EPA Superfund Docket Center

WJC West Building, Room 3334

1301 Constitution Avenue NW
Washington, DC 20004
December 4, 2022
EPA-HQ-OLEM-2017-0610-0012
To whom it may concern,
The community of Census Tract 4056, more commonly known as “The Bottoms,” has come
together to recommend the U.S. Environmental Protection Agency (EPA) to include the Tantine
Incinerator on the National Priority List (NPL). The non-profit, Rock Bottom Revival, is
committed to accurately and efficiently identifying hazards and pollution within Census Tract
4056’s four-square-mile radius. The Tantine Incinerator is an active pollutant-generating facility
within this small community, and the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA) requires that the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) include a list of national priorities among the known releases or
threatened releases of hazardous substances, pollutants, or contaminants throughout the United
States. The EPA’s choice to include the Tantine Incinerator will directly impact the community
of The Bottoms, ensuring the strongest possible protection of human health consistent with the
EPA’s overall mission.
The community of The Bottoms contains the Tantine Incinerator, which processes 250,000 tons
of waste per year. A proposal has been submitted to the State of North Carolina for the Tantine
Incinerator to expand its capacity to include another 180,000 tons of waste per year, which
would include hazardous medical waste from several county hospitals. Bountiful County, where
The Bottoms is located, has 3 additional issued permits with a total annual permit capacity of
750,000 tons per year. The Bottoms facilitates over half the capacity of 3 other facilities
combined in the four-square-mile area. With the additional capacity being considered for the
Tantine Incinerator, The Bottoms would handle 86% of what is permitted overall in Bountiful
County’s 191 square miles. What this ultimately means is that Bountiful County is 47.75 times
larger than The Bottoms and only facilitating 14% more of the commercial waste operations.
There is currently pollutant being discharged into the river that runs through this community
from these facilities. These further investigations will allow the EPA to assess the nature and
extent of public health and environmental risks associated with the site and to determine what
CERCLA-financed remedial action(s), if any, may be appropriate.
The local doctor has come forward reporting increases in respiratory illnesses in both adults and
children in the area. The increases have continued to consistently increase since he began seeing
patients in the Bottoms in the last decade. Knowing this, in order to best serve the community,
Rock Bottom Revival began working closely with Dr. Melissa Troester and the University of
North Carolina’s Center for Environmental Health and Susceptibility. Dr. Troester and her team
have assisted Rock Bottom Revival in identifying environmental pollutants present in The
Bottoms that currently affect the residents. In preliminary testing, the experts found serious soil
contamination, including the presence of PCBs, lead, and mercury at the Tantine Incinerator. Our
experts advise that the site would most certainly be at or above the Hazardous Ranking Score
(HRS) used by the EPA. The revised HRS evaluates four pathways: Ground water, surface
water, soil exposure and air. With the Tantine Incinerator located on the central and only
waterway in The Bottoms, an official HRS evaluation is pertinent to help determine the urgency
of investigations. A sufficiently high score on the HRS is one of three mechanisms for placing a
site on the NPL for possible remedial action (see 40 CFR 300.425(c) of the NCP). We have also
filed a complaint through the proper channel on the EPA's website. By adding the Tantine
Incinerator to the NPL, the EPA could further determine if the site warrants further investigation.
We are appreciative of the opportunity to provide public input and we look forward to continuing
to participate in such opportunities in the near future. Please do not hesitate to contact us with
any questions regarding these comments.
Sincerely,
Kari Michael
Founder, Rock Bottom Revival
karimichael@vermontlaw.edu