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: Jeff rey 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 2 2 , 200 8 . The purpose of the meeting was to discuss steps for redevelop ing national emission standards for hazardous air pollutants (NESHAP) for major sources in the clay ceramics ma nufacturing 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 As trachan, 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 International2 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 disc ussion 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 need s to re develop the sta ndards. Attachment 1 presents the meeting notes which cover t hese major topics. Other related topics that were cove red during the meeting included the following :

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

. ● Kohler’s faciliti es 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 e mission sources at Kohler’s facilities include particulate matter fr om fuel, hy drogen fluoride from one

- fire kilns ( not rework kilns)

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

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

● A c austic wet scrubber has been installed on a new tunn el 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 s cheduling for the NESHAP

. ● K iln chemistry and emission profil es.

● Clay ceramics i ndustry subcategories

. ● I ssues related to a clay ceramics test data request

.

IV. Action Items

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

● S end ing meeting participants a copy of the meeting minutes for the confer ence call

● S end ing meeting participants a copy of the Court decis ion on the original clay ceramics major source NESHAP

● S end ing meeting participants a draft inventory of clay ceramics fa cilities and a summary of clay ceramics emissions data for their review

● S end ing Kohler the documentation of the regulatory approach for the original clay ceramics major source NESHAP

● S end ing EPA a copy of the emission test repor t 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:

### 4 

# 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.

### 5 

# 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; 60 day 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.

### 6 

# 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.”

### 7 

# 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.)

### 8 

# 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

### 9 

# 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.)

### 10 

# 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).

### 11 

# 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.

### 12 

# 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.

### 13 

# 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?