Newsletter

ILTA worked with an industry coalition to provide comments to Chemical Safety Board on its recent reporting rule. The CSB Reporting Industry Coalition asked that CSB consider an alternative approach to what they proposed that was included in the agency’s 2009 Advance Notice of Proposed Rulemaking. That would allow CSB to continue to review media and NRC reports to identify accidents they want to investigate and then request the facility operators to report in greater detail on the incidents of interest. This would avoid CSB collecting nearly 2,000 reports annually and rather look in depth at a much smaller number of incidents each year.

The International Liquid Terminals Association (ILTA) appreciates the opportunity to provide comments on the Surface Transportation Board’s (STB’s) proposal to modify its regulations regarding demurrage billing requirements. The International Liquid Terminals Association (ILTA) represents more than 85 companies operating liquid terminals in all 50 U.S. states and in 37 countries. Our members’ facilities form a critical link in the transportation of a wide range of liquid commodities, including crude oil, refined products, chemicals, renewable fuels, fertilizers, vegetable oils and other food grade materials.

RE: Comments on Proposed National Emission Standards for Hazardous Air Pollutants:
Organic Liquids Distribution (Non-Gasoline) Residual Risk and Technology Review
Docket ID No. EPA-HQ-OAR-2018-0074, 84 Fed. Reg. 56288 (October 21, 2019).

The American Chemistry Council (“ACC”) and the International Liquid Terminals Association (ILTA)
respectfully submit these comments on the U.S. Environmental Protection Agency’s (“EPA”) proposed
National Emission Standards for Hazardous Air Pollutants (NESHAP): Organic Liquids Distribution
(OLD) (Non-Gasoline) Residual Risk and Technology Review (84 Fed. Reg. 56288, October 21, 2019)
(“proposed standards”).

The International Liquid Terminals Association (ILTA) appreciates the opportunity to provide comments on the Surface Transportation Board’s (STB’s) proposal to modify its regulations regarding demurrage billing requirements. The International Liquid Terminals Association (ILTA) represents more than 85 companies operating liquid terminals in all 50 U.S. states and in 37 countries. Our members’ facilities form a critical link in the transportation of a wide range of liquid commodities, including crude oil, refined products, chemicals, renewable fuels, fertilizers, vegetable oils and other food grade materials.