P.1 

OAR Box 1147 

Prepped by Ollie Stewart 

Document Number: 

188) IV-E-62 

Docket Number: 

A-87-11 

Printed 4/22/2008 2:42:57 PM Sheet 188 of 242 
P.2 

r \ 

- A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

June 7, 1988 

MEMORANDUM 

SUBJECT: 

FROM: 

TO: 

Meetings with Exxon and Shell ,.,/ . 

Charles L. Gray, Jr., Director /Jc-^ 

Emission Control Technology Division 

The Record 

/v 

On May 12, 1988 EPA staff met with Exxon personnel and on 

May 13, 1988 with Shell personnel to discuss several topics of 

mutual interest. The agendas and lists of attendees are 

attached. Other handouts provided by Exxon are also attached. 

The discussions followed the agenda fairly well. EPA 

staff expressed concern about the continued presence of a lower 

retail price for lead gasoline, even though wholesale prices 

are higher. Both oil companies felt that an EPA ban on leaded 

fuel was the most direct way to resolve the problem associated 

with leaded fuel. 

Attachments 
P.3 

MAY 11 '88 09:13 EPA FOSD P.2 

Attendees, May 13 Meeting: (.EPA/ShejJ, 

9:00 a.m. - 12:30 p.m. 

Conference Room 15^9 

One Shell Plaza 

900 Louisiana Street 

Houston, Texas 

713-241-3902 

fraC 

" Ron Benton 

"'Don Bennett 

""Jerry Berger 

^ i m Bonfn 

^Bil l But in 

<^Gary Di 1 lard 

s Ron Klenle 

iy 

Kl^rye^- K1 e i n 

Ray Lopez 

</ Klaus Mai 

Steve Mi 1ler 

Bill Schutzenhofer 

Manager, Plans & Integration 

Products 

Manager. Refining^ Marketing 

Operations, Gasoline 

Manager, Regulatory Affairs 

Washington, DC 

Manager, Plans & Integration 

Health, Safety & Environment 

Manager, Plans & Integration 

Vice President, Public Affairs 

Manager, Environmental Affairs 

Health, Safety & Environment 

Director. Refining & Marketing 

Research & Development 

Vice President, Manufacturing 

£• Technical 

Vice President, Health, Safety 

& Envi ronment 

General Manager, Eastern Region 

Refining & Marketing 

General Manager, Refining & 

Marketing 

ft phi 1 Carrol 1 

* Chuck Wi1 son 

/\ r it '~ ' > ' 

Senior Vice President 

Admini stration 

Vice President 

Refining & Marketing 

\J<P. c / /\ Zsr~ 1 C J 6.A %. 

* Might joi n us fo r lunc h and wrap-up . 
P.4 

ftPR-lS-'Sa 10:43 ID'.SHELL OIL CQ IdfiSH DC TEL NO:202-S59-2211 S260 P02 

DRAFT 

RECEIVED 

APR 14 1388 I 

SHELL-OIL COMPANY 

•W.«SH«fV;T0«,0.C OFFICE 

* •' 1 M.lnL.iwJ V-»^Wpff^»^||>i| i 

TOPICS FGR DISCUSSION UITH REFINERS . 

1. Discussion ot Lead Phasedown Issues 

- When will leaded gas be pnasea out? 

- Will phaseout be on a refinery-by-rerinery oasis? 

- Where will leaded gas be pnasea out? 

- What are reriners' pians, ir any, ror non-iead 

alternatives? 

- Will there be trade agreements xor marketing leaded? 

- Will "little guys" rill the market void to sell ieadeo gas? 

- is leaded gas being used as a loss leader? Will this 

intensify as it becomes a smaller voiume product? 

- Is unleaded regular th© "righting grade" on which price 

decisions are made? * "%• 

- What happened to reriners who trieo to pnase out jsaoed 

gas? Wny are they oack in many markets? 

- What is refiner reaction to a possible requirement 

for a minimum lead content level tor each gallon? 

- Would refiner market lead-in-a-can type products at their 

retail facilities? 

- What does reriner expect the market penetration OT 

alcohol fuels to oe? 

- What is reriner doing with regard to the "octane race". 

and how will this affect total rue) supplies; 

- What octane mixes will ultimately oecome avaiiaoie? 

- What do-these mixes bode for cost/availabl11ty of 

gasoline? 

2. Discussion or Volatility Issues 

- What is EPA's status on the proposed rules? 

- What is happening with regard to the safety issues 

concerning on-board technology? 

- What are EPA's and refiner's views on regional 

strategies? 

- What are EPA's and reriner's views on proposed 

enforcement techniques including screening 

tests? 

- What are the pians to oeal with possible variances 

in RVP requirements ror some alconoi fuels? 

3. Discussion of Diesei/5uiier Issues 

- What is lha EhM status on proposta ruie-s? 

- what are the reriner's views on the control or 

aromatlcs : 

- what are the views on possible smait reriner 

legislation: 
P.5 

HrK-iD-'b o li_*:- H lu:bricL L Ul L <_U Wne n U<- I =.t_ NU:iUi-cj;-^i l T-..-**:OT*J rtJ , 

DRAFT 

Discussion of Oxygenated Fuels Strategies 

. - What has been the result of the Denver program so rar'r 

- What would be the effect of the proposed 1% RVP exemptlc 

on the effectiveness of oxygenated fuels strategies 

- What areas is EPA looking at now for an oxygenated 

fuel strategy? What areas are local governments 

interested in? 

- How does tho efficacy of this technique change as 

more of the newer technology vehicles appear on 

the road? 

- What new waiver requests does EPA anticipate? 

- What is the reaction to the new stuay relating ozone anc 

CO emissions as they botn vary with oxygenated 

fuels? 

- What plans does the refiner nave to use oxygenat-Bd ryeiz 

- for octane? 

- in AQCDs with oxygenated fuel plans? 

- in areas without such plans? 
P.6 

AGENDA 

EXXON - EPA MEETING 

MAY 12, 1988 

• Introductory Comments 

• Gasoline Refuelinq 

- Review of EPA and Exxon work on canister safety 

- Analysis of onboard vs. Stage II cost-effectiveness 

• Gasoline Volatility 

- EPA's proposed enforcement approach 

- RVP treatment of oxygenate blends 

- Consumer effects of deep cuts in RVP 

• Diesel Sulfur 

- Effects of diesel sulfur and aromatic content on particulates 

- Outlook for particulate standards 

- Perspective on methanol replacement 

• Oxygenated Fuels 

- State oxygenate mandates 

- Methanol economics 

- CO reduction and ozone impact 

• Lead Phasedown 

- Exxon perspective on EPA questions 

• "Clean Air" Issues 

- Post-1987 nonattainment strategy/Clean Air Act Amendment 

• Joint Summary and Wrap-up 
P.7 

Exxon Participants 

EPA Mating. Mav 1?. 1988 

Joe T. McMillan 

Edward T. D1Core1a 

Harry T. Gibson 

Julienne M. Burton 

Raymond J. Campion 

William R. Finger 

Robert F. Haase 

Thomas H. Howard 

Bornard J. Kraus 

Michael C. Quinn 

Hugh F. Shannon 

Sr. Vice President, Downstream Business 

Exxon Company, U.S.A. 

Vice President, Refining Oept. 

Environmental Manager, Refining Oept. 

Attorney, Refining, Environment, and Health Law 

Environmental Conservation Advisor * air issues, 

vehicle and fuel effects 

Energy Analysis Coordinator - methanol economics 

Marketing Distribution Programs Coordinator • 

logistics and regulatory compliance 

Refining Technical Advisor - gasoline volatility, 

diese! sulfur 

Engineering Associate, Exxon Research and 

Engineering Company • diesel fuel/emission studies 

Consumer and Regulatory Affairs Manager, 

Marketing Oept. - Stage II oxygenated fuels 

Sr. Scientific Advisor, Exxon Research and 

Engineering Company - vehicle emission control, 

gasoline composition 

fc* ^esrk'x'y ll-f MtJyf^^ 
3.5 

1 

9 2.5 

8 

7 

2 

D 

0 

L 1.5 

L 

A 

R i 

S 

0.5 

EQUIVALENT MOTOR GASOLINE 

COST PER GALLON 

PUMP PRICE (EX TAX) 

S36/BBL 118/BBL 

$2.34 

RET 

LOGIST 

NET CST 

FEED 

$3.31 

RET 

LOGIST 

NET CST 

FEED 

o Logistics 

Base - post-1980 average 

- Gas - volume effect • upgrade 

Coal - volume effect + upgrade 

o Term - 1987 GC spot P/L term average 

o Coal & gas plant - DOE alternate 

transportation fuels study report Sl 

o Fuel - DOE alternate transportation 

fuels study report KI 

$3.31 

$1.89 

$1.30 

LOGIST 

TERM 

RET 

LOGIST 

NET CST 

FEED 

RET 

LOGIST 

NET CST 

FEED 

GAS COAL 

METHANOL---

MOGAS GAS COAL 

METHANOL 

SOURCE 

EPAMEFCS.TRN 

$ .86 

LOGIST 

TERM 

MOGAS 

4-14-8 8 JPJ 

00 
3.5 -

1 3 

9 

j 2.5 

D

 2 

0 

L 

L

 1.5 

A 

R 

S l 

0.5 

$2.50 

RET 

LOGIST 

NET CST 

FEED 

S36/BBL 

$3.57 

EQUIVALENT DIESEL 

COST PER GALLON 

PUMP PRICE (EX TAX) 

RET 

LOGIST 

NET CST 

FEED 

o Logistics 

Base - post-1980 average 

Gas - volume effect + upgrade 

- Coal - volume effect + upgrade 

o Term - 1987 GC spot P/L term average 

o Coal & gas plant - DOE alternate 

transportation fuels study report HI 

o Fuel - DOE alternate transportation 

fuels study report ttl 

S18/BBL 

$3.57 

$2.01 

$1.30 

LOGIST 

TERM 

RET 

LOGIST 

NET CST 

FEED 

RET 

LOGIST 

*ET CST 

FEED 

$0.86 

LOGIST 

TERM 

GAS COAL 

-—METHANOL 

DIESEL GAS COAL 

METHANOL 

SOURCE 

DIESEL 

EPAMDICS.TRN 4-14-8 8 JPJ 
DIESEL ENGINE PARTICULATE EMISSION STANDARDS 

• Engine/Fuel Trade Offs 

1994 Compliance 

1991 Compliance 

• Refining Industry Costs 

• Observations 

May 12, 1988 
ENGINE/FUEL TRADEOFFS IMPORTANT TO 

UNDERSTAND COMPLIANCE ISSUES 

0.7 

0.6 

0.5 

PARTICULATES, 

G/BHP HR °- 4 

0.3 

0.2 

0.1 

SOF 

SOOT 

SULFATE 

1988 STD 

MANUFACTURERS 

TARGET RANGE 

1991 STD 

1994 STD 

1988 1991 1994 

YEAR 

•ENGINE MODIFICATIONS REDUCE SOOT AND SOLUBLE ORGANICS (SOF) 

•SULFUR REDUCTION REDUCES SULFATES 

•BENEFITS GREATER FOR SOOT/SOLUBLES REDUCTION 

•AT EQUAL COST ENGINE MODIFICATIONS PREFERABLE TO SULFUR REDUCTION 
1994 COMPLIANCE 

0.16 

0.14 -

0.12 

0.1 

PARTICULATES, 

G/BHP HR 0.08 

0.06 

0.04 

0.02 

1994 STD 

H I MFRS TARGET RANGE 

I S SULFATES 

0.27 0.15 0.05 

FUEL SULFUR, WT.% 

ENGINE MODIFICATION 

0.15 0.05 

TRAP 

•BASED ON CRC STUDY AND ENGINE MAKER PROJECTIONS-SAE 88035 0 

-3-
0.3 

0.25 

0.2 

PARTICULATES, 

G/BHP HR 0.15 

0.1 

0.05 

1991 COMPLIANCE 

• MFRS TARGET RANGE 

1991 STD r^ i 

_____ S i SULFATES 

? 0.27 %S 0.20 %S 

ENGINE MODIFICATION 

•BASED ON CRC STUDY AND ENGINE MAKER PROJECTIONS-SAE 880350 

-4-
REFINING INDUSTRY COSTS 

1.195 

1 2BB-r 

^ 1,08BJ C 

Vt JQ "" ' 

o \ 

<_> e 

- J ? bee-

(O s» 

Z3 . 

£ \ ««-

'__ 

«* 200-

285 245 

Diesel Sulfur (wt%) 

Diesel Aromatics (vol%) 

Incremental Particulate Reduction^) 

(Grams/bhp-hr) 

Incremental Refining Costs(2) 

(Million $/Year) 

Total Refining Costs(2) 

(Million $/Year) 

(^From CRC VE-1, Future Engine Technology 

(2)From 1986 NPRA Survey, U.S. Refining Industry Capability to Manufacture Ultra Low Sulfur Diesel Fuels 

0.27 ----> 

34 ----> 

0.024 

690 

690 

0.15 

33 

0 .15 

33 

> 

> 

0.020 

485 

1,175 

0.05 

32 32 

>0.05 

> 20 

0.010 

1,195 

2,370 
OBSERVATIONS 

General 

• Long-term control strategy needs to be defined clearly before committing significant 

resources (e.g. fuel quality improvements and engine modifications/traps) to meet 1994 

standard. 

• Engine modifications to reduce soot and soluble organic emissions (short of traps) 

provide most cost effective regulatory option. 

+ Preferred approach environmentally. 

+ By mid-90s, 0.10-0.15 grams/bhp-hr emissions likely with current diesel sulfur 

levels. 

1994 Standard 

• Intermediate diesel quality (-0.15 wt% sulfur) appears cost effective if traps needed in 

the base to meet the standard. 

• Superior quality diesel (0.05 wt% sulfur) may be needed if standard reachable without 

trap technology. 

• Particulate traps and superior quality diesel would provide redundant controls. 

• Reduction of diesel aromatics costly, and not an effective control strategy. 

1991 Standard 

• Current diesel quality appears sufficient to meet interim standard. 

-6-
P.16 

ENFORCEMENT OF GASOLINE VOLATILITY LEVELS 

EPA PROPOSAL 

• EPA's proposed enforcement scheme requires compliance with volatility 

regulations at all points in the distribution system. 

- Tightened version of enforcement procedures for unleaded fuel 

regulations. 

- "Vicarious liability" holds the original refiner, blender, or 

importer liable unless the supplier can demonstrate compliance. 

- Effectively requires testing at all points in the distribution 

system to provide defense from liability. 

EXXON POSITION 

• Exxon proposes that enforcement take place at the point of manufacture 

or import. This would achieve the desired goal of reducing vapor 

emissions while providing a more manageable and cost efficient approach 

for both the EPA and gasoline suppliers and marketers. 

- Point of manufacture or import is where gasoline volatility is 

determined. It is the only point in the distribution network where 

the RVP can effectively be controlled. 

- Definition of manufacturer must be expanded to include importers, 

refiners, and blenders. 

- 100% compliance is not critical to overall emission reductions. 

Non-compliance caused by inadequate turnover or stratification would 

be more than offset by the large percentage of locations converted 

well in advance of the compliance date. 

- "Downstream" mixing of finished gasolines will not alter the end 

result of reduced hydrocarbon emissions. 

- Improved testing reliability versus testing at thousands of 

downstream locations. 
TERMINAL TANKAGE COMPLIANCE WITH VOLATILITY SPECIFICATION 

DAY 

1 

EVENT 

18 

25 

32 

First shipment of lower RVP unleaded 

regular motor gasoline leaves Exxon's 

Baton Rouge Refinery on the Plantation 

Pipeline bound for Richmond, Virginia. 

STATUS 

First shipment arrives at Exxon's 

Richmond, Virginia, terminal. 

Second shipment arrives at Richmond. 

Third shipment arrives at Richmond. 

UR Demand = 10 KBD 

Normal pipeline cycle - 7 days 

Normal receipt = 70 KB (10 x 7) 

Inventory prior to receipt: 

+ Safety barrels to allow for 

demand swings or pipeline 

delays = 40 KB 

+ Unavailable tk. bottoms = 14 KB 

Total = 54 KB 

Inventory of higher RVP material as 

percent of total = 44% [54/(70+54)] 

Inventory of higher RVP material as 

percent of total = 19-44% (Depends 

on degree of stratification) 

Inventory of higher RVP material as 

percent of total = 9-44% 

Factors determining status of tank compliance: 

- Safety factor on refinery shipments versus compliance specification 

- Magnitude of RVP reduction required 

- Degree of tank stratification 

Additional factors which can increase time for terminal tankage compliance: 

- Low-volume terminals may skip a cycle (one or more products) 

- Transportation time for first shipment to a terminal can be 30+ days 

(example: Baytown, TX Refinery to Bayway, NJ Refinery via Colonial 

Pipeline; Bayway to Pittsburgh, PA via Buckeye Pipeline; Pittsburgh 

to Westover, WV via barge.) . • 

- Receipt cycle times can vary from 4-30 days. Tanker supplied terminals 

may take receipts only every 30 days. 
P.18 

ENFORCEMENT OF GASOLINE VOLATILITY LEVELS 

ISSUES 

• Assurance of 100% compliance at the retail level is virtually 

infeasible. 

- Variability of shipping/receipt times. 

- Several receipts necessary to facilitate tank conversions. 

- LIFO stratification of gasoline in storage tanks. 

- Inability to empty tanks prior to delivery. 

- Slow turnover at rural locations. 

• Enforcement at any point downstream of the manufacturing point would 

not be cost effective. 

- Virtual certainty of non-compliance product remaining in the system 

will make it difficult to distinguish between innocent and willful 

violations. 

- Inability to correct the RVP downstream of manufacture; alternative 

disposition of non-compliance material; supply disruptions. 

- Costly testing requirements. 

• Detrimental impact of non-compliance with RVP specifications is less 

than non-compliance with lead levels in unleaded gasoline. 

• Issue of how to deter willful violators must be addressed. 

- All manufacturers, including blenders, must be identified and 

registered with EPA. 

- Strict penalties for non-registration; willfully altering product 

quality; knowingly selling/distributing altered product. 

- EPA random sampling program at manufacturing locations; audit of 

compliance testing records. 

- Affidavits to release "innocent" violators from liability; severe 

penalties for falsely signing documents. 

JYD:bjs 

9367o 
GASOHOL MARGIN COMPARISON AT VARIOUS RVP LEVELS 

$ Per Barrel 

Gasohol Required to Meet Mogas RVP Quality 

Unleaded Regular 

Mogas 

Butane 

Ethanol 

Blending Cost 

Tax Credits: 

Federal 

State 

Net Gasohol Cost 

Sales Value 

Margin 

24.07 

(2 .52) 

(0.92) 

20 

21. 

1, 

.63 

.89 

.26 

24.18 

(2.52) 

(0.92) 

20.74 

21.89 

1.15 

24.29 CVJ 

.52) 

(0.92) 

20 

21 

1 

.85 

.89 

.04 

Gasohol Wi 

No RVP Lin 

19.70 

-

4.37 

ith 

l i t 

RVP of Moqas 

Butane at 

Market Value 

20.02 

(0.21) 

4.37 

at 11.5 psi 

Butane at 

Fuel Value 

20.02 

(.10) 

4.37 

RVP 

at 

Bi 

Fu( 

of Mogas 

9.0 DSij ^ 

jtane at 

>1 Value 

20.01 

(.09) 

4.37 

24.29 

(2.52) 

(0.92) 

20.. 85 

21.89 

1.04 

Bases: 

Unleaded Regular Mogas (Piatt's. April 26) - 52.125^!/gal 

Normal Butane to Sales (Piatt's. April 26) - 33.125^/gal 

Normal Butane to Fuel (Foster's Natural Gas Report. April) - $1.30/MBTU 

Fuel Grade Ethanol (Alcohol Update. April 25) - 104^/gal 

Federal Tax Credit on Gasohol - 6^/gal (10% ethanol) 

State Tax Credit on Gasohol (typical - 2.2£/gal) 

_i_B_ 

21.89 

13.91 

6.71 

43.68 

2.52 

0.92 

JPJ:yg 

5/12/88 
REFUELING EMISSIONS 

EXXON RESEARCH & ENGINEERING COMPANY 

PRODUCTS RESEARCH DIVISION 

MAY 12, 1988 
GASOLINE REFUELING 

EXXON/API AND EPA WORK ON CANISTER SAFETY 

- EXXON/API OBJECTIVE IS TO PROVIDE NHTSA WITH DEMONSTRATION 

THAT VEHICLE SYSTEMS MODIFIED TO INCLUDE ONBOARD REFUELING 

CONTROLS MEET SAFETY CRITERIA AND MAINTAIN GOOD EMISSION 

CONTROL 

COST-EFFECTIVENESS OF ONBOARD VS. STAGE II EMISSION CONTROL 

- USING MOST RECENT ECONOMIC DATA ON STAGE II SYSTEM INSTALLATION, AND INFORMATION ON GASOLINE THROUGHPUTS AND OZONE 

NONATTAINMENT AREAS, A REVISED COST-EFFECTIVENESS 

COMPARISON IS BEING MADE FOR USE WITH THE OMB 
SAFETY DEMONSTRATION DEVELOPED WITH HIGH VOLUME DOMESTIC MODELS 

• 1987 BUICK LESABRE 

BASE CAR 

MODIFIED CAR 

CO HC NOx 

(GRAMS/MILE) 

2.07 

1.57 

0.28 

0.27 

0.28 

0.27 

EVAPORATIVE 

(GRAMS/TEST) 

0.58 

0.52 

REFUELING 

(GRAMS/GAL) 

~5 

0.08 

• 1988 FORD TAURUS 

CO HC NOx 

(GRAMS/M IE) 

EVAPORATIVE 

(GRAMS/TEST) 

REFUELING 

(GRAMS/GAL) 

BASE CAR 1.42 0.18 0.40 0.18 ~5 
PRINCIPAL ELEMENTS OF 

ENHANCED ONBOARD SYSTEM 

Standard 

Fillpipe 

With Vent 

Rerouted to 

Canister 

Purged 

HC Vapors 

To Engine 

Opening 

From Tank 

and 

Rollover 

Valve Enlarged 

Charcoal 

Canister 

HC Vapors 

2876-02 
REFUELINQ CANISTER PLACEMENT 

1988 TAURUS 

Line to 

Canister 

To Tank 

2835-01 
CM 

COST-EFFECTIVENESS OF REFUELING CONTROLS 

• EARLIER ESTIMATES OF STAGE II AND ONBOARD COSTS AND COST-EFFECTIVENESS 

VARIED WIDELY. 

- MBSI STUDY FOR AUTO INDUSTRY FAVORED STAGE II OVER ONBOARD. 

- API, EPA ESTIMATES HAVE BEEN SIMILAR, BUT ASSUMPTIONS DIFFERED (STAGE 

II $1600-$2400/T0N, ONBOARD $800-$1000/T0N). 

• API CARRYING OUT UPDATED COST STUDY. 

- STEPWISE BUILD-UP OF CUMULATIVE COSTS IN NON AH A I NMENT AREAS, ASSUMING 

STAGE II "CREEP""ESTABLISH "BREAKEVEN" POINT ON NATIONAL COSTS. 

- USE REVISED SERVICE STATION PROJECTIONS, GASOLINE DEMAND, ETC. 

- INCLUDES MAINTENANCE AND CAPITAL REPLACEMENT COSTS IN EXISTING STAGE II 

AREAS. 

- QUANTIFY INCONVENIENCE COSTS, USE SPILL/LEAK DATA WHERE POSSIBLE TO 

ADDRESS CAPTURE EFFICIENCY. 

- DEVELOP ONBOARD COST SENSITIVITY TO MILEAGE CREDITS, CAPTURE OF EXCESS 

EVAPORATIVE EMISSIONS. 
ACTION PLAN 

PUBLIC INTEREST GROUPS/MEDIA 

- WASHINGTON, D.C. (5/4/88), CENTER FOR AUTO SAFETY, STAPPA, 

LEAGUE OF WOMEN VOTERS, AARP; TRADE PRESS 

- PLANNED WASHINGTON BRIEFINGS WITH INSURANCE INSTITUTE, 

HIGHWAY SAFETY COUNCIL, TRIPLE A, CLEAN AIR COALITION 

(NRDC, NWF) 

NHTSA, OMB, EPA 

- WASHINGTON (EARLY JUNE, 1988) 

- DEMONSTRATE BOTH VEHICLES, MOCK-UPS 

- UPDATED COST-EFFECTIVENESS INFORMATION FOR OMB 
REGULATORY GUIDING PRINCIPLES 

• ENVIRONMENTAL STANDARDS SHOULD BE SET BY EPA TO PROTECT THE PUBLIC HEALTH 

AND WELFARE. 

• REGULATIONS TO AH A IN STANDARDS SHOULD BE: 

- CONSISTENT WITH LONG-RANGE CONTROLS STRATEGIES. 

- COST EFFECTIVE. 

- APPLIED UNIFORMLY. 

- BASED ON SOUND TECHNICAL/ECONOMIC/ENVIRONMENTAL ANALYSIS. 

- ENFORCEABLE, WITH REASONABLE ADMINISTRATIVE BURDEN ON EPA/AFFECTED 

PARTIES. 

• ONCE PROMULGATED, REGULATORY REQUIREMENTS SHOULD BE STRICTLY ENFORCED.