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Re: Fw: E-M:/ MSU's Proposed Carcass Incinerator

------------------------------------------------------------------------- Enviro-Mich message from "Alex J. Sagady & Associates" ------------------------------------------------------------------------- At 09:14 AM 08/01/2000 -0400, you wrote:

I don't know the implications of "radioactive animals" being incinerated (and it appears that you are not sure as well).  My guess is that if it were a health danger, any site on MSU campus would be a problem including the current incinerator.  Winds effects would certainly greatly outweigh a few mile change in location.  My conclusion would thus be that this change in location would not effect the farm animals.  But why don't you call and ask someone in the planning group that would know for sure.  It seems that many e-mail messages go out without the e-mailer (you in this case) checking the facts and trying to make some input.  It seems to me that it is careless and irresponsible to frighten people with e-mail messages like this one, when it is obvious that you have not checked with MSU first to get the details.

This is a regulatory issue that should be handled by MDEQ
before any permit is granted.  Unfortunately, MDEQ has
tried to avoid doing risk assessment on airborne radionuclide sources
in the past.

The risk from airborne radionuclides released from incinerating
radioactive research animals depends on the amount released,
the specific radionuclides released and their half-life, and the
stack gas exit conditions (i.e. stack height, exit velocity,
temperature, etc.).   When it comes to evaluating the source
receptor relationships and how such relationships affect predicted
exposure in non-inhalation risk assessment, the location of the
source near farm and forage areas will be very important.  The
proposed location of the new incinerator is directly adjacent to
these farm and forage areas.  The current incinerator location is
further away.

The university has not yet publicly acknowledged its intent to
burn radioactive test animals at this site, but the decision to
do so is implicit in their announcement to shut down their
existing waste incinerator that does do such disposal.

Depending on the half life of the radionuclides in question, the
residual risk could be very low.  It could even be well below
risks associated with the release of radionuclides from traditional
combustion sources (i.e. release of Carbon 14, uranium and radium from
coal and other power plants).  However, another result may also be true
as well, depending on the waste management practices involved.

My point is that glossing over all of this without doing the analysis
and assessment means that the proposed facility will not be properly evaluated for its public health and environmental impacts.   The public
should have a right to this kind of information and analysis, which has
not yet been provided.   My posting is an attempt to prod the agencies
and MSU on that point.

I do know that the issue of segregating animals has been discussed, and appropriate measures have been put into the plan.

* Stanley J. Moore                      *
* MSU CED Antrim County                *
Antrim County Building, P.O. Box 427  *
Bellaire MI 49615                     *
Phone:231-533-8818                    *
Fax:231-533-8392                      *


Alex J. Sagady & Associates        Email:  ajs@sagady.com

Environmental Enforcement, Permits/Technical Review, Public Policy and
Communications on Air, Water and Waste Issues
and Community Environmental Protection

PO Box 39  East Lansing, MI  48826-0039 
(517) 332-6971 (voice); (517) 332-8987 (fax)
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