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Review of National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing
Activity
American Chemistry Council filed 8 comments on this docket between Feb 21, 2020 and Apr 6, 2022. 4 other organizations filed here. The comment window closed 1587d ago.
What American Chemistry Council filed (8)
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Comments from the American Chemistry Council on EPA's proposed MON RTR as filed March 19, 2020.
Please see attached comments. This submission replaces the February 2020 submission from ACC's Ethylene Oxide Panel.
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ACC submits these comments on the EPA's proposed NESHAP for its risk and technology review for the Miscellaneous Organic Chemical Manufacturing source category. Although ACC supports elements of the proposal, some provisionssuch as additional controls on ethylene oxide (EO) emissionsare not supported by the science and warrant modifications or removal prior to the rule being finalized.
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Abstract
This docket contains information to address the Agency's residual risk and technology review (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Organic Chemical Manufacturing (MON). This NESHAP was promulgated pursuant to section 112(d) of the Clean Air Act (CAA) and established emission limitations and work practice requirements based on maximum achievable control technology (MACT) for controlling emissions of hazardous air pollutants. The MON, subpart FFFF, was promulgated pursuant to section 112(d) of the Clean Air Act (CAA) on November 10, 2003. The NESHAP controls emissions of HAP from continuous process vents, batch process vents, storage tanks, equipment leaks, wastewater streams, transfer racks and heat exchange systems. This review implements the residual risk review requirements of CAA section 112(f)(2) and the technology review requirements of CAA section 112(d)(6). CAA 112(f)(2) directs EPA to revise the NESHAP if such revisions are required to provide an ample margin of safety to protect public health or to prevent, taking relevant factors into account, an adverse environmental effect. CAA section 112(d)(6) requires the EPA to review and revise the MACT standards as necessary, taking into account developments in practices, processes and control technologies, no less often than every 8 years.
View on regulations.gov →Co-filers (4)
See everyone who commented →- American Chemistry CouncilTHIS ORG8 filings · confidence 97%
- Advanced Medical Technology Associationtrade assoc.2 filings · confidence 97%
- American Coatings Associationtrade assoc.1 filing · confidence 97%
- American Petroleum Institutetrade assoc.1 filing · confidence 97%
- U.S. Chamber of Commerce1 filing · confidence 97%