Date: September 2 4 , 201 5

To: Sharon Nizich , EPA/ OAQPS/SPPD

From: Gabrielle Raymond , RTI International

Subject : Development of Cost and Emission Reduction Impacts for the Final Clay Ceramics Manufacturing NESHAP

I. I ntroduction

In accordance with section 112 of the Clean Air Act (CAA), the U.S. Environmental Protection Agency (EPA) established national emission standards for hazardous air pollutants (NESHAP) on May 16, 2003

, for t he clay ceramics manufacturing industry , specifically the sanitaryware and ceramic tile industry sectors

. Sanitaryware includes plumbing and bathroom fixtures such as toilets and sinks. Ceramic tile is used to cover floors and walls. The NESHAP regulate d emissions of hydrogen fluoride (HF)

, hydrogen chloride (HCl), and particulate matter (PM)

— a surrogate for hazardous air pollutant (HAP) metals

— from new and reconstructed kilns located at clay ceramics facilities

. On March 13, 2007, the D.C. Circuit Court vacated the emission standards for clay ceramics manufacturing due to issues associated with the methodology used to determine the minimum regulatory “floors” for new and existing units

. 1
Therefore

, on December 18, 2014, the EPA propo s ed new standards for clay ceramics manufacturing

, includ ing standards for HF, HCl, mercury (Hg), non

- Hg HAP metals (specifically, the PM surrogate), and dioxins/furans ( in terms of 2,3,7,8

- tetrachlorodibenzo

- p

dioxin toxic equivalents ( TEQ ))

. The EPA provided a 90

- day public comment period following proposal of the Clay Ceramics M anufacturing NESHAP, during which all affected parties were given the opportunity to comment on the proposed rule. The EPA has considered the comments received and, as appropriate, inc orporated them into the final rule

. The list of affected sources to be regulated has been expanded to include new and existing kilns, spray dryers (ceramic tile only), press dryers (floor tile only), and spray glaze operations

. However, t he facilities cur rently projected to be subject to the NESHAP include three sanitaryware facilities. The ceramic floor and wall tile facilities have taken the necessary steps to become synthetic area sources ( i.e. , have obtained a federally enforceable limit reducing

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

.2 emissions below major source thresholds 2 ), and would not be subject to the major source Clay Ceramics Manufacturing NESHAP.

The purpose of this memorandum is to present the methodology f or estimating the costs
, emission reductions , and secondary impacts 3 a ssociated with the final standards for sanitaryware sector of the c lay c eramics source category

. (For the final rulemaking, only the impacts estimates for sanitaryware sources were updated from the proposed estimates, as there are no major sources in the ceramic tile industry sector.) A background discussion of the types of costs, emission reductions, and secondary impacts being estimated is provided in the memorandum Methodology and Assumptions Used to Estimate the Model Costs and Impacts of Clay Ceramic s Air Pollution Control Devices for the Final Rule (Holloway and Raymond , 201 5 ).

The standards include health

- based standards for acid gases (HF and HCl) and maximum achievable control technology (MACT) numeric emission limits for Hg, PM (as a surrogate for

non

- Hg HAP metals), and dioxins/furans for sources expected to emit those pollutants

. The development of these standards and options are documented in two memoranda, Risk Assessment to Determine a Health

- Based Emission Limitatio n for Acid Gases for the Clay Ceramics Manufacturing Source Category (Morris et al. , 2014) and Maximum Achievable Control Technology (MACT) Floor Analysis for Clay Ceramic s (Raymond and Sroka, 201 5 ).

In developing the proposed standards, the EPA also consi dered “beyond

- the

- floor” options for Hg, PM (as a surrogate for non

- Hg HAP metals), and dioxins/furans for all three industry sectors (sanitaryware, ceramic floor tile, and ceramic wall tile)

. Note that for the final rulemaking, the nationwide costs, emis sion reductions, and secondary impacts associated with the beyond

- the

- floor options were not recalculated from proposal, as the cost effectiveness of these options would not be significantly lower than at proposal. For the calculation of the nationwide co sts, emission reductions, and secondary impacts associated with the beyond

- the

floor options for non

- Hg HAP metals and Hg at proposal, see Development of Cost and Emission Reduction Impacts for the Clay Ceramics NESHAP (Holloway and Raymond, 2014).

Section II of this memorandum shows the nationwide baseline emissions for the major sources in the c lay c eramics industry. Section III describes the assessment of what air pollution control devices (APCD) would be needed for major source sanitaryware facilities to meet the proposed health

- based standards. Section IV describes the analysis of what APCD would be needed for sanitaryware stacks to meet the proposed MACT standards and presents the nationwide costs, emission reductions, and secondary impact s associated with those APCD.

2 A major source of HAP is a facility that has the potential to emit 10 tons per year (tpy) or more of any single HAP or 25 tpy or more of any combination of HAP.

3 The secondary impacts addressed in this memorandum include the following:

• Energy impacts: The annual amount of energy (in million British thermal units per year [MMBtu/yr]) needed to generate the electricity to operate the control devices used to comply with the proposed standards and beyond

- the

- floor options.

• Secondary emissions: The criteria air pollutant emissions

— PM, PM 2.5 , carbon monoxide (CO), nitrogen oxides (NOx), and SO 2

— (in tpy) that result from the generation of electric ity used to operate the control devices.

• Solid waste: The material (in tpy) capture d by the control devices.3 II. Baseline Emissions

The c lay c eramics industry has several sources with varying amounts of available data and information about control devices to estimate baseline emissions. As such

, the baseline emissions for sanitaryware sources were developed differently for different source s.

A. Sanitaryware Tunnel Kilns

For sanitaryware tunnel kilns, baseline emissions (tpy) were developed for HF, HCl, non

Hg HAP metals , PM, PM 2.5 , Hg, and dioxin/furan TEQ

. Test data w ere available for all of these pollutants for each kiln, so model emissions were not developed. The average lb/ton emissions for each pollutant and kiln were multiplied by the kiln d esign capacity ( tons per hour [ tp h] ), then multiplied by 8

, 760 operating hours, then divided by 2

, 000 lb/ton to estimate the baseline emissions. The nationwide baseline emissions for PM 2.5 were estimated as 48 percent of the baseline PM emissions. See Table 1 for the nationwide baseline emissions estimates for sanitaryware tunnel kilns.

Table 1

. Nationwide Baseline Emissions Estimates for Sanitaryware Tun nel Kilns

APCD Type Size Count Nationwide Emissions (tpy)

HF HCl Non

- Hg HAP Metals PM PM 2.5 Hg D/ F TEQ

None &

WS Small & Large 8 [7 None;

1 WS] 15.2 1.19 0.083 7.47 3.59 0.011 2.72E

- 07

B. Sanitaryware Glazing Operations

For sanitaryware glazing operations, baseline emissions (tpy) were developed for PM and PM 2.5 for each APCD type (FF, WS, and water curtains [WC]). Test data w ere not available for all of the operating spray booths, so data from similar units ( e.g. , similar location, APCD, glaze spray rate) w ere used to estimate emissions for the units without data. Each unit’s lb/ton emissions value was multiplied by its glaze sp ray rate ( in tph), then multiplied by the annual operating hours and di vided by 2,000 lb/ton to estimate base line emissions. The nationwide baseline emissions for PM 2.5 were estimated as 48 percent of the baseline PM emissions. See Table 2 for the nation wide baseline emissions estimates for sanitaryware glazing operations.4 Table 2 . Nationwide Baseline Emissions Estimates for Sanitaryware Glazing Operations

Unit Type APCD Type Size Count Nationwide Emissions (tpy)
PM PM 2.5 Manual glaze application FF All 2 6. 84 3.2 8
WS All 1 2. 31 1. 11
WC All 11 28. 73 13. 79
Manual glaze application total 37. 88 18.18
Robot glaze application WS All 1 0.70 0.34
WC All 9 9.75 4.68
R obot glaze application total 10.46 5.02 Spray m achine glaze application WC All 4 16.22 7.79

See Table 3 for the nationwide baseline emissions estimates for all sanitaryware unit types being regulated under the clay ceramics manufacturing final rule

.

Table 3 . Total Nationwide Baseline Emissions Estimates for Sanitaryware

Unit Type Emissions (tpy)

HF HCl Non

- Hg HAP Metals PM PM 2.5 SO 2 Hg D/ F TEQ Sanitaryware Tunnel Kilns 15.2 1.19 0.083 7.47 3.59 0.011 2.72E

- 07 Sanitaryware Manual Glaze Application 37. 9 18. 2

Sanitaryware Spray Machine Glaze Application 16.2 7.79

Sanitaryware Robot Glaze Application 10. 5 5.02

Sanitaryware Total 15.2 1.19 0.083 72.0 34. 6 0 0.011 2.72E

- 07

I II

. Cost and Emission Reduction Estimates for Meeting Health

- Based Standards

For the acid gases HF and HCl, a health

- based emission limit was developed for acid
gases under CAA section 112(d)(4)

. The rationale behind the standard is discussed in the preamble to the c lay c eramics final rule. The development of the facility

- level health

- based emission limit

, 600 tpy of HCl

- equivalent , or 140 lb/hr of HCl

- equivalent , is documented in the memorandum Risk Assessment to Determine a Health

- Based Emission Limitation for Acid Gases for the Clay Ceramics Manufacturing Source Category (Morris et al

. , 2014).

The equivalency of HCl with HF is based on the chronic Reference Concentration (RfC) values for each of the acid gases. The RfC for HCl is 2 0 micrograms per cubic meter ( μg /m 3 ) and the RfC for HF is 14 μg /m 3 ( Morris et al

. , 2014). Therefore, the following eq uation can be used to calculate the HCl

- equivalent emissions for an individual kiln :5 

###              
+ =

HF HCl HF HCl i 

### RfC RfC E E E

where:

E i = HCl

- equivalent emission s, lb/hr

E HCl = emissions of HCl, lb/hr

E HF = emission s of HF, lb/hr

RfC HCl = r eference concentration for HCl

, 20 μg /m 3

RfC HF = reference concentration for HF, 14 μg/m 3

Test data are available for some of the kilns in the clay ceramics industry (see the memorandum Test Data Used in C lay Ceramics Manufacturing Final Rule (Raymond, 201 5 ) )

. If test data were not available for all acid gas emissions ( i.e. , HF and HCl), emission factors were used to estimate emissions. This information was used in the equation above to calculate an HCl

- equivalent value for each kiln. The HCl

- equivalent values were summed for a ll kiln s at a major source facility and then compared to the health

- based emission limit

.

As shown in Table 4 , all major source clay ceramics facilit ies could meet the health

based emission limit of 140 lb/hr of HCl

- equivalent with current control configur ations

.

Table 4

. Acid Gas Emissions and HCl

- Equivalent Emissions for Major Source Kilns

Facility ID Company Name Facility Name HF ( lb/hr ) HCl ( lb/hr ) E ( lb/hr ) (Chronic)

KOHL

- SC Kohler Co. Kohler, Spartanburg Plant 0.77 0.058 1.16
KOHL

- TX Kohler Co. Kohler, Brownwood Plant 1.24 0.10 1.87
KOHL

- WI Kohler Co. Kohler, Wisconsin Plant 0.29 0.017 0.43

I V. Cost and Emission Reduction Estimates for Meeting Hg , N on - Hg HAP Metals , and Dioxin/Furan TEQ Proposed Standards

There are only three sanitaryware facilities currently classified as major sources in the

c lay c eramics industry. There are five ceramic tile facilities that were major sources at the time of the 2008 and 2010 section 114 EPA surveys of the clay ceramics industry, but these facilities

were recently re

- classified as synthetic area sources due to the installation of new APCD

. 4 The se five ceramic tile facilities would not be subject to the rule, so the impacts of requiring them to

4 A major source of HAP emissions is a source that has the potential to emit 10 tpy or more of any individual HAP or 25 tpy or more of any combinat ion of HAP. A synthetic area source is a source that obtain s a federally enforceable limit (e.g., in a title V permit) that reduces emissions below major source thresholds , by installing an APCD or taking a limit on their operating capacity, for example.6 meet the limits were not updated from pro posal

. A summary of the sources at the facilities used for all remaining analyses in this memorandum is shown in Table 5 (Raymond, 2015)

.

Table 5 . Summary of Units at Major Sources
Source Type N o. of Units N o. of Unit Stacks Sanitaryware First

- fire Tunn el Kilns 11 7 Sanitaryware Manual Glaze Application 14 14 Sanitaryware Spray Machine Glaze Application 4 4 Sanitaryware Robot Glaze Application 10 10

The C lay C eramics Manufacturing NESHAP includes MACT standards for Hg

, PM (as a surrogate for non

- Hg HAP metals) , and dioxin/furan TEQ . As noted previously, test data were available for some kilns and glazing operations in the industry ( as shown in Table 6 ).

Table 6 . Facilities with Available Test Data

Fac ID Fac ID Company City State Source Cla ssification

203 KOHL

- TX Kohler Brownwood TX Major
82 KOHL

- SC Kohler Spartanburg SC Major
204 KOHL

- WI Kohler Kohler WI Major

Data on PM emissions were available for about 55 percent of the sanitaryware tunnel kilns, 21 percent of the sanitaryware manual glaze booths, 75 percent of the sanitaryware spray machine booths, and 40 percent of the sanitaryware robot glaze booths . Data on Hg and non

- Hg HAP metals emissions were available for about 45 percent of the sanitaryware tunnel kilns

. Data

on diox in/furan TEQ emissions were available for about 45 percent of the sanitaryware tunnel kilns (Raymond, 201 5 ). There fore, rather than evaluating the impacts of the standards on a unit

by

- unit basis, as was done for the health

- based emission limit, several a ssumptions were needed to evaluate the impacts on the whole industry

. This analysis was completed in a series of three steps , described in the remainder of this section.

Step 1: Compare Test Data to Emission Limits

The first step was to compare the data available to the emission limits to get an estimate of the percentage of kilns and glazing operations in the industry that could meet the limits with current APCD configurations. For all sanitaryware unit types

, 100 percent of units were estimated to meet the MACT floor limits.

Step 2: Develop Estimate of Number of APCD Needed

For the next step, i n addition to looking at the units with data, estimates for the units without data were developed t o estimate the number of APCD needed for the units to meet the7 standards

. F or the units with no data available

, the data from similar units ( e.g. , similar location, APCD, design capacity) were used to fill in the data gaps. Those units’ similar data were then
compa red to the proposed limits to see if the data would meet the limit s or not. For those units with no data available and where data from similar units could not be used to fill in the gaps

, the
current control device of the unit was examined . For units with no control device

, it was assumed that they could not meet the PM, Hg, and dioxin/furan TEQ limits. For units with WS, DIFF, or DLS/FF, it was assumed that they could meet the PM, Hg, and dioxin/furan TEQ limits. After each unit was evaluated to see if it could meet the limits, the percentage of units (with and without data) meeting the limits were calculated for PM, Hg, and dioxin/furan TEQ. These percentages were compared to the 100 percent previously presented in Step 1 of this section

c alculated for un its with data to make sure they were similar. The ability of each unit to be able
to meet the PM, Hg, and dioxin/furan TEQ limits determined the criteria for APCD to be installed or not ( see Table 7 )

.8 Table 7 . Scenarios for Sanitaryware Units

Unit Type C urrent APCD Meets PM limit Meets Hg limit Meets D/F TEQ limit APCD / Action Needed Sanitaryware Tunnel Kilns Wet Scrubber No No No Add FF and ACI

- 2
Wet Scrubber No No Yes Add FF and ACI

- 1

- Hg
Wet Scrubber No Yes No Add FF and ACI

- 1

- D / F
Wet Scrubber No Yes Yes Add FF
Wet Scrubber Yes No No Add FF and ACI

- 2
Wet Scrubber Yes No Yes Add FF and ACI

- 1

- Hg
Wet Scrubber Yes Yes No Add FF and ACI

- 1

- D / F
Wet Scrubber Yes Yes Yes No action
None No No No Install FF and ACI

- 2
None No No Yes Install FF and ACI

- 1

- Hg
None No Yes No Install FF and ACI

- 1

- D / F
None No Yes Yes Install FF

None Yes No No Install FF and ACI

- 2
None Yes No Yes Install FF and ACI

- 1

- Hg

None Yes Yes No Install FF and ACI

- 1

- D / F
None Yes Yes Yes No action Sanitaryware Glazing Water Curtain No n/a n/a Retrofit with FF
Water Curtain Yes n/a n/a No action
Fabric Filter No n/a n/a Retrofit with FF

Fabric Filter Yes n/a n/a No action
Wet Scrubber No n/a n/a Add FF
Wet Scrubber Yes n/a n/a No action
Install: installing a brand new piece of equipment
Retrofit: removing the existing equipment and installing new equipment Add: keeping existing equipment in place and adding the new equipment to the existing control configuration
ACI

- 1: Activated Carbon Injection for Hg or D / F TEQ
ACI

- 2: Activated Carbon Injection for Hg and D / F TEQ n/a: not applicable

A ll sanitaryware tunnel kilns and glazing operations are projected to meet the limits with current controls ; therefore , t he re are no APCD expected to be installed or retrofit

. Step 3 : Calculate the Nationwide Costs, Emission Reductions, and Secondary Impacts

The final step in estimating nationwide costs and impacts would be to apply model APCD costs, emission reductions, and seconda ry impacts to the estimated counts of APCD needed

. However, because no APCD are expected to be installed, the nationwide costs

, emission reductions , and secondary impacts attributed to APCD are all zero

.9 V. References

Holloway, T. and G. Raymond. 201 5

. Methodology and Assumptions Used to Estimate the Model Costs and Impacts of Clay Ceramics Air Pollution Control Devices for the Final Rule

. Memorandum from Thomas Holloway and Gabrielle Raymond , RTI International, to Sharon Nizich , EPA/OAQPS/SPPD. September 24 , 201 5

. Morris, M., T. Palma, and C. Sarsony. 2014. Risk Assessment to Determine a Health

- Based Emission Limitation for Acid Gases for the Clay Ceramics Manufacturing Source Category

. Memorandum from Mark Morris, Ted Palma, and Chris Sarson y, EPA/OAQPS/HEID, to Docket EPA

- HQ

- OAR

- 2013

- 0291

. May 19, 2014. Docket Item No. EPA

- HQ

- OAR

- 2013

- 0290

- 0213

. Raymond, G

., and K. Sroka. 201 5

. Final Maximum Achievable Control Technology (MACT) Floor Analysis for Clay Ceramic s

. Memorandum from Gabrielle Raymond and Kristin Sroka, RTI International, to Sharon Nizich , EPA/OAQPS/SPPD. September 24 , 201 5

. Raymond, G. 2014. Updated Inventory Database and Documentation for C lay C eramics Proposed Rule

. Memorandum from Gabrielle Raymond, RTI International, to J eff Telander, EPA/OAQPS/SPPD

. November 6, 2014. Docket Item EPA

- HQ

- OAR

- 2013

- 0290

- 0222

. Raymond, G. 2015. Test Data Used in Clay Ceramics Manufacturing Final Rule

. Memorandum from Gabrielle Raymond, RTI International, to Sharon Nizich

, EPA/OAQPS/SP PD

. September 24 , 2015.