This text was obtained via automated optical character recognition.
It has not been edited and may therefore contain several errors.

---

pipeline is an important part of the substance of the air permit and is a material component for BACT analysis.
•	The presumed route for the landfill gas pipeline includes private property for which DuPont will have to acquire right of way or purchase the property. These transactions and acquisitions need to be completed before the air permit can be evaluated. Some property owners may refuse permission for a right of way, particularly in this era when chemical piant terrorism is a national concern.
•	The pipeline pathway also traverses Interstate 10 and the CSX railroad, both significant obstacles to the placement of a large underground pipeline.
•	The landfill gas has not been analyzed to determine the concentrations of voiatiie and semivolatile organic compounds (SVOC’s, VOC’s) or air-borne materials such as mercury (Hg). Landfill gas emissions need to be analyzed before using the gas in the boiler;
•	DuPont has not made an application to build the pipeline, a process that requires numerous permits. The required permits include the U.S Army Corps of Engineerss and MDEQ. This process could require more than 18 months, but the DuPont permit proposes to have the natural gas (from the pipeline) in use by the end of 2004. Neither DuPont nor any third party vendor has applied for the necessary permits. The timeline is not consistent with the facts.
If all the conditions needed for using the landfill gas in the boiler burner cannot be met, then the proposal to use the gas will fail and the BACT analysis and PSD application as submitted will not apply. The landfill gas pipeline is in the critical path and therefore, must be completed at this early stage of the permitting process.
Retroactive Permit:
The retroactive permit application requests raising the particulate matter (PM and PM10) emission limit for the #3 boiler from 0.2 pph to 1.2 pph, based on nothing more than a letter from DuPont to MDEQ (Letter of December 11, 1995 from DuPont to Mr. James Dowdy of Air Section, Pollution Control Division). Documents in the files offer no substantive explanation or justification for the request to raise the emission limit, simply the limit was incorrectly set at 0.2 pph rather than 1.2 pph. Some justification and official documentation is needed, including specifications and technical reports from the appropriate parties.
Toxic Chemicals:
The permit is now incomplete in failing to include the full range of toxic chemicals released by this facility. The permit needs to include the full range of compounds that have been reported by DuPont to EPA for the TRI list. This TRI list of chemicals may not be complete, but we have no monitoring data, stack tests or other direct assessment of the chemical composition of the air emissions, so we must use that which we have-
3