americanchemistry.com ® 700 Second St., NE | Washington, DC 20002 | (202) 249.7000

Sent Electronically May 24 , 2012 Ms. Penny Lassiter Sector Policies and Program Division , OAQPS U.S. Environmental Protection Agency Research Triangle Park, NC 27711

RE: Request for Comment Period Extension, Proposed National Uniform Emission Standards for Storage Vessel and Transfer Operations, Equipment leaks, and Closed Vent Systems and Control Devices; and Revisions to the National Uniform Emission Standards

General Pr ovisions [EPA

- HQ

- OAR

- 2010

- 0868,

- 0869,

- 0870, 0871 ; 7 7 Fed. Reg. 17898, March 26, 2012 ]

Dear Ms. Lassiter:

The American Chemistry Council (ACC) 1 requests a 9 0

- day extension of the public comment period on the proposed National Uniform Emission Standards for Storage Vessel and Transfer Operations, Equipment Leaks, and Closed Vent Systems and Control Devices; and Revision to the National Uniform Emission Standards General Provisions (Uniform Standards) . This

p roposal was published in the Federal Register o n March 26, 2012 , and has a 90

- day comment period, which is scheduled to close on June 25, 2012

.

EPA’s Uniform Standards proposal is over 150 pages long and will eventually impact almost every aspect of a chemical facility. In that these proposed Uniform Standards do not yet apply to any chemical facilities, the evaluation of each of the three proposed uniform standard s requires a detailed review of all current regulatory requirements as well as technical analysis of many newly proposed re quirements in order to provide meaningful comments. This analysis requires

the review o f many regulatory subparts applicable to the chemical industry including the hazardous organic NESHAP (“HON”), the miscellaneous organic NESHAP (“MON”), the organic liquid distribution NESHAP (“OLD”), multiple “Generic MACT” standards (40 CFR part 63, subpar ts SS, TT, UU, and WW)

, in addition to several New Source Performance Standards (NSPS) and the Synthetic Organic Chemical Manufacturing Industry (SOCMI) rules

. All of the se subparts are lengthy and complex

, and additional time is necessary to ensure that each has been fully reviewed.

1 The American Chemistry Council (ACC) represents the leading companies engaged in the business of chemistry. ACC members apply the science of chemistry to make innovative products and services that make people's lives better, healthier and safer. ACC is committed to improved environmental, health and safety performance through Responsible Care ® , common sense advocacy designed to address major public policy issues, and health and environmental research and product testing. The business of chemistry is a $720 billion enterprise and a key element of the nation's economy. It is one of the nation’s largest e xporters, accounting for ten cents out of every dollar in U.S. exports. Chemistry companies are among the largest investors in research and development. Safety and security have always been primary concerns of ACC members, and they have intensified their

e fforts, working closely with government agencies to improve security and to defend against any threat to the nation’s critica l infrastructure.May 24 , 2012

Page 2

americanchemistry.com ® 700 Second St., NE | Washington, DC 20002 | (202) 249.7000 If each technical Uniform Standard ha d been proposed separately, a 60

- day comment period for each subpart would be appropriate

, as was given with the recently proposed National Uniform Emission Standards for Heat Exchange Systems ( 77 F ed. R eg. 960 , January 6, 2012) . As such, we request that EPA extend the comment period for an additional 9 0 days, until at least September 26, 2012 , in order to provide these three standards a ful l 180 day review period

.

If you have any questions, I can be contacted at (202) 249

- 6411 or lorraine_gershman@americanchemistry.com

.

Very truly yours,

Lorraine Krupa Gershman Director, American Chemistry Cou ncil