Hwa Huang_ Letter to DEMLR on Mining Permit 92-10, July 17, 2020

Date: July 17, 2020
To: Director Brian Wrenn, Division of Energy, Minerals and Land Resources (DEMLR), NCDEQ
Engineering Supervisor and Hearing Officer Dan Sams, DEMLR, NCDEQ
From: Hwa Huang, Raleigh, NC
Re: Comments on air quality permit for Wake Stone Corp., Application for Modification of Mining
Permit —Triangle Quarry Mining Permit No. 92-10
Dear Director Brian Wrenn & Hearing Officer Dan Sams,
I am writing to the DEMLR of NCDEQ to call for the denial of the mining permit 92-10 based on
§ 74-51.(d)(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.
I would like to bring to your attention the concern with air quality. In the inspection report of
Wake Stone's quarry in 2019 (See attached document:
air quality inspection_ report_ Wake_ Stone), it was shown that the TSP emission reduced from
11.66 in 2007 to 1.53 in 2012, and the PM10 reduced from 4.35 in 2007 to 0.79 in 2012. To my
understanding, no measurements were done, and these reported emissions are only based on
crusher size and type of aggregate processed. I would like for a further investigation to better
explain how and why the emission was able to go down so dramatically in just five years. One
way to make sense of the report findings is that these recordings merely represent snapshots at
the time when the inspector was present. It is possible that dusts will settle within a few minutes
after operation comes to a stop. An inspection that took place just after a rainy day, as opposed
to a dry day with moderate wind, can lead to very different outcomes. On the subject of
difference in outcomes, it should also be noted that as the proposed quarry operation would
take place on the surface of Odd Fellows Tract for many years before becoming a pit itself, the
emission would be expected to increase and even exceed prior emissions.
Furthermore, I would also like to know if the inspection was done under similar, if not same,
conditions. It is a more accurate depiction of the air quality at the quarry site if inspections take
place not once in every five years, but daily, if not hourly. This is especially the case given the
proximity of the quarry to the William B. Umstead State Park. Based on the survey results
collected by Elizabeth Adams, a member of the Umstead Coalition and the Sierra Club Capital
Group, out of the 610 individuals who have taken the survey.
• Over 70% of the trail users visit daily
https://datastudio.google.com/u/O/reporting/77843e9d-a90b-484b-ae8f-e94b9b504l fc/pa
ge/tJQVB
• Over 50% of the trail users visited the park for over 10 years
https://datastudio.google.com/u/O/reporting/77843e9d-a90b-484b-ae8f-e94b9b504l fc/pa
ge/OHQVB

• 28.2% of the survey takers also indicated that they brought children to the Umstead
State park
https://datastudio.google.com/u/O/reporting/77843e9d-a90b-484b-ae8f-e94b9b504l fc/pa
qe/5WPVB
• The Reedy Creek Entrance (Harrison Ave) of Umstead State Park and the Town of
Cary's Old Reedy Creek Road Trailhead were considered two of the most popular
entrances for the trail users.
https://datastudio.google.com/u/O/reporting/77843e9d-a90b-484b-ae8f-e94b9b504l fc/pa
ge/S6PVB
• For comprehensive analyses, visit the site here, which consists of 17 pages of data
results:
https://datastudio.google.com/u/O/reporting/77843e9d-a90b-484b-ae8f-e94b9b5041 fc/pa
ge/QSPVB
Based on the survey findings, the Umstead State Park and its trails are used very frequently by
the public, who may not be wearing the necessary protective clothing or gears for chronic
exposure to dust and other factors contributing to reduced air quality. This is a very different
scenario from a quarry operation that takes place in an industrial setting. To better assess the
impact that the quarry operation has had on the park and trail users who have been visiting the
state park, many of them daily for over 10 years, an inspection of the air quality of the quarry
site that consists only of a snapshot with a five-year gap seems inadequate. I believe that as
there are risks to public health that do not seem to be considered, the permit application
modification should be denied, and Wake Stone should apply for a new air quality permit, one
which takes into special consideration that it is next to the state park.
In addition to concern for public health, I will also call for denial of permit application per §
74-51.(d)(5): That the operation will have a significantly adverse effect on the purposes of a
publicly owned park, forest or recreation area. Based on the trail user survey mentioned above,
one of the biggest negative impact that this proposed quarry operation would concern the
survey users is, "Access to the trails (what if Old Reedy Creek Road) closed due to loggings?)"
https://datastudio.google.com/u/O/reporting/77843e9d-a90b-484b-ae8f-e94b9b504l fc/page/o5P
VB
A letter in which I would like for DEMLR to take into serious consideration is the one which was
sent to me by Greg Ford, chair of the Wake County Board of Commissions, in order to inform
me that the commissioners have been very clear that conservation of the Odd Fellows Tract is
one of their major priorities as per his quote in his email message that "the Board resolved to:
Ensure the permanent conservation of the Odd Fellows Tract". Please see the three letters
attached to my email from Wake County.
In addition, the Division of Natural and Cultural Resources have also sent a letter stating
explicitly that "industrial mining is generally not conducive to the support and promotion
of or compatible with the very elements that led William B. Umstead State Park to being

listed on the National Register of Historic Places: land restoration through landscape
design and outdoor recreation". A list of the state park's concerns with the proposed quarry
operation can be summarized as below. (See also attached: Letter from Division of Natural and
Cultural Resources)
o Wake Stone or RDUAA would propose to build a fence, which is not compatible with
Umstead State Park's character and recreation purpose
o There's need for more study on how much noise and dust would be created for hikers
using Reedy Creek Road once trees are cleared out. Let DEQ know also, that this is a
very popular greenway for hikers and bikers. If you have photos to go with that, even
better!
o There's lack of evidence that the berm would reduce the noise impact
o There's lack of evidence that there'd be no increased lighting at night. Increased night
light would disturb the park as rustic retreat, and also nocturnal wildlife's routine.
o There are potential undiscovered prehistoric Native American resources. If true, the DEQ
should take greater measures to ensure protection of the land from mining and
excavation of a private corporation.
It should be reminded that the DEQ had once denied the quarry initially in 1980, "on the basis of
having an adverse effect upon the park, G.S. 74-51(5), including "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." See the following documentation:
https://umsteadcoalition.org/resources/Documents/Wake%20Stone/24-August%2022%201980,
%20Denial %20of%20Wake%20Stone%20Corporation%20Perm it%20Application. P D F
The DEQ only relented to give the land next to Harrison Ave entrance provided Wake Stone
ends operation in 50 years. However, Wake Stone changed the wording on the Sunset Clause
to allow for indefinite mining in 2018, after multiple reviews over 30 years with no objections.
Please see the following documentation from:
• 1986:
https://umsteadcoalition.org/resources/Documents/Airport/Wake%20Stone%20Permit/l 9
86%20April%2015%20permit%20Mod ification, %200 RC'ed. pdf
1991:
https://umsteadcoalition.org/resources/Documents/Airport/Wake%20Stone%20Permit/l 9
91 %20Apri1%201%20Signed%20Approved%20Perm it%20Renewal, %20ORC'ed.pdf
• 1992 & 1996:
https://umsteadcoalition.org/resources/Documents/Airport/Wake%20Stone%20Permit/l 9
92%20Feb%205%20%20And%20October%2011,%201996%20Approved%20Perm it%2
OMod%20for%20temporary%20extension%20of%20Saturday%20sales, %20includes%2
OSigned%20Approved%20Permit%20Mod%20Feb%205%201992,%200RC'ed pdf
2001:
https://umsteadcoalition.org/resources/Documents/Airport/Wake%20Stone%20Permit/20
01%20April%2020,%20Approved%20Perm it%20Renewal, %20ORC'ed.pdf
2010:
https://umsteadcoalition.org/resources/Documents/Airport/Wake%20Stone%20Permit/20

10%20November%2024,%20Signed%20and%20approved%20permit%20mod %2092-1
0,%200RC'ed.pdf
• 2011:
https://umsteadcoaIition.org/resources/Documents/Airport/Wake°/`20Stone%20Permit/20
11%20March%2020%20permit%20renewal,%20and%20December%202017%20permit
%20(hand%20writting%20is%20by%20DEQ%20staff%20mad e%20in%202018%20for%
20wake%20stone%20request. pdf
• Wake Stone has made not call for change with the language sooner for almost 30 years
until December 2017, see where the word "sooner" was changed to "later" in a
handwritten annotation:
https://umsteadcoaIition.org/resources/Documents/Airport/Wake°/`20Stone%20Permit/20
11%20March%2020%20permit%20renewal,%20and%20December%202017%20permit
%20(hand%20writting%20is%20by%20DEQ%20staff%20mad e%20in%202018%20for%
20wake%20stone%20request. pdf
• It was not until 2018 that the permit was changed to the word "later", with no public
notice or consultation with the NC State Park:
https://umsteadcoaIition.org/resources/Documents/Airport/Wake%20Stone%20Permit/20
18%20March%2028,%2092-10%20MOD%202018%20%20Wake%20Stone%20Mining
%20permit%20amendment,%201 st%20permit%20to%20have%20'late r'%20instead%20
of%20'sooner'%200RC'ed.pdf
Wake Stone's quarry operation was initially unwanted by the state park for its impact on this
facility which has been enjoyed by the public for decades, and its actions, including the
attempted change of the Sunset Clause to allow them to mine indefinitely in the area as
opposed to ending it by 2031, will continue to harm the state park in increasingly detrimental
manner. Please take the concern from the Division of Natural and Cultural Resources, Wake
County Commissioners, as well as other organizations and individuals, into consideration, on
how the operation would harm public land and a state park, and deny this permit application.
Thank you,
Hwa Huang
7401 Ebenezer Church Rd
Raleigh, NC