Midwest Environmental Advocates began a review of a draft Industrial Sand Mining Strategic Analysis released by the Wisconsin Department of Natural Resources in early July. The DNR’s draft Strategic Analysis is the first glimpse into a long-awaited, comprehensive look into the impacts of frac sand mining on the health, environment, economies and way of life of many Wisconsin communities.
Upon initial review, however, the draft Industrial Sand Mining Strategic Analysis will need a deeper analysis, more data and more input from experts and the public in order to be a meaningful resource for local and state policy makers and agency staff for decision making.
The air quality section has the same fundamental flaw as the agency’s recent actions regarding fine particulate matter, or PM2.5. While the DNR asserts that mechanical processes, such as those at industrial sand mines, do not produce or emit PM2.5 (only larger particles), the agency does not have evidence to support this conclusion.
The Strategic Analysis also relies on studies based on voluntary monitoring and industry-funded studies at industrial sand facilities. The report also only makes passing reference to independent research such as that of UW Eau Claire’s Dr. Crispin Pierce’s PM2.5 study that shows that industrial sand facilities may be causing or contributing to unsafe levels of fine particulate matter around mining facilities. This reliance on industry-funded research shares the same limitations as the Health Impact Assessment of Industrial Sand Mining in Western Wisconsin published by the Institute for Wisconsin’s Health, Inc. earlier this year.
However, the Strategic Analysis does acknowledge the threat of acid mine drainage from industrial sand facilities and supports further study of the potential for frac sand mining to allow metals to leave bedrock and enter surface and groundwater. DNR has known for some time that some wastewater holding ponds at industrial sand mines have had high levels of metals, which present a risk to groundwater quality and the health of rural residents who rely on private wells for drinking water.
But in the meantime, DNR should require monitoring at industrial sand facilities to ensure that these discharges are not going unnoticed. DNR recently revised its industrial sand stormwater and wastewater general permit and should have, but did not, account for uncertainty about the potential for metals in these discharges.
Public Comment Welcomed
The DNR accepted public comment until August 22. Thank you to everyone who read the draft report and submitted comments or appeared at the public hearing. Robust public comment will improve the final Strategic Analysis if the DNR will hear the public’s concerns, accept more air quality studies, and address the legal and environmental concerns with fine particulate matter associated with frac sand mining.
Read Midwest Environmental Advocates' comments on the draft Strategic Analysis (an attachment of an EPA letter with concerns about the Wisconsin DNR's guidance on air quality permits' compliance with the federal Clean Air Act was also included).
Earlier this year, the Institute for Wisconsin’s Health, Inc. released a Health Impact Assessment of Industrial Sand Mining in Western Wisconsin that failed to analyze or draw complete conclusions about the health threat of frac sand dust. While there is a great need for this type of study, MEA and experts we’ve consulted have serious concerns about the data analysis and conclusions in the HIA. MEA has shared our concerns with the Institute for Wisconsin's Health, and we’ve hired an air engineer to provide a more thorough technical response. There is more about the HIA report and MEA’s response on our website.
The Wisconsin DNR strategic analysis of frac sand mining is an opportunity for our state's natural resources protection agency to take a broader look at the air quality and human health and safety impacts of emissions of fine particulate matter (PM2.5) associated with frac sand mining and processing. Further, the strategic analysis should reflect how in the absence of requirements of air quality monitors at frac sand mines in Wisconsin, the public – and researchers such as the Institute for Wisconsin’s Health – cannot truly assess the comprehensive and cumulative impacts of the dust produced by this industry.
DNR Revises Frac Sand Stormwater General Permit
DNR released a draft stormwater general permit for the nonmetallic mining industry (including frac sand mines), and MEA raised our ongoing concerns in comments to DNR and EPA. Among other problems, the draft permit does not adequately protect surface water and groundwater from sediment and heavy metals. Visit our website to view the draft stormwater general permit and MEA’s comments.
Strategic Analysis of Frac Sand Mining: The Basics
What is a strategic analysis?
It is a DNR study of complex and contentious natural resource issues or policies. Through the strategic analysis process, the DNR evaluates potential alternative approaches to its current regulation, identifies potentially affected natural resources and likely effects of various alternatives on those natural resources.
The purpose is to develop the best information to aid decision-makers in dealing with a controversial resource issue such as frac sand mining. The DNR won’t create any new regulation through the strategic analysis process, but the information developed may lead the DNR to revise its regulations, permits, or policies, and could also be used by the legislature or local governments to create more effective and protective laws.
Why should DNR conduct a strategic analysis of frac sand mining?
The frac sand mining industry is growing at a frantic pace with citizens and our government struggling to keep up. Unlike the Minnesota legislature, our state government has not required in-depth study of this industry’s impacts or the adequacy of current regulations. The DNR’s past decisions to maintain the status quo have deferred to the lack of data or research regarding the scope of impacts from frac sand mining. The number and concentration of frac sand mines has greatly increased since the DNR last examined the frac sand industry. New developments in research, data collection, and regulation, as well as several documented instances of noncompliance and pollution by frac sand mines and processing facilities support the need for a strategic analysis now. Decisionmakers and Wisconsin citizens need a detailed study of the environmental and public health impacts of frac sand mining and alternative ways to manage this natural resource extraction industry.
What role do citizens play?
Citizens play a critical role. Wisconsin citizens are coming together to request this study of frac sand mining’s impacts. The strategic analysis process allows for citizens to be involved, so comments from members of the public and their input on the scope of the study will be valuable and encouraged. We will need citizens to stand together and participate in meetings and opportunities for comment.
Submitting the Strategic Analyis request petition to the Natural Resources Board
Petitioner Ken Schmitt presented the petition to the Wisconsin Natural Resources Board on October 29, 2014 and shared his experience as a grass-fed beef farmer in western Chippewa County whose community is increasingly dealing with the negative impacts of frac sand mining.
- Ken Schmitt
In just over a month, over 1,100 Wisconsin residents signed on to a petition with a simple request:
Industrial Sand Mining Strategic Analysis
Draft Topics Outline
March 12, 2015
1. Industrial sand mining
1.1. Historic sand mining in Wisconsin
1.2. Current market
1.3. Explanation of hydraulic fracturing
1.4. Location of sand resources
1.5. Current operations and trends
1.6. Aspects of industrial sand mining
1.6.1. Overburden removal
1.6.5. Processing (including use of chemicals)
1.6.6. Process water and stormwater management
1.6.7. Spill prevention and response
1.6.8. Storage facilities
1.6.9. Waste management
1.6.10. Transportation and load-out facilities
2. Environmental Topics – affected environment and primary, secondary and cumulative effects (as appropriate)
2.1. Air quality
2.2.1. Surface water features and locations
2.2.2. Surface water quality
2.2.3. Groundwater quality
2.2.4. Groundwater quantity
2.2.6. Fish and aquatic species
3. Socioeconomic topics – affected environment and primary, secondary and cumulative effects (as appropriate)
3.1. Local and state economy
3.2. Property values
3.5. Land use and zoning
3.6. Agricultural lands
3.7. Public parks and recreational lands
3.8. Archaeological, cultural, tribal and historic resources
3.9. Human health and safety
3.10. Visual and auditory
4. Regulatory framework 4.1. State of Wisconsin
4.5. Neighboring states
Fast facts on frac sand mining
What are some of the potential impacts of frac sand mining in Wisconsin?
Air and Public Health Impacts
- Frac sand mines and processing facilities emit air pollutants such as fine particulate matter that may include crystalline silica dust. Fine particulate matter travels deep into the lungs and causes serious respiratory and cardiovascular problems and studies show that this dust causes cancer in mine workers. Particulate matter made of crystalline silica causes silicosis, a deadly and incurable lung disease.
- The DNR currently does not require facilities to monitor for the smallest and most dangerous particulate matter, including silica dust, and has refused to set more stringent limits.
- Frac sand mines and processing facilities pump and use large quantities of groundwater for mining and processing sand. This groundwater use can lower water levels in nearby wells and surface waters.
These facilities also may cause surface water and groundwater pollution.
- They use chemicals like polyacrylamide in the sand washing process.
- Water from these sites also has clays and sediment that can affect water quality and aquatic life.
- Recent stormwater pond sampling at several facilities indicates that there may be high levels of metals in water that is released either to surface water or groundwater.
Threatened and Endangered Species Impacts
- As a high-impact, landscape-scale industry, frac sand mining can impact a variety of threatened and endangered species. The primary species of concern is the Karner blue butterfly. Its habitat overlaps a great deal with land used for frac sand mining. The majority of facilities are not participating in the state plan to prevent harm to this species.
- Wetlands are common throughout our water rich state and are critical to protect water quality, prevent flooding, and provide habitat for numerous species. Frac sand mines may fill in wetlands for construction or harm water quality in wetlands.
Long-term Impacts – Limitations of Reclaiming Mine Sites
- It is unclear whether reclamation plans will result in sites that are suitable for other uses and that will not continue to pollute the environment.
- Tribal nations and its members have a long history with the land of western Wisconsin. As out-of-state frac sand mining companies are leveling bluffs and hills in close proximity to Tribal territory, the members and leaders of Tribal Nations have sovereign power to protect its land and people from exploitation
- Frac sand mining brings questionable boom-and-bust economic benefits to communities and creates numerous negative economic impacts for the tourism industry.
Quality of Life Impacts
- Frac sand mines and processing facilities dramatically affect life in rural areas. Constant noise, light, train and truck traffic, vibrations from blasting, dust and water pollution turn quiet rural communities into industrial areas.
Petition for a Strategic Analysis of Frac Sand Mining - Full petition text with citations (PDF)
Results of DNR water sampling at frac sand facilities in WI - Water quality data collected in frac sand wash pond samples by a DNR Water Resources Management Specialist in 2013.
MEA summary of DNR water sampling results at frac sand facilities - Midwest Environmental Advocates reviewed and summarized data collected in frac sand wash pond samples by a DNR Water Resources Management Specialist in 2013, comparing the results to state and federal water quality and health standards.