December
19,
2002
Greg
H.
Guinther
Senior
Advisor
Fuels
Research
and
Development
Ethyl
Petroleum
Additives,
Inc.
P.
O.
Box
2158
Richmond,
VA
23218­
2158
Dear
Mr.
Guinther,

On
November
15,
2002,
the
Ethyl
Corporation
(
Ethyl)
submitted
to
the
Environmental
Protection
Agency
(
EPA)
a
revised
draft
manganese
emission
characterization
study
protocol
for
MMT,
as
required
under
the
Alternative
Tier
2
Health
Effects
Testing
Requirements.
These
requirements
were
finalized
in
the
notification
received
by
Ethyl
on
May
25,
2000
("
the
notification").
As
you
know,
the
notification
requires
EPA
review
and
approval
of
this
protocol.
This
letter
conveys
the
Agency's
approval
of
the
November
15,
2002,
revised
protocol
as
submitted
by
Ethyl.

We
have
one
comment
regarding
a
statement
in
the
last
sentence
of
the
first
paragraph
of
the
revised
protocol.
This
sentence
currently
reads,
"
Previous
testing
conducted
by
Ethyl
for
EPA
allowed
EPA
to
make
the
determination
that
use
of
MMT
®
will
not
increase
vehicle
emissions
or
cause
or
contribute
to
the
failure
of
these
devices2."
(
Footnote
2
in
this
quote
references
U.
S.
Federal
Register/
Volume
59,
No.
158,
August
17,
1994,
the
1994
MMT
waiver
decision.)
We
would
note
for
purposes
of
clarification
that
the
conclusion
reached
by
the
Agency
in
its
decision
was
only
in
regard
to
regulated
emissions
subject
to
vehicle
certification
standards.
­
2­

We
look
forward
to
Ethyl's
initiation
of
the
manganese
emission
characterization
study
as
required
under
the
notification.
If
you
have
any
questions,
please
contact
Joe
Sopata
of
my
staff
at
(
202)
564­
9034.

Sincerely,

/
s/

Suzanne
Rudzinski
Director
Transportation
and
Regional
Programs
Division
cc:
Monica
Alvarez,
ORD
Dr.
J
Michael
Davis,
ORD
Dr.
James
Braddock,
ORD
Tim
Backstrom,
OGC
Dr.
Don
Lynam,
Ethyl
Corporation
Kevin
Fast,
Hunton
&
Williams
