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Letter from Charles Waterman, WTI Attorney,
to Nancy Ellen Zuman, U.S. EPA

         Documents confirm:
  • The WTI incinerator is now owned and operated by a 1986 created affiliate corporation of a Swiss corporation: Von Roll (Ohio), Inc.
  • Ownership and operational control have changed without the mandatory EPA notification and preapproval.

    New partners are:
  • Energy Technology Company;
  • Waste Technologies Incorporated;
  • Environmental Elements Ohio (Inc.); and
  • Von Roll (Ohio), Inc.

Charles Waterman, WTI attorney, understands the consequences of WTI's actions involving the partnership. In his Jul 23, 1992 response to EPA's 3007 request, Mr. Waterman writes:

"In fact, but for the fact that merging the various partners would have had the undesirable effect of causing WTI to cease to exist under general partnership law (thereby leaving the RCRA permit with no "owner"), Von Roll America, Inc. might well have done just that to avoid the costs and administrative headaches of maintaining four separate partners."

Mr. Waterman admits that the reason for maintaining the four separate corporations at substantial cost was so that the "partnership" could be maintained. Otherwise, there is no permit holder. The EPA admitted on Sep 8, 1992 that Von Roll America, Inc. is the owner, and WTI must request a modification to reflect the change in ownership.

This confirms the WTI partnership no longer exists, and there is no permit holder and the permit for WTI no longer exists.