Internet Daemon Owner <idaemon@mountain.epa.gov> 

06/01/2005 11:33 AM	To

James Michael/DC/USEPA/US@EPA, GailAnn Cooper/DC/USEPA/US@EPA

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Subject

(151113357) F019 Comment Submission

	

11a. Mr.

12. Last Name

Bruchmann

13. First Name

George

14. Job Title

Chief, Waste and Hazardous Materials Division

15. Organization

MI Department of Environmental Quality

16. Address

P.O. Box 30241

17. City

Lansing

18. State

MI

19. Zip Code

48909-7741

20. Telephone

517-373-9523

21. Fax

517-373-4797

22. E-mail

bruchmag@michigan.gov

23. Question/Comments

The Michigan Department of Environmental Quality (MDEQ) offers the 

following preliminary comments on the possible amendment to the listing 

definition of F019 and may offer further comments if the proposed 

amendment is published.

The MDEQ strongly supports amending the listing definition of F019 under


the federal hazardous waste regulations.  The MDEQ has been aware of
this 

issue for years and continues to encourage the U.S. EPA to move forward 

and formally publish a proposed rule.  We offer our support in
furthering 

this project.

The MDEQ believes the analytical data collected to date through the 

delisting program, including the verification data, provides reliable
data 

for making the decision to proceed with the proposed rulemaking.  This 

information was collected through procedures and methods approved by the


U.S. EPA.  Further, much of this data was reviewed by a third party to 

validate the results.

The MDEQ supports the use of appropriate risk-based concentrations for 

decision-making.

At this time the MDEQ would prefer that the proposal does not include a 

condition of testing the waste coupled with a narrow industry focus.  We


would prefer the proposal either (1) apply more broadly and require 

testing for key constituents (because some F019 processes are not 

represented by the existing data) or (2) apply more narrowly based on
the 

existing data without additional analysis as a condition of exemption.  

Either way, the MDEQ wants to see some type of proposal published.

Please do not hesitate to contact me if we can be of assistance.

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