From: "Terry Schimmel (Bricks - Phenix City)" <Terry.Schimmel@boral.com>
Sent: 08/13/2008 05:28 PM
To: Jeff Telander/RTP/USEPA/US@EPA
Cc:
Subject: Boral MACT ICR

Jeff,

Attached please find an electronic copy of Boral's completed ICR. Please note that the facility HAP classifications listed on FORM A are based on their current status. We will likely be reviewing the status of each facility in the coming years.
You will note that two of our facilities were not operated last year  These idled kilns remain functional and will be restarted when warranted. In addition, many of our kilns were not operated the entire year of 2007. I wish business conditions were better as so far it looks like our capacity utilization for 2008 is shaping up to be worse than 2007. Projections into the future look like several more years of hard times with expectation that demand may never get back to 2006 levels.
While year-round operation is typical for our industry, we have been impacted by the tough economic conditions of the past few years- and expect that this will continue for some time. This non-continuous operation obviously increases the cost of the control per ton of bricks produced, while also reducing the total profit that our company makes. We are interested in working with you and your economics lead (Tom Walton) to ensure that these conditions are included in your assessment of the impacts of any future rulemaking.
The non-continuous operation of our kilns and associated controls also creates additional maintenance and operating burdens. These additional activities are needed to ensure that the lime/limestone in our control devices are not permanently corrupted as the temperature within the chamber drops- and moisture from the atmosphere is introduced.
The throughputs/capacities listed on FORM B are based on yearly average throughputs. As we discussed during the site visits, the "capacity" of a brick kiln is not generally a stagnant number. We believe that you should not consider the "9.9" tph capacities when evaluating the control level at various sizes. These limits are not attributable to anything except the now vacated MACT. We are submitting FORM F under the CBI procedures you outlined. We are also mailing you the test reports listed via FedEx.
Please feel free to call me regarding the information on this submission or anything we may have missed. It's a pretty big task to complete this thing with as many plants as we have and I'm sure we may have missed something. Also in my capacity as the MACT Task Force lead person just let me know when and how we can help you all in ciphering through some of this information. Some of the questions have required some interpretation and everyone may not have understood what was being asked quite the same.

We look forward to working with you and all your people on the rule making.

Thanks,
Terry

(See attached file: Brick ICR- Boral- FINAL.xls)
