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FLAWED PREMISE The LDEQ issued an emergency declaration and order to close the landfill, saying ``immediate action’’is needed. However, the plan it approved allows HMM and its few employees with very limited training up to 180 days to extinguish a subterranean fire they don’t know how to extinguish.
CONSIDER THIS “If a company transporting hazardous materials has a release of that hazardous material; that company is required to have a third party, sufficiently trained to come in and clean it up properly.” This LDEQ order ignores that standard practice altogether.
Faulty Mitigation Plan • Consultant hired to oversee fire mitigation plan has no experience extinguishing an underground fire. • Consultant has only one air monitoring device to utilize for all air monitoring on the 30-acre site and only one person trained to use it. • No plan in place to notify the public if levels of toxic gas go up. • HMM does not have enough employees to carry out day-to-day mitigation efforts to put out the fire and also provide for separation and compacting waste still being allowed under the closure plan.
Faulty Mitigation Plan cont…. • HMM intends to move the burning debris three times to accomplish this mitigation plan when a professional third party could extinguish the fire in place. • The areas designated to move the burning debris have no site preparation; no flagged corners for delineation; and DEQ engineers and the local DEQ personnel say the area designated to move the material is not large enough for the amount of waste in the landfill. • Debris still coming into the landfill.
Fire Marshal Concerns • Utilization of only 1 person and 1 air monitor for entire site • Lack of experience of landfill fire mitigation by PPM and Harrelson • Lack of engagement in producing pre-incident emergency response plan with local authorities • Lack of staffing for safe and effective mitigation efforts • PPM states that there would be one representative on site for the first few weeks, then they would scale down to one person 2-3 days per week.
Recap • FLAWED PREMISE • LDEQ order says that HMM must shut down operation • “The Devil Is In The Details” • Lack of Expertise • HMM Lacks Experience to Extinguish Sub-terrain Fire • Risk lives and could worsen the problem • Faulty Mitigation Plan • Certified Fire safety experts have identified at LEAST seven discrepancies with fire mitigation plan • State Fire Marshall Has Concerns with HMMs Fire Mitigation Plan