EPA faces lawsuit as inaction exposes millions to carcinogenic ethylene oxide every day

US EPA plaque
The US Environmental Protection Agency faces a lawsuit for inaction that exposes millions to cancer-causing ethylene oxide every day. [Image: Nojustice-Canva]

Today, Earthjustice—on behalf of Clean Power Lake County and other environmental and health advocacy groups—sent a 60-day Notice of Intent to sue the U.S. Environmental Protection Agency (EPA) over the agency’s inaction to regulate harmful carcinogenic air emissions from ethylene oxide (EtO) facilities as the law required.

The Clean Air Act directs the EPA to review its EtO standards every eight years. However, the agency has repeatedly missed this deadline—first in 2014 and again in April 2022.

The EPA admits the chemical is 60 times more toxic than previously estimated and that facilities that emit EtO, including commercial sterilizers and chemical manufacturers, pose an elevated cancer risk to nearby communities. Children are particularly sensitive to ethylene oxide when exposed.

Ethylene oxide is a colorless, typically odorless, flammable gas used to sterilize medical equipment and in the production of chemicals needed for antifreeze, plastics, detergents, and adhesives. It is one of the most toxic air pollutants EPA regulates. This toxic chemical is a known carcinogen to humans, especially when inhaled.

Facilities that emit ethylene oxide are typically found in low-income neighborhoods and communities of color, many already grappling with elevated toxic exposure and health risks from multiple forms of industrial pollution.

“EPA has delayed for too long to update sterilizer rule while communities suffer unnecessary toxic exposure and unacceptable cancer risks,” said Earthjustice attorney Marvin Brown. “Congress passed the Clean Air Act to protect communities from the harmful effects of air pollution, and tasked EPA with ensuring that industry emissions do not threaten public health. By failing to timely revise its sterilizer rule, EPA has left communities to fend for themselves against a deadly, cancer-causing chemical. We are calling on the EPA to finally remedy this injustice without further delay.”

As each day passes, ethylene oxide threatens the health of many communities that continue to wait on EPA to fulfill its legal obligations under the Clean Air Act. Today’s letter provides notice that community and environmental groups cannot wait any longer—and will sue EPA to compel the agency to enact stronger, science-based standards that are protective of public health.

“Excuse after excuse has led to death after death and EPA refuses to act. The agency waited more than eight years after the first deadline, and now missed a second deadline to properly regulate ethylene oxide, even as it recognized that the chemical was causing cancer to people in communities across the country,” said Raul Garcia, legislative director of Healthy Communities at Earthjustice. ”Our letter intends to compel long overdue protective action from EPA, but should also serve as reminder to state and local officials that their inaction is leaving people exposed to severe risk of cancer and other illnesses in the very communities they serve. Cancer-causing chemicals must be properly regulated at every level of government immediately.”

“The EPA’s mission is to protect human health and the environment. They are failing my community and communities across the country with their inaction to regulate harmful air emissions from ethylene oxide facilities. It’s unacceptable that everyday community members have been forced to file this suit in order for the EPA to be accountable and update their standards as required by law. Our rights have been violated and the EPA must do its job,” said Celeste Flores, steering committee member with Clean Power Lake County.

Earthjustice filed the Notice of Intent on behalf of Rio Grande International Study Center, Clean Power Lake County, California Communities Against Toxics, Union of Concerned Scientists, and the Sierra Club.

CPLC: Statement on EPA study that identifies 23 high-risk EtO facilities

Medical instruments being sterilized in an autoclave. sterilizer.
Steam sterilization, dry heat sterilization, chemical sterilization using gases like ethylene oxide, and radiation are among the most common methods used to properly sterilize a medical device. [Image: Robertprzybysz/Canva]

Earlier this month, the Environmental Protection Agency (EPA) released results of a study identifying 100 communities impacted by exposure to ethylene oxide (EtO) released from sterilizing facilities. The EPA named 23 high-risk ethylene oxide sterilizer facilities that have a cancer risk rate above EPA’s 100-in-a-million unacceptable risk rate. Waukegan was not among the named communities. This is great news for our community. We are grateful for this small, positive sign that our local sterilizing facility has followed through on its promise to Clean Power Lake County to install additional pollution controls.

We stand in solidarity with the named communities and urge the EPA to do more than simply engage communities about the dangers of EtO. It is essential that at-risk communities be supported through continuous fenceline monitoring for accurate emissions data. 

Moreover, we challenge the EPA to recognize that distribution and storage facilities also pose a potential risk for EtO emissions. They should be monitored as well so that all potential sources of exposure to EtO used for sterilization can be identified. 

Clean Power Lake County also recognizes that the study applies to a very specific industry. In Illinois, medical sterilization facilities are regulated by strict controls.

However, the communities of Waukegan and Gurnee are impacted by a less regulated source of EtO emissions—Vantage Specialty Chemical, which uses ethylene oxide in the manufacture of other products. This industry is currently exempt from many EPA regulations. We urge EPA to close those loopholes and undertake monitoring of the neighborhoods surrounding that facility as well. 

The EPA statement is a positive step in the fight to end EtO emissions. There are many more steps to take before all communities impacted by EtO exposure—especially those at greatest risk of negative health outcomes—can feel safe in their own homes. 

EPA must do more to hold corporate polluters responsible and require them to use the most effective emissions controls possible or develop new technologies that replace the use of EtO for sterilization. 

Read more about the EPA’s EtO risk assessments and list of high-risk communities. 

CPLC: 2021 highlights

  • Clipping of Chicago Tribune front page
  • Volunteers in Zoom room
  • Volunteers with rainbow "Love Wins" sign
  • Youths with signs at Illinois statehouse
  • Volunteers with trash bags at park
  • Youths at desk in CPLC office
  • Governor Pritzker at Chicago lakefront
  • Dulce Ortiz of Clean Power Lake County
  • CPLC leaders at Chicago lakefront
  • Man with award at Brushwood Center
  • Dulce Ortiz on beach by coal plant

As we reflect on the events of 2021, we feel grateful for—and empowered by—our community and our shared vision to make our world a better place. Clean Power Lake County (CPLC) is proud to highlight some of our recent accomplishments.

February

  • February 7: CPLC co-chair Dulce Ortiz joined the Illinois Environmental Justice Commission as a voting member. The commission advises the Governor and state entities on environmental justice and related community issues.
  • February 8: Four members of CPLC’s steering committee joined a one-day hunger strike to protest the move of General Iron Industries’ metal shredding facility from Chicago’s affluent, predominantly white Lincoln Park neighborhood to Chicago’s predominantly Latino Southeast Side.

April

  • April 15: The Illinois Pollution Control Board adopted rules for closing more than 70 coal ash ponds across the state—including two on Waukegan’s lakefront. CPLC members worked hard to make this happen!
  • April 18: CPLC demanded that President Joe Biden’s administration address the Environmental Protection Agency’s failure to investigate ethylene oxide (EtO) polluters in Lake County—or to warn residents about the carcinogen.

May

  • May 17: “Transparency is key,” said CPLC co-chair Celeste Flores in a Chicago Tribune front-page story about Medline’s failure to report toxic ethylene oxide emissions to the Environmental Protection Agency.
  • May 24: CPLC organized one of several phone banking events supporting the Clean Energy Jobs Act (CEJA).

June

  • June 2: CPLC participated in the Waukegan Pride Drive for the second consecutive year to help celebrate LGBTQ Pride Month. 
  • June 14: CPLC and allies told the Chicago Tribune that toxic waste left behind by coal-fired power plants could endanger drinking water for years to come.
  • June 15: CPLC volunteers journeyed to Springfield to advocate for passage of Gov. J.B. Pritzker’s comprehensive, equitable climate bill.
  • June 17: NRG announced plans to close the coal-fired power plant in Waukegan. “Hundreds of volunteers, thousands of hours, helped make this day a reality,” said CPLC co-chair Dulce Ortiz. 

July

August 

  • August 2: Big win! After meeting with CPLC, the Environmental Protection Agency decided to revise rules for how coal-fired power plants—including the one in Waukegan—can dispose of contaminated wastewater.
  • August 7: CPLC partnered with Illinois Sen. Adrianne Johnson to organize a clean-up at North Chicago’s Foss Park. 

September 

October

  • October 2: CPLC steering committee member Eddie Flores received the Environmental Youth Leadership Award from Brushwood Center at Ryerson Woods. 

December 

  • December 5: CPLC’s fight for clean air, clean water, and healthy soil in Waukegan was the subject of the front-page story in the Sunday edition of the Chicago Tribune. CPLC co-chair Dulce Ortiz and steering committee members Eddie Flores and Karen Long MacLeod were interviewed.
  • December 15-16: CPLC volunteers asked dozens of questions during Midwest Generation’s public meetings on proposed plans to close coal ash ponds on the Waukegan lakefront.  

2022 vision 

This year, we feel all the more energized to accomplish our mission: ensuring clean air, clean water, and healthy soil for every Lake County community member and achieving the self-determination of those disproportionately impacted by environmental pollution.

Priorities for 2022: 

  • Continue pursuing a just transition for the Waukegan coal plant. This means ensuring that coal ash is removed so it cannot contaminate Lake Michigan, the source of drinking water for 6 million people in four states. It also means ensuring proper notification and public engagement if and when the company plans any demolition at the site. 
  • Monitoring efforts to implement the Coal Ash Pollution Prevention Act (signed into law in 2019) to hold coal plant owners accountable for clean-ups.
  • Serving in key working groups to ensure effective implementation of the Climate and Equitable Jobs Act (signed into law in 2021).

CPLC: Statement on EPA’s Failure to Protect Lake County Residents From EtO

EPA map of cancer risk levels associated with ethylene oxide in Lake County, Illinois.
Residents of Lake County, Illinois, face elevated cancer risk levels due to ethylene oxide emissions. [Image: US EPA]

Political appointees in the Trump administration blocked the Environmental Protection Agency (EPA) from investigating ethylene oxide (EtO) polluters and prevented staff from warning Lake County residents about the carcinogen, according to a new report issued by the inspector general for the EPA.  

Clean Power Lake County is deeply troubled to learn of yet another example of Trump’s EPA standing with polluters instead of communities. But we are not surprised. 

Although the EPA was aware of the dangers posed by EtO, it buried this information. EPA’s action put tens of thousands of disproportionately Black and brown Lake County community members in harm’s way. The EPA failed in its mission to protect human health and the natural environment by allowing corporations to continue jeopardizing the well-being of our already overburdened communities and exposing us to highly carcinogenic toxins. 

It should not be radical for us to demand a healthy living environment. 

We will hold the Biden administration to its promise to address these findings and demand continuous, independent, fenceline monitoring for EtO in every impacted community across the nation. 

We applaud the Biden administration for creating the Environmental Justice Advisory Council—and we remind council members that tailored action must follow for each EJ community. 

The EPA must provide the necessary support and proper communications to state EPAs and county health departments. This administration must hold the EPA accountable for communicating with local governments and EJ leaders; supporting state, county, and local priorities; and enforcing federal regulations. 

We look forward to continuing to work with Senators Tammy Duckworth and Dick Durbin of Illinois—two of the four members of Congress who requested an investigation into EPA’s handling of ethylene oxide emissions—and all of our elected officials to hold the EPA accountable and to address the many EJ issues our community members face.

For more information: 

CPLC: 2020 Highlights

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After the year we just had, the term “2020 vision” will never sound quite the same. 

2020 brought more than its share of tragedies and challenges, yet Clean Power Lake County (CPLC) had moments worth celebrating. We’re excited to share some of these moments with you because they highlight the many ways our supporters continue to show up to fight for environmental justice in Lake County. 

January 

  • January 6: CPLC joined Illinois Communities for Coal Ash Cleanup to comment on the Illinois Environmental Protection Agency’s draft rules for coal ash impoundments. 
  • January 6: The Waukegan City Council passed a resolution to support Illinois’ Clean Energy Jobs Act (CEJA). The resolution recognized that environmental risks and burdens fall disproportionately on communities of color—and that these burdens cumulatively contribute to climate change. CPLC supports CEJA as a solution to both environmental racism and climate change at the local level.
  • January 14: CPLC co-chair Celeste Flores traveled to Texas for EPA public hearings on the proposed Miscellaneous Organic Chemical Manufacturing rule. The proposed rule included regulations on ethylene oxide (EtO) emissions. Representatives of environmental justice organizations from across the nation attended the hearings. 
  • January 20: CPLC co-chair and Mano a Mano Executive Director Dulce Ortiz received a Drum Major Award from Waukegan Township. Announced on Martin Luther King Jr. Day, the awards recognize people who stand up for human rights and civil rights in their personal and professional lives.
  • January 21: CPLC joined other members of the Illinois Clean Jobs Coalition (ICJC) at a press conference to demand that legislators block Trump-backed fossil fuel bailouts. ICJC said the bailouts exacerbate climate change, pollution, and energy inequity.
  • January 21: The public finally learned that Medline Industries in Waukegan had initiated a temporary shutdown of EtO operations on December 13.
  • January 27: CPLC helped deliver 38,000 petitions from Illinois residents urging Gov. J.B. Pritzker to pass CEJA. Colin Byers of Waukegan spoke on our behalf. He was accompanied by Steering Committee members Rev. Eileen Shanley-Roberts, Eddie Sandoval, and Celeste Flores.
  • January 29: Gov. J.B. Pritzker mentioned clean energy as a priority during his State of the State address. (Let’s continue to urge the governor to act on this priority in 2021; see actions at the end of this post.)

February

  • February 4: Co-chair Celeste Flores attended the State of the Union address in Washington, D.C., as a guest of Sen. Tammy Duckworth to help shine a light on environmental justice and “raise awareness of the fact that these communities face public health challenges at alarming rates while too many in power look the other way.”
  • February 18: CPLC signed a joint organization letter calling on the EPA to reduce EtO and other emissions from chemical plants to decrease the risk of cancer.
  • February 21: Co-chair Dulce Ortiz spoke at an Illinois House Public Utilities Committee hearing, urging legislators to protect communities against the harmful impacts of continued fossil fuel bailouts by passing CEJA and growing an equitable clean energy economy.

March

April  

May

August

  • August 11: CPLC joined national environmental justice organizations in sending a letter to the EPA opposing attempts to undermine the independent scientific standard for EtO.
  • August 12-13: Ten CPLC volunteers delivered public comments at the first of two sets of coal ash hearings hosted by the Illinois Pollution Control Board. 

September

October

  • October 7: Anticipating that CEJA might come up for a vote during the scheduled veto session, CPLC partnered with ICJC to create a video with our perspective on the need for CJEA.  Although the veto session was cancelled, the video remains a strategic tool to help move legislators during the next session.
  • October 31: As of this date, 1,712 people had signed a joint Sierra Club/Faith in Place/Eco-Justice Collaborative/CARE petition calling for strong coal ash rules. More than 310 petitions contained personalized messages.

November

December

Last, but not least

  • CPLC, partnering with the Illinois Environmental Council Education Fund, launched the “Support CPLC” fundraising campaign. Proceeds will help us ramp up public work to transition northeastern Lake County toward a clean, sustainable future and to fight environmental injustice in our community. As of today, we are more than halfway toward our $30K goal. To support CPLC, please make a gift here.

2021 vision

We predict that CEJA will pass in 2021—with your help! So we must tell our elected officials to pass CEJA now!

We have much justice work to do this year. Despite 2021’s disturbing start, we look forward to continuing this work, together, to create a more livable, more just world.  

President-Elect Biden: Make Right on 7 Green Priorities

President-Elect Joe Biden
President-Elect Joe Biden, shown speaking at a 2020 campaign event. [“Joe Biden” by Gage Skidmore, licensed under CC BY-SA 2.0]

By Whitney Richardson

Dear President-Elect Biden,

We see you packing your (figurative) bags in preparation for your move into the White House. As you make plans to enact your presidential agenda, we urge you to use your executive powers to simultaneously and swiftly make right on all of the following:

We must remember we are here under the condition that our planet—experienced through our micro-environments—can retain the capacity to sustain us. It’s time to restore this essential lesson within our collective conscience. Climate change won’t wait. Our health won’t wait. Meaningful action can’t wait.

Sincerely, 

Clean Power Lake County
Waukegan, Illinois

Whitney Richardson lives in Vernon Hills, Illinois, and recently completed a Master of Science degree in international environmental studies. 

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.

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.