# -;n~all Brick

U.S. EPA Mail Code D243-02 109 TW A lexander Drive RTP , NC 27709 C/ 0: JeffTelander

Dear Mr. Telander, Reply To : PINE HALL BRICK CO., INC. Lindsay Bri dg e Road Post Offi ce Box 836 Madison, N or th Ca rolina 27025·0836 Te le phone 336 -548 · 6007 Fax 336-5 4 8
- 1 837

May 10, 2010

I attended the recent S E R meeting at the EPA office in Washington, DC on April 20 , 2010 along with 

### 9 other small brick manufacturers. I represented Pine Hall Brick located in Madison, North Carolina. We are currently operating with a Title V air permit with 6 tunnel kilns. We have a great interest in this proposed brick MACT since we in fact installed a large DLA at one plant wh ich contro l s the emissions oftwo kilns t o be in compliance with the now vacated MACT ruling. 

### It fact our DLA removed in excess of 98% HF. We did this in good faith in an effort to comply with EPA's ruling fo llowing a great many hours gathering data and approximately 

### $ 720, 000 to construct and maintain the contro l device . We had stack tests run costing 

### in excess of$28 ,000 and were in complete comp li ance with the rule

. We al so i ncurred approximately $7 ,000 in consultant fees. Our good faith efforts now appear injeopardy with the possibility of not being able to use the DLA in the future with the proposed ruling. DLA ' s are used all over the United States and Europe quite successfully in controlling emissions

. We al so have two other plants( 4 kilns) at our Madison location that took a production limit of less than I 0 tons an hour. Two ofthe kilns are small and were built in the late 1 950 ' s and early 1960 ' s. The only things keeping these kilns 

### in operation today are the unique product line and the uti lization of sawdust as a fuel. The installation of a contro l device on these units may 

### in fact alter our airflow and atmospheric conditions which may affect our unique colors. The other two kilns are also small and were built 

### in 1996 and 1998 to produce clay pavers. They were constmcted with a special low profile design to give tight contro ls on our fired physical properties to meet the ASTM requirem ents for these un its
. The install ation ofcontrol devices could quite possibly alter our control of these kilns and make it difficult to product this specialty product. 

### It is quite alarming that with the new proposed ru le that we may be forced to install control devices at these plants

. Needless to say we would have to look at the economics of these installat ions to see if in fact we cou ld continue operating these kilns.
I listened to my colleag ues present their cases as to the hardship the proposed rule would have on their company even caus ing many ofthem to go out of business. I hope all in

270 1 Sh ore/a i r Drive, P.O. B o x 11 044 W ins to n -Sa l em, NC 27 116
- 1 044 T el. (33 6) 72 1 -7500 Fa x
. (336) 72 5-3940

### I listened to my coll eagues present their cases as to the hardship the proposed rule would have on their company even causing many of them to go out of business. I hope all in attendance heard what they had 

### to say. l 

### a lso hope that they heard my concern abo ut a potential Health Based Compliance standard th at was not considered in the last MACT because ofthe lack of time on EPA's part 

### to study this possibility

. This defutitely should be considered 

### as an option in the new MACT rul e. The state ofNorth Carolina is including a health-based compliance standard in their 112j ( MACT Hammer) rules. Our initial ca lculati ons show that our facility em i ssions ofHCl and HF from all6 tunnel kilns at full permit production levels would be well be low (approximately 50-60 %) the EPA allowable TW HCl equivalent limit

. . I opened my comment with the question , wasn ' t the propose of the MACT ru l e to protect human health and the environment?

. Your answer was yes. The heal th compliance standard appears to show that the brick industry does have the potential to fully protect human health and the environment without the need to install additiona l control devices for HC l and HF. Ifth i s is the case and cou ld be included in the new MACT rule it would give many, ifnot a ll , of the smal l manufacturers a way to comply with the ru le and continue to protect human health and the environment.

Sincerely ,

# ~-/J~.yj~ Haro ld B. Newman Vice President ofTechnical Services

cc : A Cristofaro C Higgins KHolman SM ill er