Document NabXJXaL8BaYnjROqw9eMBzE

The Rule also imposes a one-ton-per-year cap on chloroprene emissions from maintenance activities, but EPA did not identify any feasible control technology or control measures for meeting this limit. As Mr. Meyers explains in his declarations, DPE has already evaluated several possible options, including those recommended by EPA enforcement officials, but none of them is technically feasible. 2024 Declaration at pp. 12-14. Thus, the technology needed to implement this standard is not available. In addition, the Rule requires DPE to install and operate a comprehensive fenceline monitoring system and take all steps needed to ensure that fenceline concentrations of chloroprene in the ambient air meet a specified "action level," as determined by the fenceline monitors. In the rulemaking, EPA conducted air quality modeling which found that, once the Facility complies with all the specific control requirements in the Rule, ambient concentrations around the fenceline will correspond with an action level of 0.8 g/m3. See 89 Fed. Reg. at 42999. Yet EPA set the action level for chloroprene at 0.3 g/m3 --not based on any analysis of whether it would be possible for the Facility to achieve this level but because of EPA's desire to set the level "as low as possible" based on the detection limit of the required monitors. Id. at 42300, 43002. Thus, the technology needed to implement this standard is not available.[2] 2 Some requirements related to the fenceline monitoring program come into effect after the monitoring system has been operating for 12 months. DPE requests that all these requirements be pushed back by two years from the dates set forth in the HON Rule. An Exemption is in the National Security Interests of the United States Granting an extension to DPE is in the national security interests of the United States, as the Facility is the only Neoprene production facility in the country. Neoprene is a synthetic rubber used to make military and medical equipment as well as a wide array of additional products, including car parts, adhesives, wetsuits, and many consumer products. If the DPE Facility were forced to shut down, the U.S. would have to rely on countries like China to provide the Neoprene necessary for certain military and medical equipment. Therefore, a Presidential Exemption is in the national security interests of the U.S. and will aid in maintaining a strong domestic supply chain network aligned with President Trump's America First Trade and Investment Policy. See e.g., White House Memo, American First Trade Policy (Jan. 20, 2025); White House Memo, America First Investment Policy (Feb. 21, 2025). Extension Request For the above reasons, DPE respectfully requests that the President use his authority under Section 112(i)(4) to extend by two years the dates by which DPE must come into compliance with the CAA Section 112 standards and limitations in the HON Rule that apply to DPE's Neoprene Production Facility in LaPlace, Louisiana. Best regards, Mr. Jeffrey R. Holmstead I ? Some requirements related to the fenceline monitoring program come into effect after the monitoring system has been operating for 12 months. DPE requests that all these requirements be pushed back by tuo years from the dates set forth in the IION Rule. Sierra Club FOIA 2025-EPA-04883 ED_018388_00005540-00004 SC_EVERSPLIT0006406