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Require a cumulative impact assessment for this facility in this community and environment (including the Bay of St. Louis) prior to further consideration of the permit; Require an area-wide assessment of contamination from the DuPont DeLisle plant, as part of the above cumulative impact assessment; implement a pollution prevention and elimination pian that will eliminate releases (or production) of dioxins, styrenes, CFC’s, heavy metals and other toxic or environmentally damaging compounds; Specific Comments and issues: Considering the number of citizen issues, the complaints and the nature and magnitude of community concerns over this facility, the citizens urge MDEQ to establish an effective Citizen Advisory Board (CAB) for the DuPont DeLisle plant that serves the interests of the citizenry. A Citizen Advisory Board is supposed to serve this function, but the present structure does not serve the citizens. A community advisory board needs to hold open meetings that are announced 30 days in advance in the paper, bylaws that empower citizens, membership by representatives from citizen groups (including the Sierra Club), and absence of control by DuPont. The citizens request and should have a 24 hour, toll free phone number to call and report air quality problems. These problems may include odors, dead or dying wildlife at the fenceline, releases of particulate matter, smoke, fog, visibility impairments, auto finish problems or emissions at ground level that provoke any health or environmental condition. The air hotline should be funded by DuPont, not the state or other public sources, and should be operated and maintained either by the state or an independent company/agency that has no ties to DuPont and no financial interest in the plant. This Air Hotline should track the calls by time, date and operator, tracking the time, date and details of the report. All data needs to be backed up and checked, with MDEQ following up on reports of problems at DuPont DeLisle. The data should be reported quarterly in the form of nature of the problem, time, date and location. Use of Landfill Gas: There are a number of issues related to the use of landfill gas from the Pecan Grove Landfill as fuel in the plant, proposed for one or more boilers. These issues need to be resolved before the permit can be given full consideration and the citizens urge MDEQ and EPA to investigate the following matters before making any determination on the expansion permit. The following problems with the plan to use landfill gas need to be resolved: • The pipeline for the landfill gas requires at least one permit that should have been part of the air permit process and analysis. The landfill gas and thus the
Dupont Air Hearings Sierra-Club-Recommendations-(03)