Mr. Terry

Schimmel Vice President, Technical Services Boral Bricks, Inc . P.O. Box 1178 Columbus, G eorgia 31902 Re: Requirement to provide i nformation according to Title 42 of the Unite d State s Code, Chapter 85 , Subchapter I , Part A, section 7414 ( 4 2 U.S.C 7414 ) Dear Mr. Schimmel : We at the U.S. Environmental Protection Agency (EPA) are collectin g information about yo ur industry , brick and structural clay products (BSCP) (SIC Codes 3251 , 3253, and 3259 )

. At EPA, the developme nt of regulation s involve s gathering and analy zing a large amount of information. We are looking for your help in acquiring information specific to your company ’ s facilit ies because we believe that knowing about individual facilities is the key to knowing how an industry

operates, and what facilities do and/or can do about air pollution. We are requesting this information under the authority given to us within section 114 of the Clean Air Act (CAA) , as explained further below, and request that you send the compl e ted survey s for all of your facilities to us by August 13, 2008 **.** The law , as written in the Unite d States Code (42 U.S.C. 7414 ) , requires that you complete the enclosed survey an d return it to us

. As y ou know, the EPA previously developed national e mission standards for hazardous air pollutants (NESHAP) for BSCP manufacturing under s ection 112 (d) of the C A A. The NESHAP for BSCP manufacturing was promulgated on February 28, 2003 and published in the Federal Register on May

16, 2003. As a result of jud icial review, the standards were subsequently

vacated. We are now in the process of collecting updated information on the hazardous air pollutant ( HAP ) emission sources and controls in the BSCP industry

. This information will be used as the basis for devel oping new standards and updat ing our inventory of BSCP sources and facilities. Inthe enclosed survey , we request information on BSCP processes, emissions, and controls. Enclosure 1 includes the survey form that you should use to provide the information to us . An electronic version of the survey form can be found on the compact disc (Enclosure 2). Please complete either the hard copy survey form in Enclosure 1 , or the electronic survey form in Enclosure 2, for each of your facilities , unless any of those facilities is part of another company and is separately

incorporated as a subsidiary or affiliate of your company . If any one of yo ur2

facilities is separately

incorporated, please do not complete the survey s in Enclosure s 1 or 2 for that facility

. In struct ions for completing the survey form are provided in Enclosure 3. Using th e information yo u provide to us in th i s survey , along with similar information we receive from other companies in your industry , we will determine the amount of HAP emi tted ; define the present level of emission control ; and assess what would be the environmental, energy , and economic impacts associated with installing and operating emission control techniques that are feasible for yo ur industry

. We are sensitive to the amount of time and effort required to complete th i s survey . Therefore, we have tried to limit the information requested to only those features important to develop ing the regulation so as to minimize the time yo u need to spend

. I would like to assure you that nothing is being requested that we do not feel is necessary to achieve our goals stated above. You may respond “ Not Applicable ” to questions that do not apply to your facilities. Enclosure 4 c ontains a summary of our legal authority in s ection 114 of the CAA to o btain the information requested in th i s survey . If you believe that providing any specific information to us would reveal a trade secret, please identify this information clearly in your response . However, p lease do not label yo ur entire response “ Confiden tial ” if only a portion include s trade secret s . You can see in Enclosure 4 the ty pe of information that EPA may ask of yo u at a later time to prove that any information yo u have so identified is truly confidential. Any information determined to be a trade secret will be protected by 18 U.S.C. 1905. If yo u do not claim as confidential any

of the information in yo ur returned survey , we can make th is information available to the public without noti fying you further (40 CFR Part 2.203, September 1, 1976). Becau se s ection 114 of the CAA does not allow emission data to be claim ed as confidential, the emission data you provide to us can be made available to the public. A detailed explanation of what we consider to be emission data is contained in Enclosure 5

. We have contracted RTIInternational (RTI ) (Contract No. EP

- D

- 06

- 118) to help us gather information about your industry

. A s noted in Enclosure 6 , we have designated RTI to be our authorized representative. Therefore, RTI has the same rights discussed above an d in Enclosure 4 as EPA has

. This means that RTI will have access to all information provided to us in yo ur completed survey

. As a designated representative of the Agency , RTI must, by law, also abide by the requirements of 42 U.S.C. 7414(c) in regard to the confidentiality of what yo u claim to be trade secrets. Enclosure 7 summarizes our policies and procedures for handling trade secret information and describes how our contractor also is required to use the same procedures as we do. Because our contract ors or other authorized representatives are required to follow the requirements in Enclosure 6 , we believe that we can ensure your rights and protect any privileged information yo u submit to us. C op ies of th i s survey form have been given to representativ es of yo ur industry for their comments. We have attempted to incorporate their comments and suggestions into the final version. If you have questions regarding the need for this survey or need clarification on the3

information we are request ing , please cont act Jeffrey Telander with EPA ’ s Office of Air Quality Planning and Standards at 919

- 541

- 5 427 (e

- mail : telander.jeff @epa.gov). Please return the completed survey form(s) to Mr. Telander at the address below by August 13, 2008

.

Jeffrey Telander U

. S

. E PA Mailroom (D243

- 02) U .S. Environmental Protection Agency Office of Air Quality

Planning and Standards Research Triangle Park, NC 27711 I am sure you understand how important it is for the EPA to use the very best information available to develop the most meaningful standard. Your help in providing this information is greatly appreciated. Sincerely ,

Peter Tsirigotis Director, Sector Policies and Programs Division Office of Air Quality

Planning and Standards 7 Enclosures

cc: State AQM Offic e U.S. EPA Region (w/o Enclosures)4

Id entical l etters also sent to: Mr. Dennis Knautz, President Acme Brick P.O. Box 425 Fort Worth, TX 76107 Mr. J. David McKeown Regional Environmental Manager Hanson Building Products America P.O. Box 3307 Columbia , SC 29230 Mr. Dave McNees Director of Environment & Corporate Real Estate General Shale Brick, Inc. P.O. Box 3547 Johnson City , TN 37602 Mr. William Belden, Jr. Chairman & CEO The Belden Brick Co. P.O. Box 20910 Canton, OH 44701 Mr. Steve Matsick, Pre sident Glen

- Gery

Corporation P.O. Box 7001 1166 Spring Street Wyomissing, PA 19610 Mr. Michael Borden President & Owner Carolina Ceramics Brick Company 9931 Two Notch Road Columbia, SC 29223 Mr. Norman Davis General Manager Morin Brick Company P.O. Box 1 510 Auburn, ME 04211 Mr. Charles Taylor, Jr., President Taylor Clay

Products, Inc.5

P.O. Box 2128 Salisbury , NC 28145 Mr. Ronald Methier, Chief Air Protection Branch Georgia Environmental Protection Division 4244 International Parkway Suite 120 Atlanta, G A 30334 Mr. James Brooks, Director Bureau of Air Quality Maine Department of Environmental Protection 17 State House Station Augusta, ME 04333

- 0017 Mr. B. Keith Overcash, Acting Director Division of Air Quality North Carolina Department of Environment and Natural Resources 1601 Mail Service Center Raleigh, NC 27699

- 1601 Mr. Robert Hodanbosi, Chief Division of Air Pollution Control Ohio Environmental Protection Agency 122 S. Front Street Columbus, OH 43215 Ms. Joy ce E. Epps, Director Bureau of Air Quali ty , Pennsylvania Department of Environmental Protection P.O. Box 8468 Harrisburg, Pennsylvania 17105

- 8468 Ms. My ra C. Reece, Chief Bureau of Air Quality South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Mr . Barry R. Stephens, Director Division of Air Pollution Control Tennessee Department of Environment and Conservation 401 Church Street, 9th Floor L & C Annex6

Nashville, TN 37243

- 1531 Mr. John Steib, Director Air Permits Division Texas Commission on Enviro nmental Quality (MC 163) P.O. Box 13087 Austin, TX 78711

- 3087 Mr. Dave Conroy , Chief Air Programs Branch U.S. Environmental Protection Agency Region I 1 Congress Street, Suite 1100 Boston, MA 02114

- 2023 Mr. Judith Katz, Director Air Protection Division U .S. Environmental Protection Agency Region I II 1650 Arch Street Philadelphia, PA 19103

- 2029 Ms. Beverly

Banister, Director Air, Pesticides and Toxics Management Division U.S. Environmental Protection Agency Region IV Atlanta Federal Center 61 Forsy th Street, SW Atlanta, GA 30303

- 3104 Ms. Cheryl Newton, Acting Director Air Division U.S. Environmental Protection Agency Region V 77 W. Jackson Boulevard Chicago, I L 60604

- 3507 Ms. Becky

Weber, Associate Director Air Programs U.S. Environmental Protection Agency Region VI 1445 Ross Avenue Dallas, TX 75202

- 2733