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.

FLAWED PREMISE

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