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<br />STATE OF COLORADO <br />Bill Owens, Governor <br />Douglas H. Benevento, Acting Executive Director <br />Dedicated to protecting and improving the health and environment of [he people o(Colorado <br />4300 Cherry Creek Dr. S. Laboratory and Radiation Services Division <br />Denver, Colorado 80246-1530 8100 Lowry Blvd. <br />Phone (303) 692-2000 Denver, Colorado 80230-6928 <br />TDD Line (303) 691-7700 (303) 692-3090. <br />Located in Glendale, Colorado <br />http//www.cdphe.state. co. us <br />October 15, 2002 <br />Mr. Steve Mossberg <br />Compliance Manager, U.S. Operations <br />Cemex <br />5134 Ute Highway <br />P.O. Box 529 <br />Lyons, Colorado 80540 <br />Mr. Mossberg: <br />oF'CO~o <br />tr <br />N <br />~~ <br />} 1876 a` <br />^~ COtOt3d9 DCt12ILR1P.D[ <br />ofPubGcHeatrh <br />andF.nvirottment <br />This letter is in response to a complaint investigation conducted at Cemex's Lyons Plant on October 1, <br />2002. At the time of the inspection, skies were clear and winds were approximately 0-5 mph. Though <br />no fugitive dust was observed to be blowing off-site during the inspection, there are some areas that the <br />Division sees as potential sources of fugitive dust that may be impacting Cemex's neighbors. <br />The CKD pit (Lyons Quarry) uses both a sprinkler system on the perimeter and water trucks on <br />the interior for control of fugitive dust. The sprinklers operate throughout each day and the <br />water trucks apply water and/or calcium chloride dust suppressant as needed throughout each <br />day. It is the Division's understanding that the sprinkler system froze during the Spring 2002 <br />and was inoperable for an extended period of time due to a delay in receiving the necessary <br />parts. The Division recommends that Cemex keep spare parts for the sprinkler system on site <br />to minimize downtime during maintenance activities. <br />Piles of dust were noted under conveyor belts, kiln, dryer, etc., during the inspection. These <br />areas have a significant potential fugitive dust impact'during windy conditions, which is a <br />frequent occurrence in the area. According to Cemex, these areas are currently cleaned up <br />once per week. The Division recommends a more frequent schedule for housekeeping in these <br />areas to minimize the potential for fugitive emissions. <br />Another area of concern to the Division is the fugitive dust generated during blasting activities at the <br />Dowe Flats Quarry. Colorado Regulation No. 1, Section III.D.1.c., describes "Emission Limitation <br />Guidelines for the Submissioh of Control Plans". This regulation states that if the Division determines <br />that a source of activity that is subject to this section is operating with visible emissions that are being <br />transported off the property on which the source is located and such source is subject to the. no off <br />property transport emission limitation guideline, it shall require the ow"ner or operator of that source or <br />activity. tosubmit awritten -plan to the Division for the control of fugitive particulate emissions. Based on <br />complaints received from the community, as well as observations made during blasting activities, the <br />Division has determined that visible emissions are being transported-::off the property on which the <br />