National Emission Standards for Hazardous Air Pollutants; Risk and Technology Review; Site Remediation NESHAP

The American Chemistry Council appreciates the opportunity to submit comments on the U.S. Environmental Protection Agencys proposed National Emission Standards for Hazardous Air Pollutants: Site Remediation Residual Risk and Technology Review. ACC members perform a range of site remediation activities in compliance with the existing NESHAP and will be impacted by the proposed changes in EPAs rulemaking. ACC also filed comments on EPAs 2016 proposal to revise the NESHAP to remove the exemption for site remediation activities conducted under the authority of CERCLA or RCRA (2016 Proposal). In these comments, ACC reiterates key points from our previous submission in addition to offering new information and recommendations on discrete portions of the Proposal to support and improve upon the Agencys proposed changes.