## JAN-04-2011 TUE 11:16 AM INTERSTATE BRICK FAX NO. 8012805221 P. 01/03 

# ()INTERSTATE®BRICK

® 9780 South 5200 West WestJordan, UT 84088-5625 (801) 280-5200 (800) 233-8654 Fax (801) 280-5220 January4, 2011 Mr. JeffTelander 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 ofAppeals 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 ofthe ICR request. 

### BACKGROUND Interstate Brick (ISB) is an "Area Source", i.e., minor facility with respect hazardous air pollutants (HAPs), becausethe potentialto emit (PTE) emission rates forthe facility are below the "HAP Major"thresholds of 10 tons/year ofa 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 priorto the clean air act. The current emission control systemsconsistofthefollowing equipment:

• Kiln #3 PackedTower 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 currentoperating costs are approximately $275,000 peryear. 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 foracid gasesdoesdegrade overtime because ofthis unavoidable phenomenon. ISB replaces the packing in Kiln#3 annually in order to manage this fouling. When the scrubberfor 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 similarto thatofthe 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

adivision of 

### PACIFIC COAST building products

## JAN-04-2011 TUE 11:17 AM INTERSTATE BRICK FAX NO. 8012805221

ECONOMIC ISSUES AND BASIC FAIRNESS ISB believes thatthe 1ongst;;1nding and ongoing environmental expenditures listed above exceed those of mostcompetitors who are major HAP sources and who will therefore be subjectto the majorsource 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 unfairpunishment upon ISB. The currenteconomicclimate is extremely difficultfor ISB's business. Anumberofemployees have been laid off, and the twotunnel kilns are being operated atatotal production rate ofapproximately one third of actual 2006 annual production. Significantadditional expenditures thatdo not have any potential of improving the business bott<Jm line could easilycause ISBtotemporarily mothball orperiodically shut dawn the facility. Shutting down atunnel kiln can be disastrous because ofthe tendency ofthe tunnel roofor"crown" to collapsewhen the expansive effectofelevated temperatures is removed. With yourconsideration ofISB'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 August2005 from both Kilns. These datawill 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 allrespects, and were submitted contemporaneously to the Utah Division ofAir Quality (DAQ) as partofthe DAQ's "true minor" determinationwith respectto 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 thatthese data complywith the requirements ofthe 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 additionaltesting. With yourapproval we will submitthese data by means ofthe 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 offluoride in the clay content, from one clayto i3nother. We request that EPA acceptthe May 7, 2007 PM and HAP Metals testing as sufficientto satisfy the !CR letter. TEST OATAFORCHLORINE 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 forthe brick industry. Regardless, we would like to askthat 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 majorsource MACTwill notapply to !SB, and we respectfully requestthatthe requirementto perform testing for chlorine be removed. 

## P. 02/03

## JAN-04-2011 TUE 11:18 AM INTERSTATE BRICK FAX NO. 8012805221

SUMMARYAND CONCLUSION ISB iswilling to provide the high quality and pertinent data that has previously been collected for PM, HF, HCI, and HAP Metals. With the exception ofonly two test runs forthe metals, we believe thatthese data are completely in accordanc:e with the \CR request. In lightofthe fact that ISB is not an affected source and dueto the financial harclship involved, ISB requests that:

• EPAacceptthe May 7, 2007 HAP Metalstesting as sufficientto satisfythe \CR;

• Thatthe requirementto performtesting forchlorine be removed.

Thankyou foryourconsideration ofthese matters, Sincerely,

# 4~~JL·Ii~ Gerald Gunning 

# J Operations Manager

Cc: PatrickStevens GolderAssociates Jim Dufour Dufour &Associates 

## P. 03/03