NACAA Comments on Proposed Clay Ceramics Manufacturing Rule

October 4, 2018 – NACAA submitted comments on EPA’s proposed Risk and Technology Review (RTR) standards for the Clay Ceramics Manufacturing source category, which were published in the Federal Register on August 20, 2018 (83 Fed. Reg. 42066).  NACAA’s comments focused on provisions in the proposal related to emissions averaging.  Specifically, NACAA noted that emissions averaging can result in possible adverse health effects and implementation challenges, including for inspectors and enforcement personnel.  Therefore, if EPA plans to allow emissions averaging, it should retain the critical safeguards included in the proposal.  These include: assurance that the environmental benefits of the averaging will be equal to or greater than if each individual unit had complied separately; a prohibition on averaging for new sources; and a prohibition on averaging between different pollutants, sources or source categories.  Additionally, NACAA recommended a discount factor be applied to ensure that the average will be at least as stringent as the MACT floor limits without averaging.  NACAA’s letter essentially reiterated comments the association made regarding emissions averaging provisions contained in a December 18, 2014 proposal for the Brick and Structural Clay Products (BSCP) Manufacturing and the Clay Ceramics Manufacturing source categories.