Date: September 24, 2015

To: Sharon Nizich, EPA/OAQPS/SPPD

From: Gabrielle Raymond, RTI International

Subject: Test Data Used in Clay Ceramics Manufacturing Final Rule

I. Introduction

In accordance with section 112 of the Clean Air Act (CAA), the U.S. Environmental 

Protection Agency (EPA) established national emission standards for hazardous air pollutants 

(NESHAP) on May 16, 2003 for the clay ceramics manufacturing industry, specifically the 

sanitaryware and ceramic tile industry sectors. Sanitaryware includes plumbing and bathroom 

fixtures such as toilets and sinks. Ceramic tile is used to cover floors and walls. The NESHAP 

regulated emissions of hydrogen fluoride (HF), hydrogen chloride (HCl), and particulate matter 

(PM)—a surrogate for HAP metals—from new and reconstructed kilns located at clay ceramics 

facilities. On March 13, 2007, the D.C. Circuit Court vacated the emission standards for clay 

ceramics manufacturing due to issues associated with the methodology used to determine the 

minimum regulatory “floors” for new and existing units.1 Therefore, on December 18, 2014, the 

EPA proposed new standards for clay ceramics manufacturing, including standards for HF, HCl, 

mercury (Hg), non-Hg HAP metals (specifically, the PM surrogate), and dioxins/furans. The 

EPA provided a 90-day public comment period following proposal of the BSCP Manufacturing 

NESHAP, during which all affected parties were given the opportunity to comment on the 

proposed rule. The EPA has considered the comments received and, as appropriate, incorporated 

them into the final rule.

The list of affected sources to be regulated has been expanded to include new and 

existing kilns, spray dryers (ceramic tile only), press dryers (floor tile only), and spray glaze 

operations (sanitaryware and floor tile only). The facilities currently subject to the proposed 

NESHAP include three sanitaryware facilities. The ceramic tile facilities (including floor tile

and wall tile facilities) have taken the necessary steps to become synthetic area sources (i.e., have 

obtained a federally enforceable limit reducing emissions below major source thresholds) and 

would not be subject to the major source clay ceramics NESHAP. The purpose of this 

memorandum is to describe the sources of test data obtained and considered in the clay ceramics

 1 Sierra Club v. EPA, 479 F.3d 875 (D.C. Cir. 2007).
2

rulemaking and describe the quality assurance/quality control (QA/QC) checks performed on the 

data.

II. Sources of Data

The main sources of test data were responses to the 2008 and 2010 section 114 surveys to 

the clay ceramics industry (described in the remainder of this section) and the clay ceramics 

Legacy Docket A-2000-48. Copies of all the test reports collected from these sources are

included in Docket ID No. EPA-HQ-OAR-2013-0290.

The EPA conducted two surveys under the authority of section 114 of the CAA. In June 

2008, the EPA sent out a survey to six clay ceramics companies, including sanitaryware 

company Kohler Co. and seven ceramic tile companies: Dal-Tile Corp. (including Dal Italia, a 

joint venture between Dal-Tile and Italy-based tile maker EmilCeramica), Florida Tile 

Industries, Inc., Florim USA, Interceramic, Marazzi Tile, Inc., StonePeak Ceramics (Tsirigotis, 

2008a-c), and Monarch Ceramic Tile, Inc. (letter sent in May 2009; Tsirigotis, 2009). The 

survey was designed in the form of a Microsoft Excel® spreadsheet file that included seven 

different worksheets to complete. The main intention of the survey was to collect inventory 

information about the kilns and glaze lines at those companies. Although the 2008 survey did 

not require any new testing to be performed, the “Form D - Test Data” worksheet in the survey 

asked for information on emission tests previously performed on kilns at the facilities and asked 

each facility to submit complete copies of the reports for these emission tests. The test reports 

received contained results for HF, HCl, Cl2, and filterable PM.

In 2010, the EPA sent out another section 114 survey to five clay ceramics companies, 

including sanitaryware company Kohler Co. and four ceramic tile companies: Dal-Tile Corp.

(including Dal Italia), Florim USA, Marazzi Tile, Inc., and Monarch Ceramic Tile, Inc.

(Tsirigotis, 2010a-e). The survey required clay ceramics facilities to conduct stack tests of their 

kilns, dryers, and spray glaze operations.

The sanitaryware facilities were required2 to measure emissions of the following 

pollutants from their emission sources:

• HF, HCl, PM filterable, HAP metals (including Hg), PM2.5 filterable, PM2.5 condensable, 

and dioxin/furan from tunnel kilns;

• Dioxin/furan from ware dryers; and

• PM filterable, HAP metals (including Hg), and PM2.5 filterable, from glaze spray booths.

 2 After the survey letters were mailed out to the facilities, an agreement was reached between the sanitaryware 

industry and the EPA that removed the testing requirements of PM2.5 filterable and PM2.5 condensable from tunnel 

kiln testing and removed the testing requirements of PM2.5 filterable and HAP metals, including Hg, from glaze 

spray booth testing (Telander, 2010). 
3

The ceramic tile facilities3 were required to measure emissions of the following 

pollutants from their emission sources:

• HF, HCl, PM filterable, HAP metals (including Hg), PM2.5 filterable, PM2.5 condensable, 

and dioxin/furan from roller kilns;

• Dioxin/furan from spray dryers and press dryers; and

• PM filterable, HAP metals (including Hg), and PM2.5 filterable from glaze lines that 

spray apply the glaze.

During the public comment period, the Tile Council of North America (TCNA) (EPAHQ-OAR-2013-0290-0246) identified a production rate transcription error in the master run-byrun spreadsheet for the May 2010 stack test performed on Roller Kiln ID 77 (RK-2L) at Monarch 

Ceramic Tile’s ceramic floor tile facility in Florence, AL. The EPA has corrected this value and 

recalculated emissions for that source as such. 

III. Data Compiled and Calculations Conducted from Test Reports

From each test report, the following parameters and emissions data for each test run were 

compiled into a master run-by-run spreadsheet:

• Production rate, in tons per hour (tph)

• Flow rate, in actual cubic feet per minute (acfm)

• Flow rate, in dry standard cubic feet per minute (dscfm)

• Sample volume, in dry standard cubic feet (dscf)

• Sample volume, in dry standard cubic meter (dscm)

• Stack moisture, in percent (%)

• Stack gas temperature, in degrees Fahrenheit ( ̊F)

• Oxygen content of stack gas, in percent (%)

• Pollutant concentration, in parts per million (ppm), milligrams per dry standard cubic 

meter (mg/dscm), grains per dry standard cubic foot (gr/dscf), etc.

• Pollutant emission rate, in kilograms per hour (kg/hr), pounds per hour (lb/hr), etc.

Once the data were compiled, the following calculations were conducted in the master 

run-by-run spreadsheet:

• Converted reported concentrations to micrograms per dry standard cubic meter (μg/dscm)

• Calculated emissions in nanograms per kilogram (ng/kg) using emission rate (kg/hr) and 

converted production rate (tph) to kg/hr

• Calculated emissions in pounds per ton (lb/ton) using emission rate (lb/hr) and production 

rate (tph)

 3 After the survey letters were mailed out to the facilities, an agreement was reached between the ceramic tile 

industry and the EPA that removed the testing requirements of PM2.5 filterable and PM2.5 condensable from roller 

kiln testing; and removed the testing requirements of PM2.5 filterable from glaze line testing (Gilberg, 2010).
4

During the public comment period, several commenters suggested a mass-based 

production-related standard for the dioxin/furan emission limits for ceramic tile manufacturing 

and sanitaryware manufacturing rather than the proposed concentration format. As such, the 

dioxin/furan limits provided in the final rule for clay ceramics are in units of ng TEQ/kg of 

throughput fired or processed.

IV. Quality Assurance/Quality Control Checks

After the test data had been compiled and calculated in the master run-by-run 

spreadsheet, there were two rounds of QA/QC with the ceramic tile industry association (Tile 

Council of North America [TCNA]), test report comments from Kohler Co., and internal QA/QC 

from RTI and EPA. Test data determined to be unacceptable after the QA/QC checks were 

removed from the run-by-run spreadsheet and were not included in the calculation of MACT 

floors. See Appendix A for the list of test data that were removed from the run-by-run 

spreadsheet after the QA/QC checks. See Appendix B for the run-by-run test data that were used 

in the calculation of MACT floors.

A. Industry QA/QC

The TCNA conducted two reviews on the test data, one in November 2012 (Gilberg, 

2012) and one in March 2013 (Hartman, 2013). The TCNA review indicated the following 

problems with some of the test data:

• Glass fiber filter used

• No record of filter temperature measurements

• Low probe and filter temperatures

• Lowest Method 26A calibration standard higher than the results

• Detection limit not specified

• Plant had been demolished

The reviews from TCNA were examined with the corresponding test data, and revisions 

were made to the test data. For acid gas tests where a glass fiber filter was used, the results were 

removed from the test data set. For acid gas tests where the probe and filter temperature were 

not maintained at the proper temperature per the test method instructions, the results were 

removed from the test data set. Test results where the Method 26A calibration standard was 

higher than the results were removed from the test data set. In the three above cases, the PM 

data were retained, as errors in the acid gas testing methodology did not affect the PM results. In 

cases where the detection limits were not specified, the results for that pollutant were removed

from the test data set. All test data from kilns identified as being demolished and/or 

decommissioned were removed.

Florim USA also identified a problem with their HF and HCl results during 2010 testing 

due to production and equipment problems (Florim, 2013). After reviewing the information 

provided, the HF and HCl data for RK-1 were removed from the test data set.
5

Kohler Co. also identified within their test report for the Spartanburg, SC plant that there 

was a mix up during the sample preparation phase and filters and front-half rinses were

mismatched in the digestion vessel prior to analysis for the HAP metals TK#10 POC and RCE 

stacks (ARI, 2010). As such, these data were flagged as compromised and do not represent the 

concentrations and emission rates that correspond to the affected sources for these specific 

sample runs. The HAP metals data for TK#10 POC and RCE stacks were removed from the test 

data set.

B. Internal QA/QC

1. Mercury and Non-Mercury HAP Metals

In the internal QA/QC of the test data, inconsistencies were found between the Hg and 

individual non-Hg HAP metal values reported in the summary pages of certain test reports and 

the values reported in the laboratory sections of the test reports. Therefore, the Hg and non-Hg 

HAP metal values were reviewed for correctness, starting from the laboratory results. 

Specifically, the laboratory reports were reviewed to extract and compile the mass values for five 

Hg fractions and two non-Hg HAP metal fractions (see list below), the blank fractions, and the 

method detection limits (MDLs), or other reporting limit if MDLs were not available.

• Front Half (Hg & non-Hg HAP metal), Fraction 1: Container 1 Filter, Container 2 

Acetone Probe Rinse, Container 3 Acid Probe Rinse

• Back Half (Hg & non-Hg HAP metal), Fraction 2B: Container 4 HNO3/H2O2 (Nitric 

Acid/ Hydrogen Peroxide) Impingers

• Back Half (Hg Only), Fraction 3A: Container 5A HNO3

• Back Half (Hg Only), Fraction 3B: Container 5B KMnO4/H2SO4 (Potassium 

Permanganate/Sulfuric Acid) Absorbing Solution

• Back Half (Hg Only), Fraction 3C: Container 5C HCl Rinse and Dilution

The Hg and other HAP metal values were recalculated from the laboratory data and blank 

corrected when necessary in accordance with EPA Method 29 guidelines. These are the values 

included in Appendix B for Hg and non-Hg HAP metals data.

2. Manganese Contamination

The 2010 section 114 survey test request included kiln and glaze spray booth Hg testing 

concurrent with non-Hg HAP metal testing using EPA Method 29. There is a possibility of the 

back half fraction (Fraction 2B) for manganese (Mn) being contaminated from the permanganate 

used in Fraction 3B for Hg sampling. To check for Mn contamination, the ratio of the back half 

Mn mass to the front half Mn mass was calculated. If the ratio was over 5, that test run was 

assumed to have Mn contamination. The test runs with Mn contamination were removed from 

the data set. If it was determined that only one test run from a particular test for a source was not 

contaminated, the entire test was removed. The following table indicates the test runs that were 

removed from the kiln and glaze spray booth data sets due to Mn contamination.
6

Table 1. Kiln and Glaze Spray Booth Test Runs Removed Due to Mn Contamination

RTI 

Inventory 

- Kiln No. Test Date

Run 

No.

Facility 

Name City State Kiln ID

Source 

Type

41 5/25/2010 2, 3 a Florim USA Clarksville TN RK-1 Roller 

Kiln

60, 61, 62 5/13-

15/2010 b Dal Italia Muskogee OK RK-2, RK-3, RK-4 Roller Kiln

77 5/4-5/10 1, 2 a Monarch Florence AL RK-2L Roller 

Kiln

36 12/6-7/2010 2 Marazzi Sunnyvale TX RK-4 Roller 

Kiln

64, 65, 68, 

69

12/13-

14/2010 1 Dal-Tile El Paso TX RK-1, RK-2, RK5, RK-6 Bisque

Roller 

Kiln

70, 71, 74, 

75

12/15-

16/2010 2 Dal-Tile El Paso TX RK-7, RK-8, RK11, RK-12 Glost 

Roller 

Kiln

114; 116; 

117; 119

5/13-

15/2010 1, 2 a Dal Italia Muskogee OK GL 7 - 10 Glaze 

Line

71 5/26/2010 2 Florim USA Clarksville TN GL-1 Glaze 

Line

19 & 20 8/23-

24/2010 2 Kohler Co. Brownwood TX TK #6/12 POC stack

Tunnel 

Kiln

7 8/12-

13/2010 2 Kohler Co. Spartanburg SC TK #8 POC stack Tunnel 

Kiln

a Entire test was removed because only one test run from this test was not contaminated.

b Entire test was removed because all test runs contaminated.

3. PM Correction for Test Runs Below 1 mg

As part of the clay ceramics test data review, the mass (mg) collected for each PM test 

run was evaluated. In the EPA memorandum, Data and procedure for handling below detection 

level data in analyzing various pollutant emissions databases for MACT and RTR emissions 

limits, 1 mg is given as the Representative Detection Level (RDL) for PM (Westlin and Merrill,

2011). For test runs with less than 1 mg collected, the 1 mg RDL value was used to calculate the 

concentration, emission rate, and emission factor for that run. In these cases, the emission factor 

was calculated as follows:

hr

ton product

453.59237 mg

1lb

1hr

60 min

min

dscf

dscf

0.02831685dscm

dscm

1mg

ton product

lb 















× × × ×

=
7

4. PM Evaluation for Probe and Filter Temperatures

The EPA examined the PM test data and found that a number of the EPA Method 5 test 

runs had probe or filter temperatures outside of the range of acceptable values. EPA Method 5 

specifies that the temperature should be maintained at 248 ± 25 degrees Fahrenheit (°F) (i.e., 

between 223 and 273 °F). Test runs with temperatures outside that range were removed from the 

data set, see Appendix A.

5. Dioxins/Furans

To calculate emissions of total dioxins/furans, the mass values for each of the homologue 

group totals reported in the laboratory analysis of the test report were summed. The homologue 

groups are shown in Table 2.

 Table 2. Dioxin/Furan Homologue Group Totals

Homologue Group Totals Short Hand

Total Tetrachlorodibenzo-p-dioxins Total TCDD

Total Pentachlorodibenzo-p-dioxin Total PeCDD

Total Hexachlorodibenzo-p-dioxins Total HxCDD

Total Heptachlorodibenzo-p-dioxins Total HpCDD

Total Octachlorodibenzo-p-dioxin Total OCDD

Total Tetrachlorodibenzofurans Total TCDF

Total Pentachlorodibenzofurans Total PeCDF

Total Hexachlorodibenzofurans Total HxCDF

Total Heptachlorodibenzofurans Total HpCDF

Total Octachlorodibenzofuran Total OCDF

Next, 17 specific dioxin/furan congeners were considered separately from the homologue 

group totals. The 17 specific dioxin/furan congener mass values reported in the laboratory 

analysis of the test report were converted to 2,3,7,8-TCDD toxic equivalency (TEQ) values for 

each test run using the 2005 World Health Organization (WHO) toxicity equivalence factors 

(TEF) (EPA, 2010) in Table 3. The 17 converted TEQ values were then summed to calculate a 

total TEQ value for each run. Appendix C contains a sample calculation showing how the total 

dioxin/furan and total TEQ values were calculated from the reported laboratory masses to the 

final run by run values presented in Appendix B.
8

Table 3. Dioxin/Furan Toxicity Equivalence Factors

Dioxin/furan congener Short Hand

Toxicity equivalence 

factor

2,3,7,8-tetrachlorodibenzo-p-dioxin 2,3,7,8-TCDD 1

1,2,3,7,8-pentachlorodibenzo-p-dioxin 1,2,3,7,8-PeCDD 1

1,2,3,4,7,8-hexachlorodibenzo-p-dioxin 1,2,3,4,7,8-HxCDD 0.1

1,2,3,7,8,9-hexachlorodibenzo-p-dioxin 1,2,3,6,7,8-HxCDD 0.1

1,2,3,6,7,8-hexachlorodibenzo-p-dioxin 1,2,3,7,8,9-HxCDD 0.1

1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin 1,2,3,4,6,7,8-HpCDD 0.01

Octachlorodibenzo-p-dioxin OCDD 0.0003

2,3,7,8-tetrachlorodibenzofuran 2,3,7,8-TCDF 0.1

1,2,3,7,8-pentachlorodibenzofuran 1,2,3,7,8-PeCDF 0.03

2,3,4,7,8-pentachlorodibenzofuran 2,3,4,7,8-PeCDF 0.3

1,2,3,4,7,8-hexachlorodibenzofuran 1,2,3,4,7,8-HxCDF 0.1

1,2,3,6,7,8-hexachlorodibenzofuran 1,2,3,6,7,8-HxCDF 0.1

2,3,4,6,7,8-hexachlorodibenzofuran 2,3,4,6,7,8-HxCDF 0.1

1,2,3,7,8,9-hexachlorodibenzofuran 1,2,3,7,8,9-HxCDF 0.1

1,2,3,4,6,7,8-heptachlorodibenzofuran 1,2,3,4,6,7,8-HpCDF 0.01

1,2,3,4,7,8,9-heptachlorodibenzofuran 1,2,3,4,7,8,9-HpCDF 0.01

Octachlorodibenzofuran OCDF 0.0003

6. Non-Detects

As mentioned in Section IV.B.1, Hg and non-Hg HAP metal test runs are comprised of 

individual fractions. For any test run fraction that had values flagged as being below detection 

limit (BDL), the MDL, or other reporting limit if an MDL was not available, was used as the 

mass for that fraction. The concentration, emission rate, and emission factor for the run were 

then calculated using the sum of the fractions for each test run.

If all fractions for a run were flagged as BDL, then the run was considered BDL. If there 

was a mix of fractions flagged as BDL and above detection limit (ADL), then the run was 

considered detection level limited (DLL). If all fractions for a run were flagged as ADL, then 

the run was considered ADL.

Similarly for dioxin/furan testing there are multiple congeners for each TEQ run. The 

run was flagged as BDL if all of the congener masses were below the MDL; DLL if one or more 

congeners were below the MDL; and ADL if all the congeners were above the MDL. For each 

fraction/congener mass that is below the MDL, the MDL mass was used for the 

fraction/congener mass and subsequent emissions calculations. For more information on how 

these data were treated for purposes of calculating MACT floors, see the 

memorandum Maximum Achievable Control Technology (MACT) Floor Analysis for Clay 

Ceramics (Raymond and Sroka, 2014).
9

7. Source Configurations

In some cases, multiple sources are ducted to the outlet stack being tested. For most 

emission types, each source operating during the time of testing was assumed to have the same 

concentration and emission factor value. Their emission rate values were calculated as a 

proportion of the outlet stack value, based on a ratio of production rates. If any of the sources 

were not operating during the test, the emission values do not apply to those sources.

For tile glaze lines and wall tile roller kilns, all of the units ducted to an outlet stack were 

considered one source (Raymond 2014).

In other cases, a single source (e.g., a kiln or dryer) that is being tested is ducted to 

multiple stacks. The emissions from each stack are summed together to get one value for the 

source.

V. References

ARI (ARI Environmental, Inc.). 2010. Emissions Test Program: Clay MACT ICR Data 

Gathering – Kohler Company Vitreous Plant, Spartanburg, South Carolina. Prepared for 

Kohler Company, Attention: Michael J. Cassidy, EHS Specialist. Test Dates: August 10-17, 

2010. Docket Item No. EPA-HQ-OAR-2013-0290-0069.

EPA (U.S. Environmental Protection Agency). 2010. Recommended Toxicity Equivalence 

Factors (TEFs) for Human Health Risk Assessments of 2,3,7,8-Tetrachlorodibenzo-p-dioxin 

and Dioxin-Like Compounds. Publication No. EPA/100/R–10/005. December 2010. Docket 

Item No. EPA-HQ-OAR-2013-0290-0169.

Florim. 2013. Major Source MACT: Ceramic Tile Industry – Request for Exclusion Florim USA

May 2010 Kiln HF and HCl Data. Letter from Connie O’Neal, Florim USA, to Sharon 

Nizich, EPA/OAQPS/SPPD. August 1, 2013. Docket Item No. EPA-HQ-OAR-2013-0290-

0127.

Gilberg, H. 2010. “Tile Industry ICR's.” E-mail from Howard L. Gilberg, Guida, Slavich & 

Flores, to Jeff Telander, U.S. Environmental Protection Agency. April 23, 2010. Docket 

Item No. EPA-HQ-OAR-2013-0290-0117.

Gilberg, H. 2012. Challenge to Potential Use or Reliance on Selected HF and HCl Data. 

Confidential Memorandum from Howard Gilberg, Guida, Slavich & Flores, to Jeff Telander, 

EPA/OAQPS/SPPD, November 13, 2012.

Hartman, M. 2013. Memorandum: CONFIDENTIAL - Updated Test Reports. Confidential 

Memorandum from Michael Hartman, Air-Tech Environmental, LLC, to Howard Gilberg, 

Guida, Slavich & Flores. March 25, 2013.

Raymond, G. 2014. Updated Inventory Database and Documentation for CC Proposed Rule. 

Memorandum from Gabrielle Raymond, RTI International to Jeff Telander, 

EPA/OAQPS/SPPD. November 6, 2014. Docket Item No. EPA-HQ-OAR-2013-0290-0220.
10

Raymond, G., and K. Sroka. 2015. Final Maximum Achievable Control Technology (MACT) 

Floor Analysis for Clay Ceramics. Memorandum from Gabrielle Raymond and Kristin 

Sroka, RTI International, to Sharon Nizich, EPA/OAQPS/SPPD. September 24, 2015.

Telander, J. 2010. “Re: 114 letter and enclosures.” E-mail from Jeff Telander, U.S. 

Environmental Protection Agency, to Mike Cassidy, Kohler Co. May 4, 2010. Docket Item 

No. EPA-HQ-OAR-2013-0290-0167.

Tsirigotis, P. 2008a. “Section 114 information collection request to selected clay ceramics

facilities.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection 

Agency, to Robert Hurt, Dal-Tile Corp., transmitting section 114 information collection 

request asking for information on brick and structural clay products processes, emissions, and 

controls. Identical letters sent to other addressees listed (Florida Tile Industries, Inc., Florim 

USA, Interceramic, Marazzi Tile, Inc., and StonePeak Ceramics). June 23, 2008. Docket 

Item No. EPA-HQ-OAR-2013-0290-0009.

Tsirigotis, P. 2008b. “Section 114 information collection request to selected clay ceramics

facilities.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection 

Agency, to Robert Hurt, Dal Italia LLC, transmitting section 114 information collection 

request asking for information on brick and structural clay products processes, emissions, and 

controls. July 7, 2008. Docket Item No. EPA-HQ-OAR-2013-0290-0008.

Tsirigotis, P. 2008c. “Section 114 information collection request to selected clay ceramics

facilities.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection 

Agency, to Michael Cassidy, Kohler Co., transmitting section 114 information collection 

request asking for information on brick and structural clay products processes, emissions, and 

controls. July 10, 2008. Docket Item No. EPA-HQ-OAR-2013-0290-0013.

Tsirigotis, P. 2009. “Section 114 information collection request to selected clay ceramics

facilities.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection 

Agency, to Gianni Mattioli, Monarch Ceramic Tile, Inc., transmitting section 114 

information collection request asking for information on brick and structural clay products 

processes, emissions, and controls. May 19, 2009. Docket Item No. EPA-HQ-OAR-2013-

0290-0015.

Tsirigotis, P. 2010a. “Section 114 information collection request to Dal-Tile Corp.” Letter and 

attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Robert Hurt, 

Dal-Tile Corp., transmitting section 114 information collection request asking for 

information on startup and shutdown events and emission data for specified emission points. 

March 9, 2010. Docket Item No. EPA-HQ-OAR-2013-0290-0023.

Tsirigotis, P. 2010b. “Section 114 information collection request to Florim USA.” Letter and 

attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Connie O'Neal, 

Florim USA, transmitting section 114 information collection request asking for information 

on startup and shutdown events and emission data for specified emission points. March 9, 

2010. Docket Item No. EPA-HQ-OAR-2013-0290-0024.
11

Tsirigotis, P. 2010c. “Section 114 information collection request to Kohler Co.” Letter and 

attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Michael 

Cassidy, Kohler Co., transmitting section 114 information collection request asking for

information on startup and shutdown events and emission data for specified emission points. 

March 9, 2010. Docket Item No. EPA-HQ-OAR-2013-0290-0025.

Tsirigotis, P. 2010d. “Section 114 information collection request to Marazzi Tile, Inc.” Letter 

and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, to Steven 

Wiederwax, Marazzi Tile, Inc., transmitting section 114 information collection request 

asking for information on startup and shutdown events and emission data for specified 

emission points. March 9, 2010. Docket Item No. EPA-HQ-OAR-2013-0290-0026.

Tsirigotis, P. 2010e. “Section 114 information collection request to Monarch Ceramic Tile, 

Inc.” Letter and attachments from Peter Tsirigotis, U.S. Environmental Protection Agency, 

to Gianni Mattioli, Monarch Ceramic Tile, Inc., transmitting section 114 information 

collection request asking for information on startup and shutdown events and emission data 

for specified emission points. March 9, 2010. Docket Item No. EPA-HQ-OAR-2013-0290-

0027.

Westlin, P. and Merrill, R. 2011. Data and procedure for handling below detection level data in 

analyzing various pollutant emissions databases for MACT and RTR emissions limits. 

Memorandum from Peter Westlin, SPPD/MPG and Raymond Merrill, AQAD/MTG, to 

SPPD management and MACT rule writers. December 13, 2011. Docket Item No. EPAHQ-OAR-2013-0290-0212.
Appendix A

Test Data Not Used
A-1

Table A-1 Test Data Removed from Database after QA/QC, Not Used in MACT Floor Analyses
2

Facility ID Facility City State Test Date Unit Type Source RTI ID Source ID Explanation Why Data Excluded 

MARR-1

Marazzi, 

Sunnyvale 

Facility

Sunnyvale TX 4/14/2005 Roller Kiln 2008 

Survey 33 RK-1 Acid Gas Ceramic run -- since only one run for this type of product

MARR-1

Marazzi, 

Sunnyvale 

Facility

Sunnyvale TX 12/6-7/2010 Roller Kiln 2010 

Survey 36 RK-4 Removed Non-Hg HAP Metal Run 2 results due to Mn contamination

2100500008 Florida Tile 

Inc. Lawrenceburg KY 11/12/1996 Roller Kiln

Legacy 

Docket

A-2000-

48

38 RK-2 Acid Gas results removed per further review from 

industry and EPA due to glass fiber filter used

2100500008 Florida Tile 

Inc. Lawrenceburg KY 1/15-16/2008 Roller Kiln 2008 Survey 40 RK-6

Acid Gas results removed per further review from 

industry and EPA due to inappropriate cooling 

vent sample location and no spike/recovery data

FLOR-1 Florim USA Clarksville TN 10/25/2007 Roller Kiln 2008 

Survey 41 RK-1 Acid Gas results removed per further review from industry and EPA due to glass fiber filter used

FLOR-1 Florim USA Clarksville TN 11/18/2008 Roller Kiln 2008 

Survey 41 RK-1

Acid Gas results removed per further review from 

industry and EPA due to lack of filter temperature 

measurement records

FLOR-1 Florim USA Clarksville TN 5/25/2010 Roller Kiln 2010 

Survey 41 RK-1

Acid Gas results removed per further review from 

industry and EPA due to production and 

equipment problems during Run 2 and production 

shutdowns during Run 3; Removed Non-Hg HAP 

Metal results due to only one test run from this 

test was not Mn contaminated; Removed PM Run 

1 due to probe and filter temps outside M5 range

INTE-1 Interceramic Garland TX 8/22/1995 Roller Kiln 2008 

Survey 46 RK-1 No run by run data, only average and potential to emit calculations, only one value per kiln

INTE-1 Interceramic Garland TX 8/22/1995 Roller Kiln 2008 

Survey 47 RK-2 No run by run data, only average and potential to emit calculations, only one value per kiln

INTE-1 Interceramic Garland TX 8/22/1995 Roller Kiln 2008 

Survey 48 RK-3 No run by run data, only average and potential to emit calculations, only one value per kiln

INTE-1 Interceramic Garland TX 8/22/1995 Roller Kiln 2008 

Survey 49 RK-4 No run by run data, only average and potential to emit calculations, only one value per kiln

INTE-1 Interceramic Garland TX 8/22/1995 Roller Kiln 2008 

Survey 50 RK-5 No run by run data, only average and potential to emit calculations, only one value per kiln

MOHA-1 Dal-Tile 

Conroe Plant Conroe TX 8/23/2005 Roller Kiln 2008 Survey 51, 52, 53 RK-1, RK-2, RK-3 Plant shut down and dismantled

MOHA-2 Dal-Tile 

Dallas Plant Dallas TX 5/22/2007 Roller Kiln 2008 Survey 54, 55 RK-99-1, RK99-2

Acid Gas results removed per further review from 

industry and EPA due to high Method 26A 

calibration standards, detection limit not specified, 

and low probe and filter temperatures
3

Facility ID Facility City State Test Date Unit Type Source RTI ID Source ID Explanation Why Data Excluded 

MOHA-2 Dal-Tile 

Dallas Plant Dallas TX 5/23/2007 Roller Kiln 2008 Survey 56, 57 RK-100-2, RK100-3

Acid Gas results removed per further review from 

industry and EPA due to high Method 26A 

calibration standards, detection limit not specified, 

and low probe and filter temperatures

DALT-1 Dal Italia Muskogee OK 12/7/2005 Roller Kiln 2008 

Survey 59, 60 RK-1, RK-2

Acid Gas results removed per further review from 

industry and EPA due to high Method 26A 

calibration standards and detection limit not 

specified

DALT-1 Dal Italia Muskogee OK 4/12/2006 Roller Kiln 2008 

Survey 59, 60 RK-1, RK-2

Acid Gas results removed per further review from 

industry and EPA due to high Method 26A 

calibration standards and detection limit not 

specified

DALT-1 Dal Italia Muskogee OK 5/3/2006 Roller Kiln 2008 

Survey 59, 60 RK-1, RK-2 Removed PM Run 1 due to probe and filter tempsoutside M5 range

DALT-1 Dal Italia Muskogee OK 5/14/2010 Roller Kiln 2010 

Survey 60, 61, 62 RK-2, RK-3, RK-4

Removed Non-Hg HAP Metal results due to all 

runs being Mn contaminated

DALT-1 Dal Italia Muskogee OK 11/2/2006 Roller Kiln 2008 

Survey 61, 62 RK-3, RK-4

Acid Gas results removed per further review from 

industry and EPA due to detection limit not 

specified

DALT-1 Dal Italia Muskogee OK 12/8/2005 Roller Kiln 2008 

Survey 63 RK-5

Acid Gas results removed per further review from 

industry and EPA due to high Method 26A 

calibration standards and detection limit not 

specified

DALT-1 Dal Italia Muskogee OK 4/13/2006 Roller Kiln 2008 

Survey 63 RK-5

Acid Gas results removed per further review from 

industry and EPA due to high Method 26A 

calibration standards and detection limit not 

specified

MOHA-3 Dal-Tile El 

Paso Plant El Paso TX 12/13-14/2010 Roller Kiln 2010 Survey

64, 65, 68, 

69

RK-1, RK-2, 

RK-5, RK-6 

Bisque

Removed Non-Hg HAP Metal Run 1 results due to 

Mn contamination; Removed PM Runs 1, 2, and 3 

due to probe and filter temps outside M5 range

MOHA-3 Dal-Tile El 

Paso Plant El Paso TX 12/15-16/2010 Roller Kiln 2010 

Survey

70, 71, 74, 

75

RK-7, RK-8, 

RK-11, RK-12 

Glost

Removed Non-Hg HAP Metal Run 2 results due to 

Mn contamination; Removed PM Runs 1, 2, and 3 

due to probe and filter temps outside M5 range

MARR-2

Monarch 

Ceramic Tile, 

Inc.

Florence AL 5/4-5/2010 Roller Kiln 2010 

Survey 77 RK-2L

Removed Non-Hg HAP Metal results due to only 

one test run from this test was not Mn 

contaminated

FLOR-1 Florim USA Clarksville TN 5/26/2010 Glazing 2010 

Survey 71 GL-1 Removed Non-Hg HAP Metal Run 2 results due to Mn contamination

FLOR-1 Florim USA Clarksville TN 5/24/2010 Glazing 2010 

Survey 73, 74, 75 GL-3, 4, 5 Removed PM Run 1 due to probe and filter tempsoutside M5 range
4

Facility ID Facility City State Test Date Unit Type Source RTI ID Source ID Explanation Why Data Excluded 

DALT-1 Dal Italia Muskogee OK 10/30/2006 Glazing 2008 

Survey

114; 116; 

117; 119

GL-7 west, GL8, GL-9 west, 

GL-10

PM no production in units of lb/ton glaze sprayed

DALT-1 Dal Italia Muskogee OK 5/13-

15/2010 Glazing 2010 Survey

114; 116; 

117; 119

GL-7 west, GL8, GL-9 west, 

GL-10

Removed Non-Hg HAP Metal results due to only 

one test run from this test was not Mn 

contaminated

MARR-2

Monarch 

Ceramic Tile, 

Inc.

Florence AL 3/23/2005 Glazing 2008 

Survey 127, 128 GL-5; GL-6 PM no production in units of lb/ton glaze sprayed

KOHL-SC Kohler Co. Spartanburg SC 8/13/2010 Tunnel Kiln 2010 

Survey 9 TK #10 POC + RCE stacks Hg & HAP metals lab results were compromised

KOHL-TX Kohler Co. Brownwood TX 8/23-

24/2010 Tunnel Kiln 2010 Survey 19 & 20 TK #6/12 POC stack

Removed Non-Hg HAP Metal Run 2 results due to 

Mn contamination

KOHL-TX Kohler Co. Brownwood TX 8/12-

13/2010 Tunnel Kiln 2010 Survey 7 TK #8 POC stack

Removed Non-Hg HAP Metal Run 2 results due to 

Mn contamination

KOHL-SC Kohler Co. Spartanburg SC 8/16/2010

Manual 

glaze 

application 

2010 

Survey 2 LBM Removed PM Run 1 due to probe and filter tempsoutside M5 range
Appendix B

Final Run-by-Run Values
B-1

The final run-by-run values for HF, HCl, PM, Hg, individual non-Hg HAP metal, and 

dioxin/furan runs for kilns; dioxin/furan runs for dryers; and PM, Hg, and non-Hg HAP metal

runs for glaze spray booths are provided in the corresponding Appendix B Microsoft Excel® file. 

The file includes the parameters and emission data compiled from each test report and the

calculations conducted on the data.
Appendix C

Dioxin/Furan and TEQ Sample Calculations
C-1

A sample calculation of run by run reported laboratory masses converted into final total 

dioxin/furan and total TEQ run-by-run values is provided in the corresponding Appendix C

Microsoft Excel® file.