## MEMORANDUM

DATE : September 17 , 201 5

SUBJECT: Pote n tial for Cumulative Effects from Emissions Sources Near Facilities in the

Brick and Structural Clay Products Manufacturing and the Clay Ceramics Manufacturing Source Categor ies

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 Manufac turing 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 h ydrochloric acid (HCl)

- equivalent emissions,

and the proposed HBEL for the Clay Ceramics source category is 600 tons per year of HCl

equivalent emissions

. To determine the HBEL for each source category, the EPA performed risk

assessments to determine the l evel 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

f rom 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 “Ris k 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, the se assessments did not model other facilities near those in the source categor ies

.

Several comments were received on the p roposed 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 thos e in the source categories, and why the EPA concludes from this analysis that

the h ealth 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 9 0

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

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

7 5 percent on average at a location approximately one kilomete r 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 d escribed in this memorandum focuse s on cases where facilities are within one

kilometer of the facili ties in the source categories. The risk assessment performed to establis h the

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

, but this current analysis examines the extent to which facilities in each source category are within one kilometer of each other. For faciliti es outside the source categories, the

current a nalysis determines the amount of HCl

- equivalent emissions from such sources that are

within one kilomete r of sources in the categories. This a nalysis 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 S ource C a tegory 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

- Kil ometer Facility Clusters

Facility ID Hazard

Index C ompany Name F acility Name C ity S tate

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 sa me 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

.

Fac ility 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 kilo meter 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 pe r 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 20 11 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

locati ons 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 ha zard 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 pollut ant 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 C ompany

Name Facility

Name C ity S tate Hazard

index NEI

F acility

ID Nearby

F acility

Name Longitud e Latitude Sum of

HCl

Equivalent

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

Virginia

Salem 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. Boral

Terre

Haute

Plant Terre

Haute IN 0.0 7 4147911 SYCAMORE

RIDGE

LANDFILL - 87.3316 39.31003 0.91



## Table 3

. HAP Emissions from F acilities in the 2011 NEI Within 1 Kilometer of a BSCP Facility.

Company Name Facility Name City State Longitude Latitude Hazard

Index Count of

Nearby

Facilities 4 Sum of HCl

Equivalent

Emissions (TPY)

International Chimney Corp Continental Clay

Kittanning Kittanning 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 Brick

Plants 6 & 28 Atkins (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

Facilities 4 Sum of HCl

Equivalent

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 Cunningham

Cleveland Co Grover 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 Cunningham

Thomasville Thomasville 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 City

Plant 3 Phenix 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

Facilities 4 Sum of HCl

Equivalent

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 Shale

Corbin

- Plant 33 Woodbine 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 Shale

Moncure Facility Moncure 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 Brick

Martinsburg Martinsburg 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

Facilities 4 Sum of HCl

Equivalent

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 Materials

Newcastle Renton WA

- 122.159843 47.543276 0.1 1 0.00

Pacific Clay

Products Pacific Clay Products

Lake Elsinore Lake 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 Brick

Plant 40 Coosa 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

Facilities 4 Sum of HCl

Equivalent

Emissions (TPY)

Boral Bricks Inc. Boral

- Phenix City

Plant 4 Phenix 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 Brick

Plants 35 & 36 Blue 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 Brick

Wadesboro Plant Wadesboro 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 Finance

Cloud Ceramics Concordia 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

Facilities 4 Sum of HCl

Equivalent

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 kilome ter of a facility location in the source category dataset.

## 7

Clay Ceramics Manufacturing S ource C ategory

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

. Base d on the 2011 NEI, there are s everal 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 C lay Ceramics Facility.

Facility ID Facility Name Longitude Latitude Hazard

Index Count of

Nearby

Facilities Sum of

HCl

Equivalent

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 CO

METALS

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



## Th e 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 c ategory. 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 f acilities.

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

emissions of sources in the BSCP Manufacturing and C lay Ceramics Manufacturing source

categor ies 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 fr om 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

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

not be exceeded

. Although nonpoint sources are not conside red 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.