Date: April 7 , 2008 (Revised May 2 , 2008) Subject : Minutes of the April 1 , 2008 Meeting with Representatives of the Ceramic Tile Manufacturing Industry Standards Development for Brick, Structural Clay, and Clay Ceramics Manufacturing EPA Contract No. EP

- D

- 06

- 118; EPA Work Assignment No. 2

- 09 RTI Project No. 0210426.002.009

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 meeting with representati ves of the ceramic tile manufacturing industry and others was held at the U.S. Environmental Protection Agency facility in Research Triangle Park, NC on April 1 , 200 8 . The purpose of the meeting was to discuss steps for redevelop ing national emission
stan dards 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

Eric A strachan, Tile Council of North America , Inc. (TCNA) Michael Cassidy, Kohler Co. Howard Gilberg, Guida, Slavich & Flores (GSF) , representing Marazzi Tile Mike Johnston, Florida Tile Industries, Inc. Robert Hurt, Dal

- Tile Corp. Connie James, Florim USA Myra Warne, Ceramic Manufacturers Association (CerMA) Steven Wiederwax, Marazzi Tile

Jeff Telander, U.S. EPA, OAQPS

Thomas Holloway, RTI International Katie Hanks, RTI International2 III. Discussion

The major topics discussed during the meeting included backgrou nd on the clay ceramics industry ; regulatory history of the original clay ceramics major source NESHAP ; update on the status of Sierra Club ’s lawsuit and its impact on establishing a regulatory schedule; redevelopment of the clay ceramics standards (includ ing subcategories and the addition of glaze spray booths to the standards ) ; inventory and emissions data gaps ; and the type of data EPA need s to re develop the standards. Attachment 1 presents the meeting notes which cover t hese major topics. Other relate d topics that were cove red during the meeting included the following :

● Industry representatives noted that t here are no major source facilities with periodic kilns in the ceramic tile industry

. (However, it was also noted that the sanitaryware industry do es have periodic kilns at its major source facilities .)

● Industry representatives had confidentiality concerns about submitting data to EPA, especially production data, and suggested they submit data to TCNA first, which would mask the company identity in t he data prior to sending it on to EPA.

● An agreement was reached that EPA would provide a draft information collection request (ICR) to industry for its review (e.g., for accuracy) prior to EPA sending out the formal ICR

. The formal ICR is tentatively sch eduled to be sent out in May/June 2008, with responses due to EPA by August 2008.

● Industry representatives agreed to provide comments on the draft clay ceramics inventory, but also cited the confidentiality concerns noted previously. Mr. Hurt noted that t he Dal

- Tile facility in Conroe, Texas had permanently shut down in the last couple of years, so EPA need not request information about that facility.

● EPA noted that a draft clay ceramics inventory had already been sent to TCNA, but agreed to check to deter mine whether any additional changes had been made to the inventory before asking TCNA to distribute the inventory for review by the industry. (The inventory has since been checked, and no changes have been made since it was sent to TCNA.)

● EPA noted that s ome emissions testing may be necessary to obtain the data needed to determine any new emission limits. EPA noted that it has section 114 authority to require industry to provide this data.

● Industry representatives noted the distinction between roller and tunnel kilns with in the ceramic tile industry, and EPA suggested that industry provide more detailed information to support its claim

. If this information is already available in the original docket, EPA suggests that industry identify those documents in the docket which describe the differences between roller and tunnel kilns within the ceramic tile industry.

● Mr. Hurt requested that EPA review whether extruded tiles (e.g., roof tiles) should remain in the brick and structural clay products (BSCP) category or be added to the clay ceramics category.

● Industry representatives indicated that there are differences between ceramic tile kilns and brick tunnel kilns and argued that data from brick tunnel kilns should not be applied for ceramic tile kilns.

● Mr. Gilbe rg asked whether EPA would be establishing a separate docket for this rulemaking and whether documentation that the industry had provided before,3 particularly the difference between ceramic tile kilns and brick tunnel kilns, would be part of the new docket . EPA suggested that industry identify any documents in the original docket that they would like included in the new docket.

● Mr. Gilberg indicated he would like to speak with EPA’s representative from the Office of General Counsel for this project . Mr. T elander agreed to provide Mr. Gilberg with the necessary contact information.

● Industry representatives discussed their concerns with the format of any new emission limits, specifically the confidentiality issues associated with establishing a pound per
ton (lb/ton) limit for kilns, which would requi re sensitive production data. Industry

re presentatives also said such a format would be inappropriate for glaze lines because measures of glaze amounts (e.g., gallons, pounds, etc.) vary and also because glaze i ngredients are sensitive information . A concentration format (e.g., gr/dscf) for glaze lines was discussed , since these lines are typically controlled by a baghouse

.

IV. Action Items

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

● D etermining where data are needed, what type of data are needed, and the type of questions to ask and sending industry a copy of the draft ICR for review prior to any formal section 114 ICR submittal.

● Checking the draft inventory of clay ceramics fa cilities to det ermine whether the inventory has been revised since its submittal to TCNA , and informing TCNA of the findings . It has since been determined that no changes to the draft inventory have been made

. TCNA has the latest version of the inventory to send out to its members for review.

● Providing data to EPA to support the distinction between tunnel and roller kilns with in the ceramic tile industry , or identify documents in the original docket that make this distinction

. ● Reviewing whether to include extrud ed tiles in the BSCP or clay ceramics category.

● Providing EPA with information about any documents in the original docket that should be included in the new docket.

● Providing Mr. Gilberg with the contact information for the project’s OGC representative.

# Clay Ceramics Major Source NESHAP

Meeting with Ceramic Tile Industry to Discuss Planned Approach on Remand April 1, 2008 Attachment 12 

# Background

 

## Four industry sectors, two of which include plants that are major HAP
sources:

 

### Sanitaryware (e.g., toilets, sinks)

– 3 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 processes. (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. Clay Ceramics Manufacturing Process Emissions: 

## Casting/

Drying4 

# 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 account for the HAP content of glazes and type of 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 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 Marazzi USA 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 Major9 

# 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 25 25 Unknown 0 0 0 None 31 0 31 Total 31 49 80 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 25 25 Unknown 2 4 6 None 53 0 53 Total 70 154 224 "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 

# 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).

 

## 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?