Redland Brick Inc. 

15718 Clear Spring Road 

P.O. Box 160 

May 7, 2010 Williamsport. Maryland 21795 

(301) 223-7700 

Mr. JeffTelander 

US EPA 

Mail Code D243-02 

I 09 TW Alexander Drive 

RTP, NC 27709 

(301) 223-6675 Fax 

BRICK 

Dear Mr. Telander: 

An 1509001 Registered Quality System 

Listed below are my answers to the questions you posed. I have answered these questions to the best of 

my ability based on my interpretation and understanding. 

I have attended recent meetings with BIA and EPA at Research Triangle Park and in Washington. I also 

attended a meeting at Research Triangle Park (RTP) when the last MACT was in process. 

I do not pretend to know all of the details of hea lth based standards but I like the concept !fit can be 

proven that the level of our emissions is harming the environment and/or the public it is reasonable for us 

to have to address the problem. Apparently, they have gotten good resu lts so far in N01th Carolina so we 

be\\eNe th\s should be pursued further. This may be an opportunity for the CAA to be addressed without 

adversely affecting the brick manufacturers that are small busin esses. The smal l businesses would be 

affected the most by another costly MACT implementation. 

Questions for Potential Small Entity Representatives (SERs) 

Compliance: 

1. Do you use any monitors (e.g., emissions monitors or process parameter monitors) to ensure that 

your ki Ins are operating properly? If yes, what types of monitors and how many? 

Our brick ki Ins are operated to produce product that has the appropriate structural integrity, size, texture, 

and the correct color. We must have the capability of repeatability on all of these items from run to run. 

Please keep in mind that we sell brick primarily on appearance- color and texture. Changes in kiln 

operations have a significant effect on brick color and matching run to run. 

Our kilns are all computer controlled. Computer settings such as high and low temperature setpoints for 

the various burners, kiln pushrate, exhaust air flow, fres h air flow, pressure monitors, and gas pressure are 

some of the monitors we employ in the operation of our kilns. These controls are strictly for the kiln 

operation_ We also have controls on our DLA scrubbers that control our emissions. 

At one location we voluntarily installed continuous emission monitoring (CEM) to operate our DI FF 

scrubber. The D!FF scrubber was selected to control S02 and was in operation for about 6 years prior to 

the installation ofthe CEM. The CEM reads the emission levels and adjusts the flow of fresh lime to the 

DIFF as our levels ofS02, HF, or HCI vary. The CEM generally only has to react to the S02 changes as 

the emission reductions ofi-IF and HCI generally occur with minima l fresh lime fl ow_ 

We are one of only two companies in the United States th at have CEM's installed on brick scrubbers. 

2. Are these monitors in place for environmental regulatory reasons? Insurance reasons? Or both? 

Manufacturer of quality brick products Cushwa KF Harmar Rocky Ridge 
See# I above. Our kiln monitors are installed to monitor the kiln operation. Our CEM was installed to 

operate our DIFF scrubber. At that plant location we have widely varying amounts ofS02 emissions. 

We installed the DIFF primarily to control S02 although HF and HCI are also reduced. The local 

regulatory agency does not require us to calibrate our CEM for HF or HCI since tanks of HF and HCI, 

needed for calibration, are highly toxic and dangerous to have on site. We perform periodic RATA 

testing to show that our CEM is recording the emissions properly and have passed those tests giving the 

County justification to allow us to avoid the HF and HCl calibration. 

3. What are the costs to the facility ofthese monitors? What percentage of overall facility costs do 

these represent? 

The cost to install a CEM is about $250,000- 300,000 plus the costs of training and calibration gasses. 

4. If you operate any periodic kilns, do you currently conduct any work or operating practices that 

would have an impact on HAP emissions from these kilns? lfyes, please explain. 

We do not operate periodic kilns at this time. 

5. If your tunnel kilns were subject to emission limits, are there testing ports avai lable for 

conducting compliance tests? If not, what do you estimate the costs to be of modifying the stack 

for testing? Do you foresee any other problems with conducting stack tests on your tunnel kilns? 

If so, please explain. 

The stacks of all of our kilns have been tested in the recent past. We installed test ports when we installed 

the stacks because our operating permits required periodic stack testing. 

Three of our four plants have been shutdown since the first of December and have opened back up in the 

last month. Our fourth plant has been operating continuously during that same period (although it was 

shutdown for two extended periods last year). This plant has remained open only because we make many 

special shaped brick at this location, something most other brick manufacturers cannot supply. All of our 

plants are operating at about 35% of capacity. Representative testing is usually required to be performed 

at 95% of capacity. Since we have had so many shutdowns in the last three years, we have lost many 

employees due to attrition. In order to test at 95% of capacity, we would have to hire a second shift of 

employees at each location, train them for their jobs, ramp up to speed in production, run the test, and 

then permanently lay off all of those newly hired employees. Note that we have about 500% turnover on 

new employees due to the physical nature of the work. Since we have about 75 million brick in inventory 

on the ground at this time, we would have to expect EPA to purchase the surplus of brick made during 

this entire period as we have no buyer for it. Failure to move this extra brick would threaten shutdowns at 

each location for the shifts of employees currently working as we have no additional space available for 

additional inventory. Testing at 95% of capacity is not an option for us this year or, until the economy 

improves significantly and we are able to sell off our existing inventory. 

6. What do you estimate the costs to be of conducting stack tests for HAP emissions from your 

tunnel kilns? 

Under normal circumstances, stack testing for HF and HCl only would cost approximately $15,000-

20,000. 

The most significant costs for us to test during this time are for labor to hire and train additional 

employees, increase our production speed, and manufacture product for which we have no market. In 

order to ensure a representative test, we estimate the amount of additional brick we would manufacture 
during this time would be over 6,000,000 with a carrying cost and investment in inventory of over 

$2,000,000. 

7. If your tunnel kilns were subject to emission limits, are there alternatives to monitoring emissions 

or stack testing that would be less costly to demonstrate compliance? If so, please explain the 

alternatives and estimate how much it would cost to conduct them. 

In our circumstances, this has not been an option to us in the past. If you have a material analysis taken at 

the time of a stack test to determine the fluorine and chlorine content in the raw material, you can 

compare relative production and future material analyses with given stack test results to predict future 

emissions. The state or local regulatory agency would need to buy in to this idea as stack testing is 

specifically listed as a requirement in our operating penn its. 

8. Do you have any kilns that are controlled with a dry limestone adsorber (DLA)? If so, please 

explain the feasibility and estimate the costs of replacing the DLA with a dry injection fabric 

filter (DIFF) or other type of control device that might be more effective in controlling emissions 

of HAP. 

We own a DLA in CT and one in MD. The CT DLA was installed in order to satisfy CT regulations for 

HAP 's when constructing a new kiln and plant almost 20 years ago. The MD unit was installed as a 

resu\t of the vacated MACT. As a result, both plants are now minor sources (area sources) of HAP's. In 

both cases we were informed of the HAP emissions we would have to control and the levels that we 

would have to control to. We purchased turnkey operations with written guarantees on performance. 

These units have performed well and the scrubbers have helped us to maintain compliance with our 

permit conditions. 

Cost of a DLA is $ 1 ,000,000+. Cost of a DIFF is $2,000,000+. Cost to remove a DLA would likely be 

$200,000-$500,000. So replacement costs are $2,200,000-2,500,000+. At our CT plant a significant 

expense such as this would likely mean plant closure. Our MD scrubber is less than five years old and 

has many more years of good use. 

Throughout our discussions with EPA, it appears that EPA is not in favor of the DLA. We suspect EPA 

is misinformed. This scrubber is used throughout Europe for HF and HCI control. It is also used in 

Europe for PM control. It is relatively simple to operate. It has few breakdowns. It has a proven track 

record in Europe and now in the United States. 

Wet scrubbers may be cheaper to install but what do you do with the particulate that is created? What do 

you do with the water? At two of our plants we do not even have sewer capability as the plants are in the 

country and utilize conventional septic systems. 

The only US brick plants that purchased a scrubber other than a DLA have additional non-HAP related 

issues. Generally, these plants have large amounts of sulfur emissions and must use a DIFF to address 

that. The DIFF costs twice to purchase, twice to operate, and has many moving parts all which eventually 

must get replaced. The potential downtime is significant. When the DIFF goes down, the scrubber goes 

into bypass and there is no emission reduction. When the DLA goes down, the gas can still be ducted 

through the limestone bed and the emissions can continue to be cleaned for a significant period of time 

and until repairs can be made. I believe considering this alone, the DLA does a better job of HAP 

emission reductions over time so the DLA should be the preferred emission control. 

9. Are there any subcategories that you would recommend fo r your industry? If so, please identify 

them and document the basis for your recommendation. 
The categories that EPA determined were reasonab le in the now vacated MACT are, at a minimum, the 

subcategories that should be included in this MACT. Periodic kilns and tunnel kilns should be separate. 

EPA should also continue to distinguish small and large tunnel kilns,. The smaller kilns tend to be older, 

more open (i.e. more places for air to enter the kiln), and more expensive (per brick) to operate. 

We defer further subcategorization issues to Susan Miller, YP ofBIA, who would be better qualified to 

answer and we agree with whatever her response is. 

Permitting/Inspections: 

I. Are your kilns required to be permitted by the state? If so, what is the cost for pennitting? If not, 

what would you estimate the burden to be in terms of costs and hours if the kilns are required to 

be permitted? What is the magn itude of these costs compared to the costs of kiln operation and 

the facility as a whole? Are your permitting activities done by in-house staff or by outside 

contractors? 

We are permitted by the state at our three locations in MD and CT and are permitted by Allegheny 

County in PA. We do whatever permitting work we can in-house but must use consulting help for the 

complicated issues like Title Y and MACT. We applied for Title Y permits in MD and CT to address 

MACT. Our MD Title Y permit was never issued, MD briefly lost the authority to issue Title Y and we 

had to apply for a federally issued Title Y permit before the original application was issued. We recently 

applied for and received a state only permit now that the MACT "never happened". In CT we applied for 

Title Y which was never issued because CT DEP could not get an explanation from EPA how to address 

the vacated MACT. We have now applied again for a state only operating permit and expect to receive it 

in the coming days. I would estimate that we have already spent $50,000- I 00,000 for consulting work 

for permits that were never issued to satisfy the MACT and the re lated vacatur. In addition, it is difficult 

to determine the cost for the amount of hours that I spent working on these permits or the travel expenses 

that Redland encountered as a result of my trips to MOE and flights to CT to meet with the DEP. 

2. Are your kilns required to be inspected for safety or insurance reasons? If so, how often is this 

performed? What is the cost of these inspections? What is the magnitude of these costs 

compared to the cost of kiln operation and the facility as a whole? 

Our plants and quarries are inspected by OSHA, MOSH, MSHA, MOE, CT DEP, PA DEP, ACHD, the 

local counties, and the Township. In spections are comprehensive. Each locale has its own rules for 

inspection frequency. In my career, the brick industry has been under siege by the various regulatory 

agencies and new rules, each with the potential to be economically disastrous for us. Some examples are 

MACT, Greenhouse Gas, MACT again, silica, MSHA training regs, zoning classifications, wetland 

regulations, and more on the horizon. If all ofthese proposed regulations were promulgated at one time 

there would be no more small businesses within the brick industry. 

Capital Availability/Regulatory Impact: 

Questions of this nature must be reviewed and answers approved by executive management. We request 

more details about these questions, why they are being asked, and what EPA plans to do with the answers 

before we will provide any answers. The brick indust1y has already provided significant information 

regarding finances. In addition, in 2006 there were 9.6 billion brick produced in the United States. Last 

year there were 2.3 billion brick produced. Based on orders through today, indications are that th is year 

will be worse than last year. Virtually every brick plant in the United States has been crippled by the 
economy and poor housing market. Many, particularly the smaller ones, may not survive, particularly if 

air pollution control devices are mandated, even where they are not warranted. 

I hope the information I have provided will help us to come to an acceptable conclusion in the 

development of this MACT standard. I also hope EPA will consider my comments. 

Please contact me if you have further questions. 

Sincerely, 

~IJ!:lL Manager- Safety, Environmental, and Quality 

cc. Susan Miller, BIA