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E-M:/ RE: / Citizens get Big Win on Tire Burning in Cadillac and Hillman



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Enviro-Mich message from "Savoie, Kathryn" <KSavoie@accesscommunity.org>
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Congratulations to all involved on a victory for clean air! 

Kathryn Savoie, Ph.D.
Environmental Program Director
ACCESS
(313) 843-2844
Ksavoie@accesscommunity.org <mailto:Ksavoie@accesscommunity.org> 


	-----Original Message-----
	From:	Alex J. Sagady & Associates [SMTP:ajs@sagady.com]
	Sent:	Wednesday, March 28, 2001 2:34 PM
	To:	enviro-mich@great-lakes.net; air-mail@igc.topica.com;
conS-EQST-AIR-QUAL-FORUM@LISTS.SIERRACLUB.ORG
	Subject:	E-M:/ Citizens get Big Win on Tire Burning in
Cadillac and Hillman

	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....
	
	Alex Sagady
	Environmental Consultant
	===================
	


				March 28, 2001
				
				
				
				

	Dear Interested Party:
	
	
	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
benefit.
	
	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:
	


		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 feasibility reasons. 
		3.      The applicant has not performed a complete
additional impacts analysis for all regulated pollutants as required under
40 CFR 52.21(o). 
		4.      The applicant has not considered the ability of the
control alternatives to control hazardous air pollutants as required in a
BACT analysis. 
		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.
		
		

	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.
	
	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 process.
	
	The decision to deny an application does not prejudice CRE's right
to submit a new, complete application when the above information is
available.
	
	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.
	

				Sincerely,
				
				
				
				
				
				
				Dennis M. Drake, Chief 
				Air Quality Division 
				517-373-7023
				
				
				
				

	DMD:LF:PK
	Enclosure
	cc:     County of Wexford
	        City of Cadillac
	        Mr. Robert Miller, EPA, Region V
	        Ms. Janis Denman, District Supervisor
	
	
	

	
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	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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