[Geralt/Pixabay photo]Clean Power Lake County is working to prevent the US Environmental Protection Agency (EPA) from increasing the amount of ethylene oxide (EtO) chemical facilities can emit—and we need your help.
The Texas Commission on Environmental Quality (TCEQ) recently proposed a number that is 1,000 times worse for public health than national standards, according to environmental groups.
Unfortunately, what happens in Texas doesn’t necessarily stay in Texas.
We’re concerned that the EPA may adopt the weaker TCEQ model instead of keeping the current Integrated Risk Information System (IRIS) guidelines.
Now is the time to stop the EPA from weakening EtO standards. Will you contact your member of Congress and ask them to demand the EPA reject the TCEQ risk assessment?
Lake County residents line the Lake Michigan shoreline to demand a fossil fuel-free, clean energy future for their communities. [Karen Long MacLeod/CPLC photo]The Illinois Environmental Protection Agency will hold two public sessions in Waukegan in October on issues related to the Waukegan coal plant—and we want to be ready!
Please join Clean Power Lake County for an important community information and work meeting on Wednesday, September 25, 7 pm to 8:30 pm, at Whittier Elementary School, 901 N. Lewis Ave., Waukegan, Illinois.
We’ll work on comments for two upcoming IEPA visits to Waukegan:
The NRG Energy coal-fired power plant on Waukegan’s lakefront has two unlined coal ash ponds. [Lisa Long/CPLC photo.]For years, Clean Power Lake County has called for state action on toxic pollution from two unlined coal ash ponds at the NRG Energy coal-fired power plant on Waukegan’s lakefront. On July 30, 2019, our calls were answered as Gov. J.B. Pritzker signed SB9, the Coal Ash Pollution Prevention Act, into law.
The most significant step to protect clean water in years, the new law will result in stronger rules for coal ash cleanup, fund cleanup programs, and require companies to set aside money to close and clean up coal ash ponds.
“This is a great win for coal ash communities, especially for Waukegan residents that have been continuously affected by corporate polluters,” said Dulce Ortiz, co-chair of Clean Power Lake County.
“The governor is putting the State of Illinois in a good trajectory in signing SB9 into law, by sending a message that environmental justice communities across the state are being put before profitable industrial polluters like NRG Energy. Waukegan residents commend Gov. Pritzker and our state legislators for making SB9 into law. Our land is our children’s future and we look forward to the State of Illinois continuing to strengthen protections for our vulnerable environmental justice communities,” she added.
The Lake County News-Sun published a nice summary of the law’s potential impact on Waukegan.
The groundbreaking bill addresses the many waste pits filled with coal ash, the toxic byproduct of burning coal, located all over the state:
Creates a regulatory framework to ensure polluters, not taxpayers, pay for needed closure and cleanup.
Guarantees public participation and transparency around cleanups for affected communities.
Provides the Illinois EPA the funds it needs to properly oversee closure and cleanup.
Requires Illinois to put in place standards for coal ash impoundments that are at least as protective as federal coal ash rule requirements, with additional protections against dust and water pollution.
Now the Illinois Environmental Protection Agency (IEPA) will begin writing and proposing draft rules. The Illinois Pollution Control Board will finalize the IEPA rules.
“Illinois joins other states that are putting residents’ health before industrial polluters’ profit. We look forward to working with IEPA to engage communities most affected by coal ash in the rulemaking process,” said Celeste Flores, co-chair of Clean Power Lake County and Lake County Outreach Director for Faith in Place.
Once again, we thank the many Lake County elected officials who supported this important legislation: State Senators Melinda Bush, Terry Link, and Julie Morrison; and State Representatives Rita Mayfield, Joyce Mason, Dan Didech, Mary Edly-Allen, Bob Morgan, and Sam Yingling.
Activists representing Waukegan’s immigrant, low-income, and working-class families came together for a rally on June 22, 2019, united in the hope that achieving social and environmental justice will help them build a healthier, more sustainable community.
Here are some highlights from speeches given at the rally.
Edgar Sandoval: Environmental justice
Environmental justice is a movement that seeks to broaden the social assumptions we have about what the environment is and who can be an environmentalist. Historically, mainstream environmental groups have framed the environment as something that existed over there, in nature preserves and national parks. Many people who do environmental justice work have reframed the environment to consider three arenas: where we live, where we work, and where we play.
Championed primarily by African Americans, Latinxs, Asians, Pacific Islanders and Native Americans, the environmental justice movement addresses a statistical fact: People who live, work and play in the US’s most polluted environments are commonly people of color, immigrants, and living in impoverished conditions. Environmental justice advocates have shown that this is no accident. Communities of color, which are often poor, are routinely targeted to host facilities that have negative environmental impacts—say, a landfill, a dirty industrial plant or a truck depot. The statistics provide clear evidence of what the movement rightly calls environmental racism.
Environmental justice is about environmental racism. To address one requires addressing the other. Race is the commonsense ideology that explains difference based on biology. Racism is the exercise of unequal power relations on the basis of racial ideologies. In other words, racism is about power.
The US EPA is addressing five sites in the city of Waukegan through its Superfund program, which allows the EPA to clean up contaminated sites and forces parties responsible for the contamination to either perform cleanups or reimburse the government for EPA-led cleanup work. Three sites are listed on the National Priorities List: Johns-Manville Corp. (a former asbestos manufacturing plant that operated from the 1920s to the 1980s) and Outboard Marine Corp.—both of which are along Waukegan’s lakefront—and Yeoman Creek Landfill. The other two sites—North Shore Gas North and South plants—are being addressed under EPA’s Superfund Alternative Sites program.
These various hazards indicate that the residents of Waukegan experience cumulative exposure to a range of toxins, which means that the effects of this accumulation of chemicals is not additive but exponential. This means that the harmful effects (feeling sick, for example) of one chemical are made a lot worse by the introduction of other chemicals into your body.
Andrew Rehn: Coal ash
I work for Prairie Rivers Network, a nonprofit based in Champaign that works to protect water, heal land, and inspire change in Illinois. Some of you may be familiar with coal ash. It’s the byproduct of burning coal. Coal itself has trace elements of toxic heavy metals, and those trace elements end up getting concentrated in the coal ash, which is then stored in large holding ponds.
At the Waukegan power plant just a few miles from here, coal ash has been produced for decades over the operation and is stored in two huge ponds. Worse, coal ash has also been historically dumped across the site in unmarked areas.
The Coal Ash Pollution Prevention Act, Senate Bill 9, will force polluters to prove that they have the money to pay for cleaning up coal ash by requiring financial assurances. It funds the Illinois EPA to regulate coal ash with fees from polluters. It ensures that the public has a voice in the coal ash pond closure process. And it prioritizes environmental justice communities for cleanup.
We also won a major lawsuit, which began in 2012, that will hold NRG Energy’s subsidiary liable for the pollution at four of their coal-fired power plants, including Waukegan.
We’ve had a lot of good news, but there’s still more work to be done. Our coal ash bill is going to be drafted into rules—and the devil is in the details. We’re going to need continued grassroots support to ensure our bill becomes a good rule. And the lawsuit itself isn’t over—legal matters are never that simple. NRG’s subsidiary is found liable for their pollution. The next legal battle is remedy. We’re going to work to ensure that the coal ash is removed and stored in a safe location. I’m hopeful that we’re on the right track to solving coal ash in Illinois
Guadalupe Bueno: Coal ash
Canoeing with other Eco-Ambassadors last summer, we saw coal ash leaching into the beautiful Vermilion River, visibly discoloring the water and staining the sandstone.
In Vermilion, the coal-fired generating station was retired in 2011. The company fulfilled the minimum requirements for capping the three coal ash ponds, which are located feet from the river itself. Within five years, those ponds began leaching into the river, poisoning a scenic waterway that supports fish, animals, and farms as it flows into the Illinois River.
Seeing the Vermilion river made me realize that this could occur in Waukegan, as well. The NRG plant is located on the shore of Lake Michigan, which supplies our drinking water.
Daniela Lopez: Ethylene oxide
The most recent threats of breathing ethylene oxide (EtO) are the most recent example of environmental injustices being played out not only in our state but across the nation.
When EtO was identified as a concern in Willowbrook (Sterigenics)—a 77 percent white suburb with an average per capita income of more than $71,000 a year—US EPA officials met with residents almost immediately. They began monitoring air three months later and put a seal the plant three months after that.
In Waukegan (Medline Industries)—where the neighborhoods most affected are only 25 percent white and have a per capita income of about $14,000—residents learned about the dangerous chemical in the air from a newspaper article in November when our elected officials were informed of the elevated levels in August. Residents are still waiting for the US EPA and the Illinois EPA to act.
If you have been following these government agencies, you know that we have received the ambient air testing results for the first phase of testing. Unfortunately the results confirmed our suspicions that the levels of EtO are on par with those found around the Sterigenics facility in Willowbrook, and at the highest 500 times higher than the EPA’s actionable limit for EtO (50,000 higher than the levels linked to an increase in rates of cancer). This is also the location closest to Alice’s Discovery Academy, a daycare center for children 6 weeks to 12 years old, and the Landings at Amhurst Lake, a large apartment complex.
Celeste Flores: Clean Energy Jobs Act
The Illinois Clean Jobs Coalition is working to expand on the success of the Future Energy Jobs Act, advocating for more urgent active at the state level.
Our partner, Faith In Place Action Fund, is working to pass the Clean Energy Jobs Act. This legislation would make Illinois a national clean energy leader by bringing the state to 100% renewable energy, a carbon-free grid by 2030, and a significantly cleaner transportation sector, creating jobs and economic opportunity throughout Illinois.
The Clean Energy Jobs Act also would:
Generate more than $30 billion in new infrastructure and thousands of jobs in the state.
Create an equitable distribution of economic benefits for communities that stand to gain the most through Clean Jobs Workforce Hubs and Clean Energy Empowerment Zones.
Increase investments and incentives for clean transportation and electric vehicle charging.
Grant more residents access to popular cost-saving community solar programs
The Clean Energy Jobs Act will ensure an equitable energy transition that benefits all of Illinois and doesn’t leave communities like Waukegan behind.
[Joey Banks/Unsplash photo]By Dr. Dylan Burdette, PhD
Residents of Waukegan have heard quite a bit lately about the frightening health and cancer risks of ethylene oxide (EtO). However, they have heard very little about the explosion hazards of EtO. We would be naive to ignore these very real hazards and the risks they pose for our community—especially since Waukegan was literally shaken by a major explosion of another type of chemical facility, the AB Specialty Silicones factory, on May 3, 2019.
EtO explosions are lethal
In addition to its many industrial uses, EtO and, in some cases, propylene oxide (PO) are the main components in thermobaric and fuel air explosive (FAE) weapons used by the US military. These are among the most powerful nonnuclear weapons in our country’s arsenal. Thermobaric weapons are two-phase explosives: They first create an aerosol cloud of flammable material and then ignite it, similar to a gas leak or a coal mine explosion.. They can wound or kill via multiple mechanisms—the blast wave, exposure to burning fuel, or exposure to the residual fuel cloud.
EtO is a preferred fuel for these weapons as it has a shock wave effectiveness of 5:1 compared to dynamite,[1] according to Explosives by Rudolf Meyer et al. In other words, to duplicate the shock wave of 5 pounds of dynamite, you need just 1 pound of EtO.
Thermobaric weapons fueled by EtO react at a very high temperature and cause a self-sustaining flame, setting fire to all structures in the immediate blast radius. The decomposition reaction resulting from the primary explosion moves at nearly 4,500 miles per hour,[1] burning as it goes.
“Those near the ignition point are obliterated. Those at the fringe of explosion are likely to suffer many internal, and thus invisible injuries, including burst eardrums and crushed inner ear organs, severe concussions, ruptured lungs and internal organs, and possibly blindness,”[2] according to a 1990 CIA study.
In a 1993 document, the Defense Intelligence Agency speculated that because the “shock and pressure waves cause minimal damage to brain tissue … it is possible that victims of FAEs are not rendered unconscious by the blast, but instead suffer for several seconds or minutes while they suffocate.”[2]
“The [blast] kill mechanism against living targets is unique—and unpleasant,” according to a separate 1993 Defense Intelligence Agency document. “… What kills is the pressure wave, and more importantly, the subsequent rarefaction [vacuum], which ruptures the lungs. … If the fuel deflagrates but does not detonate, victims will be severely burned and will probably also inhale the burning fuel. Since the most common FAE fuels, ethylene oxide and propylene oxide, are highly toxic, undetonated FAE should prove as lethal to personnel caught within the cloud as most chemical agents.”[2]
EtO explosions in Waukegan?
Why are the effects of EtO-fueled weapons relevant to residents of Waukegan? Because, according to the risk management plan (RMP 3-2172) it submitted on May 29, 2019, to the Illinois EPA, the Vantage Specialty Chemicals plant in Gurnee has 700 tons of EtO stock on hand, and 205 tons of propylene oxide. This is enough to generate a shock wave equivalent to a 4.5-kiloton TNT explosive.
At the Medline Industries plant in Waukegan, the estimated on-site EtO stock would generate a shockwave equivalent to an 80-ton TNT explosive. However, we can only estimate the risk as Medline has not filed a risk management plan with the state. This means possible risks would be a mystery for first responders and environmental officials arriving on the scene in the event of an accident.
Using these figures, we can calculate a blast wave and damage radius for a catastrophic failure at either of these facilities.
At Vantage, the primary explosion would be a fireball almost 500 feet across. It would cause instant third-degree burns to people within 3,000 feet—including workers at ABC Supply, Dynapar, Gallagher Corporation, and more.
The pressure wave would cause most houses within a half mile to collapse. It would destroy Route 41 and any vehicles on the road. It would break all windows in a one-mile radius.
The result: approximately 1,000 casualties, with many additional injuries.
Barring an explosive event, Vantage’s own risk management plan concludes that a 10-minute leak event would cover 9.9 miles and affect 387,000 people. This radius includes schools, residences, hospitals, recreational facilities, churches, airports, wildlife sanctuaries, rivers, creeks, and even Lake Michigan. This would expose people within the zone to an environment “as lethal to personnel … as most chemical agents.”[2]
There is no passive mitigation in place to stop this gas once it has been released. Vantage’s active mitigation includes two independent computer control systems to control their processes, but there is no mention of any cybersecurity measures that would protect the public if one or both of these control systems were to become compromised.
At Medline, the primary explosion would be a fireball 100 feet across. It would cause third-degree burns to people within 700 feet, including workers at nearby facilities.
The pressure wave would destroy nearly every building within 600 feet—including an AbbVie facility, Fastenal, and Precision Laboratories—and other unreinforced buildings. It would destroy Route 41 and any vehicles on the road. It would break all windows at buildings within a quarter mile—including Candlewood Suites and Fountain Square Senior Apartments.
The result: approximately 190 casualties, with many additional injuries.
These are conservative estimates, and for Medline are based only on estimated EtO stocks.
One important caveat: These calculations are based on a circular blast radius. Due to the drifting of fuel that happens in thermobaric explosions between the primary aerosolizing event and main explosion, the shape of the blast radius is rarely so easily defined.[3]
It is also important to remember that both Vantage and Medline are located in industrial zones that house other facilities with their own stocks of flammable and explosive substances—like AB Specialty Silicones. However, determining the magnifying effects of these other chemical stocks on the tremendous devastation that would result from a failure at either Vantage or Medline is beyond the scope of this post.
EtO: Wrong for residential areas
We are not alone in this view. We know that ethylene oxide is an extremely dangerous chemical, both as an emitted gas and as a stockpiled explosive. We will continue to push to control this explosive, carcinogenic, and mutagenic substance until we can be sure that all of us, all of our children, and all of our communities are safe. We demand that right.
Dr. Dylan Burdette has a doctorate in biochemistry and molecular biology.
Coal ash pollution seeps into the Vermilion River in central Illinois. [Prairie Rivers Network photo]
Clean Power Lake County joined a dozen statewide and regional partner organizations on May 28, 2019, in celebrating the passage of SB9, The Coal Ash Pollution Prevention Act, by the Illinois Legislature. The bill now heads to the desk of Gov. J.B. Pritzker for signature.
The groundbreaking bill addresses the many waste pits filled with coal ash, the toxic byproduct of burning coal, located all over the state:
Creates a regulatory framework to ensure polluters, not taxpayers, pay for needed closure and cleanup.
Guarantees public participation and transparency around cleanups for affected communities.
Provides the Illinois EPA the funds it needs to properly oversee closure and cleanup.
Requires Illinois to put in place standards for coal ash impoundments that are at least as protective as federal coal ash rule requirements, with additional protections against dust and water pollution.
Illinois — which has the highest concentration of coal ash impoundments in the country — now is the third state in the country to pass legislation providing significant coal ash protections above and beyond federal requirements. Virginia and North Carolina also are addressing coal ash through state-level legislation.
The NRG Energy coal-fired power plant on Waukegan’s lakefront has two unlined coal ash ash ponds.
“The passage of SB9 out of the general assembly is a historic step forward for environmental justice communities across the state, like Waukegan,” said Dulce Ortiz, co-leader of Clean Power Lake County. “Environmental justice communities still have a long fight to assure community members have the basic human right of breathing clean air and drinking clean water. We call on Gov. Pritzker to prioritize the voices of a community like Waukegan and protect them from polluters like NRG Energy.”
“The passage of SB9 is a historical win for environmental justice communities throughout our state,” said Celeste Flores, with the Faith In Place Action Fund and co-leader of Clean Power Lake County. “People of faith across Illinois applaud the leadership of our elected leaders in the Senate and House for taking action on coal ash contamination of our land and water and implore the general assembly to continue to hold polluters accountable for injustice, oppression, and environmental degradation.”
We thank the many Lake County elected officials who supported this important legislation: State Senators Melinda Bush, Terry Link, and Julie Morrison; and State Representatives Rita Mayfield, Joyce Mason, Dan Didech, Mary Edly-Allen, Bob Morgan, and Sam Yingling.
We also thank everyone who signed petitions, made phone calls, and visited your elected officials. We are stronger together.
On March 27, 2019, Celeste Flores and Diana Burdette went to EPA headquarters in Washington, DC, to testify on the need to protect members of marginalized communities from toxic ethylene oxide (EtO) emissions. They spoke against the reversal of EPA’s Integrated Risk Information Systems data and urged EPA to follow its mandate to protect human health and the environment.
On April 26, they added their voices to those of many other environmental justice advocates by submitting their formal comment on behalf of Clean Power Lake County.
Key points in the comment:
EPA is using this rulemaking about hydrochloric acid production facilities to attempt to undercut the independent, scientific standard for ethylene oxide (which is causing extremely high cancer risk in many communities across the country), and EPA must abandon this attempt
Communities of color and low-income communities are disproportionately exposed to pollution from hydrochloric acid facilities
EPA is basing its proposal for little or no regulation of hydrochloric acid facility emissions on underreported and underestimated data
EPA claims that hydrochloric acid facility emissions are “acceptable” but is ignoring many emissions and risks that would demonstrate greater harm that requires reduction
EPA must consider and address the multiple and cumulative impacts that many communities face
Celeste Flores is Lake County Outreach Director for Faith in Place and co-chair of Clean Power Lake County. Diana Burdette is a member of Clean Power Lake County’s EtO team.
