Asphalt Plant on Taft Hill Road
April 21, 2014
•
Larimer County aerial views back to 1999 show no
asphalt plant until 2011, with first start up in March 2012
•
CDPHE records show the same asphalt plant permit was
used from 2000 until reissued in 2013
Who Permits Asphalt Plants?
Colorado Department of Public
Health & Environment
CDPHE
CDPHE Mission
The mission of the Air Pollution Control Division is to improve and protect the air quality in
Colorado through the development and implementation of cost-effective and efficient air
pollution control measures that are consistent with the requirements of state and federal
law.
Taken from CDPHE website
Permit Renewal Requirements
• Inspection is required every 3 years
• Permit renewal is required every 5
years.
Where in the World
1997
• Longmont
• Empire
• Fort Morgan
1998
• Permit approval Denver
• Production 230,590 tons/yr
• Fort Morgan
1999
• Fort Morgan
• Akron, Co
• Gordon Pit, Denver
2000
• Permit renewal Denver
• Production 235,590 tons/yr
• La Plata County, CO
• Elbert County, CO
2001
• Washington County, CO
• Huerfano County, CO
2002
• Name change from Western Mobile
to LaFarge
• Nebraska
2003
• Permit reissued, no
inspection
• Nebraska
• Logan County, CO
• Craig, CO
• Rifle, CO – Opacity Violation
due to High Heat CDOT
requirements
2004
• Rifle, CO
• Keenesburg, CO
2005
• Keenesburg, CO
• Kit Carson, CO
• Weld County, CO
2006
• Fruita, CO
• Pueblo, New Mexico
2007
• Albuquerque, New Mexico
• Permit renewal required
• Permit renewed, no inspection
due to being out of state
2010
• Phoenix, Arizona
• 1800 North Taft Hill, Fort Collins
(December)
2011
• 1800 North Taft Hill, Fort Collins
• March – Start-up
2012
2013
• 1800 North Taft Hill, Fort Collins
• 1800 North Taft Hill, Fort Collins
• June – Inspection, application for
stationary plant
• October – New Permit Issued
April 2014 – Still operating at
1800 North Taft Hill, Fort Collins
Over 3 years later
No
New
Permit
Issued
until Oct
2013
June 2013 Inspection
At this location for 2+ years?
Not remain at any
one site for more
than two (2) Years
• No State/County production records after 2000
Until the June 2013 inspection
• State regulations require production records
• Production determines levels of pollutants
Recap
• Plant moved next to schools and neighborhoods
• Plant operated for at least a year without a valid
permit
• “ ..seek to avoid locations in close proximity to
pollution sources”
• Lincoln Middle School situated in 1974 at an ideal
environmental location
• Schools would not have been built next to an
asphalt plant
• Asphalt plants were listed as major polluters in 2001, became
minor in 2002 due to industry pressure
• Major polluters emit 10 tons per year criteria pollutants like benzene
• Minor polluters are still polluters, just not highly regulated.
This plant will produce:
15 tons of VOC’s
16.5 tons NOX
11.4 tons of CO2
7.4 tons of SO2
Causes of Ground Level Ozone
Hot sunny days
VOC’s + NOX + SUN = Ozone
Air pollution contributes to
development of asthma in
previously healthy people
What triggers asthma?:
Particulates
Ground level ozone
Sulfur dioxide
Nitric Oxide
Advice on avoiding asthma
Avoid exposure to air pollution
“Take any steps you can to ensure new schools and housing is not near
industrial areas”
Natural Resources Defense Council
Ground Level Ozone
•
Ground-Level ozone affects everybody.
• At ground level, ozone is a health hazard
for all of us, especially the young and
elderly.
– Active and exercising
– Prolonged exposure – reduced resistance to
lung infections and colds
– Triggers asthma or other respiratory
infections like chronic bronchitis and COPD
Asthma
25 million Americans have asthma
3,000 die each year
No cure
Natural Resources Defense Council
Asthma
10 million lost school days/year
14 million lost workdays/year
2 million ER visits/year
30% of childhood asthma due to environmental exposure
Center for Disease Control
Advice on Avoiding Asthma
Avoid exposure to air pollution
“Take any steps you can to
ensure new schools and
housing is not near industrial
areas”
Natural Resources Defense Council
2007 Fort Collins
Ozone Non-attainment Area
Fort Collins West violates health standard
past six years
– Site located at La Porte/Horsetooth
– More out of violation than any other Fort
Collins location – Why?
Inversion
• Air
above ground is warmer than the air
below
• Typical summer morning in Fort Collins
• Pollutants are trapped at ground level
• Cold air flows down from higher ground
• Pushes under warm air rising from valley
CDPHE Modeling
Doesn’t address that plant is located in
hollow
• Doesn’t address overall inversion effect from
foothills
• Doesn’t address wind direction
• No public access within 87m of baghouse
stack
(6 feet further includes the bike path)
•
Would you let your children or
grandchildren go to Lincoln
Middle School?
Lucy J Troup, PhD
Air Pollutants and child
and adolescent development
Volatile Organic Compounds
(VOC’s) and their effect on brain
development
Risk Factors
• Proximity
–Schools, Sports Fields and general high density
neighborhoods with children
–Children engage in activities that increase likelihood
of exposure
•Running, breathing more heavily etc.
• Age
–Physiological risk elevated
•Children are smaller
•Size indicative of a more profound effect physiologically
–Children still developing
–Brain still developing well into late teens early 20’s
Paul Thompson, Ph.D. UCLA Laboratory of Neuroimaging
http://www.nimh.nih.gov/press/prbrainmaturing.cfm?styleN=one
Consequences 1
• VOC’s
can travel up to 4.8km for up to 4 days
in the air (Harnly et al. 2005)
• Children significantly more vulnerable to
respiratory conditions, even moderate levels
(Penard-Morrand et al, 2005; Ware et al,
1993).
• Greater risk as lungs still developing
(Suwanwaiphatthana et al, 2010)
Consequences 2
• Mental
health impacted, the inhalant drug literature
provides a foundation, exposure to VOC’s through
drug abuse, vast literature but for example:
–Prefrontal cortex animal models of inhalant abuse clearly
show cognitive impairment (Bowen et al, 2006)
–And in humans (Cairney et al, 2002)
• One
Danish study showed a significant increase in
the diagnosis of schizophrenia in children exposed
to Benzene and CO (Pedersen et al, 2005)
• Significant neurological and cognitive deficits when
people are exposed to oil re processing (Kilburn &
Warshaw, 1995; Kilburn, 1999)
Consequences 3
• Increase
in diagnosis of Autism Spectrum
disorder (Windham et al 2006)
• Access through the upper nasal passages to
the olfactory bulb and brain leading to
neurofibrillary tangles in Alzheimer's
(Calderón-Garcidueñas et al, 2002)
• 25 years after Camelford…significant
neurotoxic effects emerging…
–Aluminum sulphate into water supply creating
VOC’s
Julia Macmillan
Fort Collins City Plan
• Principle
ENV 10: “..strive to improve the
air so it is healthy to breathe and free of
levels of pollutants that harm human
health (and public welfare).
• Policy
ENV 8.8: “Seek Ozone Compliance”
8 Hour CO Level
Plant Model = 9,933ug/m3
9,933ug/m3
NAAQ =10,000ug/m3
≈ 10,000ug/m3
Situated in wrong place – Fence line only 87 meters from the stack
EPA guidelines set for an industry that has traditionally located
themselves a safe distance from populated areas
Martin Marietta December 2012
Form 10-K Annual Report
Environmental risk due to the use of “substances
that are hazardous”
“the Company frequently acquires large tracts of
land so that quarry, mine, and production facilities
can be situated substantial distances from
surrounding property owners.”
Permit Comment Requests
1.
Move plant to a location away from populous
areas
2.
Stack testing for all relevant pollutants including
VOC’s and heavy metals
3.
Limit hours – no emergency, no weekend
4.
Require EPA compliant opacity monitor installed
5.
Publicly accessible website with time-lapse video
showing asphalt & aggregate production
6.
All pollution control technology suggested by MM
be included as permit requirements with specified
timeline.
7.
Third party oversight of record keeping