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Re: E-M:/ EPA Proposes RCRA Exemption on Romulus Well

Enviro-Mich message from Rane Curl <ranecurl@engin.umich.edu>

On Thu, 5 Dec 2002, Julie Griess wrote:

> -------------------------------------------------------------------------
> Enviro-Mich message from Julie Griess <jgriess@provide.net>
> -------------------------------------------------------------------------
> I just got my notice of this in the mail today. Apparently they send out
> what is called a 'plain language' version. It contains statements such as:
> "Rock that contains lots of tiny holes holding liquids is called porous
> rock."
> "Geologists, who are scientists who study the earth ..."
> And a large headline:
> "Why you won't see these wastes ever again"
> (Is this plain language, or biased language? How dumb do they think the
> public is?)
> Apparently there is an informational hearing followed by a public hearing on
> January 8. The comment period goes thru January 22.

I have just received in the mail the Notice of Receipt of an Operating
License Application by the MDEQ for the Romulus deep injection well. The
operating license application may be reviewed at the Romulus Public
Library; at the MDEQ's Southeast MI District Office; and the the MDEQ's
Waste and Hazardous Materials Division Office in Lansing. The notice says
a public hearing will be held regarding the proposed decision, but does
not give a date for said hearing.

The construction license for the disposal facility was approved some time
ago, after the Hazardous Waste Site Review Board had acquiesed to the
construction application by a 4 to 3 vote. However what the HWSRB, and
subsequently the MDEQ had approved was a facility in which (in the words
of the notice just received) "Prior to disposal in the deep injection
well, the wastes would be stored in tanks and containers and treated in
tanks" (to neutralize the waste, remove oils, and precipitate heavy
metals, for separate disposal in hazardous waste landfills).

My question then is, does this EPA proposal for "an Exemption from the
'land ban' under the Resource Conservation and Recovery Act so that the
Environmental Disposal deep wells in Romulus can take untreated hazardous
waste" negate the construction permit requirements for treatment, as
originally proposed, or is this proposal just a formal step in the
operating licensing requirements, and the wastes will still be treated as
originally proposed?

If it is a proposal to dispose of the wastes in the wells *without*
treatment, then it would appear that a new sitting of the Haardous Waste
Site Review Board is called for, as that is not the proposal that they had
been empanelled to consider.

Can anyone clarify this point, of whether the exemption does or does not
change the terms of the original construction permit (and the operating
permit now being considered by MDEQ)?

--Rane L Curl

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