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Enviro-Mich message from davemec@sojourn.com (dave dempsey)
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In an earlier message, I described the proposal by industry to report only
spills of hazardous substances that exceed federal 'reportable quantities.'
This is an issue in the pending DEQ revisions of spill reporting/secondary
containment rules.  MEC opposes this proposal because spills below the
federal limits can pose huge environmental risks.  Here's an explanation:

The State of Michigan receives only a handful of reports of releases of
hazardous substances in "reportable quantities" each year despite thousands
of spills.  This is because the threshold quantities themselves are very
high, and the release must occur within a 24-hour period in that amount to
be a reportable quantity.  A slow and gradual leak may occur over months
and years and pose significant health and environmental risks, and not be a
"reportable quantity."

It does not take a large spill to cause significant groundwater
contamination.  One drum of TCE was enough to contaminate the entire
drinking water supply for the City of Charlevoix.  The Superfund program
paid several million dollars to install a new water supply for the city.
It would not have been a reportable quantity.

Examples of reportable quantities in federal rules (40 CFR 302.4):

Benzene, 1000 pounds
Xylene, 1000 pounds
Phenol, 1000 pounds
Toluene, 1000 pounds
1,2-Dichlorethane, 5000 pounds
Ethylbenzene, 1000 pounds
Hydrochloric acid, 5000 pounds
Styrene, 1000 pounds
Trichloroethene, 100 pounds

Please contact the DEQ at once to support spill prevention and reporting.

Dave Dempsey
Michigan Environmental Council
119 Pere Marquette, Suite 2A
Lansing, MI  48912
(517) 487-9539
(517) 487-9541 (fax)



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