Ohio Low RVP Fuel Requirements public comment

"John Stubbles" <john_stubbles@msn.com> 04/16/2007 01:31 PM Subject: Docket ID No. EPA-RO5-OAR-2006-0976 Dear Sir, I am a resident of Cincinnati, and prior to retirement was an Environmental Manager for Charter Steel in Wisconsin. I read the case for the low RVP gasoline, but was confused by the data that were presented. On the one hand, the LADCO model called for a reduction of 47 tpd of VOC's and 202 tpd of NOx in the Cincinnati area. It was stated however that RVP would have little effect on NOx, and the reduction of NOx of 202 tpd was an "expectation". From what? Surely the interaction of NOx and VOC's leads to ozone formation. Later it was stated that RVP would reduce VOC by 4.6 tpd in the Cincinnati area and 4.2 in the Dayton area. I cannot believe a) that the reduction in these communities would be that close considering their disparate populations. b) that the RVP only reduces the "necessary" VOC 's per LADCO by 10%. c) that this reduction would even be measurable considering the air over a circle of 75 miles diameter i.e. an area approximately covering Cinci. and Dayton weighs about 130 billion tons. In other words, if I reduce VOC's by 5.2 tpd, I would reduce the existing VOC concentration by .000000004%. I recognize that the VOC's are probably confined to a smaller volume than the troposphere but my point is made even if you consider a thin layer -- say 1 mile high--close to the surface of the earth. And what about carryover from Kentucky and Indiana ? Do they contribute to our criteria pollutants? I do not believe cost is an issue, but availability of gasoline could be severe if we refine the specifications of our supply. I question whether the introduction of RVP gasoline will have a measurable impact on VOC levels and will it be withdrawn if the data show this? By the way, Solvent Systems in Illinois are marketing a "Grease Gator" for parts cleaning withoutthe emission of VOC's. It has been adopted by several major auto companies and you might bring this to the attention of Ohio companies that emit cleaning solvent VOC's. Sincerely Dr. John Stubbles