Comment submitted by P. Bilowus

Document ID: EPA-HQ-OAR-2003-0079-1013
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: April 27 2006, at 01:02 PM Eastern Daylight Time
Date Posted: April 28 2006, at 01:02 PM Eastern Standard Time
Comment Start Date: March 27 2006, at 01:02 PM Eastern Standard Time
Comment Due Date: May 12 2006, at 11:59 PM Eastern Standard Time
Tracking Number: 8016768f
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Paul Bilowus, AAS, BA, 10319 Wood Road Fairfax, VA, 22030; April 27, 2006; 703-273 7853. I have been working in the Air Pollution field for about 24 years and made a major discovery that leads me to believe that the Ozone Standards may never be met. We well know, ozone is created by ultra- violet light from sunlight striking compounds and elements. We also know that some of these components or precursors come from manmade sources and some from natural ones. These are well known facts, but what's forgotten is the fact that ozone is created from hydrocarbon gas created by decaying vegetation, and living plants. Well that's only the half of it; the other missed major emission factor is hydrocarbons that are off-gassed from petroleum products, such as roofing materials and asphalt streets. Hydrocarbons emissions from petroleum products, like the fore mentioned natural sources, are temperature dependent, therefore the warmer it gets the more hydrocarbons are put off. This would explain why there are extraordinary high levels of ozone in Virginia's Shanandoh Mountains. My belief is that the air has improved, even though the traffic and housing heating demand have gone up, as can be seen in the (I) Fairfax County Air Quality annual report. The report also shows that the air monitoring station upwind in Chantilly, VA (where traffic is not a factor) has almost as high as an ozone pollutant level as stations downwind where traffic would be a factor. This obviously further proves my point of ozone being created where the right conditions are met. This is especially true on stagnant air days, when the ozone naturally builds upon itself. I believe the 7 th criteria pollutant Hydrocarbons usually called VOC's need to be studied further, before any final decisions are made about transport issues. It's a known fact that Hydrocarbons are pecursors to the production of O3. Why is it that Hydro carbons are so under studied and undervalued? Reference:( 1) Annual Report 2003, Air Quality, Fairfax County Health Department, Environmental Health, 10777 Main Street, Fairfax, Virginia, 22030. http://www.fairfaxcounty.gov/hd/airannualrpt.htm P. Bilowus

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