Document 70Om8Vmabvg1RrmYaBxYK4EYe

Message From: Sent: To: CC: Subject: Attachments: AirAction [/O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=FA78B98923384078995E04A73D258D83-AIRACTION] 3/28/2025 3:28:39 PM Shrager, Brian [Shrager.Brian@epa.gov]; McLamb, Marguerite [McLamb.Marguerite@epa.gov]; McGinn, Kevin [mcginn.kevin@epa.gov]; Branning, Amy [Branning.Amy@epa.gov]; South, Peter [South.Peter@epa.gov]; Anderson, Lea [anderson.lea@epa.gov]; Smith, Korbin [smith.korbin@epa.gov] Noonan, Jenny [Noonanienny@epa.gov] FW: Regarding Sterilizer Rule (89 FR 24090): KPR US, LLC d/b/a Kendall Patient Recovery ("KPR") FINAL EOSA Letter to EPA re. NESHAP March 17, 2025.pdf l ii all -- We have received another Presidential Exemption request. For awareness, please see email below and attachment. From: Leach, Arthur <arthur.leach@cardinalhealth.com> Sent: Friday, March 28, 2025 11:04 AM To: AirAction <AirAction@epa.gov> Subject: Regarding Sterilizer Rule (89 FR 24090): KPR US, LLC d/b/a Kendall Patient Recovery ("KPR") Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. I Re: Sterilizer Rule (89 FR 24090): KPR US, I,I,C d/b/a Kendall Patient Recovery ("KPR") I write on behalf of KPR 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 Standardsfie Hazardous Air Pollutants: Ethylene Oxide Emissions Standards fitr ,Sterilization Facilities Residual Risk and Technology Review, 89 FR 24090 (April 5, 2024) (Sterilizer Rule). KPR requests that the Presidential Exemption apply to the following facility regulated by the Sterilizer Rule and all sources therein: KPR US, I,I,C d/b/a Kendall Patient Recovery 1430 Marvin Griffin Road, Augusta, Georgia 30906 KPR 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 1 12(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 widely available to the sterilization industry 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 Sierra Club FOIA 2025-EPA-04883 ED_018388_00005701-00001 SC_EVERSPLIT0020895 there are not enough experienced installation professional and technical experts to install and test that equipment within the current compliance timcframes. As also explained further in EOSA's March 17 letter, it is in the national security interests of the United States to issue the requested exemption because if some facilities choose to cease operations rather than attempt compliance (which is likely), that will disrupt the supply of sterilized medical devices, raise the cost of those devices, and/or force medical suppliers or providers to source sterilized medical devices from abroad. Please don't hesitate to let me know if any additional information is needed. KPR appreciates EPA's attention to this important matter and urges EPA to recommend that the President issue the requested exemption as quickly as possible. Thanks you for your considcrsation of matter, Arthur CardinalHealth Arthur Leach Senior rice Pre.siderii, Global Manufacturing 777 West Street. Mansfield. MA 02048 508.964.6941 lel 508.212.5810 mobile Executive Assistant: .11i i.. H Well Being Notice: Receiving this email outside of normal working hours? Managing work and life responsibilities is unique for everyone. I have sent this email at a time that works for me. Please respond at a time that works for you. This message is for the designated recipient only and may contain privileged, proprietary or othenvise private information. If you have received it in error, please notify the sender immediately and delete the original. Any other use of the email by you is prohibited. Dansk - Deutsch - Espanol - Francais - Italiano - Japanese - Nederlands - Norsk - Portuguese - Chinese Svenska: . ,.vv,,v,, ca'd,: , a -ea tr-ls-n-d Sierra Club FOIA 2025-EPA-04883 ED_018388_00005701-00002 SC_EVERSPLIT0020896