Special Concerns about AIR POLLUTION and Frac Sand Mining in Wisconsin
The demand for this sand could be as insatiable as the demand for oil, gas, and coal. The volume of sand that could be removed from Wisconsin would be exponentially greater than our traditional extraction of sand for local uses. Thousands of acres of of hills, farmland, and forest will be removed with these large quarries as deep as 100 feet. To protect public health it is important to know how this will increase PM pollution.
• Mining of sandstone will create freshly fractured silica dust, which is more harmful than “aged” silica dust. Mining and processing will continue indefinitely, and year round. This means there will always be freshly fractured, sharp-edged crystalline silica dust in the air.
• DIESEL and other combustion emissions will also contribute particulate matter pollution. • The purpose of Air Quality Permits, as issued by regulatory agencies, is to ensure the
protection of natural resources and the public health.
• Neither the Wisconsin Department of Natural Resources nor the EPA have set a standard for Respirable Crystalline Silica, despite it being a known carcinogen. The safe level of respirable crystalline silica is known, and other states have adopted this safe level as an air quality standard. Wisconsin has not.
• Wisconsin DNR was suppose to have completed a Silica Study by 2006, but they failed to do so. At the prompting of citizens, WDNR has recently begun this study and issued a draft report in December 2010. ( http://dnr.wi.gov/air/pdf/DraftForPublicComment- SilicaStudyStatusReport.pdf )
• Because there is no national or state standard for Respirable Crystalline Silica this air toxic is not modeled for Air Permits. Therefore, the amount of Respirable Crystalline Silica, also called “silica dust,” that will be in the air is not predicted before permits are issued.iii
• Permitting laws in Wisconsin do not seem to be strong enough to protect natural resources and public health from the threats imposed by large scale mining of this type, much like other states are finding their laws inadequate to protect against oil and gas drilling.
• The Department of Natural Resources and the Environmental Protection Agency do not always require mining companies to model the escaped (fugitive) dust when they calculate how much PM10 will be produced by a particular mining operation. The fugitive dust produced does not count against the mining company in determining whether or not their operations are major source or minor source polluters.
• In the past, mining operations both mined and processed at the mine site, allowing significant buffer zones of protection. Now, mining is occurring distant from processing plants located within cities near residential neighborhoods. This exposes more people to potential risks, and prevents buffer zones to contain harmful dusts.