"...As determined by the Air district, cement kiln tire burning has been proven to increase substantially emissions of numerous toxic chemicals including benzene, nitrogen oxides, furans, lead, chromium, cadmium, and mercury, among others... In fact, the Air District has data that the emissions of dioxins would increase by almost 100% and lead would increase by 1000%..."(details...)

"...In the most thorough assessment of the hazards of dioxin yet undertaken, the U.S. EPA’s scientific advisory panel concluded that dioxins are more dangerous than previously believed and pose not only a risk of cancer but also a risk of disrupting reproductive processes (U.S. EPA, 1993)...). Although the temperature and residence time are high in cement kilns, optimizing cement production dictates using the minimum amount of oxygen needed to produce the cement ‘clinker.’ These oxygen levels might not achieve adequate combustion efficiency to fully burn the tire fuel..."(details...)

Background: One year ago, in August 2001, CEMEX/Southdown and the North Boulder County Task Force initiated a Memorandum of Understanding with the community constituting "...a non-binding Agreement among signatory parties to pursue a collaborative working relationship to improve health, environment, and quality of life in the St. Vrain Valley..."
The Watchdogs ask that CEMEX/Southdown abide by the spirit of this agreement and not pursue their Tire Derived Fuel (TDF) proposal.

CEMEX representatives stated at the Community Meeting on July 17, 2002, that TDF would save them approximately $500,000 per year in fuel costs. Did they also factor in their reimbursement for taking the tires?

"... After the merger with Southdown, CEMEX will have annualized combined sales in excess of US$6.3 billion pro forma as of June 30th 2000. ..." (details...)

Dr. William Marine
President, Board of Health
Boulder County Health Department
3450 Broadway
Boulder, Colorado 80304

June 17, 2002
Dear Dr. Marine,

I am writing to inform you of a questionable situation that is taking place in Boulder County that could have a serious impact on the environment and the public health.

On Sunday, June 2, 2002, John Lohr, plant manager at Cemex-Lyons, announced to the press that his facility intends to test-burn tires as fuel for its kilns. This announcement appeared as a news story in the Longmont Times-Call. (A copy of the article is enclosed.) Four day later, at a meeting of the North Boulder County Environmental Task Force, Mr. Lohr again announced Cemex’s intent to start test burning tires at the plant. Although Mr. Lohr apologized for the manner in which this fact leaked out, I remain extremely disappointed that all parties had been kept in the dark about the company’s plans.

We are alarmed at the possible consequences of this action. Least of all, this activity and the way in which it is being handled is not in keeping with the spirit of the Memorandum of Understanding that you and Mr. Lohr and I signed on August 13, 2001 agreeing “to pursue a collaborative working relationship to improve the health, environment, and quality of life of the St. Vrain Valley.” Most alarming, the well-being of this environment and its residents may be threatened once again. I requested that Mr. Lohr prepare and distribute educational materials on tire burning so that citizens in the County can be informed prior to the onset of any burning.

The Watchdogs have been gathering information regarding “tire burning in cement kilns.” What we have discovered so far leads us to believe that Cemex’s project may pose a threat to public health and the environment. John Lohr and I discussed tire burning more than a year ago. It was Mr. Lohr’s viewpoint-then-that the plant would not burn tires. At that time, however, the company was called Southdown. Now the company is Cementos de Mexico, (Cemex) and as of June 12, 2002, Cementos de Mexico has permits or authorizations to burn hazardous waste as fuel in 11 of the 18 plants in Mexico. Cementos de Mexico operates in a country with notoriously low environmental standards, and now that company wants to bring those burning practices here to Boulder County.

The Watchdogs respectfully requests the Boulder County Board of Health to:

Be adamant about safeguarding our health, environment, and quality of life. Provide educational resources and appropriate assessments of the hazards of tire burning prior to the commencement of any tire burning.
Provide staff to assist in addressing concerns expressed in future community discussion groups.
Fully assess the health risks, hazards, and environmental impacts of tire burning prior to the onset of any burning.
Assess the differences in emissions between the current practices of fuel burning and the proposed change to include the burning of tires.
What have been the problems in other communities in which tires have been burned as cement kiln fuel?
Does tire burning open the door to the burning of any other solid or liquid waste? (The USGS includes tires in the category of waste along with undefined other solids and liquids.)
The Watchdogs feel that the manipulative manner in which Cemex’s “tire-burning” project is being forged may greatly stress this community, and may compromise the spirit of cooperation that was so difficult to attain. People are already asking hard questions like, how many more truck-trips will Cemex-Lyons need in order to transport 700,000+ tires a year. (Please note that the Boulder County Commissioners recently restricted the number of truck trip permitted to Lafarge’s gravel operations in this community in order to maintain safety standards on our roadways.) Where are the tires going to be stock piled? What happens when tires are burned? What gets released at the stack? Are heavy metals, styrene, dioxins or other toxins present? What will happen to property values? Mr. Lohr spoke at the meeting of the Task Force about reducing the stockpile of used tires around the country as a service. But, I haven’t met anyone yet who would be willing to put his or her health at risk so that Cemex-Lyons can reduce this stockpile. There are many other effective and wise ways to recycle and reduce the stockpile of used tires.

We strongly feel that it would be in the best interest of the Health Department, the County, and the public for Cemex-Lyons to postpone indefinitely any test burn until appropriate public education has been completed, and until we have had an opportunity to discuss compliances, violations, and safeguards with the Air Quality Control Commission and other appropriate regulatory agencies.

We respectfully request immediate assistance of the Boulder County Health Department in directing Cemex-Lyons to delay the test burn.

The Watchdogs have persevered relentlessly for four years in our campaign to contain fugitive dust emissions from the cement plant; to secure a proper disposal plan for cement kiln dust so that it would not be released into the atmosphere and water shed; to persuade the company to install a truck wash so that cement spills on the tops of transports would be removed before the trucks entered traffic on Highway 66; to insure that traffic on Highway 66 is maintained at a reasonable level; to seek solutions to poor housekeeping practices at the cement plant; and to ferret out reasons for the cracks in the regulatory process. Enormous progress has been made. Complaints about air quality have been quieted; and residents are grateful to the Watchdogs, the Task Force, the Boulder County Health Department, the Colorado Department of Public Health and Environment, the press, the County Commissioners, Senator Campbell, Representative Saliman, John Lohr, the employees at Cemex-Lyons, and many others.

This tapestry of success may be about to take a giant step backwards in the interest of Cemex-Lyons saving money on fuel bills at the expense of our lungs and our health and the good will we so laboriously built. Is Cemex-Lyons courting the State and public by claiming that the company wants to help Colorado reduce the stockpile of tires? Does Cemex-Lyons truly believe that we will sit in silence while the company burns waste that may be hazardous? We have witnessed, through the Task Force, that a model of cooperative effort between citizens, government, and industry is possible. Cementos de Mexico; however, is far removed from Boulder County geographically; far removed from the magnificent St. Vrain Valley with its legacy of geological and ecological treasures. Cementos de Mexico appears arrogant and uncaring by venturing into its tire burning project without providing even a single paragraph of information to the public.

We all remember the terrifying story of the family in the St.Vrain Valley who had to keep the windows of their house closed for ten years because fugitive cement kiln dust was entering through the windows. We remember, too, how thankful this family was when the fugitive dust was appropriately contained and appropriately regulated, thanks to the Watchdogs and the Task Force. Let’s not go gently into this situation allowing Cementos de Mexico to manipulate this family and the rest of us in Boulder County into harm’s way again.

I sincerely hope that this questionable situation of tire burning at Cemex-Lyons may be resolved in a speedy and cooperative manner, and I hope that the Health Department and the Task Force and Cemex-Lyons may abide by the spirit of the Memorandum of Understanding:

“To work for the benefit of the general public”


Sincerely,


Richard Cargill
Executive Director
St Vrain Valley Community Watchdogs


Cc: Chuck Stout, Executive Director, Boulder County Health Department
Jeff Zayach, Director, Office of Environmental Health, Boulder County
Jane Norton, Executive Director, Colorado Department of Public Environment
North Boulder County Environmental Task Force
St. Vrain Valley Community Watchdogs’ Steering Committee
Watchdogs’ web-site: www.stvrainwatchdogs.org
Press