Mr. Warren Paschal 

Manager of Environmental Compliance 

General Shale Brick 

1600 Colon Road 

Sanford, North Carolina 27330 

Dear Mr. Paschal: 

 Thank you for your efforts in coordinating the July 29, 2008, site visit by U.S. 

Environmental Protection Agency (EPA) and RTI personnel to the General Shale Brick (General 

Shale) facility in Moncure, North Carolina. We appreciate the time that you and other 

representatives at General Shale set aside for discussing and showing your manufacturing 

process. 

 Enclosed is a draft of the trip report (Enclosure 1) that has been prepared based on the 

information obtained during our site visit. We would appreciate your reviewing the report for 

any errors or omissions. You may return the enclosed copy of the report with your written 

comments. Since this report will eventually become a part of the public record, we want to 

portray your operations as accurately as possible. A copy of the final version of the report 

incorporating your comments will be sent to you for your records. 

 The custody receipt for the trip report is also enclosed (Enclosure 2). Please sign and date 

the form to acknowledge receipt of the report and return a copy of the form to: 

Mr. Roberto Morales; U.S. Environmental Protection Agency; Office of Air Quality Planning 

and Standards; IO/PRRMS (MD-C404-02); 109 T.W. Alexander Drive; Research Triangle Park, 

North Carolina 27711. 

 If you believe that disclosure of any specific information contained in the trip report 

would reveal trade secrets or other confidential information, you should clearly identify the 

specific information. Please do not label the entire report as “confidential” if only certain 

portions consist of trade secret information. If the EPA determines that there is a need to disclose 

such information, we will need, at that time, the following to support your claim: 

 1. Measures taken by General Shale to guard against undesired disclosure of the specific 

information to others; 
 2. The extent to which the specific information has been disclosed to others and the 

precautions taken in connection therewith; 

 3. Pertinent confidentiality determinations, if any, by other Federal agencies (furnish a 

copy of any such determination, or reference to it, if available); and 

 4. Whether General Shale asserts that disclosure of the specific information would be 

likely to result in substantial harmful effects on General Shale’s competitive position, and, if so, 

what those harmful effects would be, why they should be viewed as substantial, and an 

explanation of the causal relationship between disclosure and such harmful effects. 

 Any specific information subsequently determined to constitute a trade secret will be 

protected under 18 U.S.C. 1905. If no claim of confidentiality accompanies the information 

when it is received by EPA, it may be made available to the public by EPA without further 

notice (40 CFR Part 2.203, September 1, 1976). Any specific information subsequently 

determined to constitute a trade secret will be protected under 18 U.S.C. 1905. However, all 

emissions data will be available to the public. A clarification of the information EPA considers to 

be emissions data is contained in Enclosure 3. 

 We respectfully request that you submit your review comments on the trip report by 

October 15, 2008. If you concur with the information contained in the report, we would 

appreciate a letter to that effect. In addition, please indicate in your letter the specific parts of the 

report, if any, that General Shale considers to be confidential. If we do not receive a response by 

October 15, 2008, the report will be considered nonconfidential and accurate. 

 Thank you for your cooperation. The information supplied by General Shale will be most 

helpful in our study. If you have any questions, please call Mr. Jeff Telander of my staff at (919) 

541-5427 or Mr. Rick Marinshaw of RTI at (919) 317-3735. 

Sincerely, 

Steve Fruh 

Group Leader 

Metals and Minerals Group 

Office of Air Quality Planning and Standards 

3 Enclosures 
Enclosure 3