Dec 17, 2019· Comment submitted by Brendan Mascarenhas, Director, Regulatory and Technical Affairs, American Chemistry Council, (ACC), et al.· EPA-HQ-OAR-2018-0074-0056
ACC and ILTA appreciate the opportunity to submit comments on EPA's proposed residual risk and technology review (RTR) for the Organic Liquids Distribution source category (Docket ID No. EPA-HQ-OAR-2018-0074, 84 Fed. Reg. 56288). Please find attached our joint association comments, which were also submitted today via www.regulations.gov. Both ACC and ILTA have members with OLD operations that will be directly impacted by the proposed changes in EPA's rulemaking. As such, these comments address numerous areas of the rulemaking, including EPA's proposed requirements for storage tanks, equipment leaks, fenceline monitoring options, flares, and many others. We also offer specific recommendations where appropriate.