NACAA has submitted comments to EPA on the proposed revisions to the New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry (commonly known as the Hazardous Organic NESHAP – or the “HON”) and Group I & II Polymers and Resins Industry, which were proposed on April 25, 2023. In the comments, NACAA expressed support for measures to significantly reduce emissions of EtO and other hazardous air pollutants (HAPs) from HON sources and recommended that EPA accelerate the research needed to develop accurate monitoring, sampling and analytical methods for EtO and improve the understanding of the formation, prevalence and role of background EtO concentrations. NACAA also supported EPA’s plan to require fenceline monitoring to provide nearby communities, regulatory agencies and the facilities with important information about emissions levels, exposure and the efficacy of control equipment. NACAA supported EPA’s community-based risk assessment that expanded the analysis of the impacts of emissions to include other operations and pollutants beyond the source category but recommended that it be expanded in the future to include other types of sources (e.g., mobile sources) and other routes of exposure beyond inhalation. Finally, NACAA endorsed EPA’s continued reliance on the Integrated Risk Information System (IRIS) toxicity value for EtO when assessing risk.
For further information:
https://www.4cleanair.org/wp-content/uploads/HON-NACAA-letter-June-22-2023.pdf
and
