2014 National Air Toxics Assessment

August 27, 2018

by Wilma Subra [email protected] Graphics by Michael Orr [email protected]

On August 22, 2018, the Environmental Protection Agency (EPA) released the 2014 National Air Toxics Assessment (NATA). The previous 2011 National Air Toxics Assessment, released December 17, 2015, focused on air emissions of Chloroprene. Chloroprene has been released into the air in St. John the Baptist Parish of Louisiana for 49 years from the DuPont/ Denka facility in LaPlace/Reserve. NATA estimated higher than expected levels of Chloroprene in the community of LaPlace/Reserve based on the 2011 NATA report and identified the DuPont /Denka facility as creating the greatest offsite risk of cancer of any manufacturing facility in the United States.

The 2014 National Air Toxics Assessment focuses on Ethylene Oxide. Louisiana has 13 facilities that release air emissions of Ethylene Oxide. Three of the five facilities in the Unite State, releasing the largest quantities of Ethylene Oxide into the air, are located in Louisiana. The number two ranking air emissions facility of Ethylene Oxide in the US (Union Carbide in Hahnville) is located in St. Charles Parish, Louisiana, just down river from DuPont /Denka. The Ethylene Oxide air emissions from the Union Carbide facility along with the Ethylene Oxide air emissions from the Evonik Materials facility in Reserve, St. John the Baptist Parish, are responsible for St. John the Baptist and St. Charles parishes having the highest risk of cancer from Ethylene Oxide in all of Louisiana and all of the United States. St. John the Baptist Parish also has the highest risk of cancer in the United States from air emissions of Chloroprene.

National Air Toxics Assessment (NATA)

According to the EPA, “NATA is the US EPA’s ongoing thorough evaluation of air toxics across the Unites States. EPA developed NATA as a state-of-the-science tool to inform both national and localized efforts to collect air toxics information, characterize emissions and help prioritize pollutants and areas of interest for further study to gain a better understanding of risk. The goal of NATA is to identify those air toxics which are of greatest potential concern in terms

!1 of 20! Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] of contribution to population risk. Ambient and exposure concentrations and estimates of risk and hazard of air toxics in each state are typically generated at the census tract level.”

The NATA process consist of four steps: -compile a national emissions inventory of outdoor air toxics sources -estimate ambient concentrations of air toxics across the United States -estimate population exposure across the United States -determine potential public health risks from breathing air toxics

NATA estimates the cancer risks from breathing air toxics over many years. The 2014 NATA process evaluated 179 Hazardous Air Pollutants that are released into the air.

Ethylene Oxide

EPA addressed Ethylene Oxide in the 2014 NATA because it was identified as a potential long term concern in several areas across the United States. “EPA does not expect Ethylene Oxide levels in the air in these areas to be high enough to cause immediate harm to health. The 2014 NATA estimates that Ethylene Oxide significantly contributes to potential elevated cancer risks in some census tracts across the US.”

Ethylene Oxide is a Hazardous Air Pollutant (HAP) that is a flammable, colorless gas used to make other chemicals that are used in making a range of products, including antifreeze, textiles, plastics, detergents and adhesives.

Ethylene Oxide is manufactured from Ethylene and is used primarily as a chemical intermediate in the manufacturing of Ethylene Glycol.

Ethylene Oxide is also used to sterilize spices, equipment and plastic devices, such as medical equipment, that cannot be sterilized by steam.

Health Impacts of Ethylene Oxide

Ethylene Oxide is carcinogenic to humans if inhaled, based on weight of evidence.

It may be a teratogen in humans since it is a teratogen in animals.

Limited evidence indicates it causes spontaneous abortions.

May damage developing fetus.

May damage testes.

Long term exposure harms the brain and nervous system.

!2 of 20! Breathing air containing elevated Ethylene Oxide levels over many years increases the risk of some types of cancers, including cancers of the white blood cells (non-Hodgkin’s lymphoma, myeloma and lymphocytic leukemia) and breast cancer in females.

Strong evidence that female workers have increased rate of breast cancer.

Induces tumors of the brain, lungs, connective tissues, uterus and mammary glands.

Facilities that Release Ethylene Oxide

Synthetic Organic Chemical Manufacturing Industry Polyether Polyols Production Miscellaneous Organic Chemical Manufacturing Commercial Sterilizers Hospital Ethylene Oxide Sterilizers

Based on the 2016 EPA Toxic Release Inventory, there are 118 industrial facilities in the United States releasing Ethylene Oxide into the air. In the state of Louisiana, there are 13 industrial facilities and in Texas, 25 industrial facilities releasing Ethylene Oxide into the air. Three of the top five industrial facilities in the US releasing the largest quantities of Ethylene Oxide into the air are located in Louisiana, the other two are located in Texas. Together Louisiana and Texas have the top seven industrial facilities releasing the largest quantities of Ethylene Oxide into the air in the US.

Louisiana Industrial Facilities Releasing Ethylene Oxide into the Air

The 13 industrial facilities releasing Ethylene Oxide into the air in Louisiana are presented on the attached table. Eleven of the industrial facilities are located along the Mississippi River Industrial Corridor, six in Iberville Parish, three in Ascension Parish and one each in St. John the Baptist and St. Charles parishes. The remaining two industrial facilities are located in Calcasieu Parish in southwest Louisiana near the Texas border.

The following table lists the 13 facilities in Louisiana that report Ethylene Oxide air emissions.

!3 of 20! 2016 Toxic Release Inventory of Ethylene Oxide Air Emissions in Louisiana

Fugitive Stack US Facility Address Parish (lbs) (lbs) Ranking ST CHARLES 355 LA HWY 3142 (GATE 1), OPERATIONS (TAFT/ HAHNVILLE LOUISIANA ST CHARLES 5,132 30,726 2 STAR) UNION 70057 CARBIDE CORP 8404 HWY 75, GEISMAR BASF CORP. ASCENSION 1,100 14,000 4 LOUISIANA 70734 LAKE CHARLES CHEMICAL COMPLEX.2201 SASOL CHEMICALS OLD SPANISH TRAIL, CALCASIEU 144 14,600 5 (USA) LLC WESTLAKE LOUISIANA 70669 7594 HIGHWAY 75, SHELL CHEMICAL LP GEISMAR LOUISIANA ASCENSION 1,096 3,213 20 70734 THE DOW 21255 LA HWY 1 S, CHEMICAL CO - PLAQUEMINE LOUISIANA IBERVILLE 846 2,859 22 LOUISIANA 70764 OPERATIONS EVONIK MATERIALS 474 W 19TH ST, RESERVE ST JOHN THE 1,334 1,881 26 CORP. LOUISIANA 70084 BAPTIST BCP INGREDIENTS 3830 HWY 30, SAINT IBERVILLE 3,173 0 28 INC GABRIEL LOUISIANA 70776 3790 LA HWY 30, SAINT TAMINCO US LLC. IBERVILLE 18 1,185 37 GABRIEL LOUISIANA 70776 26270 HIGHWAY 405, SE TYLOSE PLAQUEMINE LOUISIANA IBERVILLE 253.933 17.173 65 LOUISIANA LLC 70764 INEOS OXIDE A DIV 21255A HWY 1 S, OF INEOS AMERICAS PLAQUEMINE LOUISIANA IBERVILLE 164.73 3.91 77 LLC 70765 9156 HIGHWAY 75, RUBICON LLC GEISMAR LOUISIANA ASCENSION 80 3 83 70734 1600 VCM PLANT RD, GEORGIA GULF WESTLAKE LOUISIANA CALCASIEU 2 0 110 LAKE CHARLES LLC 70669 26100 HWY 405 S, AXIALL LLC PLAQUEMINE LOUISIANA IBERVILLE 0 2 111 70764

!4 of 20! Number One Air Emitter of Ethylene Oxide in Louisiana

The largest industrial emitter of Ethylene Oxide into the air in Louisiana is the Union Carbide Corp. facility in Hahnville, St. Charles Parish. The Union Carbide facility ranks second in the US based on releasing 35,858 pounds of Ethylene Oxide into the air on a yearly basis. The number one industrial facility in the US releasing Ethylene Oxide into the air is the Huntsman Petrochemical facility in Port Neches, Texas.

Number Two Air Emitter of Ethylene Oxide in Louisiana

The second largest Louisiana industrial emitter of Ethylene Oxide is the BASF Corp. in Geismar, Ascension Parish. The BASF facility ranks fourth in the US based on the release of 15,100 pounds of Ethylene Oxide into the air on a yearly basis. The third ranking national facility is the Eastman Chemical Co. in Longview, Texas.

Number Three Air Emitter of Ethylene Oxide in Louisiana

The third largest Louisiana industrial emitter of Ethylene Oxide into the air is Sasol Chemical LLC in Calcasieu Parish with 14,744 pounds per year. The Sasol facility ranks fifth in the US based on the air emissions of Ethylene Oxide.

Ethylene Oxide Cancer Risk Due to Ethylene Oxide Air Emissions

The 2014 NATA contains Cancer Risk per one million individuals for each of the 179 Hazardous Air Pollutants on a census tract basis for 76,727 census tracts in all of the United States and Puerto Rico.

Census Tract Cancer Risk Associated with Ethylene Oxide in St. Charles and St. John the Baptist Parishes

St. Charles Parish is the location of Union Carbide Corp. in Hahnville, which releases 35,858 pounds of Ethylene Oxide per year into the air. The Union Carbide facility ranks number one in the state of Louisiana and number two in the US based on Ethylene Oxide air emissions.

St. John the Baptist Parish is the location of Evonik Materials Corp. in Reserve, which releases 3,215 pounds of Ethylene Oxide per year into the air. The Evonik facility ranks number six in Louisiana based on the quantity of Ethylene Oxide released into the air and ranks number 26 in the US based on Ethylene Oxide air emissions.

!5 of 20! St. Charles and St. John the Baptist parishes have the highest risk of cancer due to Ethylene Oxide in Louisiana (see attached maps of Cancer Risk by Census Tracts in St. John the Baptist Parish and St. Charles and St. John the Baptist parishes combined).

Census Tract 601 in St. Charles Parish has the highest cancer risk, 709.79 per one million individuals, in the state of Louisiana. The census tract is directly across the Mississippi River from the Union Carbide facility, the largest Ethylene Oxide air emitter in the state of Louisiana.

The second highest cancer risk census tract in Louisiana, 710, is located in St. John the Baptist Parish adjacent to the census tract 601 in St. Charles Parish (316.66 per one million individuals).

The third highest cancer risk census tract in Louisiana, 707 in St. John the Baptist Parish is the location of the Evonik Materials Corp. (249.76 per one million individuals).

The fourth highest cancer risk census tract in Louisiana, 627 in St. Charles Parish is the location of the Union Carbide facility (210.94 per one million individuals).

The highest cancer risk census tracts in the state of Louisiana cluster on and around the Evonik and Union Carbide facilities in St. John the Baptist and St. Charles parishes and the clusters overlap the census tract boundaries of both parishes.

Census Tract Cancer Risk Associated with Ethylene Oxide in Iberville and Ascension Parishes

Iberville Parish contains six industrial facilities releasing air emissions of Ethylene Oxide.

-Dow Chemical Company in Plaquemines ranks fifth in the state of Louisiana and 22nd in the US in air emissions of Ethylene Oxide (3,705 pounds per year).

-BCP Ingredients, Inc. in St. Gabriel ranks seventh in the state of Louisiana and 28th in the US in air emissions of Ethylene Oxide (3,173 pounds per year).

-Taminco US LLC. in St. Gabriel ranks eight in the state of Louisiana and 37th in the US in air emissions of Ethylene Oxide (1,203 pounds per year).

-SE Tylose Louisiana in Plaquemine ranks ninth in the state of Louisiana and 65th in the US in air emissions of Ethylene Oxide (271 pounds per year).

-Ineos Oxide in Plaquemine ranks tenth in the state of Louisiana and 77th in the US in air emissions of Ethylene Oxide (168.6 pounds per year).

!6 of 20! -Axiall in Plaquemine ranks 13th in the state of Louisiana and 111th in the US in air emissions of Ethylene Oxide (2 pounds per year).

Ascension Parish contains three industrial facilities releasing air emissions of Ethylene Oxide.

-BASF Corp. in Geismar ranks second in the state of Louisiana and fourth in the US in air emissions of Ethylene Oxide (15,100 pounds per year).

-Shell Chemical in Geismar ranks fourth in the state of Louisiana and 20th in the US in air emissions of Ethylene Oxide (4,309 pounds per year).

Rubicon LLC in Geismar ranks 11th in the state of Louisiana and 83rd in the US in air emissions of Ethylene Oxide (83 pounds per year).

The second highest cancer risk area associated with Ethylene Oxide in the state of Louisiana is clustered in and around the census tracts of Iberville and Ascension parishes containing the industrial facilities releasing Ethylene Oxide into the air.

The highest cancer risk in Iberville Parish, 142.08 per one million individuals, is in census tract 9532 in which Taminco and BCP are located. The next highest cancer risk in Iberville Parish, 76.24 per one million individuals, is census tract 9531.02 in which Axiall and SE Tulose are located. The next highest cancer risk in Iberville Parish, 71.94 per one million individuals, is census tract 9531.01 between Dow and Axiall.

The next highest cancer risk in Iberville Parish, 63.51 per one million individuals, is census tract 9527 in which Dow and Ineos Oxide are located.

The highest cancer risk in Ascension Parish, 85.52 per one million individuals, is in census tract 303 in which Rubicon, BASF and Shell Chemical are located. Census tracts 304.01 and 304.02 have cancer risk of 61.48 and 68.62 per one million individuals and are clustered adjacent to Rubicon, BASF and Shell Chemical. Census tract 302.03 and 302.04 with cancer risks of 59.41 and 52.11 per one million individuals are also clustered near Rubicon, BASF and Shell Chemical.

All of the census tracts in Iberville and Ascension Parishes are impacted by the Ethylene Oxide air emissions from the nine industrial facilities spread throughout the two parishes.

The following maps depict Cancer risk per 1 million individuals due to ethylene oxide air emissions in St John the Baptist, St Charles, Iberville, Ascension and Calcasieu parishes by census tract.

!7 of 20! !8 of 20! !9 of 20! !10 of !20 !11 of 20! Census Tract Cancer Risk Associated with Ethylene Oxide in Calcasieu Parish

Calcasieu Parish contains two industrial facilities releasing air emissions of Ethylene Oxide.

-Sasol Chemicals LLC in Mossville ranks third in the state of Louisiana and fifth in the US in air emissions of Ethylene Oxide (14,744 pounds per year).

-Georgia Gulf in Westlake ranks 12th in the state of Louisiana and 110th in the US in air emissions of Ethylene Oxide (2 pounds per year).

The third highest cancer risk area in the state of Louisiana, as a result of air emissions of Ethylene Oxide, is in Calcasieu Parish.

The highest cancer risk in Calcasieu Parish is in census tract 26, 84.45 per one million individuals, on the adjacent east side of the Georgia Gulf and Sasol facilities. The second highest cancer risk is in census tract 31.02, 63.03 per one million individuals, on the adjacent southwest side of the Georgia Gulf and Sasol facilities. The census tract in which the Georgia Gulf and Sasol facilities are located has a cancer risk of 49.71 individuals per one million. Elevated cancer risk are also clustered around the Sasol and Georgia Gulf facilities in a number of additional census tracts ranging from 27.03 to 34.94 per one million individuals.

Texas Cancer Risk Due to Ethylene Oxide Air Emissions from Industrial Facilities

In Texas, 25 industrial facilities release Ethylene Oxide into the air. The industrial facility with the largest quantity of Ethylene Oxide released into the air in the US is Huntsman Petrochemical in Port Neches, Jefferson County, Texas. Huntsman releases 77,248 pounds of Ethylene Oxide per year into the air. The highest cancer risk in the census tracts of Jefferson County for Ethylene Oxide is 232.80 per one million individuals. Clustered around the census tract on which Huntsman is located, the cancer risk ranges from 105.92 to193.75 per one million individuals.

The facility with the six largest Ethylene Oxide air releases in the US is Midwest Sterilization Corp. in Lorado, Webb County, Texas. The facility releases 14,731 pounds of Ethylene Oxide per year. The largest cancer risks in the area of the Midwest facility is 102.33 to 119.67 per one million individuals.

!12 of !20 The facility with the seventh largest Ethylene Oxide air releases in the US is Union Carbide Corp. in Seadrift, Calhoun County, Texas. Union Carbide releases 14,391 pounds of Ethylene Oxide per year. Formosa Plastics is located in Point Comfort in Calhoun County. Formosa releases 487 pounds of Ethylene Oxide per year into the air. The largest cancer risk in Calhoun County is 20.32 per one million individuals.

Harris County, Texas has a total of 12 industrial facilities releasing Ethylene Oxide into the air. Nine of the industrial facilities are located in Pasadena. The largest census tract cancer risk in Harris County range from 119.09 to 311.63 per one million individuals.

Conroe in Montgomery County has the Huntsman Petrochemical facility that releases 5,233 pounds of Ethylene Oxide into the air on a yearly basis. The county has the highest cancer risk due to Ethylene Oxide, 73.64 per one million individuals in one census tract.

The remaining seven industrial facilities in Texas releasing Ethylene Oxide, do not have elevated cancer risk in the area census tracts in which the facilities are located. The facilities consist of two facilities in Freeport and one each in Port Arthur, San Angelo, Grand Prairie, Fresno, and Dayton, Texas.

Cancer Risk in Louisiana and Texas Due to Ethylene Oxide Air Emissions

Louisiana

The state of Louisiana average cancer risk due to the air emissions of Ethylene Oxide is 12.14 per one million individuals. The parishes in Louisiana in which industrial facilities release Ethylene Oxide into the air have the following cancer risk associated with Ethylene Oxide.

Louisiana Parishes Cancer Risk per One Million Individuals St. John the Baptist 194.34 St. Charles 80.26 Iberville 72.93 Ascension 52.96 Calcasieu 14.96

!13 of !20 The highest cancer risk in a parish in Louisiana associated with Ethylene Oxide air emissions occurs in St. John the Baptist Parish(194.34 per one million individuals). The highest census tract cancer risk in Louisiana (709.79 individuals per one million) is census tract 601 in St. Charles Parish where the largest Ethylene Oxide air emitter in Louisiana, Union Carbide, is located.

Texas

The state of Texas average cancer risk due to the air emissions of Ethylene Oxide is 4.11 per one million individuals. The counties in Texas in which industrial facilities release Ethylene Oxide into the air have the following cancer risk associated with Ethylene Oxide.

Texas Counties Cancer Risk per One Million Individuals Jefferson 31.10 Webb 25.25 Gregg 14.9 Harrison 12.22 Montgomery 10.12 Brazoria 8.28 Liberty 7.42 Fort Bend 5.03 Tom Green 2.91 Dallas 0.79 Jim Wells 0.74 Bexar 0.57 Crosby 0.25

The highest cancer risk in a county in Texas associated with Ethylene Oxide air emissions occurs in Jefferson County, Texas (31.10 per one million individuals), where the largest air emitter of Ethylene Oxide in the US is located, Huntsman Petrochemical in Port Neches. The highest census tract in Texas associated with air emissions of Ethylene Oxide is located in Harris County where there are 12 industrial facilities releasing Ethylene Oxide into the air and nine of the 12 are located in Pasadena. Census Tract 3431 in Harris County has the largest cancer risk value in Texas, 311.63 per one million individuals.

!14 of !20 The highest cancer risk associated with Ethylene Oxide in Louisiana occur in St. John the Baptist Parish (194.34 per one million individuals) and St. Charles Parish (80.26 per one million individuals) and are 3.2 to 6.2 times higher than the highest cancer risk in counties in all of the state of Texas.

St. Charles Parish highest cancer risk is 709.79 per one million individuals in census tract 601 and St. John the Baptist Parish highest cancer risk is 316.6 per one million individuals in census tract 710. The highest census tract cancer risk in Texas is 311.63 per one million individuals in census tract 3431 in Harris County.

Louisiana has the highest cancer risk in the US associated with Ethylene Oxide and St. John the Baptist and St. Charles parishes have the highest cancer risk in the United States associated with Ethylene Oxide.

Chloroprene Cancer Risk in St. John the Baptist and St. Charles Parishes

The 2014 NATA report has Chloroprene Cancer Risk per one million individuals based on 2014 data. The 2014 Chloroprene Cancer Risk are plotted on the following map. The highest Chloroprene cancer risk per one million individuals in St. John the Baptist Parish is in census tract 708, which includes most of the Denka facility. The cancer risk increased from 776.8 in 2011 to 1,279.5 per one million individuals in the 2014 NATA report. The second highest Chloroprene Cancer Risk 336.02 per one million individuals is in census tract 709, which also includes the Denka facility. These two highest Chloroprene census tracts are the highest census tracts in both 2011 and 2014 NATA reports. The third highest Chloroprene cancer risk occurred in census tract 707, 221.3 per one million individuals. Census tract 707 is also the census tract in which the Evonik facility is located and contains the second highest cancer risk from Ethylene Oxide in St. John the Baptist Parish, 249.76 per one million individuals.

The cancer risk due to Chloroprene extended well into the census tracts of St. Charles Parish. The highest cancer risk due to Chloroprene in St. Charles Parish occurred in census tract 601, the closest census tract to St. John the Baptist Parish and includes the Bonnet Carrie Spillway, 57.17 per one million individuals. The next highest cancer risk due to Chloroprene in St. Charles Parish is clustered next to census tract 601, 627 - 35.31, 625 - 33.80, 624 - 23.42, 623.02 - 21.39, and 623.01 - 19.14 per one million individuals.

The Chloroprene cancer risk from the 2014 NATA report in St. John the Baptist Parish is 181.95 per one million individuals. In St. Charles Parish it is 15.73 per one million individuals.

!15 of !20 !16 of !20 The cancer risk due to Chloroprene air emissions in St. John the Baptist Parish is still the highest in the United States.

In addition, cancer risk due to Ethylene Oxide in the census tracts of St. John the Baptist Parish ranged from 139.50 per one million individuals in the Garyville census tract due to the Evonik facility to 316.66 per one million individuals between the Denka facility and the Bonnet Carre Spillway due to the Union Carbide facility.

Thus, the individuals in St. John the Baptist Parish and St. Charles Parish are exposed to excess cancer risk due to Chloroprene and Ethylene Oxide air emissions.

Note: EPA indicated that the increase in risk from 2011 to 2014 was due to a new modeling program and did not necessarily indicate an increase in cancer risk from Chloroprene in St. John the Baptist Parish.

EPA’s Strategy for Addressing Ethylene Oxide Air Emissions

Review Clean Air Act regulations for facilities that emit Ethylene Oxide.

-Reviewing air toxics emissions standards for miscellaneous organic chemical manufacturing facilities, some of which emit Ethylene Oxide.

-Take a closer look at its rules for other types of facilities, beginning with its emissions standards for commercial sterilizers.

Get additional information on Ethylene Oxide emissions.

-Gather additional information on industrial emissions of Ethylene Oxide, which may include data from testing at some types of facilities.

-The gathered information will help EPA as it evaluates opportunities to reduce Ethylene Oxide emissions as part of its regulations review.

-Assist the agency in determining whether more immediate emission reduction steps are necessary in any particular locations.

-Existing air monitoring methods are not sensitive enough to detect Ethylene Oxide at all levels in the outdoor air. EPA is actively working to develop new techniques for measuring Ethylene Oxide in the outdoor air.

!17 of !20 Integrated Risk Information System (IRIS) Ethylene Oxide Inhalation Unit Risk

In December of 2016, EPA’s Integrated Risk Information System (IRIS) changed the Ethylene Oxide adult based inhalation unit risk from 0.0001 ug/m3 to 0.003 ug/m3, a 30 fold increase in cancer potential.

IRIS also changed cancer - weight-of-evidence description from “probable carcinogenic to humans” to “carcinogenic to humans”.

Ethylene Oxide has been on the federal list of carcinogens since 1985. In December 2016, EPA released a reassessment linking it more conclusively to breast and blood cancer.

Sterigenics International in Willowbrook, DuPage County, Illinois

Sterigenics uses Ethylene Oxide to fumigate -medical instruments -pharmaceutical drugs -food products to kill bacteria and pests

EPA stated, based on the 2014 NATA report, some of the nation’s highest cancer risks from Ethylene Oxide toxic air pollution is from the Sterigenics facility.

Note: the highest cancer risk per census tract around the Sterigenics facility is 250.77 per one million individuals. In Louisiana we have two census tracts higher than 250.77 per one million individuals:

St. Charles Parish, census tract 601 along the Bonnet Carre Spillway adjacent to St. John the Baptist census tract 710, 709.79 per one million individuals.

St. John the Baptist Parish, census tract 710 on the boarder of St. Charles Parish, 316.66 per one million individuals.

EPA stated Ethylene Oxide used by Sterigenics is far more dangerous than previously thought. Sterigenics released 4,205 pounds of Ethylene Oxide into the air in 2016.

In one census tract near the Sterigenics plant, the EPA estimates the risk of cancer is more than nine times the national average. In St. John the Baptist Parish Chloroprene in census tract 708 is 800 times the national average.

There are four schools (2 elementary, 1 middle and 1 high school) and a day care center within a one mile radius of the Sterigenics facility.

!18 of !20 Seven census tracts around the Sterigenics plant have cancer risks high enough to trigger the EPA’s concern. The cancer risk of the highest seven census tracts range from 73.81 to 250.77 per one million individuals.

In St. John the Baptist Parish, all census tracts have cancer risks high enough to trigger the EPA’s concern.

109 Census Tracts in the Nation scored greater than100 per one million Individuals.

Location No. of Census Tracts Exceeding 100 per One Million Ind. Sterigenics 3 St. John the Baptist Parish 11 St. Charles Parish 3 Iberville Parish 1 Ascension 0 Calcasieu 0

Louisiana has 15 of the 109 census tracts in the US that scored greater than100 cancer risk per one million individuals.

Louisiana has the highest cancer risk census tract in the US, census tract 601in St. Charles Parish, 709.79 per one million individuals. It is across the Mississippi River from Union Carbide – the second largest emitter of Ethylene Oxide into the air in the US, 35,857 pounds per year.

EPA indicated in reference to the census tracts around the Sterigenics facility exceeding a cancer risk of greater than100 per one million individuals, most of the other census tracts are in “Cancer Alley” an infamous stretch of chemical plants along the Mississippi River in Louisiana. In an August 28, 2018 article in the Chicago Tribune, a link associated with that Cancer Alley statement links to the NPR article on March 6, 2018 by Rebecca Hersher entitled “After Decades of Air Pollution, A Louisiana Town Rebels Against A Chemical Giant. “ The article focuses on DuPont/Denka and the St. John the Baptist Concerned Citizens fight. The major photo is of Robert Taylor addressing the Parish Council in his Only 0.2 ug/m3 Will Do, red Shirt.

The EPA requested Sterigenics to install new equipment in July 2018 to reduce the facilities Ethylene Oxide air emissions. The effectiveness of the new equipment has not yet been determined.

!19 of !20 The Agency for Toxic Substances and Disease Registry issued an “Evaluation of Potential Health Impacts from Ethylene Oxide Emissions” associated with the Sterigenics International facility in Willowbrook, Illinois on August 21, 2018. The next day, August 22, 2018, EPA issued the 2014 NATA Report focused on Ethylene Oxide air emissions.

Local officials in Illinois have been reeling since the EPA privately shared the Sterigenics study during the week of August 21, 2018. Local officials have been working non-stop with village trustees and administrators, local, state and federal officials and assembling a taskforce to help them interpret the report.

Sterigenics is, for now, working voluntarily with the agencies.

!20 of !20 Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] Chloroprene Denka Performance Elastomer Former DuPont Pontchartrain Works, LaPlace LA

By Wilma Subra Louisiana Environmental Action Network [email protected]

August 20, 2019

EPA Air Sample Results Covering the Sampling Period May 25, 2016 Through December 2018 Highest Levels of Chloroprene by Sampling Location by Year

Location 2016 2017 2018 Fifth Ward Elementary 66.4 ug/m3 151 ug/m3 57.7 ug/m3 238 Chad Baker 46.1 ug/m3 70 ug/m3 37.4 ug/m3

Miss. River Levee 147 ug/m3 35.8 ug/m3 98.7 ug/m3 Acorn and Hwy 44 153 ug/m3 17.3 ug/m3 77.3 ug/m3 Ochsner Hospital 66.7 ug/m3 89.2 ug/m3 41.0 ug/m3

East St. John Hi S. 24.9 ug/m3 39.5 ug/m3 30.3 ug/m3 The highest Chloroprene air emissions at each of the six sampling locations in each year are far in excess of 0.2 ug/m3. The 2018 Chloroprene concentrations collected by EPA are 150 to 500 times the 0.2 ug/m3 concentration. The 2018 Chloroprene concentrations collected by Denka are 32 to 407 times the 0.2 ug/m3 concentration.

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] EPA Chloroprene Air Sampling During July 2019 (ug/m3) Date Locations 1 2 3 4 5 6

7-4-19 0.551 1.44 0.646 0.74 1.46 2.34/2.24 7-10-19 0.355 3.66/3.63 0.133 ND ND 0.294 7-16-19 ND ND 0.595/0.53 ND ND ND

1 Chad Baker 4 Fifth Ward Elementary School 2 Acorn &Hwy 44 5 Mississippi River Levee 3 East St. John High School 6 Ochsner Hospital

Denka Chloroprene (ug/m3) Air Sampling During July 2019 (ug/m3) Date Locations

1 2 3 4 5 6 7-3-19 0.3 1.6 1.3 1.2 1.7 ND 7-8-19 ND 3.7 ND 0.6 0.3 ND 7-15-19 ND ND ND ND Void ND 7-18-19 1.3 1.2 ND 0.3 4.8 ND 7-22-19 ND 5.8 ND ND 1.4 ND 7-26-19 0.4 ND ND ND ND ND 7-31-19 ND 2.8 ND 2.5 2.1 ND 1 Eastern Boundary, Entergy Subst. 4 Mississippi River Levee 2 Intersection Hwy 44 and IC Railroad 5 Southwest Corner of Hospital 3 Western edge of Denka property 6 Edgard, St. John Court House

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] Toluene (ug/m3) Date Locations 1 2 3 4 5 6

7-3-19 2.3 ND 2.5 2.6 ND ND 7-8-19 ND ND ND 1.9 ND 2.8 7-15-19 ND ND ND ND Void 9.8 7-18-19 3.3 ND ND ND ND ND 7-22-19 ND 3.2 2.5 ND ND 3.4 7-26-19 ND 4 2.8 2.4 ND ND 7-31-19 9 8.4 19.1 8.5 7.8 12.1

1 Eastern Boundary, Entergy Subst. 4 Mississippi River Levee 2 Intersection Hwy 44 and IC Railroad 5 Southwest Corner of Hospital 3 Western edge of Denka property 6 Edgard, St. John Court House EPA Air Monitoring for Chloroprene During the first half of July 2019, the EPA Chloroprene air monitors detected the highest concentration of Chloroprene at five of the six monitoring locations on July 4, 2019. The concentrations ranged from 0.551 ug/m3 at Chad Baker to 2.34 ug/m3 at Ochsner Hospital.

The Acorn & Hwy 44 monitoring location had the highest Chloroprene concentration on July 10, 2019, 3.66/3.63 ug/m3. All three air sampling periods in the first half of July, detected Chloroprene. Denka Air Monitoring Six of the seven Denka sampling events detected Chloroprene at one to five sampling locations. Each of five of six sampling locations had Chloroprene detected at one to five of the sampling dates. The Edgard location was all none detect for Chloroprene in July.

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] The highest concentration of Chloroprene was detected at the Railroad location on July 22, 2019, 5.8 ug/m3. The second highest Chloroprene concentration was detected at the Hospital on July 18, 2019, 4.8 ug/m3.

The highest Toluene concentrations were detected at all six monitoring locations on July 31, 2019. The Toluene concentrations ranged from 7.8 ug/m3 at the Hospital to19.1 ug/m3 at the Western Edge of the Denka.

While the Edgard monitoring location did not detect Chloroprene during July 2019, Toluene was detected at Edgard during four of the seven July 2019 monitoring periods. The Toluene concentrations ranged from 2.8 ug/m3 on July 8, 2019 to 12.1 ug/m3 on July 31, 2019. In addition, on July 15, 2019, Ethyl Benzene and Benzene was detected at Edgard and Ethyl Benzene and Xylene were detected at Edgard on July 31, 2019. Benzene was detected at the Entergy Substation on July 18, 2019, 1.6 ug/m3.

Denka Chloroprene Air Emissions

Denka Performance Elastomer LLC purchased the DuPont Pontchartrain Works Neoprene Facility in LaPlace in November 2015. DuPont continues to operate the Diamine Unit. Denka manufactures Chloroprene and uses the Chloroprene to manufacture Neoprene. Chloroprene has been released into the air since 1969, for 50 years. Denka is the largest releaser of Chloroprene into the air in the US.

NATA Screening Level Assessment The Environmental Protection Agency’s 2010 National Air Toxics Assessment (NATA), was released in December 2015. NATA classified Chloroprene as a likely human carcinogen and established the long-term cancer based comparison level for a 100 in 1 million cancer risk comparison level as 0.2 ug/m3 for Chloroprene.

NATA estimated higher than expected levels of Chloroprene in the community of LaPlace, Louisiana. 6

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] NATA/EPA identified the DuPont/Denka facility as creating the greatest offsite risk of cancer of any manufacturing facility in the US. Chloroprene Cancers

Studies have demonstrated that Chloroprene increases the risk of cancer in humans associated with: Liver cancer Kidney Cancer Leukemia Lung cancer Colon Cancer The other 27 chemicals released into the air by DuPont/Denka are associated with various types of cancers and other severe medical conditions: Bladder Blood Breast Esophageal Heart Leukemia Liver Lung Lymph Spleen Thyroid Uterine Cancers Teratogen Mutations Reproductive Disorders Decreased fertility EPA Air Monitoring

EPA began collecting 24 hour Chloroprene air sampling events at six locations around the Denka facility on May 25, 2016. The samples are collected every three days for 24 hours using Summa Canisters. On March 1, 2019, EPA decreased their frequency of collection of Chloroprene air samples to once every six days for 24 hours each. Chloroprene and the Fifth Ward School

The Fifth Ward School is located on the Western side of the Denka facility, in census track 708 with 776.8 per million risk due to Chloroprene air emissions. This is the census track with the highest risk due to Chloroprene in the US. The following table presents the results of the EPA monitoring at the Fifth Ward School by month and the frequency when the air at the school location did not contain Chloroprene. 7

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] Month Sampling Events Highest Concentration None Detects

June 2016 10 4.97 ug.m3 2 July 2016 10 44.3 ug/m3 3 August 2016 10 38.8 ug/m3 1 Sep. 2016 10 34.7 ug/m3 1 Oct. 2016 11 42.4 ug/m3 2 Nov. 2016 10 66.4 ug/m3 1 Dec. 2016 10 39.9 ug/m3 2 Jan. 2017 10 75.1 ug/m3 5 Feb. 2017 10 8.92 ug/m3 4 March 2017 10 11.9 ug/m3 2 April 2017 10 51.1 ug/m3 1 May 2017 10 4.64 ug/m3 7 June 2017 10 11.8 ug/m3 2 July 2017 11 10.2 ug/m3 4 August 2017 10 26.2 ug/m3 1 Sep. 2017 10 22.3 ug/m3 0 Oct. 2017 10 23.2 ug/m3 0 Nov. 2017 10 151.0 ug/m3 0 Dec. 2017` 10 12.3 ug/m3 1 Jan. 2018 7 25.4 ug/m3 2 Feb. 2018 9 32.4ug/m3 0 March 2018 10 5.55 ug/m3 2 April 2018 10 8.96 ug/m3 5 May 2018 11 2.22 ug/m3 2 June 2018 10 2.04 ug/m3 5 July 2018 10 1.32 ug/m3 4 August 2018 10 3.42 ug/m3 2 September 2018 10 9.32 ug/m3 0 October 2018 11 57.7 ug/m3 1 November 2018 10 6.89 ug/m3 3 December 2018 10 24.9 ug/m3 3 January 2019 10 11.8 ug/m3 4 February 2019 10 4.24 ug/m3 3 March 2019 4 10.0 ug/m3 2 April 2019 5 2.58 ug/m3 2 May 2019 5 0.461 ug/m3 3 June 2019 5 5.15 ug/m3 1 8

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] Based on the EPA Air Monitoring data at the Fifth Ward Elementary School location, 71% of the sampling events had detectable levels of Chloroprene in the air and 29% of the times Chloroprene was not detected in the air at the school. When the wind was blowing across the Denka facility in the opposite direction of the school, the school sampling location was none detect for Chloroprene. Five months during the EPA air sampling program, no None Detection of Chloroprene was detected, thus detectable levels of Chloroprene were present during the entire months of sampling- Sep. through Nov. 2017, February 2018 and September 2018.

The highest Chloroprene air concentrations at the Fifth Ward School:

2016 66.4 ug/m3 2017 151ug/m3 2018 57.7 ug/m3 These values range from 288.5 to 755 times the EPA 0.2 ug/m3 concentration.

Letter from the St. John the Baptist Parish School Board to DEQ On March 12, 2019, the St. John the Baptist Parish School Board wrote a letter to Dr. Chuck C. Brown, Secretary of the Louisiana Department of Environmental Quality. The letter was written on behalf of the entire School Board (copy attached). The letter summarized the information released by DEQ, La Department of Health, Denka/DuPont, Concerned Citizens of St. of John and the EPA concerning Chloroprene emissions and health consequences. The School Board requested that DEQ do what is necessary to compel Denka and DuPont to immediately take whatever action is necessary to reduce the emissions of Chloroprene from their chemical plant to at or below the EPA’s upper limit of acceptability, 0.2 ug/m3.

The letter stated “You (DEQ) have the authority to close the plant if that is the only way for our children to breathe clean air.” 9

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] Strategic Toxic Air Reduction (STAR) Program in Kentucky In 2002, EPA Region 4 determined that Jefferson County, Kentucky had the highest risk in the Southeast region of the US, due to toxic/hazardous air emissions. EPA Region 4 ranked Jefferson County first out of 736 counties in the southeast for health risks from hazardous air pollutants.

The Mayor of Louisville proposed the STAR program, that would target pollution cuts at industrial facilities with air emissions that posed unacceptable health risks, on September 1, 2004.

On June 21, 2005, the STAR Program was approved unanimously by the Louisville Metro Air Pollution Control Board. The primary focus of the STAR Program was reducing levels of air emissions for 18 toxic chemicals proven to exceed the air health risk goals. As a result of the air emissions reduction program requirements of the STAR Program involving Chloroprene, the DuPont Dow Elastomer , Rubbertown Neoprene manufacturing facility in Louisville closed in 2008 and moved the Neoprene production to LaPlace/Reserve, Louisiana. Examples of Reductions in Air Emissions at Industrial Facilities in Rubbertown as a Result of the STAR Program 1,3-Butadiene – Probable Human Carcinogen American Synthetic Rubber Corp. 2000 Fugitive Air Emissions 10,000 pounds 2016 Fugitive Air Emissions 3,723.2 pounds 2000 Stack Air Emissions 140,000 pounds 2016 Stack Air Emissions 3,273.1 pounds

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] 1,3-Butadiene – Probable Human Carcinogen Zeon Chemical 2000 Fugitive Air Emissions 178 pounds 2016 Fugitive Air Emissions 44 pounds 2000 Stack Air Emissions 24,158 pounds 2016 Stack Air Emissions 1,379 pounds Denka 2016 Fugitive Air Emissions 909 pounds 2016 Stack Air Emissions 3,305 pounds

Chloroprene – Possible Human Carcinogen, now a Likely Human Carcinogen DuPont Louisville 2000 Fugitive Air Emissions 46,741 pounds 2016 Fugitive Air Emissions 0 pounds 2000 Stack Air Emissions 532,629 pounds 2016 Stack Air Emissions 0 pounds Denka 2016 Fugitive Air Emissions 10,520 pounds 2016 Stack Air Emissions 228,087 pounds

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] Toluene - Reproductive and Developmental Toxin Rohm & Hass 2000 Fugitive Air Emissions 7,600 pounds 2016 Fugitive Air Emissions 700 pounds 2000 Stack Air Emissions 166,000 pounds 2016 Stack Air Emissions 7,500 pounds Denka 2016 Fugitive Air Emissions 3,410 pounds 2016 Stack Air Emissions 24,925 pounds

National Air Toxics Assessment for Chloroprene (0.2 ug/m3)

December 2015 –EPA released the 2011 National Air Toxics Assessment (NATA). NATA classified Chloroprene as a likely human carcinogen and established the log-term cancer based comparison level of 100 in 1 million cancer risk comparison level as 0.2 ug/m3 for Chloroprene.

NATA estimated higher than expected levels of Chloroprene in the community of LaPlace, Louisiana. NATA/EPA identified the DuPont/Denka facility as creating the greatest offsite risk of cancer of any manufacturing facility in the US. August 2016 – Denka requested a reconsideration of the EPA/IRIS/ NATA Chloroprene assessment.

Ever since the EPA/DEQ meeting in Reserve on July 7, 2016, Denka has publicly stated they did not agree with the Chloroprene 0.2 ug/m3 and were challenging the 0.2 ug/m3.

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] This request for reconsideration was submitted when only preliminary ambient air monitoring data was available from EPA and La DEQ. The EPA National Center for Environmental Assessment (NCEA) scientists who prepared the 2010 IRIS Assessment declined Denka’s August 2016 request to reconsider the agency’s Chloroprene research methodology and conclusions.

June 26, 2017 Denka Requested the EPA to Withdraw, Suspend and Correct (Review and Revise) the IRIS Chloroprene 0.2 ug/m3 June 26, 2017, Liskow and Lewis on behalf of Denka wrote a letter to the Environmental Protection Agency requesting correction, suspension and review and revision of the Integrated Risk Information System (IRIS) Toxicological Review of Chloroprene.

On the same date, June 26, 2017, Koki Tabuchi, President and Chief Executive Officer of Denka Performance Elastomer, LLC wrote a letter to Scott Pruitt the Administrator of EPA requesting the withdrawal and correction of the IRIS Review of Chloroprene. In the request by Liskow and Lewis the following were presented: -The human inhalation unit risk should be withdrawn pending further IRIS review. -The classification of Chloroprene as a likely human carcinogen should instead be classified as chemical for which there is evidence only suggestive of human carcinogenicity. -The reference concentration for non-cancer inhalation exposure risks should be withdrawn pending further IRIS review.

The request were based on Denka and Denka’s consultants indicating EPA used flawed determinations concerning risk, good science not being applied, overly conservative calculations applied, flawed science being used, erroneous information and other reasons. 14

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] Denka stated based on Inhalation Unit Risk (IUR) and the Denka facility emission characteristics, the National Air Toxics Assessment (NATA) study erroneously identified Denka’s facility as associated with the highest offsite cancer risks of any chemical facility in the United States. Denka’s Inability to Meet the 0.2 ug/m3 Target Ambient Air Concentration -One of the numerous most interesting topics in the two letters were the following Denka statements: Even though Denka is installing the most advanced air pollution controls available, it will still not be able to meet the stringent 0.2 ug/m3 target (Koki Tabuchi letter).

Since acquiring the facility, Denka has committed to spend approximately $18 million on pollution controls in order to reduce Chloroprene emissions by approximately 85% below the facility’s 2014 emissions. However, theses dramatic emission reductions may not be sufficient to satisfy EPA emission reduction requirements based on the erroneous Inhalation Unit Risk and the emission profile of the facility (Liskow & Lewis letter on behalf of Denka). Denka’s state-of-the-art emission reduction projects technologically cannot achieve this extraordinarily low ambient target (LIskow & Lewis letter on behalf of Denka). Denka is installing state-of-the-art emission reduction devices at a capital cost of approximately $18 million to decrease its chloroprene emissions. However, even these significant measures will not be sufficient to meet the 0.2 ug/m3 ambient target, placing Denka’s future viability at risk (Liskow & Lewis letter on behalf of Denka). Even though Denka is installing the most advanced air pollution controls available, Denka still will not be able to meet the stringent 0.2 ug/m3 target (Liskow & Lewis letter on behalf of Denka).

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] September 8, 2017- Objections to Request for Correction, On September 8, 2017, on behalf of a group of concerned residents and leaders in a community which continues to be adversely affected by the harmful contaminants emitted by Denka in the area surrounding its chemical plant in LaPlace, LA, Objections to Denka Performance Elastomer LLC Request for Corrections was submitted to the Environmental Protection Agency. The Objections were prepared by two Ph.D.’s and a Medical Doctor. EPA’s Response to The Advocate’s request for comments in Relation to Denka’s Request for Correction – During the EPA’s Review Stage EPA takes issue with the conclusion that the science is shaky. The predictions about Chloroprene’s health effects are “based on very strong scientific studies.” The EPA’s conclusions “underwent very extensive review” by experts within the agency and independent expert peer reviewers. EPA’s Response to Denka’s June 26, 2017, Request for Correction

On January 25, 2018, EPA responded to Denka’s Request for Correction in a letter to Liskow & Lewis representing Denka Performance Elastomer.

The EPA received the Denka Performance Elastomer Request for Correction in a letter received by the EPA on June 26, 2017. The Denka Request for Correction requests the IRIS Chloroprene assessment be corrected in three ways: 1. The EPA-derived inhalation unit risk be replaced with a value derived by Rambol Environ or withdrawn.

2. The EPA cancer classification of Chloroprene as a “likely” human carcinogen be classified instead as a “suggestive” human carcinogen.

3. The EPA derived Reference Concentration be withdrawn pending further IRIS review. 16

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] The Request for Correction letter indicates, as an alternative, that the EPA immediately withdraw the IRIS IUR and RfC values pending further review.

Conclusion of EPA Letter of January 25, 2018 The EPA, after careful review of the Request for Correction submitted by Denka, has concluded that the underlying information and conclusions presented in the Toxicological Review of Chloroprene In Support of Summary Information of the Integrated Risk Information System (IRIS) are consistent with the EPA’s Information Quality Guidelines.

The denial letter also contains Attachment 1, US EPA Response to the Denka Performance Elastomer Request for Corrections of the Toxicological Review of Chloroprene in Support of Summary Information on the Integrated Risk Information System (IRIS) (9 pages) and Attachment 2 Systematic Review of Chloroprene Studies Published Since 2010 IRIS Assessment to Support Consideration of Denka Request for Correction (47 pages).

National Academy of Sciences IRIS Meeting

A National Academy of Sciences IRIS (Integrated Risk Information System) meeting was held on February 1 and 2, 2018, to review the IRIS program recent progress. Sharon Lerner of the Intercept covered the meeting. A former EPA regional administrator stated “The attacks on IRIS have reached a new level over the past year. The program that assesses the likelihood that various chemicals cause cancer and other diseases is facing some of the most intense and sustained pressures in the history of this agency.” According to the article, “IRIS had to recently revisit one completed assessment. The chemical in question, Chloroprene, has been polluting the air of a community in Louisiana for decades. Because of a 2010 IRIS 17

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] evaluation of Chloroprene, the people of St. John the Baptist, which is just across a fence from a factory that emits Chloroprene, learned that they had by far the highest risk of cancer in the country from air pollution.”

Rambo Environ, a scientific consulting company that has been paid by both Denka and DuPont, asked IRIS to review its evaluation of Chloroprene. The week before the NAS meeting, IRIS denied the request to tailor the evaluation of the chemical to its manufacturers liking. The EPA’s response included detailed explanation of the scientific evidence supporting their denial and 36-page review of Chloroprene studies that have come out since the initial evaluation.

According to an EPA official who worked on the assessment, “the response ate up considerable staff time. We killed ourselves. But it was our firm response that you can’t change the science just because you don’t like the answers.”

July 23, 2018-On behalf of Denka, Robert E. Holden submitted a third request for reconsideration to the Environmental Protection Agency. DEQ Letter to EPA Concerning the Denka Chloroprene Request for Corrections – December 17, 2018 On December 17, 2018, Chuck Carr Brown of DEQ sent a letter to EPA concerning the Denka request for corrections. The letter stated “the LDEQ has been in communication with the US EPA, Office of Environmental Information and Office of Research and Development concerning the re-evaluation of the chloroprene Inhalation Unit Risk (IUR) using the physiologically-based pharmacokinetic (PBPK) model. As this issue is of great importance to the State of Louisiana, LDEQ appreciated EPA’s efforts and looks forward to working with EPA to plan an appropriate path forward as soon as this process has been completed.”

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] February 12 , 2019 letter from EPA to Denka On February 21, 2019, EPA send an email to Chuck Carr Brown stating attached is the latest letter to Denka regarding their Request for Reconsideration. The letter from EPA to Denka was dated February 12, 2019 and was from Vaughn Noga, the Deputy Assistant Administrator for Environmental Information and Chief Information Officer of EPA in Washington, DC. The letter was addressed to Mr. Patrick A. Walsh of Denka Performance Elastomer LLC. The letter stated, “The US EPA’s interim response, issued on November 1, 2018, requested that any additional information supporting your request be submitted to EPA by February 1, 2019. This response acknowledges EPA’s receipt of the email from Robert Holden that was submitted on DPE’s behalf on February 1, 2019, containing information in support of your request. If DPE wishes to submit any additional information relevant to this RFR, it should be submitted no later than May 1, 2019. In accordance with EPA’s Information Quality Guidelines (IQG), EPA will review and assess this information and convene an IQG Executive Panel to reconsider EPA’s response to your original request for correction. Under EPA’s IQG, this Executive Panel makes the final decision on the RFR. EPA will provide DPE with a status update on this RFR by June 7, 2019, which is 90 business days from the Agency’s receipt of DPE’s supplemental information on February 1, 2019. ”

June 12, 2019 Stakeholder Meeting, Chloroprene Request for Reconsideration (follow-up), Research Triangle Park, NC. Attendees

National Center for Environmental Assessment (NCEA)/Office of Research and Development (ORD)/Environmental Protection Agency (EPA) – 13 individuals

Office of Research and Development (ORD)/EPA – 1 individual Office of Air and Radiation (OAR)/Office of Air Quality Planning and Standards (OAQPS)/EPA - 2 individuals

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] Office of Mission Support (OMS)/EPA – 1 individual Region 6 EPA – 1 individual LA Department of Environmental Quality - 4 individuals

Ramboll – 5 individuals Cardno ChemRisk – 1 individual Andersen ToxConsulting – 1 individual

Denka – 1 individual

The meeting was held to provide update information on the Physiologically Based Pharmacokinetic Modeling (PBPK) model being developed by Ramboll for Denka dealing with Chloroprene. Ramboll and EPA both provided presentations. EPA focused on their Quality Assurance process of the PGPK model before proceeding with decisions regarding the Request for Reconsideration and the Chloroprene IRIS assessment. EPA suggested the Request for Reconsideration could potentially be closed or withdrawn and potentially revisited as a new Request for Correction or Request for Reconsideration once the model is ready. Denka asked if EPA would remove the 2010 IRIS assessment or its IUR (Inhalation Unit Risk) value only based on the outcome of discussions. EPA stated the IRIS assessment will not be changed or removed unless science presented since the Request for correction necessitated reassessment. July 17, 2019 On July 17, 2019, the EPA Deputy Assistant Administrator for Environmental Information and chief Information Officer, Vaughn Noga, send a letter to Patrick Walsh of Denka regarding Request for Reconsideration concerning Toxicological Review of Chloroprene.

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] The letter acknowledged receipt of supplemental information concerning the development of the PBPK Model on May 31, 2019 and presentation of information at the agency meeting in Research Triangle Park on June 12, 2019. The letter further stated, “at this juncture, I am pausing reconsideration of your request until after the peer review results regarding your submitted PBPK model have been fully assessed. EPA estimates it will take a minimum of nine months to complete the IRIS quality assurance and peer review process. In accordance with EPA’s Information Quality Guidelines (IQG’s), EPA will then review and assess the results of these reviews and convene an IQG Executive Panel to reconsider EPA’s response to your original request for correction. Under EPA’s IQGs, this Executive Panel will make the final decision on the Request for Reconsideration. Alternatively, Denka may withdraw this Request for Reconsideration until after the peer review process has been completed, then resubmit it again at a later time. If you wish to withdraw the Request for Reconsideration, please let us know. EPA will plan to provide Denka with a status update on this Request for Reconsideration by December 30, 2019.” Earthjustice I have been working since early 2018 with Emma Cheuse, Staff Attorney with Earthjustice in Washington, DC on the Chloroprene situation, IRIS and NATA. The aim has been to meet with the EPA staff of IRIS and NATA. On August 2, 2019, Earthjustice on behalf of Concerned Citizens of St. John, Louisiana Environmental Action Network and other organizations, sent a letter to John Vandenberg, Director of Research, National Center for Environmental Assessment , EPA in Research Triangle Park. NC requesting a meeting in Opposition to Denka’s Request for Reconsideration of EPA’s Toxicological Review of Chloroprene.

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] On August 7, 2019, John Vandenberg responded to the Earthjustice request for an opportunity to meet to discuss the Request for Reconsideration of EPA’s Toxicological Review of Chloroprene. EPA stated they would look forward to arranging a time to meet with Earthjustice and their colleagues. Currently available times for the meeting are being compared to meet available times for all involved. It is anticipated the meeting or meetings will be held in September 2019 or later in Washington, DC and/or Research Triangle Park, NC.

Ethylene Oxide August 22, 2018 EPA’s 2014 National Air Toxics Assessment (NATA) dealing with Ethylene Oxide was released. Louisiana has 13 facilities releasing Ethylene Oxide into the air. The number two ranking air emissions facility of Ethylene Oxide in the US is Union Carbide in Hahnville, St. Charles Parish. St. John the Baptist has one facility, Evonik Materials, releasing Ethylene Oxide. As a result of Ethylene Oxide air emissions from Union Carbide and Evonik Materials, all 11 census tracts in St. John the Baptist Parish has cancer risks over 100 per one million individuals and are high enough to trigger the EPA’s concern. Of the 13 industrial facilities releasing Ethylene Oxide into the air in Louisiana, 11 are along the Mississippi River industrial corridor. Union Carbide in St. Charles Parish. Evonik Materials in St. John the Baptist Parish. BASF Corp, Shell Chemical and Rubicon in Ascension Parish. Dow Chemical, BCP Ingredients, Taminco US, SE Tylose, INEOS Oxide and Axiall in Iberville Parish. Ethylene Oxide has been on the federal list of carcinogens since 1985. In December 2016, EPA released a reassessment linking it more conclusively to breast and blood cancer.

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] Together Louisiana and Texas have the top seven industrial facilities releasing the largest quantities of Ethylene Oxide into the air in the US. Texas Cancer Risk Due to Ethylene Oxide Air Emissions from Industrial Facilities In Texas, 25 industrial facilities release Ethylene Oxide into the air. The industrial facility with the largest quantity of Ethylene Oxide released into the air in the US is Huntsman Petrochemical in Port Neches, Jefferson County, Texas. Huntsman releases 77,248 pounds of Ethylene Oxide per year into the air. The highest cancer risk in the census tracts of Jefferson County for Ethylene Oxide is 232.80 per one million individuals. Clustered around the census tract on which Huntsman is located, the cancer risk ranges from 105.92 to193.75 per one million individuals.

The facility with the third highest Ethylene Oxide air emissions in the US is the Eastman Chemical facility in Longview, Gregg County, Texas. Eastman releases 9,608 pounds of Ethylene Oxide per year into the air. The highest cancer risk in Gregg County from Ethylene Oxide is 49.11 per one million individuals. Clustered around the census tract of the Eastman facility, the cancer risk ranges from 26.55 to 36.24 per one million individuals. The facility with the six largest Ethylene Oxide air releases in the US is Midwest Sterilization Corp. in Lorado, Webb County, Texas. The facility releases 14,731 pounds of Ethylene Oxide per year. The largest cancer risks in the area of the Midwest facility is 102.33 to 119.67 per one million individuals.

The facility with the seventh largest Ethylene Oxide air releases in the US is Union Carbide Corp. in Seadrift, Calhoun County, Texas. Union Carbide releases 14,391 pounds of Ethylene Oxide per year. Formosa Plastics is located in Point Comfort in Calhoun County. Formosa releases 487 pounds of Ethylene Oxide per year into the air. The largest cancer risk in Calhoun County is 20.32 per one million individuals.

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] Harris County, Texas has a total of 12 industrial facilities releasing Ethylene Oxide into the air. Nine of the industrial facilities are located in Pasadena. The largest census tract cancer risk in Harris County range from 119.09 to 311.63 per one million individuals. Conroe in Montgomery County has the Huntsman Petrochemical facility that releases 5,233 pounds of Ethylene Oxide into the air on a yearly basis. The county has the highest cancer risk due to Ethylene Oxide, 73.64 per one million individuals in one census tract. The remaining seven industrial facilities in Texas releasing Ethylene Oxide, do not have elevated cancer risk in the area census tracts in which the facilities are located. The facilities consist of two facilities in Freeport and one each in Port Arthur, San Angelo, Grand Prairie, Fresno, and Dayton, Texas. Request for Corrections – Ethylene Oxide September 20, 2018-The American Chemical Council submitted a Request for Correction to EPA concerning the 2014 NATA Ethylene Oxide determination. The American Chemistry Council represents producers and users of Ethylene Oxide. The American Chemistry Council seeks the correction of Ethylene Oxide information disseminated in the 2014 update to the National Air Toxics Assessment released on August 22, 2018. The ACC states the 2014 National Air Toxics Assessment risk estimates for Ethylene Oxide should be withdrawn and corrected scientifically to support risk values. Texas Commission on Environmental Quality

In June 2019 the Texas Commission on Environmental Quality (TCEQ) released a scientific assessment that justified an increase in the amount of Ethylene Oxide that petrochemical plants can legally emit. This is the first step toward increasing the amount of legally acceptable Ethylene Oxide emissions to1,000 times the current rate. Ethylene Oxide is a known carcinogen and is linked to lymphoma, leukemia and breast cancer.

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected] TCEQ asserts that the EPA models overestimate the number of cancer deaths that can be linked to Ethylene Oxide. EPA is currently reviewing the federal limit for Ethylene Oxide emissions under the Clean Air Act. TCEQ’s assessment could have an impact on the EPA’s review, since the EPA can rely on scientific reports produced by state environmental agencies.

Natural Resources Defense Council (NRDC) Jennifer Sass of NRDC On July 22, 2019 Jennifer Sass of NRDC contacted Kristina Thayer, Director of the Integrated Risk Information System (IRIS), National Center for Environmental Assessment, Office of Research and Development of EPA to set up a stakeholder briefing for public interest groups on the Texas Commission on Environmental Quality (TCEQ) critique of the IRIS Ethylene Oxide assessment. The briefing was set for August 19, 2019 and will include representatives of NRDC, Earthjustice, Environmental Defense Fund and Louisiana Environmental Action Network (LEAN).

Tel:(225) 928-1315 Fax: (225) 922-9247 Mailing: 162 Croydon Ave. Baton Rouge, LA 70806 Web: leanweb.org Email: [email protected]