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<br /> <br />composition using state-of-the••art analytical methods by an independent lab. <br />2. Permit Application: There appears to be no fewer than three issues: <br />A. Increased PM 2.5 emissions and traffic. Not specified in permit application. <br />B. Installation of new equipment some of which may result in a decrease in <br />annual dust emissions relative to the existing permit. <br />C. A reque:~t for increased production and consequent annual increase in <br />overall annual emissions of PNI 10 and TSP. <br />Reduction of annusdl dust emissions through installation of new equipmenVprocedures <br />is an admirable objective and merits serious consideration, but keep in mind that a <br />major overall annual Increase is being requested. In advance of any <br />establishment of baseline conditions generated under existing permit stipulation, it <br />seems unwise and inappropriate to grant this increase given Southdown's historical <br />track record in persistent release of uncharacterized and unmonitored fugitive dust <br />plumes. Existing problems should be solved prior to anv consideration of increasing_ <br />emissions. (See photo <br />Again, In advance of any establishment of baseline conditions generated <br />under existing permit stipulation, It seems unwise and Inappropriate to <br />grant this Increase. <br />3. Quality of Llfe: Studies by the American Lung Association, the EPA, and other <br />scientists have shown that these air borne particulates are damaging to human health <br />and may be life-threatening: <br />"The major health effects associated with high exposure to particulate matter <br />include changes in lung function and increased respiratory symptoms, aggravation of <br />existing respiratory and cardiovascular disease, alterations in the body's defense <br />1 systems against foreign materials, damagE to lung tissue, cancer,-and, in extreme ~- <br />cases, premature dc;ath." (USEPA Journal, Vol 13, No. 10 "Particulates: Science <br />Advances, Standards Change" p. 16.) <br />Furthermore, Mr. William Yellowtail, Regional Administrator for the USEPA has <br />informed us that: "Fugitive dust is a serious problem because of the impacts it can <br />have on respiratory functions and visibility. New national Ambient Air Quality <br />Standards for particulate matter will help to safeguard the air quality in Lyons. EPA, <br />Region 8 will continue to monitor the situation for continued progress." <br />The fugitive dust from Southdornrn has aroused legitimate health concerns, and we <br />would Ilke to request; <br />1. A comprehensive inquiry into Southdown's "dusty conditions" on July 11, 1998. <br />