THE PAVER PLACE 

WHITACR,E GREER 

_. 1900 May 11, 2010 

Jeff Telander 

US Envirorunental Protection Agency 

Thank you for allowing me the chance to pai-ticipate in the SBREFA/RFA process as a 

representative for Whitacre Greer. I believe there was a lot of information provided 

during our brief ineeting in Washington and I would like to take this opportunity to 

reiterate a few points that I had the chance to express and to acquaint you with our 

company. 

Whitacre Greer manufactures high quality dry pressed clay pavers and low duty firebrick 

for niche markets. Our non automated, older facility allows us to do a large amount of 

customized work for our customers, which is one of the keys to our success in these niche 

markets. We were founded in 1916 and have been owned and operated by the Whitacre 

family since that time. 

Whitacre Greer is located in Alliance, Ohio where we operate two tunnel kilns, each of 

which is under a Federally Enforceable limit of 10 tons/hour, and three dryers. Currently 

only one kiln and two dryers are in operation. Decreased demand for our products has 

resulted in decreased production which has gone from 63,100 tons in 2007 to 44,450 tons 

in 2009. We do not believe 2010 will show any increase from last year. 

Most of our hourly employees live. locally, many of them walking to work or riding bikes 

during good weather. We do not have automatic loaders and unloaders, therefore these 

production fiulctions are performed by employees which results in a highly labor 

intensive operation. All of our 50 hourly employees receive wages above the Ohio and 

Federal minimum, although with our decreased production level they have been on a 35 

hour work week for the past two years. They receive good benefits such as paid holidays, 

vacations, retirement 401 k, and medical. As a labor intensive facility many of our 

employees have only a high school education, many far less. 

We have always tried to operate in an environmentally responsible manner. In fact in 

2009 we were the recipient of the Brick Industry Association Environmental Stewardship 

Award. We received this award for our Reduce-Reuse-Recycle prograi -n and the 

development of our environmentally friendly permeable paver that allows stoi -mwater 

runoff to soak into the ground rather than overflow into ditches and streams. Onc of the 

colors is made entirely of recycled materials. 

As a Title V facility we are inspected periodically by The Ohio Environmental Protection 

Agency (OEPA) and the Mahoning-Trumbull Air Pollution Control Agency (MTAPCA). 

Our last review stated "the facility appears to be in cotnpliance with the Title V permit 

1400 South Mahoning Ave. 

Alliance, Ohio 44601 

800 WG PAVER 

P: 330.823.1610 

F: 330.823.5502 

info@wgpaver.com 

www.wgpaver.com 

.. 
issued June 6, 2001, and all pollution control laws." in fact, we have had no negative 

findings since a paperwork issuc in cai -ly 2002. 

Although we intend to renlain environinentally conscious, we also want to remain in 

business. As a small business we are struggling to stay afloat due to the decreased 

demand for our products. A MACT that would require us to invest in an APCD would be 

a significant econoinic challenge to our company, possibly resulting in our closure and 

the elimination of SO hourly jobs with benefits. In fact, using the information provided in 

the presentation in Washington, the cost of an APCD would be greater than 20% of our 

net worth. Additional economic challenges include trying to obtain a loan of this 

magnitude in today's baiiking climate and purchasing land on which to build the device, 

as our 10 acres of land are fully occupied with our current production facility and 

inventory. As we certainly could not afford to install two devices, we would be forced to 

permanently shutdown one kiln and cap our production. 

Beyond the obvious economic factors, the installation of an APCD would have 

significant impact upon our products, therefore on our ability to successfully maintain our 

niche markets. As was acknowledged in the vacated MACT, brick color is an important 

factor in the consumer's decision to buy one brick over another and it is critical that color 

duplication be achieved on a regular basis. Color is affected by changes in airflow. An 

APCD greatly affects the air flow, certainly more so on a small tunnel kiln due to the 

slower production rates. Addition of an APCD would affect the historic color 

reproduction possibly making duplication impossible. Color is another key factor in the 

success of our niche paver product line. 

Adding an APCD on an older small kiln would also bc impractical. Older kilns are not 

designed to be airtight. The exit end has no door and the entrance to the kiln has a 

loosely fit non insulated sliding door. Sealing the kiln would cause changes in air 

pressure distribution which in turn could cause the mixing of the waste heat and the 

products of combustion (aka emissions). This would not only affect the color and quality 

of the pavers, but is also a health risk due to the fact that the waste heat is used in the 

dryers while the products of combustion are expelled through the stack. Allowing the 

product of combustion to enter the dryers would be putting emissions into an area where 

the kiln operators get the kiln cars and also throughout the plant. 

Often brick manufactures maintain their colors by coating the outside surfaces with an 

artificial coating called an engobe. As a manufacturer of pavers, in order to account for 

years of wear, it is important that the color is consistent throughout the paver. Therefore, 

we can not use an engobe. Our color is achieved by knowing, through years of 

experience, how to adjust the burners for the optimum time, temperature, and airflow. 

Operating too lean or too rich of a mixture will result in a different firing cui -ve resulting 

in a different looking product. 

An APCD clearly would be detrimental to our continued operations, but more 

iinportantly, is unwarranted. EPA should continue to distinguish between small and large 

tunnel kilns. By doing so, EPA will correctly recognize that the smaller kilns are not 
controlled at this time for HAPS and that the coiTect floor for them should not be based 

on an APCD. 

As such, we are requesting that the EPA use the discretion afforded to them in the CAA 

and continue with the sub category 10 tph differentiations between small and large kilns. 

We furthermore feel that it would be appropriate to consider a Health Based Alternative 

approach and the combining of gaseous HAPs as described during the meeting, because 

doing so would ensure that the environment is protected as required by the CAA, but also 

that the manufacturing of brick can continue in the United States. 

Sincerely, 

G• 

John E. Miller 

Engineering/EHS Manger 

jmiller@wgpaver.com 

330-823-1610 x230 

cc: 

cristofaro.alexander@epa.gov 

cortney_higgins@omb. eop. ~ov 

keith.holman@sba.gov 

smiller@bia.org