### 80452 Federal 

### Register/Vol. 76, 

### No. 247/Friday, 

### December 23, 2011 

### /Proposed Rules

ENVIRONMENTAL PROTECTION AGENCY

40 CFR Parts 60 and 241
[EPA-HQ-OAR-2003-0119 and EPA-HQReRA 2008-0329; FRl-9503-7]

RIN 206Q-AR15 and 20SQ-AG44

Commercial and Industrial Solid Waste Incineration Units: Reconsideration and Proposed Amendments; NonHazardous Secondary Materials That Are Solid Waste

AGENCY: 

### Environmental Protection Agency.

ACTION: 

### Proposed rules; Reconsideration offinal rule.

SUMMARY: 

### OnMarch 21, 2011, the EPA promulgated its final response to the 2001 voluntaryremand ofthe December 1,2000, new source performance standards and emission guidelines for commercial and industrial solid waste incinerationunits andthe vacatur and remand ofseveral definitions by the District ofColumbia Circuit Court of Appeals in 2007. Following that action, theAdministratorreceived petition[s] for reconsideration as well as identified

some issues thatwarrant further opportunity for public comment. In response to the petition!s], theEPA is reconsidering andrequesting comment

on several provisions ofthe final new

source performance standards and emission guidelines for commercial and industrial solidwaste incineration units.

In addition, the EPA is proposing amendmentsto the regulations which

were codifiedbythe Non-Hazardous Secondary Materials rule. Originally promulgated on March 21,2011, the Non-Hazardous Secondary Materials rule provides the standards and procedures for identifying whetherNonHazardous Secondary Materials are solidwasteunderthe Resource Conservation and Recovery Act when used as fuels oringredients in combustionunits. Thepurpose ofthese proposed amendments is to clarify several provisions inorderto implementthe Non-Hazardous Secondary Materials rule as theAgency originally intended.

DATES: 

### Comments must be received on

orbefore February 21, 2012.

Public Hearing. If 

### anyone contacts the EPA requesting to speak at a public hearingbyJanuary 3, 2012, a public hearing willbe held on January 9, 2012. Forfurther information onthe public hearing andrequests to speak, contact Ms. Janet Eck at (919) 541-7946 to verify that a hearing will be held. ADDRESSES: 

### Submit vour comments on the commercial and'industrial solid
waste incinerationreconsideration and proposedrule, identified byDocket ID 

### No. EPA-HQ-OAR-2003-0119, by one ofthe following methods:



### • http://www.regulations.gov:Follow· the on-line instructions for submitting
comments.



### • Email: a-and-r-Docket@epa.gov, AttentionDocket ID 

### No. EPA-HQ-­ OAR-2003--0119.



### • Fax: (202) 566-9744, Attention Docket ID 

### No. EPA-HQ-OAR-2003­ 0119.



### • Mail: EPA Docket Center (EPA/DC), Environmental Protection Agency, Mailcode 6102T, 1200 Pennsylvania Ave. NW., Washington, DC 20460, Attention Docket ID

### No. EPA-HQOAR-2003-0119. Please include a total oftwo copies. We request that a separate copy also be sentto the contact person identified below (see FOR FURTHER INFORMATION CONTACT).



### • HandDelivery: In person orby Courier, deliver comments to: EPA Docket Center (EPA/DC), Room 3334, 1301 ConstitutionAve. NW., Washington, DC 20004. Such deliveries

are accepted only during the docket's normal hours ofoperation, and special arrangements shouldbemade for deliveries ofboxed information.

Submit your comments onthe NonHazardous Secondary Materials proposedrule, identifiedby Docket ID 

### No. EPA-HQ-RCRA-2008-0329, by one ofthe following methods:



### • http://www.regulations.gov:Follow the on-line instructions for submitting
comments.



### • Email: Comments may be sentby electronic mail (email) to: 

### rcra-docket@
epa.gov, Attention Docket ID 

### No. EPAHQ-RCRA-2008-0329.



### • Fax: Comments may be faxed to (202) 566-9744, Attention Docket ID 

### No. EPA-HQ-RCRA-2008-0329.



### • A'/ail: Send comments to: RCRA Docket, EPA Docket Center, EnvironmentalProtection Agency, Mailcode: 28221T, 1200Pennsylvania Ave. NW., Washington, DC 20460, Attention Docket ID 

### No. EPA-HQRCRA-2008-0329. Please include a total oftwo copies ofyour comments. We request that a separate copy also be sent to the contact person identified below (see FOR FURTHER INFORMATION CONTACT).



### • Hand Delivery: Deliver two copies ofyour comments to: Environmental Protection Agency, EPA Docket Center, Room 3334, 1301 Constitution Avenue NW., Washington DC, Attention Docket ID No. EPA-HQ-RCRA-2008-0329. Such deliveries are only accepted duringtheDocket's normal hours of operation, and special arrangements shouldbe made for deliveries ofboxed information.



### Instructions: Directyour comments on the commercial and industrial solid
waste incinerationreconsiderationand proposal to Docket ID

### No. EPA-HQOAR-2003-0119. Direct your comments

on the Non-Hazardous Secondary Materials proposedrule to Docket ID 

### No. EPA-HQ-RCRA-2008-0329. The EPA's policy is that all comments received willbe included in the public docket without change and maybe made available online at

### http://www

. regu]ations.gov

, including any personal information provided, unless the
comment includes information claimed
to be confidential business information

or other information whose disclosure is restricted by statute. Do not submit information thatyou considerto be confidentialbusiness information or otherwise protectedthrough 

### http:// www.regulations.gov or email. The 

### http://www,regulations.govWeb site is

an "anonymous access" system, which

means theEPA will not know your identity orcontact informationunless you provide it in thebody ofyour comment. Ifyou send anemail
comment directly to theEPA without going through 

### http://M\;w.regulations

. gOY, 

### your email address will be automatically captured and included as part ofthe commentthat is placed in the public docket and made available onthe Internet. 

### Ifyou submit an electronic comment, theEPA recommends that you includeyour name and other
contact information inthebody ofyour comment and with any disk or CD-ROM you submit. If

### theEPA cannot read your comment due totechnical difficulties and cannotcontactyou for clarification, the EPA may not be able to consider your comment. Electronic files should avoid the use ofspecial characters, any form ofencryption, andbe free ofany defects orviruses. For additional information abouttheEPA's public docket, visit the EPA Docket Center homepage at 

### http://www.epa.gov / epahome/dockets.htm.

Docket:All documents inthe docket

are listed inthe 

### http://www.regulations

. govindex. Although listed in the index,

some information is not publicly available, 

### e.g., confidential business information or other information whose disclosure 

### is restricted 

### bv statute. Certain other material, such as copyrightedmaterial, will be publicly available only in hardcopy. Publicly available docket materials are available either electronically in 

### http://www

. regulations.govor inhard copy atthe EPA Docket Center, EPA West Building, Room 3334, 1301 ConstitutionAve. NW., Washington, DC. The Public

### Federal Register/Vol. 76, No. 247/Friday, December 23, 2011/Proposed Rules 

### 80463

ensure that all data are correctly identified as either non-detection or detection level limited. where some of the fractions may be non-detection, but
not all ofthem. While our findings found the most data were accurately identified, there were a few average values that were reclassified as "detection level limited." However, these correspondingrun data were correctly identified and were included in the three times the detection limit methodology. Therefore, no D/F emissionlimits were impacted due to this review.

In addition, the EPA conducted a review ofsampling volumes and detection levels across various emission testing ICR efforts on various combustion sources (See memorandum "Updated data and procedure for handlingbelow detection level data in analyzing various pollutant emissions databases for MACT and RTR emissions limits" in the CISWI docket). As a result ofthis analysis, we have determined recommended values for threetimesthe RDL (3xRDL) that maybe used as a minimum emission limit value that can be accurately measured by most laboratories. These recommended values werethen compared with calculated emission limits and, if

### the calculated limit is less than the recommended 3xRDL, the 3xRlJL value is selected as the limit. This premise for this approach is the same as described in the final rule, butusing a broader data set to establish the 3xRDL value. We have not changed the methodology ofthe emission limit calculation'or tabulation ofthe three times the detection limit value that was used in the final CISWI rule. Therefore, we are not accepting comment onthe emission limit calculation methodology.

One petitionerhas suggested that Df 

### F emission limits should not be less than 0.3 ng/dscm. We are requesting
comment and data on wh.,ther 0.3 ng/ dscm or the recommended 3xRDL values for each test method are sufficientto reflect quantifiable concentration levels, or whether other values should be selected as a lower quantification boundary for emission limits for CISWI sources.
10. Providing an Option for Sources To Use Emissions Averaging To Demonstrate Compliance

Several petitioners contend that the EPA did not adequately address
comments on the issue of allowing

sources with multiple CISWI units at a facility to use emissions averaging to demonstrate compliance, similarto the provisions provided in the major source boilerNESHAP. The boiler MACT allows emissions averaging across subcategories within an affected facility. The applicability ofCISWI is such that each unit is an affected facility, 

### if it 

### otherwise meets the applicability ofthe rule. 'We cannot allow emissions averaging across affected facilities because we establish MACT on an affected facility basis and it 

### would be impossible tojustify MACT when averaged across affected facilities.

11. Definitions

a. Establishing a Definition ofFoundry Sand Thermal Reclamation Unit

Following publication ofthe final rule and the NHSM rule, we were made

aware ofa certain class ofunit thathad
not previously been considered a CISWI unit, but could potentially be considered a type ofCISWI once the NHSM rule came into effect. These units

are called TSR units, and are a component ofa foundry's "sand loop." We have concluded that these units are parts reclamation units as defined inthe 2000 CISWI rule. We defined parts reclamation units as "unitls] that burn coatings offparts (e.g., 

### tools, equipment)

so that the parts canbe reconditioned and reused." In the 2011 CISWI rule, parts reclamation units are a subcategory ofburn-offovens. Thermal reclamation units that recover foundry sands serve the same purpose as**othe~** 

### parts reclamation units that recover metal parts. Specifically, foundry sand units recover parts (i.e., 

### sand) by removing coatings (e.g., 

### binders and resins) from the foundry molds. Thus, TSR units are part reclamation units that remove coatings that are on foundry sand, which allows re-use ofthe sand. As with otherburn-offovens, TSR parts reclamation units conserve natural

resources (j.e" 

### virgin sand] and minimize theuse oflandfill capacity for foundry sand.

As with otherburn-offovens, we do
not currently have emissions data for TSR units andregulation ofsuchunits is not required to comply withthe Agency's CAA 112(c)(6) obligation. For these reasons, we are not proposing standards for TSR units are this time.

We are soliciting comment on the proposed definition ofTSR units.

b. Removing the Definition ofContained Caseous Material

The EPA did not propose to remove the definition ofcontained gaseous material in the proposed CISWI standards. In the final CISWI rule preamble (76 FR 15708), we removed definitions that define or clarify what constitutes a solid waste from the standards to minimize confusion in light ofthe definition ofsolid waste in the final NHSM rule. The definition of "containedgaseous material" was one ofthe definitions that was removed from the 2000 CISWI standards.

Several petitioners asked for confirmation that the Agency had not changed its historical interpretation of what gases could be considered to be solid waste (i.e., 

### a "contained gas"). These petitioners also requested that the EPA reconsider the removal ofthe definition of "containedgaseous material" in the CISWI rule, since the

same definition appears in subparts EEEE and FFFF ofpart 60 (§ 

### 60.2977 and § 

### 60,3078) and subpartIII ofpart 62 (§ 

### 62.14840). The Agency did not intend
to create ambiguitybyremoving the definition of "contained gaseous material" from the CISWI rule. Accordingly, theproposedCISWI reconsiderationrule includes the same definition of "containedgaseous material" that wasremoved from the final CISWI rule, This definition is consistentwiththe definition inthe subparts cited above. Moreover, our proposal to addthe definition of "contained gaseous material" to the proposedCISWI reconsideration rule is consistent withthe position in other sections ofthis preamblethat address the NHSM rule where we make clear thatthe Agency is not changing any of its previous positions withregard to contained gas. The EPA is soliciting
comment on the needto retain the definition ofcontained gaseous material.

c. Revising Definition ofChemical Recovery Unit

Following publication ofthe final rule and the NHSM rule, wereceived additional information about a handful ofcombustion units that had previously
not been regulated as CISWI sources, butcould potentially be considered a type ofCISWI unit once the 2011 NHSM final rule came into effect. However, these units do not adequately fit into any ofthe four subcategories ofunits in the final CISWI standards. The units that have been identified are SARUs that may beburning sulfur-bearing compounds which are classified as nonhazardous waste at facilities that are non-RCRA part B permitted SARUs. Stakeholders have identified four such facilities, andhave contended that
response to comments and preamble language inboth the 2011 NHSM final rule and the final CISI/VI rule are confusing and inadequately address their particular questions on applicability ofCISWI to these units. The stakeholders ask speCifically which subcategory should apply to these units,

### 80472 

### Federal**Regish~r/Vol.** 

### 76, No. 247 

### IFriday, December 23, 2011 

### IProposed Rules

and off-specification tires, and (2) resinated wood. Thus, persons who burn these NHSMs as a fuel would not need to evaluate them using the selfimplementing legitimacy criteria when burned.

In addition, the Agency recognizes thatthere maybe other NHSMs that should also beconsidered non-waste fuels, based on a balancing ofthe legitimacy criteria with other relevant factors. Therefore, we are proposing to create a petition process that would provide the regulated community an opportunity to submit a rulemaking petitionto theEPA for a determination that a particular NHSM should not be considered solid waste when burned as

a fuel in a combustion unit. This process couldbe used when a facility does not believe that the selfimplementinglegitimacy criteria yields

a clear result or does not accurate

### Iv reflect whetherthe material is being discarded. A briefdiscussion ofthe specific NHSMs being proposed to be listed as not solid waste 

### is provided below, as well as an overview ofthe petition process for identifying additional NHSMs as not being solid
wastes when burned as a fuel in a combustion unit for energy recovery, See section 11,0.3 and 4 oftoday's proposedrule for a detailed discussion ofthese topics.

a. Scrap Tires

Inthe 2011 NHSM final rule, the EPA determinedthat scrap tires removed from vehicles and managed pursuant to established tire collection programs would not be considered a solid waste. This determination was codified in § 241.3(b)(2)(i). This determination was made after theEPA analyzed scrap tires removed from vehicles and managed pursuantto established tire collection programs and concluded that (1) these materials would meet the legitimacy criteria for fuels, and (2) these materials

were not discarded when transferred off-site from the generating facility.10

Since promulgation ofthe 2011 NHSM final rule, the EPA has receivHd information that tire manufacturers, including downstream distribution channels, may produce tires that are not suitable for use onvehicles, but like the tires removed from vehicles, are usable

as legitimate fuels. They are, for all intents and purposes, the same as the vehicle tires managed under the oversight 

### ofestablished tire collection
programs. As a result, the revised definition 

### of "establishedtire collection program," would encompass offspecification tires (including

'"See 76 FR 15490-15499. scrap tires) that are contractually arranged to be collected, managed, and transported between a tire manufacturer, which would include wtaHers and other parties involved in the distribution and sale ofnew tires and a combustor. We note that tires coming from vehicles that are part ofan established tire collectionprogram would be a non-waste fuel underthe 2011 NHSM final rule. The EPA is not reopening this determination in today's proposed rule.

For clarity, the Agency is proposing to add scrap tires that are not discarded and are managed under the oversight of established tire collection programs, including tires removed from vehicles and off-specification tires, to the categorical list ofnon-waste fuels (see 40 CFR 241.4(a)), For more on this determination and the off-specification tires from tire manufacturers or downstream distribution channels, see section ILD.3 oftoday's proposed rule,

b. Resinated Wood

The 2011 NHSM final rule determined that resinated wood is not a solid waste when used as a fuel regardless ofwhether it remained within the control ofthe generator [see 40 CFR 241.3(b)(2)(ii)). This determination was made after theEPA analyzed resinated wood and concluded that (1) resinated woodgenerally would
meetthe legitimacy criteria for fuels, and (2) resinated wood was not discarded when transferred off-site from the generating facility.11 Today's action
proposes to revise part 241 to state affirmatively that resinated wood, when used as a fuel, is not being burned for discard and is not a solid waste. We are proposing to codify this determination based on our beliefthat the use of resinated wood as fuel represents an component to the wood manufacturing process and, as such, resinated wood is not being discarded, and therefore not solid waste, when burned as fuel. For more on this proposed revision, see section II,D.3 of today's proposed rule.

c. Rulemaking Petition Process for Other**"~on-Waste** Determinations

Undertoday's rule, the Agency is proposing to create a rulemaking petition process that would provide
persons an opportunity to submit a rulemaking petition to the Administrator, seeking a categorical determination for additional NHSMs to be listed in section 241.4(a) as nonwaste fuels. The process for submitting

11 For a hlll discuBsion und rationale for reachod this coudusioll, see FR a rulemaking petition to the Agency, as well as the factors a successful application must include, is proposedin 241.4(b). For more information regarding the rulemaking petition
process, see section II.D.4 oftoday's proposal. Parties have identified the potential ofmanure notbeing solid
waste. Parties can presentinformation including data demonstrating that

manure is not discarded either through the existing non-waste petition process

orthe proposed categorical determination process.
4. Additional Request for Comment

As discussed elsewhere inthis preamble, the Agency requests additional information regarding pulp and paper sludge in orderfor the Agency to determine whether a categorical determination that pulp and paper sludge is a non-waste, whenused

as fuel, is appropriate. Information that would be particularly helpful includes: (1) Documentation ofhowthe use of pulp and paper sludges that are used as

a fuel are integrated intothe industrial production process and the steps taken industry-wide to ensurethat this NHSM is consistently used as a legitimate fuel and is not discarded, including when transferred to a different person for use

as a fuel; (2) documentation on the
amount ofpulp and paper sludges burned as a fuel (whether withinthe control ofthe generator or outside the control ofthe generator), and what determines whichpulp and paper sludges are burned as a fuel, as opposed
to being land applied or disposed; (3) additional data regarding the contaminant levels ofthe various HAP, such as chlorine and metals, and what steps the industry has taken to ensure the quality ofthese sludges when used

as a fuel are consistent with that offuel product; (4) information on standard practices used to ensurethatthese sludgeshave a meaningfulheating value, including the types 

### ofdewatering and other processing steps that these sludges are subject to, as well as information on whether any pulp and
paper sludges that are burned as a fuel

are done so without any processing, including dewatering; and (5) when shippedto a different person for use as

a fuel, how these sludges are managed, 

### including how they are shipped, any processing that may occur, and how long these sludges are typically stored prior to being burned as a fuel.

5. Clarification Letters Issued After Promulgation ofthe NHSM Final Rule

After promulgation ofthe 2011 NHSM final rule, a number ofquestions were raised regarding certain issnes,

### Federal 

### Register/Vol. 76, No. 247/Friday, December 23, 2011 I

### Proposed Rules 80473

including whetherthe EPA was changing its position regarding "contained gaseous materials" and whether they are solid wastes when burned in combustion units. While there was no regulatory text or discussion inthepreamble to the final NHSM rule, the Agency didrespond to several comments that were submitted
to the EPA during the comment period. Specifically, its response to the fourth
comment in part 3b.I3 ofthe document entitled, "Responses to Comments Document for the Identification ofNonHazardous Secondarv Materials that are Solid Waste (Februa{y 2011}," 12 created

concerns among theregulated community that the Agency had changed a long-standing interpretation ofwhat constitutes a "contained
gaseous material" for purposes of defining the term solidwaste under RCRA.

In a letter sent to the American Forest and PaperAssociation, the EPA clarified that it was not changing its previous interpretations and that such interpretations still were the Agency's position. 13 Specifically, as we state in the letter, "EPA was responding to a comment requesting that we include in the NHSM final rule a definition of 'containedgaseous materiaL' The Agency does notbelieve that including such a definition inthe rule is necessary, However, ourresponse seems to have caused confusion about whether the Agency was changing its prior interpretations regarding the burning of
gaseous materials, for example in fume incinerators, and whether or not such burning is considered to be treatment of

a solid wastebyburning. The response does not change anypreviolls EPA positions. We clarify here that the Agency's previolls statements and interpretations remain effective. Thus, burning ofgaseous material, slich as in fume incinerators (as well as other combustionunits, includingair pollution control devices that may combustgaseous material) does not involvetreatment or othermanagement ofa solid waste (as defined in RCRA section 1004(27)." Thus, we are stating again in the preamble to today's proposedrule thatwe are not changing
any ofour previous interpretations as 

### it

12 See "Responses to Comments Document for the Identification ofNon-Hazardous Secondary Materials that are SolidWaste (Febrnarv 2011). A
copy ofthis document canbe found at imp:l/

wU

1w.epa.gov/epau'Gste/nonlJazlde!inelindex.htm. 1.31vfuy 13. 2011 Letter to Tim Hunt, American Forest andPaper Association. A of this letter has been placed in the docket for proposed n:de. relates to whether "containedgaseous material" is a solid waste,

In addition to this letter, the Agency has also issued a number ofother letters in which we clarify howthe 2011 NHSM final rule addresses certain materials or activities. For example, the EPA has issued clarification letters covering the following materials and issues: (1) July 21, 2011, letter to Pamela F. Faggert, Dominion Resources Services, regarding materials that are used in recirculation/reinjection processes and CBO units; (2) August 5, 2011. letter to Sue Briggmn, Waste Management, regarding landfill gas; (3) August 5,2011, letter to Tracey Norberg, Rubber Manufacturers Association. regarding off-specification tires ' (including factory scraptires); and (4) August 15, 2011, letterto JefIA. McNelly, ARIPPA, regarding coal refuse in legacy piles. We are not taking
comment onthese letters, since they reflect the Agency's interpretation ofits existing March 21, 2011, NHSM rule,

6, Clarification ofthe Process for Submittal ofNon-Waste Petitions

The 2011 NHSM final rule established

a non-waste determinationprocess that provides persons with an administrative petition process for receiving a formal determination from the EPA Regional Administrator that a NHSM that is used

as a fuel, and which is not managed within the control ofthe generator, can be considered a non-waste fuel provided they are able to demonstrate that such material has notbeen discarded and is indistinguishable in all relevant aspects from a fuel product, (40 CFR 241.3(c)),

As discussed in the March 21, 2011 final rule (76 FR 15471), EPA has not arbitrarily determined that secondary materials transferred between companies are wastes. Instead, EPA examined a number ofspecific recycled materials, both within the control ofthe generator and transferred to a third party for recycling and decided that materials are to be considered solid
wastes except in certain instances described in 40 CFR 241.3(b). These determinations were based on the record available to EPA. In order to better reflect the evidentiary record, EPA is proposing to amend the language of40 CFR 241.3(a) to state that except 

### for materials described in 241,3(b), and newly proposed section 241.4, combusted non-hazardous secondarv materials are "presumed" to be solid
wastes.

This petition process provides an opportunityunder40 CFR 241.3(c) for companies to show thattheir materials

are not wastes, The petitionprocess is essential because NHSMs are recycled and managed in many different ways and the Agency may lack the specific details in certain cases to know whether

or not suchNHSMs are or are not waste (76 FR 15472), We believethat the petition process provides an important

assuranceto the community on waste status andrelevant standards and also provides an opportunity to demonstrate that the particularNHSM was not discarded. TheAgency solicits comment

on the petition process as itrelates this approach, and on whether or not the regulatory text should also be changed
to address this situation as it relates to the petition process where snchNHSM has not in fact been discarded,

In evaluating whetherto grant or deny the petition, the ultimate question that EPA will need to answer is whether or not the NHSM has been discarded, 

### Ifthe applicant is able to demonstrate that such NHSM has notbeen discarded, including meeting the legitimacy criteria, it is likely thatthe Agency will grant the petition. Under the existing regulations, until EPA acts on such petition. the NHSM is consideredto be

a solid waste, However, we would note that if the NHSM has not been discarded, EPA's grant ofthe petition would apply as ofthe date that the petition was submitted to the Agency, The Agency solicits comment on whether or not the regulatory text should also be changedto address this situation where suchNHSM has not in fact been discarded.

Since promulgation ofthe 2011 NHSM final rule, concerns have been raised that the information required for

a non-waste determinationpetition would be extensive andthe timeframe for issuance ofthe decision lengthy, The Agency wishes to clarify thatwe do not intend that the application required or the petition process itselfto be burdensome or time andresource intensive for the applicant.

As noted in the March 2011 final rule, the applicant must demonstrate thatthe NHSM that is to be burned as a fuel has
not been discarded, is a legitimate product fuel (per § 241,3(d)(1)), considering the five criteria identified in § 241.3(c)(1)(i)-(v):

(1) Whether market partiCipants treat the**non~hazardous** secondary material

as a productrather than as a solid waste;

(2) Whetherthe chemical and physical identity ofthe nun-hazardous secondary material is comparable to commercial fuels; 14

14As discussed elsewhere in loday's proposal, EPA is clarifying that in making comparisons between the NHSM and the traditional fuel, the ownBr or operator can considerindividual
Continued