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Show • Preliminary M A C T floor for gas and oil-fired boilers, • HAPs of Interest list for fossil fuels and • Test plan to characterize certain nonfossil fuels and to obtain data that show the effects of co-firing. The BWG contributed to the excellent Section 114 Information Collection Request (ICR). This produced an inventory data base for wood and nonfossil fuel boilers and other equipment using these fuels that was more comprehensive and more accurate than the I C C R inventory database for all units. The Works In Progress provides the EPA with very good input on HAPs of interest, MACT floor, Control Device Performance and the status of state regulations. The BWG has framed the important issues that the EPA must address to produce good regulations for boilers. These include: the critical importance of a working definition for solid waste, the issues surrounding application of pollution prevention techniques in the regulations, and the issues of establishing a M A C T floor when emissions vary by orders of magnitude on apparently similar boilers. These accomplishments have produced a solid foundation on which the EPA can build and finalize the regulations for HAPs. On the other hand, the dialogue was often impeded by an unwillingness to compromise on what seemed to be minor issues. The ICCR charter was not renewed by the agency because the progress was too slow to meet the deadlines for promulgation of the M A C T standards. The agency also indicated that the process was too expensive. However, the dialogue also enabled the stakeholders to understand opposing viewpoints and to refine their positions. This often resulted in superior work products for use in the regulatory process. Most participants in the ICCR agree that the process was worthwhile. This process should be considered for future rulemakings with modifications that would promote more rapid progress. A possible modification would be to limit the time period for discussion and dialogue. If the parties involved in the dialogue cannot reach consensus within a given time period, they should have to present their respective positions for judgment by the E P A and the process should continue to the next item on the critical path. D:^ps\ica\bwg\boflerwg 10 |