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

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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 of the 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 of the issues contained in that letter, which is attached. In addition, API seeks to have

EPA reconsider the application of the 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 for judicial review), and if such objections are

of central relevance to the outcome of the rule, EPA is authorized to reconsider the rule. As we stated

in our previous submissions, these issues were identified after the 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 of the refining industry to comply.

Thank you for your consideration of these issues. If you 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 equal opportunity employer
April 7, 2009

Mr. K. C. Hustvedt

US EPA

Office of Air Quality 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 of Air and Radiation Policy and Guidance Website on

January 16, 2009. We believe therc are .some clarifications and corrections that could make the

lUle clearer and consistent with 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 order to 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 tor consistency 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, rather than to the individual

storage vcssel or heat 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 trigger date

for new constlUction under the original rule was July 14, 1994. August 18, 1995 was the

date oflule promulgation, but applicability was based on thc proposal date.

• (h)(2) Adding a paragraph 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 impoltant point need to be made clear in

§63.640(h) as well as in §63.646(a).

We suggest the following specific revisions to the text in the posted rule to accomplish these

changes.

(I) Except as provided in paragraphs (h)( I)(i) aOOthr~:)Ugh (iv) ofthis section, new

sources that commence construction or reconstruction after July 14, 1994, shall be in

compliance with this subpart upon initial startup or August 18, 1995, whichever is later.

(i) Sltll'Age \ esseIs aAt I! new sourCe5 that commenceg construction or reconstruction

after Ll!!ill. I<)c)4Augu'it J X. 1995, bUI before September 4,2007, 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 later than [INSERT DATE 36 MONTHS

AFTER DATE OF PUBLICATION].

(ii) Heal exch<'lI1ge s)'S'.eID!i aAt!! new sourc~ that commenceQ construction or

reeonsttuction after July 14. 1994-Augu~-199~, but before September 4,2007, heal

exchange svstel1l~ shall comply with the existing source requirements for heat exchange

systems specified in *63.654 no later than [INSERT DATE 36 :YlONTHS AFTER

DATE OF PUBLICATION)

(iii) ~ltllilga ...c';se!s aAt !l new source" that commence~ construction or reconstruclion

after September 4, 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 September 4, 2007, J1Cal exchange systems shall be in compliance

with the new source requirements 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) ofsubpart A of this part, or unless 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 palt of an existing source shall be in compliance

with §63.646 as specified in paragraphs (h)(4)(i) through (h)(4)(iii).

(i) Except for existing flonling roofstorage vessels, a Group I storage vessel that is part

of an existing source shall be in compliance with §63.646(a) through (I) ofthis subpart

no later than August 18, 1998. An owner or operator may elect to 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 after August 18, 1998, or August 18,2005, whichever is first. An

owner or operator may elect to comply with *63.646(m) ofthis subpart instead of

§63.646(a) through (I) or this subpal1.

(iii) All G~oup 1 storage vessels that are palt of an 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).

We believe 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 or 6 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 required by Kb and by 61 Y, and thus sllfll11d he requireci in the: event of overll'lp with

either of those 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 not revised in these amendments.

(n) Overlap ofsubpat1 CC with other regulations for storage vessels. 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) of this section apply for Group I

storage vessels.

(I) After the compliance dates specified in paragraph (h) ofthis section, a Group 1-2-

storage vessel that is pal1 of an 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 of 40 CFR part 60, subpal1 Kb, except as provided in

paragraph (n)( 8) ofthis section: 40 FR pm1 6 I, . 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 of a new. U1ce and i. also subject to 40 CFR part 60, subpart

Kb and/or 40 CFR part 61, subpart Y is required to comply only with 40 CFR part 60,

subpart Kb except as provided in paragraph (n)(8) ofthis section; 40 CFR part 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 is j*H+-o!' a new !;o~ree emu i !i!.ll~) subject to the control requirements

in ~60.1 12b of 40 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 or 40 erR part 61. subpi.ll1 Y except as provided in

paragraph (n)( 10) of this section.

(4) After the compliance dates specified in paragraph (h) ofthis section, a Group 2

storage vessel that is pAfl of a 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. Deck fitting controls for internal floating roofs.

The IUle requires, as it always has, the control of deck 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 of thc 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) For purposes 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.~ffiaHloatingfOOfstarage

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 if an 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 of February 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 subpart Y of part 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 ofrim 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 rcqui remcntsJimitlllions 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 of heat 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, the proposal and the final

amendment preamble.

• Unlike the proposed definition. the discussion in the preamble to the final amendments,

and the precedents set in other cooling 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 or once-through system services multiple heat

exdumgers. the owner or operator may elect to monitor only the heat exchangers "in
organic HAP service" or monitor at branch points that combine several heat exchanger

cxit lines. or monitor at the combined stream for the entire system. ,'j However, the final

definition specifies that for a cooling tower system there is only onc heat exchange

system made up of all 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 heat exchange system definition 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 a single cooling tower, it is unclear where the cooling tower would be

assigned. Since including the cooling tower is not eriticalto 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 heat exchangers 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 system describes <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 a onccthrough system.

We suggcSllhc lollowing sped lie rcvisions to the text in rhe posted mil..' to accomplish these

changes.

Heal exchange system means a device or collecllonst'+ieH of devices 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/or cool the water

in a closed-loop recircul~tion system (cooling tower system) or a once-through system

(e.g., river or pond water). For closed-loop recirculation systems,!!H:rt! heat exchange

syslem consists of .l-t;.eH-I.jng-l{)\~Uone or mure heat exchangers that arc serviced by

that cooling lower, ltnd all water lines 10 and from the heal exchanger(s). For once-

, I';'g.: 21 "rlhe final rul..: a~ P'-"lCU nlllhe IiI'A ITN r&.o \\'eh~itc.
through systems, the heat exchange system consists of one or more heat exchangers

servicing aflonc or more 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 inlet concentration of once-through

heat exchange systems.

Paragraph ~63,654(c)( 1) provides for monitoring the fresh water feed line of once-through heat

exchangc systcms in order to dctcnnine the total strippable VOC concentration prior to the heat

exchange system. This is presumably for the purpose of determining how much of the exit

concentration is attributable to leaks in the heat exchange 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 or groups of heM

exchangers to verify whether or not there is a leak from a heat exchanger in organic HAP

service. The intent is undoubtedly to allow this additional monitoring for once-through systems

as weIl as for cooling towers. The wording should be revised to clarify this intent, as shown

below,

(c) lrthe owner or operator detects l:Ilcak when monitoring a cooling tower return line.Qf

hcat 'xchangcl' cxitlilw under pcuagraph (c)(l) of this section, the owner or operator may

conduct additional monitoring to identify leaks of total strippable VOC emissions using

Modified EI Paso method from each heat exchanger or group of heat 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 exchanger in 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 repair requirements in paragraph (d) ofthis

section.
8. Clarif)' in §63.654(g) that cooling watel' flow rate is to be determined by engineering

analysis,

The preamble expressly slates thai EPA docs not require a continuous now monitor for

measuring flow rate, but rather expects the flow ratc (0 be based on "pump curves, heal balance

calculations, or other engineering 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 owner or operator must

record the infonnation in paragraphs (g)(I) through (g)(4) of this section.

(4) An estimate ofthe potential emissions frolll the leaking heat exchange system or heat

exchanger following the procedures in paragraphs (g)(4)(i) and (g)(4)(ii) of Ihis 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 heat exchange system or heat 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 exchanger and 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 roof convcI1ed 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) rather than

§63.! 063(,)(! )('0.

RcJcrence eonlrollcchnology for storage vessels means either:

(a) For Group I storage vessels complying with §63.646(m):

( r) An imemal floating roof meeting the specifications of §§63.1 063(a)( I)(i) and (b) of

subpIH1 WW:

(2) An cxtemal floating roor ml.'Cting the specifications of §63.1 063(a)( I)(ii), (a)(2). and

(h) ofsubpart WW;

(3) An external floating roof converted to an internal floating roof meeting the

specifications or §63.1 063(a)( I)WW and (b): or
JO. Correct the 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 operator may delay the repair of a leaking heat exchanger ~hen one of

the conditions in paragraphs (f)(l) and (t){2H~b.tl1{4) of this section is met. The

owner or operator must detennine if a delay of repair 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 of repair, the owner or operator may delay

repair until the nex t sclu;dulcd shutdown of the heal exchange system. If, during

subsequent monthly monitoring, the total strippable VOC concentration (as methane) is

62 ppmv oj' greater. the owner or operator must repair the 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"reef the 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" rather than "subpart Y.

12. Correct the 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. Correct the citation error in §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 63.65 5(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. Correct the location of the quotation mark in the note in Table 6 for §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 Subpart CC specifies the monitoring cycle frequency specified in §63.8(c)(4)(ii)

is "once every hour: rather!2- than "for each successive IS-minute period."

15. Correct the 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 should be

corrected to §63.655(e).

Please let us know if you have any questions or if we 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 ofAir Quality Planning and Standards

Mail Drop E143-01

Research Triangle Park, NC 27711

lucas.bob@epa.gov