Public Comments and Protest before PA DEP
September 25, 2001

RE: Plan Approval No. 22-05007


My name is Mark Miller. I am a certified professional engineer in the Commonwealth of Pennsylvania, and a homeowner in the city of Harrisburg. While my initial concerns with the Harrisburg Incinerator were based on its poor financial performance, and the likelihood that it will continue to be a financial disaster for the citizens of Harrisburg, I have found several other problems that I feel should be addressed in this forum.

In light of the recent terror that has struck our great nation, I feel it is particularly inappropriate to play petty politics with an important public health and safety issue such as this plan approval for the modification of the Harrisburg Incinerator. Instead of taking sides on an issue and presenting only those facts that support your view, an open and honest discussion amongst our citizens, politicians, and regulators seems more appropriate. I have four areas I would like to comment on.


25 PA Code Section 127.11 clearly states " a person may not cause or permit the … modification of an air contamination source… unless the modification… has been approved by the Department." Modification of the Harrisburg Incinerator occurred earlier this year; obviously, this process of act first and get permits later does not meet this section of the regulations, and disrespects the rule of law in our country, our commonwealth, and our city. It is the respect for the rule of law that separates honest working people from the terrorists that plague this world. The PA Department of Environmental Protection and the City of Harrisburg should be ashamed at this flagrant disregard for the regulations designed to protect our air quality.


7. Definitions; Steam Limits - 245 TPD and 250 TPD:
It is my understanding that the 54,189 lbs/hour and 55,295 lbs/hour (respectively) of steam calculated for the purpose of this permit are based on a significant amount of data from the actual operation of the Harrisburg Incinerator prior to the modification. However, according to basic combustion theory, the steam generated per pound of waste burned is likely to change significantly with the large changes in airflow due to this modification. Therefore, these steam flow limits do not adequately reflect the true operating conditions expected at the modified Harrisburg Incinerator. An extensive testing of the steam flow rates vs. waste burned in the incinerator (after modification) is needed to accurately set these limits. I urge DEP to reject any plan approval that includes requirements based on the operating conditions of the Harrisburg Incinerator prior to the modification under discussion.


26. Conditional Requirements

In this section, the Department specifically reserves the right to deny, suspend or revoke any approval or permit and the right to order cessation of the unit(s) if any stack test results indicate that dioxin/furan emissions from either combustor unit have exceeded 1,500 ng/dscm during any test.
This limit for dioxin/furan emissions is exceedingly high, and should not be accepted, as it does not adequately protect public health. Dioxin is recognized as a Known Human Carcinogen by the US government and by the International Agency for Research on Cancer (IARC). Dioxin is believed to be a strong "Promoter" and a Weak "Initiator" in the two-stage I-P model of cancer induction. Several potential mechanisms for dioxin carcinogenicity include oxidative stress, endocrine disruption, indirect DNA damage, and a reduced loss of initiated cells through a suppression of apoptosis. There is consensus in the scientific community that dioxin's multisite carcinogenicity relates to its binding, activation, and alteration of the AhR ligands. Cancers caused by dioxin include lung cancer, liver cancer, possibly soft tissue sarcoma, non-Hodgkins lymphoma, breast cancer, and gastrointestinal cancer.
According to the US EPA and the World Health Organization, the maximum body burden level of carcinogenic risk is 5 ng/kg, or 400 ng for an 80kg person.
Body Burden can be defined as:
Body Burden = Exposure * halflife
ln 2

Since dioxin accumulates in our bodies with a half-life of 2593 days (7.1 years), a maximum safe body burden of 400ng relates to an exposure of 0.000 000 000 1 g (0.1 ng) per person per day. Calculated over a 70 year lifetime, this relates to a dose of 0.000 002 7g.
On May 22, 23, and 24, 2001 stack tests were conducted on the Harrisburg Incinerator. The lowest measured dioxin emissions of 1.45*10-6 lb/hr means the emissions of 2378-TCDD equivalent dioxin are greater than the 70 year safe body burden of a thousand (1180+) people every day the Harrisburg Incinerator operates. The results of the May 22, 23, and 24, 2001 stack test indicated that combustor unit # 1 exceeded 1,500 ng/dscm dioxin/furan, the limit set forth in this plan approval. As this limit is already ridiculously high, I strongly urge the Department to use its right to deny this plan approval based on this noncompliance.


25 PA Code Section 127.13b lists four (4) conditions when the Department will deny a plan approval. Two of these conditions may apply. A1) The Department has determined that the source is likely to cause air pollution. A4) The applicant or a related party has a violation…on the compliance docket. I strongly urge DEP to review the applicability of these sections of the regulations and apply them appropriately.

Thank you for your time and consideration of these important issues.

Mark Miller
1719 N Second Street (717) 260-9868
Harrisburg, PA 17102 Fax 260-9869