Comment submitted by Robert Lincoln, ChemTreat, Inc.

As noted in Section IV. D. paragraph three of this proposed rule, one of our rule-eligible facilities processes one of the target HAPs without PM control devices as follows. A mineral oil based liquid preparation of manganese carboxylates is blended with other additives into a petroleum based mixture that is used for corrosion inhibition in petroleum industry storage and transfer systems. The blending process is conducted in a closed but not air-tight vertical blend tank. Number 2 fuel oil is placed into the blend tank on a load cell and the liquid manganese carboxylate ingredient is poured into the fuel oil blend from a drum, by weight, as indicated by the product formulation. The mixture is blended by a low speed rotary agitator. There are no aspirations, mists, droplets or any other visible emissions from the blend tank. Particulate emissions are negligible. The mixture is gravity drained into product drums again without particulate emissions. The blending room where the manganese carboxylate liquid is processed is used exclusively for making liquid petroleum-based product blends. The blend tank itself is not vented; the blend room has separate ventilation. Less than one ton of manganese is processed annually, virtually all of which ends up in the final product. A 95% control standard for such insignificant particulate emissions will cause a compliance ambiguity. Request that either a mass-based minimum threshold exclusion or a concentration-based alternate compliance option be provided in the rule so that we may be able to comply.