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: Jeffrey Telander

OAQPS/SPPD/MMG (D243-02)

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

I. Introduction

A meeting with representatives 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, 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

Eric Astrachan, 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 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; update on the

status of Sierra Club’s lawsuit and its impact on establishing a regulatory schedule; redevelopment 

of the clay ceramics standards (including subcategories and the addition of glaze spray booths to

the standards); inventory and emissions data gaps; 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:

● Industry representatives noted that there are no major source facilities with periodic 

kilns in the ceramic tile industry. (However, it was also noted that the sanitaryware 

industry does 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 the 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 scheduled 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 the 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 determine 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 some 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 within 

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. Gilberg asked whether EPA would be establishing a separate docket for this 

rulemaking and whether documentation that the industry had provided before, 
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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. Telander 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 require sensitive production data. Industry 

representatives 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 

ingredients 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:

● Determining 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 facilities to determine 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 within 

the ceramic tile industry, or identify documents in the original docket that make this 

distinction.

● Reviewing whether to include extruded 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 1
2

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/ 

Drying
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; 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 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.)
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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

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 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 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).
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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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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?