Date: February 25, 2008

Subject: Minutes of the February 22, 2008 Meeting with Representatives of the 

Sanitaryware Manufacturing Industry

Standards Development for Brick, Structural Clay, and Clay Ceramics 

Manufacturing

EPA Contract No. EP-D-06-118; EPA Work Assignment No. 1-28

RTI Project No. 0210426.001.028

From: Thomas Holloway

To: Jeffrey Telander

OAQPS/SPPD/MMG (D243-02)

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

I. Introduction

A conference call with representatives of the sanitaryware manufacturing industry and 

others was held on February 22, 2008. The purpose of the meeting was to discuss steps for

redeveloping national emission standards for hazardous air pollutants (NESHAP) for major 

sources in the clay ceramics manufacturing industry in light of the Court’s vacature of the original

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

II. Attendees

Mike Cassidy et al., Kohler Co.

John King et al., Mansfield Plumbing Products, Inc.

Eric Astrachan, Tile Council of North America (TCNA)

Myra Warne, Ceramic Manufacturers Association (CerMA)

Jeff Telander, U.S. EPA, OAQPS

Steve Fruh, U.S. EPA, OAQPS

Bill Neuffer, U.S. EPA, OAQPS

Thomas Holloway, RTI International

Katie Hanks, RTI International
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III. Discussion

The major topics discussed during the meeting included background on the clay ceramics 

industry; regulatory history of the original clay ceramics major source NESHAP; the need for 

redevelopment of the clay ceramics standards (including a discussion of emission limits and work 

practice standards); inclusion of glaze spray booths in the standards; inventory and emissions data 

gaps; emission controls used in the industry; non-technology factors; and the type of data EPA 

needs to redevelop the standards. Attachment 1 presents the meeting notes which cover these 

major topics. Other related topics that were covered during the meeting included the following:

● Mansfield Plumbing’s Perrysville, OH facility is an area source facility.

● Kohler’s facilities are considered major due to co-location with fiberglass operations.

● Types of kilns used at Kohler’s facilities include tunnel kilns and shuttle (i.e., 

periodic) kilns.

● Kiln emission sources at Kohler’s facilities include particulate matter from fuel, 

hydrogen fluoride from one-fire kilns (not rework kilns).

● All kilns at Kohler’s facilities exclusively use natural gas.

● All glaze spray booths at Kohler’s facilities are equipped with emission controls.

● A caustic wet scrubber has been installed on a new tunnel kiln at Kohler’s 

Spartanburg, SC facility, but no other tunnel kilns at Kohler’s facilities are controlled.

● Court decision on the original clay ceramics major source NESHAP.

● Issues related to scheduling for the NESHAP.

● Kiln chemistry and emission profiles.

● Clay ceramics industry subcategories.

● Issues related to a clay ceramics test data request.

IV. Action Items

At the close of the meeting, the following action items were discussed:

● Sending meeting participants a copy of the meeting minutes for the conference call

● Sending meeting participants a copy of the Court decision on the original clay 

ceramics major source NESHAP

● Sending meeting participants a draft inventory of clay ceramics facilities and a 

summary of clay ceramics emissions data for their review

● Sending Kohler the documentation of the regulatory approach for the original clay 

ceramics major source NESHAP

● Sending EPA a copy of the emission test report for the new kiln at Kohler’s

Spartanburg, SC facility
Clay Ceramics Major Source 

NESHAP

Conference Call with Sanitaryware 

Industry to Discuss Planned Approach 

on Remand

February 22, 2008

Attachment 1
2

Background

 Four industry sectors, two of which include plants that are major HAP 

sources:

 Sanitaryware (e.g., toilets, sinks) – 4 major source plants (major due to co-location)

 Tile (e.g., floor, wall tile) – 5 major source, 2 synthetic minor plants

 Dinnerware – no major source plants identified

 Pottery – no major source plants identified

 Primary emission sources include kilns and spray glazing operations. Little, 

if any, HAP expected to be emitted from other sources. (See Figure 1.)

 HF, HCl, and PM emitted from kilns; PM from spray glazing; PM a surrogate for metals.

 Various types of kilns (e.g., tunnel, roller, periodic) – all but a few uncontrolled.

 Most kilns fired by natural gas or other clean-burning fuel.

 All spray glaze booths controlled (e.g., baghouse, wet scrubber, water curtain).

 Various methods of applying glaze to ware (e.g., spray, dip-coating, curtain-coating); 

only operations that spray the glaze on the ware have emissions.

 Ware fired with and without glazing - kilns firing glazed ware sometimes called “glost” 

kilns, while those firing unglazed ware called “bisque” kilns.

 Kilns firing glazed ceramic ware can have higher metals emissions if the glazes include 

metals (e.g., as colorants and color enhancers).
3

Background, cont’d

Material Handling, 

Screening & Mixing

Glazing Operations

(only spray glazing 

operations have emissions)

Glost Kilns

Bisque Kilns

(optional)

Optional Steps

Spray Dryers

(tile mfg. only)

Figure 1. Emission Sources - Clay Ceramics Manufacturing

Emissions: 
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Regulatory History

 Final major source rule published in Federal Register on May 16, 2003. 

The rule included four subcategories—large tunnel kilns (≥ 10 tph), small tunnel kilns (< 10 tph), roller kilns, and periodic kilns.

 The rule included HF, HCl, and PM emission limits for new large and 

small tunnel kilns and a work practice standard (use of clean-burning fuels) for existing and new tunnel, roller, and periodic kilns.

 The emission limits for new ceramics tunnel kilns were based on what 

was considered the best-controlled similar source—a brick tunnel kiln.

 Large ceramics tunnel kilns: Limits based on level of control that can be achieved by a 

kiln controlled with a DIFF, DLS/FF, or wet scrubber.

 Small ceramics tunnel kilns: Limits based on level of control that can be achieved by a 

kiln controlled with a DLA.
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Regulatory History, cont’d

 Petition for judicial review filed by Sierra Club; Court decision vacating 

Clay Ceramics rule on March 13, 2007; Mandate issued on June 18, 

2007.

 Notice of Intent to Sue filed by Sierra Club/Jim Pew in July 2007; 60day 

notice period has passed, and lawsuit could be filed at any time.

 Working to re-develop MACT floors and standards to reflect principles 

defined in Court decision. Rulemaking will go through re-proposal, 

public comment, and promulgation.
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Standards Re-development

 At promulgation, EPA adopted a work practice standard for existing 

and new kilns requiring the use of clean-burning fuels.

 EPA indicated ceramics kilns use no emission control devices and cannot feasibly 

substitute clays.

 EPA also argued that setting a more precise floor based on the emissions levels 

achieved by using clean-burning fuels was not feasible due to the lack of data needed 

to calculate the MACT floor.

 As a result of the Court decision, EPA plans to establish emission limits 

for existing and new tunnel and roller kilns based on available 

emissions data and plans to examine the feasibility of testing periodic 

kilns. If infeasible, EPA may set work practice standards for periodic 

kilns consistent with the requirements of CAA §112(h), which provides 

that:

 “if it is not feasible in the judgment of the Administrator to prescribe or enforce an 

emission standard..., the Administrator may, in lieu thereof, promulgate a design, 

equipment, work practice, or operational standard.” “Not feasible” means “the 

application of measurement methodology to a particular class of sources is not 

practicable due to technological and economic limitations.”
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Standards Re-development, 

cont’d

 Would like input from industry on whether it is technologically and/or 

economically feasible to test periodic kilns and what types of work 

practice standards would be applicable. It has to be technologically 

and economically infeasible before work practices can be allowed.

 In light of the recently promulgated Clay Ceramics area source rule 

(which included requirements for glaze spray booths), EPA also plans 

to establish emission limits for glaze spray booths. Limits would need 

to account for the wide variety of glazes used in the industry and 

recent changes in glazes and glaze application.

 EPA plans to use an updated Clay Ceramics inventory to develop the 

MACT floors for tunnel and roller kilns and glaze spray booths. 

However, our current inventory update is incomplete (new permits not 

available online for every clay ceramics facility). (See Table 1 for the 

draft updated inventory of major and synthetic minor sources.)
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Standards Re-development, 

cont’d

Table 1. Draft Updated Inventory of Clay Ceramics Facilities

Company/Facility City State Ceramic Type Source Type

Kohler Co. - Spartanburg Plant Spartanburg SC Sanitaryware Major

Kohler Co. - Main and Tank Plant Brownwood TX Sanitaryware Major

Kohler Co. - Wisconsin Pottery Kohler WI Sanitaryware Major

Mansfield Plumbing Products, Inc. Perrysville OH Sanitaryware Major

Dal-Tile Corp. - Conroe Plant Conroe TX Tile Major

Dal-Tile Corp. - Dallas Plant Dallas TX Tile Synth. minor

Dal-Italia LLC - Muskogee Plant Muskogee OK Tile Major

American Marazzi Tile, Inc Sunnyvale TX Tile Major

Monarch Ceramic Tile, Inc. Florence AL Tile Major

Florida Tile - Lawrenceburg Plant Lawrenceburg KY Tile Synth. minor

Florim USA Inc. Clarksville TN Tile Major
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Standards Re-development, 

cont’d

 Would like industry input to complete updates to inventory, such as 

changes in: company/facility, kilns and glaze spray booths, emission 

controls, size, and major source status. (See Table 2 for a summary of 

current emission controls at kilns and glaze spray booths, based on 

draft updated inventory.)

 Inventory of clay ceramics facilities also has emissions data gaps and 

data quality issues. Most of the emissions data are from summaries, 

which cannot be evaluated for data quality; the data quality from full 

test reports ranges from fair to poor.

 Plan to gather more emissions data (for HF, HCl, and PM). Would like 

industry assistance to obtain the latest emission test reports for tunnel 

and roller kilns and glaze spray booths. To address variability, would 

like individual test run data and repeat test reports, if available. (See 

Table 3 regarding the emissions data currently available for kilns and 

glaze spray booths.)
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Standards Re-development, 

cont’d

Table 2. Emission Controls at Kilns and Glaze Spray Booths

Industry Emission Control Kilns

Glaze Spray 

Booths Total

Sanitaryware Baghouse 0 4 4

Wet scrubber 0 20 20

Other control 0 32 32

Unknown 0 0 0

None 39 0 39

Total 39 56 95

Ceramic Tile Baghouse 3 44 47

Wet scrubber 12 57 69

Other control 0 0 0

Unknown 2 4 6

None 22 0 22

Total 39 105 144

Total Baghouse 3 48 51

Wet scrubber 12 77 89

Other control 0 32 32

Unknown 2 4 6

None 61 0 61

Total 78 161 239

"Other controls" include cyclones and baffles (alone or in combination with water curtain).
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Standards Re-development, 

cont’d

Table 3. Availability of Emissions Data for Kilns and Glaze Spray Booths

Emission Kilns

Glaze Spray 

Booths

Industry Control HF data HCl data PM data PM data

Sanitaryware Baghouse 0 0 0 0

Wet scrubber 0 0 0 6

Other control 0 0 0 4

Unknown 0 0 0 0

None 12 0 0 0

Total 12 0 0 10

Ceramic Tile Baghouse 0 0 3 2

Wet scrubber 3 2 3 0

Other control 0 0 0 0

Unknown 0 0 0 0

None 22 1 3 0

Total 25 3 9 2

Total Baghouse 0 0 3 2

Wet scrubber 3 2 3 6

Other control 0 0 0 4

Unknown 0 0 0 0

None 34 1 3 0

Total 37 3 9 12

Most of the emissions data are from summaries, which cannot be evaluated for data quality; the data quality

from full test reports ranged from fair to poor. Also includes emissions test data from title V permit application

review for one facility.
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Non-Technology Factors

 At promulgation, EPA stated it did not have the data to determine 

precisely how much of an effect non-technology factors (e.g., clays with lower HAP content) had on emissions, and, for various reasons, 

believed that changes in raw materials was not a viable MACT floor 

control technology. Consequently, EPA set floors for emission limits 

based only on emission control technology.

 Based on available information, most ceramics kilns already fire with 

natural gas, so EPA was not concerned about the impact of requiring 

the use of clean-burning fuels for all ceramics kilns as a work practice 

standard.

 As a result of the Court decision, EPA plans to examine all relevant 

factors to set MACT floors for emission limits—raw materials, kiln fuel 

type, etc. Would like industry assistance to obtain data on any non- technology factors that could impact emissions.
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EPA Data & Information Needs

 Input to help us complete updates to the Clay Ceramics inventory, such 

as changes in: company/facility (new company name, new facility), 

kilns and glaze spray booths (new sources, shutdowns), emission 

controls, maximum production rate (size), and major source status.

 Assistance obtaining full emission test reports for tunnel kilns, roller 

kilns, and glaze spray booths including individual test run data and any 

available repeat test reports. Requesting emissions data for kilns (HF, 

HCl, and PM) and glaze spray booths (PM).

 Assistance obtaining data on any non-technology factors, such as raw materials (e.g., clay chloride content) and kiln fuel type (e.g., natural 

gas), that could impact emissions.

 Input regarding technical and economic feasibility of testing emission 

sources such as periodic kilns. If testing is infeasible, what types of 

work practice standards would be applicable for such sources?