May 19, 2000
Robert Martin, Ombudsman
U.S. Environmental Protection Agency
Waterside Mall, Room SE 301
401 M Street SW
Washington, D.C. 20460
Dear Mr. Martin:
I am writing in response to your invitation for statements for the investigation of the East Liverpool WTI hazardous waste incinerator.
It is Ohio Citizen Action’s position that WTI should not have been issued a permit to operate, that its permit once issued should have been revoked, and that a renewal permit should not be issued for the facility because of the following issues that I am requesting you include in your investigation.
- Location: The facility’s proximity to the Ohio River, homes and East Elementary School, and the frequency of air inversions in the community.
- Accidents: The facility’s accident history and the potential for fires and accidents at the facility. WTI’s worst-case analysis under U.S. EPA’s Risk Management Plan requirements estimates a 3.9 mile endpoint for the area that could be affected by a toxic chemical spill. WTI estimates a 0.6 mile endpoint for a vapor cloud explosion of pentane, which could include East Elementary School and nearby homes. In addition, U.S. EPA’s risk assessment for the facility outlined 27 possible accident scenarios that could threaten the 400 children in East Elementary School.
- Violations: The facility’s history of ongoing and repeat violations of the terms and conditions of its permit and Ohio hazardous waste laws. In a letter to the facility on November 16, 1999, Ohio EPA director Christopher Jones wrote that, "Numerous and serious violations of the state’s hazardous waste laws and the terms and conditions of the permit have been discovered at Von Roll’s facility during each inspection conducted since 1996. Also, many of these violations are repeat violations." Ohio Citizen Action believes that past findings and orders and penalties issued by Ohio EPA have been insufficient to ensure the health and safety of the surrounding community. In addition, because WTI’s renewal permit application will not be acted on by Ohio EPA until 2001 at the earliest, citizens have had insufficient opportunity to challenge the facility’s continued operation.
I am submitting this statement via e-mail with hard copy to follow by fax and mail, and am providing printed and electronic copies to the service list.
Thank you for your consideration.
Jennifer O’Donnell, Akron Area Director
Ohio Citizen Action