Document vBvDgjBxgX4YaEZ2bz5VnV12b
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Sierra Club FOIA 2025-EPA-04883
ED_018388_00000130-00002
SC_EVERSPLIT0005286
From:
Allen, Bryan Michael
[bryan.allen@faegredrinker.com]
ent:
3/31/2025 8:59:32 PM
o:
AirAction [AirAction@epa.gov]
object:
Presidential Exemption: NESHAP:
Ethylene Oxide Emissions
Standards for Sterilization
Facilities: Livallova USA, Inc.
ttachments:2025-03-31 Livallova Request for
Presidential Exemption Final
Packet.PDF
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Dear EPA,
Please find attached a formal request on behalf of Livallova USA, Inc. for a two-year exemption from the Ethylene Oxide Emissions Standards for Sterilization Facilities, as outlined in Section 112(i)(4) of the Clean Air Act.
Facility Information: Facility Name: Livallova Arvada Facility Facility Address: 14401W 65th Way, Arvada, CO 80004
Emissions Standards or Limitations Subject to the Request: "National Emission Standards for Hazardous Air Pollutants: Ethylene Oxide Emissions Standards for Sterilization Facilities Residual Risk and Technology Review", 40 CFR Part 63, Subpart O (89 FR 24090; April 5, 2024) (Sterilizer Rule)
Length of Compliance Period Being Requested: 2-year exemption from April 6, 2026, to April 6, 2028.
The attached request includes justifications based on the unavailability of required technology and the national security interests of the United States, and an appropriate delegation of authority from Livallova to submit this request on their behalf The attached letter does not include any proprietary information. However, such information may be available if deemed necessary by the EPA, which can be submitted in accordance with applicable rules and regulations to protect confidential business information.
Please do not hesitate to contact us if you require any additional information or steps to process this request.
Kind regards,
Bryan M. Allen
Senior Manager - Federal Policy & Consulting
bryan.allen@faegredrinker.com Connect: vCard
+1 202 230 5323 direct
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Riddle F neath LLP
1500 K Street, N.W., Ste. 1100
Washington, DC 20005, USA
Sierra Club FOIA 2025-EPA-04883
ED_018388_00000132-00001
SC_EVERSPLIT0005287