Public health at stake over Millsboro plant

August 8, 2013

I am writing in response to both the agency letters sent about the zoning for the "potentially dangerous" use of the Allen Harim proposed processing facility, as well as the lack of research and due diligence by the board in terms of public health. I also would like to address the need to re-advertise the hearing and give the public notice that the board is accepting comment, as well as  a reasonable time period to comment. The agencies were given a month to comment, but to allow only seven days when many homeowners live out of state is not reasonable and could trigger an appeal of the zoning hearing.

I will first address the agency letters from DNREC , the Fire Marshal's Office and building code inspector. The comments, in each case, reference the current operation, as each agency commented on existing Vlasic permits, or buildings and the need for seeing and approving any plans Harim would submit in the future.

Although a brownfield was never mentioned in the minutes or audio at any hearing, the applicant states that a brownfield agreementhas been entered into by DNREC, Pinnacle and Allen Harim on the documents they turned into the board dated June 3. The environmental assessments refer to contaminants such as chromium, TCE and other carcinogens, VOCS and the reference to unknown contamination of groundwater wells both on and off site. In recent discussions with DNREC, no agreement "has been entered into," as of yet. There was an application for eligibility filled out by Harim June 13 and letter from DNREC stating they were eligible posted July 11. The letter dated July 11 also stated they must first enter a Brownfield Development Agreement, which has a public comment period, as these are taxpayer dollars and must gauge public support. I also learned that a new parcel would be added, so now we know there are more contaminants and a greater need to research public health, as well as air and water contamination. The board, according to the ordinance, is to pay special attention to protecting health, welfare, air and water.

In light of the need for well protection and source water protection, Allen Harim cannot say with any degree of certainty, the level of contamination or how construction will affect further contamination of air, soil and both ground and surface water. I am asking the board to deny this permit for potentially hazardous use or put conditions requiring approved permits and proper testing to identify the levels of contamination, before approving any such use. The public health of not only the community is at stake, but the fact that there are two schools within a mile, is ample reason for the board to make a decision, only after levels of all contamination are known and new permits are issued.

A poultry slaughtering plant will require new permits, as this is a totally different use from a pickle plant. To my knowledge, transferred permits should not be considered and are not adequate to protect the community from odors, gases, wastewater discharges and water allocation. Furthermore, physical plans need to be seen, as even the intensity of this operation is not clear. A recent article on July 26 references major renovations and the intensity of birds slaughtered there has increased from 350,000 per week to two million per week.

In closing, we ask the board to not rely on verbal promises and hearsay to approve a potentially dangerous use. The cumulative impact of pollution must also be considered. There are two Superfund sites in Millsboro, an unsolved cancer cluster and the National Guard was called in just a few years back when over 1,200 residents on public water experienced water contamination. This was caused by industry making poultry vaccines. We cannot subject our families to added pollution. To permit a facility that will discharge into the Coastal Zone and tributary to the Indian River is beyond reckless, not to mention the effects on the wetlands on site, as well as the endangered species, such as the bald headed eagle, which also lives here. The increased growth in population since the 2000 census and this environmentally sensitive area cannot withstand the increased traffic of trucks and 400-700 employees. The TMDL also is to systematically eliminate discharges into the Indian River.

Jay Meyer

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