Document ymeRNZj826EoNgdnr47wEwBJ2

National Security Interests: The recycling industry, including JSS and Recovermat, is vital for national security. These facilities provide essential raw materials for various industries, including defense, infrastructure, and manufacturing, thereby reducing reliance on imports and enhancing economic security. Economic and Environmental Benefits: Smith Industries supports thousands of jobs and contributes significantly to the economy. In 2021, the company recovered over 1.6 billion pounds of metals, eliminating the need for 3.4 million tons of ores and saving energy equivalent to the annual usage of approximately 471,000 U.S. households. This also prevented nearly 1.9 million tons of carbon dioxide emissions. Alignment with EPA Initiatives: Granting the exemption aligns with the EPA's "Powering the Great American Comeback" initiative, supporting clean air, energy independence, permitting reform, American innovation, and the protection of American auto jobs. Requested Compliance Period: Smith Industries is requesting a compliance period extension of four years to develop and implement feasible VOC control technologies. We appreciate your consideration of this request to allow JSS and Recovermat to continue their essential operations while working towards compliance with VOC reduction standards. Attachment Sincerely, Dale. WHITEFORD Dale G. Mullen I Partner Two James Center 1021East Cary Street Suite 2001 Richmond, Virginia 23219 T 804.799.7854 I C 804.887.0778 dmullen@whitefordlaw.com I www.whitefordlaw.com Admitted to practice in New York, Virginia and the U.S. Dist. Ct. for the District of Columbia Whiteford is a member of two global law firm networks. This transmission contains information from the law firm of Whiteford, Taylor & Prestor ALP which may be confidential and/or privileged. The informatior is intended to be for the exclusive use of the planned recipient If you are not the intended recipient, be advised that any disclosure, copying, distribution or other use of this information is strictly prohibited. If you have received this transmission in error, please notify the sender immediately. Sierra Club FOIA 2025-EPA-04883 ED_018388_00005524-00002 SC_EVERSPLIT0005408 Message From: Sent: To: Subject: AirAction [/O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=FA78B98923384078995E04A73D258D83-AIRACTION] 4/1/2025 2:02:49 PM Allen, Bryan Michael [bryan.allen@faegredrinker.com] RE: Presidential Exemption: NESHAP: Ethylene Oxide Emissions Standards for Sterilization Facilities: Trinity Sterile, Inc. Thank you for emailing the AirAction mailbox to request a Presidential Exemption under section 112(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 (CBI) that you'd like to submit, please submit it in electronic version to the CBI@epa.gov inbox or in hardcopy to: USEPA, OAQPS CORE CBI Office 4930 Old Page Road Durham, NC 27703 From: Allen, Bryan Michael <bryan.allen@faegredrinker.com> Sent: Monday, March 31, 2025 4:52 PM To: AirAction <AirAction@epa.gov> Subject: Presidential Exemption: NESHAP: Ethylene Oxide Emissions Standards for Sterilization Facilities: Trinity Sterile, Inc. I Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Dear EPA, Please find attached a formal request on behalf of Trinity Sterile, 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: Trinity Sterile, Inc. Facility Address: 201 Kiley Drive, Salisbury, MD 21801 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 Trinity 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, Sierra Club FOIA 2025-EPA-04883 ED_018388_00005531-00001 SC_EVERSPLIT0005409