United
States
Office
Of
Air
Quality
EPA­
452/
R­
03­
007
Environmental
Protection
Planning
And
Standards
February
2003
Agency
Research
Triangle
Park,
NC
27711
Air
A­
2000­
48
IV­
A­
2
Economic
Impact
Analysis
of
the
Clay
Ceramics
Manufacturing
NESHAP:
Final
Rule
Economic
Impact
Analysis
of
the
Clay
Ceramics
Manufacturing
NESHAP:
Final
Rule
U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Innovative
Strategies
and
Economics
Group,
MD­
C339­
01
Research
Triangle
Park,
NC
27711
February
2003
This
report
has
been
reviewed
by
the
Emission
Standards
Division
of
the
Office
of
Air
Quality
Planning
and
Standards
of
the
United
States
Environmental
Protection
Agency
and
approved
for
publication.
Mention
of
trade
names
or
commercial
products
is
not
intended
to
constitute
endorsement
or
recommendation
for
use.
Copies
of
this
report
are
available
through
the
Library
Services
(
MD­
35),
U.
S.
Environmental
Protection
Agency,
Research
Triangle
Park,
NC
27711,
or
from
the
National
Technical
Information
Services
5285
Port
Royal
Road,
Springfield,
VA
22161.
Acronyms
CAA
Clean
Air
Act
DIFF
Dry
Injection
Fabric
Filter
EIA
Economic
Impact
Analysis
EPA
United
States
Environmental
Protection
Agency
HAPs
Hazardous
Air
Pollutants
HCl
Hydrogen
Chloride
(
also
known
as
Hydrochloric
Acid)

HF
Hydrogen
Fluoride
ISEG
Innovative
Strategies
and
Economics
Group
MACT
Maximum
Achievable
Control
Technology
NESHAP
National
Emission
Standards
for
Hazardous
Air
Pollutants
NAICS
North
American
Industrial
Classification
Code
OAQPS
Office
of
Air
Quality,
Planning,
and
Standards
RFA
Regulatory
Flexibility
Act
SBREFA
Small
Business
Regulatory
Enforcement
Fairness
Act
SIC
Standard
Industrial
Classification
VOPS
Value
of
Product
Shipments
VOS
Value
of
Shipments
1­
4
ECONOMIC
IMPACT
ANALYSIS:
CLAY
CERAMICS
MANUFACTURING
1
INTRODUCTION
Pursuant
to
Section
112
of
the
Clean
Air
Act,
the
U.
S.
Environmental
Protection
Agency
(
EPA
or
the
Agency)
is
developing
National
Emissions
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
to
address
the
emissions
released
from
major
sources
in
the
clay
ceramics
manufacturing
source
category.
The
clay
ceramics
industry
manufactures
such
products
as
dinnerware,
kitchenware,
pottery,
sanitaryware,
and
ceramic
floor
and
wall
tile.
EPA
has
defined
the
clay
ceramics
manufacturing
source
category
to
include
only
those
facilities
that
produce
pressed
floor
tile,
pressed
wall
tile,
other
pressed
tile,
and
sanitaryware
because
no
major
sources
were
identified
in
the
other
segments
of
the
clay
ceramics
manufacturing
industry.
Ceramic
tile
and
sanitaryware
are
used
as
inputs
to
the
production
of
buildings,
structures,
and
homes.
The
NESHAP
which
this
economic
impact
analysis
(
EIA)
addresses
is
scheduled
to
be
proposed
in
mid­
2001.
The
Innovative
Strategies
and
Economics
Group
(
ISEG)
of
the
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS)
has
developed
this
analysis
in
support
of
the
evaluation
of
impacts
associated
with
the
clay
ceramics
manufacturing
NESHAP.

1.1
Scope
and
Purpose
This
report
evaluates
the
economic
impacts
of
pollution
control
requirements
on
ceramic
floor
and
wall
tile
and
sanitaryware
manufacturing
operations.
The
Clean
Air
Act
(
CAA)
was
designed
to
protect
and
enhance
the
quality
of
the
nation's
air
resources
and
Section
112
of
the
CAA
establishes
the
authority
to
control
hazardous
air
pollutant
(
HAP)
emissions.
To
reduce
emissions
of
HAPs,
the
Agency
establishes
maximum
achievable
control
technology
(
MACT)
standards.
The
term
"
MACT
floor"
refers
to
the
minimum
control
technology
on
which
MACT
standards
can
be
based.
The
MACT
floor
is
set
by
the
average
emissions
limitation
achieved
by
the
best
performing
12
percent
of
sources
in
a
category
or
subcategory
when
that
category
or
subcategory
contains
at
least
30
sources.
For
this
NESHAP,
the
MACT
floors
for
existing
kilns
at
major
sources
in
the
clay
ceramics
source
category
require
no
control
of
HAP
emissions;
however
new
kilns
at
major
sources
in
this
source
category
are
required
to
meet
a
MACT
floor
that
entails
some
level
of
control.
Since
the
proposed
rule
requires
no
control
of
existing
sources,
no
costs
will
be
incurred
by
existing
sources.

1.2
Organization
of
the
Report
The
report
is
organized
as
follows:
Section
2
provides
a
profile
of
the
industry
which
includes
a
description
of
the
producers
and
consumers
of
clay
ceramic
products.
This
section
also
presents
available
market
data
and
trends
in
the
industry,
including
domestic
production,
foreign
trade,
and
apparent
U.
S.
consumption.
Special
attention
is
given
to
the
ceramic
tile
and
sanitaryware
manufacturing
segments
of
the
industry,
since
the
facilities
that
produce
these
products
are
included
in
the
clay
ceramics
manufacturing
source
category
as
defined
by
EPA.
Section
3
describes
the
facility­
level
costs
new
sources
will
face
to
comply
with
this
NESHAP
and
Section
4
provides
facility­,
market­,
and
society­
level
impacts
of
complying
with
this
rule.
Small
business
considerations
are
made
in
Section
5
as
required
by
the
Regulatory
Flexibility
Act
(
RFA)
which
was
modified
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
of
1996
(
SBREFA).
2­
1
2
INDUSTRY
PROFILE
Though
the
clay
ceramics
manufacturing
source
category
only
includes
facilities
that
produce
ceramic
tile
and
sanitaryware,
this
industry
profile
provides
an
overall
description
of
the
clay
ceramics
manufacturing
industry.
In
some
sections,
however,
the
report
will
focus
on
ceramic
tile
and
sanitaryware
since
producers
of
these
products
are
included
in
the
clay
ceramics
manufacturing
source
category.
The
industry
profile
is
organized
as
follows:
Section
2.1
describes
the
processes
and
costs
of
producing
clay
ceramic
products,
as
well
as
the
types
of
emissions
released
during
production.
Section
2.2
explains
the
various
uses,
consumers,
and
substitute
products
available
for
ceramic
products.
Section
2.3
provides
a
summary
profile
of
the
clay
ceramics
source
category,
including
a
description
of
the
ceramic
tile
and
sanitaryware
manufacturing
facilities
and
the
companies
that
own
them.
Clay
ceramics
are
heat­
and
corrosion­
resistant
products
made
by
shaping
and
heating
clay
minerals.
Some
ceramic
products
include
pottery,
dinnerware,
kitchenware,
sanitaryware,
bathroom
accessories,
and
floor
and
wall
tile.
Kitchenware
and
dinnerware
are
used
for
food
service,
storage,
and
preparation,
while
bathroom
accessories,
sanitaryware,
and
ceramic
tile
are
used
in
the
construction
of
homes
and
buildings.
Pottery
often
serves
a
decorative
purpose,
but
is
sometimes
used
for
food
preparation
and
presentation.
Clay
ceramics
manufacturing
falls
under
the
following
North
American
Industrial
Classification
System
(
NAICS)
codes:
°
NAICS
327122
­
Ceramic
Wall
and
Floor
Tile
Manufacturing;
°
NAICS
327111
­
Vitreous
China
Plumbing
Fixture
and
China
and
Earthenware
Bathroom
Accessories
Manufacturing;
and
°
NAICS
327112
­
Vitreous
China,
Fine
Earthenware,
and
Other
Pottery
Product
Manufacturing.

These
correspond
to
the
following
Standard
Industrial
Classification
(
SIC)
codes:
°
SIC
3253
­
Ceramic
Wall
and
Floor
Tile;
°
SIC
3261
­
Vitreous
China
Plumbing
Fixtures
and
China
and
Earthenware
Fittings
and
Bathroom
Accessories;
°
SIC
3262
­
Vitreous
China
Table
and
Kitchen
Articles;
°
SIC
3263
­
Fine
Earthenware
(
Whiteware)
Table
and
Kitchen
Articles;
and
°
SIC
3269
­
Pottery
Products,
not
elsewhere
classified
(
n.
e.
c.).
Production
of
the
various
traditional
ceramic
products
follows
a
similar
process.
During
this
production
process,
HAPs
are
released.
The
primary
HAPs
emitted
are
hydrogen
fluoride
(
HF)
and
hydrogen
chloride
(
HCl)
and
the
primary
sources
of
these
emissions
are
the
kilns
used
to
fire
the
ceramic
products.

2.1
Production
Overview
This
section
provides
a
general
description
of
the
clay
ceramics
manufacturing
process.
Section
2.1.1
provides
an
overview
of
the
production
process,
while
Section
2.1.2
briefly
describes
the
emissions
released
as
clay
ceramic
products
are
produced.
Section
2.1.3
addresses
the
costs
of
producing
ceramic
products
and
last,
Section
2.1.4
discusses
the
values
of
the
types
of
clay
minerals
used
in
the
production
of
clay
ceramics.

2.1.1
General
Process
Description
The
general
process
steps
used
in
the
production
of
ceramics
include
raw
material
processing,
mixing,
forming,
shape
drying,
glazing,
firing,
and
finishing.
A
generic
process
flow
diagram
is
shown
in
Figure
2­
1
following
Section
2.1.1.
Information
in
this
section
was
taken
from
EPA's
Emission
Factor
2­
2
Documentation
on
Ceramic
Products
Manufacturing
(
1996).
Raw
material
processing
typically
includes
crushing,
grinding,
screening,
drying,
and
granulation
or
powder
formation.
Some
ceramic
manufacturers
perform
some
or
all
of
these
operations
onsite,
but
many
purchase
processed
raw
materials
that
require
little,
if
any,
additional
processing.
After
initial
processing,
the
raw
materials
are
mixed
and
formed.
In
some
ceramic
mixes,
binders
and
other
additives
are
used
to
form
a
temporary
bond
to
maintain
the
shape
of
the
ceramic
until
it
can
be
fired.
Other
additives
also
may
be
included
in
the
mix
to
impart
specific
properties
to
the
finished
product.
In
the
forming
step,
the
mixture
is
molded
or
shaped.
The
ceramic
mix
can
be
formed
by
a
variety
of
processes,
the
most
common
of
which
are
pressing
and
slip
casting.
After
forming,
the
ceramic
may
be
"
green
machined"
to
eliminate
rough
surfaces
and
edges
or
to
modify
the
shape.
The
next
step
is
shape
drying,
which
can
be
performed
in
continuous
or
periodic
dryers.
Ceramic
glazes
can
be
applied
before
firing
or
between
firing
stages,
depending
on
the
type
of
product.
Firing
may
be
performed
in
one
or
more
stages.
The
following
paragraphs
describe
each
of
the
principle
processing
steps
used
in
the
production
of
ceramics:
raw
material
processing,
mixing,
forming,
shape
drying,
glazing,
firing,
and
finishing.
2.1.1.1
Raw
Material
Processing
The
raw
materials
used
in
the
manufacture
of
ceramics
range
from
unprocessed
clays
and
other
minerals
mined
from
natural
deposits
to
high
purity
powders
prepared
by
chemical
synthesis.
Naturallyoccurring
raw
materials
used
to
manufacture
ceramics
include
a
variety
of
clays
(
including
ball
clay,
kaolin,
fire
clay,
and
common
clay),
feldspar,
talc,
silica,
and
nepheline
syenite.
Silica
can
be
in
the
form
of
silica
sand,
quartz,
or
flint.
Many
raw
materials
require
some
degree
of
beneficiation
prior
to
use
in
ceramic
production.
The
basic
beneficiation
processes
include
crushing,
grinding,
and
sizing
or
classification.
Facilities
that
form
ceramic
bodies
by
pressing,
often
granulate
raw
materials
and
raw
material
mixes
to
produce
a
freeflowing
powder.
In
addition,
some
facilities
dry
raw
materials
onsite.
Primary
crushing
is
used
to
reduce
the
size
of
coarse
materials,
such
as
clays,
down
to
approximately
1
to
5
centimeters
(
cm)
(
0.5
to
2
inches
[
in.]).
The
most
common
types
of
crushers
used
are
jaw
crushers,
cone
crushers,
gyratory
crushers,
and
roll
crushers.
Secondary
crushing
or
grinding
reduces
particle
size
down
to
approximately
1
millimeter
(
mm)
(
0.04
in.)
in
diameter.
Fine
grinding
or
milling
reduces
the
particle
size
down
to
as
low
as
1.0
micrometer
(

m)
(
4
x
10­
5
in.)
in
diameter.
Ball
mills
are
the
most
commonly
used
piece
of
equipment
for
milling.
Hammer
mills,
vibratory
mills,
attrition
mills,
and
fluid
energy
mills
also
are
used.
Crushing
and
grinding
typically
are
dry
processes,
but
some
facilities
use
wet
ball
mills
to
grind
and
mix
raw
materials
in
one
step.
Sizing
and
classification
separate
the
raw
material
into
size
ranges.
Sizing
is
most
often
accomplished
using
one
or
more
vibrating
screens
in
series.
Screens
can
have
one
or
more
decks,
with
each
successive
deck
fitted
with
an
increasingly
smaller
mesh.
A
single­
deck
screen
can
produce
two
size
fractions,
the
oversize
(
that
material
that
does
not
pass
through
the
screen)
and
the
undersize
(
the
material
that
passes
through
the
screen).
To
achieve
more
than
two
size
ranges,
multi­
deck
screens
are
used.
Often,
the
grinding
and
screening
steps
are
designed
as
a
closed­
circuit
system
in
which
the
grinder
discharge
is
conveyed
to
screens,
oversize
material
exiting
the
screen
is
conveyed
back
to
the
grinder,
and
undersize
material
is
conveyed
to
the
next
step
in
the
process
or
to
storage.
Air
classification
also
is
used
in
the
ceramics
industry
to
separate
materials
by
size.
Some
raw
materials,
particularly
those
that
are
stored
outside,
must
be
dried
before
being
processed
for
ceramics
manufacturing.
Drying
helps
prevent
caking
during
storage,
prepares
the
material
for
dry
mixing,
and
produces
a
consistent
moisture
content
among
the
raw
materials.
Rotary
dryers
are
most
commonly
used
for
drying
ceramic
raw
materials.
Vibrating
grate
dryers
and
fluidized
bed
dryers
also
are
used.
Raw
material
dryer
operating
temperatures
generally
range
from
50

to
120

C
(
120

to
250

F).
2­
3
2.1.1.2
Mixing
The
purpose
of
mixing
is
to
combine
the
constituents
of
a
ceramic
mix
to
produce
a
more
chemically
and
physically
uniform
material
for
forming.
The
type
of
mixer
used
typically
is
a
function
of
the
forming
method
that
follows
mixing.
Facilities
that
form
products
by
slip­
casting
typically
use
blungers
or
wet
mixers.
Dry
mixing
is
used
when
the
ceramic
is
to
be
dry­
pressed
or
formed
by
some
other
dry
forming
process.
Binders
and
other
additives
may
also
be
added
in
the
mixer.
Binders
are
used
to
form
temporary
bonds
between
raw
material
grains
to
help
maintain
the
shape
of
the
ceramic
until
it
can
be
fired.
Organic
binders
are
typically
burned
off
during
firing;
inorganic
binders
become
part
of
the
ceramic
matrix
during
firing.
Binders
also
can
serve
as
lubricants
and
can
impart
other
properties
to
the
final
product.
Some
examples
of
binders
used
in
the
production
of
ceramics
are
clays,
silicates,
and
phosphates.
Additives
generally
are
used
to
facilitate
processing
or
impart
specific
properties
to
the
final
product.
For
example,
clays
and
other
materials
can
be
used
as
fluxing
agents
that
allow
the
ceramic
product
to
be
fired
at
lower
temperatures.
In
slurry
processing,
deflocculants,
surfactants,
and
antifoaming
agents
may
be
added
prior
to
slip­
casting
to
improve
processing.
Deflocculants
and
surfactants
are
used
as
dispersion
aids.
2.1.1.3
Forming
In
the
forming
step,
the
ceramic
mix
is
consolidated
and
molded
to
produce
a
cohesive
body
of
the
desired
shape
and
size.
Forming
methods
can
be
classified
as
either
dry
forming,
plastic
molding,
or
wet
forming.
Dry
forming
consists
of
the
simultaneous
compacting
and
shaping
of
dry
ceramic
powders
in
a
rigid
die
or
flexible
mold.
The
most
commonly
used
dry
forming
method
is
pressing,
which
is
used
for
forming
relatively
simple
shapes.
Ceramic
tile
typically
are
formed
by
dry
pressing.
Prior
to
pressing,
many
facilities
granulate
the
ceramic
mix
to
form
a
free­
flowing
powder,
thereby
improving
handling
and
compaction.
The
most
commonly
used
method
of
granulation
is
spray­
drying.
In
this
step,
the
ceramic
mix
is
combined
with
water
to
form
a
slurry.
The
slurry
is
injected
into
a
drying
chamber
with
hot
gases.
As
the
hot
gases
contact
the
slurry,
a
powder
is
formed
and
collected
in
a
cyclone
or
fabric
filter.
Spray
dryers
generally
are
gas­
fired
and
operate
at
temperatures
of
70

to
570

C
(
160

to
1050

F).
For
more
complex
shapes,
isostatic
pressing
and
vibratory
compaction
can
be
used.
In
isostatic
pressing,
the
ceramic
mix
is
placed
inside
a
flexible
mold,
which
is
then
deaired,
sealed,
and
placed
in
a
pressurized
chamber.
Vibratory
compaction
is
used
for
producing
irregular
shapes
from
ungranulated
powders.
Plastic
molding
is
accomplished
by
jiggering,
or
injection
molding.
Jiggering
is
used
to
form
circular
or
axially
symmetrical
shapes
by
shaping
a
plastic
material
on
a
spinning
platform.
Jiggering
is
widely
used
in
the
production
of
dinnerware.
In
injection
molding,
a
ceramic
mixture,
which
typically
is
heated,
is
injected
into
a
die.
This
method
generally
is
used
for
making
small,
complex
shapes.
Wet
forming
methods
involve
the
use
of
a
ceramic
slurry.
The
most
commonly
used
wet
forming
method
is
slip
casting.
Other
wet
forming
methods
include
gelcasting
and
tape
casting.
In
slip
casting,
a
ceramic
slurry
with
a
moisture
content
of
20
to
35
percent
is
poured
into
a
porous
mold.
Capillary
suction
of
the
mold
draws
the
liquid
from
the
mold,
thereby
consolidating
the
cast
ceramic
material.
After
a
fixed
time,
the
excess
slurry
is
drained,
and
the
cast
shape
is
dried.
Slip
casting
is
widely
used
in
the
manufacture
of
sinks
and
other
sanitaryware
and
structural
ceramics
with
complex
shapes.
2.1.1.4
Shape
Drying
The
next
step
is
shape
drying,
which
can
be
performed
in
continuous
or
periodic
dryers.
Generally,
the
type
of
dryer
is
dictated
by
the
type
of
kiln
used
to
fire
the
ceramic
ware;
a
facility
that
uses
continuous
kilns
will
also
use
continuous
dryers.
Drying
reduces
the
free
moisture
content
of
the
ceramic
shape
to
prevent
differential
shrinkage,
distortion,
cracking,
and
spalling
when
the
shape
is
fired
in
the
kiln.
Drying
also
reduces
the
energy
requirements
for
firing
and
can
serve
the
purpose
of
driving
off
organic
additives.
The
most
commonly
used
method
of
drying
ceramics
is
by
convection,
in
which
2­
4
heated
air
is
circulated
around
the
ceramics.
Facilities
that
use
tunnel
kilns
often
use
the
waste
heat
from
the
cooling
zone
of
the
kiln
to
heat
the
dryer.
Natural
gas
and
electricity
also
are
used
to
provide
drying
heat.
In
addition,
some
facilities
use
steam­
heated
dryers,
and
some
dryers
are
fired
with
propane.
2.1.1.5
Glazing
Glazes
resemble
glass
in
structure
and
texture.
The
purpose
of
glazing
is
to
provide
a
smooth,
shiny
surface
that
seals
the
ceramic
body.
Not
all
ceramics
are
glazed.
Those
that
are
glazed
can
be
glazed
prior
to
firing,
or
can
be
glazed
after
firing,
followed
by
refiring
to
set
the
glaze.
Many
facilities
prepare
glazes
onsite
by
grinding
and
mixing
a
combination
of
raw
materials;
other
facilities
purchase
glazes
that
require
no
additional
processing.
In
most
cases,
the
primary
materials
in
the
glaze
mix
are
the
same
materials
that
form
the
ceramic
body.
Metal
oxides,
such
as
chromium
oxide,
cobalt
oxide,
and
manganese
oxide
often
are
used
to
color
glazes.
Glazes
generally
are
applied
by
spraying,
but
dipping
or
flooding
also
are
used
for
glaze
application.
Depending
on
their
constituents,
glazes
mature
at
temperatures
of
600

to
1500

C
(
1110

to
2730

F).
2.1.1.6
Firing
Firing
serves
three
primary
functions:
to
substantially
reduce
the
number
of
pores
in
the
ceramic;
to
increase
the
density
of
the
ceramic;
and
to
bond
together
the
individual
material
grains
into
a
strong,
hard
mass
(
ceramic
bond).
If
firing
results
in
the
formation
of
a
significant
amount
of
glass,
the
process
is
referred
to
as
vitrification.
If
no
glass
forming
or
melting
occurs,
the
process
is
referred
to
as
sintering.
Firing
cycles
generally
consist
of
three
phases:
gradual
heating
of
the
ceramic
body
to
the
soak
temperature,
which
typically
is
approximately
two­
thirds
of
the
melting
point
of
the
material
at
ambient
pressure;
a
soak
period
of
constant,
peak
temperature
(
soak
temperature),
where
the
bond
between
the
material
grains
is
formed;
and
a
gradual
cooling
down
of
the
fired
ceramic.
Maximum
kiln
temperatures
typically
range
from
about
900

to
1330

C
(
1650

to
2430

F).
As
is
the
case
for
drying,
firing
can
be
performed
as
a
continuous
or
batch
process.
Tunnel
kilns
and
roller
hearth
kilns
(
roller
kilns)
are
used
for
continuous
firing.
Tunnel
kilns
consist
of
a
long
refractory­
lined
tunnel
through
which
the
green
ceramics
move,
typically
stacked
on
rail
cars.
Tunnel
kilns
generally
have
separate
zones
for
preheating
or
drying,
firing,
and
cooling.
Roller
kilns
are
lowprofile
kilns
that
are
similar
to
tunnel
kilns
except
that
the
green
ceramics
travel
through
the
kiln
in
a
single
layer
on
rollers.
The
primary
advantages
of
tunnel
kilns
and
roller
kilns
are
lower
energy
consumption
and
the
ease
with
which
the
ceramics
can
be
transported
through
the
firing
process
when
compared
to
periodic
kilns.
Roller
kilns
have
the
additional
advantage
of
shorter
firing
times
than
are
required
when
tunnel
kilns
are
used.
The
main
disadvantages
of
tunnel
and
roller
kilns
are
the
high
capital
cost
and
inflexibility
to
changes
in
operating
conditions.
Most
tunnel
and
roller
kilns
are
fired
with
natural
gas.
Electricity
and
propane
also
are
used
to
heat
some
tunnel
kilns.
Batch
firing
kilns
are
referred
to
by
several
terms,
which
generally
relate
to
the
mechanism
by
which
the
kiln
opens
or
by
the
method
used
to
move
the
ceramic
ware
into
or
out
of
the
kiln.
Bell
kilns
and
shuttle
kilns
are
designed
with
a
removable
superstructure
that
is
tilted
or
raised
using
hydraulic
struts
to
allow
entrance
and
egress.
In
elevator
kilns,
the
kiln
structure
is
suspended.
The
base
or
floor
of
the
kiln
is
raised
into
position
during
firing
and
lowered
to
allow
the
ceramic
shapes
to
be
loaded
or
removed.
In
this
memorandum,
all
batch
firing
kilns
are
referred
to
generically
as
periodic
kilns.
The
main
advantage
of
periodic
kilns
is
that
they
can
readily
accommodate
changes
in
firing
temperature
profile
and
cycle
time
to
match
the
requirements
of
a
wide
variety
of
ceramic
products.
The
primary
disadvantage
of
periodic
kilns
is
higher
energy
costs
per
ton
when
compared
to
tunnel
kiln
and
roller
kiln
costs
per
ton.
Most
periodic
kilns
are
fired
with
natural
gas.
Some
periodic
kilns
also
are
heated
with
electricity
or
propane.
Periodic
kiln
operating
temperatures
range
from
950

to
1370

C
(
1750

to
2500

F).
Firing
cycle
times
range
from
less
than
1
hour
to
48
hours.
2­
5
2.1.1.7
Finishing
Following
firing,
some
ceramic
products
undergo
one
or
more
finishing
steps
to
enhance
their
characteristics
or
to
meet
dimensional
tolerances.
Finishing
can
include
grinding,
polishing,
sand
blasting,
drilling,
sawing,
and
lathing.
Most
grinding
and
sawing
processes
use
water
sprays
or
baths
to
minimize
particulate
matter
emissions.

2.1.2
Emissions
from
Clay
Ceramics
Manufacturing
Facilities
Production
of
clay
ceramic
products
requires
a
number
of
steps
that
result
in
the
emissions
of
pollutants.
These
pollutants
include
particulate
matter
(
PM),
nitrogen
oxides
(
NO
x),
sulfur
oxides
(
SO
x),
carbon
monoxide
(
CO),
carbon
dioxide
(
CO
2),
volatile
organic
compounds
(
VOCs),
and
hazardous
air
pollutants
including
HCl
and
HF.
The
handling
and
transfer
operations,
as
well
as
the
sizing
and
classifying
of
clay
minerals
result
in
PM
emissions.
Fuel
combustion
at
the
kilns
and
at
some
of
the
dryers
results
in
emissions
of
SO
x,
NO
x,
CO,
and
CO
2,
however
the
SO
x
emissions
also
are
a
function
of
the
sulfur
content
in
the
raw
materials
used
to
manufacture
ceramics.
Emissions
of
HF
and
HCl
are
a
result
of
the
release
of
fluoride
and
chloride
compounds
that
are
present
in
ceramic
raw
materials.
The
final
processing
of
ceramics
also
results
in
emissions.
Polishing
and
final
grinding
lead
to
PM
emissions
while
surface
coating
and
chemical
treatment
of
the
ceramics
results
in
VOCs.

2.1.3
Costs
of
Production
This
section
discusses
the
costs
of
producing
clay
ceramic
products.
There
are
several
types
of
production
costs
such
as:
°
capital
expenditures,
including
the
costs
of
equipment
and
its
installation;
°
energy
costs,
which
are
the
costs
of
electricity
and
fuels
used
in
the
production
of
clay
ceramic
products;
°
labor
costs,
including
the
costs
associated
with
wages
and
benefits;
and
°
the
cost
of
materials,
which
are
the
costs
of
tangible
inputs
such
as
clay
minerals,
parts,
and
additives.
2­
6
Raw
Material
Receiving
&
Storage
Product
Packaging
Beneficiation
(
Crushing,
Grinding,
and
Milling)

Screening
Mixing
Forming
Green
Finishing
and
Inspection
Drying
Firing
Finishing
and
Final
Inspection
Glaze
Preparation
and
Storage
Repair/
refire
(
optional)
Recycled
Material
(
optional)

Glazing
Figure
2­
1.
Ceramics
Process
Flow
Diagram
2­
7
Tables
2­
1,
2­
2,
and
2­
3
show
the
historical
production
cost
data
for
the
ceramic
floor
and
wall
tile
industry
(
NAICS
327122;
SIC
3253),
the
plumbing
fixture
and
ceramic
bathroom
accessories
industry
(
NAICS
327111;
SIC
3261),
and
the
vitreous
china,
kitchenware,
and
other
pottery
products
industry
(
NAICS
327112;
SICs
3262,
3263,
and
3269).
Data
presented
in
these
tables
have
been
gathered
from
the
U.
S.
Census
Bureau.

Table
2­
1.
Production
Costs
for
the
Ceramic
Floor
and
Wall
Tile
Industry
(
NAICS
327122;
SIC
3253)
($
106)

Year
Labor
Costs
Material
Costs
Energy
Costs
Capital
Expendituresa
1992
$
196.9
$
222.1
$
39.2
$
48.9
1993
$
206.3
$
213.7
$
47.2
$
68.0
1994
$
220.1
$
251.5
$
42.5
$
73.1
1995
$
233.9
$
290.5
$
43.9
$
61.5
1996
$
240.9
$
291.4
$
45.5
$
45.6
1997
$
236.1
$
290.9
$
48.6
$
79.6
1998
$
205.3
$
263.2
$
38.0
NA
Average
$
219.9
$
260.5
$
43.6
$
62.8
Average
Share
of
Value
of
Shipments
1992­
1998
25%
30%
5%
7%

Notes:
a
Average
for
Capital
Expenditures
excludes
figure
for
1998
since
it
is
unavailable.
Sources:
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999.
1997
Economic
Census.
Manufacturing
Industry
Series,
"
Ceramic
Wall
and
Floor
Tile
Manufacturing."
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1998
Annual
Survey
of
Manufactures,
M98(
AS)­
1
Statistics
for
Industry
Groups
and
Industries.
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1996
Annual
Survey
of
Manufactures,
M96(
AS)­
1
Statistics
for
Industry
Groups
and
Industries.
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1994
Annual
Survey
of
Manufactures,
M94(
AS)­
1
Statistics
for
Industry
Groups
and
Industries.
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1993
Annual
Survey
of
Manufactures,
M93(
AS)­
1
Statistics
for
Industry
Groups
and
Industries.
U.
S.
Government
Printing
Office.

Table
2­
2.
Production
Costs
for
the
Vitreous
China
Plumbing
Fixture
and
China
and
Earthenware
Bathroom
Accessories
Industry
(
NAICS
327111;
SIC
3261)
($
106)

Year
Labor
Costs
Material
Costs
Energy
Costs
Capital
Expendituresa
1992
$
216.8
$
205.9
$
30.5
$
14.3
1993
$
240.4
$
242.7
$
35.8
$
12.8
1994
$
251.9
$
248.9
$
35.4
$
25.3
1995
$
262.5
$
234.9
$
39.6
$
23.3
2­
8
1996
$
261.5
$
246.0
$
39.2
$
11.7
1997
$
285.2
$
253.4
$
34.5
$
14.9
1988
$
306.1
$
283.5
$
39.6
NA
Average
$
260.6
$
245.0
$
36.4
$
17.1
Average
Share
of
Value
of
Shipments
1992­
1998
27%
25%
4%
2%

Notes:
a
Average
for
Capital
Expenditures
excludes
figure
for
1998
since
it
is
unavailable.
Sources:
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999.
1997
Economic
Census.
Manufacturing
Industry
Series,
"
Vitreous
China
Plumbing
Fixture
and
China
and
Earthenware
Bathroom
Accessories
Manufacturing."
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1998
Annual
Survey
of
Manufactures,
M98(
AS)­
1
Statistics
for
Industry
Groups
and
Industries.
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1996
Annual
Survey
of
Manufactures,
M96(
AS)­
1
Statistics
for
Industry
Groups
and
Industries.
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1994
Annual
Survey
of
Manufactures,
M94(
AS)­
1
Statistics
for
Industry
Groups
and
Industries.
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1993
Annual
Survey
of
Manufactures,
M93(
AS)­
1
Statistics
for
Industry
Groups
and
Industries.
U.
S.
Government
Printing
Office.

Table
2­
3.
Production
Costs
for
the
Vitreous
China,
Fine
Earthenware,
and
Other
Pottery
Products
Industry
(
NAICS
327112;
SICs
3262,
3263,
and
3269
)
($
106)

Year
Labor
Costs
Material
Costs
Energy
Costsa
Capital
Expendituresb
1992
$
366.9
$
263.2
$
39.9
$
39.2
1993
$
369.2
$
266.1
$
41.5
$
56.9
1994
$
390.8
$
262.7
$
39.2
$
32.7
1995
$
382.8
$
267.3
$
39.0
$
35.6
1996
$
405.5
$
300.7
$
40.5
NA
1997
$
443.6
$
447.8
$
42.8
$
65.5
1998
$
510.1
$
438.9
$
45.8
NA
Average
$
408.8
$
321.0
$
41.2
$
46.0
Average
Share
of
Value
of
Shipments
1992­
1998
33%
25%
3%
4%

Notes:
a
NAICS
code
327112
corresponds
to
SIC
codes
3262,
3263,
3269,
and
3299
(
Companies
in
SIC
3299
are
not
affected
by
this
NESHAP
and
are
not
discussed
in
this
report).
Costs
in
this
table
were
generated
by
summing
the
costs
incurred
by
industries
classified
by
SIC
codes
3262,
3263,
and
3269
except
for
1997
and
1998
energy
costs,
which
are
given
on
the
basis
of
NAICS
code.
Thus
the
1997
and
1998
energy
cost
figures
includes
the
energy
cost
figures
for
SIC
3299.
2­
9
b
Average
for
Capital
Expenditures
excludes
figure
for
1996
and
1998
due
to
their
unavailability.
Sources:
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999.
1997
Economic
Census.
Manufacturing
Industry
Series,
"
Vitreous
China,
Fine
Earthenware,
and
Other
Pottery
Product
Manufacturing."
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1998
Annual
Survey
of
Manufactures,
M98(
AS)­
1
Statistics
for
Industry
Groups
and
Industries.
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1996
Annual
Survey
of
Manufactures,
M96(
AS)­
1
Statistics
for
Industry
Groups
and
Industries.
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1994
Annual
Survey
of
Manufactures,
M94(
AS)­
1
Statistics
for
Industry
Groups
and
Industries.
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1993
Annual
Survey
of
Manufactures,
M93(
AS)­
1
Statistics
for
Industry
Groups
and
Industries.
U.
S.
Government
Printing
Office.

Similar
trends
can
be
seen
in
the
production
costs
across
these
three
NAICS
codes.
Labor
costs
and
the
costs
of
materials
account
for
larger
shares
of
the
value
of
shipments
(
VOS)
relative
to
energy
costs
and
capital
expenditures.
Both
labor
costs
and
the
costs
of
materials
are
each
well
over
20
percent
of
the
value
of
shipments.
Energy
costs
and
capital
expenditures
are
each
closer
to
5
percent
across
all
three
NAICS
codes.
For
the
ceramic
floor
and
wall
tile
industry
(
NAICS
327122),
material
costs
are,
on
average,
approximately
equal
to
30
percent
of
VOS,
with
labor
costs
following
close
behind
at
25
percent.
For
the
other
two
industries,
labor
costs
make
up
the
largest
share
of
VOS,
followed
by
the
costs
of
materials.
The
1998
VOS
for
the
ceramic
floor
and
wall
tile
industry
is
$
816.9
million.
The
1998
VOS
for
the
plumbing
fixtures
and
bathroom
accessories
industry
is
almost
$
1.2
billion,
and
the
1998
VOS
for
the
vitreous
china,
kitchenware,
and
other
pottery
products
industry
is
close
to
$
1.7
billion.
Based
on
these
figures,
the
ceramic
floor
and
wall
tile
industry
is
the
smallest
of
the
three
while
the
vitreous
china,
kitchenware,
and
other
pottery
products
industry
is
the
largest.

2.1.4
Value
of
Clay
Minerals
All
types
of
clays
are
used
to
produce
ceramic
products.
However,
the
most
common
types
include
ball
clay,
common
clay
and
shale,
and
kaolin.
In
1997,
38
percent
of
all
ceramic
products
were
made
using
ball
clay,
31
percent
were
made
with
common
clay
and
shale,
and
26
percent
consisted
of
kaolin
as
the
main
clay
mineral
input
(
Virta,
1999).
Though
these
three
types
of
clay
are
commonly
used
in
ceramics
manufacturing,
they
generally
are
not
interchangeable
as
inputs
in
the
various
ceramic
products
produced
by
the
industry.
Floor
and
wall
tile
are
produced
mainly
with
common
clay
and
shale,

while
kaolin
dominates
the
fine
china,
kitchenware,
and
dinnerware
markets.
Ball
clay
is
the
predominant
clay
type
used
to
produce
sanitaryware
and
pottery.

Table
2­
4
shows
the
difference
in
values
of
ball
clay,
common
clay
and
shale,
and
kaolin.
The
most
expensive
clay
mineral
is
kaolin
at
an
average
price
of
$
114.42,
followed
far
behind
by
ball
clay
and
common
clay
and
shale,
with
average
prices
of
$
44.63
and
$
5.64,
respectively.
Over
the
1993
to
1997
time
period,
the
price
of
common
clay
and
shale
and
ball
clay
both
increased.
The
price
of
common
clay
and
shale
grew
12
percent
over
this
time
period,
reaching
a
peak
price
of
$
6.08
in
1997.
Ball
clay
also
increased
in
value,
with
a
price
in
1997
that
was
9
percent
higher
than
in
1993
($
46.25
per
metric
ton).

Contrary
to
the
behavior
of
the
values
of
common
clay
and
shale
and
ball
clay,
kaolin
sharply
dropped
in
Table
2­
4.
Price
Value
of
Clay
Minerals
Used
in
Clay
Ceramics
Production:
1993
­
1997
($/
metric
2­
10
ton)

Clay
Minerals
1993
1994
1995
1996
1997
Avg.

Ball
Clay
$
42.26
$
44.02
$
45.82
$
44.81
$
46.25
$
44.63
Common
Clay
&
Shale
$
5.42
$
5.31
$
5.90
$
5.50
$
6.08
$
5.64
Kaolin
$
108.38
$
116.31
$
117.09
$
119.83
$
110.52
$
114.42
Sources:
Virta,
Robert.
1999.
"
Clays,"
In:
Minerals
Yearbook,
Metals
and
Minerals
1997:
Volume
1.
U.
S.
Geological
Survey.
U.
S.
Government
Printing
Office.
Virta,
Robert.
1998.
"
Clays,"
In:
Minerals
Yearbook,
Metals
and
Minerals
1996:
Volume
1.
U.
S.
Geological
Survey.
U.
S.
Government
Printing
Office.
Virta,
Robert.
1997.
"
Clays,"
In:
Minerals
Yearbook,
Metals
and
Minerals
1995:
Volume
1.
U.
S.
Geological
Survey.
U.
S.
Government
Printing
Office.
Virta,
Robert.
1996.
"
Clays,"
In:
Minerals
Yearbook,
Metals
and
Minerals
1994:
Volume
1.
U.
S.
Geological
Survey.
U.
S.
Government
Printing
Office.

value
in
1997.
The
value
of
kaolin
steadily
increased
until
it
reached
a
peak
of
$
119.83
in
1996,
but
in
1997
the
price
fell
to
$
110.52.

2.2
Uses,
Consumers,
and
Substitutes
Clay
minerals
are
the
main
input
used
to
produce
ceramic
products.
These
products
include
floor
and
wall
tile,
fine
china
and
kitchenware,
pottery
products,
and
bathroom
accessories
and
sanitaryware.

Some
of
these
products
are
final
goods,
such
as
dinnerware,
kitchenware,
pottery,
and
fine
china,
that
are
purchased
and
used
by
the
same
consumer.
Other
products,
such
as
sanitaryware
and
ceramic
floor
and
wall
tile,
may
be
purchased
by
contractors
and
construction
companies
and
used
as
inputs
to
build
different
types
of
structures,
including
homes,
buildings,
and
office
facilities.
The
following
section
describes
the
uses,
consumers,
and
substitutes
of
ceramic
products.
In
Section
2.2.1,
the
various
uses
for
ceramic
products
are
described.
Section
2.2.2
identifies
the
intermediate
and
final
consumers
of
ceramic
products.
Last,
the
different
products
that
can
act
as
substitutes
for
ceramic
products
are
described
in
Section
2.2.3.

2.2.1
Uses
of
Ceramic
Products
The
various
types
of
ceramic
products
can
be
categorized
based
on
their
end
use.
Kitchenware,

dinnerware,
fine
china,
and
some
forms
of
pottery
are
products
used
for
food
preparation,
storage,
and
service.
Kitchenware
includes
containers,
canisters,
and
other
kitchen
"
hardware"
used
for
food
storage
and
preparation,
while
dinnerware
refers
to
the
plates,
bowls,
cups,
saucers,
and
other
ceramic
dishes
used
for
food
service.
Fine
china
is
a
more
expensive
form
of
dinnerware.
Ceramic
floor
and
wall
tile,

bathroom
accessories
(
i.
e.,
fixtures,
towel
racks,
and
soap
dishes),
and
sanitaryware
(
i.
e,
toilets
and
sinks)

are
used
in
the
construction
of
homes,
buildings,
and
structures,
however
these
product
types
have
very
different
functions.
Floor
and
wall
tile
serve
a
decorative
purpose
and
are
used
to
add
character
to
homes
and
buildings.
Sanitaryware
and
bathroom
accessories
are
products
installed
in
bathrooms
and
are
primarily
used
for
cleansing.
In
the
case
of
sinks,
they
also
are
installed
in
kitchens.
2­
11
Floor
and
Wall
T
ile
28%

Sanitaryware
and
Bathroom
Accessories
30%
Kitchenware,
Fine
China,
and
Tableware
17%
Pottery
Products
16%
Other
9%

1997
Valu
e
of
Product
Shipments
=
$
3.24
billion
Figure
2­
2.
Distribution
of
Clay
Ceramic
Products
by
End
Use:
1997
Sources:
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999.
1997
Economic
Census.
Manufacturing
Industry
Series,
"
Ceramic
Wall
and
Floor
Tile."
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999.
1997
Economic
Census.
Manufacturing
Industry
Series,
"
Vitreous
China
Plumbing
Fixture
and
China
and
Earthenware
Bathroom
Accessories
Manufacturing."
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999.
1997
Economic
Census.
Manufacturing
Industry
Series,
"
Vitreous
China,
Fine
Earthenware,
and
Other
Pottery
Product
Manufacturing."
U.
S.
Government
Printing
Office.

There
is
a
common
characteristic
across
the
various
ceramic
products,
even
though
they
have
differing
functions.
All
are
durable,
heat
resistant,
waterproof,
and
most
importantly,
resistant
to
germs
and
contamination.
These
features
are
particularly
important
for
products
that
come
into
contact
with
food
and
those
that
are
used
for
washing
and
cleaning.
Recently,
there
has
been
rising
concern
about
salmonella,
e.
coli,
and
other
forms
of
bacteria
that
may
be
present
in
uncooked
poultry
and
meat.
Since
kitchenware
and
dinnerware
are
used
to
prepare
and
serve
food,
it
is
important
they
do
not
become
permanently
contaminated.
Glazed
ceramic
products
such
as
kitchenware
and
dinnerware
can
be
thoroughly
cleaned
using
hot
water
and
soap
without
affecting
the
integrity
of
the
product.
It
also
is
important
for
sinks
and
toilets
to
possess
the
above
mentioned
characteristics
since
these
products
come
into
contact
with
a
number
of
germs.
These
products
are
used
for
washing,
and
it
is
imperative
that
they
are
water
resistant.

Census
data
provide
the
1997
values
of
select
clay
ceramic
products
produced
by
NAICS'

327111,
327112,
and
327122.
As
Figure
2­
2
shows,
the
value
of
sanitaryware
and
bathroom
accessories
represents
30
percent
($
982.7
million)
of
the
total
value
of
product
shipments
for
selected
output
2­
12
produced
by
the
clay
ceramics
manufacturing
industry
($
3.24
billion).
Ceramic
floor
and
wall
tile
also
represents
a
relatively
large
share
(
28
percent)
of
the
value
of
product
shipments
at
$
890.9
million.
The
value
of
kitchenware,
fine
china,
and
tableware
products
used
for
serving
and
cooking
food
is
equal
to
$
542.6
million,
or
17
percent
of
the
total
value
of
product
shipments
while
the
value
of
pottery
products
is
equal
to
$
521
million
(
16
percent).
The
other
end
products,
which
include
technical
ceramics,

unglazed
earthenware,
and
other
ceramic
products
not
elsewhere
specified
account
for
the
remaining
9
percent
of
the
overall
value
of
product
shipments.

2.2.2
Consumers
of
Clay
Ceramic
Products
Some
ceramic
products
are
purchased
directly
by
the
final
consumer.
These
products
include
kitchenware,
fine
china,
and
pottery.
Consumers
generally
purchase
pottery
for
decorative
purposes,

although
some
types
of
pottery
are
also
used
for
food
preparation
and
presentation.
Kitchenware
and
fine
china
also
are
purchased
by
consumers
to
facilitate
food
preparation
and
consumption.
Fine
china
is
more
expensive
than
dinnerware
and
typically
is
used
for
special
meals,
while
standard
dinnerware
is
designed
for
daily
dining.

Other
ceramic
products,
such
as
sanitaryware,
bathroom
accessories,
and
floor
and
wall
tile
are
purchased
by
construction
companies
to
be
used
as
inputs
to
the
production
of
homes,
buildings,
and
office
facilities.
Once
these
structures
are
built,
consumers
then
purchase
these
structures
from
the
construction
companies.
However,
if
consumers
build
homes
or
make
improvements
to
existing
structures
themselves,
they
may
directly
purchase
and
install
sanitaryware,
bathroom
accessories,
and
ceramic
tiles.

Though
ceramic
floor
and
wall
tile,
sanitaryware,
bathroom
accessories,
pottery,
dinnerware,
and
kitchenware
are
all
made
using
clay
minerals,
there
are
noticeable
price
differences
across
these
products.

For
example,
ceramic
tiles
tend
to
be
relatively
inexpensive
while
china
and
fancy
dinnerware
tend
to
cost
more.
These
differences
in
price
are
based
on
a
number
of
factors
including
the
operating
cost
of
capital,
the
level
of
skill
and
amount
of
labor
used
in
production,
and
the
cost
of
inputs
used
to
produce
the
various
ceramic
products
such
as
the
type
of
clay
minerals,
additives,
and
decorative
coatings.

2.2.3
Substitutes
for
Clay
Ceramic
Products
Clay
is
just
one
of
many
materials
that
can
be
used
to
produce
kitchenware,
dinnerware,

sanitaryware,
bathroom
accessories,
and
home
decorations.
Kitchen
storage
containers,
dishes,
and
other
miscellaneous
kitchenware
are
available
in
glass,
metal,
and
plastic.
Plastic
is
a
relatively
inexpensive
material
used
to
manufacture
different
quality
grades
of
kitchenware
and
dinnerware.
Plastic
plates,

bowls,
and
cups
can
be
made
of
relatively
sturdy
plastic
for
repeated
use
or
they
can
be
made
with
lower
quality
plastic
so
they
can
be
disposed
of
after
one
time
usage.
Consumers
often
purchase
plastic
dinnerware
because
of
its
convenience.
In
addition
to
plastic,
inexpensive
paper
or
Styrofoam
dinnerware
also
is
available.

Bathroom
accessories
such
as
soap
dishes,
towel
racks,
toothbrush
holders,
and
faucet
fixtures
come
in
an
array
of
materials,
including
plastic,
brushed
or
polished
metal,
and
glass.
Consumers
usually
2­
13
base
their
choice
of
bathroom
accessories
on
their
specific
tastes
and
the
type
of
look
they
want
to
create
as
they
decorate
the
bathroom.
Generally
plastic
accessories
are
relatively
inexpensive,
though
when
higher
quality
plastics
are
used,
producers
can
charge
prices
in
the
same
range
as
those
for
bathroom
accessories
made
from
glass,
ceramics,
or
metal.

Clay
is
the
most
common
material
used
for
the
manufacture
of
sanitaryware,
but
sinks
and
toilets
can
also
made
out
of
stainless
or
enameled
steel,
fiberglass,
or
enameled
cast
iron.
These
materials
all
possess
similar
characteristics
to
ceramic
sanitaryware,
but
to
differing
degrees.
For
example,
steel
may
less
subject
to
cracking
than
ceramic
material,
however
it
is
not
as
heat
resistant.
Another
material
used
to
produce
sanitaryware
is
marble,
which
is
one
of
the
most
expensive
materials
available
for
sanitaryware
production.

2.3
Industry
Organization
This
report
addresses
the
economic
impacts
of
pollution
control
requirements
on
facilities
included
in
the
clay
ceramics
manufacturing
source
category.
Though
existing
sources
at
facilities
in
this
source
category
face
no
compliance
costs
to
meet
the
MACT
floor,
facilities
will
be
required
to
control
their
releases
of
HAPs
from
new
kilns.
For
this
reason,
it
is
important
to
understand
the
existing
organization
of
the
clay
ceramics
industry
at
both
the
facility­
level
and
the
company­
level.
This
section
of
the
EIA
will
focus
specifically
on
the
sanitaryware
and
bathroom
accessories
producers
and
the
ceramic
floor
and
wall
tile
producers
since
these
are
the
facilities
that
are
included
in
the
clay
ceramics
manufacturing
source
category.
Section
2.3.1
first
provides
an
overview
of
the
market
structure
of
the
clay
ceramics
manufacturing
industry.
Section
2.3.2
characterizes
the
manufacturing
facilities
in
the
source
category,
while
the
parent
companies
of
these
facilities
are
described
in
2.3.3.
Last,
Section
2.3.4
provides
data
on
domestic
production,
foreign
trade,
and
apparent
consumption
of
clay
ceramic
products
.

2.3.1
Market
Structure
Market
structure
is
of
interest
because
it
determines
the
behavior
of
producers
and
consumers
in
the
industry.
In
perfectly
competitive
industries,
no
producer
or
consumer
is
able
to
influence
the
price
of
the
product
sold.
In
addition,
producers
are
unable
to
affect
the
price
of
inputs
purchased
for
use
in
production.
This
condition
is
most
likely
to
hold
if
the
industry
has
a
large
number
of
buyers
and
sellers,

the
products
sold
and
inputs
used
in
production
are
homogeneous,
and
entry
and
exit
of
firms
is
unrestricted.
Entry
and
exit
of
firms
are
unrestricted
for
most
industries,
except
in
cases
where
the
government
regulates
who
is
able
to
produce
output,
where
one
firms
holds
a
patent
on
a
product,
where
one
firm
owns
the
entire
stock
of
a
critical
input,
or
where
a
single
firm
is
able
to
supply
the
entire
market.
In
industries
that
are
not
perfectly
competitive,
producer
and/
or
consumer
behavior
can
have
an
effect
on
price.

Concentration
ratios
(
CRs)
and
the
Herfindahl­
Hirschman
index
(
HHI)
can
provide
some
insight
into
the
competitiveness
of
an
industry.
The
U.
S.
Census
Bureau
reports
these
ratios
and
indices
for
the
four­
digit
SIC
code
level
for
1992,
the
most
recent
year
available.
Table
2­
5
provides
the
four­
and
eight­
firm
concentration
ratios
(
CR4
and
CR8,
respectively)
and
the
Herfindahl­
Hirschman
index
for
all
2­
14
of
the
SIC
codes
that
characterize
the
clay
ceramics
industry.
Particular
attention
should
be
given
to
the
measures
for
SIC
3253,
the
ceramic
floor
and
wall
tile
industry,
and
SIC
3261,
the
vitreous
china
plumbing
fixtures
and
bathroom
accessories
industry,
since
facilities
operated
by
companies
in
these
industries
are
included
in
the
clay
ceramics
manufacturing
source
category
addressed
by
this
NESHAP.

The
CR4
is
lowest
for
SIC
3269
(
pottery
products,
not
elsewhere
specified
[
n.
e.
c.])
at
25
percent
and
highest
for
SIC
3262
(
vitreous
china
table
and
kitchen
articles)
and
SIC
3263
(
fine
earthenware
table
and
kitchen
articles)
at
81
percent
and
85
percent,
respectively.
The
lowest
CR8
measure
is
again
for
SIC
3269,
but
is
highest
for
SIC
3261
(
vitreous
china
plumbing
fixtures
and
china
and
earthenware
fittings
and
bathroom
accessories).
A
general
examination
of
the
table
shows
that
the
CRs
for
SIC
3269
are
relatively
small
and
those
for
SICs
3262
and
3263
are
relatively
large.
The
ratios
for
SIC
3253
are
smaller
than
those
for
SIC
3261.

The
criteria
for
evaluating
the
HHIs
are
based
on
the
1992
Department
of
Justice's
Horizontal
Merger
Guidelines.
According
to
these
criteria,
industries
with
HHIs
below
1,000
are
considered
unconcentrated
(
i.
e.,
more
competitive),
those
with
HHIs
between
1,000
and
1,800
are
considered
moderately
concentrated
(
i.
e.,
moderately
competitive),
and
those
with
HHIs
above
1,800
are
considered
highly
concentrated
(
i.
e.,
less
competitive).
In
general,
firms
in
less
concentrated
industries
are
more
likely
to
be
price
takers,
while
those
in
more
concentrated
industries
have
more
ability
to
influence
market
prices.
Based
on
these
criteria,
SIC
3253
is
moderately
competitive
and
SICs
3261
and
3262
are
highly
concentrated.
A
low
Table
2­
5.
Market
Concentration
Measures
for
the
Clay
Ceramics
Manufacturing
Industry
SIC
Codes:
1992
SIC
Code
Value
of
Shipments
($
106)
CR4
CR8
HHI
3253
$
731.3
59%
75%
1217
3261
$
902.1
71%
94%
1923
3262
$
315.6
81%
92%
2470
3263
$
45.2
85%
92%
NA
3269
$
669.4
25%
35%
273
Notes:
CR4
and
CR8
are
the
concentration
ratios
of
the
top
4
and
8
firms
in
the
industry
(
by
sales),
respectively.
HHI
refers
to
the
Herfindahl­
Hirschman
Index,
which
is
the
sum
of
the
squared
market
shares
of
each
company
in
a
given
industry.
Source:
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
2000.
1992
Concentration
Ratios
in
Manufacturing.
<
http://
www.
census.
gov/
epcd/
www/
concentration.
html>.

HHI
is
calculated
for
SIC
3269,
indicating
it
is
highly
competitive
and
no
HHI
is
available
for
SIC
3263.

2.3.2
Manufacturing
Facilities
As
of
1997,
there
were
58
facilities
in
the
clay
ceramics
manufacturing
source
category.
Of
these
2­
15
58
facilities,
32
manufacture
floor
and
wall
tile
while
the
remaining
26
manufacture
sanitaryware.

Regardless
of
what
type
of
product
the
facility
produces,
it
can
be
classified
as
either
one
of
two
types
of
facilities:
non­
integrated
producers
and
integrated
producers.
Non­
integrated
producers
purchase
clay
mineral
inputs
to
use
in
production
and
they
focus
on
the
manufacture
of
final
goods,
in
this
case
ceramic
tile
or
sanitaryware.
Integrated
producers
are
vertically
integrated,
which
means
they
mine
their
own
clay
mineral
inputs
to
use
in
the
production
of
their
final
products.

The
size
of
facilities
depends
on
whether
they
are
non­
integrated
or
integrated
producers.
Plants
that
perform
their
own
mining
operations
tend
to
be
larger
in
size
than
those
that
purchase
their
own
inputs
from
a
minerals
processing
plant.
Even
if
facilities
are
non­
integrated
producers,
it
is
likely
that
they
are
located
near
sources
of
clay
minerals
so
that
the
transportation
costs
of
this
essential
input
remains
low.
Thus,
the
locations
of
the
58
facilities
are
determined
by
the
location
of
clay
mineral
deposits.
These
facilities
are
located
across
22
states
with
the
highest
concentrations
in
Texas
with
22
facilities,
Ohio
with
7
facilities,
and
Pennsylvania
with
5
facilities.

2.3.3
Firm
Characteristics
The
Agency
identified
28
ultimate
parent
companies
that
owned
and
operated
the
58
potentially
affected
facilities
within
this
source
category
in
the
year
1997.
Sales
and
employment
data
were
obtained
for
these
owning
entities
from
either
their
survey
response
or
one
of
the
following
secondary
sources:

°
Dun
&
Bradstreet
Market
Identifiers
(
Dun
&
Bradstreet,
1999)

°
Moody's
Corporate
Profiles
(
Moody's
Investors
Service,
1999)

°
Standard
&
Poor's
Register­
Corporate
(
Standard
&
Poor's
Corp.,
1998)

°
Ward's
Business
Directory
(
Gale
Group,
1997)

Appendix
A
provides
a
listing
of
these
29
companies
identified
by
the
Agency
as
owning
the
potentially
affected
clay
ceramics
manufacturing
facilities.

Annual
sales
and
employment
data
were
available
for
27
of
the
28
companies
(
97
percent).
The
average
(
median)
sales
of
companies
with
companies
reporting
data
were
$
507.6
million
($
24.1
million).

This
includes
revenues
from
operations
other
than
tile
and
sanitaryware
production.
The
average
(
median)
employment
for
these
companies
was
4,852
(
550)
workers.
As
of
1997,
the
four
largest
companies
based
on
annual
sales
are:

°
American
Standard
Companies,
Inc.
­
$
6.7
billion
with
57,000
employees;

°
Premark
International,
Inc.
­
$
2.4
billion
with
17,200
employees;

°
U.
S.
Industries,
Inc.
­
$
2.3
billion
with
23,000
employees;
and
°
Kohler
Co.,
Inc.
­
$
1.1
billion
with
18,000
employees.

The
average
(
median)
company
sales
and
employment
were
also
calculated
for
the
companies
that
own
sanitaryware
manufacturing
facilities
and
those
that
own
ceramic
floor
and
wall
tile
manufacturing
facilities.
As
Table
4­
6
shows,
companies
that
own
and
operate
sanitaryware
manufacturing
facilities
are
much
larger,
based
both
on
annual
sales
and
employment
figures.
The
average
sales
of
companies
that
own
sanitaryware
facilities
is
almost
ten
times
larger
than
the
sales
of
those
owning
floor
and
wall
tile
facilities.
The
difference
in
the
average
number
of
employees
is
on
the
same
scale.
An
examination
of
the
median
values
of
sales
and
employment
confirm
that
companies
that
produce
sanitaryware
are
much
2­
16
larger
than
those
that
produce
tile,
though
median
values
are
an
order
of
magnitude
smaller
than
the
mean
values
of
sales
and
employment.

Another
way
these
companies
can
be
grouped
is
into
small
and
large
categories
using
Small
Business
Administration
general
size
standard
definitions
for
NAICS
codes.
These
definitions
are
based
on
either
annual
sales
or
employment
of
owning
entities.
Responses
by
the
facilities
in
the
clay
ceramics
manufacturing
source
category
indicate
that
there
are
four
different
NAICS
codes
represented
with
a
small
business
definition
range
from
500
to
750
employees.
Based
on
the
SBA
definitions,
the
Agency
identified
13
companies
owning
facilities
that
produce
sanitaryware
or
ceramic
floor
and
wall
tile
as
small
(
46.4
percent)
and
15
as
large
(
53.6
percent).
One
company
for
which
no
annual
sales
or
employment
data
were
available
was
assumed
to
be
small.
Section
4
further
details
the
small
business
analysis
conducted
to
determine
if
small
businesses
might
potentially
be
impacted
by
this
rule.

Table
2­
6.
Average
and
Median
Company
Sales
and
Employment
Based
on
Manufacturing
Facility
Ownership
($
106):
1997
Facility
Type
Company
Sales
Average
Median
Company
Employment
Average
Median
Sanitaryware
$
1,230.6
$
140.0
11,805
1,500
Floor
and
Wall
Tile
$
164.3
$
7.8
1,559
110
2.3.4
Market
Data
and
Trends
This
section
focuses
on
historical
market
data
for
the
ceramic
floor
and
wall
tile
industry
(
SIC
3253)
and
the
vitreous
china
plumbing
fixtures
segment
of
the
vitreous
china
plumbing
fixtures
and
bathroom
accessories
industry
(
SIC
3261).
Detailed
market
data
for
SIC
3261
in
its
entirety
and
the
remaining
SIC
codes
were
unavailable.
Tale
2­
7
presents
the
quantity
of
shipments,
foreign
trade,
and
apparent
consumption
for
the
ceramic
floor
and
wall
tile
industry
and
Table
2­
8
presents
the
values
of
shipments,
trade,
and
apparent
consumption
for
vitreous
china
plumbing
fixtures.
2­
17
Table
2­
7.
Historical
Data
for
the
Ceramic
Wall
and
Floor
Tile
Industry
(
SIC
3253)
(
106
square
feet):
1995­
1999
Year
Quantity
of
Shipments
Exportsa
Imports
Apparent
Consumptionb
1995
580.8
0
774.3
1,355.1
1996
575.8
0
883.7
1,459.5
1997
626.7
42.4
1,022.5
1,606.8
1998
621.0
41.6
1,232.5
1,441.9
1999
624.8
30.7
1,493.5
2,087.1
Average
Annual
Growth
Rates
1995­
1999
1.9%
­
14.0%
17.9%
14.0%

Notes:
a
Exports
for
1995
and
1996
were
reported
as
`
Not
applicable'
by
the
Census
Bureau.
It
is
therefore
assumed
that
exports
of
ceramic
floor
and
wall
tile
were
equal
to
zero
for
these
years.
b
Value
of
apparent
consumption
is
derived
by
subtracting
exports
from
manufacturers'
shipments
plus
value
of
imports.
Sources:
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
2000.
Current
Industrial
Reports
for
Clay
Construction
Products
­
Summary
1999.
MQ32D(
99)­
5.
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1998.
Current
Industrial
Reports
for
Clay
Construction
Products
­
Summary
1997.
MQ32D(
97)­
5
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1997.
Current
Industrial
Reports
for
Clay
Construction
Products
­
Summary
1995.
MQ32D(
95)­
5
U.
S.
Government
Printing
Office.

As
Table
2­
7
shows,
both
production
and
apparent
consumption
of
ceramic
floor
and
wall
tile
have
increased
since
the
mid
1990s.
This
is
evident
from
an
examination
of
the
average
annual
growth
rates.
Production
quantities
of
ceramic
tile
oscillated
slightly
year
to
year
by
increasing
one
year
and
then
decreasing
the
next.
However,
in
1997
production
increased
by
almost
9
percent.
Apparent
consumption
also
increased
each
year,
with
an
average
annual
growth
rate
of
14
percent.
The
U.
S.

exports
relatively
small
amounts
of
ceramic
tile,
and
U.
S.
imports
have
exceeded
the
amount
of
tile
produced
domestically
each
year
since
1995.
In
addition,
the
amount
of
ceramic
tile
that
is
imported
has
increased
over
the
1995
to
1999
time
period.
The
average
annual
growth
rate
of
ceramic
tile
imports
is
almost
18
percent.

The
historical
data
presented
in
Table
2­
8
captures
the
value
of
production,
trade,
and
apparent
consumption
of
vitreous
china
plumbing
fixtures,
which
includes
drinking
fountains,
lavatories,
bathtubs,

flush
tanks,
and
sinks.
Examination
of
the
data
show
positive
average
annual
growth
of
the
values
of
production,
imports,
and
consumption
over
the
1995
to
1999
time
period.
Exports
of
sanitaryware
from
the
U.
S.
showed
a
net
decrease
through
the
mid
to
late
1990s.
A
closer
look
at
Table
2­
8
shows
that
the
values
of
shipments,
trade,
and
apparent
consumption
were
all
relatively
high,
but
that
they
all
decreased
in
1996.
Production
values,
imports,
and
consumption
all
steadily
rose
from
this
point
on.
Export
values,
however,
increased
by
almost
17
percent
in
1997,
but
then
steadily
declined
in
each
subsequent
year.
3­
1
Table
2­
8.
Historical
Data
for
Vitreous
China
Plumbing
Fixtures
($
106):
1995
­
1999
Year
Value
of
Shipments
Value
of
Exports
Value
of
Imports
Value
of
Apparent
Consumptiona
1995
$
891.9
$
61.1
$
71.2
$
901.2
1996
$
859.7
$
58.5
$
64.8
$
866.0
1997
$
876.8
$
68.4
$
50.5
$
858.9
1998
$
883.7
$
65.7
$
68.0
$
886.1
1999
$
932.2
$
57.5
$
101.6
$
976.3
Average
Annual
Growth
Rates
1995­
1999
1.2%
­
0.9%
13.3%
2.1%

Notes:
a
Value
of
apparent
consumption
is
derived
by
subtracting
exports
from
manufacturers'
shipments
plus
value
of
imports.
Sources:
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
2000.
Current
Industrial
Reports
for
Plumbing
Fixtures
­
Summary
1999.
MQ332E(
99)­
5.
U.
S.
Government
Printing
Office.
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1998.
Current
Industrial
Reports
for
Plumbing
Fixtures
­
Summary
1997.
MQ34E(
97)­
5.
U.
S.
Government
Printing
Office
The
small
quantities
of
ceramic
tile
exports
and
the
negative
average
annual
growth
of
the
exports
of
vitreous
china
plumbing
fixtures
show
that
the
U.
S.
is
not
a
large
exporter
of
ceramic
products.
In
addition,
the
U.
S.
does
not
import
a
large
amount
of
plumbing
fixtures
relative
to
its
production
of
these
products,
though
plumbing
fixture
imports
values
do
exceed
their
export
values.
The
U.
S.
does,

however,
import
a
relatively
large
amount
of
ceramic
tile.

3
ENGINEERING
COST
ANALYSIS
Production
of
ceramic
tile
and
sanitaryware
results
in
emissions
of
HAPs
from
the
kilns
used
in
the
production
process.
For
this
NESHAP,
the
MACT
floor
faced
by
existing
major
sources
(
in
this
case,

kilns)
in
the
clay
ceramics
manufacturing
source
category
requires
no
control
of
their
HAP
emissions.

New
sources
will,
however,
be
subject
to
emissions
standards
developed
under
the
authority
of
Section
112
of
the
CAA.
Facilities
with
new
kilns
will
be
required
to
control
their
HAP
emissions
through
the
installation
and
operation
of
dry
injection
fabric
filters
(
DIFFs),
dry
lime
scrubber/
fabric
filters
(
DLSs),

wet
scrubbers
(
WSs),
or
equivalent
control.
This
section
describes
the
development
of
compliance
cost
estimates
for
projected
new
clay
ceramics
manufacturing
sources
associated
with
this
NESHAP.
Section
3.1
discusses
the
types
of
new
kilns
that
are
projected
for
this
source
category
and
Section
3.2
describes
the
estimated
costs
of
controlling
the
HAP
emissions
from
these
new
kilns.

3.1
Projected
New
Kilns
The
Agency
projects
one
new
kiln
to
begin
operation
in
the
clay
ceramics
manufacturing
source
category
during
the
five
year
period
following
the
promulgation
of
this
NESHAP
(
by
the
end
of
the
year
2007).
The
projected
kiln
is
a
4
tph
tunnel
kiln
projected
to
be
used
for
sanitaryware
production.
4­
1
3.2
Costs
of
Control
This
section
provides
the
estimated
costs
of
installing
and
operating
DIFFs
on
4
tph
tunnel
kilns.

The
cost
of
DIFFs
varies
based
on
the
size
and
the
type
of
kiln
upon
which
it
will
be
installed.
Table
3­
1
summarizes
the
total
and
annualized
capital
costs,
operating
and
maintenance
expenses,
and
total
annual
costs
for
DIFF
by
kiln
type,
based
on
the
Agency's
projection
of
the
one
kiln
that
will
begin
operation
during
the
five
year
period
subsequent
to
the
promulgation
of
this
NESHAP.
Though
all
new
sources
in
the
clay
ceramics
manufacturing
source
category
will
be
subject
to
the
NESHAP
and
may
choose
to
operate
DIFFs
to
control
their
HAP
emissions,
Table
3­
1
focuses
on
the
installation
of
DIFFs
on
the
specific
kiln
projected
to
begin
operation
in
this
source
category.

Table
3­
1.
New
Source
Compliance
Costs
of
the
Clay
Ceramics
Manufacturing
NESHAP
($
103)

Model
Kiln
Total
Capital
Annualized
Capitala
Annual
O&
M
Annual
MRR
Total
Annualized
b
Cost
Tunnel
(
4
tph)
Sanitaryware
$
750
$
107
$
217
$
12.6
$
340
Notes:
a
Total
capital
costs
are
annualized
over
10
years
at
7
percent.
b
Sum
of
annual
capital,
annual
O&
M,
and
annual
MRR
costs;
rounded
to
the
nearest
10th
digit.
Source:
U.
S.
Environmental
Protection
Agency.
November
21,
2002.
"
Economic
Inputs
­
Brick
and
Structural
Clay
Products
Manufacturing
and
Clay
Ceramics
Manufacturing
NESHAP",
Memorandum
from
Brian
Shrager,
Midwest
Research
Institute,
to
Mary
Johnson,
EPA,
Emissions
Standards
Division.

4
ECONOMIC
IMPACT
ANALYSIS
In
the
economic
impact
analysis,
the
Agency
typically
examines
how
facilities
will
directly
(
through
the
imposition
of
compliance
costs)
or
indirectly
(
through
a
change
in
market
prices)
affect
the
entire
U.
S.
industry.
Generally
speaking,
the
implementation
of
a
proposed
rule
will
increase
the
costs
of
production
at
affected
plants.
These
costs
will
vary
across
facilities
depending
on
their
physical
characteristics,
baseline
controls,
and
the
regulatory
standards
that
are
set.
The
response
by
producers
to
these
additional
costs
determine
the
economic
impacts
of
the
regulation.
Specifically,
the
cost
of
the
regulation
may
induce
some
owners
to
change
their
current
operating
rates
or
to
close
their
operations.

These
choices,
affect,
and
in
turn
are
affected
by,
the
market
prices
for
the
products
manufactured
by
the
affected
facilities.

For
this
regulation,
the
MACT
floor
faced
by
existing
kilns
at
ceramic
tile
and
sanitaryware
facilities
is
a
control
technology
that
already
exists
at
all
major
sources
and
sime
minor
costs
will
be
incurred
by
existing
sources
to
document
compliance
with
the
standard.
The
total
compliance
costs
for
existing
sources
are
approximately
$
9,500,
which
represents
a
negligible
impact
on
the
industry
(
i.
e.,

0.001
percent
of
total
industry
revenues).
With
the
negligible
impact
on
industry
revenues,
it
is
unlikely
prices
will
rise
in
the
industry.
Therefore,
affected
producers
are
expected
to
absorb
the
compliance
costs
as
a
component
of
their
production
costs.
The
change
in
production
costs,
however,
is
expected
to
be
minimal.
The
new
kiln
that
is
added
to
the
clay
ceramics
manufacturing
source
category
is
required
to
control
their
emissions
of
HAPs.
The
Agency
has
projected
the
addition
of
one
kilns
to
the
ceramic
1
For
the
ceramic
floor
and
wall
tile
industry,
the
average
annual
growth
rate
of
VOS
over
the
1992
to
1998
time
period
was
2.3
percent
(
calculated
using
VOS
data
from
U.
S
Bureau
of
the
Census,
Annual
Survey
of
Manufactures).
This
growth
rate
was
then
applied
to
the
1999
VOS
of
$
843.03
million
(
1999
VOS
retrieved
from
U.
S
Bureau
of
the
Census,
2000,
Current
Industrial
Reports
for
Clay
Construction
Products
­
Summary
1999).
For
the
sanitaryware
industry,
the
average
annual
growth
rate
of
VOS
for
the
same
time
period
was
higher
at
4.9
percent
(
also
calculated
using
VOS
data
from
U.
S.
Bureau
of
the
Census,
Annual
Survey
of
Manufactures).
This
was
applied
to
the
1998
VOS
of
$
1,199.10
million
(
1998
VOS
retrieved
from
U.
S.
Bureau
of
the
Census,
Annual
Survey
of
Manufactures,
2000).

4­
1
source
category
within
the
five
years
following
promulgation
as
mentioned
in
Section
3.
Section
4.1
of
this
report
will
describe
the
anticipated
the
industry
impacts
due
to
the
addition
of
the
new
kiln
while
Section
4.2
will
demonstrate
the
impacts
at
the
source
level.

4.1
Industry­
level
Impacts
To
examine
the
projected
impact
of
compliance
costs
associated
with
the
new
source
on
the
ceramic
tile
and
sanitaryware
industries,
a
screening
analysis
is
conducted
to
compare
the
annual
industry
compliance
costs
to
the
future
industry
value
of
shipments
(
VOS)
for
each
of
these
clay
ceramics
industries.
The
analysis
takes
place
using
year
2007
projections
of
VOS
because
the
new
kiln
is
expected
to
be
in
operation
within
the
five
year
period
following
the
promulgation
of
this
regulation.
A
ratio
of
industry
compliance
costs
to
the
value
of
shipments
provides
an
indication
of
the
share
that
costs
represent
of
the
total
value
of
output
produced.
To
project
the
VOS
in
the
year
2007,
the
average
annual
growth
rate
of
the
VOS
for
each
industry
was
applied
to
the
latest
VOS
estimate
available
to
estimate
the
value
of
shipments
for
the
year
2007.1
As
Table
4­
1
shows,
the
total
annual
compliance
costs
of
the
new
sanitaryware
kiln
are
equal
to
$
340,000
and
the
projected
year
2007
VOS
for
this
industry
is
close
to
$
1.84
billion.
The
share
of
compliance
costs
to
VOS
for
the
sanitaryware
industry
is
also
less
than
0.01
percent.
These
ratios
provide
evidence
showing
that
at
the
industry
level,
the
total
annual
compliance
costs
associated
with
this
rule
are
not
expected
to
lead
to
a
price
increase
for
sanitaryware
products.

Table
4­
1.
Cost­
to­
Sales
Ratios
Vitreous
China
Plumbing
Fixtures
and
Bathroom
Accessories
Industry
(
NAICS
327111;
SIC
3261)

Industry
Total
Annual
Costs
($
103)
2007
Projected
VOS
($
103)
Cost­
to­
Sales
Ratio
Sanitaryware
$
340
$
1,844,000
0.01
%

4.2
Source­
level
Impacts
5­
1
Though
no
change
in
either
ceramic
tile
or
sanitaryware
market
prices
are
expected
to
occur
from
this
rule
affecting
new
clay
ceramics
manufacturing
kilns,
it
may
be
the
case
that
this
regulation
may
delay
the
introduction
of
these
projected
kilns
into
their
respective
industries.
To
examine
this
potential
impact
of
the
proposed
MACT
standard,
a
ratio
of
kiln
compliance
costs
to
projected
kiln
sales
can
be
estimated.

If
the
costs
of
controlling
the
kiln
represent
a
significant
share
of
the
revenues
generated
from
the
sale
of
products
produced
using
the
affected
kiln,
a
facility
may
choose
to
delay
the
operation
of
these
new
sources.
The
total
compliance
costs
for
existing
sources
are
approximately
$
9,500,
which
represents
a
negligible
impact
on
the
industry
(
i.
e.,
0.001
percent
of
total
industry
revenues).

5
SMALL
BUSINESS
ANALYSIS
The
Regulatory
Flexibility
Act
(
RFA)
of
1980
requires
that
special
consideration
be
given
to
small
entities
affected
by
federal
regulation.
The
RFA
was
amended
in
1996
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
(
SBREFA)
to
strengthen
the
RFA's
analytical
and
procedural
requirements.

Prior
to
enactment
of
SBREFA,
EPA
exceeded
the
requirements
of
the
RFA
by
requiring
the
preparation
of
a
regulatory
flexibility
analysis
for
every
rule
that
would
have
any
impact,
no
matter
how
minor,
on
any
number,
no
matter
how
small,
of
small
entities.
Under
SBREFA,
however,
the
Agency
decided
to
implement
the
RFA
as
written
and
that
a
regulatory
flexibility
analysis
will
be
required
only
for
rules
that
will
have
a
significant
impact
on
a
substantial
number
of
small
entities.

A
small
business
analysis
is
conducted
to
determine
if
a
regulatory
action
will
potentially
affect
the
economic
welfare
of
owners
of
the
potentially
affected
facilities.
The
ownership
of
these
facilities
ultimately
falls
on
private
individuals
who
may
be
owner/
operators
that
directly
conduct
the
business
of
the
firm
(
i.
e.,
"
mom
and
pop
shops"
or
partnerships)
or,
more
commonly,
investors
or
stockholders
that
employ
others
to
conduct
the
business
of
the
firm
on
their
behalf
(
i.
e.,
privately­
held
or
publicly­
traded
corporations).
The
individuals
or
agents
that
manage
these
facilities
have
the
capacity
to
conduct
business
transactions
and
make
business
decisions
that
affect
the
facility.
The
legal
and
financial
responsibility
for
compliance
with
a
regulatory
action
ultimately
rests
with
these
agents;
however,
the
owners
must
bear
the
financial
consequences
of
the
decisions.
Environmental
regulations
like
this
rule
potentially
affect
all
businesses,
large
and
small,
but
small
businesses
may
have
special
problems
in
complying
with
such
regulations.

Generally,
the
small
business
analysis
identifies
the
businesses
that
will
be
affected
by
this
proposed
rule
and
provides
an
analysis
to
assist
in
determining
whether
this
rule
is
likely
to
impose
a
significant
impact
on
a
substantial
number
of
the
small
businesses
within
this
industry.
Once
these
businesses
are
identified,
a
"
sales
test"
is
conducted
which
computes
the
annualized
compliance
costs
as
a
share
of
sales
for
each
company.
Since
facilities
in
the
clay
ceramics
manufacturing
source
category
face
a
MACT
floor
that
requires
no
control
of
existing
sources,
companies
owning
these
facilities
face
no
compliance
costs.
In
other
words,
for
all
of
the
companies
that
own
facilities
included
in
the
clay
ceramics
manufacturing
source
category,
all
have
compliance
costs
that
are
zero
percent
of
their
sales.

This
rule
is
therefore
not
expected
to
have
a
significant
impact
on
a
substantial
number
of
small
businesses.
5­
2
Existing
sources
do
not
face
negligible
costs
of
control
under
this
rule,
but
a
new
source
will
be
required
to
control
releases
of
HAPs.
Even
though
new
sources
in
the
clay
ceramics
manufacturing
source
category
will
face
positive
costs
of
complying
with
this
NESHAP,
impacts
at
the
source
are
not
expected
to
be
substantial.
Since
source­
level
impacts
are
expected
to
be
small,
company­
level
impacts
are
anticipated
to
be
even
less
significant.
According
to
a
report
in
Floor
Covering
Weekly
(
2000),
the
profitability
margin
of
U.
S.
clay
ceramic
plants
in
1998
was
good,
ranked
at
almost
39
percent.
The
1998
profit
margin
is
up
from
just
over
31
percent
in
1992.
This
increasing
profit
margin
provides
some
indication
that
the
costs
of
complying
with
the
regulation
for
new
sources,
at
least
for
those
involved
in
the
manufacture
of
floor
and
wall
tile,
will
not
significantly
impact
small
businesses.
6­
1
6
REFERENCES
Dun
and
Bradstreet.
1999.
Dun
and
Bradstreet
Market
Identifiers
Electronic
Database.

Goddin,
Lesley.
2000.
"
Ceramic
Tile:
State
of
the
Industry,"
Floor
Covering
Weekly.
<
http://
www.
floorcoveringweekly.
com/
story/
story039902a.
asp>

Gale
Group.
1997.
Ward's
Business
Directory.

Moody's
Investors
Service.
1999.
Moody's
Corporate
Profiles
Database.

Standard
and
Poor's
Corporation.
1999.
Standard
and
Poor's
Register
­
Corporate
Electronic
Database.

Donio,
Paul
J.
"
Tile
With
Style:
A
Guide
to
a
Simple
Yet
Beautiful
Remodeling
Material,"
Today's
Homeowner.
<
http://
www.
todayshomeowner.
com/
interior/
19970930.
feature.
html>
retrieved
from
Internet,
2000.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
2000.
1998
Annual
Survey
of
Manufactures,
M98(
AS)­
1
Statistics
for
Industry
Groups
and
Industries.
U.
S.
Government
Printing
Office.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1998.
1996
Annual
Survey
of
Manufactures,
M96(
AS)­
1
Statistics
for
Industry
Groups
and
Industries.
U.
S.
Government
Printing
Office.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1996.
1994
Annual
Survey
of
Manufactures,
M94(
AS)­
1
Statistics
for
Industry
Groups
and
Industries.
U.
S.
Government
Printing
Office.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1995.
1993
Annual
Survey
of
Manufactures,
M93(
AS)­
1
Statistics
for
Industry
Groups
and
Industries.
U.
S.
Government
Printing
Office.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
2000.
1992
Concentration
Ratios
in
Manufacturing.
U.
S.
Government
Printing
Office.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
2000.
Current
Industrial
Reports
for
Clay
Construction
Products
­
Summary
1999,
MQ32D(
99)­
5.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1998.
Current
Industrial
Reports
for
Clay
Construction
Products
­
Summary
1997,
MQ32D(
97)­
5.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
2000.
Current
Industrial
Reports
for
Plumbing
Fixtures
­
Summary
1999,
MQ332E(
99)­
5.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1998.
Current
Industrial
Reports
for
Plumbing
Fixtures
­
Summary
1997,
MQ32D(
97)­
5.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1997.
Current
Industrial
Reports
for
Plumbing
Fixtures
­
Summary
1995,
MQ32D(
95)­
5.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999.
1997
Economic
Census,
Manufacturing
Industry
Series,
"
Ceramic
Wall
and
Floor
Tile
Manufacturing."
U.
S.
Government
Printing
Office.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999.
1997
Economic
Census,
Manufacturing
Industry
Series,
"
Vitreous
China,
Fine
Earthenware,
and
Other
Pottery
Product
Manufacturing."
U.
S.
Government
Printing
Office.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999.
1997
Economic
Census,
Manufacturing
Industry
Series,
"
Vitreous
China
Plumbing
Fixture
and
China
and
6­
2
Earthenware
Bathroom
Accessories
Manufacturing."
U.
S.
Government
Printing
Office.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
2000.
Current
Industrial
Reports
­
Survey
of
Plant
Capacity,
1998.
U.
S.
Government
Printing
Office.

U.
S.
Environmental
Protection
Agency.
1996.
Emission
Factor
Documentation
for
AP­
42,
Section
11.7,
"
Ceramic
Products
Manufacturing."

U.
S.
Environmental
Protection
Agency.
1999.
Memorandum
from
Dottie
Schmitt
and
Richard
Marinshaw,
Midwest
Research
Institute
to
Susan
Zapata,
Emissions
Standards
Division,
Office
of
Air
Quality
Planning
and
Standards,
"
Preliminary
Industry
Characterization
Data
Inputs
for
ISEG,
Clay
Ceramics
Manufacturing
Facilities,"
September
17.

U.
S.
Environmental
Protection
Agency.
2002.
Memorandum
from
Brian
Shrager,
Midwest
Research
Institute
to
Mary
Johnson,
Emissions
Standards
Division,
Office
of
Air
Quality
Planning
and
Standards,
"
Economics
Inputs
­
Brick
and
Structural
Clay
Products
Manufacturing
and
Clay
Ceramics
Manufacturing
NESHAP,"
June
11.

U.
S.
Environmental
Protection
Agency.
2001.
Memorandum
from
Brian
Shrager,
Midwest
Research
Institute
to
Mary
Johnson,
Emissions
Standards
Division,
Office
of
Air
Quality
Planning
and
Standards,
"
Costs
for
PM
CEMS
for
Kilns
­
Brick
and
Structural
Clay
Products
and
Clay
Ceramics
Manufacturing
NESHAP."
July
6.

U.
S.
Small
Business
Administration.
2001.
Small
Business
Size
Standards
Matched
to
North
American
Industry
Classification
System
(
NAICS)
Codes.
<
http://
www.
sba.
gov/
size/
Table­
of­
SS­
based­
on­
NAICS.
PDF>

U.
S.
Small
Business
Administration.
2001.
Small
Business
Size
Standards
Matched
to
Standard
Industrial
Classification
(
SIC)
Codes.
<
http://
www.
sba.
gov/
regulations/
siccodes/
siccodes.
pdf>

Virta,
Robert.
1999.
Clays,
In:
Minerals
Yearbook,
Metals
and
Minerals
1997:
Volume
1.
U.
S.
Geological
Survey.
U.
S.
Government
Printing
Office.

Virta,
Robert.
1998.
Clays,
In:
Minerals
Yearbook,
Metals
and
Minerals
1996:
Volume
1.
U.
S.
Geological
Survey.
U.
S.
Government
Printing
Office.

Virta,
Robert.
1997.
Clays,
In:
Minerals
Yearbook,
Metals
and
Minerals
1995:
Volume
1.
U.
S.
Geological
Survey.
U.
S.
Government
Printing
Office.

Virta,
Robert.
1996.
Clays,
In:
Minerals
Yearbook,
Metals
and
Minerals
1994:
Volume
1.
U.
S.
Geological
Survey.
U.
S.
Government
Printing
Office.
A­
1
APPENDIX
A:
SUMMARY
DATA
FOR
CLAY
CERAMIC
MANUFACTURING
COMPANIES
Table
A­
1.
Summary
Data
for
Companies
Operating
Facilities
in
the
Clay
Ceramic
Manufacturing
Source
Category:
1997/
8
Company
Name
Number
of
Facilities
Number
of
Employees
Annual
Sales
($
106)
Small
Business
American
Marazzi
Tile,
Inc.
2
NR
NR
N
American
Standard
Companies,
Inc.
3
NR
NR
N
Briggs
Industries,
Inc.
a
4
NR
NR
N
Clarke
Ceramic
Corp.
1
NR
NR
Y
CR/
PL
L.
L.
C.
b
6
NR
NR
N
Curran
Group,
Inc.
c
2
NR
NR
N
Dti
Investors,
L.
L.
C.
8
NR
NR
N
EPRO,
Inc.
1
NR
NR
Y
Falcon
Building
Products,
Inc.
d
3
NR
NR
N
Gerber
Plumbing
Fixtures
Corp.
e
3
NR
NR
N
Hans
Sumpf
Co.,
Inc.
1
NR
NR
Y
Homexx
International
Corp.
1
NR
NR
Y
Huntington/
Pacific
Ceramics,
Inc.
2
NR
NR
Y
Interceramic,
Inc.
1
NR
NR
N
Kepcor,
Inc.
1
NR
NR
Y
Kohler
Co,
Inc.
3
NR
NR
N
KPT,
Inc.
1
NR
NR
Y
Laufen
Ceramics,
Inc.
2
NR
NR
N
Lone
Star
Ceramics
Manufacturing
Co.,
Inc.
1
NR
NR
Y
M.
E.
Tile
Co.
1
NR
NR
Y
Peerless
Pottery,
Inc.
1
NR
NR
Y
Premark
International,
Inc.
f
3
NR
NR
N
Quarry
Tile
Co.,
Inc.
1
NR
NR
Y
Summitville
Tiles,
Inc.
1
NR
NR
N
Tilecera,
Inc.
1
NR
NR
N
U.
S.
Industries,
Inc.
g
2
NR
NR
N
Westminster
Ceramics,
Inc.
1
NR
NR
Y
Winburn
Tile
Manufacturing
Co.,
Inc.
1
NR
NR
Y
Totals
58
135,810
$
14,195.48
13
Note:
NR
means
Not
Reported.
Employment
and
sales
data
were
used
in
the
economic
impact
analysis
but
are
taken
from
Dun
&
Bradstreet
which
are
considered
proprietary
and
are
therefore
not
included
in
this
table.
a
Briggs
Industries,
Inc.
owns
CISA
Industries
b
CR/
PL
L.
L.
C.
owns
Universal
Rundle
Corp.
and
Crane
Plumbing
c
Curran
Group,
Inc.
owns
Crossville
Ceramics
d
Falcon
Building
Products,
Inc.
owns
Mansfield
Plumbing
Products,
Inc.
e
Gerber
Plumbing
Fixtures
Corp.
owns
Woodbridge
Sanitary
Pottery
Corp.
f
Premark
International,
Inc.
owns
Florida
Tile
Industries.
g
U.
S.
Industries,
Inc.
owns
Zurn
Industries,
Inc.
