-;n~all Brick 

U.S. EPA 

Mail Code D243-02 

109 TW Alexander Drive 

RTP,NC 27709 

C/0: JeffTelander 

Dear Mr. Telander, 

Reply To: 

PINE HALL BRICK CO., INC. 

Lindsay Bridge Road 

Post Office Box 836 

Madison, North Carolina 27025·0836 

Telephone 336-548·6007 

Fax 336-548-1837 

May 10, 2010 

I attended the recent SER 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 which controls the emissions of two kilns to 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 following a 

great many hours gathering data and approximately $ 720,000 to construct and maintain 

the control device. We had stack tests run costing in excess of$28,000 and were in 

complete compliance with the rule. We also incurred approximately $7,000 in consultant 

fees. Our good faith efforts now appear in jeopardy 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 also have two other plants( 4 kilns) at our Madison location that took a production 

limit of less than I 0 tons an hour. Two of the kilns are small and were built in the late 

1950's and early 1960's. The only things keeping these kilns in operation today are the 

unique product line and the utilization of sawdust as a fuel. The installation of a control 

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 controls on our fired physical properties to meet the ASTM requirements for 

these units. The installation of control 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 rule 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 installations to 

see if in fact we could continue operating these kilns. 

I listened to my colleagues 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 

2701 Shore/air Drive, P.O. Box 11044 Winsto n-Salem, NC 27116-1044 Tel. (336) 72 1-7500 Fax. (336) 725-3940 
I listened to my colleagues 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 also hope that they heard my concern about a 

potential Health Based Compliance standard that was not considered in the last MACT 

because of the lack of time on EPA's part to study this possibility. This defutitely 

should be considered as an option in the new MACT rule. The state of North Carolina is 

including a health-based compliance standard in their 112j ( MACT Hammer) rules. Our 

initial calculations show that our facility emissions ofHCl and HF from all6 tunnel kilns 

at full permit production levels would be well below (approximately 50-60 %) the 

EPA allowable TW HCl equivalent limit .. 

I opened my comment with the question, wasn't the propose of the MACT rule to protect 

human health and the environment?. Your answer was yes. The health 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 additional control devices 

for HCl and HF. If this is the case and could be included in the new MACT rule it would 

give many, if not all, of the small manufacturers a way to comply with the rule and 

continue to protect human health and the environment. 

Sincerely, 

~-/J~.yj~ Harold B. Newman 

Vice President of Technical Services 

cc: A Cristofaro 

C Higgins 

KHolman 

SMiller