Email Communication with OAR

From: Jeff Telander

To: William Swietlik

Date: Wednesday, May 21, 2014 11:23 AM

Subject: RE: Brick and Clay follow-up

There are 3 wet scrubbers at 2 different brick facilities (see list below). Both of these facilities 

are synthetic area sources that would not be subject to the BSCP rule.

Company 

Name

Facility 

Name

Emission 

Unit ID

Kiln 

Design 

Capacity

Year 

built

Kiln 

Fuel

Control 

Measure 

Description

Yr 

APCD 

Installed

Class Entity 

Size

Pacific 

Coast 

Building 

Products

Pacific CoastWest Jordan LINE 3 16.33 1977 Natural 

gas

Wet Scrubber 1996

Area 

Source 

(synthetic)

Large 

Entity

Pacific 

Coast 

Building 

Products

Pacific CoastWest Jordan LINE 4 20.79 1982 Natural 

gas

Wet Scrubber 2000

Area 

Source 

(synthetic)

Large 

Entity

Glen Gery

Glen-Gery 

CorporationHanleySID - 113 14.70 2002 Natural 

gas

Wet Scrubber 2003

Area 

Source 

(synthetic)

Large 

Entity

With regard to the Clay Ceramics source category

Sanitaryware has 2 wet scrubbers at major sources, one on a kiln, and one controlling two glaze 

spray booths. Each row represents a different wet scrubber; if multiple kilns or glaze lines are 

listed in the Kiln ID or Glaze ID column, that means they are vented together.

Kiln

Company 

Name

Facility 

Name City State

Kiln 

ID

Production 

rate, ton/hr

APCD 

ID / 

Stack 

ID Fuel

APCD 

Type Class

Kohler Co. Kohler, 

Spartanburg 

Plant

Spartanb

urg

SC 38 -

TK10

0.735 POC, 

RCE (2 

stacks)

Natu

ral 

Gas

Wet 

Scrubber

Major

Glazing

Company 

Name Facility Name City State Glaze ID

APCD 

ID

APCD 

Type Class

Kohler Co. Kohler, Wisconsin 

Plant

Kohler WI P16A-Q04, 

P16B-Q05

S16 Wet 

Scrubber

Major

Ceramic tile has four wet scrubbers controlling kilns at two facilities and five controlling glaze 

lines at two facilities, but since all the floor tile facilities became synthetic area, none of the wet 

scrubbers are at major sources. Each row represents a different wet scrubber; if multiple kilns or 
glaze lines are listed in the Kiln ID or Glaze ID column, that means they are vented together.

Also, green font in the rows for Dal Italia and Florim indicates something that changed when 

they became synthetic area.

Kilns

Company 

Name

Facility 

Name City State

Kiln 

ID

APCD 

ID / 

Stack 

ID Fuel

APCD 

Type Class Subcategory

Dal-Tile 

Corp.

Dal 

Italia

Muskogee OK RK1, 

RK-5

EPN20Natural 

Gas

Wet 

Scrubber

Area 

Source 

(synthetic)

Floor Tile

Dal-Tile 

Corp.

Dal 

Italia

Muskogee OK RK2, 

RK3, 

RK-4

EPN29Natural 

Gas

Wet 

Scrubber

Area 

Source 

(synthetic)

Floor Tile

Mohawk 

Industries

Dal-Tile 

Dallas 

Plant

Dallas TX RK99-1, 

RK99-2

EPN99Natural 

Gas

Wet 

Scrubber

Area 

Source 

(synthetic)

Wall Tile

Mohawk 

Industries

Dal-Tile 

Dallas 

Plant

Dallas TX RK100-

2, 

RK100-3

EPN100Natural 

Gas

Wet 

Scrubber

Area 

Source 

(synthetic)

Wall Tile

Glazing

Company 

Name

Facility 

Name City State Glaze ID

APCD 

ID

APCD 

Type Class

Florim 

Ceramiche 

S.p.A

Florim USA Clarksville TN GL-3, GL4, GL-5CD-2 Wet 

Scrubber

Area Source 

(synthetic)

Florim 

Ceramiche 

S.p.A

Florim USA Clarksville TN GL-6, GL7, GL-8CD-3 Wet 

Scrubber

Area Source 

(synthetic)

Florim 

Ceramiche 

S.p.A

Florim USA Clarksville TN GL-9, GL10, GL-11CD-4 Wet 

Scrubber

Area Source 

(synthetic)

Mohawk 

Industries

Dal-Tile 

Dallas Plant

Dallas TX GL-203, 

GL-204

EPN-20 Wet 

Scrubber

Area Source 

(synthetic)

Mohawk 

Industries

Dal-Tile 

Dallas Plant

Dallas TX GL-301, 

GL-302, 

GL-303, 

GL-306

EPN-43 Wet 

Scrubber

Area Source 

(synthetic)

Please let me know if you need anything else.
From: William Swietlik

To: Jeff Telander

Date: Tuesday, May 20, 2014 11:14 AM

Subject: RE: Brick and Clay follow-up

Jeff:

Got your phone call—to clarify.....

I meant to say in the email below -- Brick and Structural Clay Manufacturing, as that is what I 

was intending to talk about on the phone with you last week, but maybe wasn’t clear.

Since we are going to close out our investigation of this industry as NOT needing wastewater 

discharge standards given there is little likelihood that scrubbers are being installed and 

generating a new water wastestreams (a possibility we were pursuing prior to realizing the 

NESHAPS had been vacated), it would be good for us to have some documentation indicating 

how few of these types of facilities actually do use scrubbers.

Since you said there were less than 10 facilities using scrubbers, primarily for SO2 emissions, I 

thought maybe you could send us an inventory, a listing or something like that that we could 

refer to when making our conclusions that no new water regulation is necessary.

If you were considering only Brick manufacturing when we were talking last week, and not 

Structural Clay manufacturing, does that make any difference?

In your phone message you implied it does not. So documentation showing how few use 

scrubbers for both of these industries would be helpful for us.

_______________________________

William F. Swietlik

US EPA, Office of Water

Engineering and Analysis Division (4303T)

1200 Pennsylvania Ave., NW

Washington, DC 20460

202-566-1129: phone

202-566-1053: Fax

From: William Swietlik

To: Jeff Telander

Date: Wednesday, May 14, 2014 3:49 PM

Subject: Brick and Clay follow-up

Jeff:

Thanks for talking with me today.

In follow-up to our conversation, is there any documentation you can send me on the Brick and 

Clay facilities that do use scrubbers for SO2 control??
Since there are less than 10 such facilities, this most likely means we have no wastewater 

discharge issues with the industry, but to make this conclusion in our annual report, it would be 

good to have supporting documentation.

_______________________________

William F. Swietlik

US EPA, Office of Water

Engineering and Analysis Division (4303T)

1200 Pennsylvania Ave., NW

Washington, DC 20460

202-566-1129: phone

202-566-1053: Fax