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EPA's modeling studies indicate there aze potential human health risks due to exposure to the fine particulate matter which characterizes CKD and that these contaminants may reach food products via movement of stormwater run-off and /or windblown dust from uncontrolled CKD. (1999 Proposed Rule: "Standards for the Management of Cement Kiln Dust") It is frustrating after more than four years of citizens and regulatory agencies working in concert to improve housekeeping at Cemex-Lyons, the Watchdogs are once again observing and reporting wind dispersal of fugitive CKD. In a newspaper story in the Boulder Weeklv, July 25, 2002, Mr. Lohr, plant manager at Cemex-Lyons stated: "We make dust for a living. That's what we do out here. Sometimes it's hard to control, but that's not to say we won't try to do better." Mr. Lohr is most assuredly in the business of making dust, but does the company have the right to mismanage that dust allowing it to blow into our homes, our lungs; possibly affecting our health and safety, our property values, and our quality of life? In another story appearing in the Daily Camera, July 15, 2002, Mr. Lohr said "it took a month to order the parts for the sprinkler system and have them installed." There appeaz to be no alarms in the Cemex-Lyons CKD management system. Personnel do not usually discover accidents until we call. Even then, we receive excuses: We are under staffed; people are on vacation; we don't have enough people on the night crew; the video camera is broken; the sprinkler system is broken and on and on. It is unfortunate that the citizens need to watch the Cemex-Lyons CKD disposal site again, but these renewed incidents would go undetected by Cemex-Lyons and the regulatory agencies if we weren't here to perform these tasks. The EPA has proposed a hazardous waste listing and tailored standards for CKD where there are egregious or repeated violations of appropriate management standards. In light of the company's continuing failure to provide staff and the attention necessary to address the problem of the company's CKD issues, we respectfully request that the DMG designate a more stringent regulatory scheme for this substance~ne that will also obviate the need for citizen Watchdogs. Thank you for your consideration and prompt attention to this matter. Sincerely, Richazd E. Cazgill Executive Director St. Vrain Valley Community Watchdogs enclosures -photos Memorandum of Understanding and Appendix A "Commentary and Opinion" by Mike Oakley, Editor, Old Lvons Recorder