Federal Updates for Brick and Structural Clay Products Manufacturing and Clay Ceramics Manufacturing



On October 26, 2015, the U.S. Environmental Protection Agency (EPA) finalized updates to two National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations: 1) Brick and Structural Clay Products (BSCP) Manufacturing (40 CFR Part 63, Subpart JJJJJ) and 2) Clay Ceramics Manufacturing (40 CFR Part 63, Subpart KKKKK). This action is effective on December 28, 2015, and the initial compliance date for existing affected sources is December 26, 2018.

The facilities potentially affected by these rules are those operating under NAICS 327110 (SIC 5719, 3261, 3262, 3263, 3264, 3269, & 3299) and NAICS 327120 (SIC 3251, 3253, 3255, 3259, & 3297). All major sources in these categories must meet maximum achievable control technology (MACT) standards for mercury (Hg), non-mercury (non-Hg) metal hazardous air pollutants (HAP) (or particulate matter (PM) surrogate) and dioxins/furans (Clay Ceramics only); health-based standards for acid gas HAP; and work practice standards, where applicable.

BSCP Manufacturing NESHAP
EPA finalized MACT emission limits for non-Hg HAP metals (or PM surrogate) and Hg, and a health-based emission limit (HBEL) for acid gases (hydrogen fluoride (HF), hydrogen chloride (HCl) and chlorine (Cl2)) for BSCP tunnel kilns (See Table 4 in the final rule). In addition, the EPA finalized work practice standards for periodic kilns, dioxins/furans from tunnel kilns, and periods of startup and shutdown for tunnel kilns. To demonstrate compliance with the emission limits, the EPA is requiring initial and repeat 5-year performance testing for the regulated pollutants, parameter monitoring, and daily visible emissions (VE) checks. Owners/ operators whose BSCP tunnel kilns are equipped with a fabric filter (FF) (e.g., dry lime injection fabric filter (DIFF), dry lime scrubber/fabric filter (DLS/FF)) have the option of demonstrating compliance using a bag leak detection (BLD) system or daily VE checks.

Clay Ceramics Manufacturing NESHAP
The EPA finalized MACT emission limits for Hg, PM (surrogate for non-Hg HAP metals), and dioxins/furans and HBEL for acid gases (HF and HCl) for sanitaryware tunnel kilns and ceramic tile roller kilns (See Table 5 in the final rule). In addition, the EPA finalized MACT emission limits for dioxins/furans for ceramic tile spray dryers and floor tile press dryers, MACT emission limits for Hg and PM (surrogate for non-Hg HAP metals) for ceramic tile glaze lines, and MACT emission limits for PM (surrogate for non-Hg HAP metals) for sanitaryware glaze spray booths. The EPA also finalized work practice standards for shuttle kilns and periods of startup and shutdown. To demonstrate compliance with the emission limits, the EPA is requiring initial and repeat 5-year performance testing for the regulated pollutants, parameter monitoring, and daily VE checks. Owners/operators whose affected sources are equipped with an FF (e.g., DIFF, DLS/FF) have the option of demonstrating compliance using a BLD system or daily VE checks.

Changes to Monitoring Requirements
The original proposal included requirements to monitor scrubber chemical feed rate, pressure drop, and maintenance of the system at or above the average pressure drop for kilns equipped with a wet scrubber. These requirements were not included in the final rule. For BSCP kilns without add-on control, EPA added the requirement to initiate and complete corrective actions if the opacity is observed to be greater than 10%.

For More Information
The Federal Register publication of this final rule is available online, click here