MEMORANDUM

DATE: September 17, 2015

SUBJECT: Potential for Cumulative Effects from Emissions Sources Near Facilities in the 

Brick and Structural Clay Products Manufacturing and the Clay Ceramics 

Manufacturing Source Categories

FROM: Mark Morris

Health and Environmental Impacts Division

Office of Air Quality Planning and Standards

Ted Palma

Health and Environmental Impacts Division

Office of Air Quality Planning and Standards

TO: Docket EPA-HQ-OAR-2013-0290

Docket EPA-HQ-OAR-2013-0291

On December 18, 2014, the Environmental Protection Agency (EPA) proposed National 

Emission Standards for Hazardous Air Pollutants (NESHAP) for the Brick and Structural Clay 

Products (BSCP) Manufacturing source category and the Clay Ceramics Manufacturing source 

category (75 FR 75622)1. For both source categories, the EPA proposed health-based standards 

for acid gases, referred to as health-based emission limitations (HBEL). The proposed HBEL for 

the BSCP source category is 250 tons per year of hydrochloric acid (HCl)-equivalent emissions, 

and the proposed HBEL for the Clay Ceramics source category is 600 tons per year of HClequivalent emissions. To determine the HBEL for each source category, the EPA performed risk 

assessments to determine the level of emissions that would ensure health thresholds for acid 

gases are not exceeded (with an ample margin of safety) at any facility in each source category. 

2

 

The assessment for each source category prepared for the proposed rule included the impacts 

from all sources in the category; that is, the cumulative impacts of all sources in each source 

 

1 http://www.gpo.gov/fdsys/pkg/FR-2014-12-18/pdf/2014-28125.pdf

2 For more information, see the technical memoranda, “Risk Assessment to Determine a Health-Based Emission 

Limitation for Acid Gases for the Brick and Structural Clay Products Manufacturing Source Category,” Docket ID 

No. EPA-HQ-OAR-2013-0291-0132; and “Risk Assessment to Determine a Health-Based Emission Limitation for 

Acid Gases for the Clay Ceramics Manufacturing Source Category,” Docket ID No. EPA-HQ-OAR-2013-0290-

0213. 
2

category were considered. However, these assessments did not model other facilities near those 

in the source categories.

Several comments were received on the proposed rule regarding the potential impact of the 

emissions from multiple facilities (whether in the source category or not) to result in the 

exceedance of health thresholds. This memorandum describes an analysis of emissions data of 

facilities near those in the source categories, and why the EPA concludes from this analysis that 

the health thresholds would not be exceeded due to combined impacts of such emissions with 

those from facilities within the source categories emitting at the HBEL.

Modeled concentrations decrease nonlinearly with distance from a source. For the BSCP 

facilities with the five highest modeled hazard indices, the concentrations decreased by 90

percent on average at a location approximately one kilometer from the facility. For the clay 

ceramics facilities with the five highest modeled hazard indices, the concentrations decreased by 

75 percent on average at a location approximately one kilometer from the facility. These values

are typical, and indicate that the emissions from other facilities more than one kilometer from a 

BSCP or clay ceramics facility are unlikely to contribute significantly at the location of 

maximum concentration resulting from the source category emissions. Therefore, the analysis of 

facility locations described in this memorandum focuses on cases where facilities are within one 

kilometer of the facilities in the source categories. The risk assessment performed to establish the 

HBEL for each source category accounted for the impacts of multiple facilities in those source 

categories, but this current analysis examines the extent to which facilities in each source 

category are within one kilometer of each other. For facilities outside the source categories, the 

current analysis determines the amount of HCl-equivalent emissions from such sources that are 

within one kilometer of sources in the categories. This analysis does not assess the potential 

impacts of sources such as roadways, gas stations, and other nonpoint sources. There are 

inadequate emissions data for such sources to allow a refined assessment of their impacts at 

receptors near the sources in the source categories.

BSCP Manufacturing Source Category

Of the 91 facilities in the source category, there are only three clusters of facilities where 

there are sources within one kilometer of each other. These facilities are listed in Table 1.

Table 1. BSCP Manufacturing 1-Kilometer Facility Clusters

Facility ID

Hazard 

Index Company Name Facility Name City State

01073NEI8443 0.1 Boral Bricks Inc. Boral- Bessemer Plant #6 Bessemer AL

01073NEI8444 0.1 Boral Bricks Inc. Boral- Bessemer Plant #5 Bessemer AL

48021NEI6580 0.07 Acme Brick 

Company

Acme- Elgin Plant 

(ELP/ENP)

Elgin TX

48021NEITXRBSCP15 0.5 Elgin-Butler Brick 

Co

Elgin Butler Plant Elgin TX

39157NEI2OHT$6304 0.05 Belden Brick 

Company

Belden- Plant #6 

Sugarcreek

Sugarcreek OH

39157NEI2OHT16041 0.06 Belden Brick 

Company

Belden- Plant #2 

Sugarcreek

Sugarcreek OH

39157NEIOHT$6302 0.03 Belden Brick 

Company

Belden- Plant #8 

Sugarcreek

Sugarcreek OH

39157NEIOHT$6305 0.07 Belden Brick 

Company

Belden- Plant #3

Sugarcreek

Sugarcreek OH
3

39157NEIOHT$6306 0.1 Belden Brick 

Company

Belden- Plant #9

Sugarcreek

Sugarcreek OH

The area with the most facilities is Sugarcreek, Ohio. There are five facilities in that area, each 

within one kilometer of at least one other BSCP facility. These facilities are shown in Figure 1, 

along with the location of the highest modeled annual concentration for each facility. As shown 

in Figure 1, only two facilities share a point of maximum impact. However, even if all of the 

facilities shared the same location of maximum impact, health thresholds would not be exceeded 

because the sum of the hazard indices for all facilities is not greater than one.3 This is also the 

case for the other two facility clusters in Alabama and Texas given in Table 1.

Facility data from EPA’s 2011 National Emissions Inventory (Version 2)4 were used to locate 

nearby facilities that are not in the BSCP Manufacturing source category. Table 2 includes the 

acid gas emissions from all facilities in the 2011 NEI within one kilometer of a BSCP facility. 

Only four BSCP facilities have other facilities within one kilometer that emit acid gases. Of the 

four, the highest estimated hazard index is 0.7, and there is one facility within one kilometer that 

emits approximately 12 tons per year of HCl-equivalent emissions. This is less than five percent 

of the HBEL, so even if the additional emissions were emitted from the BSCP facility, they 

would not result in a hazard index greater than one. The other BSCP facilities with other nearby

facilities have even lower estimated hazard indices, and the emissions from the nearby facilities 

would not result in a hazard index greater than one in those cases.

Table 3 includes all HAP emissions (in HCl equivalents) from all point sources in the 2011 NEI 

that are within one kilometer of a BSCP facility, sorted by the estimated hazard index for the 

BSCP facility. Table 3 also includes the count of facilities near each BSCP facility. This count 

includes the BSCP facilities if those facilities are in the 2011 NEI, so a count of one generally 

indicates the BSCP facility itself. Some BSCP facilities have a count of zero because the facility 

is either not in the 2011 NEI or the NEI includes a single location for a facility that has multiple 

locations in the source category dataset. In the latter case, the single NEI location may not be 

within one kilometer of a facility location in the source category dataset. Because the HBEL 

level of 250 tons per year of HCl-equivalent emissions reflects a hazard index of one at the worst 

case facility, each 25 ton per year increment in emissions would reflect a contribution no more 

than 0.1 to the hazard index for any facility. Based on the HCl-equivalent emissions in Table 3, 

no BSCP facility would exceed a hazard index of one due to the emissions of nearby facilities. 

 

3

If the hazard index is not greater than one, then the concentration of each pollutant included in the index is below 

its Reference Concentration (RfC). The RfC is defined as an “estimate (with uncertainty spanning perhaps an order 

of magnitude) of a continuous inhalation exposure to the human population (including sensitive subgroups) that is 

likely to be without an appreciable risk of deleterious effects during a lifetime.”

4 http://www.epa.gov/ttn/chief/net/2011inventory.html
4

Figure 1. BSCP Facility Cluster in Sugarcreek, Ohio.
Table 2. Acid Gas Emissions from Facilities in the 2011 NEI within 1 Kilometer of a BSCP Facility.

Facility ID

Company 

Name

Facility 

Name City State

Hazard 

index

NEI 

Facility 

ID

Nearby 

Facility 

Name Longitude Latitude

Sum of 

HClEquivalent 

Emissions

(TPY)

01115NEIALRBSCP15 Ragland 

Clay 

Products, 

LLC

Ragland 

Clay 

Products

Ragland AL 0.7 949611 National 

Cement Co 

of Alabama

-86.155217 33.733584 11.83

51775NEIVA7750000 Old 

Virginia 

Brick Co

Old 

VirginiaSalem

Salem VA 0.2 6633711 Rowe Fine 

Furniture Inc

-80.088635 37.28324 0.99

28087NEIMS1773 Columbus 

Brick Co

Columbus 

Brick 

Company

Columbus MS 0.2 8231711 Sanderson 

Plumbing 

Products Inc

-88.407515 33.507213 0.56

18167NEIBORA18 Boral 

Bricks 

Inc.

BoralTerre 

Haute 

Plant

Terre 

Haute

IN 0.07 4147911 SYCAMORE 

RIDGE 

LANDFILL

-87.3316 39.31003 0.91

Table 3. HAP Emissions from Facilities in the 2011 NEI Within 1 Kilometer of a BSCP Facility.

Company Name Facility Name City State Longitude Latitude

Hazard

Index

Count of 

Nearby 

Facilities4

Sum of HClEquivalent

Emissions

(TPY)

International 

Chimney Corp

Continental ClayKittanningKittanning PA -79.518108 40.821349 1 0 0.00

Interpace

Industries Inc

Interpace Industries Ogden UT -111.995479 41.284749 1 1 0.15

American Eagle 

Brick Co

American Eagle Brick 

Co

Sunland Park NM -106.529317 31.786562 0.9 0 0.00

General Shale 

Brick, Inc

General Shale BrickPlants 6 & 28Atkins (Marion) VA -81.375359 36.882928 0.9 0 0.00

Higgins Brick Co Higgins Brick Chino Hills CA -117.690227 33.963315 0.8 0 0.00

Glen Gery Glen-Gery 

Corporation-York

York PA -76.704031 39.957846 0.8 2 21.31

Summitville Tiles, 

Inc.

Summitville Tiles, Inc.-

Minerva Plant

Minerva OH -81.123062 40.714413 0.7 1 6.13

Kasten Clay 

Products Co

Kasten Clay Products Jackson MO -89.670693 37.374147 0.7 0 0.00
2

Company Name Facility Name City State Longitude Latitude

Hazard

Index

Count of 

Nearby 

Facilities4

Sum of HClEquivalent

Emissions

(TPY)

Ragland Clay 

Products, LLC

Ragland Clay 

Products

Ragland AL -86.159171 33.737182 0.7 1 17.75

Mohawk 

Industries

Dal-Tile, Lewisport, 

Kentucky

Lewisport KY -86.904955 37.929608 0.7 1 17.00

Richards Brick 

Co

Richards Brick Edwardsville IL -89.945087 38.810684 0.6 1 7.10

Elgin-Butler Brick 

Co

Elgin Butler Plant Elgin TX -97.287295 30.319633 0.5 1 57.62

Cunningham 

Brick Company, 

Inc

CunninghamCleveland CoGrover NC -81.421986 35.182444 0.5 1 13.13

Summit Pressed 

Brick and Tile Co

Summit- Brick Plant 

and Storage Yard

Pueblo CO -104.598361 38.280178 0.5 2 7.27

Watsontown 

Brick Co

Watsontown Brick Watsontown PA -76.849829 41.069862 0.4 1 65.94

Acme Brick 

Company

Acme- Tulsa Plant 

(TUP)

Tulsa OK -95.930250 36.179775 0.4 1 70.83

Hanson Brick 

East, LLC

Hanson- Elgin Elgin TX -97.338093 30.329765 0.4 1 56.39

Acme Brick 

Company

Acme- Perla Plant 

(PEP/PWP)

Malvern AR -92.830041 34.356880 0.4 0 0.00

Old Virginia Brick 

Co

Old Virginia- Madison 

Heights

Madison Heights VA -79.147124 37.462547 0.4 1 46.94

Certainteed 

Corporation

Certainteed 

Corporation- Ludowici

New Lexington OH -82.239583 39.719549 0.3 0 0.00

Acme Brick 

Company

Acme- Wheeler Plant 

(WTP)

Jonesboro AR -90.756928 35.851781 0.3 0 0.00

Cunningham 

Brick Company, 

Inc

CunninghamThomasvilleThomasville NC -80.127336 35.797711 0.3 1 6.79

Commercial Brick 

Corp

Commercial Brick 

Corp

Wewoka OK -96.544959 35.176775 0.3 1 39.71

Statesville Brick 

Co

Statesville Brick Statesville NC -81.034210 35.712860 0.3 1 12.63

Belden Brick 

Company

Belden- Plant 1 

Strasburg

Strasburg OH -81.507642 40.591347 0.3 0 0.00

Boral Bricks Inc. Boral- Phenix CityPlant 3Phenix City AL -84.993796 32.446413 0.2 0 0.00

Acme Brick 

Company

Acme- Kanapolis 

Plant (KAP)

Kanopolis KS -98.150757 38.712805 0.2 1 0.00
3

Company Name Facility Name City State Longitude Latitude

Hazard

Index

Count of 

Nearby 

Facilities4

Sum of HClEquivalent

Emissions

(TPY)

Glen Gery Glen-Gery 

Corporation - Capitol

Manassas VA -77.505506 38.741076 0.2 0 0.00

Columbus Brick 

Co

Columbus Brick 

Company

Columbus MS -88.412461 33.514209 0.2 2 65.06

Whitacre Greer Whitacre Greer Alliance OH -81.084587 40.905877 0.2 0 0.00

Glen Gery Glen-Gery 

Corporation-Bigler

Bigler PA -78.310454 40.980834 0.2 1 11.60

Old Virginia Brick 

Co

Old Virginia-Salem Salem VA -80.099044 37.283187 0.2 3 39.05

General Shale 

Brick, Inc

General ShaleCorbin-Plant 33Woodbine KY -84.093053 36.899602 0.2 0 0.00

Acme Brick 

Company

Acme- Bennett Tunnel 

Plant (BTP)

Millsap TX -98.052484 32.716232 0.2 0 0.00

McAvoy Brick Co McAvoy Brick Phoenixville PA -75.479659 40.125548 0.2 1 22.44

Glen Gery Glen-Gery 

Corporation-Redfield

Redfield IA -94.184608 41.593004 0.2 1 1.30

L.P. McNear 

Brick Co, Inc

McNear Brickyard San Rafael CA -122.462124 37.982979 0.2 0 0.00

Hanson Brick 

East, LLC

Hanson- Stanton Stanton KY -83.860259 37.873968 0.2 1 27.00

Acme Brick 

Company

Acme- Eureka Plant 

(EBP)

Clarksville AR -93.421959 35.461203 0.2 0 0.00

Sioux City Brick 

and Tile Co

Sioux City- Sergeant 

Bluff Plant

Sergeant Bluff IA -96.357977 42.405745 0.2 1 7.01

Hebron Brick 

Company

Hebron Brick Plant Hebron ND -102.036793 46.903373 0.2 1 26.24

Marion Ceramics, 

Inc

Marion Ceramics Pee Dee SC -79.518105 34.221868 0.2 0 0.00

Lee Brick and 

Tile Co

Lee Brick Sanford 

Facility

Sanford NC -79.186502 35.545301 0.2 2 27.52

General Shale 

Brick, Inc

General ShaleMoncure FacilityMoncure NC -79.036752 35.573676 0.2 1 23.77

Kansas Brick and 

Tile Co

Kansas Brick and Tile Hoisington KS -98.777521 38.472249 0.2 1 12.96

Hanson Brick 

East, LLC

Hanson- Athens Athens TX -95.822064 32.203737 0.2 1 30.33

Continental Brick 

Co

Continental BrickMartinsburgMartinsburg WV -77.957957 39.432350 0.2 1 38.56

Acme Brick 

Company

Acme- Ochs Brick 

Plant (AOP)

Springfield MN -94.962473 44.243872 0.1 2 4.80
4

Company Name Facility Name City State Longitude Latitude

Hazard

Index

Count of 

Nearby 

Facilities4

Sum of HClEquivalent

Emissions

(TPY)

Boral Bricks Inc. Boral- Gleason Plant Gleason TN -88.632110 36.232108 0.1 0 0.00

Hanson Brick 

East, LLC

Hanson- Roseboro Roseboro NC -78.560135 34.972007 0.1 1 14.81

Boral Bricks Inc. Boral- Augusta Plant 6 Augusta GA -81.988079 33.433535 0.1 0 0.00

Hanson Brick 

East, LLC

Hanson- Ninety Six Ninety-Six SC -81.954022 34.158916 0.1 1 19.67

Endicott Clay 

Products Co

Endicott Clay 

Products

Fairbury NE -97.123924 40.071393 0.1 1 29.21

Acme Brick 

Company

Acme- Texas Clay 

Plant (TCP)

Malakoff TX -96.019510 32.166984 0.1 1 35.19

Belden Brick 

Company

Belden- Plant #9 

Sugarcreek

Sugarcreek OH -81.637848 40.501833 0.1 0 0.00

Pine Hall Brick 

Co, Inc

Pine Hall- Madison 

Plant

Madison NC -79.995027 36.376695 0.1 1 78.82

Mutual Materials 

Co

Mutual MaterialsNewcastleRenton WA -122.159843 47.543276 0.1 1 0.00

Pacific Clay 

Products

Pacific Clay ProductsLake ElsinoreLake Elsinore CA -117.401486 33.727750 0.1 0 0.00

Acme Brick 

Company

Jenkins- Coosaada 

Plant

Coosaada AL -86.329507 32.492509 0.1 1 0.00

Sioux City Brick 

and Tile Co

Sioux City- Adel Plant Adel IA -94.035257 41.616311 0.1 1 13.02

General Shale 

Brick, Inc

General Shale BrickPlant 40Coosa GA -85.302237 34.257759 0.1 1 2.57

Acme Brick 

Company

Acme- Holly Springs 

Plant (HSP)

Holly Springs MS -89.452842 34.786168 0.1 0 0.00

Henry Brick 

Company, Inc

Henry Brick Selma AL -86.993790 32.413208 0.1 0 0.00

Boral Bricks Inc. Boral- Bessemer Plant 

#6

Bessemer AL -86.962615 33.349139 0.1 1 111.66

Hanson Brick 

East, LLC

Hanson- Mineral Wells 

East

Mineral Wells TX -98.051561 32.808191 0.1 1 26.50

Hanson Brick 

East, LLC

Hanson- Columbia -

Plant 2

Columbia SC -81.065819 34.056188 0.1 1 17.45

Glen Gery Glen-Gery 

Corporation-Caledonia

Caledonia OH -82.976649 40.636169 0.1 1 19.69

Glen Gery Glen-Gery 

Corporation-Marseilles

Marseilles IL -88.684365 41.321324 0.1 2 4.43

Boral Bricks Inc. Boral- Bessemer Plant 

#5

Bessemer AL -86.969374 33.342288 0.1 1 111.66
5

Company Name Facility Name City State Longitude Latitude

Hazard

Index

Count of 

Nearby 

Facilities4

Sum of HClEquivalent

Emissions

(TPY)

Boral Bricks Inc. Boral- Phenix CityPlant 4Phenix City AL -85.001549 32.407131 0.1 1 34.29

Boral Bricks Inc. Boral- Atlanta Plant Smyrna GA -84.501697 33.821591 0.09 2 7.14

General Shale 

Brick, Inc

General Shale BrickPlants 35 & 36Blue Ridge 

(Roanoke)

VA -79.825215 37.353348 0.09 1 42.22

Mutual Materials 

Co

Mutual Materials-Mica Mica WA -117.211260 47.558662 0.09 1 16.82

Yankee Hill Brick 

and Tile

Yankee Hill Brick and 

Tile

Lincoln NE -96.751376 40.776460 0.09 0 0.00

Hanson Brick 

East, LLC

Hanson - Monroe Monroe NC -80.620611 35.043209 0.08 1 4.50

Acme Brick 

Company

Acme- Elgin Plant 

(ELP/ENP)

Elgin TX -97.293837 30.324734 0.07 1 57.62

Belden Brick 

Company

Belden- Plant #3 

Sugarcreek

Sugarcreek OH -81.629787 40.506333 0.07 0 0.00

Boral Bricks Inc. Boral- Terre Haute 

Plant

Terre Haute IN -87.329253 39.318189 0.07 2 0.92

Cherokee Brick & 

Tile Co

Cherokee Brick & Tile Macon GA -83.634934 32.805151 0.07 1 23.53

Triangle Brick Triangle Brick- Merry 

Oaks Plant

Moncure NC -79.000847 35.643338 0.06 1 9.35

Triangle Brick Triangle BrickWadesboro PlantWadesboro NC -80.087350 35.019276 0.06 1 13.80

Belden Brick 

Company

Belden- Plant #2 

Sugarcreek

Sugarcreek OH -81.642332 40.514799 0.06 1 155.24

Boral Bricks Inc. Boral- Salisbury Plant Salisbury NC -80.441013 35.673330 0.05 1 1.19

Boral Bricks Inc. Boral- Muskogee 

Plant

Muskogee OK -95.407351 35.682202 0.05 1 32.92

Boral Bricks Inc. Boral- Henderson 

Facility

Henderson TX -94.805524 32.180565 0.05 3 21.18

Belden Brick 

Company

Belden- Plant #6 

Sugarcreek

Sugarcreek OH -81.631810 40.511390 0.05 1 155.24

General Finance, 

Inc

General FinanceCloud CeramicsConcordia KS -97.611633 39.550247 0.04 1 4.52

Mohawk 

Industries

Dal-Tile, Fayette, 

Alabama

Fayette AL -87.875012 33.697982 0.04 1 28.99

Belden Brick 

Company

Belden- Plant #8 

Sugarcreek

Sugarcreek OH -81.635015 40.514392 0.03 1 155.24
6

Company Name Facility Name City State Longitude Latitude

Hazard

Index

Count of 

Nearby 

Facilities4

Sum of HClEquivalent

Emissions

(TPY)

General Shale 

Brick, Inc

General Shale 

Robinson Brick Co.-

Plant 2

Denver CO -104.866894 39.372120 0.03 13 12.01

Ironrock Capital 

(formerly 

Metropolitan 

Ceramics, Inc.)

Ironrock Capital 

(formerly Metropolitan 

Ceramics, Inc.)

Canton OH -81.366668 40.774269 0.03 2 14.18

4

 The count includes the BSCP facilities if those facilities are in the 2011 NEI. Some BSCP facilities have a count of zero because the facility is 

either not in the 2011 NEI, or the NEI includes a single location for a facility that has multiple plants in the source category dataset. In the latter 

case, the single NEI location may not be within one kilometer of a facility location in the source category dataset.
7

Clay Ceramics Manufacturing Source Category

Of the eight facilities in the source category, no facility is within one kilometer of 

another. The closest facilities are approximately 200 kilometers from each other. There are also 

no facilities outside the source category that emit acid gases within one kilometer of a clay 

ceramics facility. Based on the 2011 NEI, there are several facilities that emit other HAPs within 

one kilometer of a clay ceramics facility, and these are given in Table 4.

Table 4. HAP Emissions from Facilities in the 2011 NEI Within 1 Kilometer of a Clay 

Ceramics Facility.

Facility ID Facility Name Longitude Latitude

Hazard 

Index

Count of 

Nearby 

Facilities

Sum of 

HClEquivalent 

Emissions 

(TPY)

48113NEI12943 CERAMIC TILE 

GLAZED MFG

-96.566003 32.768019 1 1 174.84

45083NEI41474 KOHLER 

CO:VITREOUS 

PLANT

-81.851884 34.923012 0.7 4 35.49

55117NEIWI1179993 KOHLER COMETALS 

PROCESSING 

COMPLEX

-87.776856 43.740329 0.6 1 119.36

01077NEI8517 Monarch 

Ceramic Tile

-87.668354 34.827443 0.5 1 111.72

48049NEI13131 BROWNWOOD 

FACILITY

-98.997222 31.663889 0.5 2 100.18

40101NEIOK1015305 MUSKOGEE 

PORCELAIN 

FLOOR TILE 

PLT

-95.386918 35.706363 0.4 1 60.26

47125NEITNRCC123 FLORIM USA 

INC.

-87.260961 36.600472 0.3 2 3.28

48141NEI41683 CERAMIC TILE 

MFG EL PASO

-106.3549 31.955729 0.1 1 255.56

The count of nearby facilities includes the clay ceramics if those facilities are in the 2011 NEI, so 

a count of one indicates the clay ceramics facility itself. There are three clay ceramics facilities 

with nearby facilities outside the source category. Because the HBEL level of 600 tons per year 

of HCl-equivalent emissions reflects a hazard index of one at the worst case facility, each 60 ton 

per year increment in emissions would reflect a contribution no more than 0.1 to the hazard 

index for any facility. Based on the HCl-equivalent emissions in Table 3, no BSCP facility 

would exceed a hazard index of one due to the emissions of nearby facilities.

In conclusion, EPA concludes that health thresholds would not be exceeded due to combined 

emissions of sources in the BSCP Manufacturing and Clay Ceramics Manufacturing source 

categories and other emissions sources that are near them. Because concentrations decrease 

significantly with distance from the facility, multiple facilities typically do not share the same 

location of maximum impact, and the impact of facilities more than one kilometer away are not 

significant compared to the impacts from the facilities in the source categories emitting at the 

HBEL. Only about 20 percent of the BSCP facilities have other facilities within one kilometer 

of them, and three of the eight clay ceramics facilities have other facilities within one kilometer

of them. In the cases where there are nearby facilities, even if the emissions from those facilities 
8

were assumed to be emitted from the facility in the source category, the health thresholds would 

not be exceeded. Although nonpoint sources are not considered in this assessment, such sources 

would also have to be nearby and have significant emissions to contribute significantly at the 

receptor locations where concentrations are driven mostly by the emissions from sources in the 

source categories emitting at their respective HBEL levels.