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 TelanderSector 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 s ource 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 27709From: "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 Gl eason 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 great ly, 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 stackWe 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