What You Can Do Now to Prevent Ethylene Oxide Issues in the Future
January 31, 2022
By: DAVID BERKOWITZ
EPA has been expanding their attention from sterilizers to other facilities with EtO emissions. Chemical companies that use EtO as a reagent to make their products are getting attention from their communities, local agencies, and the EPA. Some are now required to submit applications and air dispersion modeling reports to demonstrate compliance with stringent EtO standards.
You may not be accounting for all your fugitive EtO emissions and a small amount can be a huge deal. You’ll want to be prepared and proactive so you’re not caught off guard.
There are several steps you can take now to prevent future problems.
Look at your current EtO emissions – ensure they are accounted for and you’re in compliance with federal AND state regulations. Stack testing data can evaluate emissions from regulated sources. However, many facilities have unregulated emissions, including fugitive, which are not accounted for in standard performance tests. Facilities may want to perform additional testing or engineering calculations to make sure they understand all of their EtO emissions.
Also, you never know what you’ll need to change based on updated regulations. For example, some agencies are now requiring Continuous Emission Rate Monitoring Systems (CERMS) and it is reasonable to believe that the EtO Commercial Sterilization and Fumigation Operations NESHAP will also include this as a requirement. Keep up to date on regulatory developments and get involved in the regulatory process if possible.
Get to know your neighbors. Are there any lawsuits or environmental groups around your facility?
Partner with environmental experts to help you navigate these issues.
To evaluate the highest expected concentrations in nearby residential areas, you can use emission testing and modelling. If necessary, control equipment can be added or reconfigured to capture and control more emissions. One way to do this is by adding dry bed scrubbers to polish emissions from primary control equipment. Also, facilities can be put under negative pressure routing indoor air through these scrubbers to eliminate fugitive emissions. These upgrades can be evaluated with stack testing using FTIR and/or GC/FID, depending on the levels expected.
If your facility uses EtO, it may be beneficial to evaluate your operations and potential impact on the surrounding area. One way to do this is to conduct ambient monitoring.
Ambient monitoring can be performed by collecting and analyzing samples by Method TO-15. Additionally, there are also some real-time monitoring techniques capable of providing data across a large area in a short period of time. When conducting ambient monitoring, it is recommended to evaluate concentrations around the facility, surrounding areas, and remote areas as background locations.
One such real-time monitoring approach is to perform mobile monitoring using optically enhanced FTIR or a Proton Transfer Reaction Time-of-Flight Mass Spectrometer that measures 1 ppb and 70 ppt, respectively. These techniques are deployed in a mobile lab and collect a measurement as frequent as every second. This approach allows us to gather a comprehensive data set quickly over a large area.
If your organization is concerned about keeping up with EtO regulations and testing, contact the experts at Montrose Environmental to walk through how we can help you. We’re prepared to offer a variety of testing and lab services including:
- Regulatory consulting services, including air dispersion modeling
- Installation and operation of Continuous Emissions Rate Monitoring Systems (CEMS), using the latest technologies including:
- Optically enhanced Fourier-Transform Infrared Spectroscopy StarboostTM (FTIR)
- CERMS operations and maintenance, as well as periodic quality assurance audits
- Source Testing for ethylene oxide down to 1-2 ppb
- Initial Start-up, Engineering and Compliance Testing
- Optimization Studies on Absorbers, Scrubbers and Oxidizers
- Ambient Air and Fenceline Sampling Studies using EPA Method TO-15 and mobile PTR-TOF-MS
- Laboratory Analysis of TO-15 canister samples for ethylene oxide down to 20 ppt
Fenceline Monitoring Expert
David Berkowitz brings over 29 years of industry expertise to the Montrose team where he currently works as our Fenceline Monitoring Testing expert. Prior to joining Montrose, he worked for Enthalpy Analytical and Triangle Laboratories. David is a member of the Air and Waste Management Association, the American Fuel and Petrochemical Association, and the American Chemical Society. He holds a Bachelor’s degree from North Carolina State University.