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epa and clean air (long but informative)

updated thu 31 jul 97

 

Gil Stengel on tue 15 jul 97

I've been following the threads here on Clayart about burning trees,
pollution and the Tozan kiln. I found the Tozan kiln problem to be
especially interesting since I just completed construction of a two
chamber wood/salt here at Western Illinois University and would like to be
able to fire it without running afoul of the law. I have an EPA operating
permit for our kiln and I was very surprised to find that I needed one to
begin with but I'm ahead of the game....

I just got off the phone with an official of the Illinois EPA. We had a
long chat about the Clean Air Act and operating permits for kilns etc.
I'll give you the details shortly but the nutshell is this: The EPA does
not care about your kiln. Now in all of life there are exceptions and the
exception here is if your kiln is in a "noncompliance zone" where the
overall pollution levels are deemed to high. In that case, you need to
obtain an operating permit which is yours for the asking. An example of a
noncompliance area would be the city of Chicago.

The federal Clean Air Act is a law enacted by Congress that attempts to
regulate the emissions of six pollution groups or types. These pollutants
are:
Particulate matter below the 10 micron threshold (PM 10)
Volatile or Organic Material (VOM)
NOx
SO2
CO
Local Health Hazards such as strong odors from various livestock farms

The federally mandated threshold beyond which you are deemed a "major
pollution source" and thus regulated is 100 tons annually in each
catagory. I don't know how you measure a ton of odor BTW. Each state is
required to submit a plan to bring their geographic area into compliance
with further mandated concentrations of pollutants. I don't have those
numbers but they are not all that relevant to the overall picture I'm
trying to depict here.

Every state has a plan and they all differ. For instance, if you have a
kiln in Chicago and you emit more than 25 tons of PM 10, you need an
operating permit and you will probably be required to change your firing
cycle and frequency to fall below 25 tons. If I understand things
correctly, you will not be shut down. This is an example of an area that
is far out of compliance and very heavily regulated. For the majority of
Illinois, the 100 ton limit applies. You have to have a pretty big kiln,
firing very often in intense and unnecessary reduction to emit even a
couple of tons of carbon monoxide annually so don't everybody go worrying.

Under the Federal Limits, there are very few potters who are even close to
needing an operating permit. My contact in the Illinois EPA was of the
opinion that pottery kilns were exempted federally but he wasn't sure. At
the fed level, the new restrictions suggested by our president were to
lower the limits on PM10 and VOM. Not likely to affect any potters, if
the lower limits become law.

At the state level, depending on where you live, you may or may not need
an operating permit. Again, my contact in the Illinois EPA was of the
opinion that the typical pottery kiln anywhere in Illinois is quite safe,
wood fired, gas fired, even coal fired. The exception might be the
Chicago metro area but even there you are probably fine for the forseeable
future though you may be required to obtain an operating permit. There
are areas of the US that are tighter than Chicago so don't assume reading
this that you don't need an operating permit. As for my permit, I needed
it because the campus on which my kiln resides is deemed a "major
polluter" by the EPA. The local physical plant guys were worried that my
emissions combined with the heating plant emissions on campus would put
them out of compliance. This has been shown to not be the case and an
operating permit was granted just recently.

Note for the sake of alot of argument on Clayart that the Clean Air Act
does not regulate, nor attempt to regulate, CO2.

If you have a wood kiln out in the country, as I did once, then good for
you. The EPA, federal or local, probably doesn't care. This is not to
say that you are not polluting, but then we all do that. Given the
limits of pollutants allowed under even strictly regulated areas, most
kilns are well within compliance and will be for some time to come.
Operating permits might become more common and possibly some wood kilns
may have to burn off more particulates but even this scenario is not
likely. Still, to be on the safe side, check with your local state EPA
office. They administer the local state compliance plan and can tell you,
even anonymously, if you need to apply for an operating permit.

I do think that to be prudent the ceramic art world as a whole needs to
begin discussion of ways to reduce PM 10 emissions from wood kilns. I see
this as the only area where pottery kilns could run out of compliance with
local CAA guidelines. I could be wrong on this point but I don't see the
levels of CO, NOx and SO2 as being any problem for just about anyone
firing fuel. Overall, the current levels of pollutants allowed under the
law are no problem but PM 10 is likely going to become much more tightly
regulated - no matter what anyone thinks of the validity of those
regulations.



Gil Stengel
email: gstengel@macomb.com
WWW: http://homepage.macomb.com/~gstengel

kinoko@junction.net on wed 16 jul 97

Gil, Thank you for the post re; Kiln emissions,....If the intent has been to
raise consciousness it seems to have certainly succeeded. It is unfortunate
as well as dangerous,that after the first few years of flurry,the attempt to
decrease poluttion has coma almost to a standstill. What happened to all of
the super-market concern which placed "Green" products upon the shelves? It
is only by continuing to prick the public tht one may make a pollution-free
atmosphere b reduced to tolerble limits.
DonM.>----------------------------Original message----------------------------
>I've been following the threads here on Clayart about burning trees,
>pollution and the Tozan kiln. I found the Tozan kiln problem to be
>especially interesting since I just completed construction of a two
>chamber wood/salt here at Western Illinois University and would like to be
>able to fire it without running afoul of the law. I have an EPA operating
>permit for our kiln and I was very surprised to find that I needed one to
>begin with but I'm ahead of the game....
>
>I just got off the phone with an official of the Illinois EPA. We had a
>long chat about the Clean Air Act and operating permits for kilns etc.
>I'll give you the details shortly but the nutshell is this: The EPA does
>not care about your kiln. Now in all of life there are exceptions and the
>exception here is if your kiln is in a "noncompliance zone" where the
>overall pollution levels are deemed to high. In that case, you need to
>obtain an operating permit which is yours for the asking. An example of a
>noncompliance area would be the city of Chicago.
>
>The federal Clean Air Act is a law enacted by Congress that attempts to
>regulate the emissions of six pollution groups or types. These pollutants
>are:
>Particulate matter below the 10 micron threshold (PM 10)
>Volatile or Organic Material (VOM)
>NOx
>SO2
>CO
>Local Health Hazards such as strong odors from various livestock farms
>
>The federally mandated threshold beyond which you are deemed a "major
>pollution source" and thus regulated is 100 tons annually in each
>catagory. I don't know how you measure a ton of odor BTW. Each state is
>required to submit a plan to bring their geographic area into compliance
>with further mandated concentrations of pollutants. I don't have those
>numbers but they are not all that relevant to the overall picture I'm
>trying to depict here.
>
>Every state has a plan and they all differ. For instance, if you have a
>kiln in Chicago and you emit more than 25 tons of PM 10, you need an
>operating permit and you will probably be required to change your firing
>cycle and frequency to fall below 25 tons. If I understand things
>correctly, you will not be shut down. This is an example of an area that
>is far out of compliance and very heavily regulated. For the majority of
>Illinois, the 100 ton limit applies. You have to have a pretty big kiln,
>firing very often in intense and unnecessary reduction to emit even a
>couple of tons of carbon monoxide annually so don't everybody go worrying.
>
>Under the Federal Limits, there are very few potters who are even close to
>needing an operating permit. My contact in the Illinois EPA was of the
>opinion that pottery kilns were exempted federally but he wasn't sure. At
>the fed level, the new restrictions suggested by our president were to
>lower the limits on PM10 and VOM. Not likely to affect any potters, if
>the lower limits become law.
>
>At the state level, depending on where you live, you may or may not need
>an operating permit. Again, my contact in the Illinois EPA was of the
>opinion that the typical pottery kiln anywhere in Illinois is quite safe,
>wood fired, gas fired, even coal fired. The exception might be the
>Chicago metro area but even there you are probably fine for the forseeable
>future though you may be required to obtain an operating permit. There
>are areas of the US that are tighter than Chicago so don't assume reading
>this that you don't need an operating permit. As for my permit, I needed
>it because the campus on which my kiln resides is deemed a "major
>polluter" by the EPA. The local physical plant guys were worried that my
>emissions combined with the heating plant emissions on campus would put
>them out of compliance. This has been shown to not be the case and an
>operating permit was granted just recently.
>
>Note for the sake of alot of argument on Clayart that the Clean Air Act
>does not regulate, nor attempt to regulate, CO2.
>
>If you have a wood kiln out in the country, as I did once, then good for
>you. The EPA, federal or local, probably doesn't care. This is not to
>say that you are not polluting, but then we all do that. Given the
>limits of pollutants allowed under even strictly regulated areas, most
>kilns are well within compliance and will be for some time to come.
>Operating permits might become more common and possibly some wood kilns
>may have to burn off more particulates but even this scenario is not
>likely. Still, to be on the safe side, check with your local state EPA
>office. They administer the local state compliance plan and can tell you,
>even anonymously, if you need to apply for an operating permit.
>
>I do think that to be prudent the ceramic art world as a whole needs to
>begin discussion of ways to reduce PM 10 emissions from wood kilns. I see
>this as the only area where pottery kilns could run out of compliance with
>local CAA guidelines. I could be wrong on this point but I don't see the
>levels of CO, NOx and SO2 as being any problem for just about anyone
>firing fuel. Overall, the current levels of pollutants allowed under the
>law are no problem but PM 10 is likely going to become much more tightly
>regulated - no matter what anyone thinks of the validity of those
>regulations.
>
>
>
>Gil Stengel
>email: gstengel@macomb.com
>WWW: http://homepage.macomb.com/~gstengel
>
>
*****************************************
*****************************************
** Don and Isao Morrill **
** Falkland, B.C. **
** kinoko@junction.net **
*****************************************
*****************************************

Evan Dresel on wed 16 jul 97

At 08:33 AM 7-15-97 EDT, Gil Stengel wrote a great summary of regulation of
wood kilns in Illinois:

A couple of comments. Rural and semi-rural areas may still have problems.
My whole region in Central Washington State is a PM10 non-compliance area.
The primary source is dust blowing from dryland agriculture (although the
farmers would have you believe it is mainly from building construction and
"natural" dust. Don't know if there would be a problem with a wood kiln for
that reason. Kind of puts the studio-cleaning issues in perspective though
because the air is worse outside.

Also, in my experience the EPA regions can vary a lot in how they interpret
regulations and of course the state regulators can take still different
views. Heck, the State Department of Ecology can't even agree with itself
much of the time. Not to say the regulators are arbitrary or power-mad;
just that there can be a lot of different views. So try to figure out the
local situation.

-- Evan in eastern Washington State where the hops are growing like crazy
and the apricot harvest is on.