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~~~ ~~~~~~~I~~~~~~~~ <br />`, <br />August 5, 1998 <br />To: Mr. Doug Lempke <br />Technical Secretary, Air Quality Control <br />Mr. Robert Jorgenson <br />Supervisor, Field Services Section <br />Colorado Department of Public Health and <br />M-~~- Zoe <br />~~ <br />C,~ <br />RECEIVED <br />auc ~ o ~e <br />DIV. OF MINERALS <br />Mr. Ram Seetharam <br />Stationary Sources Program, Air Pollution Control Division <br />From: St. Vrain Valley Community Watchdogs, P.O. Box 82, Hygiene, CO 80533 <br />Re: Request for (1) inquiry (2) information (3) public hearing on Southdown's <br />Permit Application <br />Where we stand now: <br />1. Housekeeping Dust: There appears to be a persistent housekeeping problem in <br />and around the facility's buildings, roadways, and parking area. The enclosed <br />photograph taken in the late afternoon of July 11, 1998 clearly illustrates the dust <br />plumes which are episodically generated from this area. This terrifying dust storm <br />persisted for approximately one hour, and it was reported to the Boulder County <br />Health Department and Southdown Corporation. <br />On July 13, 1998, the Watchdogs received the following correspondence from the <br />compliance officer at Southdown: "Thank you for the information concerning the dusty <br />conditions that occurred Saturday evening July 11. I have informed John Lohr and our <br />staff of the situation and we will investigate the conditions and circumstances." <br />Sadly for the suffering public, the plumes never seem to occur when government <br />inspectors ere present. Rost essured though, that these irciden*.s are teal, w^d as <br />identrfied in the photo are attributed to asite-specific point source. The concentration <br />of particles in these plumes suggests that compliance by Southdown regarding EPA <br />Ambient Air Quality Standards should be examined by appropriate regulating <br />authorities. There is a crack here (both obvious and serious) through which permit <br />compliance falls. How can this crack be sealed to insure public saferi? <br />Given the nature of the industry, it may also be possible that crystalline silica is present <br />within the plume dust. The International Agency for Research on Cancer (IARC), an <br />agency of the World Health Organization, evaluated the available medical literature on <br />crystalline silica and concluded that "crystalline silica if inhaled should be considered <br />carcinogenic (i.e., a group 1 substance)." (Crystalline Silica. Society for Mining, <br />Metallurgy, and Exploration, Inc. 1998., p. 21.) As a matter of public safety, this speaks <br />to the need for characterization of the dust's actual (not generically theoretical) <br />