January 7, 2011 

Mr. Jeffrey Telander 

ACME I 

BRICK' 

r7:ot'IJ /J'.9/ 

Submitted via email to: telander.jeff@epa.gov 

U. S. Environmental Protection Agency 

Office of Air 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 of the United States 

Code, Chapter 85, Subchapter I, Part A, section 7414 (42 U.S.C 7414) 

Dear Mr. Telander: 

In your letter dated November 17,2010, you requested information on startup and shutdown events, 

as described in your attachment labeled Enclosure 1. In addition, emissions data of hydrogen 

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 with the EPA to ensure the development of an achievable Brick MACT. As 

you are well aware, the brick industry has suffered greatly as a result of the recession. Many 

facilities have been idled and may never recover. Overly aggressive regulations may very well 

result in the permanent closure of many brick compauies and the loss ofthousands of jobs. 

Acme hopes that you accept this alternative test schedule and looks forward to your response. If 

you have any questions, please call me at 817-870-8348. 

Sincerely, 

fas~n 

o~JZ Pence .. ~. 

EHS Manager 

Acme Brick Company 

cc: Susan Miller- Brick Industry Association 

ACME BRICK COMPANY 

P.O. Box 425- 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 

Bennett Tunnel Plant (BTP) Millsap, TX requests that this facility be removed from the list of "Tunnel Kilns To Be 

Tested." Historical startup/shutdown records will be submitted by the 

requested due date of February 28,2011. 

One of the three tunnel kilns is not operating and likely won't operate until 

late 2011. Acme requests to test one tunnel kiln (Kiln A) for the requested 

pollutants since it is identical in capacity, products manufactured, and the 

Denton Tunnel Plant (DTP} Denton, TX control devices are identical to the other kiln on-site. Acme requests to have 

the test data submission deadline extended to March 31, 2011. The historical 

startup/shutdown records will be submitted by the requested due date of 

February 28, 2011. 

Facility is currently operating at a greatly reduced capacity. Acme believes 

that historical stack test data (previously submitted to EPA) sufficiently 

Denver Tunnel Plant (DVP) Castle Rock, CO represents emissions from this facility. Acme requests that this facility be 

removed from the list of "Tunnel Kilns To Be Tested." Historical 

startup/shutdown records will be submitted by the requested due date of 

February 28, 2011. 

Facility is currently operating at a greatly reduced capacity. Acme requests to 

have the test data 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 required in the ICR. Historical 

startup/shutdown records will be submitted by the requested due date of 

February 28, 2011. 

Acme believes 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 be removed from the list of "Tunnel Kilns To Be Tested." Historical 

startup/shutdown records will be submitted by the requested due date of 

February 28, 2011. 

In addition to the startup and shutdown event data requested, Acme will submit maintenance and malfunction event data for each 

facility. Acme believes this information is critcal in the development ofthe Brick MACT to ensure proper operation of the control 

devices and account for unexpected bypass conditions. 

ACME BRICK COMPANY 

P.O. Box 425- Fort Worth, Texas 76101- TEL: 817/332-4101