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Questions for Potential Small Entity Representatives (SERs)

Compliance:

1. Do you use any monitors (e.g., emissions monitors or process parameter monitors) to ensure 

that your kilns are operating properly? If yes, what types of monitors and how many?

No continuous monitoring of emissions. Record amount of time in bypass and amount of 

limestone used to ensure that gases exposed proper amount of limestone. 

2. Are these monitors in place for environmental regulatory reasons? Insurance reasons? Or both?

Bypass damper position monitored to meet environmental regulatory requirements.

3. What are the costs to the facility of these monitors? What percentage of overall facility costs 

do these represent?

Approximately $3,500 per year. The percentage will vary depending on the operating level 

of the company.

4. If you operate any periodic kilns, do you currently conduct any work or operating practices 

(i.e., other than the use of an air pollution control device) that would have an impact on 

hazardous air pollutant (HAP) emissions from these kilns? If yes, please explain.

NA

5. If your tunnel kilns were subject to emission limits, are there testing ports available for 

conducting compliance tests? If not, what do you estimate the costs to be of modifying the 

stack for testing? Do you foresee any other problems with conducting stack tests on your 

tunnel kilns? If so, please explain.

Our Kilns #2, 3, and 4 have been tested before for HF and HCl and have test ports available. 

Kiln #1 doesn’t have any and if any had to be added the cost would be approximately $4,500. 

The problem with testing at this tine is our low production volumes due to low sales 

volumes. Several of the kilns are not operating and the one that is, is on reduced schedule.

6. What do you estimate the costs to be of conducting stack tests for HAP emissions from your 

tunnel kilns?

Previous compliance testing for Kiln #4 was in 2007 and cost about $15,000 including plant 

labor for set up and monitoring of the test.

7. If your tunnel kilns were subject to emission limits, are there alternatives to monitoring 

emissions or stack testing that would be less costly to demonstrate compliance? If so, please 

explain the alternatives and estimate how much it would cost to conduct them.

Mass balance on green and fired ware has been used in the past to verify the results obtained 

from stack test with reasonable correlation. These cost about $1,000 each.

8. Do you have any kilns that are controlled with a dry limestone adsorber (DLA)? If so, please 

explain the feasibility and estimate the costs of replacing the DLA with a dry injection fabric 

filter (DIFF) or other type of control device that might be more effective in controlling 

emissions of HAP.

We have not pursued this issue as the DLA is operating with out problems and has been very 

trouble free. The DLA was installed in 2006 at a cost of $1.1 million.
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9. Are there any subcategories (e.g., product type, kiln size) that you would recommend for 

your industry? If so, please identify them and document the basis for your recommendation.

I feel that kilns should be subcategorized based on size and/or age and is addressed in a letter 

sent to Bob Perciasepe on May 11, 2010.

Permitting/Inspections:

1. Are your kilns required to be permitted by the state? If so, what is the cost for permitting? If 

not, what would you estimate the burden to be in terms of costs and hours if the kilns are 

required to be permitted? What is the magnitude of these costs compared to the costs of kiln

operation and the facility as a whole? Are your permitting activities done by in-house staff 

or by outside contractors?

As a Title V company, we are permitted by the state of North Carolina. These permits are 

required to be renewed every five years unless changes are made in our operation. We use an 

outside firm to prepare the renewal application. The cost is approximately ten thousand 

dollars. If modifications need to be made during the renewal period, a construction permit 

application must be filed. These run around ten thousand dollars and are prepared by an 

outside consultant.

2. Are your kilns required to be inspected for safety or insurance reasons? If so, how often is 

this performed? What is the cost of these inspections? What is the magnitude of these costs 

compared to the cost of kiln operation and the facility as a whole? 

No

Capital Availability/Regulatory Impact:

1. Are your firm’s expenses for the activities listed above largely paid for out of equity, 

earnings, or debt?

The above activities are paid for with regular operating income.

2. Considered together, how much of your firm’s revenues or budget are the costs of the 

activities listed above in percentage terms?

It depends on the amount of activity required and the operating level of the company.

Please provide EPA’s Jeff Telander with any written feedback no later than close of 

business on May 4, 2010:

Jeff Telander

Telander.Jeff@epa.gov

(919) 541-5427

(919) 541-5450 (fax)

Overnight mail address:

c/o: Jeff Telander

US EPA

Mail Code D243-02

109 TW Alexander Drive

RTP, NC 27709