EPN Comments on Amendments to NESHAP for HCl Production and the Ethylene Oxide Health Risk Factor

On February 4, 2019, EPA published proposed amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Hydrochloric Acid (HCl) Production source category and the Ethylene Oxide Health Risk Factor. The proposed amendments address the startup, shutdown, and malfunction provisions of the rule; add electronic reporting; and update the reporting and record keeping requirements. The agency proposal also seeks comment on the science-based health risk factor for ethylene oxide (EtO), which is a compound used for a variety of industrial purposes, from sterilizing medical equipment to producing antifreeze. The ability of EtO to damage DNA makes it an effective sterilizing agent but also accounts for its cancer-causing activity. After long classifying EtO as “possibly” carcinogenic, in December 2016, EPA reassessed the public health “risk value” for EtO and determined that long-term exposure could cause elevated risks for certain types of cancer such as non-Hodgkin lymphoma, myeloma, lymphocytic leukemia and breast cancer. In response, EPN has produced the following comments, which address the procedurally flawed and substantively inappropriate request for comment on the risk value associated with EtO, an air toxic that is not emitted by HCI Production sources.

Read a summary of the comments: Summary of EPN Comments on NESHAP for the HCl Production Source Category and the Ethylene Oxide Health Risk Factor

Read the full comments: EPN Comments on NESHAP for the HCl Production Source Category and the Ethylene Oxide Health Risk Factor