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


DETROIT, MICHIGAN
3,000 TPD INCINERATOR

THE GIANT FALLS: PART TWO

On April 17, 1990, the Michigan Air Pollution Control Commission issued an order to shut-down the Detroit incinerator because of the violations of its mercury permit.

"SOMEBODY DOUBLE-CROSSED SOMEBODY AND WE WANT TO KNOW WHO IT WAS.."

Mayor Coleman Young, Detroit Free Press, 4-19-90

The shut-down of the Detroit incinerator has to be a costly affair for the City of Detroit's Greater Detroit Resource Recovery Authority, as the giant incinerator was the most costly project ever in the city's history. Mayor Young is credited with being the major backer of this project. The Detroit Free Press captured the Mayor's curious statements intimating that the MI Air Pollution Control Commission hearing, on the gross violations of the incinerator's mercury permits, was a 'done-deal', in a 4-19-90 article: "...This is Earthweek. They wanted a sacrificial lamb to lay at the altar of the environment. And they got the big one. Detroit...I was led to believe there was an agreement and the vote would be six-four the other way [for no shut down]...Somebody double-crossed somebody and we want to know who it was...We had talked to the Governor's staff about an agreement that would allow us to continue...Two of those voting against us were the Governor's appointments. Now you figure that one out." Detroit Free Press, 4-19-90.

1986 ROY F. WESTON REPORT DISCUSSED MERCURY EMISSIONS

in its "Status of Permits for the Greater Detroit Resource Recovery Facility", Table 4-l, pages B-29-B-30: "The conditions for which the Authority [GDRRA] is responsible, to the extent that they are related to [waste] composition, are lead, hydrogen chloride, mercury, fluorides, cadmium, trivalent chromium, hexavalent chromium, dioxins, and sulfur dioxide. The Authority would be required to pay for the cost of modifications to the Facility or to the Facility's operations if these conditions were not met due to the composition. The mercury emission limit is based on data cited in the Project's air permit application, and these data indicate that the Facility will achieve the limit. However, some of the data in our evaluation suggest that mercury emissions may be several times higher than this limit. It is our opinion that it is reasonable for the Project to seek and expect to obtain a waiver (i.e., change in the emission limit in this case), if found necessary at the time of testing. The current mercury permit limit, based on the permit application, is only about 2 percent of the guideline limit referenced in the permit application in terms of maximum groundlevel concentration. Also, even at mercury emission levels more than several times the existing Facility permit limit, it can be shown that there is no significant risk to the public health. (This has been documented for another resource recovery project, for example, in a WESTON report prepared for Montgomery County, Maryland, dated July 1985.)...(on page B-38)...Combustion Engineering has not itself yet completed construction of, or operated, a solid waste disposal resource recovery facility..." On page B-39, in section 4.9, Weston summarizes with seven conclusions. No. 7. "The conditions of the air permit are likely to be met with the possible exception of the mercury emission limit. It is reasonable, however, for the Project to seek and expect to obtain a waiver for this limit, if found necessary at the time of testing, based on health effects analysis for other similar facilities and since the existing limit is only about 2 percent of the guideline limit referenced in the permit application in terms of the maximum groundlevel concentration."

"The Authority [GDRRA] claimed the dry scrubber/fabric filter controls have not been demonstrated to achieve consistent compliance on mercury emissions and that the proposed change in control systems would be financially disruptive and is not justified.." The authority and Combustion Engineering violated conditions of their permit for hydrogen chloride, mercury, and "by not maintaining negative pressure or enclosing areas where the MSW is received, processed and/or stored, and by emitting air contaminant(s) which have unreasonably interfered with the comfortable enjoyment of life and property." 4-17-90 Staff Activity Report, MI Dept. of Natural Resources, Air Quality Division.

CHRONOLOGY OF DETROIT INCINERATOR

1970: The Gordon Rockwell Environmental Act was signed into Michigan law. The act prohibits an administrative or licensing body from authorizing or approving any action which causes pollution, impairment or destruction of the air, water or other natural resources, or the public trust therein as long as there is a feasible and prudent alternative.

1974: Coleman A. Young becomes Mayor of Detroit.

1975: Mayor Young establishes a Resource Recovery Task Force.

1976: July - Detroit receives $75,000 from US EPA to help evaluate Requests for Qualifications for waste disposal.

1976: November - The City's consultant, Mitre Corp., recommends further negotiations with Combustion Engineering and one other applicant.

1977: Combustion Engineering gets contract for 3,000 RDF incinerator.

1979: US EPA gives a $375,000 President's Urban Policy grant to Detroit for an incinerator program, which includes: $l80,000 for contract negotiations; $40,000 for a source separation assessment; $20,0000 for public participation program.

1983: Roy F. Weston, as the City of Detroit's consultants, prepares Environmental Impact Statement for incinerator. Combustion Engineering submits application to MI Dept. of Natural Resources (DNR). Electrostatic precipitators (ESPs) are the only pollution controls.

1984: November 9 - MI Air Pollution Control Commission (MAPCC) issues permit to build with ESPs.

1985: MI DNR discovers "engineer calculation error" in calculating risk of dioxin and furan emissions. Originally thought less than l cancer in a million, DNR settles on 36 cancers in a million.

1986: March 11 - MI Dept. of Health releases report. Risk of cancer is 7 in a million.

1986: April 4 - Roy F. Weston, Inc. says risk is one in a million.

1986: 300 people attend MAPCC's public hearing, 100 turned away. Audience allowed to speak at 11 pm. Meeting lasts until 3 am. MAPCC votes 9-l to allow permit.

1986: City sells $438 million in municipal bonds.

1986: Federal EPA rules incinerator emissions will violate federal regulations on SO2, CO, and particulate matter. Issues notice of violation because MI DNR permit does not require "lowest achievable emission rate."

1986: May 14 - Construction begins.

1986: EPA proposes to revoke SO2 part of permit. Detroit is a non-attainment area for SO2, CO, and suspended particles.

1986: July 8 - City of Detroit sues EPA in US District Court to stop it from changing construction permit.

1986: September 19 - Ontario's Ministry of Environment files brief in support of EPA revoking the incinerator permit.

1986: September 22 - EPA drops attempt to revoke permit.

1986: Late - U.S. District Court for Eastern District of Michigan rules for the City of Detroit against EPA.

1987: Ontario, Canada; Detroit Audubon Society, & others sue Detroit in State Court saying incinerator would violate Michigan Environmental Protection Act.

1987: April l5 - Ontario sues in Wayne County Circuit Court requiring Best Available Control Technology.

1987: June 2 - Greenpeace climbs cranes at incinerator site.

1988: December 8 - Incinerator begins to burn.

1989: January 2 - Construction workers inside incinerator facility voice health complaints.

1989: January 11 - 75 construction workers walk off job because of severity of health complaints that range from respiratory problems, rashes, fatigue, swollen hands, burning eyes, and nosebleeds.

1989: January 19 - 40 electricians walk off job because of health complaints. 15 electricians sent to local clinic complaining of coughing, rashes, and tightness of breath. They were working in the area where ash is taken out of the boilers.

1989: February 22 - MI Dept. of Health cites Combustion Engineering for 18 health code violations and fines them $5,000.

1989: February 17 - explosion in one of the boilers.

1989: March 7 and March 28 - MI DNR finds ash samples test as a hazardous waste for lead and cadmium.

1989: June 3 - 500 people protest incinerator emissions. Detroit Police arrest 25 people.

1989: June 12 - Gov. Blanchard signs Public Act 52 which classifies incinerator ash a special waste.

Note: The major portion of this chronology is from, "The Greater Detroit Resource Recovery Facility, A Case Study", November 1989, by A. Duncan, P. Francis, J. Frank, M.Knoerl, K. Olsson, N. Raymond, U. of Michigan, School of Natural Resources, Dana Building, 430 E. University, Ann Arbor, MI 48109-1115


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