Comment submitted by Judith Zwicker, PhD, JZ Consulting

February 10, 2010 U.S. Environmental Protection Agency Air and Radiation Docket and Information Center Mail Code 2822T 1200 Pennsylvania Avenue, NW Washington, DC 20460 Attn: Docket ID No. EPA-HQ-OAR-2006-0406 E-mail: a-and-r-Docket@epa.gov Re: EPA-HQ-OAR-2006-0406 Comments on EPA’s Proposed Rule Concerning Revisions to National Emissions Standards for Hazardous Air Pollutants for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing Facilities (“Proposed Rule”), 74 Fed. Reg. 66470 (to be codified at 40 CFR Parts 9 and 63) I submit these comments as a citizen of the State of Missouri and of the United States. I have been working on environmental issues since 1979 and on vapor recovery in Missouri since 1995. I support the majority of changes made in the proposed revisions and find the clarifications most useful. I have two concerns about the proposal: 1. The first concern is related to the proposed amendment to §63.11066 to allow storage tanks to have an additional option for submerged fill pipes that are further from the bottom of the tank than previously allowed if adequate records are kept and made available to the Administrator on request to show that the tank never falls below the upper opening of the fill pipe. First, it is not clear what kinds of records will be required. The most likely and easiest for the facility would be the stick records before and after fueling. The before records would provide the necessary information to determine if the level had fallen below the appropriate level. However, this would provide a great deal of work for an inspector to determine that the level had actually NEVER fallen below the acceptable level between inspections and, in reality the records would probably never be checked. I have observed tests and inspection where the fill pipe was not of the correct length and had to be replaced. This replacement is not a matter or minutes, however, it also does not require breaking concrete and should not be very expensive. I would think that the effort of reviewing the proper records would be much more complicated than installing the properly cut fill pipe. 2. My second concern involves E85. I think that specifically including E85 and other ethanol blends is very good and important. I would like to suggest that it be required or at least recommended that all facilities that convert old tanks and Stage I systems for E85 or new tanks and Stage I systems follow the guidelines in the July 2006 Handbook for Handling, Storing, and Dispensing E85 put out by the U.S. Department of Energy. There can be significant problems if the proper materials are not used and if tanks that have been used for other petroleum products are not properly cleaned and proper components are not used. The California Air Conservation Board has approved a number of Stage I systems for E85. They especially have approved an E85 PV valve and vapor and fill adaptors. Thank you for receiving my comments. I appreciate the good work that the EPA is doing in reducing the emissions of hazardous air pollutants. Sincerely, Judith Zwicker, PhD JZ Consulting 325 Westgate Avenue St. Louis, MO 63130