Testimony of Robert A. Ficano, Wayne County Executive – June 25, 2014
Re: PTI Application No. 189-13, Detroit Bulk Storage Inc.
As you know, some months ago I submitted a letter in opposition to this Petition.
Wayne County applauds the Michigan Department of Environmental Quality’s proposed denial of the Permit To Install, Application No. 189-13 from Detroit Bulk Storage, Inc. for the proposed storage and handling of petroleum coke at 530 East Great Lakes St. in the Cities of River Rouge and Ecorse.
We have reviewed the analyses provided by the Air Quality Division (AQD) and agree that the proposed fugitive dust control measures are inadequate to prevent further violations of State law and County Ordinance.
In addition to the specific recommendations from AQD staff, Wayne County notes the following:
Detroit Bulk Storage, Inc. has already shown a history of noncompliance for their proposed activity at its previous location in the City of Detroit. Simply moving the bulk piles of petroleum coke downriver without any substantive changes in their proposed operation will not eliminate the problems already demonstrated by the company, it will only shift the issue to a different community.
The proposed storage site in the Cities of River Rouge and Ecorse is located in a heavily industrial neighborhood that has been identified by the University of Michigan as one of the Top 10 most polluted zip codes in Michigan. Any additional sources of air pollution will only further burden residents who are disproportionately exposed to air pollution sources.
The proposed storage site in the Cities of River Rouge and Ecorse borders our world-class walleye fishery on the Detroit River along with our international border with Canada. Special considerations should be given to these communities whenever any new source of particulate matter is proposed.
As noted in the AQD analyses, barge loading operations are exempted from any wind speed restrictions. Wayne County often receives complaints from residents regarding industrial barge loading operations along the Detroit River. The proposed fugitive dust plan from Detroit Bulk Storage does not adequately address the potential for fugitive emissions from barge loading operations.
Regardless of location, Wayne County believes that any bulk storage and handling of petroleum coke should occur within an enclosed building or structure with adequate air pollution control equipment to prevent fugitive emissions. The proposal by Detroit Bulk Storage, Inc. to continue outdoor storage and handling of this material puts Wayne County and Ontario residents at risk.
Source: Wayne County