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HomeMy WebLinkAbout4.0 BOCC Staff Report 09.04.2012 - Exhibits A - JJJJBoard of County Commissioners — Public Hearing Exhibits Bedrock Resources LLC — Contractors Yard and Accessory Uses Major Impact Review — Land Use Change Permit September 4, 2012 (File MIPA-7250) Exhibit Letter (A to Z) Exhibit Description A Proof of Publication B Return Receipts from Mailing Notice C Photo evidence of Public Notice Posting D Garfield County Unified Land Use Resolution of 2008, as amended E Garfield County Comprehensive Plan of 2030 F Application G Updated Staff Report dated 8/27/12 H Staff Presentation Clarification Cover Letter from the Applicant (SGM, dated 5/25/12) J Referral Comments County Vegetation Manager K Referral Comments from County Consulting Engineer L Referral Comments from County Road and Bridge Department M Referral Comments from Rifle Fire Protection District N Referral Comments from Colorado Division of Water Resources 0 Referral Comments from Colorado Parks and Wildlife P Public Comments from !Ilene Pevec Q Public Comments from Gwen Garcelon (7/1/12) R Public Comments from Kenneth Sack (6/30/12) S Public Comments from Kenneth Sack (6/30/12) T Public Comments from Kenneth Sack (6/14/12) U Public Comments from Fred Pulver V Public Comments from Kenneth Sack (6/27/12) W Public Comments from Amy Hutton X Public Comments from Mary Russell Y Public Comments from Jason White Z Public Comments from Kenneth Sack (7/1/12) AA Email from the City of Rifle on Water Shed Permit BB Public Comments from Stephanie Syson CC Supplemental Application Information from SGM (received 7/6/12) DD Public Comments from Eden Vardy EE Public Comments from Adrian Fielder FF Public Comments from Dawne Vrabel GG Public Comments from Dylan M. Johns HH Supplemental Application Materials on Crusher Location & Noise II Supplemental Application Materials on CDPHE Permitting Public Comments from Lisa Dancing — Light JJ KK Supplemental Application Materials on Noise Public Comments from Catherine Leonaitis LL MM Public Comments from Caitlin Bourassa NN Public Comments from Jason White (7/11/12) Public Comments from Matthew Shmigelsky 00 PP Public Comments from Jennifer Vanian QQ Public Comments from Gwen Garcelon (6/25/12) Public Comments from Diane Argenzio RR SS Public Comments from Shirley Mobley TT Public Comments from Paul Huttenhower UU Public Comments from Terry Kirk W Public Comments from Sean McWilliams WW Public Comments from Michael Gorman XX Public Comments from Catherine Leonaitis YY Public Comments from Jeannie Perry ZZ Public Comments from Ken and Gail Kuhns AAA Public Comments from Meredith Oakley Public Comments from Sue Schmidt BBB CCC Comments from Debby Ellsworth (8/8/12) including photographs DDD Comments from Debby Ellsworth (8/10/12) including photographs EEE Comments from Debby Ellsworth (8/10/12) including photographs FFF Public Comments from Skye Sieber Public Comments from Mischa Popoff Public Comments from Jim Finch GGG HHH III Public Comments from Shiloh McCollum JJJ Public Comments from Michael Thompson KKK Public Comments from Jody Powell Public Comments from Laurie Loeb LLL MMM Supplemental Application Materials — Crushing Impacts & Visual Models NNN Public Comments from Frosty Merriott 000 Public Comments from Kristie Moreno PPP Public Comments from Kim Stacey QQQ Public Comments from Rita Marsh RRR Public Comments from Nancy Watts SSS Public Comments from Laurie Loeb TTT Public Comments from Alyssa Reindel Public Comments, Email and Attachments from Ken Sack (9/3/12) UUU VVV Public Comments, Email Letter and Attachments from Ken Sack (9/3/12) WWW Public Comments from Sheri Sack XXX Public Comments, Email and Attachment from Ken Sack including Letter from Louis A. Zeller YYY Public Comments from Richard & Kay Morgan ZZZ Public Comments from Craig Spaulding Public Comments from Michael & Kenda Spaulding AAAA BBBB Email from Tina Puentes (Brady Hogan) CCCC Petition from the Applicant DDDD Information Packet & Comments from Ken Sacks (labeled A) EEEE Information Packet & Comments from Ken Sacks (labeled B) FFFF Photographs of Survey Stakes and Grading Provided by Neighboring Property Owner GGGG Photographs of Site from Neighboring Propery Power Point from the Applicant NA HHHH 1111 JJJJ Photographs of Dust in the Vicinity of the Site KKKK LLLL MMMM NNNN 0000 PPPP QQQQ RRRR SSSS Illi UUUU wVV J. FROST MERRIOTT Centc.d Pub c Accoultor.' 1101 Village Rood LLA2 Cabonclole, Colorado 81623 Office 970-704-1101 Fox 970-704-9101 Enloe fro6tAsopris.ne: Web frostycpo.com Monday. August 27. 2012 Garfield County Commissioners Glenwood Springs Colorado Dear Tom. John and Mike. EXHIBIT As a founding member of the Carbondale Community Coop I again respectfully request you deny the land use change request of Bedrock Resources LLC. The plan to put a contractor's yard (with a rock and asphalt crushing operation) adjacent to the largest organic farm in Garfield County is an incompatible use and denies their "right to farm". Again Section 7-201 of the Garfield County Land Use Code is very clear when it states that any land use changes "shall not adversely affect or otherwise limit the viability of an existing agricultural operation''. As we all know this use. if granted, may very well cause Eagle Springs Organic Farms to lose their organic certification along with their 12 million dollar capital investment and 50+ "home grown" jobs. This is too big a risk to take. I would urge each of you to go visit the new Whole Foods store in Basalt to see what big business organic farming has become and why we need to encourage and safe guard this business in Garfield County to ensure diversification in our economy. Surely there are more suitable locations for Bedrock's operations. Have they explored selling the property to Eagle Farms Organic for a future expansion or maybe to another organic farmer? That would be the right thing to do here and a possible way to mitigate what looks like a really bad business decision. Thanks again for your time and what you do. `utPrntea or. recycle.;,cae' Glenn Hartmann From: Tom Jankovsky Sent: Tuesday, August 28, 2012 9:15 AM To: Glenn Hartmann Subject: FW: Bedrock Resources Attachments: GarCo Commissioners Itr.docx From: KRISTIEMORENO@ comcast.net [mailto:KRISTIEMORENO@ comcast.net] Sent: Monday, August 27, 2012 3:36 PM To: John Martin; Tom Jankovsky; Mike Samson Subject: Bedrock Resources EXHIBIT 000 Garfield County Commissioners I have been a resident of Garfield County since 1992. I have read the back and forth commentary between Eagle Springs Organic and Bedrock Resources, I cannot comprehend how an organic farm can be "Organic" being so close to the Garfield County Airport, which was there first. The airplanes that inevitably fly over the farm emit toxins and release fuel if need be, so thinking about this, why was Eagle Springs Organic not against having the air show. My only thought would be the attraction for people to come and purchase products from them. It is all about the title of "organic" and the money to be made from that title and not necessarily about being "organic". The airport has been in the same location for many years and Eagle Springs is a fairly new company, so why did the owners decide to pick this specific location? Why were they not deterred from finding a new location where they could truly be "organic? My second thought to this is why again are they within the vicinity of any gas wells. There are studies currently and will be in the future on the effects from the gas wells on people and agriculture. We all have read the articles in our own local papers about people, especially in our area that the gas wells have affected. Each has an opinion on this subject, but to me, it just doesn't make sense. I have thought long and hard about this situation and in my opinion Bedrock Resources should be allowed to move their location. They are regulated closely and have site inspections to verify that they are in compliance. Also the recycling facility would be very useful and would free up space at the landfill. 1 Sincerely Kristie Moreno 234 Dogwood Drive Silt, CO 81652 2 Glenn Hartmann From: Mike Samson Sent: Tuesday, August 28, 2012 11:20 AM To: Andrew Gorgey: Carey Gagnon: Fred Jarman Subject: FW: farms and asphalt plants don't mix From: Kim Stacey [mailto:kstacey©rof.net] Sent: Monday, August 27, 2012 4:27 PM To: Tom Jankovsky; John Martin; Mike Samson Subject: farms and asphalt plants don't mix Dear Commissioners, EXHIBIT I am writing to ask that you please deny Bedrock Asphalt's application to locate their crushing plant adjacent to Eagle Springs Organics Farm. 5o many people have worked very hard to create a thriving business that is a true asset to the community and Garfield County. It cannot continue to operate successfully next to a crushing plant. Is it in the county's interest to put one business that employs many people out of business, in order to favor another business? It does not make sense to me and I would sure miss the good food. Thank you for your time and consideration. Sincerely, Kim Stacey Carbondale, CO Glenn Hartmann From: Carey Gagnon Sent: Tuesday, August 28, 2012 11:18 AM To: Glenn Hartmann Subject: FW: Bedrock Resources LLC proposed rock -crushing operation From: Mike Samson Sent: Tuesday, August 28, 2012 11:16 AM To: Andrew Gorgey; Carey Gagnon; Fred Jarman Subject: FW: Bedrock Resources LLC proposed rock -crushing operation From: Rita Marsh[mailto:ritamarshOmountainsuDoort.com] Sent: Monday, August 27, 2012 5:09 PM To: Tom Jankovsky; John Martin; Mike Samson Subject: Bedrock Resources LLC proposed rock -crushing operation Dear Commissioners, EXHIBIT CCS Q Please follow your thoughtful decision made earlier this year to deny the asphalt plant application by now denying Bedrock's application for an asphalt crushing operation adjacent to the thriving business of Eagle Springs Organic Farm. Denying this latest application will ensure that Eagle Springs will continue to produce organically certified produce, expand the bee population — honey production, be successful in their solar farm energy production and expand their employee base. Thank you for voting in favor of organic farming in Garfield County. Most sincerely, Rita Marsh 694 Euclid Avenue, Carbondale, CO 81623 970-963-1874 1 Glenn Hartmann From: Tom Jankovsky Sent: Tuesday, August 28, 2012 9:13 AM To: Glenn Hartmann Subject: FW: Bedrock Resources Application Original Message From: Nancy Watts [mailto:nancywOsopris.net] Sent: Monday, August 27, 2012 10:10 PM To: Tom Jankovsky Cc: John Martin; Mike Samson Subject: Bedrock Resources Application EXHIBIT Dear Garfield County Commissioners, As my representative, I urge you to deny the revised application from Bedrock Resources LLC to run a rock and concrete crushing operation on the site adjacent to Eagle Springs Organics Farm (ESO). Bedrock Resources LLC and ESO are not compatible businesses, the dust from the rock crushing operation could put ESO at risk of losing their 'USDA Organic Certification'. Please use the Unified Land Use Resolution Standard 7-103 as a guide for denial, which states "The nature, scale, and intensity of a proposed use must be compatible with adjacent land uses and will not result in an adverse impact to adjacent land." Thank you for your time. Sincerely, Nancy Watts Carbondale, CO 1 Glenn Hartmann From: Tom Jankovsky Sent: Tuesday, August 28, 2012 5:11 PM To: Glenn Hartmann Subject: FW: CORRECTED LETTER! Protect our food source!!! From: Laurie Loeb [mailto:Iloeb©rof.net] Sent: Tuesday, August 28, 2012 2:52 PM To: Tom Jankovsky; John Martin; Mike Samson Cc: news(acitizentelegram.com; Ietters(agjsentinel.com; Ietters©soprissun.com Subject: CORRECTED Lt I 1 ER! Protect our food source!!! Dear Garfield County Commissioners, I am a fifty-one year resident of the Roaring Fork Valley, with 42 of those years in Carbondale. I moved to this area for the healthy environment and resulting quality of life. Outside of the season when my 42 -year-old organic vegetable garden doesn't provide my fresh produce, I depend on organic produce from Eagle Springs Farm. It is imperative to protect this source of local, clean food, water and air, and the associated existing agricultural jobs from contamination by the proposed asphalt -plant rock -crushing operation adjacent to Eagle Springs. You heard the people the last time around and apparently understood the importance of preserving a healthy and organic food production environment. The more recent application by Bedrock Resources shows little difference in the nature of use and its impact on Eagle Springs Farm. I implore you to adhere firmly to your earlier stance and once again deny the Bedrock's application. Appreciatively, Laurie Loeb Carbondale, Colorado lloeb@rof.net "Peace is not won by those who fiercely guard their differences, but by those who with open minds and hearts seek out connections." - Katherine Paterson 1 Glenn Hartmann From: Tom Jankovsky Sent: Wednesday, August 29, 2012 9:38 AM To: Glenn Hartmann Subject: FW: deny bedrock asphalt application EXHIBIT 1 -7T --r From: Alyssa Reindel [mailto:alyssa@ evergreenevents.net] Sent: Tuesday, August 28, 2012 11:32 PM To: Tom Jankovsky Subject: deny bedrock asphalt application I purchase organic produce from Eagle Springs Organic Farm through my local food co-op. Please deny the Bedrock Asphalt application, and show your support for organic farming in Garfield County. Al yav Rent,vtde,L EverGreen Events 970.987.3140 PO Box 1661 Aspen CO 81612 www.EverGreenEvents.net www.Facebook.com/EverGreenEvents ...Contact EverGreen Events for COMPOST COLLECTIONS & ZERO WASTE SERVICE in the Roaring Fork Valley... 1 Glenn Hartmann From: Kenneth Sack [kensack@me.com] Sent: Monday, September 03, 2012 10:24 AM To: Glenn Hartmann Cc: John Martin; Tom Jankovsky; Mike Samson Subject: Bedrock Resources Application Attachments: asphalt recycled cement and asphalt info.pdf; ASPHALT PLANT POLLUTION bred study.doc; asphalt health dangers.doc; Asphalt and cement recycling health study.doc EXHIBIT 1 u u1/4, Dear Commissioners, I have reviews all of the documentation in the Bedrock Application and subsequent additional information submitted. I will insert my comments in RED i will also send documentation in additional emails SECTION 7-810 USE. ADDITIONAL STANDARDS APPLICABLE TO INDUSTRIAL C. Outdoor Storage Facilities. All outdoor storage facilities for fuel, raw materials and products shall be screened by natural topography or enclosed by a fence or wall adequate to conceal such facilities from adjacent property. There is NO concealment of the proposed Outdoor Storage Facility from Eagle Springs Organic, Organic Growers or Residence at 315 CR 482, The berm may be high on their side, however due to topography, less than one foot high in many places. There is NO concealment from Residence. Therefore, the standard has not been met. E. Sound. The volume of sound generated shall comply with the standards set forth in the Colorado Revised Statutes. Bedrocks response regarding noise 4. Noise Study Compliance: As you accurately pointed out, EDI's update letter did not address the location of the crusher relative to the ability of the plan to meet the standards of the ULUR. As identified in note 2., above, the crusher is to be located at least 270 feet from the east property line. Likewise, the crusher is noted to produce 73 dB(A) at 100 feet. In the report, it is noted in Table 3 that the noise reduction of 8 dB(A) exists at 270' (by interpolation). Likewise, the reduction due to the berm construction reduces the noise by 24 dB(A). Therefore, the total reduction for the crusher is 24+8 = 32 dB(A) at the property line. This will reduce the noise emanated from the crusher to 41 dB(A): Note that for the north property line, the noise will be reduced further as the unprocessed base pile will exists prior to the crusher starting operation, the distance to the north property line is greater and the proposed storage buildings exist. They have submitted a noise study on the crusher, a crusher that according to Jeffery Simonson from SGM, has NOT BEEN IDENTIFIED as to type. size, specs, Cannot submit a noise study on an unknown machine Notwithstanding, even what they submitted, demonstrates that their noise levels will be HIGHER than allowable The residential property has NO shielding from noise so will receive well over 55dBA They opine that the North Property Line noise will be reduced further by the unprocessed base pile. even if this were true. as they process the pile and reduce its size, there would be NO shielding from the noise Therefore, the standard has not been met 1 F. Ground Vibration. Every use shall be operated so that the ground vibration inherently and recurrently generated is not perceptible without instruments at any point of any boundary line of the property. Between the heavy equipment and the crusher, there is no way for Bedrock to meet this standard No studies have been submitted regarding ground vibration Therefore, the standard has not been met 2 G. Interference, Nuisance or Hazard. Every use shall be so operated that it does not emit heat, glare, radiation or fumes which substantially interfere with the existing use of adjoining property or which constitutes a public nuisance or hazard. Flaring of gases, aircraft warning signal and reflective painting of storage tanks, or other legal requirements for safety or air pollution control measures shall be exempted from this provision. The toxic windblown dust and particulate matter that will come from the sites large piles of recycled aspialt and cement constitute both a public nuisance and hazard and substantially interfere with the existing agricultural use, the residential use and the solar panels Therefore. the standard has not been met IV. COMPREHENSIVE PLAN The Site is designated by the Comprehensive Plan of 2030 as Residential Medium High (MH) with residential densities of 2 to < 6 acres/dwelling unit. Chapter 3, Section 4, Economy, Employment and Tourism includes a number of goals, policies, and strategies relevant to the current application. Several key elements are summarized below: Goal #1: Maintain a strong and diverse economic base (for both employment and income generation). Bedrock will only move existing employees to this site it will not crate fobs I employ 50 people on the farm My Eagle Springs Crossing in Rifle, will receive its CO this week and will add an additional 50 plus lobs Eagle Springs Solar which has been put on hold due to this issue. once reactivated will add another 30 lobs to Garfield County Policy #5: The County will direct industrial development to the airport center and other appropriately designated areas. This site is NOT the airport center and is NOT an appropriately designated area for an asphalt plant This is zoned agriculture Strategy #4: Ensure that commercial/industrial development are compatible with adjacent land uses and preserve the visual quality of the county. It has been well documented that the proposed use IS NOT COMPATIBLE with the adjacent land use and certainly does NOT preserve the visual quality of the county 3. The Applicant has documented the legal and adequate physical supply of water in accordance with Section 7-104. Water quality testing has been completed 3 gallons per minute, on a two hour test certainly does not demonstrate adequate physical supply of water for proper dust control on 35 acres 6. The landscaping plan is appropriate for the site and will provide some visual screening. Landscaping plan provides NO screening for residential property whatsoever 3 4 F. Specific Industrial Use Standards -Section 7-810 of the Unified Land Use Resolution of 2008 as Amended 1. The site plan includes a 5,000 sq.ft. shop building allowing service and repair operations to be conducted in an enclosed building. Topography, slopes, and site grading will also reduce visibility of the site. The site grading has had little impact on visibility from agricultural property There has been NO attempt to reduce visibility of site from residential property 3. The Applicant should demonstrate compliance with screening for outdoor storage. Visibility from properties to the east may be an issue. Have not seen anything to show compliance 6. Impacts from ground vibration have not been identified in the Application submittals. Have not seen anytning to snow :jornpilan _ 7. Nuisance impacts inconsistent with a typical industrial operation have not been noted As noted previously, the major change in the application submittal is that of removing the contentious use, the asphalt batch plant. In this manner, we are able to reutilize nearly every report previously prepared as the remaining uses sought for this application are less intensive from an impacts standpoint We have adjusted the Noise Assessment Report (prepared by Engineering Dynamics, Inc.) and the Traffic Study (prepared by SGM). Obviously, in both cases, the respective concerns and impacts have lessened as the batch plant has been removed. This is not true on many points. The contentious issue was the Asphalt Plant that was denied. The batch plant was just a component of the Asphalt Plant. The remaining proposed use in NOT less intensive from an impacts standpoint. Actually more impact since recycled asphalt RAP contains much more pollutants than virgin asphalt and the addition of recycled cement causes additional severe environmental issues affecting our farm and organic certification. The crusherwill be placed on site is when the volume of the uncrushed material has economically justified rental and haul of a crusher into the site. Past history has demonstrated that this process is typically every 2 years, however, there is a possibility that this could be a yearly occurrence. The crushing operations typically occur over a ten day period. During the crushing operations, the weather needs to be cool enough to keep from gumming up the crusher equipment and warm enough to allow personnel to wet the piles and to keep the water from freezing. Wetting of the material during the crushing and loading process is needed to mitigate the production of dust from the operations. Because of the sensitive weather conditions, the crushing operations typically ensue during the fall, winter and early spring time periods. 5 Note that this process never HEATS up the existing asphalt. The material processed in this operation remains in the same physical state as those associated with the roads we dr ve on With the exception that the material will be crushed to powder. that will blow on surrounding agricultural land 4. Noise Study Compliance: As you accurately pointed out, EDT's update letter did not address the location of the crusher relative to the ability of the plan to meet the standards of the ULUR. As identified in note 2., above, the crusher is to be located at least 270 feet from the east property line. Likewise, the crusher is noted to produce 73 dB(A) at 100 feet. In the report, it is noted in Table 3 that the noise reduction of 8 dB(A) exists at 270' (by interpolation). Likewise, the reduction due to the berm construction reduces the noise by 24 dB(A). Therefore, the total reduction for the crusher is 24+8 = 32 dB(A) at the property line. This will reduce the noise emanated from the crusher to 41 dB(A): Note that for the north property line, the noise will be reduced further as the unprocessed base pile will exists prior to the crusher starting operation, the distance to the north property line is greater and the proposed storage buildings exist. Ilave not seen how • they will meet standards of ULUR . [hey are depending on the berm for a lot of reduction, however the berm has been improperly constructed and sits on or over the lot line, Nvhieh causes a trespass on ES() property and changes the normal drainage flow, both of \which arc not allowed and will he addressed. They will need to move the berm back from the lot line and address the trespass and drainage issues.' 5. Particulate Material from Unprocessed or Processed Asphalt Base Piles: A further clarification is requested from you as to the particulate matter expected to be generated from the asphalt base piles. It should be noted that the particulate matter to be generated will be that of the clay soil particles that exist in the gravel that becomes mixed with the asphaltic concrete when excavated. The asphalt binder in the mix is not expected to contribute to the particulate matter due to the fact that it has been bound to the various particles during its initial "manufacturing" phase and, in fact, will help to bind to some of the clay particles that may come with the base. In any case, during the crushing operations of the unprocessed base, water is to be used in the operation to mitigate dust and, thus, the production of particulate matter. The very nature of adding water to the soils to mitigate dust is to enhance the weight of the particles by increasing density, surface tension and cohesiveness of the particles with adjacent particles. This is the same end result already achieved by the asphalt binder when the asphaltic concrete was manufactured. Asphalt base removed from highways... is NOT just clay, gravel and concrete. They have not addressed the pollutants generated from years of vehicle traffic including heavy metals and lead. They have not addressed the recycled cement and the silica and toxic components there. 6. Traffic Volumes expected: As an additional clarification, you have requested the anticipated volumes of traffic to be generated from the site in comparison with the prior proposal that included the asphalt batch plant. With the asphalt batch plant included in the trip generation calculations, the average daily trips anticipated for the project was 85 trips per day. By removing the asphalt batch plant, but still including some truck traffic for hauling materials in and out of the storage area, we anticipate the 6 projected average daily trips to be 47 trips per day. I have not seen the calculation for the amount of water trucks required to provide enough water for dust control, fire suppression, processing activity... It should also be noted that they said they would use mag chloride on the roads twice a year and later reduce to once a year??? This demonstrates once again the lack of understanding of what it will take to comply with dust mitigation standards. Also, in talking with Chip, an APEN is required for the crusher Since the APEN is equipment specific, the proposal would be that there would not be any crushing operations ensue until the specific rental equipment is found and specified. As the crushing operations proposed are very intermittent. the APEN will need to be applied for when the equipment to be rented is identified. Also, the timing of the operation at that point can be identified as well (and would be part of the permit) Thanks, Jefferey S. Simonson, PE, CFM Principal Bedrock is applying for a permit to process recycled asphalt, crushing activity.... They have submitted noise studies on machinery that they have not even identified. Since they have no idea on the equipment they will be using, they cannot provide a study on what environmental effect. dust. air or noise pollution will be generated by same. Table 2 in the ApriI30, 2012 letter addresses the noise sources that would be in Frontier Paving Contractor's Yard. Not included in that table was the noise emission of the crusher, which most recently has been included as an additional piece of equipment in the Contractor's Yard. The crusher will be used occasionally to process road material (asphalt black top). As presented in Table 2, the crusher produces 73 dB(A) at 100ft. and 65 dB(A) at the closest property line; 250ft. to the northeast when there is no noise mitigation whatsoever between the crusher and the property line. There is a berm located beyond the ditch which will initially reduce the crusher noise level at the property by 5 dB(A) making the noise level at the property line 60 dB(A), which means that an additional 5 dB(A) noise reduction is required in order to keep the noise level below the 55 dB(A) limit. Before crushing takes place salvaged roadway asphalt will be dumped from the service road onto an area between the service road and the crusher. Some of the material will be left in place to form a second 12 ft. high noise barrier berm. This berm will provide a 6 dB(A) reduction and the noise level at the property line will be less than 55 dB(A). Additional noise reduction of 5 dB(A) can also be achieved by locating the crusher at the south corner of the storage area. Providing noise information for a yet unidentified crusher. Even their best attempt to push this through, they are showing 65dBA at the lot line which is well over the allowed limits. 3. A copy of the easement document for the adjoining property needs to be provided and the status of easements for Holy Cross Electric clarified. New easements for electric service may be required Have not seen an easement document for MY adjoining property 9. The Applicant has provided a detailed Traffic Study prepared by SGM. The study addresses traffic generation from the originally proposed use, improvement warrants, and impacts on off-site intersections. A reduction in traffic generation is anticipated by the change in the proposed use. Water truck traffic is not addressed 10. A noise analysis update is provided along with a supplemental analysis of the crusher operation, which demonstrate State and ULUR compliance. The noise analysis update in NO way demonstrates compliance with State and ULUR 11. Dust mitigation plans are provided and the Applicant has further clarified wetting as the primary dust suppression for the proposed crushing activity. CDPHE air quality permitting for the crushing activity needs to be addressed Dust mitigation plan ie twice a year mag chloride for roads — not acceptable What is the plan for stock piles and the rest of the property Where are they getting the water from- 3 gallon per minute well, Untested for recovery time beyond 2 hours. 3. General description of crushing operations: As we discussed with you in your site walk, the crushing operations are to be performed when temperatures are cool and there is no chance for the asphalt in the asphaltic concrete to "gum up" the crushing equipment. This operation will not allow the asphalt to be heated nor processed in a warm state as is typical of an average late spring/early autumn and summer day. However, this process could be performed on a cool day when during that time period (such as a rainy day). The only intent is to crush piles of asphalt that have been hauled to the site from construction projects that Frontier Paving or other associated contractors have been involved in. There are going to be two piles of asphaltic concrete on the site. One that has been processed (crushed) and is now ready to be used as road base and pipe bedding and one that is yet to be crushed the description is way to vague. Temperatures COOL — how many COOL days do we have in summer. Need specific information and data. A major impact review requires more than a bunch of vague statements. What other associated contractors are allowed to bring recyclable products to the site. What products are being processed? Asphalt. Cement. Asphalt shingles? Ken Sack cell 954-249-5674 Eagle Springs Organic Eagle Springs Solar 5454 County Rd 346 Silt, CO 81650 Eagle Springs Crossing 1733 Railroad Ave Rifle, CO 81652 8 110 TEICHERT AGGREGATES MATERIAL SAFETY DATA SHEET P.O. BOX 15002 SACRAMENTO, CALIFORNIA 95851 EFFECTIVE DATE: FEBRUARY 2004 I. IDENTIFICATION TRADE NAME: RECYCLED CONCRETE AND/OR RECYCLED ASPHALT COMMON NAME: RECYCLED MATERIALS BASE, MISCELLANEOUS BASE MANUFACTURER'S NAME: TEICHERT AGGREGATES, PO BOX 15002, SACRAMENTO CA 95851 TELEPHONE NUMBER: 916 484-3011 DATE REVISED: AUGUST 2003 PRODUCT DESCRIPTION: PRODUCT IS CRUSHED RECYCLED CONCRETE, ASPHALT AND/OR SIMILAR MATERIALS ORIGINATING AS NON -CONTAMINATED CONSTRUCTION DEBRIS. DEPARTMENT OF HAZARD CLASSIFICATION N/A TRANSPORTATION SHIPPING NAME N/A II. PHYSICAL PROPERTIES BOILING POINT, 760 mm. Hg N/A FREEZING POINT N/A SPECIFIED GRAVITY (H20 = 1) 2.3 — 2.8 VAPOR PRESSURE N/A VAPOR DENSITY (air = 1) N/E SOLUBILITY IN WATER, /o BY WT. NEGLIGIBLE PERCENT VOLATILES•N/E BY VOLUME EVAPORATION RATE Butyl Acetate = 1) N/E APPEARANCE AND ODOR PIECES OF CRUSHED CONCRETE AND/OR ASPHALT MATERIAL, ODORLESS III. HAZARDOUS INGREDIENTS MATERIAL % PEL TLV CAS NUMBER CRUSHED CONCRETE AND/OR CRUSHED ASPHALT (1) (2) 100 10 mg/m3. 5 mg/m3.. 10 mg/m3 N/E CRYSTALLINE SILICA 0.3 mg/m3... 0.1 mg/m3' " 0.05 mg/m3 14808-060-7 NOTE: (1) CRUSHED CONCRETE AND CRUSHED ASPHALT CONTAIN ROCK AND SAND. NATURAL SAND INCLUDES QUARTZ, A FORM OF CRYSTALLINE SILICA. COMPOSITION VARIES. (2) MATERIAL MAY INCLUDE SMALL PERCENTAGES (LESS THAN 15%) OF GLASS, PORCELAIN, OR OTHER CERAMIC MATERIALS. •: TOTAL DUST, PARTICULATES NOT OTHERWISE REGULATED. ": RESPIRABLE DUST, PNOR. "'TOTAL SILICA *'"RESPIRABLE SILICA IV. FIRE AND EXPLOSION HAZARD DATA FLASH POINT (test method) N/A • FLAMMABLE LIMITS IN AIR, % by volume LOWER N/A UPPER N/A EXTINGUISHING MEDIA NONE SPECIAL FIRE FIGHTING PROCEDURES NONE UNUSUAL FIRE AND EXPLOSION HAZARDS NONE EMERGENCY PHONE NUMBER N/A = not applicable (916) 484-3011 N/E = not established V. HEALTH HAZARD INFORMATION EFFECTS OF ACUTE OVEREXPOSURE SWALLOWING NO SIGNIFICANT HAZARD POSED SKIN CONTACT SHORT TERM IRRITATION INHALATION PRODUCT FRAGMENTS MAY INCLUDE FINE SILICA (QUARTZ) DUST. PROLONGED OR ROUTINE INHALATION OF FINE QUARTZ DUST CAN LEAD TO THE LUNG DISEASE KNOWN AS SILICOSIS. EYE CONTACT SHORT TERM IRRITATION EFFECTS OF REPEATED OVEREXPOSURE OF VERY HIGH LEVELS OF AIRBORNE DUS'" MAY QUARTZ DUST CAN LEAD TO THE LUNG DISEASE KNOWN AS SHORTNESS OF BREATH, AND INCREASED ACUTE: AIRBORNE PARTICLES CAN CAUSE EYE IRRITATION. INHALATION PRODUCE COUGHING AND IRRITATION. CHRONIC: PROLONGED AND ROUTINE INHALATION OF RESPIRABLE SILICOSIS. EARLY SYMPTOMS OF SILICOSIS INCLUDE COUGHING, WHEEZING, LIKELIHOOD OF OTHER LUNG PROBLEMS. OTHER HEALTH HAZARDS SUCH AS DERMATITIS, PRIOR RESPIRATORY TRACT MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: PRIOR SKIN PROBLEMS CONDITIONS SUCH AS BRONCHITIS. EMERGENCY AND FIRST AID PROCEDURES 1 OF SMALL AMOUNTS OF THE MATERIAL IS HEALTH HAZARD. SWALLOWING SEEK MEDICAL ADVICE, BUT INGESTION NOT EXPECTED TO POSE A SIGNIFICANT SKIN WASH SKIN WITH WATER AND MILD SOAP. INHALATION REMOVE TO FRESH AIR. SEEK MEDICAL ATTENTION IF DISCOMFORT OR IRRITATION PERSISTS. EYES FLUSH EYES WITH LARGE AMOUNTS OF WATER. SEEK MEDICAL ATTENTION. SUSPECTED CANCER AGENT? NO FEDERAL OSHA NO NTP X IARC NOTE: IARC LISTS CRYSTALLINE SILICA AS HUMAN CARCINOGEN. CRYSTALLINE SILICA POSES A HEALTH HAZARD WHEN IT IS INHALED AS A DUST. PROP 65 WARNING: CRUSHED RECYCLED CONCRETE AND ASPHALT CONTAINS QUANTITIES OF FINE CRYSTALLINE SILICA. CRYSTALLINE SILICA (QUARTZ) DUST IS LISTED UNDER TITLE 22, SECTION 12000, AS A CHEMICAL KNOWN TO THE STATE OF CALIFORNIA TO CAUSE CANCER. ALWAYS FAMILIARIZE YOURSELF WITH THE HAZARDS OF THE MATERIALS AND EQUIPMENT YOU ARE USING AND FOLLOW THE PRECAUTIONS INDICATED ON PRODUCT LABELS, MATERIAL SAFETY DATA SHEETS AND YOUR HEALTH AND SAFETY TRAINING PROGRAM. VI. REACTIVITY DATA STABILITY UNSTABLE STABLE CONDITION NONE X TO AVOID INCOMPATIBILITY (materials to avoid) STRONG OXIDIZERS, SUCH AS STRONG ACIDS. HAZARDOUS COMBUSTION OR DECOMPOSITION PRODUCTS CARBON DIOXIDE, SULFUR DIOXIDE HAZARDOUS POLYMERIZATION May Occur Will Not Occur CONDITION NONE X TO AVOID VII. SPILL OR LEAK PROCEDURES STEPS TO BE TAKEN IF MATERIAL IS RELEASED OR SPILLED MATERIAL DOES NOT POSE HAZARD TO IMMINENT HAZARD TO WORKERS OR THE ENVIRONMENT. TRANSFER SPILLED MATERIAL TO CONTAINERS FOR REUSE OR DISPOSAL WITH NORMAL TRASH. USE NORMAL GOOD HYGIENE PRACTICES TO MINIMIZE EXPOSURE (WEAR SKIN AND EYE PROTECTION, AS NECESSARY). WASTE DISPOSAL METHOD PRODUCT IS NOT CLASSIFIED AS HAZARDOUS WASTE. VIII. SPECIAL PROTECTION INFORMATION RESPIRATORY PROTECTION (specific type) IF AIRBORNE CONCENTRATIONS EXCEED OSHA PERMISSIBLE EXPOSURE LIMITS, WEAR NIOSH-APPROVED RESPIRATORS TO ACHIEVE EXPOSURES BELOW THE PEL. VENTILATION N/A PROTECTIVE GLOVES AVOID PROLONGED OR REPEATED CONTACT WITH PRODUCT. EYE PROTECTION AVOID EYE CONTACT: WEAR SAFETY GLASSES OR GOGGLES, AS NEEDED. OTHER PROTECTIVE EQUIPMENT COVERALLS OR OTHER WORK CLOTHING THAT MINIMIZES SKIN CONTACT WITH PRODUCT. IX. SPECIAL PRECAUTIONS PRECAUTIONS TO BE TAKEN IN HANDLING AND STORING: NONE X. ADDITIONAL INFORMATION ADDITIONAL HEALTH DATA PROP 65 WARNING: CRUSHED RECYCLED CONCRETE AND ASPHALT CONTAINS QUANTITIES OF CHRYSENE, BENZO(A)PYRENE AND BENZO(A)ANTHRACENE. THESE PETROLEUM ASPHALT COMPONENTS ARE LISTED UNDER TITLE 22, SECTION 12000, AS CHEMICALS KNOWN TO THE STATE OF CALIFORNIA TO CAUSE CANCER AND BIRTH DEFECTS OR OTHER REPRODUCTIVE HARM. ALWAYS FAMILIARIZE YOURSELF WITH THE HAZARDS OF THE MATERIALS AND EQUIPMENT YOU ARE USING AND FOLLOW THE PRECAUTIONS INDICATED ON PRODUCT LABELS, MATERIAL SAFETY DATA SHEETS, AND YOUR HEALTH AND SAFETY TRAINING PROGRAM. SKIN EXPOSURE TO ASPHALT CAN CAUSE WORKERS TO EXPERIENCE PHOTOSENSITIZATION, A CONDITION WHERE THE EXPOSED AREA OF SKIN BECOMES VERY SENSITIVE TO SUN LIGHT AND OTHER SOURCES OF ULTRAVIOLET (UV) LIGHT. WITHOUT EXPOSURE TO UV, SENSITIVE SKIN MAY APPEAR TO BE SUNBURNED. WITH EXOSURE TO UV, THE SKIN MAY BLISTER AND DEVELOP SORES. AS WITH ANY CHEMICAL, SKIN CONTACT WITHTHIS PRODUCT, AND THE BREATHING OF RODUCT DUST SHOULD BE MINIMIZED. WE STRONGLY RECOMMEND THAT THE PRECAUTIONS STATED IN THIS MSDS BE FOLLOWED WHEN HANDLING THE PRODUCT. Teichert Aggregates believes the information contained herein is accurate; however, Teichert Aggregates makes no guarantees with respect to such accuracy and assumes no liability in connection with the use of the information contained herein by any party. The provision of the information contained herein is not intended to be and should not be construed as legal advice or as ensuring compliance with any federal, state, or local laws and regulations. Any party using this product should review all such laws, rules, or regulations prior to use. NO WARRANTY IS MADE, EXPRESSED, OR IMPLIED OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR OTHERWISE. REVISED 2/04 What Are the Dangers of Working in a Concrete -Based Plant? By Lee Morgan, eHow Contributor Concrete factory workers face several health hazards. Employees who work with concrete are subject to clangers from exposure to the material. While the extent of the danger related to the concrete is significant in jobs such as construction, the highest risk to concrete -specific hazards is within the facilities that manufacture the concrete, according to the 10P Science website. Knowing the potential risks associated with working in a concrete -bused plant can help workers prepare for the fob and minimize the dungers of working there. 1. Inhalation Dangers o People who work in a concrete factory setting are constantly exposed to the dust from the dried raw materials. Those who sweep and clean are especially susceptible to inhalation hazards. Portland cement is a common material used to make concrete, and the dust from the dried cement has been labeled a possible cancer risk, according to the IOP Science website. Inhaling this dust is suspected to increase risk of several cancers, including pharyngeal carcinoma and gastric cancer. Inhaling this material is also known to cause nose and throat irritation and respiratory difficulties. Exposure to crystalline silica dust, another concrete raw material, can lead to a serious lung disease called silicosis, according to the State Compensation Insurance Fund website. 2. Skin Contact o While working with and mixing concrete in a plant, workers are likely to expose their skin to wet concrete from time to time. As long as the substance is washed off immediately, irritation is unlikely. However, extended contact with the skin will cause concrete to burn the skin because of the alkaline nature of the mixture. These burns can range from first- to third-degree and skin ulcers may result if the substance is in contact with the skin for long periods. Even with protective clothing, workers may get bits of concrete trapped inside boots or have it soak through layers of clothing, according to the Electronic Library of Construction Occupational Safety and Health. This risk is the same for both concrete plant workers and construction workers dealing with concrete. 3 Eye Injury The same dust that can cause lung problems when inhaled can also do damage to the worker's eyes. Depending on the amount of dust that enters the eyes and the duration before they are rinsed clean with water, the effects can range from minor eye irritation and redness to chemical burns on the eyeballs, according to the State Compensatior Insurance Fund website. Allergies Some workers who are in the presence of cement regularly develop an allergy (or occupational asthma) to the hexavalent chromium in the product. This asthma -like allergy causes breathing difficulty and wheezing. Chromium allergies may also lead to skin rash or skin ulcers, according to the Electronic Library of Construction Occupational Safety and Health website. Inhalation and Dermal Exposure among Asphalt Paving Workers M. D. McCLEANI,', 2. R. D. RINEHART2, 3. L. NGOI, 4. E. A. EISENI, 5. K. T. KELSEY I and 6. R. F. HERRICKI +Author Affiliations 1. 'Harvard School of Public Health, Boston, MA 02115, USA: 'Occupational Safety and Health Administration, Washington, DC 20210, USA 1. 'E-mail: mmcclean@hsph.harvard.edu Next Section Abstract The primary objective of this study was to identify determinants of inhalation and dermal exposure to polycyclic aromatic compounds (PACs) among asphalt paving workers. The study population included three groups of highway construction workers: 20 asphalt paving workers, as well as 12 millets and 6 roadside construction workers who did not work with hot -mix asphalt. During multiple consecutive work shifts, personal air samples were collected from each worker's breathing zone using a Teflon filter and cassette holder connected in series with an XAD-2 sorbent tube, while dermal patch samples were collected from the underside of each worker's wrist. All exposure samples were analyzed for PACs, pyrene and benzo[a]pyrene. Inhalation and dermal PAC exposures were highest among asphalt paving workers. Among paving workers, inhalation and dermal PAC exposures varied significantly by task, crew, recycled asphalt product (RAP) and work rate (inhalation only). Asphalt mix containing high RAP was associated with a 14)11 increase in inhalation PAC exposures and a 2 -fold increase in dermal PAC exposure, compared with low RAP mix. The inhalation PAC exposures were consistent with the workers' proximity to the primary source of asphalt fume (paver operators > screedmen > rakers > roller operators), such that the adjusted mean exposures among paver operators (5.0 .tg/m3, low RAP; 24 lig/m3, high RAP) were 12 times higher than among roller operators (0.4 pg/m3, low RAP; 2.0 µg/m3, high RAP). The dermal PAC exposures were consistent with the degree to which the workers have actual contact with asphalt -contaminated surfaces (rakers > screedmen > paver operators > roller operators), such that the adjusted mean exposures among rakers (175 ng/cm2, low RAP; 417 ng/cm2, high RAP) were approximately 6 times higher than among roller operators (27 ng/cm2, low RAP; 65 ng/cm2, high RAP). Paving task, RAP content and crew were also found to be significant determinants of inhalation and dermal exposure to pyrene. The effect of RAP content, as well as the fact that exposures were higher among paving workers than among millers and roadside construction workers, suggests that the PAC and pyrene exposures experienced by these paving workers were asphalt -related. INTRODUCTION Asphalt (or bitumen) is a dark, semi-solid residual that results from the non-destructive distillation of crude petroleum oil and is widely used as an industrial material (Gamble el al., 1999). The annual production of hot -mix asphalt amounts to -267 million tons in Western Europe and -440 million tons in the USA (Partanen and Boffetta. 1994), while the road -paving industry employs -300 000 workers in the United States and accounts for 87% of domestic asphalt production (Asphalt Institute, 1990). The American Conference of Governmental Industrial Hygienists (ACGIH) currently recommends a threshold limit value for asphalt fumes of 0.5 mg/m3 (benzene -soluble aerosol), while the National Institute for Occupational Safety and Health (NIOSH) recommends an exposure limit of 5 mg/m3 (total particulate during any 15 min period). The Occupational Safety and Health Administration (OSHA) currently has no standard for exposure to asphalt fumes. Asphalt contains a complex mixture of polycyclic aromatic hydrocarbons (PAHs), some of which are either known or suspected to be carcinogenic. Because asphalt workers are occupationally exposed to PAHs via inhalation and dermal absorption, the carcinogenic potential of asphalt has been under investigation since the 1960s. In fact, numerous epidemiological studies have described an excess risk of cancer (lung, stomach, bladder, leukemia, and non -melanoma skin cancer) among asphalt -exposed workers (Partanen and Boffetta, 1994; Boffetta et al., 1997, 2003). However, the relationship between occupational asphalt exposure and cancer risk remains unclear. Comprehensive reviews of the available literature have been conducted (IARC, 1985; Chiazze el al., 1991; Partanen el al., 1995; NIOSH, 2000). These reviews were consistent in their evaluation of existing studies, concluding that the lack of data on exposure and potential confounders (such as smoking and exposure to coal tar) were significant limitations that made it impossible to demonstrate a causal association. Specifically, the existing studies were criticized for weak or absent exposure assessments that lacked quantitative measurements of exposure to asphalt or its constituents. Occupational exposure to PAHs has been shown to be associated with an excess risk of cancer in other populations such as coke oven (Costantinoet al., 1995), foundry (Andjelkovich el al., 1990) and aluminum production workers (Armstrong et al., 1994), and it is possible that random misclassification of exposure has limited the ability of previous studies to detect a positive association between occupational asphalt exposure and cancer. Accordingly, the risk of work-related cancer among asphalt workers continues to be an important and controversial issue. As an alternative to the more common approach of evaluating inhalation exposure to individual PAHs, this study uses a task -based approach to evaluate both inhalation and dermal exposure to polycyclic aromatic compounds (PACs) among asphalt paving workers. The primary objectives of this study were: (i) to determine whether inhalation and dermal exposures to PACs are higher among asphalt - exposed workers than among non -exposed workers; (ii) to identify job factors (i.e. paving task, percent recycled asphalt, etc.) that affect inhalation and/or dermal exposure to PAC; and (iii) to characterize the relationship between inhalation and dermal exposures. Previous SectionNext Section MATERIALS AND METHODS Study population The study population included three groups of highway construction workers: 20 asphalt paving workers, as well as 12 millers and 6 roadside construction workers who did not work with hot -mix asphalt. All participants were male, worked for the same company, and lived in the Greater Boston area. Written and informed consent was obtained from each study subject prior to sampling, and all sampling was conducted in accordance with a standardized human subjects protocol that was approved by the Institutional Review Board at the Harvard School of Public Health. The paving workers were exposed to hot -mix asphalt while resurfacing roads. At the job -sites, the asphalt was loaded into the front hopper of a paving machine while the screed (attached to the back of the paving machine) was used to adjust the thickness and width of the applied mix. The specific characteristics of the asphalt varied by job and contained recycled asphalt pavement (RAP) in amounts ranging from 0 to 40% of the total mix. An alternative to using 100% virgin mix, RAP refers to milled material that is generated during the grinding of old roads, transported to the asphalt plant and recycled into a new batch of asphalt. Each of the three paving crews consisted of six to eight workers who performed four different tasks: paver operators, screedmen, rakers and roller operators. The paver operator sat between the hopper and the screed while controlling the path and speed of the paving machine. Two screedmen stood on a platform behind the screed, one controlling the left side and the other controlling the right side. Two to three rakers worked in close proximity to the back of the screed, using rakes and shovels to fill holes and gaps. One or two rolling machines. each with their own operator, were then used to smooth and compact the laid -down asphalt. The milling workers and roadside construction workers were evaluated because the location and nature of their work is similar to the paving workers, except that neither group typically works with hot -mix asphalt. The milling workers used a large grinding machine and a smaller trimming machine to remove layers of aged asphalt from existing roads in preparation for resurfacing by the paving crews, whereas the roadside construction workers worked with hand tools while repairing guardrails or installing curbs and sidewalks. Study design Personal air and dermal patch samples were collected from 38 workers during full work shifts at job - sites located within 1 h of Boston, MA. In May and June 1999, three days of exposure measurements were obtained from 20 pavers. In May and June 2000, multiple days of exposure measurements were obtained from 12 millers and 6 construction workers. Due to the repeated -measures design, the total number of `worker -days' evaluated in the exposure assessment includes 60 worker -days for pavers, 39 worker -days for millers and 11 worker -days for construction workers. Each worker -day of sampling included the collection of personal air samples (particulate and vapor), dermal patch samples and meteorological information. Questionnaire information (including demographic, job characteristics and lifestyle) and detailed observations for each worker were also obtained. Personal air samples Personal air samples were collected from each worker in accordance with NIOSH Method 5506 (NIOSH, 1998a). The air sampling system consisted of a Teflon filter and cassette holder to collect particulate PACs, an XAD-2 sorbent tube to collect the vapor phase PACs, and a personal air sampling pump operating at 2 1/min. The 37 mm diameter filter (PTFE -laminated with 2 µm pore size) was placed in a cassette and attached to each worker's lapel near the breathing zone, and the sorbent tube containing XAD-2 was attached inline and downstream from each filter cassette. Flow rates were checked before, during and after sample collection using a calibrated rotameter. Opaque filter cassettes and foil -wrapped sorbent tubes were used to prevent sample degradation from sunlight. Samples were transported in coolers and stored at —20°C. Dermal patch samples The dermal patch samples were collected from both wrists of each worker. The dermal sampling method was a modification of the method described by Jongeneelen et al. (1988) and Van Rooij et al. (1993). A soft polypropylene filter (Gelman Sciences, 47 mm diameter, 10 gm pore size) was attached to an exposure pad to create a dermal patch with an effective surface area of 8.71 cm2. Using an adhesive backing, the patches were attached to the underside of each wrist and resulted in the collection of two samples per worker -day. Following sample collection, the exposure pads were placed in foil -wrapped Petri dishes, transported in coolers, and stored at —20°C. Laboratory analysis The analytical method for measuring PACs was developed using a modified version of NIOSH Method 5800 (NIOSH, 1998b). NIOSH Method 5800 was initially developed because the individual components of asphalt -related PACs cannot be easily separated or quantified (NIOSH, 2000). For the PAC analyses in this study, the excitation and emission wavelengths (excitation 270 nm and emission 415 nm) were optimized to target the four -ring and larger PACs, a range that includes carcinogenic compounds such as benzo[a]pyrene (BAP), benzo[a]anthracene, benzo[b]fluoranthene, chrysene and dibenz[a,h]anthracene. Particulate and vapor samples were extracted as follows: (i) 4 ml of hexane were added; (ii) samples were sonicated for 1 h; (iii) 2 ml were syringe -filtered and transferred to a clean tube; and (iv) 2 ml DMSO were added for a final extraction volume of 4 ml. Dermal patch samples were: (i) cut with a 33.3 mm punch and each cut out transferred to a labeled culture tube; (ii) 4 ml of DMSO were added; (iii) tubes were capped and sonicated for 1 h; (iv) 2 ml of the extract were transferred to a clean culture tube; and (v) 2 ml of hexane were added for a final extraction volume of 4 ml. For all air and dermal samples, the extracted mixtures were `tumbled' overnight, layers were transferred to separate tubes and the DMSO layer was analyzed on the high-pressure liquid chromatograph (HPLC; Hewlett-Packard Agilent Model #1100) for PACs, pyrene and BAP. Known amounts of PAC, pyrene and BAP were diluted to prepare concentrations of 0, 10, 30, 100, 200, 400 and 800 ng/ml. The resulting data produced linear standard curves with intercepts close to 0.0, and r - squared values of -1 (0.97-0.99). Estimated as three times the standard deviation of the field blanks, method limits of detection (LOD) were calculated for PACs (LOD& = 0.2 µg/m3, LODde„„,, = 38 ng/cm2), pyrene (LOD,;, = 0.01 LODder,,,,,= 2.6 ng/cm2) and BAP (LOD,, = 0.01 .tg/m3, LODda„,,, = 0.6 ng/cm2). The total number of field blanks equaled 17% of air samples and 18% of dermal samples. In cases where the mean field blank amounts were significantly different from zero (a = 0.05), the corresponding data were corrected by subtracting the mean field blank amounts from the sample amounts. Data analysis The air and dermal exposure data were analyzed using descriptive statistics, graphic displays, correlation coefficients and linear mixed -effects models. Shapiro -Wilks' tests and graphic displays indicated that the air and dermal data were not normally distributed; however, a log -transformation of the data did result in an approximately normal distribution. Accordingly, all statistical analyses were conducted using the log -transformed air and dermal data. All statistical analyses were conducted using SAS statistical software, and statistical significance is reported at the 0.05 level. One total air exposure estimate was calculated for each worker on each sampling day by adding the particulate and vapor measurements. Similarly, one dermal exposure estimate was calculated for each worker on each sampling day by averaging the left and right wrist measurements. When only one wrist measurement was available, the result from that one sample was used in place of the average. Values less than detection limits were included in analyses as one-half the detection limit. Six individual dermal samples collected from two workers were excluded from the analysis because there was sufficient evidence to suspect that the samples had been contaminated with diesel fuel. Both workers were laborers on the same paving crew who were observed to be deliberately contaminating the dermal patches with fuel. Furthermore, these six patches were visibly discolored due to saturation, and the resulting PAC measurements were orders of magnitude higher than all other samples. Traditional methods of estimating correlation coefficients (i.e. Pearson, Spearman) could not be used due to the repeated -measures design of the study. Use of these traditional methods would erroneously ignore the number of subjects as the correct sample size while instead using the total number of observations as the incorrect sample size, thereby increasing the degrees of freedom (Hamlett et al., 2003). As an alternative, all correlation coefficients were estimated using linear mixed -effects models as described by Hamlett et al. (2003). Linear mixed -effects models were also used to analyze the inhalation and dermal PAC data by job, by paving task, and to evaluate the other potentially important job factors such as RAP, crew, work rate (tons of asphalt applied per hour) and ambient temperature (°F). The repeated -measures design and use of linear mixed -effects models allowed for evaluation of the fixed effects while estimating between- and within -worker variation. The models used to evaluate inhalation and dermal PAC exposure among the asphalt paving workers can be described as Kik/ = ht (,lyra;r) = I10 + ills; TASKi,,- + 32iCREtitir.i;r + ;taR.AP, + .H.LWORK RATE,, follows:+ i4TEMP;; + h; + &a.m.! where X,,k, represents the exposure level of the ith paving worker on thejth day, and Y 0 is the natural logarithm of measurement X„k,. The 13s in the paving model represent the fixed effects for each of the covariates where k = {paver operator, roller operator, raker, screedman} and 1= {crew A, crew B, crew C}. Models were fitted using a compound symmetry covariance matrix and different combinations of fixed effects were evaluated using maximum likelihood (ML) estimation (Wolfinger, 1993). The different versions of the models were compared using Akaike's Information Criteria diagnostic values, and the final model was fit using restricted maximum likelihood (REML) estimation. Previous SectionNext Section RESULTS Table 1 presents the summary statistics for the inhalation and dermal exposure data, summarizing the PAC, pyrene and BAP data for paving workers, milling workers and roadside construction workers. Because the data were not normally distributed, the geometric mean, geometric standard deviation and range were used to describe the distribution of the data. Among all workers, BAP was rarely detected above the detection limits in air (LOD = 0.01 µg/m3) or dermal samples (LOD = 0.6 ng/cm2). Summary statistics for inhalation and dermal exposure data In air samples collected from paving workers, PACs were detected above the LOD (0.2 .tg/m3) in 97% of the samples. The partitioning of PACs was such that 65% was detected in the particulate phase (filters) and 35% in the vapor phase (XAD tubes). In the same samples, pyrene was detected above the LOD (0.01 µg/m3) in 98% of samples, and partitioned such that 24% was detected in the particulate phase and 76% in the vapor phase. Inhalation exposure to PACs was higher among paving workers than among millers (P = 0.007) and roadside construction workers (P < 0.001). In dermal samples collected from paving workers, PACs were detected above the LOD (38 ng/cm2) in 68% of the samples, and the PAC measurements from left and right wrists were strongly correlated (r = 0.87, P < 0.001). In addition, the results of a Wilcoxon signed -rank test indicated that dermal exposure to PACs was not significantly different between dominant hand and non-dominant hand (P = 0.2). Dermal exposure to PAC was higher among paving workers than among millers (P< 0.001) and roadside construction workers (P = 0.09). Figure 1 shows the relationship between PACs and pyrene among paving workers. In air samples (Fig. la), there was a strong correlation between PAC and pyrene (r = 0.87, P < 0.001), whereas Fig. lb shows a weaker correlation between PAC and pyrene in dermal samples (r = 0.65, p = 0.002). Figure 2 shows the relationship between inhalation exposure and dermal exposure among paving workers. For exposure to PACs (Fig. 2a), the relationship between inhalation and dermal exposure was different among rakers (r = 0.15, P = 0.5) than among non -rakers (r = 0.45, P = 0.01). However, for exposure to pyrene (Fig. 2b), the correlation between inhalation and dermal exposure (r = 0.59, P = 0.006) was stronger than for PAC exposure and did not vary by task. w` • ...sem.. View larger version: • In this page • Ina new window • Download as PowerPoint Slide Fig. 1. Correlation between PACs and pyrene among paving workers, evaluated in (a) air samples and (b) dermal samples. View larger version: • In This page • In a new window • Download as PowerPoint Slide Fig. 2. Correlation between inhalation and dermal measurements among paving workers, evaluated for (a) PAC exposure and (b) pyrene exposure. Table 2 presents the parameter estimates and P -values for all variables in the final paving models evaluating inhalation and dermal exposure to PACs and pyrene. The models evaluated the fixed effects of five variables: task, a categorical variable consisting of four levels (paver operator, roller operator, screedman and laborer); crew, a categorical variable consisting of three levels (crew A, crew B and crew C); RAP, a categorical variable that was dichotomized as 'high RAP' and low RAP' using the average RAP of 26% as a cut-off point (using the median RAP of 29% would have resulted in identical 'high RAP' and 'low RAP' categories); work rate, a continuous variable representing the tons of asphalt applied per hour; and ambient temperature, modeled as a continuous variable. Ambient temperature was not found to be a significant determinant of exposure and was excluded from the final models. View this table: • In this window • In a new window Table 2. Results of final models evaluating PAC and pyrene exposure among paving workers For inhalation exposure to PACs among paving workers, the variables task (P < 0.0001), RAP (P = 0.0005) and work rate (P = 0.004) were significant while crew was marginally significant (0.06), such that these variables explained 78% of the between -worker variability and 63% of the within -worker variability. With the exception of work rate, the same variables were found to be significant determinants of inhalation exposure to pyrene, such that the variables in the final pyrene model explained 90% of the between -worker variability and 83% of the within -worker variability. The task - based results for both PACs and pyrene indicated that paver operators were the highest exposed, followed by screedmen, rakers and roller operators. Inhalation exposures to PAC and pyrene were found to be significantly higher when asphalt contained high RAP versus low RAP, and were found to increase as the work rate increased. The variable crew was retained in the model so that the fixed effects of the other job factors could be evaluated while adjusting for crew -based differences. For dermal exposure to PACs among paving workers, the variables task (P= 0.003), RAP (P = 0.03) and crew (P = 0.03) were significant determinants of exposure, such that these variables explained 57% of the between -worker variability and 15% of the within -worker variability. Task, RAP and crew were also found to be significant determinants of dermal exposure to pyrene, such that the variables in the final pyrene model explained 13% of the between -worker variability and 32% of the within - worker variability. As with the inhalation exposures, dermal exposures to PACs and pyrene were also found to be significantly higher when asphalt contained high RAP versus low RAP. The task -based results for dermal PAC exposure indicated that rakers were the highest exposed, followed by screedmen, paver operators and roller operators. The task -based results for dermal pyrene exposure were slightly different in that the screedmen were the highest exposed, followed by the rakers, paver operators and roller operators. Table 3 presents the mean PAC exposure estimates that result from the final models, estimating the inhalation and dermal exposures associated with each paving task while considering the between- and within -worker variability and adjusting for other important determinants of exposure. Since the data analysis was conducted using the normally distributed logged data, the mean exposure concentrations AsK were estimated according to Rappaport et al. (1999): + 011 -ti• . The task -based inhalation and dermal estimates are stratified by RAP content to demonstrate the extent to which the presence of recycled asphalt increases exposure. Similarly, results are presented at the median (115 tons/h), minimum (55 tons/h) and maximum (282 tons/h) work rate values; however, the effect of work rate was only significant for inhalation exposure to PACs. View this table: • In this window • In a new window Table 3. Adjusted mean PAC exposures' among paving workers Previous SectionNext Section DISCUSSION The primary objective of this exposure assessment was to identify determinants of inhalation and dermal PAC exposure among asphalt paving workers. Because the majority of existing studies focus on inhalation exposure, we collected both dermal and air samples in an effort to obtain a more complete assessment of total exposure. In coke oven workers, there is evidence to suggest that dermal absorption is actually the primary route of exposure to PAHs (Van Rooij el al., 1993). In fact, after evaluating pyrene exposure data (inhalation and dermal) and urinary I -hydroxypyrene data, Van Rooij et al. (1993) estimated that -75% of the total absorbed dose was attributable to dermal exposure. Accordingly, an assessment of PAH exposure that excludes dermal absorption may underestimate cumulative exposure. The dermal data are presented in units of ng/cm2, which represents the average amount of PACs that was deposited per square centimeter of exposed skin (at the wrist) during an 8 h shift. As such, these measurements are not intended to represent total dermal exposure. Also, dermal exposures assessed at the wrist may not be representative of exposures at other parts of the body. For instance, the magnitude of `hand' exposures would probably be higher than wrists, but the magnitude of `forearm' or `neck' exposures would probably be lower than wrists. However, the wrist samples do provide a useful tool for comparing dermal exposures across individual workers and across groups of workers. Paving task, crew and RAP content were consistently found to be important determinants of exposure in each of the four models evaluating inhalation and dermal exposure to PACs and pyrene. The mean PAC exposure estimates associated with each paving task varied -12-fold for inhalation exposure and -6-fold for dermal exposure. The task -based inhalation results for PACs and pyrene were consistent with a task's proximity to the primary source of asphalt fume (paver operators > screedmen > rakers > roller operators), while the task -based dermal results for PACs were consistent with the degree to which each task requires actual contact with asphalt -contaminated surfaces (rakers > screedmen > paver operators > roller operators). The task -based dermal results were similar for pyrene, although exposures among screedmen were slightly higher than among rakers. In all four models, we found that the lowest exposures were experienced by roller operators, workers who spend the least amount of time near the source and have the least amount of contact with asphalt -contaminated surfaces. The task -based results for PACs in personal air are considerably higher than those observed by Heikkila el al. (2002), a European study in which the arithmetic mean of total PAHs ranged from 2.38 .tg/m3 (roller operators) to 4.28 µg/m3 (paving operators). The discrepancy is probably due to the fact that Heikkila el al. estimated total PAH using the sum of 15 individual unsubstituted PAHs, while the PAC estimates in the present study include all substituted and unsubstituted PACs with at least four rings. Regional differences in asphalt operations may also account for part of the observed differences. The mean exposure estimates associated with each of the three crews varied -2-fold for inhalation exposure (2.2, 3.1 and 5.1 pg/m3) and --6-fold for dermal exposure (36, 49 and 219 ng/cm2). Since each crew was measured at different worksites and different days, the variable crew could be serving as a surrogate for any number of factors (e.g. work practice, equipment, unmeasured weather conditions and/or other production characteristics) that have an actual effect on exposure. Regardless of the true cause, the fact that inhalation and dermal exposures vary by crew suggests that crew is an important factor that should be considered when characterizing PAC exposure among paving workers. The mean PAC exposure estimates associated with RAP content varied -5-fold for inhalation exposure and -2-fold for dermal exposure, such that RAP content was a significant determinant of inhalation and dermal exposure. It is unclear whether these increases in exposure actually result from the RAP material or from the higher temperatures required when RAP is added to a new batch of asphalt. The temperature of the asphalt mix was not measured during sampling and therefore could not be evaluated in the exposure models. However, since RAP is specifically a characteristic of the asphalt mix, the fact that RAP content was a significant determinant of exposure in all four exposure models suggests that the PAC and pyrene exposures among paving workers were asphalt-related. Work rate was calculated as the tons of asphalt applied per hour during a full shift of work in an effort to compare workdays of varying work intensity. Some days were observed to be considerably busier or slower than other days, since the pace of work was often slowed due to the delayed transportation of asphalt mix from the asphalt plant to the jobsite. Increasing work rate was found to increase inhalation exposure to PACs, although work rate was otherwise not a significant determinant of exposure. The ability to evaluate the effect of ambient temperature on inhalation and dermal exposure was limited by a fairly narrow range of ambient temperature measurements (65-76°F). Although initially included in the exposure models, ambient temperature did not have a significant effect on inhalation or dermal exposures and was excluded from the final models. The temperature of the asphalt would probably have been a more useful measure as a potential determinant of exposure. Inhalation and dermal exposures to PACs were higher among paving workers than among millers and roadside construction worker. The increased exposure can be attributed to working with hot-mix asphalt, since pavers, millers and roadside construction workers otherwise have a similar potential for exposure to PACs. Millers were probably exposed to PACs during the grinding of old asphalt roads, while roadside construction were probably exposed to PACs in roadside soils while installing curbs, guardrails and sidewalks (Tuhackova et al., 2001). However, such exposures may have resulted in under estimating rather than overestimating the portion of exposure that is attributable to working with hot mix asphalt. The manner in which dermal exposure to asphalt-related PACs occurs is unclear. Dermal exposures may result from direct contact with asphalt-contaminated surfaces, such as hand tools and/or equipment controls, the settling of airborne particles and/or the condensation of vapor. Among paving workers, Burstyn el al. (2002) found inconsistent patterns between airborne organic matter and organic matter collected on cotton pads, although it is likely that the sample size (n = 7) and the use of different solvents to extract organic matter from dermal pads and filters limited their ability to evaluate the correlation. We found that the correlation between inhalation and dermal PAC exposure was stronger for non-rakers than for rakers, which is probably related to the fact that the rakers have the highest potential for direct contact with asphalt-contaminated surfaces; however, even among non- rakers the correlation was relatively weak (r = 0.45, P = 0.01). The correlation between inhalation and dermal exposure was stronger for exposure to pyrene (P = 0.59, P = 0.006), suggesting that dermal exposure may be more likely to be associated with airborne levels for lower molecular weight compounds. Previous SectionNext Section CONCLUSIONS The task performed by a member of a paving crew was found to be the most important determinant of inhalation and dermal exposure to PACs. The task -based inhalation exposures were consistent with each task's proximity to the primary source of asphalt fume (the hopper), while the task -based dermal exposures were consistent with the degree to which each task requires actual contact with the asphalt - contaminated surfaces. In addition, inhalation and dermal exposures were significantly higher when the asphalt contained high RAP compared with low RAP, suggesting that the PAC exposures experienced by these paving workers were asphalt related. Similarly, inhalation and dermal PAC exposures were higher among paving workers than among millers and roadside construction workers, further suggesting that the higher PAC exposures were attributable to asphalt. PROBLEMS OF RECYCLING CONCRETE COMMES May 19, NT2010 1 By Bambi Turner Concrete waste comes from demolished buildings, repaved roads, sidewalks and other structures. By recycling concrete debris, builders can reduce energy consumption and related emissions to help the environment while reducing the amount of waste sent to landfills. Recycled concrete can be used for new building projects, or as a source of gravel for landscaping and erosion control. While recycling offers many benefits, there are still many problems associated with this process that require further research. Contaminants The concrete recycling process is relatively simple. Large crushing machines grind the concrete into relatively small pieces of aggregate, or gravel. To make this process easier, many recycling centers only accept concrete that's free of rebar, steel and other contaminants. Those who wish to recycle reinforced concrete must first dedicate resources to removing the steel, which can be expensive and time consuming. Some facilities may also reject concrete that's contaminated by asphalt, soil, paint or other forms of construction debris. Cost According to the Environmental Council of Concrete Organizations, concrete costs up to $4 per ton to crush, not including equipment and related expenses. This cost may cause companies to take concrete to the landfill instead of recycling, particularly when the added cost of sorting and decontaminating the concrete is taken into account. Strength The Environmental Council of Concrete Organizations explains that concrete made from recycled material has only 80 to 90 percent of the strength of concrete manufactured from raw materials. This not only poses design challenges for engineers and builders, but may limit the applications for which recycled concrete can be safely used. According to the Portland Cement Association, most concrete mixtures should contain no more than 30 percent recycled aggregate, and less than 20 percent recycled fine aggregate. This means that all concrete must contain roughly 50 percent virgin materials, which limits the benefits of recycling in some areas. Water Absorption Most concrete damage is caused by freeze -thaw cycles, which occur when water is absorbed into the hardened concrete. According to the Environmental Council of Concrete Organizations, recycled concrete absorbs 2 to 6 percent more water than new concrete, making it more susceptible to cracks and other damage. This issue is particularly problematic in colder climate zones, which often experience temperatures below freezing. Potential Health Effects Hardened concrete contains chemicals like chloride, alkali and silica. Most demolition companies have no way of knowing the ratio of these contaminants in the concrete. During demolition and recycling, these materials are released into the air as dust, where they can affect the health of workers and nearby residents. According to the U.S. Occupational Health and Safety Administration, silica dust is a known carcinogen. Read more: http://www.livestrong.com/article/126614-problems-recycling- concrete/#ixzz255gceFmN Recycling facilities that handle asphalt roofing shingles break the material into small pieces and market it for a range of uses. Ground-up roofing has been used in road construction as bedding under road surfaces, on gravel roads and as an additive to hot mix or cold patch asphalt. More uses have included horse arenas, unpaved home driveways, landscaping, animal bedding, trail construction and other purposes. Concerns about potential contaminants in the roofing lead the Washington Department of Ecology (Ecology) to test ground asphalt-based roofing for chemical composition. Test results indicate that several metals (including arsenic) and polycyclic aromatic hydrocarbons (PAHs) are present at levels that may be harmful to human health and the environment. Arsenic and certain types of PAHs, including those present in the roofing, cause cancer in humans. The use of recycled asphalt roofing in loose form presents risks ingest or absorb asphalt roofing particles and its contaminants. may carry the material into water sources. As a result, Ecology expects a recycler of asphalt roofing to obtain either a solid waste permit or a Beneficial Use Determination (BUD) before distributing it for uses in the loose form. To obtain a permit or BUD, a recycler will need to show that any proposed use will prevent exposure to contaminants in the material. Roofing materials bound in asphalt, as in hot mix or cold patch asphalt, are not mobile in the environment so present less of a risk. Ecology does not expect these uses to go through an approval process under solid waste regulations. Humans may inhale, Wind or precipitation ASPHALT PLANT POLLUTION Young & McQueen Grading Company wants to build an asphalt plant in Mitchell County. The draft air pollution permit proposed by the NC Division of Air Quality (Permit No. 09808R00) would allow the plant to produce up to 225,000 tons of asphalt per year at a maximum of 160 tons per hour. If given final approval by the state, the Young & McQueen plant would be allowed to emit the following air pollutants annually: Chronic toxicants carbon disulfide methyl ethyl ketone toluene xylene Acute system toxicants styrene Carcinogens benzene trichloroethylene (TCE) perchloroethylene (PCE) Annual totals based on production rate for 1,406 hours per year or 175 days at produce 225,000 tons of asphalt. 682 13,650 17,150 9,975 3,780 64 4,000 13,000 all pollutants in pounds per year of 160 tons per hour 8 hours per day to Chronic toxicants include neurotoxins and developmental toxins, substances which have a negative impact on the human nervous system and/or human growth and development. Acute system toxicants are pollutants which cause the death of laboratory ani- mals within 14 days of exposure or is toxic based on human experience. Carcinogens are substances which are known to cause cancer or which are sus- pected to cause cancer in humans. Definitions from the US Code of Fed- eral Regulations (16CFR1500) for the Federal Hazardous Substances Control Act. October 2007 Certain pollution sources at the asphalt plant would be exempted from its state permit: 1) an Asphalt Tank Heater burning No. 2 fuel oil at 1.6 million BTU heat input and 2) a 10,000 gallon liquid asphalt storage tank. These units are known sources of toxic air pollution but are exempted by state statute; that is, they are listed in the permit but not included in the air pollution limits. Asphalt Plant Pollution: A Public Health Hazard Road asphalt contains gravel and sand mixed with asphalt cement obtained from crude oil. Asphalt cement is a mixture of hydrocarbons including naphtha which contribute to the va- porization of organic compounds at operating temperatures of 300-350 degrees F. Hydrocar- bons released into the air by the hot mix asphalt as it is loaded into trucks and hauled from the plant site include volatile organic compounds, polycyclic aromatic hydrocarbons, and con- densed particulates. Also, arsenic, benzene, formaldehyde, and cadmium are toxic air pollutants emitted from asphalt plants. Condensation of particulates occurs at (continued next page) BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE www.BREDL.org PO Box 88 Glendale Springs, NC 28629 (336) 982-2691 BREDL@skybest.com (from page one) ambient temperatures of 70 degrees F. These very fine particles carry polycyclic aromatic hy-drocarbons which are a danger to public health. Animal studies show that PAHs affect repro- duction, cause birth defects, and cause harmful effects on skin, body fluids, and the immune system. The US Department of Health and Human Services has determined that PAHs may be carcinogenic to humans. [Source: Agency for Toxic Substances and Disease Registry (ATSDR). 1995. Toxicological Profile for polycyclic aromatic hydrocarbons (PAHs). Atlanta, GA: U.S.Department of Health and Human Services, Public Health Service] The effect of fugitive emissions on local pollution levels may exceed the effects of pollutants emitted from the smokestack. In addition to smokestack emissions asphalt plants emit large quantities of harmful fugitive emissions at ground level. A small asphalt plant producing 100 thousand tons of asphalt a year may generate 50 tons of toxic fugitive emissions. The bulk of fugitive emissions are condensed particulates. Volatile organic compounds (VOC's) emissions are about 29% of the this total. To this must be added the total emitted from the smokestack itself. Stagnant air conditions and inversions increase the level of exposure to the local community. The Blue Ridge Environmental Defense League has released two studies showing the adverse impacts on property values and public health for residents living near operating asphalt plants. A prop- erty value study documented losses of up to 56% as a direct result of an asphalt plant. In another study nearly half of the residents report negative impacts on their health after only two years of asphalt plant operations. The door-to-door survey shows that 45% of the residents living within a half mile of a two year old asphalt plant report a deterioration of their health which began after the plant opened. The most frequent problems include high blood pressure (18% of people surveyed), sinus problems (18%), headaches (14%), and shortness of breath (9%). Action recommendations Federal regulation of asphalt plant emissions is inadequate to protect public health. EPA's emission estimates (AP -42) are inadequate to protect worker health and public health. Therefore, citizens must join together to protect their communities. Any county or town faced with an asphalt plant proposal should push for setbacks from residences and community buildings, site specific health- based air pollution modeling and monitoring, enclosures for load -out zones, and preferably a zero emissions asphalt plant, with total containment of air pollutants. A, TEICHERT AGGREGATES MATERIAL SAFETY DATA SHEET .a a P 0 BOX 15002 SACRAMENTO, CALIFORNIA 95851 EFFECTIVE DATE: --- FE=B=R=U A.. ..R Y�=? I. IDENTIFICATION TRADE NAME: RECYCLED CONCRETE AND/OR RECYCLED ASPHALT COMMON NAME: RECYCLED MATERIALS BASE, MISCELLANEOUS BASE MANUFACTURER'S NAME: TEICHERT AGGREGATES, PO BOX 15002, SACRAMENTO CA 95851 TELEPHONE NUMBER: 916 484-3011 I DATE REVISED: AUGUST 2003 PRODUCT DESCRIPTION: PRODUCT IS CRUSHED RECYCLED CONCRETE, ASPHALT AND/OR SIMILAR MATERIALS ORIGINATING AS NON -CONTAMINATED CONSTRUCTION DEBRIS. DEPARTMENT OF TRANSPORTATION HAZARD CLASSIFICATION N/A SHIPPING NAME N/A II. PHYSICAL PROPERTIES BOILING POINT. 760 mm Hg N/A 1 FREEZING POINT N/A SPECIFIED GRAVITY (H20 = 1) 2.3-2 . 8 IIVeL9 L I DATER, N/A VAPOR DENSITY (air= 1) N/E% BYWT NEGLIGIBLE PERCENT VOLATILES. BY VOLUME N/E EVAPORATION RATE ! (Butyl Acetate = 1) N/E APPEARANCE AND ODOR PIECES OF CRUSHED CONCRETE AND/OR ASPHALT MATERIAL. ODORLESS III. HAZARDOUS INGREDIENTS MATERIAL ‘,/, PEL TLV CAS \L \IWSR CRUSHED CONCRETE AND/OR CRUSHED ASPHALT(1) (2) 100 10 mg/m' 5 mg/m3. 10 mg/m3 N/E CRYSTALLINE SILICA 0.3 mg/m ' 0.1 mg/m3 . . 0.05 mg/m3...- 14808-060-7 NOTE: (1) CRUSHED CONCRETE AND CRUSHED ASPHALT CONTAIN ROCK AND SAND NATURAL SAND INCLUDES QUARTZ, A FORM OF CRYSTALLINE SILICA. COMPOSITION VARIES. (2) MATERIAL MAY INCLUDE SMALL PERCENTAGES (LESS THAN 15%) OF GLASS, PORCELAIN, OR OTHER CERAMIC MATERIALS. * TOTAL DUST, PARTICULATES NOT OTHERWISE REGULATED. -* RESPIRABLE OUST, PNOR '*TOTAL SILICA —RESPIRABLE SILICA IV. FIRE AND EXPLOSION HAZARD DATA FLASH POINT N/A (test method) FLAMMABLE LIMITS IN AIR, % by volume I LOWER 1 NA 1 UPPER 1 N'A EXTINGUISHING MEDIA NONE SPECIAL FIRE FIGHTING NONE PROCEDURES UNUSUAL FIRE AND EXPLOSION HAZARDS NONE MI = ..ns onnlirohlc EMERGENCY PHONE NUMBER /AAAAA AAAA V. HEALTH HAZARD INFORMATION EFFECTS OF ACUTE OVEREXPOSURE SWALLOWING NO SIGNIFICANT HAZARD POSED SKIN CONTACT SHORT TERM IRRITATION INHALATION PRODUCT FRAGMENTS MAY INCLUDE FINE SILICA (QUARTZ) DUST. PROLONGED OR ROUTINE INHALATION OF FINE QUARTZ DUST CAN LEAD TO THE LUNG DISEASE KNOWN AS SILICOSIS. EYE CONTACT SHORT TERM IRRITATION EFFECTS OF REPEATED OVEREXPOSURE OF VERY HIGH LEVELS OF AIRBORNE DUST MAY QUARTZ DUST CAN LEAD TO THE LUNG DISEASE KNOWN AS SHORTNESS OF BREATH. AND INCREASED ACUTE: AIRBORNE PARTICLES CAN CAUSE EYE IRRITATION. INHALATION PRODUCE COUGHING AND IRRITATION. CHRONIC: PROLONGED AND ROUTINE INHALATION OF RESPIRABLE SILICOSIS. EARLY SYMPTOMS OF SILICOSIS INCLUDE COUGHING. WHEEZING, LIKELIHOOD OF OTHER LUNG PROBLEMS. OTHER HEALTH HAZARDS MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: PRIOR SKIN PROBLEMS SUCH AS DERMATITIS. PRIOR RESPIRATORY TRACT CONDITIONS SUCH AS BRONCHITIS. EMERGENCY AND FIRST AID PROCEDURES SWALLOWING SEEK MEDICAL ADVICE, BUT INGESTION OF SMALL AMOUNTS OF THE MATERIAL IS NOT EXPECTED TO POSE A SIGNIFICANT HEALTH HAZARD. SKIN WASH SKIN WITH WATER AND MILD SOAP. INHALATION REMOVE TO FRESH AIR. SEEK MEDICAL ATTENTION IF DISCOMFORT OR IRRITATION PERSISTS. EYES FLUSH EYES WITH LARGE AMOUNTS OF WATER. SEEK MEDICAL ATTENTION. SUSPECTED CANCER NO FEDERAL NOTE: IARC LISTS HEALTH HAZARD PROP 65 WARNING: CRYSTALLINE SILICA. AS A CHEMICAL YOURSELF WITH PRECAUTIONS INDICATED AND SAFETY TRAINING AGENT? OSHA NO NTP X IARC CRYSTALLINE SILICA AS HUMAN CARCINOGEN. CRYSTALLINE SLICA POSES A WHEN IT IS INHALED AS A DUST. CRUSHED RECYCLED CONCRETE AND ASPHALT CONTAINS QUANTITIES OF FINE CRYSTALLINE SILICA (QUARTZ) DUST IS LISTED UNDER TITLE 22, SECTION 12000, KNOWN TO THE STATE OF CALIFORNIA TO CAUSE CANCER. ALWAYS FAMILIARIZE THE HAZARDS OF THE MATERIALS AND EQUIPMENT YOU ARE USING AND FOLLOW THE ON PRODUCT LABELS, MATERIAL SAFETY DATA SHEETS AND YOUR HEALTH PROGRAM. VI. REACTIVITY OATA STA31I ITY CONDITION TO AVOID NONE UNSTABLE STABLE X INCOMPATIBILITY (materials to avoid) STRONG OXIDIZERS. SUCH AS STRONG ACIDS. HAZARDOUS COMBUSTION OR DECOMPOSITION PRODUCTS CARBON DIOXIDE, SULFUR DIOXIDE HAZARDOUS POLYMERIZATION CONDITION TO AVOID NONE May Occur Will Not Occur X VII. SPILL OR LEAK PROCEDURES STEPS TO BE TAKEN IF MATERIAL IS RELEASED OR SPILLED MATERIAL DOES NOT POSE HAZARD TO IMMINENT HAZARD TO WORKERS OR THE ENVIRONMENT. TRANSFER SPILLED MATERIAL TO CONTAINERS FOR REUSE OR DISPOSAL WITH NORMAL TRASH. USE NORMAL GOOD HYGIENE PRACTICES TO MINIMIZE EXPOSURE (WEAR SKIN AND EYE PROTECTION, AS NECESSARY). WASTE DISPOSAL METHOD PRODUCT IS NOT CLASSIFIED AS HAZARDOUS WASTE. VIII. SPECIAL PROTECTION INFORMATION RESPIRATORY PROTECTION (specific type) IF AIRBORNE CONCENTRATIONS EXCEED OSHA PERMISSIBLE EXPOSURE LIMITS, WEAR NIOSH-APPROVED RESPIRATORS TO ACHEVE EXPOSURES BELOW THE PEL. VENTILATION N/A PROTECTIVE GLOVES AVOID PROLONGED OR REPEATED CONTACT WITH PRODUCT. EYE PROTECTION AVOID EYE CONTACT; WEAR SAFETY GLASSES OR GOGGLES, AS NEEDED. OTHER PROTECTIVE EQUIPMENT COVERALLS OR OTHER WORK CLOTHING THAT MINIMIZES SKIN CONTACT WITH PRODUCT. IX. SPECIAL PRECAUTIONS PRECAUTIONS TO BE TAKEN IN HANDLING AND STORING: NONE X. ADDITIONAL INFORMATION ADDITIONAL HEALTH DATA PROP 65 WARNING: CRUSHED RECYCLED CONCRETE AND ASPHALT CONTAINS QUANTITIES OF CHRYSENE, BENZO(A)PYRENE AND BENZO(A)ANTHRACENE. THESE PETROLEUM ASPHALT COMPONENTS ARE LISTED UNDER TITLE 22, SECTION 12000, AS CHEMICALS KNOWN TO THE STATE OF CALIFORNIA TO CAUSE CANCER AND BIRTH DEFECTS OR OTHER REPRODUCTIVE HARM. ALWAYS FAMILIARIZE YOURSELF WITH THE HAZARDS OF THE MATERIALS AND EQUIPMENT YOU ARE USING AND FOLLOW THE PRECAUTIONS INDICATED ON PRODUCT LABELS, MATERIAL SAFETY DATA SHEETS, AND YOUR HEALTH AND SAFETY TRAINING PROGRAM. SKIN EXPOSURE TO ASPHALT CAN CAUSE WORKERS TO EXPERIENCE PHOTOSENSITIZATION, A CONDITION WHERE THE EXPOSED AREA OF SKIN BECOMES VERY SENSITIVE TO SUN LIGHT AND OTHER SOURCES OF ULTRAVIOLET (UV) LIGHT. WITHOUT EXPOSURE TO UV. SENSITIVE SKIN MAY APPEAR TO BE SUNBURNED WITH EXOSURE TO UV. THE SKIN MAY BLISTER AND DEVELOP SORES. AS WITH ANY CHEMICAL, SKIN CONTACT WITHTHIS PRODUCT, AND THE BREATHING OF RODUCT DUST SHOULD BE MINIMIZED. WE STRONGLY RECOMMEND THAT THE PRECAUTIONS STATED IN THIS MSDS BE FOLLOWED WHEN HANDLING THE PRODUCT. Teichert Aggregates believes the information contained herein is accurate; however. Teichert Aggregates makes no guarantees with respect to such accuracy and assumes no liability in connection with the use of the information contained herein by any party. The provision of the information contained herein is not intended to be and should not be construed as legal advice or as ensuring compliance with any federal, state or local laws and regulations. Any party using this product should review all such laws, rules, or regulations prior to use. NO WARRANTY IS MADE, EXPRESSED, OR IMPLIED OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR OTHERWISE. EXHIBIT Glenn Hartmann From: Kenneth Sack [kensack@me.com] Sent: Monday, September 03, 2012 10:44 AM To: Tom Jankovsky; John Martin; Mike Samson Cc: Glenn Hartmann Subject: additional docs bedrock Attachments: Popoff_Backgrounder.pdf; Mischa Popoff Bedrocks expert.doc; Leaching recyled asphalt contains lead.doc; asphalt2 permit for plant in MO.pdf; asphalt2 Cement and Concrete report.doc; ASPHALT2 HEALTH ISSUES WITH CEMENT2.pdf Dear Commissioners I have sent numerous documents which demonstrate why the current application before you regarding recycling asphalt plant is actually worse than the first application that you denied in February and should be denied as well. The application is filled with ommissions and misstated facts. Even their "expert" Mr Popoff has questionable credentials. The bottom line here is that the land use change requested by Bedrock, would adversly affect my agricultural property and residential property,and is not compatible with my agricultural property and under the land use regulations, SHALL not be allowed. I have confidence that once again, you will make the unanimous decision to DENY this application and Eagle Springs Organic can continue growing with more jobs for residents of Garfield County.. Ken Sack cell 954-249-5674 Eagle Springs Organic Eagle Springs Solar 5454 County Rd 346 Silt, CO 81650 Eagle Springs Crossing 1733 Railroad Ave Rifle, CO 81652 1 CORNUCOPIA INS TITUTE Mischa Popoff: Backgrounder Dear Organic community stakeholders: Please resist the temptation to surf through Mr. Popoffs two websites (one promoting his book and the other promoting his conservative political views). Visiting his sites will only elevate them on Google and other search engines. We hesitated "outing" his ideologically driven attack on organics because this will undoubtedly raise his profile somewhat. But his broad distribution of the unfounded allegations he's made (of widespread fraud and 80-90% organic products being imported) warranted a response. Right now, when searching the word "Popoff," he makes his first appearance in the Google search report on page 6 (a commentary carried on a politically conservative Canadian website) and his own political site does not appear until page 9 (his organic site falls in somewhere after that). There is a common Latin axiom, used in the law, that goes, "Falsus in uno, falsus in omnibus." False in one, false in all. Attorneys know that if you can prove a witness Tied on the stand, in even a minor way, that his or her credibility will be tainted in the eyes of the jury. We have collected a few snippets of Mr. Popoffs writings (please see below) so hopefully you, the jury, can come to some conclusions about his approach to accuracy, and his willingness to risk injuring the reputation of the organic label in an attempt to advance his own agenda, without helping him by purchasing his self -published book or elevating his presence on the web. We have taken the liberty of highlighting in yellow some of the key points in his writing, and our observations have been included in red text. Will Fantle Research Director The Cornucopia Institute In Conclusion... Being organic is no longer about farming fields. It's about filling forms. Your taxes underwrite this marketing subterfuge and help drive a stake into the heart of the most efficient food system ever known [defending conventional/industrial agriculture]. Who's behind this? You'll be surprised. Is it ORGAN I C Mischa Popoff The I0odowry .l who J ,0,, ed dra...gam mdo0 v. named J. m1.. n 400AM mme0MTt and made mifecd to The proms AM A a.mptchvM.e history of Clown . wxfa.eoM Wear's" orduatb. Wen 1615 to dr pn+red Organic farming began in England as a Christian movement. Organic farmers in the United States and Canada overwhelmingly identify as conservatives, and until 1997 their industry actually had a sound scientific basis, subject to free-market rules with no government interference. But you'll never hear about that from the pro -organic media, or about the key role Presidents H.W. and G.W. Bush played in vaulting organics from hippie movement to multi -billion -dollar industry. [The organic movement has always transcended political labels and certainly religious orientation.] Is it Organic? is a tell -all history by an industry insider who saw too much to keep quiet. Organics can get back to basics by producing food using age-old methods like natural composting, or it can be ruled by banality, fraud and eco -politics. KC Active (US): Hook, line and sticker by Beck Ireland The higher prices levied on food and drink carrying an organic label can cause sticker shock in many consumers. However, an increasing appetite for fruits and vegetables free of toxic pesticides and synthetic fertilizer has recently transformed organic farming into a $30 -billion - dollar -a -year industry. Yet, for the last 14 years, no organic farm in the United States or Canada has been subjected to systematic and unannounced field testing. "You're flipping a coin every time you pay a premium for organic food at a store," says Mischa Popoff, an advanced organic inspector with the International Organic Inspectors Association and author of Is It Organic?: The Inside Story of Who Destroyed the Organic Industry, Turned It into a Socialist Movement and Made Millions in the Process. According to Popoff, many of the foods labeled organic could contain substances prohibited by the Organic Materials Review Institute, such as toxic pesticides and fungicides. "Even the most educated consumer has no idea what's really going on with any of their food," he says. Although spot testing for pesticides has been required by law since 1990, it hasn't been systematically carried out. In 1997, according to Popoff, President Bill Clinton and the America Consumers Union considered adding a more stringent field test requirement to the U.S. Department of Agriculture's National Organic Program. However, lobbying interests "watered down" the wording. "They turned it into a glorified marketing system," Popoff says. "It's based on the honor of all the people involved—all the people on the farm all the way up to the retail. If they're all honorable, it works, but then why do you even need a certification system if it's just going to be honor -based?" ...This should come as good news to organic proponents such as Popoff. However, only domestic organic farmers, who make up just 15 percent of the domestic market for organic food in the US and Canada, will be subjected to tests on their crops. Foreign organic operations, which provide 85 percent of the organic produce to the market in the US and Canada, will remain untested. ..."The certified farms are paying for bureaucracy, and it's subsidized by your taxes," Popoff says.... None of the money stays with the farmer. It all goes into the hands of the certifiers, and they use it to build their bureaucracy and lobbying." More information about Is it Organic?: The Inside Story of Who Destroyed the Organic Industry, Turned It into a Socialist Movement and Made Millions in the Process can be found at www.isitorganic.ca. National Post(Canada) Mischa Popoff: Beware of Organic Crusaders From field to fork, organic food isn't just trendy – it's big business. The combined market in Canada and the United States is estimated at $30 -billion a year. Touted as healthier, tastier, and more "authentic" than conventional agricultural products, organic fare has become a must - stock in vegetable aisles, meat counters and menus across the nation. Yet most consumers likely have no idea that the organic heirloom tomato salad they ingest at their local bistro cannot be guaranteed "pesticide -free." Nor are they aware that organic farming has morphed into a political crusade, attacking farmers' use of everything from fossil fuels to synthetic fertilizer, and even modern, disease -resistant seed varieties [once again defending conventional agriculture, synthetic inputs and genetic engineering] all the while resisting routine testing of organic produce. I am an ardent proponent of organic farming [this juxtaposition is why we call Mr. Popoff a wolf in organic sheep's clothing]. I grew up on an organic farm, and worked for five years as an advanced organic farm and process inspector in the United States and Canada. Based on this experience, I firmly believe that farming is still 100 percent organic even when it adapts to changing times. The main goal of organics is to avoid toxins that end up in our food and the environment. But unless every organic operation is tested at least once a year, these regulations are meaningless. For those who raise the issue of cost, they should know that a test for more than 200 commonly used toxic herbicides can be purchased for only $150. Farmers pay on average 10 times that sum just to have their paperwork examined. [It's preposterous to think that samples can be taken by independent inspectors, addressing the broad array of synthetic pesticides, herbicides, fungicides and synthetic fertilizers and drugs, and diversified crops and livestock, for $150. Furthermore, the average farm inspection is nowhere near $1500.] In addition to their resistance to testing, organic activists have also become resistant to the use of modern seed varieties, thus imperiling the very sustainability of our food supply. They are not merely rejecting genetically modified seed, but seeds that have simply been bred to protect a crop against common threats like rust, fungus and mildew, which can wipe out a field as thoroughly as any hail storm. [We know of no prohibitions in organics against any hybrid or open pollinated seed varieties other than those that are produced through genetic engineering.] The gross assumption on the part of urban organic activists -many of whom have never worked a day on a farm -is that old varieties are superior because they were bred in an era when pesticides and synthetic fertilizers did not exist, and they therefore must possess natural pest resistance and the ability to seek nutrients deeper in the soil. This fanciful thinking has never been researched. Such seed varieties were abandoned long ago precisely because they were not as resistant as modern varieties. But the activists cling to their mantra: If it's old seed, it's good seed. They browbeat organic farmers into use old seed varieties that no one knows much about, all in the name of rejecting everything modern. [Baseless hyperbole] ... American Thinker April 09, 2011 Warmists and the Organic Farming Activists By Mischa Popoff Organic farming creates more CO2 (which is a good thing, of course). So why do urban organic activists pretend it's the other way 'round? Urban organic activists begin every argument by pining for the good ol' days. They point out that in 1940 one calorie of fossil -fuel energy produced two calories of food. But now, due to the dreaded effects of industrialization, 20 calories of fossil -fuel energy are required per calorie of food. And this, for them, illustrates why an immediate transformation of the food biz is required to "save the planet." How? By converting from a fossil -fuel -based food economy to one based instead on sunshine. Case closed! After all, it's a 20 -fold increase, right?[i] Well... turns out it's not. A wise man once said an ordinary mind is incapable of making distinctions. The distinction not being made in this case is that while we're using 20 times the fossil fuel energy, we're certainly not using 20 -times the total energy. Not even close... If only they had ever worked a day on a farm, these "slow," urban activists would appreciate the massive amounts of human and animal labor that used to be required before machines driven by fossil fuels came along. The reason only a single calorie of fossil fuel energy was required to produce two calories of food was that, prior to the mass industrialization during the Second World War, farmers did the rest of the work by hand and by back! Far more calories were consumed emitting far more CO2. Otherwise, industrialization would not have made economic sense. Slow food activists will try to tell you that a great deal of today's fossil -fuel consumption results from the transportation of food, and that all food should therefore be procured locally. But transportation turns out to only account for a tiny fraction of energy use. (Were this not the case, greedy capitalists wouldn't ship food over long distances; it's that simple.) It's energy -intensive activities like the plowing of land, harvesting, and the handling and processing of food that account for the lion's share of energy consumption and hence CO2 emissions.[ii] And when our ancestors relied on horses to do this work -- which of course meant fully one-half of their arable land was dedicated to growing crops for feed (something which clearly had both an economic and environmental impact) -- they still expended enormous amounts of human energy. And all that work, human and animal, had a measurable carbon footprint which greatly exceeds the 20 -fold increase in fossil -fuel energy -use that occurred over the last 70 years. How much more exactly? Hold onto your hat. ...They seek to replace evil ol' fossil -fuels with biofuels like ethanol. Instead of burning 20 calories of fossil fuel energy to yield two calories of food as we currently do, in a biofuel food - economy farmers would burn 20 calories of biofuel, and would once again find themselves setting aside half of all their land to grow that fuel... just like their ancestors did to grow feed for their horses. See a pattern here? All you achieve with biofuels is a shift in where the fuel comes from, not in how much is consumed. So much for the sunshine economy! Besides, fossil fuels are sunshine -based as surely as crops are. The sunshine was captured in forests millions of years ago and remains stored in underground reserves in the form of crude oil. Why is today's sunshine any better than yesterday's? Most members of the urban -environmentalist crowd don't have the slightest conception of what they're promoting in taking us back to what they perceive to be the good of days. But the really scary part is that many do. CropLife (US) Organics Industry: Led Astray The corporate approach to organics has undermined locally produced food and put the full force of its marketing message on tearing down biotechnology. By Mischa Popoff March 2011 Editor's Note: Mischa Popoff is an advanced organic inspector based in Canada [this is a false claim Popoff frequently makes], and has been outraged over the hijacking of the organic industry by big corporations. In his new book, Is It Organic?, Popoff provides insight into how the organics movement became an industry that lost its focus and is in danger of losing its identity. Fifteen percent. That's a generous estimate of the sum total of the organic industry that could be considered "legitimate." No, I'm not someone with an interest in the chemical or biotech industries. I'm someone with a vested interest in the organic industry. Fifteen percent is the paltry market share left over for American and Canadian organic farmers after cheap imports fill the shelves. Did you think, like so many Americans, that the organic industry supported local family farms? Silly ... that's what's referred to as propaganda, or rather, public relations. Way back when this industry was still a movement, almost all organic food was domestic. But then something interesting happened on the way to Washington. Ambitious corner health -food store owners realized they could make more money if they imported "organic" food from China, Mexico and Indonesia. Is that stuff really organic? Well, the paperwork says it is. But what do the field tests say? Ahh ... now you're asking the right question. Failing The Test Asking if organic farms and processing facilities are tested should be akin to asking if Olympic athletes are tested. "Well of course they are!" Or so you'd assume. Well, it turns out they're not. Back in 1998, President Bill Clinton listened to the American Consumers Union and required that organic farms and processing facilities be tested at least once a year. Honest organic farmers rejoiced, firm in the belief that the main role of government is to keep things fair for everyone. But the corner health -food store owners lobbied to eliminate field testing from USDA organic standards. Can you say free-for-all? Activists love to blame this on Bush, but it all happened under Clinton. Anything can now be sold as organic as long as the paperwork is completed and exorbitant fees are paid to private certifying companies that only make money when they give their approval. Conveniently, these certifiers all have branch offices over in China. Corner health -food stores quickly grew into huge box stores and ceased doing business domestically 85% of the time. [Random testing is part of the law passed by Congress governing organics. After overt criticism by Cornucopia and many others in the organic community, the Obama USDA is now implementing the program.] Without testing for the very things the organic industry claimed to exclude from food, the industry leaders realized they desperately needed some credibility. They weren't quite sure where to turn until they made the collective decision in 1999 to 'go hard' against a new enemy, an enemy which Clinton had thought might actually be an ally: biotechnology. This is why you never see the words chemical -free or synthetic -fertilizer -free on organic foods. Sure, organic crops aren't supposed to be grown with the aid of chemicals or synthetic fertilizer. But it turns out the best you can do is hope there are no residues in your organic food. There's no guarantee; not even the suggestion that chemical residues are reduced to some sort of an acceptable level. But you do see bold statements like "100% GMO free" proudly displayed on organic labels because genetic engineering has replaced crop protection chemicals and synthetic fertilizer as the arch -nemesis of organics. All About Biotech Now when you read in the news that the CEO's of "organic" corporations like Whole Foods Market, Organic Valley, and Stonyfield Farm are "fuming" over the Obama administration's decision to approve the use of genetically engineered alfalfa, you'll know it has absolutely nothing to do with bringing purer, more nutritious food to market. It's all just PR. These CEOs claim to be concerned about the environment, but they're really just worried because of their own self-imposed, zero tolerance for biotechnology. They made the "100% GMO free" labeling claim their sole raison d'etre, and now have to stick with it no matter what. There's no proof that biotechnology leads to more chemical use on farms (quite the opposite actually) or that it will "threaten the rights of farmers and consumers," or "damage the environment." [There is substantial documentary evidence indicating that the use of herbicides has exploded since the introduction of Monsanto's genetically engineered crops that resist their proprietary Roundup herbicide.] But from a marketing perspective, the prospect of minute quantities of biotech alfalfa cross-pollinating with organic alfalfa undermines the bold claim — the only bold claim — that premium -priced organic foods are always "100% GMO free." The only way organic farmers will suffer is if an organic certifier makes their lives hell when their organic alfalfa fields are within a five -mile radius of a crop of biotech alfalfa. This is why hardly anyone grows organic canola anymore in North America: the for-profit organic certifiers forced organic farmers to stop growing canola so the leaders of the organic industry could then launch legal action against the makers of Roundup Ready, biotech canola; legal action that, ironically enough, organic farmers were then forced to fund through their exorbitant certification fees. Feeling all warm and fuzzy yet? In the meantime, if an organic farmer's crop becomes contaminated by a sprayed chemical, whether through negligence or fraud, or if an "organic" crop over in the People's Republic of China is fraudulently treated every step of the way with synthetic fertilizer, prohibited herbicides, pesticides and fungicides, well ... everything's just fine as long as the paperwork's all in order, the fees are paid, and no one blows the whistle. [This is false and highly objectionable.] But for gosh -sake, don't let genes from a genetically engineered crop get anywhere near an organic crop! It'd wreak havoc with the industry's image. The organic industry claims to provide purer, more nutritious food — for a price — but it doesn't do anything to ensure that's what consumers get. Nothing that is, except for a stupid, self-imposed zero -tolerance on GMO. Painted In A Corner I worked the land with my family back when the organic industry was still just a movement. I then had the honor of working across the U.S. and Canada as an Advanced Organic Farm and Process Inspector and met with hundreds of honest organic farmers who want nothing to do with any of the political activism we're seeing. Never once did I ever see proof that organic food was harmed in any way by biotechnology. On the contrary I met many people who believe, as Bill Clinton did, that organic farming could very well benefit from biotechnology. But millionaire organic activists have painted themselves into a tight corner and have no choice but to continue scaring the crap out of the public when it comes to biotechnology. Now that they're firmly committed to cheap overseas supply, being anti-GMO is all they've got left to hang their hats on. Australia News (Australia) Is it Organic? How would you know? Mischa Popoff So... remind me again... why aren't organic farms ever tested? If you still think the term "certified organic" means that an organic farmer, broker or exporter receives a surprise visit from an organic inspector, or that the food you're paying double or more for was ever field- tested to ensure prohibited substances weren't used, you are mistaken. My new book, Is it Organic? provides the comprehensive history of organics and includes the full story of my decade -plus experience working in the organic industry. We can get back to basics by producing food using age-old, scientifically -proven methods like natural, intensive composting, or we can continue to be dominated by banality, fraud and eco -politics. What do you think we should do? As far as government and urban activists are concerned, farmers, consumers are mere afterthoughts. ...Here's an excerpt from Is it Organic?... The Clinton Administration caved in to the desires of millionaire organic activists by mentioning the need for organic testing, then passing the final organic rule only after undermining testing by saying it would "not be routine practice conducted on every operation." Sadly, when the Clinton Administration said that organic field testing "is seen as a useful tool," it turned out to really hang on what the definition of "is" is. Clinton then placed the whole watered-down mess on the back burner and left it for George W. Bush to pass into law. Feel better now? (p. 161) Yes, it's true dear readers, organic farms are never tested anywhere in the world [this is incorrect]. And all of the "organic" food available at your supermarket is certified solely on the basis of paperwork. Try to imagine the Olympics without athletes being tested. Would paperwork ever be accepted as proof that an athlete was clean? Here's more from the book... Those turning tidy profits in the organic biz will try to argue that the true value of organics cannot be proven by science. [This is false. There is a growing body of peer- reviewed scientific literature illustrating the nutritional and safety benefits of eating organically.] How convenient to discover something so vital to human and planetary wellbeing but to also discover that its veracity is essentially and inherently unprovable. As Francis Bacon puts it, "whatever any art fails to attain, they ever set it down upon the authority of that art itself as impossible of attainment." Convenient indeed; too convenient by far in fact. (p. 556) ...The history of organics traces all the way back to 1645 in England and was based on solid science right up until the late 1990s when mysticism, magic and bureaucracy took over. The industry has now become little more than glorified food pornography, promising everything but delivering nothing. Being organic is no longer about farming fields. It's about filling forms, which explains why it continues to grow at the astounding rate of 20 percent -per -annum in spite of the recession. And who's behind all of this? You'll be surprised. Mischa Popoff holds a bachelor's degree in history and is an IOIA Advanced Organic Inspector. the environment and From: Mischa Popoff [mailto:mischa@isitorganic.ca] Sent: Thursday, April 21, 2011 9:57 AM To: kastel@cornucopia.org Subject: George Soros undermines the organic movement No one epitomizes the huge difference between rural organic -farming and urban organic - activism better than George Soros. With the openly stated goal of undermining the American economy, Soros supports organizations that are devoted to undermining the North -American food economy, the most efficient food delivery system ever known. Sure, the North -American food economy is far from perfect. But as 1 travelled across North America inspecting family -run organic farms I learned pretty quickly what honest organic farmers all know intuitively: there's no way we're going to ever replace conventional farming. Improve upon it? You betcha'! But replace it? Never. A few weeks ago I called out Mark Kastel, his Cornucopia Institute, along with George Siemon and his Organic Valley Family of Farms Brand, for pretending to stand up for family organic farmers. They, along with people like Soros, make it their business to attack anyone they don't like in the organic biz. But what do they do to actually help organic farmers? All they really care about is that their political message sells. And that hurts domestic farmers. And anyone who doesn't believe this can try to explain why 80% of the certified -organic food sold in the United States every year is imported! How does that help our farmers? Please go to the new page on my website to read more about how some urban activists hurt domestic organic farmers. And, if you're in the mood for a 45 -minute, in-depth radio interview on the subject, please go straight to Carol & Chris's Homegrown Podcast. Mischa Popoff, IOIA Advanced Organic Farm and Process Inspector Author of 1s it Organic? The inside story of the organic industry Some people won't like this book, but you will Osoyoos BC Canada From: Mischa Popoff [mailto:mischa@isitorganic.ca] Sent: Tuesday, May 03, 2011 11:54 AM To: kastel@cornucopia.org Subject: Popoff - Organic farming more efficient than conventional, and pigs fly! Okay... now I've heard everything. A new study co-authored by a member of the Faculty of Environmental Studies at York University claims organic farms can be more energy efficient than conventional operations. That's like saying "Hey! I can be a faster runner than Usain Bolt!" In case you don't know, Usain is the fastest man in the world (he's also referred to as Lightning Bolt). So, how the heck can I claim to run faster than him? Well, you see, the key words in my dubious claim are "can be." 1 mean, sure, if Usain is fast asleep I can be way faster than he is. It all depends on the circumstances. And, until Usain and I have a race, well... my statement stands! So there. This study is a total sham. Really. I mean, how much of my taxes were wasted on this? But, alas this is what happens when people who've never worked a day on a farm and who work at a university located in the downtown core of a large city decide to attack modern farming in a fight against the phantom menace of climate change. As I show in my book, organic farming is less efficient than conventional farming. In most cases, far less so. But that's perfectly fine! There's nothing wrong with burning fossil fuels, especially on a farm! And since when is organic farming supposed to fall into line with every single "green" desire environmentalists have? [Please note, Mr. Popoff is on the record as a climate change skeptic.] We're supposed to produce food that's purer and more nutritious in the organic sector. We rely on time -proven methods that have sustained humankind for thousands of years; so who cares if we burn a bit more diesel? Every organic farmer I know will tell you straight up that he burns more fuel for every bushel he produces compared to his conventional neighbors. And you know what? It doesn't bother him in the least. What bothers organic farmers, young and old, is when they're used as pawns to fight someone else's environmental battle, in this case, the crazy battle against climate change. [Local and organic food might very well have a lower carbon footprint due in part to increased grazing and not using a myriad of petrochemicals in its production.] Attention, anyone working in the environmental department of a university! North -American farmers don't care about climate change! Never did, never will. In case you haven't heard about this study, click here. And if you have, and thought perhaps it might be true, ask yourself why Al Gore never mentions organic farming. It's because he knows organic farming requires more fossil fuel than conventional farming, and it releases more CO2. Too bad the authors of this study don't know what Gore knows. If you haven't heard about my book that debunks this type of malarkey while promoting true, honest, domestic organic farming, please go to my website. For my specific comments on the issue of organics and CO2, just click here. Mischa Popoff, B.A. (Hons.), IOIA Organic Inspector Author of 1s it Organic? The inside story of the organic industry Some people hate this book, but if you've ever worked on a farm, you'll love it Osoyoos BC Canada www.isitorganic.ca Mischa Popoff website 3-18-11 A Cornucopia of nonsense It's hardly a stretch to assume the public is extremely concerned with things like toxic residues and un -composted fecal matter in their food, especially if they're paying hefty premiums for organic food. But, for some reason, corporations seem to make better targets for organic activists. A relatively new organic lobby group called the Cornucopia Institute [established 2004] bills itself as the promoter of "Economic Justice for Family Scale Farming. It's headed by Mark Kastel, a guy who used to work for multi-million dollar "agribusiness giants" before making the "paradigm shift to sustainable farming." It wasn't a huge shift mind you because he now works for a multi-million dollar organo -activist company called Organic Valley Family of Farms Brand, referred to as Organic Valley for short. Confused? Well, you see, it's perfectly simple really; Organic Valley isn't an evil agribusiness giant because it has the words "organic" and "family" in its name. That means it's friendly and sustainable, not evil and profit -driven. Okay? [Organic Valley contributes no funding to Cornucopia and Mr. Kastel has no professional relationship with the organization. He started his career with International Harvester and, like many conventional farmers, switched to organic production after a pesticide -related illness presented his "wake-up" moment almost 30 years ago.] Seriously though, Kastel rails against large corporations doing business in the organic sector for no other reason except that they're large. [Cornucopia's philosophy is that it's corporate watchdogging is, "all about corporate ethics, not corporate scale."] And he pretends to no longer be on Organic Valley's payroll even though they're the single largest contributor to his Cornucopia Institute. Never hurts to have a rich benefactor nowadays, does it? [Again, Organic Valley contributes no funding to Cornucopia and Mr. Kastel has no professional relationship with the organization.] He also fails to explain that the CEO of Organic Valley, a groovy millionaire by the name of George Siemon, "was instrumental in creating the USDA rules, and is working to see that they remain intact." That's right Siemon is one of the many people I expose in my book who has a vested interest in the multi -billion -dollar organic industry, who literally wrote his own federal code, and who now assumes control of that code while big brother watches over pretending to look out for the little people. Such conflict of interest would never be tolerated in the conventional food sector. But, shameless to a fault, Kastel recently came out swinging against Golden Temple granola and Peace Cereal. Why? Because they used to be organic and now they're not. Both processors removed the word "Organic" from their labels and sent letters to all their wholesale and retail customers informing them they were no longer organic, but Kastel wants more. He wants them to do an advertising campaign to inform consumers they're no longer organic. Is he serious? Yup, he is. [Golden Temple/Peace Cereal changed from organic to conventional ingredients, without lowering the price, and without adequately notifying stores, or changing the UPC codes of the products. Many retailers continued to use signage to identify these products as "made with organic ingredients," misinforming consumers. The Cornucopia Institute has proposed to the USDA a regulation that would require full notification and changing the scanning codes when product formulation is changed from organic to conventional.] There are serious problems in the organic industry. Most notably, the fact that organic crops and livestock are not tested. This has led to a situation where over 80 percent of the certified organic food sold is imported from places like China, Indonesia and Mexico, all based on paperwork and the payment of hefty fees. But Kastel doesn't care. Who knows? Maybe his boss likes the current laxity of the organic certification system. Under Siemon's watchful eye, Kastel has been obsessed with one certifying company in particular, Quality Assurance International (QAI), which is a good certifier working consistently within federal standards, [QAI has been involved in some of the largest documented scandals in the organic industry. Cornucopia watchdogs all certifiers but calls QAI, "the corporate certifier of convenience." Their practices, on a number of occasions, had been sanctioned by the USDA but, under the Bush administration, were not penalized.] I should know; I worked for QAI back when I was an IOIA Advanced Organic Farm and Process Inspector. But Siemon and Kastel think QAI is "too corporate." Cornucopia has never shown where QAI has done anything illegal or even untoward. QAI's only crime according to Siemon and Kastel is that they are successful and their clients are large. [Although Cornucopia has publicly criticized QAI, to our knowledge neither Organic Valley nor Mr. Siemen have done so.] Siemon and Kastel also used Cornucopia to attack President Barack Obama's pick of Iowa Democratic Governor Tom Vilsack for Secretary of Agriculture. Siemon and Kastel didn't like the fact that Vilsack had supported genetic engineering and that he had a "close relationship" with agribusiness corporations. [Cornucopia had not criticized Sec. Vilsack until after his decision to legalize the sale of genetically engineered alfalfa, a grave threat to organic production. In fact, we were pleased and surprised at the changes he made to staff at the USDA and the commitment to organics.] Sounds just like any Secretary of Agriculture you care to mention from the last 50 years (and any Minister of Agriculture in Canada). It also sounds a lot like Bill Clinton and Al Gore who both have the exact same views as Vilsack on the need for advanced science in agriculture. But Siemon and Kastel won't dare go after Clinton or Gore; so, instead, Kastel decided to remind Obama of his promise for "change," citing the need to "Clean up Bush's Organic Mess." [Our call to Obama was made prior to Sec. Vilsack's appointment.] This in spite of the fact that the final rules for the USDA's NOP which Siemon and Kastel enthusiastically support were passed during George W. Bush's administration after being written by Clinton's administration. (This is all explained in Chapter 5 of my book.) [Cornucopia's criticism of the Bush administration was for their refusal to enforce the regulations. Although Cornucopia was not in existence during the Clinton administration, it has since criticized the Clinton USDA for "monkeywrenching" the adoption of regulations resulting in a 12 -year delay in implementation.] I tried communicating with Kastel about the need to reduce bureaucracy in the organic industry and introduce field testing. His position is that he and his boss defend "the hoops organic farmers have had to jump through," and he stresses that testing cannot substitute for record- keeping and form -filling because, in his mind, "Most alarm systems are never tested by burglars." Can someone tell me just what the hell that's supposed to mean? Organic farmers want field testing, less paperwork and a reduction in the fees they're forced to pay year after year. Why not do something to help them? [Cornucopia supports random testing in addition to farm inspections and audits of record-keeping.] Big Organic players like Siemon are directing minions like Kastel all across the land to lobby Obama for "change" in the food industry, a change which, let's face it, they hope will continue to be completely unscientific. Perhaps Siemon and Kastel never did well in science and math when they were in school and they honestly just don't understand how things like food safety and quality control work. Or... it could be Siemon and Kastel actually did very well in science and math and just don't want food safety and quality control to work, at least not in their racket... I mean sector. So how 'bout it guys? Can we see your college transcripts? There is currently little proof of actual cleanliness, nutrition and fair play in the global organic industry. [There is a growing body of scientific literature, from the USDA, Consumers Union and peer-reviewed publications, illustrating the nutritional and safety advantages of consuming organic food.][It's fast approaching a complete free-for all, and domestic organic farmers suffer as a result. Professional organic lobbyists like Kastel either honestly don't get that, or they don't want to. And that's a total shame. NOTE: After Popoff distributed this manifesto, which is an excerpt from his book, Cornucopia Codirector Will Fantle contacted him requesting a retraction/correction and the removal of this material from his website based on its factual inaccuracy. The material is still posted. Leaching Characteristics of Asphalt Road Waste CITATION: T. G. Townsend. , HMAT, HOT MIX ASPHALT TECHNOLOGY, Vol. 3, No. 4, ABSTRACT: A proposed alternative for the management of reclaimed asphalt pavement (RAP) is use as fill material. However, two different types of environmental concerns relate to leaching of pollutants from RAP. The first is that the leachate produced when rainfall infiltrates RAP stockpiles could potentially be contaminated with trace amounts of organic compounds or heavy metals. A second environmental concern is that RAP used a fill material could potentially leach off contaminants when rainfall infiltrates the waste (unsaturated condition) or when used as fill below the water table (saturated condition). In both situations, the leachate produced could potentially be contaminated with trace amounts of the hazardous chemicals. Thus, a series of leaching tests were performed in Florida at both batch -scale and in leaching columns. The primary chemicals investigated were volatile organic compounds (VOCs), polycyclic aromatic hydrocarbons (PAHs), and heavy metals. Results were consistent with previous studies showing that organic compounds do not leach from typical RAP. Heavy metals are sometimes encountered. The literature indicated the presence of chromium, lead, and barium; however, only lead was detected in this study and was ascribed to prolonged exposure to traffic and vehicle emissions. Cement and Concrete: Environmental Considerations Cement and concrete are key components of both commercial and residential construction in North America. The cement and concrete industries are huge. There are approximately 210 cement plants in the U.S. and 4,000 to 5,000 ready mix plants (where cement is mixed with aggregate and water to produce concrete). The Portland Cement Association estimates that U.S. cement consumption has averaged between 75 and 90 million tons per year during the last decade, and projects that consumption will exceed 100 million tons per year by 1997. Worldwide, cement production totaled 1.25 billion tons in 1991, according to the U.S. Bureau of Mines. What does this mean in terms of the environment? Are these products good or bad? As builders and designers, should we be looking for alternatives or embracing concrete over competing materials? As with most building issues, the answers are not clear-cut. Concrete and other cementitious materials have both environmental advantages and disadvantages. This article takes a look at how these materials are made, then reviews a number of environmental considerations relating to their production, use, and eventual disposal. Cement and Concrete Production Cement is the key ingredient in concrete products. Comprising roughly 12% of the average residential -grade ready mix concrete, cement is the binding agent that holds sand and other aggregates together in a hard, stone-like mass. Portland cement accounts for about 95% of the cement produced in North America. It was patented in England by Joseph Aspdin in 1824 and named after a quarried stone it resembled from the Isle of Portland. Cement production requires a source of calcium (usually limestone) and a source of silicon (such as clay or sand). Small amounts of bauxite and iron ore are added to provide specific properties. These raw materials are finely ground and mixed, then fed into a rotary cement kiln, which is the largest piece of moving industrial equipment in the world. The kiln is a long, sloping cylinder with zones that get progressively hotter up to about 2700°F (1480°C). The kiln rotates slowly to mix the contents moving through it. In the kiln, the raw materials undergo complex chemical and physical changes required to make them able to react together through hydration. (See illustration, pages 8- 11.) The most common type of cement kiln today (accounting for 70% of plants in the U.S.) is a dry process kiln, in which the ingredients are mixed dry. Many older kilns use the wet process. The first important reaction to occur is the calcining of limestone (calcium carbonate) into lime (calcium oxide) and carbon dioxide, which occurs in the lower -temperature portions of the kiln—up to about 1650°F (900°C). The second reaction is the bonding of calcium oxide and silicates to form dicalcium and tricalcium silicates. Small amounts of tricalcium aluminate and tetracalcium aluminoferrite are also formed. The relative proportions of these four principal compounds determine the key properties of the resultant portland cement and the type classification (Type I, Type II, etc.). These reactions occur at very high temperatures with the ingredients in molten form. As the new compounds cool, they solidify into solid pellet form called clinker. The clinker is then ground to a fine powder, a small amount of gypsum is added, and the finished cement is bagged or shipped bulk to ready mix concrete plants. Concrete is produced by mixing cement with fine aggregate (sand), coarse aggregate (gravel or crushed stone), water, and—often—small amounts of various chemicals called admixtures that control such properties as setting time and plasticity. The process of hardening or setting is actually a chemical reaction called hydration. When water is added to the cement, it forms a slurry or gel that coats the surfaces of the aggregate and fills the voids to form the solid concrete. The properties of concrete are determined by the type of cement used, the additives, and the overall proportions of cement, aggregate, and water. Raw Material Use The raw materials used in cement production are widely available in great quantities. Limestone, marl, and chalk are the most common sources of calcium in cement (converted into lime through calcination). Common sources of silicon include clay, sand, and shale. Certain waste products, such as fly ash, can also be used as a silicon source. The iron and aluminum can be provided as iron ore and bauxite, but recycled metals can also be used. Finally, about 5% of cement by weight is gypsum, a common calcium- and sulfur -based mineral. It takes 3,200 to 3,500 pounds of raw materials to produce one ton (2,000 lbs.) of finished cement, according to the Environmental Research Group at the University of British Colombia (UBC). Table 1 Typical Concrete Mix Typical Concrete Mix Component Percent by weight Portland cement 12% Sand 34% Crushed stone 48% Water 6% The water, sand, and gravel or crushed stone used in concrete production in addition to cement are also abundant (typical proportions of a residential concrete mix are shown in Table 1). With all of these raw materials, the distance and quality of the sources have a big impact on transportation energy use, water use for washing, and dust generation. Some aggregates that have been used in concrete production have turned out to be sources of radon gas. The worst problems were when uranium mine tailings were used as concrete aggregate, but some natural stone also emits radon. If concerned, you might want to have the aggregate tested for radon. The use of fly ash from coal-fired power plants is beneficial in two ways: it can help with our solid waste problems, and it reduces overall energy use. While fly ash is sometimes used as a source of silica in cement production, a more common use is in concrete mixture as a substitute for some of the cement. Fly ash, or pozzolan, can readily be substituted for 15% to 35% of the cement in concrete mixes, according to the U.S. EPA. For some applications fly ash content can be up to 70%. Of the 51 million tons of fly ash produced in 1991, 7.7 million tons were used in cement and concrete products, according to figures from the American Coal Ash Association. Thus, fly ash today accounts for about 9% of the cement mix in concrete. Fly ash reacts with any free lime left after the hydration to form calcium silicate hydrate, which is similar to the tricalcium and dicalcium silicates formed in cement curing. Through this process, fly ash increases concrete strength, improves sulfate resistance, decreases permeability, reduces the water ratio required, and improves the pumpability and workability of the concrete. Western coal- fired power plants produce better fly ash for concrete than eastern plants, because of lower sulfur and lower carbon content in the ash. (Ash from incinerators cannot be used.) There are at least a dozen companies providing fly ash to concrete producers. Talk to your concrete supplier and find out if they are willing to add fly ash to the mix. (If your local plant doesn't know where to get the fly ash, a list of companies is available from EBN.) Portland cement with fly ash added is sometimes identified with the letter P after the type number (Type IP). The EPA requires fly ash content in concrete used in buildings that receive federal funding (for information call the EPA Procurement Guidelines Hotline at 703/941-4452). Fly ash is widely used in Europe as a major ingredient in autoclaved cellular concrete (ACC); in the U.S., North American Cellular Concrete is developing this technology (see EBN, ). Other industrial waste products, including blast furnace slag, cinders, and mill scale are sometimes substituted for some of the aggregate in concrete mixes. Even recycled concrete can be crushed into aggregate that can be reused in the concrete mix—though the irregular surface of aggregate so produced is less effective than sand or crushed stone because it takes more cement slurry to fill all the nooks and crannies. In fact, using crushed concrete as an aggregate might be counterproductive by requiring extra cement—by far the most energy -intensive component of concrete. Energy Table 2 Embodied Energy for Cement and Concrete Production Embodied Energy for Cement and Coner.IG Production Z.Gr EC,: 4..•.._I eta c._ &WI leocfI M:tJwt, .. tt7jT2 Yr:I'4 t';.-rrr 12-: 6!Ve f.sO `.OL fro 15/5! O 5'4% y:.,1:: }it ±!Ye 17 dui i0 1:0 Iii CRer S'.su tet 45.573 53000 IW000 5.9% RWM. e s r c, 0 CM re, 7.1..• Iwww. : 1X1 17mCO3 uL? Notes: Calculations of energy requirements for cement production based on figures supplied by the Portland Cement Association, 1990 data. Aggregate and hauling energy requirements based on data supplied by PCA and based on the following assumptions: • Cement hauled 50 miles to ready -mix plant • Aggregate hauled 10 miles to plant • Concrete mix hauled 5 miles to building site • Concrete mix: 500 lbs. cement, 1,400 lbs. sand, 2,000 lbs. crushed stone, 260 lbs. water/yard. Energy consumption is the biggest environmental concern with cement and concrete production. Cement production is one of the most energy intensive of all industrial manufacturing processes. Including direct fuel use for mining and transporting raw materials, cement production takes about six million Btus for every ton of cement (Table 2). The average fuel mix for cement production in the United States is shown in Table 3. The industry's heavy reliance on coal leads to especially high emission levels of CO2, nitrous oxide, and sulphur, among other pollutants. A sizeable portion of the electricity used is also generated from coal. The vast majority of the energy consumed in cement production is used for operating the rotary cement kilns. Newer dry -process kilns are more energy efficient than older wet -process kilns, because energy is not required for driving off moisture. In a modern dry -process kiln, a pre -heater is often used to heat the ingredients using waste heat from the exhaust gases of the kiln burners. A dry -process kiln so adapted can use up to 50% less energy than a wet -process kiln, according to UBC researchers. Some other dry -process kilns use a separate combustion vessel in which the calcining process begins before the ingredients move into the rotary kiln—a technique that can have even higher overall efficiency than a kiln with pre -heater. In the United States, producing the roughly 80 million tons of cement used in 1992 required about .5 quadrillion Btus or quads (1 quad = 10`' Btus). This is roughly .6% of total U.S. energy use, a remarkable amount given the fact that in dollar value, cement represents only about .06% of the gross national product. Thus, cement production is approximately ten times as energy intensive as our economy in general. In some Third World countries, cement production accounts for as much as two-thirds of total energy use, according to the Worldwatch Institute. Table 3 Fuel Use for Cement Production Fuel Use for Cement Production 1 rru3orK2 Brus per Ft191 tom of c.am9r1 PRrcent PetfOlErUrnproducts 63. 1 l (diesal. 0morroa. LPG) Nultsul (jus 476 8.2 Cool&coke 3.524 bo.a Woste tuelt 256 4.0 ElecttIcity' 1.443 24.0 Told 5,792. 103. While cement manufacturing is extremely energy intensive, the very high temperatures used in a cement kiln have at least one advantage: the potential for burning hazardous waste as a fuel. Waste fuels that can be used in cement kilns include used motor oil, spent solvents, printing inks, paint residues, cleaning fluids, and scrap tires. These can be burned relatively safely because the extremely high temperatures result in very complete combustion with very low pollution emissions. (Municipal solid waste incinerators operate at considerably lower temperatures.) Indeed, for some chemicals thermal destruction in a cement kiln is the safest method of disposal. A single cement kiln can burn more than a million tires a year, according to the Portland Cement Association. Pound for pound, these tires have a higher fuel content than coal, and iron from the steel belts can be used as an ingredient in the cement manufacturing. Waste fuels comprise a significant (and growing) part of the energy mix for cement plants (see Table 3), and the Canadian Portland Cement Association estimates that waste fuel could eventually supply up to 50% of the energy. Energy use for concrete production looks considerably better than it does for cement. That's because the other components of concrete—sand, crushed stone, and water—are much less energy intensive. Including energy for hauling, sand and crushed stone have embodied energy values of about 40,000 and 100,000 Btus per ton, respectively. The cement, representing about 12% of concrete, accounts for 92% of the embodied energy, with sand representing a little under 2% and crushed stone just under 6% (see Table 2). Use of fly ash in concrete already saves about 44 trillion Btus (.04 quads) of energy annually in the U.S. Increasing the rate of fly ash substitution from 9% to 25% would save an additional 75 trillion Btus. CO 2 Emissions Table 4 CO Emissions from Cement and Concrete Production CO, Emasions from Camant and Concroto Ptoduction • There are two very different sources of carbon dioxide emissions during cement production. Combustion of fossil fuels to operate the rotary kiln is the largest source: approximately �/4 tons of CO per ton of cement. But the chemical process of calcining limestone into lime in the cement kiln also produces CO?: CaCO 3 ' CaO + CO 2 limestone ' lime + carbon dioxide This chemical process is responsible for roughly 1/2 ton of CO? per ton of cement, according to researchers at Oak Ridge National Laboratory. Combining these two sources, for every ton of cement produced, 1.25 tons of CO? is released into the atmosphere (Table 4). In the United States, cement production accounts for approximately 100 million tons of CO., emissions, or just under 2% of our total human -generated CO,. Worldwide, cement production now accounts for more than 1.6 billion tons of COI—over 8% of total CO? emissions from all human activities. The most significant way to reduce CO? emissions is improving the energy efficiency of the cement kiln operation. Indeed, dramatic reductions in energy use have been realized in recent decades, as discussed above. Switching to lower -CO, fuels such as natural gas and agricultural waste (peanut hulls, etc.) can also reduce emissions. Another strategy, which addresses the CO? emissions from calcining limestone, is to use waste lime from other industries in the kiln. Substitution of fly ash for some of the cement in concrete can have a very large effect. Other Air Emissions Besides CO,, both cement and concrete production generate considerable quantities of air -pollutant emissions. Dust is usually the most visible of these pollutants. The U.S. EPA (cited by UBC researchers) estimates total particulate (dust) emissions of 360 pounds per ton of cement produced, the majority of which is from the cement kiln. Other sources of dust from cement production are handling raw materials, grinding cement clinker, and packaging or loading finished cement, which is ground to a very fine powder—particles as small as `/„.goo of an inch. The best way to deal with the dust generated in cement manufacturing would be to collect it and put it back into the process. This is done to some extent, using mechanical collectors, electric precipitators, and fabric filters (baghouses). But recycling the dust is difficult, according to UBC researchers; it first has to be treated to reduce its alkalinity. Some cement kiln dust is used for agricultural soil treatments, and the rest (of that collected) is often landfilled on site. There was investigation into the possibility of using cement kiln dust for treatment of acidified lakes in eastern Canada, but rather than simply buffering the low pH of the water, the dust chemically created a potentially harmful salt. In addition to dust produced in cement manufacturing, dust is also generated in concrete production and transport. Common sources are sand and aggregate mining, material transfer, storage (wind erosion from piles), mixer loading, and concrete delivery (dust from unpaved roads). Dust emissions can be controlled through water sprays, enclosures, hoods, curtains, and covered chutes. Other air pollution emissions from cement and concrete production result from fossil fuel burning for process and transportation uses. Air pollutants commonly emitted from cement manufacturing plants include sulfur dioxide (S02) and nitrous oxides (NOx). SO? emissions (and to a lesser extent SO3, sulfuric acid, and hydrogen sulfide) result from sulfur content of both the raw materials and the fuel (especially coal). Strategies to reduce sulfur emissions include use of low -sulfur raw materials, burning low -sulfur coal or other fuels, and collecting the sulfur emissions through state-of-the-art pollution control equipment. Interestingly, lime in the cement kiln acts as a scrubber and absorbs some sulfur. Nitrous oxide emissions are influenced by fuel type and combustion conditions (including flame temperature, burner type, and material/exhaust gas retention in the burning zone of the kiln). Strategies to reduce nitrogen emissions include altering the burner design, modifying kiln and pre- calciner operation, using alternate fuels, and adding ammonia or urea to the process. The cement industry claims to have reduced overall pollution emissions by 90% in the last 20 years. Water Pollution Another environmental issue with cement and concrete production is water pollution The concern is the greatest at the concrete production phase. "Wash-out water with high pH is the number one environmental issue for the ready mix concrete industry," according to Richard Morris of the National Ready Mix Concrete Association. Water use varies greatly at different plants, but Environment Canada estimates water use at batching plants at about 500 gallons per truck per day, and the alkalinity levels of washwater can be as high as pH 1 2. Highly alkaline water is toxic to fish and other aquatic life. Environment Canada has found that rainbow trout exposed to portland cement concentrations of 300, 500, and 1,000 milligrams/liter have 50% mortality times (the time required for 50% of the population in test samples to be killed) of 68, 45, and 29 minutes, respectively. At the batch plant, washwater from equipment cleaning is often discharged into settling ponds where the solids can settle out. Most plants are required to have process water discharge permits from state, federal, or provincial environmental agencies to dispose of wastewater from these settling ponds. As long as the pH of this wastewater is lower than 12.5, it is not considered a hazardous material by U.S. law. Some returned concrete also gets put into settling ponds to wash off and recover the aggregate. On the positive side, many newer ready mix plants have greatly reduced water use in recent years because of both wastewater disposal issues and drought conditions in some parts of the country. "More companies are going to completely closed-loop systems," according to Terek Kahn of the National Ready Mix Concrete Association. Despite the apparent significance of the wastewater concern, the National Ready Mix Concrete Association to date has not developed standards for member companies on wastewater treatment, including rinsing of trucks and chutes at the building site. John Mullarchy of the association says that procedures are developed on a company -by -company basis. In many areas, environmental regulations dictate procedures relative to wastewater treatment. In more urban areas, the on-site rinse water (for chutes) often has to be collected and treated or disposed of at the plant. Solid Waste While the cement and concrete industries can help reduce some of our solid waste problems (burning hazardous waste as cement kiln fuel and using fly ash in concrete mixtures, for example), one cannot overlook the fact that concrete is the largest and most visible component of construction and demolition (C&D) waste. According to estimates presented in the AIA Environmental Resource Guide, concrete accounts for up to 67% by weight of C&D waste (53% by volume), with only 5% currently recycled. Of the concrete that is recycled, most is used as a highway substrate or as clean fill around buildings. As more landfills close, including specialized C&D facilities, concrete disposal costs will increase and more concrete demolition debris will be reprocessed into roadbed aggregate and other such uses. Concrete waste is also created in new construction. Partial truckloads of concrete have long been a disposal problem. Ready mix plants have come up with many innovative solutions through the years to avoid creating waste—such as using return loads to produce concrete retaining wall blocks or highway dividers, or washing the unset concrete to recover the coarse aggregate for reuse. But recently, there have been some dramatic advances in concrete technology that are greatly reducing this waste. Concrete admixtures are available that retard the setting of concrete so effectively that a partial load can be brought back to the ready mix plant and held overnight or even over a weekend—then reactivated for use. When it is possible to use pre -cast concrete components instead of poured concrete, doing so may offer advantages in terms of waste generation. Material quantities can be estimated more precisely and excess material can be utilized. Plus, by carefully controlling conditions during manufacture of pre -cast concrete products, higher strengths can be achieved using less material. The Superior Wall foundation system, for example, uses only about a third as much concrete as the typical poured concrete wall it replaces. Waste water run-off can also be more carefully controlled at centralized pre -cast concrete facilities than on jobsites. Another interesting trend that relates to waste minimization is the idea of producing reuseable concrete masonry units. The National Concrete Masonry Association has been working on interlocking blocks called Formwall'", designed specifically so that they can be reused. While these blocks are not yet on the market, this type of thinking is a big step forward. Health Concerns Working with wet concrete requires a number of precautions, primarily to protect your skin from the high alkalinity. Rubber gloves and boots are typically all that is required to provide protection. Cement dermatitis, though relatively uncommon, occasionally occurs among workers in the concrete industry who fail to wear the proper protective clothing. Once it has hardened, concrete is generally very safe. Traditionally, it has been one of the most inert of our building materials and, thus, very appropriate for chemically sensitive individuals. As concrete production has become higher -tech, however, that is changing. A number of chemicals are now commonly added to concrete to control setting time, plasticity, pumpability, water content, freeze -thaw resistance, strength, and color. Most concrete retarders are relatively innocuous sucrose- (sugar-) based chemicals, added in proportions of .03% to .15%. Workability agents or superplasticizers can include such chemicals as sulfonated melamine -formaldehyde and sulphonated napthalene formaldehyde condensates. Air -entraining admixtures function by incorporating air into the concrete to provide resistance to damage from freeze -thaw cycles and to improve workability. These are usually added to the cement and identified with the letter A after the type (Type IA). These materials can include various types of inorganic salts (salts of wood resins and salts of sulphonated lignin, for example), along with more questionable chemicals such as alkyl benzene sulphonates and methyl -ester -derived cocamide diethanolamine. Fungicides, germicides, and insecticides are also added to some concrete. Because of these chemical admixtures, today's concrete could conceivably offgas small quantities of formaldehydes and other chemicals into the indoor air. Unfortunately, it is difficult to find out from the manufacturers the actual chemicals in these admixtures. For chemically sensitive clients, it may be advisable to specify concrete with a bare minimum of admixtures, or use a sealer on the finished concrete to minimize offgassing. Asphalt -impregnated expansion joint filler, curing agents that are sometimes applied to the surface of concrete slabs to reduce water evaporation, special oils used on concrete forms, and certain sealants used for treating finished concrete slabs and walls can also cause health problems with some chemically sensitive individuals. Finally, concrete floors and walls can cause moisture problems and lead to mold and mildew growth, which cause significant health problems in certain individuals. There are two common sources of moisture: moisture wicking through concrete from the surrounding soil; and moisture from the house that may condense on the cold surface of concrete. To eliminate the former, provide good drainage around a foundation, dampproof or waterproof the outside of the foundation walls before backfilling, provide a layer of crushed stone beneath the slab, and install a polyethylene moisture barrier under the slab (protected from the concrete with a layer of sand if possible). To reduce the likelihood of condensation on concrete surfaces, they should be insulated. In northern climates, installing a layer of rigid foam on the outside of the foundation wall and under the slab will generally keep inner surface of the concrete warm enough that condensation will not occur. With interior foundation insulation, provide a vapor barrier to keep moisture from reaching the concrete surface. In southern climates, protecting against condensation may be more difficult. Summing Up Cement and concrete are vital components in building construction today. Concrete has many environmental advantages, including durability, longevity, heat storage capability, and (in general) chemical inertness. For passive solar applications, concrete's ability to function as a structural element while also providing thermal mass makes it a valuable material. In many situations concrete is superior to other materials such as wood and steel. But cement production is very energy intensive—cement is among the most energy -intensive materials used in the construction industry and a major contributor to CO, in the atmosphere. To minimize environmental impact, therefore, we should try to reduce the quantity of concrete used in buildings, use alternative types of concrete (with fly ash, for example), and use that concrete wisely. Who is Mischa Popoff? June 14th, 2011 Reigniting Organic Attack by Corporate Agribusiness Interests CORNUCOPIA, WIS: When The Cornucopia Institute, a farm policy research group, officially launched in April 2004, one of its primary issue areas was what it referred to as "The Corporate Attack on Organic Agriculture." At the time, Cornucopia's focus was on the father and son team of Dennis and Alex Avery at the ultra- conservative Hudson Institute's campaign to discredit organics. Now, in 201 1 , after seven years of successfully exposing the genesis of Hudson's ire, and greatly diminishing its effectiveness, a new generation of "Trojan horse" naysayers has emerged. The latest attacks come from Mischa Popoff, a Canadian who purports to be an advocate for organics and is publicizing his self - published book entitled Is /t Organic? The author misses few opportunities to impugn the integrity of the organic label, or USDA oversight, while simultaneously defending biotechnology and the industrial agriculture system that organics seeks to replace. "Addressing the potential damage from attacks by the Hudson Institute, and other right-wing think tanks such as the Hoover Institution, the Heartland Institute, and the Competitive Enterprise Institute, was relatively easy," said Mark A. Kastel, Codirector at the Wisconsin -based Cornucopia Institute. "Every rebuttal that we published, or preemptive media advisory we issued, was put into context by including the corporate agribusiness funding base for the work of these entities." Like the Averys, Popoff is a conservative ideologue, a global warming denier, an ardent critic of hybrid automobiles, and has suggested that the American mortgage crisis that precipitated the financial meltdown was caused by "overregulation." His book sold on his website is subtitled: The Inside Story of Who Destroyed the Organic Industry, Turned It into a Socialist Movement and Made MillionS in the Process, and a Comprehensive History of Farming, Warfare and Western Civilization from 1645 to the Present. "Popoff calling the S30 billion organic industry a `socialist movement," says Cornucopia's Kastel, "is akin to the fascist leaders in Germany, during the 1 920s and '30s, referring to their movement as the National Socialist party. It's Orwellian doublespeak. Nowhere in the food industry have entrepreneurs and investors realized greater financial reward, with virtually no governmental funding, than in meeting the higher standards consumers are seeking by paying a premium for organic food." Popoff acted as an organic inspector a number of years ago. He now challenges the propriety of organic accreditation and third - party certification by suggesting, echoing the Averys at Hudson, that "There is currently little proof of actual cleanliness, nutrition and fair play in the global organic industry." Popoff's unsubstantiated claim is that 80-90% of organic food in North America is fraudulent and imported. That's not to say that Cornucopia doesn't share some of Popoff's concerns. Popoff suggests that the entire certification process is without merit and should be replaced with a testing protocol for prohibited toxic chemicals. "We think there is great merit in doing spot testing, as Congress required, and we have criticized the USDA for not having implemented testing until now, but it would be prohibitively expensive to test all farms and crops and would not substitute for other careful oversight protocols," said Will Fantle, Research Director at The Cornucopia Institute. The USDA's National Organic Program, sensitive to the need for spot tests, is currently soliciting public comments on a new federal rule outlining the periodic residue testing of organically produced agricultural products. The proposal calls upon independent organic certifiers to conduct more surprise inspections of organic operations. Cornucopia, in its role as an organic industry watchdog, along with many other organic advocacy groups, supports the proposed new regulation recently published in the Federal Register (available for public comment until dune 28). "This is a scheme similar to how the Internal Revenue Service conducts audits," added Fantle. "Strategically conducted tests, and aggressive prosecution if willful violations are discovered, will surely act as a powerful deterrent. I will add that there is no documentary evidence to believe that widespread fraud is currently occurring in the organic industry." It appears that Popoff pins his credibility to his role as an insider and organic supporter. But even that is open to debate as he hasn't actually done any organic inspections in years and has been inappropriately identifying himself as an "International Organic Inspectors Association (IOIA) Advanced Inspector." The Executive Director of IOIA, Margaret Scoles, says that she often gets calls and messages from people who are confused by Popoff's claimed credentials. "A recent message I received was signed, `Mischa Popoff, IOIA Advanced Organic Farm and Process Inspector'," says Scoles. "I was surprised," she adds. "In 2008, I asked him to discontinue using the term because there is no such thing [Advanced Inspector]. He just made up the title. We asked him not to use the IOIA name in any way to imply membership status with our association, but his continued use of our name on his website and in his emails still causes confusion." Popoff was an Inspector member of IOIA between 1 998 and 2004, Scoles notes. But "he has never worked for us and has no affiliation with IOIA." Popoff's political ideology comes through strong and clear in some of his writings (Click here to view a sampling) and statements; his other website also exposes ultra -conservative views. In addition to his suggesting that organics is some kind of socialist construct he has stated that, "Liberals destroy agriculture in B.C. [British Columbia]" and suggested that the liberal American financier George Soros is somehow financing an organic "bureaucracy" instead of substantive oversight. "Mr. Popoff's contention that the organic industry has some kind of socialist/liberal agenda is a gross misnomer," stated Kastel. "Support for organics cuts across all demographics with liberals and conservative suburban consumers, urbanites and rural farmers ranging from dreadlocked hippies to conservative Christians, Mennonites and the Amish." Like the Averys at the Hudson Institute he's also attacked The Cornucopia Institute, suggesting that they have partnered with Soros and claiming that the organization's largest funder is the farmer -owned cooperative Organic Valley (another one of Popoff's targets in his book). "Because Organic Valley CEO George Siemen doesn't back his thesis to switch all organic oversight exclusively to testing he attacked Siemen and now is going after Cornucopia," said Kastel. "Interestingly, Popoff has also promoted a testing business that would directly benefit from this recommended approach." Kastel and Siemen are in good company. Popoff's book also attacks Deputy USDA Secretary Kathleen Merrigan, a well-known organic supporter, and Michael Pollan, the New York Times journalist and author of the bestseller The Omnivore's Dilemma. "By trying to tie all of his favorite villains together Mr. Popoff discredits himself, and leaves all of his statements open to question," noted Kastel. "Not only is Organic Valley not our largest funder, we do not receive any financial support from the cooperative, or from Mr. Soros, and fully stand by our independence as an organic industry watchdog," Fantle affirmed. Almost no element in the organic farming movement has been spared attacks on its credibility by Popoff. One of the certifiers impugned, OCIA International, responded to what they referred to as "false statements about our organization and organic certification in general." "We would like to set the record straight. On a YouTube video Mr. Popoff states that there are no unannounced inspections performed on certified organic farms. This is untrue and is covered in the NOP Final Rule and also in the OCIA Standards." The USDA organic regulatory language includes: Additional inspections may be announced or unannounced at the discretion of the certifying agent or as required by the Administrator or State organic program's governing State official. And the contract OCIA, one of the original nonprofit certifiers predating the USDA, has with its farmers and processors reads: The inspector shall have the right to make unannounced visits, take samples, and require residue tests. "We take our responsibility to follow up on any questionable activities in organics very seriously," said OCIA President Peggy Linzmeier. "Mr. Popoff's fictitious stories, challenging the credibility of the organic label, are injurious to all the farmers and organizations in this industry that are acting with high integrity.' Although his material has primarily appeared on what has been referred to as the "echo chamber" of conservative websites, Popoff has developed an extensive database of e-mail addresses in the organic industry. "Either he's had tremendous financial support in his data mining efforts or he's personally invested countless hours in developing this electronic mailing list," stated Fantle. "If it weren't for this level of outreach, we would probably entirely ignore his rantings, which all too often grossly distort the facts." Research indicating organics' nutritional superiority, and demonstrably lower level of exposure to agrichemicals, antibiotics and hormones, can be found on Cornucopia's website or that of the Organic Center. "Whether it is research conducted by the USDA, Consumers Union, publisher ofConsumer Reports Magazine, or numerous peer- reviewed journals, there is considerable scientific back-up for the faith consumers have in the ethical approach organic farmers have taken," added Kastel. "Mr. Popoff's claims to the contrary just don't hold water." STATE OF MISSOURI DEPARTMENT OF NATURAL RESOURCES MISSOURI AIR CONSERVATION COMMISSION 0 A PERMIT BOCK PERMIT TO CONSTRUCT Under the authority of RSMo 643 and the Federal Clean Air Act the applicant is authorized to construct the air contaminant source(s) described below, in accordance with the laws, rules and conditions as set forth herein. Permit Number: 11 2 0 0 7 - 0 0 6 Project Number: 2007-08-047 035-0024 Owner: Colyott BackHoe, Dump Truck & Dozer Service Owner's Address: P. O. Box 2348, Ellsinore, MO 63937 Installation Name: Hunter Stone Company Installation Address: Hwy E, Hunter, MO 63937 Location Information: Carter County, S20, T26N, R2E Application for Authority to Construct was made for: The installation of a new rock crushing plant. Rock is processed through 1 crusher(s) and 1 screen(s). The rock crushing plant has a maximum hourly design rate (MHDR) of 150 tons per hour (tph). Best Management Practices will be used to control fugitive emissions from storage piles and haul roads. This review was conducted in accordance with Section (5), Missouri State Rule 10 CSR 10-6.060, Construction Permits Required. D Standard Conditions (on reverse) are applicable to this permit. Er Standard Conditions (on reverse) and Special Conditions (listed as attachments starting on page 2) are applicable to this permit. NOV 2 0 2007 EFFECTIVE DATE MO 780-1204 (1.03) OR DESIGNEE MENT OF NATURAL RESOURCES STANDARD CONDITIONS: Permission to construct may be revoked if you fail to begin construction or modification within two years from the effective date of this permit. Permittee should notify the Air Pollution Control Program if constructton:or modification is not started within two years after the effective date of this permit, or if Construction 6r modification is suspended for one year or more. You will be in violation of 10 CSR 10-6.060 if you fail to adhere to the specifications and conditions listed in your application, this permit and the project review. Specifically, all air contaminant control devices shall be operated and maintained as specified in the application, associated plans and specifications. You must notify the Air Pollution Control Program of the anticipated date of start up of this (these) air contaminant source(s). The information must be made available not more than 60 days but at least 30 days in advance of this date. Also, you must notify the Department of Natural Resources Regional Office responsible for the area within which you are located within 15 days after the actual start up of this (these) air contaminant source(s). A copy of this permit and permit review shall be kept at the installation address and shall be made available to Department of Natural Resources' personnel upon request. You may appeal this permit or any of the listed Special Conditions as provided in RSMo 643.075. If you choose to appeal, the Air Pollution Control Program must receive your written declaration within 30 days of receipt of this permit. If you choose not to appeal, this certificate, the project review, your application and associated correspondence constitutes your permit to construct. The permit allows you to construct and operate your air contaminant source(s), but in no way relieves you of your obligation to comply with all applicable provisions of the Missouri Air Conservation Law, regulations of the Missouri Department of Natural Resources and other applicable federal, state and local laws and ordinances. The Department of Natural Resources has established the Outreach and Assistance Center to help in completing future applications or fielding complaints about the permitting process. You are invited to contact them at 1-800-361-4827 or (573) 526-6627, or in writing addressed to Outreach and Assistance Center, P.O. Box 176, Jefferson City, MO 65102-0176. The Air Pollution Control Program invites your questions regarding this air pollution permit. Please contact the Construction Permit Unit at (573) 751-4817. If you prefer to write, please address your correspondence to the Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102-0176, attention Construction Permit Unit. MO 780.1204 (1.03) Page No. 2 Permit No. Project No. 2007-08-047 SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions: The special conditions listed in this permit were included based on the authority granted the Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically 643.075); by the Missouri Rules listed in Title 10, Division 10 of the Codes of State Regulations (specifically 10 CSR 10-6.060); by 10 CSR 10-6.060 paragraph (12)(A)10. "Conditions required by permitting authority"; by 10 CSR 10-6.010 "Ambient Air Quality Standards" and 10 CSR 10-6.060 subsections (5)(D) and (6)(A); and by control measures requested by the applicant, in their permit application, to reduce the amount of air pollutants being emitted, in accordance with 10 CSR 10-6.060 paragraph (6)(E)3. Furthermore, one or more of the Subparts of 40 CFR Part 60, New Source Performance Standards (NSPS), applies to this installation. 1. Best Management Practices Hunter Stone Company shall control fugitive emissions from all of the haul roads and stockpiles at this site by performing Best Management Practices, which include the usage of paving, chemical dust suppressants, or documented watering. These practices are defined in Attachment AA. 2. National Ambient Air Quality Standards (NAAQS) Limitation for Particulate Matter Less Than Ten Microns in Diameter (PM,o) A. The operator(s) for Hunter Stone Company's rock crushing plant (035-0024) shall ensure, while operating at this site, that the ambient impact of PK() at or beyond the nearest property boundary does not exceed 150 pg/m3 in any 24-hour period, in accordance with the Federal NAAQS requirements (40 CFR 50.6). B. To demonstrate compliance, the operator(s) shall maintain a daily record of material processed. Attachment A, Daily Ambient PM10 Impact Tracking Record, or other equivalent form(s), will be used for this purpose. 3. Annual Emission Limit of Particulate Matter Less Than Ten Microns in Diameter (PM10) A. The operator(s) shall ensure that Hunter Stone Company's rock crushing plant emits less than 15 tons of PM10 into the atmosphere in any 12 -month period. B. To demonstrate compliance, the operator(s) shall maintain a daily record of material processed and PM10. Attachment B, Monthly PM10 Emissions Tracking Record. or other equivalent form(s), will be used for this purpose. 4. Usage of Wet Suppression Control System on Equipment A. Hunter Stone Company shall install and operate wet spray devices to restrict the emission of particulate matter. These wet spray devices must be used to control fugitive emissions whenever these units are in operation. The wet spray devices shall be installed on the following units: 1) The primary crusher (EP01) 2) Screen (EP02) B. Watering may be suspended during periods of freezing conditions, when use of the wet spray devices may damage the equipment. During these conditions, the operator(s) shall adjust the production rate to control fugitive emissions from these units. The operator shall record a brief description of such events in a daily log. 5. Performance Testing for New Source Performance Standards (NSPS) A. Hunter Stone Company shall submit the enclosed testing plan to the Enforcement section of the Air Pollution Control Program for all equipment applicable to NSPS Subpart "000". Hunter Stone Company shall contact the Enforcement section to obtain all requirements for testing, and the plan must be submitted to the Enforcement section at least 30 days prior to the proposed test date. B. Testing must be performed no later than 60 days after achieving the maximum production rate of the process, and in any case no later than 180 days after initial startup. The performance test results shall be submitted to the Enforcement section no later than 30 days after completion of any required testing. 6. Prohibition Against Concurrent Operations Without Further Air Pollution Control Program Review A. The rock crushing plant (035-0024) is prohibited from operating whenever any other plant(s) are located at this site. Page No. 3 Permit No. Project No. 2007-08-047 SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions: 7. Restriction on Process Configuration of Primary Emission Point(s) The maximum hourly design rate of the plant is equal to the sum of the design rate(s) of the primary emission point(s). Hunter Stone Company has designated the following unit(s) as the primary emission point(s) of the rock crushing plant: primary crusher (EP01). Bypassing the primary emission point(s) for processing is prohibited. 8. Restriction on Minimum Distance to Nearest Property Boundary The primary emission point of the rock crushing plant, which is the primary crusher (EP01), shall be located at least 300 feet from the nearest property boundary whenever it is operating at this site. 9. Power Generation No diesel engines or generators shall be operated for any purpose other than powering processing equipment. 10. Record Keeping Requirement The operator(s) shall maintain all records required by this permit for not less than five (5) years and shall make them available immediately to any Missouri Department of Natural Resources' personnel upon request. 11. Reporting Requirement The operator(s) shall report to the Air Pollution Control Program Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, no later than ten (10) days after any exceedances of the limitations imposed by this permit. TECHNICAL REVIEW OF APPLICATION FOR AUTHORITY TO CONSTRUCT PROJECT DESCRIPTION Rock, composed of non-metallic minerals, is drilled/blasted, loaded into haul trucks, and transported to processing. Rock is processed through feeder(s), crusher(s), screen(s). Processing equipment is powered with diesel engine(s). The emission points are listed in the attached spreadsheet summary. This installation is not on the List of Named Installations [10 CSR 10-6.020(3)(B), Table 2]. The installation is located in Carter County, an attainment area for all criteria air pollutants. EMISSIONS EVALUATION Criteria air pollutants will be emitted from this operation. The main air pollutant of concern is PM,o. The potential emissions were calculated from the maximum hourly design rate (MHDR) of the equipment, appropriate emission factors, control device efficiencies, and the limiting operating hours at MHDR. The sources of the emission factors and control efficiencies are listed in the section "Permit Documents". In order to avoid having to perform increment analysis, the installation has agreed to hold all of its emissions under de minimis levels so the operation can be considered a de minimis source under 10 CSR 10-6.060 section (5). The rock crushing plant has an annual emission limit of less than 15 tons of PM,o in any 12 -month period. A composite PM lo emission factor was developed for the rock crushing plant. The composite emission factor is incorporated into the monthly record-keeping table, Attachment B. If the conditioned potential emissions of PM10 were above these levels, then the owner would be required to perform increment analysis. Table 2: Emissions Summary (tons per year Air Pollutant Regulatory De Minimis Levels Existing Potential Emissions Existing Actual Emissions (year EIQ) Potential Emissions of the Application *New Installation Conditioned Potential Emission Factor (Ib/ton) PM,o 15.0 N/A N/A 27.55 <15 0.0419 SOx 40.0 N/A N/A 4.61 2.42 N/A NOx 40.0 N/A N/A 70.16 36.76 N/A VOC 40.0 N/A N/A 5.73 3.0 N/A CO 100.0 N/A N/A 15.11 7.92 N/A HAPs 10.0/25.0 N/A N/A 0.06 0.03 N/A N/A = Not Apprcable ' PK() conditioned potential based on limits in permit conditions. Other pollutants proportionately educed based on PM10 conditioned potential. AMBIENT AIR QUALITY IMPACT ANALYSIS Screening tools were used to evaluate the ambient air impact of the hourly emissions from this operation. The ambient impact was evaluated at a distance of 300 feet to the nearest property boundary. The ambient impact at this site shall not exceed the National Ambient Air Quality Standard (NAAQS) of 150 pg/m3 of PM10 at or beyond the nearest property boundary in any single 24-hour period. The screening tools were used to develop an ambient impact factor for the rock crushing plant. This ambient impact factor is incorporated into the daily record keeping table, Attachment A. For sources agreeing to use Best Management Practices (BMPs), as defined in Attachment AA, haul roads and stockpiles are not modeled with screening tools. Instead, they are addressed as a background level of 20 pg/m3 of PM10. To ensure conformity with NAAQS, the remaining process emissions are limited to an impact of less than 130 pg/m3 of PM,o at or beyond the nearest property boundary. Table 3: Ambient Air Quality Impact Analysis of PM10, 24 -Hour Averaging Time Operation Ambient Impact Factor (Ng/m3ton) ModeledDaily Impact (Ng/m3) *Background 3 (P9/1113) NAAQS a (14013) Production Limit (tons) 1. Solitary 0.0469 130.00 20.00 150.00 2,769 * Background PM10 level of 20.00 pg/m3 from haul roads and stockpiles 4 APPLICABLE REQUIREMENTS The owner is subject to compliance with the following applicable requirements. The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping, monitoring, and reporting requirements. • Submission of Emission Data, Emission Fees and Process Information, 10 CSR 10-6.110 • Operating Permits, 10 CSR 10-6.065 • An Operating Permit application is required for this installation within 30 days of equipment startup. • Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin, 10 CSR 10-6.170 • Restriction of Emission of Visible Air Contaminants, 10 CSR 10-6.220 • Restriction of Emission of Odors, 10 CSR 10-3.090 • Restriction of Emission of Particulate Matter From Industrial Processes, 10 CSR 10-6.400 • Restriction of Emission of Sulfur Compounds, 10 CSR 10-6.260 • 40 CFR Part 60 Subpart "OOO", Standards of Performance for Nonmetallic Mineral Processing Plants, of the New Source Performance Standards (NSPS) • The National Emission Standards for Hazardous Air Pollutants (NESHAPs) and the currently promulgated Maximum Achievable Control Technology (MACT) regulations do not apply to the proposed equipment. STAFF RECOMMENDATION On the basis of this review conducted in accordance with Section (5), Missouri State Rule 10 CSR 10-6.060, Construction Permits Required, I recommend this permit be granted with special conditions. Samer Al-Shoukhi Date Environmental Engineer PERMIT DOCUMENTS The following documents are incorporated by reference into this permit: • The Application for Authority to Construct form, designating Colyott BackHoe, Dump Truck & Dozer Service as the owner and operator of the installation. • Environmental Protection Agency (EPA) AP -42, Compilation of Air Pollutant Emission Factors; Volume I, Stationary Point and Area Sources, Fifth Edition. • Noyes Data Corp. book, Orlemann, et aI.1983, Fugitive Dust Control. • EPA Factor Information Retrieval (FIRE) Version 6.21. • Spreadsheet calculations of potential -to -emit and ambient impact. • Southeast Regional Office Site Survey. • Best Management Practices 5 o a) a: a� c c Y N U — 0 03 O 0.r O - 4a• O d f aO U O C M d O E c Q Q to O DU Q c • o o V) E c ca w N • 14)z N 1 w N 0 M • 7 co U O d) Q m O @ LC) 0) NUS n O ai N_ 03 ra��Z ZU o U T c w o c •- aUaO (Copy this sheet as needed.) (Month, Day, Year) 0 This sheet covers the period from J j E O o t a IT) .a >,,,,p o) 20.00 20.00 • O 20.00 20.00 20.00 20.00 20.00 20.00 20.00 20.00 20.00 20.00 20.00 20.00 m 0 Ambient Impact Factor (pg/m3ton) Daily Production (tons) LPlant Name: Plant ID: Permit #: 'Daily PM10 Impact /m3 Ambient Impact Factor (pg/m3ton) Daily Production (tons) Plant Name: Plant ID: Permit #: 'Daily PM10 Impact (pg/m3) Ambient Impact Factor (pg/m3ton) Daily Production (tons) Hunter Stone Company 035-0024 Project # 2007-08-047 'Daily PM,;, Impact •/m3 JI* 0.0469 0.0469 0.0469 0.0469 0.0469 0 0.0469 0.0469 0.0469 ci 0.0469 1 0.0469 0.0469 0.0469 0.0469 0.0469 0.0469 0.0469 Daily Production (tons) 0) m 0 0 U IL U 0. E 1(3 E rn c 0 U m E 0) .0 c0 0 c 0 U 0 0 0 a` cti0 0) T 0. PM10 Ambient Impact(s) and the Background PM10 Level. A TOTAL PM10 Level of less than 150 pg/m3 in any 24-hour E=0 T y 0) .0 U O N N c_ D c U co E 0o 7 U 0 � CO r O Q — CO a .c m U E U co U 0) w 0 O N N M ch E E 0) • 7-1) ma)>�E E =o0 o_ a_ 0 OY10 0) U 0) 'C 01 L0) — c -- 0. - N C) 0) 0) 0) zz°z° The Monthly Emissions (lbs) are calculated by multiplying the Monthly Production (tons) by the Composite Emission Factor (lbs/ton). The Monthly Emissions (tons) are calculated by dividing the Monthly Emissions (lbs) by 2,000. The 12 -Month Emissions (tons/year) are a rolling total calculated by adding the Month's Emissions (tons) to the Monthly Emissions (tons) of the previous eleven (11) months. A total of less than 15 tons in any consecutive 12 -month period indicates compliance Attachment B: Monthly PM10 Emissions Tracking Record Hunter Stone Company, 035-0024 — Rock Crushing Plant Project Number: 2007-08-047 County, CSTR: Carter County (S20, T26N, R2E) Primary Unit Size: 150 tph Distance to Nearest Property Boundary: 300 feet This sheet covers the period from (Copy this sheet as needed.) to (Month, Day, Year) Month Monthly Production (tons) Composite PM10 Emission Factor (lbs/ton) 'Monthly PM10 Emissions (lbs) 2Monthly PM10 Emissions (tons) '12 -Month PM10 Emissions (tons/year) 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 Note 1: Note 2: Note 3: Attachment AA: BMPs Page 1 of 2 Attachment AA: Best Management Practices (BMPs)- Construction Industry Fugitive Emissions Construction Industry Sites covered by the Interim Relief Policy shall maintain Best Management Control Practices (BMPs) for fugitive emission areas at their installations when in operation. Options for BMPs are at least one of the following: For Haul Roads: 1. Pavement of Road Surfaces — A. The operator(s) may pave all or any portion of the haul roads with materials such as asphalt, concrete, and/or other material(s) after receiving approval from the program. The pavement will be applied in accordance with industry standards for such pavement so as to achieve "Control of Fugitive Emissions'" while the plant is operating. B. Maintenance and/or repair of the road surface will be conducted as necessary to ensure that the physical integrity of the pavement is adequate to achieve control of fugitive emissions from these areas while the plant is operating. C. The operator(s) shall periodically water, wash and/or otherwise clean all of the paved portions of the haul road(s) as necessary to achieve control of fugitive emissions from these areas while the plant is operating. 2. Usage of Chemical Dust Suppressants — A. The operator(s) shall apply a chemical dust suppressant (such as magnesium chloride, calcium chloride, lignosulfonates, etc.) to all the unpaved portions of the haul roads. The suppressant will be applied in accordance with the manufacturer's suggested application rate (if available) and re-applied as necessary to achieve control of fugitive emissions from these areas while the plant is operating. B. The quantities of the chemical dust suppressant shall be applied, re-applied and/or maintained sufficient to achieve control of fugitive emissions from these areas while the plant is operating. C. The operator(s) shall record the time, date and the amount of material applied for each application of the chemical dust suppressant agent on the above areas. The operator(s) shall keep these records with the plant for not less than five (5) years, and the operator(s) shall make these records available to Department of Natural Resources personnel upon request. 3. Usage of Documented Watering — A. The operator(s) shall control the fugitive emissions from all the unpaved portions of the haul roads at the installation by consistently and correctly using the application of a water spray. Documented watering will be applied in accordance with a recommended application rate of 100 gallons per day per 1,000 square feet of unpaved/untreated surface area of haul roads as necessary to achieve control of fugitive emissions from these areas while the plant is operating. For example, the operator(s) shall calculate the total square feet of unpaved vehicle activity area requiring control on any particular day, divide that product by 1,000, and multiply the quotient by 100 gallons for that day. B. The operator(s) shall maintain a log that documents daily water applications. This log shall include, but is not limited to, date and volumes (e.g., number of tanker applications and/or total gallons used) of water application. The log shall also record rationale for not applying water on day(s) the plant is in operation (e.g., meteorological situations, precipitation events, freezing, etc.) C. Meteorological precipitation of any kind, (e.g. a quarter inch or more rainfall, sleet, snow, and/or freeze thaw conditions) which is sufficient in the amount or condition to achieve control of fugitive emissions from these areas while the plant is operating. D. Watering may also be suspended when the ground is frozen, during periods of freezing conditions when watering would be inadvisable for traffic safety reasons, or when there will be no traffic on the roads. The operator(s) shall record a brief description of such events in the same log as the documented watering. E. The operator(s) shall record the date and the amount of water applied for each application on the above areas. The operator(s) shall keep these records with the plant for not less than five (5) years, and the operator(s) shall make these records available to Department of Natural Resources personnel upon request. For purposes of this document, Control of Fugitive Emissions means to control particulate matter that is not collected by a capture system and visible emissions to the extent necessary to prevent violations of the air pollution law or regulation. (Note: control of visible emission is not the only factor to consider in protection of ambient air quality.) Attachment AA: BMPs Page 2 of 2 For Vehicle Activity Areas around Open Storage Piles: 1. Pavement of Stockpile Vehicle Activity Surfaces — A. The operator(s) may pave all or any portion of the vehicle activity areas around the storage piles with materials such as asphalt, concrete, and/or other material(s) after receiving approval from the program. The pavement will be applied in accordance with industry standards for such pavement so as to achieve control of fugitive emissions while the plant is operating. B. Maintenance and/or repair of the road surface will be conducted as necessary to ensure that the physical integrity of the pavement is adequate to achieve control of fugitive emissions from these areas while the plant is operating. C. The operator(s) shall periodically water, wash and/or otherwise clean all of the paved portions of the vehicle activity areas around the storage piles as necessary to achieve control of fugitive emissions from these areas while the plant is operating. 2. Usage of Chemical Dust Suppressants — A. The operator(s) shall apply a chemical dust suppressant (such as magnesium chloride, calcium chloride, lignosulfonates, etc.) to all the vehicle activity areas around the open storage piles. The suppressant will be applied in accordance with the manufacturer's suggested application rate (if available) and re-applied as necessary to achieve control of fugitive emissions from these areas while the plant is operating. B. The quantities of the chemical dust suppressant shall be applied, re-applied and/or maintained sufficient to achieve control of fugitive emissions from these areas while the plant is operating. C. The operator(s) shall record the time, date and the amount of material applied for each application of the chemical dust suppressant agent on the above areas. The operator(s) shall keep these records with the plant for not less than five (5) years, and the operator(s) shall make these records available to Department of Natural Resources personnel upon request. 3. Usage of Documented Watering — A. The operator(s) shall control the fugitive emissions from all the vehicle activity areas around the storage piles at the installation by consistently and correctly using the application of a water spray. Documented watering will be applied in accordance with a recommended application rate of 100 gallons per day per 1,000 square feet of unpaved/untreated surface area of vehicle activity areas around the storage piles as necessary to achieve control of fugitive emissions from these areas while the plant is operating. (Refer to example for documented watering of haul roads.) B. The operator(s) shall maintain a log that documents daily water applications. This log shall include, but is not limited to, date and volumes (e.g., number of tanker applications and/or total gallons used) of water application. The log shall also record rationale for not applying water on day(s) the plant is in operations (e.g., meteorological situations, precipitation events, freezing, etc.) C. Meteorological precipitation of any kind, (e.g. a quarter inch or more rainfall, sleet, snow, and/or freeze thaw conditions) which is sufficient in the amount or condition to achieve control of fugitive emissions from these areas while the plant is operating. D. Watering may also be suspended when the ground is frozen, during periods of freezing conditions when watering would be inadvisable for traffic safety reasons, or when there will be no traffic on the roads. The operator(s) shall record a brief description of such events in the same log as the documented watering. E. The operator(s) shall record the date and the amount of water applied for each application on the above areas. The operator(s) shall keep these records with the plant for not less than five (5) years, and the operator(s) shall make these records available to Department of Natural Resources personnel upon request. Mr. Brad Colyott Owner Colyott BackHoe, Dump Truck & Dozer Service P. O. Box 2348 Ellsinore, MO 63937 RE: New Source Review Permit - Project Number: 2007-08-047 Dear Mr. Colyott: Enclosed with this letter is your New Source Review permit. Please review your permit carefully and note the special conditions, if any, and the requirements in your permit. Operation in accordance with the conditions and requirements in your permit, the New Source Review application submitted for project 2007-08-047 and your operating permit, if required, is necessary for continued compliance. Please review your operating permit, as it will contain all applicable requirements for your rock -crushing plant, including any special conditions from your New Source Review permit.. The section of the permit entitled "Technical Review of Application for Authority to Construct" should not be separated from the main portion of your permit. The entire permit must be retained in your files. The reverse side of your permit certificate has important information concerning standard permit conditions and your rights and obligations under the laws and regulations of the State of Missouri. If you have any questions regarding this permit, please do not hesitate to contact Samer Al-Shouki at the department's Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102 or (573) 751-4817. Thank you for your attention to this matter. Sincerely, AIR POLLUTION CONTROL PROGRAM Kendall B. Hale, P.E. New Source Review Unit Chief KBH:sal Enclosures c: Southeast Regional Office PAMS File: 2007-08-047 Permit Number: FINAL February 2005 CHRONIC TOXICITY SUMMARY SILICA (CRYSTALLINE, RESPIRABLE) (silicon dioxide, quartz, tridymite, cristobalite) CAS Registry Number: 7631-86-9 I. Chronic Toxicity Summary II. Inhalation Reference Exposure Level Critical effect(s) Hazard index target(s) 3 pg/m3 [respirable, as defined occupationally by ACGIH (2004)/ISO (1995) Silicosis in miners and other workers Respiratory system Physical and Chemical Properties (HSDB, 2001) Description Molecular formula Molecular weight Density Melting point Boiling point Vapor pressure Solubility Conversion factor Transparent crystals SiO2 60.09 g/mol 2.65 g/cm3 @ 0 °C (quartz) 1610 °C 2230 °C (2503.20 °K) l0 torr @ 1732 °C Practically insoluble in water or acids, except hydrofluoric acid; very slightly sol. in alkali. Not applicable In crystalline silica, the silicon and oxygen atoms are arranged in a definite regular pattern throughout the crystal. The characteristic crystal faces of a crystalline form of silica are the outward expression of this regular arrangement of the atoms (HSDB, 2001). This REL is meant to be applied only to particles of crystalline silica (quartz, cristobalite, tridymite), of respirable size, as defined by the occupational hygiene methods described by ACGIH (2004)/ISO (1995) which has a 50% cut -point at 4 gm particle aerodynamic diameter. This occupational definition of respirable differs from the environmental definition of respirable, which is PMio. (The occupational particle category "thoracic" has a 50% cut -point at 10 gm particle diameter (ACGIH, 2004) and the category "inhalable" has a 50% cut -point at 100 µm particle diameter (ACGIH, 2004).) III. Major Uses and Sources At least 11 chemically identical forms (polymorphs) have been described for crystalline silica. Alpha -quartz is the most abundant polymorph and constitutes 12% of the earth's crust (Elzea, 1997). Silica is also found in the amorphous (non -crystalline) state. The amorphous silica in diatomaceous earth (composed mainly of the cell walls of diatoms) can be converted to the crystalline form cristobalite by heating to 1000-1100 °C (calcining). Silica is often associated 1 FINAL February 2005 with silicates, which, in addition to silicon and oxygen, contain other metals such as iron, magnesium, aluminum, calcium, potassium, and sodium. The major uses of silica are in the manufacture of glass, abrasives, ceramics, and enamels, in scouring and grinding compounds, and in molds for castings. Silica is also used in decolorizing and purifying oils and petroleum products; as a clarifying agent; in filtering liquids; and in the manufacture of heat insulators, firebrick, and fire- and acid -proof packing materials. As diatomite (naturally occurring diatomaceous earth), silica is used as a filtration agent, as an abrasive, and as an industrial filler. Sources of ambient respirable crystalline silica in California include mines, quarries, diatomaceous earth calcining plants, sand blasting, and entrained fines (e.g., PM10) from surface soil. The annual statewide industrial emissions from facilities reporting under the Air Toxics Hot Spots Act in California based on the most recent inventory were estimated to be 2,514,981 pounds of crystalline silica (CARB, 2001. The fraction, which is respirable as defined either occupationally or environmentally, is not known. Measurement of crystalline silica has evolved. Instrumentation has varied by country. In South Africa since the 1930s, dust was collected with a konimeter (Le Roux, 1970; Cherrie and Aitken, 1999). A small volume of air (e.g., 5 cm3 captured in less than a second) was collected (impacted) onto a small area of a glass slide coated with adhesive. Total dust particles were counted and expressed as dust particles per cubic centimeter. Later, slides were heated to 500- 550 °C (ignition) to remove carbonaceous materials and immersed in hot 50% hydrochloric acid followed by a second ignition to remove acid -soluble materials. The remainder was mostly silica particles, which could be counted. The konimeter was superseded by the thermal precipitator, which also deposited particles onto glass but could sample larger air volumes at high flow rates (> 1 L/minute) for several hours. With time, particle counting was replaced by estimation of a particle's surface area, initially by examining slides but more recently by an automated method (Kitto, 1960; 1970). In the United States the impinger method was used from 1922 until 1984 (Lippmann, 2001). Air was drawn into a trap containing fluid, particles in an aliquot of the fluid were counted under magnification, and concentrations were expressed as million particles per cubic foot of air sampled. Later, gravimetric analysis was introduced. Gravimetric analysis is dominated by the larger particles in any given size range. When it was realized that only a fraction of the dust was responsible for silicosis, respirable dust was collected onto filters using size -specific dust collectors, such as horizontal plate elutriators in South Africa and cyclones in the United States. The sizes of particles collected on the filter were a function of the apparatus used and the rate of airflow through the apparatus. Quartz dust was quantified by examining filters in an electron microscope with a specific X-ray diffraction beam absorbed by crystalline silica. The National Institute of Occupational Sciences and Health (NIOSH, 2003) has approved Method 7500, which uses one of three approved cyclones and a 5 µm PVC membrane filter to sample, and X-ray diffraction to measure crystalline silica. The ARB has used Method 7500 in research projects. In order to harmonize respirable particulate sampling methodology in workers, an international agreement has been reached to use dust samplers that have a 50% cut point for particles of 4 µm aerodynamic diameter (ISO, 1995; ACGIH, 2004). 2 FINAL February 2005 Various attempts have been made to estimate the changes in silica levels in workplaces over time (e.g., Seixas et al., 1997 for diatomaceous earth facilities in California; Verma et al., 1989 for Ontario hard rock miners). However, although some conversion factors have been proposed, correlation between dust particle number in earlier studies, when dust concentrations were higher, and dust particle weight in the later studies, when the dust concentrations have been lowered, is imprecise so it is difficult to compare the earlier silica measurements with the more recent ones. IV. Effects of Human Exposures Inhalation of crystalline silica initially causes respiratory irritation and an inflammatory reaction in the lungs (e.g., Vallyathan et al., 1995). Acute exposures to high concentrations cause cough, shortness of breath, and pulmonary alveolar lipoproteinosis (acute silicosis). After chronic but lower workplace exposures to silica for six to sixteen years, the small airways become obstructed as measured by pulmonary function tests (e.g., decreased FEV1) in granite quarry workers (no measurement of silica levels reported; Chia et al., 1992). In a report on the hazards of exposure to crystalline silica, the American Thoracic Society (1997) stated: "Studies from many different work environments suggest that exposure to working environments contaminated by silica at dust levels that appear not to cause roentgenographically visible simple silicosis can cause chronic airflow limitation and/or mucus hypersecretion and/or pathologic emphysema." Hnizdo and Vallyathan (2003) also concluded that "chronic levels of silica dust that do not cause disabling silicosis may cause the development of chronic bronchitis, emphysema, and/or small airways disease that can lead to airflow obstruction, even in the absence of radiological silicosis." Fibrotic lesions associated with crystalline silica have also been found at autopsy in the lungs of granite workers who lacked radiological evidence of silicosis (Craighead and Vallyathan, 1980). Silicosis results from chronic exposure; it is characterized by the presence of histologically unique silicotic nodules and by fibrotic scarring of the lung. The histological progression of silicosis has been described as: (1) granuloma composed of histiocytic cells, collagen, and lymphocytes; (2) cellular fibrotic nodule with irregular collagen at the center and circular collagen at the periphery; (3) more mature nodule with acellular and avascular center; and (4) late mature nodule composed of dust and collagen including a calcified center (Green and Vallyathan, 1996). Lung diseases other than cancer associated with silica exposure include silicosis, tuberculosis/silicotuberculosis, chronic bronchitis, small airways disease, and emphysema (Oxman et al., 1993; Park et al., 2002; Hnizdo and Vallyathan, 2003; Balmes et al., 2003). Silica exposure has been implicated in autoimmune diseases (rheumatoid arthritis, scleroderma, systemic lupus erythematosus) in gold miners and granite workers (Steenland and Goldsmith, 1995; Parks et al., 1999) and in the causation of kidney disease in some occupations (Goldsmith and Goldsmith, 1993; Stratta et al., 2001), possibly by an immune mechanism. At the cellular level, silica particles are engulfed in the lung by alveolar macrophages (AM). According to the generally assumed pathological model, the AM subsequently release various growth factors and reactive oxygen species (ROS; superoxide anion, hydrogen peroxide, hydroxyl radical) (Lapp and Castranova, 1993; Mossman and Churg, 1998; Ding et al., 2002). ROS and some growth factors (e.g., activator protein -1, platelet activating factor) are inflammatory and attract neutrophils to the site of inflammation, while other factors (fibronectin, 3 Glenn Hartmann From: Kenneth Sack [kensack@me.com] Sent: Tuesday, September 04, 2012 7:30 AM To: Tom Jankovsky; Mike Samson; Glenn Hartmann; John Martin Subject: bedrock application From: Sheri Sack <sherisackna,me.com> Date: September 03, 2012 8:30:45 PM Commissioners, EXHIBIT 1 vivi A travesty of justice occurred on August, at the Garfield County Planning and Zoning hearing. That the County Attorney allowed to go forward Bedrock's application for an asphalt processing plant (ridiculously disguised as a contractor yard), when the County Commission had denied it just 7 months earlier is an outrage. That staff recommended it AGAIN, and the Zoning Board approved it AGAIN is worse. It is government gone awry. And even worse yet, for the Zoning Board to again approve this application without requiring of Bedrock a SINGLE environmental safeguard evidences a total disregard for the health, safety, and welfare of the citizens of this County. Moreover, to put a citizen like Eagle Springs through this time, expense, and anxiety is just shameful. It is a slap in the face of every citizen. Commissioners, we now put our faith in you. You must again deny Bedrock's application for all of the same reasons it was denied in the first place. Sincerely, Sheri Sack 1 Glenn Hartmann From: Kenneth Sack [kensack@me.com] Sent: Tuesday, September 04, 2012 7:25 AM To: Glenn Hartmann; Tom Jankovsky; Mike Samson; John Martin Subject: Expert Letter Attachments: RAP letter to Ken Sack_120903.pdf Glenn EXHIBIT 'XXX Please incorporate the following letter from Louis Zeller, Science Director of BREDL into today's meeting As you can see, the approval of Bedrock's application would have severe and immediate affect on our organic certification. The application should be once again denied. thank you Ken Sack cell 954-249-5674 Eagle Springs Organic Eagle Springs Solar 5454 County Rd 346 Silt, CO 81650 Eagle Springs Crossing 1733 Railroad Ave Rifle, CO 81652 1 Blue Ridge Environmental Defense League wtitw.BREDL.org PO Box 88 Glendale Springs, North Carolina 28629 BREDL@skybcst.com (336) 982-2691 September 3, 2012 Ken Sack Eagle Springs Organic 5454 County Rd 346 Silt, Colorado 81652 kensack@me.com Dear Mr. Sack: I write in response to your request for my professional opinion about the potential impacts of reclaimed asphalt pavement operations on a nearby organic farm. Reclaimed asphalt pavement, or RAP, is produced by the removal, repair and/or reconstruction of existing roadways. In addition to the components of newly manufactured asphalt pavement, RAP includes substances deposited by vehicular use on the roadway including oil, gas, metals and tire compounds. The specific toxic substances included in this mixture include lead, cadmium and polycyclic aromatic hydrocarbons. The two main vectors for environmental contamination by RAP operations are aerial contaminants carried by fine particles on the wind and liquid leachate contaminants transported by rainwater infiltration into the stored RAP. I have located several published articles and EPA documents which point to potential problems from RAP aggregate piles which I will present below. The US Environmental Protection Agency studied aerial pollution from aggregate storage piles in the form of fugitive dust. Emissions are created at three distinct points: 1) during loading of materials on the pile, 2) wind currents and 3) during load out from the pile. The study found that "When freshly processed aggregate is loaded onto a storage pile, its potential for dust emissions is at a maximum."' Dust emissions and fines can be spread over great distances, the smallest several miles or more. Information on liquid highway runoff from the US Geological Survey indicates that there is a pollution risk created by toxic chemicals deposited on roadway surfaces regardless of the pavement type. The impacts of stormwater runoff from Washington State freeways on aquatic ecosystems was investigated through a series of bioassays utilizing algae, and zooplankton and fish. Algae and zooplankton were adversely affected by the soluble fraction of the runoff, while suspended solids caused high moralities of rainbow trout fry. In addition, BODS values similar to those reported in the stormwater literature were Development of Emission Factors for Fugitive Dust Sources, United States Environmental Protection Agency Publication No. EPA -450/3-74-037 egge quam bibere I'at, 2 September 3, 2012 measured; however, there were indications that results were influenced by toxicity to microbial populations.2 Further, a study done by the State of Minnesota focused specifically on the problem of water pollution resulting from rainwater deposition and runoff from both asphalt and concrete aggregate piles creating contaminated leachate. The Stockpile Runoff Project addressed environmental concerns regarding the quality of runoff water from salvaged pavement stockpiles. Three experimental stockpiles were studied, one pile consisted of coarse concrete, a second consisted of fine concrete material, and the third consisted of salvaged bituminous material (recycled asphalt product) obtained from a pavement milling project. The leachate water from the piles flowed through a sampling and flow monitoring system with data loggers and automated sequence samplers. Composite water samples were analyzed using EPA approved methods and quality control protocols. Comparing the observed median values for the stockpile runoff with Minnesota standards for leachates emanating from stockpiles, the long-term concern reduces to suspended and dissolved solids, and pH. Polynuclear aromatic hydrocarbons (PAH) concentrations from the bituminous millings pile were near of below detectable limits. Planning for stockpile storage sites should include management practices of controlling runoff similar to those that are used for construction sites. Berms, straw bales, grass or other filter channels, and locating stockpile site some distance form surface waters may be appropriate practices. Possible impacts on the groundwater system should be considered. Bituminous aggregate piles resulting from pavement reclamation created leachate which clearly contained the toxic asphalt contaminant PAH, which is actually a large group of toxic compounds. Also, the National Asphalt Pavement Association provides the following information on RAP. This study concludes that groundwater contamination from asphalt toxins could result from the use of the material. Data regarding the composition of leachate from Recycled Asphalt Pavement (RAP) is limited. This paper suggests that RAP can be used as construction fill or in embankments. It has been suggested that heavy metals or polycyclic aromatic hydrocarbons (PAHs) might be present in RAP and may therefore leach from it given the proper circumstances. An investigation performed to address these concerns found that, based on waste management policy in Florida, the RAP tested in this study would result in exceedance of groundwater guidance concentrations of the pollutants studied.4 Finally, as you know, federal regulations for organic foods require the farmer to notify 2 Portele, G.J., Mar, B.W., Horner, R.R., and Welsh, E.B., 1982., Effects of Seattle area highway stormwater runoff on aquatic biota: Interim Report No. WA -RD -39.11, 45 p. httn://webdmamrl.er.usas.gov, t2, 1; thwa/gw/stateabs.htm 3 Sadecki, R.W., Busacker, G.P., Moxness, K.L., Faruq K.C., and Allen, L.G., 1996, An investigation of water quality in runoff from stockpiles of salvaged concrete and bituminous paving: Minnesota Department of Transportation Final Report MNR-96/31, 112 p. Leaching Characteristics of Asphalt Road Waste: Timothy G. Townsend, University of Florida, 1998 http://www.wi Iderconstruction.com/pdfs/MatCon%20Leach in e,%20Techn ical%20Paper.pdf CMS(' quam bibere Page 3 September 3, 2012 the appropriate regulatory agency if and when prohibited substances or other changes are observed. The relevant regulation on requirements for organic certification states:5 § 205.400—A person seeking to receive or maintain organic certification under the regulations in this part must: (f) Immediately notify the certifying agent concerning any: (1) Application, including drift, of a prohibited substance to any field, production unit, site. facility, livestock, or product that is part of an operation; and (2) Change in a certified operation or any portion of a certified operation that may affect its compliance with the Act and the regulations in this part. Environmental contaminants such as those known to come from reclaimed asphalt v1/4„ouId be among the impacts requiring notification. Such changes could result in disqualification of an otherwise certified organic farm. In conclusion, I believe the evidence points to a clear risk caused by reclaimed asphalt pavement operations to organic farms in the vicinity. I hope this information is helpful. Sincerely, Lo. Louis A. Zeller Executive Director Blue Ridge Environmental Defense League 5 National Organic Program regulations, 7 C.F.R. Part 205, promulgated under the Organic Foods Production Act, 7 U.S.C. §§6501 — 6523 Qr55e quam Intim Renelle Lott From: Kenda Spaulding [kendaspaulding23@gmail.com] Sent: Tuesday, September 04, 2012 8:38 AM To: Web Administrator Subject: Bed Rock Request Follow Up Flag: Follow up Flag Status: Flagged Dear Commissioners Tom Jankovsky, John Martin, and Mike Sampson: strongly encourage the commissioners to approve the Bed Rock request before them at the September 4th meeting. This request would allow for storage, shop and office use of the Bed Rock property. I also ask the commissioners, in the future, to be more than receptive to Bed Rock's efforts to find a suitable site for their batch plant. Their lease terminates and they must move their plant within the next year. In spite of having spent $200,000.00 to satisfy requirements given them to use this same property for a batch plant, their first request related to use of their property was denied. Bed Rock has respectfully followed guidance from Garfield Planning and Zoning, at great expense, and their current request deserves approval. Respectfully, Richard and Kay Morgan 0293 313 Road New Castle, CO 81647 970.876.2252 1 Renelle Lott From: Kenda Spaulding [kendaspaulding23@gmail.com] Sent: Tuesday, September 04, 2012 8:37 AM To: Web Administrator Subject: Bed Rock request Follow Up Flag: Flag Status: Follow up Flagged Dear Commissioners Tom Jankovsky, John Martin, and Mike Sampson: I strongly encourage the commissioners to approve the Bed Rock request before them at the September 4th meeting. This request would allow for storage, shop and office use of the Bed Rock property. I also ask the commissioners, in the future, to be more than receptive to Bed Rock's efforts to find a suitable site for their batch plant. Their lease terminates and they must move their plant within the next year. In spite of having spent $200,000.00 to satisfy requirements given them to use this same property for a batch plant, their first request related to use of their property was denied. Bed Rock has respectfully followed guidance from Garfield Planning and Zoning, at great expense, and their current request deserves approval. Respectfully, Craig Spaulding 1601 County Road 313 New Castle, CO 81647 970.309.4335 1 Renelle Lott From: Kenda Spaulding [kendaspaulding23@gmail.com] Sent: Tuesday, September 04, 2012 8:36 AM To: Web Administrator Subject: Bed Rock request September 4th Commissioners Meeting Follow Up Flag: Follow up Flag Status: Flagged Dear Commissioners Tom Jankovsky, John Martin, and Mike Sampson: I strongly encourage the commissioners to approve the Bed Rock request before them at the September 4th meeting. This request would allow for storage, shop and office use of the Bed Rock property. I also ask the commissioners, in the future, to be more than receptive to Bed Rock's efforts to find a suitable site for their batch plant. Their lease terminates and they must move their plant within the next year. In spite of having spent $200,000.00 to satisfy requirements given them to use this same property for a batch plant, their first request related to use of their property was denied. Bed Rock has respectfully followed guidance from Garfield Planning and Zoning, at great expense, and their current request deserves approval. Respectfully, Michael and Kenda Spaulding 1601 County Road 313 New Castle, CO 81647 970.876.5911 1 Debbie From: Tina Puentes <tina.puentes@yahoo.com> Sent: Monday, September 03, 2012 7:29 PM To: msamson@garfield-county.com Subject: Bedrock resources EXHIBIT 6,b66 Mike Samson, In light of the recent controversy over the Bedrock Resources property, I can't help but notice the bias in the liberal Post Independent constantly publishing letters to the editor that are representing only one side of the story. As an independent, small business owner in Garfield County, I feel that my opinion in this matter should also be relevant. The majority of the letters against Bedrock Resources' request for property use seem to submitted, as a majority, from individuals who don't even live, work, or raise families in our community. They are stating their opinions from a minimum of 40 miles away. I find it hard to believe that the organic farm would suffer any ill consequences due to Bedrocks operation in light of the fact that they were able to get their organic certification with a natural gas well pad located on their property. Not a quarter of a mile away from Bedrocks property line. To the best of my knowledge, this is still an active gas pad, of course paying Eagle Springs' owners, I am sure, royalties and lease payments. So I feel that someone's complaints 'not in my backyard' is being used, we should really consider what is ACTUALLY in their backyard. (In Eagle Springs case, that would be a natural gas well.) I can't help but wonder if they would be raising such a stink about Bedrock if Bedrock was willing to PAY them royalties....like the gas companies are. Please consider Bedrock's ability to manage their property responsibly and the active role that the company takes in providing jobs, revenue and infrastructure to Garfield County and our surrounding areas. They are a reputable company that has our regions best interests at heart and deserve to be respected as such and granted the opportunity to expand their operation. We should be grateful for a small business that wants to grow and stay in our county! Thanks for your consideration. Brady Hogan No virus found in this message. Checked by AVG - Version: 2012.0.2197 / Virus Database: 2437/5246 - Release Date: 09/03/12 1 BEDROCK RESOURCES I, the undersigned, hereby express my support for the Major Impact Review application of Bedrock Resources to locate a contractor's yard and associated facilities on Mamm Creek Road (County Road 315), Rifle, Colorado. Name Address /132 Soul CPc ^ 5rri%JS. CO/7/%%, J -; G�D ��,C l'�. • 'ST' L . / � 5 -� 3k1 \ A /3/5 Sfd.vo,»+(, lLEIL O/C,eo v/G s- 1 -0C C L? (9.Ci L.f _ct IAL 12 U' 5 ria GUi9r shYi /9/ /2 ')/e- Y/oS k\‘ rf\`CoC k . 5 L-'� (3- • q \ (cam l'!O f /71� 4'// C0 5s / 6s c) G 3/3 ee,f_t4 /%?s- x,31/ 4/0 j4LIA' 706 n24i`rt 5,Y( g' 6#, L031 Ccu, y 0131,1, g, , Ccs 31050 " 366 b' 11P-4 2`` S`r'•n-.C6' 909 &dude• -44 64 . 71.141 , Co 1.2; bib BEDROCK RESOURCES I, the undersigned, hereby express my support for the Major Impact Review application of Bedrock Resources to locate a contractor's yard and associated facilities on Mamm Creek Road (County Road 315), Rifle, Colorado. 4,4A daTZL Aa l rZ{ Address 1 1524 eoun Rcl 352 , R,.4 k 0-0 I510 eALUlfi-7 Rd 35Z, Rifle 0'0 602/-c/ -23.2 /° 8;1- 3 a G S /S7 Ayryj fi/Adlcv -,/ Co, /15-4 c %? 35-2 Picric 3Lkcl ! `W t o ~N C f J CL.d 61ci4l, \ //_'/.R "Rozv.i ,— : IjF Cv . ,Q c ti'' C i c><-- 5 3 /671/e 1 ' i/Ct i1 /71 a -1 / /(1) ('g . 3f e6 1 `60 0 Nxctscwft coVf 1 ST1CQ ._ . .7o y 'f 1/c7,✓ L f/4'Ga 1132/; � / ('C��'/(�� 355 z , /t OP,-, 20. ,fl 0 7 s ya c 3a) 6;H- 6502. oq/bs Mcsrl /fir' W/PCL-, 251-I %mind eri v -c, 514t, t 0 KI t 62 BEDROCK RESOURCES I, the undersigned, hereby express my support for the Major Impact Review application of Bedrock Resources to locate a contractor's yard and associated facilities on Mamm Creek Road (County Road 315), Rifle, Colorado. Name X4-/k/pvAr Address 41/47 NI CC. 'Stir 06 /1 34-x` Cf2, -551 1 &3' `/Sf ,Pe 3R3f atai � (�.� frb12 (v SYS - P -o 60/ k'l'll (a e -945 - App CL/G7an7 (b. 8/c2 o ,,Q1L)3 / 69x ins J e./45-3 /037 CDaanfie e 4M- Ole, S ' 1017— A) c., 8/(42,y -a m7/( Ze) d �'fid 1033 C.72, 335 -riL/75 ,, //(,Li(i`1 -4 (5.4c21 \M; Zpi\\_g( 7,06) cer,i210 zip: Ikeac-14,9/by? BEDROCK RESOURCES I, the undersigned, hereby express my support for the Major Impact Review application of Bedrock Resources to locate a contractor's yard and associated facilities on Mamm Creek Road (County Road 315), Rifle, Colorado. Name i,7 cut47v //) ,.o !4114 3EFe Cit 1°'7/" C+.ke\ n.Cv 7z/Z( rmi 1 Address 1//4-4, 1 c i CC`)f /2 `51" 1I8 c_t2 -31z w p ,�, Cc6,11c 16y`I q u- C -fie5--Rd- 67, GIA.Y.teD 26 ' a$rIe e‘ .111 C% K-/tt6 ;« �� si :.2.2e 4+4 1, e+ V.F1r (1, / Z AvE 51/CD g(65 -Z 10\ �� C� r� �1 t vk CV(' 0- Co X316 SZ /02 5-/;114-, Lc Avc-P-P)eco. l�1 Golc.�e� cit Sc)Wei 2V S'2 ,;f -le 6,0 g/(S 16-3 b bsik t5l Src.T, Co f�S� t'9• 131/ /32-1 g;f/(o. 96 6/SS 6k- 1 f, VO 8165-0 BEDROCK RESOURCES I, the undersigned, hereby express my support for the Major Impact Review application of Bedrock Resources to locate a contractor's yard and associated facilities on Mamm Creek Road (County Road 315), Rifle, Colorado. Name ,TAAE,c44(vc,Q4 10,1 gr° 11 vOr < Address 10-44 tcli 3s-• ,('c filo 4+h 1.6-70 e0 cvdA .A6 Q?US' /,4_ i'),^ 4/, /;5-0D die 255 f?. ,G) 3L-c1C_L, c cc, AN, e K i V \k- T12- CR-. 2-31 , 5'33 c2 3 20 4/-A. e S'/ -a ?D.4 � 51 N -C. /b - -- 7gso, °A & 1V// C --/e), faro g.J633 s/ti Ok e C/C /p P r`dc 81635 g6 etc 1-t(.24 7)-t,*r(- 1e 35- -5,23 ss,3 4JA4f.ve--0 ) L 6,1/, /e (/�. (? �� 7- /1(.1( lel D /l r' SV BEDROCK RESOURCES I, the undersigned, hereby express my support for the Major Impact Review application of Bedrock Resources to locate a contractor's yard and associated facilities on Mamm Creek Road (County Road 315), Rifle, Colorado. Name `1 kwa. .17(axo 7444-6 le*A-11 kirloQS80- 4Ih , 02,L, 44/14W1 /I( /4~' Cz,oca fitgA Address 2,2_5 Gc,` , i/>‘/ 32yr 6 0.s34tsa4k- u 4.C.b. (-47a) 42nEl 71A,/,tc, C0 I! ta 780 react a— 8 /cc5D /3s CJ37 S-/4/G,f2 6-6 7 P'C X4.1 Cc) c 76 S -C) Rey i / d sl y /i' "12e CO 81,65'0 641), Q_K.*aAci Sfr% ,('c f"). LIMM 6/1 6(s ksot,„ Sa4(cMr 8101 fi'D (Li r.frt-Ljln F.6/7 BEDROCK RESOURCES I, the undersigned, hereby express my support for the Major Impact Review application of Bedrock Resources to locate a contractor's yard and associated facilities on Mamm Creek Road (County Road 315), Rifle, Colorado. Name < 9```" eva(if C. -i\ e... c \. c c 9oN••••- l /D/1`-0 1 r'<7 A bni *QX_1, Address � 0/:' UlanASie /1)4' de1;Q p (L> 2299 FlZ 31\ Tlcw (ankle. Co 81(044'1 /s/5-7 ei2C kez/`iEL j a FO02O 3419 S eo , S re) /� . 8452 -/Des '41r -- %o l) • m e -aci tot - Cc: f e , %'v fiJ 11 0 N c,1 LJ S P% BEDROCK RESOURCES I, the undersigned, hereby express my support for the Major Impact Review application of Bedrock Resources to locate a contractor's yard and associated facilities on Mamm Creek Road (County Road 315), Rifle, Colorado. Name : (1 (1 I 1 / - 1 717 '(-770 ,fin r r a- {ir z, 2a - t"— �lt�G Gl it ( (O - Address g 3 3; ( (1- 3I i r -/?- (4,1.1 r �c 2- //00,2 - Op C?S://- .41:detco-/s/6.3-2,_ , :,,,, . I Co3 5 30,2--9f 6 s 1i I A i3 std , 1 f -c BEDROCK RESOURCES I, the undersigned, hereby express my support for the Major Impact Review application of Bedrock Resources to locate a contractor's yard and associated facilities on Mamm Creek Road (County Road 315), Rifle, Colorado. opeedar � fR-Q,rd qipcv ‘LY irej- tg, r/C q\A 201-1S Address 4' aaI , 3/7 ectudy /sk 50 (%; i lq sP /1" g;f7 e /4 3^e 4-.. ,'1, LL X17 Des; Ave ( : f J 5_5 f i (o nI-vfs l (1 /ono / •/x/64- Ate7S / Pie (A. o, 7o 54-a-, 64-7 3 2 5 /302 2 /-heieP / �" (2 ,/65c) yr/& 6 ,23} f4 6, 6 f 1(3 ijj /Y/P/4:j°&() v;ll4�� (�« T(f (n,i�; „ r/17 Lh 51 mss, )72,// s G/' i2.vc, -c°Q 14- BEDROCK RESOURCES 1, the undersigned, hereby express my support for the Major Impact Review application of Bedrock Resources to locate a contractor's yard and associated facilities on Mamm Creek Road (County Road 315), Rifle, Colorado. / Name A. ill. 1---4Xe5 Address 05- £7 k /fl'/tw,ti.s% Q7657, Mu.y 6 #/706" q?,10 co- BEDROCK RESOURCES I, the undersigned, hereby express my support for the Major Impact Review application of Bedrock Resources to locate a contractor's yard and associated facilities on Mamm Creek Road (County Road 315), Rifle, Colorado. Name WUnfe�� �P is1{ ra Gfitne94-"'A- ;n /9/ &C,n, /4 C � CaLt,414,( 41c4'l vt44-zr4-s IA 6- F >: Waell Address ii 23q cWocd T (i ale , `�'� , Qt , CD R 1105"2 L'-rx g . 231 RAC-4 C 5"2, 3 3 3 5 t' /6 7 /1%- c4 9* (_?o O Co i4wit ✓1. � 3�� . /'2f/t' , ttZ -! t4. 2 leo ReKo 07 /4 C4x"%cam & )2,0 CAtzlivz VJP C&y- sf� i / 0/ AC 31 k-#1 Ca( -1-1.e_. aim (' c� 9id7 RP 2/ eV— BEDROCK RESOURCES I, the undersigned, hereby express my support for the Major Impact Review application of Bedrock Resources to locate a contractor's yard and associated facilities on Mamm Creek Road (County Road 315), Rifle, Colorado. 11( Address (oft 0)e,li C;/G),to PAi'adwi e, (0 (500 Ca g6.9 Voe, co n4 /Of& & kp0/ LK 3/3, 7//PGi s14 /� o C �� � 43,7 BEDROCK RESOURCES I, the undersigned, hereby express my support for the Major Impact Review application of Bedrock Resources to locate a contractor's yard and associated facilities on Mamm Creek Road (County Road 315), Rifle, Colorado. Address 9 'azo i? 302 3 1?2 5T. cL/LT6�I/ l /'. �� C po,FeeC Printed By: Toby Guccini Date: Mon, Sep 3 2012 04:15 PM From: Toby Guccini <tobyguccini@gmail.Com> To: "toby@teamrmr.com" <toby@teamrmr.com> Subject: Fwd: additional docs bedrock Cc: Forwarded message From: "Kenneth Sack" <kensack@me.com> Date: Sep 3, 2012 10:44 AM Subject: additional docs bedrock To: "Tom Jankovsky" <tiankovsky@garfield-county.com>, "John Martin" <jmartin@garfield-county.com>, "Mike Samson" <msamson@garfield-county.com> Cc: "Glenn Hartmann" <ghartmann@garfield-county.com> 4 EXHIBIT Dear Commissioners I have sent numerous documents which demonstrate why the current application before you regarding recycling asphalt plant is actually worse than the first application that you denied in February and should be denied as well. The application is filled with ommissions and misstated facts. Even their "expert" Mr Popoff has questionable credentials. The bottom line here is that the land use change requested by Bedrock, would adversly affect my agricultural property and residential property,and is not compatible with my agricultural property and under the land use regulations, SHALL not be allowed. I have confidence that once again, you will make the unanimous decision to DENY this application and Eagle Springs Organic can continue growing with more jobs for residents of Garfield County.. Ken Sack cell 954-249-5674 Eagle Springs Organic Eagle Springs Solar 5454 County Rd 346 Silt, CO 81650 Eagle Springs Crossing 1733 Railroad Ave Rifle, CO 81652 ilk POPOFF BACKGROUNDER.PDF 760 KB MISCHA POPOFF BEDROCKS EXPERT.DOC 39 KB IIS LEACHING RECYLED ASPHALT CONTAINS LEAD.DOC 26 KB ASPHALT2 PERMIT FOR PLANT IN MO.PDF 172 KB 1111 ASPHALT2 CEMENT AND CONCRETE REPORT.DOC 96 KB IIS ASPHALT2 HEALTH ISSUES WITH CEMENT2.PDF 152 KB FINAL February 2005 II. CHRONIC TOXICITY SUMMARY SILICA (CRYSTALLINE, RESPIRABLE) (silicon dioxide, quartz, tridymite, cristobalite) CAS Registry Number: 7631-86-9 Chronic Toxicity Summary Inhalation Reference Exposure Level Critical effect(s) Hazard index target(s) 3 µg/m3 [respirable, as defined occupationally by ACGIH (2004)/ISO (1995) Silicosis in miners and other workers Respiratory system Physical and Chemical Properties (HSDB, 2001) Description Molecular formula Molecular weight Density Melting point Boiling point Vapor pressure Solubility Conversion factor Transparent crystals Si02 60.09 g/mol 2.65 g/cm3 @ 0 °C (quartz) 1610 °C 2230 °C (2503.20 °K) 10 torr @ 1732 °C Practically insoluble in water or acids, except hydrofluoric acid; very slightly sol. in alkali. Not applicable In crystalline silica, the silicon and oxygen atoms are arranged in a definite regular pattern throughout the crystal. The characteristic crystal faces of a crystalline form of silica are the outward expression of this regular arrangement of the atoms (HSDB, 2001). This REL is meant to be applied only to particles of crystalline silica (quartz, cristobalite, tridymite), of respirable size, as defined by the occupational hygiene methods described by ACGIH (2004)/ISO (1995) which has a 50% cut -point at 4 gm particle aerodynamic diameter. This occupational definition of respirable differs from the environmental definition of respirable, which is PM10. (The occupational particle category "thoracic" has a 50% cut -point at 10 gm particle diameter (ACGIH, 2004) and the category "inhalable" has a 50% cut -point at 100 gm particle diameter (ACGIH, 2004).) III. Major Uses and Sources At least 11 chemically identical forms (polymorphs) have been described for crystalline silica. Alpha -quartz is the most abundant polymorph and constitutes 12% of the earth's crust (Elzea, 1997). Silica is also found in the amorphous (non -crystalline) state. The amorphous silica in diatomaceous earth (composed mainly of the cell walls of diatoms) can be converted to the crystalline form cristobalite by heating to 1000-1100 °C (calcining). Silica is often associated 1 FINAL February 2005 with silicates, which, in addition to silicon and oxygen, contain other metals such as iron, magnesium, aluminum, calcium, potassium, and sodium. The major uses of silica are in the manufacture of glass, abrasives, ceramics, and enamels, in scouring and grinding compounds, and in molds for castings. Silica is also used in decolorizing and purifying oils and petroleum products; as a clarifying agent; in filtering liquids; and in the manufacture of heat insulators, firebrick, and fire- and acid -proof packing materials. As diatomite (naturally occurring diatomaceous earth), silica is used as a filtration agent, as an abrasive, and as an industrial filler. Sources of ambient respirable crystalline silica in California include mines, quarries, diatomaceous earth calcining plants, sand blasting, and entrained fines (e.g., PM10) from surface soil. The annual statewide industrial emissions from facilities reporting under the Air Toxics Hot Spots Act in California based on the most recent inventory were estimated to be 2,514,981 pounds of crystalline silica (CARB, 2001. The fraction, which is respirable as defined either occupationally or environmentally, is not known. Measurement of crystalline silica has evolved. Instrumentation has varied by country. In South Africa since the 1930s, dust was collected with a konimeter (Le Roux, 1970; Cherrie and Aitken, 1999). A small volume of air (e.g., 5 cm3 captured in less than a second) was collected (impacted) onto a small area of a glass slide coated with adhesive. Total dust particles were counted and expressed as dust particles per cubic centimeter. Later, slides were heated to 500- 550 °C (ignition) to remove carbonaceous materials and immersed in hot 50% hydrochloric acid followed by a second ignition to remove acid -soluble materials. The remainder was mostly silica particles, which could be counted. The konimeter was superseded by the thermal precipitator, which also deposited particles onto glass but could sample larger air volumes at high flow rates (> 1 L/minute) for several hours. With time, particle counting was replaced by estimation of a particle's surface area, initially by examining slides but more recently by an automated method (Kitto, 1960; 1970). In the United States the impinger method was used from 1922 until 1984 (Lippmann, 2001). Air was drawn into a trap containing fluid, particles in an aliquot of the fluid were counted under magnification, and concentrations were expressed as million particles per cubic foot of air sampled. Later, gravimetric analysis was introduced. Gravimetric analysis is dominated by the larger particles in any given size range. When it was realized that only a fraction of the dust was responsible for silicosis, respirable dust was collected onto filters using size -specific dust collectors, such as horizontal plate elutriators in South Africa and cyclones in the United States. The sizes of particles collected on the filter were a function of the apparatus used and the rate of airflow through the apparatus. Quartz dust was quantified by examining filters in an electron microscope with a specific X-ray diffraction beam absorbed by crystalline silica. The National Institute of Occupational Sciences and Health (NIOSH, 2003) has approved Method 7500, which uses one of three approved cyclones and a 5 pm PVC membrane filter to sample, and X-ray diffraction to measure crystalline silica. The ARB has used Method 7500 in research projects. In order to harmonize respirable particulate sampling methodology in workers, an international agreement has been reached to use dust samplers that have a 50% cut point for particles of 4 p.m aerodynamic diameter (ISO, 1995; ACGIH, 2004). 2 FINAL February 2005 Various attempts have been made to estimate the changes in silica levels in workplaces over time (e.g., Seixas et al., 1997 for diatomaceous earth facilities in California; Verma et al., 1989 for Ontario hard rock miners). However, although some conversion factors have been proposed, correlation between dust particle number in earlier studies, when dust concentrations were higher, and dust particle weight in the later studies, when the dust concentrations have been lowered, is imprecise so it is difficult to compare the earlier silica measurements with the more recent ones. IV. Effects of Human Exposures Inhalation of crystalline silica initially causes respiratory irritation and an inflammatory reaction in the lungs (e.g., Vallyathan et al., 1995). Acute exposures to high concentrations cause cough, shortness of breath, and pulmonary alveolar lipoproteinosis (acute silicosis). After chronic but lower workplace exposures to silica for six to sixteen years, the small airways become obstructed as measured by pulmonary function tests (e.g., decreased FEV1) in granite quarry workers (no measurement of silica levels reported; Chia et al., 1992). In a report on the hazards of exposure to crystalline silica, the American Thoracic Society (1997) stated: "Studies from many different work environments suggest that exposure to working environments contaminated by silica at dust levels that appear not to cause roentgenographically visible simple silicosis can cause chronic airflow limitation and/or mucus hypersecretion and/or pathologic emphysema." Hnizdo and Vallyathan (2003) also concluded that "chronic levels of silica dust that do not cause disabling silicosis may cause the development of chronic bronchitis, emphysema, and/or small airways disease that can lead to airflow obstruction, even in the absence of radiological silicosis." Fibrotic lesions associated with crystalline silica have also been found at autopsy in the lungs of granite workers who lacked radiological evidence of silicosis (Craighead and Vallyathan, 1980). Silicosis results from chronic exposure; it is characterized by the presence of histologically unique silicotic nodules and by fibrotic scarring of the lung. The histological progression of silicosis has been described as: (1) granuloma composed of histiocytic cells, collagen, and lymphocytes; (2) cellular fibrotic nodule with irregular collagen at the center and circular collagen at the periphery; (3) more mature nodule with acellular and avascular center; and (4) late mature nodule composed of dust and collagen including a calcified center (Green and Vallyathan, 1996). Lung diseases other than cancer associated with silica exposure include silicosis, tuberculosis/silicotuberculosis, chronic bronchitis, small airways disease, and emphysema (Oxman et al., 1993; Park et al., 2002; Hnizdo and Vallyathan, 2003; Balmes et al., 2003). Silica exposure has been implicated in autoimmune diseases (rheumatoid arthritis, scleroderma, systemic lupus erythematosus) in gold miners and granite workers (Steenland and Goldsmith, 1995; Parks et al., 1999) and in the causation of kidney disease in some occupations (Goldsmith and Goldsmith, 1993; Stratta et al., 2001), possibly by an immune mechanism. At the cellular level, silica particles are engulfed in the lung by alveolar macrophages (AM). According to the generally assumed pathological model, the AM subsequently release various growth factors and reactive oxygen species (ROS; superoxide anion, hydrogen peroxide, hydroxyl radical) (Lapp and Castranova, 1993; Mossman and Churg, 1998; Ding et al., 2002). ROS and some growth factors (e.g., activator protein -1, platelet activating factor) are inflammatory and attract neutrophils to the site of inflammation, while other factors (fibronectin, 3 Cement and Concrete: Environmental Considerations Cement and concrete are key components of both commercial and residential construction in North America. The cement and concrete industries are huge. There are approximately 210 cement plants in the U.S. and 4,000 to 5,000 ready mix plants (where cement is mixed with aggregate and water to produce concrete). The Portland Cement Association estimates that U.S. cement consumption has averaged between 75 and 90 million tons per year during the last decade, and projects that consumption will exceed 100 million tons per year by 1997. Worldwide, cement production totaled 1.25 billion tons in 1991, according to the U.S. Bureau of Mines. What does this mean in terms of the environment? Are these products good or bad? As builders and designers, should we be looking for alternatives or embracing concrete over competing materials? As with most building issues, the answers are not clear-cut. Concrete and other cementitious materials have both environmental advantages and disadvantages. This article takes a look at how these materials are made, then reviews a number of environmental considerations relating to their production, use, and eventual disposal. Cement and Concrete Production Cement is the key ingredient in concrete products. Comprising roughly 12% of the average residential -grade ready mix concrete, cement is the binding agent that holds sand and other aggregates together in a hard, stone-like mass. Portland cement accounts for about 95% of the cement produced in North America. It was patented in England by Joseph Aspdin in 1824 and named after a quarried stone it resembled from the Isle of Portland. Cement production requires a source of calcium (usually limestone) and a source of silicon (such as clay or sand). Small amounts of bauxite and iron ore are added to provide specific properties. These raw materials are finely ground and mixed, then fed into a rotary cement kiln, which is the largest piece of moving industrial equipment in the world. The kiln is a long, sloping cylinder with zones that get progressively hotter up to about 2700°F (1480°C). The kiln rotates slowly to mix the contents moving through it. In the kiln, the raw materials undergo complex chemical and physical changes required to make them able to react together through hydration. (See illustration, pages 8- 11.) The most common type of cement kiln today (accounting for 70% of plants in the U.S.) is a dry process kiln, in which the ingredients are mixed dry. Many older kilns use the wet process. The first important reaction to occur is the calcining of limestone (calcium carbonate) into lime (calcium oxide) and carbon dioxide, which occurs in the lower -temperature portions of the kiln—up to about 1650°F (900°C). The second reaction is the bonding of calcium oxide and silicates to form dicalcium and tricalcium silicates. Small amounts of tricalcium aluminate and tetracalcium aluminoferrite are also formed. The relative proportions of these four principal compounds determine the key properties of the resultant portland cement and the type classification (Type I, Type II, etc.). These reactions occur at very high temperatures with the ingredients in molten form. As the new compounds cool, they solidify into solid pellet form called clinker. The clinker is then ground to a fine powder, a small amount of gypsum is added, and the finished cement is bagged or shipped bulk to ready mix concrete plants. Concrete is produced by mixing cement with fine aggregate (sand), coarse aggregate (gravel or crushed stone), water, and—often—small amounts of various chemicals called admixtures that control such properties as setting time and plasticity. The process of hardening or setting is actually a chemical reaction called hydration. When water is added to the cement, it forms a slurry or gel that coats the surfaces of the aggregate and fills the voids to form the solid concrete. The properties of concrete are determined by the type of cement used, the additives, and the overall proportions of cement, aggregate, and water. Raw Material Use The raw materials used in cement production are widely available in great quantities. Limestone, marl, and chalk are the most common sources of calcium in cement (converted into lime through calcination). Common sources of silicon include clay, sand, and shale. Certain waste products, such as fly ash, can also be used as a silicon source. The iron and aluminum can be provided as iron ore and bauxite, but recycled metals can also be used. Finally, about 5% of cement by weight is gypsum, a common calcium- and sulfur -based mineral. It takes 3,200 to 3,500 pounds of raw materials to produce one ton (2,000 lbs.) of finished cement, according to the Environmental Research Group at the University of British Colombia (UBC). Table 1 Typical Concrete Mix Typical Concrete Mix Fr ril:�r�_ •:..e1 Sor 34% Cn_.st 4?g% We;1- i t,% The water, sand, and gravel or crushed stone used in concrete production in addition to cement are also abundant (typical proportions of a residential concrete mix are shown in Table 1). With all of these raw materials, the distance and quality of the sources have a big impact on transportation energy use, water use for washing, and dust generation. Some aggregates that have been used in concrete production have turned out to be sources of radon gas. The worst problems were when uranium mine tailings were used as concrete aggregate, but some natural stone also emits radon. If concerned, you might want to have the aggregate tested for radon. The use of fly ash from coal-fired power plants is beneficial in two ways: it can help with our solid waste problems, and it reduces overall energy use. While fly ash is sometimes used as a source of silica in cement production, a more common use is in concrete mixture as a substitute for some of the cement. Fly ash, or pozzolan, can readily be substituted for 15% to 35% of the cement in concrete mixes, according to the U.S. EPA. For some applications fly ash content can be up to 70%. Of the 51 million tons of fly ash produced in 1991, 7.7 million tons were used in cement and concrete products, according to figures from the American Coal Ash Association. Thus, fly ash today accounts for about 9% of the cement mix in concrete. Fly ash reacts with any free lime left after the hydration to form calcium silicate hydrate, which is similar to the tricalcium and dicalcium silicates formed in cement curing. Through this process, fly ash increases concrete strength, improves sulfate resistance, decreases permeability, reduces the water ratio required, and improves the pumpability and workability of the concrete. Western coal- fired power plants produce better fly ash for concrete than eastern plants, because of lower sulfur and lower carbon content in the ash. (Ash from incinerators cannot be used.) There are at least a dozen companies providing fly ash to concrete producers. Talk to your concrete supplier and find out if they are willing to add fly ash to the mix. (If your local plant doesn't know where to get the fly ash, a list of companies is available from EBN.) Portland cement with fly ash added is sometimes identified with the letter P after the type number (Type IP). The EPA requires fly ash content in concrete used in buildings that receive federal funding (for information call the EPA Procurement Guidelines Hotline at 703/941-4452). Fly ash is widely used in Europe as a major ingredient in autoclaved cellular concrete (ACC); in the U.S., North American Cellular Concrete is developing this technology (see EBN, ). Other industrial waste products, including blast furnace slag, cinders, and mill scale are sometimes substituted for some of the aggregate in concrete mixes. Even recycled concrete can be crushed into aggregate that can be reused in the concrete mix—though the irregular surface of aggregate so produced is less effective than sand or crushed stone because it takes more cement slurry to fill all the nooks and crannies. In fact, using crushed concrete as an aggregate might be counterproductive by requiring extra cement—by far the most energy -intensive component of concrete. Energy Table 2 Embodied Energy for Cement and Concrete Production Notes: Calculations of energy requirements for cement production based on figures supplied by the Portland Cement Association, 1990 data. Aggregate and hauling energy requirements based on data supplied by PCA and based on the following assumptions: • Cement hauled 50 miles to ready -mix plant • Aggregate hauled 10 miles to plant n Concrete mix hauled 5 miles to building site • Concrete mix: 500 lbs. cement, 1,400 lbs. sand, 2,000 lbs. crushed stone, 260 lbs. water/yard. Energy consumption is the biggest environmental concern with cement and concrete production. Cement production is one of the most energy intensive of all industrial manufacturing processes. Including direct fuel use for mining and transporting raw materials, cement production takes about six million Btus for every ton of cement (Table 2). The average fuel mix for cement production in the United States is shown in Table 3. The industry's heavy reliance on coal leads to especially high emission levels of CO2, nitrous oxide, and sulphur, among other pollutants. A sizeable portion of the electricity used is also generated from coal. The vast majority of the energy consumed in cement production is used for operating the rotary cement kilns. Newer dry -process kilns are more energy efficient than older wet -process kilns, because energy is not required for driving off moisture. In a modern dry -process kiln, a pre -heater is often used to heat the ingredients using waste heat from the exhaust gases of the kiln burners. A dry -process kiln so adapted can use up to 50% less energy than a wet -process kiln, according to UBC researchers. Some other dry -process kilns use a separate combustion vessel in which the calcining process begins before the ingredients move into the rotary kiln—a technique that can have even higher overall efficiency than a kiln with pre -heater. Tn the United States, producing the roughly 80 million tons of cement used in 1992 required about .5 quadrillion Btus or quads (1 quad = 107 Btus). This is roughly .6% of total U.S. energy use, a remarkable amount given the fact that in dollar value, cement represents only about .06% of the gross national product. Thus, cement production is approximately ten times as energy intensive as our economy in general. In some Third World countries, cement production accounts for as much as two-thirds of total energy use, according to the Worldwatch Institute. Table 3 Fuel Use for Cement Production fuel Use for Ccrncrt P(oaucticn While cement manufacturing is extremely energy intensive, the very high temperatures used in a cement kiln have at least one advantage: the potential for burning hazardous waste as a fuel. Waste fuels that can be used in cement kilns include used motor oil, spent solvents, printing inks, paint residues, cleaning fluids, and scrap tires. These can be burned relatively safely because the extremely high temperatures result in very complete combustion with very low pollution emissions. (Municipal solid waste incinerators operate at considerably lower temperatures.) Indeed, for some chemicals thermal destruction in a cement kiln is the safest method of disposal. A single cement kiln can burn more than a million tires a year, according to the Portland Cement Association. Pound for pound, these tires have a higher fuel content than coal, and iron from the steel belts can be used as an ingredient in the cement manufacturing. Waste fuels comprise a significant (and growing) part of the energy mix for cement plants (see Table 3), and the Canadian Portland Cement Association estimates that waste fuel could eventually supply up to 50% of the energy. Energy use for concrete production looks considerably better than it does for cement. That's because the other components of concrete—sand, crushed stone, and water—are much less energy intensive. Including energy for hauling, sand and crushed stone have embodied energy values of about 40,000 and 100,000 Btus per ton, respectively. The cement, representing about 12% of concrete, accounts for 92% of the embodied energy, with sand representing a little under 2% and crushed stone just under 6% (see Table 2). Use of fly ash in concrete already saves about 44 trillion Btus (.04 quads) of energy annually in the U.S. Increasing the rate of fly ash substitution from 9% to 25% would save an additional 75 trillion Btus. CO 2 Emissions Table 4 CO2 Emissions from Cement and Concrete Production CO; trt micro horn Carrell and Cor:,c o P,odl.=dlort There are two very different sources of carbon dioxide emissions during cement production. Combustion of fossil fuels to operate the rotary kiln is the largest source: approximately /a tons of CO2 per ton of cement. But the chemical process of calcining limestone into lime in the cement kiln also produces CO2: CaCO 3 ' CaO + CO 2 limestone ' lime + carbon dioxide This chemical process is responsible for roughly 1/2 ton of CO2 per ton of cement, according to researchers at Oak Ridge National Laboratory. Combining these two sources, for every ton of cement produced, 1.25 tons of CO2 is released into the atmosphere (Table 4). In the United States, cement production accounts for approximately 100 million tons of CO2 emissions, or just under 2% of our total human -generated CO2. Worldwide, cement production now accounts for more than 1.6 billion tons of CO2- o ve r 8% of total CO2 emissions from all human activities. The most significant way to reduce CO2 emissions is improving the energy efficiency of the cement kiln operation. Indeed, dramatic reductions in energy use have been realized in recent decades, as discussed above. Switching to lower -CO2 fuels such as natural gas and agricultural waste (peanut hulls, etc.) can also reduce emissions. Another strategy, which addresses the CO2 emissions from calcining limestone, is to use waste lime from other industries in the kiln. Substitution of fly ash for some of the cement in concrete can have a very large effect. Other Air Emissions Besides CO2, both cement and concrete production generate considerable quantities of air -pollutant emissions. Dust is usually the most visible of these pollutants. The U.S. EPA (cited by UBC researchers) estimates total particulate (dust) emissions of 360 pounds per ton of cement produced, the majority of which is from the cement kiln. Other sources of dust from cement production are handling raw materials, grinding cement clinker, and packaging or loading finished cement, which is ground to a very fine powder—particles as small as `/25.D00 of an inch. The best way to deal with the dust generated in cement manufacturing would be to collect it and put it back into the process. This is done to some extent, using mechanical collectors, electric precipitators, and fabric filters (baghouses). But recycling the dust is difficult, according to UBC researchers; it first has to be treated to reduce its alkalinity. Some cement kiln dust is used for agricultural soil treatments, and the rest (of that collected) is often landfilled on site. There was investigation into the possibility of using cement kiln dust for treatment of acidified lakes in eastern Canada, but rather than simply buffering the low pH of the water, the dust chemically created a potentially harmful salt. In addition to dust produced in cement manufacturing, dust is also generated in concrete production and transport. Common sources are sand and aggregate mining, material transfer, storage (wind erosion from piles), mixer loading, and concrete delivery (dust from unpaved roads). Dust emissions can be controlled through water sprays, enclosures, hoods, curtains, and covered chutes. Other air pollution emissions from cement and concrete production result from fossil fuel burning for process and transportation uses. Air pollutants commonly emitted from cement manufacturing plants include sulfur dioxide (50,) and nitrous oxides (NOX). SO2 emissions (and to a lesser extent S03, sulfuric acid, and hydrogen sulfide) result from sulfur content of both the raw materials and the fuel (especially coal). Strategies to reduce sulfur emissions include use of low -sulfur raw materials, burning low -sulfur coal or other fuels, and collecting the sulfur emissions through state-of-the-art pollution control equipment. Interestingly, lime in the cement kiln acts as a scrubber and absorbs some sulfur. Nitrous oxide emissions are influenced by fuel type and combustion conditions (including flame temperature, burner type, and material/exhaust gas retention in the burning zone of the kiln). Strategies to reduce nitrogen emissions include altering the burner design, modifying kiln and pre- calciner operation, using alternate fuels, and adding ammonia or urea to the process. The cement industry claims to have reduced overall pollution emissions by 90% in the last 20 years. Water Pollution Another environmental issue with cement and concrete production is water pollution. The concern is the greatest at the concrete production phase. "Wash-out water with high pH is the number one environmental issue for the ready mix concrete industry," according to Richard Morris of the National Ready Mix Concrete Association. Water use varies greatly at different plants, but Environment Canada estimates water use at batching plants at about 500 gallons per truck per day, and the :Ikalmity levels o lavas wa=e. ca b� as high as pH 12. Highly alkaline water is toxic to fish and other aquatic life. Environment Canada has found that rainbow trout exposed to portland cement concentrations of 300, 500, and 1,000 milligrams/liter have 50% mortality times (the time required for 50% of the population in test samples to be killed) of 68, 45, and 29 minutes, respectively. At the batch plant, washwater from equipment cleaning is often discharged into settling ponds where the solids can settle out. Most plants are required to have process water discharge permits from state, federal, or provincial environment& agencies to dispose of wastewater from these settling ponds. As long as the pH of this wastewater is lower than 12.5, it is not considered a hazardous material by U.S. law. Some returned concrete also gets put into settling ponds to wash off and recover the aggregate. On the positive side, many newer ready mix plants have greatly reduced water use in recent years because of both wastewater disposal issues and drought conditions in some parts of the country. "More companies are going to completely closed-loop systems," according to Terek Kahn of the National Ready Mix Concrete Association. Despite the apparent significance of the wastewater concern, the National Ready Mix Concrete Association to date has not developed standards for member companies on wastewater treatment, including rinsing of trucks and chutes at the building site. John Mullarchy of the association says that procedures are developed on a company -by -company basis. In many areas, environmental regulations dictate procedures relative to wastewater treatment. In more urban areas, the on-site rinse water (for chutes) often has to be collected and treated or disposed of at the plant. Solid Waste While the cement and concrete industries can help reduce some of our solid waste problems (burning hazardous waste as cement kiln fuel and using fly ash in concrete mixtures, for example), one cannot overlook the fact that concrete is the largest and most visible component of construction and demolition (C&D) waste. According to estimates presented in the AIA Environmental Resource Guide, concrete accounts for up to 67% by weight of C&D waste (53% by volume), with only 5% currently recycled. Of the concrete that is recycled, most is used as a highway substrate or as clean fill around buildings. As more landfills close, including specialized C&D facilities, concrete disposal costs will increase and more concrete demolition debris will be reprocessed into roadbed aggregate and other such uses. Concrete waste is also created in new construction. Partial truckloads of concrete have long been a disposal problem. Ready mix plants have come up with many innovative solutions through the years to avoid creating waste—such as using return loads to produce concrete retaining wall blocks or highway dividers, or washing the unset concrete to recover the coarse aggregate for reuse. But recently, there have been some dramatic advances in concrete technology that are greatly reducing this waste. Concrete admixtures are available that retard the setting of concrete so effectively that a partial load can be brought back to the ready mix plant and held overnight or even over a weekend—then reactivated for use. When it is possible to use pre -cast concrete components instead of poured concrete, doing so may offer advantages in terms of waste generation. Material quantities can be estimated more precisely and excess material can be utilized. Plus, by carefully controlling conditions during manufacture of pre -cast concrete products, higher strengths can be achieved using less material. The Superior Wall foundation system, for example, uses only about a third as much concrete as the typical poured concrete wall it replaces. Waste water run-off can also be more carefully controlled at centralized pre -cast concrete facilities than on jobsites. Another interesting trend that relates to waste minimization is the idea of producing reuseable concrete masonry units. The National Concrete Masonry Association has been working on interlocking blocks called FormwalITM, designed specifically so that they can be reused. While these blocks are not yet on the market, this type of thinking is a big step forward. Health Concerns Working with wet concrete requires a number of precautions, primarily to protect your skin from the high alkalinity. Rubber gloves and boots are typically all that is required to provide protection. Cement dermatitis, though relatively uncommon, occasionally occurs among workers in the concrete industry who fail to wear the proper protective clothing. Once it has hardened, concrete is generally very safe. Traditionally, it has been one of the most inert of our building materials and, thus, very appropriate for chemically sensitive individuals. As concrete production has become higher -tech, however, that is changing. A number of chemicals are now commonly added to concrete to control setting time, plasticity, pumpability, water content, freeze -thaw resistance, strength, and color. Most concrete retarders are relatively innocuous sucrose- (sugar-) based chemicals, added in proportions of .03% to .15%. Workability agents or superplasticizers can include such chemicals as sulfonated melamine -formaldehyde and sulphonated napthalene formaldehyde condensates. Air -entraining admixtures function by incorporating air into the concrete to provide resistance to damage from freeze -thaw cycles and to improve workability. These are usually added to the cement and identified with the letter A after the type (Type IA). These materials can include various types of inorganic salts (salts of wood resins and salts of sulphonated lignin, for example), along with more questionable chemicals such as alkyl benzene sulphonates and methyl -ester -derived cocamide diethanolamine. Fungicides, germicides, and insecticides are also added to some concrete. Because of these chemical admixtures, today's concrete could conceivably offgas small quantities of formaldehydes and other chemicals into the indoor air. Unfortunately, it is difficult to find out from the manufacturers the actual chemicals in these admixtures. For chemically sensitive clients, it may be advisable to specify concrete with a bare minimum of admixtures, or use a sealer on the finished concrete to minimize offgassing. Asphalt -impregnated expansion joint filler, curing agents that are sometimes applied to the surface of concrete slabs to reduce water evaporation, special oils used on concrete forms, and certain sealants used for treating finished concrete slabs and walls can also cause health problems with some chemically sensitive individuals. Finally, concrete floors and walls can cause moisture problems and lead to mold and mildew growth, which cause significant health problems in certain individuals. There are two common sources of moisture: moisture wicking through concrete from the surrounding soil; and moisture from the house that may condense on the cold surface of concrete. To eliminate the former, provide good drainage around a foundation, dampproof or waterproof the outside of the foundation walls before backfilling, provide a layer of crushed stone beneath the slab, and install a polyethylene moisture barrier under the slab (protected from the concrete with a layer of sand if possible). To reduce the likelihood of condensation on concrete surfaces, they should be insulated. In northern climates, installing a layer of rigid foam on the outside of the foundation wall and under the slab will generally keep inner surface of the concrete warm enough that condensation will not occur. With interior foundation insulation, provide a vapor barrier to keep moisture from reaching the concrete surface. In southern climates, protecting against condensation may be more difficult. Summing Up Cement and concrete are vital components in building construction today. Concrete has many environmental advantages, including durability, longevity, heat storage capability, and (in general) chemical inertness. For passive solar applications, concrete's ability to function as a structural element while also providing thermal mass makes it a valuable material. in many situations concrete is superior to other materials such as wood and steel. But cement production is very energy intensive—cement is among the most energy-intensive materials used in the construction industry and a major contributor to CO, in the atmosphere. To minimize environmental impact, therefore, we should try to reduce the quantity of concrete used in buildings, use alternative types of concrete (with fly ash, for example), and use that concrete wisely. STATE OF MISSOURI DEPARTMENT OF NATURAL RESOURCES MISSOURI AIR CONSERVATION COMMISSION PERMIT BOA PERMIT TO CONSTRUCT Under the authority of RSMo 643 and the Federal Clean Air Act the applicant is authorized to construct the air contaminant source(s) described below, in accordance with the laws, rules and conditions as set forth herein. Permit Number: (Tuner: 112007-006 2007-08-047 Project Number: 035-0024 Colyott BackHoe, Dump Truck & Dozer Service Owner's Address: P. O. Box 2348, Ellsinore, MO 63937 Installation Name: Hunter Stone Company Installation Address: Hwy E, Hunter, MO 63937 Location Information: Carter County, S20, T26N, R2E Application for Authority to Construct was made for: The installation of a new rock crushing plant. Rock is processed through 1 crusher(s) and 1 screen(s). The rock crushing plant has a maximum hourly design rate (MHDR) of 150 tons per hour (tph). Best Management Practices will be used to control fugitive emissions from storage piles and haul roads. This review was conducted in accordance with Section (5), Missouri State Rule 10 CSR 10-6.060, Construction Permits Required. ❑ Standard Conditions (on reverse) are applicable to this permit. Standard Conditions (on reverse) and Special Conditions (listed as attachments starting on page 2) are applicable to this permit. NOV 2 0 2007 EFFECTIVE DATE MO 780.1204 (1-03) DI I D OR DESIGNEE MENT OF NATURAL RESOURCES STANDARD CONDITIONS: Permission to construct may be revoked if you fail to begin construction or modification within two years from the effective date of this permit. Permittee should notify the Air Pollution Control Program if construction or modfication is not started within two years after the effective date of this permit, or i donstructioitt ur mouilicaiion is suspended for one year or more. You will be in violation of 10 CSR 10-6.060 if you fail to adhere to the specifications and conditions listed in your application, this permit and the project review. Specifically, all air contaminant control devices shall be operated and maintained as specified in the application, associated plans and specifications. You must notify the Air Pollution Control Program of the anticipated date of start up of this (these) air contaminant source(s). The information must be made available not more than 60 days but at least 30 days in advance of this date. Also, you must notify the Department of Natural Resources Regional Office responsible for the area within which you are located within 15 days after the actual start up of this (these) air contaminant source(s). A copy of this permit and permit review shall be kept at the installation address and shall be made available to Department of Natural Resources' personnel upon request. You may appeal this permit or any of the listed Special Conditions as provided in RSMo 643.075. If you choose to appeal, the Air Pollution Control Program must receive your written declaration within 30 days of receipt of this permit. If you choose not to appeal, this certificate, the project review, your application and associated correspondence constitutes your permit to construct. The permit allows you to construct and operate your air contaminant source(s), but in no way relieves you of your obligation to comply with all applicable provisions of the Missouri Air Conservation Law, regulations of the Missouri Department of Natural Resources and other applicable federal, state and local laws and ordinances. The Department of Natural Resources has established the Outreach and Assistance Center to help in completing future applications or fielding complaints about the permitting process. You are invited to contact them at 1-800-361-4827 or (573) 526-6627, or in writing addressed to Outreach and Assistance Center, P.O. Box 176, Jefferson City, MO 65102-0176. The Air Pollution Control Program invites your questions regarding this air pollution permit. Please contact the Construction Permit Unit at (573) 751-4817. If you prefer to write, please address your correspondence to the Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102-0176, attention Construction Permit Unit. MO 780.1204 (1.03) Page No. Permit No. 2 Project No. 2007-08-047 SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions: The special conditions listed in this permit were included based on the authority granted the Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically 643.075); by the Missouri Rules listed in Title 10, Division 10 of the Codes of State Regulations (specifically 10 CSR 10-6.060); by 10 CSR 10-6.060 paragraph (12)(A)10. "Conditions required by permitting authority"; by 10 CSR 10-6.010 "Ambient Air Quality Standards" and 10 CSR 10-6.060 subsections (5)(D) and (6)(A); and by control measures requested by the applicant, in their permit application, to reduce the amount of air pollutants being emitted, in accordance with 10 CSR 10-6.060 paragraph (6)(E)3. Furthermore, one or more of the Subparts of 40 CFR Part 60, New Source Performance Standards (NSPS), applies to this installation. 1. Best Management Practices Hunter Stone Company shall control fugitive emissions from all of the haul roads and stockpiles at this site by performing Best Management Practices, which include the usage of paving, chemical dust suppressants, or documented watering. These practices are defined in Attachment AA. 2. National Ambient Air Quality Standards (NAAQS) Limitation for Particulate Matter Less Than Ten Microns in Diameter (PM10) A. The operator(s) for Hunter Stone Company's rock crushing plant (035-0024) shall ensure, while operating at this site, that the ambient impact of PM10 at or beyond the nearest property boundary does not exceed 150 pg/m3 in any 24-hour period, in accordance with the Federal NAAQS requirements (40 CFR 50.6). B. To demonstrate compliance, the operator(s) shall maintain a daily record of material processed. Attachment A, Daily Ambient PM10 Impact Tracking Record, or other equivalent form(s), will be used for this purpose. 3. Annual Emission Limit of Particulate Matter Less Than Ten Microns in Diameter (PM10) A. The operator(s) shall ensure that Hunter Stone Company's rock crushing plant emits less than 15 tons of PM10 into the atmosphere in any 12 -month period. B. To demonstrate compliance, the operator(s) shall maintain a daily record of material processed and PM10. Attachment B, Monthly PA Emissions Tracking Record, or other equivalent form(s), will be used for this purpose. 4. Usage of Wet Suppression Control System on Equipment A. Hunter Stone Company shall install and operate wet spray devices to restrict the emission of particulate matter. These wet spray devices must be used to control fugitive emissions whenever these units are in operation. The wet spray devices shall be installed on the following units: 1) The primary crusher (EP01) 2) Screen (EP02) B. Watering may be suspended during periods of freezing conditions, when use of the wet spray devices may damage the equipment. During these conditions, the operator(s) shall adjust the production rate to control fugitive emissions from these units. The operator shall record a brief description of such events in a daily log. 5. Performance Testing for New Source Performance Standards (NSPS) A. Hunter Stone Company shall submit the enclosed testing plan to the Enforcement section of the Air Pollution Control Program for all equipment applicable to NSPS Subpart "000". Hunter Stone Company shall contact the Enforcement section to obtain all requirements for testing, and the plan must be submitted to the Enforcement section at least 30 days prior to the proposed test date. B. Testing must be performed no later than 60 days after achieving the maximum production rate of the process, and in any case no later than 180 days after initial startup. The performance test results shall be submitted to the Enforcement section no later than 30 days after completion of any required testing. 6. Prohibition Against Concurrent Operations Without Further Air Pollution Control Program Review A. The rock crushing plant (035-0024) is prohibited from operating whenever any other plant(s) are located at this site. Page No. 3 Permit No. Project No. 2007-08-047 SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions: 7 Restriction on Process Configuration of Primary Emission Point(s) The maximum hourly design rate of the plant is equal to the sum of the design rate(s) of the primary emission point(s). Hunter Stone Company has designated the following unit(s) as the primary emission point(s) of the rock crushing plant: primary crusher (EP01). Bypassing the primary emission point(s) for processing is prohibited. 8. Restriction on Minimum Distance to Nearest Property Boundary The primary emission point of the rock crushing plant, which is the primary crusher (EP01), shall be located at least 300 feet from the nearest property boundary whenever it is operating at this site. 9. Power Generation No diesel engines or generators shall be operated for any purpose other than powering processing equipment. 10. Record Keeping Requirement The operator(s) shall maintain all records required by this permit for not less than five (5) years and shall make them available immediately to any Missouri Department of Natural Resources' personnel upon request. 11. Reporting Requirement The operator(s) shall report to the Air Pollution Control Program Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, no later than ten (10) days after any exceedances of the limitations imposed by this permit. TECHNICAL REVIEW OF APPLICATION FOR AUTHORITY TO CONSTRUCT PROJECT DESCRIPTION Rock, composed of non-metallic minerals, is drilled/blasted, loaded into haul trucks, and transported to processing. Rock is processed through feeder(s), crusher(s), screen(s). Processing equipment is powered with diesel engine(s). The emission points are listed in the attached spreadsheet summary. This installation is not on the List of Named Installations [10 CSR 10-6.020(3)(B), Table 2]. The installation is located in Carter County, an attainment area for all criteria air pollutants. EMISSIONS EVALUATION Criteria air pollutants will be emitted from this operation. The main air pollutant of concern is PM10. The potential emissions were calculated from the maximum hourly design rate (MHDR) of the equipment, appropriate emission factors, control device efficiencies, and the limiting operating hours at MHDR. The sources of the emission factors and control efficiencies are listed in the section "Permit Documents". In order to avoid having to perform increment analysis, the installation has agreed to hold all of its emissions under de minimis levels so the operation can be considered a de minimis source under 10 CSR 10-6.060 section (5). The rock crushing plant has an annual emission limit of less than 15 tons of PM,o in any 12 -month period. A composite PM10 emission factor was developed for the rock crushing plant. The composite emission factor is incorporated into the monthly record-keeping table, Attachment B. If the conditioned potential emissions of PM10 were above these levels, then the owner would be required to perform increment analysis. 1 Cl/JIC G. GIIUJJwuJ Air Pollutant vunuuu.y Regulatory De Minimis Levels µ.v..., Ff.... yv..., Existing Potential Emissions Existing Actual Emissions (year EIQ) Potential Emissions of the Application *New Installation Conditioned Potential Emission Factor (lb/ton) PM,o 15.0 N/A N/A 27.55 <15 0.0419 SOx 40.0 N/A N/A 4.61 2.42 N/A NOx 40.0 N/A N/A 70.16 36.76 N/A VOC 40.0 N/A N/A 5.73 3.0 N/A CO 100.0 N/A N/A 15.11 7.92 N/A HAPs 10.0/25.0 N/A N/A 0.06 0.03 N/A N/A = Not Applicable PM10 conditioned potential based on limits in permit conditions. Other pollutants proportionately reduced based on PM10 conditioned potential. AMBIENT AIR QUALITY IMPACT ANALYSIS Screening tools were used to evaluate the ambient air impact of the hourly emissions from this operation. The ambient impact was evaluated at a distance of 300 feet to the nearest property boundary. The ambient impact at this site shall not exceed the National Ambient Air Quality Standard (NAAQS) of 150 pg/m3 of PM10 at or beyond the nearest property boundary in any single 24-hour period. The screening tools were used to develop an ambient impact factor for the rock crushing plant. This ambient impact factor is incorporated into the daily record keeping table, Attachment A. For sources agreeing to use Best Management Practices (BMPs), as defined in Attachment AA, haul roads and stockpiles are not modeled with screening tools. Instead, they are addressed as a background level of 20 pg/m3 of PM,o. To ensure conformity with NAAQS, the remaining process emissions are limited to an impact of less than 130 pg/m3 of PM,o at or beyond the nearest property boundary. •A bent Air Quality Impact Analysis of PM,o 24 -Hour Averaging Time 1 QNIG N. m I Ambient Modeled*Background NAAQS Daily Operation Impact Factor Impact (pg/m3) (pg/m3) Production (pglm ton) (pglm) Limit (tons) 1. Solitary 0.0469 130.00 20.00 150.00 2,769 * Background PM10 level of 20.00 pg/m3 from haul roads and stockpiles 4 APPLICABLE REQUIREMENTS The owner is subject to compliance with the following applicable requirements The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping, monitoring, and reporting requirements. • Submission of Emission Data, Emission Fees and Process Information, 10 CSR 10-6 110 • Operating Permits, 10 CSR 10-6.065 • An Operating Permit application is required for this installation within 30 days of equipment startup. • Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin, 10 CSR 10-6.170 • Restriction of Emission of Visible Air Contaminants, 10 CSR 10-6.220 • Restriction of Emission of Odors, 10 CSR 10-3.090 • Restriction of Emission of Particulate Matter From industrial Processes. 10 CSR 10-6.400 • Restriction of Emission of Sulfur Compounds, 10 CSR 10-6.260 • 40 CFR Part 60 Subpart "000", Standards of Performance for Nonmetallic Mineral Processing Plants, of the New Source Performance Standards (NSPS) • The National Emission Standards for Hazardous Air Pollutants (NESHAPs) and the currently promulgated Maximum Achievable Control Technology (MACT) regulations do not apply to the proposed equipment. STAFF RECOMMENDATION On the basis of this review conducted in accordance with Section (5), Missouri State Rule 10 CSR 10-6.060, Construction Permits Required, I recommend this permit be granted with special conditions. Samer AI-Shoukhi Date Environmental Engineer PERMIT DOCUMENTS The following documents are incorporated by reference into this permit: • The Application for Authority to Construct form, designating Colyott BackHoe, Dump Truck & Dozer Service as the owner and operator of the installation. • Environmental Protection Agency (EPA) AP -42, Compilation of Air Pollutant Emission Factors; Volume I, Stationary Point and Area Sources, Fifth Edition. • Noyes Data Corp. book, Orlemann, et al.1983. Fugitive Dust Control. • EPA Factor Information Retrieval (FIRE) Version 6.21. • Spreadsheet calculations of potential -to -emit and ambient impact • Southeast Regional Office Site Survey. • Best Management Practices 5 O c f6 ca Y N V cC �U ITS c E O oN s- d O 0 C M D N O .- N E c a 05 cr) E coco a c +r O cuE C w N z N 1 O O N O N- c ca CO U 0 L O Q N 0_ CO ti O -t O — O (3 10 NUr 2 0 a N (6 Z E U) c O ZU� T ` U (B c N c O L7- .N Q-00 ] (Copy this sheet as needed.) (Month, Day, Year) This sheet covers the period from J � ; Attachment B: Monthly PM10 Emissions Tracking Record Hunter Stone Company, 035-0024 — Rock Crushing Plant Project Number: 2007-08-047 County, CSTR: Carter County (S20, T26N, R2E) Primary Unit Size: 150 tph Distance to Nearest Property Boundary: 300 feet This sheet covers the period from (Copy this sheet as needed.) to (Month, Day, Year) Month Monthly Production (tons) Composite PM10 Emission Factor (lbs/ton) 'Monthly PM10 Emissions (lbs) 2Monthly PM10 Emissions (tons) 312 -Month PM10 Emissions (tons/year) 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 0.0419 Note 1 Note 2: Note 3: The Monthly Emissions (lbs) are calculated by multiplying the Monthly Production (tons) by the Composite Emission Factor (lbs/ton). The Monthly Emissions (tons) are calculated by dividing the Monthly Emissions (lbs by 2,000. The 12 -Month Emissions (tons/year) are a rolling total calculated by adding the Month's Emissions (tons) to the Monthly Emissions (tons) of the previous eleven (11) months. A total of less than 15 tons in any consecutive 12 -month period indicates compliance Attachment AA: BMPs Page 1 of 2 Attachment AA: Best Management Practices (BMPs)- Construction Industry Fugitive Emissions Construction Industry Sites covered by the Interim Relief Policy shall maintain Best Management Control Practices (BMPs) for fugitive emission areas at their installations when in operation. Options for BMPs are at least one of the following: For Haul Roads: 1. Pavement of Road Surfaces — A. The operator(s) may pave all or any portion of the haul roads with materials such as asphalt, concrete, and/or other material(s) after receiving approval from the program. The pavement will be applied in accordance with industry standards for such pavement so as to achieve "Control of Fugitive Emissions'" while the plant is operating. B. Maintenance and/or repair of the road surface will be conducted as necessary to ensure that the physical integrity of the pavement is adequate to achieve control of fugitive emissions from these areas while the plant is operating. C. The operator(s) shall periodically water, wash and/or otherwise clean all of the paved portions of the haul road(s) as necessary to achieve control of fugitive emissions from these areas while the plant is operating. 2. Usage of Chemical Dust Suppressants — A. The operator(s) shall apply a chemical dust suppressant (such as magnesium chloride, calcium chloride, lignosulfonates, etc.) to all the unpaved portions of the haul roads. The suppressant will be applied in accordance with the manufacturer's suggested application rate (if available) and re-applied as necessary to achieve control of fugitive emissions from these areas while the plant is operating. B. The quantities of the chemical dust suppressant shall be applied, re-applied and/or maintained sufficient to achieve control of fugitive emissions from these areas while the plant is operating. C. The operator(s) shall record the time, date and the amount of material applied for each application of the chemical dust suppressant agent on the above areas. The operator(s) shall keep these records with the plant for not less than five (5) years, and the operator(s) shall make these records available to Department of Natural Resources personnel upon request. 3. Usage of Documented Watering — A. The operator(s) shall control the fugitive emissions from all the unpaved portions of the haul roads at the installation by consistently and correctly using the application of a water spray. Documented watering will be applied in accordance with a recommended application rate of 100 gallons per day per 1,000 square feet of unpaved/untreated surface area of haul roads as necessary to achieve control of fugitive emissions from these areas while the plant is operating. For example, the operator(s) shall calculate the total square feet of unpaved vehicle activity area requiring control on any particular day, divide that product by 1,000, and multiply the quotient by 100 gallons for that day. B. The operator(s) shall maintain a log that documents daily water applications. This log shall include, but is not limited to, date and volumes (e.g., number of tanker applications and/or total gallons used) of water application. The log shall also record rationale for not applying water on day(s) the plant is in operation (e.g., meteorological situations, precipitation events, freezing, etc.) C. Meteorological precipitation of any kind, (e.g. a quarter inch or more rainfall, sleet, snow, and/or freeze thaw conditions) which is sufficient in the amount or condition to achieve control of fugitive emissions from these areas while the plant is operating. D. Watering may also be suspended when the ground is frozen, during periods of freezing conditions when watering would be inadvisable for traffic safety reasons, or when there will be no traffic on the roads. The operator(s) shall record a brief description of such events in the same log as the documented watering. E. The operator(s) shall record the date and the amount of water applied for each application on the above areas. The operator(s) shall keep these records with the plant for not less than five (5) years, and the operator(s) shall make these records available to Department of Natural Resources personnel upon request. For purposes of this document. Control of Fugitive Emissions means to control particulate matter that is not collected by a capture system and visible emissions to the extent necessary to prevent violations of the air pollution law or regulation (Note: control of visible emission is not the only factor to consider in protection of ambient air quality.) Attachment AA: BMPs Page 2 of 2 For Vehicle Activity Areas around Open Storage Piles: 1. Pavement of Stockpile Vehicle Activity Surfaces — A. The operator(s) may pave all or any portion of the vehicle activity areas around the storage piles with materials such as asphalt, concrete, and/or other material(s) after receiving approval from the program. The pavement will be applied in accordance with industry standards for such pavement so as to achieve control of fugitive emissions while the plant is operating. B. Maintenance and/or repair of the road surface will be conducted as necessary to ensure that the physical integrity of the pavement is adequate to achieve control of fugitive emissions from these areas while the plant is operating. C. The operator(s) shall periodically water, wash and/or otherwise clean all of the paved portions of the vehicle activity areas around the storage piles as necessary to achieve control of fugitive emissions from these areas while the plant is operating. Usage of Chemical Dust Suppressants — A. The operator(s) shall apply a chemical dust suppressant (such as magnesium chloride, calcium chloride, Iignosulfonates, etc.) to all the vehicle activity areas around the open storage piles. The suppressant will be applied in accordance with the manufacturer's suggested application rate (if available) and re-applied as necessary to achieve control of fugitive emissions from these areas while the plant is operating. B. The quantities of the chemical dust suppressant shall be applied, re-applied and/or maintained sufficient to achieve control of fugitive emissions from these areas while the plant is operating. C. The operator(s) shall record the time, date and the amount of material applied for each application of the chemical dust suppressant agent on the above areas. The operator(s) shall keep these records with the plant for not less than five (5) years, and the operator(s) shall make these records available to Department of Natural Resources personnel upon request. 3. Usage of Documented Watering — A. The operator(s) shall control the fugitive emissions from all the vehicle activity areas around the storage piles at the installation by consistently and correctly using the application of a water spray. Documented watering will be applied in accordance with a recommended application rate of 100 gallons per day per 1,000 square feet of unpaved/untreated surface area of vehicle activity areas around the storage piles as necessary to achieve control of fugitive emissions from these areas while the plant is operating. (Refer to example for documented watering of haul roads.) B. The operator(s) shall maintain a log that documents daily water applications. This log shall include, but is not limited to, date and volumes (e.g., number of tanker applications and/or total gallons used) of water application. The log shall also record rationale for not applying water on day(s) the plant is in operations (e.g., meteorological situations, precipitation events, freezing, etc.) C. Meteorological precipitation of any kind, (e.g. a quarter inch or more rainfall, sleet, snow, and/or freeze thaw conditions) which is sufficient in the amount or condition to achieve control of fugitive emissions from these areas while the plant is operating. D. Watering may also be suspended when the ground is frozen, during periods of freezing conditions when watering would be inadvisable for traffic safety reasons, or when there will be no traffic on the roads. The operator(s) shall record a brief description of such events in the same log as the documented watering. E. The operator(s) shall record the date and the amount of water applied for each application on the above areas. The operator(s) shall keep these records with the plant for not less than five (5) years, and the operator(s) shall make these records available to Department of Natural Resources personnel upon request. Mr. Brad Colyott Owner Colyott BackHoe, Dump Truck & Dozer Service P. O. Box 2348 Ellsinore, MO 63937 RE: New Source Review Permit - Project Number: 2007-08-047 Dear Mr. Colyott: Enclosed with this letter is your New Source Review permit. Please review your permit carefully and note the special conditions, if any, and the requirements in your permit. Operation in accordance with the conditions and requirements in your permit, the New Source Review application submitted for project 2007-08-047 and your operating permit. if required, is necessary for continued compliance. Please review your operating permit, as it will contain all applicable requirements for your rock -crushing plant, including any special conditions from your New Source Review permit.. The section of the permit entitled "Technical Review of Application for Authority to Construct" should not be separated from the main portion of your permit. The entire permit must be retained in your files. The reverse side of your permit certificate has important information concerning standard permit conditions and your rights and obligations under the laws and regulations of the State of Missouri. If you have any questions regarding this permit, please do not hesitate to contact Samer Al-Shouki at the department's Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102 or (573) 751-4817. Thank you for your attention to this matter. Sincerely, AIR POLLUTION CONTROL PROGRAM Kendall B. Hale, P.E. New Source Review Unit Chief KBH:sal Enclosures c: Southeast Regional Office PAMS File: 2007-08-047 Permit Number: Leaching Characteristics of Asphalt Road Waste CITATION: T. G. Townsend. , HMAT, HOT MIX ASPHALT TECHNOLOGY, Vol. 3, No. 4, ABSTRACT: A proposed alternative for the management of reclaimed asphalt pavement (RAP) is use as fill material. However, two different types of environmental concerns relate to leaching of pollutants from RAP. The first is that the leachate produced when rainfall infiltrates RAP stockpiles could potentially be contaminated with trace amounts of organic compounds or heavy metals. A second environmental concern is that RAP used a fill material could potentially leach off contaminants when rainfall infiltrates the waste (unsaturated condition) or when used as fill below the water table (saturated condition). In both situations, the leachate produced could potentially be contaminated with trace amounts of the hazardous chemicals. Thus, a series of leaching tests were performed in Florida at both batch -scale and in leaching columns. The primary chemicals investigated were volatile organic compounds (VOCs), polycyclic aromatic hydrocarbons (PAHs), and heavy metals. Results were consistent with previous studies showing that organic compounds do not leach from typical RAP. Heavy metals are sometimes encountered. The literature indicated the presence of chromium, lead, and barium; however, only lead was detected in this study and was ascribed to prolonged exposure to traffic and vehicle emissions. June .14 h, ?0•1 1 Reigniting Organic Attack by Corporate Agribusiness Interests CORNUCOPIA, WIS: When The Cornucopia Institute, a farm policy research group, officially launched in April 2004, one of its primary issue areas was what it referred to as "The Corporate Attack on Organic Agriculture." At the time, Cornucopia's focus was on the father and son team of Dennis and Alex Avery at the ultra- . conservative Hudson Institute's campaign to discredit organics. Now, in 201 1 , after seven years of successfully exposing the genesis of Hudson's ire, and greatly diminishing its effectiveness, a new generation of "Trojan horse" naysayers has emerged. The latest attacks come from Mischa Popoff, a Canadian who purports to be an advocate for organics and is publicizing his self - published book entitled Is /t Organic? The author misses few opportunities to impugn the integrity of the organic label, or USDA oversight, while simultaneously defending biotechnology and the industrial agriculture system that organics seeks to replace. "Addressing the potential damage from attacks by the Hudson Institute, and other right-wing think tanks such as the Hoover Institution, the Heartland Institute, and the Competitive Enterprise Institute, was relatively easy," said Mark A. Kastel, Codirector at the Wisconsin -based Cornucopia Institute. "Every rebuttal that we published, or preemptive media advisory we issued, was put into context by including the corporate agribusiness funding base for the work of these entities." Like the Averys, Popoff is a conservative ideologue, a global warming denier, an ardent critic of hybrid automobiles, and has suggested that the American mortgage crisis that precipitated the financial meltdown was caused by "overregulation." His book sold on his website is subtitled: The Inside Story of Who Destroyed the Organic Industry, Turned /t into a Socialist Movement and Made Million.$ in the Process, and a Comprehensive History of Farming, Warfare and Western Civilization from 1645 to the Present. "Popoff calling the $30 billion organic industry a `socialist movement,"" says Cornucopia's Kastel, "is akin to the fascist leaders in Germany, during the 1 920s and '30s, referring to their movement as the National Socialist party. It's Orwellian doublespeak. Nowhere in the food industry have entrepreneurs and investors realized greater financial reward, with virtually no governmental funding, than in meeting the higher standards consumers are seeking by paying a premium for organic food." Popoff acted as an organic inspector a number of years ago. He now challenges the propriety of organic accreditation and third - party certification by suggesting, echoing the Averys at Hudson, that "There is currently Tittle proof of actual cleanliness, nutrition and fair play in the jlobal organic industry." Popoff's unsubstantiated claim is that b0-90% of organic food in North America is fraudulent and imported. That's not to say that Cornucopia doesn't share some of Popoff's concerns. Popoff suggests chat the entire certification process is without merit and should be replaced with a testing protocol for prohibited toxic chemicals. "We think there is great merit in doing spot testing, as Congress required, and we have criticized the USDA for not having implemented testing until now, but it would be prohibitively expensive to test all farms and crops and would not substitute for other careful oversight protocols," said Will Fantle, Research Director at The Cornucopia Institute. The USDA's National Organic Program, sensitive to the need for spot tests, is currently soliciting public comments on a new federal rule outlining the periodic residue testing of organically produced agricultural products. The proposal calls upon independent organic certifiers to conduct more surprise inspections of organic operations. Cornucopia, in its role as an organic industry watchdog, along with many other organic advocacy groups, supports the proposed new regulation recently published in the Federal Register (available for public comment until June 28). "This is a scheme similar to how the Internal Revenue Service conducts audits," added Fantle. "Strategically conducted tests, and aggressive prosecution if willful violations are discovered, will surely act as a powerful deterrent. I will add that there is no documentary evidence to believe that widespread fraud is currently occurring in the organic industry." It appears that Popoff pins his credibility to his role as an insider and organic supporter. But even that is open to debate as he hasn't actually done any organic inspection_ in years and has been inappropriately identifying himself as an "International Organic Inspectors Association (IOIA) Advanced Inspector." The Executive Director of IOTA, Margaret Scoles, says that she often gets calls and messages from people who are confused by Popoff's claimed credentials. "A recent rnessage I received was signed, 'Mischa Popoff, IOIA Advanced Organic Farm and Process Inspector'," says Scoles. "I was surprised," she adds. "In 2008, I asked him to discontinue using the term because there is no such thing [Advanced Inspector]. He just made up the title. We asked him not to use the IOTA name in any way to imply membership status with our association, but his continued use of our name on his website and in his emails still causes confusion." Popoff was an Inspector member of101A between 1 998 and 2004, Scoles notes. But "he has never worked for us and has no affiliation with i01A." Popoff's political ideology comes through strong and clear in some of his writings (Click here to view a sampling) and statements; his other website also exposes ultra -conservative views. In addition to his suggesting that organics is some kind of socialist construct he has stated that, "Liberals destroy agriculture in B.C. [British Columbia]" and suggested that the liberal American financier George Soros is somehow financing an organic "bureaucracy" instead of substantive oversight. "Mr. Popoff's contention that the organic industry has some kind of socialist/Iibera.l agenda is a gross misnomer," stated Kastel. "Support for organics cuts across all demographics with liberals and conservative suburban consumers, urbanites and rural farmers ranging from cireadlocked hippies to conservative Christians, Mennonites and the Amish." Like the Averys at the Hudson Institute he's also attacked The Cornucopia Institute, suggesting that they have partnered with Soros and claiming that the organization's largest funder is the farmer -owned cooperative Organic Valley (another one of Popoff's targets in his book). "Because Organic Valley CEO George Siemen doesn't back his thesis to switch all organic oversight exclusively to testing he attacked Siemen and now is going after Cornucopia," said Kastel. "Interestingly, Popoff has also promoted a testing business that would directly benefit from this recommended approach." Kastel and Siemen are in good company. Popoff's book also attacks Deputy USDA Secretary Kathleen Merrigan, a well-known organic supporter, and Michael Pollan, the New York Times journalist and author of the bestseller The Omnivore's Dilemma. "By trying to tie all of his favorite villains together Ivlr. Popoff discredits himself, and leaves all of his statements open to question," noted Kastel. "Not only is Organic Valley not our largest funder, we do not receive any financial support from the cooperative, or from Mr. Soros, and fully stand by our independence as an organic industry watchdog," Fantle affirmed. Almost no element in the organic farming movement has been spared attacks on its credibility by Popoff. One of the certifiers impugned, OCIA International, responded to what they referred to as "false statements about our organization and organic certification in general." "We would like to set the record straight. On a YouTube video Mr. Popoff states that there are no unannounced inspections performed on certified organic farms. This is untrue and is covered in the NOP Final Rule and also in the OCIA Standards." The USDA organic regulatory language includes: Additional inspections may be announced or unannounced at the discretion of the certifying agent or as required by the Administrator or State organic program's governing State official. And the contract OCIA, one of the original nonprofit certifiers predating the USDA, has with Mr. Popoff's claims to the contrary just don't its farmers and processors reads: The inspector shall have the right to make un announc eel visits, take samples, and require residue tes tS. "We take our responsibility to follow up on any questionable activities in organics very seriously," said OCTA President Peggy Lin%meier. "Mr. Popoff's fictitious stories, challenging the credibility of the organic label, are injurious to all the farmers and organizations in this industry that are acting with high integrity." Although his material has primarily appeared on what has been referred to as the "echo chamber" of conservative websites, Popoff has developed an extensive database of e-mail addresses in the organic industry. "Either he's had tremendous financial support in his data mining efforts or he's personally invested countless hours in developing this electronic mailing list," stated Fantle. "If it weren't for this level of outreach, we would probably entirely ignore his rantings, which all too often grossly distort the facts." Research indicating organics' nutritional superiority, and demonstrably lower level of exposure to agrichemicals, antibiotics and hormones, can be found on Cornucopia's website or that of the Organic Center. "Whether it is research conducted by the USDA, Consumers Union, publisher of Consumer Reports Magazine, or numerous peer- reviewed journals, there is considerable scientific back-up for the faith consumers have in the ethical approach organic farmers have taken," added l<astel. " hold water." CORNUCOPIA rl s _ T a T E Mischa Popoff: Backgrounder Dear Organic community stakeholders: Please resist the temptation to surf through Mr. Popoffs two websites (one promoting his book and the other promoting his conservative political views). Visiting his sites will only elevate them on Google and other search engines. We hesitated "outing" his ideologically driven attack on organics because this will undoubtedly raise his profile somewhat. But his broad distribution of the unfounded allegations he's made (of widespread fraud and 80-90% organic products being imported) warranted a response. Right now, when searching the word "Popoff," he makes his first appearance in the Google search report on page 6 (a commentary carried on a politically conservative Canadian website) and his own political site does not appear until page 9 (his organic site falls in somewhere after that). There is a common Latin axiom, used in the law. that goes, "Falsus 111 uno,.falsus in omnibus." False in one, false in all. Attorneys know that if you can prove a witness Tied on the stand, in even a minor way, that his or her credibility will be tainted in the eyes of the jury. We have collected a few snippets of Mr. Popoffs writings (please see below) so hopefully you, the jury, can come to some conclusions about his approach to accuracy, and his willingness to risk injuring the reputation of the organic label in an attempt to advance his own agenda, without helping him by purchasing his self -published book or elevating his presence on the web. We have taken the liberty of highlighting in yellow some of the key points in his writing, and our observations have been included in red text. Will Fantle Research Director The Cornucopia Institute In Conclusion... Being organic is no longer about farming fields. It's about filling forms. Your taxes underwrite this marketing subterfuge and help drive a stake into the heart of the most efficient food system ever known [defending conventional/industrial agriculture]. Who's behind this? You'll be surprised. Is it ORGANIC? Mischa Popoff ..wMt.i.l,«r.ay..ai.1hrr,.,.. NH A<..lq rh-n.,v h. dI.r.cnrr ...t..rAnd N'�.LTn c..tn." 1..0. tv rmn t Organic farming began in England as a Christian movement. Organic farmers in the United States and Canada overwhelmingly identify as conservatives, and until 1997 their industry actually had a sound scientific basis, subject to free-market rules with no government interference. But you'll never hear about that from the pro -organic media, or about the key role Presidents H.W. and G.W. Bush played in vaulting organics from hippie movement to multi -billion -dollar industry. [The organic movement has always transcended political labels and certainly religious orientation.] Is it Organic? is a tell -all history by an industry insider who saw too much to keep quiet. Organics can get back to basics by producing food using age-old methods Tike natural composting, or it can be ruled by banality, fraud and eco -politics. KC Active (US): Hook, line and sticker by Beck Ireland The higher prices levied on food and drink carrying an organic label can cause sticker shock in many consumers. However, an increasing appetite for fruits and vegetables free of toxic pesticides and synthetic fertilizer has recently transformed organic farming into a $30 -billion - dollar -a -year industry. Yet, for the last 14 years, no organic farm in the United States or Canada has been subjected to systematic and unannounced field testing. "You're flipping a coin every time you pay a premium for organic food at a store," says Mischa Popoff, an advanced organic inspector with the International Organic Inspectors Association and author of Is It Organic?: The Inside Story of Who Destroyed the Organic Industry, Turned It into a Socialist Movement and Made Millions in the Process. According to Popoff, many of the foods labeled organic could contain substances prohibited by the Organic Materials Review Institute, such as toxic pesticides and fungicides. "Even the most educated consumer has no idea what's really going on with any of their food," he says. Although spot testing for pesticides has been required by law since 1990, it hasn't been systematically carried out. In 1997, according to Popoff, President Bill Clinton and the America Consumers Union considered adding a more stringent field test requirement to the U.S. Department of Agriculture's National Organic Program. However, lobbying interests "watered down" the wording. "They turned it into a glorified marketing system," Popoff says. "It's based on the honor of all the people involved—all the people on the farm all the way up to the retail. If they're all honorable, it works, but then why do you even need a certification system if it's just going to be honor -based?" ...This should come as good news to organic proponents such as Popoff. However, only domestic organic farmers, who make up just 15 percent of the domestic market for organic food in the US and Canada, will be subjected to tests on their crops. Foreign organic operations, which provide 85 percent of the organic produce to the market in the US and Canada, will remain untested. ..."The certified farms are paying for bureaucracy, and it's subsidized by your taxes," Popoff says.... None of the money stays with the farmer. It all goes into the hands of the certifiers, and they use it to build their bureaucracy and lobbying." More information about Is it Organic?: The Inside Story of Who Destroyed the Organic Industry, Turned It into a Socialist Movement and Made Millions in the Process can be found at www.isitorganic.ca . National Post (Canada) Mischa Popoff: Beware of Organic Crusaders From field to fork, organic food isn't just trendy – it's big business. The combined market in Canada and the United States is estimated at $30 -billion a year. Touted as healthier, tastier, and more "authentic" than conventional agricultural products, organic fare has become a must - stock in vegetable aisles, meat counters and menus across the nation. Yet most consumers likely have no idea that the organic heirloom tomato salad they ingest at their local bistro cannot be guaranteed "pesticide -free." Nor are they aware that organic farming has morphed into a political crusade, attacking farmers' use of everything from fossil fuels to synthetic fertilizer, and even modern, disease -resistant seed varieties [once again defending conventional agriculture, synthetic inputs and genetic engineering] all the while resisting routine testing of organic produce. I am an ardent proponent of organic farming [this juxtaposition is why we call Mr. Popoff a wolf in organic sheep's clothing]. I grew up on an organic farm, and worked for five years as an advanced organic farm and process inspector in the United States and Canada. Based on this experience, I firmly believe that farming is still 100 percent organic even when it adapts to changing times. The main goal of organics is to avoid toxins that end up in our food and the environment. But unless every organic operation is tested at least once a year, these regulations are meaningless. For those who raise the issue of cost, they should know that a test for more than 200 commonly used toxic herbicides can be purchased for only $150. Farmers pay on average 10 times that sum just to have their paperwork examined. [It's preposterous to think that samples can be taken by independent inspectors, addressing the broad array of synthetic pesticides, herbicides, fungicides and synthetic fertilizers and drugs, and diversified crops and livestock, for $150. Furthermore, the average farm inspection is nowhere near $1500.] In addition to their resistance to testing, organic activists have also become resistant to the use of modern seed varieties, thus imperiling the very sustainability of our food supply. They are not merely rejecting genetically modified seed, but seeds that have simply been bred to protect a crop against common threats like rust, fungus and mildew, which can wipe out a field as thoroughly as any hail storm. [We know of no prohibitions in organics against any hybrid or open pollinated seed varieties other than those that are produced through genetic engineering.] The gross assumption on the part of urban organic activists -many of whore have never worked a day on a farm -is that old varieties are superior because they were bred in an era when pesticides and synthetic fertilizers did not exist, and they therefore must possess natural pest resistance and the ability to seek nutrients deeper in the soil. This fanciful thinking has never been researched. Such seed varieties were abandoned long ago precisely because they were not as resistant as modern varieties. But the activists cling to their mantra: If it's old seed, it's good seed. They browbeat organic farmers into use old seed varieties that no one knows much about, all in the name of rejecting everything modern. [Baseless hyperbole] ... American April 09, 2011 Warmists and the Organic Farming Activists By Mischa Popoff Organic farming creates more CO2 (which is a good thing, of course). So why do urban organic activists pretend it's the other way 'round? Urban organic activists begin every argument by pining for the good ol' days. They point out that in 1940 one calorie of fossil -fuel energy produced two calories of food. But now, due to the dreaded effects of industrialization, 20 calories of fossil -fuel energy are required per calorie of food. And this, for them, illustrates why an immediate transformation of the food biz is required to "save the planet." How? By converting from a fossil -fuel -based food economy to one based instead on sunshine. Case closed! After all, it's a 20 -fold increase, right?[i] Well... turns out it's not. A wise man once said an ordinary mind is incapable of making distinctions. The distinction not being made in this case is that while we're using 20 times the fossil fuel energy, we're certainly not using 20 -times the total energy. Not even close... If only they had ever worked a day on a farm, these "slow," urban activists would appreciate the massive amounts of human and animal labor that used to be required before machines driven by fossil fuels came along. The reason only a single calorie of fossil fuel energy was required to produce two calories of food was that, prior to the mass industrialization during the Second World War, farmers did the rest of the work by hand and by back! Far more calories were consumed emitting far more CO2. Otherwise, industrialization would not have made economic sense. Slow food activists will try to tell you that a great deal of today's fossil -fuel consumption results from the transportation of food, and that all food should therefore be procured locally. But transportation turns out to only account for a tiny fraction of energy use. (Were this not the case, greedy capitalists wouldn't ship food over long distances; it's that simple.) It's energy -intensive activities like the plowing of land, harvesting, and the handling and processing of food that account for the lion's share of energy consumption and hence CO2 emissions.[ii] And when our ancestors relied on horses to do this work -- which of course meant fully one-half of their arable land was dedicated to growing crops for feed (something which clearly had both an economic and environmental impact) -- they still expended enormous amounts of human energy. And all that work, human and animal, had a measurable carbon footprint which greatly exceeds the 20 -fold increase in fossil -fuel energy -use that occurred over the last 70 years. How much more exactly? Hold onto your hat. ...They seek to replace evil ol' fossil -fuels with biofuels like ethanol. Instead of burning 20 calories of fossil fuel energy to yield two calories of food as we currently do, in a biofuel food - economy farmers would burn 20 calories of biofuel, and would once again find themselves setting aside half of all their land to grow that fuel... just like their ancestors did to grow feed for their horses. See a pattern here? All you achieve with biofuels is a shift in where the fuel comes from, not in how much is consumed. So much for the sunshine economy! Besides, fossil fuels are sunshine -based as surely as crops are. The sunshine was captured in forests millions of years ago and remains stored in underground reserves in the form of crude oil. Why is today's sunshine any better than yesterday's? Most members of the urban -environmentalist crowd don't have the slightest conception of what they're promoting in taking us back to what they perceive to be the good of days. But the really scary part is that many do. CropLife (US) Organics Industry: Led Astray The corporate approach to organics has undermined locally produced food and put the full force of its marketing message on tearing down biotechnology. By Mischa Popoff March 2011 Editor's Note: Mischa Popoff is an advanced organic inspector based in Canada [this is a false claim Popoff frequently makes], and has been outraged over the hijacking of the organic industry by big corporations. In his new book, Is It Organic?, Popoff provides insight into how the organics movement became an industry that lost its focus and is in danger of losing its identity. Fifteen percent. That's a generous estimate of the sum total of the organic industry that could be considered "legitimate." No, I'm not someone with an interest in the chemical or biotech industries. I'm someone with a vested interest in the organic industry. Fifteen percent is the paltry market share left over for American and Canadian organic farmers after cheap imports fill the shelves. Did you think, like so many Americans, that the organic industry supported local family farms? Silly ... that's what's referred to as propaganda, or rather, public relations. Way back when this industry was still a movement, almost all organic food was domestic. But then something interesting happened on the way to Washington. Ambitious corner health -food store owners realized they could make more money if they imported "organic" food from China, Mexico and Indonesia. Is that stuff really organic? Well, the paperwork says it is. But what do the field tests say? Ahh ... now you're asking the right question. Failing The Test Asking if organic farms and processing facilities are tested should be akin to asking if Olympic athletes are tested. "Well of course they are!" Or so you'd assume. Well, it turns out they're not. Back in 1998, President Bill Clinton listened to the American Consumers Union and required that organic farms and processing facilities be tested at least once a year. Honest organic farmers rejoiced, firm in the belief that the main role of government is to keep things fair for everyone. But the corner health -food store owners lobbied to eliminate field testing from USDA organic standards. Can you say free-for-all? Activists love to blame this on Bush, but it all happened under Clinton. Anything can now be sold as organic as long as the paperwork is completed and exorbitant fees are paid to private certifying companies that only make money when they give their approval. Conveniently, these certifiers all have branch offices over in China. Corner health -food stores quickly grew into huge box stores and ceased doing business domestically 85% of the time. [Random testing is part of the law passed by Congress governing organics. After overt criticism by Cornucopia and many others in the organic community, the Obama USDA is now implementing the program.] Without testing for the very things the organic industry claimed to exclude from food, the industry leaders realized they desperately needed some credibility. They weren't quite sure where to turn until they made the collective decision in 1999 to 'go hard' against a new enemy, an enemy which Clinton had thought might actually be an ally: biotechnology. This is why you never see the words chemical -free or synthetic -fertilizer -free on organic foods. Sure, organic crops aren't supposed to be grown with the aid of chemicals or synthetic fertilizer. But it turns out the best you can do is hope there are no residues in your organic food. There's no guarantee; not even the suggestion that chemical residues are reduced to some sort of an acceptable level. But you do see bold statements like "100% GMO free" proudly displayed on organic labels because genetic engineering has replaced crop protection chemicals and synthetic fertilizer as the arch -nemesis of organics. All About Biotech Now when you read in the news that the CEO's of "organic" corporations like Whole Foods Market, Organic Valley, and Stonvfield Farm are "fuming" over the Obama administration's decision to approve the use of genetically engineered alfalfa, you'll know it has absolutely nothing to do with bringing purer, more nutritious food to market. It's all just PR. These CEOs claim to be concerned about the environment, but they're really just worried because of their own self-imposed, zero tolerance for biotechnology. They made the "100% GMO free" labeling claim their sole raison d'etre, and now have to stick with it no matter what. There's no proof that biotechnology leads to more chemical use on farms (quite the opposite actually) or that it will "threaten the rights of farmers and consumers," or "damage the environment." [There is substantial documentary evidence indicating that the use of herbicides has exploded since the introduction of Monsanto's genetically engineered crops that resist their proprietary Roundup herbicide.] But from a marketing perspective, the prospect of minute quantities of biotech alfalfa cross-pollinating with organic alfalfa undermines the bold claim — the only bold claim — that premium -priced organic foods are always "100% GMO free." The only way organic farmers will suffer is if an organic certifier makes their lives hell when their organic alfalfa fields are within a five -mile radius of a crop of biotech alfalfa. This is why hardly anyone grows organic canola anymore in North America: the for-profit organic certifiers forced organic farmers to stop growing canola so the leaders of the organic industry could then launch legal action against the makers of Roundup Ready, biotech canola; legal action that, ironically enough, organic farmers were then forced to fund through their exorbitant certification fees. Feeling all warm and fuzzy yet? In the meantime, if an organic farmer's crop becomes contaminated by a sprayed chemical, whether through negligence or fraud, or if an "organic" crop over in the People's Republic of China is fraudulently treated every step of the way with synthetic fertilizer, prohibited herbicides, pesticides and fungicides, well ... everything's just fine as long as the paperwork's all in order, the fees are paid, and no one blows the whistle. [This is false and highly objectionable.] But for gosh -sake, don't let genes from a genetically engineered crop get anywhere near an organic crop! It'd wreak havoc with the industry's image. The organic industry claims to provide purer, more nutritious food — for a price — but it doesn't do anything to ensure that's what consumers get. Nothing that is, except for a stupid, self-imposed zero -tolerance on GMO. Painted In A Corner I worked the land with my family back when the organic industry was still just a movement. I then had the honor of working across the U.S. and Canada as an Advanced Organic Farm and Process Inspector and met with hundreds of honest organic farmers who want nothing to do with any of the political activism we're seeing. Never once did I ever see proof that organic food was harmed in any way by biotechnology. On the contrary I met many people who believe, as Bill Clinton did, that organic farming could very well benefit from biotechnology. But millionaire organic activists have painted themselves into a tight corner and have no choice but to continue scaring the crap out of the public when it comes to biotechnology. Now that they're firmly committed to cheap overseas supply, being anti-GMO is all they've got left to hang their hats on. Australia News (Australia) Is it Organic? How would you know? Mischa Popoff So... remind me again... why aren't organic farms ever tested? If you still think the term "certified organic" means that an organic farmer, broker or exporter receives a surprise visit from an organic inspector, or that the food you're paying double or more for was ever field- tested to ensure prohibited substances weren't used, you are mistaken. My new book, Is it Organic? provides the comprehensive history of organics and includes the full story of my decade -plus experience working in the organic industry. We can get back to basics by producing food using age-old, scientifically -proven methods like natural, intensive composting, or we can continue to be dominated by banality, fraud and eco -politics. What do you think we should do? As far as government and urban activists are concerned, farmers, the environment and consumers are mere afterthoughts....Here's an excerpt from Is it Organic?... The Clinton Administration caved in to the desires of millionaire organic activists by mentioning the need for organic testing, then passing the final organic rule only after undermining testing by saying it would "not be routine practice conducted on every operation." Sadly, when the Clinton Administration said that organic field testing "is seen as a useful tool," it turned out to really hang on what the definition of "is" is. Clinton then placed the whole watered-down mess on the back burner and left it for George W. Bush to pass into law. Feel better now? (p. 161) Yes, it's true dear readers, organic farms are never tested anywhere in the world [this is incorrect]. And all of the "organic" food available at your supermarket is certified solely on the basis of paperwork. Try to imagine the Olympics without athletes being tested. Would paperwork ever be accepted as proof that an athlete was clean? Here's more from the book... Those turning tidy profits in the organic biz will try to argue that the true value of organics cannot be proven by science. [This is false. There is a growing body of peer- reviewed scientific literature illustrating the nutritional and safety benefits of eating organically.] How convenient to discover something so vital to human and planetary wellbeing but to also discover that its veracity is essentially and inherently unprovable. As Francis Bacon puts it, "whatever any art fails to attain, they ever set it down upon the authority of that art itself as impossible of attainment." Convenient indeed; too convenient by far in fact. (p. 556) ...The history of organics traces all the way back to 1645 in England and was based on solid science right up until the late 1990s when mysticism, magic and bureaucracy took over. The industry has now become little more than glorified food pornography, promising everything but delivering nothing. Being organic is no longer about farming fields. It's about filling forms, which explains why it continues to grow at the astounding rate of 2.0 percent -per -annum in spite of the recession. And who's behind all of this? You'll be surprised. Mischa Popoff holds a bachelor's degree in history and is an IOIA Advanced Organic Inspector. From: Mischa Popoff [mailto:mischa@isitorganic.ca] Sent: Thursday, April 21, 2011 9:57 AM To: kastel@cornucopia.org Subject: George Soros undermines the organic movement No one epitomizes the huge difference between rural organic -farming and urban organic - activism better than George Soros. 80% of the certified -organic food sold in the United With the openly stated goal of undermining the American economy, Soros supports organizations that are devoted to undermining the North -American food economy, the most efficient food delivery system ever known. Sure, the North -American food economy is far from perfect. But as I travelled across North America inspecting family -run organic farms I learned pretty quickly what honest organic farmers all know intuitively: there's no way we're going to ever replace conventional farming. Improve upon it? You betcha'! But replace it? Never. A few weeks ago I called out Mark Kastel, his Cornucopia Institute, along with George Siemon and his Organic Valley Family of Farms Brand, for pretending to stand up for family organic farmers. They, along with people like Soros, make it their business to attack anyone they don't like in the organic biz. But what do they do to actually help organic farmers? All they really care about is that their political message sells. And that hurts domestic farmers. And anyone who doesn't believe this can try to explain why States every year is imported! How does that help our farmers? Please go to the new page on my website to read more about how some urban activists hurt domestic organic farmers. And, if you're in the mood for a 45 -minute, in-depth radio interview on the subject, please go straight to Carol & Chris's Homegrown Podcast. Mischa Popoff, IOIA Advanced Organic Farm and Process Inspector Author of Is it Organic? The inside story of the organic industry Some people won't like this book, but you will Osoyoos BC Canada From: Mischa Popoff [mailto:mischa@isitorganic.ca] Sent: Tuesday, May 03, 2011 11:54 AM To: kastel@cornucopia.org Subject: Popoff - Organic farming more efficient than conventional, and pigs fly! Okay... now I've heard everything. A new study co-authored by a member of the Faculty of Environmental Studies at York University claims organic farms can be more energy efficient than conventional operations. That's like saying "Hey! I can be a faster runner than Usain Bolt!" In case you don't know, Usain is the fastest man in the world (he's also referred to as Lightning Bolt). So, how the heck can I claim to run faster than him? Well, you see, the key words in my dubious claim are "can be." I mean, sure, if Usain is fast asleep I can be way faster than he is. It all depends on the circumstances. And, until Usain and I have a race, well... my statement stands! So there. This study is a total sham. Really. I mean, how much of my taxes were wasted on this? But, alas this is what happens when people who've never worked a day on a farm and who work at a university located in the downtown core of a large city decide to attack modern farming in a fight against the phantom menace of climate change. As I show in my book, organic farming is less efficient than conventional farming. In most cases, far less so. But that's perfectly fine! There's nothing wrong with burning fossil fuels, especially on a farm! And since when is organic farming supposed to fall into line with every single "green" desire environmentalists have? [Please note, Mr. Popoff is on the record as a climate change skeptic.] We're supposed to produce food that's purer and more nutritious in the organic sector. We rely on time -proven methods that have sustained humankind for thousands of years; so who cares if we burn a bit more diesel? Every organic farmer I know will tell you straight up that he burns more fuel for every bushel he produces compared to his conventional neighbors. And you know what? It doesn't bother him in the least. What bothers organic farmers, young and old, is when they're used as pawns to fight someone else's environmental battle, in this case, the crazy battle against climate change. [Local and organic food might very well have a lower carbon footprint due in part to increased grazing and not using a myriad of petrochemicals in its production.] Attention, anyone working in the environmental department of a university! North -American farmers don't care about climate change! Never did, never will. In case you haven't heard about this study, click here. And if you have, and thought perhaps it might be true, ask yourself why Al Gore never mentions organic farming. It's because he knows organic farming requires more fossil fuel than conventional farming, and it releases more CO2. Too bad the authors of this study don't know what Gore knows. If you haven't heard about my book that debunks this type of malarkey while promoting true, honest, domestic organic farming, please go to my website. For my specific comments on the issue of organics and CO2, just click here. Mischa Popoff, B.A. (Hons.), IOIA Organic Inspector Author of is it Organic? The inside story of the organic industry Some people hate this book, but if you've ever worked on a farm, you'll love it Osoyoos BC Canada www.isitorganic.ca Mischa Popoff website 3-18-11 A Cornucopia of nonsense It's hardly a stretch to assume the public is extremely concerned with things like toxic residues and un -composted fecal matter in their food, especially if they're paying hefty premiums for organic food. But, for some reason, corporations seem to make better targets for organic activists. A relatively new organic lobby group called the Cornucopia institute [established 2004] bills itself as the promoter of "Economic Justice for Family Scale Farming." It's headed by Mark Kastel, a guy who used to work for multi-million dollar "agribusiness giants" before making the "paradigm shift to sustainable farming." It wasn't a huge shift mind you because he now works for a multi-million dollar organo -activist company called Organic Valley Family of Farms Brand, referred to as Organic Valley for short. Confused? Well, you see, it's perfectly simple really; Organic Valley isn't an evil agribusiness giant because it has the words "organic" and "family" in its name. That means it's friendly and sustainable, not evil and profit -driven. Okay? [Organic Valley contributes no funding to Cornucopia and Mr. Kastel has no professional relationship with the organization. He started his career with International Harvester and, like many conventional farmers, switched to organic production after a pesticide -related illness presented his "wake-up" moment almost 30 years ago.] Seriously though, Kastel rails against large corporations doing business in the organic sector for no other reason except that they're large. [Cornucopia's philosophy is that it's corporate watchdogging is, "all about corporate ethics, not corporate scale."] And he pretends to no longer be on Organic Valley's payroll even though they're the single largest contributor to his Cornucopia Institute. Never hurts to have a rich benefactor nowadays, does it? [Again, Organic Valley contributes no funding to Cornucopia and Mr. Kastel has no professional relationship with the organization.] He also fails to explain that the CEO of Organic Valley, a groovy millionaire by the name of George Siemon, "was instrumental in creating the USDA rules, and is working to see that they remain intact." That's right Siemon is one of the many people I expose in my book who has a vested interest in the multi -billion -dollar organic industry, who literally wrote his own federal code, and who now assumes control of that code while big brother watches over pretending to look out for the little people. Such conflict of interest would never be tolerated in the conventional food sector. But, shameless to a fault, Kastel recently came out swinging against Golden Temple granola and Peace Cereal. Why? Because they used to be organic and now they're not. Both processors removed the word "Organic" from their labels and sent letters to all their wholesale and retail customers informing them they were no longer organic, but Kastel wants more. He wants them to do an advertising campaign to inform consumers they're no longer organic. Is he serious? Yup, he is. [Golden Temple/Peace Cereal changed from organic to conventional ingredients, without lowering the price, and without adequately notifying stores, or changing the UPC codes of the products. Many retailers continued to use signage to identify these products as "made with organic ingredients," misinforming consumers. The Cornucopia Institute has proposed to the USDA a regulation that would require full notification and changing the scanning codes when product formulation is changed from organic to conventional.] There are serious problems in the organic industry. Most notably, the fact that organic crops and livestock are not tested. This has led to a situation where over 80 percent of the certified organic food sold is imported from places like China, Indonesia and Mexico, all based on paperwork and the payment of hefty fees. But Kastel doesn't care. Who knows? Maybe his boss likes the current laxity of the organic certification system. Under Siemon's watchful eye, Kastel has been obsessed with one certifying company in particular, Quality Assurance International (QAI), which is a good certifier working consistently within federal standards. [QAI has been involved in some of the largest documented scandals in the organic industry. Cornucopia watchdogs all certifiers but calls QAI, "the corporate certifier of convenience." Their practices, on a number of occasions, had been sanctioned by the USDA but, under the Bush administration, were not penalized.] I should know; I worked for QAI back when I was an IOIA Advanced Organic Farm and Process Inspector. But Siemon and Kastel think QAI is "too corporate." Cornucopia has never shown where QAI has done anything illegal or even untoward. QAI's only crime according to Siemon and Kastel is that they are successful and their clients are large. [Although Cornucopia has publicly criticized QAI, to our knowledge neither Organic Valley nor Mr. Siemen have done so.] Siemon and Kastel also used Cornucopia to attack President Barack Obama's pick of Iowa Democratic Governor Tom Vilsack for Secretary of Agriculture. Siemon and Kastel didn't like the fact that Vilsack had supported genetic engineering and that he had a "close relationship" with agribusiness corporations. [Cornucopia had not criticized Sec. Vilsack until after his decision to legalize the sale of genetically engineered alfalfa, a grave threat to organic production. In fact, we were pleased and surprised at the changes he made to staff at the USDA and the commitment to organics.] Sounds just like any Secretary of Agriculture you care to mention from the last 50 years (and any Minister of Agriculture in Canada). It also sounds a lot like Bill Clinton and Al Gore who both have the exact same views as Vilsack on the need for advanced science in agriculture. But Siemon and Kastel won't dare go after Clinton or Gore; so, instead, Kastel decided to remind Obama of his promise for "change," citing the need to "Clean up Bush's Organic Mess." [Our call to Obama was made prior to Sec. Vilsack's appointment.] This in spite of the fact that the final rules for the USDA's NOP which Siemon and Kastel enthusiastically support were passed during George W. Bush's administration after being written by Clinton's administration. (This is all explained in Chapter 5 of my book.) [Cornucopia's criticism of the Bush administration was for their refusal to enforce the regulations. Although Cornucopia was not in existence during the Clinton administration, it has since criticized the Clinton USDA for "monkeywrenching" the adoption of regulations resulting in a 12 -year delay in implementation.] tried communicating with Kastel about the need to reduce bureaucracy in the organic industry and introduce field testing. His position is that he and his boss defend "the hoops organic farmers have had to jump through," and he stresses that testing cannot substitute for record- keeping and form -filling because, in his mind, "Most alarm systems are never tested by burglars." Can someone tell me just what the hell that's supposed to mean? Organic farmers want field testing, less paperwork and a reduction in the fees they're forced to pay year after year. Why not do something to help them? [Cornucopia supports random testing in addition to farm inspections and audits of record-keeping.] Big Organic players like Siemon are directing minions like Kastel all across the land to lobby Obama for "change" in the food industry, a change which, let's face it, they hope will continue to be completely unscientific. Perhaps Siemon and Kastel never did well in science and math when they were in school and they honestly just don't understand how things like food safety and quality control work. Or... it could be Siemon and Kastel actually did very well in science and math and just don't want food safety and quality control to work, at least not in their racket... I mean sector. So how 'bout it guys? Can we see your college transcripts? There is currently little proof of actual cleanliness, nutrition and fair play in the global organic industry. [There is a growing body of scientific literature, from the USDA, Consumers Union and peer-reviewed publications, illustrating the nutritional and safety advantages of consuming organic food.][It's fast approaching a complete free -for all, and domestic organic farmers suffer as a result. Professional organic lobbyists like Kastel either honestly don't get that, or they don't want to. And that's a total shame. NOTE: After Popoff distributed this manifesto, which is an excerpt from his book, Cornucopia Codirector Will Fantle contacted him requesting a retraction/correction and the removal of this material from his website based on its factual inaccuracy. The material is still posted. Wine K MdOe 4iinvirnramentrAl N ,P;acr ae mvu.BR1•.Dt..org PO Box 88 (;Irnclalc Springs, \ot111 ('amlina 28629 September 3, 2012 Ken Sack Eagle Springs Organic 5454 County Rd 346 Silt, Colorado 8I652 kensack@me.com Dear Mr. Sack: B1 Fi1)1 «'skyIn•st.com 1331115182-2691 i write in response to your request for my professional opinion about the potential impacts of reclaimed asphalt pavement operations on a nearby organic farm. Reclaimed asphalt pavement, or RAP, is produced by the removal, repair and/or reconstruction of existing roadways. In addition to the components of newly manufactured asphalt pavement, RAP includes substances deposited by vehicular use on the roadway including oil, gas, metals and tire compounds. The specific toxic substances included in this mixture include lead, cadmium and polycyclic aromatic hydrocarbons. The two main vectors for environmental contamination by RAP operations are aerial contaminants carried by fine particles on the wind and liquid leachate contaminants transported by rainwater infiltration into the stored RAP. I have located several published articles and EPA documents which point to potential problems from RAP aggregate piles which I will present below. The US Environmental Protection Agency studied aerial pollution from aggregate storage piles in the form of fugitive dust. Emissions are created at three distinct points: I) during loading of materials on the pile. 2) wind currents and 3) during load out from the pile. The study found that "When freshly -processed aggregate is loaded onto a storage pile, its potential for dust emissions is at a maximum:' Dust emissions and fines can be spread over great distances. the smallest several miles or more. Information on liquid highway runoff from the US Geological Survey indicates that there is a pollution risk created by toxic chemicals deposited on roadway surfaces regardless of the pavement type. The impacts of stornnvater runoff from Washington State freeways on aquatic ecosystems was investigated through a series of bioassays utilizing algae, and zooplankton and fish. Algae and zooplankton were adversely affected by the soluble fraction of the runoff, while suspended solids caused high moralities of rainbow trout fry. In addition, BOD5 values similar to those reported in the stormwater literature were 1 Development or Emission Factors fi r Fugitive Dust Sources, United States Environmental Protection Agency Publication No. EPA -450/3-74-037 e55e quant Uibere Pam 2 Sctttcrtthcr,'1.2012 measured; however, there were indications that results were influenced by toxicity to microbial populations.' Further, a study done by the State of Minnesota focused specifically on the problem of water pollution resulting from rainwater deposition and runoff from both asphalt and concrete aggregate piles creating contaminated leachate. The Stockpile Runoff Project addressed environmental concerns regarding the quality of runoff water from salvaged pavement stockpiles. Three experimental stockpiles were studied, one pile consisted of coarse concrete, a second consisted of fine concrete material, and the third consisted of salvaged bituminous material (recycled asphalt product) obtained from a pavement milling project. The leachate water f•oni the piles (lowed through a sampling and flow monitoring system with data loggers and automated sequence samplers. Composite water samples ‘vere analyzed using EPA approved methods and quality control protocols. Comparing the observed median values for the stockpile runoff with Minnesota standards for leachates emanating from stockpiles, the long-term concern reduces to suspended and dissolved solids. and pFl. Polynuclear aromatic hydrocarbons (PAI -I) concentrations from the bituminous millings pile were near of below detectable limits. Planning for stockpile storage sites should include management practices of controlling runoff similar to those that are used for construction sites. Berms, straw bales, grass or other filter channels. and locating stockpile site some distance form surface waters may he appropriate practices. Possible impacts on the groundwater system should be considered.' Bituminous aggregate piles resulting from pavement reclamation created leachate which clearly contained the toxic asphalt contaminant PAH, which is actually a Targe group of toxic compounds. Also, the National Asphalt Pavement Association provides the following information on RAP. This study concludes that groundwater contamination from asphalt toxins could result from the use of the material. Data regarding the composition of leachate from Recycled Asphalt Pavement (RAP) is limited. This paper sing ests that RAP can be used as construction till or in embankments. it has been suggested that heavy metals or polycyclic aromatic hydrocarbons (PAHs) might be present in RAP and may therefore leach from it given the proper circumstances. An investigation performed to address these concerns found that, based on waste management policy in Florida. the RAP tested in this study would result in exceedance of groundwater guidance concentrations of the pollutants studied. 4 Finally, as you know, federal regulations for organic foods require the farmer to notify 2 Portele, G.J., Mar, B.W., Horner. R.R., and Welsh, E.B., 1982.. Effects of Seattle area highway stormwater runoff on aquatic biota: interim Report No. WA -RD -39.1 I.45 p. http://webdinamrl.er.usgs.gov/21/fhwakp‘istateabs.htm 3 Sadecki, R.W., Busacker, G.P., Moxness, K.L., Faruq K.C., and Allen, L.G., 1996, An investigation of water quality in runoff foni stockpiles of salvaged concrete and bituminous paving: Minnesota Department of Transportation Final Report MMR -96/3 I. 112 p. a Leaching Characteristics ofAsphalt Road lVas/e: Timothy G. Townsend, University of Florida, 1998 http://www.wilderconstruction.com/pdfs/MatCon%2oLeachinl%20 Fechnical%20 PaDer. pdt C55c grant Ui0crc CURRICULUM VITAE OF LOUIS A. ZELLER September 4, 2012 1. 1 am currently employed as the Executive Director of the statewide Blue Ridge Environmental Defense League, a non-profit environmental education organization incorporated in the State of North Carolina and other states. For many years I served as the League's science director. 2. in 1975 1 earned an Associate Degree in Allied Health Science from Emory University. I practiced as a Physician Assistant in North Carolina before 1 began my employment with Blue Ridge Environmental Defense League in 1986. 3. Relevant completed college level work includes "Energy and the Environment" (1988) and "Environmental Science" (1987) University of North Carolina—Asheville, "Evidence Law" (2005) and "Winning Strategies for the Courtroom," (2006) "Notary Public" (2008) Wilkes Community College, North Carolina. 4. Relevant in-service training includes: a) Law Seminars International "Energy in the Southeast" (2008) featuring the Commissioner of the Federal Energy Regulatory Commission and public utility commissioners from Alabama, Florida, Georgia and North Carolina. b) US Environmental Protection Agency Region 4 "Learning the Tools to Conduct an Environmental Justice Assessment" (2012). 5. I am the author of Sow the Wind, a report on air pollution from the atomic weapons production plant at Savannah River in South Carolina. available in soft cover from the Blue Ridge Environmental Defense League, (2007) 74 pp. 6. I am the author of Smoke and Mirrors: A Report on Biomass. Bio -energy and Global Warning, available in soft cover from the Blue Ridge Environmental Defense League (2011), 61 pp. 7. 1 wrote the chapter entitled "The Clean Air for Children's Health Campaign" published in Standing Our Ground: Connnlinities Organizing to Stop Dioxin Exposure, published by the Center for Health, Environment and Justice, July 1998 8. 1 wrote the section entitled "Citizens Spotlight Nuke Waste imports: Hot Stuff and Nonsense" published in Synthesis/Regeneration 9—A Magazine of Green Social "Thought, ISSN: 1083-7639, Alternative Press Index, Baltimore, MD, Winter 1996 9. 1 am co-author of the "Minority Report on Fugitive Emissions from Asphalt Plants," for the United States Environmental Protection Agency Office of Air Quality Planning and Standards. Research Triangle Park, NC, Document No. EPA -454-/R-00-030, April 2001 10. 1 am co-author of the Duke University Medical Center poster "Elevated Suicides Among Downwind Residents and a Potential Link to Chemical Releases from Nearby Industries," Weisler RH, et al, June 2005 11. 1 was an invited presenter at the Fourth International Radioecological Conference "Utilization of Plutonium: Problems and Solutions." in Krasnoyarsk, Russia, June 5-10, 2000 12. i have more than 26 years of experience working on a variety of projects for the Blue Ridge Environmental Defense League including but not limited to air and water pollution from fossil - fuel power plants, nuclear waste dumps, nuclear power plants, waste incinerators, paper mills and asphalt plants. 1 of I co DEPARTMENT OF AGRICULTURE 700 Kipling Street, Suite 4000 Lakewood, CO 80215-8000 303-239-4100 ♦ Fax 303-239-4125 www.colorado.gov/ag John T. Salazar, Commissioner Ron P. Carleton, Deputy Commissioner John Hickenlooper Governor July 20, 2012 Mr. Bryan Reed Eagle Springs Organic, LLC 5454A County 346 Silt, CO 81652 Dear Mr. Reed: Upon review of your application and inspection of your crop and livestock operation we are granting continuation of your organic certification according to 7 CFR Part 205, the National Organic Program rule. Enclosed please find a copy of your updated organic certificate. If you have any questions please call me at 303.239.4143. Sincerely, a 1 0 -o, -- Casey Palmer Organic Program Manager Enclosures cc: Becky England, CDA oiazfsZls spnp©ad 40 WnPU@ppV D@S lir© antPa33 IeI;IUI ;IVO A IVS'I9AINNV b]9Wf1N NOLLVJIdiflJ2J sai4S Pawsn 25918 013e1010D `aUS 9f€ P!°J £un©3 visas SIH{DOId Z[OZ 01-50 A3 Livestock (100% organic): eggs, chickens, turkeys sa:e>s Pajun ZS918 OPe3OIOD `41 9$E peal' Cunoj Vi65#15 t J [IDV JTii `,DINVI11 l l l ley r nHJ d — PZJ n z � n n JJJ 4 n WV1190):1d Id ti CROP (and ON Inspector: COLORADO DEPARTMENT OF AGRICULTURE DIVISION OF PLANT INDUSTRY 700 Kipling Street, Suite 4000 Lakewood, Colorado 80215-8000 303-239-4139 -FARM HANDLER) INSPECTION NARRATIVE REPORT COVER SHEET Farm Name: Ot SpR11.1e5 04A-el/C LING Describe your observations for the following categories: • General and Farm Plan Information • History and Eligibility • Seeds • Seedlings and Perennial Stock • Soil and Crop; Fertility Management • Crop Management • Maintenance of Organic Integrity • Record Keeping System • Audit Trail • Recommended Sampling • Other Considerations • Summary • List of Attachments If an On -Farm Handler Plan is needed please include the following categories: • CompanyOverview • Cleaning/Sanitation • Packing, Processing • Post Harvest Materials • Water • Shipping/Storage Containers • Storage • Pest Management • Quality Assurance The information contained in this report is confidential between the inspector, the inspected party and the certification agent. This report does not constitute certification or consultation, nor should it be used for promotional purposes. All compliance assessments are made in reference to the standards and policies of the above-mentioned certification agent, and are based on the inspector's observations, review of documents and operator interview. Inspector Signat Date: 6 rIc2 Farm Inspection Narrative Report Cover Sheet and Guide 1 Revised 3/17/11 Operation: tJ J 5 Qp.pjC inspector: 'Fb6Cti 6uq4Jo Reviewing an Organic Plan Here are some helpful questions to keep in mind when preparing for an organic inspection. A Pre- inspection Review is conducted in order for an inspector to understand what the applicant is saying about his/her operation. Completeness of answers and identification of issues (Organic Control Points) will need to be identified before the inspection and explored further during the inspection if needed. If you need assistance with this OSP or feel you are not qualified to conduct this inspection, please contact us at the office. We are more than happy to provide more training, accompany you on the inspection or/ and assist you in any way we can! 1. Has the operation been previously certified organic or is this a first time application for organic certification? de 1)ycj. 2. What does the applicant want certified? Are the finished product labels for the products, if applicable, found in the plan? If not, which are missing? ° OUS LkGr riea5, WI' ) Whi karcre o 3. A,re directions to the facility/operation provided? 4. What missing documents need to be gathered at time of inspection? Dtoot-'- kg_ S- po -- Ekrz 0P- 0-1-141% aw SA Os I- 5. What potential issues of contamination have you, the inspector, flagged? 6. What potential issues of conarningling have you, the inspector, identified? ° Cooc- hem I veo 1awA-170/410,,,pespuz.-tS 7. What possible violations to the standard have you identified? Site citation. PLEASE NOTE: Keep visits brief, businesslike, and as professional as possible. Addressing issues beyond the scope of an organic inspection (e.g. discussing ways to improve the operation, or asking about chemigation perrnits) adds to the time of the inspection and is not part of the inspector's duties. We have received feedback from our operations regarding these issues in the past Colorado Department of Agriculture Organic Crop Production Inspection Report 0. leration's Name: r ►� ►-to S '_ ' j , Ph; steal Address: 49/ etrkktici i-ICOi Type of Inspection: ❑ New A'plicant Inspector: Continuation Person Interviewed: Ito "Veep Others Present ?or Ispe: bac-64-I J72(/e1k/ Has a Carrel t opy of NOP Standards? Yes ❑ No Date: 5_ rlc9 Time In: /150 Time Out: /02 61) General and Farm Plan Information Has any of the demographic or contact information changed? If yes, list the changes: Yes No Moo 7'0 /6 ❑ Conditions from last inspection NIA List condition(s) and how operation h addressed them: n Verify crops and acreages listed in OSP Describe • changes/discrepancies (if applicable): ❑ All Organic Crops Harvested at time of application Split Total Acres Farmed: /(d7 Owned: ibei, Rented: Acres added this year (should be included in Total farmed): Acres Organic (including fallow) / Acres Conventional, Ei 1 p &sp. Stiction 2: History and Eligibility Is all ground requested for certification eligible? Yes n No (Verify compliant with NOP §205.202 Land Requirements) Comments: NOP Rule §205.202 0 If new acreage is listed, verify Field History Sheet or Land Use Affidavit is found in plan Map(s) accurate and complete? • Describe changes/discrepancies: Section 3: Seeds NOP Rule §205.204 Verify operation consistent with Section 3 of OSP • Describe changes/discrepancies: Are current organic certificates available for all seeds purchased? Yes n No li,.Inspect seed labels n N/A • If non-organic seeds were used - verify reason and required documentation J Comments: • Section 4: Source of Seedlings and Perennial Stock NOP Rule §205,204 n Verify source of organic seedlings Comments r74 NIA Verify operation consistent with Greenhouse part of OSP 0 N/A (no greenhouse) • Describe changes/discrepancies: st4 Verify compliant with §205.206(f) No treated lumber n Verify perennial stock 1r! N/A • If non-organic planting stock was used, then verify reason and required documentation Comments: • If newly planted verify source; if non-organic verify management compliant with §205.204(a)(4) Comments: Page 2 of 11 CDA Organic Crop Inspection Form — Rev 3112 Section A. 5: Soil and Crop; Fertility Management NOP Rule §205.203, 205.205, 1A1 Verify operation consistent with Section 5 of OSP • Describe changes/discrepancies: 205.601, 205.602 Review all fertility inputs Are all products being used listed in the OSP? Yes rf No Are all products used listed on the "Materials Review Sheet"? Yes ❑ No Are all products allowed for use (National List restrictions being followed?)(Yes • Describe changes/discrepancies: ❑ No B. If compost was used, verify compliant with NOP §205.203 (c)(2)(i)(ii) and (iii) [Yes ® No ❑ N/A Letter from compost manufacturer provided? ❑ Yes ❑ No ssK N/A If produced on site, is documentation available? gYes No ❑ N/A Comments: C. If raw manure was use , erify compliant with NOP §205.203 (c)(1)(i), (11) and (iii). ❑ Yes ❑ No N/A Is the 90 day preharvest interval met? ❑ Yes ❑ No N/A Is the 120 day preharvest interval met? ❑ Yes ❑ No N/A Comments: D. Is soil erosion a problem? ❑ Yes VNo ❑ N/A Comments: E. Is water quality a problem? © Yes XNo ❑ N/A Comments: ° 'g) 1) ett,giAn j° -i Th Page 3 of 11 CDA Organic Crop Inspection Form — Rev 3/12 Staotion 6: Crop Management NOP Rule §205.205, 205.206, 205.601, 205.602 Verify operation consistent with Section 6 of OSP. • Describe changes/discrepancies: A. Crop Rotation Is there a crop rotation program compliant with 205.205 Yes ❑ No l l N/A Comments: ( .P&7) Ci p .4' / ! t I4 21- ( i 1k 1 O g& -vi it) -- O1j ("top op le � A No /J1&4o B. Weed Management — NOP Rule 205.206 Is there evident of restricted or prohibited strategies/inputs? n Yes No ❑ NIA Comments: TTT [[[ C. Pest Management — NOP Rule 205.206 Ishere evidence o estrictes or prohibited strategies/inputs? 14 Yes LI No • N/A Comments: 9 4 ►Arra 1►mmim.g1awmI►I~`:jG!!%lero/Gra tei.ti•••[�rt a m�l.il L�.�..�►.�'` i IIS 40 r r i ! rig 0 +s >rA D. Disease Management — NOP Rule 205.206 Is here evidence olCi--estrl or prohibited strategies/inputs? Yes ©No O N/A Comments: 4-7 ✓f Page 4 011 CDA Organic Crop inspection Form — Rev 3/12 60-1 Review all crop protection inputs Are all products being used listed in the OSP? X Yes No Are all products used listed on the "Materials Review Sheet"? © Yes Are all products allowed for use (National List restrictions being followed?) • Describe changes/discrepancies: Section 7: Maintenance of Organic Integrity NOP RULE §205.201(a)(5) and 205.202(c) A (adjoining land use) of this section of the OSP. A. 7 Verify operation consistent with Part • Describe changes/discrepancies: Is roadside spraying an issue? n Yes C mmertts: No n N/A Buffer zones appropriate Additional buffer zones needed? Comments: B. Parallel/Split Operations • Describe changes/discrepancies: Any issues of concern regarding congling or transitional production? [1] Yes Comments: or cross -contamination (e.g. parallel/split production No ® N/A Page 5 of 11 CDA Organic Crop inspection Form — Rev 3/12 C.Equipment • Describe changes/discrepancies: Does custom harvesting occur at operation? • Yes No If yes, please verify cleaning logs or affidavits are used by custom harvester. (This includes seed cleaners.) Verify if needed, chlorine procedures and labels are in plan if bleach is used to sanitize equipment and tools. Comments D. Harvest • Describe changes/discrepancies: Harvest by applicant • Custom harvest Verify cleaning procedures and any relevant documentation if equipment is used for both organic and on -organic. Comments E. Post- Harvest Handling Is this section completed in such a way that accurately reflects what is occurring post-harvest? • 1741 Yes LI No Comments: F. Storage NOP Rule 205.272(b)(1) and (2) • Describe changes/discrepancies: Any prohibited materials stored in or near organic crop storage? • Yesix No Comments: Are labels included for all storage crop inputs? rd Yes • No 0 N/A Are these materials on the "Materials Review Sheet"? r1 Yes ❑ No N/A Page 6 of 11 CDA Organic Crop Inspection Form — Rev 3/12 Transportation �• 1, Describe changes/discrepancies: Is the inspection and cleanliness of transport units verified and documented? Yes ❑ No ❑ N/A Comments: Section 8: Record Keeping System NOP §205.103 1`1 Verify operation consistent with Section 8 of OSP Complete audit form and attach all supporting documents. List issues with record keeping not identified on the crop audit form: Conduct yield verification on at least one crop. ate: I operation is a parallel operation, conduct the yield verification on one of these crops. "to 5 l 4,4- ih. � J rop: Nito■w��‘■. ; Estimated Yield: 2- +-AgtActual Yield: pi -AM Does actual yield closet * reflect estimated yield? es No 1 04 co If no, describe reason(s): Recommended Sampling NOP §205.402, 205.403 14 None n Samples Obtained • Number of samples taken • Sample Type: ❑ Crop ❑ Vegetation C] soil ❑ Other • Reason for sample(s) obtained: What type of receipt was provided? Page 7 of 11 CL)A Organic Crop Inspection Form — Rev 3/12 Are labels used for sale of the crops? 1174 Yes © No Review all Iabels Are all labels being used included in the label file? Yes No Do the labels appear to rneet §205.300?XYes ,[f No • Describe changes/discrepancies: • List labels that were added during inspection: LA-13 Page 8 of 11 CDA Organic Crop Inspection Form — Rev 3/12 Exit Interview Instructions NOP §205.403(d) The purpose of an exit interview is to give the applicant and the reviewer a recap of your inspection, make the operation aware of any possible issues of concern, and let the applicant ask any questions they may have about the certification process. Please remember to remind the applicant that as an inspector, you are there to report your findings and are unable to provide solutions or suggestions about how their operation can become or stay in compliance with the NOP rules. Changes made to the OSP during the inspection List changes made by the applicant: ® None 1. Page: Lit change:. -1tv. & ! C kr s1 L rag. 4sol . C" i [ 2. Page: A) Change: 3. Page: Change: 4. Page: Change: 5. Page: Change: 6. Page: Change: 7. Page: Change: Comments: Additional documents needed List below any documents that the operation was unable to supply at the inspection that may be needed to make a final determination on their organic certification: 2. 3. 4. 5. 6. Comments: Please do not ask for these documents to be sent to you or into the office; the final reviewer may do that. Page 9 of 11 CDA Organic Crop Inspection Form -- Rev 3/12 Issues of concern (cite the standard) NOP §205.403(d) Comments Other D ---MutikiClis ro 3 1, jtare4-- CA,4366 67. 051 Io6T-- Page 10 of 11 CDA Organic Crop Inspection Form — Rev 3112 r **If new applicant complete a full narrative in addition to the inspection form** The information contained in this report is confidential between the inspector, the inspected party and the certification agent. This report does not constitute certification or consultation, nor should it be used for promotional purposes. AH compliance assessments are made in reference to the standards and policies of the above-mentioned certification agent, and are based on the inspector's observations, review of documents and ;- rator interview. 7/:// Repress ve of Op ration Signature Date Attachments: Inspection Time Inspection Narrative Write-up Time Per diem Page 11 of 11 6` rat fc 2 nspector Signature Date Y- Farm Questionnaire Field Maps Complete Field Histories Other (specify) a 4907 hour(s) hour(s) Driving Time Mileage Il hour(s) 10 ,t.crzi 01 IA/ tela r 60 iv ig0A--110,d 0 �j� I 1 -o 1W� b1 CDA Organic Crop Inspection Form — Rev 3112 Colorado Department of Agriculture Organic On - Farm Handler Inspection Report DEPARTMENT OF AGRICULTURE Section A: General Information Has any of the demographic or contact information changed? LJ Yes If yes, list the changes: [] Conditions from last inspection E1 N/A List condition(s) and how operation , as addressed them: Section B: Company Overview Verify information listed in this section. E] Organic Split • Describe changes/discrepancies (if applicable): XIs the description of the Handling operation an adequate representation of what is occurring? Yes No escribe changes/discrepancies (if applicable): Is the operation inspected/regulated by another government agency? If yes, what is the name of the agency? Obtain a copy of the report. If it is not a health dept. report, has the company ever been inspected by the health dept? [] Yes No Review reports and document items relevant to organic certification. Section C: Cleaning/Sanitation NOP Rule §205.103, 205.270, 205.272 Verify all information in this section. • Describe changes/discrepancies: Are all cleaning products listed and labels provided? Comments: Yes ❑ No ❑ NIA For products not found on §205.605 or §205.606, is a clean water rinse documented? Do records of cleaning/sanitation activities document all procedures? Yes ❑ No ❑ N/A Section 0: Packing and Processing Verify all information in this section. • • Describe changes/discrepancies: NOP §205.103, 205.270, 205.272 Section E: Post Harvest Materials NOP Rule §205.272, 205.601 MI Verify all information in this section. • Describe changes/discrepancies: Are all post-harvest products listed and labels provided? ❑ Yes ❑ No N/A Comments: Are these materials on the "Materials Review Sheet"? ❑ Yes ❑ No X. N/A Page 2 of 6 CDA Organic On -Farr Handler Inspection Report —312411 •Sectionc: Water 1 Verify all information in this section. • Describe changes/discrepancies: NOP §205.103, 205.272, 205.601, 205.605 For facilities that use chlorine products, do records document monitoring of discharge or effluent water toa sure the residual chlorine level in water leaving your facility is maintained at or below 4ppm? Yes ❑ No In NIA Comments /j91-1ioiJA op . rr!Do is Are all boiler water additives listed and labels provided? n Yes ❑ No ] N/A Comments: Are these materials on the national list (205.605 or 205.606? ❑ Yes ❑ No [N/A Section G: Packing, Shipping/Storage Containers NOP Rule §205.270, 205.272 Verify all information in this section. Describe changes/discrepancies: Were all labels for all products produced provided? Yes ❑ No ❑ N/A Labeling w Are product labels used? n Yes ❑ No Review all labels affixed to boxes, cartons, clamshells, bags or any other packaging material used Are all labels being used included in the label file? Xi Yes ❑ No Do the labels appear to meet §205.300? Yes ❑ No • Describe changes/discrepancies: NOP §205.300 ▪ List labels that were added during inspection: {1 N/A AVAToijie5 Page 3 of 6 CDA Organic On -Fame Handler inspection Report—3t2011 Section H: Storage NOP Rule §205.270, 205.272 Verify all information in this section. Describe changesldiscrepancies: Is off-site storage utilized? L i Yes Section 1: Pest Management NOP Rule §205,271 w ai►4Verify all information in this section. • Describe changesldiscrepancies: Are exclusion/sanitation practices used? V Yes ❑, No Are mechanical methods being used? PI Yes ■ No '''t4Allowed materials: Are all pest control products used listed and labels included? Yes • No ❑ N/A Are all products used listed on the "Materials Review Sheet"? ❑ Yes !ii No Are all products allowed for use (National List restrictions being followed?) `:1 Yes ❑ No Comments Are materials not on the national list being used? El Yes No Does the company have approval from CDA to use items not on the national list? Yes 0 No N/A Comments Were any pest infestations noted? Yes No ❑ N/A If yes, what type of pest(s) were observed? What evidence of the pest did you observe? ❑ Actual pest 0 Feces ❑ other (describe) Is the facility map complete and accurate? Yes ❑ No ❑ N/A Comments Page 4 of 6 CDA Organic On-farm Handler Inspection Report —312011 Sectioe7 J: Quality Assurance NOP Rule §205.703. 205.270, 205.272 Verify all information in this section. • Describe changes/discrepancies: Product Audit NOP §205.103 1. Conduct a Traceability Audit, using the appro r to form. Were all documents complete and accessible? Yes ❑ No ❑ NIA If no, explain missing components. Is the word "organic" clearly denoted on all relevant documents to track product? r VJ Yes ❑ No Comments 2. If relevant to the operation, conduct a Mass In and Out Balance using the Mass In and Out Balance Audit Form. ❑ N/A to operation Does applicant maintain records to balance organic ingredients in vs. organic products out? ly1 Yes ❑ No *Please make sure ALL audit results are listed clearly on Audit Forms Samples None ❑ Samples Obtained • Number of samples taken Sample Type: Final Product ❑ Ingredient • Reason for sample(s) obtained: Other NOP §205.402, 205.403 What type of receipt was provided? Page 5 of 6 CDA Organic On -Farm Handler Inspection Report 3/2031 Aticifticlhal Issues Describe any additional issues/changes/discrepancies not covered by the inspection, or of importance, that may affect the operation's ability to comply with the standards, or any potential non -compliances (cite the section(s) of the NOP standards that are relevant): Exit interview Ii Conducted omments: NOP §205.403(d) The information contained in this report is confidential between the inspector, the inspected party and the certification agent. This report does not constitute certification or consultation, nor should it be used for promotional purposes. All compliance assessments are made in reference to the standards and policies of the above-mentioned certification agent, and are based on the inspector's observations, review of documents andjferator intervie Si +natureo!Aiithorized Representative spector Signature Date Attachments: Page 6 of 6 CDA Organic On -Farm handler inspection Report —312011 Forwarded message ---------- From: "Kenneth Sack" <kensackcd me.corn> Date: Sep 3, 2012 10:24 AM Subject: Bedrock Resources Application To: "Glenn Hartmann" <ghartmann@gartield-county.coin> Cc: "John Martin"' .jmartin aarfield-countv.coni>. "Tom Jankovsky" <tjankovslcv( cart e1 -county .com>. ► i e Samson" {rnsamson? garfield-countv.com> Dear Commissioners, I have reviews all of the documentation in the Bedrock Application and subsequent additional information submitted. I will insert m i will also send documentation in additional ema:ls. SECTION 7-810 USE. ADDITIONAL STANDARDS APPLICABLE TO INDUSTRIAL C. Outdoor Storage Facilities. All outdoor storage facilities for fuel, raw materials and products shall be screened by natural topography or enclosed by a fence or wail adequate to conceal such facilities from adjacent property. is NO concealment of the proposed Outdoor Storage Facility from Eagle Springs Organic, Organic Growers or Residence at E. Sound. The volume of sound generated shall comply with the standards set forth in the Colorado Revised Statutes. Bedrocks response regarding noi- 4. Noise Study Compliance: As you accurately pointed out, EDI's update letter did not address the location of the crusher relative to the ability of the plan to meet the standards of the ULUR. As identifled in note 2.. above, the crusher is to be located at least 270 feet from the east property line. Likewise, the crusher is noted to produce 73 dB(A) at 103 feet. In the report, it is noted in Table 3 that the noise reduction of 8 dB(A) exists at 270' (by interpolation). Likewise, the reduction due to the berm construction reduces the noise by 24 dB(A). Therefore, the total reduction for the crusher is 24+8 = 32 dB(A) at the property line, This will reduce the noise emanated from the crusher to 41 dB(A): Note that for the north property line, the noise will be reduced further as the unprocessed base pile will exists prior to the crusher starting operation, the distance to the north property line is greater and the proposed storage buildings exist. They ey have submitted a noise study on the crusher: a crusher that according to Jeffery Simonson from SGM. has NOT BEEN IDE Therefore, the standard has not been met F. Ground Vibration. Every use shall be operated so that the ground vibration inherently and recurrently generated is not perceptible without instruments at any point of any boundary line of the property. Between the heavy equipment and the crusher, there is no way for E Brock to meet this standard. No studies have been subrnitt€ Therefore, the standard has not been met G. interference, Nuisance or Hazard. Every use shall be so operated that it does not ernit heat, glare, radiation or fumes which substantially interfere with the existing use of adjoining property or which constitutes a public nuisance or hazard. Flaring of gases, aircraft warning signal and reflective painting of storage tanks, or other legal requirements for safety or air pollution control measures shall be exempted from this provision. The toxic windblown dust and particulate matter that will come from the sites large piles of recycled asphalt and cement constitutf Therefore, the standard has not been met V. COMPREHENSIVE PLAN The Site is designated by the Comprehensive Plan of 2030 as Residential Medium High (MH) with residential densities of 2 to < 6 acres/dvvelling unit. Chapter 3, Section 4, Economy, Employment and Tourism includes a number of goals, policies, and strategies relevant to the current application, Several key elements are summarized below: Goal #1: Maintain a strong and diverse economic base (for both employment and income generation). Bedrock will only move existing employees to this site, It will not create jobs. I employ 50 people on the farm. My Eagle Springs C Policy #5: The County will direct industrial development to the airport center and other appropriately designated areas. This site is NOT the airport center and is NOT an appropriately designated area for an asphalt plant. This is zoned agriculture. Strategy #4: Ensure that commercial/industrial development are compatible with adjacent land uses and preserve the visual quality of the county. It has been veli documented that the proposed use IS NOT COMPATIBLE with the adjacent land use and certainly does NOT prE 3. The Applicant has documented the legal and adequate physical supply of water in accordance with Section 7-104. Water quality testing has been completed 5 Iv:- i'eFi aciegoziie rd-hiscca,1 stipply of ae fol proper dust control 3. The landscaping plan is appropriate for the site and will provide some visual screening. Landscaping plan Q+rovides NO screeninq fol residential property +''hatsoever F. Specific Industrial Use Standards -Section 7-810 of the Unified Land Use Resolution of 2008 as Amended 1. The site plan includes a 5,000 sq.tt. shop building allowing service and repair operations to be conducted in an enclosed building. Topography, slopes, and site grading will also reduce visibility of the site. The site grading has had lithe impact on visibility from agricultural property. There has been NO attempt to reduce visibility of site from residential property. 3. The Applicant should demonstrate compliance with screening for outdoor storage. Visibility from properties to the east may be an issue. Have not seen anything to show compliance 6. Impacts from ground vibration have not been identified in the Application submittals. Have not seer) anything to show compliance 7. Nuisance impacts inconsistent with a typical industrial operation have not been noted As noted previously, the major change in the application submittal is that of removing the contentious use, the asphalt batch plant. In this manner, we are able to reutilize nearly every report previously prepared as the remaining uses sought for this application are less intensive from an impacts standpoint We have adjusted the Noise Assessment Report (prepared by Engineering Dynamics, Inc.) and the Traffic Study (prepared by SUM). Obviously, in both cases, the respective concerns and impacts have lessened as the batch plant has been removed, This Is not true on many points. The contentious issue was the Asphalt Plant that was denied. The batch plant was just a compon The remaining proposed use in NOT less intensive from an impacts standpoint. Actually more impact since recycled asphalt RAP The crusherwlll be placed on site is when the volume of the uncrushed material has economically justified rental and haul of a crusher into the site. Past history has demonstrated that this process is typically every 2 years, however, there is a possibility that this could be a yearly occurrence. The crushing operations typically occur over a ten day period. During the crushing operations, the weather needs to be cool enough to keep from gumming up the crusher equipment and warm enough to allow personnel to wet the piles and to keep the water from freezing. Wetting of the material during the crushing and loading process is needed to mitigate the production of dust from the operations. Because of the sensitive weather conditions, the crushing operations typically ensue during the fall, winter and early spring time periods. Note that this process never HEATS up the existing asphalt. he rnalsrial t.'rouessed in this operation ienir,ins in the same physica With the exception That the material will be crushed to powder, that ,. ,ill blow on surrounding agricultural land 4. Noise Study Compliance: As you accurately pointed out, EDI's update letter did not address the location of the crusher relative to the ability of the plan to meet the standards of the ULUR. As identified in note 2., above, the crusher is to be located at least 270 feet from the east property line. Likewise, the crusher is noted to produce 73 dB(A) at 100 feet. In the report, it is noted in Table 3 that the noise reduction of 8 dB(A) exists at 270' (by interpolation). Likewise, the reduction due to the berm construction reduces the noise by 24 dB(A). Therefore, the total reduction for the crusher is 24+8 = 32 dB(A) at the property line. This will reduce the noise emanated from the crusher to 41 dB(A): Note that for the north property line, the noise will be reduced further as the unprocessed base pile will exists prior to the crusher starting operation, the distance to the north property line is greater and the proposed storage buildings exist. Have not seen how they will meet standards oi' L; LU R . They acre, depending on the herrn tbr a lot of reduction. however the berm has been improperly constructed and sits on or over the lot line. which causes a trespass on ESO property- and chances the normal drainage botE of which are not allowed and will be addressed. They will need to move the berm back from the lot tine and address the trespass and drainage issues' 5. Particulate Material from Unprocessed or Processed Asphalt Base Piles: A further clarification is requested from you as to the particulate matter expected to be generated from the asphalt base piles. It should be noted that the particulate matter to be generated will be that of the clay soil particles that exist in the gravel that becomes mixed with the asphaltic concrete when excavated. The asphalt binder in the mix is not expected to contribute to the particulate matter due to the fact that it has been bound to the various particles during its initial"manufacturing'" phase and, in fact, will help to bind to some of the clay particles that may come with the base. In any case, during the crushing operations of the unprocessed base, water is to be used in the operation to mitigate dust and, thus, the production of particulate matter. The very nature of adding water to the soils to mitigate dust is to enhance the weight of the particles by increasing density, surface tension and cohesiveness of the particles with adjacent particles. This is the same end result already achieved by the asphalt binder when the asphaltic concrete was manufactured Asphalt base removed from highways. is NOT just clay, gravel and concrete. They have not addressed the pollutants generated from years of vehicle traffic including heavy metals and lead. They have not addressed the recycled cement and the silica and toxic components there. 6. Traffic Volumes expected: As an additional clarification, you have requested the anticipated volumes of traffic to be generated from the site in comparison with the prior proposal that included the asphalt batch plant. With the asphalt batch plant included in the trip generation calculations, the average daily trips anticipated for the project was 85 trips per day. By removing the asphalt batch plant, but still including some truck traffic for hauling materials in and out of the storage area, we anticipate the projected average daily trips to be 47 trips per day. I have not seen the calculation for the amount of water trucks required to provide enough water for dust control, fire suppression. processing activity... it should also be noted that they said they would use mag chloride on the roads twice a year and later reduce to once a year??? This demonstrates once again the lack of understanding of what it will take to comply with dust mitigation standards. Also, in talking with chip, an APEN is required for the crusher Since the APEN is equipment specific, the proposal would be that there would not be any crushing operations ensue until the specific rental equipment is found and specified. As the crushing operations proposed are very intermittent. the APEN will need to be applied for when the equipment to be rented is identified. Also, the timing of the operation at that point can be identified as well (and would he part of the permit). Thanks, Jefferey S. Simonson, PE, CFM Principal Bedrock is applying For a permit to process recycled asphalt, crushing activity.... They have submitted noise studies on machinery that they have not even identified. Since they have no idea on tlhe equipment they will be using, they cannot provide a study on \,'hat environmental effect. dust. air or noise pollution will be generated by same. Table 2 in the April3O, 2012 letter addresses the noise sources that would be in Frontier Paving Contractor's Yard. Not included in that table was the noise emission of the crusher,occasionally ichnost recently has been included as an to process road material (asphalt blacdkditional piece of equipment in the Contractor's Yard. The crusher will be used eeTable 2, the crush r produces 73 dB(A) at whatsoever between the crusher and. and 65 Bthe}at the propertylosest property line. There is al berm the northeast d the ditch when there is nolnoise amitigationh5 dB(A) makingthe noise level at the property line 60 dB(A), which will initially reduce the crusher noise level at the property by ( } which means that an additional 5 takes place oiae lt reductionwllis requiredmpin ther to road onto an athe noise lrealow the between5th dB(A)limit.itroad and the crusher. Some of the salvaged roadway asphalt will be dumped from material will be left in place to form a second 12 ft. high noise barrier berm. This berm will provide a 6 dB(A) reduction and the noise level at the property line will be less than 55 dB(A). Additional noise reduction of 5 dB(A) can also be achieved by locating the crusher at the south corner of the storage area. Providing noise information for a yet unidentified crusher. Even their best attempt to push this through„ they are showing 65dBA at the lot line which is well over the allowed limits. 3. A copy of the easement document for the adjoining property needs to be provided and the status of easements for Holy Cross Electric clarified. New easements for electric service may be required Have not seen an easement document for MY adjoining property 9. The Applicant has provided a detailed Traffic Study prepared by SGM. The study addresses traffic generation from the originally proposed use, improvement warrants, and impacts on off-site intersections. A reduction in traffic generation is anticipated by the change in the proposed use. Water truck traffic is not addressed 10. A noise analysis update is provided along with a supplemental analysis of the crusher operation, which demonstrate State and ULUR compliance. The noise analysis update in NO way demonstrates compliance with State and ULUR 11. Dust mitigation plans are provided and the Applicant has further clarified wetting as the primary dust suppression for the proposed crushing activity. CDPHE air quality permitting for the crushing activity needs to be addressed Dust mitigation plan ie twice a year mag chloride for roads - not acceptable What is the plan for stock piles and the rest of the property Where are they getting the water from- 3 gallon per minute well, Untested for recovery time beyond 2 hours. 3. General description of crushing operations: As we discussed with you in your site walk, the crushing operations are to be performed when temperatures are cool and there is no chance for the asphalt in the asphaltic concrete to "gum up" the crushing equipment. This operation will not allow the asphalt to be heated nor processed in a warm state as is typical of an average late spring/early autumn and summer day. However, this process could be performed on a cool day when during that time period (such as a rainy day). The only intent is to crush piles of asphalt that have been hauled to the site from construction protects that Frontier Paving or other associated contractors have been involved in. There are going to be two piles of asphaltic concrete on the site. One that has been processed (crushed) and is now ready to be used as road base and pipe bedding and one that is yet to be crushed the description is way to vague. Temperatures COOL — how many COOL days do we have in summer.. Need specific information and data. A major impact review requires more than a bunch of vague statements. What other associated contractors are allowed to bring recyclable products to the site. What products are being processed? Asphalt, Cernent. Asphalt shingles? Ken Sack cell 954-249-5674 Eagle Springs Organic Eagle Springs Solar 5454 County Rd 346 Silt, CO 81 650 Eagle Springs Crossing 1733 Railroad Ave Rifle, CO 81652 ill ASPHALT RECYCLED CEMENT AND ASPHALT INFO.PDF 737 KB 1C0 ASPHALT PLANT POLLUTION BRED STUDY.DOC 77 KB I ASPHALT HEALTH DANGERS.DOC 151 KB 19 ASPHALT AND CEMENT RECYCLING HEALTH STUDY.DOC 207 KB TEICHERT AGGREGATES MATERIAL SAFETY DATA SHEET P 0.130X, 15002 3ACRAPE'TO, CALIFORNIA G ?'1 EFFECTIVE DATE: --- FE=B=R=U: ....R-: .... `.:'-=='c:�; I. IDENTIFICATION (FADE NAME: RECYCLED CONCRETE AND/OR RECYCLED ASPHALT COMMON NAME: RECYCLED MATERIALS BASE, i ISCELLANEO _. 5 BASE MANUFACTURER'S NAME: TEICHERT AGGREGATES, PC BOX 15002, SACRAMENTO C. 95851 TELEPHONE NUMBER: 916 48=-3011 DATE REVISED: A,_'GUST 2003 PRODUCT DESCRIPTION. PRODUCT I5 ORtiSH ED RECYCLED CONCRETE, E, ASPH ",L AND/OR SIMILAR ..TERIALS ORIGINATING AS NON -CONTAMINATED CONSTRUCTIOr'! DEBRIS. DEPARTMENT OF TRANSPORTATION HAZARD CLASSIFICATION N/A SHIPPING NAME N/A II. PHYSICAL PROPERTIES BOILIV,IG POINT, 760 mni Hg N/A FREEZING PCI: SPECIFIED GRAVITY (H?0 = 1) VAPOR DENSITY (air= 1) NE PERCENT VOLATILES BY VOLUi iE APPEARANCE AND COCK MATERIA'_ NIE VAPOR PRESSURE °D BYWT. N/A EVAPORATION RATE (Butyl Acetate = 1) N; A. NEGLIGIBLE NiE PIECES OF CRUSHED CONCRETE AND OR ASP -LT I+,'IA T ERIAL ODORLESS HAZARDOUS INGREDIENTS CRUSHED CONCRETE AND/OR CRUSHED ASPHALT (1) (2) CRYSTAL LII"E SILICA EL 100 10 rnafir' 5 mg ;1 0.3 rng/rn 0 1 rng/m' TL 10 me`JTr 0 05 mcllm3--.. ..BAR N 4808-060-7 NOTE:(1) CRUSHED CONCRETE Aa .D CRUSHED ASPHALT COMTA N ROCK AND SAND.I'!ATi_RAL SA .ID INCLUDES O'U RIZ.,A. FORM OF CRYSTALLINE S LICA. COMPOSITION .'AR ES (2) MATERIAL MAY INCLUDE SHALL PERCENTAGES (LESS THAs` 15r'.) OF GLASS PORCELAIN OR OTHER CERAN C MATERIALS TOTAL DUST, PART C+. LA. T ES NOT 0THER0ISE REGULATED. -': RESPIRABLE GUST. P, OR TOTAL SILICA 'RESPIRABLE SILICA IV. FIRE AND EXPLOSION HAZARD DATA FLASH POINT (test method) FLAMMABLE LIMITS IN A!R 1b;. volu'T!s. EXTINGUISHING MEDIA NOP'IE ILO\''NER 1 NA 1 UPPER 4 N A SPECIAL FIRE FIGHTING NONE PROCEDURES UNUSUAL FIRE ARID EXPLOSION HAZARDS N/A = not applicable NONE EMERGENCY PHONE NUMBER 1916 484-3011 N/E = not 65 21,,11 HEALTH HAZARD INFORMATION EFFECTS OF ACUTE OVEREXPOSURE SWALLOWII.9G NO SIGNIFICANT HAZARD POSED SKIN CONTACT SHORT TERM IRRITATION INHALATION PRODUCT FRAGMENTS MAY INCLUDE FINE EILIC,A (QUARTZ) Z) DUS J . PROLONGED OR ROUTINE INHALATION OF FINE QUARTZ DUST CAN LEAD TO THE LUNG DISEASE KNOWN AS SILICOSIS EYE CONTACT SHORT TERM IRRITATION EFFECTS OF REPEATED OVEREXPOSURE ACUTE: .,Ii= SNE _ =T = _ - N CAUSE CYE IRR. — 7ON —. N : = '.ER . HIGH LE EL F r I -_)F; JE DUST !'9 PRODUCE COUGHING AND = TION. CHRONIC: PROLONGEDAND RCS_ NE INHALATION OF RESPIRABLE OU.M:RTZ DUST CAN LEAD TO THE LUNG DISEASE I1NO7:;11 AS S_LICOES. EARLY SYMPTOMS OF SILICOSIS N= .UDECOUGHING. WHEEZING SHORTNESS OF BREATH. AND INCREASED LIKELIHOOD OF OTHER L".II!Y PR :.ELEMS. OTHER HEALTH HAZARDS MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE. PRIOR SKIN PROBLEMS SUCH AS DERMATITIS PRI JR RESPIRATORY TRACT CO;'DITi') "S SUCH AS BROsNCHITIS. EMERGENCY AND FIRST Ala PROCEDURES SWALLOWING SEEK 'MEDICAL ADVICE. BUT INGESTION OF SMALL AMOUNTS OF THE MATERIAL IS NOT EXPECTED TO POSE A SIGNIFICANT HEALTH HAZARD. SKIN WASH SKIN WITH WATER AND MILD SOAP, INHALATION REMOVE TO FRESH AIR. SEEK MEDICAL ATTENTION IF DISCOMFORT OR IRRITATION PERSISTS, EYES FLUSH EYES WITH LARGE AMOUNTS OF'v\IA T ER SEEK MEDICAL ATTENTION. SUSPECTED CANCER AGENT? NO FEDERAL OSHA _ .UO ... NTP PARC NOTE: IARC LISTS CRYSTALLINE SILICA AS HUMAN CARCINOGEN. CRYSTALLINE SLICA POSES HEALTH HAZARD WHEN IT IS INHALED AS A DUST. PROP 65 WARNING: CRUSHED RECYCLED CONCRETE AND ASPHALT CONTAINS QUANTITIES OF F NE CRYSTALLINE SILICA CRYS T / LLINE SILICA i'-'UARTZ) DUST IS LISTED ! JV DER TITLE 22, SECTION 12000, AS A CHEMICAL KNOWN TO THE STATE OF CALIFORNIA TO CAUSE CANCER. ALWAYS FAMILIARIZE YOURSELF WITH THE HAZARDS OF THE i+AP, T ER!ALS AND EQUIPMENT YOU ARE (USING AND FOLLOW THE PRECAUTIONS INDICATED ON PRODUCT LABELS, MATERIAL SAFETY DATA SLEETS AND YOUR HEALTH AND SAFETY TRAINING PROGRAM. SIB UNSTABLE miry' STABLE ABLE INCOMPATIBILITY (materials to tOk ) VIVI REACTIVITY OATA CONDITION NONE TO AVOID STRONG OXIDIZERS, SUCI-I AS STRONG ACIDS. HAZARDOUS COMBUSTION OR CARBON DIOXIDE, SULFUR DIOXIDE DECOMPOSITION PRODUCTS HAZARDOUS POLYMERIZATION May Occur Will Not Occur CONDITION TO AVOID NONE VII. SPILL OR LEAK PROCEDURES STEPS TO BE TAKEN IF MATERIAL IS RELEASED OR SPILLED WASTE DISPOSAL METHOD IUiA T ERIAL DOES NOT POSE HAZARD TO IMMINENT HAZARD TO WORKERS OR THE ENVIRONMENT. TRANSFER SPILLED MATERIAL TO CONTAINERS FOR REUSE OR DISPOSAL WITH NORMAL TRASH. USE NORMAL GOOD HYGIENE PRACTICES TO MINIMIZE EXPOSURE (WE :,.F SKIN AND EYE PROTECTION, AS NECESSARY), PRODUCT IS NOT CLASSIFIED AS HAZARDOUS WASTE. Vill. SPECIAL PROTECTION INFORMATION RESPIRATORY PROTECTION (specific type) L IF AIRBORNE CONCENTRATIONS EXCEED OSHA PERMISSIBLE EXPOSURE LIMITS, \NEAR 1N110SH-APPROVED RESPIRATORS TO ACHEVE EXPOSURES BELOW THE PEL. VENTILATION NIA PROTECTIVE L.C" \i ES AVOLD PROLONGED OR REPEATED CONTACT WITH PRODUCT. EYE PROTECTION D T I.1;.F PROTECTIVE EQUIPMENT AVOID EYE CONTACT: WEAR SAFETY GLASSES OR GOGGLES. AS NEEDED. COVERALLS OOTHER WORK CLOTHING THAT IvL v!11qIZES SKIN G0'1TACT WITH PRODUCT. IX, SPECIAL PRECAUTIONS PRECAUTIONS TO BE TAKEN IN HANDLING AND STORING: NONE - X. ADDITIONAL INFORMATION ADDITIONAL HEALTH DATA PROP 65 WARNING: CRUSHED RECYCLED CONCRETE AND ASPHALT CONTl QUANT rIES OF CHRYSENE, BENZO. -..PYRENE AND BENZO THESE PETROLEUM ASPHALT COMPONENTS ARE LISTED UNDER. TITLE 22 SECTION 12000 AS CHEM KNOWN TO THE STATE OF CALIFORNIA TO CAUSE CANCER AND BIRTH DEFECTS OR OTHER REPRODUCTIVE HARM. ALWAYS FAMILIARIZE YOURSELF WITH THE HAZARDS OF THE MATERIALS ANC EQUIPMENT YOU ARE USING AND FOLLOW THE PRECAUTIONS INDICATED ON PRODUCT LABELS, MATERIAL SAFETY DATA SHEETS, AND YOUR HEALTH AND SAFETY TRAINING PROGRAM. SKIN EXPOSURE TO ASPHALT CAN CAUSE WORKERS TO EXPERIENCE PHOTOSENSITTION A CONDITION WHERE THE EXPOSED AREA OF SKIN BECOMES VERY SENSITIVE TO SUN LIGHT ANC OTHER SOURCES OF ULTRAVIOLET (UV) LIGHT. WITHOUT EXPOSURE TO UV SENSITIVE SKIN MA APPEAR TO BE SUNBURNED WITH EXOSURE TO UV THE SKIN MA 'Y BLISTER AND DEVELOP SORES. AS WITH ANY CHF.JviICAL, SKIN COi‘ITACT WITHTHiS PRODUCT AND THE BREATHING OF RODUCT DUST SHOULD BE NolINIMIZED. WE STRONGLY RECOMMEND THAT THE PRECAUTIONS STATED THS 3DS BE FOLLOWED WHEN HANDLING THE PRODUCT. Teichert Aggregates believes the information contained herein is accurate; however, Teichert Aggregates makes no guaranfi.ees with respect to such .accuracy and assumes no liabilty in connecton with the use of the information contained herein by any party. The provision of the information contained herein is not intended to be and should not be construed as legal advice or as ensuring compliance with any federal state or local laws and regulations. Any party using this product should review 211 such le+iys, rules or regulations prior to us NO WARRANTY IS MADE, EXPRESSED, OR ifv1PLIED OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR OTHERVVISE. lk MATERIAL SAFETY DATA SHEET TEICHERT AGGREGATES PO. BOX 15002 SACRAMENTO, CALIFORNIA 95851 EFFECTIVE DATE: FEBRUARY 2004 TRADE NAME: COMMON NAME: MANUFACTURER'S NAME: TELEPHONE NUMBER: I. IDENTIFICATION RECYCLED CONCRETE AND/OR RECYCLED ASPHALT RECYCLED MATERIALS BASE, MISCELLANEOUS BASE TEICHERT AGGREGATES, PO BOX 15002, SACRAMENTO CA 95851 916 484-301 1 DATE REVISED:. AUGUST 2003 PRODUCT DESCRIPTION: PRODUCT IS CRUSHED RECYCLED CONCRETE, ASPHALT AND/OR SIMILAR MATERIALS ORIGINATING AS NON -CONTAMINATED CONSTRUCTION DEBRIS. DEPARTMENT OF TRANSPORTATION BOILING POINT, 760 mm. Hg HAZARD CLASSIFICATION N/A SPECIFIED GRAVITY (H20 = 1) SHIPPING NAME II. N/A N/A PHYSICAL PROPERTIES FREEZING POINT VAPOR PRESSURE 2.3 - 2.8 NIA N/A VAPOR DENSITY (air = 1) N/E SOLUBILITY IN WATER, NEGLIGIBLE % BY WT. PERCENT VOLATILES BY VOLUME N/E EVAPORATION RATE Butyl Acetate = 1 NUE APPEARANCE AND ODOR PIECES OF CRUSHED CONCRETE AND/OR ASPHALT MATERIAL, ODORLESS III. HAZARDOUS MATERIAL CRUSHED CONCRETE AND/OR CRUSHED ASPHALT (1) (2) INGREDIENTS 100 PEL 10 mg/m3. 5 mglm3- TLV 10 mg/n-0 CAS NUMBER N/E CRYSTALLINE SILICA 0.3 mg/m3 0.05 mg/m3_... 0.1 mglm3... 14808-060-7 NOTE: (1) CRUSHED CONCRETE AND CRUSHED ASPHALT CONTAIN ROCK AND SAND. NATURAL SAND INCLUDES QUARTZ, A FORM OF CRYSTALLINE SILICA. COMPOSITION VARIES. (2) MATERIAL MAY INCLUDE SMALL PERCENTAGES (LESS THAN 15%) OF GLASS, PORCELAIN, OR OTHER CERAMIC MATERIALS TOTAL DUST. PARTICULATES NOT OTHERWISE REGULATED. ": RESPIRABLE DUST, PNOR. —TOTAL SILICA "—RESPIRABLE SILICA FLASH POINT test method IV. FIRE AND EXPLOSION HAZARD DATA N/A FLAMMABLE LIMITS IN AIR, % by volume EXTINGUISHING MEDIA SPECIAL FIRE FIGHTING PROCEDURES NONE NONE UNUSUAL FIRE AND EXPLOSION NONE HAZARDS N/A = not applicable LOWER NIA EMERGENCY PHONE NUMBER (916) 484-3011 UPPER N/A N/E = not established V. HEALTH HAZARD INFORMATION EFFECTS OF ACUTE OVEREXPOSURE NO SIGNIFICANT HAZARD POSED SWALLOWING SKIN CONTACT INHALATION SHORT TERM IRRITATION PRODUCT FRAGMENTS MAY INCLUDE FINE SILICA (QUARTZ) DUST. PROLONGED OR ROUTINE INHALATION OF FINE QUARTZ DUST CAN LEAD TO THE LUNG DISEASE KNOWN AS SILICOSIS. EYE CONTACT SHORT TERM IRRITATION EFFECTS OF REPEATED OVEREXPOSURE ACUTE: AIRBORNE PARTICLES CAN CAUSE EYE IRRITATION. INHALATION OF VERY HIGH LEVELS OF AIRBORNE DUST MAY PRODUCE COUGHING AND IRRITATION. CHRONIC: PROLONGED AND ROUTINE INHALATION OF RESPIRABLE QUARTZ DUST GAN LEAD TO THE LUNG DISEASE KNOWN AS SILICOSIS. EARLY SYMPTOMS OF SILICOSIS INCLUDE COUGHING, WHEEZING, SHORTNESS OF BREATH, AND INCREASED LIKELIHOOD OF OTHER LUNG PROBLEMS. OTHER HEALTH HAZARDS MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE PRIOR SKIN PROBLEMS SUCH AS DERMATITIS, PRIOR RESPIRATORY TRACT CONDITIONS SUCH AS BRONCHITIS. EMERGENCY AND FIRST AID PROCEDURES 1 - SWALLOWING SEEK MEDICAL ADVICE, BUT INGESTION OF SMALL AMOUNTS OF THE MATERIAL IS NOT EXPECTED TO POSE A SIGNIFICANT HEALTH HAZARD. SKIN INHALATION WASH SKIN WITH WATER AND MILD SOAP. REMOVE TO FRESH AIR. SEEK MEDICAL ATTENTION IF DISCOMFORT OR IRRITATION PERSISTS. EYES FLUSH EYES WITH LARGE AMOUNTS OF WATER. SEEK MEDICAL ATTENTION. SUSPECTED CANCER AGENT? NO FEDERAL OSHA NO NTP X IARC NOTE: IARC LISTS CRYSTALLINE SILICA AS HUMAN CARCINOGEN. CRYSTALLINE SILICA POSES A HEALTH HAZARD WHEN IT IS INHALED AS A DUST. PROP 65 WARNING: CRUSHED RECYCLED CONCRETE AND ASPHALT CONTAINS QUANTITIES OF FINE CRYSTALLINE SILICA. CRYSTALLINE SILICA (QUARTZ) DUST IS LISTED UNDER TITLE 22, SECTION 12000, AS A CHEMICAL KNOWN TO THE STATE OF CALIFORNIA TO CAUSE CANCER. ALWAYS FAMILIARIZE YOURSELF WITH THE HAZARDS OF THE MATERIALS AND EQUIPMENT YOU ARE USING AND FOLLOW THE PRECAUTIONS INDICATED ON PRODUCT LABELS, MATERIAL SAFETY DATA SHEETS AND YOUR HEALTH AND SAFETY TRAINING PROGRAM. VI. REACTIVITY DATA STABILITY UNSTABLE STABLE X CONDITION NONE TO AVOID INCOMPATIBILITY (materials to avoid) STRONG OXIDIZERS, SUCH AS STRONG ACIDS. HAZARDOUS COMBUSTION OR DECOMPOSITION PRODUCTS HAZARDOUS POLYMERIZATION May Occur Will Not Occur X VII. CARBON DIOXIDE, SULFUR DIOXIDE CONDITION NONE TO AVOID SPILL OR LEAK PROCEDURES STEPS TO BE TAKEN IF MATERIAL IS RELEASED OR SPILLED MATERIAL DOES NOT POSE HAZARD TO IMMINENT HAZARD TO WORKERS OR THE ENVIRONMENT. TRANSFER SPILLED MATERIAL TO CONTAINERS FOR REUSE OR DISPOSAL WITH NORMAL TRASH. USE NORMAL GOOD HYGIENE PRACTICES TO MINIMIZE EXPOSURE (WEAR SKIN AND EYE PROTECTION, AS NECESSARY). WASTE DISPOSAL METHOD PRODUCT IS NOT CLASSIFIED AS HAZARDOUS WASTE. VIII. SPECIAL PROTECTION INFORMATION RESPIRATORY PROTECTION (specific type) IF AIRBORNE CONCENTRATIONS EXCEED OSHA PERMISSIBLE EXPOSURE LIMITS, WEAR NIOSH -APPROVED RESPIRATORS TO ACHIEVE EXPOSURES BELOW THE PEL. VENTILATION NIA AVOID PROLONGED OR REPEATED CONTACT WITH PRODUCT, PROTECTIVE GLOVES EYE PROTECTION AVOID EYE CONTACT; WEAR SAFETY GLASSES OR GOGGLES, AS NEEDED. OTHER PROTECTIVE EQUIPMENT COVERALLS OR OTHER WORK CLOTHING THAT MINIMIZES SKIN CONTACT WITH PRODUCT. IX. SPECIAL PRECAUTIONS PRECAUTIONS TO BE TAKEN IN HANDLING AND STORING: NONE X. ADDITIONAL INFORMATION ADDITIONAL HEALTH DATA PROP 65 WARNING: CRUSHED RECYCLED CONCRETE AND ASPHALT CONTAINS QUANTITIES OF CHRYSENE, BENZO(A)PYRENE AND BENZO(A)ANTHRACENE. THESE PETROLEUM ASPHALT COMPONENTS ARE LISTED UNDER TITLE 22, SECTION 12000, AS CHEMICALS KNOWN TO THE STATE OF CALIFORNIA TO CAUSE CANCER AND BIRTH DEFECTS OR OTHER REPRODUCTIVE HARM. ALWAYS FAIVIILIARIZE YOURSELF WITH THE HAZARDS OF THE MATERIALS AND EQUIPMENT YOU ARE USING AND FOLLOW THE PRECAUTIONS INDICATED ON PRODUCT LABELS, MATERIAL SAFETY DATA SHEETS, AND YOUR HEALTH AND SAFETY TRAINING PROGRAM. SKIN EXPOSURE TO ASPHALT CAN CAUSE WORKERS TO EXPERIENCE PHOTOSENSITIZATION, A CONDITION WHERE THE EXPOSED AREA OF SKIN BECOMES VERY SENSITIVE TO SUN LIGHT AND OTHER SOURCES OF ULTRAVIOLET (UV) LIGHT. WITHOUT EXPOSURE TO UV, SENSITIVE SKIN MAY APPEAR TO BE SUNBURNED WITH EXOSURE TO UV. THE SKIN MAY BLISTER AND DEVELOP SORES. AS WITH ANY CHEMICAL, SKIN CONTACT WITHTHES PRODUCT, AND THE BREATHING OF RODUCT DUST SHOULD BE MINIMIZED. WE STRONGLY RECOMMEND THAT THE PRECAUTIONS STATED IN THIS MSDS BE FOLLOWED WHEN HANDLING THE PRODUCT. Teichert Aggregates believes the information contained herein is accurate; however, Teichert Aggregates makes no guarantees with respect to such accuracy and assumes no liability in connection with the use of the information contained herein by any party. The provision of the information contained herein is not intended to be and should not be construed as legal advice or as ensuring compliance with any federal, state, or local laws and regulations Any party using this product should review all such laws, rules, or regulations prior to use. NO VVARRANTY IS MADE, EXPRESSED. OR IMPLIED OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR OTHERWISE. REVISED 2(04 PROBLEMS OF RECYCLING CONCRETE (COMMENTS May 19, 2010 1 By Bambi Turner Concrete waste comes from demolished buildings, repaved roads, sidewalks and other structures. By recycling concrete debris, builders can reduce energy consumption and related emissions to help the environment while reducing the amount of waste sent to landfills. Recycled concrete can be used for new building projects, or as a source of gravel for landscaping and erosion control. While recycling offers many benefits, there are still many problems associated with this process that require further research. Contaminants The concrete recycling process is relatively simple. Large crushing machines grind the concrete into relatively small pieces of aggregate, or gravel. To make this process easier, many recycling centers only accept concrete that's free of rebar, steel and other contaminants. Those who wish to recycle reinforced concrete must first dedicate resources to removing the steel, which can be expensive and time consuming. Some facilities may also reject concrete that's contaminated by asphalt, soil, paint or other forms of construction debris. Cost According to the Environmental Council of Concrete Organizations, concrete costs up to $4 per ton to crush, not including equipment and related expenses. This cost may cause companies to take concrete to the landfill instead of recycling, particularly when the added cost of sorting and decontaminating the concrete is taken into account. Strength The Environmental Council of Concrete Organizations explains that concrete made from recycled material has only 80 to 90 percent of the strength of concrete manufactured from raw materials This not only poses design challenges for engineers and builders, but may limit the applications for which recycled concrete can be safely used. According to the Portland Cement Association, most concrete mixtures should contain no more than 30 percent recycled aggregate, and less than 20 percent recycled fine aggregate. This means that all concrete must contain roughly 50 percent virgin materials, which limits the benefits of recycling in some areas. Water Absorption Most concrete damage is caused by freeze -thaw cycles, which occur when water is absorbed into the hardened concrete. According to the Environmental Council of Concrete Organizations, recycled concrete absorbs 2 to 6 percent more water than new concrete, making it more susceptible to cracks and other damage. This issue is particularly problematic in colder climate zones, which often experience temperatures below freezing. Potential Health Effects Hardened concrete contains chemicals like chloride, alkali and silica. Most demolition companies have no way of knowing the ratio of these contaminants in the concrete. During demolition and recycling, these materials are released into the air as dust, where they can affect the health of workers and nearby residents. According to the U.S. Occupational Health and Safety Administration, silica dust is a known carcinogen. Read more: http:flwww livestrong corm/article!12$614-problerns-recyclirtg- concretel#ixzz255gceFmN Recycling facilities that handle asphalt roofing shingles break the material into small pieces and market it for a range of uses. Ground -up roofing has been used in road construction as bedding under road surfaces, on gravel roads and as an additive to hot mix or cold patch asphalt. More uses have included horse arenas, unpaved home driveways, landscaping, animal bedding, trail construction and other purposes. Concerns about potential contaminants in the roofing lead the Washington Department of Ecology (Ecology) to test ground asphalt -based roofing for chemical composition. Test results indicate that several metals (including arsenic) and polycyclic aromatic hydrocarbons (PAHs) are present at levels that may be harmful to human health and the environment. Arsenic and certain types of PAHs, including those present in the roofing, cause cancer in humans. The use of recycled asphalt roofing in loose form presents risks. Humans may inhale, ingest or absorb asphalt roofing particles and its contaminants. Wind or precipitation may carry the material into water sources. As a result, Ecology expects a recycler of asphalt roofing to obtain either a solid waste permit or a Beneficial Use Determination (BUD) before distributing it for uses in the loose form. To obtain a permit or BUD, a recycler will need to show that any proposed use will prevent exposure to contaminants in the material. Roofing materials bound in asphalt, as in hot mix or cold patch asphalt, are not mobile in the environment so present less of a risk. Ecology does not expect these uses to go through an approval process under solid waste regulations. ASPHALT PLANT POLLUTION Young & McQueen Grading Company wants to build an asphalt plant in Mitchell County. The draft air pollution permit proposed by the NC Division of Air Quality (Permit No. 09808800) would allow the plant to produce up to 225,000 tons of asphalt per year at a maxinusm of 160 tons per hour. If given final approval by the state, the Young & McQueen plant would be allowed to eniit the following air pollutants annually: Chronic toxicants carbon disulfide methyl ethyl ketone toluene xylene 682 13,650 17,150 9,975 Acute system toxicants styrene 3,780 Carcinogens benzene trichloroethylene (TCE) perchloroethylene (PCE) 64 4,000 13,000 Annual lords based on produdllon rate of 160 turas per hour for 1,406 hours per year or 175 dais at 8 hours per day to produce 225,000 tons of asphalt Chronic toxicants include neurotoxins and developmental toxins. substances which have a negative impact on the litnnan nervous system and'or human growth and development. Acute system toxicants are pollutants which cause the death of laboratory ani- mals within 14 days of exposure or is toxic based on human experience. Carcinogens are substances which are known to cause cancer or which are sus- pected to cause cancer in humans, Def initions :from the C'S Code of Fed- eral Regulations (16C'FR1500) Jur the Federal Hazardous Substances Conical Act. October 2007 Certain pollution sources at the asphalt plant would be exempted from its state permit: 1) an Asphalt Tank Heater burning No. 2 fuel oil at 1.6 million BTU heat input and 2) a 10,000 gallon liquid asphalt storage tank. These units are known sources of toxic air pollution but are exempted by state statute: that is. they are listed in the permit but not included in the air pollution limits. Asphalt Plant Pollution: A Public Health Hazard Road asphalt contains gravel and sand mixed with asphalt cement obtained from crude oil. Asphalt cement is a mixture of hydrocarbons including naphtha which contribute to the va- porization of organic compounds at operating temperatures of 300-350 degrees F. Hydrocar- bons released into the air by the hot mix asphalt as it is loaded into trucks and hauled from the plant site include volatile organic compounds, polycyclic aromatic hydrocarbons, and con- densed particulates. Also, arsenic, benzene, formaldehyde, and cadmium are toxic air pollutants emitted from asphalt plants. Condensation of particulates occurs at (continued next page) BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE wwsw.BR EDL.org PO Box 88 Glendale Springs. NC 28629 (336) 982-2691 BREDl. skybest.com {from page one) ambient temperatures of 70 degrees F. These very fine particles carry polycyclic aromatic hy-drocarbons which are a danger to public health. Animal studies show that PAHs affect repro- duction, cause birth defects. and cause harmful effects on skin. body fluids, and the immune system. The US Department of Health and Human Services has determined that PAHs may be carcinogenic to humans. [Source: Agency for Toxic Substances and Disease Registry (ATSDR). 1995. Toxicological Profile /or polycyclic uronxatic hydrocarbons (PAI -Js). Atlanta. GA: U.S.Department of Health and Human Services. Public Health Servicel The effect of fugitive emissions on local pollution levels may exceede e t ect o -pollutants emit frmnThe smokestack. In addition to smokestack emissions asphalt plants emit large quantities of harmful fugitive emissions at ground level. A small asphalt plant producing 100 thousand tons of asphalt a year may generate 50 tons of toxic fugitive emissions. The bulk of fugitive emissions are condensed particulates. Volatile organic compounds (VOC's) emissions are about 29% of the this total. To this must be added the total emitted from the smokestack itself. Stagnant air conditions and inversions increase the level of exposure to the local community. The Blue Ridge Environmental Defense League has released two studies showing the adverse impacts on property values and public health for residents living near operating asphalt plants. A prop erty value study documented losses of up to 56% as a direct result of an asphalt plant. In another study nearly half of the residents report negative impacts on their health after only two years of asphalt plant operations. The door-to-door survey shows that 45% of the residents living within a half mile of a two year old asphalt plant report a deterioration of their health which began after the plant opened. The most frequent problems include high blood pressure (18% of people surveyed), sinus problems (18%). headaches (14%), and shortness of breath (9%). Action recommendations Federal regulation of asphalt plant emissions is inadequate to protect public health. EPA's emission estimates (AP -42) are inadequate to pro ec wor er 1eatth and publichealth. erefore, citizens must join together to protect their communities. Any county or town faced with an asphalt plant proposal should push for setbacks from residences and community buildings, site specific health- based air pollution modeling and monitoring, enclosures for load -out zones, and preferably a zero emissions asphalt plant, with total containment of air pollutants. What Are the Dangers of Working in a Concrete -Based Plant? By Lee Morgan, eHow Contributor Concrete factory workers face several health hazards. C911.1...'iVtf2 (i; 2 !.L) tiUdgeTS fl'0171 exposureto the. material, •!,Thite the exteot c_lf the (lamer relat?d to the concrete is. significant in jobs such as construction) the highest risk to c:;ocrete-speeffic hazards is within the facilities that nualufacture the c(-nicite, accordinc) to the ICY- SeiC15 W2bSit'2. KnOitliHg the prit,?noi.-r! risks ossor±ic,ted in a connr?te-basect plant i_007.k21.5 P7'e))17C2101' th? (17. -?1? 1 Inhalation Dangers People who work in a concrete factory setting are constantly exposed to the dust from the dried raw materials. Those who sweep and clean are especially susceptible to inhalation hazards. Portland cement is a common material used to make concrete, and the dust from the dried cement has been labeled a possible cancer risk, according to the IOP Science website. Inhaling this dust is suspected to increase risk of several cancers, including pharyngeal carcinoma and gastric cancer. Inhaling this material is also known to cause nose and throat irritation and respiratory difficulties. Exposure to crystalline silica dust, another concrete raw material, can lead to a serious lung disease called silicosis, according to the State Compensation Insurance Fund website. 2. Skin Contact While working with and mixing concrete in a plant, workers are likely to expose their skin to wet concrete from time to time. As long as the substance is washed off immediately, irritation is unlikely. However, extended contact with the skin will cause concrete to burn the skin because of the alkaline nature of the mixture. These burns can range from first- to third-degree and skin ulcers may result if the substance is in contact with the skin for long periods. Even with protective clothing. workers may get bits of concrete trapped inside boots or have it soak through Layers of clothing, according to the Electronic Library of Construction Occupational Safety and Health. This risk is the same for both concrete plant workers and construction workers dealing with concrete. 3 Eye Injury The same dust that can cause lung problems when inhaled can also do damage to the worker's eyes. Depending on the amount of dust that enters the eyes and the duration before they are rinsed clean with water, the effects can range from minor eye irritation and redness to chemical burns on the eyeballs, according to the State Compensation Insurance Fund website. Allergies Some workers who are in the presence of cement regularly develop an allergy (or occupational to the hexavalent chromium in the product. This asthma -like allergy causes breathing difficulty and wheezing. Chromium allergies may also lead to skin rash or skin ulcers, according to the Electronic Library of Construction Occupational Safety and Health website. Inhalation and Dermal Exposure among Asphalt Paving Workers 1. ;11. D. \lrc t_F_ 1\ 1, . 2. R.D.R.1%F;H,IRI?, 3. L. NG©I, 4. E_ A. EISEN 1, 5. K. T. KEt.SE1 ! and 6. R. F. HERRIC 1 Author Affiliations 1. 'Harvard School of Public Health, Boston. MA 02115. USA; 'Occupational Safety and Health Administration, Washington. DC 20210, USA 1. `E-mail: mtrtcctean;ri:hsph.har ard.edu Nett Section Abstract The primary objective of this study was to identify determinants of inhalation and derrnal exposure to polycyclic aromatic compounds (PACs) among asphalt paving workers. The study population included three groups of highway construction workers: 20 asphalt paving workers, as well as 12 tnillers and 6 roadside construction workers who did not work with hot -mix asphalt. During multiple consecutive work shifts. personal air samples were collected From each worker's breathing zone using a Teflon filter and cassette holder connected in series with an XAD-2 sorbent tube, while dermal patch samples were collected from the underside of each worker's wrist. All exposure samples were analyzed for PACs. pyrene and benzo[a]pyrene. Inhalation and dermal PAC exposures were highest among asphalt paving workers. Among paving workers, inhalation and dermal PAC exposures varied significantly by task, crew, recycled asphalt product (RAP) and work rate (inhalation only). Asphalt mix containing high RAP was associated with a increase in inhalation PAC exposures and a 2 -fold increase in dermal PAC exposure, compared with low RAP mix. The inhalation PAC exposures were consistent with the workers' proximity to the primary source of asphalt fume (paver operators > screedmen > rakers > roller operators), such that the adjusted mean exposures among paver operators (5.0 lrgfm3, low RAP; 24 1.tgltn3. high RAP) were 12 €imes higher than among roller operators (0.4 p.glm3. (ow RAP; 2.0 ha/m3, high RAP). The dermal PAC exposures were consistent with the degree to which the workers have actual contact with asphalt -contaminated surfaces (rakers > screedmen > paver operators > roller operators), such that the adjusted !Wean exposures among rakers (175 nglcnY, low RAP; 417 ng/cm'. high RAP) were approximately 6 times higher than among roller operators (27 ng/cm2, low RAP: 65 nglcm'. high RAP). Paving task. RAP content and crew were also found to be significant determinants of inhalation and dermal exposure to pyrene. The effect of RAP content, as well as the fact that exposures were higher among paving Nvorkers than among millers and roadside construction workers, suggests that the PAC and pyrene exposures experienced by these paving workers were asphalt -related. INTRODUCTION Asphalt (or bitumen) is a dark, semi-solid residual that results from the non-destructive distillation of crude petroleum oil and is widely used as an industrial material (Gamble er al., 1999). The annual production of hot -mix asphalt amounts to -267 million tons in Western Europe and -440 million tons in the USA (Partanen and 13offetta, 1994), while the road -paving industry employs ~300 000 workers in the United States and accounts for 87% of domestic asphalt production (Asphalt Institute. 1990). The American Conference of Governmental Industrial Hygienists (ACGIH) cun-ently recommends a threshold limit value for asphalt fumes of 0.5 maim' (benzene -soluble aerosol), while the National Institute for Occupational Safety and Health (NIOSH) recommends an exposure limit of 5 mg/in' (total particulate during any 15 min period). The Occupational Safety and Health Administration (OSHA) currently has no standard for exposure to asphalt fumes. Asphalt contains a complex mixture of polycyclic aromatic hydrocarbons (PAHs). some of which are either known or suspected to be carcinogenic. Because asphalt workers are occupationally exposed to PAHs via inhalation and dermal absorption. the carcinogenic potential of asphalt has been under investigation since the 1960s. In fact, numerous epiderniologicai studies have described an excess risk of cancer (lung. stomach, bladder, leukemia. and non -melanoma skin cancer) among asphalt -exposed workers (Partanen and Botietta. 197-1; Boiretta 1907, 2093). However. the relationship between occupational asphalt exposure and cancer risk remains unclear. Comprehensive reviews of the available literature have been conducted (IARC, 1985; Chia/7e el L. 1991; Partanen er al.. 1995; NIOSH. 2000). These reviews were consistent in their evaluation of existing studies, concluding that the lack of data on exposure and potential confounders (such as smoking and exposure to coal tar) were significant limitations that made it impossible to demonstrate a causal association. Specifically, the existing studies were criticized for weak or absent exposure assessments that lacked quantitative measurements of exposure to asphalt or its constituents. Occupational exposure to PAHs has been shown to be associated with an excess risk of cancer in other populations such as coke oven (Costantinoer al., 1995), foundry (Andjelkovich et al.. 1990) and aluminum production workers (Armstrong et al., 1994). and it is possible that random misclassification of exposure has limited the ability of previous studies to detect a positive association between occupational asphalt exposure and cancer. Accordingly, the risk of work-related cancer among asphalt workers continues to be an important and controversial issue. As an alternative to the more common approach of evaluating inhalation exposure to individual PAHs. this study uses a task -based approach to evaluate both inhalation and dermal exposure to polycyclic aromatic compounds (PACs) among asphalt paving workers. The primary objectives of this study were: (i) to determine whether inhalation and dermal exposures to PACs are higher atnong asphalt- exposed workers than among non -exposed workers; (ii) to identify job factors (i.e. paving task, percent recycled asphalt, etc.) that affect inhalation and/or dermal exposure to PAC: and (iii) to characterize the relationship between inhalation and dermal exposures. freviotrs SectionNe'+r Section MATE 1 AND METHODS Study population The study population included three groups of highway construction workers: 20 asphalt paving workers, as well as 12 millers and 6 roadside construction workers who did not work with hot -mix asphalt. All participants were male, worked for the same company. and lived in the Greater Boston area. Written and informed consent was obtained from each study subject prior to sampling, and all sampling was conducted in accordance with a standardized human subjects protocol that was approved by the Institutional Review Board at the Harvard School of Public Health. The paving workers were exposed to hot -mix asphalt while resurfacing roads. At the job -sites, the asphalt was loaded into the front hopper ofa paving machine while the screed (attached to the back of the paving machine) was used to adjust the thickness and width of the applied mix. The specific characteristics of the asphalt varied by job and contained recycled asphalt pavement (RAP) in amounts ranging from 0 to 40% of the total mix. An alternative to using 100% virgin mix. RAP refers to milled material that is generated during the grinding of old roads. transported to the asphalt plant and recycled into a new batch of asphalt. Each of the three paving crews consisted of six to eight workers who performed four different tasks: paver operators. screednten, rakers and roller operators. The paver operator sat between the hopper and the screed while controlling the path and speed of the paving machine. Two screedmen stood on a platform behind the screed. one controlling the left side and the other controlling the right side. Two to three rakers worked in close proximity to the back of the screed, using rakes and shovels to fill holes and gaps. One or two rolling machines, each with their own operator, were then used to smooth and compact the laid -down asphalt. The milling workers and roadside construction workers were evaluated because the location and nature of their tvork is similar to the paving workers. except that neither group typically works with hot -mix asphalt. The milling workers used a large grinding machine and a smaller trimming machine to remove layers of aged asphalt from existing roads in preparation for resurfacing by the paving crests. tvhereas the roadside construction workers worked with hand tools while repairing guardrails or installing curbs and sidewalks. Study design Personal air and dermal patch samples were collected from 38 workers during Full work shifts at job - sites located within 1 h of Boston, MA. In May and June 1999, three days of exposure measurements were obtained from 20 pavers. In May and June 2000. multiple days of exposure measurements were obtained from 12 millers and 6 construction workers. Due to the repeated -measures design, the total number of `worker -days' evaluated in the exposure assessment includes 60 worker -days for pavers, 39 worker -days for millers and 1 I worker -days for construction workers. Each worker -day of sampling included the collection of personal air samples (particulate and vapor), dermal patch samples and meteorological information. Questionnaire information (including demographic, job characteristics and lifestyle) and detailed observations for each worker were also obtained. Personal air samples were collected from each worker in accordance with. NIOSH Method 5506 (NIOSH. 1998a), The air sampling system consisted of a Teflon filter and cassette holder to collect particulate PACs, an XAD-2 sorbent tube to collect the vapor phase PACs, and a personal air sampling pump operating at 2 lfmin. The 37 nun diameter filter (PTFE -laminated with 2 pin pore size) was placed in a cassette and attached to each worker's lapel near the breathing zone. and the sorbent tube containing XAD-2 was attached inline and downstream from each filter cassette. Flow rates were checked before, during and after sample collection using a calibrated rotameter. Opaque litter cassettes and foil -wrapped sorbent tubes were used to prevent sample degradation from sunlight. Samples were transported in coolers and stored at —20°C. The dermal patch samples were collected from both wrists of each worker. The dermal sampling method was a modification of the method described by Jongeneelen et ca/. (1988) and Van Rooij et al. (1993). A soft polypropylene filter (Gelman Sciences, 47 mm diameter. 10 um pore size) was attached to an exposure pad to create a derrnal patch with an effective surface area of 8.71 cm'. Using an adhesive backing. the patches were attached to the underside of each wrist and resulted in the collection of two samples per worker -day. Following sample collection, the exposure pads were placed in foil -wrapped Petri dishes. transported in coolers. and stored at —20°C. The analytical method for measuring PACs was developed using a modified version of NIOSH Method 5800 (NIOSH, 1998b). NIOSH Method 5800 was initially developed because the individual components of asphalt -related PACs cannot be easily separated or quantified (NIOSH. 2000). For the PAC analyses in this study. the excitation and emission wavelengths (excitation 270 nm and emission 415 nm) were optimized to target the four -ring and larger PACs, a range that includes carcinogenic compounds such as benzo[a]pyrene (BAP), benzo[a]anthracene. benzo[h]fluoranthene, chrysene and d i benz[a,la] anthracene. Particulate and vapor samples were extracted as follows: (1) 4 ml of hexane were added: (ii) samples were sonicated for 1 h; (iii) 2 mi were syringe -filtered and transferred to a clean tube: and (iv) 2 ml DMSO were added for a final extraction volume of4 mi. Dermal patch samples were: (i) cut with a 33.3 rnm punch and each cut out transferred to a labeled culture tube: (ii) 4 int of DMSO were added: (iii) tubes were capped and sonicated for 1 h; (iv) 2 mi of the extract were transferred to a clean culture tube; and (v) 2 mi of hexane were added for a final extraction volume of 4 ml. For all air and dermal samples. the extracted mixtures were `tumbled' overnight, layers were transferred to separate tubes and the DMSO layer was analyzed on the Thigh -pressure liquid chromatograph (HPLC: Hewlett-Packard Agilent Model #1 100) for PACs, pyrene and BAP. Known amounts of PAC, pyrene and BAP were diluted to prepare concentrations of 0, 10, 30. 100, 200, 400 and 800 ng/int. The resulting data produced linear standard curves with intercepts close to 0.0, and r - squared values of -1 (0.97-0.99). Estimated as three times the standard deviation of the field blanks, method limits of detection (LOD) were calculated for PACs (LODai, = 0.2 Ttg/rn3, = 38 nglcm2), pyrene (LOD„ = 0.01 pg/m3, LODdermar— 2.6 n« crn2) and BAP (LODa;, = 0.01 = 0.6 ng/cm2). The total number of field blanks equaled 17% of air samples and 18% of dermal samples. In cases where the mean field blank amounts were significantly different from zero (a = 0.05), the corresponding data were corrected by subtracting the mean field blank amounts from the sample amounts. Data analysis The air and dermal exposure data were analyzed using descriptive statistics. graphic displays, correlation coefficients and linear mixed -effects models. Shapiro—Wilks" tests and graphic displays indicated that the air and dermal data were not normally distributed; however. a log -transformation of the data did result in an approximately normal distribution. Accordingly. all statistical analyses were conducted using the log -transformed air and dermal data. All statistical analyses were conducted using SAS statistical software. and statistical significance is reported at the 0.05 level. One total air exposure estimate was calculated for each worker on each sampling day by adding the particulate and vapor measurements. Similarly, one dermal exposure estimate was calculated for each worker on each sampling day by averaging the left and right wrist measurements. When only one wrist measurement was available. the result from that one sample was used in place of the average. Values less than detection limits were included in analyses as one-half the detection limit. Six individual dermal samples collected from two workers were excluded from the analysis because there was sufficient evidence to suspect that the samples had been contaminated with diesel fuel. Both workers were laborers on the same paving crew who were observed to be deliberately contaminating the dermal patches with fuel. Furthermore, these six patches were visibly discolored due to saturation, and the resulting PAC measurements were orders of magnitude higher than all other samples. Traditional methods of estimating correlation coefficients (i.e. Pearson, Spearman) could not be used due to the repeated -measures design of the study. Use of these traditional methods would erroneously ignore the number of subjects as the correct sample size while instead using the total number of observations as the incorrect sample size, thereby increasing the degrees of freedom (Hamlett el al.. 2003). As an alternative, all correlation coefficients were estimated using linear mixed -effects models as described by Hamlett er al. t2003). Linear mixed -effects models were also used to analyze the inhalation and dermal PAC data by job, by paving task, and to evaluate the other potentially important job factors such as RAP, crew, work rate (tons of asphalt applied per hour) and ambient temperature (°F). The repeated -measures design and use of linear mixed -effects models allowed for evaluation of the fixed effects while estimating between- and within -worker variation. The models used to evaluate inhalation and dermal PAC exposure among the asphalt paving workers can be described as ! Ir',d` ;s''f[I I,. follows: € 1 where .T;,x, represents the exposure level of the rth paving worker on thejth day, and Y„, is the natural logarithm of measurement X„kr. The Rs in the paving model represent the fixed effects for each of the covariates where k = {paver operator,. roller operator, raker, screedman} and f = {crew A, crew B, crew C}. Models were fitted using a compound symmetry covariance matrix and different combinations of fixed effects were evaluated using maximum likelihood (ML) estimation (Wolfinger. 1993). The different versions of the models were compared using Akaike's Information Criteria diagnostic values. and the final model was fit using restricted maximum likelihood (REM L) estimation. Pre% RESULTS Table I presents the summary statistics for the inhalation and dermal exposure data, summarizing the PAC, pyrene and BAP data for paving workers. milling workers and roadside construction workers. Because the data were not normally distributed. the geometric mean. geometric standard deviation and range were used to describe the distribution of the data. Among all workers. BAP was rarely detected above the detection limits in air (LOD = 0.01 pg/m') or dermal samples (LOD = 0.6 ng/cm'). Summary statistics for inhalation and dermal exposure data In air samples collected from paving workers, PACs were detected above the LOD (0.2 Reit') in 97% of the samples. The partitioning of PACs was such that 65% was detected in the particulate phase (filters) and 35% in the vapor phase (XAD tubes). lir the same samples, pyrene was detected above the LOD (0.01 pg/m3) in 98% of samples, and partitioned such that 24% was detected in the particulate phase and 76% in the vapor phase. Inhalation exposure to PAC's was higher among paving workers than among millers (P = 0.007) and roadside construction workers (P e 0.001). In dermal samples collected from paving workers, PACs were detected above the LOD (38 nglcrn2) in 68% of the sarnples, and the PAC measurements from left and right wrists were strongly correlated (r = 0.87, P <0.001). In addition, the results of a Wilcoxon signed -rank test indicated that dermal exposure to PACs was not significantly different between dominant hand and non-dominant hand (P -- 0.2). Dermal exposure to PAC was higher among paving workers than among millers (P< 0.001) and roadside construction workers (P a 0.09). Figure 1 shows the relationship between PACs and pyrene among paving workers. In air samples (Fig. a), there was a strong correlation between PAC and pyrene (r = 0.87. P < 0.001), whereas Fig. 1 b shows a weaker correlation between PAC and pyrene in dermal samples (r = 0.65. p = 0.002). Figure 2 shows the relationship between inhalation exposure and dermal exposure among paving workers. For exposure to PACs (Fig. 2a). the relationship between inhalation and dermal exposure was different among rakers (r = 0. € 5. P = 0.5) than among non -rakers (r = 0.45. P = 0.01). However, for exposure to pyrene (Fig. 2b), the correlation between inhalation and dermal exposure (r = 0.59, P = 0.006) was stronger than for PAC exposure and did not vary by task. Fig. 1. Correlation between PACs and pyrene among paving workers, evaluated in (a) air samples and (b) dermaI samples. View larger version • in OH, [?ace • 11! dicri �t l: p{rn • f Iduaid PC.i111' !.)h)h. View larger version: • Ili this Lavage • Irt a 'too, a tnttwm • Drurtload as P('' crPoint Shde Fig. 2. Correlation between inhalation and dermal measurements among paving workers, evaluated for (a) PAC exposure and (b) pyrene exposure. Table 2 presents the parameter estimates and P -values for all variables in the final paving models evaluating inhalation and dermal exposure to PACs and pyrene. The models evaluated the fixed effects of five variables: task. a categorical variable consisting of four levels (paver operator. roller operator. screedrnan and laborer); crew. a categorical variable consisting of three levels (crew A, crew 13 and crew C); RAP, a categorical variable that was dichotomized as `high RAP' and 'low RAP' using the average RAP of 26% as a cut-off point (using the median RAP of 29% would have resulted in identical `high RAP' and 'low RAP' categories): work rate, a continuous variable representing the tons of asphalt applied per hour; and ambient temperature. modeled as a continuous variable. Ambient temperature was not found to be a significant determinant of exposure and was excluded from the final models. View this table: • hith�s • In 3 neu 1q6,0 Table 2. Results of final models evaluating PAC and pyrene exposure among paving workers For inhalation exposure to PACs among paving workers, the variables task (P < 0.0001). RAP (P = 0.0005) and work rate (P = 0.004) were significant while crew was marginally significant (0.06), such that these variables explained 78% of the between -worker variability and 63% of the within -worker variability. With the exception of work rate, the same variables were found to be significant determinants of inhalation exposure to pyrene. such that the variables in the final pyrene model explained 90% of the between -worker variability and 83% of the within -worker variability. The task - based results for both PACs and pyrene indicated that paver operators were the highest exposed, followed by screedmen, rakers and roller operators. Inhalation exposures to PAC and pyrene were found to be significantly higher when asphalt contained high RAP versus low RAP, and were found to increase as the work rate increased. The variable crew was retained in the model so that the fixed effects of the other job factors could be evaluated while adjusting for crew -based differences. For dermal exposure to PACs among paving workers. the variables task (P= 0.003). RAP (P = 0.03) and crew (P = 0.03) were significant determinants of exposure, such that these variables explained 57% of the between -worker variability and 15% of the within -worker variability. Task, RAP and crew were also found to be significant determinants of dermal exposure to pyrene, such that the variables in the final pyrene model explained 13% of the between -worker variability and 32% of the within - worker variability. As with the inhalation exposures, dermal exposures to PACs and pyrene were also found to be significantly higher when asphalt contained high RAP versus low RAP. The task -based results for dermal PAC exposure indicated that rakers were the highest exposed, followed by screedmen, paver operators and roller operators. The task -based results for dermal pyrene exposure were slightly different in that the screedmen were the highest exposed, followed by the rakers, paver operators and roller operators. Table 3 presents the mean PAC exposure estimates that result from the final models, estimating the inhalation and dermal exposures associated with each paving task while considering the between- and within -worker variability and adjusting for other important determinants of exposure. Since the data analysis was conducted using the norrnally distributed logged data, the mean exposure concentrations were estimated according to Rappaport er vl. (1999): ; t . The task -based inhalation and dermal estimates are stratified by RAP content to demonstrate the extent to which the presence of recycled asphalt increases exposure. Similarly_ results are presented at the median (1 15 tons/h). minimum (55 tons/h) and rnaxirnurn (282 tons/h) work rate values; however, the effect of work rate was only significant for inhalation exposure to PACs. View this table. • In Nit:,,:tdow • In a no., ' ftjOW Table 3. Adjusted mean PAC exposures- among paving workers Previous SectiotnNext Section DISCUSSION The primary objective of this exposure assessment was to identify determinants of inhalation and dermal PAC exposure among asphalt paving workers. Because the majority of existing studies focus on inhalation exposure. we collected both dermal and air samples in an effort to obtain a more complete assessment of total exposure. in coke oven workers, there is evidence to suggest that dermal absorption is actually the primary route of exposure to PAHs (Van Rooii q al.. 1993). In fact, after evaluating pyrene exposure data (inhalation and dermal) and urinary 1-hydroxypyrene data, Van Rooij &i al. (1993) estimated that ~75%a of the total absorbed dose was attributable to dermal exposure. Accordingly, an assessment of PAH exposure that excludes dennal absorption may underestimate cumulative exposure. The dermal data are presented in units of nglcin-, which represents the average amount of PACs that was deposited per square centimeter of exposed skin (at the wrist) during an 8 h shift. As such. these measurements are not intended to represent total dermal exposure. Also. dennal exposures assessed at the wrist may not be representative of exposures at other parts of the body. For instance, the magnitude of 'hand` exposures would probably be higher than wrists, but the magnitude of 'forearm' or 'neck' exposures would probably be lower than wrists. However, the wrist samples do provide a useful tool for comparing dermal exposures across individual workers and across groups of workers. Paving task, crew and RAP content were consistently found to be important determinants of exposure in each of the four models evaluating inhalation and dermal exposure to PACs and pyrene. The mean PAC exposure estimates associated with each paving task varied -12-fold for inhalation exposure and -6-fold for dermal exposure. The task -based inhalation results for PACs and pyrene were consistent with a task's proximity to the primary source of asphalt fume (paver operators > screedrnen > rakers > roller operators), while the task -based dermal results for PACs were consistent with the degree to which each task requires actual contact with asphalt -contaminated surfaces (rakers > screedrnen > paver operators > roller operators). The task -based dermal results were similar for pyrene, although exposures among screedrnen were slightly higher than among rakers. In all four models, we found that the lowest exposures were experienced by roller operators, workers who spend the least amount of time near the source and have the least amount of contact with asphalt -contaminated surfaces. The task -based results for PACs in personal air are considerably higher than those observed by Heikkila er al. (2002), a European study in which the arithmetic mean of total PA Hs ranged from 2.38 gglm' (roller operators) to 4.28 ttglrn' (paving operators). The discrepancy is probably due to the fact that Heikkila et al. estimated total PAH using the stun of 15 individual tnsubstituted PAHs, while the PAC estimates in the present study include all substituted and unsubstituted PACs with at least four rings. Regional differences in asphalt operations may also account for part of the observed differences. The mean exposure estimates associated with each of the three crews varied -2-fold for inhalation exposure (2.2, 3.1 and 5.1 ug/m') and -6-fold for dermal exposure (36, 49 and 219 ng/cm'). Since each crew was measured at different worksites and different days, the variable crew could be serving as a surrogate for any number of factors (e.g. work practice, equipment, unmeasured weather conditions and/or other production characteristics) that have an actual effect on exposure. Regardless of the true cause, the fact that inhalation and dermal exposures vary by crew suggests that crew is an important factor that should be considered when characterizing PAC exposure among paving workers. The mean PAC exposure estimates associated with RAP content varied -5-fold for inhalation exposure and -2-fold for dermal exposure, such that RAP content was a significant determinant of inhalation and dermal exposure. It is unclear whether these increases in exposure actually result from the RAP material or from the higher temperatures required when RAP is added to a new batch of asphalt. The temperature of the asphalt mix was not measured during sampling and therefore could not be evaluated in the exposure models. However. since RAP is specifically a characteristic of the asphalt mix, the fact that RAP content was a significant detenriinant of exposure in all four exposure models suggests that the PAC and pyrene exposures among paving workers were asphalt-related. Work rate was calculated as the tons of asphalt applied per hour during a full shift of work in an effort to compare workdays of varying work intensity. Some days were observed to be considerably busier or slower than other days, since the pace of work was often slowed due to the delayed transportation of asphalt mix from the asphalt plant to thejjobsite. Increasing work rate was found to increase inhalation exposure to PACs, although work rate was otherwise not a significant determinant of exposure. The ability to evaluate the effect of ambient temperature on inhalation and dermal exposure was limited by a fairly narrow range of ambient temperature measurements (65-76°F). Although initially included in the exposure models. ambient temperature did not have a significant effect on inhalation or dermal exposures and was excluded from the final models. The temperature of the asphalt would probably have been a more useful measure as a potential determinant of exposure. inhalation and dermal exposures to PACs were higher among paving workers than among millers and roadside construction worker. The increased exposure can be attributed to working with hot-mix asphalt. since pavers, millers and roadside construction workers otherwise have a similar potential for exposure to PACs. Millers were probably exposed to PACs during the grinding of old asphalt roads. while roadside construction were probably exposed to PACs in roadside soils while installing curbs. guardrails and sidewalks (Tuhackova et 61.., 2001). However, such exposures may have resulted in under estimating rather than overestimating the portion of exposure that is attributable to working with hot nlix asphalt. The manner in which dermal exposure to asphalt-related PACs occurs is unclear. Dermal exposures may result from direct contact with asphalt-contaminated surfaces, such as hand tools and/or equipment controls, the settling of airborne particles and/or the condensation of vapor. Among paving workers. Burstyn Ear al. (2002) found inconsistent patterns between airborne organic matter and organic matter collected on cotton pads, although it is likely that the sample size (n = 7) and the use of different solvents to extract organic matter from dermal pads and filters limited their ability to evaluate the correlation. We found that the correlation between inhalation and dermal PAC exposure was stronger for non-rakers than for rakers, which is probably related to the fact that the rakers have the highest potential for direct contact with asphalt-contaminated surfaces; however, even among non- rakers the correlation was relatively weak (r = 0.45, P = 0.01). The correlation between inhalation and dermal exposure was stronger for exposure to pyrene (P = 0.59. P = 0.006), suggesting that dermal exposure may be more likely to be associated with airborne levels for lower molecular weight compounds. I'reN. ions SectionNexi Section CONCLUSIONS The task performed by a member of a paving crew was found to be the most important determinant of inhalation and dermal exposure to PACs. The task -based inhalation exposures were consistent with each task's proximity to the primary source of asphalt fume (the hopper). while the task -based dermal exposures were consistent with the degree to which each task requires actual contact with the asphalt - contaminated surfaces. In addition. inhalation and dermal exposures were significantly higher when the asphalt contained high RAP compared with low RAP, suggesting that the PAC exposures experienced by these paving workers were asphalt related. Similarly. inhalation and dermal PAC exposures were higher among paving workers than among millers and roadside construction workers, further suggesting that the higher PAC exposures were attributable to asphalt. • 0.` 4 A r toe . 1 Dust from Airport Dust from Airport Same day -no dust on Bedrock property 6howin: wind and lack of •usi Dust at Airport Dust at airport _ ir4 r 11 K If A pus ram Ea: a S•rin: V1 ttOL. O. eaW 0 11)0 .47-11 fa w Q G c 10) CO Q . Looking at Bedrock property/adjacent residence . - Open burning on pad sites near residence