Additional questions will be added as more are shared with SWE. This grows as more review of the Bulk Sampling is provided. It is vitally important the WDNR receives feed back before September 3. If you have questions or need assistance contact savethewatersedge@gmail.com and include Bulk Sampling in the subject line. Thanks
Comment on GTac’s Bulk Sampling (A mini Mining Permit) Permit (For more information see the hearing announcement or read the DNR Webstie.)
30-day public comment period ends September 17th
Any member of the public may also submit written comments on the proposed bulk sampling activity or the preapplication description of the potential mining project. The DNR will review all comments that are received on or before Sept. 17, 2013.
Comments may be submitted via mail to Larry Lynch, DNR, 101 S. Webster Street, Madison, Wisconsin 53707, or by e-mail to: DNRWAMINING-GOGEBICTACONITE@Wisconsin.gov
Talking points:
A five year, $5 million University of Minnesota study of mine workers on the Iron Range showed three times the number of mesothelioma cases than the rest of Minnesota’s population. Asbestos fibers are linked to mesothelioma, an aggressive cancer that has no cure. “We’re a long ways away in this project to really understanding how waste material is being handled [or] what the nature of the waste material is,” says (Larry) Lynch. The fibers become airborne or end up in the water during mining operations. But Lynch says there are ways to control the release of the particles if they are present in the Penokee Hills.
What are the ways Gtac can use to eliminate the release of cancer causing particles?
If a permit is granted, will elimination of cancer causing particles meet a zero discharge threshold?
Who will monitor the air quality?
How will the air quality be monitored?
What evidence does Larry Lynch have to support his belief that there are ways to control the cancer causing particles from being released in the air, the soil, and the water?
How will GTac address improving the very poor way they have opted to manage the roads through the forest?
Will the number of armed guards be increased to patrol the roads and protect the trucks?
Which roads will be used to transport the bulk sample rocks?
Exactly what kinds of tests will the sample rocks will be used to test the rocks?
What is the purpose of the bulk sampling process?
How will the bulk sample sites be reclaimed, as the product will be removed from the sites?
Where will the bulk sample product be shipped?
What chemicals and /or explosives will be used or might be used to complete the bulk sampling process?
How will the groundwater be protected?
What does GTac and DNR hope to learn as a result of the bulk sampling process?
Although Gogebic Taconite has suggested it obtain sample rock from previously sampled material left onsite, WDNR must review the application assuming that (Ammonium Nitrate Fuel Oil) ANFO will be used at all five sites for the purposes of evaluating air, groundwater and surface water impacts, and wastewater collection and discharge.
Gogebic Taconite must supply maps and documentation detailing how it would deal with disturbing pyrite (a sulfide mineral that is the source of acid mine drainage) it may encounter in the targeted Plymouth, Norrie and Pence members of the Ironwood formation, and how it will avoid disturbing the pyrite-rich Yale member or the overlying Tyler slate.
Gogebic Taconite has stated no wastewater pumping and discharge will take place and instead proposes to design excavations to be "freely draining."
The application contains no information on the quality or quantity of the wastewater let alone where each excavation will drain. How will GTac define "freely draining" waste water?
GTac must provide a detailed description of where this water will be freely drained and a plan to remove all potential contaminants which may result from their bulk Sampling process?
How wili DNR should regulate each discharge as a point source.
Gogebic Taconite must submit a storm water permit, as DNR reported in a July 2, 2013 letter, and as required under s. 283.33, Stats.
A survey of threatened and endangered species, likely to occur in this area, should be conducted prior to sampling.
Gogebic Taconite must provide documentation to support its claim that asbestiform minerals such as grunerite, common in the Penokees, will not be encountered during testing.
GTAC must provide sufficient information to the DNR now, before it begins bulk sampling, in order for DNR to comply with its legal obligation to assess the potential impacts and necessary permits required under GTAC’s vague bulk sampling plan.
What is the specific information will DNR require from GTac for DNR to comply with their legal obligation to assess the potential impacts of GTac's Bulk Sampling plan?
Gtac needs to provide a detailed plan to address handling sulfide minerals, including management of of possible acid mine drainage into the groundwater and surface waters.
The WDNR requested that GTAC describe what precautions will be taken with respect to rock and water handling procedures if sampling unearths visible or known quantities of sulfide mineralization. Instead of answering the question, GTAC responded, “The Yale member is not proposed for disturbance with this activity. The target zones are the Pence, Norrie and Plymouth members.” Not only is the Yale member sulfide-rich, but the Tyler formation is also documented to contain sulfide minerals. Sulfide minerals may also be found within the Ironwood formation. From GTAC’s failure to answer the question, we can assume it will take no precautions to safely handle sulfide rock it encounters during the bulk sampling process.
Before a permit is issued, GTac must be required to submit a plan that includes precautions to safely handle all potential sulfide rock encounters. Has this plan been submitted?
GTAC must provide maps and documentation detailing how it would deal with disturbing sulfide minerals it may encounter in the targeted Plymouth, Norrie and Pence members of the Ironwood formation, and how it will avoid disturbing the pyrite-rich Yale member or the overlying Tyler slate. A complete bulk sampling plan must address how GTAC will deal with the disturbance of sulfide minerals in any members of the Ironwood formation so that it is prepared for all potential scenarios.
Before issuing a permit this information is important for public review and comment. This is especially important as all aspects of the Ironwood formation will be included if mining is allowed. This is the time to require complete information and analysis.
The WDNR requested that GTAC describe what precautions will be taken with respect to rock and water handling procedures if sampling unearths visible or known quantities of sulfide mineralization. Instead of answering the question, GTAC responded, “The Yale member is not proposed for disturbance with this activity. The target zones are the Pence, Norrie and Plymouth members.” Not only is the Yale member sulfide-rich, but the Tyler formation is also documented to contain sulfide minerals. Sulfide minerals may also be found within the Ironwood formation. From GTAC’s failure to answer the question, we can assume it will take no precautions to safely handle sulfide rock it encounters during the bulk sampling process.
GTac must be required to answer the question: If sulfide mineralization is found, what is the plan to protect the environment and human health?
This information will provide fodder for more questions for WDNR to ask for GTac's response before issuing the bulk sampling permit.
GTAC must provide maps and documentation detailing how it would deal with disturbing sulfide minerals it may encounter in the targeted Plymouth, Norrie and Pence members of the Ironwood formation, and how it will avoid disturbing the pyrite-rich Yale member or the overlying Tyler slate. A complete bulk sampling plan must address how GTAC will deal with the disturbance of sulfide minerals in any members of the Ironwood formation so that it is prepared for all potential scenarios.
No accounting for small streams and stream headwaters throughout the mining site.
GTAC has not submitted any information on how it will avoid harming the small streams and stream headwaters that it is likely to impact during the bulk sampling process. These streams and stream headwaters feed into the Tyler’s Fork and other feeder rivers for the Bad River, with the water eventually making its way to Lake Superior. Destroying these small streams and stream headwaters or contaminating them by the improper handling of blasting waste or sulfide minerals could irreparably harm downstream water resources.
Incomplete wetland delineation. Wetlands blanket the mining site and the DNR asked for a full wetland delineation. Why did G-Tac leave the access road out of the delineation when it has plans to continue to use that road and has applied for a stormwater permit to control erosion on that access road?
No information on impacts to groundwater. GTAC has conducted no studies, apart from a site inspection of the area, to determine the contours of the groundwater table in the areas set to be disturbed in the bulk sampling process. A high groundwater table raises the risk of groundwater contamination, and impacts to streams and wetlands. Why hasn’t G-Tac analyzed the location of the groundwater table?
No plan for treating water contaminated in the bulk sampling process. Gogebic Taconite has stated no wastewater pumping and discharge will take place and instead proposes to design excavations to be "freely draining." The application contains no information on the quality or quantity of the wastewater let alone where each excavation will drain to. DNR should regulate each discharge as a point source.
Failure to take precautions related to asbestos
As reported by Terri Hansen in Indian Country Today on August 6, 2013, the presence of asbestiform minerals could be very significant for GTAC’s mining and bulk sampling plans. According to the WDNR, asbestiform minerals (amphiboles of the cummingtonite-grunerite) are present in similar ore bodies in Minnesota, and there are reports of similar minerals near Gogebic’s proposed bulk sampling activity. The National Academy of Sciences has determined that grunerite is one of the most toxic forms of asbestos. According to the Centers for Disease Control, exposure to amphibole asbestos is primarily associated with mesothelioma, a rare cancer of the lining of the lungs that has occurred after exposure at low levels.
The Wisconsin Geological Survey has found grunerite is a widespread contact metamorphic mineral in the Ironwood formation around mafic (a silicate mineral) intrusions, with known occurrences near the proposed bulk sampling sites.
According to WDNR, it will be necessary to evaluate the bulk sampling activity to determine whether regulation pertaining to control of asbestos emissions is required. Furthermore, if minerals in an asbestiform habit are present or potentially present in the excavated material, some of the total emissions would likely be asbestos emissions.
Instead of providing the WDNR with data from the mine site it has obtained from its core samples or U.S. Steel core samples, GTAC provided statements using faulty logic and misstatements on the topic of asbestos. “[Laws pertaining to the safe handling of asbestos] do not apply to the proposed bulk sampling activities because asbestiform minerals are not likely to
be present in the Gogebic Iron Range near Mellen, Wisconsin. There are documented occurrences of amphibole minerals in the geology of this area but not all amphibole minerals are asbestiform minerals or asbestos.” GTAC relies on faulty logic here: just because some amphibole minerals are not asbestiform or asbestos does not mean that all amphibole are not asbestosiform or asbestos. GTAC never addresses the findings from the Wisconsin Geologic Survey that grunerite is a widespread contact metamorphic mineral in the Ironwood formation around mafic intrusions, nor does it provide any verification from the core samples to back up its assertion that asbestiform minerals are unlikely to be present in the Gogebic Iron Range. GTAC must provide this information to DNR before proceeding with ANY bulk sampling.
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