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2018-12-12_REVISION - M2018016 (7)
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2018-12-12_REVISION - M2018016 (7)
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Last modified
12/27/2024 7:10:03 AM
Creation date
12/12/2018 2:16:33 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M2018016
IBM Index Class Name
Revision
Doc Date
12/12/2018
Doc Name Note
Impact Economic Assessment
Doc Name
Objection
From
Emily S. Andrews, Ph.D.
To
DRMS
Type & Sequence
AM1
Email Name
PSH
Media Type
D
Archive
No
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' Vulnerability to Health.Risks <br /> Significant increases in respiratory ailments are a concern for residents near sand <br /> ' and gravel mining. Mining, processing and transporting sand and gravel generate <br /> large quantities of silica dust,which is known to damage respiratory systems when <br /> inhaled. Studies of residential populations chronically exposed to dust show <br /> ' shortened life expectancy and high rates of cancer, infectious diseases, respiratory <br /> and heart disease, reproductive pathologies, adverse pregnancy outcomes, anemia, <br /> birth defects, and infant mortality. Children and the elderly, as well as groups with <br /> pre-existing lung or heart disease, are particularly vulnerable. <br /> ' DMRM understands that the excavation and processing of sand and gravel has the <br /> potential to raise significant quantities of this type of dust if not adequately <br /> controlled. DMRM proposals outline a number of controls to minimize dust <br /> generation ensuring that the mine will stay in compliance with all state dust <br /> regulations.43 <br /> ' However, the DMRM suggested methods are not necessarily the best. One study <br /> indicates that chemical dust suppressants are the most effective at controlling dust <br /> at the gravel processing site but that these methods are much more costly. The <br /> ' other control strategies that DMRM is suggesting, however, can work if they include <br /> increasing the frequency of water spraying, implementing the use of windbreak <br /> fencing, and re-vegetation.44 Further review and more information about DMRM's <br /> ' methods of controlling dust would help us understand if they are using the best <br /> approaches possible. <br /> ' Nonetheless, according to the Environmental Protection Agency,there is no evidence <br /> of a safe level of exposure or a threshold below which adverse health effects will not <br /> ' occur from gravel mining.45 Exposure is influenced by proximity to the source, i.e., close <br /> proximity leads to higher exposure and higher risk. Other factors include winds and <br /> 43 DMRM-July 2018 states: "Stockpiles and roads will be watered as needed to minimize <br /> dust.This will occur multiple times a day during the height of the summer and less <br /> frequently in colder or lower activity times of the year.All crushing and screening <br /> ' equipment will operate with spray bars to wet the material during processing and is a <br /> proven very effective method of dust control.Stockpiles of topsoil and overburden that will <br /> be in place longer than 120 days will be seeded with vegetation to prevent erosion and the <br /> ' spread of dust. Crushed gravel will be placed on areas of the site that are regularly <br /> trafficked including the access road. Due to the regularly changing nature of the interior of <br /> the site, no areas will be paved.' <br /> ' 44 Chang, Chang-Tang et al. 2012. "Fugitive Dust Emission Source Profiles and Assessment <br /> of Selected Control Strategies for Particulate Matter at Gravel Processing Sites in Taiwan," <br /> Journal of the Air&Waste Management Association, page 1268. <br /> https://www.ncbi.nlm.nih.gov/pubmed/2109OSS4 <br /> ' 45https://www3.epa.gov/airnow/particle/pm-color.pd <br /> 17 <br /> 1 <br />
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