NACAA submitted comments to EPA on the proposed National Emission Standards for Hazardous Air Pollutants (NESHAP) for ethylene oxide (EtO) emissions standards for Commercial Sterilizers and the associated Residual Risk and Technology Review, which was proposed on April 13, 2023. NACAA expressed support for measures to significantly reduce emissions of EtO and other hazardous air pollutants (HAPs) from commercial sterilizers and offered recommendations pertaining to EPA’s proposal. Specifically, NACAA urged EPA to: accelerate the research needed to develop accurate monitoring, sampling and analytical methods for EtO; improve the understanding of the formation, prevalence and role of background EtO concentrations; call for fenceline monitoring or some sort of ambient monitoring to provide nearby communities, regulatory agencies and the facilities with important information about emissions levels, exposure and the efficacy of control equipment; address off-site emissions, which can be significant, including those from aeration facilities, storage warehouses and other locations; require that area source EtO commercial sterilizers subject to subpart O obtain Title V permits; and expand its analysis of the risks and impacts of emissions to include other operations and pollutants beyond those in the source category. NACAA also 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/Commercial-Sterilizers-NACAA-Letter-June-22-2023.pdf
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