back to 1998. As you know, at proposal we stated that we had data from all kilns that use fabric filters for PM control, and for that reason we believed that we had PM data from all the best performing sources in the source category. Commenters noted that there were uncontrolled kilns that also had low emissions and that these kilns should have been included in the floor. The kilns we believe that they were referring to are the Boral Gleason plant, and the three kilns shown below. We note that the emission from these uncontrolled kiln are much lower than the average for uncontrolled kilns, and we do not understand the reason. Terry stated that the kiln at the Gleason plant may have had low emission due to low draft which resulted in less PM entrainment. This kiln has undergone significant modifications, and that the old 1998 test may no longer be representative of current emissions. However, it would be helpful if we understood the reason why the other three kilns are showing low emissions. Perhaps you can answer the following:

1. Do you have any other test information for these kilns that you could send that would indicate that the emissions shown below are no longer representative of current performance?

2. Have these kilns been modified since they were tested, and if so, what specifically changed? What can be said about design types that would influence emission profiles?

3. Do you have any information on kiln des ign and operation that would help support our reasonable belief that fabric filter kilns do represent the best controlled sources for PM?

Let me know if you could send the info early next week.

Thank you!

RTI Inventory - Kiln No Company Plant Location

(City) Plant Location

State APCD Type QA1 Average PM for each kiln (lb/ton), corrected for PM<1mg 695 Lee Brick and Tile Co Sanford NC None 0.013

549 Boral Bricks, Inc. - Gleason Plant Gleason TN None 0.020

665 Hanson Brick (formally Jannock Limited) Columbia SC None 0.050037879

Sharon Nizich US EPA Office of Air Quality Planning and StandardsSector Policies and Programs Division/SPPD RTP NC 27711 (919) 541 2825