Jeff Troth, Teresa Mills

Jeff Troth, owner of Universal Purifying Technology, makes his case
to Teresa Mills at an October 16 community meeting.


The things you don't know

Teresa Mills, Director
Buckeye Environmental Network

Testimony, November 6, 2003

Ohio EPA public hearing
Tire-melting project proposed for the old Columbus trash-burning power plant


My name is Teresa Mills, I am the director of the Buckeye Environmental Network, and a member of the Southwest Neighbors Protecting Our Environment. Our address is P.O. Box 182, Grove City 43123. My comments are made on behalf of the Buckeye Environmental Network, Southwest Neighbors Protecting Our Environment and the citizens of Franklin County. We offer comments here tonight and reserve the right to make further comment up until the close of the comment period.

One of the values instilled in me by my parents was that "People don't care how much you know, until they know how much you care."

Right now I care more about the things you don't know when it comes to this process.

Let me list just some of the things you don't know.

  1. You do not know how the tire chips will be feed into the reactor.
  2. You do not know how the auger moves the tires in the six pass process within the reactor.
  3. You do not know the height of the reactor even though the height of the reactor and the process structure is listed in the application as a process hazard.
  4. You do not know how long the reactor will be.
  5. You do not know the residence time within the reactor.
  6. You do not know the amount of fugitive emission from the reactor even though every non-welded connection to this reactor is a possible point of leakage. This includes the inlet and outlet connection, the points where the auger shafts penetrate the reactor, and any points where instruments penetrate the reactor.
  7. You do not know why there is a sampling valve in the reactor.
  8. You do not know where the pressure relief value on the reactor will be located.
  9. You do not know how often this pressure relief valve will be used.
  10. You will not know when this pressure relief valve releases uncontrolled pollution into our air, because you do not require any monitoring or reporting of this valve. You also do not require that the emission from this value be routed to a pollution control device.
  11. You do not know how Universal Purifying Technology will guarantee that the reactor will operate in a vacuum.
  12. You do not know if there will be excess oxygen within the reactor.
  13. You do not know the temp. range within the reactor.
  14. You do not know how Universal Purifying Technology will prevent the typical problems associated with screw type reactors, such as material backup due to the metals in the chips.
  15. You do not know how the melted material will exit the reactor.
  16. You do not know when or how often the pressure relief valve in the filter will be used.
  17. You do not know when or how often the pressure relief valve in condenser # 1 or #2 will be used.
  18. You do not know what the catalyst used inside the reactor will be.
  19. You do not know the chemical composition of the catalyst and how it will effect emissions.
  20. You do not know how the catalyst will be stored on site.
  21. You do not know how much of the catalyst will be stored.
  22. You do not know how or if the air lock down stream from the cooling unit will work to prevent air from catching the melted material on fire.
  23. You do not know how the company will assure that air does not enter the conveyor containing the carbon black dust which could cause an explosion.
  24. You do not know what steps Universal Purifying Technology will take if there is an emergency condition that would necessitate the shut down of the facility. Such as an explosion or fire.
  25. You do not know where the company will obtain the necessary pollution control equipment. They could in all reality purchase used control equipment.
  26. You do not know the temperature range and retention time within the wet scrubber.
  27. You do not know if by trying to drop the temperature of the gas exiting the incinerator it will be quick enough to stop the formation of dioxin.
  28. You do not know if dioxin will form in the carbon activation furnaces.
I could go on but I think you get my point. No reasonable person could have concluded that there was a basic for the agency claim that no or little dioxin would be formed due to these critical gaps in information.

I understand that Ohio EPA considers this source a minor source of air pollution and the citizens a major inconvenience in this process that has a pre-determined outcome, but: How on God's green earth did you issue the draft permit for this facility?