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-IND owe owl orA3 February 26, 2025 Ms. Mary Greene Director, Air Enforcement Division Office of Civil Enforcement United States Environmental Protection Agency Mail Code 2242-A 1200 Pennsylvania Ave, N.W. William Jefferson Clinton Building/Room 1119 Washington, DC 20460-0001 Submittal of Additional Information Requested Request for Extension of Compliance Time -- Two Projects Compliance with the Ethylene Oxide Provisions 40 CFR 63 Subpart G -- National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry (HON Rule) Union Carbide Corporation Seadrift, Texas Operations Title V Operating Permit No. 02031 -- Glycol Ethers Plant and & Oxide Derivatives Plant TCEQ Regulated Entity Number RN 102181526 TCEQ Customer Reference Number CN601688781 Dear Ms. Greene, This letter and the attached information provides additional information requested by USEPA in a letter December 20, 2024, regarding our request for an extension to the current July 15, 2026, due date for compliance with all ethylene oxide requirements in EPA's amendments to the HON air pollution rule t40 CFR 63 Subparts F, G, and H). Our request for a compliance extension and these projects involve: Installation of two new vent scrubber projects to control any process vents that may contain low emissions of ethylene oxide, but that are "In Ethylene Oxide Service- from the Glycol Ethers Plant and the Ethanolamines Plant. The liquid from these scrubbers will be further processed in two Purge Glycol Reactors to convert any residual ethylene oxide to other organic compounds. Process wastewater streams from the Glycol Ethers Plant and the Ethanolamines Plant will also flow to the same Purge Glycol Reactors that are installed by the vent scrubber project. The Purge Glycol Reactors will react small concentrations of ethylene oxide to other chemical compounds. Sierra Club FOIA 2025-EPA-04883 ED_018388_00000033-00001 SC_EVERSPLIT0005200