PCWP
­
Overview
PCWP
­
Overview
Presented
to:
OMB
Presented
to:
OMB
Presented
by:
Mary
Tom
Kissell
Presented
by:
Mary
Tom
Kissell
Date:
08
October
2003
Date:
08
October
2003
1
Today
­­
overview
of
impacts,
rule,
significant
Today
­­
overview
of
impacts,
rule,
significant
comments,
and
possible
risk
option
comments,
and
possible
risk
option
While
developing
rule
­­

While
developing
rule
­­

Focused
on
cost
reductions
Focused
on
cost
reductions
Provided
flexible
compliance
options
for
Provided
flexible
compliance
options
for
impacted
facilities
impacted
facilities
Made
legally
defensible
decisions
Made
legally
defensible
decisions
Worked
closely
with
industry
trade
associations
Worked
closely
with
industry
trade
associations
Schedule
Schedule
Background
Background
2
Costs
Costs
capital
costs
­
$
479
million
capital
costs
­
$
479
million
annual
costs
­
$
142
million
(
worst
case)

annual
costs
­
$
142
million
(
worst
case)

cost
per
ton
HAP
(
VOC)
­
$
13,000
($
5,000)

cost
per
ton
HAP
(
VOC)
­
$
13,000
($
5,000)

Emissions
Emissions
HAP
reduction
­
11,000
tpy
HAP
reduction
­
11,000
tpy
VOC
reduction
­
27,000
tpy
VOC
reduction
­
27,000
tpy
NOx
increases
due
to
control
device
NOx
increases
due
to
control
device
Impacts
without
Risk
Option
Impacts
without
Risk
Option
3
Impacts
without
Risk
Option
Impacts
without
Risk
Option
(
continued)

(
continued)

Economic
impacts
­

Economic
impacts
­

$
134
million
in
social
costs
$
134
million
in
social
costs
$
8.5
million
in
quantifiable
benefits
$
8.5
million
in
quantifiable
benefits
Predicted
closures
at
proposal
­
one
line
at
Predicted
closures
at
proposal
­
one
line
at
one
facility
(
small
business)

one
facility
(
small
business)
4
Small
Business
Small
Business
Acceptable
economic
impacts
and
no
Acceptable
economic
impacts
and
no
SISNOSE
SISNOSE
17
of
52
companies
(
32%)
are
small
17
of
52
companies
(
32%)
are
small
businesses
businesses
Incur
8%
of
costs
Incur
8%
of
costs
Only
3
small
firms
with
compliance
costs
Only
3
small
firms
with
compliance
costs
greater
than
or
equal
to
3%
of
their
sales
greater
than
or
equal
to
3%
of
their
sales
Seven
small
firms
with
sales
ot
cost
ratios
Seven
small
firms
with
sales
ot
cost
ratios
between
1
and
3%

between
1
and
3%
5
Description
of
Industry
Description
of
Industry
Industry
produces
several
types
of
building
Industry
produces
several
types
of
building
materials
made
from
wood
that
is
glued
or
materials
made
from
wood
that
is
glued
or
mixed
with
resin,
and
pressed
mixed
with
resin,
and
pressed
Wood
slices
­­
e.
g.,
plywood
and
veneer,

Wood
slices
­­
e.
g.,
plywood
and
veneer,

engineered
wood
products
engineered
wood
products
Wood
flakes
­­
e.
g.,
oriented
strandboard,

Wood
flakes
­­
e.
g.,
oriented
strandboard,

parallel
strand
lumber
parallel
strand
lumber
Wood
particles
­­
e.
g.,
particleboard,

Wood
particles
­­
e.
g.,
particleboard,

hardboard,
fiberboard
hardboard,
fiberboard
6
Description
of
Industry
Description
of
Industry
(
continued)

(
continued)

Dryers
and
presses
two
most
significant
Dryers
and
presses
two
most
significant
emission
points
emission
points
Formaldehyde,
methanol,
acetaldehyde,

Formaldehyde,
methanol,
acetaldehyde,

propionaldehyde,
acrolein,
and
phenol
propionaldehyde,
acrolein,
and
phenol
account
for
96%
of
emissions
account
for
96%
of
emissions
Emissions
originate
from
wood
and
resins
Emissions
originate
from
wood
and
resins
Other
pollutants
include
PM,
VOC,
and
small
Other
pollutants
include
PM,
VOC,
and
small
amounts
of
benzene
and
metals
amounts
of
benzene
and
metals
HAP
emitted
linked
to
lung
damage,
cancer,

HAP
emitted
linked
to
lung
damage,
cancer,

and
other
adverse
health
effects
and
other
adverse
health
effects
7
Many
process
units
have
MACT
controls
Many
process
units
have
MACT
controls
MACT
control
is
capture
+
control
of
90%

MACT
control
is
capture
+
control
of
90%

11%
to
71%
of
dryers
have
MACT
controls
11%
to
71%
of
dryers
have
MACT
controls
15%
of
presses
have
MACT
controls
15%
of
presses
have
MACT
controls
Most
MACT
controls
are
RTOs
Most
MACT
controls
are
RTOs
Other
MACT
controls:
RCOs,
biofilters,
process
Other
MACT
controls:
RCOs,
biofilters,
process
incineration
incineration
All
existing
RTOs
can
achieve
90
percent
All
existing
RTOs
can
achieve
90
percent
Many
RTOs
can
achieve
95+
percent
Many
RTOs
can
achieve
95+
percent
Existing
Controls
Existing
Controls
8
All
process
units
can
use
­­

All
process
units
can
use
­­

Add­
on
controls,
e.
g.,
RTO,
RCO,
biofilter,
and
Add­
on
controls,
e.
g.,
RTO,
RCO,
biofilter,
and
process
incineration
process
incineration
Emissions
averaging
Emissions
averaging
Some
process
units
can
use
a
Some
process
units
can
use
a
production­
based
compliance
option
production­
based
compliance
option
(
pollution
prevention
option)

(
pollution
prevention
option)

Compliance
Options
Compliance
Options
9
Emissions
averaging
compliance
option
Emissions
averaging
compliance
option
Production­
based
compliance
options
Production­
based
compliance
options
(
PBCO)
(
industry
calls
these
PBELs)

(
PBCO)
(
industry
calls
these
PBELs)

Most
Significant
Nonrisk
Issues
Most
Significant
Nonrisk
Issues
10
Emissions
Averaging
­
What
We
Emissions
Averaging
­
What
We
Proposed
Proposed
Simple
system
of
emissions
debits
and
credits
Simple
system
of
emissions
debits
and
credits
Allows
facility
to
control
emissions
from
Allows
facility
to
control
emissions
from
unregulated
process
unit
and
under
control
unregulated
process
unit
and
under
control
emissions
from
a
regulated
process
unit
emissions
from
a
regulated
process
unit
Based
on
actual
emissions
Based
on
actual
emissions
No
additional
emission
reductions
required
to
No
additional
emission
reductions
required
to
participate
(
no
discount
factor)

participate
(
no
discount
factor)

No
demonstration
hazard
or
risk
required
No
demonstration
hazard
or
risk
required
Only
process
units
with
add­
on
controls
can
Only
process
units
with
add­
on
controls
can
generate
credits
generate
credits
11
EA
­
Control
Efficiency
EA
­
Control
Efficiency
Proposed
credit/
debit
based
on
90%
control
Proposed
credit/
debit
based
on
90%
control
Industry
requests
credit
for
>
90%
control
Industry
requests
credit
for
>
90%
control
while
using
MACT
technology
while
using
MACT
technology
We
recommend
maintaining
90%

We
recommend
maintaining
90%

Higher
control
efficiency
for
emissions
Higher
control
efficiency
for
emissions
averaging
brings
into
question
MACT
limits,

averaging
brings
into
question
MACT
limits,

especially
for
new
sources
especially
for
new
sources
Should
use
same
value
for
credit
and
debit
Should
use
same
value
for
credit
and
debit
12
EA
­
Credits
for
P2,
Shutdowns,
&

EA
­
Credits
for
P2,
Shutdowns,
&

Downtime
Downtime
Proposed
that
only
process
units
with
add­
on
Proposed
that
only
process
units
with
add­
on
controls
can
generate
emissions
credits
controls
can
generate
emissions
credits
Industry
wants
to
generate
emissions
credits
Industry
wants
to
generate
emissions
credits
for
­

for
­
Pollution
prevention
projects
Pollution
prevention
projects
Production
shutdowns
Production
shutdowns
Unused
portion
of
downtime
allowance
Unused
portion
of
downtime
allowance
13
EA
­
Credits
for
P2,
Shutdowns,
&

EA
­
Credits
for
P2,
Shutdowns,
&

Downtime
Downtime
(
continued)

(
continued)

We
recommend
not
allowing
other
than
We
recommend
not
allowing
other
than
add­
on
controls
to
generate
emission
credits
add­
on
controls
to
generate
emission
credits
Pollution
prevention
Pollution
prevention
Can
be
difficult
to
establish
a
baseline
Can
be
difficult
to
establish
a
baseline
Do
not
agree
on
what
is
pollution
prevention
Do
not
agree
on
what
is
pollution
prevention
Introduces
uncertainty
in
average
and
may
Introduces
uncertainty
in
average
and
may
erode
rationale
against
including
a
discount
erode
rationale
against
including
a
discount
factor
factor
Shutdowns
and
unused
downtime
allowance
Shutdowns
and
unused
downtime
allowance
Do
not
reflect
MACT
Do
not
reflect
MACT
14
EA
­
HAP
Considered
EA
­
HAP
Considered
Proposed
that
emissions
average
based
on
six
HAP
Proposed
that
emissions
average
based
on
six
HAP
Industry
wants
to
consider
only
one
pollutant:

Industry
wants
to
consider
only
one
pollutant:

methanol,
formaldehyde,
or
THC
methanol,
formaldehyde,
or
THC
We
recommend
basing
compliance
on
six
HAP
We
recommend
basing
compliance
on
six
HAP
Predominant
HAP
varies
with
process
unit
and
Predominant
HAP
varies
with
process
unit
and
one
of
six
we
specified
will
always
be
one
of
the
one
of
six
we
specified
will
always
be
one
of
the
predominant
predominant
Looking
at
all
six
considers
96%
of
emissions
by
Looking
at
all
six
considers
96%
of
emissions
by
mass
mass
No
hazard
or
risk
assessment
required
No
hazard
or
risk
assessment
required
15
Process
unit
emission
rate
limit
for
10
types
Process
unit
emission
rate
limit
for
10
types
of
process
units
of
process
units
Developed
option
to
encourage
pollution
Developed
option
to
encourage
pollution
prevention
and
innovation
prevention
and
innovation
Proposed
limits
based
on
90%
reduction
Proposed
limits
based
on
90%
reduction
from
the
highest
emission
rate
which
achieve
from
the
highest
emission
rate
which
achieve
less
emissions
reduction
than
MACT
less
emissions
reduction
than
MACT
Applies
to
uncontrolled
emissions
Applies
to
uncontrolled
emissions
Results
in
more
emissions
than
MACT
floor
Results
in
more
emissions
than
MACT
floor
PBCO
­­
What
We
Proposed
PBCO
­­
What
We
Proposed
16
PBCO
­
Limits
PBCO
­
Limits
Proposed
limits
based
on
90%
of
the
highest
Proposed
limits
based
on
90%
of
the
highest
emission
rate
emission
rate
Industry
suggested
higher
emission
limits
Industry
suggested
higher
emission
limits
based
on
theoretical
worst
case
emissions
based
on
theoretical
worst
case
emissions
Industry
data
we
used
to
set
limits
was
based
Industry
data
we
used
to
set
limits
was
based
on
maximum
operating
conditions
on
maximum
operating
conditions
We
recommend
no
change
to
proposed
We
recommend
no
change
to
proposed
PBCO
limits
PBCO
limits
Moves
us
further
from
MACT
Moves
us
further
from
MACT
17
Green
Rotary
Particle
Dryers
RTO
0
0.1
0.2
0.3
0.4
0.5
0.6
Uncont
rolled
90%
MACT
cont
rol
Proposed
PBCO
(
0.058)

AF&
PA
PBCO
(
0.15)
18
Rotary
Strand
Dryers
RTO
RTO
0
0.2
0.4
0.6
0.8
1
1.2
1.4
1.6
1.8
2
Uncont
rolled
90%
MACT
cont
rol
Proposed
PBCO
(
0.18)

AF&
PA
PBCO
(
0.54)
19
Proposed
PBCO
limits
apply
to
emissions
Proposed
PBCO
limits
apply
to
emissions
from
the
process
from
the
process
Industry
wants
us
to
allow
add­
on
controls
to
Industry
wants
us
to
allow
add­
on
controls
to
meet
PBCO
limits
meet
PBCO
limits
We
recommend
no
changes
to
limits
We
recommend
no
changes
to
limits
Inconsistent
for
a
pollution
prevention
Inconsistent
for
a
pollution
prevention
alternative
alternative
Less
HAP
reduction
Less
HAP
reduction
Does
not
eliminate
NOx
formed
by
combustion
Does
not
eliminate
NOx
formed
by
combustion
PBCO
­
Using
Add­
on
Controls
to
PBCO
­
Using
Add­
on
Controls
to
Comply
Comply
20
Combining
EA
and
PBCO
Combining
EA
and
PBCO
Proposed
emissions
averaging
and
PBCO
as
Proposed
emissions
averaging
and
PBCO
as
separate
compliance
options
separate
compliance
options
Industry
wants
to
use
emissions
averaging
to
Industry
wants
to
use
emissions
averaging
to
meet
PBCO
limits
meet
PBCO
limits
We
recommend
the
options
remain
separate
We
recommend
the
options
remain
separate
Not
pollution
prevention
Not
pollution
prevention
Emissions
averaging
already
allows
a
facility
to
Emissions
averaging
already
allows
a
facility
to
generate
an
emission
credit
controlling
part
of
generate
an
emission
credit
controlling
part
of
an
exhaust
stream
and
achieves
MACT
an
exhaust
stream
and
achieves
MACT
21
Why
Consider
Risk
in
PCWP
Why
Consider
Risk
in
PCWP
MACT?

MACT?

PCWP
rule
has
relatively
high
cost
PCWP
rule
has
relatively
high
cost
PCWP
proposal
preamble
discussed
PCWP
proposal
preamble
discussed
possibility
of
including
a
risk
option
in
final
possibility
of
including
a
risk
option
in
final
PCWP
rule
to
lower
costs
PCWP
rule
to
lower
costs
22
How
We
Could
Implement
a
Risk
How
We
Could
Implement
a
Risk
Option
in
PCWP
MACT
Option
in
PCWP
MACT
Use
112(
c)(
1)
and
112(
c)(
9)
to
define
and
delist
a
Use
112(
c)(
1)
and
112(
c)(
9)
to
define
and
delist
a
subcategory
of
low­
risk
facilities
subcategory
of
low­
risk
facilities
Delist
low­
risk
subcategory
with
final
rule
Delist
low­
risk
subcategory
with
final
rule
Specific
facilities
would
not
be
identified
Specific
facilities
would
not
be
identified
Facility
demonstrates
it
is
low
risk
Facility
demonstrates
it
is
low
risk
Look­
up
tables,
or
Look­
up
tables,
or
Site­
specific
risk
assessment
Site­
specific
risk
assessment
Facility
not
part
of
low­
risk
subcategory
until
emission
Facility
not
part
of
low­
risk
subcategory
until
emission
rates
are
established
in
its
Title
V
permit
rates
are
established
in
its
Title
V
permit
Establish
low­
risk
status
by
compliance
date
Establish
low­
risk
status
by
compliance
date
23
Basis
of
Low
Risk
Demonstration
Basis
of
Low
Risk
Demonstration
Include
all
HAP
emitted
by
PCWP
source
category
Include
all
HAP
emitted
by
PCWP
source
category
Consider
cancer
and
non­
cancer
effects
Consider
cancer
and
non­
cancer
effects
Consider
ecological
health
and
effects
on
threatened
Consider
ecological
health
and
effects
on
threatened
and
endangered
species
are
not
a
concern
and
endangered
species
are
not
a
concern
24
Basis
of
Low
Risk
Demonstration
Basis
of
Low
Risk
Demonstration
(
continued)

(
continued)

Base
URE
and
RfC
values
on
OAQPS
website
(
note
Base
URE
and
RfC
values
on
OAQPS
website
(
note
hierachy)

hierachy)

Emission
rates
for
each
HAP
Emission
rates
for
each
HAP
Rule
will
specify
acceptable
measurement
and
Rule
will
specify
acceptable
measurement
and
estimation
procedures
estimation
procedures
25
Look­
up
Tables
Look­
up
Tables
Two
look­
up
tables
would
provide
the
allowable
tox­
weighted
Two
look­
up
tables
would
provide
the
allowable
tox­
weighted
emission
rate
limits
(
one
for
carcinogens
and
one
for
emission
rate
limits
(
one
for
carcinogens
and
one
for
non­
carcinogens)

non­
carcinogens)

Rule
would
specify
methods
for
calculating
tox­
weighted
Rule
would
specify
methods
for
calculating
tox­
weighted
emission
rates
emission
rates
Tox­
weighted
emission
rates
must
be
less
than
emission
limits
Tox­
weighted
emission
rates
must
be
less
than
emission
limits
in
look­
up
tables
to
be
considered
low­
risk
in
look­
up
tables
to
be
considered
low­
risk
Maximum
tox­
weighted
emission
rate
allowable
for
Maximum
tox­
weighted
emission
rate
allowable
for
carcinogens
must
impose
<
1
in
a
million
cancer
risk,
and
carcinogens
must
impose
<
1
in
a
million
cancer
risk,
and
Maximum
tox­
weighted
emission
rate
allowable
for
Maximum
tox­
weighted
emission
rate
allowable
for
non­
carcinogens
must
impose
HI
<
x
non­
carcinogens
must
impose
HI
<
x
Need
to
decide
what
HI
limit
should
be
Need
to
decide
what
HI
limit
should
be
26
Example
Look­
up
Table
Example
Look­
up
Table
Stack
Height
(
ft)
Minimum
Distance
to
Fenceline
(
m)

20
50
100
200
500
20
­­
­­
2.0
X
10­
­
7
5.8
X
10­
­
7
1.2
X
10­
­
6
40
­­
6.2
X
10­
­
7
7.8
X
10­
­
7
1.5
X
10­
­
6
3.5
X
10­
­
6
80
6.6
X
10­
­
6
6.6
X
10­
­
6
6.6
X
10­
­
6
6.6
X
10­
­
6
7.0
X
10­
­
6
100
9.0
X
10­
­
6
9.0
X
10­
­
6
9.0
X
10­
­
6
9.0
X
10­
­
6
9.3
X
10­
­
6
Maximum
Allowable
Toxicity­
weighted
Carcinogen
Emission
Rate
Units:
T/
yr*(
ug/
m33)­
­
1
27
Site­
specific
Risk
Assessment
Site­
specific
Risk
Assessment
Risk
must
be
<
1
in
a
million
for
carcinogens,
and
Risk
must
be
<
1
in
a
million
for
carcinogens,
and
Total
HI
must
be
<
x
for
non­
carcinogens
Total
HI
must
be
<
x
for
non­
carcinogens
Risk
Assessment
Guidance
currently
under
Risk
Assessment
Guidance
currently
under
development
development
28
Review
of
Low
Risk
Demonstration
Review
of
Low
Risk
Demonstration
Permitting
authority
reviews
and
Permitting
authority
reviews
and
approves/
denies
approves/
denies
Emission
rates
included
in
Title
V
permit
to
Emission
rates
included
in
Title
V
permit
to
ensure
facility
remains
in
low­
risk
ensure
facility
remains
in
low­
risk
subcategory
subcategory
29
Risk
Option:
Analysis
Risk
Option:
Analysis
Of
188
facilities
modeled:

Of
188
facilities
modeled:

111
have
cancer
risk
<
1
in
a
million
111
have
cancer
risk
<
1
in
a
million
Of
these;

Of
these;

52
have
HI
<
0.2
52
have
HI
<
0.2
83
have
HI
<
0.5
83
have
HI
<
0.5
94
have
HI
<
0.8
94
have
HI
<
0.8
97
have
HI
<
1.0
97
have
HI
<
1.0
111
have
HI
<
10.0
111
have
HI
<
10.0
max
HI
(
of
the
low
cancer
risk
facilities)
is
3.1
max
HI
(
of
the
low
cancer
risk
facilities)
is
3.1
30
HI
limit
less
than
Total
Capital
Costs
($
MM)
Total
Annual
Cost
($
MM)
Total
HAP
Reduction
(
tpy)
Total
THC
Reduction
(
tpy)

0.2
$
427
$
126
10,206
23,214
0.5
$
370
$
109
9,363
19,457
0.8
$
347
$
102
9,016
17,773
1.0
$
340
$
101
8,815
17,607
10.0
$
302
$
90
8,037
15,894
No
risk
option
$
479
$
142
11,000
27,000
Impacts
of
HI
Limit
on
Costs
and
Emissions
Impacts
of
HI
Limit
on
Costs
and
Emissions
31
Commenters:
Using
112(
c)
to
Delist
Commenters:
Using
112(
c)
to
Delist
a
Low­
risk
Subcategory
a
Low­
risk
Subcategory
AF&
PA
­
Congress
gave
EPA
broad
authority
to
delist
low­
risk
AF&
PA
­
Congress
gave
EPA
broad
authority
to
delist
low­
risk
subcategory
subcategory
NRDC
NRDC
Creating
and
delisting
is
allowable
for
operationally
similar
Creating
and
delisting
is
allowable
for
operationally
similar
sources
and
cannot
be
based
on
risk
sources
and
cannot
be
based
on
risk
Cannot
implement
on
a
case­
by­
case
site­
specific
basis
Cannot
implement
on
a
case­
by­
case
site­
specific
basis
because
Congress
rejected
doing
that
under
112(
d)(
4)

because
Congress
rejected
doing
that
under
112(
d)(
4)

requiring
that
for
subcategory
to
be
delisted,
each
facility
in
requiring
that
for
subcategory
to
be
delisted,
each
facility
in
the
subcategory
must
be
low
risk
the
subcategory
must
be
low
risk
States
­
mixed
opinions
States
­
mixed
opinions
32
Commenters:
HI
Value
Limit
Commenters:
HI
Value
Limit
AF&
PA
­
supports
HI
>
1
and
suggested
AF&
PA
­
supports
HI
>
1
and
suggested
going
as
high
as
10
going
as
high
as
10
RfC
health
benchmark
is
highly
protective
and
RfC
health
benchmark
is
highly
protective
and
meets
CAA
"
ample
margin
of
safety"

meets
CAA
"
ample
margin
of
safety"

No
legal
obligation
or
policy
reason
to
consider
No
legal
obligation
or
policy
reason
to
consider
background
or
multipathway
exposures
background
or
multipathway
exposures
EPA
has
existing
regulations
to
address
other
EPA
has
existing
regulations
to
address
other
sources
sources
Multipathway
exposure
is
insignificant
for
Multipathway
exposure
is
insignificant
for
PCWP
PCWP
33
Commenters:
HI
Value
Limit
Commenters:
HI
Value
Limit
(
continued)

(
continued)

HQ's
for
chemical
mixtures
should
not
be
HQ's
for
chemical
mixtures
should
not
be
summed
summed
NRDC
NRDC
Should
consider
background
concentration
Should
consider
background
concentration
Cannot
rely
on
blanket
assumptions
about
Cannot
rely
on
blanket
assumptions
about
exposure
exposure
NATA
not
designed
or
precise
enough
to
use
NATA
not
designed
or
precise
enough
to
use
for
background
estimates
for
background
estimates
States
­
Opinions
vary
States
­
Opinions
vary
34
Commenters:
HAP
Evaluated
Commenters:
HAP
Evaluated
AF&
PA
AF&
PA
Consider
only
most
prevalent
HAP
Consider
only
most
prevalent
HAP
Industry
analysis
demonstrates
some
Industry
analysis
demonstrates
some
compounds
will
never
drive
risk
compounds
will
never
drive
risk
NRDC
­
No
direct
comment,
but
have
NRDC
­
No
direct
comment,
but
have
commented
on
using
subset
of
HAP
as
commented
on
using
subset
of
HAP
as
surrogates
surrogates
States
­
Did
not
comment
States
­
Did
not
comment
35
Commenters:
Ecological
Effects
Commenters:
Ecological
Effects
AF&
PA
AF&
PA
Supports
broad
definition
of
"
adverse
Supports
broad
definition
of
"
adverse
environmental
impact"

environmental
impact"

No
risks
to
ecological
receptors
at
HI
of
1.0
No
risks
to
ecological
receptors
at
HI
of
1.0
NRDC
­
CAA
requires
EPA
to
consider
all
NRDC
­
CAA
requires
EPA
to
consider
all
ways
a
pollutant
could
affect
human
health
ways
a
pollutant
could
affect
human
health
and
the
environment,
including
deposition,

and
the
environment,
including
deposition,

persistence,
and
bioaccumulation
persistence,
and
bioaccumulation
States
­
Ecological
risks
must
be
addressed
States
­
Ecological
risks
must
be
addressed
36
Commenters:
Implementation
Commenters:
Implementation
Burden
for
States
Burden
for
States
AF&
PA
AF&
PA
No
significant
increase
in
burden
No
significant
increase
in
burden
Increases
could
be
offset
by
fees
Increases
could
be
offset
by
fees
NRDC
­
Did
not
comment
NRDC
­
Did
not
comment
States
States
Do
not
have
resources
to
implement
Do
not
have
resources
to
implement
Can
reject
delegation
Can
reject
delegation
37
