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Mr. JeffTelander 

U.S. EPA 

Mailcode 0243-02 

109 TW Alexander Drive 

Martinsburg, West Virginia 25405 

March 28, 2013 

Research Triangle Park, NC 27709 

Dear Mr. Telander: 

Phone: 304-263-697 4 

Fax: 304-267-0793 

I would like to express my appreciation for the time and effort you and the other 

representatives of the EPA took to meet with those of us representing small brick 

manufacturers on Thursday, March 14. The meeting struck me as being very helpful and 

informative for all participating parties. 

As the representative of Continental Brick Company, a small, single plant manufacturer of brick 

located in Martinsburg, West Virginia, it was encouraging to hear from Mr. Barrett that the EPA 

intends to consider ways to subcategorize small brick plants which may provide alternative 

ways for them to comply with the new Brick MACT rule. 

The brick manufacturer's group was also pleased to hear that the EPA is considering including a 

health based compliance alternative which may continue to protect the public health without 

requiring the substantial capital and operating expenditures that we cannot afford. To put it 

bluntly, the installation of any type of emission control system scrubber is beyond the financial 

capability of Continental Brick Company. We have endured many years of financial stress and 

losses because of the economic problems experienced by most of the country. The extremely 

competitive nature of the brick industry would not allow the company to pass along any 

increases in financing or operating expenses and would put us out of business. 

I understand that the EPA cannot consider financial or economic issues when establishing a 

MACT floor, but it is critical to Continental Brick Company that alternative methods of 

complying with the allowable emission levels is included as part of the MACT rule. There are 

many ways that sub-categorization of older and smaller brick plants can be justified. Among 

these is the difference in the design, operation, and performance of older (typically smaller) 

plants and more modern plants. I would be happy to provide you with additional information 

and details about these differences at the proper time. 

As we pointed out at the March 14 meeting, the industry representatives are concerned about 

the compressed schedule contained in the draft of the Sierra Club consent decree. The timing, 

as we currently understand it, requires a draft Brick MACT be written by August 30 of this year, 
followed by a final MACT rule in July of 2014. I believe that everyone at the meeting 

questioned whether sub-categorization and health based compliance alternatives could 

adequately and fairly be evaluated in that time frame. 

I would like to mention that Continental Brick Company is not a member ofthe Brick Industry 

Association (BIA) which has been very active in representing the interests of the industry during 

the MACT process. While we cannot afford to participate as paid members of the BIA, we do 

recognize, support, and appreciate the effort of their management and staff. We will continue 

to participate and support their efforts in every way a small company like ours can. 

I am looking forward to continuing to participate with the BIA and EPA as a representative of 

Continental Brick Company and a Small Entity Representative in the upcoming formal panel 

meeting. I would appreciate being informed when the specific date of the next meeting has 

been set. 

Thank you again for the time and effort you and your associates took to meet with us. 

cc: Susan Miller, BIA 

Sincerely, 

Donald B. Suit 

Vice President