HomeMy WebLinkAboutFW_ _External_ Request to deny mining permit 92-10Johnson, Robert E
From: Sams, Dan
Sent: Friday, July 17, 2020 1:32 PM
To: NCMiningProgram
Subject: FW: [External] Request to Deny Mining Permit 92-10
Attachments: 061720-Crabtree and Sycamore Creeksjpg
From: Michael Taylor[mailto:michaeldtaylor@live.com]
Sent: Friday, July 17, 2020 11:56 AM
To: Sams, Dan <dan.sams@ncdenr.gov>; NCMiningProgram <NCMiningProgram@ncdenr.gov>
Subject: [External] Request to Deny Mining Permit 92-10
Dear NC DEQ
I am Michael D. Taylor, Ph.D., DABT, and I live at 209 Sedgemoor Dr, Cary NC, 27513. I'm calling for DEQ to deny mining
permit 92-10 under subsection 74-51d Subsection 4: that the operation will constitute a direct and substantial physical
hazard to public health and safety or to a neighboring dwelling house, school, church, hospital, commercial or industrial
building, public road or other public property, excluding matters relating to use of a public road; and Subsection 5: that
the operation will have a significantly adverse effect on the purposes of a publicly owned park, forest or recreation area.
I am a stakeholder in this issue due to both my frequent use of Umstead State Park and the Old Reedy Creek Corridor
and a homeowner in Cary's Wessex neighborhood close to both the existing and proposed quarries. I can hear and feel
the detonations of explosions from the current quarry inside my house. Quarry traffic, including large trucks, are a
constant hazard when navigating the Harrison Rd/1-40 interchange area. In fact, large truck traffic from the quarry has
made one lane of the westbound entrance ramp to 1-40 dangerous and nearly unusable by destroying the pavement due
to their heavy loads and frequent travel. The quarry is certainly not a good neighbor! If this permit is approved, this
hazard will be extended. Heavy trucks removing logs and overburden will drive directly on a designated highly trafficked
greenway (in fact, the East Coast Greenway) at Old Reedy Creek Road, an area typically busy with people including
families with children walking, running, hiking, or biking. These uses are clearly not compatible.
As a board -certified Ph.D.-level inhalation toxicologist, I am concerned about the particulate pollution an expanded
quarry will cause at Umstead State Park and the East Coast Greenway. These are areas where people are actively
exercising, which increases their respiration rate and volume and percentage of mouth -breathing. These factors
facilitate the deposition of particulate pollution from the quarry, particularly in the PM2.5 size range, deep into the lung
regions where gas exchange occurs. In addition, there are nearby residences, most notably the Dunns, that would have
continuous exposure to particulate pollution from the proposed quarry. Due to the fact that the rock being mined
contains quartz, the PM2.5 particulate pollution from the quarry will contain toxic and carcinogenic crystalline silica
particulates. It is unavoidable that the quarry expansion will cause silica exposure to people using nearby Umstead State
Park, the East Coast Greenway, and living in neighboring houses. I have personally conducted laboratory research on
silica dust. Freshly fractured silica is the most toxic form of the material and can cause severe lung toxicity, and
furthermore is classified as a known human carcinogen by the US Department of Health and Human Services and the
WHO. Exposure standards to both PM2.5 and crystalline silica dust have become markedly more stringent since the initial
quarry permit was issued due to more information on their toxic effects at lower exposure levels. DEQ cannot rely on
any previous air permits to assess the public health risks of this proposed expansion. This is especially true since the
active pit will be much closer to highly trafficked recreational corridors and nearby residents. Last year in their
Toxicological Profile for Silica, the US Agency for Toxic Substances Disease Research (ATSDR) identified people who live
near rock quarries as a population of concern for crystalline silica overexposure. The document can be accessed here:
https:/Cwww.atsdr.cdc.g2y/Tgx_aLgh.l_gs/t.g.asp?id-1483&tid-290. DEQ should consider the worst -case impacts of quarry
activities on nearby park users and residences according to the latest health standards for particulates and deny the
quarry permit due to its hazard to public health.
I have reviewed publicly available air quality inspection reports done by DEQ at the current Triangle quarry. It does not
appear that air quality was routinely monitored by proper air sampling techniques on a regular basis (e.g., to calculate
annualized particulate exposures to nearby areas in the park and residences). In fact, the extent of most inspections on
air quality conclude that no fugitive dust emissions were visible. Dust concentrations need to be extremely high to be
visible; silica and PM2.5 pollution have to be measured with specialized equipment, as they are not visible at
concentrations near and even above their current safety standards. A visible inspection of dust emissions from the
quarry is not sufficient to protect human health from the current quarry or the proposed expansion.
It is clear that many of the reasons the DEQ can deny a quarry permit are met in this case. As I have stated, there is no
way particulate pollution will not increase in the nearby park and greenway corridor. There will certainly be adverse
effects on the purposes of a publicly owned park, forest or recreation area. There will be unavoidable adverse effects
wildlife and freshwater. Increased air and noise pollution as well as heavy truck and equipment traffic in the middle of a
busy population center clearly presents multiple hazards to public health and safety and hazards to neighboring houses,
public roads, and other public property. Director Conrad was correct in denying the original quarry permit in 1980 based
on Subsection 5: that the operation will have a significantly adverse effect on the purposes of a publicly owned park,
forest or recreation area. At that time he stated:
The combined effects of noise, sedimentation, dust, traffic and blasting vibration associated with the proposed
quarry operation would produce primary impacts on William B. Umstead State Park in the form of noise
intrusion and deterioration of visual resources. Our evaluation of your permit application further indicates there
are no feasible modifications that can be made to the application that would make it acceptable.
The quarry exists only because of a political overruling of that permit denial. There have been no changes since that time
that would alter Director Conrad's assessment, and his predictions have been borne out. I hear and feel the detonations
from the quarry routinely. I have to deal with noise, dust, and quarry traffic just getting into Umstead Park on Harrison
Avenue. I have seen Crabtree Creek turn cloudy after rain due to runoff. In fact, I have attached a recent picture taken
on June 17, 2020, at the confluence of Crabtree Creek and Sycamore Creek. It is obvious which creek runs by the current
quarry (Crabtree Creek on the left) and which one does not (Sycamore Creek on the right). The Umstead Coalition has
complied much more evidence that shows that Director Conrad's concerns that the "combined effects of noise,
sedimentation, dust, traffic and blasting vibration associated with the proposed quarry operation would produce
primary impacts on William B. Umstead State Park in the form of noise intrusion and deterioration of visual resources"
have been realized. An expansion of the quarry would only lead to more severe impacts on the park and represent a
larger hazard to public health. Therefore I respectfully urge DEQ to deny the mining permit for the expanded quarry. I
also ask DEQ to restore the Sunset Clause to the current Wake Stone quarry operations that were promised to end in
2031. 1 look forward to a future without negative quarry impacts on my daily life and recreational enjoyment.
Sincerely,
Michael D. Taylor
N