In October 2015, the United States Environmental Protection Agency (USEPA) finalized the NESHAP for Brick and Structural Clay Products Manufacturing, also known as the Brick MACT (Maximum Achievable Control Technology). This rule, codified as Title 40 of the Code of Federal Regulations (CFR), Part 63, Subpart JJJJJ, sets emission limits on hazardous air pollutants (HAPs) for Major Source Brick and Structural Clay Products (BSCP) manufacturing facilities. BSCP manufacturing facilities are defined as facilities that produce brick, clay pipe, roof tile, extruded wall or floor tile, and/or other extruded, dimensional clay products. BSCPs generally process raw clay and shale, form materials into bricks, tiles, or other shapes, and dry and fire the shaped material in dryers, kilns, and or ovens. Facilities that manufacture refractory products or clay ceramics are not BSCP manufacturing facilities.
The regulated sources of the new rule fall into the following three categories:
The primary pollutants regulated by the new rule are particulate matter, mercury and other toxic metals, and acid gases. Specific emission limits vary depending on the size and type of the facility’s kiln, and the complete list quantitative emission limits can be found in Table 1 of Subpart JJJJJ. In order to meet these limits, many facilities will need to install new control equipment, including particulate filters and scrubbers.
In addition to emission limits, the new rule establishes operating requirements and work practice standards. Operating requirements vary depending on the type of control device installed at the facility, but in general, they involve monitoring and recordkeeping to ensure that control devices are operating properly and emissions are adequately controlled. Work practice standards include the development of temperature and firing profiles and procedures to help reduce HAP emissions at the source, performance of periodic tune ups and maintenance on affect kiln burners, and establishment of startup push rates for tunnel kilns.
Existing facilities must meet the requirements of this rule by December 18th, 2018. Installing new control devices is expensive, and the design and permitting process can take over twelve months to complete. BSCP facilities need to start planning immediately in order to meet the emission limits by the December 2018 compliance date.
For more information on the Brick MACT or control strategies and device options, contact Chris Waller at (800) 777-0605 or firstname.lastname@example.org.