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Clay Ceramics Area Source NESHAP May 23, 2007

Clay Ceramics Area Source NESHAP May 23, 2007 CERMA - PITTSBURGH Definitions Under the Clean Air Act, an area source is defined as a stationary source that has the potential to emit less than 10 tons per year of any single HAP, or 25 tons per year of any combination of HAPs.

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Clay Ceramics Area Source NESHAP May 23, 2007

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  1. Clay Ceramics Area Source NESHAPMay 23, 2007 CERMA - PITTSBURGH

  2. Definitions • Under the Clean Air Act, an area source is defined as a stationary source that has the potential to emit less than 10 tons per year of any single HAP, or 25 tons per year of any combination of HAPs. • Includes all 188 HAPs, not just the urban HAPs

  3. Background – Area Source NESHAP • Section 112(k) of the CAA requires EPA to: • develop an urban air toxics strategy • identify at least 30 urban HAPs • list area source categories • ensure 90% of the emissions of each urban HAPs from area sources are subject to standards (by November 15, 2000)

  4. Court Schedule • Court Order - March 31, 2006 • Contained deadlines for area source categories under 112(k) • 4 source categories by December 15, 2006 • 6 source categories by June 15, 2007 • 10 source categories by December 15, 2007 • 10 source categories by June 15, 2008 • 10 source categories by December 15, 2008 • 10 source categories by June 15, 2009

  5. Background – Area Source NESHAP • Individually area sources are small emitters • Many sources emit less than 100 pounds of HAPs • There are numerous facilities • Sources are difficult to locate • Many are small businesses • Most have not been regulated before • Many sources emit fine particulate matter, precursors for ozone, and lead • Collectively, these sources are important toxic contributors in urban areas

  6. Clay Ceramics Area Source Listing • Listed in the November 2002 FR notice as Clay Products. Two source categories will be addressed: • Clay Ceramics • Brick and Structural Clay Products (BSCP) – last bin – may not have rule • Listed for lead, manganese, chromium, and nickel • NEI (1990) showed 16 tpy of HAP metal emissions for Clay Ceramics and BSCP combined (Pb = 12 tpy). • Current baseline estimate = 9 tpy HAP metals from Clay Ceramic manufacturing operations. (Cr = 35%, Pb = 50%, Ni = 10%, and Mn/Cd = 5%) • Pb emissions from Clay Ceramics operations (~4.5 tpy) very small compared to total area source Pb emissions nationwide (450 tpy). • Leaded glazes used by 2 area sources.

  7. Industry Sectors sanitaryware tile dinnerware pottery

  8. Issues Addressed During Standard Development – Clay Ceramics . • Processes to be regulated/controlled • Applicability threshold • Urban HAP (metals) vs. All HAP (metals, HF, HCl) • Level of control and associated Monitoring, Reporting & Recordkeeping (MR&R)

  9. Work Performed – Clay Ceramics • Developed emission factors • Estimated nationwide baseline emissions • Developed GACT and MR&R options • Estimated costs of the options • Identified small businesses (most use< 250 tpy wet glaze) • Prepared draft proposal (preamble and rule)

  10. Sanitaryware e.g., toilets, sinks 10 area source plants 1 plant is small business Tile e.g., floor, wall 15 area source plants 12 plants - small businesses Dinnerware/Pottery - Mechanized, mass produced Commercial, mostly dinnerware 28 area source plants 22 plants - small businesses Dinnerware/Pottery - Individual Artisan Potteries Mostly hand-made ware of various types Individual potters, community centers, educational institutions (< 50 tpy clay) Non-profit and commercial ~ 10,000 facilities Not included in source category Clay Ceramics Industry Sectors

  11. Clay Ceramics – Area Sources (53 plants) • American Standard, Inc. Chandler AZ • Catalina China, Inc. Tucson AZ • Westminster Ceramics Inc. Bakersfield CA • Jeffrey Court, Inc. Corona CA • Homexx International Corona CA • Westile, Inc Corona CA • Burden China Co., Inc. El Monte CA • B & W Tile Co. Gardena CA • Clay Design, Inc. Long Beach CA • Justice Design Group Los Angeles CA • Hans Sumpf Co., Inc. Madera CA • Handcraft Tile, Inc. Milpitas CA • B & W Tile Co. Riverside CA • Toto Industries Inc. Atlanta GA • Toto Industries Morrow GA • Pickard, Inc. Antioch IL • Haeger Industries, Inc.. E. Dundee IL • Kokomo Sanitary Pottery Co. Kokomo IN • Ceramics Designs Inc. Cunningham KY •  Florida Tile Inc. Lawrenceburg KY • Louisville Stoneware Co. Louisville KY • Monroe Salt Works Inc . Monroe ME •  F.W. Ritter Sons Co.. S. Rockwood MI • Red Wing Stoneware Co. Red Wing MN • Crane Plumbing Nevada MO • Gail Pittman China Ridgeland MS • Salty Dog Pottery Barnstead NH

  12. Clay Ceramics – Area Sources (cont) • Lenape Products, Inc. Trenton NJ • Mackenzie-Childs Ltd. Aurora NY • Niagara Ceramics Corp. Buffalo NY • Syracuse China Co. Syracuse NY • Lenox, Inc. Kinston NC • Ironrock Capital Inc. Canton OH • East Palestine China E. Palestine OH •  Hall China Co.. E. Liverpool OH • Summitville Tiles, Inc. Minerva OH • Workshops of Gerald E. Henn Pottery, Inc. New Waterford OH • American Standard Tiffin OH • Hartstone Pottery Zanesville OH • Frankoma Pottery Sapulpa OK • Eljer Inc Ford City, PA • Crossville Ceramics Co .Crossville TN • Crossville Ceramics Co. Dickson TN • Lone Star Ceramics Mfg. Co. DallasT X • Interceramic Garland TX • Gilmer Potteries, Inc. Gilmer TX •   Crane Plumbing LLC Hearne TX • Crane Plumbing LLC Hondo TX • Bennington Potters, Inc. Bennington VT • Emerson Creek Pottery, Inc. Bedford VA • Williamsburg Pottery Factory, Inc. Williamsburg VA • Quarry Tile Co. Spokane WA • Homer Laughlin China Co. Newell WV

  13. Clay Ceramics Emission Sources - Glazing • Various methods of applying glaze to clay ware. • Spray, dip-coated, hand-applied, other • Only spray glaze operations that atomize are expected to have air emissions – primarily from overspray. • Account for ~90% of HAP metal emissions • Lead added as a fluxing agent in only dinnerware/ pottery sector. • Leaded glazes voluntarily phased out over past 10 years except for 2 large dinnerware plants (Niagara Ceramics, Syracuse China). • Other metals (Cr, Ni, Cd, Mn, As, Be) added in much smaller quantities as colorants or color enhancers. • Add-on controls for glaze spray booths – BH, WS, water curtain

  14. Clay Ceramics Emission Sources – Kilns Firing Glazed Ware • More than 95% of all clay ceramic products are coated with a glaze and then fired in a kiln • Urban HAP emissions – primarily volatilized metals from the glaze • Account for ~10% HAP metal emissions. • No existing add-on controls for area sources

  15. Proposed Area Source NESHAP • Applicability – clay ceramics manufacturing facilities that are area sources with atomized glaze spray booths or kilns that fire glaze ceramic ware. • Not included – artisan potters, art studios, schools, universities – use less than 50 TPY of wet clay • Compliance Date - Final Rule (~12/07) • Affected sources • Atomized glaze spray booths • Kilns that fire glazed ceramic ware

  16. > 250 TPY of wet glaze at facility ** Air pollution control device or Wet glazes <0.1% urban HAP metals ** - Does not include glazes <0.1 urban HAP metals ≤ 250 TPY of wet glaze at facility ** Waste minimization or Air pollution control device or Wet glazes <0.1% urban HAP metals ** - Does not include glazes <0.1 urban HAP metals Standards- Glaze Spray Booths

  17. Standards - Kilns Peak temperature < 2,700 F and • Use natural gas or • Equivalent clean burning fuel or • Electric powered kiln

  18. Monitoring Requirements • Kiln • Daily check of firing temperature Glaze spray booths with air pollution controls Existing weekly visual inspection or alternate monitoring under 63.8 (f) New/Reconstructed daily check of operating parameter or daily 30-minute Method 22 or alternate monitoring under 63.8 (f)

  19. Clay Ceramics Mfg. Major Source Rule • Promulgated May 16, 2003 • Compliance date  May 16, 2006 • 8 major sources (because of co-located emissions) • Existing, new and reconstructed kilns  Use natural gas or equivalent as kiln fuel • New or reconstructed tunnel kilns: • Emission limits for tunnel kilns firing <10 tons per hour: - HF < 0.057 lb/ton of fired product (90% reduction) - HCl < 0.26 lb/ton or fired product (30% reduction) - PM < 0.42 lb/ton of fired product • Emission limits for tunnel kilns firing ≥ 10 tons per hour: - HF < 0.057 lb/ton of fired product (90% reduction) - HCl < 0.056 lb/ton or fired product (85% reduction) - PM < 0.12 lb/ton of fired product • Operating limits based on type of control equipment • Vacated in Court Decision – 3/13/07

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