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Recent Activity
Early Action Reduction Plan:
Overview
South Coast AQMD has an ongoing investigation into emissions of EtO from facilities within our jurisdiction. For more information on the overall initiative please visit: www.aqmd.gov/eto
Sterigenics conducts sterilization of medical equipment using a gas called Ethylene Oxide (EtO) and operates in Vernon within two buildings between 49th St. and 50th St. on Gifford Ave in an industrial area. The nearest residential area is about 500 feet away, and the nearest school is 1700 feet away.
Based on sampling around the facilities, high levels of EtO have been discovered, and South Coast AQMD is taking several actions to identify emission sources and reduce emissions as quickly as possible including:
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Air monitoring efforts at the facilities and near the surrounding community.
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Proposition 65 Notice
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A complete investigation into the facilities’ equipment and compliance with South Coast AQMD rules, regulations and permit requirements.
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Evaluation of immediate actions to be taken by the facilities to reduce leaks or fugitive emissions, including leak and source testing.
More Information
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For more information, please contact the South Coast AQMD Public Advisor at publicadvisor@aqmd.gov.
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To receive notifications related to the Sterigenics Vernon facilities, please fill out the form at www.aqmd.gov/sign-up.
Comments from Local Officials & Community Groups
Response Letters to Local Officials & Community Groups
South Coast AQMD has provided informational letters to local officials to address concerns regarding Sterigenics:
Ongoing Investigation
During a visit to the Sterigenics buildings in Vernon on March 31st, South Coast AQMD detected odors near various equipment. Initial air samples were taken directly outside the facilities, and results showed elevated levels of EtO, prompting more comprehensive air monitoring and further investigation.
South Coast AQMD is working with the operator on immediate and near-term actions. A source test was required and has been conducted on the wet scrubber at the 50th Street building, a team of South Coast AQMD engineers and inspectors conducted an assessment to identify potential emission sources that are contributing to the elevated levels, and to identify measures to further reduce EtO emissions.
South Coast AQMD inspectors issued a Notice of Violation to the Sterigenics 50th Street building on May 5th for failure to operate the air pollution control system in accordance with the facility’s permit; for failure to maintain the air pollution control system in good operating condition; and for failure to equip control equipment with a pressure gauge and a pH meter, both of which were required in the permit. Inspectors also issued Notices to Comply requiring the facility to provide operating records. South Coast AQMD continues to conduct a full investigation and evaluation of all equipment to ensure that the Vernon facilities are adhering to permit conditions, meeting rule requirements and using proper emissions control equipment.
On June 30, additional Notices of Violation were issued to Sterigenics for installing control equipment at both buildings without first obtaining air quality permits. For the 50th Street facility, during an on-site visit on June 17, inspectors also observed equipment operating in violation of permit conditions.
Notices of Violation:
Proposed Order for Abatement Findings and Decision:
AB 2588 Air Toxic “Hot Spots” program
On June 7, the Sterigenics facility (49th and 50th Street buildings) was designated as a Potentially High Risk Level Facility. A facility is designated a Potentially High Risk Level Facility when emissions data show either a potential to exceed or that emissions have already exceeded cancer risk thresholds (greater than 100 chances in a million). As a Potentially High Risk Level Facility, Sterigenics was required to develop an Early Action Reduction Plan that includes measures that can be taken immediately to reduce health risks. In addition, the facility was required to submit an air toxics emissions inventory report, conduct a Health Risk Assessment (HRA), and submit a Risk Reduction Plan (RRP). As of early March 2023, these documents have all been submitted by the facility. South Coast AQMD staff identified deficiencies and rejected the draft Air Toxics Inventory Report and is currently reviewing the HRA and RRP.
Early Action Reduction Plan
Curtailment
The approved Early Action Reduction Plan set a temporary threshold for EtO emissions from the facility of 17.5 parts per billion (ppb) over a 24-hour period (see below). This temporary threshold ensures that the facility does not reverse any emission reductions that have been achieved recently while more permanent engineering controls are put into place. If air monitoring results near the facility show one EtO value at 17.5 ppb or higher, the facility must initiate curtailment of its operations. Repeated exceedances of the threshold within a rolling 30-day period will result in a temporary shutdown of the facility.
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EtO Level ≥ 17.5 ppb
but <25 ppb
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Action
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EtO Level ≥ 25 ppb
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Action
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First Sample
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20% Curtailment of Operations
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First Sample
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50% Curtailment of Operations
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Second Sample
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50% Curtailment of Operations
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Second Sample
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100% Curtailment of Operation
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Third Sample
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100% Curtailment of Operations
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Curtailment begins after South Coast AQMD is notified of an exceedance of the threshold. Laboratory analysis can take many days to complete. Sterigenics must provide results for sites M1 andM3 (see figure 7 below) within 14 days of collecting the sample. Sterigenics must also provide sample data within three hours of receiving results from their laboratory analysis when levels are above curtailment thresholds.
Sterigenics may resume normal operations once data from the same monitor that triggered the curtailment shows EtO levels are below the thresholds set under the plan.
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Sterigenics Vernon Curtailment
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EtO Sample Level That Required Curtailment
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Curtailment Sample Date
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Monitor Location
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Action
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Curtailment
Start Date*
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EtO Sample to End Curtailment
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Date of Sample
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Curtailment
End Date
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20 ppb
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2/23/23
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Sterigenics Monitor M1
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20% Curtailment of Operations
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3/4/23
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1.8 ppb
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3/1/23
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3/7/23
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Air Monitoring Efforts
South Coast AQMD is conducting local air sampling to determine levels of EtO in the surrounding community and evaluate potential sources of emissions coming from the Sterigenics buildings. Individual grab samples (an air sample collected at one location at one point in time) were taken near the facilities (Figure 1), and two monitors were placed nearby on 50th Street and 49th Street (Figure 3) to collect 24-hour samples (Figure 4).
Grab samples were also collected near the surrounding community and closest school and a monitor has been placed in the community to collect 24-hour samples. The data collected so far shows levels of EtO in the community to be within background levels (Figure 2).
Additionally, mobile monitoring was conducted to collect data on volatile organic compounds (VOCs) around the facilities and the surrounding community. VOC signals associated with EtO were elevated near the facilities; however, levels in the community were within typical background levels.
Grab Samples
Figure 1. Map of grab samples. Concentrations are in parts per billion volume (ppbv).
Community Grab Samples
Figure 2. Map of community grab samples. Concentrations are in parts per billion volume (ppbv).
24-Hour Integrated Sample Locations
Figure 3. Map of 24-hour sampling locations.
This plot is interactive, individual data points can be viewed with a mouse hover. The view can be reset by selecting the circular arrows to the right of the plot.
Figure 4. 24-hour samples
24-hour Time-integrated Sample data (concentrations in ppbv)
*Discontinued sampling at Site 2
ND = Not Detected
Figure 5: 24-hour Time-integrated Sample data (concentations in ppbv)
Facility Air Monitoring
As part of the facility’s Early Action Reduction Plan the facility has installed two air monitors around the facility (see figure 6) and provides that data to South Coast AQMD.
Data from the air monitors operated by the facility can be found here. (PDF).
Ramboll Sampling Sites
Figure 6. Map of Early Action Reduction Plan
Health Impacts
South Coast AQMD is required to use methodologies developed by OEHHA in its health risk programs. Based on preliminary monitoring data, the primary concern is off-site worker exposure. This data indicates that workers at facilities adjacent to the Sterigenics facilities could be experiencing cancer risks as high as about 750 in a million, if they are or have been exposed for long periods (i.e., a 25-year worker exposure). This risk level is more than one and a half times higher than the average lifetime cancer risk throughout the region according to South Coast AQMD’s Multiple Air Toxics Exposure Study V. The preliminary air monitoring results also show that EtO levels and off-site worker cancer risk drops off substantially (about 50 times lower) a short distance away (about 150 feet), from the facility.
South Coast AQMD issued a Proposition 65 notice on May 5, 2022 notifying the Los Angeles County Board of Supervisors, the Los Angeles County Health Officer, and the City of Vernon Director of Health and Environmental Control of the illegal discharge likely to impact public health or safety.
South Coast AQMD has also notified the California Division of Occupational Safety and Health Administration (Cal/OSHA) of potential exposure to employees at the Vernon facilities. Cal/OSHA subsequently launched its own investigation and has visited the Sterigenics facility. Additionally, South Coast AQMD is working closely with the Los Angeles County Department of Public Health and is providing data to public health officials for additional risk assessment.
Permitting
Each Vernon facility is permitted for multiple EtO sterilization chambers, aeration rooms and associated air pollution control equipment. Products are loaded into sealed sterilization chambers where EtO is injected. The chamber is required to have equipment to capture the EtO gas and control 99.9% of emissions. When the sterilization cycle is complete the chamber is opened, and the chamber is vented through additional vents to control equipment called catalytic oxidizers. The catalytic oxidizer is required to further reduce EtO emissions by 95%. The products then off-gas in aeration rooms which are also vented to the catalytic oxidizers. On May 25, 2022, Sterigenics Vernon submitted four applications as a result of the NOVs issued for operating equipment without first obtaining a permit. On June 7, 2022, Sterigenics Vernon submitted five permit applications. Three of the applications are for the construction and installation of new control equipment and two applications are to update the buildings to a Permanent Total Enclosure. The facilities’ permits can be accessed through South Coast AQMD’s Facility Information Detail (F.I.N.D.) using the facility address or ID numbers (126191 and 126197).
Rulemaking
EtO sterilization and aeration facilities are subject to local, state, and federal regulations. South Coast AQMD Rule 1405 (PDF) - Control of Ethylene Oxide and Chlorofluorocarbon Emissions from Sterilization or Fumigation Processes reduces emissions of EtO from sterilization operations.
During South Coast AQMD's monitoring efforts at several commercial EtO sterilization facilities, the agency became aware of fugitive emissions from sources that were not previously known. South Coast AQMD’s investigation has identified that existing pollution controls will need to be upgraded and measures will be needed to reduce fugitive emissions. We are working on amending Rule 1405 to strengthen requirements to address fugitive emissions, as well as provisions to further reduce EtO emissions from operations at these facilities. The rulemaking process, including Working Group meetings are ongoing and open to the public. Upcoming meeting dates can be found at the Proposed Amended Rule 1405 page.
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