[Date Prev][Date Next][Date Index]
E-M:/ Citizens get Big Win on Tire Burning in Cadillac and Hillman
- Subject: E-M:/ Citizens get Big Win on Tire Burning in Cadillac and Hillman
- From: "Alex J. Sagady & Associates" <email@example.com>
- Date: Wed, 28 Mar 2001 14:34:18 -0500
- Delivered-To: firstname.lastname@example.org
- Delivered-To: email@example.com
- List-Name: Enviro-Mich
- Reply-To: "Alex J. Sagady & Associates" <firstname.lastname@example.org>
MDEQ Air Quality Division turns down tire burning
without scrubbers in Cadillac and Hillman in Michigan
for two existing major stationary sources.
Similar letter for Hillman denial....
I'm proud to have served as a technical consultant
to this group's efforts....
Dear Interested Party:
- March 28, 2001
This letter is in reference to Cadillac Renewable Energy’s (CRE) Permit
to Install application No.373-86D, which proposed to add 6,250 pounds per
hour of tire-derived fuel (TDF) as a supplemental fuel at the existing
wood-fired power plant located at 1525 Miltner Avenue, Cadillac,
Michigan. After careful consideration of the issues and pursuant to
the delegation of authority from the Director of the Department of
Environmental Quality, I have denied the permit application.
In the permit application, CRE proposed a fuel change that would increase
the emission of several air contaminants, including sulfur dioxide and
sulfuric acid mist. My decision to deny the CRE permit application
is based largely on the failure of CRE to include a plan to install
additional control technology to reduce these additional emissions.
In particular, it is my decision that the permit application does not
meet the standard of Best Available Control Technology (BACT) that is
required by federal air pollution regulations. The BACT analysis
presented as justification for the absence of control failed to address
all of the potential impacts and costs associated with the proposed
emission increase. Control of sulfur dioxide often provides the
benefit of limiting other impacts to the environment. The absence
of control in the CRE proposal provided no such corresponding
In the case of CRE’s proposal, I have determined the use of a scrubber is
appropriate for the control of emissions generated by the use of 6,250
pounds per hour of TDF as a supplemental fuel. Both wet scrubbers
and dry scrubbers are proven technologies for air pollution control and
are readily available for use. Based on current practice, the
installation and operation of a scrubber to control emissions of sulfur
dioxide and sulfuric acid mist would also reduce emissions of particulate
matter and hazardous air pollutants known to be present in the exhaust
gases from wood-fired boilers using TDF as a supplemental fuel.
In addition to the need for the installation of a scrubber, the permit
application has been denied for several technical deficiencies. It
is my determination that the permit application is deficient regarding
the following information:
During the technical review of the permit application, the Air
Quality Division (AQD) also evaluated the available information on the
proposed increase in emissions and the impacts on air quality.
Protection of public health is the first priority of the AQD. That
assessment did not find compelling evidence that the emissions would
cause environmental damage or unacceptable public health risks.
- 1. The
applicant has not conducted a proper top-down BACT analysis for control
of particulate matter emissions.
- 2. The
top-down BACT analysis for control of sulfur dioxide and sulfuric acid
mist emissions lacked sufficient detail to clearly substantiate the
elimination of various control alternatives for technical or cost
- 3. The
applicant has not performed a complete additional impacts analysis for
all regulated pollutants as required under 40 CFR
- 4. The
applicant has not considered the ability of the control alternatives to
control hazardous air pollutants as required in a BACT
- 5. Sufficient
data concerning potential emissions of polychlorinated dibenzodioxins and
furans and the associated health and environmental impacts are not
included in the application.
- 6. Significant
concerns were expressed during the comment period about the ability of
the CRE facility to demonstrate compliance with Michigan Air Pollution
Control Rule 901, which prohibits emissions that cause unreasonable
interference with the comfortable enjoyment of life and property.
There is insufficient information concerning the quantity and composition
of emissions from the CRE facility related to odors and particulate
fallout to address the Rule 901 concerns.
Finally, based on a review of past decisions of the Environmental Appeals
Board, it is my determination that a decision to issue Permit to Install
No. 373-86D would, if appealed, likely result in the permit being
remanded to the AQD for correction of these deficiencies. An
additional public comment period would then be required for review of
changes to the permit. It is in the best interests of all parties
that the present permit application be denied, thus avoiding unnecessary
appeals and the associated costs and delays inherent in that
The decision to deny an application does not prejudice CRE’s right to
submit a new, complete application when the above information is
If you have any questions, please contact Ms. Lynn Fiedler, at
517-373-7087, or Ms.Mary Ann Dolehanty, at 517-373-2098, of our staff, or
you may contact me.
- Dennis M. Drake, Chief
- Air Quality Division
cc: County of Wexford
Miller, EPA, Region V
Denman, District Supervisor
Alex J. Sagady & Associates
Environmental Enforcement, Permits/Technical Review, Public Policy
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)