clay ceramics area source neshap may 23 2007
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Clay Ceramics Area Source NESHAP May 23, 2007

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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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definitions
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
background area source neshap
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)
court schedule
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
background area source neshap5
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
clay ceramics area source listing
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.
industry sectors
Industry Sectors

sanitaryware

tile

dinnerware

pottery

issues addressed during standard development clay ceramics
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)
work performed clay ceramics
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)
clay ceramics industry sectors
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
clay ceramics area sources 53 plants
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
clay ceramics area sources cont
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
clay ceramics emission sources glazing
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
clay ceramics emission sources kilns firing glazed ware
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
proposed area source neshap
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
standards glaze spray booths
> 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
standards kilns
Standards - Kilns

Peak temperature < 2,700 F and

  • Use natural gas or
  • Equivalent clean burning fuel or
  • Electric powered kiln
monitoring requirements
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)

clay ceramics mfg major source rule
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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