Enclosure 3 **Information Collection Request for Brick and Structural Clay Products Instructions**  For hard cop y submittals, p lease return the completed information collection request (I CR) by August 13, 2008 to: Mr. Jeffrey

Telander Secto r Policies and Programs Di vision (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 IC R 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 I CR 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 sy nthetic minor sources of HAP
. In addition to general information about your company

and facilities, information is requested for all kilns at each plant, the emi ssion 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 clearl y 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 consis t of CBI
. Als o, 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 cop y version of the I CR, either highlight or label any information that you consider CBI (e.g., b y circling the data and writing “ CBI ” adjacent to the data). This I CR has been designed in the form of an Excel spreadsheet. We would appreciate yo ur completing the survey electronicall y. However, you may also fill in the attached paper cop y of the I CR.2

The I CR consists of s even different worksheets : **Form A -**  **General Information .**  Th is 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., i nactive kilns)
. **Form C -**  **APCD Info rmation**  **.** This worksheet addresses air pollution control device s (APCDs) that are used to control emissions from any kiln. **Form D -**  **Test Data**
. This work sheet asks for i nformation o n 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 work sheet 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**  **- Economi**  **c Impacts Information**
. This worksheet requests information on product selling price and labor rates
. **Form G**  **- Additional Questions** 
. This work sheet requests information on control device costs, raw materials, work practices, periodic kiln operation, and o verall 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 cop y v ersion, these forms are two or more pages long, as follows: Form B
-- 3 pages; Form C
-- 5 pages, For m D
-- 2 pages, and Form E
-- 2 pages. M any of the worksheets include cells that are shaded ye llow. Each of these cells has a pull
- down menu for response s. Click on the box, then on the arrow on the right hand side of box , and select a response from the lis t. 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 cel l. Inthe hard cop y 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 mos t recent ye ar for which you have the requested data. If you provide annual data for a year other than 2007, please indicate the ye ar in the appropriate cells. A list of abbreviations used in the I CR is attached.3

The following paragraphs provide more details on how to complete the requested information on each of the worksheets. FORM A
-- GENERAL INFORMATION Th e information at the top of this worksheet (Rows 5 through 1 7 ) pertains to your overall parent company. Please fill this information in the fir st column. The remaining rows, beginning with Row 2 2 apply

to individual facilities. Please fill in a column for each facility
. P lease assign a Facility Id entification ( ID ) number consisting of the first four letters in the parent company name, followed b y a number (e.g., ABCD
- 1, ABCD
- 2, etc.). These same facility IDs must be used throughout the IC R 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 INFORMATI ON Please provide the requested information for each kiln at each facility , including any kilns that are not currentl y in operation (i.e., inactive kiln)
. Enter the Facility ID assigned on Form A, then enter the ID from yo ur permit, or us e 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 currentl y in operation, p lease provide the requested information based on the most recent operating data you have and select “ Tunnel
- inactive ” under “ Ty pe of Kiln ” in Column C. Enter the reporting ye ar (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 ty

pes of products that primarily are fired in the kiln, particularly if products other than standard or king brick are frequentl y made and if the typ e of product significantly impacts processing or production rate
. Do not list products that are made infrequentl y 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 Ty

pes Brick & Pipe Face Brick Special Shapes Brick Fire Brick Structural Tile Brick Pavers Fired Clay or Shale Brick Structural Brick Clay Pipe , Flue Li ners , 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.4

FORM C
-- APCD INFO RMATI ON 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, CD
2 , etc. F or 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 parameter s 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 cop y of each complete test report. For each test, enter the same Facil ity ID, kiln ID, and Control ID numbers that you entered on previous worksheets. When submitting the test reports, f ield notes and raw reading sections can be omitted. However, you must submit all other sections of the reports, including sample calculati ons, 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 tes t: production rate in units of fired product (tph) , and APCD parameter monitoring data. FORM E
-- MONIT ORING 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 1 4 , 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 3 7 , please estimate the total hours, frequency , and staff levels for each of the listed activities. Inrows 4 1 through 4 7 , please provide the costs and other information for each stack test conducted during the past 3 ye ars. Please also provide separatel y an itemized list of site preparation co sts 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 entere d on Form B, please enter the average selling price per ton of the products fired in the kiln s . 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 fac ilities, companies, and the industry
. FORM G
-- ADDIT IONALQUESTIONS 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
.5

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 DL S dry

lime scrubber ft foot, feet ft2 square 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 max imum achievable control technology NAI CS North American Industry Classification System NG natural gas PM particulate matter SI C Standard Industrial Classification SO 2 sulfur dioxide tph ton s per hour yr ye ar(s)