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E-M:/ EPA Heats up Cadillac Tire Burning Issue

Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>

EPA-Region V just released its comments to
MDEQ Air Quality Division concerning the
proposed tire-derived fuel burning permit for Cadillac
Renewable Energy

Here are some snippets....I've got full text if anyone wants it,
but I'm still working on my comments  so I won't be checking email
until after about 3-4 pm....

It turns out also that MDEQ is relaxing carbon monoxide control requirements
by allowing compliance to be determined on a 24 hour average
rather than 8 hour average.  This allows the facility more latitude to
operate with poor combustion during wet wood conditions without violating
its permit.....

"It is the USEPA's belief that the applicant has not performed an 
appropriate Best Available Control Technology (BACT) analysis. "

"The applicant has not conducted a proper top-down BACT analysis for 
control of particulate matter emissions (PM-10)"

"The applicant should further consider the feasibility of a semi-dry 
scrubber with the existing or an improved electrostatic precipitator for 
control of SO2."

"The applicant should further consider the technical and cost feasibility 
of a wet scrubber."

"Finally, the Purchase Equipment Cost (PEC) for a wet scrubber for the 
Champion International Facility (Courtland Alabama) is documented as 
costing approximately $600,000.  The Champion International facility is a 
very similar 50 MW wood waste and tire burning facility permitted to burn 
approximately 40 percent tire on a BTU basis (16% tires by weight).  Where 
controls have been effectively employed for similar sources, the economic 
impact of such controls on the particular source under review should not be 
nearly as pertinent in the BACT decision making process.  Further, where 
there are severe discrepancies in the PEC of controls applied to similar 
sources and the source under review, the applicant must document reasons 
for the significant cost differences."

"The applicant has not performed a complete additional impacts analysis."

"The applicant must consider the toxic emissions of unregulated pollutants 
as part of the BACT analysis."

"The permit should contain short-term emission limitations for all PSD 
emissions limitations"

Looks like Tamra Van Till from EarthTech, the consultant
for Cadillac Renewable Energy, has her work cut out for her....

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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