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E-M:/ Holnam's disappearing VOC emissions....



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Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>
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Tonight's "ranting and raving" concerns the Holnam Cement 
Plant in Monroe County......

Curiosity finally got the better of me in regard to Holnam tire burning....
Holnam
is one of these foreign-owned corporations taking over United States basic
industry and they run the plant South of Dundee next to U.S. 23.    Presently
they are seeking to burn large numbers of tires at this cement plant.....

Holnam's environmental staff must practice some kind of pollution 
disappearing act.   MDEQ's air emission inventory web site reports 0.00 tons per
year of volatile organic compounds, which should reflect a company report to 
MDEQ.    

Yet, Holnam did a stack test showing over 800 pounds an hour of total 
gaseous organic compounds burning their usual fuel and over 700 pounds per
hour of total gaseous organic compounds burning a mix of tires and their
usual fuel.  This would be equivalent to over 3000 tons of these compounds
per year.   

The proposed permit would allow up to 7,217 tons per year of volatile organic
compounds.   Why MDEQ would allow over twice as much VOC as a permit
limit compared to what was measured in a stack test also boggles the brain...

Either of these emission amounts would easily make this plant the largest 
volatile organic compound source in Michigan.... much larger than any 
of the auto plants....  far larger than the VOC emission report for 
the other large cement plant in Michigan, Lafarge up in Alpena.

It is also in a location which is directly upwind of Southeastern Michigan
under general SW winds and at a distance likely to produce significant
ozone formation by the time the plant's emission reach more populated 
areas in the SE Michigan Region.

The 7,217 tons per year figure would make this plant the 23rd 
largest volatile organic compound source in 
the United States (comparing this number to the results from 
EPA's  AIRSWEB.

Despite the presence of large amounts of  potential dioxin precursors in 
the stack gases, MDEQ Air Division must have been in a "generous"
mood to allow the company to conduct a tire trial burn stack test without
testing 
for the highly toxic chlorinated dibenzo-dioxin emissions.   They were 
also allowed not to test for the toxic metal vanadium which is frequently
found in 
high concentrations in the petroleum coke which the plant burns.

MDEQ AQD's staff report by Asad Khan tries to explain away the possibility of 
dioxin formation by the temperature of the flue gases being below 
a threshold (by the company using dilution air in the stack gas...."the 
solution to pollution is dillution").   This ignores at least some 
experience with hazardous waste combustion in cement kilns whereby 
dioxin formation occurs in a few cases below the temperature windows
mentioned in the MDEQ staff report.

The high VOC emissions, which likely include the carcinogens formaldehyde
and acetaldehyde, also explains why this plant stinks so bad when you 
are downwind.   The emissions are very irritating.

Someone should go and  look at the Title V clean air act operating permit
application for this plant and see if the company coughed up information
about the likely hazardous air pollutants from this plant or whether these 
figures were low-balled.   I

A report of 0.00 tons per year of VOC emissions for Holnam (if
this properly reflects what they reported and is not an MDEQ
error in their database) should prompt a 
proposed notice of violation, but don't expect to MDEQ to issue one.
Under Russ Harding, the vast majority of clean air enforcement is being 
done by EPA Region V..   This is the Engler policy....  let the Chicago
guys do it when it comes to enforcement, but we'll collect permit fees 
which are supposed to finance inspection and enforcement efforts.












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NEW EMAIL ADDRESS!!!            ajs@sagady.com
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Alex J. Sagady & Associates        Email:  ajs@sagady.com
Environmental Consulting and Database Systems
PO Box 39  East Lansing, MI  48826-0039  
(517) 332-6971 (voice); (517) 332-8987 (fax)



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