RECOMMENDATIONS BASED ON THE TOSC REVIEW
OF MINERGY AIR USE PERMIT APPLICATION

We recommend the following:

1. Minergy specify the chemical to be used to supply nitrogen to reduce NO_x to N₂.

2. Minergy supply data from actually operating systems to justify their assumption that their process will control 60% of NO_x emissions.

3. Minergy submit a written review in which they discuss and justify their not using one of the other more efficient NO_x reduction processes such as SCR or the newly developed ozone process.

4. Minergy perform yearly, at a minimum, stack sampling after initial compliance is attained.

5. Minergy install its own on-site ambient air monitoring equipment for, at the very least, particulates and metals associated therewith.

6. Minergy provide details on coal delivery, preparation, storage and resultant emissions therefrom. 

7. Minergy specify the chemicals that will be used in the cooling tower to maintain water quality.

8. Minergy discuss whether the use of the cooling tower chemicals has any air quality ramifications.

9. Minergy discuss the ramifications on air emissions from their process if they do not attain the desired 12% sludge moisture content.

10. Minergy discuss the disposition of the dust (solids) collected in the diverse air quality control devices.

11. Minergy supply results of stack testing on their currently operating Wisconsin plant, especially since emissions predicted for the Detroit plant were based on predictions from data in AP-42, the U.S. EPA Emissions Source Book (compilation of air pollution emission factors), and those emissions may be significantly different from the proposed operating process.

12. Minergy discuss and validate their choice of emission factors from a glass furnace rather than emissions factors from a sewage sludge incinerator.

13. Minergy supply supporting information to substantiate their adsorbent process choice for mercury removal.

14. Minergy perform dioxin concentration tests on their stack emissions after a successful plant startup and that those test data be reported to and discussed with the Michigan DEQ (MDEQ).

15. Minergy perform monthly sampling analysis of the delivered sludge for heavy metals.

16. Minergy only be allowed to bring in a limited amount of sludge from other municipal wastewater treatment plants to supplement the material supplied by the City of Detroit and only be allowed to do so if the contaminants in that sludge are equal to or less than those in the City of Detroit's sludge. 

17. Minergy substantiate their basis for choosing a temperature of 1700° F for two (2) seconds residence time for high temperature of toxic organics.  This review and the dioxin combustion review should be conducted by a skilled incineration combustion engineer.

18. Minergy establish a local advisory committee composed of nearby residents and local business representatives.  This committee should meet periodically to interact with the plant manager and discuss the plant operations, especially the impact of those operations on the local community.

19. Minergy rewrite and resubmit their permit supplying necessary backup details to justify their assumptions and calculations.  In our opinion, that application should contain, as I have noted before, information on their currently operating system in Wisconsin.

20. Minergy supply the missing flow sheet details in the revised permit application. AND

21. MDEQ be requested to comment on Minergy's choice of a glass furnace permit rather than a sewage sludge incinerator permit and report on the differences in emissions allowed by each permit choice.

22. City of Detroit shut down their current incinerators once Minergy's process is operational.