1 Questions for Potential Small Entity Representatives (SERs)

Compliance:

1. Do you use any monitors (e.g. , emissions monitor s or process parameter monitor s ) to ensure that your kilns are operating properly ? If yes, what types of monitors and how many?

No co ntinuous 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? Bypa ss 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 depen ding 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 tes ting? 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 a dded 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 test s 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 emissi on 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 war e 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 an d 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 h as been very

trouble free. The DLA was installed in 2006 at a cost of $1.1 million.2 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 recom mendation. 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 permi tting activities done by in

- house st aff 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

outsid e 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 prepare d 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 t hese costs compared to the cost of kiln operation a nd the facility as a whole?

No

Capital Availability /R egulatory Impact :

1. A re 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. Conside red 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 wr itten 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