Date: September 27, 2013

Subject: Minutes of the March 28, 2013 Meeting with Representatives of the Tile 

Manufacturing Industry

NESHAP for Brick and Structural Clay Products Manufacturing and NESHAP for 

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 the tile manufacturing industry was held at the U.S. 

Environmental Protection Agency (EPA) on March 28, 2013. The purpose of the meeting was to

discuss steps for redeveloping national emission standards for hazardous air pollutants 

(NESHAP) for the clay ceramics manufacturing industry in light of the vacatur of the original

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

II. Attendees and Affiliations

Eric S. Astrachan, Tile Council of North America (TCNA)

Howard Gilberg, Guida, 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 Standards (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 standards may be considered in lieu of numerical limits 
2

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 technology (MACT) limits were still claimed as Confidential 

Business Information (CBI), and the EPA representatives and industry representatives discussed 

the process of releasing the companies’ CBI claims on those specific pieces of data. The EPA 

representatives 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 confirmed 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 differences 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 subcategories 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 glazing operations would also be subject to that PM limit, even if those sources do not 

emit metal HAP. Therefore, they asked if EPA would consider setting a total metals limit 

instead of a PM limit. The EPA representatives agreed to investigate the possibility.

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 Dal 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. Need 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 Industry – 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, the industry representatives also requested that EPA allow 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 Method 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.