(8b) Requirement for New Ethylene Oxide Cems in the MON

Reducing emissions of ethylene oxide has recently become a focus of U.S. EPA following revised risk assessments for the compound. On November 11, 2019, the U.S. EPA released a pre-publication version of proposed amendments to the Miscellaneous Organic NESHAP (MON). The MON amendments include new monitoring and testing requirements for control devices used to control ethylene oxide emissions. Part of these new requirements include continuous monitoring of ethylene oxide concentrations using Fourier Transform Infrared (FTIR) Continuous Emissions Monitoring System (CEMS) for control devices other than a flare. This presentation will describe how FTIR can be used to monitor ethylene oxide and elaborate on the continuous ethylene oxide monitoring requirements found in the MON.