UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

William J. Erny 

Senior Director 

American Chemistry Council 

700 2nd Street NE ' Washington, DC 20002 

Dear Mr. Erny: 

MAR 2 4 2016 

OFFICE OF 

SOLID WASTE AND 

EMERGENCY RESPONSE 

NOW THE 

OFFICE OF LAND AND 

EMERGENCY MANAGEMENT 

Thank you for your letter of March 15, 2016, to the U.S. Environmental Protection Agency (EPA), 

requesting an extension of the comment deadline for the Accidental Release Prevention Requirements: 

Risk Management Programs under the Clean Air Act proposed rule and the related Information 

Collection Request (ICR). After considering your request, the EPA is unable to grant your request to 

extend the comment deadline on both the proposed rule and the ICR. 

Executive Order (EO) 13650, Improving Chemical Facility Safety and Security, focuses on reducing 

risks associated with hazardous chemical incidents. The EO Working Group, led by the EPA, the 

Department of Homeland Security, and the Occupational Safety and Health Administration, held 

multiple listening sessions, webinars, and meetings with stakeholder groups to solicit feedback on issues 

related to chemical facility safety and security. In addition, the Working Group published a preliminary 

list of options for improving chemical facility safety and security for stakeholder comment. In the EO 

13650 Report for the President entitled Actions to Improve Chemical Facility Safety and Security - A 

Shared Commitment, modernizing the Risk Management Program (RMP) rule was identified as one of 

the top priorities to improve chemical facility safety and security. The report committed the EPA to 

conduct a request for information (RFI) to gather input and begin the regulatory process to modernize 

the RMP. On July 31 , 2014, EPA issued an RFI, seeking comment on potential revisions to modernize 

its regulations, guidance, and policies. 

Since the publication of the RFI, we have held numerous outreach meetings with industry groups and 

collected information through the Small Business Advocacy Review (SBAR) Panel. Thus, EPA's RMP 

proposal reflects substantial input from stakeholders on the elements of the proposed rule to improve 

chemical process safety, assist local emergency authorities in planning for and responding to accidents, 

and improve public awareness of chemical hazards at regulated facilities. 

In addition to the proposed rule's 60-day comment period, the EPA made available a pre-publication 

version on our website two weeks prior to publication. Also via the web, we made available many 

critical supporting documents, including the regulatory impact analysis, the technical background 

document, and the SBAR Panel final report and executive summary. Additionally, the pre-publication 

version of the proposed rule contained numerous footnote references to supporting documents that are 

otherwise available, including reports of the Chemical Safety Board, EPA accident investigation reports, 

Internet Address (UAL) • httpJ/www.epa.gov 

Recycled/Rec yclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer. Process Chlorine Free Recycled Paper 
specific public conunents on the RFI, technical reports and journal articles. In light of the significant 

outreach efforts described above, as well as the substantial amount of supporting material in the public 

domain prior to publication of the proposed rule, we believe that the comment period's current closing 

date allows sufficient time for all interested parties to develop and submit comments on the proposal. 

We trust this timely response is helpful. We look forward to receiving your comments on the proposal 

and the continued collaboration with you and other stakeholders on this important effort. If you have any 

questions, please feel free to contact me. 

Sincerely, 

Reggie Ch

~ eatham, Director 

Office of Emergency Management 
3

EPA sent to the following organizations an identical response dated March 24, 2016 (same response 

sent to ACC) regarding their requests for extension of the comment period deadline for both the 

RMP rule and the RMP ICR. The organizations’ request letters can be found in docket EPA-HQOEM-2015-0725 with the following document IDs:

Addressees Date of Request 

Letter

Document ID

William J. Erny

Senior Director

American Chemistry Council (ACC)

700 2nd Street NE

Washington, DC 20002

March 15, 2016 EPA-HQ-OEM-2015-0725-0288

David C. Ailor, P.E.

President

American Coke and Coal Chemicals Institute

25 Massachusetts Ave, NW, Suite 800

Washington, DC 20001

March 14, 2016 EPA-HQ-OEM-2015-0725-0289

David C. Ailor, P.E.

Regulatory Affairs Advisor

National Oilseed Processors Association

1300 L Street NW, Suite 1020

Washington, DC 20005-4168

March 15, 2106 EPA-HQ-OEM-2015-0725-0290

Robyn Brooks

Director, Health, Environmental, Safety and 

Security

The Chlorine Institute

1300 Wilson Boulevard, Suite 525

Arlington, VA 22209

March 15, 2016 EPA-HQ-OEM-2015-0725-0291

G. Tracy Mehan III

Executive Director, Government Affairs

American Water Works Association

1300 Eye St. NW #701

Washington, DC 20005

March 15, 2016 EPA-HQ-OEM-2015-0725-0307

Javeneh Nekoomaram

Counsel, Government Affairs

American Coatings Association

1500 Rhode Island Ave., NW

Washington, DC 20005

March 15, 2016 EPA-HQ-OEM-2015-0725-0305

Andrew T. O' Hare, CAE

VP, Public Policy

The Fertilizer Institute

425 Third Street, SW, Suite 950

Washington, DC 20024

March 18, 2016 EPA-HQ-OEM-2015-0725-0308

Sharon S. Broome

Counsel for the Chemical Safety Advocacy 

Group

Katten Muchin Rosenman

2900 K Street NW, North Tower, Suite 200

Washington, DC 20007-5118

March 17, 2016 EPA-HQ-OEM-2015-0725-0298

EPA-HQ-OEM-2015-0725-0295
4

Ron Chittim

American Petroleum Institute

1220 L St., NW, # 900

Washington, DC 20005

March 21, 2016 EPA-HQ-OEM-2015-0725-0306

Daniel L. Chartier

Vice President, Government Affairs

Com Refiners Association

1701 Pennsylvania Ave, NW, Suite 950

Washington, DC 20006-5805

March 17, 2016 EPA-HQ-OEM-2015-0725-0309

Kathy G. Beckett

Chair, Environmental Committee

West Virginia Chamber of Commerce

1624 Kanawha Boulevard East

Charleston, WV 25311

March 21, 2016 EPA-HQ-OEM-2015-0725-0296

Keith Robson

Manager Corporate Security, Security, and 

Emergency Preparedness

Marathon Petroleum Company

539 South Main St

Findlay, OH 45840

March 21, 2016 EPA-HQ-OEM-2015-0725-0301

Ross E. Eisenberg

VP, Energy & Resources Policy

National Association of Manufacturers

733 10th Street, NW, Suite 700

Washington, DC 20001

March 22, 2016 EPA-HQ-OEM-2015-0725-0303

Peter Lidiak

VP, Government Affairs

International Liquid Terminals Association

1005 North Glebe Road, Suite 600

Arlington, VA 22201

March 22, 2016 EPA-HQ-OEM-2015-0725-0304

Anne M. Beauchesne

Senior VP, National Security and Emergency 

Preparedness

U.S. Chamber of Commerce

1615 H Street, NW

Washington, DC 20062

March 22, 2016 EPA-HQ-OEM-2015-0725-0310

Richard D. Gupton

Senior Vice President, Public Policy & Counsel

Agricultural Retailers Association

1156 15111 St., NW, Suite 500

Washington, DC 20005

March 22, 2016 EPA-HQ-OEM-2015-0725-0305

Jennifer C. Gibson

VP, Regulatory Affairs

National Association of Chemical Distributors

1560 Wilson Boulevard, Suite 1100

Arlington, VA 22209

March 23, 2016 EPA-HQ-OEM-2015-0725-0306