Thursday, December 29, 2011

Will Sparta's Conditional Use Permit Protect You? Maybe Not!

Will the current conditional use permit for Sparta's sand mine protect you? One local resident is dubious. Here's what she had to say about it.

First, here's a link to US Silica's Conditional Use Permit for the Sparta plant, located here:

Now, read Donna Evans' analysis of the permit and how what it describes would translate into Sparta's everyday life with a sand mine.

See page 14 about station 1:
"From station 1, the sand will delivered to wet attrition scrubbers, which clean the grains before they
are hydraulically classified (station 2) into two streams – one coarse and one fine. The fine stream of
sand will be pumped to a location where it can be either further processed at a later date, or returned
to the mined out section of the mine pond for deposition."

"Since mining and operation of the wet plant are seasonal, coarse sand surge piles will be established
each year in order to allow the continuous operation of the dry plant. The surge piles will be
depleted by early spring each year."

"The coarse sand stream will be placed in surge in front of one or more natural gas fired fluid bed
dryers, which will remove all residual moisture from the grains."

It is my understanding that some of the large stationary piles of sand that I have seen off Hwy N in Oakdale are referred to as "the fines", which, according to this CUP would make sense. The "fines" are not the ideal grains used for the final product, they are are smaller in size than the coarser grains, and can sit stationary in large piles for an extended period of time. So, my first question would be, do these "fines" emit harmful levels of fugitive silica dust? I would also question whether the larger coarse surge piles emit fugitive silica dust as well.

Finally, read page 18 of US Silica's Conditional Use Permit where it states:

"ii. Fugitive Dust Emission Controls
Emissions associated with sand mining, material handling, outdoor storage, and vehicle emissions are
referred to as “fugitive” emissions. Fugitive emissions will be controlled with best management
practices that include paving drive areas, watering dirt roads and stockpiles, application of nonhazardous
dust suppressants, limiting the amount of “open area”, restoring vegetative cover,
installing and operating spray bars on dry processes and conveyor drop points, installing wind
screens as appropriate, and general good housekeeping at the facility. Since dredge or wet mining
techniques will be used, little if any dust or fugitive emissions will be generated from actual mining.
The fines stockpiles and surge pile will likely be the biggest potential sources of fugitive emissions.
Controls will include regular visual emission observations, wetting the piles when visual emissions
are observed, and utilization of wind screening as necessary."

So, not only will US Silica be using groundwater to wet down dust piles, but local residents are relying on U.S. Silica's "visual observations" to determine if wetting is necessary? Didn't US Silica's MSDS state, "Do not rely on your sight to determine if dust is in the air"?

There is obviously conflicting information between what is suggested to be acceptable dust control in the Conditional Use Permit, and what US Silica's own MSDS states about protective measures in handling silica dust. The Sparta plant will be operating in very close proximity to residents, and this concern should not be taken lightly.

On a windy day like today, December 26, where gusts are up to 27 mph and there is hardly any snow, it is only logical to think that some level of fugitive dust is going to be a problem to nearby residents with a 100-200 acre open pit sand mine and very large piles of fine and coarse sand exposed to the elements (reference the youtube clip above). Would anyone would actually "wet" the piles down in the winter if there is no snow and when watering is impractical in low temperatures? At what point does U.S. Silica's visual observation warrant dust control implementation; is there a certain wind speed that dictates this? Do people have to complain first? Should sand processing plants be prohibited from operating withing a certain distance of schools and housing to protect people from blowing silica dust? These are just a few questions that should be addressed and clarified in writing prior to C.U.P. approval.

Due to these concerns, I believe the methods for controlling fugitive dust emission on US Silica's Conditional Use Permit are potentially inadequate for the public's best interest, and the C.U.P. was issued without allowing the Sparta residents and elected officials enough time to discuss and research this matter.

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