A­
2000­
48
IV­
B­
7
From:
Brian
Shrager
To:
Mary
Johnson
EPA/
ESD/
CG
(
C439­
01)
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
Date:
February
28,
2003
Project:
Clay
Ceramics
Manufacturing
NESHAP
Re:
Final
Rule:
Beyond­
the­
floor
Analysis
I.
Introduction
The
purpose
of
this
memorandum
is
to
present
the
beyond­
the­
floor
(
BTF)
analyses
for
the
clay
ceramics
manufacturing
industry
maximum
achievable
control
technology
(
MACT)
standards
development
project.
Beyond­
the­
floor
analyses,
including
estimates
of
nationwide
emission
reductions,
secondary
air
impacts,
non­
air
quality
impacts,
cost
impacts,
and
cost­
effectiveness,
were
completed
for
the
following
sources:
(
1)
existing
tile
tunnel
kilns;
and
(
2)
existing
sanitaryware
tunnel
kilns.
After
identifying
the
MACT
floors
for
the
existing
kilns,
regulatory
alternatives
more
stringent
than
the
MACT
floor
levels
were
investigated.
These
regulatory
alternatives
are
discussed
in
Section
II
of
this
memorandum.
Sections
III
through
V
of
this
memorandum
present
the
results
of
the
BTF
analyses
for
the
three
types
of
clay
ceramics
kilns.

II.
Beyond­
the­
floor
Options
Available
data
on
the
performance
of
add­
on
air
pollution
control
devices
(
APCDs)
and
pollution
prevention
techniques
(
i.
e.,
substitution
of
raw
materials
and/
or
fuels)
were
reviewed
to
identify
the
MACT
floor
and
regulatory
alternatives
for
clay
ceramics
kilns.
No
existing
clay
ceramics
kilns
are
equipped
with
APCDs
that
reduce
hydrogen
fluoride
(
HF),
hydrogen
chloride
(
HCl),
and
hazardous
air
pollutant
(
HAP)
metals.
Therefore,
the
MACT
floor
for
all
existing
clay
ceramics
kilns
does
not
include
use
of
an
APCD.
Low­
HAP
raw
material
use
is
not
a
viable
MACT
option
for
the
clay
ceramics
industry
because
all
facilities
use
product­
specific
raw
materials
that
are
integral
to
the
various
products.
Changes
in
raw
materials
would
change
the
end
products,
and
because
of
this,
it
would
not
be
feasible
for
facilities
to
meet
requirements
based
on
the
use
of
low­
HAP
raw
materials.
With
respect
to
requiring
kilns
to
fire
low­
HAP
fuels,
all
clay
ceramics
kilns
for
which
EPA
has
information
are
fired
with
natural
gas
or
propane.
2
Thus,
a
requirement
to
use
natural
gas
(
or
equivalent
fuel)
to
fire
all
existing
kilns
would
not
have
any
impact
on
the
end
products
of
existing
kilns.
Therefore,
the
MACT
floor
for
all
existing
clay
ceramics
periodic
kilns,
tunnel
kilns,
and
roller
kilns
is
based
on
firing
the
kilns
with
natural
gas
or
an
equivalent
fuel
(
such
as
propane
or
other
clean­
burning
fuel).

Regulatory
alternatives
more
stringent
than
the
MACT
floor
for
clay
ceramics
kilns
include
use
of
an
APCD
such
as
a
dry
limestone
adsorber
(
DLA),
dry
lime
injection
fabric
filter
(
DIFF),
dry
lime
scrubber/
fabric
filter
(
DLS/
FF),
wet
scrubber
(
WS).
Based
on
comments
received
following
proposal
of
the
brick
and
structural
clay
products
(
BSCP)
MACT
rule,
it
appears
that
DLAs
are
the
only
available
APCD
that
can
be
used
to
retrofit
existing
tunnel
kilns
without
changing
the
production
process
and
product
characteristics.
Therefore,
DLAs
were
the
only
APCD
considered
for
the
BTF
analyses
for
tunnel
kilns.
No
APCDs
have
been
demonstrated
to
control
HAP
emissions
from
roller
kilns
and
periodic
kilns.
Therefore,
beyond­
the­
floor
control
options
for
roller
kilns
and
periodic
kilns
were
not
considered.

II.
Tile
Tunnel
Kilns
The
available
data
show
14
existing
tunnel
kilns
at
ceramic
tile
facilities
that
are
estimated
to
be
major
sources.
1
The
largest
of
these
tunnel
kilns
produces
10
tons
per
hour
(
tph)
of
fired
product.
This
BTF
analysis
assumes
that
each
existing
tile
tunnel
kiln
would
be
retrofitted
with
a
DLA
to
control
HAP
emissions.
The
BTF
analysis
includes:
(
1)
estimates
of
primary
air
pollution
impacts
(
emission
reductions);
(
2)
estimates
of
secondary
air
impacts;
(
3)
estimates
of
solid
waste
impacts;
(
4)
estimates
of
energy
impacts;
and
(
5)
an
evaluation
of
costs
and
costeffectiveness

A.
Primary
Air
Pollution
Impacts.
Primary
HAP
air
pollution
impacts
consist
of
the
reduction
of
HF,
HCl,
and
HAP
metals
emissions.
Implementation
of
the
BTF
regulatory
approach
would
reduce
total
HAP
emissions
from
existing
tile
tunnel
kilns
by
99
tons
per
year
(
tpy),
or
70
percent,
from
a
baseline
HAP
emission
level
of
141
tpy.
Particulate
matter
(
PM)
emission
reductions
(
PM
is
used
as
a
surrogate
for
HAP
metals)
and
co­
control
of
sulfur
dioxide
(
SO
2)
emissions
(
from
the
baseline
level)
also
would
result
from
implementation
of
the
BTF
approach.
The
estimated
baseline
emissions
and
reductions
for
the
BTF
approach
for
existing
tile
tunnel
kilns
are
summarized
in
Table
1,
and
are
based
on
average
emission
factors
for
ceramics
kilns
and
brick
kilns
(
if
ceramics
data
are
not
available)
and
DLA
control
efficiencies
from
the
brick
industry
applied
to
model
tile
tunnel
kilns.
2­
4
B.
Secondary
Air
Pollution
Impacts.
Table
2
shows
a
summary
of
secondary
air
pollution
impacts
associated
with
the
BTF
regulatory
approach.
These
impacts
were
estimated
according
to
the
methodology
outlined
in
Reference
5.
In
general,
the
methodology
assumes
that
the
secondary
air
impacts
consist
of
the
emissions
from
the
generation
of
electricity
to
power
the
DLAs
that
would
be
installed
on
14
tile
tunnel
kilns.
3
C.
Solid
Waste
Impacts.
Table
2
shows
a
summary
of
solid
waste
impacts
associated
with
implementation
of
the
BTF
regulatory
approach.
These
impacts
were
estimated
according
to
the
methodology
outlined
in
Reference
5.
In
general,
the
methodology
assumes
that
the
solid
waste
impacts
consist
of
the
solid
waste
(
spent
limestone
and
reaction
products)
generated
by
the
DLAs
that
would
be
installed
on
14
tile
tunnel
kilns.

D.
Energy
Impacts.
Table
2
shows
a
summary
of
energy
impacts
associated
with
implementation
of
the
BTF
regulatory
approach.
These
impacts
were
estimated
according
to
the
methodology
outlined
in
Reference
5.
In
general,
the
methodology
assumes
that
the
energy
impacts
consist
of
the
energy
requirements
of
the
DLAs
that
would
be
installed
on
14
tile
tunnel
kilns.

E.
Cost
Impacts.
The
estimated
capital
cost
of
a
DLA
on
a
tile
tunnel
kiln
is
$
510,000.
The
annualized
capital,
operation,
and
maintenance
costs
are
estimated
at
$
172,000.
Emission
testing,
monitoring,
and
recordkeeping
and
reporting
costs
are
estimated
at
$
23,500.
Table
2
shows
a
summary
of
cost
impacts
associated
with
implementation
of
the
BTF
regulatory
approach.
These
impacts
were
estimated
by
applying
the
estimated
control,
monitoring,
testing,
and
recordkeeping
and
reporting
costs
for
DIFFs
to
each
of
the
14
tile
tunnel
kilns
included
in
this
analysis.
2,
6­
8
F.
Cost­
Effectiveness.
To
estimate
the
cost­
effectiveness
of
controlling
HF,
HCl,
HAP
metals,
PM,
and
SO
2,
the
estimated
emission
reductions,
shown
in
Table
1,
were
used
in
conjunction
with
the
total
estimated
costs
for
installation
and
operation
of
DLA
systems
shown
in
Table
2.
The
estimated
nationwide
cost­
effectiveness
of
requiring
BTF
control
of
existing
tile
tunnel
kilns
is
$
28,000
per
ton
of
HAP
removed.
Nationwide
cost­
effectiveness
numbers
for
each
pollutant
are
presented
in
Table
3.

TABLE
1.
PRIMARY
AIR
IMPACTS
FOR
EXISTING
TILE
TUNNEL
KILNS
Tile
tunnel
kilnsa
Pollutant
Baseline
emissions,
tpya
BTF
emission
reductions,
tpyb
HF
88.0
82.5
HCl
52.8
16.2
HAP
metals
0.54
0.27
Total
HAP
Emissions
141
99.0
PM
75.4
37.7
SO
2
379
126
a
Emission
estimates
based
on
average
emission
factors
from
brick
tunnel
kilns
applied
to
14
model
tile
tunnel
kilns,
each
producing
2.5
tons
per
hour
of
fired
tile.
b
Emission
reductions
based
on
93.7
percent
HF
control,
30.7
percent
HCl
control,
50
percent
HAP
metals
and
PM
control,
and
33.2
percent
SO
2
control.
4
TABLE
2.
SUMMARY
OF
SECONDARY
AIR,
ENERGY,
AND
SOLID
WASTE
IMPACTS
OF
BTF
CONTROL
FOR
EXISTING
TILE
TUNNEL
KILNS
Type
of
impact
BTF
impact
Comments
Secondary
air:
NO
x
1
ton
per
year
NO
x
increase
Based
on
electricity
provided
by
gas
turbines
Solid
waste
4,480
tons
per
year
Assumes
facilities
must
dispose
of
all
waste
lime
as
solid
waste
Energy
9,350
MMBtu/
yr
Energy
required
to
power
DIFFs
Cost
$
2.74
million
TABLE
3.
SUMMARY
OF
COST­
EFFECTIVENESS
OF
BTF
CONTROL
FOR
EXISTING
TILE
TUNNEL
KILNS
Cost
effectiveness,
$/
ton
of
pollutant
removed
Pollutant
DIFF
HF
33,000
HCl
169,000
HAP
metals
10,000,000
Total
HAP
28,000
PM
73,000
SO
2
22,000
All
criteria
pollutants
17,000
All
pollutants
10,000
IV.
Sanitaryware
Tunnel
Kilns
The
available
data
show
23
existing
tunnel
kilns
at
sanitaryware
facilities
that
are
estimated
to
be
major
sources.
All
of
these
tunnel
kilns
produce
less
than
10
tph
of
fired
product.
This
BTF
analysis
assumes
that
each
existing
sanitaryware
tunnel
kiln
would
be
retrofitted
with
a
DLA
to
control
HAP
emissions.
The
BTF
analysis
includes:
(
1)
estimates
of
primary
air
pollution
impacts
(
emission
reductions);
(
2)
estimates
of
secondary
air
impacts;
(
3)
estimates
of
solid
waste
impacts;
(
4)
estimates
of
energy
impacts;
and
(
5)
an
evaluation
of
costs
and
cost­
effectiveness.

A.
Primary
Air
Pollution
Impacts.
Primary
HAP
air
pollution
impacts
consist
of
the
reduction
of
HF,
HCl,
and
HAP
metals
emissions.
Implementation
of
the
BTF
regulatory
approach
would
reduce
total
HAP
emissions
from
existing
sanitaryware
tunnel
kilns
by
150
tpy,
or
70
percent,
from
a
baseline
HAP
emission
level
of
214
tpy.
Particulate
matter
emission
reductions
(
PM
is
used
as
a
surrogate
for
HAP
metals),
and
co­
control
of
SO
2
emissions
(
from
5
the
baseline
level)
also
would
be
directly
attributable
to
implementation
of
the
regulation.
The
estimated
baseline
emissions
and
emission
reductions
for
the
BTF
approach
for
existing
sanitaryware
tunnel
kilns
are
summarized
in
Table
4,
and
are
based
on
average
emission
factors
for
ceramics
kilns
and
brick
kilns
(
if
ceramics
data
are
not
available)
and
DLA
control
efficiencies
from
the
brick
industry
applied
to
model
sanitaryware
tunnel
kilns.
2­
4
B.
Secondary
Air
Pollution
Impacts.
Table
5
shows
a
summary
of
secondary
air
pollution
impacts
associated
with
the
BTF
regulatory
approach.
These
impacts
were
estimated
according
to
the
methodology
outlined
in
Reference
5.
In
general,
the
methodology
assumes
that
the
secondary
air
impacts
consist
of
the
emissions
from
the
generation
of
electricity
to
power
the
DLAs
that
would
be
installed
on
23
sanitaryware
tunnel
kilns.

C.
Solid
Waste
Impacts.
Table
5
shows
a
summary
of
solid
waste
impacts
associated
with
implementation
of
the
BTF
regulatory
approach.
These
impacts
were
estimated
according
to
the
methodology
outlined
in
Reference
5.
In
general,
the
methodology
assumes
that
the
solid
waste
impacts
consist
of
the
solid
waste
(
spent
limestone
and
reaction
products)
generated
by
the
DLAs
that
would
be
installed
on
23
sanitaryware
tunnel
kilns.

D.
Energy
Impacts.
Table
5
shows
a
summary
of
energy
impacts
associated
with
implementation
of
the
BTF
regulatory
approach.
These
impacts
were
estimated
according
to
the
methodology
outlined
in
Reference
5.
In
general,
the
methodology
assumes
that
the
energy
impacts
consist
of
the
energy
requirements
of
the
DLAs
that
would
be
installed
on
23
sanitaryware
tunnel
kilns.

E.
Cost
Impacts.
The
estimated
capital
cost
of
a
DLA
on
a
sanitaryware
tunnel
kiln
is
$
510,000.
The
annualized
capital,
operation,
and
maintenance
costs
are
estimated
at
$
172,000.
Emission
testing,
monitoring,
and
recordkeeping
and
reporting
costs
are
estimated
at
$
23,500.
Table
5
shows
a
summary
of
cost
impacts
associated
with
implementation
of
the
BTF
regulatory
approach.
These
impacts
were
estimated
by
applying
the
estimated
control,
monitoring,
testing,
and
recordkeeping
and
reporting
costs
for
DLAs
to
each
of
the
23
sanitaryware
tunnel
kilns
included
in
this
analysis.
2,
6­
8
F.
Cost­
Effectiveness.
To
estimate
the
cost­
effectiveness
of
controlling
HF,
HCl,
HAP
metals,
PM,
and
SO
2,
the
estimated
emission
reductions,
shown
in
Table
4,
were
used
in
conjunction
with
the
total
estimated
costs
for
installation
and
operation
of
DLA
systems
shown
in
Table
5.
The
estimated
nationwide
cost­
effectiveness
of
requiring
BTF
control
of
existing
sanitaryware
tunnel
kilns
is
$
30,000
per
ton
of
HAP
removed.
Nationwide
cost­
effectiveness
numbers
for
each
pollutant
are
presented
in
Table
6.
6
TABLE
4.
PRIMARY
AIR
IMPACTS
FOR
EXISTING
SANITARYWARE
TUNNEL
KILNS
Pollutant
Baseline
emissions,
tpya
BTF
emission
reductions,
tpyb
HF
133
125
HCl
79.8
24.5
HAP
metals
1.43
0.71
Total
HAP
Emissions
214
150
PM
198
99.1
SO
2
995
330
a
Emission
estimates
based
on
average
emission
factors
for
sanitaryware
tunnel
kilns
applied
to
23
model
sanitaryware
tunnel
kilns,
each
producing
4
tons
per
hour
of
fired
sanitaryware.
b
Emission
reductions
based
on
93.7
percent
HF
control,
30.7
percent
HCl
control,
50
percent
HAP
metals
and
PM
control,
and
33.2
percent
SO
2
control.

TABLE
5.
SUMMARY
OF
SECONDARY
AIR,
ENERGY,
AND
SOLID
WASTE
IMPACTS
OF
BTF
CONTROL
FOR
EXISTING
SANITARYWARE
TUNNEL
KILNS
Type
of
impact
BTF
impact
Comments
Secondary
air:
NO
x
2
tons
per
year
NO
x
increase
Based
on
electricity
provided
by
gas
turbines
Solid
waste
7,450
tons
per
year
Assumes
facilities
must
dispose
of
all
waste
lime
as
solid
waste
Energy
15,400
MMBtu/
yr
Energy
required
to
power
DIFFs
Cost
$
4.51
million
TABLE
6.
SUMMARY
OF
COST­
EFFECTIVENESS
OF
BTF
CONTROL
FOR
SANITARYWARE
TUNNEL
KILNS
Cost
effectiveness,
$/
ton
of
pollutant
removed
Pollutant
DIFF
HF
36,000
HCl
18,000
HAP
metals
6,400,000
Total
HAP
30,000
PM
46,000
SO
2
14,000
All
criteria
pollutants
10,000
All
pollutants
7,800
7
V.
References
1.
Memorandum
from
B.
Shrager,
MRI,
to
M.
Johnson,
EPA:
ESD.
Documentation
of
Database
of
Responses
to
the
1997
EPA
Information
Collection
Request
for
Clay
Ceramics
Manufacturing.
December
6,
2001.

2.
Memorandum
from
B.
Shrager
and
M.
Abraczinskas,
MRI,
to
M.
Johnson,
EPA:
ESD.
Model
Plants
 
Clay
Ceramics
Kilns.
Clay
Ceramics
Manufacturing
NESHAP.
November
15,
2000.

3.
Memorandum
from
B.
Shrager
and
M.
Abraczinskas,
MRI,
to
M.
Johnson,
EPA:
ESD.
Abbreviated
Summary
of
Clay
Ceramics
Emissions
Test
Data.
Clay
Ceramics
Manufacturing
NESHAP.
July
10,
2000.

4.
Memorandum
from
B.
Shrager,
RTI,
to
M.
Johnson,
EPA:
ESD.
Final
Rule:
Test
Data
Summary.
Brick
and
Structural
Clay
Products
Manufacturing
NESHAP.
February
27,
2003.

5.
Memorandum
from
B.
Shrager,
RTI,
to
M.
Johnson,
EPA:
ESD.
Final
Rule:
Environmental
and
Energy
Impacts.
Brick
and
Structural
Clay
Products
Manufacturing
NESHAP
and
Clay
Ceramics
Manufacturing
NESHAP.
February
27,
2003.

6.
Memorandum
from
B.
Shrager,
RTI,
to
M.
Johnson,
EPA:
ESD.
Final
Rule:
Costs
for
Air
Pollution
Control
Devices
on
Clay
Ceramics
Kilns.
Clay
Ceramics
Manufacturing
NESHAP.
February
26,
2003.

7.
Memorandum
from
B.
Shrager,
RTI,
to
M.
Johnson,
EPA:
ESD.
Final
Rule:
Monitoring
and
Monitoring
Costs.
Brick
and
Structural
Clay
Products
Manufacturing
and
Clay
Ceramics
Manufacturing
NESHAP.
February
26,
2003.

8.
OMB­
83I
Form
Supporting
Statement,
for
OMB
Review
of
ICR
No.
2023.01.
Information
Collection
Request
for
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
the
Clay
Ceramics
Source
Category.
U.
S.
Environmental
Protection
Agency,
February
2003.

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