Document YjeEpJNEX3y4n7Zg91gowKamy

Message From: Sent: To: Subject: AirAction [/O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBO HF23SPDLT)/CN =RECIPIENTS/CN =FA78 B98923384078995E04A73D258D83-AlRACTION] 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 1 12(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 (CRI) that you'd like to submit, please submit it in electronic version to the OAQPS CRI(depa.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 Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. I 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 Standardsl0r Hazardous Air Pollutants. Ethylene Oxide Emissions Standards finSterilization 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, AI. 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(e 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 limber in the attached letter submitted to EPA on March 17 on behalf ofthe 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 arc not enough experienced installation professional and technical experts to install and test that equipment within the current compliance timcframes. Sierra Club FOIA 2025-EPA-04883 ED_018388_00005694-00001 SC_EVERSPLIT0020889 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. APS appreciates EPA's attention to this important matter and urges EPA to recommend that the President issue the requested exemption as quickly as possible. Joseph Bowen Mani Manager, APS-ETU APS ADVANCED PRDIDUC 50W7L6N5 grl E lt O: 334.699.7044 C: 334.441.5493 CON' [DI N1I.ALEIY N()IICI ettriirrt.enctnon inc:illeci lot he or the tnier.(!e(:. :ectpte:11(iti :mined alitrt 'L.. The Con- tor.e(!tr. corillimntetiiitin :tuliclune:11, n Ci1:1LC'i::-Lc: prtiprteitini p:ut tteFeci ln :.:e ,er.cier. 11 yi).1 recen Corrart.:ntett- ton ;Ind triaelniLr. error or not - le tr.itiluted rectiiten- , any .1;e, rep:oc:.itntin tir citititeuti:mittin tit 1-.K comnittmetvton and twat:I:me:Hit prtikihniec:. if :tott .r.t_ arrl ulc rec:pie:r tir :ecenec: e-mait LommanLLauon ei:o:, a`_)[Lty imincdLatct.' by icptv e-mail 0: tetep:10:ie de.,:ior L(wies of thc onpinat c-mait Loinina:ILLau`_)n and 2n:aLanic:ns. Sierra Club FOIA 2025-EPA-04883 ED_0l 8388_00005694-00002 SC_EVERSPLIT0020890