September 30, 2026
These comments are submitted in response to the Ohio Environmental Protection Agency’s (OEPA) public notice Draft State Implementation Plan: Source-Specific VOC Reasonably Available Control Technology (RACT) for Alterra Energy LLC (Facility ID 1677011258). The signers have no direct or indirect financial or fiduciary interests in the subjects of these comments.
Since 2023, Alterra’s annual volatile organic compounds (VOC) emissions have more than tripled.1 Ozone forms when VOCs react with oxides of nitrogen (NOx) in the presence of sunlight. Exposure to ozone causes respiratory effects and is associated with exacerbation of asthma and chronic obstructive pulmonary disease (COPD), respiratory infection, and hospital admissions and emergency department visits for respiratory diseases. People with asthma, children, older adults, and outdoor workers are at increased risk of health effects from ozone.2 Evidence also indicates increased risks for pregnant people and fetuses.3
According to an analysis conducted in June 2026 using the U.S. Environmental Protection Agency’s EJScreen tool, version 3.2022.2, the population within 3 miles of the Alterra facility is disproportionately low income (44% compared to 30% average in the U.S.) and suffers from higher rates of asthma (11.8% compared to 10.3% in the U.S.). There are 20 schools within 3 miles of this facility.4 In addition, Alterra is in close proximity to childcare and early childhood education facilities—it is across the street from a daycare center, and several other pre-schools are within 1 mile. The Herzing University campus with its nearly 400 students (studying nursing and other health professions) is a mere 0.5 mile away. Multiple places of worship are situated within a 2-mile radius. The location is burdened with pollution—it ranks in the 85th percentile nationally for nitrogen dioxide and in the 95th percentile nationally for toxic releases to air.5
Ozone is not the only concern with VOC emissions. OEPA permits Alterra to release 0.55 tons per month (rolling average) of VOCs, including the known carcinogens benzene, vinyl chloride, acetaldehyde, and1,3-butadiene. Some of these carcinogens are mutagens that damage DNA, meaning that any level of exposure carries some risk. Fetuses, infants and children are more susceptible and early-life exposures to such carcinogens carry greater risks.6 VOCs are not the only carcinogens released by Alterra; the May 2022 stack test confirms the release of toxic, cancer-causing dioxins and furans, which are persistent organic pollutants.7 Cumulative exposures to multiple carcinogens may raise cancer risks.8
These data raise serious concerns for people living, working, attending school and engaging in other activities near Alterra—especially for susceptible groups including infants, children, and people with asthma.
The Alterra RACT study is inadequate-it does not include NOx and potential significant sources of VOCs.9 For protection of public health and vulnerable populations like children, OEPA should require Alterra to update the RACT study to comprehensively consider and reduce emissions of both NOx and VOCs that contribute to harmful ozone formation and other health risks.
These comments cover the following main points:
- NOx should be included in the RACT study and Alterra should conduct additional stack testing.
- Pyrolysis oil storage tanks, hazardous waste and char should be included in the RACT study and Alterra should submit data on the vapor pressures of such materials stored on site.
- Pollution during power failures and other likely incidents should be included in the RACT study.
- The RACT study and stack testing data must be released to the public.
1. NOx should be included in the RACT study and Alterra should conduct additional stack testing.
As noted above, NOx contributes to ozone formation. According to OEPA’s draft 2025 permit, Alterra has the potential to emit (PTE) 35.2 tons of NOx per year.10 NOx should be included in the RACT study to ensure that available interventions to reduce such emissions are considered and implemented.
Additionally, source testing of the vapor combustion unit conducted in December 2023 found NOx emissions significantly higher than estimated by Alterra in its 2022 permit renewal application.11 The source testing should be repeated to verify that the PTE in the draft 2025 permit is accurate. In general, Alterra should be required to perform regular stack testing to confirm the vapor combustion unit is operating at the required destruction efficiency.
2. Pyrolysis oil storage tanks, hazardous waste and char should be included in the RACT study and Alterra should submit data on the vapor pressures of such materials stored on site.
Alterra has reported producing the following plastics-pyrolysis derived chemical products to the U.S. Environmental Protection Agency:12
- Waste plastics, pyrolyzed, C5-55 fraction, CASRN 2020340-46-7
- Waste plastics, pyrolyzed, C5-12 fraction, CASRN 2055370-07-3
- Waste plastics, pyrolyzed, C9-20 fraction, CASRN 2055370-08-4
- Waste plastics, pyrolyzed, C20-55 fraction, CASRN 2055370-09-5
These are all chemical mixtures of variable composition that contain VOCs, yet the Alterra RACT study lists VOC emissions from 4 pyrolysis oil storage tanks (10,000 gallons each) as “negligible.”13 Storage tanks are significant sources of VOC emissions.14
Unless Alterra has monitoring data to demonstrate that VOC emissions from the storage tanks are “negligible,” the tanks should be included as VOC sources in the RACT study.
Alterra has reported generating over 300,000 kg of hazardous waste since 2023.15 This hazardous waste contains VOCs (benzene, methyl ethyl ketone and halogenated solvents) and was shipped offsite for disposal.16 The hazardous waste storage tanks, loading and transfer operations would all contribute to VOC emissions and should be included in the RACT study.
The char generated by Alterra is a likely source of VOCs and should be included in the RACT study. OEPA has testing data documenting that char generated by other plastics pyrolysis facilities contains benzene at high enough levels to be considered hazardous waste.17
Alterra should also provide data on the vapor pressures of pyrolysis oils and hazardous waste stored on site to ensure such materials are being stored in tanks with appropriate control systems.
3. Pollution during power failures and other likely incidents should be included in the RACT study.
The RACT study assumes best-case scenario operations. It does not account for likely incidents such as power failures, leaks, fires, and explosions. While Figure 2 includes the VOC Potential to Emit of 0.4 tons per year from the diesel-fueled emergency generator, that number is a major underestimate because it excludes the excess emissions that occur when power loss or other operational failures cause the pollution control devices to go offline, leading to the release of raw, untreated, toxic gases into surrounding neighborhoods.
The diesel generator cannot prevent the ongoing emissions from the pyrolysis reactors: the un-cracked plastic inside the reactor continues to vaporize in the intense heat (between 800 and 1,100 degrees F) which the generator cannot cool down. Pumps and compressors that are knocked offline can no longer condense and move the volatile vapors and syngas into the storage tanks, and pressure can build up quickly. Depending on the status of the generator, the air pollutants may be flared off—incompletely combusting the VOCs and other toxic chemicals—or, when the flaring system fails, the pressure-relief valves vent the VOCs and hazardous air pollutants directly into communities to try and ward off an explosion.
4. The RACT study and stack testing data must be released to the public.
Redactions in the RACT study make it impossible to determine the adequacy of the study.
Table B-1 on VOC emissions data is redacted in four entire columns. The daily and annual feedstock throughput data is also redacted. This data is needed to understand how well Alterra’s current VOC control plans are working.
In addition, OEPA has not released the results from the stack testing that Alterra was required to conduct on May 22, 2026, for dioxins and furans, VOCs, and hazardous air pollutants. While a singular pre-announced stack test may underestimate more typical emissions levels, it is nonetheless a critical data set that the public needs to review in conjunction with the VOC RACT documents.
This information is in the public interest, and a proper analysis by the community is not possible without access to the data. The Ohio Revised Code (Section 3704.08) clearly states that “emission data” may not be classified as a trade secret and should be made available for public inspection. We ask that you make this data publicly available.
Recommendations
As detailed in our comments above, the RACT study is deficient and does not support OEPA’s determination that “the RACT study is sufficient to justify employment of an enclosed vapor combustion unit with a control efficiency of not less than 98%, by weight, for VOC…”
The vapor combustion unit efficiency was above 99% in Alterra’s stack tests and that should be required at a minimum, along with a revised RACT study that comprehensively considers NOx and VOC sources and the most effective methods to reduce these harmful emissions. This is required to ensure better protection of the health of infants, children, pregnant people, and other susceptible populations in Akron.
Thank you and please feel free to contact us with any questions.
Sincerely,
Becca Pollard
Executive Director
Buckeye Environmental Network
anaïs peterson
Lead Petrochemicals Campaigner
Earthworks
Cynthia Palmer
Senior Analyst, Petrochemicals
Moms Clean Air Force
Veena Singla, PhD
Affiliate, Program on Reproductive Health and the Environment
University of California, San Francisco*
*Institutional affiliation is included for identification purposes only and does not imply institutional endorsement or support
1 Alterra Energy, LLC. VOC RACT Engineering Study. March 2026. Available: https://scs-public.s3-us-gov-west-1.amazonaws.com/env_production/oid372/did200149/pid_215619/project-documents/AlterraDRAFT%20RACT_Full.pdf
2 United States Environmental Protection Agency (2020). Integrated Science Assessment for Ozone and Related Photochemical Oxidants. Available: https://www.epa.gov/system/files/documents/2026-06/isa_ozone_final-2020.PDF
3 Aguilera J, Konvinse K, Lee A, Maecker H, Prunicki M, Mahalingaiah S et al. Air pollution and pregnancy. Seminars in Perinatology 2023; 47: 151838.
Decrue F, Townsend R, Miller MR, Newby DE, Reynolds RM. Ambient air pollution and maternal cardiovascular health in pregnancy. Heart 2023; 109: 1586–1593.
Zhang C, Yang J, Wei J, Liu Y, Zhu H, Li X et al. Individual ambient ozone exposure during pregnancy and adverse birth outcomes: Exploration of the potentially vulnerable windows. Journal of Hazardous Materials 2024; 464: 132945.
Zhao Y, Qu Y, Huang X, Wu F, Sun S, Qin R et al. Ambient ozone exposure and pregnancy complications and adverse birth outcomes: A systematic review and meta-analysis. Environmental Research 2025; 270: 120996.
Rappazzo KM, Nichols JL, Rice RB, Luben TJ. Ozone exposure during early pregnancy and preterm birth: A systematic review and meta-analysis. Environmental Research 2021; 198: 111317.
4 United States Environmental Protection Agency. EJScreen: Environmental Justice Screening and Mapping Tool. Available: https://pedp-ejscreen.azurewebsites.net/index.html
5 United States Environmental Protection Agency. EJScreen: Environmental Justice Screening and Mapping Tool. Available: https://pedp-ejscreen.azurewebsites.net/index.html
6 California EPA (2009). California Environmental Protection Agency, Office of Environmental Health Hazard Assessment. Technical Support Document for Cancer Potency Factors: Methodologies for derivation, listing of available values, and adjustments to allow for early life stage exposures. http://oehha.ca.gov/media/downloads/crnr/tsdcancerpotency.pdf.
7 Alliance Technical Group. Source Test Report: Alterra Energy LLC. May 2022.
8 Goodson, et al. Assessing the carcinogenic potential of low-dose exposures to chemical mixtures in the environment: the challenge ahead, Carcinogenesis, Volume 36, Issue Suppl_1, June 2015, Pages S254–S296, https://doi.org/10.1093/carcin/bgv039
9 Alterra Energy, LLC. VOC RACT Engineering Study. March 2026. Available:https://scs-public.s3-us-gov-west-1.amazonaws.com/env_production/oid372/did200149/pid_215619/project-documents/AlterraDRAFT%20RACT_Full.pdf
10 Ohio Environmental Protection Agency. Draft Air Pollution Permit-to-Install and Operate: Alterra Energy, LLC. Permit Number: P0133062. April 2025. Available: https://ukozvhzgrcnkcatjqfoo.supabase.co/storage/v1/object/public/03-00-air-construction/2025_04_18_P0133062_Draft_Permit__6423_882a825f.pdf
11 Akron Regional Air Quality Management District. Letter to Alterra Energy, LLC re: Stack Test Results. March 5, 2024. Available: https://edocpub.epa.ohio.gov/publicportal/ViewDocument.aspx?docid=2764511
12 United States Environmental Protection Agency. ChemView search: Alterra Energy LLC. Sept 23, 2026. Available: https://chemview.epa.gov/chemview/
13 Alterra Energy, LLC. VOC RACT Engineering Study. March 2026. Available: https://scs-public.s3-us-gov-west- 1.amazonaws.com/env_production/oid372/did200149/pid_215619/project-documents/AlterraDRAFT%20RACT_Full.pdf
14 Peters DR, Mohr EJ, Padilla LE, Alvarez RA. Fenceline measurements reveal regional disparities in United States refinery benzene emissions and emission sources. Environ Res Lett 2026; 21: 074019.
Guo S, Wang Y, Wang P, Wang H, Sun X. Volatile Organic Compounds from the Oil and Gas Extraction and Processing: Emission Characteristics, Monitoring Technologies, Control Technologies, and Environmental and Health Impacts. Am J Environ Sci Eng 2026; 10: 82–92.
15 EPA ECHO. Detailed Facility Report: Alterra Energy LLC- e-Manifest Hazardous Waste History. Accessed Sept 24, 2026. Available: https://echo.epa.gov/detailed-facility-report?fid=110063893461
16 United States Environmental Protection Agency. RCRAInfo Biennial Report. https://rcrapublic.epa.gov/rcra-hwip/data-access/csv-downloads.
17 Eurofins. Analytical Report: Hebron Waste Streams- Waste Characterization. Jan 2025. https://edocpub.epa.ohio.gov/publicportal/ViewDocument.aspx?docid=4275562
Safety-Kleen. Waste Material Profile Sheet: Freepoint Eco-Systems, LLC. March 2026. https://edocpub.epa.ohio.gov/publicportal/ViewDocument.aspx?docid=4275580