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 already 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-1 
664 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 already 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 Sanford 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 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 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 already 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 design 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 Standards 
Sector Policies and Programs Division/SPPD 

RTP NC 27711 

(919) 541 2825