In November 2011, INGAA commented on proposed amendments. In response to final Subpart HHH amendments published in August 2012, INGAA submitted a request for reconsideration in September 2012. INGAA understands that EPA likely will amend Subpart HHH after evaluating new information received from interested stakeholders. In addition to responding to the request for information, this letter discusses several items related to clarifications and implementation issues that INGAA anticipates EPA will address in upcoming amendments to Subpart HHH.
INGAA appreciates the opportunity to provide this response on Subpart HHH.