WESTAR PROPPANT, LLC NONMETALIC RECLAMATION PLAN Hearing held on November 6, 2013 Comments by Thomas J. Reininger, P.E. ERRORS ON FIGURES As part of my job as an engineer for the Department of Natural Resources, I have reviewed numerous sets of drawings including specifications prior to project bid lettings. Each of the 18 Figures in this reclamation document was reviewed by a person with the initials TG. Reviews are supposed to catch errors made by draftsmen and others who have worked on the project. This was obviously not the case with this document. I have found errors that should have been caught and corrected prior to issuance of the document to the County. I’m unsure if geologists in Minnesota are registered with the state, but there is a registration here in Wisconsin. And with that registration, certain responsibilities to act in a professional manner are expected, and even demanded. I suspect that Summit Envirosolutions, Inc. was pressured with a deadline and figured that no one would ever look at a three inch binder full of technical stuff. Just get it out the door. But this technical stuff will affect the lives of many citizens of Hixton Township as well as surrounding townships. We the citizens of Hixton will likely get only one chance at this, so it needs to be right. This document isn’t right. Here is a summary of 30 errors that I easily discovered just by reading the reclamation plan: • The mine boundary is misrepresented on eight different figures. Errors were found on Figures 1, 2, 3, 4, 5, 6, 8 and 10. (Parcel number 024-0532-0005 was excluded.) • Figure 13 is a Cross Section Transect Map. Figure 14e represents the E to E’ transect. The borings shown on these two figures are inconsistent with each other. Figure 13 borings along transect E to E’ are PCH-08, PCH-09, and PCH-10. Figure 14e borings along transect E to E’ exclude PCH-08, and include PCH-04 and PCH-11. • There are 16 Phase labeling errors. Phases shown on Figure 13 as well as numerous other Figures are inconsistent with Phases shown on Figures 14a, 14b, 14c, 14d and 14e. • There are 4 sheet titling errors. Figures 14b, 14c, 14d and 14e are all incorrectly titled as “Generalized Mining Section A-A “. GENERAL OPERATIONS • There is an indication that there will not be a processing plant at the Westar strip mine. The introduction says that material will be transported approximately 4 miles north of the site for processing. I assume that this will be at the Jewel Hagen/Todd Darst processing plant. (Ref: Introduction Section and Section 2.2) But Section 2.3 talks about a silt fence around a wet plant. (Ref: Section 2.3) And then Section 3.0 talks about “The final site of the processing facility, phase 1, and the transload facility will be reclaimed to agricultural and pasture land.” (Ref: Section 3.0) I saw nothing in the Westar plans for a wet plant, processing facility or transload facility. Are any of these being planned for the Westar strip mine? • Section 1.7 talks about the reuse of captured stormwater if necessary. What use of captured stormwater is being planned for the Westar strip mine? (Ref: Section 1.7) • Are there any plans for reclamation of the stormwater holding ponds either before, during or after active mining? I’m curious as to how they will be left for future generations. (Found no reference.) • WDOT’s Standard Specification for Highway and Structures Construction (SSHSC) is used as a reference document. Section 2.4 specifies the 2011 version. Appendix 3 specifies the 2012 version. I know for a fact there is a 2013 version and they are probably working on putting out the 2014 version. The point being that the current version should be referred to in case there are changes or modifications to the referred sections within. (Ref: Section 2.4 and Appendix 3) • The reclamation permit application seems to be incomplete. If Sections 6, 7, 8, and 9 are not applicable at this time, it should be so stated with an explanation. (Ref: Appendix 1) • Land uses will comply with Federal, State and Local laws. Does this include the Town of Hixton Non-Metallic Mining Ordinance? (Ref: Section 3.4) GROUNDWATER • Plans are to excavate to 1127’ elevation, but maintain a separation with groundwater. This maintained separation distance is not defined. What is the distance? (Ref: Section 1.7) • Groundwater elevation is reported to be from 980’ to 1000’. (Ref: Section 1.7) The Groundwater Elevation Map seems to indicate a large area of unknown GW elevation. (Ref: Figure 10) Were these elevations disproven by any of the borings? Did any of the borings encounter groundwater? PCH-05 was bored to 1062’ elevation. MONITORING WELLS • How many monitoring wells will be installed and where will they be located? Will the monitoring wells be nested in groups of three or more so that flow direction can be inferred? (Ref: Section 1.7) • How often will monitoring wells be tested for the listed compounds and depth to water? Quarterly, yearly or once in a decade? (Ref: Section 1.7) PRIVATE WELLS AND STRUCTURES • The plan indicates testing for private owners within ½ mile of strip mine, but lacks detail. Is this at the mine’s cost or the owner’s cost? (Ref: Section 1.7) • Is the private well testing a one shot deal or will it be periodic like the monitoring wells? If so, what is the frequency? (Ref: Section 1.7) • Approximately 8 man-made structures are to be raised along with wells and septic systems. Shouldn’t this reclamation plan inventory, designate and show all wells needing to be abandoned? (Concern: Reininger property well) (Ref: Section 1.5) • There is no mention of asbestos testing prior to demolition. (Found no reference.) • The reclamation plan should also explain how the structure areas will be reclaimed. Things like burial on site should be discussed. (Ref: Section 1.5) WETLANDS • Section 1.4 indicates that a wetland determination will be performed in any area of concern. Who determines that an area is an area of concern? Shouldn’t all areas be fully defined before the start of strip mining? Are some of the proposed settling basins located in wetlands? (Concern: Darst Home Farm Pond.) (Ref: Section 1.4) SOIL & PLANTINGS • Section 1.6 indicates that the depth of topsoil ranges from a depth of 9” to 60” with 24” being used as average. This is supposedly supported by borings. Using the boring log records for the 11 borings, the average depth of topsoil is 9.82”, far from the 24” suggested. Even if the 5’ of reported clay is added in, the average is only 15.27”, a little more than half the 24” average used. o Topsoil = 9’ total in 11 borings = 9.82” average. o Clay = 5’ total in 11 borings = 5.45” average. o Topsoil + Clay = 14’ total in 11 borings = 15.27” average. I believe topsoil is greatly overestimated and the strip mine will end up with less than 8” of topsoil on reclaimed areas. All you need to do is look at some of the uprooted trees to see there is very little topsoil. (Ref: Section 1.6 and Section 2.1) • Section 3.0 indicates that the strip mine will be reclaimed as wildlife habitat and forested lands. How long will it take to reforest this land? (Ref: Section 3.0) • Areas with 18” or more are to be reforested to mixed hardwoods. (Ref: Section 3.2) The Figures do not designate any areas of reclaimed land that will have over 18” of topsoil and therefore be available for re-forestation. (Ref: Section 3.1) How many acres of each Phase will be reforested? How many acres will this cover of the 670 acres total? I suspect that 18” of topsoil will be rare and that reforestation will be even rarer. • Mine Area Financial Assurances does not include any trees and shrubs. Why not? (Ref: Section 3.2.4) NATIIONAL HERITAGE INVENTORY AND LANDSCAPE • There are five concerns in the NHI Inventory, a turtle, fish, snail, bird and plant. Section 1.8 states that “Based on our reclamation concept, habitant will be enhanced and improved for the benefit of these species.” So how will the reclamation plan enhance and improve the habitat for NHI species? If wetlands are avoided, the turtle, fish and snail hopefully will not be adversely affected. But if a stormwater release occurs, those species could also be in danger. The hooded warbler habitat will be diminished with the removal of the tree canopy and underbrush. Only the Dwarf Milkweed, a sandy prairie plant, might benefit. (Ref: Section 1.8) Ref: This is a link to a web page titled “Predicting Bird Habitat Quality” specific for the hooded warbler. lmvjv.org/hsi_model/species/howa/s_howa.aspx • Explain the practical way oak ecosystems the oak woodlands and oak savannas will be regenerated. It will take centuries to return these areas to oaks. (Ref: Section 1.9) AIR AND NOISE MONITORING • Air monitoring sites are referred to in Section 2.5. Who decides where and how many sites will setup? (Ref: Section 2.5) • Section 2.5 indicates that noise monitoring will only be available at active Phases for residences that are 300’ or less away from the strip mine boundary. However, the noise level is not defined. (Ref: Section 2.5) • Section 2.2 indicates the use of white noise back-up alarms. Will all vehicles in the strip mine be equipped with these devices? Will it be mandatory? (Ref: Section 2.2) CONCLUSION The reclamation plan for Westar Proppants, LLC leaves numerous questions unanswered. It failed to provide a complete picture for the restoration of this mine. The plan appears to have been hastily assembled and contains numerous errors despite being signed off as being reviewed. One can only hope that the quality of the mine operation will be better than the quality of its reclamation plan. I feel that the Jackson County Land Conservation Department should reject this reclamation plan and require that a revised plan be drafted. Another public hearing should be made available to the Hixton residence for them to review and be assured that corrections have been made. Thomas J. Reininger, P.E.
Posted on: Wed, 06 Nov 2013 22:31:30 +0000
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