Date: February 15, 2013
Subject: Minutes of the January 28, 2013 Mee ting with Representatives of the Brick Manufacturing Industry NESHAP for Brick and Stru ctural Clay Products Manuf acturing and NESHAP for Clay Ceramics Manufacturing EPA Contract No. EP-D-11-084; EPA Work Assignment No. 1-04 RTI Project No. 0213199.001.004
From: Kristin Sroka, Thomas Holloway, Gabrielle Raymond
To: Jeffrey Telander OAQPS/SPPD/MMG (D243-02) U.S. Environmental Protection Agency Research Triangle Park, NC 27711

I. Introduction

A meeting with representatives of the brick manufacturing industry wa s held at the U.S. Environmental Protection Agency (EPA) on Janua ry 28, 2013. The purpose of the meeting was to discuss steps for redeveloping national emission standards for hazardous air pollutants (NESHAP) for the brick and structural clay prod ucts (BSCP) manufacturi ng industry in light of the vacatur of the original NE SHAP. This memorandum summarizes the major topics discussed during the meeting.

II. Attendees and Affiliations

Susan Miller, The Brick I ndustry Association (BIA) Irene Kuo, BIA Paul Regina, BIA Terry Schimmel, Boral Bricks Inc./BIA John E. Miller, Whitacre Greer Co. Garth Tayler, Acme Brick Company

Jeffrey Telander, U.S. EPA, Office of Ai r Quality Planning and Standards (OAQPS) Keith Barnett, U.S. EPA, OAQPS Ted Palma, U.S. EPA, OAQPS Steve Fruh, U.S. EPA, OAQPS Marguerite McLamb, U.S. EPA, OAQPS

Kristin Sroka, RTI International Thomas Holloway, RTI International Gabrielle Raymond, RTI International2 III. Discussion

Prior to the meeting, industry re presentatives provided the EPA w ith a list of topics they wanted to discuss during the meeting (see Attachme nt 1). At the start of the meeting, the EPA representatives noted that the draft schedule fo r redevelopment of the BSCP NESHAP had been set by a proposed settlement agreement, with a draft proposal date of August 30. Industry representatives indicated that they had submitted comments on the proposed agreement recommending that the schedule be extended to include more time to ensure that the rule is wellwritten and as flexible as possible, and that full consideration can be given to small business concerns. The EPA representatives stated that they hoped to schedule a meeting with potential small entity representatives (SERs) in February. Industry representatives noted that they had conducted a case study to determine the potential imp acts of a rule consisting solely of maximum achievable control technology (MACT) limits on a small business model facility, and they provided a handout showing the results of that study (see Attachment 2).

In addition to a compliance option based so lely on MACT limits, another option under consideration is a he alth-based compliance option for the acid gases hydrogen fluoride (HF), hydrogen chloride (HCl), and chlorine (Cl 2 ) that would be supported by the results of risk modeling of those pollutants. The EPA represen tatives explained how the normalized inputs for the modeling were developed (including incorpor ating data previously provided by industry representatives) and how the models were run to obtain chronic and acute ri sk results. For acute risk, the biggest source of uncertain ty is the distance from the stack to the facility fenceline. Although satellite and aerial images can be used to assign and confirm the coordinates of stacks, those images do not definitively show the property boundary, so the EPA used assumed distances in many cases. Industry representatives stated they w ould look into providing actual distances to the fenceline. The EPA representati ves also stated that, based on the information in hand about kiln operations (e.g., continuous operation) , a variability factor of 2 was used in the analysis. (In many industries, the default factor is 10, partially to account for non-continuous operation.) The EPA representative s agreed to provide a descripti on of the considerations used when selecting variability factor s so that industry c ould provide any additional information that might support a different factor.

Prior to the meeting, the EPA provided industry representatives with a description of the methodology used to calculate MACT floors and a c opy of the BSCP tunnel kiln test data set (see Attachments 3 and 4, respectivel y). Industry representatives no ted that they are working to collect more data on mercury emissions from BS CP kilns, including the source of the mercury, control options, and ideas for alternative methods of compliance. Industry representatives also noted that the EPA’s methodology indicates that th e MACT floor is based on the average of the top 12 percent of the available data, and they as ked the EPA to consider basing the MACT floor on the average of the top 12 percent of all the ki lns in the category, based on the contention that the EPA had already obtained data fo r the top 12 percent of kilns. As part of this analysis, they also asked the EPA to consider assigning test data for one kiln to a similar kiln at the same facility which would increase the number of kilns with data. Th e EPA representatives indicated that they are considering work practice standard s for periodic kilns and dryers as well as for dioxin/furan emissions from tunnel kilns.3 Industry representatives stated they have c onsidered pursuing the process of getting the source category delisted. They indicated that they don’t have enough information to make a decision yet and asked the EPA for general inform ation on the process. The EPA representatives stated that the industry would have to petition to have the source category delisted in accordance with section 112(c)(9) of the Clean Air Act, and the petition would need to include sufficient information to show that all of the facilities in the category are below the applicable thresholds for cancer and non-cancer risk.

The EPA representatives noted that it would be helpful for industry to provide data to support the answers to tec hnical questions that may arise going forward. Industry representatives also indicated that they plan to provide sugge stions for revisions to the BSCP NESHAP to improve the clarity and enforceability of provisi ons originally included in the vacated rule.Attachment 1

General Topics for Discussion Provided by Susan Miller, BIA, via Email on January 23, 2013

 Database/Data

 MACT Approach – Update and Questions

o MACT floor approach/“Traditional” approach

o Health-based alternative standard

o Delisting

 Small Business Panel meeting – schedule

 Schedule and timing for input on applicab ility/definition of category, monitoring, recordkeeping, and re porting requirementsAttachment 2

“Case Study – Why Health-Based Is So Critical” Handout Provided by BIA during January 28, 2013, MeetingCase Study- Why Health-8ased is so Critical

Facility: A 100- year old family owned brick manufacturing facility. The facility has been in
the same location for since the company opened. They currently have two natural gas-fired kilns firing pressed brick/pavers:

• 6.8 ton per hour (tph) kiln constructed in 1954, uncontrolled

• 11.9 tph kiln constructed in 1964, uncontrolled
Health-based compliance approach.

• Used site-specific stack parameters for both kilns; Stack test data from one kiln test applied to both

• used emissions model as directed by EPA, combined HQs for HF, HCI and CI2
in to a single HI.

• Total HI for plant: 0.059

"Traditional Approach." Assumptions:

Total capital investment: $ 4,600,000
Total annualized investment (A): $835,082

Total operating costs (B): $857,835

Total annualized costs (A + B): $1,692,917
Emissions and estimated reductions: 

## •

•

Results:



## •

•



## •

•



## • • Based on last discussions with EPA, we are assuming that both kilns would
be required to install a dry-injection/fabric filter (DIFF) system to control HF, HCI, CI2 and PM as a surrogate for metal HAPs Using EPA's cost algorithms provided in 2008 dollars for small and large
kilns. Assuming 99 percent reduction for conservative calculation of cost
effectiveness.

Pollutant Emission lib/ton) Percent Reduction Total emission reduction for 18.7 tph HF .13 99 10.7 HCI .0096 99 0.78 PM-HAP (1% of PM) CI2
TOTAL .0081 99 .66

0.03
12.17

• Annualized cost per ton of emission reduction: $139.100/ton

Costs not included: Any control requirements for mercury, dioxin, SSM requirements, etc

....Attachment 3

Procedure for Calculating MACT Floors Provided to BIA by Jeff Telander, EPA, via Email on January 22, 2013

When calculating MACT floors, here is a summary of the approach we follow:

 Step 1. Run by run stack test data from the BSCP data set were used to calculate an average emission factor (pound per ton brick [l b/ton]) for each tunnel kiln per pollutant.

 Step 2. Ranked all of the BSCP tunnel kilns by their average emission factor per pollutant (lowest to highest).

 Step 3. From this ranking, a MACT floor pool of sources was identified. For existingsource MACT floors took 12% of sources for which we had data ( ≥ 30 tunnel kilns nationwide) and rounded up to nearest whole num ber. For the new-source MACT floors, the best-controlled similar source was identi fied for which there were individual source test run data in the BSCP data set.

 Step 4. Each MACT floor pool data set (for each pollutant) was evaluated for Kurtosis and skewness to determine if the data set for the best performing source(s) was normally distributed. If these tests indica ted the data set was normally distributed, the data set was treated as normally distributed in subsequent upper predictive limit (UPL) calculations. If either of these tests indicated the data set was not normally distributed, the data set was log transformed, and the log transformed da ta set was evaluated for Kurtosis and skewness. If these tests indicat ed the data set was log-norma lly distributed, the data set was treated as log-normally di stributed in subsequent UPL cal culations. If either of these tests indicated the log transformed data set wa s not log-normally distributed, the data set was treated as non-normally/non-l ognormally distributed in subsequent UPL calculations. For data sets consisting of only three valu es (n=3), a subsequent UPL calculation was used for data sets with n=3.

 Step 5. After completing the determination of the type of data distribution for the best performing source’s data set, the data set was in put to the series of calculations necessary to calculate the UPL.

 Step 6a. For data sets that contained any da ta that were Below Detection Level (BDL) or Detection Level Limited (DLL), there was an additional step take n after the UPL was calculated. Individual BDL or DDL values were used as is within the data set. The UPL was calculated with the appropriate equation for the data distribution. Then, the results of the UPL calculation were compared to the emission limit value determined to be equivalent to 3 times the representative detection limit (3xRDL) of the relevant performance test method(s).The 3xRDL values given in guidance documen t were given in units of concentration (μg/dscm). The emission limits for this rule are in units of lb/ton of brick. In order to be able to compare the calculated UPL to 3xRDL , the 3xRDL value was converted to units of lb/ton using a ratio. The ratio was deve loped from the available concentration and lb/ton data for each dataset. Calculated the ratio of the emission factor to the concentration value for each run with both values by taking the lb/ton value and dividing it by the concentration value. Calculated the average of all the ratio values. Identified the typical sample size for the dataset. Id entified the appropriate 3xRDL concentration value to use from the guidance document according to pollutant and typical sample size. Multiplied the appropriate 3xRDL concentration value by the av erage ratio to convert the 3xRDL value into lb/ton units.

 Step 6b. Compare the 3xRDL value to the calculated UPL. If the calculated UPL value was less than the emission limit value determined to be equivalent to 3xRDL value, the 3xRDL value was used as the basis for the standard because the 3xRDL value provides the lowest emission rate that can be measured using the performance test method while maintaining a relative method precision on the order of 10 to 20 percent of the measured value. If the UPL value was equal to or gr eater than the 3xRDL value, then the UPL value was used as the basis for the standard.Attachment 4

BSCP Tunnel Kiln Test Data Set (Run-by-Run) Provided to BIA by Jeff Telander, EPA, via Email on January 22, 2013