On May 16, 2003 (68 FR 26690-26755), EPA issued final maximum achievable control technology (MACT) standards for new and existing sources at brick, structural clay, and clay ceramic products manufacturing facilities. Originally treated as the single source category listed as "clay products manufacturing," EPA has regulated the source categories separately, given their variability in processes, emissions, control options, and finished products. The brick and structural clay products standards and the standards for clay ceramics manufacturing are codified as 40 CFR Part 63, Subparts JJJJJ and KKKKK, respectively. A correction to the final MACT standards was published in the Federal Register on May 28, 2003 (68 FR 31744) that corrected several dates in the final standards. The dates used in this article reflect the corrected dates. The two regulations are expected to reduce nationwide hazardous air pollutant (HAP) emissions from affected facilities by about 2,300 tons per year (tpy), which represents an emission reduction of 35% from current levels. The facilities potentially affected by the MACTs make a variety of products, such as porcelain bathroom fixtures, roofing tiles, adobe brick, earthenware, and many other items comprised of brick and structural clay or clay ceramic material. In the manufacturing process, products are fired in either continuous kilns (i.e., tunnel kilns or roller kilns), or in batch (periodic) kilns. HAPs emitted during the kiln drying process include hydrogen fluoride (HF), hydrogen chloride (HCl), and particulate matter (PM) containing antimony, arsenic, beryllium, cadmium, chromium, cobalt, mercury, manganese, nickel, lead, and selenium. Because they are combustion processes, kilns are also sources of additional PM and sulfur dioxide (SO_2). EPA indicates there are 189 brick and structural clay products manufacturing facilities in the United States. There are 314 permitted and operable continuous kilns at these facilities, of which 302 are located at facilities believed to be major sources. Major sources are those facilities with the potential to emit ≥10 tpy of any single HAP, or ≥25 tpy of any combination of HAPs. There are also 227 permitted and operable periodic kilns, of which 164 are located at facilities believed to be ma-jor sources. Under the brick and structural clay products manufacturing MACT, most existing and new kilns at major sources are required to comply with HF, HCl, and PM emission limits. There are 58 facilities that produce clay ceramics, of which only eight are estimated to be major sources of HAPs. While the continuous or periodic kilns used at the eight facilities are regulated under the clay ceramics manufacturing MACT, no emission limits apply to existing sources. Existing affected sources need only meet a work practice standard requiring facilities to fire natural gas or an equivalent fuel in their kilns―something all existing sources already do. New kilns at clay ceramics manufacturing facilities are required to meet emission limits for HF, HCl, and PM.
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