Ethylene Oxide Update #28: December 19, 2019

In this update:

• IEPA issues construction permit to Vantage limiting EtO emissions to 110lbs per calendar year: https://bit.ly/36ZdC5J
• IEPA provides responses to questions asked during construction permit Public Comment period: https://bit.ly/2S6xJuw
• US EPA has released an Advanced Notice of Proposed Rulemaking for Commercial Sterilization: https://bit.ly/2EuotYP
• US EPA is proposing amendments to the 2003 Miscellaneous Organic Chemical Manufacturing National Emission Standards for Hazardous Air Pollutants (NESHAP): https://bit.ly/2r5KnyB
• Village website updated to include user-friendly, abbreviated EtO updates: www.gurnee.il.us/eto
• Continuous monitoring equipment on Vantage emissions stack now operational.

The following developments and communications have occurred since the last formal Village update provided on December 12, 2019:

Illinois Environmental Protection Agency (IEPA): On December 17, 2019 the IEPA issued a construction permit to Vantage Specialties, Inc. which sets an annual cap on the emissions of ethylene oxide (EtO).  The cap is 110lbs per calendar year, with no more than 60lbs from fugitive emissions.  The cap is a 90% reduction in EtO emissions compared to prior year reporting, which can be found at:  https://enviro.epa.gov/facts/tri/ef-facilities/#/Release/60031MZRCH3938P.  The permit also sets requirements for emissions monitoring, operational monitoring, monitoring of components for leaks, recordkeeping and reporting related to EtO emissions to address compliance with the 110lb annual cap. The permit does not authorize changes that would increase production capacity or EtO emissions.  Under the permit, Vantage must submit quarterly reports to the IEPA within 30 days of the end of each quarter.  The reporting must contain cumulative emissions of ethylene oxide from the facility in total, which includes a breakdown of stack vs. fugitive emissions.  This reporting will be posted on the IEPA website.  Per the permit, if total emissions are trending ahead of what is expected on a quarterly basis, Vantage must report why and if this trend is expected to continue.  Any deviations from the permit must be reported to the IEPA within 5 days of the deviation.  Finally, the permit states that the IEPA may, as specifically provided for by Public Act, reopen this permit if the IEPA determines that the emissions of EtO from Vantage pose a risk to  the public health as defined by the IEPA. 

The permit can be viewed at:  https://www2.illinois.gov/epa/topics/community-relations/sites/ethylene-oxide/Documents/19100015.pdf

The IEPA has also posted its responses to 106 questions raised during the Public Comment period for the construction permit.   The responses have been arranged by subject matter. The Village strongly encourages interested individuals to take the time to review the IEPA responses. 

The responses can be viewed at:  https://www2.illinois.gov/epa/topics/community-relations/sites/ethylene-oxide/Documents/Responsiveness%20Summary%20-%20Vantage%20Specialties.pdf

United States Environmental Protection Agency (US EPA): The US EPA has released an Advanced Notice of Proposed Rulemaking for Commercial Sterilization. This action promulgates National Emission Standards for Hazardous Air Pollutants (NESHAP) for ethylene oxide commercial sterilization and fumigation operations. These standards implement section 112 of the Clean Air Act and are based on the Administrator's determination that commercial sterilization and fumigation operations emit ethylene oxide, a pollutant identified in the Act list of 189 hazardous air pollutants (HAP). The intent of the standards is to protect public health by requiring existing and new major sources to control emissions to the level achievable by the maximum achievable control technology (MACT) and by requiring existing and new area sources to control emissions using generally available control technology (GACT).

The full proposed rulemaking summary can be found here: https://www.epa.gov/stationary-sources-air-pollution/ethylene-oxide-emissions-standards-sterilization-facilities

The US EPA is also proposing amendments to the 2003 Miscellaneous Organic Chemical Manufacturing National Emission Standards for Hazardous Air Pollutants (NESHAP), known as the MON. After fully implementing the NESHAP, EPA has evaluated the risks remaining  and determined cancer risks from the miscellaneous organic chemical manufacturing source category to be unacceptable. To reduce risks to an acceptable level, EPA is proposing additional requirements for process vents, storage tanks and equipment in ethylene oxide service. Once these requirements are implemented, EPA proposes that risks are acceptable and provide an ample margin of safety to protect public health and the environment.

The full fact sheet and memorandum on risk estimates to dose-response model selection can be found here: https://www.epa.gov/stationary-sources-air-pollution/miscellaneous-organic-chemical-manufacturing-national-emission-0

Village of Gurnee:  The Village of Gurnee has updated its website to include a more user-friendly, abbreviated summary of EtO updates since October 22, 2018.  The summary is in chronological order starting with the most recent information released by the Village.  It can be viewed at: www.gurnee.il.us/eto or www.gurnee.il.us/residents/safety/ethylene-oxide

Vantage Specialty Chemical:  Vantage Specialty Chemical has completed the installation of continuous monitoring equipment on its emissions stack.  The equipment became operational on December 16^th.   

For all Village of Gurnee updates on ethylene oxide, visit www.gurnee.il.us/eto