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July 13, 2001
for immediate release
NO MORE INCINERATORS IN SOUTHEAST MICHIGAN
The Citizens Environment Alliance has requested that the Michigan
Department of Environmental Quality (MDEQ) reject a permit to build yet
another incinerator in Detroit. “We’ve got to end southeast
Michigan’s love affair with incinerators,” said Shawn Hupka President of
the Citizens Environment Alliance. The Alliance is a bi-national
organization with members in both metro-Detroit and Windsor,
Ontario.
Minergy Detroit, LLC, the proponent of the new incinerator, has suggested
that this will be a less polluting facility than the one that currently
burns Detroit’s municipal wastewater sludge. Consider:
1) 150 lbs. of mercury can be emitted per year from the proposed
facility;
2) 637.1 tons of coal can be burnt per day by the proposed
facility;
3) 662.4 tons of municipal wastewater solids (sludge) can be burnt per
day by the proposed facility;
4) There is no guarantee that the current Detroit wastewater solids
(sludge) incinerator will be decommissioned;
5) Minergy has the option of bringing in sludge from other treatment
plants;
6) Appropriate air pollution control devices (carbon absorption) are
deemed to be not cost effective, and
7) Without proper controls large amounts of heavy metals, polychlorinated
dibenzofurans, dioxin and other harmful pollutants will be routinely
released into the Detroit River ecosystem.
In its submission, the Citizens Environment Alliance wrote: The MDEQ
has stated that the best available pollution control technology is not
cost effective. It is unacceptable that public health impacts are
“acceptable risks” while diminished profit, the result of best available
control technology, is the deciding factor for the use of carbon
injection controls. That this position is promulgated by a state
environmental regulatory agency is unconscionable.
“If the MDEQ doesn’t prevent this environmental disaster, we’ll be
looking at other options that will help to protect public health and our
environment,” said Hupka. “In the least, the US Environmental
Protection Agency and Environment Canada need to investigate and take
action.”
Contact: Shawn Hupka at (519) 973-1116
(letter enclosed below)
Ms. Lynn Fiedler
Permit Section Supervisor
Michigan Department of Environmental Quality (MDEQ)
Air Quality Division (AQD)
P.O. Box 30260, Lansing
Michigan, 48909
Telephone: (517) 373-2856
Fax: (517) 373-1265
Ms. Fiedler,
Re: Minergy Detroit LLC, Detroit Michigan Proposed Permit
Number 175-00
The Citizens Environment Alliance of southwestern Ontario &
southeast Michigan (CEA) has concerns with the proposed permit for the
Minergy Detroit LLC Sewage Sludge Incinerator. Issuing this permit is not
in the best interest of the residents southwestern Ontario nor southeast
Michigan; the permit application should be dismissed.
The CEA views all new sources of persistent toxic substances to the
Detroit River Area of Concern (AOC) as a violation of the General
Principles of Annex 12 of the Great Lakes Water Quality Agreement: “the
philosophy adopted for control of inputs of persistent toxic substances
shall be zero discharge …” Specific emissions of concern include lead,
mercury and dioxin.
In a United States Environmental Protection Agency (US-EPA) draft plan
entitled Great Lakes 2001: A Plan for the New Millennium, the EPA
has established a target for a 50% reduction nationally in the release of
mercury from sources resulting from human activity. The EPA also
established a target for 75% reduction nationally in total releases of
dioxins and furans from sources resulting from human activity.
Permitting the Minergy Detroit LLC Sewage Sludge Incinerator will
certainly impede the achievement of these goals.
Since Detroit wastewater sewage has not been test-burned in a facility
similar to the one proposed by Minergy, the pollution control data
provided to the public is dubious. The data that has been submitted
in MDEQ-AQD documents also lacks context. For example, mercury
already is a contaminant of concern in the Detroit River AOC. Yet
assurances are made in the MDEQ Questions and Answers Document (dated
June 28, 2001) that allowing this facility to emit mercury and other
persistent toxic substances will not significantly add to the
environmental degradation of the Detroit River AOC. This contention
is beyond rational belief.
The Questions and Answers Document prepared by the MDEQ-AQD also focuses
on the potential impacts of mercury contamination to the Lake St. Clair
recreational fishery, ignoring the recreational fishing that occurs
throughout the Detroit River and western basin of Lake Erie.
Certainly, prevailing wind patterns will ensure that mercury emissions
will have a geographic impact beyond Lake St. Clair.
Further, the Questions and Answers Document also states that the best
available pollution control technology is not cost effective (Best
Available Control Technology-3.) It is unacceptable that public
health impacts are “acceptable risks” while diminished profit, the result
of best available control technology, is the deciding factor for the use
of carbon injection controls. That this position is promulgated by
a state environmental regulatory agency is unconscionable.
To summarize, contentious issues include:
1. 150 lbs. of mercury can be emitted per year;
2. 637.1 tons of coal can be burnt per day;
3. 662.4 tons of municipal wastewater solids (sludge) can be burnt per
day;
4. There is no guarantee that the current Detroit wastewater solids
(sludge) incinerator will be decommissioned;
5. Minergy has the option of bringing in sludge from other treatment
plants;
6. Appropriate air pollution control devices are deemed to be not cost
effective;
7. Without proper controls large amounts of heavy metals, polychlorinated
dibenzofurans, dioxin and other harmful pollutants will be routinely
released into the Detroit River ecosystem;
8. The proposed permit lacks relevant context, ie. it does not consider
the heavy burden of pollution endured by southeast Michigan and
southwestern Ontario.
Not only does the permit allow for unacceptable emissions of toxic
pollutants, it invites Minergy to import wastewater sludge from
surrounding municipalities. Possible sludge “importation” coupled
with no commitment to decommission the existing Detroit wastewater sludge
incinerator implies that incinerators are seen as a welcome industry in
southeast Michigan; they are not!
The permit process is far too myopic to consider the context in which the
Minergy proposal exists. However, the CEA does expect the MDEQ, as
well as all signatories, to abide by the principles of the Great Lakes
Water Quality Agreement. As such, the MDEQ must reject this permit
proposal.
Sincerely,
Shawn Hupka
President
cc. Kim Ferguson, Supervisor, Ontario Ministry of Environment, Windsor
Ontario
Telephone: (519) 254-7098 ~ Fax: (519) 254-5894
Robert Miller, Section Chief Michigan Permitting Section, United States
Environmental Protection Agency, Region Five Air and Radiation Division,
Chicago Illinois
Telephone: (312) ~ Fax: (312) 886-0617
Esther Bobet, Manager, Air & Inventories Division, Environment
Canada, Ontario Region Environmental Protection Branch, Downsview
Ontario
Telephone: (416) 739-5880 ~ Fax: (416) 739-4251
Citizens Environment Alliance of southwestern Ontario and southeast
Michigan
P.O. Box 548, Windsor, Ontario, N9A 6M6, Canada
phone: (519) 973-1116 -- fax: (519) 973-8360
http://www.mnsi.net/~cea/
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