SCS Engineers and Dr. Paul Damian - A Summary of Findings

Paul Damian, PhD, MPH, DABT, is the National Practice Leader for Risk Assessment and Toxicology with SCS Engineers in Sacramento, California, and a Board Certified Toxicologist. He was hired by the Coalition to assess the health risks caused by the Quarry’s blasting, mining, crushing and materials transport activities. In a letter that was included in the Coalition’s response to the FEIR (see below), he identified health issues related to these activities that were inadequately addressed in the FEIR. His focus was on crystalline silica (C-silica) and diesel particulate matter (DPM) generated by these activities that have been identified as carcinogenic and hazardous to health by California, federal and international health organizations such as the International Agency for Research on Cancer.

He distinguished between naturally occurring or "aged" C-silica and that which was created recently by the blasting, mining and crushing of rock that occurs at the Quarry. The latter C-silica has sharp, jagged edges while the former generally has smooth edges. If inhaled, the "jagged" C-silica lodges in the lungs and is not readily expelled. It accumulates in the lungs, causing irritation that can result in lung damage such as silicosis and cancer. C-silica created by blasting is also much more chemically reactive than "aged" C-silica. This increases the irritation to the lungs. This problem can be compounded with the co-existence of other particulate matter such as DPM (from diesel trucks), which is a carcinogen in its own right.

Dr. Damian finds that many of the statements and conclusions in the FEIR with regard to the danger of C-silica and DPM are misleading and significantly underestimate these dangers. He found that the FEIR did not include any supporting evidence regarding the expected highest 1-hour concentrations of these two contaminants nor any short-term averages of them and that no acute evaluation of them was actually conducted. He points out that, in fact, the FEIR modeling files which he reviewed show that the maximum 7-hour average concentration of C-silica is roughly 20 times greater than the American Conference of Governmental Industrial Hygienists occupational exposure limit. However, this information was not included in the FEIR nor taken into consideration in the FEIR findings.

Dr. Damian points out that the health risk assessment improperly averaged risks over a 70-year period with the assumption that the Quarry would operate for 17 years and then cease operations for the remaining 53 years. However, (1) there is no commitment by the Quarry that it will cease operations in the 17th year (and strong reason to believe it will continue to mine indefinitely) and (2) the FEIR does not consider the short-term health risks to individuals exposed to these contaminants during the operational timeframe, including young people and the elderly.