Laserfiche WebLink
~ .~ ~ 111 Illlllllllllllll <br />r 999 <br />- ~l <br />~. <br />. ~„<°ao ~~.~ <br />C <br />Environmental <br />Science & <br />Engineering, Inc. <br /> <br /> <br />FEE 1 61993 <br />L,..~ <br />MINEA~LS u ~~ <br />February 10, 1993 <br />Mr. Paul E. Clarkson <br />Zoning Administrator <br />Eagle County Community Development Depaztmen[ <br />500 Broadway <br />P.O. Box 179 <br />Eagle, CO 81631 <br />Dear Mr. Clarkson: <br />Environmental Science & Engineering, Inc. (ESE) has been retained by B&B Excavating, Inc. [o assess the <br />compliance status of their operations with respect to the state and federal air quality rules and regulations. <br />ESE has previously performed services regarding air quality compliance issues including preparation and <br />submission of the Colorado Air Pollution Emission Notice (APEN) (Colorado Air Quality Commissron <br />Regulation No. 3, Section II,D.) updates which is an inventory of all potential air emissions from the B&B <br />operations. <br />[n your letter of December 17, 1992, regarding the Special Use Permit for [he Montgomery Pit (ZS-241-86), <br />you made reference [o an observation of "(B&B) employees were burning material (waste oil) that resulted <br />in noxious emissions". On February 9, 1993, I made a operational inspection of the operations of [he <br />Montgomery Pit to assess the current air quality compliance status of [he overall operation of the facility. I <br />did observe [he containers that were attached to the hopper area of the primary crusher. Because [he <br />temperatures on [he day of the December 17, 1992 observation were below 23°F these containers were used <br />to beat the hopper and keep the raw material from freezing. The containers were partially filled with No. 2 <br />diesel oil and ignited to provide heat to the hopper area. Waste oil is not used for any combustion purposes <br />a[ the Montgomery Pit operation. <br />Your understanding [ha[ [he (Eagle County) Environmental Health Division issues burn permits for [he <br />burning of waste is correct. This is a function of the Environmental Health Division granted under the <br />authority of the Colorado Air Quality Control Act (25-7-128) to enforce the Colorado Air Quality Control <br />Commission Regulation No. 1, Section II.,C., Open Burning. However, this regulation is specifically designed <br />to deal with the burning (disposal) of waste material in [he open air. The burn'mg of No. 2 Diesel oil [o <br />prevent freezing is not regulated under Section IL,C., but under Regulation No. 1, Section [i., A.,2., <br />Intermittent Sources, and Section [II. A., Fuel Burning EquipmenC In addition, [here are no regulations <br />pertaining W control of noxious emissions that have been promulgated either by the Colorado Air Quality <br />Control Commission or [he EPA. Regulations pertaining [o [hc control or restriction of air pollutants are <br />complex and specific to the type of emissions. Currently, there is no defuri[ion, let alone any regulations, <br />defuring noxious emissions. Unless Eagle County has adopted specific resolutions, plans, or regulations <br />addressing noxious emissions in accordance with CRS 25-7-128 (1), Local government -authority - nenal(v, <br />[here is no authority granted for regulating noxious emissions. <br />2 Inverness Dri~•e East, Suite 201 Englewood, CO 80112 Phone 1303) 790 0770 Fax (303) i90-4411 <br />