JAN

042011 TUE 11:16 AM INTERSTATE BRICK FAX NO. 8012805221 P. 01/03 

()INTERSTATE® BRICK 

® 

9780 South 5200 West 

West Jordan, UT 84088-5625 

(801) 280-5200 

(800) 233-8654 

Fax (801) 280-5220 

January 4, 2011 

Mr. Jeff Telander 

United States Environmental Protection Agency 

Research Triangle Park, NC 27711 

Re: November 17, 2010 ICH Letter 

Dear Mr. Telander: 

Interstate Brick (ISB) is in receipt of the US Environmental Protection Agency (EPA) letter of November 

17, 2010 requesting certain information pursuant to Section 114 of the Clean Air Act. It is our 

understanding that this lette'r is an Information Collection Request (ICR) related to the "Brick MACT", 40 

CFR 63, Subparts A and J.JJJJ, (National Emission Standard for Hazardous Air Pollutants for Brick and 

Structural Clay Products M~mufacturing), which is being redeveloped after being vacated by the US Court 

of Appeals on March 13, 2007. 

The purpose of this letter is to inform you of how ISB proposes to provide most of the requested 

information, and to request your leniency and understanding with respect a portion of the ICR request. 

BACKGROUND 

Interstate Brick (ISB) is an "Area Source", i.e., minor facility with respect hazardous air pollutants (HAPs), 

because the potential to emit (PTE) emission rates for the facility are below the "HAP Major" thresholds of 

10 tons/year of a single HAP or 25 tons/year of aggregated (combined) HAP emissions. All emissions 

controls and permit limits that play a role in ISB being an area source are federally enforceable. There 

are no "synthetic" restrictions on production or process throughputs required in order for ISB to maintain 

its status as an Area Source. 

ISB has operated scrubbers on its kilns since 1962, well prior to the clean air act. The current emission 

control systems consist of the following equipment: 

• Kiln #3 Packed Tower Scrubber (EPA Control Stack ID SC-3) installed in 1995 

• Kiln #4 Bionomic HotoBed Scrubber (EPA Control Stack ID SC-4) installed in 1999 (with packing 

added by ISB in 2004, and maintained on an ongoing basis) 

• Water Treatment Plant installed in 2008 to handle the continuous liquid discharge from the two 

scrubbers 

The capital and major repair costs for this equipment total well over $2 million dollars (not adjusted to 

today's dollars), and the current operating costs are approximately $275,000 per year. 

The Kiln #3 scrubber is a conventional packed tower scrubber. In the very challenging flue gas 

environment of the brick tunnel kilns, the packing becomes fouled steadily over time. The control 

efficiency for acid gases does degrade over time because of this unavoidable phenomenon. ISB replaces 

the packing in Kiln#3 annually in order to manage this fouling. When the scrubber for Kiln #4 was being 

procured, a design that does not use packing was specified in order to handle the fouling problem. 

Although the RotoBed scrubber as designed does not have any problem with fouling, the control 

efficiency for acid gases was consistently tower than the packed tower scrubber on Kiln#3. In 2004 ISB 

chose to add some packing to the Kiln#4 scrubber on an ongoing basis (adopting the annual packing 

replacement practice to manage the fouling problem), and the control efficiency for acid gases is now 

similar to that of the Kiln#3 scrubber. 

CLAY DIVISION 

H.C. MUDDOX: 4875 Bradshaw Road • Sacramento, CA 95827-9727 • (BOO) 776-1244 • Fax (916) 362-9182 

INTERSTATE BRICK: 9780 South 5200 West • West Jordan, Utah 84088-5625 • (BOO) 233-8654 • Fax (801) 280-5220 

GLADDING, McBEAN: 601 7tl1 Street • P.O. Box 97 • Lincoln, CA 95648-0097 • (800) 776-1133 • Fax (916) 645-1723 

a division of PACIFIC COAST 

building products 
J

N00U:7 NSC

FAX NO. 8012805221 

ECONOMIC ISSUES AND BASIC FAIRNESS 

ISB believes that the 1ongst;;1nding and ongoing environmental expenditures listed above exceed those of 

most competitors who are major HAP sources and who will therefore be subject to the major source Brick 

MACT. These investments and ongoing costs place ISB at a competitive disadvantage in the market 

place, and requiring ISB to perform expensive testing for a regulatory program that will not apply to !SB 

constitutes an unwarranted and unfair punishment upon IS B. 

The current economic climate is extremely difficult for ISB's business. A number of employees have been 

laid off, and the two tunnel kilns are being operated at a total production rate of approximately one third of 

actual 2006 annual production. Significant additional expenditures that do not have any potential of 

improving the business bott<Jm line could easily cause ISB to temporarily mothball or periodically shut 

dawn the facility. Shutting down a tunnel kiln can be disastrous because of the tendency of the tunnel 

roof or "crown" to collapse when the expansive effect of elevated temperatures is removed. 

With your consideration of ISB's circumstances, the fallowing sections indicate ISB's proposed response 

to EPA's ICR letter. 

TEST DATA FOR PM, HF, HCL 

ISB proposes to submit test data far particulate matter (PM), hydrogen fluoride (HF) and hydrogen 

chloride (HCI), collected in August 2005 from both Kilns. These data will be submitted by means of EPA's 

required Electronic Reporting Tool (ERT) Version 3, as required by the ICR letter. These data comply 

with the requirements of the ICR letter In all respects, and were submitted contemporaneously to the 

Utah Division of Air Quality (DAQ) as part of the DAQ's "true minor" determination with respect to the HAP 

major threshold. This testing represents the facility as it is currently operating, with packing installed in 

Kiln#4 scrubber. 

TEST DATA FOR HAP METALS 

ISB conducted some informational testing for PM and HAP Metals from both kilns on May 7, 2007. We 

believe that these data comply with the requirements of the ICR in all respects, with one exception. Two, 

rather than three one-hour runs were conducted. We request that the EPA accept this data and not 

require additional testing. With your approval we will submit these data by means of the ERT. 

We agree that for compliance purposes three runs is required. However, the ICR is an information 

request, not a compliance1 demonstration requirement Any deficiency related to having two rather than 

three test runs pales in cClmparison to EPA's decision to ignore the varying content of fluoride in the clay 

content, from one clay to i3nother. 

We request that EPA accept the May 7, 2007 PM and HAP Metals testing as sufficient to satisfy the !CR 

letter. 

TEST OAT A FOR CHLORINE 

ISB has not conducted any chlorine (CI2) testing. We are somewhat surprised by this request, since we 

have not seen literature or governmental publications that raised chlorine as a particular air quality 

emission concern for the brick industry. Regardless, we would like to ask that permission be granted to 

not comply with this pa1ticu!ar portion of the ICR letter. As previously stated, additional testing is a 

significant economic hardship far ISB. The major source MACT will not apply to !SB, and we respectfully 

request that the requirement to perform testing for chlorine be removed. 

P. 02/03 
JAN

042011 TUE 11:18 AM INTERSTATE BRICK FAX NO. 8012805221 

SUMMARY AND CONCLUSION 

ISB is willing to provide the high quality and pertinent data that has previously been collected for PM, HF, 

HCI, and HAP Metals. With the exception of only two test runs for the metals, we believe that these data 

are completely in accordanc:e with the \CR request. In light of the fact that ISB is not an affected source 

and due to the financial harclship involved, ISB requests that: 

• EPA accept the May 7, 2007 HAP Metals testing as sufficient to satisfy the \CR; 

• That the requirement to perform testing for chlorine be removed. 

Thank you for your consideration of these matters, 

Sincerely, 

4~~JL·Ii~ Gerald Gunning J 

Operations Manager 

Cc: Patrick Stevens 

Golder Associates 

Jim Dufour 

Dufour & Associates 

P. 03/03