The following are the key highlights, as seen by TRAA, from a powerful 70-page document submitted by 21 Attorney Generals across the United States, including California AG Rob Bonta. This document focuses on the 11 pages directly related to the use of HF in refineries. The special focus put on HF by the AGs comments is both a reflection of the chemical’s extreme risk to frontline communities, and of the decades-long effort to eliminate the use of HF in favor of a vastly safer alternative.
The bottom line of this Comment Letter is stated on page 43: “It is EPA’s responsibility to pave the way for the elimination of hydrofluoric acid alkylation.”
The Comment Letter submitted to EPA is extremely dense and heavily footnoted with powerful support for each of the points. While selecting most (but not all) of the key points, this summary is still 6 Pages! We added the numbering for clarity, but did not add wording or change the order of the arguments.
Read More to see the full TRAA Comments.
We urge readers to review the entire document with its extensive supporting arguments and footnotes. Link to full AG document.