Best Practices for Ethylene Oxide (EtO) Stack Testing in 2024

While we don’t yet know the exact specifics regarding the EPA’s forthcoming regulatory updates on Ethylene Oxide (EtO) stack testing and monitoring, we do know this:

Requirements found in the current Performance Specification 19 (PS-19) will serve as the foundation for whatever final ruling the EPA has coming down the pipe. Fortunately, armed with this knowledge, facility operators can position themselves to comply with the new PS-19 quickly when it does go into effect, which is anticipated to happen in late Q1/early Q2 of 2024.

The main goal of PS-19, stack testing, and ambient air monitoring is to promote safety for those who could be exposed to EtO emissions. Along with PS-19, these tests ensure that a continuous emissions monitoring system (CEMS) and existing technologies can accurately and consistently measure low levels of EtO to keep communities, employees, and all stakeholders nearby safe.

The importance of monitoring EtO emissions, efficiently

Because EtO poses potential health risks to facility workers, the environment, and surrounding communities, PS-19 as it stands today already mandates a CEMS to monitor EtO emission levels. But since we anticipate the PS-19 updates to involve stricter requirements for monitoring and testing EtO emissions, merely having a compliant CEMS in place today may not suffice.

To ensure compliance with 2024 updates to PS-19, your best move is to adopt a highly efficient and effective CEMS technology. This CEMS would ideally have a proven track record and is widely used in several other industries.

Monitoring EtO emissions with FTIR technology

Fourier Transform Infrared Spectroscopy (FTIR) technology enables real-time monitoring of EtO emissions. It analyzes and shares valuable information based on how those compounds interact with infrared light. With a CEMS that uses FTIR technology to analyze the characteristic absorption bands of EtO, facility operators can:

• Have better understanding of the process matrix and abatement systems used to treat EtO
• Identify and quantify the concentration levels of EtO compounds in the surrounding environment
• Collect appropriate detection limits and emissions data quantification to meet upcoming PS-19 requirements. Some detection limits being as low as 1 ppb.

Benefits of FTIR for monitoring EtO emission levels

Montrose has partnered with facility operators to implement real-time EtO EMS-10 CEMS manufactured by Thermo Fisher Scientific to great effect. The positive results have been well documented in case studies like this one. And aside from the capabilities noted above, facility operators also see tangible benefits such as:

Cost savings

The real-time monitoring of FTIR technology allows users to optimize EtO abatement equipment on site with less mobilizations.

Time savings

Instead of having to send samples to a lab, which usually come with turnaround times of three to four weeks, FTIR technology enables EtO emission testing to be conducted within two to four hours after our team’s arrival. This means a Montrose client will know if they’re compliant with the PS-19 updates before we leave.

Regulatory compliance

Essentially, FTIR takes “photographs” of spectra and saves them for data validation. This information is critical to ensuring the high-quality, precise measurements. We keep this raw data on file for third-party verification whenever necessary.

Prepare yourself for upcoming PS-19 updates

We can review your existing CEMS program, even if it already utilizes FTIR, to find opportunities for procedural and technological improvement. We can also assist with CEMS installation, develop and deploy an active FTIR sampling strategy, and work to make sure you have highly effective and efficient EtO stack monitoring and testing capabilities ready for regulatory updates in 2024. Get in touch.