23m Gamay, 9m. P. O. Box 1242, Station A EAST LIVERPOOL, OHIO 43920 Mr. Bob Perciasepe July 12, 2013 Acting Administrator and Deputy Administrator US Environmental Protection Agency 1200 Avenue, NW. Mail Code 4101M. Washington, DC 20460 Dear Administrator Perciasepe: I am writing on behalf of Save Our County (SOC) and the residents of East Liverpool, Ohio. In March of this year, the USEPA Region 5 signed an Administrative Consent Order with Industries Ohio (PPG) under Sections 113(a)(3) and 114(a)(l) of the Clean Air Act (see attached). As you may know, PPG owns and operates a hazardous waste incinerator in Circleville, Ohio. Under the Order, by no later than July 1 2013, PPG will either notify EPA and Ohio EPA that it has initiated closure of its hazardous waste incinerator or will submit a compliance plan to EPA that outlines the steps that PPG will take to bring into compliance with the dioxin/furan emission standard of the National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors (HWC MACT) at 40 CPR. Part 63, Subpart Under the Order, PPG must conduct a comprehensive performance test before the end of March 2014. We applaud the agency for taking this step to enforce its regulations and protect the health of the residents of this community. We wonder, however, why similar action has not been taken with regards to the Heritage-WTI (HWTI) hazardous waste incinerator in East Liverpool. We compared the dioxin air stack releases using the agency?s Toxic Release Inventory (TRI) data base from 2011 for these two facilities. This is what we found: PPG Ohio 0.00497826 grams HWTI 0.05 grams According to this data, HWTI released 10 times as much dioxin into the air as did the PPG facility. This is not speci?c emissions testing (we are trying to get this data via a FOIA request); however, it is hard to believe that HWTI can release 10 time as much dioxin as PPG who is in violation of the National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors, yet HWTI has not been cited for being in violation of these same standards. EPA Region 5 has issued an order to PPG to shut down because of its dioxin air releaSes, yet HWTI has received no notice of any violation of its dioxin air releases. Over the past 5 years, PPG was cited for 9 informal enforcement actions and 5 formal enforcement actions and was ?ned $175,000 in 2009 and WW 4M 24 elem 3mm $155,793 in 2012, both due to high dioxin/furan emission tests. 0n the other hand, has been cited for 23 informal enforcement actions and 3 formal enforcement actions over the past 5 years and has been ?ned only $50,100, also due to high dioxin/furan emission tests. We are concerned that EPA Region 5 is giving preferential treatment to HWTI in terms of how the agency is enforcing the regulations of the Clean Air Act (0AA). Wewant meageney toenforce the rules and regulations of the CAA as well as other relevant regulations equally to all companies, including HWTI. How can HWTI continue to operate when it releases more than 10 times as much dioxin to the air as PPG which was ordered to cease operating due its dioxin emissions? Can you tell us whether dioxinffuran emission concentration testing, similar to what was done at the PPG facility, has also been conducted at the HWTI facility? If so, can you please provide the resuits of this testing for the past 3 years. If this testing has not been done, can you please provide an explanation as to why this testing was not done at'HWTl? Using the TRI data for the year 2011, we see that PPG released a total 22,121 pounds (lbs) of chemicals from its facility in Circleville. For this same year, HWTI released a total of 627,084 lbs. The total releases (to air and water) and transfers from the PPG facility were 71,163 compared to 1,040,794 from HWTI. And lastly, PPG managed 14,218,148 of waste, about half the waste managed at the HWTI facility which was 29,878,317 lbs. Even though HWTI is releasing substantially much more toxic chemicals from its facility that is being released by PPG, PPG is being held accountable while it appears that HWTI is not. Can you please explain this apparent contradiction? We hope you will look into the issues we have raised about emissions in relation to PPG and respond to the questions we have raised in this letter. As citizens of the state of Ohio, we expect the USEPA to enforce its laws equally and to take whatever steps are necessary to protect the health of the citizens of this state. Sincerely, . WM e/?quu. Alonzo President cc: US EPA Region 5 Administrator