A publication of Work On Waste USA, Inc., 82 Judson, Canton, NY 13617 315-379-9200 APRL 5, 1990

Hydrogen Chloride Emissions (pound per hour)

Run l Run 2 Run 3 Average Limit

Boiler 11 389 386 394 390 294

Boiler 12 404 393 399 399 294

Boiler 13 356 381 362 366 294

Mercury Emissions (pounds per hour)

Run l Run 2 Run 3 Average Limit

Boiler 11 0.31 0.39 <0.22* 0.31 0.07 * None detected

Boiler 12 0.30 0.31 0.33 0.31 0.07 at stated levels.

Boiler 13 <0.22* 0.22 0.34 0.26 0.07

[ Ed. Note: The incinerator has three boilers at l.450 tpd each. "No more than two boilers shall be fired at any one time."

"The county has also cited the Authority for violation of Rule 901 with respect to odors, and for failure to utilize adequate fugitive emission control....the Authority submitted the results of stack tests conducted by CAE between October 20 and November 2, 1989 and November 27 and November 29, 1989. Of these tests, some were conducted with waste up to four inches in size that pass through the primary trommels being excluded [an effort to exclude mercury containing batteries.Ed.] from direct introduction into the boilers and with the manual addition of hydrated lime at a rate of l,200 pounds per hour directly to the waste before introduction into the boilers. The test results under these conditions appear to show emissions within the permit limitation for hydrogen chloride. Mercury emissions, however, again exceeded the permit limitations." 4-l7-90 Staff activity report of the MI Department of Natural Resources, Air Quality Division. As reports can be difficult to obtain, Waste Not will make available this 6-page report for $l.

Volland explained how poor electrostatic precipitators were at removing mercury, and how poor the science was that was going into the redesign of the plant to minimize mercury emissions. He suggested that mass-balance studies be performed to see where the mercury was coming from and where it was going, not just simply relying on air emissions testing. He further suggested that both wet scrubbers and activated charcoal filters were superior at removing mercury. Cook explained how much he regretted that when he first joined the Michigan Toxics Waste Commission, he did not prevail against those who told him not to bother to pursue the Detroit incinerator because it "was a sensitive moment politically and any public statements could interfere with obtaining bonds for the plant." He pointed out the dangers of the current emission levels of mercury and other pollutants. He also stressed the poor science involved in the mercury removal strategy. He urged the Commissioners to have the courage to shut the plant down now before it did any more damage to the environment or the people living in the area. Connett supported the points made by both Volland and Cook on the poor science involved in approaching the mercury problem. He explained how he, and others, had testified in Detroit on several occasions prior to the plant being built, on the inadequacy of the air pollution control equipment, on the gross underestimates in the health risk assessments performed by consultants (particularly Dr. Kay Jones of Roy F. Weston who had used his infamous comparison with peanut butter sandwiches to defend this project), and on the misuse of resources represented by the building of this half a billion dollar incinerator before even a rudimentary recycling program had been studied, let alone pursued. He further explained how each argument raised had always been counteracted with the refrain "the plant will meet all state and federal regulations." However, he noted that when the ash failed the "federally designed EP toxicity test," the Michigan authorities quickly changed the regulations. A case of heads the incinerator industry wins, and tails the citizens lose. He asked whether the commission would now oblige by changing the mercury standard. He emphasized that the difference between "consent decree to operate," and a "permit to operate," was academic, as far as the citizens, who suffer near the facility, were concerned. Currently, he estimated that each year over 5,000 pounds of mercury were coming out of the stack, and, based upon one test, as much as 26 lbs of dioxins and furans per year. Much of this he feared would end up in the Great Lakes or on farmland in Ontario. The "consent decree", if issued, would simply be a licence to continue to experiment with the people who live near the plant, the dairy farmers who graze their cattle downwind in Ontario and the people who eat fish from the Great Lakes. He concluded that Michigan shouldn't be permitting experiments with the world's largest trash incinerator. He asked the Commissioners to deny the permit to operate, and force the company to do their experiments in the lab. Meanwhile, he suggested, Detroit should pursue the solution of the trash crisis in the way they should have pursued it in the first place: source separation, recycling and composting. A strategy which allows toxics to be removed at the front end, and places a premium on educating the public on the larger battles we all have to face, reducing global warming and conserving our resources for future generations. Environment Canada, gave a clear and powerful presentation, showing that a facility it had been monitoring in Hartford, CT, fitted with different air pollution control equipment, was achieving dioxin and furan emissions a thousand times lower than the Detroit incinerator and mercury emissions which would meet the Detroit permit level. After many citizens testified, nearly all indicating that they had no desire to see the Detroit experiment continued at their expense, the Michigan Air Pollution Control Commissioners voted to deny the Detroit incinerator a permit to operate. The City of Detroit is expected to appeal, and that hearing date is scheduled for May 3, l990.

FOR MORE INFORMATION CONTACT RALPH FRANKLIN, EVERGREEN ALLIANCE, 313-833-4998.

Editors: Ellen & Paul Connett, 82 Judson Street, Canton, New York 13617. Tel: 315-379-9200. Fax: 315-379-0448.