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Enviro-Mich message from marybeth@ecocenter.org (Mary Beth Doyle)

It's time to speak out on toxic sludge.  Michigan's Proposed Biosolids
Rules are up for public comment.  The rules set allowable pollutant limits
for the land application of sewage sludge, and does not allow stricter
local ordinances.  So this is a matter that has the potential to affect all
of us.

The Michigan Biosolids Act was passed last year to promote the land
application of sewage sludge.  The DEQ's Proposed Biosolids Rules are now
out for public comment (the public comment period closes December 31,
1998).  There will be a public hearing on the DEQ's Proposed Biosolids
Rules at 1 pm, December 10 (next Thursday) in the Forum Room of the Library
of Michigan, 717 West Allegan Street, Lansing.  Comments can be sent to
Laura Rauwerda, MDEQ-SQWD, Grand Rapids District Office, 350 Ottowa Ave,
Grand Rapids, MI 49503.

Michigan's proposed rules are based upon the EPA's 503 rules , which are
horribly weak.  If the proposed rules are passed, limits will be set for
only 9 of the 70,000 industrial chemicals in use.  There will be no limits
at all for many chemicals commonly found in sewage sludge, including PCBs;
chlorinated pesticides, including DDT, dieldrin, chlordane, 2,4,5-T, and
2,4-D; dioxins and other chlorinated compounds; polynuclear aromatic
hydrocarbons; asbestos and industrial solvents.

The proposed rules have limits for only 9 heavy metals.  Proposed allowable
concentrations of sludge contaminants are Arsenic: 41 ppm; Cadmium: 39 ppm;
Copper: 1500 ppm; Lead: 300 ppm;  Mercury: 17 ppm;  Nickel: 420 ppm;
Selenium: 100 ppm; Zinc: 2800 ppm

The proposed rules also do not adequately address liability issues.  Who is
liable for damages--the generator of the sludge, the person who applies it,
or the landowner or farmer?  Without a clear chain of liabilty, the final
liability ends up resting with the landowner/farmer, who would have the
most to lose in this situation, and would be least able to protect him or
herself from damages.

Copies of the proposed rules can be found on the DEQ's Website at
http://www.deq.state.mi.us/swq/ or by calling 517-373-1949.


Mary Beth Doyle, MPH
Environmental Health Project
Ecology Center of Ann Arbor
117 N. Division
Ann Arbor MI 48104

734-663-2400 ext 108
734-663-2414 (fax)

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