Nature Coast Conservation, Inc. Neighbors Against Mining Project

Nature Coast Conservation, Inc.

Neighbors Against Mining Project

222 East Liberty Street

Brooksville, Florida 34601

September 22, 2015
David Read, Environmental Administrator

Florida Department of Environmental Protection

Division of Air Resource Management, Office of Permitting and Compliance

2600 Blair Stone Road, MS #5505

Tallahassee, FL 32399-2400

Via personal delivery to Mr. David Read at FL-DEP open house in Brooksville on Sept. 24

Re: Draft/Proposed permit # 0530021-054-AV CEMEX Construction Materials Florida, LLC, Brooksville, Florida.

Dear Mr. Read:

We take this opportunity to raise new issues not previously addressed, expand on issues raised earlier and provide you with hard copy documentation for the comments submitted to you on August 7^th, 2015, during the public comment period for the above-referenced proposed CEMEX permit.

We recognize that the 8-month and 12-month time periods for this proposed permit will require that a new permit be issued before these time periods expire next year. During the next permitting period, we hope that the State of Florida will have progressed in the development of a clean energy plan according to the criteria of the President Obama’s Clean Power Plan to reduce emissions. We encourage the Florida Department of Environmental Protection to play an active part in adopting and implementing such a clean energy plan as soon as possible so that it can be applied to the CEMEX South Brooksville Cement Plant.

Most importantly for the permit at hand, we hope it will promote clean renewable energy and replace dangerous coal-burning, tire-burning and biomass plants such as the ones currently allowed at the CEMEX South Brooksville Cement Plant. We raise this issue now so that you are aware that citizens of Hernando County do support the adoption of cleaner energy standards that do not threaten public health as the existing CEMEX plant currently does.

To document our health concerns, we attach a copy of the 2015 County Health Rankings Florida and direct your attention to page 3 where Hernando County is ranked 52 of 67 counties and included in the second lowest ranking for health outcomes. Also attached are select pages from the long report entitled Florida Health: Burden of Asthma in Florida dated September 2013. Please note on page 27 that Hernando County is 10^th highest statewide for Current Adult Asthma rates, page 31 that shows Hernando as 4^th highest for Lifetime Adolescent Asthma, page 35 showing Hernando as 3^rd highest for Current Adolescent Asthma, and the conclusion on page 80 that cites “environmental control” as one of the ways to manage asthma.

See attached an article published on April 15, 2015 entitled “Fine Particle Exposure liked to Brain Damage in Older Adults.” This long-term study found that “Exposure to air pollution is associated with insidious effects on structural brain aging, even in dementia-and stroke-free individuals” and “The systematic inflammation resulting from the deposit of fine particles in the lungs is likely important.”

How does Hernando County compare to other counties for smog and particulates? See attached chart from Scorecard, the online pollution information site that ranks Hernando among the Dirtiest/Worse Counties in the U.S. Hernando County is in the 80% highest rates for carbon monoxide and sulfur dioxide emissions, and in the 70% highest for nitrogen oxide and volatile organic compound emissions.

The attached online RTK NET CitySearch for Toxic Pollution from large, currently operating sources reveals that for the reporting year 2013, our Congressional District 11 accounted for 3,900 pounds of a total of 14,166 pounds of on-site releases of chemical pollution. That’s 28% of the statewide total. CEMEX is listed as the second highest producer of these toxic releases at 3,861 pounds of releases for cement manufacturing after Sparton Corporation with 6,910. Biomass Electric Power Generation accounted for an additional 3,395 pounds of release.

Reports on the FL DEP website include the attached report entitled Emission Sources: Facility Search Results of annual emissions for the CEMEX Cement Plant. It shows that in 2014, hundreds of tons of emissions were released into the air in Hernando County. A second report entitled Florida AOR Data Search (FADS) Facility Detail Report (annual emissions, tons per year) reflected figures for the past five years. The cumulative volume of such emissions is daunting.

Among the dangerous fuels employed at that plant are tires. See attached report from Earth Justice entitled What is “Tire-Derived Fuel” and why is it dangerous? It states that “It is common knowledge that burning tires in the open is extremely harmful to human health and the natural environment. The fumes emitted are packed with the many toxic chemicals that tires contain (including volatile organic compounds such as benzene, metals such as lead, polycyclic aromatic hydrocarbons such as benzo(a)pyrene, and synthetic rubber components such as butadiene and styrene). Certain metals present in tires (such as copper, iron, manganese, nickel, sodium and zinc) serve as catalysts for dioxin formation, providing a surface on which dioxins can readily form during and after the combustion process. It is the likely reason why burning tires with coal has been found to produce more dioxin pollution that burning only coal. The chlorine content in tires leads to the creation of dioxins and furans (which are extremely toxic chemicals) when tires are burned.

The report goes on to quote Dr. Seymour I. Schwartz, a professor of environmental science and policy at the University of California at Davis. “Virtually nothing is known about the dose-response functions for important categories of health effects, particularly disruptions of hormone systems of humans, which could produce life long damage in developing infants. Also, virtually nothing is known about the health effects caused by combinations of toxic chemicals that are emitted when burning tires. Without such scientific knowledge, and because some toxic pollutants increase from burning tires, there is no scientific basis for the Board to conclude that burning waste tires in cement kilns is safe.”

Added to the sheer volume of emissions that are allowed is the fact that the CEMEX South Brooksville Cement Plant has exceeded regulations for mercury emissions 19 times since 2002, yet is still allowed to operate within a six mile radius of every resident of our county seat, Brooksville, and has not been required to remediate even one such incident. See attached list of 18 enforcement cases from 2002—2012, plus see the Consent Order and email from Ana Gibbs describing a 19^th event that occurred in 2013. That final consent order was not finalized until a few months ago and included approximately 80 hours of possible emissions that violated air quality standards for mercury and two failure to report events. A paltry fine of $2500. was levied for this egregious continuing violation that went unreported for about a month.

These statistics and reports document the extensive legal and illegal aerial pollution emitted in Hernando County from the CEMEX South Brooksville Cement Plant. Coupled with the health reports documenting high levels of asthma and low health outcomes rankings for Hernando County, and the published dangers of burning coal, biomass and tires, you can easily understand why so many are deeply concerned about the continued operation of this plant. There is no comparable source of aerial pollution in the county that would account for such poor health outcomes.

In addition, the existing CEMEX South Brooksville Cement Plant operation includes several large sludge ponds that pose an environmental risk that can contaminate local water supplies. See attached report from Duke University entitled Radioactive Contaminant Found in Coal Ash. The study found that “Radioactive radium and lead-210 ends up concentrated in these tiny particles of fly ash, which though individually small, collectively comprise the largest volume of coal ash waste going into holding ponds and landfills.”

How long will CEMEX be allowed to expand these dangerous sludge ponds before clean-up is begun? This area is rich in natural springs that are vulnerable to groundwater contamination that could likely affect fresh water wells and drinking water supplies.

In conclusion, we urge you to take a skeptical view of renewing this permit as currently drafted to allow the coal-burning and biomass plants to continue to operate. The dangerous volume of aerial pollutants permitted and the existing record of poor health in this community, coupled with the knowledge that the release of particulate matter is associated with such poor health impacts has raised considerable community concern that has been expressed in numerous comments. Citizens attending the open house on September 24^th will no doubt add to that record of opposition to this plant’s continued permitting as it is currently proposed. At a minimum, we hope these concerns will be addressed in the development and permitting incorporating the new Clean Power Plan in coming years. Thank you for the opportunity to submit this additional content to the record of this proceeding.

Very truly yours,

DeeVon Quirolo

President

Enclosures per above