THE PAVER PLACE 

WHITACRE GRE R 

Q__u-a,lity SiiHe- 19 0 0 

Mr. Jeff Telander 

Telander.Jeff@epa .gov 

Re : Comments for pre-SBREFA panel 

March 26, 2013 

On March 141

h I was in attendance at the pre-SBREFA meeting in Washington regarding the 

Brick MACT. I would like to thank you and your staff for that meeting. I believe it was very 

helpful to hear directly from Keith on where the MACT stands and the current thoughts. 

While the high cost of a traditional MACT was once again brought up, so was what we 

believe to be the more practical and affordable Health Based MACT. The industry model ing 

of the Health Based approach has results which show this is an acceptable, more practical 

way to proceed. We support the Health Based approach. 

I would like to respond to the request for comments, specifically sub-categorization and the 

differences between small and large kilns. I firmly believe that there is a significant 

difference between large and small kilns and that 10 tph is a reasonable breakpoint. You 

were able to use that level for sub-categorization previously and I feel that there is now a 

significant gap at this level and it should continue to be used. 

We have two small kilns in which we produce firebrick and pavers. In the past we have run 

our larger kiln at 8-9 tph. However, due to decline in sales we are currently running at 6.5 

tph . The smaller kiln has not been run in years, but typically ran intermittently at 4-5 tph. 

The total emissions from an older kiln at 6.5 tph, or 4-5 tph should not be handled in the 

same manner as the emissions from a newer kiln at 25-30 tph. 

As outlined below, there are several design and operational differences between small and 

large kilns: 

Firing. Both of our small kilns are fired using high velocity side burners. The burners 

are positioned at the very bottom of the car deck. The high air volume is used to 

churn the air around in the kiln. Even so, the temperature difference between the 

top and bottom is as much as 100 degrees. Larger kilns are top fired with a more 

even temperature distribution. 

Car Size. Our kiln cars are narrow (6' wide) but higher (5' in our larger kiln, but lower 

in the small kiln) than new kiln cars, with a large space (1') down the center to aid 

with air flow. The two separate rows of hacks are done so very loosely in several 

distinct columns, again to help with air flow. Typically the newer, larger kilns are of a 

low and wide design, with the hacks continuing across and down the deck with much 

less airflow between. 

Doors. Our kilns were designed without being completely sealed. The exit end on 

our kilns have no door at all. You can see straight through the kiln, right down the 

1400 South Mahoning Ave . 

Al liance, Ohio 44601 

BOO WG PAVER 

P: 330.823.1 610 

F: 330.823.5502 

info@wgpaver.com 

www. wgpaver.com 
open center, through the glowing fire zone, to the entrance. While the entrance has a 

single door, no vestibule, it is not sealed in any way. It is there strictly to keep the heat 

from blasting out. When a new car is loaded, the single door is opened which changes the 

dynamics of the firing zones. These firing differences are part of the inherent appeal of 

our product. 

Kiln Construction. The walls and ceilings of the smaller older kilns were designed with 

sizeable amounts of refractory bricks in the walls and the arched ceilings. The arched 

ceilings allow for considerable open spaces above the kiln cars, something not found in 

the large kilns. Large kilns are typically designed with a lighter fiber lined ceiling. 

The design and operational differences of the small kilns is what makes our product and colors 

unique. The addition of APCD to our kilns, along with being financially insupportable, would 

require a kiln redesign which would not allow for the same product to be duplicated. 

We continue to urge you to use the discretion afforded you and evaluate fully the Health Based 

approach along with sub-categorization at 10 tph . This approach fulfills the requirements of the 

Clean Air Act while not putting a financial burden on the entire industry. 

Sincerely, 

John E Miller, PE 

Engr/EHS Manager 

Whitacre Greer Co.