SOCMA: Society of Chemical Manufacturers and Affiliates

Comments & Testimony

Comments on 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; Proposed Rule, September 24, 2012.

Comments on National Emission Standards for Hazardous Air Pollutant Emissions: Group IV Polymers and Resins; Pesticide Active Ingredient Production; and Polyether Polyols Production: Proposed Rule, March 30, 2012.

Comments on National Emission Standards for Hazardous Air Pollutants for Chemical Manufacturing Area Sources: Reconsideration of Final Rule; Request for Interpretation. March 30, 2012.

Comments on National Uniform Emission Standards for Heat Exchange Systems: Proposed Rule, March 6, 2012.

Comments on National Emission Standards for Hazardous Air Pollutants for Area Sources: Industrial, Commercial, and Institutional Boilers, February 21, 2012.

Comments on Definition of Solid Waste Proposed Rule, October 20, 2011

SOCMA Statement at DSW Public Meeting, September 12, 2011

Letter regarding Chemical Manufacturing Area Sources -- National Emission Standards for Hazardous Air Pollutants, August 10, 2011

Coalition Letter on Financial Assurance, July 27, 2011

Coalition Letter of Support for Boiler MACT Legislation in the Senate, July 20, 2011

SOCMA Letter of Support for H.R. 2250, The EPA Regulatory Relief Act of 2011; June 30, 2011

Comments on “Considering Environmental Justice in Permitting”; June 30, 2011

Testimony on Impact of EPA Regulations on Small Businesses; May 16, 2011

Comments on the Design of EPA’s Plan for the Periodic Retrospective Review of Its Regulations; April 4, 2011

Comments on “National Emissions Standards for Hazardous Air Pollutants for Chemical Manufacturing Area Sources” Proposed Rule; January 28, 2011

Comments on “National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial and Institutional Boilers” Proposed Rule; August 23, 2010

Comments on “National Emission Standards for Hazardous Air Pollutants for Area Sources: Industrial, Commercial and Institutional Boilers” Proposed Rule; August 23, 2010

Comments on "Oil Pollution Prevention: Spill Prevention, Control, and Countermeasure (SPCC) Rule — Proposed Rule (Compliance Date Extension)"; August 18, 2010

Comments on “Identification of Additional Classes of Facilities for Development of Financial Responsibility Requirements Under CERCLA Section 108(b)” -- Advance Notice of Proposed Rulemaking, 75 Fed. Reg. 816 (Jan. 6, 2010); April 6, 2010 

Comments on "Draft Environmental Justice Methodology for the Definition of Solid Waste Final Rule"; March 15, 2010

Comments on Definition of Solid Waste June 30, 2009 Public Meeting; August 13, 2009

Comments on “Oil Pollution Prevention; Spill Prevention, Control, and Countermeasure (SPCC) Rule Requirements – Amendments”; March 5, 2009

Comments on Proposed Performance Specification 17 (PS-17) and Quality Assurance Requirements (Procedure P-4) for Continuous Parameter
Monitoring Systems; February 5, 2009

Comments on Chemical Manufacturing Area Sources NPRM; January 5, 2009

Testimony of Steve Poorman, International EHS Manager of FujiFilm Imaging Colorants, on behalf of SOCMA regarding EPA’s Proposed NESHAP “Area Sources” Rule before an U.S. EPA Public Hearing, October 21, 2008.

Comments on Oil Pollution; Spill Prevention, Control, and Countermeasure (SPCC) Rule Requirements-Amendments; December 14, 2007.

Comments on the Supplemental Reproposal on the Definition of Solid Waste; June 25, 2007 

Comments in support of National Emissions Standards for the Hazardous Air Pollutants for Source Categories; General Provisions (Once In, Always In); May 4, 2007

Comments in support of EPA's proposed compliance extension for SPCC plans; January 25, 2007 

Comments on Draft Kentucky Air Toxics Regulations; November 15, 2006

Comments on Prevention of Significant Deterioration (PSD), and Nonattainment New Source Review (NSR): Debottlenecking, Aggregation and Project Netting; November 13, 2006

Comments on Revisions to Standards of Performance for New Stationary Sources, National Emission Standards for Hazardous Air Pollutants, and National Emission Standards for Hazardous Air Pollutants for Source Categories; November 7, 2006

Letter to U.S. Senators from SOCMA and Industry Coalition in Support of Protecting TRI Reform; November 2, 2006

Comments on EPA's Proposed Rule-Standards Applicable to Generators of Hazardous Waste; Subpart K-Standards Applicable to Academic Laboratories; September 20, 2006

Comments on EPA's Proposed Residual Risk Rule for the Synthetic Organic Chemical Manufacturing Industry; August 14, 2006 

Comments on the Oil Pollution; Spill Prevention, Control, and Countermeasure Plan Requirements-Amendments; February 10, 2006

Comments on the SPCC Guidance for Regional Inspectors; February 10, 2006

Comments on National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing ("MON"); January 24, 2006

Comments on the Toxics Release Inventory Burden Reduction Proposed Rule; January 13, 2006

Comments on Oil Pollution Prevention and Response; Non-Transportation-Related Onshore and Offshore Facilities; January 11, 2006

Comments on Availability and Procedures for Removal Credits; December 13, 2005

Comments on National Emissions Standards for Hazardous Air Pollutants; General Provisions; September 12, 2005

Comments on Reconsideration of the National Emission Standards of Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters; August 11, 2005

Comments on Toxic Release Inventory Reporting Forms Modification Proposed Rule; March 11, 2005

Comments on Oil Pollution Prevention and Response; Non-Transportation-Related Onshore and Offshore Facilities; November 19, 2004

Comments on Streamlining the General Pretreatment Regulations for Existing and New Sources of Pollution; November 17, 2004

Comments in support of Petition to Delist Methyl Isobutyl Ketone from the list of Hazardous Air Pollutants; August 16, 2004

Comments on the Proposed Rule on Revisions to the Definition of Solid Waste; February 25, 2004

Comments on EPA's Proposed Rule on Identification and Listing of Hazardous Wastes: Dyes and/or Pigments Production Wastes; February 23, 2004

Comments on the Accidental Release Prevention Requirements: Risk Management Program Requirements Under Clean Air Act Section 112(r)(7); Amendments to the Submission Schedule and Data Requirements; September 10, 2003

Comments on Toxic Chemical Release Reporting; Alternate Threshold for Low Annual Reportable Amounts; Request for Comment on Renewal Information Collection; September 2, 2003

Comments on List of Hazardous Air Pollutants, Petition Process, Lesser Quantity Designations, Source Category List; August 28, 2003

Comments on EPA's Proposed Changes to the National Emissions Standards for Hazardous Air Pollutants for Source Categories: General Provisions (Once In, Always In); July 14, 2003

Comments on EPA's new Enforcement and Compliance Online (ECHO) database; March 31, 2003

Comments on EPA's Proposed Rule On Establishing National Emissions Standards For Hazardous Air Pollutants For Industrial/Commercial/Institutional Boilers And Process Heaters; March 14, 2003

Comments on EPA's Draft Strategy for National Clean Water Industrial Regulations; March 11, 2003

Comments on the Proposed Effluent Guidelines Program for 2002/2003; July 18, 2002