Office of Public Affairs	Illinois Indiana

United States	Region 5	Michigan Minnesota

Environmental Protection	230 South Dearborn Street	Ohio Wisconsin

Agency	Chicago, Illinois 60604

A -q. Public Involvement Plan
Obnr\ Ohio Technology Corporation

Proposed Incineration Facility

April 1989 - Revised





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United States
Environmental Protection
Agency

Region 10
1200 Sixth Avenue
Seattle, WA 98101

Alaska

Idaho

Oregon

Washington

&EPA News Release

90-14

Contact: Dawnee Dahm

EPA Region 10
Hazardous Waste Program

442-2867

March 12, 1990

FOR IMMEDIATE RELEASE

EPA AND DEQ ANNOUNCE HAZARDOUS WASTE PERMIT FOR TEKTRONIX

A draft hazard waste permit has been issues for public comment
which would allow Tektronix to operate hazardous waste storage units, to
administer "post-closure" care to closed hazardous waste disposal units,
and to carry out corrective activities or the closed hazardous and solid
waste disposal units at its Beaverton facility.

The draft permit will be available for public review and comment
until April 23, 1990.

Tektronix manages hazardous waste generated as by-products of
manufacturing operations at its Beaverton facility and routinely manages
wastes from other Tektronix facilities.

The draft permit requires Tektronix to take corrective action for
tricholoethylene (TCE) contaminated groundwater at the facility and to
monitor and maintain I closed surface impoundments for a at least 30
years. The permit also sets out operational requirements for
Tektronix's hazardous waste storage units. These storage units include
tanks and containers.

Copies of the permit are available at the Oregon Department of
Environmental Quality, 811 S.W. Sixth Avenue, Portland and at the
Beaverton City Library, 12500 S.W. Allen Blvd.

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Public comments on the draft permit will be accepted until Apr
23, 1990. A public hearing will be held if enough interest is
expressed. Comments should be sent to:

Fred Bromfeld	Dawnee Dahm

DEQ	EPA Region 10, HW-112

811 S.W. Sixth Avenue	1200 Sixth Avenue

Portland, OR 97204	Seattle, Washington 98101


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PUBLIC INVOLVEMENT PLAN
OHIO TECHNOLOGY CORPORATION
PROPOSED INCINERATION FACILITY
NOVA, OHIO
APRIL 1989

EPA WORK ASSIGNMENT NUMBER 96-5Q00.0

Prepared for:	U.S. Environmental Protection Agency

Region V

230 South Dearborn Street
Chicago, Illinois 6064

Prepared by:	ICF Technology, Inc.

35 East Wacker Drive
Suite 800

Chicago, Illinois 60601

Associates Firm, REM IV Contract No. 68-01-7251


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TABLE OF CONTENTS

I.	Introduction 		1

II.	Description of the Proposed Facility		3

A.	Location and Description of Facility 		3

B.	Owner/Operator Information		4

C.	Regulatory Agencies		4

III.	Community Information		5

A.	Community Profile		5

B.	Public Involvement to Date 		6

1.	STOP IT 		6

2.	Citizens Against Pollution 		7

3.	The Amish Communities 		8

IV.	Community Concerns		9

V.	Objectives of the Public Involvement Program		13

VI.	Public Involvement Activities 		14

VII.	Implementation Schedule		18

Appendix A: Local Governments and Organizations Issuing Written Statements of

Opposition to the Proposed Incinerator		19

Appendix B: List of Contacts, Interested Parties, and Media		21

Appendix C: List of Information Repository Locations and Public Meeting Facilities		30


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I . INTRODUCTION

In 197 6, Congress passed the Resource Conservation and Recovery
Act (RCRA) to regulate the generation, treatment, storage, and disposal
of municipal and industrial solid wastes that are generated across the
country. The RCRA law requires that before a facility can treat, store,
or dispose of any hazardous waste, it must obtain a permit rom either
the United States Environmental Protection Agency (U.S. EPA) or an
authorized state government agency. 1 In addition to reviewing technical
information, federal and state agencies encourage public involvement
during the permitting process to ensure that residents understand
proposed plans for handling hazardous wastes in their communities, and
to provide an opportunity for residents to voice any concerns they may
have.

This public involvement plan identifies some community concerns
regarding Ohio Technology Corporation's application to build and operate
a hazardous waste incinerator facility in Nova, Ohio. The plan details
specific activities that U.S. EPA will engage in to disseminate
information to the Nova community and to encourage public involvement as
the Ohio Technology Corporation application is reviewed. The plan
consists of the following sections:

€	Description of the proposed facility;

€	Community information;

€	Community concerns;

€	Objectives of the public involvement program;

€	Public involvement activities; and an

€	Implementation schedule.

The objectives and activities discussed in this plan are based on
an assessment of community concerns collected during interviews with
local officials, several residents, and local community opposition

1 In many instances, authority for implementing RCRA has been given to the states by
U.S. EPA. The State of Ohio, however, does not have such authority and all RCRA laws are
currently enforced in Ohio by U.S. EPA.

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groups conducted by U.S. EPA and contractor personnel in August 1988.
Background information included in the plan was obtained from reviewing
state and federal files; interviews with state, federal, and local
officials; and local community opposition groups.

This plan has been prepared in accordance with U.S. EPA's	Guidance

on Public Involvement in the RCRA Permitting Program	 (Draft, January

1986) .

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II. DESCRIPTION OF THE PROPOSED ACTIVITY

A. Location and Description of Facility

Ohio Technology Corporation (OTC) proposed to construct and
operate a hazardous waste and toxic substance treatment facility in
Nova, Ohio, located in Troy Township, Ashland County. The property
purchased by OTC in 1987 consists of approximately 280 acres of rural
farm land along Township Road 7 91, one mile east of Nova and
approximately 12 miles northeast of the City of Ashland (see Figures 1
and 2). The Nova Reservoir is located on the southwest portion of the
property. Of the 280 acres, approximately 40 acres would be used for
the facility.

The proposed facility includes construction of an incinerator
called a Hybrid Thermal Treatment System developed by IT Corporation.
The system involves a modularly designed rotary kiln incinerator for the
destruction of a wide variety of organic wastes. As designed, fumes
resulting from the kiln are burned in a secondary combustion chamber.
In Nova, the proposed incinerator would be operated to burn both general
hazardous wastes and polychlorinated biphenyls (PCBs). The Hybrid
Thermal Treatment System would be designed to incinerate liquid wastes,
viscous fluids, solids, soil, and other contaminated debris.

The proposed facility is designed not to discharge wastewater from
the facility operating areas, but would be designed to treat wastewater
on the site and reuse wastewater in the incineration process. Debris
resulting from the incineration process, including processed solids and
incinerator ash, are proposed to be disposed of in a RCRA licensed
disposal facility off the site.

Access to the proposed OTC facility would be gained from Township
Road 7 91. Trucks entering the facility would include tractor-trailer
trucks carrying wastes contained in drums. Tankers trucks containing
bulk liquids also would enter the facility. Fully loaded trucks would
weigh approximately 30,000 to 50,000 pounds. An average of eight to 12

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Figure 1
Proposed Facility Location Map

trucks would enter the facility per day.

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Proposed Facility Area Map

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B. Owner/Operator Information

The current owner of the property is OTC which is also named as
the proposed owner of the incineration facility in the RARA permit
application. IT Corporation would operate the facility. OTC's
headquarter offices are located in Cleveland, Ohio and IT Corporation's
regional offices are located in Monroeville, Pennsylvania. According to
an OTC official, the facility as proposed could reach its capacity by
accepting wastes from within Ohio, although the facility is designed to
be a regional hazardous waste treatment facility.

C. Regulatory Agencies

In order to obtain the required permits to construct and operate
the incineration facility, OTC must submit permit applications to the
Ohio Environmental Protection Agency (OEPA) and the U.S. EPA. Because
OTC desires to build a facility that will burn both hazardous waste and
PCBs, U.S. EPA permits are required from under both RARA and the Toxic
Substance Control Act (TSCA). The RCRA permit is required for
incineration of hazardous wastes, and the TSCA permit is required for
incineration of wastes containing PCBs.

In addition, OTC must apply for and be issued permits from the
State of Ohio. The primary permits required are a permit to install and
a permit to operate a hazardous waste facility, both of which would be
issued by the Ohio Hazardous Waste Facility Board. All proposed
facilities in Ohio must receive these permits before any construction
can begin. The application for the permits must be submitted for review
to OEPA's Division of Solid and Hazardous Waste Management before a
ruling on the applications is approved or denied by the Hazardous Waste
Facility Board. In addition, OTC must receive an Air Permit to Install
from OEPA's Division of Air Pollution, and a National Pollutant
Discharge Elimination System (NPDES) permit — a provision of the Clean
Water Act — from the Division of Water Pollution control. The air
permit addresses the potential air emissions that could result from
operations from the proposed incinerator, and the NPDES permit addresses
potential discharges to water.

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Currently, OTC has submitted permit applications to both OEPA and
U.S. EPA. By law, permit applications must be reviewed for completeness
and technical adequacy before the permits are either granted or denied.

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III. COMMUNITY INFORMATION

A. Community Profile

Located in Troy Township, Nova is a rural, unincorporated town
with a population of approximately 200 people. According to several
residents interviewed, approximately 50% of the population are full-time
farmers, and the remainder farm half time in addition to having jobs in
other parts of the region.

Nova residents describe themselves as people not interested in
urbanization. Several expressed pride in their families that have a
long regional heritage, and have continued to live in the Nova area
generation after generation. Several residents have recently move into
the area away from more urban surroundings, preferring the clean air and
rural atmosphere. According to residents interviewed, Nova residents
view their population as one consisting of diverse individuals who
possess a broad range of interests, all of which add to the character of
the community.

Troy Township has a population of 450 people and is governed by a
board consisting of three trustees and one clerk. Trustee and clerk
elections are held every two years. The next election will be held in
November 1989. The township chairperson is appointed every January by
the trustees. The township administration also includes a Township
Zoning Commission and a Zoning Board of Appeals. Both the Commission
and Board of Appeals consists of five members of the community who are
appointed by the township trustees to serve four-year terms.

Ashland County is governed by three county commissioners who each
serve four-year terms. County Commissioner elections are held every two
years. The commissioners elect a president each January.

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B. Public Involvement to Date

In the Nova community, public involvement in issues surrounding
the proposed facility has to date been primarily channeled through
community groups. The next few paragraphs characterize the major
community groups involved.

1. STOP IT

According to residents interviewed, community interest and concern
over the proposed facility began when OTC purchased its property at an
auction in 1987. Soon after the property was purchased, the community
learned that OTC planned to install and operate a hazardous waste
incinerator on the property. Concerned over the potential impact of the
incinerator on the Nova community, Nova residents formed a citizens
group called Nova's Right to Know in July 1987. The intent of the group
was to collect information about the proposed project from Ohio
Technology, International Technology, and local, state, and federal
government agencies. In September 1987, the group change its name to
STOP IT ("IT" stands for IT Corporation, the proposed operator of the
facility) because the group's constituency broadened beyond the Nova
community. STOP IT is managed by a director, three co-chairpersons, and
an executive committee. Currently, membership in the group consists of
approximately 400 people.

STOP IT activities have included establishing an information
center in Nova, holding public meetings working with the state of
legislature, coordinating with national and international environmental
groups, and disseminating information to its membership and other
interested parties. The goal of STOP IT is to prevent the proposed
incinerator from being built. According to group members, STOP IT does
not want to negotiate a permit; the organization does not want any
permits issued to OTC at all. STOP IT is a highly organized group whose
leadership possesses a strong commitment to its position. STOP IT has
conducted various activities to heighten awareness of the proposed
incinerator, and has worked to increase support for its position in
Ashland County and other surrounding counties. According to an August

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1988 STOP IT newsletter, the group's networking activities have resulted
in the formation of other STOP IT chapters in Ashland, Parma, and
Wellington. When U.S. EPA granted an extension for completion of the
application to OCT in May 1988, U.S. EPA received over 400 telephone
calls in protest. The telephone calling was largely organized by STOP
IT. U.S. EPA responded in writing to each telephone call.

2.	Citizens Against Pollution

In August 1987, residents from communities near the proposed
facility formed a grassroots citizens group called Citizens Against
Pollution (CAP). News of the proposed facility in Nova motivated the
formation of the group which is run by a director and a board of
trustees. With offices in Huntington, Ohio, the group consists of
chapter representatives from neighboring communities such as Sullivan,
Nova, Homerville, Medina, Ruggles, Spencer, and Elyria. CAP's major
issue is the proposed incinerator, although the group's focus has
widened over the past year to address several other environmental issues
in Ohio, and is viewed as a growing grassroots environment organization
in the state. Adopting a global ecosystem philosophy, CAP
representatives indicated that they would like to see a moratorium
placed on incineration technologies until the global impact of
incineration can be adequately evaluated. According to a CAP
representative, the group is interested in working with both OEPA and
U.S. EPA to "stop the environmental degradation of Ohio."

3.	The Amish Communities

One of the distinct features of the proposed facility is its
proximity to several Amish settlements. The Lodi and Ashland
settlements are the closest to the OTC property, but the proposed
facility has captured the interest of Amish settlements throughout the
region, including Holmes County, the largest Amish settlement in the
world.

In April 1988, leaders of the Amish community traveled to
Columbus, Ohio and participated in a press conference conducted with

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support from STOP IT. The purpose of the conference was to present over
4,000 petition signatures from the Amish community in opposition to the
proposed facility. Invited to the press conference were OEPA, U.S. EPA,
the Ohio Hazardous Waste Facility Board, and state and federal
government representatives. In a written statement, the Amish
contingency voiced their concerns:

We are meeting here today because of a concern. The old
Order Amish are thankful to God for the privilege to live in a
country where we can live, work and share our lives with our
neighbors and fellowman.

We still adhere to and believe in the Golden Rule: Do unto
others as you world that others do unto you.

It is with this in mind that we have over 4,000 signatures
protesting a proposed toxic waste incinerator site in Ashland
County.

Living close to this site is an Amish community of over 100
families that would be severely disrupted and handicapped if this
site was approved. Without any doubt these people would have to
relocate.

Also from information we have received we would be subject to
toxic emissions in our area.

So we plead with meekness to please accept our protests with
an open mind and sincere concern.

The involvement of the Amish in this manner — a people not known
for their political activism — generated significant media attention
and was reported by the Chicago Tribune , U.S.A. Today , and the New York
Times . Leaders of the Amish settlements keep informed about the status
of the project, and are in contact with both STOP IT and CAP.

Public involvement over the last year can be characterized as
significant. The work of the citizens groups has served to heighten
awareness of the proposed project all over the region. In April 1988,
the Troy Township Trustees polled their constituents and concluded that
94% of the responders were opposed to the proposed facility. In
addition, several communities and organizations from a wide geographical
area have adopted ordinances and resolutions in opposition to the
proposed facility (see Appendix A). Although opposition to the proposed
facility is widely known and publicized, there is some evidence of

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support for OTC's project within the region. Newspaper reports
indicate, however, that although there may be support for the facility,
the strength of the opposition to the facility has caused proponents to
keep their views to themselves.

Political interest in the proposed project has also grown over the
last year. Responding to letters of concern from their constituents,
U.S. Senator Howard Metzenbaum, U.S. Senator John Glenn, Congressman Don
Pease, State Representative Ron Amstutz, and State Senator Dick
Schafrath have all taken positions in opposition to the proposed
facility. In addition, Cleveland's mayor, George Voinovich, has opposed
the project. Many residents have written their concerns to both U.S.
EPA and OEPA.

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IV. COMMUNITY CONCERNS

The following community concerns were expressed by Nova area
residents and local officials during interviews conducted in August
1988.

A)	Lack of trust in the proposed operator of the facility	.

Residents interviewed expressed concern regarding IT Corporation's
involvement in the proposed project. Nova area residents and members of
STOP IT and CAP feel strongly that IT Corporation is not a reliable
company to be operating the proposed facility. The citizens groups have
distributed information about IT Corporation, including a list of
violations of State of California environmental regulations and the
Louisiana State Ethics Code. Members of STOP IT cite a recent	Forbes

article which discusses management and financial problems of IT
Corporation, and the fact that the company insures itself against
environmental liabilities as proof of IT Corporation's instability (see
"Warning — Hazardous Management," Forbes , Volume 142, Number 2, July
25, 1988, Page 60). Residents also are concerned that IT Corporation
will purchase OTC and that OTC is merely acting as a "front" for IT
Corporation.

B)	Effects of proposed facility on quality of life	Residents
interviewed stressed their concern regarding the impact of the proposed
facility on the quality of life in the area. Residents said that the
major reason why people move into rural areas and stay in these areas is
the clean air, and non-urbanized, undeveloped characteristics of these
regions. These residents feel that construction and operation of an
incinerator in the area would destroy the appeal of the area, negatively
impact property values, and drive people away. Moreover, residents and
members of the Amish community pointed out that siting an incinerator in
the Nova area is counter-culture to the Amish way of life. CAP stressed
the fact that the Amish communities increase the tourist appeal of the
area. According to newspapers reports, the Amish community has hinted

to the possibility that the Amish settlements in the area may relocate
if the incinerator is licensed and built. Community interviews with

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Amish representatives, however, indicated that this would be a last
resort.

C)	Effects of proposed facility on environmental quality in the	

region . All residents interviewed expressed the greatest concern about

the impacts of the proposed facility on the environment. The community
is very concerned about air emissions from the proposed incinerator and
feels strongly that there would be a threat of toxic air contamination.
CAP and STOP IT also spoke about the fact that the facility would be
located near the headwaters of the Black and Vermilion rivers. The
groups feel that these rivers would be endangered by contamination
resulting rom operation of the incinerator. The Amish leaders voiced
their concern that air emissions would contaminate rainwater which is a
primary water source through cisterns and wells on many of the Amish
properties. The Amish are concerned about how their livestock and crops
may be affected by the proposed incinerator. Such a concern is echoed
by other farmers in the area who view the proposed incinerator as a
threat to their livelihoods.

D)	Inappropriateness of site selection	Most people interviewed
questioned why Nova was chosen as the site for OTC's project. These
people feel that it is inappropriate for an incinerator to be located in

a rural community where natural resources are a significant aspect of
the economy. Two residents interviewed, one that breeds Navajo Churro
sheep (an endangered species) and another that propagates native
American seeds, were particularly concerned that an incinerator in the
area could endanger their projects. The Amish leaders expressed similar
concerns and asked why incinerators had to be cited in places where
people lived. They suggested that a better location would be in a
desert, or some other unpopulated area.

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E)	Waste management in Ohio	Both CAP and STOP IT said that
they wanted to obtain more information about the waste management
industry in Ohio. These groups feel that there are plenty of
incinerators in the area, and that building another one is not
necessary. The groups are interested in exploring alternative waste
management technologies to incineration. Their interests in this area
reflect their concerns that OTC and IT are not acting in the best
interest of the community or the state, and are proposing the
incinerator for their own financial benefit.

F)	Safety of the proposed incinerator	Residents and local
officials brought up several safety issues. Most people interviewed
said they are concerned about having trucks filled with contaminated
material driving through the area. According to several residents, the
roads in the area have several sharp curves which could lead to
accidents by trucks traveling to the facility. In addition, residents
cited air and fugitive emissions, and public health effects of long-term
exposure to such emissions as major concerns.

Residents who oppose incineration altogether as a waste management
technology believe that too little information is known about the
synergistic effect of several chemicals burning at once, and feel that
such an occurrence is a health threat to the area.

Many of the people interviewed wanted clarification on monitoring
of the incinerator should it become operational. These residents wanted
to know who would conduct the monitoring and how often it would be done.
STOP IT and CAP expressed reservations about monitoring programs and
said that the proposed incinerator would not be adequately monitored.
These groups suspect that officials would only monitor for a narrow
range of contaminants.

CAP representatives shared their frustration about the safety
issue and rhetorically asked why the burden of making the incinerator
safe rested with the residents. They expressed distrust in the ability
of government officials to protect the environment and public health.

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G)	Emergency response capabilities in the area	Several
concerned residents and local officials felt that siting the facility in
the Nova area places the region in peril should an accident occur. Nova
itself has no emergency response capabilities and relies on the City of
Ashland and other communities for such assistance. The community is
concerned that should an accident occur, there would be no efficient and
comprehensive way of responding. Moreover, the Amish representatives
expressed concern that should an accident occur, emergency communication
with the settlements and evacuation would be impossible due to their
lack of telephone, electricity, and modern transportation systems.

H)	Confusion regarding the permitting process	Most of all the
residents and local officials agreed that the permitting process is
confusing. Many expressed frustration about the many levels of
government involved and wanted clarification on the authorities of the
federal, state, and local governments. In March 1988, OEPA held an
informational session for Nova area residents. At the session, several
division representatives from OEPA and U.S. EPA answered questions and
provided information on the permitting process. Community members and
OEPA officials indicated that the session was informative, although
residents said that some confusion still remains about the permitting
process.

I)	Poor response from government officials	While many
residents appeared satisfied with the information provided by government
officials, several residents and the citizens groups felt that both the
state and federal government officials should provide more information
regarding the permitting process and should be more accessible. STOP IT
complained bout being "hung up on" by U.S. EPA officials, and said they
were frustrated that U.S. EPA had not acknowledged much of the
information sent to them by STOP IT. CAP representatives expressed the
same concerns.

J) Frustration over limited opportunities for public	

involvement . Most people interviewed did not understand the extent to
which formal opportunities for public involvement exist during the
permitting process. Those residents and local officials that are more

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aware of public opportunities feel that they are limited and that they
do not serve the interests of the communities. Most people interviewed,
including the Amish leaders, asked about effective ways of becoming
involved in the process so that their concerns can be officially
considered before the agencies make any final decisions.

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V. OBJECTIVES OF THE PUBLIC INVOLVEMENT PROGRAM

Based on the concerns voiced by area residents and local
officials, the following are the objectives of the public involvement
program during the permitting process:

A)	Establish accessibility among U.S. EPA personnel to the	

community . As the Nova community works toward becoming informed about
the issues surrounding the proposed facility, it will be very important
for U.S. EPA personnel to be available to answer questions and provide
information. Both STOP IT and CAP already are frustrated with the
difficulty they have in contacting U.S. EPA personnel. Maintaining good
positive contact with concerned citizens in the Nova community will
strengthen U.S. EPA's credibility and allow people to become more
involved in the process.

B)	Coordinate with OEPA to make sure the community understands	

the permitting process and opportunities for public involvement	.

Community interviews reflected the confusion that residents and local
officials have about the permitting process and opportunities for public
involvement. A crucial component of the public involvement program is

to make certain that interested residents and local officials have
adequate opportunities to understand and be involved in the permitting
process and the opportunities for their involvement. Because so many
levels of government are involved in the process, U.S. EPA should work
closely with OEPA to provide the community with adequate information and
opportunities to ask questions of appropriate government officials.

C)	Provide specific information on issues of interest to ensure

a strong level of understanding by the community	Both STOP IT and CAP

are working hard to acquire information that will put many of the issues
of concern into perspective. Much of CAP and STOP IT's activities will
involve disseminating information to all interested parties. U.S. EPA
and OEPA should work together to provide the community with accurate
information on subjects such as incineration technology, alternative
waste management practices, emergency response procedures, monitoring

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practices, and environmental impacts of waste management practices.

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VI. PUBLIC INVOLVEMENT ACTIVITIES

Specific public involvement activities related to the OTC RCRA
permit application are required by Title 40 of the Code of Federal
Regulations, Part 124 and RCRA Section 7004. The public involvement
activities describe below include required activities (indicated by an
asterisk), as well as other activities intended to address community
concerns and to carry out the objectives established for the public
involvement program.

A)	Designate U.S. EPA contact to respond to questions from the
community . U.S. EPA has assigned one member of the Office of Public
Affairs (OPA) staff in the Region V office in Chicago to be the central
U.S. EPA liaison for the community (see Appendix B). This person will
respond to community requests for information and will field telephone
requests for information to other appropriate U.S. EPA personnel. The
OPA's name and telephone number will appear on all correspondence
between U.S. EPA and the community in addition to U.S. EPA's toll-free
number. The OPA official also will be the central contact for local
media to acquire information regarding the proposed incinerator, and
will keep an up-to-date mailing list of interested individuals.

B)	Establish local information repositories for interested	

parties to review material	In Nova as well as in other nearby

communities (see Appendix C), information repositories will be
established to provide the community with copies of the permit
applications, applicable laws, and other relevant information. As new
information is developed, the information repositories will be updated.

C)	Coordinate with OEPA to provide fact sheets on issues of	

concern regarding the proposed facility	U.S. EPA will coordinate

closely with OEPA to provide the community with fact sheets that
summarize the permitting process in a clear and easy to read format.

The first fact sheet will include information on the state and federal
permitting process, and on the role of local government and
opportunities for public involvement. In addition, separate fact sheets

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will be distributed to provide information on other topics of concern
expressed by the community. These fact sheets will cover incineration
technology, monitoring practices of the U.S. EPA and OEPA, alternative
waste management practices, and current information on environmental
impacts of incinerators. The fact sheets will be printed and
distributed to individuals on U.S. EPA's current mailing list.

D)	Conduct availability sessions to answer specific questions
After the fact sheets are prepared and distributed, U.S. EPA in
cooperation with OEPA will hold at least three availability sessions in
the community. The availability sessions will be designed to
accommodate small groups and will consist of representatives of OEPA and
U.S. EPA who will be available to answer specific questions of the
community. The sessions will be held in different geographic areas of
the region and will accommodate members of the Amish community. Notices
announcing the availability sessions will be published in local
newspapers.

E)	Notify the community about progress made on application	

review . As progress is made on processing of the permit application, or
if the schedule for reviewing the application alters significantly, U.S.
EPA will notify the community by providing a written update to
individuals on the mailing list and media representatives.

*F) Develop and distribute fact sheet on draft permit or denial
It is required by RCRA regulations that one fact sheet, or "Statement of
Basis," be distributed that describes both the facility and the permit
that is being proposed for that facility. Such a fact sheet will be
developed and distributed to individuals on the mailing list, media, and
any other interested parties in advance of the public comment period.

*G) Conduct a public comment period on draft permit or denial
RCRA regulations require that the public must be notified through a
local newspaper and broadcast over local radio stations that a draft
permit has been prepared. A forty-five day period is also required
under RCRA regulations to accept public comments. U.S. EPA may extend
the public comment period if necessary. U.S. EPA will distribute a

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press release to local media and a notice to the mailing list announcing
the beginning of the public comment period.

H) Hold public hearing on draft permit or denial	RCRA

regulations require that a public hearing be held if an individual
organization or community requests one, or if the Regional Administrator
determines that one is needed. The purpose of having a public hearing
is to officially accept and record public comments. For this site, U.S.
EPA has decided to hold a public hearing. U.S. EPA will hold such a
hearing and will publicize it via a press release to local media, and
advertisements in local newspapers. A notice also will be sent to the
mailing list. After the hearing has been held, a tape or transcript
will be placed in the information repositories.

*1) Prepare Response to Comments to address community concerns
RCRA regulations require that a response to comments be prepared at the
conclusion of the public comment period. This document will consist of
a summary of the written comments received, the oral comments presented
at the haring, and a response to those comments prepared by U.S. EPA.
The Response to Comments will be placed in local information
repositories for public review.

* denotes required activity

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VI. TIME LINE FOR IMPLEMENTING PUBLIC INVOLVEMENT ACTIVITIES

The following is a time line for public involvement activities through
issuance of a final decision on the Ohio Technology Corporation's RCRA
permit application. Should a permit be issued, U.S. EPA would continue
the public involvement program.

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Activity

Approval of the
Public Involvement
Plan

Completion of
Technical Review

Issuance of Draft
Permit (if
applicable)

Issuance of Final
Permit (if
applicable)

1. Designate
Contact

X

2.	Establish
Information
Repositories

3.	Fact Sheets

4.	Availability
Sessions

5.	Updates

X

X-

X

-X

X-

-X-

-X-

	X

X	As needed-

	x

6.	Public Comment
Period

7.	Public Hearing

8.	Responsiveness
Summary

X-

-X

X
X

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APPENDIX A

LOCAL GOVERNMENTS AND ORGANIZATIONS ISSUING
WRITTEN STATEMENTS OF OPPOSITION TO THE PROPOSED INCINERATOR

[obtained from state and federal files]

Government Body

Village of Savannah

City of Avon Lake

Troy Township

Village of Lodi

Ashland County Soil and Water
Conservation District

Russia Township
City of Allure

Date resolution adopted
December 15, 1987
December 14, 1987
September 28, 1987
October 19, 1987
April 26, 1988

March 22, 1988
March 21, 1988

Local Organization

Cinnamon Lake Association, Inc.

Ashland County Farm Bureau, Inc.

Episcopal Diocess of Ohio

Lodi Rotary Club

Lodi Chamber of Commerce

Ruritan Club of Lodi

Date of written position
December 16, 198
May 16, 1988
July 12, 1988
January 20, 1988
January 20, 1988
January 20, 1988

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APPENDIX B

LIST OF CONTACTS, INTERESTED PARTIES, AND MEDIA

1.	Federal Elected Officials

Senator John Glenn	(202) 224-3353

503 Senate Hart Office Building
Washington, DC 20510-3501

District Office	(216) 522-7095

Federal Courthouse
201 Superior Avenue
Cleveland, OH 44114

Senator Howard Metzehbaum	(202) 224-2315

140 Senate Russell Office Building
Washington, DC 20510-3502

District Office	(216) 522-7272

Celebreeze Federal Building
Room 2 915

12 40 East Ninth Street
Cleveland, OH 44199

Congressman Donald Pease	(202) 225-3401

2410 Rayburn House Office Building
Washington, DC 20515

District Office	(419) 325-4184

The Centre
Suite 101

42 East Main Street
Ashland, OH 44805-2336

2.	State Elected Officials

Governor Richard Celeste	(614) 466-3555

Office of the Governor
Statehouse
Columbus, OH 43216

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State Senator Richard Schafrath
Ohio Senate
Statehouse
Columbus, OH 43216

Local Address

42 4 West Main Street

Loudonville, OH 44842

State Representative Ronald Amstutz
Ohio House of Representatives
Statehouse
Columbus, OH 43216

Local Address

22 43 Friar Tuck Circle

Wooster, OH 44691

3.	Local Government Officials

Ashland County Commissioners
Court House
West Second Street
Ashland, OH 44805
Marilyn Byers, President
C.R."Dick" Myers
Robert Valentine

Ashland County Board of Health

c/o Ashland County Health Department
110 Cottage Street
Ashland, OH 44805

Gloria Weirick, President

Ashland County Regional Planning Commission
110 Cottage Street
Ashland, OH 44805

Mike Wolfson, Director

(614) 466-8086

(419) 994-4161

(614) 466-1474

(216) 262-7371

(419) 289-0000

(419) 289-0000

(419) 289-0000

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Ashland County Disaster Services	(419) 289-6511

c/o Ashland City Fire Department
274 Cleveland Avenue
Ashland, OH 44805

John Augustine, Director

Troy Township Trustees

Donald Biddinger, Chairman
Ralph Smith, Vice Chairman
Richard Robertson
Mary Judith Fox, Clerk

(419) 652-3462
(419) 652-3258

(419) 652-3361
(419) 652-3187

Troy Township Zoning Inspector
Willard Smith

(419) 652-3362

Troy Township Zoning Commission
Leslie White
Richard Hawley
Delmar Rife
Janet Cleugh
John M. Gorman

(419)	652-3842

(419)	652-3021

(419)	625-3851

(419)	652-3760

(419)	652-3354

Troy Township Zoning Board of Appeals
James R. Callihan
Dean Sheppard
Tod Crumrine
Janice Schneiter
Eugene Fowler

(419)	652-2225

(419)	652-3838

(419)	652-3194

(419)	652-3181

(419)	652-3808

4 .	Federal Government Agencies

U.S. Environmental Protection Agency
Region V

230 South Dearborn Street
Chicago, IL 60604

Valdas Adamkus, Regional Administrator	(312) 353-2000

Anne Rowan, Public Participation Coordinator	(312) 88 6-7857

Office of Public Affairs
Wen Huang, Environmental Engineer	(312) 886-6191

RCRA Permit Branch

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Charles Slaustas, Supervisor	(312) 886-6190

RCRA Permit Branch
Lisa Pierard , Ohio Section Chief	(312) 353-4789

RCRA Permit Branch
Sheldon Simon, Regional PCB Coordinator	(312) 886-6087

Pesticides and Toxic Substances Branch

John Connell, Chief	(312) 886-6832

PCB Compliance Section

Office of the Environmental Sciences Division
5.	State Government Agencies

Ohio Environmental Protection Agency
P.O. Box 1049
18 00 Water Mark Drive
Columbus, OH 432 66-0149

Richard Shank, Director

Linda Whitmore, Public Involvement Coordinator

Public Interest Center
Robert Babik, Environmental Engineer

Division of Solid and Hazardous Waste
Management

Ohio Hazardous Waste Facility Board	(614) 644-2742

P.O. Box 1049
1700 Water Mark Drive
Columbus, OH 432 66-0149
James Adair III, Executive Director

Board members :

Richard C. Sahli, Deputy Director

Legal and Governmental Affairs
Ohio Environmental Protection Agency
Warren W. Tyler, Chairman

Ohio Water Development Authority
Charles E. Mauger, Assistant Director

Ohio Department of Natural Resources
Thomas Sweeney, Ph.D., Assistant Vice

President of Research and Graduate Studies
The Ohio State University
W.B. Clapham Jr., Ph.D., Associate Professor of Geology

(614) 644-2782
(614) 644-2160

(614) 644-2949

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Cleveland State University

6.	Citizens Groups

STOP IT	(419) 652-3000

P.O. Box 134
Nova, OH 44859

Dave Schlaufman, Director	(419) 652-38 62

Vern Hurst, Co-chairperson
Diana Schlaufman, Co-chairperson

Citizens Against Pollution
P.O. Box 122
Sullivan, OH 44880
Ardith Jordan, Trustee

(216) 647-6127

(Mon.,Wed., Fri.)

7.	Media

Newspapers

Ashland Times Gazette
40 East Second Street
Ashland, OH 44805
(419) 281-0581

New London Record
P.O. Box 110
New London, OH 44851
(419) 929-3411

Akron Beacon-Journal
44 East Exchange Street
Akron, OH 4432 8
(216) 375-8111

Mansfield News Journal
P.O. Box 25
70 West Fourth Street
Mansfield, OH 44901
(419) 522-3311

Elyria Chronicle-Telegram
P.O. Box 4010
225 East Avenue
Elyria, OH 44035
(216) 329-7000

Wellington Enterprise
P.O. Box 38
Wellington, OH 44090
(216) 647-3171

Cleveland Plain Dealer
18 01 Superior Avenue
Cleveland, OH 44114
(216) 344-4500

Television

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WAKC-TV

853 Copley Road
Akron, OH 4432 0
(216) 525-7831

WEAO-TV

275 Martinel Drive
Kent, OH 44240
(216) 678-1656

WEWS-TV

3001 Euclid Avenue
Cleveland, OH 44115
(216) 431-5555

WKYC-TV

1403 East Sixth Street
Cleveland, OH 44114
(216) 344-3333

WVIZ-TV

4300 Brockpart Road
Cleveland, OH 44134
(216) 398-2800

"WNCO-Radio
P.O. Box 311
Ashland, OH 44805
(419) 289-2605

WLKR-Radio
P.O. Box 547
Norwalk, OH 44857
(419) 668-8151

WBNX-TV
P.O. Box 2091
Akron, OH 44309
(216) 928-5711

WQHS-TV

2681 West Ridgewood
Parma, OH 44134
(216) 888-0061

WJW-TV

58 00 South Marginal Road
Cleveland, OH 44102
(216) 431-8888

WUAB-TV
8443 Day Drive
Cleveland, OH 44129
(216) 845-6043

Radio

WRDL-Radio
Ashland College
401 College Avenue
Ashland, OH 44805
(419) 289-2480

WCLS-Radio
711 McPherson Street
Mansfield, OH 44906
(419) 525-2331

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WMAN-Radio

WVNO-Radio

P.O. Box 8
Mansfield, OH 44901
(419) 524-2211

2900 Park Avenue West
Mansfield, OH 44906
(419) 529-5900

WCWS-Radio
College of Wooster
Wooster, OH 44691
(216) 263-2240

WWST-WQKT Radio
South Hillcrest Drive

Wooster, OH 44691
(216) 264-5122

8 .	Owner/Operator

Ohio Technology Corporation (owner)

(216) 464-2121

3350 Lander Road

Cleveland, OH 44124

John Tracy, Principal Manager

International Technology Corporation (operator)

(412) 243-3230

Regional Office
William Penn Plaza
2790 Mosside Boulevard
Monroeville, PA 15146-2792

Brian Borofka, Site Assessment Group Leader
Headguarters

23456 Hawthorne Boulevard	(213) 378-9933

Torrence, CA 90509

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APPENDIX C
LIST OF INFORMATION REPOSITORY LOCATIONS
AND PUBLIC MEETING FACILITIES

1)	Information Repository Locations

Ashland Public Library
22 4 Claremont Avenue
Ashland, OH 44805
(419) 289-8188
Contact:

Constance Wolfson, Librarian

New London Public Library
67 South Main Street
New London, OH 44851
(419) 929-3981
Contact:

Melissa Karnosh, Librarian

Troy Township Trustees
Nova, Ohio
(419) 652-3200
Contact:

Ralph Smith

2)	Public Meeting Facilities

Mapleton Middleton School
(Ruggles Troy School)
U.S. Highway 224
Nova, OH 44859
(419) 652-3540
Contact:

John Neighbors, Principal
Capacity: Approximately 250

Citizens Against Pollution
Corner School House
Sullivan, OH 44880

Mapleton High School
County Rod 620
Polk, OH 448 61
(419) 945-2188
Contact:

Mr. Schneider, Principal
Capacity: Approximately 600

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APPENDIX D

LIST OF PERSONS CONTACTED FOR PREPARATION
OF THE PUBLIC INVOLVEMENT PLAN
(for U.S. EPA and Ohio EPA use only)

Ashland County Board of Commissioners	(419) 289-0000

Court House
West Second Street
Ashland, OH 44805

J. Myron Leininger
Marilyn Byers
C. Jay Welsh

Troy Township Trustees

Donald Biddinger
Ralph Smith
Richard Robertson

(419) 652-3463
(419) 652-3258
(419) 652-3361

Ohio Environmental Protection Agency
P.O. Box 1049
18 00 WaterMark Drive
Columbus, OH 432 66-0149

Linda Whitmore, Public Involvement Coordinator	(614) 644-2160

Public Interest Center
Michael Greenberg, Public Information Specialist	(614) 644-2160

Public Interest Center
Robert Babik, Environmental Engineer	(614) 644-2949

Division of Solid and Hazardous Waste
Management

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U.S. Environmental Protection Agency

Region V

230 South Dearborn Street
Chicago, IL 60604

Anne Rowan, Public Participation Coordinator/RCRA

Office of Public Affairs
Nancy Sullivan, Public Affairs Specialist/TSCA

Office of Public Affairs
Margaret McCue, RCRA Public Participation Manager

Office of Public Affairs
George Harper, Ohio Section Chief

RARA Permit Branch
Wen Huang, Environmental Engineer

RCRA Permit Branch
Charles Slaustas, Supervisor

RCRA Permit Branch
Sheldon Simon, Regional PCB Coordinator

Pesticides and Toxic Substances Branch

Local Residents and Interested Individuals

Mike Stanfield
962 County Route 40
Nova, OH 44859
(419) 652-3133

Elaine Drotliff
83 6 Township Road 150
Nova, OH 44859
(419) 652-3122

(312) 886-7857
(312) 886-6687

(312) 886-6694
(312) 353-4789
(312) 886-6191

(312) 886-6190
(312) 886-6087

Gladys Thomas
838 U.S. Highway 224
Nova, OH 44859
(419) 652-3818

Diana Schlaufman
94 6 Township Road 150
Nova, OH 44859
(419) 652-3862

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David Schlaufman
94 6 Township Road 150
Nova, OH 44859
(419) 652-3862

Frank Rickett
402 Township Road 791
Sullivan, OH 44880
(419) 652-3238

Lois Kinter
Box 15

U.S. Highway 224 West
Nova, OH 44859
(419) 652-3892

Judith Casteel
7730 Firestone Road
Homerville, OH 44235
(419) 625-2141

Joanne Slorgie
12 9 Broadway Street
Lodi, OH 44254
(216) 948-2482

Vern Hurst

995 Township Road 150
Nova, OH 44859
(419) 652-3337

Tod Crumrine
173 State Route 511
Nova, OH 44859
(419) 652-3194

Bob Janca

12595 New London E Road
Homerville, OH 44235
(419) 648-2853

John Nethers, Ph.D.

Professor of History
Department of Social Sciences
Bixler Hall — Ashland College
Ashland, OH 44805
(419) 289-5381

Anne Slorgie
12 9 Broadway Street
Lodi, OH 44254
(216) 948-2482

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Linda Martz

Mansfield News-Journal
P.O. Box 25
40 West Fourth Street
Mansfield, OH 44901
(419) 522-3311

Phil Dague

210 Township Road 2150
Jeromesville, OH 44840
(419) 368-3281

Sue Grycza

Ashland Times - Gazette
40 East Second Street
Ashland, OH 44805
(419) 281-0581

Leroy J. Keim
Lodi, OH

David Yoder
Firestone Road
Homerville, OH

Ardith Jordan
Mary Beth Derekito
Mary Warner
Eli Troyer

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