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E-M:/ Public Comments needed.- City Medical Waste Incinerator
- Subject: E-M:/ Public Comments needed.- City Medical Waste Incinerator
- From: RobC313@aol.com
- Date: Fri, 30 Jul 1999 00:44:04 EDT
- List-Name: Enviro-Mich
- Reply-To: RobC313@aol.com
Enviro-Mich message from RobC313@aol.com
If the State will allow a source to rewrite their own standards than non of
us will ever be safe. Nearly two years after failing their mercury test (by
60 times the permitted limit) the City Medical Waste Incinerator in Hamtramck
Mi is having a public hearing to weaken the mercury standards. In fact I have
found at least 27 "really bad things" about the new pending consent agreement
that either weaken the standards or allow unnecessary endangerment of the
We need your voice in this struggle. Demand that this not be allowed. There
are safe alternatives to the incineration of medical waste .and the continued
operation of this facility will only serve to poison our environment while
discouraging source reduction and. separation.
The public hearing will be held in Hamtramck on August 25th and written
comments will be accepted up til then. Please help us close this
incinerator. Find an item of interest let me know and I'll provide background
information for your comments. Or if you want to review any of the documents
pertaining to the consent order you can find them on the MDEQ web site at
You can send written comments to the Department of Environmental Quality ,
Air Quality Division, PO Box 30260, Lansing MI 48909. If you would like more
details or like to participate in other ways please contact Rob Cedar by
phone, mail or e-mail. I would be glad to discuss this further.
Here are the 27 items arranged into four general categories of Standards,
Environmental health, Enforcement and compliance, and Economics and
Environmental Justice. Read them and share your outrage.
1) Raises emission limit for mercury by 183 times original permit
2) Allows unlimited time-frame for voluntary source reduction of mercury.
3) Reduces incentives toward source reduction by allowing substantial input
of mercury products and then relying on end of pipe reduction efficiency.
4) Relies on projections based on volunteer participation, symbolic pledges,
recommendations and moving targets from a variety of programs some
unrealistic in their goals
5) Assumes goals from Mercury Waste Management Plan (MWMP) that even the
company claims can not be met.
6) Relies on Fed MACT (Maximum Achievable Control Technology) level for
mercury with no mention of successful court challenge that declared the Fed
MACT to be "hopelessly irrational" by the federal appellate court in
Washington, D.C. "
7) Eliminates testing for arsenic, PCBs, Chromium (total and hex) and VOCs
8) Weakens standards for on sight storage of unprocessed medical waste. From
3 to 90 days
9) Weakens opacity standard from 5 to 10%
10) Allows operation of a source of carbon monoxide within an EPA
non-attainment area in spite of a record of numerous CO permit violations at
11) Ignores current data of accumulative urban air toxics in denying
potential health effects.
12) Ignores background and other sources of exposure including
bioaccumulation within a current and historically heavy industrial community.
13) Denies consideration of negative health effects to sensitive populations
common to area.
Economics and Environmental Justice
14) While admitting that "background levels already may pose a problem" and
that deposition impacts were "difficult to estimate", the consent order fails
to address Great Lakes fish advisories for mercury on Lake St. Clair a major
sport fishing lake and closest to the socio-politically and economically
depressed east side of Detroit.
15) Fails to consider or acknowledge the environmental justice facts related
to the location and effects of this incinerator. Down wind zip code is most
economically depressed zip code in Michigan.
16) Denies that operation of a 25 ton per day medical incinerator has
negative effect on property values in residential area directly across the
Enforcement and Compliance
17) Delegates enforcement authority to the same agency that they themselves
criticized for non enforcement.
18) Fails to assess monitory penalties proportionate to repeated violations.
Nor sufficient to deter further violations. .
19) Allows facility a release from all stipulations in the 1996 consent order
20) Admits Mercury Waste Management Plan MWMP falls short of ensuring mercury
reduction yet projects compliance on the success of the same plan.
21) Allows for long delays in testing..
22) Acknowledges that that improper operations and maintenance caused the
majority of the violations while ignoring that these factors have remained a
constant over the 8 years of operation. They naively act as though proper
operation and maintenance are a new idea being tried for the first time. The
1996 consent agreement abounded with maintenance and operations procedures.
23) Allows for unlimited delays of test dates for preparation and fine tuning
of incinerator immediately prior to required test dates.
25) Calls for a malefaction abatement plan that emphasizes downtime
minimization over preventing equipment failure.
26) Suggests State Law mandates DEQ accept companies voluntary agreement
27) Sets a dangerous precedent for the operation of other medical waste
incinerators operating within the state.
So there's the tidy 27, let me know your plans. If you can attend the Aug
25th hearing but need help with transportation let me know and well work on
car pools or cost deferment. If you can't attend then please send written
Thank You for your interest and help
HEAT- Hamtramck Environmental Action Team
Hamtramck, Mi 48212
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