“From the Comments” dept. — Jim Drost on “documentation that should be collected”

Hi all,

I will periodically pull some of the comments up into the blog so that people will have a better chance of seeing them.  Here’s the first post like that.  Originally posted as a comment on the Steal These Documents page and a darn nifty addition to the list of standard documentation that should be collected when reviewing a sand-mine application.

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Jim Drost says:

Jim Drost is a graduate of the University of Wisconsin Engineering School holding Bachelors and Masters degrees in Mining and Metallurgical Engineering. He has Worked for ALCOA, Lead Smelters, Foundries, etc. While employed with the U.S. Bureau of Mines he researched the Reserve Mining—Silver Bay, MN debacle. His Masters thesis studied the effects of chemicals on sand used for fracturing.

FRAC SAND MINING IN WESTERN WISCONSIN
Conundrum

“To mine or not to mine, that is the question.” Unfortunately, this riddle cannot, in all seriousness, be answered by a pun; nor can it be answered by our elected officials. The companies wanting to mine could answer the question most of the time; they choose not to answer any question that goes to weight against them. Our elected officials should not be expected to know the answers to the hidden problems; however, they do have the responsibility to keep an open mind and find a way to educate themselves. The Wisconsin Constitution states that their first priority is to the health and welfare of their citizens (their health is first and then their welfare). This is a difficult job, especially when miners are auguring on them and flashing dreams of large amounts of money.

There are good signs that our officials are doing their best to sort it all out, but it is almost an insurmountable job. Listed below are some of the questions that need to be answered case by case:
1) What is the hydrology of the area where they wish to mine and process?
2) What is the topography of that same area?
3) Is there a runway for run-off water such as a creek, river or marsh? If so,
can the runway be successfully protected?
4) What kind of aquifer exists in the area? How fragile is it? How many
gal./min. can it provide? How will this affect the others using the aquifer?
5) How big an operation do they plan on having? Does the size of their equipment indicate later expansion? Is there sufficient space to properly and safely protect the environment, etc.? Could the area be protected with double or triple the expansion?
6) Does the company answer pertinent questions, or do they fall back on the 5th amendment by saying “that is proprietary information”? Companies have been mining frac sand since the 1940s when Halliburton was the first to do “fracking”. There have been minimal changes during all that time.
7) Will the Town and County Boards be able to rely on the DNR to assist in their decision- making process, considering the DNR’s now-diminished role?
8 ) Can the Boards allow self monitoring of air and water pollution? Is one air monitor and one sentinel well enough? Should the Boards require an independent firm to do the testing at the miner’s expense?
9) What pollution controls should the Boards be applying to conveyor belts moving sand across multiple properties in one Township and across Township lines?
10) Should the Boards be granting rezoning in wetlands and marshes too fragile to protect?
11) Should not the Boards investigate the company’s record of accidents and violations? Should the Boards check how many names and LLC changes have Occurred?
12) Given the sensitivity of children to silica air pollution, should any dry plant be allowed within a mile of a school? What kind of chemicals are in and on the silica dust?
13) Are other companies holding to their required level of pollution control?
14) Will the US Highways and other roads hold up to a continual pounding of 80,000 Lb. trucks? Has a qualified engineer inspected the proposed route?
15) Does the company’s reclamation and disposal of sludge and tailings plans stand up to the known data? Can the Boards trust the off-the-cuff data that the companies provide?

In addition, officials need to also address the following issues:

1) Insist on a complete list of all chemicals used, no matter the amount. Insist on knowing how each chemical is used, the chemical’s toxicity impact, a water flow chart, how much water is used, how much water is recycled, how much water is spilt. (Companies refuse to call this waste water, and yet they will not say how it is disposed; they avoid this question by simply refusing to answer.
2) There is a need to coordinate between Towns and Counties, as this explosion of mining companies and farm irrigators will draw down the aquifers in all the counties around the area. Since eastern Barron County’s aquifer is one of the most bountiful and quickest to renew, this county will have the problem that the water flow within the aquifer will have water directional changes, leading to aquifer pollution from contaminates released by mining companies being sucked into the aquifer and eventually polluting the entire aquifer. The Counties and Towns need to have a unified approach, rather than everyone for themselves, which results in an over-all-damaged patch-quilt disaster. At the rate mining companies are proposing plants, all Town and County Boards should consider moratoriums until the Boards can have a unified enforceable set of rules which will protect the health and welfare of citizens, while limiting mining to what the regional environment can handle. Do not expect help from the State or the DNR; as a people you must be pioneering in this effort.
3) As of now, the Wisconsin State Politicians are busy dismantling the mining laws and the wetland laws. If you want anything left that resembles fresh water lakes and streams full of life, then get involved. Make them mine correctly!

There are many examples of companies that have assured the citizens of an area that everything was perfectly safe, but too late the citizens realized it was not. Examples are:
Pacific Gas & Electric, (PG&E) Hinkley, Ca. (Movie named “Erin Brockovich”)—- Love Canal, NY—–Reserve Mining of Silver Bay, MN—Flambeau Mining (Kennecott Mining) Ladysmith, WI—–Hurley, WI cannot drink their tap water due to mining iron ore that unearthed toxic heavy metal sulfides more than 40 years ago.

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