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
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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.
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