Document 91Ry6JxO0gOnw4L457pd45Y8D

RIO controls the higher concentration flows at the Facility meaning that the Facility will face more challenges associated with capturing the more diffused sources and routing them to the new 'Fa Also, nearly two years of work was donc by DPE on an accelerated schedule to meet the requirements of the January 2017 Administrative Order on Consent. Based on that experience and the dangerous risks that were revealed during the accelerated nearly two-year process, I would not authorize a similar accelerated implementation schedule for a new, much larger and more complicated 1O. 1 believe the risk inherent in attempting to complete such a task in only 90 days is unthinkable. Additionally, after DPE completed work on the existing RTO and MERP control systems, the new systems did not function effectively upon startup and required several months of shakedown and then over a year of process optimization before they were considered fully successful. Based on this prior experience alone, I estimate that the Facility would require at least 30-36 months to complete another TO. 17. Safety Bypass Lines. 1 am also very concerned with EPA's prohibition of the use of bypass lines that would prevent the Facility from bypassing control devices without incurring a potentially enforceable permit violation. The Final Rule will require monitoring systems for flow on bypass lines to detect whether vent stream flow is present every 15 minutes and to estimate and report any releases.' A unqualified prohibition is alarming because bypass lines arc critical process safety devices used to prevent an explosive mixture of gases from accumulating within the header systems connected to the RTO and avoid catastrophic failure. These bypass lines cannot be fully eliminated--without these bypass lines there is nowhere else for these dangerous vapor streams to go. I am concerned that use of the bypass lines for their intended process safety purpose 16 Final Rule at 68, 336, 690. -9- Sierra Club FOIA 2025-EPA-04883 ED_018388_00000138- 00010 SC_EVERSPLIT0005845