Clean The Bottoms Coalition

12 Main St
Bottoms, South Carolina

March 19, 2018

Attn: U.S. Environmental Protection Agency

EPA Superfund Docket Center
Mailcode 28221T
1200 Pennsylvania Avenue N.W.
Washington, D.C. 20460

RE: Docket No. EPA-HQ-OLEM-2017-0610

To Whom it May Concern:

On behalf of the residents of Bountiful County, I respectfully submit comments to the Environmental
Protection Agency (EPA) regarding the National Oil and Hazardous Substances Pollution Contingency
Plan. We strongly urge your favorable action in considering an addition to its National Priority List, the
Westinghouse Incinerator site located in Region 4. The Bottoms has been disproportionally impacted by
the site’s pollution generating facilities, and residents ask that it be added for the possibility of remedial or
site clean-up action.

Human Health Impact

Our comments are mainly prompted by information we received from a recent FOIA request which your
agency provided. Indicating serious soil contamination problems concerning high levels of PCBs, lead,
and mercury at the Westinghouse Incinerator. Bountiful County has been ranked as one of the most
impoverished communities within the state, and many residents feel their public health and safety are
affected by having to breathe in these chemicals on a daily basis.1 They are concerned for their families,
the environmental damage already done, and the effects it will have on their children. Exposure to these
chemicals have shown to2:

 Cause development effects in children.

 Increase the likelihood of neurobehavioral birth defects.
 Disrupt the birth reproductive functions.
 Heighten the risk for cancer and non-Hodgkin’s lymphoma.

Agencies, including the EPA, have noted enough scientific information is available concerning, in
particular PCBs, to warrant action by public health officials, medical providers, and environmental
organizations.3

1
The Bottoms Case Study.
2
U.S. Public Health Service the Agency for Toxic Substances, Disease Registry U.S. Department of Health and
Human Services, and The U.S. Environmental Protection Agency. “Public Health Implications of Exposure to
Polychlorinated Biphenyls (PCBs)” (2015). Retrieved from https://www.epa.gov/sites/production/files/2015-
01/documents/pcb99.pdf
3
Ibid.
Environmental Impact

As our problems have concerned air pollution, contaminated soil naturally contributes to unhealthy air
quality by releasing volatile compounds into the air. According to researchers4:
 The more toxic the soil, the more polluted the air.
 Soil pollution can mobilize nonorganic forms, that are extremely toxic to plants and can leak into
the groundwater, affecting the infrastructure of homes, and creating “toxic dust” which residents
could then breathe into to their bodies.
 Negative impacts may come from direct contact with polluted soil or from contact with other
resources, such food which has been grown on or come in direct contact with the contaminated
soil.

As residents are near these facilities, the harmful effects from the soil that it proses to Bountiful County
productivity is concerning. The community is unable to support plant life, grow local food, or attract the
attention of farmers because of the soil and air pollution problems. Similarly, many residents are
concerned about the overall contamination of their living spaces which could affect mundane activities.

Meet NPL Criteria

In addition, upon reading the proposed NPL list, we noticed there are three mechanisms for
placing sites on the list for possible remediation. We view our community, not having a “Hazard
Ranking System” score, fits within the criteria of the third option which outlines5:

 The Agency for Toxic Substances and Disease Registry (ATSDR) of the U.S. Public Health
Service has issued a health advisory that recommends dissociation of individuals from the release.
 The EPA determines that the release poses a significant threat to public health.
 The EPA anticipates that it will be more cost-effective to use its remedial authority than to use its
removal authority to respond to the release.

As we believe all these criteria have been met by our communication with ATSDR and the EPA after the
release of information from our FOIA request. The Westinghouse addition to the NPL is a progressive
move to remedying the issues of Bountiful County residents who often feel unheard and unaddressed
about the environmental harms that have impacted their lives.

Recommendation

In conclusion, we propose the EPA consider adding the Westinghouse Incinerator to the NPL as the
community has been impacted by risk factors outlined in the proposed rule and above statements. We ask
that you reconsider the final list, assessing the Bottoms in conjunction with the sites already and currently
in remediation within Region 4.

Thank you for your consideration of these comments in advance.

4
What Is Soil Pollution? (n.d.). Retrieved December 7, 2018, from
https://www.environmentalpollutioncenters.org/soil/
5
National Priorities List. (18, January 01). “U.S. Environmental Protection Agency”. Retrieved December 7, 2018,
from https://www.regulations.gov/document?D=EPA-HQ-OLEM-2017-0610-0001
Sincerely,

Ricardo J.J. Edwards Jr.

Organizer, Clean The Bottoms Coalition