In 1992, EPA listed "Clay Products Manufacturing" as a category of major sources pursuant to Section 112(c)(1) of the Clean Air Act (CAA). The Clay Products Manufacturing MACT is due for promulgation in mid-2001. Over the last three years, the Brick Industry Association (BIA) has attempted to work with EPA in developing a technical and economically feasible Structural Clay Products MACT. However, the time and resources available to EPA have prevented the type of negotiated rulemaking desired by the BIA. Several basic issues such as the determination of the MACT floor, subcategorization within the industry, cost, and technical feasibility of proposed controls remain to be resolved. Because of the enormous financial impact of this proposed standard, the industry will not be able to accept a MACT that is not both technically and economically viable for the industry as a whole.
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