Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from...

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Asphalt Plant on Taft Hill Road May 14, 2014

Transcript of Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from...

Page 1: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Asphalt Plant on Taft Hill Road

May 14, 2014

Page 2: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

More than 7,000 residents

Six schools with more than 2,500

children

Lincoln Middle School just ½ mile

Poudre Bike Trail where 10,000 people

pass each month just 290 feet

Toxic fallout from asphalt production drops

within 2 miles of the facility

Page 3: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Who Permits Asphalt Plants?

Colorado Department of

Public Health & Environment

CDPHE Mission

The mission of the Air Pollution Control

Division is to improve and protect the air

quality in Colorado through the

development and implementation of cost-

effective and efficient air pollution control

measures that are consistent with the

requirements of state and federal law. Taken from CDPHE website

Page 4: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Most HMA plants

are inspected every

3 to 5 years, while

others are

inspected annually.

..violation or

noncompliance

issues leads to

enforcement

proceedings and

fines of up to $15,000

per violation per

day…

Page 5: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Permit Renewal Requirements

• Inspection required every 3 years

• Permit renewal required every 5 years

Page 6: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Where in the World

• Longmont

• Empire

• Fort Morgan 1997

• Permit approval Denver

• Production 230,590 tons/yr

• Fort Morgan 1998

• Fort Morgan

• Akron, Co

• Gordon Pit, Denver 1999

• Permit renewal Denver

• Production 235,590 tons/yr

• La Plata County, CO

• Elbert County, CO

2000

Page 7: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

• Washington County, CO

• Huerfano County, CO 2001

• Name change from Western Mobile to LaFarge

• Nebraska 2002

• Permit reissued, no inspection

• Nebraska

• Logan County, CO

• Craig, CO

• Rifle, CO – Opacity Violation due to High Heat CDOT requirements

2003

Page 8: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

• Rifle, CO

• Keenesburg, CO 2004

• Keenesburg, CO

• Kit Carson, CO

• Weld County, CO 2005

• Fruita, CO

• Pueblo, New Mexico 2006

• Albuquerque, New Mexico

• Permit renewal required

• Permit renewed, no inspection due to being out of state

2007

Page 9: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

• 1800 North Taft Hill, Fort Collins 2012

• 1800 North Taft Hill, Fort Collins

• June – Inspection, application for stationary plant

• October – New Permit Issued

2013

• Phoenix, Arizona

• 1800 North Taft Hill, Fort Collins (December)

2010

• 1800 North Taft Hill, Fort Collins

• March – Start-up 2011

May 2014 – Still operating at 1800 North Taft

Hill, Fort Collins, Over 3 years later

No

New

Permit

Issued

until

October

2013

Page 10: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

June 2013 Inspection

At this location for 2+ years?

Page 11: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Not remain

at any one

site for

more than

two (2)

years

Page 12: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

• No State/County production records after 2000

until the June 2013 inspection

• State regulations require production records

• Production determines levels of pollutants

We asked for Production

Records History of Plant

Page 13: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Recap

• Plant moved next to schools and neighborhoods

• Plant operated for at least a year without a valid permit

Page 14: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

• “ ..seek to avoid locations in close proximity to

pollution sources”

• Lincoln Middle School situated in 1974 at an ideal

environmental location

• Schools would not have been built next to an

asphalt plant

Page 15: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Amended Special Review 3/23/09

“to change location of asphalt plant”

Special Review originally granted permission July 22, 1985

Page 16: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

• No evidence of an asphalt plant ever being

established on the property in County and State

records

• No visual evidence of an asphalt plant from aerial

photos

Prior to 2011 There Never Was an

Asphalt Plant on Taft Hill Road

1999 Aerial View

Page 17: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

In 2009 Review Staff States:

1. “Proposed use is compatible with existing and allowed uses in the

surrounding area and in harmony with the neighborhood.”

2. “The proposed use is not anticipated to have substantial adverse

impacts on property in the vicinity.”

3. “Approval of the appeal will not be detrimental to the public health,

safety or property values in the neighborhood.”

Page 18: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

0.34 Mile

0.53 Mile

Lincoln Middle School

Neighborhoods

Poudre Bike Trail, 290 Feet

Taft Hill Plant sits low in a hollow Top of stacks sit lower than neighborhoods & schools

Prevailing winds are from north and northwest

Page 19: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Asphalt disasters like this happen.

What is the plan for the six schools with 2,500 students,

the 7,000+ local residents and the Poudre River?

Page 20: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

MODEL

8 hour CO

9,933ug/m3

NAAQS

8 Hour CO

10,000ug/m3

Model is

within 1% of

max

Model for 475,000 Tons per year

Fence line only 87 meters from stack

Page 21: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

20% more Carbon Monoxide

Model for 600,000 Tons per Year

Page 22: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Message to: Larimer County Commissioners,

“This is detrimental to Public Health!”

For the past 3 years

this plant has had a

permit that exceeds

National Ambient Air

Quality Standards for

Carbon Monoxide.

Page 23: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

CDPHE Mathematical Model for

Carbon Monoxide Dispersion

Why? Winter

Why? Not Arid Climate

Why? Moisture Normal

Why? Rural

Why? Background sample from Downtown Fort Collins

Page 24: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road
Page 25: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Trucks are not

included in the

CDPHE air

dispersion

model

Trucks like this emit:

10g/mile - NOX

0.22g/mile – PM2.5

0.25g/mile – PM10

Lower levels of CO

than gasoline

Higher emissions with

acceleration and

deceleration (along

city streets and up

hills)

Page 26: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Quote from CDPHE “…there are CO emissions associated with the trucks used for this

business that we have not modeled in this screening analysis.

Measurements from downtown Fort Collins would account for

higher vehicle emissions. Absent any data collected at this facility,

it makes sense to continue to use the CO value in Nancy’s ABC

background layer.”

Page 27: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

On Friday, May 9, 2014 from 7AM – 6PM

308 truck trips to and from Asphalt Plant

634 total truck trips to and from Asphalt Plant and adjoining Aggregate Facility

CAAT Study 5/9/14

Page 28: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Congratulations!

You do not need to

be regulated.

“speaks well of the

environmental

accomplishments of the

industry”

SERIOUSLY?

Page 29: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

CDPHE & Asphalt

Industry….

Working Together.

How does this

protect the public’s

health?

Page 30: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Asphalt plants listed as major polluters in 2001

Asphalt plants minor in 2002 due to industry pressure

This plant will produce: 15 tons of VOC’s

16.5 tons NOX

11.4 tons of CO

7.4 tons of SO2

Minor polluters are still polluters just

not highly regulated.

Page 31: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Causes of Ground Level Ozone

Hot sunny days

VOC’s + NOX + SUN = Ozone

Page 32: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Air pollution contributes to

development of asthma in

previously healthy people

What triggers asthma?:

Particulates - TRUCKS

Ground level ozone

Sulfur dioxide

Nitric Oxide

Advice on avoiding asthma Avoid exposure to air pollution

“Take any steps you can to ensure new schools and housing is not near

industrial areas”

Natural Resources Defense Council

Page 33: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

At ground level,

ozone is a health hazard

for all of us, especially the

young and elderly.

Active and exercising

Prolonged exposure:

reduced resistance to

lung infections and colds

Triggers asthma or other

respiratory infections like

chronic bronchitis and

COPD

Page 34: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Asthma

Natural Resources Defense Council

25 million Americans have asthma

3,000 die each year

No cure

Page 35: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Asthma

10 million lost school days/year

14 million lost workdays/year

2 million ER visits/year

30% of childhood asthma due to environmental exposure

Center for Disease Control

Page 36: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Advice on Avoiding Asthma

Avoid exposure to air pollution

“Take any steps you can to ensure new schools and

housing is not near industrial areas”

Natural Resources Defense Council

Page 37: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

2007 Fort Collins

Ozone Non-attainment Area

Fort Collins West violates health standard

past six years

– Site located at La Porte/Horsetooth

– More out of violation than any other Fort

Collins location – Why?

Page 38: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Air above ground warmer than air below

Typical summer morning in Fort Collins

Pollutants are trapped at ground level

Cold air flows down from higher ground

Pushes under warm air rising from the valley

Page 39: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

CDPHE Modeling

Doesn’t address that the plant is located in hollow.

Doesn’t address overall inversion effect from foothills.

Doesn’t address wind direction.

Doesn’t address truck traffic.

CDPHE needs new leadership.

We have no confidence the Department is

fulfilling their statutory duties.

Page 40: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Martin Marietta December 2012

Form 10-K Annual Report

Environmental risk due to the use of “substances

that are hazardous”

“the Company frequently acquires large tracts of

land so that quarry, mine, and production facilities

can be situated substantial distances from

surrounding property owners.”

Page 41: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Neighborhood to

West about 1 Mile

No Neighbors to

East for Miles

No

Neig

hb

ors

to S

ou

th

for M

iles

No

Neig

hb

ors

to N

orth

for

Mile

s

Connell Plant

Harmony & I 25

Fort Collins

Page 42: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Permit Expectations

1. Stack testing for all relevant pollutants including

VOC’s and heavy metals

2. Limited hours – no emergency, no weekends – to

make sure a plant can never operate 24/7.

3. Require EPA compliant opacity monitor installed

4. Publicly accessible website with time-laps video

showing asphalt & aggregate production

Page 43: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

5. All planned pollution control technology be

included as permit requirements with specified

timeline.

6. Third party oversight of record keeping

7. Specification that plants are located safe

distances away from schools and populated

areas.

Page 44: Asphalt Plant on Taft Hill Road - Fort Collins, Colorado No visual evidence of an asphalt plant from aerial photos Prior to 2011 There Never Was an Asphalt Plant on Taft Hill Road

Lincoln Middle

School is ½ Mile

from Plant

Would you let your

children or grandchildren

go to Lincoln Middle

School?