GLIN==> Granholm Administration Accepts 390 lbs of airborne mercury from Lafarge-Alpena

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

Granholm Administration proposes allowing Lafarge Cement in Alpena, MI
to emit up to 390 lbs of mercury per year next to Lake Huron.

http://www.deq.state.mi.us/aps/downloads/permits/15-05con.pdf

The permit allows for this limit to be relaxed without a clear requirement
for public notice and a public hearing if tested emissions of mercury
actually exceed that amount.

No clear protocols for testing of all five kiln stacks, clinker coolers
and dryers are contained in the proposal.   No concurrent testing is
being required for  mass balance considerations on coal and pet coke
used, cement kiln dust generated and mercury content of limestone to ensure that
non-characteristic conditions are not being used during the test.....such 
as substituting more pet coke/waste oil for coal during the test.   In other words, 
the facility is free to substitute lower mercury-containing fuels during the 
mercury stack test.   No continuing coal mercury content testing is being required.
No ultimate measure and multimedia review of disposition of mercury in the 
process is being required.

The proposed permit appears to have left out any testing, monitoring and emissions limitation of 
chlorinated dibenzo dioxin/furan.....known producers of PCDD/PCDF emissions.
Requirements of federal MACT standard emission limitations not incorporated into the 
emission limit tables for the permit.   I don't know if they are claiming some kind of 
exemption from the federal MACT standards....haven't conducted a detailed review of that
issue.

This permit action constitutes the Granholm Administration/MDEQ
abrogating the Great Lakes Air Permitting Agreement
requiring Best Available Control Technology for sources of persistent, 
bioaccumulative toxicants in the Great Lakes basin.

Copy of that agreement is at:
http://www.sagady.com/stuff/GLStateAirPermittingAgreement.pdf

See also:

http://www.deq.state.mi.us/aps/downloads/permits/15-05ip.pdf

http://www.deq.state.mi.us/aps/downloads/permits/15-05nohcor.pdf

http://www.deq.state.mi.us/aps/downloads/permits/15-05fact.pdf

Note in particular that no quantitative information about mercury/PCDD-PCDF/toxics is 
contained in the "fact sheet"

Unfortunately, the public comment period on this just ended....I just
noticed this matter tonight.

Looks like the "volunteer to do nothing" approach to mercury emission control.


==========================================
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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