### From: Telander, Jeff

Sent: Thursday, December 04, 2014 10:35 AM

To: Cassidy Mike

Cc: Nizich, Sharon; Barnett, Keith

Subject: "Development of Cost and Emission Reduction Impacts for the Clay Ceramics

NESHAP” memo is enclosed

Mike, The memo you requested is attached.

Jeff

<<CC_Impacts_Memo.pdf>>

From: Cassidy Mike [ mailto:MICHAEL.CASSIDY@kohler.com ]

Sent: Thursday, December 04, 2014 9:34 AM

To: Telander, Jeff

Cc: Nizich, Sharon; Barnett, Keith

Subject: RE: Link to proposed NESHAP for Brick and Structural Clay Products Manufacturing; and NESHAP for Clay Ceramics Manufacturing is enclosed

Thank you Jeff. Can you also provide the “Development of Cost and Emission Reduction Impacts for the Clay Ceramics NESHAP” memo?

Mike

## Date: November 6 , 2014

To: Jeff Telander , EPA/ OAQPS/SPPD

From: Gabrielle Raymond , RTI International

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

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 the clay ceramic s 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

, the EPA is propo sing 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 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 facilities currently projected to be subject to the proposed NESHAP include three sanitaryware facilities. The ceramic f loor and wall tile facilities have taken the necessary steps to become synthetic area sources ( i.e. , have obtained a federally enforceable limit reducing emissions below major source thresholds 2 

## ), and would not be subject to the major source clay

ceramics NESHAP.

The proposed 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

1 

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

. 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.

## 2 surrogate for non

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

. In developing the proposed standards, the EPA also considered “beyond

- the

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

- Hg HAP metals), and dioxins/fur ans. The development of these standards and options are documented in two memorand a, Risk Assessment

to Determine a Health

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

. , 2014) and Maximum Achie vable Control Technology (MACT) Floor Analysis for Clay Ceramic s (Raymond and Sroka, 2014).

The purpose of this memorandum is to present the methodology f or estimating the costs

, emission reductions , and secondary impacts 3 

## associated with the proposed standards and beyond

the

- floor options for the c lay c eramics source category

. 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 Estim ate the Model Costs and Impacts of Clay Ceramics Air Pollution Control Devices (Holloway and Raymond , 2014).

Section II of this memorandum shows the nationwide baseline emissions for the c lay

c eramics industry. Section III describes the assessment of wh at air pollution control devices (APCD) would be needed for major source facilities to meet the proposed health

- based standards. Section IV describes the analysis of what APCD would be needed for clay ceramics stacks to meet the proposed MACT standards an d presents the nationwide costs, emission reductions, and secondary impacts associated with those APCD. Section V describes the analysis of what APCD would be needed for clay ceramics stacks to meet the beyond

- the

- floor options for PM, Hg, and dioxins/fur ans and presents the nationwide costs, emission reductions, and secondary impacts associated with those APCD.

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 were developed differently for different source s. T he ceramic tile synthetic area

sources would not be subject to the proposed rule, but the baseline emissions were calculated in

Section IV of this memorandum so that the incremental impacts of meeting the MACT floor options for ceramic tile sources could be assessed.

A. Ceramic Tile Roller Kilns

For floor and wall tile roller kilns, baseline emissions ( in tons per year [ tpy ] ) were developed for HF, HCl, non

- Hg HAP metals , PM, PM with p articles less than 2.5 micrometers in

diameter ( PM 2.5 

## )

, sulfur dioxide ( SO 2 

## ) , Hg, and dioxin/furan TEQ. U ncontrolled emission

3 

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

• Energy impacts: The annual amount of energy (in millio n 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 

### , car bon monoxide (CO), nitrogen
oxides (NOx), and SO 2 

### — (in tpy) that result from the generation of electricity used to operate the control

devices.

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

## 3 factors, model source production rates, and model source operating hours were developed as
described in the memorandum Methodology and Assumptions Used to Estimate the Model Costs and Impacts of Clay Ceramics Air Pollution Control Devices (Holloway and Raymond , 2014).

The memorandum also documents control efficiencies and emission reductions for new/retrofit APCD installations. The existing (baseline) APCD include: dry sorbent injection followed by a
fabric filter (DIFF), dry lime scrubber and fabric filter (DLS/FF), fabric filter (FF), and wet
scrubber (WS) . Most of the control efficiencies were based on all the available Brick and Structural Clay Products ( BSCP ) test data (see the memorandum Test Data Used in BSCP Proposed Rule (Raymond, 2014 a )). The control effici encies were based on the BSCP test data because there was a larger amount of data from uncontrolled sources that later put on APCDs,

where the control efficiencies could be calculated for the APCD

. Table 1 shows the control

efficiencies of baseline control s for each pollutant for ceramic tile roller kilns

.

Table 1. Control Efficiencies for Baseline APCD for Ceramic Tile Roller Kilns

APCD Type Control Efficiency

HF HCl PM a 

### SO 2

DIFF 98% 82% 72% 48%

DLS/FF 98% 82% 72% 48%

WS 95% 30% 20% 12%

a Control efficiencies for non

- Hg HAP metals and P M 2.5 are estimated to be the same as the efficiency for PM.



## The inventory of c eramic tile roller kilns and facilities, including the APCD for each

stack

, is presented in the memorandum Updated CC Inventory Database and Documentation
( Raymond , 2014 c ). To develop the nationwide baseline emission estimates for ceramic tile roller kilns, each stack in this inventory was assigned the appropriate baseline emissions from Table 2 based on the size and type of APCD on the stack.

Table 2 . Annual Baseline Emissions for E ach APCD for Ceramic Tile Roller Kilns

APCD Type Size Emissions per APCD (tpy)

HF HCl Non

- Hg

HAP Metals PM PM 2.5 a 

### SO 2 

### Hg D/ F TEQ

None Small 4.93 2.88 0.091 2.61 1.25 50.79 0.00345 1.15E

- 07

DIFF Small 0.10 0.52 0.026 0.73 0.35 26.41 0.00345 1.15E

- 07

DLS/FF Small 0.10 0.52 0.026 0.73 0.35 26.41 0.00345 1.15E

- 07

WS Small 0.10 0.52 0.026 0.73 0.35 26.41 0.00345 1.15E

- 07

None Large 78.69 11.48 0.11 6.59 3.16 64.48 0.00614 1.01E

- 07

DIFF Large 1.57 2.07 0.031 1.84 0.88 33.53 0.00614 1.01E

- 07

DLS/FF Large 1.57 2.07 0.031 1.84 0.88 33.53 0.00614 1.01E

- 07

WS Large 1.57 2.07 0.031 1.84 0.88 33.53 0.00614 1.01E

- 07

a Estimated as 48 percent of PM emissions.



## Table 3 sum marizes the number of tile roller kiln stacks with each type of APCD and the

nationwide baseline emissions for tile roller kilns

.

## 4 Table 3. Nationwide Baseline Emissions Estimates for Ceramic Tile Roller Kilns

Unit Type APCD Type Size Count Nationwide Emissions (tpy)

HF HCl Non

- Hg

HAP

Metals PM PM 2.5 

### SO 2 

### Hg D/ F TEQ

Floor

Tile

Roller

Kilns None Small 9 44.4 25.9 0.823 23.5 11.3 457 0.0311 1.03E

- 06

DIFF Small 1 0.0987 0.518 0.0256 0.732 0.35 26.4 0.00345 1.15E

- 07

None Large 2 157 23.0 0.220 13.2 6.34 129 0.0123 2.02E

- 07

DLS/FF Large 1 1.57 2.07 0.0308 1.84 0.88 33.5 0.00614 1.01E

- 07

DIFF Large 1 1.57 2.07 0.0308 1.84 0.88 33.5 0.00614 1.01E

- 07

WS Large 2 3.15 4.13 0.0616 3.69 1.77 67.1 0.0123 2.02E

- 07

Floor Tile Roller Kiln Subt otal 208 58 1.2 45 9.87 74 7 0.071 1.8E

- 06

Wall

Tile

Roller

Kilns None Large 1 78.7 11.5 0.110 6.59 3.16 64.5 0.00614 1.01E

- 07

Tile Roller Kiln Total 286.8 9 69.16 1.30 51.38 13.07 811 0.078 1.9E

- 06



## B. Ceramic Tile Press Dryers and Spray Dryers

For floor and wall tile press and spray dryers

, baseline emissions were developed only for

dioxin/furan TEQ , which is the pollutant being regulated under the proposed rule for those

emission units

. Because the current controls of WS and FF on spray dryers do not control

dioxin/furan TEQ, they were considered equivalent to no control for that pollutant . For each

current ceramic tile press or spray dryer

, an uncontrolled model dioxin/furan TEQ value was developed in pounds per hour (lb/hr) . The model lb/hr value for each APCD and size was multiplied by 8

, 760 operating hours, then divided by 2

, 000 pounds per ton (lb/ton) to calculate

model emissions (tpy) for the emission units . See Table 4 for the model emissions valu es for

each ceramic tile press dryer and spray dryer

.

Table 4

. Emissions (tpy) for Each Ceramic Tile Press Dryer and Spray Dryer

Unit Type APCD Type Size D/F TEQ Emissions

per Unit Type (tpy)

Floor Tile Press Dryers None Small 7.16E

- 10

Floor Tile Spray Dryers WS and FF Large 4.88E

- 08

Wall Tile Spray Dryers WS Large 4.05E

- 09



## To calculate the nationwide baseline emissions (tpy) for floor and wall tile press and spray dryers, the model emissions value for each dryer was multiplied by the count of unit stacks

for that unit type nationwide. See Table 5 for the nationwide baseline emissions estimates for

ceramic tile press and spra y dryers.

## 5 Table 5 . Nationwide Baseline Emissions Estimates for Ceramic Tile Press Dryers and Spray Dryers

Unit Type APCD Type Size Count Nationwide D/F

TEQ Emissions (tpy)

Floor Tile Press Dryers None Small 18 1.29E

- 08

Floor Tile Spray Dryers WS & FF Large 7 [2 WS; 5 FF] 3.42E

- 07

Wall Tile Spray Dryers WS Large 1 4.88E

- 08



## C. Ceramic Tile Glazing

For ceramic tile glazing operations, baseline emissions were developed for PM, PM 2.5 

## , Hg , and non

- Hg HAP metals

. For each current APCD ( i.e. , WS and FF)

, a model emissions value was developed for PM and Hg in lb/ ton glaze sprayed, regardless of size

. See Table 6 for

the model emissions values per APCD type for PM and Hg

.

Table 6 . Emissions per APCD (lb/ton) for Ceramic Tile Glazing

APCD Type Size Emissions per APCD ( lb/ton )

PM Hg

WS All 1.44 7.37E

- 06

FF All 0.028 2.60E

- 05



## To calculate the nationwide baseline emissions (tpy) for ceramic tile glazing operations,

the model emissions value for each APCD type was multiplied by each glaze line ’ s annual glaze use (tpy) and divided by 2

, 000 lb/ton

. The nationwide baseline emissions for PM 2.5 

## were
estimated as 48 percent of the baseline PM emissions

. The nationwide baseline emissions for

non

- Hg HAP metals were estimated as 2.9 percent of the baseline PM emissions (based on the

average percentage of the PM that is HAP metals from the available emissions data for ceramic tile glazing )

. See Table 7 for the nationwide baseline emissions estimates for tile glazing operations

.

Table 7 . Nationwide Baseline Emis sions Estimates for Ceramic Tile Glazing

APCD Type Size Count Nationwide Emissions (tpy)

Non

- Hg HAP Metals PM PM 2.5 

### Hg

FF All 9 0.155 5.35 2.57 0.000495

WS All 3 0.245 8.45 4.06 0.000043

Ceramic T ile Glazing Total 0.40 13.8 6.63 0.000538



## D. 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 we re 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

## 6 multiplied by 8

, 760 operating hours, then divided by 2

, 000 lb/ton to estimate the baseline

emissions. The n ationwide baseline emissions for PM 2.5 

## were estimated as 48 percent of the

baseline PM emissions. See Table 8 for the nationwide baseline emissions estimates for sanitaryware tunnel kilns.

Table 8

. 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] 15.24 1.19 0.083 7.47 3.59 0.011 2.72E

- 07



## E. 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 spray 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 9 for the nationwide baseline emissions estimates for sanitaryware glazing operations.

Table 9 . Nation wide 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 6.74 3.23

WS All 1 2.28 1.09

WC All 11 28.41 13.64

Manual glaze application total 37.42 17.96

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 1 0 for the nationwide baseline emissions estimates for all clay ceramics unit

types being regulated under the clay ceramics proposed rule

.

## 7 Table 1 0 . Total Nationwide Baseline Emissions Estimates for Clay Ceramics

Unit Type Emissions (tpy)

HF HCl Non

- Hg

HAP

Metals PM PM 2.5 

### SO 2 

### Hg D/ F TEQ

Floor Tile Roller Kiln 208 58 1.2 45 9.87 746.63 0.071 1.8E

- 06

Wall Tile Roller 78.7 11.5 0.110 6.59 3.16 64.5 0.00614 1.01E

- 07

Floor Tile Press Dryers 1.29E

- 08

Floor Tile Spray Dryers 3.42E

- 07

Wall Tile Spray Dryers 4.88E

- 08

Ceramic Tile Glazing 0.40 13.8 6.63 0.000538

Sanitaryware Tunnel Kilns 15.24 1.19 0.083 7.47 3.59 0.011 2.72E

- 07

Sanitaryware Manual Glaze Application 37.42 17.96

Sanitaryware Spray Machine Glaze Application 16.22 7.79

Sanitaryware Robot Glaze Application 10.46 5.02

Clay Ceramics Total 302 71 1.8 137 54 811 0.089 1 2.58 E

- 06



## 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 proposed rule. The development of the facility

- level health

- based

emission limit

, 6 00 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 equival ency 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 equation can be used

to calculate the HCl

- equivalent emissions for an individual kiln :



##              

+ =

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

## 8 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 Proposed Rule (Raymond, 2014 b ) )

. 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

- equival ent values were summed for all kiln s at a major

source facility and then compared to the health

- based emission limit

.

As shown in Table 11 , all major source clay ceramics facilit ies could meet the health

based emission limit of 140 lb/hr of HCl

- equivalent with current control configurations

.

Table 11

. 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 i ndustry, 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 proposed rule, but the impacts of requiring

them to meet the limits we re calculated so that the incremental impacts of the beyond

- the

- floor options for ceramic tile sources could be assessed in Section V of this memorandum

. A summary of the sources at the facilities used for all remaining analyses in this memorandum is

show n in Table 1 2

.

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 combination 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.

## 9 Table 1 2 . Summary of Units at Major and Recent Synthetic Area Sources

Source Type N o. of Units N o. of Unit Stacks

Floor Tile Roller Kilns 22 16

Floor Tile Press Dryers 21 18

Floor Tile Spray Dryers 8 7

Wall Tile Roller Kilns 12 1

Wall Tile Spray Dryers 1 1

Tile Glaze Lines 39 12

Sanitaryware First

- fire Tunnel Kilns 11 7

Sanitaryware Manual Glaze Application 14 14

Sanitaryware Spray Machine Glaze Application 4 4

Sanitaryware Robot Glaze Application 10 10



## The proposed c lay c eramics 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 , dryers, and glazing operations in the industry (including major and synthetic are a sources

, as shown in Table 13 ).

Table 13. Facilities with Available Test Data

Fac ID Fac ID Company City State Source Classification

203 KOHL

- TX Kohler Brownwood TX Major

82 KOHL

- SC Kohler Spartanburg SC Major

204 KOHL

- WI Kohler Kohler WI Major

5 MARR

- 1 Marazzi Sunnyvale TX Recent Synth Area

123 FLOR

- 1 Florim Clarksburg TN Recent Synth Area

DALT

- 1 Dal Italia Muskogee OK Recent Synth Area

50 MOHA

- 3 Dal

- Tile El Paso TX Recent Synth Area

222 MARR

- 2 Monarch Florence AL Recent Synth Area



## Data on PM emissions were available for about 50 percent of the floor tile roller kilns, 100 percent of the wall tile roller kilns, 55 percent of the sanitaryware tunnel kilns, 25 percent of

the ceramic tile glazing operations , 21 percent of the sanitaryware manua l 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

38 percent of the floor tile roller kilns, 100 percent of the wall tile roller kilns, 45 percent of the sanitaryware tunnel kilns, and 25 percent of the ceramic tile glazing operations. Data on

dioxin/furan TEQ emissions were available for about 31 percent fo r floor tile roller kilns,

100 percent of the wall tile roller kilns, 45 percent of the sanitaryware tunnel kilns, 71 percent of the floor tile spray dryers, 22 percent of the floor tile press dryers, and 100 percent of the wall tile spray dryers (Raymond, 2014 b ). 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 assumptions 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.

## 10 Step 1: Compare Test Data to Emission Limits

The first step was to compare the data available to the proposed emission limits to get an estimate of the percentage of kilns , dryers, and glazing operations in the industry that could meet the limits with current APCD configurations. Table 1 4 shows the percentages for the PM

, Hg

, and dioxin/furan TEQ emission limits. Note that Table 14 only shows the percentages for floor

tile roller kilns b ecause floor tile roller kilns are the only emissions source with unit s that w ould

not meet the proposed standards (if the units were located at major sources). For all of the other clay ceramic unit types

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

limits.

Table 1 4

. Estimated Percentages of Floor Tile Roller Kilns w ith Data Less Than or Equal to Proposed Emission Limits

Unit Type Size APCD Type N o. of Kiln

Stacks

with Data % of Kilns Meeting

PM lb/ton

Limit N o. of Kiln

Stacks

wit h Data % of Kilns Meeting Hg lb/ton

Limit N o. of

Kilns

Stacks

with Data % of Kilns Meeting

D/F TEQ

conc. Limit

Floor Tile

Roller Kilns All All 8 75% 6 83% 5 80%

ND = no test data available for that pollutant, unit type, and APCD combination.

n/a = not applicable



## 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 floor tile roller

kilns to meet the proposed 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 compared 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 t hat 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

percenta ge of units (with and without data) meeting the limits were calculated for PM, Hg, and

dioxin/furan TEQ. These percentages were compared to the percentage s previously c alculated

for units with data (Table 14) to make sure they were similar. For Hg two a dj ustments and for

dioxin/furan TEQ three adjustments to the meeting limit decisions were made in order to make the percentage meeting limit values similar to those in Table 14. The ability of each unit to be

able to meet the PM, Hg, and dioxin/furan TEQ li mits determined the criteria for APCD to be

installed or not ( see Table 15 )

. Note : Table 15 includes criteria for the other clay ceramic unit types, as they will be used in the beyond

- the

- floor analyses in Section V of this memorandum

.

## 11 Table 1 5 . Scenarios for Units

Unit Type Current APCD Meets

PM limit Meets Hg limit Meets D/F

TEQ limit APCD / Action Needed

Floor and Wall

Tile Roller Kilns DIFF & DLS/FF No No No Retrofit with DIFF and ACI

- 2

DIFF & DLS/FF No No Yes Retrofit with DIFF and ACI

- 1

- Hg

DIFF & DLS/FF No Yes No Retrofit with DIFF and ACI

- 1

- D / F

DIFF & DLS/FF No Yes Yes Retrofit with DIFF

DIFF & DLS/FF Yes No No Add ACI

- 2

DIFF & DLS/FF Yes No Yes Add ACI

- 1

- Hg

DIFF & DLS/FF Yes Yes No Add ACI

- 1

- D / F

DIFF & DLS/FF Yes Yes Yes No action

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

Floor and Wall Tile Spray and Press Dryers Fabric Filter n/a n/a No Add ACI

- 1

- D / F

Fabric Filter n/a n/a Yes No Action

Wet Scrubber n/a n/a No Add ACI

- 1

- D / F

Wet Scrubber n/a n/a Yes No Action

None n/a n/a No Install FF and ACI

- 1

- D / F

None n/a n/a Yes No Action

Tile Glazing Fabric Filter No No n/a Retrofit with FF and ACI

- 1

- Hg

Fabric Filter No Yes n/a Retrofit with FF

Fabric Filter Yes No n/a Add ACI

- 1

- Hg

Fabric Filter Yes Yes n/a No Action

Wet Scrubber No No n/a Add FF and ACI

- 1

- Hg

Wet Scrubber No Yes n/a Add FF

Wet Scrubber Yes No n/a Add ACI

- 1

- Hg

Wet Scrubber Yes Yes n/a No Action

## 12 Unit Type Current 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



## The final estimates of APCD counts are shown in Table 1 6. Note that Table 16 only shows the APCD actions for floor tile roller kilns because floor tile roller kilns are the only

emissions s ource with units that would not meet the proposed standards (if the units were located at major sources). All of the other clay ceramic units types had “No action” when it came to meeting the proposed MACT floor limits ( i.e. , 100 percent of units would meet the limits)

.

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

The final step in estimating nationwide costs and impacts was to apply model APCD costs, emission reductions, and secondary impacts to the APCD counts shown in Table 16.

Table s 17 , 18, and 19 show the summary of nationwide costs

, emission reductions , and secondary impacts , respectively, for clay ceramics sources. Note that these thre e tables only show impacts for floor tile roller kilns because floor tile roller kilns are the only emissions source with units that would not meet the proposed standards (if the units were located at major
sources).

## 13 Table 1 6 . Summary of Stacks and Esti mate of APCD to B e Installed

Unit Type Existing

APCD Type Size N o. of

Stacks Estimate of Stacks

Add

ACI

1 Add

ACI

2 Add

FF Add

FF

and

ACI

1 Add

FF

and

ACI

2 Install

FF Install

FF and

ACI

- 1 Install

FF and

ACI

- 2 Retrofit

with

DIFF Retrofit

with

DIFF

and

ACI

- 1 Retrofit

with

DIFF

and

ACI

- 2 Retrofit

with FF Retrofit

with FF

and

ACI

- 1 No

action

Floor Tile

Roller Kilns None Small 9 3
[1 Hg; 2

D / F] 1
[Hg &

D / F] 5

DIFF Small 1 1 [Hg] 0

None Large 2 2

DLS/FF Large 1 1

DIFF Large 1 1

WS Large 2 1 1

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



### Table 17 . Summary of Nationwide Costs to Meet Proposed Standards

Unit Type Current

APCD Action APCD

Size Unit Capital

Cost Unit Annual

Cost N o. of

APCD Total Capital

Cost Total Annual

Cost

Floor Tile

Roller

Kilns None Install FF and ACI

- 1 Small $497,508 $356,208 3 $1,492,524 $1,068,624

None Install FF and ACI

- 2 Small $497,508 $372,975 1 $497,508 $372,975

DIFF Add ACI

- 1 Small $86,738 $72,656 1 $86,738 $72,656

WS Add FF Large $577,158 $352,579 1 $577,158 $352,579

Total Nationwide 6 $2,653,930 $1,866,834

## 14 Table 18 . Summary of Nationwide Emission Reductions to Meet Proposed Standards

Unit Type Current

APCD Action APCD

Size Emissions Type N o. of

APCD Emission Reductions (tpy)

HF HCl HAP

Metals PM Hg D/F D/F TEQ SO 2 PM 2.5 a

Floor

Tile

Roller

Kilns None Install FF and

ACI

- 1 [Hg] Small Unit 0 0 0.086 2.5 2.93E

- 03 0 0 0 1.2

Total 1 0 0 0.086 2.5 2.93E

- 03 0 0 0 1.2

Install FF and

ACI

- 1 [D / F] Small Unit 0 0 0.086 2.5 0 5.70E

- 06 9.75E

- 08 0 1.2

Total 2 0 0 0.17 5.0 0 1.14E

- 05 1.95E

- 07 0 2.4

Install FF and

ACI

- 2 [Hg & D / F] Small Unit 0 0 0.086 2.5 2.93E

- 03 5.70E

- 06 9.75E

- 08 0 1.2

Total 1 0 0 0.086 2.5 2.93E

- 03 5.70E

- 06 9.75E

- 08 0 1.2

DIFF Add ACI

- 1 [Hg] Small Unit 0 0 0 0 2.93E

- 03 0 0 0 0

Total 1 0 0 0 0 2.93E

- 03 0 0 0 0

WS Add FF Large Unit 0 0 0.029 1.7 0 0 0 0 0.082

Total 1 0 0 0.029 1.7 0 0 0 0 0.082

Total Nationwide 6 0 0 0 0 0.0088 1.7E

- 05 2.9E

- 07 0 4.9

a Estimated as 48 percent of PM reductions.



### Table 19

. Summary of Nationwide Secondary Impacts for to Meet Proposed Standards a

Unit Type Current

APCD Action APCD

Size Emissions Type N o. of

APCD Energy

I mpacts, MMBtu/yr Solid W aste

I mpacts, tpy Secondary Air Emissions Increase (tpy)

PM PM 2.5 CO NO
x SO 2

Floor

Tile

Roller

Kilns None Install FF and

ACI

- 1 [Hg] Small Unit 2,410 12.1 0.0194 0.00932 0.131 0.265 0.758

Total 1 2,410 12.1 0.0194 0.00932 0.131 0.265 0.758

Install FF and

ACI

- 1 [D / F] Small Unit 2,410 12.1 0.0194 0.00932 0.131 0.265 0.758

Total 2 4,820 24.2 0.0389 0.0186 0.261 0.531 1.52

Install FF and

ACI

- 2 [Hg & D / F] Small Unit 2,410 21.71 0.0194 0.00932 0.131 0.265 0.758

Total 1 2,410 21.71 0.0194 0.00932 0.131 0.265 0.758

DIFF Add ACI

- 1 [Hg] Small Unit 293 9.64 0.00216 0.00104 0.00364 0.0289 0.0843

Total 1 293 9.64 0.00216 0.00104 0.00364 0.0289 0.0843

WS Add FF Large Unit 3,678 6.19 0.0300 0.0144 0.221 0.411 1.17

Total 1 3,678 6.19 0.0300 0.0144 0.221 0.411 1.17

Total Nationwide 6 13,610 73.8 0.110 0.0527 0.747 1.50 4.29

a A negative increase in secondary impacts would be equivalent to a reduction in secondary impacts.

## 15 V. Cost and Emission Reduction Estimates for Meeting Hg

, N on

- Hg HAP Metals , and

Dioxin/Furan TEQ Beyond

- the

- Floor Options

As noted in the preamble to the proposed rule, the beyond

- the

- floor options considered

for c lay c eramics sources a re emission limits equal to the new source limits for Hg, PM , and

dioxin/furan TEQ. The development of these limits is documented in the memorandum Maximum Achievable Control Technology (MACT) Floor Analysis for Clay Ceramics (Raymond and Sroka, 2014). The process to estimate costs, emission reductions, and secondary impacts for the beyond

- the

- floor options is the same three

- step process described in Section IV of this memorandum. The beyond

- the

- floor options for Hg, PM, and dioxin/furan TEQ were considered separately to clearly evaluate the impacts of applying each o ption. When considering each beyond

- the

- floor option, all other standards were applied as proposed, and the impacts calculated in Section IV associated with the proposed standards were removed to calculate incremental impacts for the beyond

- the

- floor opti on. Beyond

- the

- floor options were not evaluated for some unit types because the new and existing MACT floors were set at the same

value. As such

, meeting the beyond

- the

- floor option would be the same as meeting MACT

. Those unit types and pollutants for which impacts were not evaluated for beyond

- the

- floor options were :

• PM, Hg, and dioxin/furan TEQ from wall tile roller kiln s ;

• Hg from ceramic tile glazing operations ;

• Dioxin/furan TEQ from wall tile spray dryer s ; and

• Dioxin/furan TEQ from floor tile press dryer s

.

A. Floor Tile Roller Kilns Beyond

- the

- Floor Option

1. P articulate M atter (Surrogate for Non

- Hg HAP Metals)

Step 1: Compare Test Data to Emission Limits

The first step was to compare the data available to the emission limit for the beyond

- the

floo r option for PM (surrogate for non

- Hg HAP metals). Table 20 shows the percentage of floor tile roller kilns meeting the emission limit for the PM beyond

- the

- floor option.

Table 20 . Percentage of Floor Tile Roller Kiln Stacks w ith Data Less Than or Equal to PM Beyond

- the

- Floor Option

Size APCD Type N o. of Kiln Stacks

with Data Percentage of Kilns Meeting PM lb/ton Limit

All None 5 13

DIFF 1

DLS/FF ND

WS 2

ND = no data

## 16 Step 2 : Develop Estimate of Number of APCD Needed

The same process used in Step 2 of Section IV was followed

, with the exception of comparing the units to the emission limit for the PM beyond

- the

- floor option

, as opposed to the proposed PM emission limit

. In addition

, t he requirements for meeting the proposed Hg and

dioxin/furan TEQ limits remained unchanged. After each unit was evaluated to see if it could meet the limits, the percentage of units (with and without data) meeting the emission limit for the

PM beyond

- the

- f loor option was calculated. This percentage was compared to the percentage previously calculated for units with data (Table 20) to make sure they were similar. Two additional adjustments to the meeting limit decisions were made in order to make the percent age meeting limit value similar to that in Table 20. The criteria for APCD to be installed or not from

Table 15 were used to determine the final estimates of APCD counts for the PM beyond

- the

floor option , as shown in Table 21.

Step 3: Calculate the Natio nwide Costs, Emission Reductions, and Secondary Impacts

The final step in estimating nationwide costs and impacts for the PM beyond

- the

- floor option was to apply model APCD costs, emission reductions, and secondary impacts to the

APCD counts shown in Table 21. Table s 22 , 23, and 24 show the summary of nationwide costs

, nationwide emission reductions, and nationwide secondary impacts, respectively, for floor tile

roller kilns for the PM beyond

- the floor option.

## 17 Table 2 1

. Summary of Floor Tile Roller Kiln Stacks and Estimate of APCD to B e Installed for PM Beyond

- the

- Floor Option

Existing APCD Type Size N o. of

Stacks Estimate of Stacks

Add

ACI

- 1 Add

ACI

- 2 Add

FF Add FF

and

ACI

- 1 Add FF

and

ACI

- 2 Install

FF Install

FF and

ACI

- 1 Install

FF and

ACI

- 2 Retrofit

with

DIFF Retrofit

with DIFF

and ACI

- 1 Retrofit

with DIFF

and ACI

- 2 No

action

None Small 9 5 2 [D / F]
1 [Hg] 1 [D / F & Hg]

DIFF Small 1 1 [Hg]

None Large 2 2

DLS/FF Large 1 1

DIFF Large 1 1

WS Large 2 2

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



### Table 2 2 . Summary of Nationwide Costs for Floor Tile Roller Kiln Stacks for PM Beyond

- the

- Floor Option

Current

APCD Action APCD Size Unit Capital

Cost Unit Annual

Cost N o. of

APCD Total Capital

Cost Total Annual

Cost

None Install FF Small $410,770 $283,552 5 $2,053,850 $1,417,760

None Install FF and ACI

- 1 [D / F] Small $497,508 $364,592 2 $995,016 $729,184

None Install FF and ACI

- 1 [Hg] Small $497,508 $364,592 1 $497,508 $364,592

None Install FF and ACI

- 2 [D / F & Hg] Small $497,508 $381,358 1 $497,508 $381,358

DIFF Retrofit with DIFF and ACI

- 1 [Hg] Small $1,596,904 $517,889 1 $1,596,904 $517,889

None Install FF Large $412,256 $330,417 2 $824,512 $660,834

DLS/FF Retrofit with DIFF Large $2,916,026 $685,272 1 $2,916,026 $685,272

DIFF Retrofit with DIFF Large $2,916,026 $685,272 1 $2,916,026 $685,272

WS Add FF Large $577,158 $352,579 2 $1,154,316 $705,158

Total Nationwide 16 $13,451,667 $6,147,320

Total for Proposed Standards $2,653,930 $1,866,834

Incremental Nationwide Cost $10,797,738 $4,280,486

## 18 Table 2 3 . Summary of Nationwide Emission Reductions for Floor Tile Roller Kiln Stacks for PM Beyond

- the

- Floor Option

Current

APCD Action APCD

Size Emissions Type N o. of

APCD Emission Reductions (tpy)

HF HCl HAP

Metals PM Hg D/F D/F TEQ SO 2 

### PM 2.5 a

None Install FF Small Unit 0 0 0.086 2.5 0 0 0 0 1.2

Total 5 0 0 0.43 12.5 0 0 0 0 6.0

None Install FF and

ACI

- 1 [D / F] Small Unit 0 0 0.086 2.5 0 6.37E

- 06 1.09E

- 07 0 1.2

Total 2 0 0 0.17 5.0 0 1.27E

- 05 2.18E

- 07 0 2.4

None Install FF and

ACI

- 1 [Hg] Small Unit 0 0 0.086 2.5 3.28E

- 03 0 0 0 1.2

Total 1 0 0 0.086 2.5 3.28E

- 03 0 0 0 1.2

None Install FF and

ACI

- 2 [D / F & Hg] Small Unit 0 0 0.086 2.5 3.28E

- 03 6.37E

- 06 1.09E

- 07 0 1.2

Total 1 0 0 0.086 2.5 3.28E

- 03 6.37E

- 06 1.09E

- 07 0 1.2

DIFF Retrofit with

DIFF and

ACI

- 1 [Hg] Small Unit 0.07 0.04 0.02 0.6 3.28E

- 03 0 0 0.37 0.288

Total 1 0.07 0.04 0.02 0.6 3.28E

- 03 0 0 0.37 0.288

None Install FF Large Unit 0 0 0.103 6.2 0 0 0 0 3.0

Total 2 0 0 0.206 12.4 0 0 0 0 6.0

DLS/FF Retrofit with

DIFF Large Unit 1.18 0.14 0.024 1.4 0 0 0 0.47 0.672

Total 1 1.18 0.14 0.024 1.4 0 0 0 0.47 0.672

DIFF Retrofit with

DIFF Large Unit 1.18 0.14 0.024 1.4 0 0 0 0.47 0.672

Total 1 1.18 0.14 0.024 1.4 0 0 0 0.47 0.672

WS Add FF Large Unit 0 0 0.029 1.7 0 0 0 0 0.816

Total 2 0 0 0.058 3.4 0 0 0 0 1.632

Total Nationwide 2.4 0.32 1.1 41 0.0098 1.91E

- 05 3.27E

- 07 1.3 20

Total for Proposed Standards 0 0 0.37 12 0.0088 1.7E

- 05 2.9E

- 07 0.00 4.9

Incremental Nationwide Emissions 2.4 0.32 0.74 30 0.0010 2.11E

- 06 3.70E

- 08 1.3 15

a Estimated as 48 percent of PM reductions.

## 19 Table 2 4 . Summary of Nationwide Secondary Impacts for Floor Tile Roller Kiln Stacks for PM Beyond

- the

- Floor Option a



### Current

APCD Action APCD

Size Emissions Type N o. of

APCD Energy

I mpacts, MMBtu/yr Solid W aste

I mpacts, tpy Secondary Air Emissions Increase (tpy)

PM PM 2.5 

### CO NO

x 

### SO 2

None Install FF Small Unit 2,117 2.46 0.0173 0.00829 0.127 0.236 0.673

Total 5 10,587 12.28 0.0863 0.0414 0.635 1.18 3.37

None Install FF and

ACI

- 1 [D / F] Small Unit 2,410 16.91 0.0194 0.00932 0.131 0.265 0.758

Total 2 4,820 33.82 0.0389 0.0186 0.261 0.531 1.52

None Install FF and

ACI

- 1 [Hg] Small Unit 2,410 16.91 0.0194 0.00932 0.131 0.265 0.758

Total 1 2,410 16.91 0.0194 0.00932 0.131 0.265 0.758

None Install FF and

ACI

- 2 [D / F & Hg] Small Unit 2,410 26.55 0.0194 0.00932 0.131 0.265 0.758

Total 1 2,410 26.55 0.0194 0.00932 0.131 0.265 0.758

DIFF Retrofit with DIFF

and ACI

- 1 [Hg] Small Unit 293 15.70 0.0022 0.00104 0.00364 0.0289 0.0843

Total 1 293 15.70 0.0022 0.00104 0.00364 0.0289 0.0843

None Install FF Large Unit 3,678 6.19 0.0300 0.0144 0.221 0.411 1.170

Total 2 7,355 12.38 0.0600 0.0288 0.441 0.821 2.339

DLS/FF Retrofit with DIFF Large Unit 0 3.67 0 0 0 0 0

Total 1 0 3.67 0 0 0 0 0

DIFF Retrofit with DIFF Large Unit 0 3.67 0 0 0 0 0

Total 1 0 3.67 0 0 0 0 0

WS Add FF Large Unit 3,678 6.19 0.0300 0.0144 0.221 0.411 1.17

Total 2 7,355 12.38 0.0600 0.0288 0.441 0.821 2.34

Total Nationwide 35,230 137 0.286 0.137 2.04 3.92 11.2

Total for Proposed Standards 13,610 73.8 0.110 0.0527 0.747 1.50 4.29

Incremental Nationwide Emissions 21,620 63.6 0.176 0.0847 1.30 2.42 6.87

a A negative increase in secondary impacts would be equivalent to a reduction in secondary impacts.

## 20 2. Mercury

Step 1: Compare Test Data to Emission Limits

The first step was to compare the data available to the emission limit for the Hg beyond

the

- floor option. Table 25 shows the percentage of floor tile roller kilns meeting the emission

limit for the Hg beyond

- the

- floor option.

Table 2 5 . Percentages of Floor Tile Roller Kiln Stacks w ith Data Less Than or Equal to Hg Beyond

- the

- Floor Opti on

Size APCD Type N o. of Kiln Stacks

with Data Percentage of Kilns Meeting Hg

lb/ton Limit

All None 3 17 %

DIFF 1

DLS/FF ND

WS 2

ND = no data



## Step 2 : Develop Estimate of Number of APCD Needed

The same process used in Step 2 of Section IV was followed

, with the exception of comparing the units to the emission limit for the Hg beyond

- the

- floor option

, as opposed to the proposed Hg emission limit. In addition

, the requirements for meeting the proposed PM and

dioxin/furan TEQ li mits remained unchanged. After each unit was evaluated to see if it could meet the limits, the percentage of units (with and without data) meeting the emission limit for the
Hg beyond

- the

- floor option was calculated. This percentage was compared to the per centage previously calculated for units with data (Table 25) to make sure they were similar. The criteria

for APCD to be installed or not from Table 15 were used to determine the final estimates of

APCD counts for the Hg beyond

- the

- floor option, as shown i n Table 26.

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

The final step in estimating nationwide costs and impacts for the Hg beyond

- the

- floor option was to apply model APCD costs, emission reductions, and secondary i mpacts to the

APCD counts shown in Table 26. Table s 27 , 28, and 29 show the summary of nationwide costs

, nationwide emission reductions, and nationwide secondary impacts, respectively, for floor tile

roller kilns for the Hg beyond

- the floor option.

## 21 Table 2 6 . Summary of Floor Tile Roller Kiln Stacks and Estimate of APCD to B e Installed for Hg Beyond

- the

- Floor Option

Existing APCD Type Size N o. of

Stacks Estimate of Stacks

Add

ACI

- 1 Add

ACI

- 2 Add

FF Add FF

and

ACI

- 1 Add FF

and

ACI

- 2 Install

FF Install

FF and

ACI

- 1 Install

FF and

ACI

- 2 Retrofit

with

DIFF Retrofit

with

DIFF and

ACI

- 1 Retrofit

with

DIFF and

ACI

- 2 No

action

None Small 9 5 [Hg] 3 [D / F & Hg] 1

DIFF Small 1 1 [Hg]

None Large 2 2 [Hg]

DLS/FF Large 1 1

DIFF Large 1 1

WS Large 2 2 [Hg]

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



### Table 2 7 . Summary of Nationwide Costs for Floor Tile Roller Kiln Stacks for Hg Beyond

- the

- Floor Option

Current

APCD Action APCD Size Unit Capital

Cost Unit Annual

Cost N o. of

APCD Total Capital

Cost Total Annual

Cost

None Install FF and ACI

- 1 [Hg] Small $497,508 $364,592 5 $2,487,540 $1,822,960

None Install FF and ACI

- 2 [D / F & Hg] Small $497,508 $381,358 3 $1,492,524 $1,144,074

DIFF Add ACI

- 1 [Hg] Small $86,738 $81,039 1 $86,738 $81,039

None Install FF and ACI

- 1 [Hg] Large $599,154 $484,563 2 $1,198,308 $969,126

WS Add FF and ACI

- 1 [Hg] Large $764,057 $506,725 2 $1,528,114 $1,013,450

Total Nationwide 13 $6,793,226 $5,030,647

Total for Proposed Standards $2,653,930 $1,866,834

Incremental Nationwide Cost $4,139,296 $3,163,813

## 22 Table 28 . Summary of Nationwide Emission Reductions for Floor Tile Roller Kiln Stacks for Hg Beyond

- the

- Floor Option

Current

APCD Action APCD

Size Emissions Type N o. of

APCD Emission Reductions (tpy)

HF HCl HAP

Metals PM Hg D/F D/F TEQ SO 2 

### PM 2.5 a

None Install FF and

ACI

- 1 [Hg] Small Unit 0 0 0.086 2.5 3.28E

- 03 0 0 0 1.2

Total 5 0 0 0.43 12.5 1.64E

- 02 0 0 0 6.0

None Install FF and

ACI

- 2 [D / F & Hg] Small Unit 0 0 0.086 2.5 3.28E

- 03 6.37E

- 06 1.09E

- 07 0 1.2

Total 3 0 0 0.258 7.5 9.84E

- 03 1.91E

- 05 3.27E

- 07 0 3.6

DIFF Add ACI

- 1 [Hg] Small Unit 0 0 0 0 3.28E

- 03 0 0 0 0

Total 1 0 0 0 0 3.28E

- 03 0 0 0 0

None Install FF and

ACI

- 1 [Hg] Large Unit 0 0 0.103 6.2 5.83E

- 03 0 0 0 3.0

Total 2 0 0 0.206 12.4 1.17E

- 02 0 0 0 6.0

WS Add FF and

ACI

- 1 [Hg] Large Unit 0 0 0.029 1.7 5.83E

- 03 0 0 0 0.82

Total 2 0 0 0.058 3.4 1.17E

- 02 0 0 0 1.6

Total Nationwide 0 0 0.95 36 0.053 1.91E

- 05 3.27E

- 07 0 17

Total for Proposed Standards 0 0 0.37 12 0.0088 1.7E

- 05 2.9E

- 07 0 4.9

Incremental Nationwide Emissions 0 0 0.58 24 0.044 2.01E

- 06 3.46E

- 08 0 12

a Estimated as 48 percent of PM reductions.

## 23 Table 29 . Summary of Nationwide Secondary Impacts for Floor Tile Roller Kiln Stacks for Hg Beyond

- the

- Floor Option a



### Current

APCD Action APCD

Size Emissions Type N o. of

APCD Energy

I mpacts, MMBtu/yr Solid W aste

I mpacts, tpy Secondary Air Emissions Increase (tpy)

PM PM 2.5 

### CO NO

x 

### SO 2

None Install FF and

ACI

- 1 [Hg] Small Unit 2,410 16.9 0.0194 0.00932 0.131 0.265 0.758

Total 5 12,050 84.5 0.0971 0.0466 0.654 1.33 3.79

None Install FF and

ACI

- 2 [D / F & Hg] Small Unit 2,410 26.5 0.0194 0.00932 0.131 0.265 0.758

Total 3 7,230 79.6 0.0583 0.0280 0.392 0.796 2.27

DIFF Add ACI

- 1 [Hg] Small Unit 293 14.5 0.00216 0.00104 0.00364 0.0289 0.0843

Total 1 293 14.5 0.00216 0.00104 0.00364 0.0289 0.0843

None Install FF and

ACI

- 1 [Hg] Large Unit 4,556 49.1 0.0365 0.0175 0.232 0.498 1.42

Total 2 9,111 98.2 0.0729 0.0350 0.463 0.995 2.85

WS Add FF and ACI

1 [Hg] Large Unit 4,556 49.1 0.0365 0.0175 0.232 0.498 1.42

Total 2 9,111 98 0.0729 0.0350 0.463 0.995 2.85

Total Nationwide 37,795 375 0.303 0.146 1.98 4.14 11.8

Total for Proposed Standards 13,610 73.8 0.110 0.0527 0.747 1.50 4.29

Incremental Nationwide Emissions 24,185 301 0.193 0.0929 1.23 2.64 7.55

a A negative increase in secondary impacts would be equivalent to a reduction in secondary impacts.

## 24 3. Dioxin/Furan TEQ

Step 1: Compare Test Data to Emission Limits

The first step was to compare the data available to the emission limit for the dioxin/furan
TEQ beyond

- the

- floor option. Table 30 shows the percentage of floor tile roller kilns meeting the

emission limit for the dioxin/furan TEQ beyond

- the

- floor option.

T able 3 0 . Percentages of Floor Tile Roller Kiln Stacks w ith Data Less Than or Equal to

Dioxin/Furan TEQ Beyond

- the

- Floor Option

Size APCD Type N o. of Kiln Stacks

with Data Percentage of Kilns Meeting D/F TEQ ng/dscm @ 7% O 2 

### Limit

All None 2 20 %

DIFF 1

DLS/FF ND

WS 2

ND = no data



## Step 2 : Develop Estimate of Number of APCD Needed

The same process used in Step 2 of Section IV was followed

, with the exception of comparing the units to the emission limit for the dioxin/furan TEQ beyond

- the

- floor option

, as opposed to the proposed dioxin/furan TEQ emission limit. In addition

, the requirements for meeting the proposed PM and Hg limits remained unchanged. After each unit was evaluated to see if it could meet the limits, the percentage of units (with and without data) meeting the

emission limit for the dioxin/furan TEQ beyond

- the

- floor option was calculated. This percentage was compared to the percentage previously calculated for units with data (Table 30) to make sure they were similar. The criteria f or APCD to be installed or not from Table 15 were used to

determine the final estimates of APCD counts for the dioxin/furan TEQ beyond

- the

- floor option,

as shown in Table 31.

Step 3: Calculate the Nationwide Costs, Emission Reductions, and Secondary Impa cts

The final step in estimating nationwide costs and impacts for the dioxin/furan TEQ beyond

- the

- floor option was to apply model APCD costs, emission reductions, and secondary impacts to the APCD counts shown in Table 31. Table s 32 , 33, and 34 show the s ummary of

nationwide costs

, nationwide emission reductions, and nationwide secondary impacts, respectively, for floor tile roller kilns for the dioxin/furan TEQ beyond

- the floor option.

## 25 Table 3 1 . Summary of Floor Tile Roller Kiln Stacks and Estimate of APCD to B e Installed for Dioxin/Furan TEQ Beyond

- the

Floor Option

Existing

APCD Type Size N o. of

Stacks Estimate of Stacks

Add

ACI

- 1 Add

ACI

- 2 Add

FF Add

FF and

ACI

- 1 Add

FF and

ACI

- 2 Install

FF Install

FF and

ACI

- 1 Install

FF and

ACI

- 2 Retrofit

with

DIFF Retrofit

with DIFF

and ACI

- 1 Retrofit

with DIFF

and ACI

- 2 No

action

None Small 9 4 [D / F] 2 [D / F & Hg] 3

DIFF Small 1 1 [D / F & Hg]

None Large 2 2

DLS/FF Large 1 1 [D / F]

DIFF Large 1 1 [D / F]

WS Large 2 2 [D / F]

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



### Table 3 2 . Summary of Nationwide Costs for Floor Tile Roller Kiln Stacks for Dioxin/Furan TEQ Beyond

- the

- Floor Option

Current

APCD Action APCD

Size Unit Capital

Cost Unit Annual

Cost N o. of

APCD Total Capital

Cost Total Annual

Cost

None Install FF and ACI

- 1 [D / F] Small $497,508 $364,592 4 $1,990,032 $1,458,368

None Install FF and ACI

- 2 [D / F & Hg] Small $497,508 $381,358 2 $995,016 $762,716

DIFF Add ACI

- 2 [D / F & Hg] Small $86,738 $97,806 1 $86,738 $97,806

DLS/FF Add ACI

- 1 [D / F] Large $186,898 $154,146 1 $186,898 $154,146

DIFF Add ACI

- 1 [D / F] Large $186,898 $154,146 1 $186,898 $154,146

WS Add FF and ACI

- 1 [D / F] Large $764,057 $506,725 2 $1,528,114 $1,013,450

Total Nationwide 11 $4,973,698 $3,640,629

Total for Proposed Standards $2,653,930 $1,866,834

Incremental Nationwide Cost $2,319,769 $1,773,794

## 26 Table 3 3 . Summary of Nationwide Emission Reductions for Floor Tile Roller Kiln Stacks for Dioxin/Furan TEQ Beyond

- the

Floor Option

Current

APCD Action APCD

Size Emissions Type N o. of

APCD Emission Reductions (tpy)

HF HCl HAP

Metals PM Hg D/F D/F TEQ SO 2 

### PM 2.5 a

No ne Install FF and ACI

1 [D / F] Small Unit 0 0 0.086 2.5 0 6.37E

- 06 1.09E

- 07 0 1.2

Total 4 0 0 0.344 10 0 2.55E

- 05 4.36E

- 07 0 4.8

None Install FF and ACI

2 [D / F & Hg] Small Unit 0 0 0.086 2.5 3.28E

- 03 6.37E

- 06 1.09E

- 07 0 1.2

Total 2 0 0 0.172 5 6.56E

- 03 1.27E

- 05 2.18E

- 07 0 2.4

DIFF Add ACI

- 2 [D / F & Hg] Small Unit 0 0 0 0 3.28E

- 03 6.37E

- 06 1.09E

- 07 0 0

Total 1 0 0 0 0 3.28E

- 03 6.37E

- 06 1.09E

- 07 0 0

DLS/FF Add ACI

- 1 [D / F] Large Unit 0 0 0 0 0 4.08E

- 06 9.61E

- 08 0 0

Total 1 0 0 0 0 0 4.08E

- 06 9.61E

- 08 0 0

DIFF Add ACI

- 1 [D / F] Large Unit 0 0 0 0 0 4.08E

- 06 9.61E

- 08 0 0

Total 1 0 0 0 0 0 4.08E

- 06 9.61E

- 08 0 0

WS Add FF and ACI

- 1 [D / F] Large Unit 0 0 0.029 1.7 0 4.08E

- 06 9.61E

- 08 0 0.816

Total 2 0 0 0.058 3.4 0 8.16E

- 06 1.92E

- 07 0 1.632

Total Nationwide 0 0 0.57 18 0.0098 6.1E

- 05 1.1E

- 06 0 8.8

Total for Proposed Standards 0 0 0.37 12 0.0088 1.7E

- 05 2.9E

- 07 0 4.9

Incremental Nationwide Emissions 0 0 0.20 6.8 0.0010 4.4E

- 05 8.6E

- 07 0 3.9

a Estimated as 48 percent of PM reductions.

## 27 Table 3 4 . Summary of Nationwide Secondary Impacts for Floor Tile Roller Kiln Stacks for Dioxin/Furan TEQ Beyond

- the

Floor Option a



### Current

APCD Action APCD

Size Emissions Type N o. of

APCD Energy

I mpacts, MMBtu/yr Solid

W aste

I mpacts, tpy Secondary Air Emissions Increase (tpy)

PM PM 2.5 

### CO NO

x 

### SO 2

None Install FF and

ACI

- 1 [D / F] Small Unit 2,410 16.9 0.0194 0.00932 0.131 0.265 0.758

Total 4 9,640 67.6 0.0777 0.0373 0.523 1.06 3.03

None Install FF and

ACI

- 2 [D / F & Hg] Small Unit 2,410 26.5 0.0194 0.00932 0.131 0.265 0.758

Total 2 4,820 53.1 0.0389 0.0186 0.261 0.531 1.52

DIFF Add ACI

- 2 [D / F & Hg] Small Unit 293 24.1 0.00216 0.00104 0.00364 0.0289 0.0843

Total 1 293 24.1 0.00216 0.00104 0.00364 0.0289 0.0843

DLS/FF Add ACI

- 1 [D / F] Large Unit 878 42.9 0.00648 0.00311 0.0109 0.0868 0.253

Total 1 878 42.9 0.00648 0.00311 0.0109 0.0868 0.253

DIFF Add ACI

- 1 [D / F] Large Unit 878 42.9 0.00648 0.00311 0.0109 0.0868 0.253

Total 1 878 42.9 0.00648 0.00311 0.0109 0.0868 0.253

WS Add FF and ACI

1 [D / F] Large Unit 4,556 49.1 0.0365 0.0175 0.232 0.498 1.42

Total 2 9,111 98.2 0.0729 0.0350 0.463 0.995 2.85

Total Nationwide 25,620 329 0.205 0.0982 1.27 2.79 7.98

Total for Proposed Standards 13,610 73.8 0.110 0.0527 0.747 1.50 4.29

Incremental Nationwide Emissions 12,010 255 0.0946 0.0455 0.53 1.29 3.69

a A negative increase in secondary impacts would be equivalent to a reduction in secondary impacts.

## 28 B

. Floor Tile Spray Dryers Beyond

- the

- Floor Option

1. Dioxin/Furan TEQ

Step 1: Compare Test Data to Emission Limits

The first step was to compare the data available to the emission limit for the dioxin/furan
TEQ beyond

- the

- floor option. Table 35 shows the percentage of floor tile spray dryers meeting

the emission limit for the dioxin/furan TEQ beyond

- the

- floor option.

Table 3 5 . Percentages of Floor Tile Spray Dryer Stacks w ith Data Less Than or Equal to

Dioxin/Furan TEQ Beyond

- the

- Floor Option

Size APCD Typ e N o. of Spray Dryer

Stacks with Data Percentage of Spray Dryers Meeting

D/F T EQ ng/dscm @ 7% O 2 

### Limit

Large WS 2 6 0 %

FF 3



## Step 2 : Develop Estimate of Number of APCD Needed

For the next step, in addition to looking at the units with data, estimates for the units without data were developed to estimate the number of APCD needed for the floor tile spray dryers to meet the dioxin/furan TEQ beyond

- the

- floor option. For 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 compared to the emission limit for the
dioxin/furan TEQ beyond

- the

- floor option to s ee if the data would meet the limits or not. After each unit was evaluated to see if it could meet the limits, the percentage of units (with and without data) meeting the emission limit for the dioxin/furan TEQ beyond

- the

- floor option was
calculated. This percentage was compared to the percentage previously calculated for units with
data (Table 35 ) to make sure they were similar. The criteria for APCD to be installed or not from

Table 15 were used to determine the final estimates of APCD counts for the diox in/furan TEQ beyond

- the

- floor option, as shown in Table 3 6

.

Table 3 6 . Summary of Floor Tile Spray Dryer Stacks and Estimate of APCD to B e Installed

for Dioxin/Furan TEQ Beyond

- the

- Floor Option

Existing APCD Type Size N o. of Stacks Estimate of Stacks

Add ACI

- 1 No action

WS Large 2 2 [D / F]

FF Large 5 5

Add: keeping existing equipment in place and adding the new equipment to the configuration

ACI

- 1: Activated Carbon Injection for D / F TEQ



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

The final step in estimating nationwide costs and impacts for the dioxin/furan TEQ beyond

- the

- floor option was to apply model APCD costs, emission reductions, and secondary impacts to the APCD counts shown in Table 36. Ta ble s 37 , 38, and 39 show the summary of

nationwide costs

, nationwide emission reductions, and nationwide secondary impacts, respectively, for floor tile spray dryers for the dioxin/furan TEQ beyond

- the floor option.

## 29 Table 37 . Summary of Nationwide Costs for Floor Tile Spray Dryer Stacks for Dioxin/Furan TEQ Beyond

- the

- Floor Option

Current

APCD Action APCD

Size Unit Capital

Cost Unit Annual

Cost N o. of APCD Total Capital

Cost Total Annual

Cost

WS Add ACI

- 1 [D / F] Large $167,585 $138,815 2 $335,170 $277,630

Total Nationwide 2 $335,170 $277,630

Total for Proposed Standards $0 $0

Incremental Nationwide Cost $335,170 $277,630



### Table 38 . Summary of Nationwide Emission Reductions for Floor Tile Spray Dryer Stacks for Dioxin/Furan TEQ Beyond

the

- Floor Option

Current

APCD Action APCD

Size Emissions Type N o. of

APCD Emission Reductions (tpy)

HF HCl HAP

Metals PM Hg D/F D/F TEQ SO 2 

### PM 2.5 a

WS Add ACI

1 [D / F] Large Unit 0 0 0 0 0 8.27E

- 06 4.63E

- 08 0 0

Total 2 0 0 0 0 0 1.65E

- 05 9.26E

- 08 0 0

Total Nationwide 0 0 0 0 0 1.65E

- 05 9.26E

- 08 0 0

Total for Proposed Standards 0 0 0 0 0 0.00E

- 00 0.00E

- 00 0 0

Incremental Nationwide Emissions 0 0 0 0 0 1.65E

- 05 9.26E

- 08 0 0

a Estimated as 48 percent of PM reductions.



### Table 39 . Summary of Nationwide Secondary Impacts for Floor Tile Spray Dryer Stacks for Dioxin/Furan TEQ Beyond

- the

Floor Option a



### Current

APCD Action APCD

Size Emissions Type N o. of

APCD Energy

I mpacts, MMBtu/yr Solid

W aste

I mpacts, tpy Secondary Air Emissions Increase (tpy)

PM PM 2.5 

### CO NO

x 

### SO 2

WS Add ACI

- 1 [D / F] Large Unit 749 36.8 0.00553 0.00265 0.00932 0.0741 0.216

Total 2 1,499 73.6 0.0111 0.0053 0.0186 0.148 0.432

Total Nationwide 1,499 73.6 0.0111 0.0053 0.0186 0.148 0.432

Total for Proposed Standards 0 0 0 0 0 0 0

Incremental Nationwide Emissions 1,499 73.6 0.0111 0.0053 0.0186 0.148 0.432

a A negative increase in secondary impacts would be equivalent to a reduction in secondary impacts.

## 30 C

. Ceramic Tile Glazing Beyond

- the

- Floor Option

1. P articulate M atter (Surrogate for Non

- Hg HAP Metals)

Step 1: Compare Test Data to Emission Limits

The first step was to compare the data available to the emission limit for the beyond

- the

floor option for PM (surrogate for non

- Hg HAP metals). Table 40 shows the percentage of ceramic tile glazing stacks meeting the emission limit for the PM beyond

- the

- f loor option.

Table 4 0 . Percentages of Ceramic Tile Glazing Stacks w ith Data Less Than or Equal to

PM Beyond

- the

- Floor Option

Size APCD Type N o. of Ceramic Tile Glazing Stacks with Data Percentage of Ceramic Tile Glazing

Stacks Meeting PM lb/ton Limit

Small & Large FF 2 67 %

WS 1



## Step 2 : Develop Estimate of Number of APCD Needed

For the next step, in addition to looking at the units with data, estimates for the units without data were developed to estimate the number of APCD needed for the ceramic tile glazing stacks to meet the PM beyond

- the

- floor option . For those units with no data available,

the current control device of the unit was examined. For units with WS

, it was assumed that they

could not meet the PM beyond

- the

- floor limits. For units with FF, it was assumed that they could

meet the PM beyond

- the

- floor limits . After each unit was evaluated to see if it could meet the limits, the percentage of units (with and without data) meeting the emission limit for the PM beyond

- the

- floor option was calculated. This percentage was compared to the percentage previously calc ulated for units with data (Table 40) to make sure they were similar. One additional adjustment to the meeting limit decisions were made in order to make the percentage meeting limit value similar to that in Table 40. The criteria for APCD to be installed or not from

Table 15 were used to determine the final estimates of APCD counts for the PM beyond

- the

floor option, as shown in Table 41.

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

The final step in estimating natio nwide costs and impacts for the PM beyond

- the

- floor option was to apply model APCD costs, emission reductions, and secondary impacts to the

APCD counts shown in Table 41. Table s 42 , 43, and 44 show the summary of nationwide costs,

nationwide emission redu ctions, and nationwide secondary impacts, respectively, for ceramic tile glazing stacks for the PM beyond

- the floor option.

## 31 Table 4 1 . Summary of Ceramic Tile Glazing Stacks and Estimate of APCD to B e Installed for PM Beyond

- the

- Floor Option

Existing APCD Type Size N o. of Stacks Estimate of Stacks

Add ACI

- 1 Add FF Add FF

and ACI

- 1 Retrofit with

FF Retrofit with

FF and ACI

- 1 No action

FF Small 6 6

WS Small 3 3

FF Large 3 1 2

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



### Table 4 2 . Summary of Nationwide Costs for Ceramic Tile Glazing Stacks for PM Beyond

- the

- Floor Option

Current

APCD Action APCD

Size Unit Capital

Cost Unit Annual

Cost N o. of

APCD Total Capital

Cost Total Annual

Cost

WS Add FF Small $919,932 $275,096 3 $2,759,796 $825,288

FF Retrofit with FF Large $1,207,844 $542,348 1 $1,207,844 $542,348

Total Nationwide 4 $3,967,639 $1,367,637

Total for Proposed Standards $0 $0

Incremental Nationwide Cost $3,967,639 $1,367,637

## 32 Table 4 3 . Summary of Nationwide Emission Reductions for Ceramic Tile Glazing Stacks for PM Beyond

- the

- Floor Option

Current

APCD Action APCD

Size Emissions Type N o. of

APCD Emission Reductions (tpy)

HF HCl HAP

Metals PM Hg D/F D/F TEQ SO 2 

### PM 2.5 a

WS Ad d FF Small Unit 0 0 0.0104 0.772 0 0 0 0 0.371

Total 3 0 0 0.0312 2.32 0 0 0 0 1.11

FF Retrofit

with FF Large Unit 0 0 0.00288 0.214 0 0 0 0 0.103

Total 1 0 0 0.00288 0.214 0 0 0 0 0.103

Total Nationwide 0 0 0.0341 2.53 0 0 0 0 1.21

Total for Proposed Standards 0 0 0 0 0 0 0 0 0

Incremental Nationwide Emissions 0 0 0.0341 2.53 0 0 0 0 1.21

a Estimated as 48 percent of PM reductions.



### Table 4 4 . Summary of Nationwide Secondary Impacts for Ceramic Tile Glazing Stacks for PM Beyond

- the

- Floor Option a



### Current

APCD Action APCD

Size Emissions Type N o. of

APCD Energy

I mpacts, MMBtu/yr Solid W aste

I mpacts, tpy Secondary Air Emissions Increase (tpy)

PM PM 2.5 

### CO NO

x 

### SO 2

WS Add FF Small Unit 2,464 0.772 0.0182 0.00874 0.0307 0.244 0.71

Total 3 7,392 2.32 0.0546 0.0262 0.0921 0.732 2.13

FF Retrofit with

FF Large Unit 11,706 0.214 0.0864 0.0415 0.146 1.16 3.37

Total 1 11,706 0.214 0.0864 0.0415 0.146 1.16 3.37

Total Nationwide 19,099 2.53 0.141 0.0677 0.238 1.89 5.5

Total for Proposed Standards 0 0 0 0 0 0 0

Incremental Nationwide Emissions 19,099 2.53 0.141 0.0677 0.238 1.89 5.5

a A negative increase in secondary impacts would be equivalent to a reduction in secondary impacts.

## 33 D

. Sanitaryware Tunnel Kilns Beyond

- the

- Floor Option

1. P articulate M atter (Surrogate for Non

- Hg HAP Metals)

Step 1: Compare Test Data to Emission Limits

The first step was to compare the data available to the emission limit for the beyond

- the

floor option for PM (surrogate for non

- H g HAP metals). Table 45 shows the percentage of sanitaryware tunnel kilns meeting the emission limit for the PM beyond

- the

- floor option.

Table 4 5 . Percentages of Sanitaryware Tunnel Kiln Stacks w ith Data Less Than or Equal

to PM Beyond

- the

- Floor Option

Size APCD Type N o. of Kiln Stacks

with Data Percentage of Kilns Meeting PM

lb/ton Limit

Small & Large None 4 2 0 %

Small & Large WS 1



## Step 2 : Develop Estimate of Number of APCD Needed

For the next step, in addition to looking at the units with data, estimates for the units without data were developed to estimate the number of APCD needed for the sanitaryware tunnel

kilns to meet the PM beyond

- the

- floor option . For 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 compared to the emission limit for the PM beyond

- the

- floor option to see if the data would meet the limits 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 design capacit y from units with data were used with the design capacity f rom units without data , at the same facility, t o ratio

the emissions as estimated data for the unit s without data. Those units’ estimated data were then compared to the emission limit for the PM beyond

- the

- floor option to see if the data would meet

the limits or not. In addition

, the requirements for meeting the proposed Hg and dioxin/furan TEQ limits remained unchanged. After each unit was evaluated to see if it could meet the limits, the percentage of units (with and without data) meeting the emission limit for the PM beyond

the

- floor option was calculated. This percentage was compared to the percentage previously calculated for units with data (Table 45) to make sure they were similar. The criteria for APCD

to be installed or not from Table 15 were used to determine the final es timates of APCD counts

for the PM beyond

- the

- floor option, as shown in Table 46.

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

The final step in estimating nationwide costs and impacts for the PM beyond

- the

- floor optio n was to apply model APCD costs, emission reductions, and secondary impacts to the

APCD counts shown in Table 46. Tables 47, 48, and 49 show the summary of nationwide costs,

nationwide emission reductions, and nationwide secondary impacts, respectively, f or sanitaryware tunnel kilns for the PM beyond

- the floor option.

## 34 Table 4 6 . Summary of Sanitaryware Tunnel Kiln Stacks and Estimate of APCD to B e Installed for PM Beyond

- the

- Floor Option

Existing APCD Type Size N o. of

Stacks Estimate of Stacks

Add

ACI

- 1 Add

ACI

- 2 Add

FF Add FF

and

ACI

- 1 Add FF

and

ACI

- 2 Install

FF Install

FF and

ACI

- 1 Install

FF and

ACI

- 2 Retrofit

with

DIFF Retrofit

with

DIFF and

ACI

- 1 Retrofit

with

DIFF and

ACI

- 2 No

action

None Small 6 4 2

WS Small 1 1

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



### Table 4 7 . Summary of Nationwide Costs for Sanitaryware Tunnel Kiln Stacks for PM Beyond

- the

- Floor Option

Current APCD Action APCD

Size Unit Capital

Cost Unit Annual

Cost N o. of

APCD Total Capital

Cost Total Annual

Cost

None Install FF Small $694,183 $385,403 4 $2,776,734 $1,541,613

WS Add FF Small $1,130,379 $464,956 1 $1,130,379 $464,956

Total Nationwide 5 $3,907,113 $2,006,569

Total for Proposed Standards $0 $0

Incremental Nationwide Cost $3,907,113 $2,006,569

## 35 Table 48 . Summary of Nationwide Emission Reductions for Sanitaryware Tunnel Kiln Stacks for PM Beyond

- the

- Floor Option

Current

APCD Action APCD

Size Emissions Type N o. of

APCD Emission Reductions (tpy)

HF HCl HAP

Metals PM Hg D/F D/F

TEQ SO 2 

### PM 2.5 a

None In stall

FF Small Unit 0 0 0.00395 0.293 0 0 0 0 0.141

Total 4 0 0 0.0158 1.17 0 0 0 0 0.562

WS Add FF Small Unit 0 0 0.00395 0.293 0 0 0 0 0.141

Total 1 0 0 0.00395 0.293 0 0 0 0 0.141

Total Nationwide 0 0 0.0197 1.46 0 0 0 0 0.703

Total for Proposed Standards 0 0 0 0 0 0 0 0 0

Incremental Nationwide Emissions 0 0 0.0197 1.46 0 0 0 0 0.703

a Estimated as 48 percent of PM reductions.



### Table 49 . Summary of Nationwide Secondary Impacts for Sanitaryware Tunnel Kiln Stacks for PM Beyond

- the

- Floor Option a



### Current

APCD Action APCD

Size Emissions Type N o. of

APCD Energy

I mpacts, MMBtu/yr Solid W aste

I mpacts, tpy Secondary Air Emissions Increase (tpy)

PM PM 2.5 

### CO NO

x 

### SO 2

None Install FF Small Unit 4,198 0.293 0.0310 0.0104 0.0522 0.415 1.21

Total 4 16,791 1.17 0.124 0.0415 0.209 1.66 4.84

WS Add FF Small Unit 4,198 0.293 0.0310 0.0104 0.0522 0.415 1.21

Total 1 4,198 0.293 0.0310 0.0104 0.0522 0.415 1.21

Total Nationwide 20,989 1.46 0.155 0.0519 0.261 2.07 6.05

Total for Proposed Standards 0 0 0 0 0 0 0

Incremental Nationwide Emissions 20,989 1.46 0.155 0.0519 0.261 2.07 6.05

a A negative increase in secondary impacts would be equivalent to a reduction in secondary impacts.

## 36 2. Mercury

Step 1: Compare Test Data to Emission Limits

The first step was to compare the data available to the emission limit for the Hg beyond

the

- floor option. Table 50 shows the percentage of sanitaryware tunnel kilns meeting the

emission limit for the Hg beyond

- the

- fl oor option.

Table 5 0 . Percentages of Sanitaryware Tunnel Kiln Stacks w ith Data Less Than or Equal

to Hg Beyond

- the

- Floor Option

Size APCD Type N o. of Kiln Stacks with

Data Percentage of Kilns Meeting Hg

lb/ton Limit

All None 4 100 %

WS 1



## Step 2 : Develop Estimate of Number of APCD Needed

For the next step, in addition to looking at the units with data, estimates for the units without data were developed to estimate the number of APCD needed for the sanitaryware tunnel

kilns to meet the Hg beyond

- th e

- floor option . For 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 compared to the emission limit for the Hg beyond

- the

- f loor option to see if the data would meet the limits 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 design capacit y from units with data were used with the design capacity from u nits without data, at the same facility, to ratio

the emissions as estimated data for the units without data. Those units’ estimated data were then compared to the emission limit for the Hg beyond

- the

- floor option to see if the data would meet

the limits o r not. In addition

, the requirements for meeting the proposed PM and dioxin/furan TEQ limits remained unchanged. After each unit was evaluated to see if it could meet the limits, the percentage of units (with and without data) meeting the emission limit fo r the Hg beyond

the

- floor option was calculated. This percentage was compared to the percentage previously calculated for units with data (Table 50) to make sure they were similar. The criteria for APCD

to be installed or not from Table 15 were used to det ermine the final estimates of APCD counts

for the Hg beyond

- the

- floor option, as shown in Table 51.

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

The final step in estimating nationwide costs and impacts for the Hg beyond

- the

- floor option was to apply model APCD costs, emission reductions, and secondary impacts to the APCD counts shown in Table 51. However, all the sanitaryware tunnel kil ns can meet the emission limit for the Hg beyond

- the

- floor option with no additional controls. As such, there are
no additional nationwide costs, nationwide emission reductions, or nationwide secondary impacts for sanitaryware tunnel kilns for the Hg beyon d

- the floor option.

## 37 Table 5 1 . Summary of Sanitaryware Tu nnel Kiln Stacks and Estimate of APCD to B e Installed for Hg Beyond

- the

- Floor Option

Existing APCD Type Size N o. of

Stacks Estimate of Stacks

Add

ACI

- 1 Add

ACI

- 2 Add

FF Add FF

and

ACI

- 1 Add FF

and

ACI

- 2 Install

FF Install

FF and

ACI

- 1 Install

FF and

ACI

- 2 Retrofit

with

DIFF Retrofit

with

DIFF and

ACI

- 1 Retrofit

with

DIFF and

ACI

- 2 No

action

None Small 6 6

WS Small 1 1

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

## 38 3. Dioxin/Furan TEQ

Step 1: Compare Test Data to Emission Limits

The first step was to compare the data available to the emission limit for the dioxin/furan
TEQ beyond

- the

- floor opt ion. Table 52 shows the percentage of sanitaryware tunnel kilns meeting the emission limit for the dioxin/furan TEQ beyond

- the

- floor option.

Table 5 2 . Percentages of Sanitaryware Tunnel Kiln Stacks w ith Data Less Than or Equal

to Dioxin/Furan TEQ Beyond

- th e

- Floor Option

Size APCD Type N o. of Kiln Stacks

with Data Percentage of Kilns Meeting D/F TEQ ng/dscm @ 7% O 2 

### Limit

Small & Large None 3 25 %

Small & Large WS 1



## Step 2 : Develop Estimate of Number of APCD Needed

For the next step, in addition to looking at the units with data, estimates for the units without data were developed to estimate the number of APCD needed for the sanitaryware tunnel

kilns to meet the dioxin/furan TEQ beyond

- the

- floor option . For those un its with no data available and where data from similar units could not be used to fill in the gaps, the design capacit y from units with data were used with the design capacity from units without data, at the same facility, to ratio the emissions as estimat ed data for the units without data. Those units’ estimated data were then compared to the emission limit for the dioxin/furan TEQ beyond

- the

floor option to see if the data would meet the limits or not. In addition

, the requirements for meeting the propose d PM and Hg limits remained unchanged. After each unit was evaluated to see if it could meet the limits, the percentage of units (with and without data) meeting the

emission limit for the dioxin/furan TEQ beyond

- the

- floor option was calculated. This percen tage was compared to the percentage previously calculated for units with data (Table 52) to make sure they were similar. Two additional adjustments to the meeting limit decisions were made in order to make the percentage meeting limit value similar to that in Table 52. The criteria for APCD to

be installed or not from Table 15 were used to determine the final estimates of APCD counts for

the dioxin/furan TEQ beyond

- the

- floor option, as shown in Table 5 3

.

Step 3: Calculate the Nationwide Costs, Emission Red uctions, and Secondary Impacts

The final step in estimating nationwide costs and impacts for the dioxin/furan TEQ beyond

- the

- floor option was to apply model APCD costs, emission reductions, and secondary impacts to the APCD counts shown in Table 53. Table s 54, 55, and 56 show the summary of
nationwide costs, nationwide emission reductions, and nationwide secondary impacts, respectively, for sanitaryware tunnel kilns for the dioxin/furan TEQ beyond

- the floor option.

## 39 Table 5 3 . Summary of Sanitaryware Tunnel Kiln Stacks and Estimate of APCD to B e Installed for Dioxin/Furan TEQ Beyond

the

- Floor Option

Existing APCD Type Size N o. of

Stacks Estimate of Stacks

Add

ACI

- 1 Add

ACI

- 2 Add

FF Add FF

and

ACI

- 1 Add FF

and

ACI

- 2 Install

FF Install

FF and

ACI

- 1 Install

FF and

ACI

- 2 Retrofit

with

DIFF Retrofit

with

DIFF and

ACI

- 1 Retrofit

with

DIFF and

ACI

- 2 No

action

None Small 6 4 [D / F] 2

WS Small 1 1

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



### Table 5 4 . Summary of Nationwide Costs for Sanitaryware Tunnel Kiln Stacks for Dioxin/Furan TEQ Beyond

- the

- Floor Option

Current

APCD Action APCD

Size Unit Capital

Cost Unit Annual

Cost N o. of

APCD Total Capital

Cost Total Annual

Cost

None Install FF and ACI

- 1 [D / F] Small $744,449 $444,600 4 $2,977,795 $1,778,402

Total Nationwide 4 $2,977,795 $1,778,402

Total for Proposed Standards $0 $0

Incremental Nationwide Cost $2,977,795 $1,778,402

## 40 Table 5 5 . Summary of Nationwide Emission Reductions for Sanitaryware Tunnel Kiln Stacks for Dioxin/Furan TEQ Beyond

the

- Floor Option

Current

APCD Action APCD

Size Emissions Type N o. of

APCD Emission Reductions (tpy)

HF HCl HAP

Metals PM Hg D/F D/F

TEQ SO 2 

### PM 2.5 a

None Install FF and

ACI

- 1 [D / F] Small Unit 0 0 0.00395 0.293 0 8.59E

- 09 0 0.141

Total 4 0 0 0.0158 1.17 0 3.44E

- 08 0 0.562

Total Nationwide 0 0 0.0158 1.17 0 3.44E

- 08 0 0.562

Total for Proposed Standards 0 0 0 0 0 0.00E

- 00 0 0

Incremental Nationwide Emissions 0 0 0.0158 1.17 0 3.44E

- 08 0 0.562

a Estimated as 48 percent of PM reductions.



### Table 5 6 . Summary of Nationwide Secondary Impacts for Sanitaryware Tunnel Kiln Stacks for Dioxin/Furan TEQ Beyond

the

- Floor Option a



### Current

APCD Action APCD

Size Emissions Type N o. of

APCD Energy

I mpacts, MMBtu/yr Solid W aste

I mpacts, tpy Secondary Air Emissions Increase (tpy)

PM PM 2.5 

### CO NO

x 

### SO 2

None Install FF and

ACI

- 1 [D / F] Small Unit 4,198 6.92 0.0310 0.0104 0.0522 0.415 1.21

Total 4 16,791 27.7 0.124 0.0415 0.209 1.66 4.84

Total Nationwide 16,791 27.7 0.124 0.0415 0.209 1.66 4.84

Total for Proposed Standards 0 0 0 0 0 0 0

Incremental Nationwide Emissions 16,791 27.7 0.124 0.0415 0.209 1.66 4.84

a A negative increase in secondary impacts would be equivalent to a reduction in secondary impacts.

## 41 E. Sanitaryware Glaz ing Beyond

- the

- Floor Option

1. P articulate M atter (Surrogate for Non

- Hg HAP Metals)

Step 1: Compare Test Data to Emission Limits

The first step was to compare the data available to the emission limit for the beyond

- the

floor option for PM (surrogate for non

- Hg HAP metals). Table 57 shows the percentage of sanitaryware glaze application stacks meeting the emission limit for the PM beyond

- the

- floor option.

Table 5 7 . Percentages of Sanitaryware Glaze Application Stacks w ith Data Less Than or Equal to PM Beyond

- the

- Floor Option

Unit Type Size APCD Type N o. of Glaze Application Stacks

with Data Percentage of Glaz e Application Stacks Meeting PM lb/ton Limit

Manual Glaze Application All FF ND 33%

WS ND

WC 3

Robot Glaze Application All WC 4 25%

WS ND

Spray Machine Glaze Application All WC 3 33%

ND = no data



## Step 2 : Develop Estimate of Number of APCD Needed

For the next step, in addition to looking at the units with data, estimates for the units without data were developed to estimate the number of APCD needed for the sanitaryware glaze application stacks to meet the emission limit for the PM beyond

- the

- floor option. For those units

with no data available

, the current control device of the unit was examined. For units with a

water curtain (WC), it was assumed that they could not meet the PM beyond

- the

- floor limit. For

units with a WS or FF, it was assumed that they could meet the PM beyond

- the

- floor limit. 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. These percentages were compared to the percentages previously calculated for units with data (Table 57) to make sure they were similar. Two additional adjustments for manual glazing application units

, one additional adjustment for robot glaze application

, and one additional adjustment for spray machine gl aze application were made to the meeting limit decisions in order to make the percentage meeting

limit value similar to that in Table 57

. The criteria for APCD to be installed or not from Table 15

were used to determine the final estimates of APCD counts f or the PM beyond

- the

- floor option,

as shown in Table 58.

## 42 Table 58 . Summary of Sanitaryware Glaze Application Stacks and Estimate of APCD to

B e Installed for PM Beyond

- the

- Floor Option

Unit Type Existing APCD Type Size N o. of

Stacks Estimate of Stacks

Add FF Retrofit

with FF No

action

Manual Glaze Application FF All 2 2

WS All 1 1

WC All 11 8 3

Robot Glaze Application WC All 9 7 2

WS All 1 1

Spray Machine Glaze Application WC All 4 2 2

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



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

The final step in estimating nationwide costs and impacts for the beyond

- the

- floor option for PM was to apply model APCD costs, emission reductions, and secondary impacts to the

APCD counts shown in Table 58. Table s 59 , 60, and 61 show the summary of nationwide costs

, nationwide emission reductions, and nationwide secondary impacts, respectively, for sanitaryware glaze application stacks for the PM beyond

- the floor option

Table 59 . Summary of Nationwide Costs for Sanitaryware Glaz e Application Stacks for

PM Beyond

- the

- Floor Option

Unit Type Current

APCD Action APCD

Size Unit Capital

Cost Unit

Annual

Cost N o. of

APCD Total Capital

Cost Total

Annual

Cost

Manual

Glaze Application WC Retrofit

with FF All $847,658 $273,927 8 $6,781,260 $2,191,413

Robot

Glaze Application WC Retrofit

with FF All $709,950 $316,895 7 $4,969,648 $2,218,268

Spray

Machine

Glaze Application WC Retrofit

with FF All $942,509 $449,833 2 $1,885,018 $899,667

Total Nationwide 17 $ 13

, 635

, 926 $ 5

, 309 ,3 48

Total for Proposed Standards $0 $0

Incremental Nationwide Cost $13,635,926 $5,309,348

## 43 Table 60 . Summary of Nationwide Emission Reductions for Sanitaryware Glaze Application Stacks for PM Beyond

- the

Floor Option

Unit Type Current

APCD Action APCD

Size Emissions Type N o. of

APCD Emission Reductions (tpy)

HF HCl HAP

Metals PM Hg D/F D/F

TEQ SO 2 

### PM 2.5 a

Manua l Glaze

Application WC Retrofit

with FF All Unit 0 0 0.0301 2.24 0 0 0 0 1.07

Total 8 0 0 0.241 17.9 0 0 0 0 8.59

Robot Glaze Application WC Retrofit

with FF All Unit 0 0 0.0138 1.02 0 0 0 0 0.491

Total 7 0 0 0.0965 7.17 0 0 0 0 3.44

Spray Machine Glaze Application WC Retrofit

with FF All Unit 0 0 0.0700 5.20 0 0 0 0 2.50

Total 2 0 0 0.140 10.4 0 0 0 0 4.99

Total Nationwide 0 0 0.4 78 35.5 0 0 0 0 17.0

Total for Proposed Standards 0 0 0 0 0 0 0 0 0

Incremental Nationwide Emissions 0 0 0. 4 78 35.5 0 0 0 0 17.0

a Estimated as 48 percent of PM reductions.



### Table 61 . Summary of Nationwide Secondary Impacts for Sanitaryware Glaze Application Stacks for PM Beyond

- the

- Floor Option for PM a



### Unit Type Current

APCD Action APCD

Size Emissions Type N o. of

APCD Energy

I mpacts, MMBtu/yr Solid

W aste

I mpacts, tpy Secondary Air Emissions Increase (tpy)

PM PM 2.5 

### CO NO

x 

### SO 2

Manu al Glaze

Application WC Retrofit

with FF All Unit 2,474 2.24 0.0182 0.00612 0.0308 0.245 0.713

Total 8 19,791 17.9 0.146 0.0490 0.246 1.96 5.70

Robot Glaze Application WC Retrofit

with FF All Unit 3,109 1.02 0.0229 0.00769 0.0387 0.307 0.896

Total 7 21,762 7.17 0.161 0.0538 0.271 2.15 6.27

Spray Machine Glaze Application WC Retrofit

with FF All Unit 6,998 5.20 0.0516 0.0173 0.0871 0.692 2.02

Total 2 13,997 10.4 0.103 0.0346 0.174 1.38 4.03

Total Nationwide 55,550 35.5 0. 4 10 0. 137 0.6 91 5.49 16.0

Total for Proposed Standards 0 0 0 0 0 0 0

Incremental Nationwide Emissions 55,550 35.5 0.410 0.137 0.691 5.49 16.0

a A negative increase in secondary impacts would be equivalent to a reduction in secondary impacts.

## 44 VI. References

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 International, to Jeff Telande r, EPA/OAQPS/SPPD. November 6, 2014

.

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 Sarsony, EPA/OAQPS/HEID, to

Docket EPA

- HQ

- OAR

- 2013

- 0291 . May 19, 2014.

Raymond, G. and K. Sroka. 2014. Maximum Achievable Control Technology (MACT) Floor Analysis for Clay Ceramic s . Memorandum from Gabrielle Raymond and Kristin Sroka, RTI
International, to Jeff Telander, EPA/OAQPS/SPPD. November 6, 2014

.

Raymond, G. 2014 a

. Test Data Used in BSCP Proposed Rule . Memorandum from Gabrielle Raymond, RTI International, to Jeff Telander, EPA/OAQPS/SPPD

. November 6, 2014

.

Raymond, G. 2014 b

. Test Data Used in Clay Ceramics Proposed Rule

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

. November 6,

2014

.

Raymond, G. 2014 c

. Updated Inventory Database and Documentation for CC Proposed Rule

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

. November 6, 2014

.