Comment submitted by David F. Wesson, EH&S Operations Regulatory Management, The Dow Chemical Company

August 8, 2007 Via Email Email: A-and-R-Docket@epa.gov Attention E- Docket Number EPA?HQ?OAR?2006?0699 RE: Docket ID Number EPA-HQ-OAR-2006-0699; Standards of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry; Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries; Notice of Data Availability Dear Sir/Madam: On November 7, 2006, EPA proposed revisions to the Standards of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry and the Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries. The Dow Chemical Company (Dow), as an owner and operator of numerous facilities throughout the United States, has had many occasions to address NSPS regulations and the compliance requirements therein. Dow is generally supportive of efforts to make regulations more consistent and is supportive of several of EPA?s proposed changes. Dow does, however, have reservations concerning some of the proposed changes and the economic justifications used by EPA. Below are Dow?s concerns. We are pleased to submit these comments in response to EPA?s July 9, 2007 Notice of Data Availability (NODA) dealing with changes to 40 CFR Part 60 Standards of Performance for Equipment Leaks of VOC (Subpart VV) and (Subpart GGG). Dow appreciates the opportunity to comment and EPA?s consideration of Dow?s comments. Regards, David Wesson