cover image: Via Electronic Submission at Regulations.gov

20.500.12592/grvmgg

Via Electronic Submission at Regulations.gov

31 Oct 2022

(“EPA believes that the consolidation of the required chemical hazard and facility information may present a more comprehensive picture of the vulnerabilities of a facility than would be apparent from any individual element and requiring it to be made more easily available to the public from a single source (i.e., the facility itself) could increase the risk of a terrorist attack on some facilitie. [...] 4 Further, the Proposal is redundant to the extent that it would require the disclosure of certain information already available to the public under the Emergency Planning and Community Right- to-Know Act (EPCRA) reporting requirements, the 40 C. [...] While regulated facilities will certainly continue to coordinate with local emergency responders in notifying the public of and responding to a release, regulated facilities should not be subject to a regulatory condition that involves attempting to control whether and how third-party local emergency responders notify the public of and respond to releases. [...] Changes to the definition of “stationary source” USWAG agrees with the position of the American Gas Association (“AGA”) supporting EPA’s proposal to continue excluding from the definition of “stationary source” at 40 C. [...] Like AGA, however, we take issue with EPA’s proposal to change the definition of “storage incident to transportation” to state that “A transportation container is in storage incident to transportation as long as it is attached to the motive power that delivered it to the site (e.g., a truck or locomotive).

Authors

Keithline, Nathan C.

Pages
5
Published in
United States of America