Date: September 24, 2015

To: Sharon Nizich, EPA/OAQPS/SPPD

From: Thomas Holloway and Gabrielle Raymond, RTI International

Subject: Methodology and Assumptions Used to Estimate the Model Costs and Impacts of 

Clay Ceramics Air Pollution Control Devices for the Final Rule

I. Introduction

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 the 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 

regulated 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 proposed new standards for clay ceramics

manufacturing, including standards for HF, HCl, mercury (Hg), non-Hg HAP metals 

(specifically, the PM surrogate), and dioxins/furans. The EPA provided a 90-day public 

comment period following proposal of the Clay Ceramics Manufacturing 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, incorporated 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. The purpose of this memorandum is to present the methodology and assumptions 

used in estimating the model costs and environmental and energy impacts for the control 

technologies used to meet the standards in the final rule.

 1 Sierra Club v. EPA, 479 F.3d 875 (D.C. Cir. 2007).
2

II. General Model Parameters

Model control device costs and impacts were developed for kilns and spray glaze

operations in both the sanitaryware and ceramic tile industry sectors and for press dryers and 

spray dryers in the ceramic tile industry sector. The model control device costs and impacts for 

kilns, spray glaze operations, process dryers, and spray dryers were estimated based on a variety 

of model parameters: (1) general parameters such as operating hours, production rate (for kilns), 

glaze spray rate (for spray glaze operations), process rate (for press dryers and spray dryers), gas 

flow rate, electricity and waste disposal unit costs, labor wage rates, and emissions; and 

(2) control-specific parameters such as control device horsepower (hp) requirements, filter bag

life, filter bag area, filter bag unit cost, sorbent requirements, and sorbent unit cost. This section 

discusses the basis for the general model parameters.

Model parameters for sanitaryware tunnel kilns and ceramic tile roller kilns were 

developed for two control device sizes--large control devices (LCD) and small control devices 

(SCD)--based on kiln production rate. Model control device parameters for sanitaryware spray 

glaze operations were developed for each of the glazing processes used in the sanitaryware 

sector: manual, spray machine (or chain-on-edge), and robot. Model control device parameters 

for ceramic tile spray glaze operations were developed for large and small wet scrubbers and 

large and small fabric filters, based on data for spray glaze operations equipped with those 

controls. Model parameters for ceramic tile press dryers were developed for a single model, 

based on all press dryers. Similarly, model parameters for ceramic tile spray dryers were 

developed for a single model, based on all spray dryers. Note that for the final rulemaking, only 

the general model parameters for sanitaryware sources were updated from the proposed 

parameters, as there are no major sources in the ceramic tile industry sector. See Methodology 

and Assumptions Used to Estimate the Model Costs and Impacts of Clay Ceramics Air Pollution 

Control Devices (Holloway and Raymond, 2014) for the model parameters for ceramic tile 

sources. The final general model parameters for sanitaryware are presented in Appendix A at the 

end of this memorandum.

The operating hours for model kilns, model spray glaze operations, model press dryers, 

and model spray dryers (in hours per year [hr/yr]) were based on actual operating hours from 

industry responses to the 2008 clay ceramics section 114 survey. The model kiln production rates 

(in tons per hour [tph]) were based on permitted capacities; i.e., the maximum production rates to 

which the kilns are actually limited. The model glaze spray rates (in tph), model exhaust gas flow 

rates (in actual cubic feet per minute [acfm]), model press dryer process rates, and model spray

dryer process rates were based on data from clay ceramics stack tests (Raymond, 2014b).

Unit costs for electricity ($0.067/kilowatt-hour [kWh]) were based on actual cost data

from the 2008 clay ceramics survey responses. Unit costs for waste disposal ($51.90/ton waste) 

were based on data from a 2015 survey of the brick and structural clay products (BSCP) industry 

conducted by the Brick Industry Association (BIA), provided to the EPA in the BIA’s public 

comments on the BSCP proposed rule (Regina, 2015). The operator wage rate ($22.67/hr) was 

based on mean hourly wage data from the May 2011 Bureau of Labor Statistics for NAICS 

327100 (Clay Product and Refractory Manufacturing) for an Industrial Engineering Technician

(BLS, 2012). The maintenance wage rate ($24.94/hr) was assumed to be 10 percent higher than

the operator wage rate.
3

Capital recovery factors were calculated using Equation 1 for the control devices

expected to be used to comply with the new standards for clay ceramics manufacturing:

Equation 1—Capital recovery factor:

(1 ) 1

(1 )

+ −

× + = n

n

i

i i CRF

where:

i = interest rate (percent [%]) and

n = payment period, e.g., equipment life (yrs).

Model uncontrolled emissions estimates (in pounds per ton [lb/ton]) were used to 

estimate the amount of material captured by the control devices, based on each device’s control 

efficiency. The pollutants of interest were HF, HCl, PM, Hg, non-Hg HAP metals, 

dioxins/furans, and sulfur dioxide (SO2). The model uncontrolled emissions estimates for 

sanitaryware tunnel kilns and ceramic tile roller kilns were based on the average of kiln 

emissions data from stack tests for those types of kilns (Raymond, 2014b). Uncontrolled 

emissions estimates for non-Hg HAP metals from glazing operations were assumed to be equal 

to the ratio of HAP metals to PM emissions for sanitaryware tunnel kilns.

III. Model Costs

This section discusses the methodology and assumptions used to estimate the model costs 

for the emission control devices that clay ceramics facilities are expected to install new or retrofit

in order to comply with the new standards for the clay ceramics industry. The cost estimates are 

presented in 2011 dollars, which was the latest year for which an annual cost index value was 

available for scaling costs at the time that costs were first being developed for the clay ceramics

rule. The model cost tables for new and retrofit control devices are presented in Appendices B

and C, respectively. (Note: The annual operating costs for replacement control devices presented 

in this memorandum are a conservative estimate. The operating costs for control devices to be 

replaced have not been subtracted out.)

Dry sorbent injection/fabric filter (DIFF). Dry sorbent injection followed by a fabric filter 

(DIFF) can be used to reduce emissions of both particulates and acid gases from clay ceramics 

kilns. This type of control system is already in use in the ceramic tile sector (Raymond, 2014a)

and would be expected to be installed on uncontrolled kilns or retrofitted to replace or 

supplement less efficient kiln controls to enable facilities to comply with the new clay ceramics 

standards.

The DIFF costs were estimated using cost algorithms from the original clay ceramics 

rulemaking (Shrager, 2003a), which were generated following guidelines in the OAQPS Control 

Cost Manual (EPA, 2002). The algorithms were updated to include more recent model 

parameters, including the general parameters discussed previously and the following parameters 

specific to DIFF control devices:
4

• Control efficiency (e.g., 99.5% HF, 94% PM)

• Fan horsepower (varies by industry sector, model size)

• Total horsepower for other motors (varies by industry sector, model size)

• Stoichiometric ratio of hydrated lime (varies by industry sector, model size)

• Bag life (5 yrs)

• Gas-to-cloth ratio (3.4 feet per minute [ft/min])

• Bag area (28 square feet [ft2])

• Compressed air (0.9 cubic feet [ft3

] of compressed air/1,000 ft3 of gas)

• Time to replace bags (2.25 hr/bag)

• Hydrated lime unit cost ($160/ton)

• Bag fabric cost ($8.15/ft2)

• Compressed air unit cost ($0.363/1,000 ft3

)

• System capital recovery factor (0.0944, based on 20-yr equipment life and 7% 

interest)

• Bag capital recovery factor (0.244, based on 5-yr bag life and 7% interest)

With a few exceptions, the values of the model DIFF parameters were determined based 

on averages of industry responses to the 2008 survey for the brick and structural clay products 

(BSCP) industry, or data from the 2003 BSCP survey database (Shrager, 2003b), both of which 

had significantly more information on DIFF controls. The compressed air unit cost was based on 

data from the 2015 BIA survey (Regina, 2015), while the model DIFF control efficiencies, 

horsepower, and stoichiometric ratios of hydrated lime were determined differently, as discussed 

below. 

The control efficiencies for new and retrofit DIFF were estimated based on the average of 

those BSCP stack tests with better efficiencies than the baseline control efficiency (which was 

determined based on the average of all available BSCP stack tests with control efficiency data)

(Raymond, 2014c). For example, the baseline HF control efficiency for a DIFF is estimated to be 

98 percent; in BSCP stack tests with HF control efficiencies better than 98 percent, the average 

HF control efficiency is 99.5 percent. The horsepower values for fans and other motors and the 

stoichiometric ratio of hydrated lime were scaled from the respective values estimated for the 

small BSCP model, using model gas flow rates to scale the values. The stoichiometric ratio of 

hydrated lime for new and retrofit DIFF was estimated by scaling down the ratio used for BSCP 

models using a ratio of model flow rates.

The model DIFF capital costs were estimated by taking DIFF capital cost data from the 

industry responses to the 2008 BSCP survey or from the 2003 BSCP survey database (Shrager, 

2003b), escalating the costs to 2011 dollars using the Chemical Engineering Plant Cost Index 

(CEPCI) (CE, 2011), scaling the costs to the large and small model sizes using the six-tenths cost 

rule (see Equation 2 below), taking the average of the scaled costs for each model size, and 

rounding the results to three significant figures.
5

Equation 2—Six-tenths cost rule:

0.6

2

1

2

1















 = Q

Q

C

C

where:

C = capital cost and

Q = capacity parameter (e.g., exhaust gas flow rate).

For retrofits, the capital costs were further adjusted using a retrofit factor of 1.4, which is 

in the middle of the range of retrofit factors for emission control devices, according to guidance 

from EPA’s Control Cost Manual (EPA, 2002).

The model DIFF annual costs were estimated based on the aforementioned cost 

algorithms, and include the following cost items:

• Operating labor (assumed to be twice the maintenance labor hours at $22.67/hr)

• Supervisory labor (estimated at 15% of operating labor)

• Maintenance labor (estimated based on 1.25 hr/shift from BSCP survey responses and 

an assumed $24.94/hr wage rate)

• Maintenance materials (estimated at 100% of maintenance labor)

• Electricity (estimated based on hp requirements, 0.745 kW/hp, and $0.067/kWh

electricity unit cost)

• Lime (estimated based on hydrated lime makeup and $160/ton hydrated lime unit 

cost)

• Compressed air (estimated based on 0.9 ft3

/1,000 ft3 compressed air requirements and 

$0.363/1,000 ft3 compressed air unit cost)

• Replacement bags (estimated based on 3.4 ft/min gas-to-cloth ratio, $8.15/ft2 bag 

fabric cost, and 0.244 bag capital recovery factor)

• Bag replacement labor (estimated based on 3.4 ft/min gas-to-cloth ratio, 28 ft2 bag 

area, $24.94/hr maintenance wage rate, and 0.244 bag capital recovery factor)

• Waste disposal (estimated based on waste generated and $51.90/ton waste disposal 

unit cost)

• Overhead (estimated at 60% of labor and maintenance materials)

• Property taxes, insurance, and administrative charges (estimated at 4% of total capital 

cost)

• Capital recovery (estimated as the product of a 0.0944 capital recovery factor and 

total capital cost, minus the cost of capital recovery for replacement bags and bag 

replacement labor)

Fabric filter. Fabric filters are currently used to control emissions of particulates from 

spray glaze operations at clay ceramics plants. Fabric filters can also be used to control emissions 

of particulates from kilns at clay ceramics plants if the kilns already have acid gas control or 
6

have inherently low acid gas emissions (e.g., due to low fluoride and chloride content in the raw 

materials). While stand-alone fabric filters are not currently used by the clay ceramics industry to 

control kiln emissions, DIFF are used by the ceramic tile sector to control kiln emissions

(Raymond, 2014a). The following concerns were expressed by the BSCP industry about using 

stand-alone fabric filters to control their kiln emissions (Holloway, 2013b), which may also 

apply to the clay ceramics industry:

• Without the dry lime injection that reduces the acid gas, there will not be enough 

particulates in the kiln exhaust to coat the bags and get good performance from the 

fabric filter.

• The uncontrolled acid in the exhaust stream could rot the bags.

• The exhaust gas temperatures from kilns can be high (about 400°F on average, as 

high as 668°F).

• The use of membrane bags on low inlet loadings.

In response to these concerns, we contacted two major fabric filter vendors—Solios 

Environment and McGill AirClean—and a major filter bag vendor—W.L. Gore & Associates—

to determine the feasibility of using stand-alone fabric filters in the BSCP industry.

A representative from one of the fabric filter vendors (Solios Environment) agreed with 

BSCP industry concerns that that the lack of a dust cake would negatively impact total outlet 

emissions and that the dust cake serves an important function for acid gas neutralization. He 

noted that the bag choices for high-temperature applications are limited to fiberglass, with an 

upper temperature limit of 500°F, and that fiberglass degrades rapidly in the presence of HF acid 

gas. While polytetrafluoroethylene (PTFE) fabric (known by the brand name Teflon®) also has a 

limit of 500°F and is impervious to most acid gases, he noted that it carries a very significant 

price premium. He indicated that Aramid, Ryton, and P-84 fabrics are generally limited to 400°F 

operation, but noted that these fabrics are sensitive to degradation not only by the acid gases but 

also the relatively high oxygen concentration in brick kiln gases (Hansen, 2013).

A representative from the other fabric filter vendor (McGill AirClean) stated that a brick 

plant should be able to use a stand-alone baghouse to control just filterable particulate emissions 

from a brick kiln. According to the vendor, if the concern is low dust load and not being able to 

establish a good dust cake, then bags with an expanded PTFE membrane could be used. He noted 

that membrane bags usually control outlet particulate emissions to very low levels and are not 

cost prohibitive any more. Like Solios, he stated that the base fabric for the membrane can be a 

woven fiberglass fabric, which is good for a 500°F continuous operating temperature. If there is 

HF in the gas stream, he said that this could damage the fiberglass, so scrubbing would be a good 

idea, depending on the amount of HF present. He said that acid gases in moderate concentrations 

usually do not cause fabric degradation if the bags are continuously operated above the acid gas 

dewpoints. Regarding operating temperatures above 500°F, he said there are some fabrics that 

are available for continuous operation at these temperatures but none with a membrane. He noted 

that the plant could consider flue gas cooling using a dry-bottom evaporative cooler or a gas-toair heat exchanger to reduce the gas temperature to a level where conventional fabrics could be 

used safely (Childress, 2013b).
7

A representative from the bag fabric vendor (W.L. Gore & Associates) noted that his 

company had done business with the brick industry before and that they have two kinds of bags 

that could be used for the industry: (1) high-temperature fiberglass bags, and (2) hightemperature PTFE (Teflon®) bags. Both are rated to 500°F. He indicated that a ceramic style bag 

would be needed for temperatures above 500°F. He could not speak to the concern regarding PM 

loading, but did say that there would be no problem with PM loadings as low as 1 to 2 grains per 

cubic foot. He noted that HF destroys fiberglass, so PTFE bags would be needed if HF emissions 

are a concern. He noted that PTFE bags, unlike fiberglass bags, are chemically inert, but are very 

expensive, about 2 to 5 times more expensive than fiberglass. He also noted that PTFE bags have 

high chemical and thermal resistance and would control PM but not acid gas (Holloway, 2013c).

Based on the information obtained from vendors, we stated at proposal that fabric filters 

can potentially be an effective control option for clay ceramics kilns, if acid gas levels 

(especially HF) are already inherently low or effectively controlled and exhaust gas temperatures 

are not too high. The fabric filter costs for kilns and spray glaze operations were estimated using 

the DIFF cost algorithms, minus the capital cost for a dry sorbent injection system (Holloway, 

2009) and annual cost for sorbent, and with a revised annual cost for waste disposal that excludes 

any acid gas control.

Activated carbon injection (ACI) and other mercury controls. Injecting activated carbon 

before the particulate control device (e.g., fabric filter) has been demonstrated to control 

emissions of mercury and dioxins/furans from a variety of combustion devices (e.g., waste 

incinerators, industrial boilers, cement kilns). In the absence of a national mercury standard for 

the clay ceramics industry, there are currently no clay ceramics plants that use ACI. However, 

given the effective mercury and dioxin/furan control performance achieved in these other 

industries and on similar sources (e.g., Portland cement kilns), we believed it prudent to explore 

this control technology as an option to reduce mercury and dioxin/furan emissions from the clay 

ceramics industry. Both mercury and dioxin are present in the raw materials used in the clay 

ceramics industry (dioxins in particular can be found in ball clay).

To obtain information on the feasibility and cost of adding an ACI system to an existing 

DIFF control system for kilns, we first contacted a fabric filter vendor (McGill AirClean). While 

a representative from the vendor indicated that his company does not have data on control of 

mercury emissions from kilns (all of the company’s mercury control experience is with 

municipal waste incinerators), he indicated that it should not be difficult or expensive to add an 

ACI system to an existing DIFF control system on a kiln. He said that a simple bag dump system 

with a blower could be used and would require little additional space at the site. He also noted 

that the slight increase in inlet PM loading to the baghouse should not affect the performance of 

the baghouse (Childress, 2013a).

We then contacted an ACI vendor (Cabot Norit Activated Carbon) to obtain information 

on the feasibility and cost of installing an ACI system for control of mercury emissions from 

kilns. A representative from the company stated that he thought ACI would work well with kilns. 

He indicated that it would cost about $0.80 to $0.90/lb for carbon (Holloway, 2013a). He also 

indicated that, for applications using baghouses (e.g., a DIFF), an activated carbon feed rate of 

0.5 to 3 pounds per million actual cubic feet (lb/MMacf) is typical; he suggested using 

2 lb/MMacf as a baseline (Thompson, 2013).
8

The model ACI costs for clay ceramics kilns were estimated based on ACI cost 

algorithms for a similarly-sized combustion device, specifically hazardous waste combustors 

(HWCs). We used the cost algorithms in the 2005 technical support document (TSD) for the 

HWC MACT replacement standards (EPA, 2005), using the general parameters discussed in the 

previous section and the carbon injection rate (2 lb/MMacf [Thompson, 2013]) and carbon unit 

cost (average of $0.85/lb [Holloway, 2013a]) from the ACI vendor. To determine the purchased 

equipment cost (PEC), the total equipment cost from the TSD was scaled to the clay ceramics 

model kiln sizes using the six-tenths cost rule, sales tax and freight charges were added, the 

resulting cost was escalated to 2011 dollars, and a retrofit factor of 1.15 was applied (CE, 2011;

EPA, 2005). To determine the total direct capital costs, installation costs were added to the total 

PEC (EPA, 2005). In addition to these direct costs, indirect costs of engineering, construction 

and field expense, contractor fees, startup, performance test, model study, and contingencies 

were also estimated (EPA, 2005).

The model ACI annual costs were also estimated based on the aforementioned cost 

algorithms (EPA, 2005) and include the following cost items:

• Operating labor (assumed based on 1 hr/day at $22.67/hr)

• Supervisory labor (estimated at 15% of operating labor)

• Maintenance labor (estimated based on 0.5 hr/shift and an assumed $29.94/hr wage 

rate)

• Maintenance materials (estimated at 5% of the PEC)

• Electricity (estimated based on hp requirements, 0.9 fan efficiency, 0.745 kW/hp, and 

$0.067/kWh electricity unit cost)

• Carbon (estimated based on carbon feed rate and $0.85/lb carbon unit cost)

• Waste disposal (estimated based on waste generated and $51.90/ton waste disposal 

unit cost)

• Overhead (estimated at 60% of labor and maintenance materials)

• Property taxes, insurance, and administrative charges (estimated at 4% of total capital 

cost)

• Capital recovery (estimated as the product of a 0.1098 capital recovery factor and 

total capital cost, assuming a 15-year equipment life and 7% interest)

In public comments on the proposed rule, the Tile Council of North America (TCNA) 

(Gilberg, 2015) objected to the use of activated carbon injection (ACI) systems in their industry. 

However, the commenter did not provide specific data to demonstrate the infeasibility of the 

emission control, which has been demonstrated for similar sources, e.g., Portland cement kilns.

Nonetheless, as a result of this comment, we investigated other possible technologies for limiting 

mercury emissions, including, but not limited to, the following:

• Halogenated carbon sorbents, such as brominated activated carbon from Albemarle 

Corp., which is effective in reducing both elemental and oxidized mercury 

(Albemarle, 2015).

• Reagents, such as Amended Silicates HgX (As-HgXTM) from Novinda, which reacts 

chemically with vapor-phase mercury to create a solid compound that is effectively 

captured by the plant’s PM control system (Novinda, 2015).
9

• Enhanced ACI technology, such as the Mer-CureTM mercury reduction system from 

Alstom, which uses a unique injection methodology designed to minimize mass 

transfer limitations between the vapor phase mercury and carbon sorbent (Alstom, 

2014).

• New technologies, such as Mercury Capture Systems (MCS) from SCB International 

Materials, Inc., which thermally desorb and chemically capture mercury (Poling et al., 

2015).

Brominated ACI and AS-HgXTM are expected to be more expensive that plain ACI 

(Morris, 2012; Novinda, 2015). Because Mercury Capture Systems include more complex 

equipment, such as thermal desorbers and gas reactors (Poling et al. 2015), compared to plain 

ACI, they also are expected to be more expensive. While costs for the Mer-CureTM system may 

become less expensive than plain ACI over time (Alstom, 2014), this is a new market that will 

likely need time to grow. For these reasons, we decided to use ACI costs in our cost and impacts 

analyses for mercury control. However, this decision is not intended to indicate that the EPA 

expects every clay ceramics manufacturing owner or operator to select ACI as the technology to 

reduce mercury emissions. Instead, the EPA expects that each owner or operator will evaluate 

the available technologies, including those listed above, and determine which technology would 

be most appropriate for the individual kiln.

IV. Model Impacts

This section discusses the methodology and assumptions used to estimate the model 

environmental and energy impacts associated with emission control devices that clay ceramics 

plants are expected to install new or retrofit in order to comply with the new standards for the 

clay ceramics industry. The model impacts parameters and calculations are presented in 

Appendix D. The model impacts tables for new and retrofit control devices are presented in 

Appendices E and F, respectively.

A. Emission Reductions

Model emission reductions were estimated for the major pollutants emitted from clay 

ceramics kilns, including both HAP (HF, HCl, HAP metals, and dioxins/furans) and non-HAP

(PM and SO2). In most cases, we were able to determine the model emission reductions (in tons 

per year [tpy]) by multiplying the model uncontrolled emission factors (lb/ton) in Appendix A by 

the model production rate (tph) and operating hours (hr/yr) in Appendix A and the appropriate 

control efficiency (%) in Appendix D, and dividing by a conversion factor of 2,000 lb/ton.

B. Energy Impacts

To determine the annual amount of electricity (in kilowatt-hours per year [kWh/yr])

needed to power the control device, the horsepower requirements (hp) of the control device were 

multiplied by a conversion factor of 0.745 kW/hp and the annual operating hours (hr/yr). The 

annual amount of energy (in million British thermal units per year [MMBtu/yr]) needed to 

generate this electricity was then determined by dividing the electricity requirements (kWh/yr) 

by the nationwide average power plant efficiency (35 percent) and multiplying by a conversion 

factor of 3,415 British thermal units per kilowatt hour (Btu/kWh).
10

The efficiency for each type of power plant was determined by dividing the heat content 

of electricity (3,415 Btu/kWh) by the heat rate for each type of plant (10,415 Btu/kWh for coal; 

8,185 Btu/kWh for natural gas; 10,452 Btu/kWh for nuclear power; and 9,756 Btu/kWh for 

renewable energy). The nationwide average power plant efficiency was determined as a 

weighted average of these power plant efficiencies, based on the projected fuel mix for 2015 

from Version 3.0 of EPA’s Integrated Planning Model (IPM), which is a forecast model of the 

U.S. electric power sector (EPA, 2011). The projected fuel mix is 53 percent coal, 22 percent 

natural gas/other, 17 percent nuclear, and 8 percent renewable/hydroelectric (EPA, 2011).

C. Secondary Air Emissions

Once the model energy impacts were determined, the associated model secondary air 

emissions were estimated. Secondary emissions typically include the criteria air pollutant 

emissions—PM, carbon monoxide (CO), nitrogen oxides (NOX), and SO2—that result from the 

generation of electricity used to operate the control devices. For purposes of this analysis, the 

electricity was assumed to be purchased from offsite power plants. The secondary emissions 

were estimated by multiplying emission factors for the pollutants by the energy impacts, 

assuming a specific mix of fuels to generate the needed electricity (noted in the previous section)

(EPA, 2011).

We used a variety of information sources to obtain the emission factors used to estimate 

the secondary emissions. For natural gas combustion, we used emission factors (in pound per 

cubic foot [lb/ft3

] of natural gas) from the AP-42 chapter on natural gas combustion to estimate 

the secondary emissions for PM, CO, NOX, and SO2 (EPA, 1998a). We used the AP-42 

conversion factor of 1,020 Btu/ft3 of natural gas to convert the emission factors to pounds per 

million British thermal units (lb/MMBtu) to facilitate estimating the secondary emissions for

these pollutants from natural gas (EPA, 1998a).

For solid fuel (coal) combustion, we used emission limits (in lb/MMBtu) from the new 

source performance standards (NSPS) for utility plants (40 CFR part 60, subpart Da; 2006 CFR 

edition) to estimate the secondary emissions for PM and SO2 (EPA, 2006). We used emission 

factors (in lb/ton coal) from the AP-42 chapter on coal combustion to estimate the secondary 

emissions for NOX and CO; we specifically used the AP-42 emission factors for 

bituminous/subbituminous coal combustion/spreader stokers (EPA, 1998b). The NOX emission

factor was based on an average of the AP-42 emission factors for spreader stoker type boilers

burning bituminous (11 lb/ton) and subbituminous (8.8 lb/ton) coal. We used the AP-42 

conversion factor of 13,000 Btu/lb of coal to facilitate estimating the secondary emissions for 

NOX and CO from coal (EPA, 1998b).

All secondary air impacts were attributed to the combustion of coal, natural gas, or 

“other” fuels at offsite power plants. We attributed no secondary air impacts to nuclear, 

hydroelectric, or renewable energy generation. The secondary air impacts for “other” fuels were 

assumed to be equivalent to those for natural gas.
11

D. Solid Waste and Wastewater Impacts

We estimated the solid waste impacts associated with the DIFF and fabric filter by 

calculating the amount of material captured by the control device. The material captured by the 

fabric filter includes just PM from the kiln, while the material captured by the DIFF includes:

• Reaction products from the reaction of the lime with the acid gases,

• Unreacted lime, and

• Particulate matter from the kiln.

E. Impacts for New vs. Retrofit Control Devices

Impacts were estimated for the following control scenarios for sanitaryware sources and 

are presented in the appendix tables cited below:

• Installation of new DIFF on uncontrolled kiln (see Table E-1)

• Installation of new fabric filter on uncontrolled kiln (where acid gas levels and 

exhaust gas temperatures are low) or retrofit of fabric filter on controlled kiln (see 

Table E-2)

• Replacement of existing control system (e.g., wet scrubber, DIFF, FF) on kiln with a 

new control system (e.g., DIFF, FF) (see Table F-1)

• Addition of ACI system to an existing control system (e.g., DIFF) on kiln (see Table 

F-2)

• Retrofit of fabric filter on glaze spray booth (see Table F-3)

To estimate the incremental impacts for replacement control devices (e.g., replacing an 

existing wet scrubber with a new DIFF), the impacts associated with baseline controls were 

subtracted from the impacts associated with new controls.

V. References

Albemarle Corp. 2015. Sorbents. Available at: http://www.albemarle.com/products---

markets/performance-chemicals/specialty-chemicals/mercury-control/sorbents-164.html.

Accessed September 14, 2015.

Alstom. 2014. Mer-CureTM: Mercury reduction system. Boiler Service Solutions. 2014. 

Available at: http://www.alstom.com/Global/Power/Resources/Documents/Brochures/aqcsmer-cure-mercury-reduction-system.pdf?epslanguage=en-GB. Accessed September 14, 2015.

BLS (U.S. Department of Labor, Bureau of Labor Statistics). 2012. Occupational Employment 

Statistics: May 2011 National Industry-Specific Occupational Employment and Wage 

Estimates. NAICS 327100 - Clay Product and Refractory Manufacturing. Industrial 

Engineering Technician. March 27, 2012. Available at: 

http://www.bls.gov/oes/2011/may/naics4_327100.htm. Docket Item No. EPA-HQ-OAR2013-0290-0176.

CE (Chemical Engineering). 2011. Plant Cost Index.
12

Childress, J. 2013a. “RE: From McGill AirClean Web Site.” E-mail from Jerry Childress, 

McGill AirClean LLC, to Thomas Holloway, RTI. April 18, 2013. Docket Item No. EPAHQ-OAR-2013-0290-0103.

Childress, J. 2013b. “RE: From McGill AirClean Web Site.” E-mail from Jerry Childress, 

McGill AirClean LLC, to Thomas Holloway, RTI. June 27, 2013. Docket Item No. EPAHQ-OAR-2013-0290-0108.

EPA (U.S. Environmental Protection Agency). 1998a. Compilation of Air Pollutant Emission 

Factors. Volume 1: Stationary Point and Area Sources. AP-42, Section 1.4: Natural Gas 

Combustion. July 1998. Docket Item No. EPA-HQ-OAR-2013-0290-0149.

EPA (U.S. Environmental Protection Agency). 1998b. Compilation of Air Pollutant Emission 

Factors. Volume 1: Stationary Point and Area Sources. AP-42, Section 1.1: Bituminous and 

Subbituminous Coal Combustion. September 1998. Docket Item No. EPA-HQ-OAR-2013-

0290-0150.

EPA (U.S. Environmental Protection Agency). 2002. EPA Air Pollution Control Cost Manual. 

Sixth Edition. Office of Air Quality Planning and Standards, Research Triangle Park, NC. 

Publication No. EPA/452/B-02-001. January 2002. Docket Item No. EPA-HQ-OAR-2013-

0290-0153.

EPA (U.S. Environmental Protection Agency). 2005. Technical Support Document for the HWC 

MACT Replacement Standards, Volume V: Emissions Estimates and Engineering Costs. 

Office of Solid Waste and Emergency Response, Washington, DC. September 2005. Docket 

Item No. EPA-HQ-OAR-2013-0290-0160.

EPA (U.S. Environmental Protection Agency). 2006. “Subpart Da—Standards of Performance 

for Electric Utility Steam Generating Units for Which Construction is Commenced After 

September 18, 1978.” Code of Federal Regulations. Title 40, Part 60. Published by Office of 

the Federal Register, National Archives and Records Administration. As of July 1, 2006.

EPA (U.S. Environmental Protection Agency). 2011. Regulatory Impact Analysis for the Final 

Mercury and Air Toxics Standards. Table 3-6: Generation Mix with the Base Case and the 

MATS, 2015 (Thousand GWh). Publication No. EPA-452/R-11-011. December 2011.

Docket Item No. EPA-HQ-OAR-2013-0290-0173.

Gilberg, H. 2015. “RE: Public Comments of the Tile Council of North America, Inc.” Letter 

from Howard L. Gilberg, Guida, Slavich & Flores (TCNA Counsel), to EPA Docket ID No. 

EPA-HQ-OAR-2013-0290 and Sharon Nizich, EPA/OAQPS/SPPD. March 19, 2015. Docket 

Item No. EPA-HQ-OAR-2013-0290-0247.

Hansen, L. 2013. “RE: Question regarding use of fabric filters for brick kilns.” E-mail from Lars 

Hansen, Solios Environment Corp., to Thomas Holloway, RTI International. July 2, 2013.

Docket Item No. EPA-HQ-OAR-2013-0290-0109.

Holloway, T. 2009. Revised Baseline Operating Costs for Existing HMIWI. Memorandum from 

Thomas Holloway, RTI International, to Ketan Patel, OAQPS/SPPD/NRCG. June 19, 2009.
13

Holloway, T. 2013a. Telephone Contact Summary: Jeff Thompson, Cabot Norit Activated 

Carbon. Contacted by Thomas Holloway, RTI International. May 16, 2013. Docket Item No.

EPA-HQ-OAR-2013-0290-0106.

Holloway, T. 2013b. “RE: From McGill AirClean Web Site.” E-mail from Thomas Holloway, 

RTI International, to Jerry Childress, McGill AirClean LLC. June 26, 2013. Docket Item No.

EPA-HQ-OAR-2013-0290-0108.

Holloway, T. 2013c. Telephone Contact Summary: Chris Polizzi, W.L. Gore & Associates, Inc.

Contacted by Thomas Holloway, RTI International. July 16, 2013. Docket Item No. EPAHQ-OAR-2013-0290-0110.

Holloway, T., and G. Raymond. 2014. Methodology and Assumptions Used to Estimate the 

Model Costs and Impacts of Clay Ceramics Air Pollution Control Devices. Memorandum 

from Thomas Holloway and Gabrielle Raymond, RTI, to Jeff Telander, 

USEPA/OAQPS/SPPD. November 6, 2014. Docket Item No. EPA-HQ-OAR-2013-0290-

0227.

Morris, L. 2012. “Solutions for Controlling Mercury.” Power Engineering. Volume 116, Issue 4. 

April 1, 2012. Available at: http://www.power-eng.com/articles/print/volume-116/issue4/features/solutions-for-controlling-mercury.html. Accessed September 14, 2015.

Novinda. 2015. What is Amended SilicatesTM? Available at: http://www.novinda.com/producttechnologies/mercury-removal/what-is-amended-silicates/. Accessed September 14, 2015.

Poling, C. et al. 2015. A Novel Approach for Mercury Capture. Presentation by Christopher L. 

Poling, Melissa Harrison, and Paul Longo, SCB International Materials, Inc., to U.S. 

Environmental Protection Agency. 2015.

Raymond, G. 2014a. Updated Inventory Database and Documentation for Clay Ceramics

Proposed Rule. Memorandum from Gabrielle Raymond, RTI International, to Jeff Telander, 

EPA/OAQPS/SPPD. November 6, 2014. Docket Item No. EPA-HQ-OAR-2013-0290-0222.

Raymond, G. 2014b. Test Data Used in Clay Ceramics Proposed Rule. Memorandum from 

Gabrielle Raymond, RTI International, to Jeff Telander, EPA/OAQPS/SPPD. November 6, 

2014. Docket Item No. EPA-HQ-OAR-2013-0290-0224.

Raymond, G. 2014c. Test Data Used in BSCP Proposed Rule. Memorandum from Gabrielle 

Raymond, RTI International, to Jeff Telander, EPA/OAQPS/SPPD. November 6, 2014.

Docket Item No. EPA-HQ-OAR-2013-0290-0221.

Regina, P. 2015. “RE: Docket no. EPA-HQ-OAR-2013-0291 Brick and Structural Clay Products 

Manufacturing.” Letter from Paul Regina, The Brick Industry Association, to Environmental 

Protection Agency, EPA Docket Center. March 19, 2015. Docket Item No. EPA-HQ-OAR2013-0291-0542.
14

Shrager, B. 2003a. Final Rule: Costs for Air Pollution Control Devices on Clay Ceramics Kilns.

Memorandum from Brian Shrager, RTI International, to Mary Johnson, U.S. Environmental 

Protection Agency. February 26, 2003. Docket ID No. A-2000-48, Item No. IV-B-4.

Shrager, B. 2003b. Final Rule: Documentation of Database and Responses to the 1997 

Information Collection Request for Brick and Structural Clay Products. Memorandum from 

Brian Shrager, RTI International, to Mary Johnson, U.S. Environmental Protection Agency. 

February 28, 2003. Docket ID No. A-99-30, Item No. IV-B-16.

Thompson, J. 2013. “FW: Cabot Norit Activated Carbon–question.” E-mail from Jeff Thompson, 

Cabot Norit Activated Carbon, to Thomas Holloway, RTI International. May 31, 2013.

Docket Item No. EPA-HQ-OAR-2013-0290-0107.
Appendix A

Model Parameters for Sanitaryware Sources
A-2

Table A-1. General Parameters for Sanitaryware Model Tunnel Kiln Control Devices

Parameters SCD TK LCD TK Footnotes

Process parameters

Production rate, ton/hr 0.6 2.4 1

Operating hours, hr/yr 8,760 8,760 1

Exhaust flow, acfm 8,400 17,000 2

Unit costs

Electricity cost, $/kWh 0.067 0.067 1

Waste disposal cost, $/ton 51.90 51.90 3

Operator wage rate, $/hr 22.67 22.67 4

Maintenance wage rate, $/hr 24.94 24.94 5

Uncontrolled emissions, lb/ton

Hydrogen fluoride 0.26 0.26 2

Hydrogen chloride 0.02 0.02 2

HAP metals 0.002 0.002 2

Particulate matter 0.12 0.12 2

Mercury 1.63E-04 1.63E-04 2

Dioxin/furan TEQ 3.44E-09 3.44E-09 2

Sulfur dioxide 3.23 3.23 2

Uncontrolled emissions, lb/hr

Hydrogen fluoride 0.16 0.63 6

Hydrogen chloride 0.01 0.05 6

HAP metals 0.001 0.004 6

Particulate matter 0.07 0.28 6

Mercury 9.78E-05 3.91E-04 6

Dioxin/furan TEQ 2.07E-09 8.26E-09 6

Sulfur dioxide 1.94 7.76 6

1. Average from sanitaryware section 114 survey responses.

2. Average from sanitaryware test data.

3. Average from 2015 BIA survey data.

4. Mean hourly wage, from Bureau of Labor Statistics, May 2011 National Industry-Specific Occupational 

Employment and Wage Estimates, NAICS 327100, Industrial Engineering Technician. Website: 

http://www.bls.gov/oes/2011/may/naics4_327100.htm.. Wage rates from Bureau of Labor Statistics were used 

because site-specific wage rates were considered confidential by clay ceramics section 114 survey respondents.

5. 10 percent higher than operator rate.

6. Calculated from lb/ton times production rate.
A-3

Table A-2. General Parameters for Sanitaryware Model Glaze Spray Booth Control 

Devices

Parameters Manual GSB

Spray 

Machine GSB Robot GSB

Footnote

s

Process parameters

Glaze spray rate, ton/hr 0.09 0.22 0.08 1

Operating hours, hr/yr 3,672 8,568 6,252 2

Exhaust flow, acfm 11,810 14,318 8,717 1

Unit costs

Electricity cost, $/kWh 0.067 0.067 0.067 2

Waste disposal cost, $/ton 51.90 51.90 51.90 3

Operator wage rate, $/hr 22.67 22.67 22.67 4

Maintenance wage rate, $/hr 24.94 24.94 24.94 5

Baseline emissions, lb/ton glaze

HAP metals 0.19 0.08 0.06 6

Particulate matter 14.48 5.93 4.42 2

Baseline emissions, lb/hr

HAP metals 0.02 0.02 0.005 7

Particulate matter 1.32 1.29 0.35 7

1. Average from sanitaryware test data.

2. Average from sanitaryware section 114 survey responses.

3. Average from 2015 BIA survey data.

4. Mean hourly wage, from Bureau of Labor Statistics, May 2011 National Industry-Specific Occupational 

Employment and Wage Estimates, NAICS 327100, Industrial Engineering Technician. Website: 

http://www.bls.gov/oes/2011/may/naics4_327100.htm.. Wage rates from Bureau of Labor Statistics were used 

because site-specific wage rates were considered confidential by clay ceramics section 114 survey respondents.

5. 10 percent higher than operator rate.

6. Assumed HAP metals equal to 1.35% of PM, based on ratio of HAP metals/PM for sanitaryware kilns.

7. Calculated from lb/ton times glaze spray rate.
Appendix B

New Model Costs for Sanitaryware Sources
B-2

Table B-1. Model Costs to Install New DIFF on Sanitaryware Tunnel Kilns

Parameters SCD TK LCD TK Footnotes

Control efficiency, percent

Hydrogen fluoride 99.5% 99.5% 1

Hydrogen chloride 83% 83% 2

HAP metals 94% 94% 3

Particulate matter 94% 94% 1

Sulfur dioxide 49% 49% 4

Design and operating parameters

Fan hp 55 111 5

Total hp for other motors 11 22 5

Hydrated lime, fraction of stoichiometric amount 0.96 1.96 6

Operator labor, hr/shift 2.5 2.5 7

Maintenance labor, hr/shift 1.25 1.25 5

Bag life, yr 5 5 5

Gas-to-cloth ratio (gross), ft/min 3.4 3.4 5

Bag area, ft2 28 28 5

Compressed air, ft3/1,000 ft3 0.9 0.9 5

Time to replace bags, hr/bag 2.25 2.25 5

Added cooling air, ft3/min 0 0 8

Calculated parameters

Hydrated lime makeup, lb/hr 2.5 20

Reaction products, lb/hr 0.02 0.08 9

Reacted lime, lb/hr 0.01 0.05

Waste, lb/hr 2.5 20 10

Cost factors

Hydrated lime, $/ton 160 160 5

Bag fabric cost, $/ft2 8.15 8.15 5

Compressed air, $/1,000 ft3 0.363 0.363 11

Capital recovery factor--system 0.0944 0.0944 12

Capital recovery factor--bags 0.244 0.244 12

Capital costs, $

Total capital investment 1,090,490 1,670,521 13

Annual costs, $/yr

Operating labor 62,059 62,059

Supervisory labor 9,309 9,309 14

Maintenance labor 34,133 34,133

Maintenance materials 34,133 34,133 15

Electricity 28,620 58,263 16

Lime 1,718 13,993

Compressed air 1,442 2,936

Annualized replacement bags 4,911 9,997

Annualized bag replacement labor 1,098 2,235 17

Cage replacement 0 0 18

Waste disposal 559 4,545

Overhead 83,780 83,780 19
B-3

Parameters SCD TK LCD TK Footnotes

Administrative charges 21,810 33,410 20

Property taxes 10,905 16,705 21

Insurance 10,905 16,705 21

Capital recovery 102,796 157,404

Total annual cost 408,177 539,607

1. Average from BSCP test data with better efficiency than baseline.

2. Based on ratio of enhanced HF reduction and baseline HCl reduction from BSCP test data.

3. Percent reduction for HAP metals assumed same as PM.

4. Based on ratio of enhanced HF reduction and baseline SO2 reduction from BSCP test data.

5. Average from BSCP section 114 survey responses; hp values ratioed from BSCP section 114 survey responses

using BSCP and sanitaryware tunnel kiln gas flow rates (acfm).

6. Assume hydrated lime is 0.96/1.96 times the stoichiometric amount needed to get additional control re baseline 

(from 98% to 99.5%).

7. Assume 2 times maintenance labor (based on OAQPS Manual).

8. Assume none.

9. CaF2, CaCl2, and CaSO3.

10. Inlet lime minus reacted lime plus reaction products and PM.

11. Average from 2015 BIA survey data.

12. Based on system life of 20 years, bag life of 5 years, and 7 percent interest.

13. Average of costs from BSCP section 114 survey responses scaled to sanitaryware tunnel kilns using 6/10 rule 

(based on acfm), escalated to 2011 dollars, and rounded.

14. 15 percent of operator labor.

15. 100 percent of maintenance labor.

16. Based on conversion factor of 0.745 kW/hp.

17. Performed by maintenance personnel.

18. May be no need to replace.

19. 60 percent of labor and maintenance materials.

20. 2 percent of TCI.

21. 1 percent of TCI.
B-4

Table B-2. Model Costs to Install New Fabric Filter on Sanitaryware Tunnel Kilns

Parameters SCD TK LCD TK Footnotes

Control efficiency, percent

HAP metals 94% 94% 1

Particulate matter 94% 94% 2

Design and operating parameters

Fan hp 55 111 3

Total hp for other motors 11 22 3

Operator labor, hr/shift 2.5 2.5 4

Maintenance labor, hr/shift 1.25 1.25 3

Bag life, yr 5 5 3

Gas-to-cloth ratio (gross), ft/min 3.4 3.4 3

Bag area, ft2 28 28 3

Compressed air, ft3/1,000 ft3 0.9 0.9 3

Time to replace bags, hr/bag 2.25 2.25 3

Added cooling air, ft3/min 0 0 5

Calculated parameters

Waste, lb/hr 0.07 0.27 6

Cost factors

Bag fabric cost, $/ft2 8.15 8.15 3

Compressed air, $/1,000 ft3 0.363 0.363 7

Capital recovery factor--system 0.0944 0.0944 8

Capital recovery factor--bags 0.244 0.244 8

Cost of dry injection system 396,307 635,764 9

Capital costs, $

Total capital investment 694,183 1,034,757 10

Annual costs, $/yr

Operating labor 62,059 62,059

Supervisory labor 9,309 9,309 11

Maintenance labor 34,133 34,133

Maintenance materials 34,133 34,133 12

Electricity 28,620 58,263 13

Compressed air 1,442 2,936

Annualized replacement bags 4,911 9,997

Annualized bag replacement labor 1,098 2,235 14

Cage replacement 0 0 15

Waste disposal 15 61

Overhead 83,780 83,780 16

Administrative charges 13,884 20,695 17

Property taxes 6,942 10,348 18

Insurance 6,942 10,348 18

Capital recovery 65,388 97,392

Total annual cost 352,654 435,687

1. Percent reduction for HAP metals assumed same as PM.

2. Average from BSCP test data with better efficiency than baseline.
B-5

3. Average from BSCP section 114 survey responses; hp values ratioed from BSCP section 114 survey responses 

using BSCP and sanitaryware tunnel kiln gas flow rates (acfm).

4. Assume 2 times maintenance labor (based on OAQPS Manual).

5. Assume none.

6. Particulate matter.

7. Average from 2015 BIA survey data.

8. Based on system life of 20 years, bag life of 5 years, and 7 percent interest.

9. Based on cost equations in the June 19, 2009 memorandum Revised Baseline Operating Costs for Existing 

HMIWI, in Docket ID No. EPA-HQ-OAR-2006-0534 for the hospital/medical/infectious waste incinerator (HMIWI)

rule.

10. Average of costs from BSCP section 114 survey responses scaled to sanitaryware tunnel kilns using 6/10 rule 

(based on acfm), subtracted cost of dry injection system, escalated to 2011 dollars, and rounded.

11. 15 percent of operator labor.

12. 100 percent of maintenance labor.

13. Based on conversion factor of 0.745 kW/hp.

14. Performed by maintenance personnel.

15. May be no need to replace.

16. 60 percent of labor and maintenance materials.

17. 2 percent of TCI.

18. 1 percent of TCI.
Appendix C

Retrofit Model Costs for Sanitaryware Sources
C-2

Table C-1. Model Costs to Retrofit Sanitaryware Tunnel Kilns with DIFF

Parameters SCD TK LCD TK Footnotes

Control efficiency, percent

Hydrogen fluoride 99.5% 99.5% 1

Hydrogen chloride 83% 83% 2

HAP metals 94% 94% 3

Particulate matter 94% 94% 1

Sulfur dioxide 49% 49% 4

Design and operating parameters

Fan hp 55 111 5

Total hp for other motors 11 22 5

Hydrated lime, fraction of stoichiometric amount 0.96 1.96 6

Operator labor, hr/shift 2.5 2.5 7

Maintenance labor, hr/shift 1.25 1.25 5

Bag life, yr 5 5 5

Gas-to-cloth ratio (gross), ft/min 3.4 3.4 5

Bag area, ft2 28 28 5

Compressed air, ft3/1,000 ft3 0.9 0.9 5

Time to replace bags, hr/bag 2.25 2.25 5

Added cooling air, ft3/min 0 0 8

Calculated parameters

Hydrated lime makeup, lb/hr 2.5 20

Reaction products, lb/hr 0.02 0.08 9

Reacted lime, lb/hr 0.01 0.05

Particulate matter, lb/hr 2.5 20

Waste, lb/hr 2.5 20 10

Cost factors

Hydrated lime, $/ton 160 160 5

Bag fabric cost, $/ft2 8.15 8.15 5

Compressed air, $/1,000 ft3 0.363 0.363 11

Capital recovery factor--system 0.0944 0.0944 12

Capital recovery factor--bags 0.244 0.244 12

Retrofit factor 1.4 1.4 13

Capital costs, $

Total capital investment 1,526,686 2,338,729 14

Annual costs, $/yr

Operating labor 62,059 62,059

Supervisory labor 9,309 9,309 15

Maintenance labor 34,133 34,133

Maintenance materials 34,133 34,133 16

Electricity 28,620 58,263 17

Lime 1,718 13,993

Compressed air 1,442 2,936

Annualized replacement bags 4,911 9,997

Annualized bag replacement labor 1,098 2,235 18

Cage replacement 0 0 19
C-3

Parameters SCD TK LCD TK Footnotes

Waste disposal 559 4,545

Overhead 83,780 83,780 20

Administrative charges 30,534 46,775 21

Property taxes 15,267 23,387 22

Insurance 15,267 23,387 22

Capital recovery 143,970 220,478

Total annual cost, $/yr 466,799 629,409

1. Average from BSCP test data with better efficiency than baseline.

2. Based on ratio of enhanced HF reduction and baseline HCl reduction from BSCP test data.

3. Assume same as PM.

4. Based on ratio of enhanced HF reduction and baseline SO2 reduction from BSCP test data.

5. Average from BSCP section 114 survey responses; hp values ratioed from BSCP section 114 survey responses

using BSCP and sanitaryware tunnel kiln gas flow rates (acfm).

6. Assume hydrated lime is 0.96/1.96 times the stoichiometric amount needed to get additional control re baseline 

(from 98% to 99.5%).

7. Assume 2 times maintenance labor (based on OAQPS Manual).

8. Assume none.

9. CaF2, CaCl2, and CaSO3.

10. Inlet lime minus reacted lime plus reaction products and PM.

11. Average from 2015 BIA survey data.

12. Based on system life of 20 years, bag life of 5 years, and 7 percent interest.

13. Average for various control devices (based on OAQPS Control Cost Manual).

14. Average of BSCP costs from section 114 survey responses scaled to sanitaryware tunnel kilns sing 6/10 rule 

(based on acfm), escalated to 2011 dollars, multiplied by retrofit cost factor, and rounded.

15. 15 percent of operator labor.

16. 100 percent of maintenance labor.

17. Based on conversion factor of 0.745 kW/hp.

18. Performed by maintenance personnel.

19. May be no need to replace.

20. 60 percent of labor and maintenance materials.

21. 2 percent of TCI.

22. 1 percent of TCI.
C-4

Table C-2. Model Costs to Retrofit Sanitaryware Tunnel Kilns with Fabric Filter

Parameters SCD TK LCD TK Footnotes

Control efficiency, percent

HAP metals 94% 94% 1

Particulate matter 94% 94% 2

Design and operating parameters

Fan hp 55 111 3

Total hp for other motors 11 22 3

Operator labor, hr/shift 2.5 2.5 4

Maintenance labor, hr/shift 1.25 1.25 3

Bag life, yr 5 5 3

Gas-to-cloth ratio (gross), ft/min 3.4 3.4 3

Bag area, ft2 28 28 3

Compressed air, ft3/1,000 ft3 0.9 0.9 3

Time to replace bags, hr/bag 2.25 2.25 3

Added cooling air, ft3/min 0 0 5

Calculated parameters

Waste, lb/hr 0.07 0.27 6

Cost factors

Bag fabric cost, $/ft2 8.15 8.15 3

Compressed air, $/1,000 ft3 0.363 0.363 7

Capital recovery factor--system 0.0944 0.0944 8

Capital recovery factor--bags 0.244 0.244 8

Cost of dry injection system 396,307 635,764 9

Retrofit factor 1.4 1.4 10

Capital costs, $

Total capital investment 1,130,379 1,702,965 11

Annual costs, $/yr

Operating labor 62,059 62,059

Supervisory labor 9,309 9,309 12

Maintenance labor 34,133 34,133

Maintenance materials 34,133 34,133 13

Electricity 28,620 58,263 14

Compressed air 1,442 2,936

Annualized replacement bags 4,911 9,997

Annualized bag replacement labor 1,098 2,235 15

Cage replacement 0 0 16

Waste disposal 15 61

Overhead 83,780 83,780 17

Administrative charges 22,608 34,059 18

Property taxes 11,304 17,030 19

Insurance 11,304 17,030 19

Capital recovery 106,561 160,466

Total annual cost 411,276 525,489

1. Assume same as PM.

2. Average from BSCP test data with better efficiency than baseline.
C-5

3. Average from BSCP section 114 survey responses; hp values ratioed from BSCP section 114 survey responses 

using BSCP and sanitaryware tunnel kiln gas flow rates (acfm).

4. Assume 2 times maintenance labor (based on OAQPS Manual).

5. Assume none.

6. Particulate matter.

7. Average from 2015 BIA survey data.

8. Based on system life of 20 years, bag life of 5 years, and 7 percent interest.

9. Based on cost equations in the June 19, 2009 memorandum Revised Baseline Operating Costs for Existing 

HMIWI, in Docket ID No. EPA-HQ-OAR-2006-0534 for the HMIWI rule.

10. Average for various control devices (based on OAQPS Control Cost Manual).

11. Average of costs from BSCP section 114 survey responses scaled to sanitaryware tunnel kilns using 6/10 rule 

(based on acfm), subtracted cost of dry injection system, escalated to 2011 dollars, multiplied by retrofit cost factor, 

and rounded.

12. 15 percent of operator labor.

13. 100 percent of maintenance labor.

14. Based on conversion factor of 0.745 kW/hp.

15. Performed by maintenance personnel.

16. May be no need to replace.

17. 60 percent of labor and maintenance materials.

18. 2 percent of TCI.

19. 1 percent of TCI.
C-6

Table C-3. Model Costs to Retrofit Sanitaryware Tunnel Kilns with ACI System

Parameters

MACT Floor Beyond the Floor

Footnotes

Add ACI-1 Add ACI-2 Add ACI-1 Add ACI-2

SCD TK LCD TK SCD TK LCD TK SCD TK LCD TK SCD TK LCD TK

Control efficiency, percent

Mercury 85% 85% 85% 85% 95% 95% 95% 95%

Dioxin/furan TEQ 85% 85% 85% 85% 95% 95% 95% 95%

Design and operating parameters

Carbon injection rate, lb/MMft3 [CIR] 2 2 4 4 3 3 5 5 1

Injection blower fan power, hp 

[Powerfan]

1.9 3.8 1.9 3.8 1.9 3.8 1.9 3.8 2,3

Projected equipment life, yrs [n] 15 15 15 15 15 15 15 15 2

Interest rate, % [i] 7 7 7 7 7 7 7 7

Calculated parameters

Carbon feed rate, lb/hr [CFR] 1.0 2.1 2.0 4.1 1.5 3.1 2.5 5.1 4

Cost factors

Carbon unit cost, $/lb [CC] 0.85 0.85 0.85 0.85 0.85 0.85 0.85 0.85 5

Escalation factor [EF] 1.78 1.78 1.78 1.78 1.78 1.78 1.78 1.78 2,6,7

Capital recovery factor [CRF] 0.1098 0.1098 0.1098 0.1098 0.1098 0.1098 0.1098 0.1098 2,8

Retrofit factor [RF] 1.15 1.15 1.15 1.15 1.15 1.15 1.15 1.15 2

Direct capital costs, $

Purchased equipment costs

Total equipment [TEC] (see Note) 11,967 19,682 11,967 19,682 11,967 19,682 11,967 19,682 2,9

Sales tax 359 590 359 590 359 590 359.00 590 2,10

Freight 598 984 598 984 598 984 598.33 984 2,11

Purchased equipment with tax and 

freight

12,924 21,257 12,924 21,257 12,924 21,257 12,924 21,257 2,12

Purchased equipment with 

escalation

23,005 37,837 23,005 37,837 23,005 37,837 23,005 37,837 2,13

Purchased equipment with retrofit 

factor [PEC]

26,455 43,513 26,455 43,513 26,455 43,513 26,455 43,513 2,14

Installation cost [IC] 7,937 13,054 7,937 13,054 7,937 13,054 7,937 13,054 2,15

Total direct costs [TDC] 34,392 56,567 34,392 56,567 34,392 56,567 34,392 56,567 2,16
C-7

Parameters

MACT Floor Beyond the Floor

Footnotes

Add ACI-1 Add ACI-2 Add ACI-1 Add ACI-2

SCD TK LCD TK SCD TK LCD TK SCD TK LCD TK SCD TK LCD TK

Indirect capital costs, $

Engineering 5,291 8,703 5,291 8,703 5,291 8,703 5,291 8,703 2,17

Construction and field expense 5,291 8,703 5,291 8,703 5,291 8,703 5,291 8,703 2,17

Contractor fees 2,646 4,351 2,646 4,351 2,646 4,351 2,646 4,351 2,18

Start-up 265 435 265 435 265 435 265 435 2,19

Performance test 265 435 265 435 265 435 265 435 2,19

Model study 529 870 529 870 529 870 529 870 2,20

Contingencies 1,587 2,611 1,587 2,611 1,587 2,611 1,587 2,611 2,21

Total indirect costs [TIC] 15,873 26,108 15,873 26,108 15,873 26,108 15,873 26,108 2,22

Total capital cost, $

Total capital investment [TCI] 50,265 82,674 50,265 82,674 50,265 82,674 50,265 82,674 2,23

Annual costs, $/yr

Operating labor 8,275 8,275 8,275 8,275 8,275 8,275 8,275 8,275 2,24

Supervisory labor 1,241 1,241 1,241 1,241 1,241 1,241 1,241 1,241 2,25

Maintenance labor 13,653 13,653 13,653 13,653 13,653 13,653 13,653 13,653 2,26

Maintenance materials 1,323 2,176 1,323 2,176 1,323 2,176 1,323 2,176 2,27

Electricity cost 925 1,849 925 1,849 925 1,849 925 1,849 2,28

Carbon cost 7,506 15,279 15,011 30,558 11,258 22,919 18,764 38,198 2,29

Solid waste disposal cost 229 466 458 933 344 700 573 1,166 2,30

Overhead 14,695 15,207 14,695 15,207 14,695 15,207 14,695 15,207 2,31

Administrative charges 1,005 1,653 1,005 1,653 1,005 1,653 1,005 1,653 2,32

Property tax 503 827 503 827 503 827 503 827 2,33

Insurance 503 827 503 827 503 827 503 827 2,33

Capital recovery 5,519 9,077 5,519 9,077 5,519 9,077 5,519 9,077 2,34

Total annual cost 55,375 70,530 63,110 86,276 59,243 78,403 66,977 94,149 2,35

Notes:

- “Add ACI-1” assumes that 2 lb/MMft3 would be used to achieve either mercury or dioxin/furan emissions reductions. “Add ACI-2” assumes reductions of both.

- Total equipment includes storage silo, feed bin, gravimetric feeders, pneumatic conveyor, and injection ports.

Footnotes:

1. E-mail from Cabot Norit Activated Carbon. May 31, 2013. Suggested carbon concentration of 2 lb/MMft3.
C-8

2. Technical Support Document for HWC MACT Replacement Standards. Volume V: Emissions Estimates and Engineering Costs, Appendix J. September 2005.

3. Scaled HWC hp estimate using ratio of exhaust flow rates: (15 hp) x Q / (66,870.6 acfm).

4. Equal to CIR / 1E6 x exhaust flow x (60 min/hr).

5. Telecon. Cabot Norit Activated Carbon. May 16, 2013. Indicated carbon price would be $0.80 to $0.90/lb. Used average of $0.85/lb.

6. Escalating costs from 2004 (HWC) to 2011 (BSCP) using the following factors: (HWC escalation factor, 1.1319 x 1.064) x (BSCP escalation factor, 1.4805).

7. Chemical Engineering Plant Cost Index.

8. Equal to = [i x (1 + i)n] / [(1 + i)n - 1], where i = 7 percent interest and n = 15-year equipment life.

9. Equal to 90,000 x (exhaust flow/150,000)0.7.

10. Equal to 0.03 x TEC.

11. Equal to 0.05 x TEC.

12. Equal to TEC + (sales tax) + (freight).

13. Equal to EF x (purchased equipment with tax and freight).

14. Equal to RF x (purchased equipment with escalation).

15. Equal to 0.3 x PEC.

16. Equal to PEC + IC.

17. Equal to 0.2 x PEC.

18. Equal to 0.1 x PEC.

19. Equal to 0.01 x PEC.

20. Equal to 0.02 x PEC.

21. Equal to 0.06 x PEC.

22. Equal to sum of indirect costs.

23. Equal to TDC + TIC.

24. Equal to (1 hr/d) x operating hr/yr / (24 hr/d) x operator wage rate ($/hr).

25. Equal to 0.15 x (operator labor cost).

26. Equal to (0.5 hr/shift) x (3 shifts/d) x operating hr/yr / (24 hr/d) x maintenance wage rate ($/hr).

27. Equal to 0.05 x PEC.

28. Equal to Powerfan / (1.34 hp/kW) / (0.9 Efficiencyfan) x operating hr/yr x electricity unit cost ($/kWh).

29. Equal to CFR x operating hr/yr x carbon unit cost ($/lb).

30. Equal to CFR x operating hr/yr / (2000 lb/ton) x waste disposal unit cost ($/ton).

31. Equal to 0.6 x (operating labor cost + maintenance cost).

32. Equal to 0.02 x TCI.

33. Equal to 0.01 x TCI.

34. Equal to CRF x TCI.

35. Equal to sum of annual costs.
C-9

Table C-4. Model Costs to Retrofit Sanitaryware Glaze Spray Booths with Fabric Filter

Parameters Manual GSB

Spray Machine

GSB Robot GSB Footnotes

Control efficiency, percent

HAP metals 94% 94% 94% 1

Particulate matter 94% 94% 94% 2

Design and operating parameters

Fan hp 77 93 57 3,4

Total hp for other motors 15 19 11 3,5

Operator labor, hr/shift 2.5 2.5 2.5 6

Maintenance labor, hr/shift 1.25 1.25 1.25 3

Bag life, yr 5 5 5 3

Gas-to-cloth ratio (gross), ft/min 3.4 3.4 3.4 3

Bag area, ft2 28 28 28 3

Compressed air, ft3/1,000 ft3 0.9 0.9 0.9 3

Time to replace bags, hr/bag 2.25 2.25 2.25 3

Added cooling air, ft3/min 0 0 0 7

Calculated parameters

Waste, lb/hr 1.2 1.2 0.3 8

Cost factors

Bag fabric cost, $/ft2 8.15 8.15 8.15 3

Compressed air, $/1,000 ft3 0.363 0.363 0.363 9

Capital recovery factor--system 0.1424 0.1424 0.1424 10

Capital recovery factor--bags 0.244 0.244 0.244 11

Cost of dry injection system 490,150 559,193 405,022 12

Retrofit factor 1.4 1.4 1.4 13

Total capital cost, $

Total capital investment 847,658 942,509 709,950 14

Annual costs, $/yr

Operating labor 26,014 60,699 44,292 15

Supervisory labor 3,902 9,105 6,644 16

Maintenance labor 14,308 33,384 24,360 17

Maintenance materials 14,308 33,384 24,360 18

Electricity 16,867 47,715 21,196 19

Compressed air 850 2,405 1,068 20

Annualized replacement bags 6,904 8,371 5,096 21

Annualized bag replacement labor 1,543 1,871 1,139 22

Cage replacement 0 0 0 23

Waste disposal 102 234 46 24

Overhead 35,119 81,944 59,794 25

Administrative charges 16,953 18,850 14,199 26

Property taxes 8,477 9,425 7,099 27

Insurance 8,477 9,425 7,099 27

Capital recovery 120,394 133,836 100,864 28

Total annual cost 274,216 450,648 317,257 29

1. Percent reduction for HAP metals assumed same as PM.
C-10

2. BSCP test data database; fabric filter control assumed in addition to control with water curtain.

3. BSCP inventory database.

4. Scaled down from 150 hp using ratio of model flow rates.

5. Scaled down from 30 hp using ratio of model flow rates.

6. Assume 2 times maintenance labor (based on OAQPS Manual).

7. None (use cooling water in cooling chamber).

8. Particulate matter.

9. Average from 2015 BIA survey data.

10. 10 years, 7% interest.

11. 5 years, 7% interest.

12. Based on cost equations in the June 19, 2009 memorandum Revised Baseline Operating Costs for Existing 

HMIWI, in Docket ID No. EPA-HQ-OAR-2006-0534 for the HMIWI rule.

13. Average for various APCD (based on OAQPS Manual).

14. Cost for sanitaryware GSB FF based on brick kiln DIFF costs, minus the cost of the dry injection system and 

scaled down using "six-tenths" rule (based on acfm). All costs scaled to 2011 using CEPCI.

15. Equal to 2.5 hr/shift / (8 hr/d) x operating hours x operator wage rate.

16. Equal to 0.15 x (operating labor cost).

17. Equal to 1.25 hr/shift / (8 hr/d) x operating hours x maintenance wage rate.

18. Equal to maintenance labor cost.

19. Equal to total hp x 0.745 kW/hp x operating hours x electricity cost.

20. Equal to compressed air/1000 x exhaust flow x compressed air cost/1000 x 60 min/hr x operating hours.

21. Equal to exhaust flow / gas-to-cloth ratio x bag fabric cost x capital recovery factor—bags.

22. Equal to exhaust flow / gas-to-cloth ratio / bag area x time to replace bags x operator wage rate x capital recovery 

factor—bags.

23. May be no need to replace.

24. Equal to waste x operating hours x waste disposal cost x 1 ton/ 2000 lb.

25. Equal to 0.6 x total direct annual cost.

26. Equal to 0.02 x TCI.

27. Equal to 0.01 x TCI.

28. Equal to CRF x TCI.

29. Equal to sum of annual costs.
Appendix D

Model Impacts Equations
D-2

Table D-1. Equations Used to Estimate Model Energy and Secondary Impacts

Parameters Value Notes, units, and equations

Energy impacts

Heat factors

Heat content of electricity 

(HCelec)

3,415 Btu/kWh

Heat rate

Coal (HRcoal) 10,415 Btu/kWh

Natural gas (HRgas) 8,185 Btu/kWh

Nuclear power (HRnuclear) 10,452 Btu/kWh

Renewable energy (HRrenew) 9,756 Btu/kWh

Percent of generation

Coal (% coal) 48% Used for solid fuel

Oil/natural gas (% gas) 18% Used for natural gas

Nuclear (% nuclear) 20% No secondary emissions estimated

Hydroelectric (% hydro) 7% No secondary emissions estimated

Renewable (% renew) 6% No secondary emissions estimated

Other (% other) 1% Used for natural gas (assumed equivalent)

Power plant efficiency (E)

Coal (Ecoal) 33% % = HCelec / HRcoal x 100

Natural gas/other (Egas) 42% % = HCelec / HRgas x 100

Nuclear (Enuclear) 33% % = HCelec / HRnuclear x 100

Renewable/hydroelectric 

(Erenew)

35% % = HCelec / HRrenew x 100

Average (Eavg) 35% % = (Ecoal x % coal) + (Egas x % gas/other) + (Enuclear x % 

nuclear) + (Erenew x % renew/hydro)

Energy impacts calculations

Electricity requirements model-specific kWh/yr = total hp x (0.745 kW/hp) x operating hr/yr

Energy impacts model-specific MMBtu/yr = (kWh/yr) x (HCelec) x (MMBtu/1E6 Btu) / Eavg

Secondary emissions 

Emission factors, natural gas

Particulate matter/PM2.5 1.9 lb/MM ft3 natural gas

0.00186275 lb/MMBtu natural gas

Carbon monoxide 84 lb/MM ft3 natural gas

0.0824 lb/MMBtu natural gas

Nitrogen oxide 100 lb/MM ft3 natural gas

0.0980 lb/MMBtu natural gas

Sulfur dioxide 0.6 lb/MM ft3 natural gas

0.00059 lb/MMBtu natural gas

Emission factors, solid fuel

Particulate matter 0.03 lb/MMBtu solid, liquid, gaseous fuel

PM2.5 0.00957 lb/MMBtu solid, liquid, gaseous fuel

Carbon monoxide 0.19 lb/MMBtu bituminous coal

Nitrogen oxide 0.38 lb/MMBtu solid fuel

Sulfur dioxide 1.2 lb/MMBtu solid fuel
D-3

Parameters Value Notes, units, and equations

Secondary emissions 

calculation

Secondary emissions, for each 

pollutant

model-specific lb/yr = MMBtu/yr x [(lb/MMBtu natural gas) x (% 

gas/other) + (lb/MMBtu solid fuel) x (% coal)]

Solid waste and wastewater impacts

Solid waste impacts model-specific tpy = waste (lb/hr) x operating hr/yr / (2,000 lb/ton)

Wastewater impacts model-specific gpy = water usage (gpd) x operating hr/yr / (24 hr/d)

Notes:

1. gpy = gallons per year; gpd = gallons per day.

2. Assume electricity generated using the above mix (from IPM Version 3.0 for the year 2015), as determined from 

Table 3-6 of Regulatory Impacts Analysis for the final Mercury and Air Toxics Standards. IPM = EPA Integrated 

Planning Model, which is a multi-regional, dynamic, deterministic linear programming model of the U.S. electric 

power sector that provides forecasts of least-cost capacity expansion, electricity dispatch, and emission control 

strategies for meeting energy demand and environmental, transmission, dispatch, and reliability constraints.

3. For natural gas, used PM, CO, NOX, and SO2 emission factors from AP-42 chapter on natural gas combustion.

Assumed 1,020 Btu/ft3 of natural gas in estimating PM, CO, NOX, and SO2 secondary emissions. Also assumed 

that 100% of PM is PM2.5, based on statement in AP-42 that PM from natural gas combustion is estimated to be 

less than 1 micron in size.

4. For solid fuel, used PM and SO2 emission limits for solid fuel-fired boilers from 2006 CFR edition of NSPS for 

electric utility plants (40 CFR part 60, subpart Da) and used NOX and CO emission factors from AP-42 chapter on

coal combustion (bituminous/subbituminous coal). The NOX emission factor was based on average of NOX

emission factors for PC dry-bottom wall-fired NSPS boilers burning bituminous (12 lb/ton) and subbituminous (7.4 

lb/ton) coal. Assumed 13,000 Btu/lb of coal in estimating NOX and CO secondary emissions. According to AP-42, 

the percentage of PM that is PM2.5 for dry-bottom coal-fired boilers is 29% with ESP, 53% with FF, and 6% if 

uncontrolled. Assumed 84% of utility boilers controlled with ESP and 14% with FF, leaving 2% uncontrolled, based 

on information from EPA document on control of emissions from coal-fired utility boilers.
Appendix E

New Model Impacts for Sanitaryware Sources
E-2

Table E-1. Model Impacts of Installing New DIFF on Sanitaryware Tunnel Kilns

Parameters SCD TK LCD TK

Control efficiency, percent

Hydrogen fluoride 99.5% 99.5%

Hydrogen chloride 83% 83%

HAP metals 94% 94%

Particulate matter 94% 94%

Sulfur dioxide 49% 49%

Parameters

Fan hp 55 111

Total hp for other motors 11 22

Waste, lb/hr 2.5 20

Emissions reductions, tpy

Hydrogen fluoride 0.684 2.73

Hydrogen chloride 0.0411 0.165

HAP metals 0.00395 0.0158

Particulate matter 0.293 1.17

PM2.5 0.141 0.562

Sulfur dioxide 4.14 16.6

Energy impacts, MMBtu/yr 4,198 8,545

Solid waste impacts, tpy 10.8 87.6

Secondary air impacts, tpy

Particulate matter 0.0310 0.0630

PM2.5 0.0104 0.0211

Carbon monoxide 0.0522 0.106

Nitrogen oxides 0.415 0.845

Sulfur dioxide 1.21 2.46
E-3

Table E-2. Model Impacts of Installing/Retrofitting New Fabric Filter on Sanitaryware 

Tunnel Kilns

Parameters SCD TK LCD TK

Control efficiency, percent

HAP metals 94% 94%

Particulate matter 94% 94%

Parameters

Fan hp 55 111

Total hp for other motors 11 22

Waste, lb/hr 0.07 0.27

Emissions reductions, tpy

HAP metals 0.00395 0.0158

Particulate matter 0.293 1.17

PM2.5 0.141 0.562

Energy impacts, MMBtu/yr 4,198 8,545

Solid waste impacts, tpy 0.293 1.17

Secondary air impacts, tpy

Particulate matter 0.0310 0.0630

PM2.5 0.0104 0.0211

Carbon monoxide 0.0522 0.106

Nitrogen oxides 0.415 0.845

Sulfur dioxide 1.21 2.46
Appendix F

Retrofit Model Impacts for Sanitaryware Sources
F-2

Table F-1. Model Impacts of Replacing Existing Wet Scrubber with New DIFF on 

Sanitaryware Tunnel Kilns

Parameters

SCD TK LCD TK

Existing 

WS

New 

DIFF Increm.

Existing 

WS

New 

DIFF Increm.

Control efficiency, percent

Hydrogen fluoride 92% 98% 6% 92% 98% 6%

Parameters

Total hp 32 66 34 64 133 69

Waste, lb/hr 0 2.5 2.5 0 20 20

Water flow, gpm 121 0 (121) 246 0 (246)

Emissions reductions, tpy

Hydrogen fluoride 1 0.629 0.684 0.0546 2.52 2.73 0.219

Energy impacts, MMBtu/yr 2,717 4,198 1,481 5,530 8,545 3,015

Solid waste impacts, tpy 0 10.8 10.8 0 87.6 87.6

Wastewater impacts, MM gpy 63.4 0 (63.4) 129 0 (129)

Secondary air impacts, tpy

Particulate matter 0.0200 0.0310 0.0109 0.0408 0.0630 0.0222

PM2.5 0.00672 0.0104 0.00366 0.0137 0.0211 0.00746

Carbon monoxide 0.0338 0.0522 0.0184 0.0688 0.106 0.0375

Nitrogen oxides 0.269 0.415 0.146 0.547 0.845 0.298

Sulfur dioxide 0.783 1.21 0.427 1.59 2.46 0.869

1. Insufficient emissions data to determine emissions reductions for other pollutants (e.g., HCl, PM, HAP metals, 

SO2).
F-3

Table F-2. Model Impacts of Retrofitting Activated Carbon Injection on Sanitaryware Tunnel Kilns

Parameters

MACT Floor Beyond the Floor

Add ACI-1 Add ACI-2 Add ACI-1 Add ACI-2

SCD TK LCD TK SCD TK LCD TK SCD TK LCD TK SCD TK LCD TK

Parameters

Injection blower fan power, hp 1.9 3.8 1.9 3.8 1.9 3.8 1.9 3.8

Carbon feed rate, lb/hr 1.0 2.1 2.0 4.1 1.5 3.1 2.5 5.1

Emissions reduction, tpy

Mercury 0.000364

OR

0.00146

OR

0.000364

AND

0.00146

AND

0.000407

OR

0.00163

OR

0.000407

AND

0.00163

AND

Dioxin/furan TEQ 7.69E-09 3.08E-08 7.69E-09 3.08E-08 8.59E-09 3.44E-08 8.59E-09 3.44E-08

Energy impacts, MMBtu/yr 122 244 122 244 122 244 122 244

Solid waste impacts, tpy 4.42 8.99 8.83 18.0 6.62 13.5 11.0 22.5

Secondary air impacts, tpy

Particulate matter 0.000899 0.001798 0.000899 0.001798 0.000899 0.001798 0.000899 0.001798

PM2.5 0.000301 0.000603 0.000301 0.000603 0.000301 0.000603 0.000301 0.000603

Carbon monoxide 0.00152 0.00303 0.00152 0.00303 0.00152 0.00303 0.00152 0.00303

Nitrogen oxides 0.0120 0.0241 0.0120 0.0241 0.0120 0.0241 0.0120 0.0241

Sulfur dioxide 0.0351 0.0702 0.0351 0.0702 0.0351 0.0702 0.0351 0.0702
F-4

Table F-3. Model Impacts of Retrofitting Fabric Filter on Sanitaryware Glaze Spray Booths

Parameters Manual GSB

Spray 

Machine GSB Robot GSB

Control efficiency, percent

HAP metals 94% 94% 94%

Particulate matter 94% 94% 94%

Parameters

Fan hp 77 93 57

Total hp for other motors 15 19 11

Waste, lb/hr 1.2 1.2 0.3

Emissions reductions, tpy

HAP metals 0.0301 0.0700 0.0138

Particulate matter 2.27 5.20 1.02

PM2.5 1.09 2.50 0.491

Energy impacts, MMBtu/yr 2,474 6,998 3,109

Solid waste impacts, tpy 2.27 5.20 1.02

Secondary air impacts, tpy

Particulate matter 0.0182 0.0516 0.0229

PM2.5 0.00612 0.0173 0.0077

Carbon monoxide 0.0308 0.0871 0.0387

Nitrogen oxides 0.245 0.692 0.307

Sulfur dioxide 0.713 2.02 0.896