Date: September 27, 2013

Subject : Minutes of the March 28 , 20 13 Meeting with Representatives of the Tile Manufacturing Industry

NESHAP f or Brick a nd Structural Clay Products Manufacturing a nd NESHAP f or Clay Ceramics Manufacturing

EPA Contract No. EP

- D

- 11

- 084 ; EPA Work Assignment No. 1

- 04 RTI Project No. 0213199.001.004

From : Kristin Sroka

To: Jeff Telander OAQPS/ SPPD/ MMG (D243

- 02) U.S. Environmental Protection Agency Research Triangle Park, NC 27711

I. Introduction

A meeting with representatives of t he tile manufacturing industry was held at the U.S. Environmental Protection Agency (EPA) on March 2 8 , 20 13 . The purpose of the meeting was to discuss steps for redevelop ing national emission standards for hazardous air pollutants (NESHAP) for the clay ce ramics manufacturing industry in light of the vacatur of the original

NESHAP. This memorandum summarizes the major topics discussed during the meeting

.

II. Attendees and Affiliation s

Eric S. Astrachan, Tile Council of North America (TCNA) Howard Gilberg, G uida, Slavich & Flores, PC (representing TCNA) Bob Hurt, Dal

- Tile Corp. Connie O’Neal, Florim USA Tim Swaw, Florim USA

Steven Wiederwax, American Marazzi Tile (AMT )/Monarch Ceramic Tile (MCT)

Jeff Telander, U.S. EPA, Office of Air Quality Planning and Sta ndards ( OAQPS ) Keith Barnett, U.S. EPA, OAQPS

Mariel Morales

, U.S. EPA, OAQPS

Kristin Sroka , RTI International

III. Discussion

The EPA representatives explained the process of developing MACT floors for each pollutant , as well as when work practice standar ds may be considered in lieu of numerical limits2 and in what ways a risk analysis may be used in the standard

- setting process

. The EPA representatives also acknowledged that some of the test production data used to develop the

maximum achievable control t echnology (MACT) limits were still claimed as Confidential Business Information (CBI) , and the EPA representatives and industry representatives discussed the process of releas ing the companies’ CBI claims on those specific pieces of data. The EPA

represen tatives stated that as soon as all of the production data are released as non

- confidential, they would send the industry representatives a copy of the test data summary file used to develop

the MACT limits.

The industry representatives noted that some of the test data in EPA’s data set should be removed based on the review of a test contractor. The specific details of why these tests should be removed are provided in a separate document

. 1 In addition, the representatives from Florim USA provided a letter documenting an inconsistency in the production rate during one run of one

of their tests. 2 The EPA representatives agreed to review these requests and revise the data set (if needed) based on the results of their review.

The EPA representatives confirme d that sanitaryware and ceramic tile will be treated separately in the NESHAP. The industry representatives also suggested that within ceramic tile, EPA should consider subcategories for wall tile and floor tile because there are design and operational di fferences in the processes to make these two different types of products. They agreed to provide written documentation of these differences for EPA to review. The industry representatives also asked EPA to consider separate subcategori es of dioxin/furan limits based on

the use of ball clay as a raw material and to consider setting a dioxin/furan limit for an entire facility.

The industry representatives then addressed metal hazardous air pollutants (HAP) from glazing operations. They stated that at some facilities, glazing operations, dryers, and other sources of emissions may be routed to a single stack, and they expressed concern that if EPA sets a PM limit as a surrogate for metal HAP from glazing operations , any sources routed to the same stack as gl azing operations would also be subject to that PM limit, even if those sources do not

emit metal HAP. Therefore, t hey asked if EPA would consider setting a total metals limit instead of a PM limit. The EPA representatives agreed to investigate the possib ility

.

The industry representatives requested that the EPA consider an alternate emission limit during periods of startup and shutdown for tile manufacturing roller kilns , for up to 4 percent of annual production. This request was based on a test that Da l Italia conducted during a period when their control device was not operating ; the results of that test were provided in Dal Italia’s response to the information collection request (ICR).

1 Hartman, M.W

. CONFIDENTIAL

– Updated Test Reports . Memorandum to Howard Gilberg dated March 25,

2013. N eed to ask Howard to provide copy without confidential markings or ask for his permission to remove them

ourselves.

2 Swaw, T. Major Source MACT: Ceramic Tile In dustry

– Request for Exclusion of Florim May 2010 Kiln HF and

HCl Data . Letter to Jeff Telander, U.S. Environmental Protection Agency, dated March 2/, 2013.3 Finally, t he industry representatives also requested that EPA allo w testing of acid gases to be conducted using either EPA Method 320 or EPA Method 26A. The representatives from Florim USA noted that that state of Tennessee does not recognize results conducted using EPA Method 320 and instead requires the use of EPA Met hod 26A. They stated that if the clay ceramics NESHAP specifies that EPA Method 320 must be used, they will have to test twice for the same pollutants. The EPA representatives agreed to ask their testing experts to review the

request.