Does Rule 2210(y) Revoke Groundwater Discharge Permit Exemption?

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Michigan Department of Environmental Quality Rule 2210(y) exempts a facility from the requirement for a goundwater permit with an MDEQ determination that the discharge has an insignificant potential to be injurious. However, what MDEQ has been doing is simply issuing a permit pursuant to “Rule 2210(y)” rather than providing the exemption from the permit that is required by the Rule. Thus, MDEQ’s “Rule 2210(y) permits” are of questionable validity and often impose obligations considerably in excess of those required by the statue or rules, including such things as submittal of self-monitoring data, unreasonably low discharge limits, retention of records, and burdensome reporting requirements.

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