Request for Variance for Pentachlorphenol, Dioxins, and Furans Treatment Standards for Land Disposal Restrictions for Wastes Generated at the Strebor Inc. facility in Kalamazoo, Michigan People
Message body
Jim Ferritto
Michigan Department of Environmental Quality
Waste Mangement and Radiological Protection Division
Hazardous Waste Section
120 W. Chapin Street
Cadillac, Michigan 49601
Via email at This email address is being protected from spambots. You need JavaScript enabled to view it.
Dear Mr. Ferritto:
Environmental Review, Inc. has reviewed the request for a variance for this site. We have the following comments:
1) Please improve your notification system to interested parties for projects subject to public noticing to foster community involvement. In this case I initially found out about the project from an electronic posting on your website about 8 months ago. In early November I received your email informing me that the documents were available for review however it turned out that the comment period had ended before I had a chance to review the documents. My sense is that if I have been notified earlier (e.g. at the same time as the newpaper public notice occurred), I would have had time to conduct a more thorough review.
2) Page 1-4 section 1.3.1 discusses the effectiveness of the treatment system. Has the investigation considered the colloidal transport mechanism on small carbon or mineral particles? For example depending on aquifer characteristics small carbon particles, for example 0.3 microns in size may migrate freely in some aquifer matrices. Since dioxins are extremely toxic, it is important to determine if the colloidal transport mechanism is significant for this site. Related considerations should include testing for organic carbon in the groundwater and testing of the groundwater samples by the high resolution mass spectroscopy method.
3) Section 1.3.2 Surface and Subsurface Soil Excavation and Disposal section, last paragraph on page 1-6 – a description of the bench treatability tests discusses that due to an error in the testing procedure, the batches were not adequately segregated so the testing results could not validated. What was described is an error in a testing procedure and should not be considered a failure to meet a treatment standard. So the tests should be repeated.
4) Page 1-9 Section 1.5.2 Alternative Treatment Standard 1st paragraph last sentence cites the “derived from” rule which states that “residual wastes derived from treatment must continue to be regulated as hazardous waste.” However the next sentence in the next paragraph inconsistently states that it is not technically or environmentally appropriate to manage soil and groundwater treatment system waste streams as if they are discarded unused formulations, therefore a variance is being proposed. The rationale here does not make sense. The phrase “is not technically or environmentally appropriate” is so general it should be deleted or clarified with supporting information. This section appears to rely on the inaccurate information discussed in comment 3 above.
5) Page 2-2 section 3.3 Environmental Benefits of a treatability variance bullet 2 lists a benefit of “Equivalent or superior protection of human health and the environment” is an unsupported statement. This should be deleted or substantial supporting information should be added.
6) Same section below the bullets the 2nd sentence states that tests were not successful in showing adequate reductions in contaminant concentrations appears to be inaccurate. As discussed in comment 3 above, failed testing procedures during bench testing does not qualify as a failure to reach contaminant reductions.
7) Section 4.0 Conclusions first paragraph – the apparently inaccurate information discussed in comment 3 above is repeated in the statement that the tests were “found to be unable to achieve contaminant reductions.
8) Same section second paragraph cites “significant environmental benefits” as discussed in section 2.2 which are unsupported.
9) For these reasons the proposed variance should not be granted at the present time.
10) When responses to these comments are available, please email them to me at This email address is being protected from spambots. You need JavaScript enabled to view it..
Sincerely yours, Tom Price-Program Mgr., Environmental Review, Inc., 1792 Rogers Ave, San Jose, CA 95112 www.envreview.org