"Grahame, Thomas" <Thomas.Grahame@HQ.DOE.GOV> 

05/01/2006 06:00 PM

	

To

Bill Wehrum/DC/USEPA/US@EPA

cc

Jason Burnett/DC/USEPA/US@EPA, "Daniels, Jarad"
<Jarad.Daniels@HQ.DOE.GOV>, "Rudins, George" <George.Rudins@HQ.DOE.GOV>

Subject

comments from DOE on proposed NAAQS for Particulate Matter









Dear Mr. Wehrum:

The Department of Energy is pleased to have the opportunity to submit
comments for EPA’s consideration on the January 17, 2006 National
Ambient Air Quality Standard for Particulate Matter Proposed Rule.  In
providing them, we have attempted to address the major questions about
which the Administrator requested information and analysis in the
Proposed Rule.  These comments:  (1) assess the newest methodologies
used in studying health effects of particulate matter; (2) analyze well
over 100 studies from different disciplines, including many very recent
ones, to prepare a coherent analysis of the toxicity of different types
or sources of particles; (3) summarize the health impacts of the major
sources of fine particles in the air today, in separate sections; and,
(4) address specific studies mentioned in the Proposed Rule.  

DOE staff has prepared approximately 220 pages of comments (attached),
which represent the culmination of four years of analysis, work which
produced several previous comments on drafts of the Criteria Document
and of the Staff Paper, as well as two papers published in professional
journals in 2004 and 2005.  These two papers are among the list of 181
new studies, published since the April, 2002 cutoff date for new
studies, which was sent by EPA Administrator Stephen L. Johnson to
Senator James Imhofe at the Senator’s request (letter of November 29,
2005).  DOE staff has also found an additional 59 new studies with
information bearing on the proposed rule, which have already been
provided to EPA staff.  

Attached below are the Table of Contents to the eight sections of the
comments, and the sections themselves.  Sections I, II, and III discuss
how one might look at some of the new literature since the cutoff date
for new studies. Section IV has seven separate subsections, five of
which address specific types or sources of fine PM.  Section V examines
some of the studies critical to the development of the two proposed fine
PM standards.  Section VI addresses coarse PM, and Section VII focuses
on new science helpful in answering the question, “What will happen if
certain types of fine PM are reduced in ambient air?”  The last
attachment is Section VIII, the Summary.  

Thank you for the opportunity to provide comments on the Proposed Rule. 


Thomas J. Grahame

Thomas J. Grahame

U.S. Department of Energy

1000 Independence Ave., SW

Washington, DC 20585

202 586 7149 (voice)

202 586 7085 (fax)

  

  <<TABLE OF CONTENTS.doc>>        <<PM comments -- Sections I, II, and
III.doc>>   <<PM comments -- Strengths and Weaknesses of Source
Apportionment by Receptor Modelling and Factor Analysis.doc>> <<PM
comments -- Vehicular emissions and roadside dust.doc>>   <<PM Comments
-- Industrial PM emissions -- SECTION IV C.doc>>     <<PM comments --
RESIDUAL OIL -- Section IV D.doc>> 

<<PM comments -- SECONDARY SULFATES AND SOA .doc>>     <<PM comments --
Metals .doc>>   <<PM comments -- Recent studies with contrary
findings.doc>>    <<PM comments -- EXAMINATION OF STUDIES CRITICAL TO
PROPOSED FINE PM PROPOSED RULE.doc>>   <<PM comments -- Coarse PM.doc>> 
 

<<PM comments -- what happens if PM types are reduced.doc>>     <<PM
comments -- Summary of PM findings (5).doc>> 

