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Environmental Stewardship Concepts
Comments of Dr. Peter L. deFur
on behalf of the Mississippi Chapter of the Sierra Club
Re:
Du Pont DeLisle i itanium Dioxide Plant Air Permits Retroactive 1989 PSD Permit Sustainable Growth PSD Construction Permit
May 20, 2004
These two permit applications seek two goals: 1) amend the original 1989 permit that DuPont claims is in error; and 2) apply for approval to expand the existing facility capacity by enlarging boilers.
We recognize that the two permits do not represent the complete package of air permits required for this expansion, nor the entire set of permits that must be approved for the whole facility. These are but two of several, including the Title V air permit and the landfill and wetland filling (CWA section 404) permits. Notwithstanding’the specifics of each permit, there are issues related to the whole facility operation and environmental record that need to be evaluated when MDEQ considers any permit application for a facility of this size and complexity.
Recommendations
The Sierra Club recommends that MDEQ take the following steps:
Deny the permit for expanding the DuPont Delisle Titanium Tetrachloride plant as submitted, or return for revisions to show elimination of PBT pollutants;
Delay further action on the retroactive permit pending full public disclosure of the technical justification for the error;
Revise the retroactive air permit to include the full range of toxic chemicals that are now listed in the TRI database;
Hold another pubiic hearing on the revised retroactive air permit, following revision to accommodate the public comments and corrections for the deficiencies.
MDEQ needs to establish an effective mechanism to involve the citizens in the relations between the facility and the community; the present one is not effective.
Delay action on, and insist on revision of the “expansion permit” pending and to include permitting of the landfill gas pipeline;
Peter L. deFur, Ph.D.
Richmond, Virginia 23233
A