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 Provisions [EPA-HQ-OAR-2010-0868,-0869,-0870, 0871; 77 Fed. Reg. 17898,

March 26, 2012]

Dear Ms. Lassiter:

The American Chemistry Council (ACC)1requests a 90-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 

proposal was published in the Federal Register on 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 standards requires a 

detailed review of all current regulatory requirements as well as technical analysis of many 

newly proposed requirements in order to provide meaningful comments. This analysis requires 

the review of 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, subparts 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 these 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 exporters, 

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 

efforts, working closely with government agencies to improve security and to defend against any threat to the nation’s critical 

infrastructure.
May 24, 2012

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

If each technical Uniform Standard had 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 Fed. Reg. 960, January 6, 2012). As such, 

we request that EPA extend the comment period for an additional 90 days, until at least 

September 26, 2012, in order to provide these three standards a full 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 Council