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E-M:/ Lafarge-Alpena-Mercury -- More on bad Granholm Administration Decision



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Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>
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The Granholm Administration issued a permit for expansion of the 
Lafarge Alpena Cement plant that included an expandable emission 
limitation of 390 lbs/year of mercury and no requirements for 
air pollution controls or process modifications for mercury.

MDEQ toxic risk assessors apparently believe it is OK to emit 
this much mercury on the shores of Lake Huron.  I've not 
examined their work, but I have to believe that their analysis must
be limited to just looking at water column mercury concentrations and 
not to the issue of overall long term accumulation.  If  we don't have 
a policy that protects the Great Lakes from that kind of emission, we're
in real trouble.

In any event, this permit was supposed to get a review for T-BACT....best
available control technology for toxics.

The Granholm Administration issued the permit and, low and behold, the 
plant emitted BASELINE emissions before the expansion of over 500 lbs
of mercury per year.

Thanks to the efforts of the Huron Environmental Activists League and dedicated
citizens up there and their freedom of information act request, some new information 
has come to light.....information that was never shared with the public in the 
MDEQ public release materials on the air permit for the proposed expansion.

Lafarge imports significant quantities of canadian power plant flyash to mix in 
with their raw kiln meal for making clinker.   Although the flyash is about 5% of 
the tonage of raw materials charged to its 5 kilns, it contributes over 50% of the 
mercury that is input to the kiln system. 

http://www.sagady.com/stuff/Lafarge_Mass_Balance.pdf

Other substitute raw materials should be 
able to easily provide any clinker constituents provided by the flyash without 
charging the kiln system with all of the mercury coming in with the flyash.   

MDEQ's decision on TBACT should have reached the issue of process 
raw material substitutes and process modifications
and limitations on mercury in raw materials.   It apparently never did and MDEQ never
told the public about how significant the power plant fly ash was for mercury discharges.

The high mercury Canadian power plant 
fly ash was introduced as a new raw material sometime in the 1990's and it is 
apparent that either MDEQ never inquired on the mercury potential or that Lafarge either
didn't want to know or deliberately withheld information on the fly ash mercury problem.

Anyway you look at this, both MDEQ Air Quality Division and Lafarge seriously blew it.

Now the question should be what will MDEQ do to get the high mercury canadian 
fly ash out of this plant?  

Will Granholm/MDEQ demand the permit be re-opened to re-do the 
T-BACT determination?  

Why did it take nearly a decade or more to discover that the original decision
of MDEQ to allow use of power plant flyash at the Lafarge plant was not 
only a bad idea but potentially unlawful as well?

Why was it that it took the citizens of Alpena in HEAL to bring this to light?

Lafarge presently has MDEQ in Alpena County Circuit Court trying to allow 
even more mercury emissions.   Just what will Mike Cox do about this?   What 
will Granholm do?   Who is going to be accountable for this bum decision?

Alex Sagady 
Environmental Consultant

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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 

657 Spartan Ave,  East Lansing, MI  48823  
(517) 332-6971; (517) 332-8987 (fax); ajs@sagady.com
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