ACME 

SRICK 

~~ee 1~91 

August 12, 2008 

Submitted via FedEx 

Mr. Jeffrey Telander 

U.S. EPA Mailroom (D243-02) 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711 

Re: Information Collection Request 

Acme Brick Company 

Dear Mr. Telander, 

Please find enclosed the completed forms for all brick manufacturing facilities owned and 

operated by Acme Brick Company. As you will see in the attached forms, footnotes have 

been added where additional explanation is necessary. In addition, comments on specific 

forms are provided below: 

Form A 

• The size classification for each facility is based on the current permit for that 

location. The classifications may change in the future based upon re-evaluations 

of the operations. 

Form B 

• Kilns that have been demolished are specifically noted to assist the EPA in 

updating the database. 

• Periodic kiln permitted capacity (column L) is represented in tons per year/kiln as 

opposed to tons per hour/kiln. Tunnel kiln permitted capacity is based on a 

rolling 12-month average and not an instantaneous limit. 

• Permitted throughFut limits that are less than the full design capacity are due to 

the previous MACT rule and should not be considered when evaluating the full 

capacity of the kiln. 

• Controls installed on ACME-5 were not in response to MACT but were installed 

for other permitting reasons. Throughput limits (<10.0 tph) were taken on the 

kilns to ensure that the kilns were not subj ect to the now vacated MACT JJJJJ. 

All other controls installed, with the exception of Acme 17, were installed for 

non-MACT compliance requirements. 

• Column M, "Actual Capacity Utilization" identifies the significantly reduced 

production output for the majority of Acme's facilities during 2007. For 2008, 

ACME BRICK COMPANY 

P.O. Box 425 — Fort Worth, Texas 76101 — TEL: 817/332-4101 
total production will be even lower. In fact, more kilns/plants have been idled this 

year and more are likely to come. Acme would like the EPA to recognize that 

any additional control, be it in the form of new air pollution control devices or 

modifications to existing controls, would be devastating to the viability and 

continued operation of many brick facilities. Permanent plant closings will result 

in the event that the new MACT requires additional controls. 

Form F 

• The data requested in Form F is confidential and was submitted separately as 

confidential business information (CBI) as indicated in the instructions. 

Acme appreciates the opportunity to provide comment and assist with the information 

gathering process and hopes that these efforts will result in a MACT rule that is fair, 

equitable, and considers the significant economic hardship the industry is currently 

undergoing and by all forcasts will continue to suffer for years to come. 

If you have any questions regarding this submittal please call me at 817-870-8354 or call 

Jason Pence at 817-870-8348. 

Company 

Enclosures: 

Forms A-G (excluding Form F) 

Stack Test Data Reports as Included on Form D 

cc: Dennis Knautz, Ed Watson, Jason Pence 

ACME BRICK COMPANY 

P.O. Box 425 — Fort Worth, Texas 76101 — TEL: 817/332-4101