Comment submitted by Brian Bunger for Jack P. Broadbent, Executive Officer/APCO, Bay Area Air Quality Management District

August 24, 2007 EPA Docket Center (6102T) New Source Performance Standards for Petroleum Refineries Docket 1200 Pennsylvania Ave., NW. Washington, DC 20460 Dear Sirs/Madams: I am writing to comment on the proposed amendments to 40 CFR 60, Subpart J, Standards of Performance for Petroleum Refineries, and the new proposed 40 CFR 60, Subpart Ja, Standards of Performance for Petroleum Refineries for Which Construction, Reconstruction, or Modification Commenced After May 14, 2007. The Bay Area Air Quality Management District is the agency responsible for achieving clean air in the San Francisco Bay Area. The District has five major petroleum refineries operating within our jurisdiction, and has adopted a number of stringent rules and regulations intended to minimize air emissions from these facilities. Among these are innovative rules that are intended to closely monitor and minimize emissions from refinery flares. In recent years, the District has spent a great deal of time with EPA discussing the applicability of New Source Performance Standard (NSPS) Subpart J requirements to refinery flares in conjunction with Title V permit issuance. During these discussions, the District urged EPA to amend the NSPS to clarify rule requirements so that the applicable requirements can be implemented and enforced in a uniform manner throughout the U.S. We encourage EPA to clarify this issue through this rulemaking. Our specific comments on the proposed amendments to Subpart J, and to the proposed new Subpart Ja, are enclosed. If you have any questions regarding this letter, please contact Brian Bateman, the District?s Director of Engineering, at (415) 749-4653. Sincerely, Brian Bunger for Jack P. Broadbent Executive Officer/APCO Attachments