Document 93zZQ848x25LpY9Yy9L9YaoQL

associations the American Chemistry Council (ACC) and the American Fuel & Petrochemicals Manufacturers (AFPM). We believe that the Administration has already been provided with sufficient information (including prior comments and the underlying petition for reconsideration on the HON rule) to support an exemption covering all regulated facilities or on a facility-specific basis. This letter provides additional detail and support on the time-critical 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 facility-specific information if the President pursues a facility-specific exemption action. SABIC operates a manufacturing plant in Mt. Vernon Indiana that is subject to EPA's HON final rule. Specifically, the final HON rule significantly impacts manufacturing processes for phenol and BPA that are key raw materials for polycarbonate (PC) and co-polycarbonates. PC and co-polycarbonates are amorphous engineering thermoplastics used in a diverse set of domestic applications and markets, including health care; consumer electronics, aerospace, mobility, military, infrastructure, and personal protective wear. Their transparency, high impact strength, mechanical performance, heat resistance, thermal performance, chemical resistance, and resistance to fire and corrosion, along with other chemical and physical properties uniquely suit them for key applications in medical devices, health care, and automotive safety. SABIC's HON plants are significant contributors to the economic health and employment opportunities in their locations. SABIC estimates that to comply with HON final rule, significant upgrade to existing equipment including new or updated emissions control devices will be required resulting in significant capital expenditures and operating expenses for our SABIC HON affected process units. In addition, our phenol and BPA plant would require unplanned shutdowns to implement capital projects and would tremendously impact the production of polycarbonates. SABIC's PC plants represent over 60% of the domestic PC capacity to serve the American markets. Based on compliance timeline provided in the final HON rule at 40 CFR 63.100(k)(10) and (12) for existing sources, the decision about capital expenditures would need to be made as early as April/May of 2025. The HON final rule does not provide sufficient time to upgrade existing equipment and emissions control devices or install new control devices which require significant time in planning, designing, procurement and installing equipment. Therefore, we request additional compliance time of at least two more years to comply with final HON rule for existing sources beyond compliance time provided at 40 CFR 63.100(k)(10) and (12). We thank EPA for your consideration of this request. If you have any questions, please free to contact Balvant Darji via email at balvant.darji@sabic.com. Thank you very much. Sincerely, Niall McConville President and Director SABIC Mt. Vernon Manufacturing Sierra Club FOIA 2025-EPA-04883 ED_018388_00000243-00002 SC_EVERSPLIT0006011