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



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Enviro-Mich message from "Steven Sliver" <SLIVERS@michigan.gov>
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The authorization to inject restricted wastes is a requirement under the
construction permit issued in February 2001.  Without this exemption
from the land disposal restrictions, EDS would be very limited in what
it could inject in the deep wells, even after treatment.  The treatment
processes authorized and required under the construction permit are
those that are necessary to make the wastewaters amenable for injection,
not to meet the land disposal restrictions.  A new Site Review Board is
not required. 

Please direct any questions or comments about the EDS operating license
application to Steve Sliver of the Michigan Department of Environmental
Quality.

Steven R. Sliver
Environmental Engineer Specialist
Hazardous Waste and Radiological Protection Section
Waste and Hazardous Materials Division
Department of Environmental Quality
P.O. Box 30241
Lansing, Michigan  48909

Phone: 517-373-1976
Fax: 517-373-4797
E-mail: slivers@michigan.gov

>>> Rane Curl <ranecurl@engin.umich.edu> 12/05/02 10:06PM >>>
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Enviro-Mich message from Rane Curl <ranecurl@engin.umich.edu>
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On Thu, 5 Dec 2002, Julie Griess wrote:

>
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> Enviro-Mich message from Julie Griess <jgriess@provide.net>
>
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>
> 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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==============================================================
ENVIRO-MICH:  Internet List and Forum for Michigan Environmental
and Conservation Issues and Michigan-based Citizen Action.   Archives at
http://www.great-lakes.net/lists/enviro-mich/

Postings to:  enviro-mich@great-lakes.net      For info, send email to
majordomo@great-lakes.net  with a one-line message body of  "info enviro-mich"
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