Several Examples of Alex J. Sagady & Associates Workproduct for Clients

=============================================================================

National and State Rulemaking, Rules Analysis, Educational Material and Environmental Policy Formation

First comments and second comments of the American Lung Association concerning U.S. EPA proposed rules for hazardous waste combustion and maximum achievable control technology for cement kilns, light weight aggregate kilns and hazardous waste incinerators

Briefing memorandum for the Sierra Club Mackinac Chapter on Michigan Department of Environmental Quality groundwater discharge permitting applicability requirements for concentrated animal feeding operations (CAFOs).

Petition to EPA Region III concerning deficiencies of the Virginia DEQ program on the issuance of air operating permits concerning the handling of alleged confidential information in such permit applications, done for the Sierra Club of Virginia

Comments developed for the Sierra Club national office on EPA's supplemental Notice of Data Availability in the development of NPDES regulations for effluents from concentrated animal feeding operations (CAFOs).

Petition of the Little River Band of Ottawa Indians to EPA Region V seeking a designation of nonattainment for the 8 hour average ozone National Ambient Air Quality Standard for Manistee and Oceana Counties in Michigan

Work product developed by Alex J. Sagady & Associates for the Sierra Club Great Lakes Program Air Toxics Project. Documents include:

Environmental Enforcement Matters, Site Issues Assessments/Reviews and Inspections

[AJSA does many more of these than those listed but most of them are confidential and are solely for Plaintiff's lawyers in anti-pollution litigation and cannot be disclosed at this web site.]

Enforcement and site review of criteria air pollutant and toxic emissions, process upsets and malfunctions and Texas environmental policy requirements concerning the ExxonMobil Baytown Refinery, Baytown, TX, done for the Texas Sustainable Energy and Economic Development Coalition (TX Seed Coalition), Austin, TX

Petition to U.S. EPA seeking the disapproval of a proposed Title V air operating permit for the Entergy Monroe Power Plant, Monroe, LA and public hearing testimony for Citizens for Clean Air and Water, Monroe, LA

Enforcement and site review report on air pollution and toxics from the Smurfit-Stone Container Kraft Pulp Mill, Hopewell, VA done for the Sierra Club Virginia Chapter

Petition to the Virginia DEQ concerning disclosure of alleged confidential information related to an air discharge operating permit of the Honeywell facility, Hopewell, VA for the Sierra Club of Virginia

Comment to the U.S. Department of Justice on lodging a Consent Decree Addendum with the Federal District Court to allow a delayed compliance schedule for the Motiva Delaware City Refinery, done for the the Sierra Club of Delaware and the Mid-Atlantic Environmental Law Center

COMMENTS IN AGENCY PROCEEDINGS ON PROPOSED PERMITS:

AIR POLLUTION PERMITTING

Memorandum on a Best Available Control Technology determination on a Ford motor vehicle assembly plant paint shop done for the Ecology Center of Ann Arbor

Air Permitting Comments on a Proposed Title V Air Operating Permit for the Washington, DC Blue Plains Wastewater Treatment Plant, done for the Sierra Club Columbia Chapter and Appalachian Regional Office.

Comments on a proposed prevention of significant deterioration permit modification to allow tire derived fuel combustion at Cadillac Renewable Energy wood burning power plant, Cadillac, MI for Cadillac Area Citizens for Clean Air

Comments on a proposed prevention of significant deterioration permit for a integrated gasification combined cycle (IGCC) coal power plant for Global Energy in Lima, OH, done for the Allen County Citizens for the Environment

Comments on a proposed prevention of significant deterioration permit for a proposed BP Chemical 1,4-Butanediol chemical production plant, Lima, OH

Comments on a proposed Clean Air Act Title V Operating Permit for the BP Chemical Complex, Butanediol Production Process Grouping, filed for the Allen County Citizens for the Environment, Lima, OH

Comments of the Plumbers and Steamfitters Local 166 concerning an air permit modification on a rotary hearth iron reduction furnace at Iron Dynamics, Inc., Butler County, IN

Comments of the Owensborough Building and Construction Trades Council concerning a proposed prevention of significant deterioration permit for the Peabody Coal Thoroughbred Power Plant in Kentucky

Comments of the Flint United for Justice and Environmental Safety concerning a proposed air permit for S & S Metal Processing, Flint, MI

Comments of the Sierra Club of Mississippi concerning a proposed prevention of significant deterioration major modification permit for the Chevron Pascagula Refinery, Pascagula, MS

Comments of the Plumbers and Pipefitters Local 166 concerning an air permit for a two sided steel coal coating operation at Steel Dynamics, Butler County, IN

Comments of Our Children's Earth and the Environmental Law and Justice Clinic of the Golden Gate University School of Law concerning a proposed Title V operating permit for the Tesoro Refinery, Martinez, CA (AJSA significantly contributed to and collaborated on this work product, which also includes comments from Clinic lawyers and staff)

Comments of the Granby Hill Alliance, Whaley Street Neighborhood Association and We Are Olympia done for Attorney Robert Guild concerning an air operating permit and site evaluation for the Columbia Quarry, Vulcan Materials Corporation, Columbia, SC

Comments of the Central Ohio Group of the Sierra Club to the Ohio EPA concerning an air permit to install application for UPT, Inc. of Columbus, OH for a tire pyrolysis unit

Comments of the Western Maine Citizens for Clean Air and Water concerning a proposed Title V air operating permit for the MeadWestvaco Kraft Pulp and Paper Mill, Rumsford, ME

Comments of the Plumbers & Pipefitters Local 157 concerning a proposed Illinois EPA air discharge permit for the Lincolnland AgriEnergy ethanol production plant

WATER POLLUTION PERMITTING:

Comments of the Little River Band of Ottawa Indians (LRBOI) on a proposed Michigan NPDES wastewater permit for Packaging Corporation of America, Filer City, MI plant and water quality standard violations for color. [This workproduct includes content provided by natural resources staff of LRBOI].

NPDES Water Permitting Comments of Cook Inlet Keeper, Nanwalek IRA Council, Port Graham Village Council, Ninilchik Traditional Council, Chickaloon Village Traditional Council, Kachemak Bay Conservation Society and Alaska Center for the Environment concerning a proposed NPDES wastewater discharge permit for the Tesoro Alaska Petroleum Company, Kenai, AK

First Comments and Water Enforcement/Site Review and Second Comments of the Codorus Monitoring Network, Inc., Dover, PA, concerning a NPDES wastewater discharge permit for effluent from the P. H. Glatfelter bleached kraft pulp and paper mill, Spring Grove, PA

Comments of the Sierra Club Mackinac Chapter on the first draft of a proposed Michigan Department of Environmental Quality general Concentrated Animal Feeding Operation NPDES wastewater permit

HAZARDOUS WASTE MANAGEMENT & COMBUSTION PERMITTING

Comments Prepared for the American Lung Association of Texas concerning a proposed permit for hazardous waste combustion at TXI Cement, Midlothian, TX

================================

[NOTE: All of the materials available on this page require Adobe Acrobat in order to open and read; Adobe Acrobat is available for free at http://www.adobe.com/products/acrobat/readstep.html

Satellite Photo from NASA Goddard Space Flight Center, Industrial Photo by Alex Sagady, Cormorrant and Sunset from EPA GLNPO