Is CEMEX Lyons The Next CKD Superfund Site?
Why are we talking about CKD?
CKD can be harmful to humans, wildlife, and the environment.
CKD composition is dependent on source and type of materials.
CKD has now been shown to be toxic in experiments.
CKD disposal for 20+ years caused a Superfund site in Salt Lake City
CKD has been created and disposed of at CEMEX Lyons for 50+ years
CKD disposal is managed by CEMEX Lyons with DRMS oversight
CKD dust plumes have been well chronicled at CEMEX Lyons
DRMS inspections and subsequent corrective actions are largely triggered by community reports.
An alteration to CKD source and type of material has implications to public health and safety and ongoing nonconforming use status.
CKD is an extreme health hazard
The EPA began regulating CKD in 1995 “in order to protect the public from human health risks and to prevent environmental damage resulting from current disposal of this waste.”
The primary environmental concerns to be addressed through additional controls are documented damages to ground water and potable water supplies, and potential human health risks from inhalation of airborne CKD and ingestion via food chain pathways”. In 1999, DRMS took on CKD disposal regulation for the cement industry in Colorado.
“Cement kiln dust exhibits variability in chemical composition and physical characteristics depending on the source and type of raw materials, plant operation, extracting and disposal practices.”
The CKD that the Lyons Plant produces is dependent on the specific source material from Dowe Flats.
Why does it matter?
Fugitive dust storms at the CEMEX Lyons Plant are a weekly occurrence regardless of wind speed, unfortunately.
CKD dust plumes have been well chronicled at CEMEX Lyons as the plant has been disposing of CKD for well over 50 years. Since 1999, CKD has been disposed of in C-Pit, with a modeled capacity of 600,000 cubic yards over a 20 year time frame. From 1969 to 1999, it’s unclear how much CKD was disposed and where exactly onsite the CKD was disposed.
The CEMEX Lyons plant is responsible for disposing of CKD properly, with DRMS oversight. We are currently unsure how much oversight there actually is with this process and to what extent it has harmed the surrounding environment.
Is CEMEX Lyons The Next CKD Superfund Site?
The 71-acre Portland Cement site is located in Salt Lake City, Utah. Between 1963 and 1983, about 500,000 cubic yards of cement kiln dust (CKD) were collected from the Portland Cement Plant in Salt Lake City and deposited as fill material at the site. [1]
CKD contains several heavy metals, including arsenic, lead, chromium, cadmium and molybdenum. Additional waste disposal activities at the site included disposal of a few hundred tons of chromium-bearing bricks. These activities contaminated soil, air and groundwater with heavy metals. While the EPA’s performance measures are in good standing at this point, cleanup is still ongoing almost 40 years later!
We just don’t know enough about the disposal practices at CEMEX Lyons to know if the it will end up becoming a Superfund site like the Salt Lake City plant. What we do know is that there are several concerns with the current handling of CKD at CEMEX Lyons:
According to a DRMS memo, fresh CKD should never be placed or allowed to be placed inadvertently in open flowing water or in areas such as flood plains where open flowing water may reach the fresh CKD prior to a few weeks of curing.
It cannot be understated how potentially hazardous this is!
Most Recent DRMS Inspection
The following text contains excerpts from the most recent DRMS inspection of the CEMEX Lyons plant:
“A haul truck returning to the plant after having dumped CKD material at Pit C accidentally left its bed in a raised position which collided with the overhead conveyor that runs across the access road. According to the operator, operations were suspended for 4 days while the damaged portions of the conveyor were being repaired. During this time, equipment access to the CKD disposal area was limited, as the road beneath the conveyor is the only access road to the area south of the plant. This meant that water trucks were unable to access Pit C to water the freshly dumped CKD material. Considering the high wind gusts that occurred on January 31, 2022 and the operator’s inability to get water trucks to the CKD disposal area during that time, it seems likely the dust was generated from the CKD disposal area (as well as from the raw material stockpile area). The photos provided with the complaint appear to support this.
DRMS also commented on the fugitive dust events which have been documented on the site over the years:
Given the multiple fugitive dust events that have been documented at the site over the years (including the most recent event that occurred on January 31, 2022), with dust generating from both the CKD disposal area and the raw material stockpile area, it appears the operator is not effectively controlling wind erosion of these materials. Therefore, the Division is citing a problem in this report, requiring the operator to submit a Technical Revision…provide an updated material handling plan that includes fugitive dust control measures to be implemented at the site.”
CKD Exposure Risks
According to a series of experiments conducted regarding the health risks of CKD, it was concluded that:
Occupational and environmental exposure to cement dust has been known to precede a number of systemic injuries with particular reference to the respiratory, gastrointestinal, and integumentary systems characterized by fibrosis, emphysema, cough, cancer, inflammation, and liver diseases among workers and host community residents of cement factories”
Additionally, it was noted that:
“The operation of the standardized apparatus mimics a typical occupational exposure and the findings show that cement dust induces systemic toxicity via respiratory perturbation and body/organ weight discordance mediated by heavy metal bioaccumulation.”
Land Use Code Implications
An alteration of the source and type of materials for the Lyons Cement Plant would alter the CKD produced, which would have public health and safety implications.
This event would constitute an “alteration in the nonconforming use which has the threatened effect of creating a hazard or nuisance on or off the property” (4-1003.C.1.d)
Therefore, pursuant to 4-1003.C.1, the right to continue the nonconforming use would terminate immediately.
Conclusion
The CKD saga at CMEX Lyons is just one more loose end that has not been tied up. Regulators and health officials have made their recommendations and file their reports, but CEMEX has not addressed many of these issues. As we can see from the Salt Lake City CKD fiasco, it can take decades to cleanup sites like this, and if we were to give CEMEX 15 more years of mining, who knows if CEMEX would ever address their CKD issues.
The bottom line is that we can’t wait any longer. We need your help to persuade the Boulder County Commissioners to recommend rejection of the Dowe Flats Mining Permit extension on September 14th! Please register to attend and subscribe to our newsletter for updates!
