MACT Task Force

October 17, 2008

Jeffrey Telander

Sector Policies and Programs Division

Office or Air Quality Planning and Standards

Research Triangle Park, North Carolina   27711

Dear Jeff,  

As we have discussed, we have emailed you a file that provides our most recent information on the kilns

in our industry.  This update includes information for facilities that responded to BIA’s recent Update

Survey.  For facilities that did not respond, we included the most recent information we have.  We have

used the same basic format that you used in the spreadsheet you provided us earlier this year.  We have

included the ID numbers that EPA used in the previous assessment, where known, for reference, as well

as the reference numbers we use for each facility in our database.  We anticipate that this will help

ensure any updates either of us makes to the database can be quickly referenced and updated in the

other’s database.  We have provided separate spreadsheets for tunnel and periodic kilns.  Please note

that we did not gather the additional information for periodic kilns that you requested in your ICR;

therefore, that information is not summarized in our spreadsheet.

Overall, we received update surveys from approximately half of the companies in our industry; however,

these surveys represent over 90 percent of the facilities, kilns, and known control devices.  Here is a

summary of our results.

Number of companies on our initial list: 78 

Number of companies removed (closed, bought out, etc): 7 

Total number of surveys “in play”: 71 

 Respondents Non-Respondents TOTAL 

Number of 

Companies 36 (51%) 35 ~71 

Number of Facilities 136 (75%)* ~45 ~181 

Number of Tunnel 

Kilns 263 (77 %) 77 ~340 

Number of Periodic 

Kilns 105 (46%) 123 ~228 

Number of Controlled 

Kilns 97 (95%) 5 (have old data for 3) 

~102 

Number of Control 

Devices 86(97%) ~3 ~89 

 *This total combines some previously separate co-located plants

Via email
We believe that the number of operating periodic kilns is likely high as many companies have moved

away from the use of these batch units.  However, even with the number in the current database, the

total throughput from these units is very small.  The following is a figure showing the estimated

throughput capacities of tunnel kilns, idle tunnel kilns, and all periodic kilns.  [Note: demolished tunnel

and periodic kilns are not included in this figure.]  It should be noted that a kiln that is listed as “inactive”

could be restarted if the market conditions dictated such an action.

 Tunnel (demolished) ‐> at least 83 tons per hour since 1998 (not included in

figure)

 Tunnel (total still in existence)‐> ~3250 tons per hour

 Tunnel‐ inactive‐ at least= 332 tons per hour  (DOES NOT INCLUDE kilns

operated below their capacity)

 Periodic‐> ~75 tons per hour  (equivalent capacity)  

We are still evaluating the information that has been submitted and still following up on some questions

identified in our review.  However, we do want to share a few preliminary graphs of information that we

have found most interesting.  We look forward to the opportunity to discuss these graphs and others

that you or we generate.

In Figure 2, we have graphed the number of control devices installed by year in our industry.  As you can

see, the vast majority of controls were installed in the years since the MACT was proposed.   We believe

that this is particularly relevant to any discussion of an appropriate “MACT on MACT” discussion.  It is

our understanding that the MACT floor approach, which EPA states does not allow for fully assessing

costs, was intended to be a review of the industry without a federal regulatory driver.  However, as we

know, that is clearly not the case for our industry.  We will be continuing to explore this issue and look

forward to submitting our thoughts on this issue in the near future.  We also believe that the argument

we raised last time, in regards to the use of synthetic minor sources in determining the floor for existing

sources, will also be important.   

In Figure 3, we have graphed the cumulative percent control by kiln size range.  For this assessment, we

have used one ton per hour increments, but believe that smaller increments may be warranted to better

assess the data.  Please note that, for this initial graph, we have not attempted to figure in rationale that

would relate to the “MACT on MACT” and “No synthetic minor sources in the floor” discussions.  We will

introduce these factors in a later submittal (which will also include our rationale for how these positions

should enter into a fair and reasonable assessment of the “updated” MACT floor for this industry.

We look forward to continuing to work with you on this important project.  As you might expect, a

reasonable and attainable rule is critical for our industry’s survival during these potentially devastating

economic times.  Please do not hesitate to contact me at (334) 480‐2488 or at

terry.schimmel@boral.com if you have any questions or are ready to share any of your own insights.

Sincerely,

B. Terry Schimmel

Boral Bricks

MACT Task Force Lead

cc:  BIA MACT Task Force