Document NE0M1MaDYGBaXRy5mkJowBp3E

March 28, 2025 U.S. Environmental Protection Agency 1200 Pennsylvania Ave. NW Washington, DC 20460 RE: Presidential Exemption: New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Synthetic Organic Chemical Manufacturing Industry (SOCMI) and Group I & II Polymers and Resins Industry: SABIC Innovative Plastics Mt. Vernon, LLC To Whom It May Concern, SABIC Innovative Plastics Mt. Vernon, LLC ("SABIC") requests an exemption from the compliance obligations of the New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Synthetic Organic Chemical Manufacturing Industry (SOCMI) and Group I & II Polymers and Resins Industry (collectively referred to as the HON Rule).' For the reasons highlighted in this letter, we believe it is necessary and appropriate for the President to grant an exemption under Clean Air Act (CAA) Section 112(i)(4) for sources regulated by the final rule either on an individual basis or collectively. If done collectively, we request that EPA include SABIC's regulated facilities under that collective action. We urge the Administration to swiftly consider and issue such an action based on an understanding that both: 1) "availability" for the purposes of this section refers not only to the existence of technology capable of achieving compliance with the rule, but encompasses practical challenges with the timeframes necessary to plan, procure, and install required technologies and such activity cannot occur within the current compliance timeframe; and 2) national security encompasses not only military defense applications and infrastructure, but also economic security, a perspective that has been acknowledged by the President in Executive Orders and key security agencies like the Department of Defense. Indeed, as the White House has stated regarding domestic priorities, 'economic security is national security."2 As additional support on this point. we reference the separate joint coalition submission sent to EPA from 1 National Emissions Standards for Hazardous Air Pollutants (NESHAP), Powering the Great American Comeback https://www epa.goWsystem/files/documents/2025-03/neshap_powering-the-great-americancomeback_fact-sheet_2.pdf 89 Fed. Reg. 42932 (May 16, 2024). 2 https://www whitehouse.gov/presidential-actions/2025/02Iamerica-first-investment-policy/. SABIC Innovative Plastics Mt. Vernon, LLC One L&an Lane Mount Vernon, IN 47620 USA T: .1 812 833 8891 F. +1812 8314856 E: MTV Environmental@sabic.carn www.sabic.corn Sierra Club FOIA 2025-EPA-04883 ED_018388_00000243-00001 SC_EVERSPLIT0012685 associations the American Chemistry Council (ACC) and the American Fuel & Petrochemicals Manufacturers (AFPM). We believe that the Administration has already been provided with sufficient information (including prior comments and the underlying petition for reconsideration on the HON rule) to support an exemption covering all regulated facilities or on a facility-specific basis. This letter provides additional detail and support on the time-critical nature of the request for relief and to address EPA's request for information. We submit both in support of a category-wide grant, as well as to provide facility-specific information if the President pursues a facility-specific exemption action. SABIC operates a manufacturing plant in Mt. Vernon Indiana that is subject to EPA's HON final rule. Specifically, the final HON rule significantly impacts manufacturing processes for phenol and BPA that are key raw materials for polycarbonate (PC) and co-polycarbonates. PC and co-polycarbonates are amorphous engineering thermoplastics used in a diverse set of domestic applications and markets, including health care; consumer electronics, aerospace, mobility, military, infrastructure, and personal protective wear. Their transparency, high impact strength, mechanical performance, heat resistance, thermal performance, chemical resistance, and resistance to fire and corrosion, along with other chemical and physical properties uniquely suit them for key applications in medical devices, health care, and automotive safety. SABIC's HON plants are significant contributors to the economic health and employment opportunities in their locations. SABIC estimates that to comply with HON final rule, significant upgrade to existing equipment including new or updated emissions control devices will be required resulting in significant capital expenditures and operating expenses for our SABIC HON affected process units. In addition, our phenol and BPA plant would require unplanned shutdowns to implement capital projects and would tremendously impact the production of polycarbonates. SABIC's PC plants represent over 60% of the domestic PC capacity to serve the American markets. Based on compliance timeline provided in the final HON rule at 40 CFR 63.100(k)(10) and (12) for existing sources, the decision about capital expenditures would need to be made as early as April/May of 2025. The HON final rule does not provide sufficient time to upgrade existing equipment and emissions control devices or install new control devices which require significant time in planning, designing, procurement and installing equipment. Therefore, we request additional compliance time of at least two more years to comply with final HON rule for existing sources beyond compliance time provided at 40 CFR 63.100(k)(10) and (12). We thank EPA for your consideration of this request. If you have any questions, please free to contact Balvant Darji via email at balvant.darji@sabic.com. Thank you very much. Sincerely, Niall McConville President and Director SABIC Mt. Vernon Manufacturing Sierra Club FOIA 2025-EPA-04883 ED_018388_00000243-00002 SC_EVERSPLIT0012686 cc: Aaron Szabo, Senior Advisor to the Administrator, Office of the Administrator Abigale Tardif, Principal Deputy Assistant Administrator, Office of Air and Radiation Sean Donahue; Principal Deputy General Counsel, Office of General Counsel Alex Dominguez, Deputy Assistant Administrator for Mobile Sources, Office of Air and Radiation Peter Tsirigotis, Director, Office of Air Quality Planning and Standards Penny Lassiter, Director, Sector Policies and Programs Division, Office of Air Quality Planning and Standards Patrick Lessard, Refining and Chemicals Group Leader, Office of Air Quality Planning and Standards Andrew Bouchard, General Engineer, Office of Air Quality Planning and Standards Sierra Club FOIA 2025-EPA-04883 ED_018388_00000243-00003 SC_EVERSPLIT0012687