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Re: E-M:/ Sewer Sludge Incinerator Permit Comments



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Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>
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On the issue of the Minergy Sewage Incinerator (a subsidiary of
those WEPCO guys ....Wisconsin Electric Power Company), folks should
take note that the Minergy plant would be built where the old
Detroit Coke plant used to be.

The Detroit News reported a couple of days ago that someone wants
to build a new 600 million dollar suspension bridge very near to
this location.  The map on the article showed it to be very close
to the Detroit Coke site.

Wouldn't it be just appropriate that the first thing that visitors
to the United States would see would be this sludge incinerator as
they arrive in the US on the new bridge?

One issue you may want to investigate is to determine whether
Minergy is benefitting from the relaxation of air toxics rules
passed under the Engler Administration at the request of Dow Chemical
that allowed airborne carcinogens to be considered at 1/10th the
potentcy in industrially zoned areas as compared to residential areas.

Everything near there between West Jefferson and the River is in
industrial zoning.  Prior to this rule, if a source was "ambient
air toxics limited" because predicted ambient impacts in industrial
areas exceeded screening levels, they would have to cut their
emissions in ways that would also reduce exposure in residential
areas that were further from the plant.  However, under the new rule,
if the location of maximum ambient impact of an airborne carcinogen
falls in an industrial zoned area, they can consider that exposure
against a screening level that is ten times higher than would be
considered for a residential area.  This means that they would not
have to cut emissions.

If the new bridge is a sure thing, you'll want to give those
Air Quality Division air quality modellers a workout by filing comments
saying that the elevated bridge location should be protected as
a non-industrial exposure residential area.

Also, you'll want to press on the issue of airborne deposition of
toxicants into the Detroit river, you'll want to find out what happens
to the mercury contaminated air pollution control equipment sludge and
you'll want to figure out what happens to sludge drying emissions when
the plant goes down and can't burn them up.

It would also be useful to start working with the Canadian enviros
on this obvious trans-border air pollution source.

At 03:55 PM 05/29/2001 -0400, you wrote:
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>Enviro-Mich message from RobC313@aol.com
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>
>The Minergy Permit Documents are available on the MDEQ website at:
>
>http://www.deq.state.mi.us/aqd/permits/cwerp.html
>
>Comment Period; May 29th to June 29th
>Public Hearing: June 29th. The Friday Before the July 4th Holiday!
>
>They call them municipal wastewater solids.
>We call it SEWER SLUDGE !
>
>They call it a glass aggregate facility.
>We call it a SLUDGE INCINERATOR!
>
>They said it would replace the old sludge incinerator.
>We say the old incinerator will continue operation!
>
>They said it would reduce toxins by 90%.
>We say it would add toxins to an already over exposed community!
>
>We know that if Minergy builds this sludge incinerator they will be allowed
>to import sludge from out of state and from out of the country.
>
>We need to tell them that we do not want Wayne County to become the Midwest
>or Great Lake's dumping ground.
>
>They are holding a public hearing for all interested parties.
>We had better tell them we're very interested!
>
>They are allowing a 30-day comment period before issuing the permit
>We need to study the permit draft and tell them what we think.
>
>If you or your organization is interested in becoming active in this
>important Issue please reply and perhaps we can coordinate our efforts
>
>Thank you for your interest,
>Rob Cedar
>HEAT- Human Environmental Action Team
>AKA
>Hamtramck Environmental Action Team
>
>
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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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