THE PAVER PLACE 

41'0 

WHITACRE GREER Mayll, 2010 

Qwa64ty f4wc2 1900 

Compliance 

1. Monitoring of our kilns consists of monitoring temperature and pressure by zone. 

There are 10 thermocouples of which 3 make automatic control changes. The PC fan 

is also monitored for speed and damper settings, which controls the pressure. 

2. Monitors are in place for process control only 

3. Before providing cost information we would like to know how you intend to use this 

data to assure that we are providing the proper information. 

4. We do rlot operate periodic kilns 

5. Yes, we have testing ports on our stacks. Our tunnel kilns are subject to emissions 

limits via the Title V and federally enforceable limit to 10 tph. As such we perform 

periodic tests for S02 and particulates. Our current low production rates would be a 

hindrance to any stack tests. Our dryers do not have stacks that would be available 

for any type of testing. 

6. We do not perfotm HAP tests and do not have the necessary testing costs to supply. 

However, the total cost is much more involved than just the actual invoiced test costs. 

Prior to the test day the work load is reviewed to verify that the kiln will be operating 

at or near maximum and that the product mix is typical. The day before the stack test 

the product that will be moving through the kiln during the test is recorded. The day 

of the test significant time is involved to oversee and review the testing. Afterwards 

test results must be developed, reviewed and filed. 

7. I am unaware of any methods acceptable as a replacement for stack testing; however, 

mass balance testing could be a viable option. 

8. Our kilns operate under 10 tph and as such are uncontrolled. As noted below we are 

concemed that being required to install any type of APCD would be detrimental to 

our continued operation. 

9. We believe that there should remain a subcategory for 10 tph. Additionally, an 

investigation into the feasibility of a Health Based Alternative and combining of all 

gaseous HAPs rather than individual limits, as discussed at the SER meeting, is 

warranted. 

1400 South Mahoning Ave. 

Alliance, Ohio 44601 

800 WG PAVER 

P: 330.823.1610 

F: 330.823.5502 

info@wgpaver.com 

www.wgpaver.com 
Permitting/Inspections 

Capital Available/Regulatory Impact 

1. Our kilns are permitted by a Title V in Ohio. If we were requir ed to install an APCD, 

as we are currently uncontrolled, the costs indicated on page 17 of your presentation 

are our best indicator. The annual operating cost would more than double our current 

facility costs. The cost to install an APCD would be more than 20% of our net 

company value. Using our average income over the last five years, and subtracting 

the additional operating cost, it is extremely unlikely that we could ever earn enough 

to recoup this investment. The magnitude of these costs is very large, and potentially 

enough to drive us out of business. 

The cost indicated to install an APCD is for one kiln only. As we certainly could not 

afford to install two devices, we would be forced to permanently shutdown one kiln 

and cap our production. 

However, economics aside, we do not believe that the installation of an APCD on an 

older small kiln is a feasible option due to the technical difficulties involved with the 

original design and functionality of the kiln. 

Feel free to contact me for clarification or any additional inf-ormation. 

Sincerely, 

John E Miller, PE 

Engineering/EHS Manager 

Whitacre Greer Co. 

: mi llei.cr,wgpaver.com 

330-823-1610 x230 

Fax 330-823-6689