EPA Publishes Final Brick & Structural Clay and Clay Ceramics Manufacturing
NESHAP Standards
EPA has published two National Emission Standards for Hazardous Air Pollutants (NESHAP) rules for Brick and Structural Clay Products (BSCP) Manufacturing and for Clay Ceramics Manufacturing on May 16, 2003 (68 FR 26689). The rule does not establish Maximum Available Control Technology (MACT) standards for the clay minerals processing or lightweight aggregate manufacturing industries. EPA will not issue MACT standards for these two related source categories as originally planned.
Potentially affected facilities manufacture a variety of products, including porcelain bathroom fixtures, adobe brick, roofing tiles, pressed floor and wall tile, and earthenware. There may be many other manufactured items that may meet the rule applicability criteria. The following standard industrial classification (SIC) categories are affected:
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3251 Brick and structural clay tile |
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3253 Ceramic wall and floor tile |
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3259 Other structural clay products |
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3261 Vitreous plumbing fixtures (sanitaryware) |
The facility must be a major source of HAP emissions. A major HAP facility is one that emits or has the potential to emit 10 tons per year of any one HAP or 25 tons per year of a combination of HAPs.
EPA has determined that during the kiln drying process, the following Hazardous Air Pollutants (HAPs) may be emitted: hydrogen fluoride (HF), hydrogen chloride (HCl), sulfur dioxide (SO2) and particulate matter (PM) containing antimony (Sb), arsenic (As), beryllium (Be), cadmium, chromium, cobalt, mercury, manganese, nickel, lead and selenium.
BSCP Manufacturing (40 CFR Part 63 Subpart JJJJJ)
Affected Sources
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If the kiln vents through a sawdust dryer and the dryer was in use prior to July 22, 2002, then the kiln would not be an affected source.
Also excluded are those tunnel kilns that have design capacities < 10 tons per hour or those that have federally enforceable permit conditions that limit operation to < 10 tph of fired product on a 30-day rolling average basis. Kilns used for R&D purposes or for setting glazes on already-fired products are not subject to Subpart JJJJJ.
EPA was receptive to development of a risk-based rule using two separate approaches. In the first, there would be an applicability cutoff for threshold pollutants under CAA Section 112(d). The other approach involves sub-categorization and delisting under CAA Sections 112(c)(7) and (c)(9).
Emission Limits
For the existing, new, and reconstructed sources mentioned above:
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Sources would be able to use either a capture and collection system and air pollution control device to meet the emission reduction limits shown above or they could use low-HAP raw materials or make process changes in order to meet the emissions limits.
Operating limits on various parameters such as fabric filter inlet temperature, lime feed hopper settings, dry lime scrubber water injection rates, average scrubber pressure drops, average scrubber liquid flow rates, average scrubber liquid pH, and average scrubber chemical feed rates will be established during performance testing. A bag leak detection system must be in place on fabric filters. Note that EPA rejected dry lime adsorbers (DLA) as MACT.
Other Requirements
Performance testing must occur within 180 calendar days following the sources compliance date with subsequent testing every 5 years.
An Operating & Maintenance Plan and a Startup, Shutdown and Malfunction Plan must be prepared and adhered to.
Sources would be subject to initial notification requirements, notification of performance testing, notification of compliance status and periodic (semi-annual) reporting and several recordkeeping requirements.
Clay Ceramics Manufacturing (40 CFR Part 63 Subpart KKKKK)
Affected Sources
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New or Reconstructed: |
Tunnel or roller kilns constructed or reconstructed after July 22, 2002, regardless of size. |
Excluded are existing tunnel or roller kilns at clay ceramic manufacturing facilities. Kilns used for R&D purposes or for setting glazes on already-fired products or for refiring products are not subject to Subpart KKKKK.
Emission Limits
For the new and reconstructed sources mentioned above:
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Sources would be able to use either a capture and collection system and air pollution control device to meet the emission reduction limits shown above or they could use low-HAP raw materials or make process changes in order to meet the emissions limits.
As with Subpart JJJJJ, operating limits on various parameters such as fabric filter inlet temperature, lime feed hopper settings, dry lime scrubber water injection rates, average scrubber pressure drops, average scrubber liquid flow rates, average scrubber liquid pH, and average scrubber chemical feed rates will be established during performance testing. A bag leak detection system must be in place on fabric filters.
Other Requirements
Performance testing must occur within 180 calendar days following the sources compliance date with subsequent testing every 5 years.
An Operating & Maintenance Plan and a Startup, Shutdown and Malfunction Plan must be prepared and adhered to.
Author: Nancy Hriko, Senior Environmental Engineer
Date: 03/07/03
Updated: Kimberly D. Coy, 01/28/04