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Dick Bennet has put together excellent talking points. This is a good starting point to help you craft your own response. It is a long read however it is well worth the time. It is not intended as a copy and paste piece. As Mr. Bennet says "... We need to convince the county to extend the deadline on comments and preferably schedule a public meeting. "
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The following is submitted in accordance with request for comments by Jefferson County DCD pertaining to the subject application.
The following outlines issues, concerns and questions relative to the application.
Air & Particulate Pollution
About 15% of the concrete mixture is cement and use of cement creates health hazards. According to the EPA, cement & concrete plants are significant sources of nitrogen oxide, sulfur dioxide, carbon monoxide and hydrocarbons which are associated with certain health and environmental impacts.
Nitrogen oxide can cause or contribute to a variety of health problems and adverse environmental
impacts, such as ground-level ozone, acid rain, water quality deterioration, and visual impairment.
Sulfur dioxide in high concentrations can affect breathing and may aggravate existing respiratory and cardiovascular disease. Carbon monoxide can cause harmful health effects by reducing oxygen delivery to the body’s organs and tissues, as well as adverse effects on the cardiovascular and central nervous systems.
There are multiple studies that report the batch plants are extremely dusty and issue respirable dust particulates that lead to many health complications, including lung function impairment (carcinoma of the lungs and colon, chronic obtrusive lung disease, pneumoconiosis and restrictive lung disease.
Cement dust can enter the systemic circulation and get to body organs such as the liver, heart,
spleen, muscles and this affects the performance of the physiological and microstructure.
Portland cement contains carcinogens such as chromium and free silica, the inhalation of cement
dust can cause respiratory tract cancers. Studies of cement plant operations have detected crystalline compounds including the metals Al,Ca,, Fe, Mg, Na, and K.
Studies of cement plant health impacts conducted in Italy, Texas and Korea showed an association between the exposure to plant emissions and the risk of hospital admission for cardiovascular or respiratory causes. A review of 1491 studies on the health effects of cement plant exposure found positive associations between cement plant exposure and respiratory diseases and symptoms. An excess risk of cancer incidence and mortality in both children and adults mainly concerning respiratory tract cancers was also reported in some studies.
Many scientific studies recommend that cement plants be at least five miles away from residences.
These emissions do not include the results of fuel combustion emissions by products from trucks,
generators or other equipment.
Has an air permit been granted by the Olympic Regional Clean Air Agency? If so, please share it with the surrounding communities around the proposed site.
What methods will be used to remove particulate matter and dust from roads and other paved areas to mitigate particulate matter that has been deposited in one place, and then liberated into the ambient air by vehicular travel, wind, or other causes?
How are stack emissions from silos, batchers, and other confined storage and conveying equipment to be controlled?
Other than dust bags, what other actions will be initiated to reduce airborne particulate matter?
The Gardiner community frequently receives high winds from both the Northwest and Southeast.
What types of barriers, wind breaks, etc. will be used to mitigate wind disbursement of particulate
matter and aggregate dust into the community?
What are the planned periods for cleaning/replacing the dust bags? How will the dust bags be
disposed of and to where?
How is the operator going to control unconfined emissions from hoppers , conveying equipment, droppoints, truck loading and unloading, roads, parking areas, stock piles and yards?
What, if any, environmentally safe dust-suppressant chemicals are to be used to control emissions?
Where will visual tests of silo dust emissions be conducted?
How often will tests be conducted for visible emissions and what type of EPA test will be used?
The U.S. Environmental Protection Agency requires TRI (Toxic Release Inventory) reporting by the
plant operators to estimate how much toxic pollution they released over the course of a year. Will this information be released to Jefferson County and to the Gardiner community?
Tier II Reporting (also called Community Right-to-Know or EPCERA Reporting) requires the operator to advise Jefferson County, emergency responders, neighbors and community to know what is stored on site. At what point does the operator plan to release that information?
Water Pollution
The plant operator plans to use water from a private well as the source of water for plant batch
operation and water washdown .
Water run-off from cement plant operations and wash out water are highly alkaline which can cause water pollution. Cement contains a number of potentially toxic chemicals including chromium which is particularly toxic for watercourses and to groundwater.
Trucks, hoppers, mixers and pumps must be washed out in a contained area and be located away
from any watercourses or drainage channels to prevent accidental escape of liquid or slurries to the water environment. Measures must be installed to control, store, treat cement wash water arising from the operation on site.
Wash down water arising from the washing of equipment that has come in contact with the cement
must be collected in an impervious container. Water washdown must not be used for wheel washes or dust suppression purposes.
The batch plant is to be located above the existing Gardiner drinking water well. Measures must be taken to absolutely prevent any discharge of effluent or water to the groundwater.
What actions are being taken to prevent toxic water from entering either the operator's well or Gardiner's public water well or infiltrating the ground water source of Gardiner’s drinking water well located immediately below the proposed site?
What actions are being taken to guarantee that any toxic water runoff will be prevented from escaping the site and leaching into the groundwater?
What notification and communication has occurred with the Jefferson County PUD? Have they been made aware of the proximity of the site to the Gardiner Community well that provides the public water source?
If water is used for dust suppression how is any runoff and groundwater entry controlled?
What will be used to enclose or mitigate emissions at the drop point to the truck (e.g. spray bar,
chute, or partial enclosure)?
How frequent will water testing occur in the water settling ponds to determine the level of toxicity and who will conduct the tests?
How will wash water from equipment be captured and contained? Will the contained wash water be treated?
How will the sediments from the settling tanks be contained and disposed of and where will it be
transported for disposal?
Further, the plant is located above the existing Eagle Creek, a potential salmon migration source
which a considerable amount of tax dollars was spent to protect by the installation of an enlarged
conduit to enable better migration of the salmon.
What is planned to guarantee that effluent and wash water does not enter this watercourse?
Has Jefferson County or the plant operator notified the SKlallam Tribe in Blyn of potential impacts to Eagle Creek which crosses tribe property prior to flowing below the proposed plant site?
Fire Risk
The contractor plans to use dust bags to collect dust and particulates. Dust and storage bags are
made of combustible material that can easily catch and spread fire. If the dust bags are not cleaned or replaced in a periodic timely manner the dust bags become highly combustible and can ignite a fire. Dust explosions, static electricity, spontaneous combustion, and high-temperature materials passing through the bag filters can cause fire.
In recent years the Gardiner and Diamond point communities have experienced significant drought
periods and elevated fire risks. The proposed site and community is surrounded by forested and
highly vegetated areas. A fire during these conditions would quickly become a wildfire endangering
the entire community.
What fire prevention and fire suppression measures are available at the proposed site?
Has Clallam County Fire District 3 been informed by Jefferson County of this project? CCFD 3 is
responsible for responding to Gardiner fires and emergencies.
Light Pollution
What are the hours of operation for the plant? One document said the proposed hours of operation
were to be 7am to 10 pm. This will require wide area lighting for the plant during darkness.
What type of lighting will be used? What actions will be taken to prevent light pollution leaking into the neighboring residential areas during the nighttime?
Noise & Traffic Impacts
Old Schoolhouse Rd and Gardiner Beach roads are quiet rural roads that family members and pets use for exercise and walking. They are not intended for use by heavy industrial vehicles. Access to and from these roads via Hwy 101 will have a traffic impact on the communities particularly during periods of Sequim and Port Angeles public festivals and events and during summer months with the high tourist traffic to the Olympic National Park and Peninsula camping areas which already impact access to the highway by Gardiner residents.
How and how frequently will the noise of the plant operation and truck traffic be measured, monitored and mitigated for this quiet residential neighborhood?
How many trucks will be entering and leaving the site daily?
How is this plant in keeping with the zoning of Gardiner as a rural residential neighborhood otherwise free of industrial manufacturing?
..................................................................................................
The following is submitted in accordance with request for comments by Jefferson County DCD pertaining to the subject application.
The following outlines issues, concerns and questions relative to the application.
Air & Particulate Pollution
About 15% of the concrete mixture is cement and use of cement creates health hazards. According to the EPA, cement & concrete plants are significant sources of nitrogen oxide, sulfur dioxide, carbon monoxide and hydrocarbons which are associated with certain health and environmental impacts.
Nitrogen oxide can cause or contribute to a variety of health problems and adverse environmental
impacts, such as ground-level ozone, acid rain, water quality deterioration, and visual impairment.
Sulfur dioxide in high concentrations can affect breathing and may aggravate existing respiratory and cardiovascular disease. Carbon monoxide can cause harmful health effects by reducing oxygen delivery to the body’s organs and tissues, as well as adverse effects on the cardiovascular and central nervous systems.
There are multiple studies that report the batch plants are extremely dusty and issue respirable dust particulates that lead to many health complications, including lung function impairment (carcinoma of the lungs and colon, chronic obtrusive lung disease, pneumoconiosis and restrictive lung disease.
Cement dust can enter the systemic circulation and get to body organs such as the liver, heart,
spleen, muscles and this affects the performance of the physiological and microstructure.
Portland cement contains carcinogens such as chromium and free silica, the inhalation of cement
dust can cause respiratory tract cancers. Studies of cement plant operations have detected crystalline compounds including the metals Al,Ca,, Fe, Mg, Na, and K.
Studies of cement plant health impacts conducted in Italy, Texas and Korea showed an association between the exposure to plant emissions and the risk of hospital admission for cardiovascular or respiratory causes. A review of 1491 studies on the health effects of cement plant exposure found positive associations between cement plant exposure and respiratory diseases and symptoms. An excess risk of cancer incidence and mortality in both children and adults mainly concerning respiratory tract cancers was also reported in some studies.
Many scientific studies recommend that cement plants be at least five miles away from residences.
These emissions do not include the results of fuel combustion emissions by products from trucks,
generators or other equipment.
Has an air permit been granted by the Olympic Regional Clean Air Agency? If so, please share it with the surrounding communities around the proposed site.
What methods will be used to remove particulate matter and dust from roads and other paved areas to mitigate particulate matter that has been deposited in one place, and then liberated into the ambient air by vehicular travel, wind, or other causes?
How are stack emissions from silos, batchers, and other confined storage and conveying equipment to be controlled?
Other than dust bags, what other actions will be initiated to reduce airborne particulate matter?
The Gardiner community frequently receives high winds from both the Northwest and Southeast.
What types of barriers, wind breaks, etc. will be used to mitigate wind disbursement of particulate
matter and aggregate dust into the community?
What are the planned periods for cleaning/replacing the dust bags? How will the dust bags be
disposed of and to where?
How is the operator going to control unconfined emissions from hoppers , conveying equipment, droppoints, truck loading and unloading, roads, parking areas, stock piles and yards?
What, if any, environmentally safe dust-suppressant chemicals are to be used to control emissions?
Where will visual tests of silo dust emissions be conducted?
How often will tests be conducted for visible emissions and what type of EPA test will be used?
The U.S. Environmental Protection Agency requires TRI (Toxic Release Inventory) reporting by the
plant operators to estimate how much toxic pollution they released over the course of a year. Will this information be released to Jefferson County and to the Gardiner community?
Tier II Reporting (also called Community Right-to-Know or EPCERA Reporting) requires the operator to advise Jefferson County, emergency responders, neighbors and community to know what is stored on site. At what point does the operator plan to release that information?
Water Pollution
The plant operator plans to use water from a private well as the source of water for plant batch
operation and water washdown .
Water run-off from cement plant operations and wash out water are highly alkaline which can cause water pollution. Cement contains a number of potentially toxic chemicals including chromium which is particularly toxic for watercourses and to groundwater.
Trucks, hoppers, mixers and pumps must be washed out in a contained area and be located away
from any watercourses or drainage channels to prevent accidental escape of liquid or slurries to the water environment. Measures must be installed to control, store, treat cement wash water arising from the operation on site.
Wash down water arising from the washing of equipment that has come in contact with the cement
must be collected in an impervious container. Water washdown must not be used for wheel washes or dust suppression purposes.
The batch plant is to be located above the existing Gardiner drinking water well. Measures must be taken to absolutely prevent any discharge of effluent or water to the groundwater.
What actions are being taken to prevent toxic water from entering either the operator's well or Gardiner's public water well or infiltrating the ground water source of Gardiner’s drinking water well located immediately below the proposed site?
What actions are being taken to guarantee that any toxic water runoff will be prevented from escaping the site and leaching into the groundwater?
What notification and communication has occurred with the Jefferson County PUD? Have they been made aware of the proximity of the site to the Gardiner Community well that provides the public water source?
If water is used for dust suppression how is any runoff and groundwater entry controlled?
What will be used to enclose or mitigate emissions at the drop point to the truck (e.g. spray bar,
chute, or partial enclosure)?
How frequent will water testing occur in the water settling ponds to determine the level of toxicity and who will conduct the tests?
How will wash water from equipment be captured and contained? Will the contained wash water be treated?
How will the sediments from the settling tanks be contained and disposed of and where will it be
transported for disposal?
Further, the plant is located above the existing Eagle Creek, a potential salmon migration source
which a considerable amount of tax dollars was spent to protect by the installation of an enlarged
conduit to enable better migration of the salmon.
What is planned to guarantee that effluent and wash water does not enter this watercourse?
Has Jefferson County or the plant operator notified the SKlallam Tribe in Blyn of potential impacts to Eagle Creek which crosses tribe property prior to flowing below the proposed plant site?
Fire Risk
The contractor plans to use dust bags to collect dust and particulates. Dust and storage bags are
made of combustible material that can easily catch and spread fire. If the dust bags are not cleaned or replaced in a periodic timely manner the dust bags become highly combustible and can ignite a fire. Dust explosions, static electricity, spontaneous combustion, and high-temperature materials passing through the bag filters can cause fire.
In recent years the Gardiner and Diamond point communities have experienced significant drought
periods and elevated fire risks. The proposed site and community is surrounded by forested and
highly vegetated areas. A fire during these conditions would quickly become a wildfire endangering
the entire community.
What fire prevention and fire suppression measures are available at the proposed site?
Has Clallam County Fire District 3 been informed by Jefferson County of this project? CCFD 3 is
responsible for responding to Gardiner fires and emergencies.
Light Pollution
What are the hours of operation for the plant? One document said the proposed hours of operation
were to be 7am to 10 pm. This will require wide area lighting for the plant during darkness.
What type of lighting will be used? What actions will be taken to prevent light pollution leaking into the neighboring residential areas during the nighttime?
Noise & Traffic Impacts
Old Schoolhouse Rd and Gardiner Beach roads are quiet rural roads that family members and pets use for exercise and walking. They are not intended for use by heavy industrial vehicles. Access to and from these roads via Hwy 101 will have a traffic impact on the communities particularly during periods of Sequim and Port Angeles public festivals and events and during summer months with the high tourist traffic to the Olympic National Park and Peninsula camping areas which already impact access to the highway by Gardiner residents.
How and how frequently will the noise of the plant operation and truck traffic be measured, monitored and mitigated for this quiet residential neighborhood?
How many trucks will be entering and leaving the site daily?
How is this plant in keeping with the zoning of Gardiner as a rural residential neighborhood otherwise free of industrial manufacturing?