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E-M:/ Public Comments needed.- City Medical Waste Incinerator



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Enviro-Mich message from RobC313@aol.com
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 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 
publics health

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 
http://www.deq.state.mi.us/aqd/permits/cwerp.html.

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.

Standards 
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%


Environmental Health
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 
this facility. 

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 
street. 


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 
comments.

Thank You for your interest and help

Rob Cedar
HEAT- Hamtramck Environmental Action Team
1999 Trowbridge
Hamtramck, Mi 48212
313-365-4722

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