EPA Issues Final MACT for Brick and Structural Clay Products and Clay Ceramics Manufacturing

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Section 112(d) of the Clean Air Act requires EPA to set emission standards for hazardous air pollutants emitted by sources in certain specified source categories and subcategories.  EPA recently published final maximum achievable control technology (MACT) requirements for hazardous air emissions from major sources in the Brick and Structural Clay Products (BSCP) and Clay Ceramic Manufacturing (CCM) categories.  It did so after the original BSCP and CCM MACTs were challenged by industry and environmental groups and were ultimately vacated and remanded to EPA by the D.C. Circuit in 2007.

Major provisions of the BSCP MACT include the following:

  • Emission limits for mercury (Hg) and non-Hg HAPs as surrogates for particulate matter (PM) emissions;

  • Health-based emissions limits for hydrogen fluoride, hydrogen chloride, and chlorine;
  • Work practices for periods of startup, shutdown, malfunction (SSM) and all dioxins/furans emissions at tunnel kilns;
  • Less stringent work practice requirements for periodic kilns; and
  • Initial and 5 year stack tests with daily visible emission (VE) readings or bag leak detections provisions.

The CCM MACT includes significant new provisions:

  • Final limits for Hg, PM, and dioxins/furans for sanitary waretunnel kilns and tile rollers;
  • Final dioxins/furans limits for ceramic tile spray dryers;
  • Final Hg and PM limits for glaze lines and PM for sanitary ware glaze spray booths;
  • Work practices during SSM; and
  • Initial and 5 year stack tests, daily VE, and “parameter monitoring.” 

The rule is effective on December 28, 2015, and existing BSCP and CCM facilities must comply with the applicable MACT by December 28, 2018.

80 Fed. Reg. 65470 (Oct. 26, 2015)

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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