Vulcan has applied for Permit # 76337, a new source rock crusher permit,
from the Texas Commission on Environmental Quality (TCEQ). TCEQ held a
public meeting on this proposal on April 10, 2006. Over
200 persons attended the public meeting, most of them MCEAA members
opposed to the quarry. However, the draft permit at that time had not been
finalized. Additional changes have since occurred to purportedly finalize it. The public comment period closed on July 21, 2006.
MCEAA has requested a contested case hearing from TCEQ, and did so in the
initial public comment period for this permit in August of 2005, before it
was withdrawn and resubmitted.
Vulcan has directly referred the case to a contested case hearing on September 12, 2006, at 10:00 a.m.
The contested case hearing will be held on the second floor of the Medina County Courthouse in Hondo.
Particulate matter (dust) from the quarry is a serious concern. Silicosis
and other ultimately fatal respiratory health threats are a reality of
living near quarries that do not control fugitive dust. Vulcan's own modeling data shows that those living west of the quarry site will have a 10.7-acre stockpile along their fence-line, which will cause exceedances of the "Effects Screening Level" for limestone (silica) 54 times per year. In addition, the modeling also shows that the state propertly line nuisance standard (conveniently repealed by TCEQ) will be nearly equaled. No doubt the standard would be exceeded if Vulcan's modelers would include the blasting and operations inside the quarry pit instead of modeling the crushing and loading operations in the south portion of the site in a vacuum.
Vulcan says that it will control dust by using vast quantities of water, but refuses to provide a basis (in gallons per ton) for that water use. Vulcan's existing Loop 1604 quarry is permitted to use 740 gallons per ton for washing and dust control, which would mean truly astronomical (11-18,000 acre-feet/yr) use for the proposed Medina Quarry at peak operation (5-8 million tons). Vulcan says it does not and will not use that much, but refuses to state the basis for the numbers in its Medina County proposal. The source, quantity,
and enforceability of actual water use are factors hidden from public view.
In addition, Vulcan does not even consider fugitive dust from blasting and
other quarry pit operations.
TCEQ styles the air permit as a very narrow inquiry into emissions from
the rock crusher. But the reality is that TCEQ must assess and model
background emissions from other parts of the quarry to avoid analyzing the
crushers in a vacuum.
Ultimately, the air permit is completely unenforceable, because there is
no way to verify if Vulcan is attaining the moisture content of the rock
that it alleges will keep it from tripping regulatory emissions thresholds.
In addition, the permit application contained no monitoring, on site or off
site, for anything other than visual opacity, which is not tied to any
health-based standard.
MCEAA's Comments on the Proposed Air Permit are now posted:
Comments and Exhibits
You can also consult MCEAA's air quality handout and the Loop 1604 background document (showing water use of 740 gallons per ton for washing and dust control, permitted by the Edwards Aquifer Authority).