Comment submitted by Kevin McGrath, Senior Manager of Environmental Affairs, Onyx Environmental Services, L.L.C.

January 16, 2006 Air and Radiation Docket U.S. Environmental Protection Agency Mailcode: 6102T 1200 Pennsylvania Avenue, NW Washington, DC 20460 Re: Docket ID Number OAR-2003-0138 Dear Sir or Madam: Onyx Environmental Services, L.L.C. (Onyx), a leader in the hazardous waste service industry, is pleased to present comments to the USEPA on the amendments to the proposed National Emission Standards for Hazardous Air Pollutants: Organic Liquids Distribution (Non-Gasoline) regulations (69 FR 69210- 69237) published on November 14, 2005. Onyx is a provider of hazardous waste management services to generators nationwide. These services include field operations, transportation, commercial storage, recycling, incineration, and fuel blending operations. These proposed regulations could impact the storage and transfer requirements for recycled solvents at Onyx facilities. In general, Onyx supports the proposed regulations to control emissions from Organic Liquids Distribution. Onyx?s specific comments are provided below. 40 CFR 63.2342 ? When Do I Have To Comply With This Subpart The proposed rule requires that an existing affected source must comply with the emission limitations and work practice standards for existing sources no later than three years after the effective date of the final rule. As proposed, 40 CFR 63.2342 (b)(2) would allow floating roof storage tanks to come into compliance with these regulations after the next degassing and cleaning activities, or within ten years after the effective date of the final rule. Similar relief in the proposal is not provided to other types of storage tanks. Onyx believes the same flexibility for providing upgrades should apply to all existing storage tanks. It is Onyx?s opinion that the emissions produced by emptying and degassing a tank in order to perform the required alterations would exceed the cumulative reductions in emissions occurring in the years following alteration of the tank. The emissions released during the alterations typically would not be offset by the total emission reductions until at least seven years after the alterations are completed. Upon review of these comments, should the Agency have a need for additional information from Onyx, please contact Kevin McGrath at (402) 991-6666 (e-mail; kmcgrath@onyxes.com), or Tom Baker at (973) 691-7330 (e-mail; tbaker@onyxes.com). Onyx appreciates the opportunity to provide input on these proposed regulations. Sincerely, Kevin D. McGrath Senior Manager of Environmental Affairs