July 25, 2005
To: Bob Jorgenson, Supervisor, Colorado Air Pollution Control Division
Chuck Stout, Executive Director, Boulder County Health Department
Re: Cemex-Lyons╠ Truck Wash
I am hearing concerns from residents living along the Route 66 corridor that they are witnessing transports exiting Cemex with cement dust blowing off the loading ports. Residents are alarmed that this dust may also be blowing into their homes.
We respectfully request that you initiate an appropriate inquiry into this potential health hazard and source of haze.
The issue of trucks transporting cement dust onto Route 66 is not a new issue for the community and the Health Department. In 1999, as a party on the Health Department╠s Northern Boulder County Environmental Health Community Task Force, the Watchdogs discussed this matter with Cemex and the other members of the Task Force. When the transports are loaded with cement product, spills frequently occur on top of the transports As the trucks exit the property and turn onto Route 66, the spills go airborne. The Task Force recommended a truck wash as a feasible, low-maintenance solution for removing the spills from the trucks. The truck wash, as a pollution control devise, was incorporated into the Health Department╠s ¤Memorandum of UnderstandingË that Cemex signed on August 13, 2001.
It appears this point source needs to be revisited by the regulatory agencies. Dust controls at a cement plant should be a fundamental activity of proper routine management. Truck washing appear to be a relatively minor, easily managed activity. Why can╠t the simple process of rinsing cement dust spillage off the top of a truck be managed reliably?
Process Control for Fugitive Dust Ď A History of Laxity:
The recent dust events from the transports once again affirms our concerns about the lack of reliable management of process controls at this facility. What else, things either simple or complex, might slip between the cracks?
The truck washing may appear to be of such a minor nature█maybe someone simply forgot to turn on the water, or plug in the equipment, or the company didn╠t have spare parts for a repair, or a new driver didn╠t get instruction on how to use the wash. But these cracks in the process controls don╠t help us breathe easier, and they make us alarmed about what may happen in tire combustion.
Cemex has a permit to burn tires and Petroleum Coke█a waste product of the petroleum industry. It would seem that this activity would require consistently good, reliable management practices. Will there be process control problems with this activity too? Due to Cemex╠s past and present behavior, we are convinced that there will be problems. Will there be any assurances given to the public that stack emissions will remain within the ranges measured during the source test? How will the regulatory agencies enforce operating conditions and process controls at Cemex?
Wasn╠t it a simple ¤0-ringË gasket that brought the space shuttle down in a ball of flame? We don╠t want any accidents and sloppy process controls at Cemex. Things have a way of happening at Cemex.
On April 14, 2004 a volcanic like eruption occurred at Cemex, and a monstrous cloud of dust and gases spewed out across the landscape. Cemex experienced what it referred to as an Act of God█an unpreventable, an uncontrollable, and an unforeseeable disaster. Cemex filed a report with the Air Pollution Control Division that it had experience a ¤Catatrophic Failure.Ë
In a phone conversation with Health Department inspector, Gabi Hoefler, I was informed that ¤the ring coating was lost in the kiln. A thick coating had closed the interior of the kiln. This caused hot feed to blast out of the discharge that destroyed control wires. Nobody was aware of the build up. The feed caused a coating over the grates in the cooler, and dust blew out of the cooler.Ë We don╠t want a tragedy from tire burning or Pet Coke burning to occur in the St. Vrain Valley or Boulder County. We don╠t want it!!
Since the citizens have been instrumental in the reporting of Cemex╠s mishaps, we want to remind the regulatory agencies that we will not be able to see any future mishaps in regards to tire combustion.
Accountability and Reality Check:
More than two years ago the Air Pollution Control Division encouraged residents Judy Koslov (Hygiene) and Don Lutter (Lyons) to move ahead on developing an ¤accountabilityË project that would provide the community with reliable data on emissions and temperatures during the combustion process. Koslov-Lutter completed the proposal and got it endorsed by the Boulder County Health Department and the Colorado Air Pollution Control Division. The proposal was then presented to Cemex Citizens Advisory Panel which endorsed it and recommended it for adoption by the company. The proposal seems to be lost in ¤non-decisionË limbo at the corporate office.
Simply stated, the project requires Cemex to release data that it already has, and that it will collect in the future: (1) Data of temperatures at inlet to the bag house, (2) Continuous Opacity Monitor data, and (3) Continuous Emissions Monitor data. With this data, Koslov-Lutter will be able to determine what is being released. It could also be used to provide irrefutable evidence: Is tire derived fuel better or worse? The community would like to see this accountability project up and running as soon as possible. Is there anything you can do to get it (as the project has been repeatedly proposed) moving?
The Truck Wash Situation:
We urge you to step up to the plate for us on this truck wash matter as you did in the recent past. Please keep the pressure on this facility until management brings all point sources of dust emissions into compliance with a sound, reliable environment plan.
We respectfully request that you consider adding the truck wash to the facility╠s Operating Permit.
Cc: Ms. Christine Suarez, President, Boulder County Board of Health
Ms. Margie Perkins, Director, Colorado Air Pollution Control Division
Mr. Tom Mayer, Mr. Will Tour, Mr. Ben Pearlman, Board of County Commissioners
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