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E-M:/ protect the right to know



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Enviro-Mich message from davemec@sojourn.com (dave dempsey)
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Representatives of regulated business and industry outnumbered
environmental organizations by more than 12-1 at a meeting hosted by DEQ
Monday to discuss proposed changes in spill prevention and reporting rules.
Any citizen who thinks it's the public's right to know about spills that
may contaminate groundwater or surface water, and who thinks there should
be measures in place to prevent such spills in the first place, should let
the DEQ know NOW!

Letters should go BY JUNE 30 to:

Jim Sygo, Chief,
Waste Management Division
DEQ
P.O. Box 30241
Lansing, 48909

AND INDICATE YOUR COMMENTS ARE ABOUT THE "PART 31, PART 5 RULES."

Here are the two most critical issues that remain:

       *  Industry is adamantly opposed to a DEQ draft which would require
reporting to the state of all hazardous material spills over 10 pounds.
Such spills, especially of highly toxic substances, can cause significant
groundwater contamination and fish kills or other surface water problems.
Industry wants to use federal "reportable quantities" (RQs) under
Superfund, which can run as high as 1000 pounds for many hazardous
materials, and must occur within a 24-hour period.

        DEQ is at this point holding firm on the 10-pound reporting rule,
but citizens must offer their support! Industry will exert enormous
pressure on the agency.  The right to know about spills is one of the
biggest deterrents to them.  Limits tied to RQs will further undermine
public information and environmental protection, by preventing the state
from assuring cleanup of spills it never hears about.  Let the DEQ know you
support is 10-pound rule.

        *  DEQ and industry have proposed limiting secondary containment
requirements, which protect groundwater and surface water from spills by
capturing overflows, only to users of polluting materials in excess of
2,200 pounds (except for acutely hazardous wastes).  Current rules require
secondary containment for ANY volume of polluting materials.  And the DEQ
proposal is a step back from a previous draft in which the agency proposed
requiring secondary containment for anyone using more than about 100 pounds
of most polluting materials.

        Let the DEQ know that you support secondary containment
requirements for less than 2,200 pounds because it takes far less volume to
contaminate rivers, and spoil an aquifer for generations.

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



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