Document aD1jKyBXaV1Kn1jrb4rpZ0KGa

exposure due to an environmental release incident. As explained in the DPE Comments, an insufficient compliance period unsafely ignores the potential for human error that can arise in (1) designing processes; (2) engineering projects; (3) specifying process components; (4) predicting safeguards necessary to control risk to an acceptable level and sustain the required safeguards for the life of the process; (5) managing process changes; (6) startup testing; and (7) trouble-shooting (shakedown) physical process changes.` In its Final Rule, EPA has still not addressed process safety actions or demonstrated that sound change-management principles were used in developing the required Section 112(f) Control Projects. EPA's demand for compliance on such an unreasonable schedule poses serious risks to DPE, its employees, and the surrounding community. 8. I have reviewed the requirements of the Final Rule in relation to the Section 112(t) Control Projects. As detailed further below, none of these projects can be feasibly or safely implemented in only 90 days, let alone all of them simultaneously. 9. Thermal Oxidizer. The Final Rule requires emissions from process vents and storage vessels in chloroprene service to be routed to a closed vent system to a non-flare control device that reduces chloroprcne by greater or equal to 98% Destruction Removal Efficiency (DRE).7 As EPA concluded, this requires routing of all chloroprene emissions from the polymer batch reactors, emulsion storage vessels, strainers, and wash belt dryers to a thermal oxidizer (TO).8 6 DPE Comment at 108. Final Rule at 19-20. 88 Fed. Reg. at 25117; see ERG Control Options for Process Vents and Storage Vessels Memo at 7. See also Final Rule at 196-97 (EPA has reiterated in the Final Rule that it "continue[s] to stand by [their] analysis" and finalized control requirements for those same sources.). -5- Sierra Club FOIA 2025-EPA-04883 ED_018388_00000138-00006 SC_EVERSPLIT0005841