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									Mr. Brian Freeman                                                   February 1, 2007
C/O County Administration Building
1840 25th Street
Vero Beach, FL 32960
Ref: Ocean Concrete
Application No: 571127

Dear Mr. Freeman,

I object to any approval of this application by Ocean Concrete on the following grounds.
They fall into 4 general categories: Health, Safety, Pollution and Standards. Please allow
me to go into some detail.

Pollution (Noise)
        Typical concrete batch plants with 70’ “Silos” have a maximum capacity 180 to
200 YPH (Cubic Yards Per Hour) (Max 12 Yards Per Batch Cycle). Typical concrete
Redi-mix trucks have a capacity of about 11 cubic yards. This means this plant would be
capable of shipping out over 18 full truck loads per hour; more at reduced truck loads.
That’s an 80,000 pound truck leaving the proposed plant every 3 minutes. Every truck
that leaves has to return. That’s a truck entering or exiting the facility every minute and
30 seconds. Now add the very large trucks that will bring locally produced sand into the
proposed plant. Sand makes up about 50% of a cubic yard of concrete, therefore up to 90
to 100 yards of sand need to be available per hour. Most of Fischer’s trucks haul up to 17
cubic yards. That translates into 11 entries and exits per hour. We could now see a truck
on Old Dixie Highway and 512 East bound every 75 seconds. If this proposed plant only
did 25% of its capacity that would mean some concrete or sand truck using the East
bound lanes of 512 every 5 minutes. The 512 turn signal takes almost 4 minutes to cycle.
How would you like to live down wind of all this noise? Now let’s add the din of a front
end loader pushing the sand into piles, retrieving it to dump into the processing hopper.
Next, add the noise from a train slowing down to shuttle cars loaded with Portland
cement and hopper cars of aggregate on to a siding (don’t forget that this train may block
512 East bound and/or Schumann Drive during this moving of cars to a siding). Now
unload these cars and transport the cement to the “Silo” and the aggregate to its storage
bin. Then when batching use the front end loader to keep the aggregate hopper full and
add the sand. All of these trucks and end loaders use diesel engines that are noisy, smelly
and have loud backup warning beepers for safety.
        Every once in awhile; a concrete truck returns with some concrete that has
hardened in the trucks mixer. The only way to remove it is put a man in the mixer with a
jackhammer to get it out. Just imagine the noise that makes. A kid playing drums in
your house would almost be silent compared to this noise.
        Neighbors of the Tarmac plant in Melbourne make all the same complaints as
well as the conveyor belts make noises like a roller coaster and rattle the dishes.
        Many typical cement batching plants begin operations at 4:00AM and continue
until the last truck has returned for the day and been washed out. Most of us are still a
sleep at 4:00AM and would like to remain so. Do we know the hours of operation of the

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proposed plant and have any kind of guarantee they would not operate outside these

Pollution (Dust and Dirt)
        Movement of all this material around the property will cause wind blown debris
consisting of fine sand, dirt and fine cement particles. All truck and end loader
movement will pick this material off the ground and allow the wind to catch it. This is a
fact that anyone living around a plant, whether state of the art or old, can attest to.
        According to NOAA the National Climatic Data Center, the 46 year average for
prevailing winds in this area is: ESE or SE for 9 months of the year at an average speed
of 7 to 10 MPH. This means that most of The City of Sebastian is downwind of this
blowing material. Will the plant operators come to my house each day to clean the fine
layers of cement dust, sand and dirt from my deck, pool and outdoor furniture? That’s
what the people around the Tarmac plant in Melbourne have to put up with day in and
day out. What about the dangers to our new $ 14 million preserve located ½ to ¾ of a
mile from the proposed plant? Cement dust kills vegetation. THAT’S EVIDENT FROM

Health Hazards
         The very fine particles of sand can cause “Silicosis”, a debilitation disease, and
cancer per OSHA, and can prove fatal. These very fine light particles can fly great
distances and can affect the respiratory function of older people as well as the sick and
young. Why does OSHA mandate respiratory protection for all concrete and cement
industry workers?
         Portland cement dust is a “Immediately Dangerous To Life or Health” in large
concentrations per OSHA (IDLH): 5000mg/m3. What about longer term exposure of
lower concentrations? According to OSHA, symptoms include: “Irritation of eyes, nose;
cough, sore throat, expectoration; exertional dyspnea (breathing difficulty); wheezing,
asthma, chronic bronchitis; dermatitis, skin burns, INGES, ACUTE: Burning sensation,
abdominal pain.” The industry workers can make use of protections, but what about the
rest of us? Will we all need to wear respirators, goggles and protective clothing to stay
safe and healthy? See OSHA Hazard Communication Rule, 29 CFR 1910.1200; SARA
(Title III), Section 311 and 312; EPA Toxic Substance Control Act (TSCA) inventory
under CAS# 14808-80-7. Under most manufactures Material Safety Data Sheets
(MSDS) for Portland cement; if worker exposure exceeds OSHA limits, the manufactures
MSDS says “Use local exhaust to vent to the atmosphere”. Pass the problem on to the
general public and environment!
         Another common ingredient of concrete is fly ash. It is used to reduce the
quantity of Portland cement in a batch. Why? It’s a by product of coal burning in
electrical generating plants. It either has to be buried in specially lined disposal areas or
disposed of by other legal means or usages. It also is considered a health hazard.
According to the Environmental Protection Agency (EPA), fly ash contains heavy metals,
including nickel, vanadium, arsenic, beryllium, cadmium, chromium, copper,

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molybdenum, zinc, lead, selenium and radium. Since it is dangerous, it is very cheap to
buy, as producers are anxious to be rid of it. And it is an excellent substitute for up to
45% of Portland cement used in a concrete mix. Do we know if fly ash would be used in
this proposed plant?
        Other “additives” can also be used in concrete production. These are known as
“admixes”. They are chemicals added to a batch to impart some additional properties to
the concrete. Many of these “admixes” are poisons and dangerous. What about the
proper storage and use of these chemicals. What about spills and atmospheric releases
and health hazards?

         Standards (Height Restrictions)
        The term “Silo” may be a standard term in concrete plant terminology, but of
more then 40 on-line dictionaries, all indicate only 2 common usages. One a “Silo” is
used to store silage for agriculture uses or two, a structure designed to hold “missiles”. A
third meaning can be a below ground structure for holding coal. There is absolutely no
mention of concrete plant structures. A FRIEND OWNED A FARM IN NEBRASKA
The question is: what were the definitions that the zoning ordinance had in mind for a
“Silo”? Since common usage of the term does not include a concrete batching plant
structure, I think that if it were to include a concrete plant structure, it would have been
spelled out like the church steeple. Clearly a 70’ tall concrete plant structure was not
meant to be allowed over the 35’ limit. Only structures of worship (churches) and
communication towers are exempt. Why, because these exemptions relate to almost all
citizens for either worship or the common good for communication and safety. A
cement silo serves neither purpose. Therefore; a cement “silo” is a very big stretch.

Standards (Zoning Issues)
        This issue gets a little murky. Indian River County zoning regulations appear to
consider a concrete batch plant as “Light Industry”. Most citizens totally disagree. Most
counties and cities will not allow this type of industry next to residentially zoned areas
even if zoned heavy industry. Most require a conditional use certificate even in heavy
industry zones.

Brevard County uses this definition:

Sec. 62-1102. Definitions and rules of construction.
       Heavy industry means the manufacture of goods under the following NAICS
codes: 21-Mining, 322-Paper Manufacturing, 324-Petroleum and Coal Products, 325-
Chemical Manufacturing, 311611, 311615-Slaughtering of Animals or Poultry, 31611-
Leather Tanning, 3221-Pulp or Paper Mills, 32531-Fertilizer, 32732-Ready-mix

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Concrete, 336-Transportation       Equipment,    outdoors,   and   2211-Electric    Power

The NAICS code 32732 supersedes to code 327320 listed below.

North American Industry Classification System
From: (From US Census Bureau)

 327320 Ready-Mix Concrete Manufacturing This industry comprises establishments,
such as batch plants or mix plants, primarily engaged in manufacturing concrete
delivered to a purchaser in a plastic and unhardened state. Ready-mix concrete
manufacturing establishments may mine, quarry, or purchase sand and gravel.

Palmer Lake, CO agreed that Concrete Batch Plants were not “Light Industrial” and in
2001 denied Transit Mix a permit to build a plant on property zoned “light industrial”.

California plant denied approval

Other locals denied approval

Our county appears to be out of step with surrounding and national codes pertaining to
Light and Heavy Industrial manufacturing.

Safety (Traffic Impact)
        See my objections list under Noise. Where would the railroad siding be located
and how long would it be? Current freight trains that carry aggregate and cement along
this right away are over 1 mile long. They take a very long time and distance to slow to a
speed (actually come to a complete stop) that would allow transfer of cars to a siding. No
matter what they do they will shut down either the Schumann Drive or 512 East bound
lanes for 15 minutes or more. Emergency responders will not be able to use these
crossings and will require long detours. Minutes and seconds count in emergencies!
        The center of the plant property is only 1/2 mile from Schumann Dr. and slightly
less then 1 mile from 512. Since a siding would have to be hundreds of feet long, as well
as having some portion of it on the plant property, a one mile long train will definitely
close one or the other crossing during siding offloads.

Pollution (Water)
        Eventually some material from such a plant would find its way of the property in
water run off. What controls would be in place to capture and neutralize the materials?
What guaranties do we have that it will not contaminate the shallow aquifer by leaching
or the Indian River Lagoon by air borne or runoff?

Pollution (Light)

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        Early and late operation of a plant will mean that some hours of operation will be
in the dark. This will require powerful flood lights to illuminate the property for safe
operation. These typically are mounted on the highest structure, like a tower. This will
cause nearby residential and preserve property to be subjected to light pollution. Native
animals in our new $ 14 million preserve will be living in conditions that Mother Nature
never intended and will eventually be driven away. Not a good legacy for citizens who
are very concerned with environmental issues.

Thank you for your indulgence,

William & Sandra Sandy
542 Balboa St.
Sebastian, FL 32958

cc:      Mr. Gary Wheeler, IRC, County Commission Chairman
         Mr. Joe Baird, IRC, County Manager
         Mr. Robert Keating, IRC, Director of Community Development
         Mr. Stan Boling, IRC, Director of Planning and Zoning
         Mr. David Hays, IRC Reviewing Engineer
         Mr. Ken Oristaglio, IRC Code Enforcement
         Ms. Jeanne Bresett
         Ms. Donna Keyes, IRC Planning and Zoning Board
         Ms. Rebecca Grohall, City of Sebastian
         Mr. Al Miner, City Manager, City of Sebastian
         Mr. Rich Stringer, City Attorney, City of Sebastian

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