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E-M:/ protect the right to know

Enviro-Mich message from davemec@sojourn.com (Dave Dempsey)

The DEQ has opened a public comment period on proposed changes to rules
designed to require reporting of spills of polluting materials and
installation of secondary containment to prevent such spills from harming
the environment and public health.  Citizens must speak out in opposition
to a massive outpouring of industrial energy to weaken the rules.  A public
hearing on the new draft will take place October 7 in Lansing and written
comments will be accepted until October 22.

These rules are important because they can prevent a repetition of
Michigan's wretched legacy of more than 5,000 groundwater contamination
sites.  They will also prevent fish kills and other environmental hazards
at the surface.  Reporting spills enables governments to respond to protect
public safety and also deters such spills in the first place.  Secondary
containment can help capture materials before they reach soils,
groundwater, drains, rivers or lakes.  We urge you to write a short letter
during the public comment period ending October 22 which calls for these
features in the final rules:

        *  The threshold for reporting spills ("threshold reporting
quantity" remains 10 pounds, or less if there is a small federal trigger).
This is important for right-to-know and for the DEQ's ability to prevent
major spills and disasters.  This needs strong support.

        *  The threshold for a secondary containment requirement for
outdoor storage is 200 kilograms (440 pounds), instead of the 1000 kilogram
level the DEQ was contemplating.  The 1000 kilogram level will apply to
indoor storage as an incentive to promote this method.  We should urge a
100 kilogram threshold for outdoor storage.

        *  Outdoor secondary containment structures must provide
containment for a 25-year/24-hour storm event, in addition to other
requirements.   Although not all we wanted, this is an improvement on the
last draft, which simply required a containment capacity of 10% of the
total volume of all containers or 100% of the largest single container.
But we should call for the current rules language of containment capacity
for 150% of the volume of all materials stored at the site.

        *  Pollution incident prevention plans will be publicly available
through the local emergency planning committee or health department.  At
one point the regulated community was insisting they not be public
documents.  We should support this provision, which will allow neighbors
and concerned citizens to see the plans and understand how releases will be
prevented and/or minimized.

Please address your comments to:  Jim Sygo, Chief, Waste Management
Division, MDEQ, 608 W. Allegan, Lansing, MI, 48909.

The October 7 hearing will take place at 1 p.m. at the Law Building
Auditorium, 525 W. Ottawa, Lansing.  Copies of the rules can be obtained
from WMD offices around the state or at the DEQ WMD's web page:
http://www.deq.state.mi.us/wmd/.  Copies of the rules can be obtained by
contacting DEQ at 517-373-2730, fax 517-373-4797.

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

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