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E-M:/ Audit Secrecy Update

Enviro-Mich message from jeffg@ecocenter.org (jeff gearhart)

As of September 1998, 60 facilties (see list below) have filed Notice of
Intent to conduct audits which will be covered by the Environmental Audit &
Immunity Act.  Audit conducted under this act are immune from enforcement
action by the DEQ.  There also appears to be general strategy by industry
to file blanket pre-audit notifications to protect themselves against
violations they may discover in ways other than auditing.  The following
information was obtained through FOIA requests.

Environmental Audit & Immunity Act
Notice of Intents ('97- Sept. '98)

Multifastener Spring Division, Livonia
Char-Tech, Livonia
Multifastner, Redford (3 plants)
Profile Steel & Wire, Redford
Fabristeel, Southfield
Profile West, Novi
Kean Manufactoring. Romulus
Machine Tool & Gear, Corunna
Machine Tool & Gear, Fenton
Deco Grand, Royal Oak (2)
Sepctrum Cubic, G.R.
GM Truck, Detroit
GM Global Headquarters, Detroit (2)
GM SPO, Pontiac
GM Powertrain, Romulus
Mid-lux Car Group, Lake Orion
GM Powertrain, Bay City
GM Truck, Pontiac TVC
GM Truck, Pontiac East
Delphi, Adrian
GM Powertrain, Saginaw
Gm Powertrain, Warren
Mid-lux Car Group, Hamtramck
GM Truck, Flint
Plastomer, Livonia
Spectrum/Belding, Belding
Crown Coat, G.R.
Tenneco, Filer City
Wyandotte WWTP
Dow Corning, Midland
Pullman Industries, Pullman
Ford Wixom Assembly, Wixom
Almond Corp., Muskegon (2)
Almond Corp., Spring Lake
GMPT-Warren Transmission, Warren
GM NOA Truck, Pontiac
GM SPO, Pontiac
GM Powertrain/Engine Plant, Romulus
GM Turck, Pontiac East Assembly
GM Orion Assembly, Orion
GM Truck Group, Detroit
GM Truck, Flint
Delphi, Adrian
GM Components Plant, Bay City
GM Malleable Iron, Saginaw
Syron, Saline
Owens Corning, G.R.
Rock-Tenn Company, Otsego (2)
GM Assembly, Hamtramck
Georga Pacific, Kalamazoo
March Coatings, Brighton
Delphi, G.R.
Oakite Products, Romulus

Audit Disclosures form May to September 1998

General Motors Service Parts Operations (SPO)
Pontiac, MI
Audit Date:   June 26, 1998
Memo Date:  July 10, 1998
--Potential noncompliance with Michigan Rule 299.9304.  The manifests for
certain waste shipments may not have been sent to MDEQ, and so were sent at
time of Audit.
--Land Disposal Restriction Forms were absent from manifest files for 3
hazardous waste shipments.  Noncompliance with Michigan Rule 299.9311
--Weekly inspections of the hazardous waste storage area were not
documented, as required by 40 CFR 265.174
--Maintenance paint booth may have exceeded the 15 lbs of VOC emissions per
day exemption limit (for Oakland County) 17 days out of a 22-month period
--The facility is also checking to see if it has any appliances which
contain >50 lbs CFC refrigerant, and is preparing a Spill Prevention
Containment and Countermeasure plan and a Pollution Prevention Incident

GM Powertrain, Romulus Engine Operations
Audit Date:   June 3, 1998
Memo Date:   June 12, 1998
--Noncompliance with Special Condition No. 18, Permit No. C-7687, which
requires an 18 inch diameter discharge stack for their natural gas fired
carousel type engine. (Part of stack above roof expands to 34 inches to
house an exhaust fan).
--The Cuttergrind daily operating log indicated that the permitted
operating hours were exceeded in 1997. Violation of the Tool Sharpening and
Cuttergrind Operation Permit Requirements.

Renosol Corporation
Saline, MI
Audit Date:    June 11-12, 1997
Memo Date:    April 23, 1998
--Audit dealt with soil and groundwater sampling in areas of known or
suspected impact.  No violations were cited in the audit.
--MDEQ's Environmental Response Division stated that they do not have
sufficient information related to historical and current noncompliance,
what part of ACT 451 is violated, what activities are in place to prevent
further noncomplianc or improve compliance or an implementation plan that
addresses past noncompliance.

E.B. Eddy Paper Company
Port Huron, MI
Audit Date:    October 2, 1997
Memo Date:    March 12, 1998
-- 1986-1997:  Failure to submit to the Air Quality Division an updated
Fugitive Dust plan as required by the Consent Order.
-- 1988:  Stack dimensions on paper machine #8 do not comply with air
permit No. 690-88, and company is requesting permit modification since they
no longer use formaldehyde-containing additives in their process.

Michigan Seat Company
Jackson, MI
Audit Date:    November 24, 1997 to March 10, 1998
Memo Date:   March 19, 1998
--Soil contaminated with methylene chloride, toluene, ethylbenzene, and
xylene was discovered on-site.  Violation of NREPA Rule 201.
--Possible contamination of on-site retention pond due to residual oil from
a vacuum pump observed in the truck dock.  Violation of NREPA Rule 201.
--Violation of NREPA Rule 31 since neither a spill plan nor a Pollution
Incident Prevention Plan had been developed, and the stormwater Pollution
Prevention Plan does not adequately address best management practices.
--Violation of NREPA Rule 111 since a Hazardous Waste Contingency Plan has
not been developed and there are no laboratory results available to ensure
that wastes are being properly characterized.

International Foam & Trim Company
Jackson, MI
Audit Date:    November 24, 1997 to May 10, 1998
Memo Date:   March 19, 1998
--Violation of NREPA Rule 31 since neither a spill plan or a Pollution
Incident Prevention Plan has been developed, and the stormwater Pollution
Prevention Plan does not adequately address BMP's.
--Violation of NREPA Rule 55.  The Synthetic Minor Permit needs to  be
modified to add the glass/resin mixing operation.

Jeff Gearhart
Ecology Center of Ann Arbor
117 N. Division
Ann Arbor, MI  48104
(734)663-2414 fx.

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