From: Terry Schimmel (Bricks - Phenix City) 

Sent: 05/21/2010 07:22 AM 

To: Jeff Telander 

Cc: "Susan Miller" 

Subject: FW: Additional test locations 

JeffWe were finally able to identify another DIFF that is operating. Hanson's plant in ElginTexasis 

currently operating. We should point out that the control device is now operating as a DIFF and not 

a DLS. We must point out that we are very concerned that this test may not be representative of 

what the control would do at full operation since the kiln is currently operating at only 45% of full 

operation. While we understand that the limits are based on a "lb/ton" value, the control device in 

this case would be over-designed for the load that it will be bearing during the test. This facility is 

not able (due to permit restrictions remaining from the now-vacated MACT) to reduce their reagent 

flow proportional to their load. 

To clarify- here is our new list of sources that we believe would be able to respond to a request to 

test under Section 114 of the CAA: 

To test for HF, HCl, PM, metals, AND dioxin/furans from uncontrolled and controlled kiln exhaust 

 Boral Bessemer (DIFF)- will also test one "associated dryer” for dioxin/furan. 

 Hanson- Elgin(DIFF) 

 Belden- Plant 2 (DIFF). Please note that this DIFF is controlled by a CEM. [The Spray 

dryer/ESP at this site is not an option for testing at this time since the control is not being 

utilized as designed due to low throughput] 

[NOTE: Acme and Belden are unable to test at dryer stacks due to technical reasons.] 

To test for HF, HCl, PM, and metals from uncontrolled and controlled kiln exhaust 

 Acme Elgin(DIFF) 

 General Shale Blue Ridge/Roanoke(DLA) 

We believe that the above tests of FIVE kilns will provide EPA (and industry) with sufficient 

information to determine what tests would be required in a "Phase II" of testing, while minimizing 

unnecessary costs to industry. 

Thank you. 
-----Original Message----- 

From: Telander.Jeff@epamail.epa.gov 

Sent: Tuesday, May 18, 2010 4:04 PM 

To: Terry.Schimmel@boral.com; Susan Miller 

Subject: Fw: Additional test locations 

Susan and Terry, 

FYI, 

I've received no response to the attached email. 

Jeff Telander 

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

(D243-02) 

RTP, NC 27711 

919 - 541-5427 

919 - 541-5450 (FAX) 

Overnight mail address: 

US EPA 

Mail Code D243-02 

109 TW Alexander Drive 

RTP, NC 27709 

----- Forwarded by Jeff Telander/RTP/USEPA/US on 05/18/2010 04:02 PM ----- 

From: Jeff Telander/RTP/USEPA/US 

Sent: 05/10/2010 01:29 PM 

To: "Terry Schimmel (Bricks - Phenix City)" 

Cc: SMiller@bia.org, Scott Jordan/DC/USEPA/US@EPA 

Subject: Re: Fw: Additional test locations 

Terry, 

We have sufficient DLA data, therefore inclusion of Acme Malakoff rather than another kiln with a 

DIFF does not appear justified. It would be helpful to see a list of the candidates you've considered 

and the factors that led you to conclude that these two were the best. 

Also, are you suggesting a total of 5 facilities at this point? 

Jeff Telander 
Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

(D243-02) 

RTP, NC 27711 

919 - 541-5427 

919 - 541-5450 (FAX) 

Overnight mail address: 

US EPA 

Mail Code D243-02 

109 TW Alexander Drive 

RTP, NC 27709 

From: "Terry Schimmel (Bricks - Phenix City)" 

Sent: 05/07/2010 09:30 PM 

To: Jeff Telander/RTP/USEPA/US@EPA 

Subject: Fw: Additional test locations 

----- Original Message ----- 

From: Susan Miller 

Sent: Fri May 07 15:07:53 2010 

To: Terry Schimmel (Bricks - Phenix City) 

Subject: Additional test locations 

We have identified two additional locations that can conduct stack tests of their kilns (inlet and 

outlet)- and come closest to meeting all of the criteria listed below . We remain concerned that, 

even though emission rates are evaluated on a lb/ton basis, testing as near to capacity as possible 

is necessary to ensure that the tests are representative. While both of these sources will test for 

dioxin, neither is technically capable of testing their dryer stacks. We are hopeful that the one dryer 

test for dioxin will suffice for Phase I. 

The two additional sites: 

Acme- Malakoff (DLA, but chosen because it offers the ability to test a clay) 

Belden- Plant 2 (DIFF). Please note that this DIFF is controlled by a CEM. [The Spray dryer/ESP at 

this site is not an option for testing at this time since the control is not being utilized as designed 

due to low throughput] 
As before, we would still need for the test requests to come under Section 114 authority. 

-----Original Message----- 

From: Telander.Jeff@epamail.epa.gov 

Sent: Tuesday, April 27, 2010 1:03 PM 

To: Terry.Schimmel@boral.com; Susan Miller 

Subject: Re: Test locations 

Susan and Terry, 

Regarding selection criteria of Phase 1 testing facilities: 

While we do not object to inlet/outlet testing, we do not agree that it is a primary consideration, or 

that control efficiency is a valid indicator of source performance from an emissions perspective. We 

agree that it is desirable that tested units be operating near capacity if possible. When we spoke 

last week, you indicated that BIA could probably obtain and provide info regarding the production 

status of all of the well controlled kilns. Is that correct? If so, when do you expect to be able to 

provide that information? 

We have sufficient data from DLA-controlled kilns and do not agree with inclusion of DLA in the 

Phase 1 testing. 

Dioxin testing is needed at several facilities and it is preferred that the kilns tested differ from each 

other in the raw materials used and should use both clay and shale. 

Jeff Telander 

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

(D243-02) 

RTP, NC 27711 

919 - 541-5427 

919 - 541-5450 (FAX) 

Overnight mail address: 

US EPA 

Mail Code D243-02 

109 TW Alexander Drive 

RTP, NC 27709 
From: "Terry Schimmel (Bricks - Phenix City)" 

Sent: 04/16/2010 04:03 PM 

To: Jeff Telander/RTP/USEPA/US@EPA 

Cc: Person 

Subject: Fw: Test locations 

JeffThe following is our list of recommended sources for Phase I of testing. 

Some notes: 

 As you can see from our list, we do not have Gleason on our list. This is largely due to the fact 

that Gleason will be down for at least the next eight months. We believe that any tests 

conducted on ball clay at similar facilities (e.g., tile kilns if there are no other potential dioxin 

sources) would likely provide the answer on potential dioxin emissions from ball clay-based 

controls. Please bear in mind that the brick body used at Gleason is only approximately 35 

percent ball clay and any results derived from other source testing should be scaled 

accordingly. [Please note that nothing in this comment should be construed to say that we have 

changed our position, in the slightest, that raw material that is also mined material has no role 

in MACT development.] 

 We have spoken with members and attempted to provide a Phase I that accomplishes the 

following: 

o Tests at kilns that are as close to full capacity as available during this extremely low 

production time period (this narrowed the pool greatly, but we feel strongly that this is 

critical to representative testing). 

o Allow for testing of both inlet and outlet to the control. As we have repeatedly stated, we 

believe that a percent reduction standard is the only primary standard that makes sense 

for this specific industry. We believe that any emission limit (i.e., lb/ton) standard should 

flow from the percent reduction standard, as EPA did (and no one questioned) in the nowvacated MACT. 

o For the dioxin test, a site where we believe dryer testing is likely to be feasible. We will 

test for the presence of dioxin in the dryer exhaust air stream; however, at this time and 

until the testing is actually done, we are not sure how accurate the airflow numbers may 

be in that this stack, as well as all other dryer stacks that we have researched in the 

industry, may not have the upstream and downstream diameter to length ratios 

prescribed for ideal and accurate airflow measurements. 

o No more than one test per company during Phase I to keep costs as low as possible per 

company. 

Here is what our MACT TF recommends: 

 Boral Bessemer (DIFF, NG)- HF, HCl, PM, metals, dioxin/furans from uncontrolled kiln and 

control device stack; dioxin/furans from one “associated dryer” 

 Acme Elgin(DIFF, NG)- HF, HCl, PM, metals from uncontrolled kiln and control device stack 

 General Shale Blue Ridge/Roanoke(DLA, coal)- HF, HCl, PM, metals from uncontrolled kiln 

and control device stack 
We would still need these letters to come under 114 authority in order to justify the expenditures to 

the respective companies. We believe that these tests could be completed by the end of 

September, at which time we could regroup and evaluate the need for Phase 2 testing. 

Terry Schimmel 

BIA MACT TF Lead