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MORE Re: burning tires in Syracuse



At 05:12 PM 12/14/1999 -0500, you wrote:
>In Syracuse NY USA the county-run incinerator is trying to get a permit to
>add shredded tires (to be mixed in with the garbage). Comparative stack
>tests Ogden-Martin provided the state environmental agency showed dioxin

One other parenthetical note.....

....it is possible that use of shredded tires will trigger prevention of
significant deterioration applicablility as a major modification from a
change in the method of operation.   If you can make a case that this
is a major modification, then they'll have to show that they are
employing best available control technology for all PSD pollutants which
include municipal waste incinerator organics and metals.    I have recently
written for the Sierra Club a guide on how to use PSD provisions of
the Clean Air Act to address toxics, even when the pollutants are federally
unregulated.

The other issue is to ensure one way or another that the new source
performance standard for municipal waste incinerators was not triggered
with this change.
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