## January 7, 2011

Mr. Jeffrey Telander 

# ACME

# I BRICK' r7:ot'IJ /J'.9/



## Submitted viaemail to: telander.jeff@epa.gov

U. S. Environmental Protection Agency Office ofAir Quality Planning and Standards Research Triangle Park, NC 27711 Certified Mail No.: 7009 1680 0000 9316 6222 Re: Response to requirement to provide information according to Title 42 ofthe United States Code, Chapter 85, Subchapter I, PartA, section 7414 (42 U.S.C 7414) DearMr. Telander: In

## your letter datedNovember 17,2010, you requested information on startup and shutdown events, as described in your attachment labeled Enclosure 1. Inaddition, emissions data ofhydrogen fluoride, hydrochloric acid, chlorine, metals, and particulate matter from tunnel kilns, as listed in your attachment labeled Enclosure 2, was requested. Acme proposes modifications to the schedule and testing plan as outlined in Attachment 1. Acme is eager to work withthe EPAto ensure the development ofan achievable BrickMACT. As you are well aware, the brick industry has suffered greatly as a result ofthe recession. Many facilities have been idled and may never recover. Overly aggressive regulations may very well result inthe permanent closure ofmany brick compauies and the loss ofthousands of jobs. Acme hopes that you accept this alternative test schedule and looks forward to yourresponse. If you have any questions, please call me at 817-870-8348. Sincerely,

# o~JZ

# ..**~. fas~n**  Pence EHS Manager Acme Brick Company

cc: SusanMiller- Brick Industry Association

ACME BRICK COMPANY P.O. Box425- Fort Worth, Texas 76101- TEL: 817/332-4101

## ATTACHMENT 1

Facility Location 

### Comments Facility 

### is currently idle and is not scheduled 

### to operate in 2011. Acme BennettTunnelPlant (BTP) Millsap, TX requests that this facility be removed from the list of "TunnelKilns ToBe Tested." Historical startup/shutdown records will be submitted by the requested duedate ofFebruary28,2011. Oneofthe three tunnel kilns is not operating and likely won't operateuntil late 2011. Acmerequests 

### to test onetunnel kiln (Kiln A) for the requested pollutants since 

### it is identical in capacity, products manufactured, and the DentonTunnel Plant(DTP} Denton, TX control devices areidentical to the other kiln on-site. Acme requests to have the test data submission deadline extended to March 31, 2011. Thehistorical startup/shutdown records will be submitted 

### by the requested due date of February 28, 2011. Facility is currently operating at a greatly reduced capacity. Acmebelieves thathistorical stacktest data (previously submitted to EPA) sufficiently DenverTunnel Plant (DVP) Castle Rock, CO represents emissions from this facility. Acme requests that this facility be removed from the list of "TunnelKilns To Be Tested." Historical startup/shutdown records will be submitted by the requested due date of February 28, 2011. Facility is currentlyoperating at a greatly reduced capacity. Acmerequests to have the testdata submission deadline extended to July31, 2011. An increase Elgin New Plant (ENP) Elgin, 1X in production rate is planned in April and the time extension should allow for the scheduling, testing, and data input requiredin the ICR. Historical startup/shutdown records will be submitted by the requested due date of February 28, 2011.
Acmebelieves that historical stack test data (previously submitted to EPA) Ouachita Tunnel Plant (OEP) Malvem,AR sufficiently represents emissions from this facility. Acme requests that this facility beremoved from the list of "Tunnel Kilns To Be Tested." Historical startup/shutdown records will be submitted by the requested due date of February28, 2011. 

### In addition to the startup and shutdown event data requested, Acme will submitmaintenance and malfunction event data for each facility. Acmebelieves this information is critcal in the development ofthe BrickMACT to ensure proper operation ofthe control devices and account for unexpected bypass conditions.



## ACME BRICK COMPANY P.O. Box425- Fort Worth, Texas 76101- TEL: 817/332-4101