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Transportation Officials. He said they have established standards for sampling that are <br />clear and objective that when sampling deposits of this kind, one must separate units of <br />rock of different character. He said that EGR mixed the two. He commented if the lower <br />part alone fails the test, then under his reading of the rule, it would mean it would not <br />pass the significance criteria under the rule. <br /> <br /> Reed stated in response to that criticism, EGR took some new samples. He said they <br />responded by getting laboratory tests on the lower unit alone, but their tests only took six <br />and a half feet of material out of a total of 35 feet. He said that was a failure of <br />representative sampling, as it calls for sampling all of the material over the interval. He <br />commented that all or part of the lower 35 feet of the rock may fail the test. <br /> <br /> Reed noted in their final rebuttal before the Planning Commission, EGR contended <br />wrongly that the standards “state that it is preferable to sample the rock as processed as it <br />will be used to assure that it will meet the standards in its ready to use state.” He thought <br />that was an incorrect reading of the standards. He said they took part of the standards on <br />the sampling of processed rock. He noted there is another standard that addresses the <br />sampling of rock in the ground instead of rock that had been processed. He said there is <br />nothing in the OAR that would disallow the processing of the rock prior to testing it. He <br />said they brought up the argument in context of trying to justify mixing the full extent of <br />their sample. He said if they process it before they test it, they are biasing the result. He <br />said in today’s testimony they brought up new work by ODOT in relation to the <br />DOGAMI opinion. He commented that DOGAMI in their opinion fails to address the <br />sampling issues he is raising. He said they defer to ODOT. He said ODOT does testing, <br />they don’t do geology. He indicated in his review of the ODOT sampling, that they <br />referred to late in the testimony today, it appeared that is not a representative sampling to <br />address before the closure of testimony. He said from what he had seen tonight, the <br />ODOT samples are not representative because they are not all inclusive. He commented <br />there is a resource of lava that they could mine and they don’t need to take high quality <br />farmland for aggregate. <br /> <br /> Dr. Steven Kimberly, Eugene, stated he is a board certified specialist in internal medicine <br />and works full time for WebMD creating health risk appraisals. He reported for the past <br />ten years he had specialized in health risk evaluations and research. He stated he had 25 <br />years as a physician. He discussed rock dust. He said that rock dust pneumoconiosis is <br />the name for the disease in quarry workers and others who have been exposed to <br />significant amount of rock dust over a significant period of time. Rock dust <br />pneumoconiosis is a type of emphysema. He said there are two measures of dust they use <br />for evaluating particulate matter: PM 2.5 and PM 10. He commented that particulate <br />matter of that size is invisible to the naked eye. He said there would be no assurance that <br />that dust was not being carried as PM 10 as far as ten to thirty miles and PM 2.5 particles <br />could travel farther. He said PM 10 particles are larger and tend to get stuck in the <br />sinuses and the upper airways and don’t make it down to the lungs. He added PM 2.5 <br />goes down into the lungs and can cause significant lung damage if enough is breathed in. <br />He explained there is a difference between the organic dust they see from agriculture and <br />inorganic dust that is rock dust. He said that inorganic dust cannot be broken down by <br />Page 9 – Joint Elected Officials' Meeting – December 12, 2006 <br />WD bc/m/06121/T <br /> <br />