Dear Administrator Wheeler:
In light of the U.S. Environmental Protection Agency's (EPA's) recent announcement regarding proposed amendments to the Miscellaneous Organic Chemical Manufacturing National Emission Standards for Hazardous Air Pollutants (NESHAP), the status of the NESHAP for ethylene oxide (EtO) at commercial sterilization, and the inclusion of EtO in the National Air Toxics Trends Stations network and the Urban Air Toxics Monitoring Program, we write to reiterate our requests to better protect communities from this carcinogenic gas.
The EPA has taken some steps to address the public health risks associated with EtO, but it has a responsibility to do more to provide strict, protective standards for harmful chemicals emitted by industrial processes. Therefore, we ask that EPA move forward with the following measures to protect communities in Illinois--and the rest of the country--from EtO exposure:
-Quickly promulgate new rules for ethylene oxide emissions at commercial sterilization facilities, and publish a timeline of regulatory actions, along with a status of progress and estimated completion;
-In addition to monitoring EtO background concentrations, conduct site-specific ambient air monitoring at facilities identified by the EPA's National Air Toxics Assessment (NATA) to have an increased cancer risk due to EtO exposure, including facilities in Lake County, Illinois;
-Conduct inspections at all Region 5 facilities that use EtO to identify and quantify fugitive emissions and to evaluate the pollution control technologies in all rooms that contain EtO, including EtO drum, vessel, and aeration rooms;
-Work with the Agency for Toxic Substances and Disease Registry to provide measurements and complete a Letter Health Consultation for the communities surrounding Medline and Vantage in Lake County; and
-Work with the Food and Drug Administration to identify a safe alternative to EtO, or a proven way to effectively limit EtO exposure to both employees and those who live in nearby communities.
In addition, we request that you meet with us as soon as allows to discuss the recent announcements and other issues related to EtO emissions.
While the Sterigenics facility in Willowbrook, Illinois, will not reopen, other facilities located across the country that use EtO, including Medline in Waukegan and Vantage in Gurnee, are continuing operations with potentially insufficient federal standards--as described by your own Agency. The EPA is taking too long to move forward with new rules, ignoring many of our requested actions aimed at protecting communities.
Thank you for considering our requests, and we look forward to your prompt response.