E-M:/ More.....MDEQ mercury report.....

["Alex J. Sagady & Associates" <ajs@sagady.com>]

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Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>
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The MDEQ mercury report can be found here.....

http://www.michigan.gov/deq/0,1607,7-135--184638--,00.html

One thing is for sure.....until Michigan amends its air toxics rules, 
any mercury limit (or other hazardous air pollutant limit) that is 
imposed under state authority and permitting will get relaxed or 
dropped when the federal government comes out with a 
hazardous air pollution control standard for a particular
industrial source category.....then whatever Michigan accomplished
previously to control emissions gets wiped out.   Once the 
federal standard comes out, then emission limitations based on 
Michigan rules for best available control technology for toxics gets
overruled by the federal rule....even if that federal rule doesn't 
explicitly regulate mercury or the particular hazardous air pollutant
in question.  

For example, the federal maximum achievable control 
technology standards for coke ovens and portland cement plants
don't regulate mercury emissions, but Michigan's present toxic air 
pollution rules sweeps aside state toxic air pollution control technology 
requirements once a federal rule reglates hazardous air pollutants from 
that source category.

MDEQ permit revision actions at Dow, the Detroit Incinerator, 
Genesee Power plant and other sites wiped out hard-won toxic 
emission limits that were previously imposed.   The Detroit Incinerator
case was one of the most hard fought toxics battles in the history of 
Michigan citizen environmental action, but permit revisions over the years enacted
by MDEQ wiped out such requirement as the mass rate emission limitation 
of 0.14 lbs/hr for any two incinerator units and the requirement to collect and 
separate batteries in the waste processing stream for that plant.

While Michigan environmentalists have always opposed efforts to 
say that Michigan environmental controls should be no more stringent 
than federal standards, they've left this problem fester with sudden death of toxic air 
contaminant requirements after federal rule promulgation go on for over
15 years.


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

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

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