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Re: E-M:/ RE: / Dearborn Air Pollution

Enviro-Mich message from "Alexander J. Sagady" <ajs@sagady.com>


My understanding of this area is that there are two
schools nearby....an elementary and a middle school.
I have a call in to the school's plant engineer to find out
when the soccer field construction was completed/when
they spread the straw I observed the other day which would eliminate any 
particulate emissions for the field right around the air monitoring

Although diesel exhaust from construction equipment
contains PM 2.5, I would not expect more than a small percentage of the 
fugitive dust from the soccer field earth movement to be 2.5 microns or 
less.   We'll have to track whether MDEQ intends to discount what, if any, 
data that was accumulated over the summer showing high PM 2.5 concentrations.

MDEQ operates several air quality monitors at this site
as well as a meteorological tower.   There are monitors
which are considered as "federal reference method monitors"
and there are continuous PM 2.5 monitors which are "tapered
element oscillating microbalance" (TEOM) monitors which provide data
continuously to MDEQ's website.

It turns out that the 24 hour average for PM 2.5 at
the Salina School monitor in Dearborn ending at 8 AM
this morning  (detected by the TEOM monitor) is 54.1 micrograms per cubic 

Comparing this TEOM instant air pollution monitoring result
with the federal reference method data reporting.... which is
not a completely  fair comparison because the monitoring methods
are different.... This most recent 24 hour average would have been the 
second highest 24 hour average recorded in the time period of years 1999 
through 2003.... the highest being 57 micrograms/cubic meter in that time 
period measured by a federal reference method.   Although this is less than 
the federal ambient air quality standard for 24 hour averages, that 
standard doesn't protect public health given recent PM health study results.

In the last hour of data recorded this morning, they have had another
1 hour PM 2.5 93 microgram/cubic meter spike at the Salina monitor.

You can see this as it happens at http//www.deq.state.mi.us/aqi/PM.asp

MDEQ's air quality index is showing "unhealthy for sensitive groups" for 
Dearborn at this hour   http//www.deq.state.mi.us/aqi/AQI.asp   ...the 
worst air quality in Michigan at this hour at the Salina School Dearborn site.

I think they run the federal reference method monitors only
every third day for a 24 hour period at Dearborn, so that has to be taken 
into consideration when considering/comparing the FRM monitoring results.

Frankly, I think this site is a real good candidate for operating
FRM monitors every day instead of every 3rd day.   The only other PM 2.5 
federal reference method monitor in Wayne County that is
operated nearly every day is the monitor on Linwood Street
in Detroit.   The Linwood monitor with everyday monitoring
shows lower (but still violative) annual averages than the
annual average results detected at the Dearborn Salina school
PM 2.5 monitor.

Here are the most recent annual averages for the Salina School
monitor in micrograms per cubic meter

1999    17.0
2000    20.1
2001    19.6
2002    19.8
2003    19.1

         15.0  national ambient air quality standard

Also, this morning 6 of the last 9 hours had PM 10 over 100 micrograms
per cubic meter, 1 hour average, with a very high 241 microgram/cubic
meter spike in just the last hour.   You might want to look out your
window to see if there is a lot of visible particulate matter over
by the Rouge complex.

If MDEQ Air Division Detroit District does not do some
air enforcement against Rouge Steel on fugitive emission problems, I think 
we should complain to the air enforcement section at EPA
Region 5.  I think we need to call for a comprehensive industrial
process fugitive emission inspection at Rouge Steel at both the
metal forming and the metal melting emission units.  In addition,
there may be some point sources at Rouge Steel which should
be examined from emissions compliance, such as holding furnace stacks.

The toughest inspection would probably be one conducted by EPA's National 
Enforcement Investigation Center (NEIC) in Denver.   If U.S. EPA is serious 
about  environmental justice in Detroit, they should commit to this kind of 
inspection effort at Rouge Steel.   MDEQ district offices don't have the 
kind of resources to do what an NEIC inspection team would do.  I know some 
EPA NEIC staff....they tend to be very tough and very thorough.

The other issue I'd suggest tracking is to determine whether
Cadillac Asphalt is subject to any particulate emission
limitation for condensible particulate matter and whether
they have had any recent stack tests.  Asphalt plants are
strong candidates for examination when it comes to
condensible particulate matter (as opposed to filterable
particulate matter).   Condensible particulate is emitted
as a high temperature gas and the high molecular weight/
high boiling point compounds then condense to the solid
phase when the emission plume cools.   Sometimes emission
sources will only have emission limitations and testing
requirements for filterable particles and not for condensible

An asphalt plant applies high molecular weight hydrocarbon
compounds to hot rock and may  have significant potential to
release condensible particulate matter if there is no
thermal after-treatment of process exhaust gases.


Alex Sagady

At 0906 AM 09/23/2004, you wrote

Enviro-Mich message from "Savoie, Kathryn" <KSavoie@accesscommunity.org>

Alex, emissions of particulate matter at this Dearborn site have been
high. The usual explanation is that it's a result of the construction of
the soccer field at the school next to the monitoring station, but I
have suspected, based on my own observations here in the neighborhood,
that there is more going on. Now the construction is done and the PM
problem is still there.

The problem of heavy fugitive emissions from Rouge Steel occurs quite
frequently, and in my experience it has gotten progressively worse over
the past year or so. . .

No doubt, the heavy traffic of diesel trucks in the area also
contributes to the high PM-2.5 pollution. (Amazingly though, it is
exactly in this neighborhood, which has the highest levels of PM-2.5 in
the state, where the Michigan Department of Transportation proposes to
locate the Detroit Intermodal Freight Terminal, a huge truck-rail
freight terminal that would enormously increase truck and train traffic
in the area.)

Kathryn Savoie, Ph.D.
Environmental Program Director

Arab Community Center for Economic and Social Services (ACCESS)
6450 Maple Street
Dearborn MI 48126
(313) 216-2225

-----Original Message-----
[mailtoowner-enviro-mich@great-lakes.net] On Behalf Of Alex J. Sagady &
SentWednesday, September 22, 2004 317 PM
SubjectE-M/ Dearborn Air Pollution

Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>

Dearborn Air Pollution

Today PM 2.5 is high at Salina School
in Dearborn....in the "unhealthy for sensitive groups"
at this school location.....today's worst PM 2.5 air quality
in Michigan.

At  2 PM, the Salina School site is at 42.6 micrograms/cubic meter
for a 24 hr average today.   This site is frequently the most PM
2.5-contaminated site in the state.   There was a one hour spike of 94
ug/cubic meter for  PM 2.5 about 9 AM this morning.

This site is in a largely Arab low income
neighborhood in Dearborn.

Although there were some doubts about typically high air quality
results at this site through the summer because of construction of  an
adjacent soccer field, I visited this site yesterday and the field
complete and is mulched extensively with straw.

After visiting the site yesterday and observing conditions
in the area, it isn't hard to see what is causing high particulate
emissions at this school site location.   Within 1 mile to the
southwest of this site are two very significant emitters of particulate
matter....Rouge Steel and Cadillac Asphalt.   During site
observations yesterday, Rouge Steel was emitting heavy fugitive
emissions from metal forming building and from its iron
melting facilities.    Cadillac Asphalt was emitting what
appeared to be a great deal of condensible particulate

I have periodically watched the Rouge Steel facility over the years and
emissions there yesterday appeared to be the worse I've ever
seen in the last 15-20 years particularly from the metal
forming buildings.

Given emissions from Rouge Steel and Cadillac Asphalt yesterday,
local visibility was reduced and there was a large cloud of particulate
visible over the lower Detroit and Dearborn areas.

At the present time there are no outstanding notices of violation
that are issued by either U.S. EPA or Michigan DEQ
concerning Rouge Steel, notwithstanding their obvious
serious problems with fugitive particulate emissions
from several emission units at the site.   All of the
facilities in downriver Wayne County were long ago
supposed to have instituted tough fugitive emission
controls to deal with past particulate problems in the

Why does Rouge Steel now act as though these controls
don't apply?   Why has the Granholm Administration
not begun air enforcement actions on Rouge Steel through
the MDEQ Detroit District office?

Alex J. Sagady & Associates        http//www.sagady.com

Environmental Enforcement, Permit/Technical Review, Public Policy,
Evidence Review and Litigation Investigation on Air, Water and
Waste/Community Environmental and Resource Protection
Prospectus at http//www.sagady.com/sagady.pdf

PO Box 39,  East Lansing, MI  48826-0039
(517) 332-6971; (517) 332-8987 (fax); ajs@sagady.com

Alex J. Sagady & Associates        http://www.sagady.com

Environmental Enforcement, Permit/Technical Review, Public Policy,
Evidence Review and Litigation Investigation on Air, Water and
Waste/Community Environmental and Resource Protection
Prospectus at:  http://www.sagady.com/sagady.pdf

PO Box 39,  East Lansing, MI  48826-0039
(517) 332-6971; (517) 332-8987 (fax); ajs@sagady.com

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