ISSUE: CEMEX is seeking a state permit to extend the air pollutants permit for the Brooksville South Cement Plant. This outdated coal burning plant has been cited 19 times since 2001 for mercury emissions that exceeded air quality standards and is considered a major source of air pollution under current state and federal laws.
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Or you can mail comments to: Florida Department of Environmental Protection, Air Resource Management, Office of Permitting and Compliance, MS #5505, 2600 Blair Stone Road, Tallahassee, FL 32399-2400.
DEADLINE: Public comments must be submitted by August 9th. Note that it is Re: Draft/Proposed permit # 0530021-054-AV CEMEX Construction Materials Florida, LLC, Brooksville, Florida.
See sample comment letter below. You can add your own comments to the letter or draft your own comments. State your concerns and ask the state to hold a public hearing for this Title V (major source) air operating permit.
Why Neighbors Against Mining opposes the proposed permit for the CEMEX Brooksville South Cement Plant:
* It is time to retire this obsolete coal-burning plant now! Coal plants are the nation’s top source of carbon dioxide and sulfur dioxide, and pollute the air with nitrogen oxides, particulate matter, mercury emissions and other harmful pollutants. More than 7100 residents live within a few miles of the plant including Brooksville, Brookridge and Silverthorne.
* It is dangerous and threatens our public health and our environment. Closing the plant will help reduce Hernando’s high asthma rates and the serious health risks from mercury and other air pollutants that we have been exposed to over and over again as recently as 2013.
* CEMEX cannot be trusted; they have misled county commissioners, misrepresented lime rock mine blasting reports, and failed to report emissions and blasting violations, as required by law.
* We want a clean, prosperous future. CEMEX’s declining economic impact is less than one-third that of tourism that generates sustainable growth and protects our environment.
* We ask the Florida Department of Environmental Protection to schedule a public hearing so we can learn how we will be protected from additional mercury and other aerial pollutants.
Learn more: The Florida Department of Environmental Protection has published intent to issue a revised permit for the Title V Air Operation Permit for the CEMEX Brooksville South Cement Plant. View the proposed permit # 0530021-054-AV at: http://www.dep.state.fl.us/air/emission/apds/default.asp. Contact us at firstname.lastname@example.org or call 352 277-3330.
******************SAMPLE COMMENT LETTER********************
Florida Department of Environmental Protection
Division of Air Resource Management, Office of Permitting and Compliance
2600 Blair Stone Road
Tallahassee, FL 32399-2400
Re: Public Comment on Draft/Proposed permit # 0530021-054-AV CEMEX Construction Materials Florida, LLC, Brooksville, Florida
I am a resident of Brooksville in Hernando County, site of the CEMEX Brooksville South Cement and live within a three-mile radius of the plant along with more than 7,100 other residents. I am opposed to issuing this permit to allow the coal burning plant to continue to operate. It is a threat to my health, the health of others, and the environment. Exposure to even small amounts of mercury can have major public health impacts, especially to children and pregnant women.
Many of us have invested our life earnings in our homes in this area. Mercury emissions from this plant have violated air quality regulations regularly over the past 15 years. Asthma rates for children in Hernando County are among the highest in the state with no other major source of pollution in the area and an absence of heavy vehicular traffic other than cement trucks.
On July 3, 2015, the latest Consent Order was issued for this plant for an air quality violation that occurred over two years ago. Perhaps others have occurred since then. Prior to that CEMEX paid over a million dollars for 18 air quality violations at this plant that occurred from 2001 to 2011. Rather than retire the plant then, CEMEX was allowed to add wood to the fuel of the power plant to reduce harmful emissions. Biomass plants produce nearly 50% more carbon dioxide than coal-burning plants and more than double the nitrogen oxide, soot, carbon monoxide and volatile organic matter as coal plants.
CEMEX has failed to disclose blasting violations for lime rock mining activities near Brooksville, failed to report violations of air emissions at the cement plant and misled county commissioners. There is every likelihood that similar violations will occur in the future if this plant is allowed to continue to operate, even if updated monitoring equipment is installed. Monitoring alone is no assurance that violations will not occur if you continue to allow the use of coal burning and biomass as is currently used. This permit would allow up to 200 pounds per year of mercury emissions by law and potentially much more if past performance is any indicator.
Furthermore, I request that you hold a public hearing on this matter to explain what is being done to insure our protection in the future. Thank you for your consideration.
Very truly yours,
Re: Draft/Proposed permit # 0530021-054-AV CEMEX Construction Materials Florida, LLC, Brooksville, Florida.
The Florida Department of Environmental Protection has published its intent to issue a revised permit for the Title V Air Operation Permit for the CEMEX Brooksville South Cement Plant. This obsolete coal burning plant has been cited for mercury emissions that exceed air quality standards on numerous occasions and threatens the public health of everyone in Brooksville and our environment.
The CEMEX Brooksville Cement plant violated air quality standards for mercury emissions in August 2013 but came back into compliance in September 2013. During this incident, CEMEX kept the power plant going without wood added for a total of 80 hours–equal to 3 days, 8 hours in all– when they knew that without the wood added, those emissions were probably violating air pollution laws. There is every likelihood that similar violations will occur in the future if this plant is allowed to continue to operate.
The Consent Order for this violation was issued in June, 2015, two years after the dangerous mercury emission. We do not have any current records indicating whether additional violations have occurred since then. FDEP imposed a fine of just twenty three hundred dollars for this egregious, intentional and harmful continuing violation and despite the fact that CEMEX also failed to properly report this violation, as required by law. Exposure to even small amounts of mercury can have major public health impacts.
Prior to that, CEMEX paid over a million dollars for 18 air quality violations at this plant that occurred from 2001 to 2011. Rather than retire the obsolete coal-burning plant, CEMEX was allowed to add wood to the fuel mix of the power plant to reduce harmful emissions and prevent ongoing violations.
Within a few miles of this obsolete coal-burning plant live more than 7,100 people, with the county seat of Brooksville located nearby. Some are retirees and others still-employed residents, many with children who have invested their life earnings in their home here. In addition, the mining operations have reduced their property values.
Asthma rates for children in Hernando County are among the highest in the state with no other major source of air pollution in the area and an absence of heavy vehicular traffic other than cement trucks. How will the new permit protect all of the residents of Brooksville who are greatly concerned with the impacts to our health and environment that the continued operation of this plant presents from mercury and other toxic air emissions?
Nature Coast Conservation, Neighbors Against Mining Project learned of the 2013 violation several months ago and submitted comments to the Florida Department of Environmental Protection on May 22, 2015. We reported three areas of concern and were unable to actually reach a spokesperson to resolve them at that time. It was a month later that we received the finalized Consent Order from Ana Gibbs, public affairs director for the Florida Department of Environmental Protection.
We are still concerned with the following items noted in that earlier statement:
“Coal plants are the nation’s top source of carbon dioxide and sulfur dioxide, and pollute the air with nitrogen oxides, particulate matter, mercury emissions and other harmful pollutants as well. This is the primary cause of global warming, a leading cause of smog, acid rain, and toxic air pollution, and takes a major toll on public health and the environment according to the Union of Concerned Scientists and others. Union of Concerned Scientists
The burning of biomass such as the wood used at the Brooksville Power Plant, is widely mistaken to be clean. In fact, biomass plants produce nearly 50 percent more carbon dioxide than coal-burning plants and more than twice as much nitrogen oxide, soot, carbon monoxide and volatile organic matter as coal plants. Worsening the problem, many plants use contaminated waste wood, including paint-coated construction debris, all the while professing to be clean and green, according to the Partnership for Public Integrity report published last year. What’s worse than burning coal? FL-DEP should never have allowed the raw mill to be added to this plant as part of the 2011 settlement. Knowing what we do now about the air quality consequences of a raw mill, DEP should re-consider allowing it to fuel the power plant.
CEMEX officials met with Hernando County Commissioners about the 2013 incident and released a press statement that was factually inaccurate and blatantly misleading. CEMEX stated that “The consent decree was issued in regards to an administrative error made by CEMEX in 2014. At no time was CEMEX out of compliance with environmental emissions or operational limits. The health and safety of the local community or our employees was at no time threatened. All emission rates remained well below federal guidelines and Florida permit limits.” Compare that to the facts provided by the state (see below) and it is obvious that CEMEX misrepresented this latest incident to local residents and county leaders. This reinforces our lack of trust in CEMEX, a foreign corporation that can well afford to be responsible and upgrade its Hernando County facilities to meet state pollution laws so that no more violations of this nature occur that threaten public health. “
The August 2013 violations exceeded the mercury standard of 41 micrograms per day standard cubic meter and emitted 52.71 ub/dscm. Since the Consent Order was issued, questions remain. Has FDEP evaluated this impact on local communities? Besides the $2,300 fine, what has the state done or what can it do to assure our community that this mercury is properly cleaned up? Equally as important going forward, how is the state ensuring that the local communities are protected from toxic mercury emissions? How does the new permit provide assurances that emissions exceeding air quality standards will not occur again, even with the installation of a continuous emission monitoring system? Who monitors the emissions? How can we as a community track and confirm that there will be no further mercury violations? How can we access real time monitoring results and learn what is being done to address violations if they do occur?
Concerned citizens in the community want to learn about exposure to mercury and other pollution from the CEMEX South Brooksville plant and the state plans to help and protect our community. We request a public hearing so that the state can explain what steps are being taken and if they will insure our health and environmental safety, prior to issuing this proposed permit. Since the permit is needed to begin work on air pollution control equipment, a public hearing is requested to offer the public an opportunity to learn how we will be protected going forward from additional mercury and other aerial pollutant violations and to ask the state to seriously consider the alternative of requiring that CEMEX retire the coal-burning and biomass plant.
At a time when many communities are seeking to reduce their dependence on dirty coal, CEMEX and FL DEP are insuring that we will be subject to up to 200 pounds per year of mercury emissions by law and potentially much greater amounts from future violations, if past performance is any indicator.
Allowing CEMEX to continue to operate the cement plant in a manner that can easily lead to future violations of the same nature fails to insure that you are protecting the public health of Hernando residents and insuring clean air in our environment when the technical ability to do so is readily available. This coal-burning plant and raw mill should be shut down and the CEMEX Cement plant either upgraded with newer technology or abandoned.