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EPARulemakingEPA-HQ-OAR-2007-0352

Review of the Primary NAAQS for Sulfur Dioxide

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American Petroleum Institute filings
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American Petroleum Institute filed 3 comments on this docket between Sep 2, 2008 and Feb 12, 2010. 60 other organizations filed here. The comment window closed 6006d ago.

What American Petroleum Institute filed (3)

Feb 12, 2010· Comment submitted by Ted Steichen, Policy Advisor, Regulatory and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-OAR-2007-0352-0914

API represents about 400 member companies involved in all aspects ofthe oil and natural gas industry. API is pleased to provide these comments as follow-up to the public testimony on the Sulfur Oxides (SO2) NAAQS Proposal provided at the Environmental Protection Agency (EPA) public hearing in Atlanta on January 5, 2010. API has been participating in EPA's review of the primary National Ambient Air Quality Standard (NAAQS) for SO2 and has always asserted any NAAQS should be based on sound science. API finds EPA's proposal to add a 1-hour primary NAAQS for SO2 in the range of 50 to 100 ppb -- or as high as 150 ppb -- is not justified and recommends the Administrator withdraw this proposal. If EPA proceeds to set a standard at this time is should be no lower than 150 ppb.

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Jun 15, 2009· Comment submitted by Ted Steichen, Advisor, Regulatory and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-OAR-2007-0352-0029

API finds that the clinical and epidemiological data in the REA do not support the US EPA suggested 1-hour daily maximum SO2 NAAQS 50-150 ppb. For the following reasons explained in the attached comments: (1) The clinical SO2 data are based on sensitive sub-populations (exercising adult and adolescent asthmatics), in a rare exposure scenario, in which symptoms (if they occur) can be relieved by discontinuing exercise. Statistically and biologically-relevant lung function effects attributable to SO2 do not occur at exposures < 400 ppb, (2) The use of clinical data makes the use of safety factors for sensitive individuals, non- human data, use of a LOAEL, and use of chronic exposures unnecessary, and (3 ) epidemiological studies provide inadequate support for the proposed standard owing to their many limitations, including exposure misclassification, measurement error, confounders, weak and inconsistent findings within and among studies, and incoherence with clinical studies.

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Sep 2, 2008· Comment submitted by Ted Steichen, Advisor, Regulatory and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-OAR-2007-0352-0011

API finds that the REA generally includes the information required by the Administrator to determine if revisions of the NAAQS are needed to protect public health. While some of the techniques used in the SO2 REA to examine exposures under "as is" conditions could be refined or better justified, the overall analysis of current air quality is very useful for this purpose and demonstrates that a minimal number of exposures to SO2 concentrations of concern currently occur in ambient air. The examination of exposures if the present primary standards were just attained, on the other hand, should be deleted. This examination is unnecessary, technically flawed, and examines conditions that will never occur.

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