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 notcontrolled 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