July 1, 2004

EPA Docket Center

1301 Constitution Ave., NW.,

EPA West, Suite B--102

Washington, DC 20460

> Re: Proposed Rule to Extend, by Twelve Months Certain Upcoming
> Compliance Dates for the July 2002 Spill Prevention Control and
> Countermeasure (SPCC) Amendments. Docket ID No. OPA--2004--0003.

Dear Sir/Madam:

The Synthetic Organic Chemical Manufacturers Association (SOCMA) is
pleased to submit these comments in support of EPA's proposal to extend
the compliance dates for the SPCC amendments. SOCMA is the leading trade
association representing the batch and custom chemical industry. SOCMA's
300+ member companies make the products and refine the raw materials
that make our standard of living possible. From pharmaceuticals to
cosmetics, soaps to plastics and all manner of industrial and
construction products, SOCMA members make materials that save lives,
make our food supply safe and abundant, and enable the manufacture of
literally thousands of other products. Over 70% of SOCMA's active
members are small businesses.

Due to the number and complexity of outstanding concerns and technical
issues related to the amendments, this compliance extension is much
needed and long over-due. Many SOCMA members, faced with the impending
August deadline to revise their plans, have been squeezed between
regulatory deadlines and uncertainty with regard to the substantive
requirements. This situation does not create a good environment in which
to develop robust SPCC plans which ensure the protection of our nation's
waterways while avoiding wasteful and unnecessary expenditures of
limited resources. SOCMA requests that this proposed extension be
enacted post-haste.

SOCMA believes that a twelve month extension is the *minimum* needed for
resolution of the numerous outstanding issues. While we understand that
EPA is not accepting comments on substantive issues through this
rulemaking, we would like to at least highlight some of the areas where
there is still concern and uncertainly. These issues include integrity
testing requirements for certain tanks, secondary containment
requirements for loading racks and piping, clarification of the
definition of oil, oil in operating and electrical equipment, oil in

wastewater treatment, and the definition of "waters of the U.S." SOCMA
also supports the measures proposed by the U.S. Small Business
Administration in its June 10, 2004 letter to EPA to develop a tiered
regulatory approach for small facilities.

We believe that while progress has been made in resolving these and
other issues that remain the subject of consideration and discussion,
there is still much work to be done. Due to the technical complexity of
many of the questions that have arisen, the twelve month extension is an
aggressive time frame to work through the outstanding issues and still
provide sufficient time for the facilities to prepare their revised
plans. We believe that an eighteen month extension would be more
appropriate, especially if the White House Office of Management and
Budget and the EPA Office of Policy will be asked to review any rule
changes.

While we appreciate the degree to which EPA has been engaged with
stakeholders, including SOCMA, on these issues, most remain far from
resolution. The amendments potentially affect a large number of SOCMA's
membership, and the cost of revising and implementing plans, including
inspection and certification requirements, will be quite expensive.
Based on the diversity of issues and affected stakeholders, all
participants in this process will have be diligent in working to resolve
these issues over the next few months in order for the regulated
community to amend their SPCC plans by August 2005.

Thank you again for the opportunity to comment on this important
proposal. In closing, I would like to reiterate the importance of this
extension being finalized as soon as possible, especially prior to the
current deadline to amend SPCC plans on August 17, 2004. If you have any
questions please contact either myself at (202) 721-4198 or Eric Clark
at (202) 721-4143.

Sincerely,

Jeff Gunnulfsen

Manager, Government Relations