By: Rachel Meyer, Ohio River Valley Field Organizer, Moms Clean Air Force
Date: November 25, 2025
About: EPA’s Proposed Rule for Hazardous Air Pollution from Hazardous Waste Combustors, Docket ID No.: EPA-HQ-OAR-2004-0022
To: U.S. Environmental Protection Agency
My name is Rachel Meyer, and I am the Ohio River Valley Field Organizer for Moms Clean Air Force. I live in Beaver County, PA. My family’s home is about ten miles from the East Liverpool, OH Arcwood Environmental (formerly called Heritage Thermal Services) hazardous waste combustor. Families like mine are in danger of negative health impacts from hazardous waste combustors. The EPA must strengthen the proposed emission standards for hazardous air pollution from these incinerators.
The emissions are linked to elevated risk of lung and heart diseases, neurological disorders, cancers, and other health harms. Living near incinerators is especially dangerous for children. We know that, relative to their body weight, children inhale more air than adults causing them to take in more pollutants such as lead which can have devastating effects on children’s development. Even before birth, children can suffer impacts from hazardous waste combustors from pollutants such as mercury.
The Arcwood hazardous waste combustor burns PFAS. PFAS incinerators are known to release PFAS and its byproducts, which travel far distances through the air. Exposure has been linked with harmful health effects in humans, including decreased fertility, cancer, liver damage, thyroid problems, immune effects, and cholesterol changes. Because babies’ and children’s bodies are still developing, they may be more sensitive to PFAS. I worry about how the pollution from this combustor is affecting my daughter and all the children in the area.
Other emissions from hazardous waste combustors include particulate matter, sulfur dioxide, hydrogen chloride, nitrogen oxides, carbon monoxide, cadmium, and dioxins and furans. All of these pollutants need to be strictly regulated and monitored, and the proposed rule does not go far enough.
The EPA should require stricter limits on pollutants using the Clean Air Act’s required minimum stringencies as a baseline – and then considering “beyond the floor” measures, and should require fenceline monitoring to track what chemicals and amounts of chemicals are traveling into the surrounding areas. Hazardous waste combustors are often within highly polluting petrochemical facilities adding to the burden of communities already facing a high level of industrial pollution. Any community near a hazardous waste combustor should be able to know what they are being exposed to. Fenceline monitoring is an important tool with which to improve industry accountability.
The proposal’s claim that the use of additional pollution control technologies is not cost effective needs to be reexamined. The costs of prevention may be much more affordable to companies than the health care costs taken on by the surrounding communities if the pollution is not controlled.
EPA must strengthen the proposed emission standards for air pollution from hazardous waste combustors and require more expeditious compliance. A deadline of three years while communities are exposed to unsafe levels of toxic pollution is too long. My family and many others are waiting.
Thank you