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 1998 1999 2000 Longmont Empire Fort Morgan Permit approval Denver Production 230,590 tons/yr Fort Morgan Fort Morgan Akron, Co Gordon Pit, Denver 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 2005 Rifle, CO Keenesburg, CO Keenesburg, CO Kit Carson, CO Weld County, CO 2006 2007 Fruita, CO Pueblo, New Mexico Albuquerque, New Mexico Permit renewal required Permit renewed, no inspection due to being out of state
2010 2011 2012 2013 Phoenix, Arizona 1800 North Taft Hill, Fort Collins (December) 1800 North Taft Hill, Fort Collins March Start-up 1800 North Taft Hill, Fort Collins 1800 North Taft Hill, Fort Collins June Inspection, application for stationary plant October New Permit Issued No New Permit Issued until Oct 2013 April 2014 Still operating at 1800 North Taft Hill, Fort Collins Over 3 years later
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