Document XO1RZvp2dqnoY5JKV7eX1Gea4

Message From: Sent: To: CC: Subject: Attachments: Roger Claff [Claff@api.org] 6/8/2018 8:03:01 PM Damico, Brian [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=5293065367ab48c2bb2ebadcf992c0d6-BDamico] Wood, Robert [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=b2676cl37cf54db0a5d98df232901821-Wood, Robert]; Forsgren, Lee [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=a055d7329d5b470fbaa9920celb68a7d-Forsgren, D]; Ross, David P [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=119cd8b52ddl4305a84863124ad6d8a6-Ross, David]; Jeff Gunnulfsen [JGunnulfsen@afpm.org] API/AFPM Detailed Comments on Refining ELGs Detailed Study and Refinery Self-Monitoring Program ATT00001.txt; RefiningEffluentGuidelinesLetter.pdf Importance: High Brian, Please find attached our detailed comments on the refining effluent guidelines detailed study, and in particular on the refinery self-monitoring program. As we have discussed, API/AFPM believe refining ELG revisions are not warranted. Should EPA continue the detailed study, the refining self-monitoring program should be narrowly tailored to fill in data gaps, and we maintain naphthenic acids and alkylated PAHs should be removed from the detailed study. We appreciate the on-going dialogue and cooperative relationship that has been forged on the detailed study. As suggested in the letter, we think perhaps a face-to-face meeting to discuss the attached would be a reasonable next step. Once you have had a chance to review the attached, please contact us to arrange such a meeting. We look forward to continuing the discussion with you. Thanks! Roger E. Claff, P.E. Senior Scientific Advisor API 1220 L Street Northwest Washi-n--g--to--n, DC I20005 '(202)6'82-8270'(FAX) claff@api.org www.api.org Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00095285-00001