OFFICE OF THE ATTORNEY GENERAL S'l?Xl?li Lisa Madigun \l September 17, 2018 Sent via email Mr. Edward K. Nam, Director, Air and Radiation Division United States Environmental Protection Agency, Region 77 w. Jackson Blvd., MS A-18J Chicago, IL 60604 Re: Sterigenics International, lnE/Wi/lowbrook, IL Dear Mr. Nam: Thank you again for meeting with us on Wednesday, September 12, 2018, and providing information on the work that US. EPA and the Agency for Toxic Substances and Disease Registry (ATSDR) have and continue to perform related to the ethylene oxide emissions from the Sterigenics facility in Willowbrook, Illinois. We appreciate your work on this important matter. As you know, we have reviewed the Letter Health Consultation regarding Sterigenics, prepared by the ATSDR dated August 21, 2018, along with numerous other documents related to this issue. Based on that Letter Health Consultation, it is clear that the requirements for controlling emissions contained in the Clean Air Act Permit Program (CAAPP) Permit No. 95120085, issued to Sterigenics by the IEPA on June 8, 2015 (?Operating Permit?), are alarmingly inadequate and not protective of the community around the facility. It remains to be seen whether recent modifications to the facility?s emission control system pursuant to the Construction Permit issued to Sterigenics by the Illinois Environmental Protection Agency on June 26, 2018, will mitigate the risk identified in the Letter Health Consultation. By this letter, we make the following requests. . First, please provide your timetable for implementing the secOnd recommendation made by ATSDR in the Letter Health Consultation, which is: 501) South Street. Spring?eld. Illinois 02700 (ll7l 783-2000 (877) 844-3401 Fax: (217) 783-7040 Hill West Randolph (313) 814-3000 0 ?lvl'Y: (Sill!) 964-30]; 0 Smith l?nivmsirv \?uiri- ll)? . Mr. Edward K. Nam September 17, 2018 Page 2 ATSDR recommends that US. EPA work with the Sterigenics facility to initiate long-term air monitoring as soon as possible to measure ambient air levels of Ongoing air monitoring can demonstrate the effectiveness of actions taken by the company to reduce emissions andsubsequent exposures in the community. The Illinois Attorney General's Office agrees with ATSDR that ambient air monitoring data is a critical piece of information necessary to evaluate ongoing impacts to the community, due to the fact that the company recently installed equipment to control previously uncontrolled emissions. This ambient air monitoring should be expedited, because the modifications to control emissions from the back vents ofthe sterilization chambers at the facility reportedly have been in place since July 27, 2018. The neighboring community needs to know if the level of measured in the ambient air by US EPA in May, 2018, has abated. Second, it is imperative that US. EPA work with ATSDR to immediately provide relevant information to the public to assist the community in understanding the current risks posed by the monitored levels of near the facility. US EPA prepared public outreach documents, and, in fact, posted them on its website for a short period of time, only to pull them offline. It is typical for US. EPA to publish a Fact Sheet in this type of situation and we ask that US. EPA immediately publish such a Fact Sheet and FAQs on the Sterigenics webpage that currently exists on US. website. The shared information can and should be updated as matters develop. The void left by US. EPA providing NO community relations information is causing significant anxiety to hundreds, if not thousands, of Illinois residents concerned about their health and that of their children and loved ones. US. EPA should act immediately to address these real concerns. Please let us know as soon as possible whether and when US EPA anticipates accomplishing the two issues identified herein. Very truly yours, Matthew]. Dunn, Chief Environmental Enforcement/ Asbestos Litigation Division Illinois Attorney General?s Office 500 South Second Street Springfield, IL 62706 (312) 814-2550