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Your last inspection report and the stipulations that you established for controlling CICD should have been sufficient to bring the company into compliance with proper management practices. That has not been the case..Did you know that 18 months after your inspection report, Jani Rix from the Boulder County Health Department conducted an inspection. The following is a quote from page 42 of Ms. Rix's report: . Item 19: ;good Operating Practices: "Although this source has taken many positive steps to control fugitive emissions from the plant and have worked hard with the North Boulder Environmental Health Community Task Force, there is still, room for improvement. At the time of inspection, roads were adequately watered, however, under parts of the kiln and cooler, piles of cement dust could be seen: This area is swept/shoveled by hand since the sweeper can not get under the equipment. There areas should be cleaned more frequently since it Is source of fugitive dust when it gets windy." It is frequently very windy in this valley, and the company takes refuge behind the ancient 3Qmph wind regulation established by the Air Quality Control Commission more than 25 years ago. In a letter to the Watchdogs on February 10, 2000, Ms. Mazgie Perkins, Drrector of the CDPHE, states that "The Commission has attempted to provide a reasonable approach in the application of its, fugitive dust regulations when events are beyond the control a€facitity operators such as might be the case on very windy days. Even so, operators are required to continue to implement fugitive dust control measures during these high wind events. This can be viewed as a `safeguard' built into the regulation and we believe it will prevent abuse of the 30mph provision" The Watchdogs sari appreciate.this provision when it is conscientiously followed by plant operators,; but we feel that "piles of cement dust under parts. of the krZn and cooled' constitutes an abuse of this regulation, and yet another abuse to the residents in the community. The St. Vrain Valley Watchdogs remember that up until 1998, when we first organized, the company was dumping its CY.D in piles in an open field just a few hundred feet from Hygiene Road. Windy conditions caused almostdaily occurrences of CKD dust storms. We remember that residents ept tie wm~ows c ose year roan and we str ayers of white dust inside and out: We were elated wfien Mr. Jorgenson from the CDPHE directed the company to cover the CKD with shale after it was dumped so that it would not go airborne. True to form, 45 days passed before the first toad of top coating for the CICD arrived. 44 months have passed since the DMGaxtempted-ta get-Cemex's CKII problem----- ...--- resolved, and it still isn't under control. Recently the sprinkler system at the CKD disposal site was broken for weeks because the company didn't keep spare parts on hand. On Apri15, 1999, Mr. David Quimette, and Ms. Mazgie Perkins submitted a memo to Ms. Jane Norton advising her of the regulatory agency's activities to control fugitive CICD dust from tfie disposal azea at Cemex-Lyons.; The memo conetudes_with the assurance that the combination of activities should significantly reduce.blowing dust from the disposal site. But, the recent photos submitted to the DMG and the CDPHE clearly depict that dust plums from the disposal site continue.