Document 0JyQ6YJYwxx7q7ng7j58gVNLx

Vesttake PO Box 2449 Sulphur LA 70664 Tel 337 583 3100 We align our request with the perspective acknowledged by the President in Executive Orders and by key security agencies that economic security is indeed national security. This viewpoint is critical as our industry plays a foundational role in various domestic manufacturing supply chains, and any disruption could pose risks to our nation's security interests. The joint coalition submission from the American Chemistry Council (ACC) and the American Fuel & Petrochemicals Manufacturers (AFPM) further underscores the importance of HON regulated chemicals as crucial building blocks and the potential national security risks if production is hindered. As outlined in a letter submitted on behalf of industry by AFPM and ACC, Westlake agrees that CAA 112(i)(4) does not require that the President provide the bare minimum amount of time needed to obtain and install controls, and similarly requests that any exemption granted under this section be a length of 2 years with an option for EPA to consider a renewal for facilities for which compliance processes may run longer than 2 years, As previously outlined in Westlake's prior requests for extension of time as well as the joint coalition's comments on and petition for reconsideration of the HON Rule, we believe that the Administration has already been provided with sufficient information to support an exemption covering all regulated facilities or on a facility-specific basis. This letter provides additional detail and support on the timecritical nature of the request for relief and to address EPA's request for information. We submit both in support of a category-wide grant, as well as to provide company-specific information if the President pursues a facility-specific exemption action. This letter serves to reinforce the urgency of our request and to respond to F.PA's call for additional information. Details to support this request are summarized below. Specifically, our Westlake Petrochemical Complex, Styrene Monomer Production Facility, and Styrene Marine Terminal are subject to the HON Rule amendments and would face challenges in obtaining and implementing the technology required to corne into compliance with the new standards by the compliance deadlines currently in place. The potential for delays in coming into compliance due to availability of equipment, long lead times in project planning, availability and coordination of resources including contractor resources and the time needed to undertake detailed planning and engineering for compliance projects could potentially lead to impacts in production and possible decreases in production volumes or unit shut downs. First, Westlake's Petrochemical Complex, Styrene Monomer Production Facility, and Styrene Marine Terminal are likely subject to the lION's new requirements in 40 C.F.R. Part 63, Subparts F, G, and Il. The Site's units, were constructed or reconstructed on or before April 25, 2023. Accordingly, the HON's compliance date for the new Section 112(d) requirements is July 15, 2027, (i.e., three years after the Rule's effective date). Next, Westlake's Petrochemical Complex, Styrene Monomer Production Facility, and Styrene Marine Terminal are also impacted by the removal of Startup, Shutdown and Malfunction (SSM) provisions, which will require certain HON process, storage vessel, surge control and bottoms receiver vents be captured and sent to control. This impact may require installation of additional controls due to the additional process vent loads, which will be required to be routed to control at all times. the current compliance dates for control of all HON process vent, storage vessel, surge control and bottoms receiver vents are insufficient for Westlake's Petrochemical Complex, Styrene Monomer Production Facility, and Styrene Marine Terminal to effectively plan, purchase, and install emission control equipment that is needed to comply with the new HON rule requirements. Page 2 of 4 www.Westlake.com Sierra Club FOIA 2025-EPA-04883 ED_018388_00000104-00002 SC_EVERSPLIT0005664