February 10, 2016

Mr. Keith Creagh

Director
Michigan Department of Environmental Quality
P.O. Box 30473
Lansing, Michigan 48909RE: Protecting the Health and Safety of Wayne County Communities
Dear Mr. Creagh:
I am writing in my official capacity as Wayne County Executive, and on behalf of the countys 1.8
million residents, to express concerns over several environmental issues that are impacting the health of
our residents.
Our concerns are not abstract. We see the effects of industrial pollution on the health and quality of life of
Wayne County residents every day.
Wayne County ranked 82/82 in air pollution and particulate matter density in several County Health
Rankings reports over the past few years, compared to 44 to our neighbor Washtenaw County. Pollution
levels in Wayne County (12.8) exceed both the national (11.9) and the State (11.5) levels.
This explains the disparity and inequity in health between those living in Wayne County and those living
elsewhere. 16.4% of Wayne County residents, excluding the city of Detroit, report poor to fair health.
Residents in Detroit reporting poor to fair health are almost double that number, at 31.4%. The number of
children reporting poor health is particularly alarming, as are the higher rates among minority populations
and African Americans.
These disparities can only be explained by looking upstream and addressing the root causes of disease,
issues related to both the social and built environment of where people live. Every resident is entitled to
the basic right for social and environmental justice.
To that end, my administration and I have identified three potential issues that could exacerbate the
ecological threat to the residents of Michigans most populous county at a time when policy makers and
corporate citizens should be working to alleviate the damage done to our air and water.

Marathon Petroleum Refinery - Detroit

As you know, the Air Quality Division is currently considering proposed Permit to Install Nos. 118-15
and 122-15 at the Marathon Petroleum Company LP Refinery in southwest Detroit. We are especially
concerned with the proposed increase of 22 tons/yr. of SO2 that will be emitted from the Tier 3 Fuels
Project. Although we understand that this project will potentially lead to a reduction in tailpipe
emissions for our region, the residents near the refinery are being asked to pay a disproportionate price in
the form of increased air pollution.
Wayne County finds it unconscionable that MDEQ would consider increasing SO2 emissions from any
source in a Clean Air Act non-attainment area. The Marathon Refinery is located in a neighborhood that
has been identified by the University of Michigan as the most polluted zip code in the State of Michigan.
Any additional sources of air contamination will further burden residents who already face greater health
risks from their exposure to the many sources of air pollution in this neighborhood.
It is scientifically documented that S02, when inhaled, is an irritant that causes coughing, wheezing and
shortness of breath or a tight feeling in the chest. The neighborhoods near the refinery are already
overburdened and underserved, with high health risk factors and chronic illnesses.
Asthma rates in Wayne County are 16.1% and 20.1 % in Detroit; both are higher than Michigans overall
rate of 15.8%. Our asthma rates are also significantly higher than other southeast Michigan counties,
14% in Monroe and 10% in Livingston.
Chronic Obstructive Pulmonary Disease (COPD) rates in Wayne County are higher than the Michigan
rates at 8.5%, 12.1% in Detroit while they are less than half that in Livingston (3.6%) and 4% in
Washtenaw.
The aggregate of pollutants is of grave concern to the overall health of Wayne County residents,
especially those that reside near the refinery and within the City of Detroit.
Wayne County urges MDEQ to withhold approval of the permits until it can demonstrate SO2
reductions from other sources in the area that exceed the proposed increase from the Tier 3 Fuels
Project.
US Ecology Detroit North Facility
The MDEQ Office of Waste Management and Radiological Protection is currently considering a request
from US Ecology to significantly expand the capacity of its hazardous waste processing facility located at
6520 Georgia Street in Detroit. This facility is a known processor of fracking waste from out-of-state oil
and gas industries and we are concerned that this proposed expansion will make Wayne County a
dumping ground for this material.

The expansion of the US Ecology Detroit North facility will also expose area residents to an increasing
number of dangerous liquid and solid waste materials which potentially threaten air quality from
processing emissions and water quality from its discharge to the GLWA sewerage system. Further,
expanding the capacity of this facility will also increase truck traffic and the likelihood of accidental spills
of hazardous materials along transport routes throughout Wayne County.
Fracking wastewater that is produced in Pennsylvania contains chemicals, high concentrations of salt,
heavy metals like lead, arsenic, and strontium, and radioactive elements like uranium, radium, and radon.
Pennsylvania has a unique geology containing relatively high levels of natural uranium and thorium
(according to Pennsylvanias DEP).
Fracking wastewater contains high levels of Cumene, classified as reasonably anticipated to cause
cancer by The National Toxicology Programs 13th Report on Carcinogens in 2014. Its been listed as
Hazardous Air Pollutant (HAP) by the U.S. Environmental Protection Agency since 1990, so its been a
known health hazard for decades.
Cumene isnt the only health hazard associated with fracking. Diesel particulate matter, nitrogen oxides
(NOx), road dust, BTEX chemicals (benzene, toluene, ethylbenzene and xylene) are all potential
pollutants associated with fracking that pose health risks. Benzene is also a known carcinogen listed by
the Report on Carcinogens. Additionally, NOx contributes to the formation of regional ozone, which
causes smog and is very harmful to the respiratory system.
Particulate matter can cause respiratory problems including coughing, airway inflammation and
worsening of existing respiratory illnesses such as asthma and COPD, and premature death.
Wayne County urges MDEQ to deny US Ecologys request for an expansion at their Georgia Street
facility.
TENORM Waste
Related to the US Ecology expansion, Wayne County has significant concerns over the potential increase,
transportation and disposal of TENORM waste.
In order to ensure the safety of our residents and the protection of our natural resources, Wayne County
urges MDEQ to fully adopt the recommendations from the Michigan TENORM Advisory Panel that
Governor Snyder appointed in 2014. In addition to the six specific recommendations from the Panel,
MDEQ should devote resources to fully explore the Areas for Future Consideration identified in the
Panels White Paper.
We understand that the Solid Waste and Sustainability Advisory Panel are currently making
recommendations for a substantial revision to Part 115 of Act 451, the Natural Resources and
Environmental Protection Act.

The recommendations from the TENORM Advisory Panel should be incorporated into State law to
provide an enforceable mechanism that will better protect the residents of Wayne County, where a
substantial amount of this waste is being hauled, processed and disposed.
The TENORM study, which began in January 2013 in Pennsylvania, developed a report based on the
study of radioactivity levels in ongoing produced and flow-back waters and brines, radon in natural gas
levels, pipe scale causing worker exposure, metal recycle concerns, treatment solids and drill cuttings,
along with transportation, storage and disposal of drilling wastes relating to DOT transport and landfill
limits. While the study found little or limited potential from radiation exposure to workers and the public,
it did conclude that there is potential radiological environmental impact from spillage and from the
potential long term disposal in landfills. The study also recommended further studies to assess the
environmental impact of all facilities in Pennsylvania that treat waste water. These results should be
taken into consideration before exposing the residents of Van Buren Township to environmental hazards.
The possibilities of leaks and spills of fracking fluid, which often contain known carcinogens (e.g.
benzene) and endocrine-disrupting chemicals, can pollute rivers, streams and groundwater and pose threat
to public health.
I would appreciate any updates and information you can provide as to the progress on these issues. I
appreciate your full consideration and trust that your Department will look beyond strict technical
compliance in its decision making processes in order to improve the quality of life for those living in
some of the most vulnerable areas of the State.
Sincerely,

Warren C. Evans
Wayne County Executive