ILTA and the American Chemistry Council submitted joint comments December 5 on EPA’s proposed National Emission Standards for Hazardous Air Pollutants: Organic Liquids Distribution (Non-Gasoline) Residual Risk and Technology Review. ACC and ILTA said they agreed with EPA’s determination that risk from the OLD source category is acceptable, and that no changes to the standards are necessary to provide an ample margin of safety.
“Implementation of the underlying NESHAP has been successful,” they stated. “Despite finding very low risk from the source category, EPA has proposed to increase the regulatory burden of the standards. We offer explanations of our disagreements with the agency’s proposal as well as further suggestions and comments to support and improve upon the agency’s determinations.”