Comment submitted by James L. Kavanaugh, Director, Air Pollution Control Program,Missouri Department of Natural Resources

Air and Radiation Docket U.S. Environmental Protection Agency (EPA) Mailcode: 6102T 1200 Pennsylvania Avenue, Northwest Washington, DC 20460 Attention: Docket Indentification Number EPA-HQ-OAR-2006-0406 The purpose of this letter is to provide comments on the following Federal Register action: Agency Information Collection Activities; Submission to Air and Radiation Docket for Review and Approval; Comment Request; NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities. (Federal Register, November 9, 2006, Volume 71, Number 217, Proposed Rules, Pages 66064-66092) In reviewing the U.S. Environmental Protection Agency's (EPA's) proposed Information Collection Request, the Missouri Department of Natural Resources' Air Pollution Control Program offers the following comments. Regulatory Alternative 1 requires loading racks at bulk terminals (federally defined as having a maximum daily throughput of 20,000 gallons per day) to meet an emissions standard of 80 mg/l. Missouri currently requires all of these type of facilities located in either an ozone maintenance or nonattainment area to meet a 10 mg/l standard. These facilities may also request an exemption if their monthly throughput is 120,000 gallons or less averaged over the last calendar year and the exemption can be renewed yearly. EPA chose the 80 mg/l standard because most of the loading facilities in the nation are currently required to meet this level. However, EPA found that some states require their loading facilities to meet 35mg/l. EPA did a cost benefit analysis of all three levels (i.e 10, 35 and 80 mg/l) and decided the two lower standards were not cost effective. While the cost benefit analysis for the 80 mg/l option did take into account the value of the gasoline captured and recovered, it is not apparent whether the value added from gasoline captured and recovered was considered in the 10 and 35 mg/l options. This analysis should be included in the proposal document so all options are evaluated fairly. Attention: Docket Identification Number EPA-HQ-OAR-2006-0406 Page Two Regulatory Alternative 1 also requires tanker trucks to undergo annual testing to insure tightness. EPA proposes a standard of not more than three (3) inches of pressure drop over a five (5) minute period. Missouri currently requires annual testing to insure tankers which serve either the Kansas City Maintenance Area or the St. Louis Nonattainment Area meet a tightness of no pressure drop in thirty (30) minutes when pressurized to at least four and one-half (4.5) pounds per square inch (psi). The Missouri requirement has proven to be both reasonable and effective and we suggest that this requirement replace the EPA proposed requirement. When the cost benefit analysis is performed, it should include vapor reclamation technology rather than flaring so that the value of gasoline captured and recovered is accounted for. Regulatory Alternative 2 in addition to the items required under Regulatory Alternative 1 also requires submerged fill at Gasoline Dispensing Facilities (GDF?s) in Urban 1 and 2 areas. It is unclear from the proposal document whether the value added from the vapors captured and condensed were considered in the EPA cost benefit analysis for nation-wide submerged fill at GDF?s. This analysis should be done for all options prior to selection of the areas covered by this Regulatory Alternative. Regulatory Alternative 3 calls for the provisions in the first two alternatives, as well as the requirement that all GDF's located in Urban 1 areas utilize vapor balancing when loading gasoline into their storage tanks. We believe the use of vapor balancing is very important in the reduction of emissions of hazardous air pollutants and ozone precursors from GDF's and is a much more effective control technology than submerged filling alone. Additionally, we believe the benefit of these HAP reductions would be mutually beneficial to those living near GDF's in rural areas as well, with no additional cost to rural GDF's to implement than urban facilities. Therefore, we would recommend that EPA select Regulatory Alternative 3, but with the application of submerged filling and vapor balancing requirements nationwide to all GDF's, not just those in urban areas. The department?s Air Pollution Control Program appreciates the opportunity to comment on this Federal Register action. Should EPA require further information on this matter, please contact the department?s Air Pollution Control Program, Operations Section, at P.O. Box 176, Jefferson City, MO 65102-0176, or by telephone at (573) 751-4817. Sincerely, AIR POLLUTION CONTROL PROGRAM James L. Kavanaugh Director JLK:pms