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HomeMy WebLinkAboutDEQ Please Deny Mining Permit 92-10 (2)Bill Padgett 1213 Dixie Trail Raleigh NC 27607 I am requesting that DEQ to deny mining permit 92-10 under General Statute 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; Subsection 5: That the operation will have a significantly adverse effect on the purposes of a publicly owned park, forest or recreation area; Subsection 3: That the operation will violate standards of air quality, surface water quality, or groundwater quality that have been promulgated by the Department; First let me thank you for providing an opportunity for citizens to comment publically on the mining permit and specifically for the time allotted for me to speak on 6/23/20 Graduate studies and research in Physical Chemistry at NCSU, 1970-74; MS in Electrical & Computer Engineering, NCSU; MA in Education, Converse College. And from 1972 —1990 I did long distance training in Umstead State Park. (-250 mi/yr) NOTE: My colleague at NCSU and good friend, Allen Beals, 71, died July 9, 2014 after a long battle with cancer. He lived with his wife, Betsy, at 2335 Old Reedy Creek Rd for 41 years boarding on the NW edge of the quarry. He was one of 4 residents residing adjacent to and nearest the quarry. Whether 24x7 exposures to Crystalline Quarry Dust PM2.5 attributed to his cancer and subsequent death, cannot be verified; however health studies documented by research & the EPA have shown exposure to such dust can cause cancers, compromise one's health and create other life-threating illnesses. Negative health impacts to persons subject to working in factories or mines over a period of time where granite dust is produced, has been shown to be significant. These studies have led the EPA over the years to continually monitor, study and put in place safety regulations for workers in these environments. While this helps to protect those working in enclosed spaces coming in frequent contact with PM2.5 particles, those studies have not been extended to residents that live nearby or those that frequent the areas close to PM2.5 producing environments. However, there are published scientific studies of PM 2.5 and its impact on health relative to the 1918 Spanish Flu pandemic. And we do know that compromised health conditions are factors in increasing the probability of death from COVID-19. It is too early to however to know the magnitude of those effects. Whether one is a frequent visitor or lives nearby, the need to minimize factors that impair one's health like PM2.5 (and PM10) since risks in general are or in a pandemic have been shown to be significant. I think we can expect that the probably of increased health risks to folks visiting or living in the area, but not the magnitude. But even the possibility higher risk diminishes the desirability to live or recreate in such an area. And that is unfortunate for NC and for the 1.8 million visitors that came to Umstead State Park this past year; and the new homes that being built around the park. NOTE: More is spent on public healthcare, than on public education & military expenditures combined. Ref: www.worldommeters.info Unfortunately since most of the free world was engaged in World War I, no country wanted to report the real impact of death from the pandemic either on the troops or their civilian population. Spain reported the impact of the pandemic, hence the Spanish Flu, since it was not at war. Also it was seen as courageous and with valor to have died in war, but to die from the Spanish flu reflected poorly on both the individual and the family. That greatly limited data collection and subsequent studies in 1918-1920. Even finding monuments in cemeteries that marked the devastation of the pandemic are very rare. However, the impacts of a pandemic and exposure to PM 2.5 dust fortunately do have few studies upon which to do some research studies during the Spanish flu which was estimated have killed 50 million people in 1918 and 675, 000 death in the US (0.65% of the population). These studies and documented research show that those with existing medical conditions for more susceptible to death from the Spanish flu. There are also studies from 1918 that show working in a quarry and being exposed to the fine dust produced, weaken the lungs, heart and other organs. And in those areas where quarries employed a significant percent of the population, suffered dramatically higher death rate from Spanish flu. Several references are cited which document these rare sites were data was actually collected. Barre, Vermont. The factory and town were known for producing cemetery monuments. Monument workers understanding the potential risk of death from the pandemic and existing compromised health conditions (lungs) from granite dust, endeavored to prepare their own tombstones. In Barre, 75% of those graves sites are marked with monuments of their maker. Data from monitoring granite dust levels and the accumulation and health impacts on folks living near and frequently visiting the area close to such quarry mines, is limited. The health of folks is not monitored over long term. But there are EPA threshold standards established for exposure, and since those levels at and around the Wakestone quarry are at times higher than those EPA standards, closely monitoring and publishing exposure data should be part of the criteria for any quarry going forward, as well as the liability of Wakestone. In the case of Umstead park visitors also travel close to the quarry, they should be first warned, their journeys documented and real time risks of PM2.5 concentrations shared with those visitors. In cases of more frequent visitors and exposure on days of higher levels, the health of those visitors should followed over time & should be part of the monitoring program. And during the time of a pandemic, folks that visit Umstead or live near it, should be followed and tested as to the impact of PM 2.5 dust creating existing conditions that might make them more susceptible illness and even death when exposed to the COVID-19. If we follow the past and do little monitoring and no testing for impacts of PM2.5 on COVID-19, then one would have no deaths from COVID-19. Better stated: "NO scientifically verified deaths." This approach of course is unacceptable. But even if we do know monitoring of PM 2.5 and levels of exposures to those visiting or living near these quarries, there is no way to link any time of a pandemic or just years of expectancy of life, without tracking. And no way in future to monitor levels PM 2.5 exposure, the frequency, and the impact on the quality of life of folks that do visit Umstead Park for vigorous recreation and natural enjoyment. Also as further scientific studies are produced in various parts of the world on the impact of PM 2.5; the data collected at Umstead, could identify health risks for our citizens in the future. Not tracking individuals that visit or live near the site, not monitoring their health conditions over time and not knowing their collective exposure over time to quarry dust, is not acceptable. The easiest and most economical solution is not grant mining permission especially for areas where visitor populations and those living in the near vicinity are high. A final alternative could be to close portions of Umstead Park near the quarry to visitors, and simply monitor those that live nearby. While the loss part of the park is unfortunate, at least the safety of those individuals is put first while studies of those that live nearby can be monitored over time, and in this case probably decades. Citations follow: Crystalline Quarry Dust /// PM2.5 Shown to be produced in Quarries Processes: Blasting, Hauling Trucks; Hydraulic Hammering, Crushing, Grinding, Screening All of which take place at the Wake Stone Quarry adjacent to Umstead State Park. At sufficient levels/exposure Creating Health Issues: TB, Silicosis, Asthma, Cancer, Bronchitis Referencing quickly SEVERAL articles (of many) concerning Quarries / Crystalline Silica: health effect on lungs — in relation to the Spanish Flu & COVID-19 https://www.mz.co.nz/national/programmes/sunday/audio/2018663721/jason-reeve-compiling- the-first-list-of-nz-s-spanish-flu-pandemic-victims Compiling the first list of NZ's Spanish flu pandemic victims 23 Sepember 2018 RNZ reported Jason Reeve: Occupations of deceased due to Spanish Flu "There was two reoccuring occupations that absolutely jumped out of the data ... it's blacksmiths and miners. https:Hen.wikipedia.org/wiki/Hope—Cemetery Hope Cemetery Barre, Vermont. The city calls itself the "Granite Capital of the World", and the cemetery is known for the superb granite craftsmanship on its memorials and tombstones. Barre is also home to the world's largest "deep hole" granite quarry, the Rock of Ages quarry, One of the main uses of granite throughout the country was in tombstones and memorials. It is estimated that one-third of all memorials in the United States came from Barre.r"xa"°" needed] Silicosis, a respiratory disease caused by granite dust, was common among the artisans and sculptors who were breathing it in every day, which led to an abnormally high death rate. In addition, the 1918-19 Spanish flu epidemic caused many additional deaths, adding to the need for tombstones.'Q Knowing that death was imminent and possibly around the corner, many sculptors were given to designing their own tombstones to showcase their skill. It is estimated that 75% of the tombstones were designed by the occupants of the graves.0 https://vermonthistoiy.or flu-epidemic-1918 https://www.nytimes.com/2020/05/14/business/1918-flu-memorials.htmlIn Vermont, Mr. Zecchinelli decided he was uniquely situated to light a torch in this darkness. His grandfather and dozens of his colleagues perished, he learned, because Germinio worked in a poorly ventilated granite factory, where he and others breathed in vast amounts of dust. A lung disease called silicosis was an occupational hazard and left them vulnerable to the influenza. No policies concerning risks OR MONITORING for those that live near -by, visit the park No notifications of possible health risks, Blasting dates & times or Wind directions No tracking No testing of individuals over years as to measure impact of exposure "Slow the testing down" as suggested by some for COVID-19 is terrible, but at Umstead we have NO testing. Yes, limiting testing of COVID-19, there will be less reported cases BUT that does nothing to the number of actual cases. https://www.nvtimes.com/2016/08/04/ODinion/health-secrets-of-the-amish.html Amish children have little high immunity to asthma, while other children in the past few decades are showing a high level of problems ... b Why in a study of two closely related Amish sects, immunity was only in the Amish sect. b Their way of life was essential the same But living beside domestic animals seems to have produced an immunity in one sect. Notes from studies ... Millennials (26-40) while less likely to die from COVID-19, still demonstrate Ground -Glass Opacification ... YOU WILL NOT KNOW FOR YEARS and like with exposure to SiO2, health impacts worsen over time, sometime leading to death. Policies: Currently is there testing & tracking, monitoring data: air quality, silica, Risk > in young children & babies: take in more air; immune system; pre-existing conditions Folks exercising in Umstead State Park will breathe more deeply and consume more air Doug Michaels: OSHA head 2009-17 reports: PM2.5 PM10 National Ambient Air Quality 150 microgram/1\43 Crystalline Silica Dust 4 scars and can lead to silicosis OSHA lowered PM2.5 / SiO2 exposure standards in 2016 (not implemented by the Trump administration). So currently no OSHA standards to exposure ... N95 masks could would filter our PM2.5 PM2.5 & PM10 micrometer levels are studied since they can penetrate deep into the lungs Buffer setback for Washington State 150% Alaska 400% Wake Stone: 50' (40 lb rock went >1300' after a blast at a Wakestone quarry). Transparency: Some Wake Stone maps and permit conditions NOT available to the public Need Better Regulation, montoring, public notification, Buffers, wind direction Asthma, tuberculosis, Silicosis, cronic bronchitis ... creating even a minor `existing condition' increases severity of illness with an existing COVID-19 Pandemic The rise of silicosis in workers in quarries brought about monitoring and safety for the workers But there are no regulations for those that live nearby or venture on the trails close to the quarry. i.e. no limit for Si02 exposure. In fact, since the RDUAA is exempt from Wake County UDO regulations ... Wakestone is not subject to regulations requiring special use permit. THE QUARRY EXPANSION SHOULD BE REVIEWED UNDER THE NC STATE EVIRONMENTAL PROTECTION ACT comply with those permitting, safety & regulatory policies, as well as the Wake County UDO regulations which apply to all other quarry operations in the county should be applied. 12 micrograms/m3 reduced to 3 micrograms ... monitors have shown 200+ micrograms after blasting at points outside the quarry. Air/wind conditions & blasting time -table public announcements, tracking folks in the area, etc. Air quality from Blasting of course sees a rise in crystalline silica BUT if you are down 100' in the quarry, the mixing with surface level air is less than if the blast were at surface ... That is where this new mine would be. Visitors or close by residents are not notified of blasting schedules, wind directions ... even for trails may be nearer the quarry site — so at these times & days, show more caution. Randall & Tamere Randall Dunn 2232 Old Reedy Creek Rd; 1.2 acres adjacent to the park 2011 Allen Betsy Beals 2335 OldReedy Creek Rd; purchased in 1971 He lived there 43 years before his death 5 years ago after a long struggle with cancer Wake Stone: 219 acres Land & buildings & mining operations: WC tax value - $1.737M (land: $1.344M Odd Fellow Track: 105 acres bordering on Umstead State Park, Crabtree creek, East Coast Greenway Wakestone: Mining for —38 years ... Conservation Fund & Umstead State Park offered $6.46M for all to enjoy as a park. Wake Stone $1M/yr for a 25 year lease (it would be 14 years before the two offers matched in value). Wake Stone ownership: In 1984, in the prime of health, John Bratton gave his stock in Wake Stone equally to his seven children, but with strings attached. Johnny Bratton and his two brothers, who run the company, got the only shares with voting rights. DATE of mining operation, size of site, concentration levels & risk levels During the early years of quarry mining at Umstead, it was close to the surface, few homes around and no monitoring. This new quarry will be at the surface again and exposure to dust will be higher. Umstead State Park 2018 saw 1.84M visitor days per year (up 35% from year before) 5000 acre highly used State Park & highly visited Lake Crabtree; often there for exercise NO social distancing from the Quarry, NO masks suggested or supplied — even on highly active blasting days, high wind days, etc. In Umstead, @ quarry site silica dust is deposited on rocks in the creek, on plant leaves, in the air, washed off the roads coming into the quarry Site is required to wet down areas within the quarry to diminish silica dust It impacts health of plants, animals and humans ... the closer to the quarry site, studies have shown that concentration of SiO2 is greater and can lead to greater health risks. The main difference was that cattle with the Amish were at their individual homes ... the other sect were kept herd together but away from their homes. "We are all in this together" takes on a shift in meaning of the term "ALL"1 year old pigs living close to quarries were shown to be highly susceptible to silica dust & lung damage. Higher levels of exposure to silica dust & and longer time frames leads to more frequent and severe cases of silicosis.