202·682·8529 202·6l<2·llOD wagncl1!IJapi.orl! 

# I John P. Wagner senior AlIornt)'
om•• of(;<ntrAl COUMtl
1220 l. Strtcl, :>IW Woshi"S,on, IX' 20005·4070 USA T.ltphu,," Fox**EIIl~il \\'ww.Jpi.or~** 

December 23,2009
The Honorable Lisa Jackson Administrator U. S. Environmental Protection Agency Room 3000, Ariel Rios Building 1200 Pennsylvania Ave., NW Washington, DC 20460

_ Re: Request for Administrative Reconsideration of the National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries, 74 Fed. Reg. 55670 (October 28, 2009).
Dear Administrator Jackson:
The American Petroleum Institute (API) is writing to request administrative reconsideration of several elements ofthe recently-signed National Emission'Standards for Hazardous Air Pollutants from Petroleum Refineries, published at 74 Fed. Reg. 55670 (October 28,2009). On April 7, 2009 API submitted a letter**sugg~sting** several important changes to the rule. Today, API is seeking reconsideration ofthe issues contained in that letter, which is attached. In addition, API seeks to have EPA reconsider the application ofthe rule to heat exchanger systems which use salt water.
Pursuant to Clean Air Act 

### § 307{d) (7) (B), 42 U.S.C. 

### § 7607(d)(7)(B), where it was impracticable to raise an objection during the period of public comment or if the grounds for such an objection arise after the public comment period (but within the time specified forjudicial review), and if such objections are of central relevance to the outcome ofthe rule, EPA is authorized to reconsider the rule. As we stated in our previous submissions, these issues were identified afterthe rule was initially finalized. Hence,**ther~** was no opportunity to raise objections to these provisions during the public comment period and these issues are of central relevance to the ability ofthe refining industry to comply.
Thank you for your consideration ofthese issues. Ifyou have any questions, do not hesitate to contact me.

cc. 

# v:eIY'ru

Associate General counsel,1 c;

. for the Office of Air and Radiation P. Tsirigotis 

### K. Hustvedt

Art equalopportunityemployerApril 7, 2009

Mr. K. 

### C. Hustvedt 

### US EPA Office ofAirQuality Planning and**Stand~rds** Mail Drop 

### EI43-0

### I Research Triangle Park, NC 27711 Hustvedt.Ken@epamail.epa.gov


### Rc: Environmental Protection Agency's (EPA's)National Emission Standards for 

### Hazardous Air Pollutants From Petroleum Refineries: Final Rule.
The American Petroleum Institute (API) and the National Petrochemical and Refiners AS'sociation (NPRA) submit these suggestions on the Environmental Protection Agency's (EPA's) "National Emission Standards for Hazardous Air Pollutants From Petroleum Refineries: Final Rulc" as posted on the EPA Office ofAir and Radiation Policy and Guidance Website on January 16, 2009. We believe therc are.some clarifications and corrections that could make the lUle clearerand consistentwith the stated intent. 

### 1. Compliance schedule and applicability provisions in §63.640(h). We believe the following revisions are needed to§63.640(h) in orderto clearly and properly reflect the intent as indicated in the preamble and to correct editorial errors.

• (h)(I) Changing "and" to "through", which is clearly the intent.

• (h)(I)(i) and (iii) Changing "Storage vessels" to "Group I storage vessels", for correctness and torconsistency with (h)(4).

• (h)(I)(i) through (iv) Changing the sentence structure to clarify that the date of consUllction./reconstmction is referring to the entire source, ratherthan to the individual storage vcssel orheat exchange system.

• (h)(I)(i) and (ii) Correcting the dale upon which the original new source requirements kicked in, from August 18, 1995 to July 14, 1994. As shown in (h)(I), the triggerdate for new constlUction under the original rule was July 14, 1994. August 18, 1995 was the date oflule promulgation, but applicability was based on thcproposal date.

• (h)(2) Adding aparagraph return to separate this paragraph from (h)(I)(iv).• (h)(4)(ii) Editing the text for correctness and for consistency with (h)(4)(i).

• (h)(l)(i) and (h)(4)(iii) Revising the language to clarify that compliance with §63.646(a) through (I) is no longer required once compliance with §63.646(m) is achieved. CUiTently this language could be read to assume both sets ofrequirements apply, despite the language in §63.646(a) on this point. This impoltantpoint need to be made clearin §63.640(h) as well as in §63.646(a).
We suggest the following specific revisions to the text inthe posted rule to accomplish these changes. (I) Except as provided in paragraphs (h)(I)(i)**aOOthr~:)Ugh** (iv) ofthis section, new
sources thatcommence constructionorreconstruction afterJuly 14, 1994, shall be in compliance with this subpart upon initial startup orAugust 18, 1995, whichever is later. (i) 

### Sltll'Age \esseIs aAt I! new sourCe5 thatcommenceg construction orreconstruction after

### Ll!!ill. I<)c)4Augu'it JX. 1995, bUI before September4,2007, Group 1 slorilgc vessels shall comply with the new source requirements for storage vessels specified in *63.646(a) through (I) upon startup"**~ColTlpljam;e** with Ihe new source requirements for storage vessels specified in §63.646(m) shall**bc_a~hi~ye_~jjnj)l(j!&...QJJh~** requirement· 111 §6 .646(a) through (j) no laterthan [INSERT DATE 36 MONTHS AFTER DATE OF PUBLICATION]. (ii) Heal exch<'lI1ge s)'S'.eID!i aAt!! new**sourc~** that commenceQ construction or reeonsttuction afterJuly 14.**1994-Augu~-199~,** butbefore September4,2007, heal exchange**svstel1l~** shall comply with the existing source requirements for heat exchange systems specified in *63.654 no later than [INSERTDATE 36 :YlONTHS AFTER DATE OF PUBLICATION) (iii)**~ltllilga** 

### ...c';se!s aAt !l new source" that**commence~** construction or reconstruclion after September4, 2007,**~Jroup** I storage vessels shall be in compliance with the new
source requirements in §63.646(m) upon initial startup or [INSERT DATE OF PUBLICATION), whichever is later. (iv)**l-1ei-l1-£'KC-hitHge--sy"7t~~** : _I!! new source5 that commence§ construction or reconstruction after September4, 2007, J1Cal exchange systems shall be in compliance with the new sourcerequirements in §63.654 upon initial startup or [INSERT DATE OF PUBLICATION], 

### whidlt:ver is later. (2) Except as provided in paragraphs (h)(3) through (h)(6) ofthis section, existing
sources shall be in compliance with this subpart no later than August 18, 1998, except
as provided in §63.6(c)(5) ofsubpartA ofthis part, orunless an extension has been granted by the Administrator as provided in §63.6(i) ofsubpart A ofthis part

..at< 

### * at< at< '" 

### (4) A Gro\lP I storage vessel that is paltofan existing source shall bein compliance with §63.646 as specified in paragraphs (h)(4)(i) through (h)(4)(iii). (i) 

### Except for existing flonling roofstoragevessels, aGroup I storage vessel that is part ofan existing source shall be in compliance with §63.646(a) through (I) 

### ofthis subpart
no laterthan August 18, 1998. An 

### owner oroperatormay electto comply with §63.646(m) ofthis subpalt instead of§63.646(a) through (I) ofthis subpart. (ii) Existing

## GA group 1 floating roofstorage vessels that is p rt 

### f an existing SOUll: 

### shall be in compliance with §63.646(a) through (I) ofthis subpart at the first degassing and cleaning activity afterAugust 18, 1998, orAugust 18,2005, whichever is first. An
owneroroperator may electto comply with *63.646(m) ofthis subpart instead of §63.646(a) 

### through (I) 

### orthis subpal1. (iii) All**G~oup** 

### 1 storage vessels that are paltofan existing source shall complvee-ffi oompliofH!C 

### with §63.646(m) ofthis subpart instead of§63.646(al throQgh (I) 

### orlhis 'lib art no later than [INSERT DATE 36 MO THS FROM DATE OF 

### PUBLICATIO;,,!]. 2. Overlap provisions for storage vessels in §63.640(n). Webelieve the following revisions are needed to§63.640(n) in order to clearly and properly reflect the intent as indicated in the preamble and to correct editorial errors.

• (n)(I), (0)(3), & 

### (n)(4) Consolidating the overlap provisions for Group 2 tanks and NSPS SUbpCll1 

### Kb (Kb) into (n)(3) & 

### (n)(4), and additionally addressing overlap ofGroup 2 tanks and Part 6/ subpa11 Y (61 Y) in (n)(3).

• (n)(I) & 

### (n)(2) Separating new sources from existing sources in the overlap provisions for Group I tanks and either Kb or6 I Y. with existing sources addressed in (n)(I) and
new sources in (n}(2).

• (n)(I) Stipulating that, when opting to comply with subpart WW in lieu ofKb or 61 Y for an internal floating roofstorage vessel at an existing source, the deck fitting requirements of§63.1 063(a)(2) are required. While §63.646(m)(2) exempts internal floating roofstorage vessels at existing facilities from these requirements, these controls
are requiredby Kb and 

### by 61 Y, and thus sllfll11d he requireci in the: event ofoverll'lp with eitherofthose rules.

• (n)(3) Adding overlap with 61 Y to this provision for overlap ofGroup 2 tanks and Kb.

• (n)(3) & 

### (n}(4) Deleting the reference to new sources, thereby rendering these provisions applicable to both new and existing sources.We suggest the following spedfie revisions to the text in the posted rule to accomplish these changes. Note that §63.640(n)(3) and (4) were notrevised in these amendments. (n) Overlap ofsubpat1 CC with other regulations for storagevessels. As applicable, paragraphs (11)( I), (n)(3), (n)(4), (n)(6), and (n)(7) ofthis section apply for Group 2 storage vessels and paragraphs (11)( I), (n)(2) and (n)(5) ofthis section apply for Group I storage vessels. (I) After the compliance dates specified in paragraph (h) ofthis section, 

### aGroup

### 1-2- storage vessel that is pal1 

### ofan existing source and is also subject to the provisions 

### of 40 efR pa11 60, subpart Kb and/or_4Q.['FR part G

..h.subO;lrl Y, is required 10 comply only with the requirements 

### of40 CFR part 60, subpal1 Kb, except as provided in paragraph (n)(8) ofthis section: 40 FR pm1 6I,

.ubpart 'l.:X 'cpl as pro ld d in paragraph (n)( I0) 

### ofthis 

### sc '!iQ!h.Qf**lhL~~ubpaI1** cept that \i(13.1063{a)(2} doc. appl\ 10 illl 1Il!,1 flo. ling roofslurag

.**V~** •·Is. (2) After the compliance dates specified 

### in paragraph (h) ofthis section, a Group 1 storag<:: vessellhal 

### is 121!.n ofa new. 

### U1ce and i. also subject to 40 CFR part 

### 60, subpart Kb and/or 40 CFR part 61, subpartY is required to comply only with 40 CFR part 60, subpart Kb except as provided in paragraph (n)(8) ofthis section; 40 CFRpart

### 6I, subpal1 Y except as provided in paragraph (n)(IO) ofthis section; or this subpart. (3) After the compliance dates specified in paragraph (h) ofthis section, a Group 2 storage vessel that isj*H+-o!'a new**!;o~ree** 

### emu i**!i!.ll~)** subject to the control requirements in**~60.1** 12b of40 CFR P8J1 60. subpart Kb and/or §61 271 01"40 FR part 61

. .'ubpart Y is required (0 comply only with 40 CFR part 60, subpart Kb except as provided in paragraph (n)(8) ofthis section or40 erR part 61. subpi.ll1 Y except as provided 

### in paragraph (n)( 10) ofthis section. (4) After the compliance dates specified in paragraph (h) ofthis section, a Group 2 storage vessel that is pAfl ofa flew**:;II~ree** and i!ialso subject to 40 CFR 60.11 Db, but is not required to apply controls by 40 CPR 60.11 Db or 60.1l2b is required to comply only with this subpal1, 

### 3. Deckfitting controlsforinternal floating roofs.
The IUle requires, as it always has, the control ofdeck fittings for floating roofstorage vessels at ne\\; sources (the lUle now refers to Part 63 subpart WW rather than to Pal1 63 subpart G for the specific requiremcnts, but the requirements in these two IUles arc substantially equivalent). The understood intent ofthc lule is to exempt internal floating roofstorage vessels at existing sources ii·om the requirement for controlled deck fittings, but to require these controls at new sources_ The new language. however, inexplicably exempts internal floating roofstorage vessels at new
sources from the requirement to control the deck fittings tor slotted and unslottcd guidepoles.This would seem to be an oversight, which would be corrected by striking the last sentence in paragraph *63.646(m)(2). §63.646(O1)(2) Forpurposes ofthis subpart, §63.1063(a)(2) does not apply to internal floating roofstorage vessels at existing sources subject to this subpa11. ror purpo:>e:;

# or**tlt¥.;·s-ul·}fh'tfl.-.-§~·q'()6J{a)(2)(** ...ji) and (viii) do not 'apply to**.j.~ffiaHloating** fOOfstarage vesE.els ilt flew :;OllrCO:i subjecllO thi:; :;ullpill1. 

### 4. MA(:T reporting paradigm for overlap with Part 61 subpart Y.
Thc MACT lule requires rcporting ofinspection**r~sults** only ifan inspection failure has been observed, and allow for these rep0l1s to be gathered into semi-annual periodic repol1S. The overlap provisions 

### allow this same reporting paradigm to be applied to other rules that apply to the same emission points (consistent with EPA's Rccordkeeping and Rcp0l1ing Burden Reduction Rule ofFebruary 12. 1999). The new language. however, applies this paradigm only to failed seal gap measurements, and not to other inspection failures. This would seem to be 

### an oversight, which would be cOiTected by editing paragraph §63.640(n)(lO) as follows. §63.640(n)(

### I0) Storage vessels described by paragraph' (n)( 

### I), (n)(2). 

### and (11)(3) electing to comply with 40 CFR pal1 61, subpart Y shall comply with subpart Y except as provided for in paragraphs (n)(10)(i) through (n)(IO)(vii) ofthis section.



## ****** (v) Owners and operators ofstorage vessels complying with subpartY ofpart 61 may submit the inspection reports required by 40 CFR 61.275(a), (b)(l), and (d) as part ofthe periodic repo11s required by this subpart, rather than within the 60-day period specified in 40 CFR**61.275(a)~ftAJ** (b)(I) and (d). (vi) The repol1s of

### rim tical-inspections specified in 40 CFR 61.275{21

.....

### !l>.llJJ, and (d) are 

### nOl required**if~all** orthe 

### nbSCJ ted c ndlti 

### I1S meet 

## *hnea !:!;ufl Hrefl!i I:!Jicced the 

### rcquiremcntsJimitlllions spectlied in 40 CFR 61.272(a} 

### or (b 

### as li!1plicClolc. Documentation ofthe inspections shall be recorded as specified 

### in 40 

### eFR 61.276(a). 

### 5. Clarify the §63.641 definition ofheat exchange system. We believe four clarifications, as follows. are needed to make the definition consistent with the way such systems exist in refineries, the monitoring requirements, theproposal and the final amendment preamble.

• Unlike the proposed definition. the discussion in the preamble to the final amendments, and the precedents set in othercooling tower monitoring rules. the second sentence ofthc heal exchange system definition defines "heat exchange system" proscriptively for recirculating systems and precludes critical flexibility. According to the preamble to the final amendments,

..... 

### ifthe cooling tower oronce-through system services multiple heat exdumgers. the owner or operatormay elect to monitor only the heat exchangers "inorganic HAP service" or monitor at branch points that combine several heat exchanger cxit lines. ormonitorat the combined stream for the entire system. ,'j However, the final definition specifies that for 

### acooling tower system there is only onc heat exchange system made up ofall exchangers serving tJlat cooling tower. This would preclude monitoring at branch points that combine several heat exchanger exit lines. This grouping flexibility 

### is clitical. since cooling towers often sClvice multiple proccss units, have multiple return lines and service many exchangers that are not "in organic HAP service" and would havc been provided had the proposed heat exchange definition been finalized. Furthennore, the §63.654(b) monitoring exemption language presumes this Jlcxibilit)' 

### and is mude unusable ifthere is only II single heat exchange system for each cooling lower. Thus, the wording ofthe second sentence should be reviSI.:d to allow such grouping.

• Including the cooling tower in the heatexchange systemdefinition was not proposed and is confusing. It further suggests that heal exchangers cannot be subgrouped for monitoring purposes. Furthennorc, since there may be many heat cxchange systems associated with 

### asingle cooling tower, it is unclear where the cooling tower would be assigned. Since including the cooling tower is noteriticalto the definition or to the monitoring requirements, we suggest it be deleted.

• The usc ofthe word "series" 

### in the first sentence ofthe definition could result in the misl<lkt:n impression that heatexchangers must be 31l111lgcd in series, as opposed to being an'angcd in parallel. This unintended conclusion would be avoided ifthe word "colleclion" were used.

• In the third sentence, Ihe delinitioll ofhcat exchange systemdescribes <l once-through sysLem as "servicing an individual process unit:' However, if

### a once-tlu'ough systcm services more than one process unit. liS they often do, it is still a once-through system. Thc ddinition should be cditcd so as 1I0t to inappropriatdy limit the definition of

### aonccthrough system. We suggcSllhc lollowing spedlie rcvisions to the text in rhe posted mil..' to accomplish these changes. Heal exchange system means 

### adevice orcollecllonst'+ieH ofdevices used to transfer heat 

### from process fluids to water without intentional direct contact orthe process fluid with tlw Wille:r**(i.t~.,** non-contact heat exchanger) and Lo transport and/orcool the water in 

### a closed-loop**recircul~tion** system (cooling tower system) or aonce-through system (e.g., river orpond water). Forclosed-loop recirculation systems,!!H:rt! heat exchange syslem consists of**.l-t;.eH-I.jng-l{)\~U** one or mure heat exchangers that arc serviced by that cooling lower, ltnd all water lines 10 and from the heal exchanger(s). Foronce-

, I';'g.: 21 "rlhe final rul..:**a~** P'-"lCU nlllhe IiI'A ITN r&.o**\\'eh~itc.**through systems, the heat exchange system consists ofone or more heat exchangers servicing aflonc ormore individual process unit,2 and all water lines Lo and from the heat exchanger(s). Intentional direct contact with process fluids results in the formation of

### a wastewater. 

### 6. Clarify the intent with I'cspect to monitoring the inletconcentration ofonce-through heat exchange systems. Paragraph**~63,654(c)(** 1) provides for monitoring the fresh water feed line ofonce-through heat exchangc systcms in orderto dctcnnine the total strippable VOC concentration priorto the heat exchange system. This is presumably for the purpose ofdetermining how much ofthe exit concentration is attributable to leaks in the heatexchange system as opposed to having already been in 

### the feed water. This intent should be 

### clarified by editing paragraph §63.654(c)(2) as follows.



### 7. Clarify that §63.654(e) is applicable to once-through heat exchange systems. Paragraph §63.654(e) provides for monitoring individual heat exchangers orgroups ofheM exchangers to verify whetherornot there is a leak from a heat exchangerin organic HAP service. The intent is undoubtedly to allow this additional monitoring for once-through systems as weIl as forcooling towers. The wording should be revised to clarify this intent, as shown 

### below, (c) lrthe owneroroperator detects l:Ilcak when monitoring acooling tower return line.Qf hcat 'xchangcl' cxitlilw underpcuagraph (c)(l) ofthis section, the owner or operator may conduct additional monitoring to identify leaks oftotal strippable VOC emissions using Modified EI Paso method from each heat exchangerorgroup ofheat exchangers in organic HAP service associated with the heat exchange system for whieh the leak was detected. Ifthe additional monitoring shows that the total strippable VOC concentration in the stripped air at the heat exchanger exit line for eaeh heat exchangerin organic HAP service is less than 6.2 ppmv for existing sources or less than 3.\ ppmv for new sources, the heat exchange system is excluded from repairrequirements in paragraph (d) ofthis section.

### 8. Clarif)' in §63.654(g) thatcooling watel' flow rate is to be determined by 

### engineering analysis, The preamble expressly slates thai EPA docs not require acontinuous now monitorfor measuring flow rate, but rather expects the flow ratc (0 be based on "pump curves, heal balance calculations, or otherengineering methods." The wording in §63,654(g) should be revised to c1mify this intent. (g) To delay the repair under"paragraph (f) ofthis section, the owneroroperatormust record the infonnation in paragraphs (g)(I) through (g)(4) ofthis section.

(4) An estimate ofthe potential emissions frolll the leaking heat exchange system orheat exchanger following the procedures in paragraphs (g)(4)(i) and (g)(4)(ii) ofIhis section. (i) Detenninc the total sHippable VOC concentration in the cooling water, in palts per million by weight (ppmw), using equation 

### 7-1 from Modified 

### EI Paso method (incorporated by reference in §63.14), based on the total strippable concentration in the stripped air, ppmv. from monitoring. (ii) Calculate the VOC emissions fm the leaking heatexchange system orheat cxchanger by multiplying the VOC concentration in the cooling water

.. ppmw, by the flow rate of the cooling water from the leaking towcr or heat exchangerand hy the expected duration ofthe delay. The now mlC n1:lY he ha!'iecl all pump CUlVCS, hCll! halance calculations, or (llhel"**engill(~cri]]g** methods. 

### 9. Correct the citation in the "reference control technology for storage vessels" definition. The rim scall'cquircmcnts for 

### An external floating roofconvcI1ed to an intemal floating roof im:olTcctly cite the provisions for an cxternal floating 

### roof. Once converted to an internal floating roof. the storage vessel should be subject to the requirements for internal floating roof storage vessels. This is con·ccted 

### hy changing the reference to read §63.1 063(a)(

### I)(i) ratherthan 

### §63.!063(,)(! 

### )('0. RcJcrence eonlrollcchnology for storage vessels means either: (a) ForGroup I storage vessels complying with §63.646(m): ( r) An imemal floating roofmeeting the specifications of§§63.1 063(a)(I)(i) and (b) of subpIH1 WW: (2) An cxtemal floating roorml.'Cting the specifications of§63.1 063(a)(I)(ii), (a)(2). and (h) ofsubpart WW; (3) An external floating roofconverted to an internal floating roofmeeting the specifications or§63.1 063(a)(I

### )WW and (b): orJ

### O. Correctthe citation to a 

### nonexistent paragraph in §63.654(f). Paragraph 

### (I) of§63.654 refers to paragraph (f)(3), but there is no paragraph (t)(3). This requires two corrections, as follows. 

### §63.654 Heat exchange systems. 

# "'.*.** «() The owner or operatormay delay the repair ofa leaking heat exchanger**~hen** one 

### of the conditions in paragraphs (f)(l) and**(t){2H~b.tl1{4)** ofthis section is met. The
owneror operator must detennine ifa delay ofrepair is necessary as soon as practicable, but no later than 45 days after first identifying the leak. (I) Ifthc repair is technically infeasible without 

### a shutdown and the total strippable VOl" concentration (flS methane) is initially and remains less than 62 ppmv for all monthly monitoring periods during the delay 

### ofrepair, the owner oroperatormay delay repair until the next sclu;dulcd shutdown ofthe heal exchange system. 

### If, during subsequent monthly monitoring, the total strippable VOC concentration (as methane) is 62 ppmv oj' greater. the owner oroperatormust repairthe leak within 30 days ofthe monitOl;ng event in which the leak was equal to or exceeded 62 ppmv total strippable VOC (as methane). e](cepl AS**pl"O'"jd~d** iA fHlrugraph (l)(3) oflhi:; seetion. 11. 

### COI"reefthe subpart reference in the Table 4 heading. Table 4 pertains to overlap with the Gasoline Distribution MACT rule, which is part 63 subpart R. The heading for the Reference should read "subpart R" ratherthan "subpart Y. 12. 

### Correctthe subscripts in the Table 7 

### Title. The subscripts on the variables are shown as upper case in the title, but as lower case in the table itself. The title should be con-ected as follows.
TABLE 7-FRACTION MEASURED

## t+: 1frLII}' FRACTION EMITTED 

### f-F 

### KLJ, AND 1>1

. ,. FRACTION REMOVED 

### tRBIId FOR HAP COMPOUNDS IN WASTEWATER STREAMS 12. 

### Correctthe citation errorin §63.655(g)(2)(i)(B). Pnragraph 63.655(g)(2)(i)(B) should reference (g)(2)(i)(B)(l) not (g)(2)(ii)(B)(l). 

### 13. Correct the incomplete and incol"rect citations in §63.6SS(g)(S). Paragraph 63.655(g)(5) should reference "(g)(5)(i) through (g)(5)(iij), as applicable' instead of "(g)(4)(i) through (g)(4)(iii), as applicable." Paragraph 63.655(g)(5)(i) should reference "(g)(5)(i)(A) and (g)(5)(i)(B)" rather than "(g)(4)(i)(A) and 

### (g)(4)(i)(B)."'

### 14. Correctthe location ofthe quotation mark in the note in Table 6for §63.8(c)(4). The quotation mark after the word rather in this note appears to be misplaced and should be moved to after the word hour, as follows. Except SubpartCC specifies themonitoring cycle frequency specified in §63.8(c)(4)(ii) is "once every hour: rather!2- than "foreach successive IS-minute period." 

### 15. Correctthe note for**~63.l0(b)(1)** 

### in Table 6. The note 

### in Table 6 for §63.IO(b)(l) mistakenly references §63.644(d) and this shouldbe corrected to §63.655(e). Please let us know ifyou have any questions or

### ifwe can amplify on any ofthese comments. Sincerely,

Matthew Todd API toddm@api.org (202) 682-8319 David Friedman 

### NPRA dfriedman@npra.org (202) 552-8461

cc R. 

### B. Lucas US EPA Office ofAirQuality Planning and Standards Mail Drop E143-01 Research Triangle Park, NC 27711 lucas.bob@epa.gov