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E-M:/ Important Michigan DEQ Waste Water Permit Hearings

Enviro-Mich message from rohrert@deq.state.mi.us (Tom Rohrer)

On June 11, 1997 Alex Sagady wrote:

>The Michigan Department of Environmental Quality has just announced
>two significant NPDES wastewater permit hearings in its calendar published
>last Monday at:
>....concerning two significant dischargers in Michigan with potential statewide
>and basinwide interest.... Dow Chemical and City of Detroit discharges.
>The DEQ notice says that the Dow permit will be issued together with
>an administrative consent order but, of course, they don't say anything
>about the order because you, the citizens, must track this abatement 
>information down yourselves....

The PROPOSED Administrative Consent Order between the MDEQ and Dow - 
Michigan Operations contains a compliance schedule for the company to meet 
the effluent limitations in the proposed NPDES permit for a number of 
problematic compounds.  These include 2,3,7,8-TCDD 
(tetrachlorodibenzo<p>dioxin) and HCB (hexachlorobenzene).  Dow is in the 
process of performing a multi-million dollar upgrade (we guesstimate about 
$10-15 million in capital costs) to their wastewater treatment system in 
Midland and requires an abatement schedule to assure that permit limits will 
be met within a defined time period.

The order also incorporates the Dow Tertiary Pond Solids Removal Project 
that was agreed to as part of our lawsuit against the company last August in 
Ingham County Circuit Court.  This project will remediate some 22 years of 
contaminated solids accumulation in the Dow T-ponds which are adjacent to 
the Tittabawassee River.  The MDEQ feels it is necessary and appropriate for 
Dow to remove and properly dispose of these solids.  The end result should 
be higher effluent quality, removal and disposal of some 50,000 cubic yards 
of dioxin-contaminated solids, and removal of the threat of a possible 
catastrophic loss of these solids to the waters of the state (recall the 
tornado and torrential rain of 1995 in this area). The overall project costs 
are estimated to be around $25 million for the three years of the solids 
removal project.  The administrative consent order (ACO) recognizes that 
during this abatement program there may be some variability in the quality 
of the Dow effluent and provides a schedule and mechanism for the assessment 
of stipulated penalties should violations of permitted effluent limits 
occur.  The order also provides for recovery of a good portion of the MDEQ 
costs for oversight of this major project by providing both funds and 
equipment to the agency. 

The draft ACO is out for public comment along with the permit.  Persons 
desiring a copy can obtain it by writing to me @ the address below.  You can 
also request it by e-mail to me if you supply a USPS mailing address.  
Comments will be accepted in writing or can be made at the public meeting on 
the Permit and ACO scheduled for June 23, 1997 in Midland.

Enviro-Mich--your source for quick answers....Thanks, Alex for all your hard 
work and special thanks to Dave Dempsey and Lana Pollack for the MEC support 
of this great information exchage system.


Protecting and Enhancing the Quality of the State's Waters
Thomas K. Rohrer, Chief
Enforcement Unit
Surface Water Quality Division
Michigan Department of Environmental Quality
Lansing,  MI  48909-0273

Voice  = (517)  335-4101
Fax    =  (517)  373-2040


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