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.

Marc Karell is the owner of the consulting firm Climate Change & Environmental Services, LLC (website: www.CCESworld.com). He is a licensed professional engineer (P.E.) in the State of New York with over 30 years of technical consulting experience in the areas of energy, climate change, sustainability, and air and environmental compliance. He is also a Certified Energy Manager and an Existing Building Commissioning Professional with a Masters Degree in Chemical Engineering from Columbia University.

Marc has a passion for environmental and energy issues and started his firm, CCES, in 2009. Since then, Marc has served a wide variety of client types, large and small, to help them deal with issues involving energy and the environment. He knows these are new, confusing, technical subjects. However, there is opportunity out there and a company making the right technical choices can benefit tremendously financially and stay ahead of the competition. Marc provides technical options to firms.

In addition, CCES has no employees besides Marc. He will gladly bring in technical specialists, when needed, for a client. And CCES clients know that Marc, with 30+ years of experience, will be intimately involved in their projects and is responsible for their success. No young “kid” right out of school will be thrown out there to perform evaluations for you!

Marc has extensive experience performing ASHRAE Level I, II, and III energy audits for diverse building types (such as office buildings, schools, warehouses, and multi-families) in the New York City Metropolitan area and nationally. Marc also performs building retro-commissioning evaluations, to assure building owners that their systems are operating optimally (they are getting their money’s worth). Marc has combined both his energy auditing and retro-commissioning experience to help dozens of buildings comply with New York City’s Local Law 87, mandatory energy auditing and retro-commissioning for large buildings, discovering many opportunities for savings in buildings. Marc uses this knowledge to perform project management projects for clients to ensure that energy savings are fully realized in the actual implementation of upgrades.

Marc also performs greenhouse gas emission inventories (carbon footprints), green building assessments, and has led training to ensure that operators understand how to maintain their energy upgrade strategies so that they continue to benefit the building in the future.

Marc also performs evaluations of air emissions from commercial and industrial processes, including emission inventories, design of air pollution control equipment, permitting, and evaluation of potential health effects of air toxics.

Marc has performed successful projects for such major firms as ExxonMobil, Alberto-Culver, Toyota, Regeneron, Cytec, New York Medical College, the United Nations, and the New York Archdiocese.

Marc Karell can be reached at 914-584-6720 or at Karell@CCESworld.com. Do not hesitate to contact him for a free preliminary consultation. Good luck in your environmental and clean energy journey!

Large companies spend billions of dollars directly on energy each year. We used to think that only traditional manufacturers are dependent on energy. But now that we live in a data-driven world, even “office-based” companies depend on electricity to save and manage data in huge data centers. Imagine the impact on them of even a brief electrical interruption. Yet most firms still approach energy as just another cost on their ledgers, overlooking the risks of energy shortages or losses and the opportunities to reduce risk, improve resilience, and create new value.

Many firms are treating energy as a higher priority due to business trends, changes in energy technologies, the realities of Climate Change, and changing costs of energy sources. All companies that need energy (and that’s nearly everyone) need to study and track trends and evaluate risks and opportunities to save costs and create value.

Here are some issues to consider, even if your firm is fairly small and simple in operation.

Energy Availability

Questions:  Where do you get your energy from? Do you know it will be reliable and affordable in the future?

Concern:  If you are a simple firm and get your electricity from the grid and natural gas from a utility, how reliable is service? While the U.S. has a power infrastructure, much of it is now old. Also, while some parts of the country have grown, the ability to provide it energy has lagged (i.e., Texas), as this can be a high hundred million-dollar investment by a utility, who won’t make it unless it is sure of success and, even if they do, will take time to implement. Utilities in a growing number of areas have stated they cannot guarantee meeting full demand for energy, especially on hot summer days. Costs will rise, too. Might high costs and potential interruptions in delivery affect your business?

Strategies to Consider:  Consider having backup energy sources. Consider the costs involved to develop and maintain vs. potential losses if you must stop operations. Your own power generation, maintenance of batteries, and dual fuel boilers are potential backup energy sources to better ensure you do not get an interruption of energy.

Renewable Energy

Questions:  Does it really work?  Will it benefit my business? Is it a pain to maintain?

To consider:  Renewable energy works and it is cheaper than ever. In fact, from a utility point of view, a solar or wind farm is cheaper to build and maintain than an oil- or coal-fired power plant of the same output. If your facilities have proper roofs without blockage (from trees or hills), then solar can be an affordable alternative to provide electricity. If your facilities have space, geothermal energy for heating and cooling can be a safer and cheaper alternative to combusting a fuel for heat and using electric for cooling. With utility and government incentives, this may be a good financial investment giving you a good alternative source. Do consider that renewable sources have their drawbacks, too, and you may wish to do overall planning to give you flexibility.

Investing in Energy Efficiency

Question:  For a simple company, is it worth the effort to invest in energy efficiency?

To Consider:  There is no simple answer to this question. One size does not fit all. Each company and operation is unique. However, there has been literally a revolution in advancements in technology where many types of energy-using equipment are much more energy efficient than they were just 5 years ago. In many projects I’ve managed, the ROI for energy upgrade projects has been 20, 30, even more % per year. In other words, the money put into the efficiency project made that equivalent amount of “yield” in terms of avoided cost to the utility. A lot better than investing in a bank, right?

However, one must approach energy efficiency smartly and not just change “willy-nilly”. One example, a small company rejected a proposal to change their many lights in a professional, thorough manner to LEDs, as the CEO said he and his brother would just go to the local hardware store, buy LEDs and install them themselves. Well, things “happened” and they never got around to the project for quite some time, paying a premium for the added time the old lights were still operating. And buying the cheapest LEDs in the store and not evaluating the fixtures increased the likelihood of failure. Evaluating the fixtures that would hold the tubes and buying the best (and not necessarily the cheapest) will guarantee them lasting without a change for 7 or more years. Getting them from the local store: risk of quick failure without a warrantee.

Another example, a school selected a vendor for solar panels solely on the cheapest price. Well, some panels failed and others did not provide the output expected.

In summary, energy efficiency can save even a small firm significant cost. And the one-time effort, again, if done smartly, will save the company costs year after year and ensure reliable use of equipment. Therefore, even small firms should devote – invest – resources in evaluating their energy usage and use it more effectively, with no reduction in reliability of operations.

CCES has the experts to advise your company or entity on ways to diversify your energy supply and to evaluate technical strategies for more reliable and cheaper power for your operations. Contact us today at karell@CCESworld.com or at 914-584-6720.