Enclosure 3

Information Collection Request for Brick and Structural Clay Products

Instructions

For hard copy submittals, please return the completed information collection request 

(ICR) by August 13, 2008 to:

Mr. Jeffrey Telander

Sector Policies and Programs Division (D243-02)

U. S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Research Triangle Park, North Carolina 27711

If you wish to complete the ICR electronically, you can return the ICR file on compact 

disc (CD) or diskette to Mr. Telander at the address above. You can also email your submittal to 

Mr. Telander at: telander.jeff@epa.gov. If you email the ICR to Mr. Telander, please send the 

other requested documents (e.g., emission test reports) to Mr. Telander at the above address.

If you need clarification of any question or requested information, you can contact 

Mr. Telander at (919) 541-5427.

This information request should be completed for each facility that manufactures brick 

and structural clay products, including facilities that are major sources of hazardous air pollutants 

(HAP) and facilities that are synthetic minor sources of HAP. In addition to general information 

about your company and facilities, information is requested for all kilns at each plant, the 

emission controls associated with kilns, emission data, and other information related to 

monitoring emissions and complying with applicable emission standards.

If you believe that any of the specific information requested is proprietary or confidential,

hereafter referred to as confidential business information (CBI), you should clearly highlight or

label the specific information. Please do not label the entire ICR, or an entire page of the ICR, as 

“confidential” if only certain portions consist of CBI. Also, do not submit information that you 

consider to be CBI through e-mail.

If you are completing the electronic version of the ICR, highlight in red each cell that 

contains CBI. To highlight a cell or cells in Excel in red, first select the cell(s) to be highlighted, 

then on the Format menu, click on “Cells...,” then click on “Pattern,” then under “Cell Shading”

and “Color,” click on the small red colored box. If you are completing the hard copy version of 

the ICR, either highlight or label any information that you consider CBI (e.g., by circling the data 

and writing “CBI” adjacent to the data).

This ICR has been designed in the form of an Excel spreadsheet. We would appreciate 

your completing the survey electronically. However, you may also fill in the attached paper copy 

of the ICR.
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The ICR consists of seven different worksheets:

Form A - General Information. This worksheet requests information on your overall 

parent company and on each facility that manufactures brick and/or structural clay products.

Form B - Kiln Information. This worksheet requests information on each kiln at each 

facility, including kilns that currently are not in operation (i.e., inactive kilns).

Form C - APCD Information. This worksheet addresses air pollution control devices 

(APCDs) that are used to control emissions from any kiln.

Form D - Test Data. This worksheet asks for information on emission tests performed 

on kilns at your facilities. Please note that complete copies of emission test reports are requested.

Form E - Monitoring and Other Costs. This worksheet requests information about the 

costs for monitoring and operation and maintenance (O&M) activities associated with kiln 

APCDs. Emission test cost data also are requested on this worksheet.

Form F - Economic Impacts Information. This worksheet requests information on 

product selling price and labor rates.

Form G - Additional Questions. This worksheet requests information on control device 

costs, raw materials, work practices, periodic kiln operation, and overall process operations at 

each facility.

If needed to provide the requested information on each of your facilities, kilns, or control 

devices, please insert columns or rows to the spreadsheets. For the hard copy version, please 

copy pages as needed to provide all of the requested information. Note also that Forms B, C, D, 

and E in the spreadsheet version do not fit on one screen, and you must either scroll to the right 

(Forms B, C, and D) or down (Form E) to see the entire worksheet. In the hard copy version, 

these forms are two or more pages long, as follows: Form B -- 3 pages; Form C -- 5 pages, 

Form D -- 2 pages, and Form E -- 2 pages.

Many of the worksheets include cells that are shaded yellow. Each of these cells has a 

pull-down menu for responses. Click on the box, then on the arrow on the right hand side of box,

and select a response from the list. For the unshaded cells, the information should be keyed in.

There is no need to change the column widths if your response does not fit within the cell. In the 

hard copy version of the ICR, suggested responses are listed in the footnotes to each form.

Several worksheets request data on annual production, consumption, sales, or hours for 

various activities. Please provide the totals for 2007 or the most recent year for which you have 

the requested data. If you provide annual data for a year other than 2007, please indicate the year 

in the appropriate cells.

A list of abbreviations used in the ICR is attached.
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The following paragraphs provide more details on how to complete the requested 

information on each of the worksheets.

FORM A -- GENERAL INFORMATION

The information at the top of this worksheet (Rows 5 through 17) pertains to your overall 

parent company. Please fill this information in the first column. The remaining rows, beginning 

with Row 22 apply to individual facilities. Please fill in a column for each facility. Please assign

a Facility Identification (ID) number consisting of the first four letters in the parent company 

name, followed by a number (e.g., ABCD-1, ABCD-2, etc.). These same facility IDs must be 

used throughout the ICR where requested on other worksheets. We will assume that all plants 

with the same street address are within one “source” for major source determination, unless you 

note otherwise.

FORM B -- KILN INFORMATION

Please provide the requested information for each kiln at each facility, including any kilns 

that are not currently in operation (i.e., inactive kiln). Enter the Facility ID assigned on Form A, 

then enter the ID from your permit, or use TK-1, TK-2, etc. for tunnel kilns, and PK-1, PK-2, 

etc., for periodic kilns. Use a separate row for each tunnel kiln. However, if a facility has several 

identical periodic kilns, you can use one row to represent all of the identical periodic kilns. In

such a case, the kiln IDs should be assigned to indicate the number of periodic kilns (e.g., PK-1 

to PK-12). For kilns that are not currently in operation, please provide the requested information 

based on the most recent operating data you have and select “Tunnel-inactive” under “Type of 

Kiln” in Column C.

Enter the reporting year (if not 2007). For stack diameter, enter the diameter of the kiln 

stack if it is uncontrolled, or the diameter at the outlet of the APCD if the kiln is controlled.

Indicate the major types of products that primarily are fired in the kiln, particularly if products 

other than standard or king brick are frequently made and if the type of product significantly

impacts processing or production rate. Do not list products that are made infrequently or that 

comprise a small percentage of total production for the kiln. Some example products are listed 

below, but do not feel limited to use only the listed products.

Brick and Structural Clay Product Types

Brick & Pipe Face Brick Special Shapes

Brick Fire Brick Structural Tile

Brick Pavers Fired Clay or Shale Brick Structural Brick

Clay Pipe, Flue Liners, etc. Flashed Product (fuel flashed) Thin Brick

Clay Roofing Tile Floor Tile

Common Brick Reduction Fired Products

For the actual capacity utilization (%), enter the actual production rate divided by the 

design or maximum production rate for the kiln.
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FORM C -- APCD INFORMATION

Please enter the requested information in each row for each APCD that controls 

emissions from any of your kilns. Enter the same Facility ID and kiln ID numbers that you 

entered on Forms A and B. For each control device, enter the ID from your permit, or CD-1, CD2, etc. For baghouses or fabric filters, the air-to-cloth ratio is determined as the design exhaust 

flow (actual cubic feet per minute [acfm]) divided by the total surface area of the bags (square 

feet [ft2]). For control devices other than those listed in the worksheet, please specify up to three 

design or monitoring parameters for each and indicate the units for each parameter. 

FORM D -- TEST DATA

Please complete the summary information requested in this worksheet and also provide a 

copy of each complete test report. For each test, enter the same Facility ID, kiln ID, and Control 

ID numbers that you entered on previous worksheets.

When submitting the test reports, field notes and raw reading sections can be omitted.

However, you must submit all other sections of the reports, including sample calculations, 

laboratory data, run-by-run emission data, and a description of any deviations from test methods 

or other anomalies that occurred with the process or control device operations during the test.

Please also provide records for the following for each test: production rate in units of fired 

product (tph), and APCD parameter monitoring data.

FORM E -- MONITORING AND OTHER COSTS

Please provide the requested information for each facility. Indicate the Facility ID 

number using the same ID number indicated on other worksheets. In rows 10 through 14, 

provide the requested unit costs for January 2008. If you provide unit costs for a different period, 

please indicate the period in the appropriate cells. In rows 18 through 37, please estimate the 

total hours, frequency, and staff levels for each of the listed activities. In rows 41 through 47, 

please provide the costs and other information for each stack test conducted during the past 3 

years. Please also provide separately an itemized list of site preparation costs that are not 

included in the test cost estimate. Examples include the costs for drilling testing ports in the kiln 

stack and the costs for installing permanent access to sampling ports.

FORM F -- ECONOMIC IMPACTS INFORMATION

For all kilns entered on Form B, please enter the average selling price per ton of the 

products fired in the kilns. Also enter the average labor rates for the staff levels listed. This 

information will be used to estimate the economic impacts of the final rule on specific facilities, 

companies, and the industry.

FORM G -- ADDITIONAL QUESTIONS

Please provide the requested information on control device costs, raw materials, work 

practices, and periodic kiln operation. Also provide a process flow diagram for each facility.
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Attachment

List of Abbreviations used in Brick and Structural Clay Products Manufacturing ICR

acfm actual cubic feet per minute

APCD air pollution control device

DIFF dry injection fabric filter

DLA dry limestone adsorber

DLS dry lime scrubber

ft foot, feet

ft2square feet

gal gallon(s)

gpd gallons per day

gpm gallons per minute

HAP hazardous air pollutant

HCl hydrochloric acid

HF hydrogen fluoride

ICR information collection request

hp horsepower

hr hour(s)

ID identification

kwh kilowatt hour(s)

MACT maximum achievable control technology

NAICS North American Industry Classification System

NG natural gas

PM particulate matter

SIC Standard Industrial Classification

SO2 sulfur dioxide

tph tons per hour

yr year(s)