Document 0gDQqmoLRzKx5EV3Y3QjBvoBO

If you have any question, please contact: Ed Gunderson (ed.l.gundersongus.indorama.net) Allen Kacenjar (allen.kacenjar squrepb.com) Best regards, SQUIRE :()NHf)GGS "" ,n A. Kacenjar Partner Squire Patton Boggs (US) LLP 1000 Key Tower 127 Public Square Cleveland, Ohio 44114 T +1 216 479 8296 O +1 216 479 8500 F +1 216 479 8780 M +1 216 406 0072 ,,,,,n.kacenjar@squirepb.^om I squirepattonboggs.com Find Us: Twitter I Linkedln I Facebook I Instagram Over 40 Offices across 4 Continents This message is confidential and may be legally privileged or otherwise protected from disclosure. If you are not the intended recipient, please telephone or email the sender and delete this message and any attachment from your system; you must not copy or disclose the contents of this message or any attachment to any other person. For information about how Squire Patton Boggs processes personal data that is subject to the requirements of applicable data protection laws, please see the relevant Privacy Notice regarding the processing of personal data about clients and other business contacts at www.squirepattonboggs.corn. Squire Patton Boggs (US) LLP is part of the international legal practice Squire Patton Boggs, which operates worldwide through a number of separate legal entities. Please visit vvww.squirepattonboggs.com for more information. #US Sierra Club FOIA 2025-EPA-04883 ED_018388_00005690-00002 SC_EVERSPLIT0005473 Message From: Sent: To: Subject: AirAction [/O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=FA78B98923384078995E04A73D258D83-AIRACTION] 4/2/2025 3:52:05 PM Joseph Bowen [jbowen@gri-aps.com] RE: Sterilizer Rule (89 FR 24090): APS- Owned and Operated Facilities Thank you for emailing the AirAction mailbox to request a Presidential Exemption under section 112(i)(4) of the Clean Air Act and for engaging with EPA in advancing President Trump's Executive Orders and Powering the Great American Comeback. We have received your email and will be in contact soon. If you have Confidential Business Information (CBI) that you'd like to submit, please submit it in electronic version to the OAQPS CBIgepa.gov inbox or in hardcopy to: USEPA, OAQPS CORE CBI Office 4930 Old Page Road Durham, NC 27703 From: Joseph Bowen <jbowen@gri-aps.com> Sent: Monday, March 31, 2025 9:59 PM To: AirAction <AirAction@epa.gov> Subject: Sterilizer Rule (89 FR 24090): APS- Owned and Operated Facilities I Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. I write on behalf of APS- Advanced Product Solutions to request that the President issue a two-year exemption pursuant to his authority under CAA Section 112(i)(4) for all emission standards and associated requirements set or revised in EPA's April 4, 2024 National Emission Standardsfor Hazardous Air Pollutants: Ethylene Oxide Emissions Standardsfor Sterilization Facilities Residual Risk and Technology Review, 89 FR 24090 (April 5, 2024) (Sterilizer Rule). APS requests that the Presidential Exemption apply to the following facilities regulated by the Sterilizer Rule and all sources therein: APS- Advanced Product Solutions, 502 West Church Street Columbia, AL 36319 APS requests that the President issue a two-year exemption as quickly as possible, but designate it as taking effect on the compliance deadlines for the standards in the Sterilizer Rule. Specifically: For standards set or revised under CAA Section 112(f) and all corresponding requirements (including monitoring requirements), the exemption should apply as of April 6, 2026 (the compliance deadline for those standards); For standards set or revised under CAA Section 112(d) and all corresponding requirements (including monitoring requirements), the exemption should apply as of April 5, 2027 (the compliance deadlines for those standards). As explained further in the attached letter submitted to EPA on March 17 on behalf of the Ethylene Oxide Sterilization Association (EOSA), the technology necessary to implement the standards is not available because manufacturers cannot guarantee that existing emissions control equipment will enable sources to meet the new standards; there is not a sufficient supply of the necessary technology; and there are not enough experienced installation professional and technical experts to install and test that equipment within the current compliance timeframes. Sierra Club FOIA 2025-EPA-04883 ED_018388_00005694-00001 SC_EVERSPLIT0005474