Daily Archives: July 6, 2021

Potential New Air Toxic Rules for EtO, Formaldehyde?

On June 17, 2021, the USEPA agreed to reconsider the August 2020 NESHAP: Miscellaneous Organic Chemical Manufacturing (the “MON Rule”). The MON rule is the first USEPA rule to use the 2016 toxicity values from IRIS. Responding to five petitions, the USEPA granted reconsideration that more stringent standards are required for the MON sector, particularly for ethylene oxide (EtO), given more data that EtO may result in a greater carcinogenic risk than previously thought.

EtO is a flammable, colorless gas used to sterilize medical equipment and common in the chemical industry in manufacturing many common products. The revised 2016 IRIS risk assessment for EtO characterized the chemical as a more potent carcinogen for humans by inhalation than previously understood. However, critics claim that the USEPA used improper statistical modeling that resulted in an overestimation of the risk of EtO exposure. Texas, home to many chemical industries, performed an in-depth review of the 2016 assessment and claimed scientific deficiencies and that EtO is a less potent carcinogen than the USEPA estimated in its 2016 report.

The USEPA declared that it would use 2016 IRIS risk values for future rulemaking, including for the December 2019 proposed MON Rule and an Advance Notice of Proposed Rule Making: NESHAP: Ethylene Oxide Commercial Sterilization and Fumigation Operations. The MON Rule was finalized in August 2020 with the USEPA not addressing comments regarding the validity of the 2016 IRIS values. The USEPA will now do a more formal review of the generation of the 2016 IRIS risk values and modify the MON Rule accordingly, if necessary.

Besides the effects on EtO emission regulations, the USEPA’s actions on EtO may suggest how the agency will proceed on other outstanding chemical and toxics issues, such as formaldehyde, a naturally occurring chemical found in a variety of products, such as construction materials, insulation, glues, paints, and in plywood and particleboard used in consumer products like cabinets, flooring, and furniture. Formaldehyde is also used as a preservative in medical laboratories and mortuaries.

Like with EtO, the USEPA issued an IRIS risk assessment for formaldehyde in 2010. It underwent much scientific criticism. 11 years later, the USEPA has still not addressed the formaldehyde IRIS criticisms and confirmed or updated its level of toxicity.

2016 amendments to TSCA require the USEPA to conduct risk evaluations for certain high-priority chemicals to determine whether each presents an unreasonable risk to health or the environment, under the conditions of common use. The USEPA must exclude cost considerations and base decisions on the weight of scientific evidence.

Last year, the Trump Administration issued final TSCA risk evaluations for the first 10 high-priority chemicals. In February 2021, the Biden Administration announced that it will revisit the final TSCA risk evaluations for these 10 chemicals.

CCES has the technical experts to help you assess the quantity and toxicity of air emissions from your various processes and facility. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Many Factors Make Electric Heat Pumps a Good Alternative for Heating and Cooling

Heating and cooling expenses are often the highest energy costs most businesses have to pay for each year. So in these times of looking for ways to both reduce expenses and welcome back employees into the office and customers in your space comfortably and safely, one strategy to consider is investing in electric heat pumps for both your heating and cooling needs. Heat pumps are a cost-effective, energy efficient, and reliable way to reduce your building’s energy bills and also assure your employees and customers are comfortable. It will improve your carbon footprint and existing air quality, too.

When properly installed, heat pumps are efficient in delivering heat to a space. Why? Because a heat pump moves heat rather than converts it from a fuel like combustion heating systems do. Heat pumps have been around for a long time but have gotten a boost in recent years due to improvements for working better in sub-freezing weather.

Here are some basic facts about heat pumps.

How they work. Yes. Although they are called “heat pumps”, they provide both space heating and cooling. Heat pumps are called that because they draw heat from the environment and move it indoors when it’s cold outside or can move heat from rooms outdoors when cooling is needed in your building.

Different types. There are two types of heat pumps – air source or ground source (geothermal), depending on how heat is transferred. Depending on your facility and property features, a qualified contractor will recommend which type is best for you.

In terms of how they are placed in the building, there are ducted and ductless systems. Ductless systems go in an exterior wall and need just a relatively small hole to connect the outdoor condenser and indoor heads. They are good for individual spaces. If a building already has duct work, a heat pump can use the existing duct system.

They’re better for the environment. Unlike conventional heating systems (furnaces or boilers), heat pumps use electricity. Thus, there is no combustion of fossil fuels onsite and, thus, no carbon monoxide emissions to worry about. There is also less need for natural gas lines or storage/delivery of oil. In most parts of the country, depending on how electricity is produced, switching from gas or oil combustion to electric heat pumps results in lower greenhouse gas emissions.

They’re built to last. Heat pumps last longer than conventional furnaces and cooling units and require less maintenance, meaning you’ll spend less money on O&M and can devote your maintenance staff to other matters. Combustion by its nature is a complex, high temperature process that strains a system and will damage components over time.

Others will pay for them. In most parts of the country (and in New York), utilities and governments encourage heat pumps to lessen the costs of upgrading gas distribution lines and to reduce oil truck traffic. Many utilities and agencies have direct incentive programs to pay part of the cost of installing heat pumps in most qualified buildings. Learn about these programs and take advantage. Remember, these incentive funds come from funds in your electric or tax bills, so you are getting your money back.

CCES has the technical experts to assess your heating and cooling system and determine whether heat pumps could be feasible to reduce your energy expenses and, at the same time, provide reliable heating and cooling in the building. We can estimate the costs and savings for your specific space and set up or determine other ways to reduce energy costs. Contact us today at 914-584-6720 or at karell@CCESworld.com.