1. Fumigation used to protect from invasive species 2. Inconsistent requirements for air permitting fumigation activities state-by-state 3. Multiple methodologies employed to conduct fumigation 4. No MACT standards promulgated for methyl bromide or phosphine 5. Toxicity standards vary state-by-state 6. AERMOD a useful tool, but better suited to continuous, Gaussian emission plumes 7. Generally, all examined possible control technologies are technically and/or economically infeasible 8. Will EPA promulgate a MACT?
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