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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