Comment submitted by W. H. Lane

The proposed federal register notice 71 FR 25531 clarifies EPA intent to apply the 1 Mg/year exemption on a facility wide basis. Please confirm that this means that a facility may designate up to 1 Mg/year of organic HAP content exempt from the standards pursuant to this exemption, even though other site remediations activities that are either controlled by the rule or qualify for other exemptions result in the facilitywide total organic HAP content greater than 1 Mg/yr. Also, the general standards in subpart GGGGG for process vents and remediation material management units provide owners an alternative compliance option for units already subject to air pollution controls pusuant to 40 CFR Part 61 or Part 63. In this federal register notice, EPA extends the compliance option for equipment leaks. Please confirm for source already following Part 61 standards that SSM plans are not required pursuant to Subpart GGGGG and Subpart A of Part 63.