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. 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, the EPA is proposing new standards for clay ceramics manufacturing, including

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 floor 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 thresholds2), 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/furans. The 

development of these standards and options are documented in two memoranda, 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 Achievable Control 

Technology (MACT) Floor Analysis for Clay Ceramics (Raymond and Sroka, 2014).

The purpose of this memorandum is to present the methodology for estimating the costs,

emission reductions, and secondary impacts3 associated with the proposed standards and beyondthe-floor options for the clay ceramics 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 Estimate 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 clay 

ceramics industry. Section III describes the assessment of what 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 and 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/furans and presents the nationwide costs, emission reductions, 

and secondary impacts associated with those APCD.

II. Baseline Emissions

The clay ceramics 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 sources. The 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 particles less than 2.5 micrometers in 

diameter (PM2.5), sulfur dioxide (SO2), Hg, and dioxin/furan TEQ. Uncontrolled emission 

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

• Energy impacts: The annual amount of energy (in million British thermal units per year [MMBtu/yr]) 

needed to generate the electricity to operate the control devices used to comply with the proposed standards 

and beyond-the-floor options.

• Secondary emissions: The criteria air pollutant emissions—PM, PM2.5, carbon monoxide (CO), nitrogen 

oxides (NOx), and SO2—(in tpy) that result from the generation of electricity used to operate the control 

devices.

• Solid waste: The material (in tpy) captured 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, 2014a)). The control efficiencies 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 controls 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 PMa SO2

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 PM2.5 are estimated to be the same as the efficiency for PM.

The inventory of ceramic tile roller kilns and facilities, including the APCD for each 

stack, is presented in the memorandum Updated CC Inventory Database and Documentation

(Raymond, 2014c). 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 Each APCD for Ceramic Tile Roller Kilns

APCD 

Type Size

Emissions per APCD (tpy)

HF HCl

Non-Hg 

HAP Metals PM PM2.5

a SO2 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 summarizes 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 PM2.5 SO2 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 Subtotal 208 58 1.2 45 9.87 747 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 286.89 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 values 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 spray 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, PM2.5, 

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 PM2.5 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 Emissions Estimates for Ceramic Tile Glazing

APCD Type Size Count

Nationwide Emissions (tpy)

Non-Hg HAP Metals PM PM2.5 Hg

FF All 9 0.155 5.35 2.57 0.000495

WS All 3 0.245 8.45 4.06 0.000043

Ceramic Tile 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, nonHg HAP metals, PM, PM2.5, Hg, and dioxin/furan TEQ. Test data were available for all of these 

pollutants for each kiln, so model emissions were not developed. The average lb/ton emissions

for each pollutant and kiln were multiplied by the kiln design capacity (tons per hour [tph]), then 
6

multiplied by 8,760 operating hours, then divided by 2,000 lb/ton to estimate the baseline 

emissions. The nationwide baseline emissions for PM2.5 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 Tunnel Kilns

APCD

Type Size Count

Nationwide Emissions (tpy)

HF HCl

Non-Hg 

HAP 

Metals PM PM2.5 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 

PM2.5 for each APCD type (FF, WS, and water curtains [WC]). Test data were not available for 

all of the operating spray booths, so data from similar units (e.g., similar location, APCD, glaze 

spray rate) were 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 divided by 2,000 lb/ton to estimate baseline emissions. The nationwide 

baseline emissions for PM2.5 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. Nationwide Baseline Emissions Estimates for Sanitaryware Glazing Operations

Unit Type

APCD

Type Size Count

Nationwide Emissions (tpy)

PM PM2.5

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

Robot glaze application total 10.46 5.02

Spray machine glaze application WC All 4 16.22 7.79

See Table 10 for the nationwide baseline emissions estimates for all clay ceramics unit 

types being regulated under the clay ceramics proposed rule.
7

Table 10. Total Nationwide Baseline Emissions Estimates for Clay Ceramics 

Unit Type

Emissions (tpy)

HF HCl

Non-Hg 

HAP 

Metals PM PM2.5 SO2 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 0.0891 2.58E-06

III. 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 clay ceramics proposed rule. The development of the facility-level health-based 

emission limit, 600 tpy of HCl-equivalent, or140 lb/hr of HCl-equivalent, is documented in the 

memorandum Risk Assessment to Determine a Health-Based Emission Limitation for Acid Gases 

for the Clay Ceramics Manufacturing Source Category (Morris et al., 2014).

The equivalency of HCl with HF is based on the chronic Reference Concentration (RfC) 

values for each of the acid gases. The RfC for HCl is 20 micrograms per cubic meter (μg/m3) and

the RfC for HF is 14 μg/m3 (Morris et al., 2014). Therefore, the following equation can be used 

to calculate the HCl-equivalent emissions for an individual kiln:





 



















 = +

HF

HCl

i HCl HF RfC

RfC E E E

where:

Ei = HCl-equivalent emissions, lb/hr

EHCl = emissions of HCl, lb/hr

EHF = emissions of HF, lb/hr

RfCHCl = reference concentration for HCl, 20 μg/m3
8

RfCHF = reference concentration for HF, 14 μg/m3

Test data are available for some of the kilns in the clay ceramics industry (see the 

memorandum Test Data Used in Clay Ceramics Proposed Rule (Raymond, 2014b)). 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 HClequivalent value for each kiln. The HCl-equivalent values were summed for all kilns at a major 

source facility and then compared to the health-based emission limit.

As shown in Table 11, all major source clay ceramics facilities could meet the healthbased 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

IV. Cost and Emission Reduction Estimates for Meeting Hg, Non-Hg HAP Metals, and 

Dioxin/Furan TEQ Proposed Standards

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

clay ceramics industry. There are five ceramic tile facilities that were major sources at the time 

of the 2008 and 2010 section 114 EPA surveys of the clay ceramics industry, but these facilities 

were recently re-classified as synthetic area sources due to the installation of new APCD.

4 These

five ceramic tile facilities would not be subject to the proposed rule, but the impacts of requiring 

them to meet the limits were 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 

shown in Table 12. 

 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 obtains 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 12. Summary of Units at Major and Recent Synthetic Area Sources

Source Type No. of Units No. 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 clay ceramics 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 area 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 manual glaze booths, 

75 percent of the sanitaryware spray machine booths, and 40 percent of the sanitaryware robot 

glaze booths. Data on Hg and non-Hg HAP metals emissions were available for about 

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 for 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, 2014b). Therefore, 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 14 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 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). For all of the other 

clay ceramic unit types, 100 percent of units were estimated to meet the proposed MACT floor 

limits.

Table 14. Estimated Percentages of Floor Tile Roller Kilns with Data Less Than or Equal 

to Proposed Emission Limits

Unit Type Size

APCD 

Type

No. of Kiln

Stacks 

with Data

% of Kilns

Meeting 

PM lb/ton 

Limit

No. of Kiln

Stacks 

with Data

% of Kilns

Meeting 

Hg lb/ton 

Limit

No. 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, 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 roller 

kilns to meet the proposed standards. 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 proposed limits 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 current control device of the unit was examined. For units with no 

control device, it was assumed that they could not meet the PM, Hg, and dioxin/furan TEQ 

limits. For units with WS, DIFF, or DLS/FF, it was assumed that they could meet the PM, Hg, 

and dioxin/furan TEQ limits. After each unit was evaluated to see if it could meet the limits, the 

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

dioxin/furan TEQ. These percentages were compared to the percentages previously calculated 

for units with data (Table 14) to make sure they were similar. For Hg two adjustments 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 limits 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 15. 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 16. Note that Table 16 only 

shows the APCD actions 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). 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. 

Tables 17, 18, and 19 show the summary of nationwide costs, emission reductions, and

secondary impacts, respectively, for clay ceramics sources. Note that these three 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 16. Summary of Stacks and Estimate of APCD to Be Installed

Unit Type

Existing 

APCD 

Type Size

No. of 

Stacks

Estimate of Stacks

Add 

ACI1

Add 

ACI2

Add 

FF

Add 

FF 

and 

ACI1

Add 

FF 

and 

ACI2

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

No. 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

No. of 

APCD

Emission Reductions (tpy)

HF HCl

HAP 

Metals PM Hg D/F D/F TEQ SO2 PM2.5a

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 Standardsa

Unit 

Type

Current 

APCD Action

APCD 

Size

Emissions 

Type

No. of 

APCD

Energy 

Impacts, 

MMBtu/yr

Solid Waste 

Impacts, 

tpy

Secondary Air Emissions Increase (tpy)

PM PM2.5 CO NOx SO2

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, Non-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 clay ceramics sources are 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 option. 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 option. 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 kilns;

• Hg from ceramic tile glazing operations;

• Dioxin/furan TEQ from wall tile spray dryers; and

• Dioxin/furan TEQ from floor tile press dryers.

A. Floor Tile Roller Kilns Beyond-the-Floor Option

1. Particulate Matter (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-thefloor 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 with Data Less Than or Equal to PM 

Beyond-the-Floor Option

Size APCD Type

No. 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, 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 20) 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 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-thefloor option, as shown in Table 21.

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 

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

APCD counts shown in Table 21. Tables 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 21. Summary of Floor Tile Roller Kiln Stacks and Estimate of APCD to Be Installed for PM Beyond-the-Floor Option

Existing 

APCD Type Size

No. 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 22. 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

No. 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 23. Summary of Nationwide Emission Reductions for Floor Tile Roller Kiln Stacks for PM Beyond-the-Floor Option

Current 

APCD Action

APCD 

Size

Emissions 

Type

No. of 

APCD

Emission Reductions (tpy)

HF HCl

HAP 

Metals PM Hg D/F D/F TEQ SO2 PM2.5

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 24. Summary of Nationwide Secondary Impacts for Floor Tile Roller Kiln Stacks for PM Beyond-the-Floor Optiona

Current 

APCD Action

APCD 

Size

Emissions 

Type

No. of 

APCD

Energy 

Impacts, 

MMBtu/yr

Solid Waste 

Impacts, 

tpy

Secondary Air Emissions Increase (tpy)

PM PM2.5 CO NOx SO2

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

limit for the Hg beyond-the-floor option.

Table 25. Percentages of Floor Tile Roller Kiln Stacks with Data Less Than or Equal to Hg 

Beyond-the-Floor Option

Size APCD Type

No. 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 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 

Hg beyond-the-floor option was calculated. This percentage was compared to the percentage 

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 in 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 impacts to the 

APCD counts shown in Table 26. Tables 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 26. Summary of Floor Tile Roller Kiln Stacks and Estimate of APCD to Be Installed for Hg Beyond-the-Floor Option

Existing 

APCD Type Size

No. 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 27. 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

No. 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

No. of 

APCD

Emission Reductions (tpy)

HF HCl

HAP 

Metals PM Hg D/F D/F TEQ SO2 PM2.5

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

No. of 

APCD

Energy 

Impacts, 

MMBtu/yr

Solid Waste 

Impacts, 

tpy

Secondary Air Emissions Increase (tpy)

PM PM2.5 CO NOx SO2

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 ACI1 [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.

Table 30. Percentages of Floor Tile Roller Kiln Stacks with Data Less Than or Equal to 

Dioxin/Furan TEQ Beyond-the-Floor Option

Size APCD Type

No. of Kiln Stacks 

with Data

Percentage of Kilns Meeting D/F 

TEQ ng/dscm @ 7% O2 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 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 31.

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 31. Tables 32, 33, and 34 show the summary 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 31. Summary of Floor Tile Roller Kiln Stacks and Estimate of APCD to Be Installed for Dioxin/Furan TEQ Beyond-theFloor Option

Existing 

APCD 

Type Size

No. 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 32. 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

No. 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 33. Summary of Nationwide Emission Reductions for Floor Tile Roller Kiln Stacks for Dioxin/Furan TEQ Beyond-theFloor Option

Current 

APCD Action

APCD 

Size

Emissions 

Type

No. of 

APCD

Emission Reductions (tpy)

HF HCl

HAP 

Metals PM Hg D/F D/F TEQ SO2 PM2.5

a

None Install FF and ACI1 [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 ACI2 [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 34. Summary of Nationwide Secondary Impacts for Floor Tile Roller Kiln Stacks for Dioxin/Furan TEQ Beyond-theFloor Option a

Current 

APCD Action

APCD 

Size

Emissions 

Type

No. of 

APCD

Energy 

Impacts, 

MMBtu/yr

Solid 

Waste 

Impacts, 

tpy

Secondary Air Emissions Increase (tpy)

PM PM2.5 CO NOx SO2

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 ACI1 [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 35. Percentages of Floor Tile Spray Dryer Stacks with Data Less Than or Equal to 

Dioxin/Furan TEQ Beyond-the-Floor Option

Size APCD Type

No. of Spray Dryer

Stacks with Data

Percentage of Spray Dryers Meeting

D/F TEQ ng/dscm @ 7% O2 Limit

Large WS 2 60%

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 see 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 dioxin/furan TEQ 

beyond-the-floor option, as shown in Table 36. 

Table 36. Summary of Floor Tile Spray Dryer Stacks and Estimate of APCD to Be Installed 

for Dioxin/Furan TEQ Beyond-the-Floor Option

Existing APCD Type Size No. 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. Tables 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 No. 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 Beyondthe-Floor Option

Current 

APCD Action

APCD 

Size

Emissions 

Type

No. of 

APCD

Emission Reductions (tpy)

HF HCl

HAP 

Metals PM Hg D/F D/F TEQ SO2 PM2.5

a

WS Add ACI1 [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-theFloor Option a

Current 

APCD Action

APCD 

Size

Emissions 

Type

No. of 

APCD

Energy 

Impacts, 

MMBtu/yr

Solid 

Waste 

Impacts, 

tpy

Secondary Air Emissions Increase (tpy)

PM PM2.5 CO NOx SO2

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. Particulate Matter (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-thefloor 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-floor option.

Table 40. Percentages of Ceramic Tile Glazing Stacks with Data Less Than or Equal to 

PM Beyond-the-Floor Option

Size APCD Type

No. 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 calculated 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-thefloor option, as shown in Table 41. 

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 

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

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

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

glazing stacks for the PM beyond-the floor option.
31

Table 41. Summary of Ceramic Tile Glazing Stacks and Estimate of APCD to Be Installed for PM Beyond-the-Floor Option

Existing APCD Type Size No. 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 42. 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

No. 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 43. Summary of Nationwide Emission Reductions for Ceramic Tile Glazing Stacks for PM Beyond-the-Floor Option

Current 

APCD Action

APCD 

Size

Emissions 

Type

No. of 

APCD

Emission Reductions (tpy)

HF HCl

HAP 

Metals PM Hg D/F D/F TEQ SO2 PM2.5

a

WS Add 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 44. Summary of Nationwide Secondary Impacts for Ceramic Tile Glazing Stacks for PM Beyond-the-Floor Optiona

Current 

APCD Action

APCD 

Size

Emissions 

Type

No. of 

APCD

Energy 

Impacts, 

MMBtu/yr

Solid Waste 

Impacts, 

tpy

Secondary Air Emissions Increase (tpy)

PM PM2.5 CO NOx SO2

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. Particulate Matter (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-thefloor option for PM (surrogate for non-Hg HAP metals). Table 45 shows the percentage of 

sanitaryware tunnel kilns meeting the emission limit for the PM beyond-the-floor option.

Table 45. Percentages of Sanitaryware Tunnel Kiln Stacks with Data Less Than or Equal 

to PM Beyond-the-Floor Option

Size APCD Type

No. of Kiln Stacks 

with Data

Percentage of Kilns Meeting PM 

lb/ton Limit

Small & Large None 4 20%

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 capacity from units 

with data were used with the design capacity from units 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 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 beyondthe-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 estimates 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 

option 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, for 

sanitaryware tunnel kilns for the PM beyond-the floor option.
34

Table 46. Summary of Sanitaryware Tunnel Kiln Stacks and Estimate of APCD to Be Installed for PM Beyond-the-Floor 

Option

Existing 

APCD Type Size

No. 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 47. 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

No. 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

No. of 

APCD

Emission Reductions (tpy)

HF HCl

HAP 

Metals PM Hg D/F

D/F 

TEQ SO2 PM2.5

a

None Install

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 Optiona

Current 

APCD Action

APCD 

Size

Emissions 

Type

No. of 

APCD

Energy 

Impacts, 

MMBtu/yr

Solid Waste 

Impacts, tpy

Secondary Air Emissions Increase (tpy)

PM PM2.5 CO NOx SO2

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

emission limit for the Hg beyond-the-floor option.

Table 50. Percentages of Sanitaryware Tunnel Kiln Stacks with Data Less Than or Equal 

to Hg Beyond-the-Floor Option

Size APCD Type

No. 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-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 Hg 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 capacity from units 

with data were used with the design capacity from units 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 or 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 for the Hg beyondthe-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 determine 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 kilns 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 beyond-the floor option.
37

Table 51. Summary of Sanitaryware Tunnel Kiln Stacks and Estimate of APCD to Be Installed for Hg Beyond-the-Floor 

Option

Existing 

APCD Type Size

No. 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 option. Table 52 shows the percentage of sanitaryware tunnel kilns 

meeting the emission limit for the dioxin/furan TEQ beyond-the-floor option.

Table 52. Percentages of Sanitaryware Tunnel Kiln Stacks with Data Less Than or Equal 

to Dioxin/Furan TEQ Beyond-the-Floor Option

Size APCD Type

No. of Kiln Stacks 

with Data

Percentage of Kilns Meeting D/F 

TEQ ng/dscm @ 7% O2 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 units with no data 

available and where data from similar units could not be used to fill in the gaps, the design 

capacity from units with data were used with the design capacity from units 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 dioxin/furan TEQ beyond-thefloor option to see if the data would meet the limits or not. 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 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 53.

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 53. Tables 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 53. Summary of Sanitaryware Tunnel Kiln Stacks and Estimate of APCD to Be Installed for Dioxin/Furan TEQ Beyondthe-Floor Option

Existing 

APCD Type Size

No. 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 54. 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

No. 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 55. Summary of Nationwide Emission Reductions for Sanitaryware Tunnel Kiln Stacks for Dioxin/Furan TEQ Beyondthe-Floor Option

Current 

APCD Action

APCD 

Size

Emissions 

Type

No. of 

APCD

Emission Reductions (tpy)

HF HCl

HAP 

Metals PM Hg D/F

D/F 

TEQ SO2 PM2.5

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 56. Summary of Nationwide Secondary Impacts for Sanitaryware Tunnel Kiln Stacks for Dioxin/Furan TEQ Beyondthe-Floor Option a

Current 

APCD Action APCD Size

Emissions 

Type

No. of 

APCD

Energy 

Impacts, 

MMBtu/yr

Solid Waste 

Impacts, 

tpy

Secondary Air Emissions Increase (tpy)

PM PM2.5 CO NOx SO2

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 Glazing Beyond-the-Floor Option

1. Particulate Matter (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-thefloor 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 57. Percentages of Sanitaryware Glaze Application Stacks with Data Less Than or 

Equal to PM Beyond-the-Floor Option

Unit Type Size

APCD 

Type

No. of Glaze 

Application Stacks 

with Data

Percentage of Glaze

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 glaze 

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 for 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 

Be Installed for PM Beyond-the-Floor Option

Unit Type Existing APCD Type Size

No. 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. Tables 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 Glaze Application Stacks for 

PM Beyond-the-Floor Option

Unit Type

Current 

APCD Action

APCD 

Size

Unit 

Capital 

Cost

Unit 

Annual 

Cost

No. 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 $5,309,348

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-theFloor Option

Unit Type

Current 

APCD Action

APCD 

Size

Emissions 

Type

No. of 

APCD

Emission Reductions (tpy)

HF HCl

HAP 

Metals PM Hg D/F

D/F 

TEQ SO2 PM2.5

a

Manual 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 0.478 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 0.478 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 PMa

Unit Type

Current 

APCD Action

APCD 

Size

Emissions 

Type

No. of 

APCD

Energy 

Impacts, 

MMBtu/yr

Solid 

Waste 

Impacts, 

tpy

Secondary Air Emissions Increase (tpy)

PM PM2.5 CO NOx SO2

Manual 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 0.410 0.137 0.691 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 Telander, 

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 Ceramics. Memorandum from Gabrielle Raymond and Kristin Sroka, RTI 

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

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

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

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.

Raymond, G. 2014c. Updated Inventory Database and Documentation for CC Proposed Rule. 

Memorandum from Gabrielle Raymond, RTI International, to Jeff Telander, 

EPA/OAQPS/SPPD. November 6, 2014.