ILTA, Allies, Comment on Proposed Amendments for Liquid Tank Inspections
International Liquid Terminals Association
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Letters, Comments & Testimony

Cathy Landry

ILTA, Allies, Comment on Proposed Amendments for Liquid Tank Inspections

Strongly support the proposed amendments, greatly appreciate EPA’s efforts

U.S. Environmental Protection Agency
WJC West Building (Air Docket), Room 3334
1301 Constitution Ave., NW
Washington, DC 20004

Attention: Docket ID Number EPA–HQ–OAR–2020–0372
submitted via

Re: Environmental Protection Agency’s (EPA’s) revisions to 40 CFR part 60 subpart Kb, proposed at 85 FR 65774 (October 16, 2020).
To Whom It May Concern:

The International Liquid Terminals Association (ILTA), the American Fuel & Petrochemical Manufacturers (AFPM), and the American Petroleum Institute (API) appreciate the opportunity to provide comments on the proposed amendments to the “Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984,” 40 CFR Part 60, Subpart Kb (85 FR 65774, October 16, 2020).

Our organizations strongly support the proposed amendments and we greatly appreciate EPA’s efforts to address an issue that became especially challenging in recent months due to imbalances in petroleum and fuels markets constraining the storage sector. We urge the Agency to finalize this proposal as quickly as possible and to provide interim regulatory relief until promulgation.

We appreciate your consideration of our comments. If you have any questions about this submittal, please contact us.


Kathryn Clay
International Liquid Terminals Association 1005 N. Glebe Road, Suite 600 Arlington, VA 22201

David N. Friedman
Vice President
Regulatory Affairs
American Fuel & Petrochemical
1800 M Street NW, Suite 900 N
Washington, DC 20036

David Murk
Pipeline Manager
American Petroleum Institute
200 Massachusetts Ave NW
Washington, D.C. 20001
(202) 682-8080


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