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E-M:/ Dow Chemical Hazwaste Incinerator



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Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>
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Dow Chemical is seeking a permit to build a
new hazardous waste incinerator up in Midland.  This
application deserves some review from Michigan
enviro's concerned about toxic emissions.  Comment
deadline is August 22.  An informational hearing and
then public hearing will be held on August 15  (don't
make the mistake of providing public comments only during
an MDEQ "informational meeting"....you must raise comments
during the public hearing or by writing by the comment
deadline to ensure such comments are actually considered.)

See for details (look for Dow Chemical):

http://www.deq.state.mi.us/aqd/permits/cwerp.html

Someone ought to figure out the effect of the court
remand that the Sierra Club won on the federal
emission standards for hazardous waste combustors on
the setting of emission limitations for this plant.

The federal standard (brought to you by Bill Clinton and Carol
Browner) featured a chlorinated dioxin limitation that reflected
the worst performing hazardous waste incinerators in
the United States.  The proposed limitation for the Dow
plant is set to be equal to that standard.  Under Michigan
rules, the source can escape control technology review
if there is no federal maximum achievable control technology
standard.  However EPA published such a standard, but
the Sierra Club got it overturned last month.  As a result,
someone ought to figure out if there is a good basis for
arguing that this proposed facility be subject to a review for
best available control technology for toxics under state
law in view of the federal developments.

MDEQ didn't put ambient impacts for chlorinated dibenzo dioxins
in their ambient impact table....that strikes me as odd.

On this permit, Dow may be benefiting from a Dow-sought/Engler-
Harding granted rules change allowing 10 times higher concentrations of
airborne carcinogens to occur around such facilities and still be
considered one in a million risk if there is industrial zoning.






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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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