American Chemistry Council
EPARulemakingEPA-HQ-OAR-2017-0357

Residual Risk and Technology Review for National Emission Standards for Hazardous Air Pollutants for Ethylene Production

RIN
Last modified
Feb 28, 2025
Comment window
closed 484d ago
American Chemistry Council filings
2

Activity

American Chemistry Council filed 2 comments on this docket between Dec 13, 2019 and Oct 16, 2020. 6 other organizations filed here. The comment window closed 484d ago.

What American Chemistry Council filed (2)

Oct 16, 2020· Petition for Reconsideration submitted by Brendan Mascarenhas, Director, Regulatory and Technical Affairs, American Chemistry Council and David Friedman, Vice President, Regulatory Affairs, American Fuel Petrochemical Manufacturers· EPA-HQ-OAR-2017-0357-0076

Filed on regulations.gov — full text not in the inline record.

Dec 13, 2019· Comment submitted by Brendan Mascarenhas, Director, Regulatory and Technical Affairs, American Chemistry Council (ACC) and David Friedman, Vice President, Regulatory Affairs, American Fuel & Petrochemical Manufacturers (AFPM)· EPA-HQ-OAR-2017-0357-0040

ACC and AFPM appreciate the opportunity to submit comments on EPA's proposed residual risk and technology review for the ethylene production source category (Docket ID No. EPA-HQ-OAR-2017-0357). Please find attached our joint association comments. Both associations' members have significant facility representation in the EMACT source category and are thus directly impacted by the proposed changes in EPA's rulemaking. As such, these comments address numerous areas of the rulemaking, including EPA's proposed conclusions from its risk analysis, proposed technology changes (e.g. requirements for flares, PRDs, storage tanks, equipment leaks, heat exchangers, etc.), and proposed requirements for decoking and SSM periods. The comments provide a detailed analysis of priority areas and accompanying recommendations for each.

Abstract

Pursuant to Clean Air Act sections 112(d)(6) and 112(f)(2), this action will address the agency’s residual risk and technology review (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Ethylene Production (i.e., 40 CFR part 63, subparts XX and YY). All significant materials associated with the development of the Ethylene Production RTR will be maintained in this docket.

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