GREATER FALLSTON
ASSOCIATION, INC.
July 10, 2007
Mr. Herbert Meade
Director, Oil Control Program
Maryland Department of the Environment
1800 Washington Boulevard
Baltimore, Maryland 21230
Dear Mr. Meade
I wanted to comment favorably on your presentation at the Maryland Ad Hoc Committee on Oil On June 7th, 2007.
What I found remarkable was the profound change in the philosophy of the Oil Control Program from being “closed door” to “public conscious”. This new firm stance taken by you and the Department permeated the audience (most of whom were in the oil industry). Many of the comments by the participants on the new regulations reflected your stance on public safety and protection as the highest priority.
I would like to reiterate that the Greater Fallston Association still accepts the invitation to be part of the ad hoc committee on future regulations. As I mentioned to you personally at the close of the meeting, having input from the general public adds a perspective that insures greater public acceptance and support of the objectives of the Oil Control Department. While we may not have the technical expertise, common sense and participation gives the public the assurance that “industry” is the only voice heard in these discussions.
During my presentation at the public comment period on the proposed regulations in 2005 at the MDE, I make it clear that in addition to “beefing-up” regulations on new installations, the MDE needed to impose more stringent regulations on existing petroleum stations and defining the point at which repair can no longer be performed, mandating a required upgrade. As you mentioned in the meeting, repairs versus upgrades were not part of the regulations under current discussion for fear that introducing this subject would thwart passage of the regulations currently under discussion. We ask again to be represented in future meetings when this issue is revived.
The GFA is in process of updating the community on the situation with regards to the MTBE contamination at Uppercrossroads. At your earliest convenience, could you please provide us with any and all relevant information regarding remediation, testing, trends, geological investigations, Exxon-Mobil’s compliance with the Northern investigation etc. and what prompted the MDE to require further onsite drilling to the northeast of the remediation site. We will disseminate this information via our WEB site and mailings in lieu of a 2007 summer public meeting. I would be glad to meet with you to review this update.
At the meeting of June 7th you mentioned the successful legislation regarding “lock-down” of tanks that were not incompliance with current mandatory inspections. Could you please direct me to a copy of this legislation so that I can relate this information to the community?
You also stated that the MDE Oil Control Division had undertaken the initiative to inform residents on petroleum leakages that occurred prior to the effective date of the current legislation requiring mandatory notification. Could you please state the parameters that would prompt notification, the area for which notification will made, number of cases that involve the residents in Harford County and the progress of this endeavor.
Finally, I would like to know the position of the MDE on permitting new petroleum stations in areas served by potable wells. In our phone conversation this spring, you commented that one of your main concerns regarding the opening of new petroleum stations in Harford County was the potential hazzard associated with the delivery of high volumes of petroleum products in high-risk areas. You mentioned that in your discussions at a meeting this spring with Councilwoman Chenowith and Royal Farms that the representative from Royal Farms stated that in order for a station to be profitable, there would need to be a delivery of 200,000 gallons of petroleum products per month. You remarked that this volume astonished you. You also mentioned that in a sole source aquifer there is no second chance if a catastrophe occurs. Finally, even with the new regulations and the best detection devices, you mentioned that if someone is asleep at the wheel in responding to the high tech devices, a major catastrophe can still occur, e.g. the Jacksonville poster case. Will the MDE take a position on this issue? You also mentioned that Carroll County was in the process of considering a similar restrictive ban on petroleum stations in areas served by potable wells. Do you have a contact source or update regarding this pending legislation in Carroll County?
As always, we are most appreciative of your time efforts. The requested information is voluminous. I would be more than happy to come to MDE to gather any and all of this information.
Thank you.
Yours truly,
Roman E. Ratych, M.D.
President, Greater Fallston Association
cc: Shari T. Wilson, Secretary of the Environment
Open letter to the community