20240724_Richmond-Bryant-J-NCstate

College of Natural Resources Campus Box 8001
NC STATE Department of Forestry and Environmental Resources 2820 Faucette Drive
UNIVERSITY Raleigh,NC 27695-8001
cnr.ncsu.edu/fer/ P:919.515.6300
July 24, 2024
Mr. Adam Parr
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality (NC DEQ)
1612 Mail Service Center
Raleigh, NC 27699-1612
Dear Mr. Parr:
I am writing to express concern for the health of community members living in close proximity to the
proposed Rouse Pit in Lenoir County, NC after reading the related permit application.' The proposed
sand mining operation has the potential to emit particulate matter that can be transported to the
surrounding neighborhood, producing inhalation exposures that can lead to adverse health effects.
The Rouse Pitt is a proposed sand mine on the property of James and Susan Rouse on Davis-Hardy
Road. Sand would be gathered through excavation, and mined sand would sit in a pile on the Rouse
property. The excavation site, waste pile, haul roads, and other affected areas are proposed to take up
over 23 acres of land. The excavation site would have areas of exposed sand at the interface between
the earth and air. These exposed sand locations create potential for emissions of hazardous particulate
matter (PM). Moreover, a 23-acre area is too large to control in its entirety by wetting. Even if road dust
is controlled via regular wetting, there will likely be a significant amount of land with exposed sand.
Although much sand dust is super-coarse (63 µm or larger)3, elevated coarse (PM10-2.5, or particulate
matter with a nominal mass median aerodynamic diameter between 2.5 and 10 µm) and fine (PM2.5, or
PM with a nominal mass median aerodynamic diameter of 2.5 µm) PM have both been measured in the
vicinity of sand mining, although particles of these sizes are too small to be seen with a human eye'.
Once airborne, PM2.5 can travel several kilometers. With some mining occurring above the water table,
dry mining will increase the tendency of PM sitting on the pile or at the edge of the pit to become
airborne.
' MKE Environmental. Application to the North Carolina Department of Environmental Quality for a proposed mine
off Davis-Hardy Road. March 23, 2024; MKE Environmental. Application to the North Carolina Department of
Environmental Quality for a proposed mine off Davis-Hardy Road. June 21, 2024.
2 Ibid MKE Environmental 2024.
3 Fan K, Zheng Y, Baudet BA, Cheng YPH. Investigation of the ultimate particle size distribution of a carbonate
sand. Soils Foundations. 2021;61:1708-1717.
' Peters TM, O'Shaughnessy PT, Grant R, Altmaier R, Swanton E, Falk J, Osterberg D, Parker E, Wyland NG,
Sousan S, Stark AL, Thorne, PS. Sci Tot Environ. 2017;609:1475-1482.

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January 1 — March 31 April 1 — June 30
Wind rose for KGSB in Goldsboro,NC Wind rose for KGSB in Goldsboro,NC
For Jan I to Mx s1 from 1944 10 2023 170%of data avaiLao lei For Apr 1 to Jun 30 from 19"to 2023(72%of data availahle)
NNW N NNE NNW N NNE
Nu. 75A NW 75% NF
WNN , ENE N.'NVJ �� ENE
2 4 o�
W , E W ' r , l E
r
'IVSW ESE 'NSW ESE
Calm Winds(<3.2 kmlhl: SW SE Calm Winds(<3.2 kmlh): 5E
203%of observations SSW S SSE 183%ofohservations SSW s SSE
Wind Speed; Wind Speed,
3.2 to 8 kph 11 to 15 kph 4P 24 to 32 kph 0 3.210 8 Mph 11 to 16 kph f 24 to 32 kph
®8 to 11 kph 1610 24 kph 0>_32 kph dimale ncsu edu '-n.St.11 kph 16 to 24 kph 0>_32 kph dimate.ncsu.edu
July 1 — September 30 October 1 — December 31
Wind rose for KGSB in Goldsboro,NC Wind rose for KGSB in Goldsboro,NC
For Jul 1 to Sep 30 from 1944 to 2023)67%of data availahle} For Oct 1 to Qec 31 from 1944 to 2023(65%of data available)
NNW N NNE NNW N NNE
r�
NW —15'A NE NW NE
_ 25%
g.S96 �
WNW \ ENE WNW ENE
w E w r �� E
WSW 1 ESE WSW — ESE
Calm Winds(<3.2 kmlh): SE Calm Winds(43.2 kmlh): sW SE
26.5%ofobservations SSW S SSE 30.4%of observations SSW s SSE
Wind Speed: Wind Speed,
3.2 to 8 Mph 11 to 16 kph 24 to 32 kph 3.210 8 Mph 11 to 16 kph 24 to 32 kph
B le 11 kph 16 to 24 kph 0 2 32 kph climate ncsu edu 0 at.11 kph 16 to 24 kph 0 Z 32 kph dlmaie ncsu edu
Figure. Seasonal wind roses from Seymour-Johnson Air Force Base Airport, 1944 — 2023.
The adjoining property ("Elizabeth, Jan, John Davis" and "John Davis III") containing homes located
within 0.5 km to the west of the Rouse property would receive the greatest exposures through transport
by wind. Reentrainment (lifting of settled particulate into the air) occurs when shear stress (stress on
the surfaces of particles) from wind or turbulent air recirculation from passing traffic exceed the frictional
force that the ground exerts on particles to keep them in place. Once reentrainment occurs, fine and
coarse PM will be carried by the wind before depositing on the ground due to gravitational forces.' This
process repeats, with particles thereby spreading over an area surrounding the source. Sustained
winds measured at the Seymour-Johnson Air Force Base Airport range from 3.2 to over 30 kilometers
per hour and are prevalent from the northeast, north, northwest, and southwest, depending on the time
of year(See Figure).'At these wind speeds, neighboring residents (especially those living to the
southwest, south, southeast, and northeast) within several kilometers are likely to be exposed to
' Punjrath JS, Heldman DR. Mechanisms of small particle re-entrainment from flat sufaces. Aerosol Sci. 1972;
3:429-440; Theerachaisupakij W, Matsusaka S, Akashi Y, Masuda H. Reentrainment of deposited particles by
drag and aerosol collision. Aerosol Sci. 2003;34:261-274; Adhiwidjaja I, Matsusaka S, Tanaka H, Masuda H.
Simultaneous phenomenon of particle deposition and reentrainment: Effects of surface roughness on deposition
layer of striped pattern. Aerosol Sci. Technol. 2000;33:323-333.
6 North Carolina State Climate Office. Wind roses for KISO in Kinston, NC for Jan 1, 1944 to Dec 31, 2023.
httos://aircivality.climate.ncsu.edu/wind/Accessed July 22, 2024.

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reentrained airborne dust transported from the mine. This includes occupants of several homes and the
schoolchildren, staff, and faculty of Moss Hill Elementary School.
Tailings from the sand mine pose a concern to public health for two reasons: composition and particle
size. Sand is composed primarily of silicon oxides. Exposure to silicon dioxide, or "silica", is known to
produce a host of health impacts, including chronic obstructive pulmonary disease? and lung cancers
such as pneumoconiosis and silicosis.$ Exposure to silica also makes individuals susceptible to
infectious diseases, such as tuberculosis.9 Fine PM is typically small enough to travel deep into the
lungs, while coarse PM can be inhaled and deposited along the upper airways. Both exposures may
trigger asthma attacks, while PM2.5 exposure may also trigger cardiovascular health effects or even
premature mortality.10 One sampling site in the Peters et al. study1l recorded long-term average
concentrations above the annual NAAQS for PM2.5, illustrating that hazardous conditions can be
produced by sand mines. The irregular shape of sand particles may also facilitate lodging of the
particles into the airways to trigger allergic asthma responses.12 Individuals with pre-existing diseases,
young children, and older adults experience increased susceptibility to health effects.13 Sand particles
excavated from sand mines have been observed to have moved several kilometers from the tailings
site.
Excavation equipment fueled by diesel or gasoline presents an additional source of PM. Combustion-
generated PM tends to be fine (PM2.5) or ultrafine (<0.1 µm) and can be transported several kilometers
by wind. Health effects of PM2.5 cited above are known to be caused by combustion-generated
particles."
For all of the listed reasons, the presence of the sand mine in an area near residential buildings
increases the risk of exposure to silica in the surrounding area. As a result of the increased risk, I urge
the NC DEQ to consider denying the Rouse Pit permit.
Sincerely,
Jennifer Richmond-Bryant, PhD
Merget R, Bauer T, Kupper HU, Philippou S, Bauer HD, Breitstadt R, Bruening T. Health hazards due to the
inhalation of amorphous silica. Arch Toxicol. 2002;75:625-634.
8 McLaughlin JK, Chow W-H. Amorphous Silica: A review of health effects from inhalation exposure with particular
reference to cancer. J Tox Environ Hlth. 1997;50:553-566; Ibid Merget et al. 2002.
8 Ibid Merget et al. 2002.
10 U.S. EPA. Supplement to the 2019 Integrated Science Assessment for Particulate Matter(Final Report, 2022).
U.S. Environmental Protection Agency, Washington, DC, EPA/635/R-22/028, 2022.
11 Ibid Peters et al. 2017.
12 Qellek S. Comparison of grain size distribution and grain shape of various sand samples. Geotech Geol Eng.
2019;37:5019-5033.
13 Ibid U.S. EPA 2022.
14 Ibid U.S. EPA 2022.