CPLC Works to Prevent Weakening of EtO Standards

[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?

Feel free to write your own letter or copy our letter.

Then:

Or go to GovTrack to find your senator or representative.

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CPLC Environmental Justice Rally: Highlights

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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.

Last year, a report we released in partnership with the Environmental Integrity Project, Earthjustice and Sierra Club showed that 22 of the 24 coal-fired power plants that we examined had groundwater above health-based thresholds.

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.

Ethylene Oxide Poses Explosion Risks in Lake County 

[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.

Ethylene oxide risk chart

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. 

References
1. Meyer R, Köhler, J., Homberg A. Explosives. 6th ed. Weinheim, Germany: Wiley-VCH; 2007. 2. Human Rights Watch. Backgrounder on Russian fuel air explosives (“vacuum bombs”). https://www.hrw.org/report/2000/02/01/backgrounder-russian-fuel-air-explosives-vacuum-bombs. Published February 1, 2000. 3. Cross K, Dullum O, Jenzen-Jones NR, Garlasco M. Explosive weapons in populated areas: technical considerations relevant to their use and effects [PDF]. Armament Research Services (ARES): May 2016. https://www.icrc.org/en/download/file/23603/aresweb-generic.pdf. Accessed June 24, 2019.

This post has been updated. An earlier version contained a quotation from a third party. 

CPLC Submits Formal Comments on Toxic Ethylene Oxide to EPA

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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.

Read our comments to the EPA.

Ethylene Oxide: Lake County Moves Forward on Air Test Plans

Officials expect to complete plans for air testing in Waukegan and Gurnee in early May. [Stuart Miles/Stockvault photo]

After speaking earlier this week with Lake County Health Department officials Mark Pfister and Larry Mackey, members of Clean Power Lake County’s ethylene oxide (EtO) team say there is good reason to be excited about moving forward to document and address EtO pollution in our community.

“It is important to note that what is happening here is rather unprecedented,” said Dr. Dylan Burdette of Clean Power Lake County. “This is a situation where every official from Rep. Brad Schneider down to the mayors in the fenceline communities affected by EtO is amazed by the failure of the US EPA and the Illinois EPA to take action and ensure the safety of citizens in the face of what has happened 50 miles away in Willowbrook at the Sterigenics facility, and that it is an obvious environmental justice issue. That being said, our local officials are making remarkable strides, and very quickly.”

First, we are nearing the end of air modeling that will inform the placement of testing canisters surrounding the Medline Industries plant in Waukegan and the Vantage Specialty Chemicals plant in Gurnee, Burdette explained.

As we were able to observe from the Willowbrook test case, many of the sites that were selected by the community ended up producing data that could not be used by either the EPA or the Agency for Toxic Substances and Disease Registry (ATSDR), the wing of the Centers for Disease Control and Prevention (CDC) devoted to calculating risk based on exposure, Burdette added.

In our case, all testing locations, and the number of locations, will be set using EPA modeling of air patterns, Burdette said.

A vendor has been chosen to do the air sampling, and all air samples will be analyzed using EPA facilities. In order to maintain full scientific integrity, the exact testing locations will be released only after the tests have begun.

For the air testing itself, there will be some regularity of every 3 days. There also will be randomly inserted tests in order to make sure that the facilities are not gaming the system.

The initial plan for testing is 30 days. However, if there are any valid scientific reasons for extending the testing, mechanisms are set in place by Pfister at the Lake County Health Department to extend that period as needed.

The entire planning portion of the air testing is expected to be completed over the next week, with testing due to commence in June. Once the plan is complete, contracts will be sent to the participating municipalities for votes of approval. At that point, the contract will be ratified by the Lake County Board of Health and testing will commence.

As we attempt to maintain maximum transparency during this time, we will issue updates when we can. However, we will only release factual and correct information, which may take time to vet, Burdette said.

Ethylene Oxide: CPLC Fights Toxic Emissions in Our Community

Diana Burdette
Diana Burdette of Clean Power Lake County discusses community efforts to ban ethylene oxide emissions during an appearance on Adelante.

Tens of thousands of residents in western Waukegan, Gurnee, Park City, North Chicago, Warren Township, and Naval Station Great Lakes, are at risk from ethylene oxide (EtO) emissions — the same cancer-causing chemicals that prompted Gov. J.B. Pritzker to order the shutdown of Sterigenics in DuPage County.

And that is unacceptable!

Clean Power Lake County and Faith in Place have worked actively on this issue since November 2018, when an article about cancer-causing ethylene oxide gas emissions in Waukegan and Gurnee appeared on page 1 of the November 4, 2018, Chicago Tribune.  Our own Celeste Flores and Rev. Eileen Shanley-Roberts were key sources in that article.

That was when we learned that Medline Industries in Waukegan and Vantage Specialty Chemicals in Gurnee posed significant health risks to our communities.

Officials from Lake County, Waukegan and Gurnee knew about the hazards before the Chicago Tribune article was published. However, they did not warn neighbors of the hazards.

  • More than 19,000 people live within areas at risk from ethylene oxide emitted at the Medline Industries plant in Waukegan (near Skokie Highway and Casimir Pulaski Drive—just west of Greenbelt Forest Preserve).
  • More than 23,000 people live within areas at risk from ethylene oxide emitted at the Vantage Specialty Chemicals plant in Gurnee (near Route 41 and Delaney Road).

What’s happening on ethylene oxide in Lake County

February 12, 2019: U.S. Senators Dick Durbin (D-IL) and Tammy Duckworth (D-IL), along with U.S. Representatives Brad Schneider (D-IL-10), Bill Foster (D-IL-11), Dan Lipinski (D-IL-03), and Sean Casten (D-IL-06), introduced bills that would hold the U.S. Environmental Protection Agency accountable for its poor oversight of ethylene oxide emissions.

March 27, 2019: U.S. Senators Tammy Duckworth (D-IL), Dick Durbin (D-IL) and Tom Carper (D-DE) sent a letter to Environmental Protection Agency Administrator Andrew Wheeler seeking information related to the agency’s recent decision to question EPA career staff’s assessment of the health risks and political appointees’ handling of potentially illegal releases of ethylene oxide (EtO). They also requested documents shedding light on the Trump EPA’s enforcement efforts at the Sterigenics Illinois plant and its management of risks posed by EtO at facilities nationwide.

March 27, 2019: Celeste Flores and Diana Burdette testified in Washington, D.C., on the need to protect members of marginalized communities from toxic ethylene oxide emissions.

April 2, 2019: U.S. Senators Tammy Duckworth (D-IL) and Dick Durbin (D-IL) asked the Department of Homeland Security to revise its characterization of ethylene oxide, as required under the Chemical Facility Anti-Terrorism Standard, as both flammable and explosive.

April 8, 2019: The Lake County Health Department and Community Health Center, City of Waukegan, and Village of Gurnee officials announced plans to hire one vendor to collect air quality samples from four sites near Vantage Specialty Chemicals in Gurnee and four sites near Medline Industries in Waukegan. Read more.

April 10, 2019: The Illinois Senate passed SB 1852, requiring facilities to alert nearby property owners and local government of ethylene oxide leaks, and SB 1854, restricting and testing for fugitive emissions of ethylene oxide.

April 12, 2019:  U.S. Representative Brad Schneider (D-IL-10), spoke on the House floor regarding the need for ambient air testing of ethylene oxide in Waukegan and Gurnee so families can have confidence the air they and their children breathe is safe.

What is ethylene oxide?

Ethylene oxide (EtO) is a colorless gas used in the manufacturing of several industrial chemicals and as a sterilizing agent for medical equipment and supplies. People can be exposed to EtO through direct inhalation, ingestion, or contact to the skin, according to the Occupational Safety and Health Administration.

In December 2016, the U.S. EPA updated the risk status of ethylene oxide from “probably carcinogenic to humans” to “carcinogenic to humans.”

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