Environmental Impact Statement as prepared by students in the course ENVD 4023 supervised by Professor Brian Muller of the Environmental Design Department at the University of Colorado at Boulder.

Here are a couple of excerpts: "Information on tire derived fuel is often highly contradictory...This Environmental Impact Statement is written in response to the controversy and potential environmental degradation associated with the use of Tire Derived Fuel. The purpose is to create a relatively unbiased account of the influence of tire derived fuel, and to provide a proposed action for Cemex Corporation.

Page 9 Issues and Concerns Section:

1. Cement kilns operate under weak standards that allow them to burn hazardous fuels with higher emissions than other hazardous waste incinerators. Ability to regulate emissions produced during the cement process is further hindered by the exemption of recycled materials, i.e. tires. Expansion of fuel resources used by incinerators could negatively impact the environment in a manner that is not easily regulated.

2. Tire Derived Fuel could amplify the negative impact on air quality by introducing new compounds into the incineration process and increasing the concentrations of compounds already present. Compounds of interest include particulates, sulfur dioxide, nitrogen oxides, carbon monoxide, benzene, and heavy metalsl.

3. Numerous health effects ranging from increased respiratory problems to increased incidences of cancer can result from additional emissions that may be released during incineration of Tire Derived Fuel. The elderly and the young are at particular risk to these substances.

4. The Cemex Plant lies in close proximity to the city of Boulder, Colorado. Improper incineration and the release of additional emissions could put a large population at risk.

5. Workers may be exposed to high concentrations of metals and other compounds that are in the kiln due to the incineration of tires. This direct contact could severely impact the health of workers.

6. The method of tire incineration may simply be instituted as a means of reducing costs. Resulting economic benefit could hinder Cemex's ability to properly evaluate other options that are more advantageous. Possibly allowing the company to avoid upgrading to more efficient technology.

7. Cemex has a poor environmental track record for compliance with the EPA. Safety issues are amplified due to the possibility of wide scale negative consequences. Research indicates problems at the Lyons plant as well as other Cemex operations around the county. Proper tire incineration relies on consistent management practices that may not be present at Cemex.

Page 10: EPA's Detailed Facility Report for Cemex shows the plant was in violation of the Clean Air Act from January 2001 until March 2003. All violations are outstanding at the time of press and state and local agencies are delegated enforcers.