From: "McKeown, David (Columbia) NA" David.McKeown@hanson.biz
Sent: 08/12/2008 02:12 PM
To: Jeff Telander/RTP/USEPA/US@EPA
Cc:
Subject: Hanson Brick ICR Submittal

Dear Mr. Telander:

Attached is the completed response to EPA's information collection request for the brick and structural clay products industry.  We have included each plant owned and operated by Hanson in this response.  Some items to note are as follows:

Form A:  We have provided each facility's current classification as it relates to Hazardous Air Pollutants.  We may review these designations in the future and reclassify any of the facilities as warranted from that review.

Form B:  Please note that, in 2007, all of our kilns did not operate
8760 hours per year, as would be typical for most tunnel kilns.  Given the difficult economy, we found it necessary to limit production at several facilities to match the ailing economy's decreased demand.
Any new MACT that requires changes in our current controls (particularly one that could endanger our ability to maintain the same pollution control devices we currently have) could have further debilitating impacts on an already struggling industry.

Form B:  We understand the need to gather data related to each kiln's production throughput.  However, we do not believe that, when assessing the control status of kilns of various sizes, that throughput limits, which were accepted in lieu of MACT control requirements, should be included.  We believe that each kiln's full design capacity should be used in this evaluation.

Form B:  As you can see, one of our controlled kilns (Corunna Michigan) did not operate at all last year and several other controlled kilns were not continuously operated.  As such, this increases the impact of control device costs on the variable cost (dollars per thousand brick) basis and creates additional maintenance and operating burdens to ensure the controls remain viable and ready to operate when needed (e.g., to ensure that limestone does not absorb any moisture as it cools within the chamber).  We believe these costs should be considered when evaluating the impact of future rulemaking.

Form D:  In order to avoid submitting redundant data, we did not include any test reports that were previously submitted to you during the last round of rulemaking for this category.  Our test reports will follow as separate emails due to their electronic sizes.

Form F:  We are not submitting completed FORM Fs with this submittal.
Our brick prices are considered highly confidential and will be submitted under separate cover, as directed in your instructions.  While we opted not to submit our FORM Es as CBI, you should be aware that most facilities consider their reagent costs to be sensitive as well.  We encourage you to treat that information accordingly (e.g., use ranges in reports or presentations; mask data sources; etc.)

Please feel free to contact me via email or by phone at (803) 691-3121 if you have any questions.

Thank you.
J. David McKeown

Hanson
5100 Brickyard Road
Columbia, SC 29203

Tel:  803 786 1260
Cell: 803 351 0635
Fax:  803 786 9703
David.McKeown@Hanson.Biz

(See attached file: Brick ICR- Hanson-FINAL VERSION-submitted 08.12.2008.xls)
