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BE SAFE
NC Campaign
Protecting Children's
Health
Safeguarding Our Air, Water and
Workplaces
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LETTERS NEEDED BY
MID-MAY 2004
UPDATE: The NC Rules Review Commission (RRC)
received more than 10 letters objecting to the H2S exemptions
for pulp and paper mills, thus sending the issue
to the NC General Assembly. On June 17, 2004,
industry lawyers argued that the RCC should
rescind the approval of the new H2S AALs because the
new rules should be considered as a
"package". The RRC obliged and
rescinded the new H2S
rules. Discussions are underway . . . stay tuned.
Thank you for your letters.
Write the NC
Rules Review Commission to ask them to oppose NC
Environmental Management Commissions
exemption for Paper Mills from
Hydrogen Sulfide Air Emissions Limits
Background: The North Carolina
Environmental Management Commission has exempted
one of the largest sources of hydrogen sulfide
emissions -- the waste ponds at paper mills. The
commission, by an 11-5 vote, granted paper mills
a permanent free pass from having to control the
hydrogen sulfide fumes that rise off the
treatment ponds and give the air a distinctive
rotten egg smell. Hydrogen sulfide, H2S, is formed by the
breakdown of organic materials and is typically
found near agricultural locations, waste
treatment plants and industrial sites. It is a
known carcinogen and neurotoxin, and can cause
developmental and reproductive harm to animals.
More info: http://www.bredl.org/air/H2S.htm
Please send letters (see sample
letter below map) as soon
as possible to:
Rules
Review Commission
1307 Glenwood Ave., Suite 159
Raleigh, NC 27605
OR Fax to 919-733-9415
Also,
please send copies to:
Thomas C. Allen
Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
or email to thom.allen@ncmail.net, and
BREDL
PO Box 88
Glendale Springs, NC 28629
or email to BREDL@skybest.com
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Sample
letter
>>
If you live near one of the North
Carolina pulp and paper mills, please add
that to your letter. <<
Rules
Review Commission
1307 Glenwood Ave., Suite 159
Raleigh, NC 27605
Dear Rules Review
Commission:
In accordance with G.S. 150B-21.3(b2), I
object to the Environmental Management
Commission's permanent rules regarding
the exemption of wastewater treatment
systems at pulp and paper mills from the
toxic air pollutant procedures as they
relate to hydrogen sulfide and the levels
set in the rules. These rules are found
in 15A NCAC 02Q .0702, 15A NCAC 02Q.0711,
and 15A NCAC 02Q .0714.
The NC EMC wastewater pond decision
exempts 90 percent of hydrogen sulfide
emissions from paper mills. It is unfair
that the largest sources of hydrogen
sulfide, a chronic toxicant and acute
systemic toxicant, are exempted from the
regulation of air pollutants.
I respectfully request that you deny the
exemption of wastewater treatment systems
at pulp and paper mills from the toxic
air pollutant procedures as they relate
to hydrogen sulfide and the levels set in
the rules.
Sincerely,
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more info:
Hydrogen sulfide
Dec. 15, 2003: BREDL additional
comments on NC DAQ rulemaking for Hydrogen
Sulfide limits.
Oct. 20, 2003:
Factsheet: Hydrogen Sulfide -
The Human Health Effect of a Toxic Pollutant. (.pdf)
North Carolina Dept. of Environment and
Natural Resources Division of Air Quality webpage
regarding the Rulemaking Proposal to Amend the
Hydrogen Sulfide Acceptable Ambient Level.
BE
SAFE NC Campaign
BE SAFE NC member groups
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