By LeAnn R. Ralph
TOWN OF HOWARD — If the recommendations of an independent engineering company are followed, mining activities at the Albertville Valley sand mine could be delayed by at least a year.
“There is a lot of work to do yet,” said Vernon Schindler, chair of the Town of Howard, at the August 4 meeting.
The Howard Town Board is under no time limitation to issue a license for the Albertville Valley sand mine, he said.
“It’s going to take a while,” Schindler said.
Northern Sands and Red Flint Group are proposing to develop a 1,300-acre sand mine in the Town of Howard a few miles southeast of Colfax.
In addition to mining for frac sand, the proposal includes a sand processing plant and transloading facility.
Chippewa County Land Conservation and Forest Management held a public hearing on the reclamation plan for the Albertville Valley sand mine July 29.
SCS Engineers out of Madison, a company that specializes in environmental consulting and contracting, has reviewed the proposed reclamation plan and has made a number of recommendations.
One of the recommendations is to do a pre-mining detailed analysis of the groundwater and install a minimum of three water table wells in each area where the frac sand will be mined and to measure the water levels monthly for one year.
SCS also is recommending that piezometers be installed next to the water table wells to evaluate the vertical flow pattern of the groundwater.
The information from the groundwater monitoring should then be used to prepare groundwater flow maps for the months with the highest and lowest groundwater elevations, according to the SCS report.
The detailed analysis with site-specific data is needed to meet the provisions for groundwater management and protection in Wisconsin’s administrative code NR 135.08, the report states.
Experience has shown that in this part of Wisconsin, the water table is not always where it was thought to be.
At the July 29 hearing on the reclamation plan, Ron Koshoshek, the Town of Howard’s mining consultant, said that the groundwater location at the S&S mine in the Town of Howard on county Highway B turned out to closer to the surface, which means that the number of tons of sand available to be mined was cut in half, from 33 million tons down to 13 to 15 million tons.
Chippewa County regulations allow frac sand mining to within ten feet of the groundwater.
Another complicating factor for the Albertville Valley sand mine is that the proposed location involves two different watersheds, one for Elk Creek, which drains to the Chippewa River, and one for Eighteen Mile Creek, which drains to the Red Cedar River.
In this area of the country, groundwater discharges to surface water.
Base flow rates will need to be established for Elk Creek and Eighteen Mile Creek, Koshoshek said at the August 4 Howard Town Board meeting.
SCS recommends that a Wisconsin registered hydrogeologist should supervise the planning, design and completion of the groundwater study.
The draft reclamation plan indicates that wetlands will be identified prior to the start of mining in each phase and that the wetlands will be avoided during mining.
The draft plan states there will be a setback of 75 feet from wetlands identified by the state Department of Natural Resources, and a setback of 300 feet from steams identified by U.S. Geological Survey maps.
To meet the provisions of surface water and wetland protection in NR135.07, field observations are needed, along with detailed current site specific information, according to the SCS report.
SCS recommends a field study to identify the location of all wetlands and water bodies, including intermittent streams, and to establish a buffer zone of 100 feet from the wetland boundaries and the center lines of water bodies.
A map should be prepared showing the location of wetlands, water bodies and setbacks, and the map should be submitted to Chippewa County as a revision to the draft reclamation plan, the report says.
The reclamation plan should be reviewed and revised as needed to assure wetland and stream hydrology are preserved by final grading, revegetation, pond discharges and stormwater diversions, the SCS report states.
According to the SCS report, the water well inventory for the Albertville Valley sand mine is “likely incomplete” because the DNR database only includes information for water wells drilled in 1988 or later.
SCS recommends searching well records on file with the Wisconsin Geological and Natural History for more well records because the file contains records from 1936 to 1988.
SCS also recommends reviewing current aerial photos and county property records to further identify water wells and to revise the map in the draft reclamation plan and submit the map to Chippewa County as a revision to the draft plan.
After the water wells have been identified, then samples should be collected from wells within 660 feet of the proposed mine (one-eighth of a mile) before mining starts, and then water wells within 660 feet of the active phases of the mine should be sampled and tested every year, SCS recommends.
Well owners should receive the reports within 30 days of the company receiving the analytical reports, and well owners also should receive comparisons of the results to applicable groundwater standards and an explanation of changes in groundwater quality, the report states.
In the draft reclamation plan and the storm water management plan included with it, a more detailed design will be needed, the SCS report notes.
The storm water management plan indicates that storm water will be diverted around the mine sites, but the detailed design should verify that water is not being diverted into a different watershed, and that it will not damage a wetland or water body.
The infiltration rate used in the design (1.63 inches per hour) was based on loamy sand, but the soil description in the reclamation plan is silty or sandy loam with infiltration rates of .13 inches per hour and .5 inches per hour, the report states.
“The reduction in runoff quantity to the downstream watershed should be evaluated to ensure minimal impacts to aquatic habitat and species,” according to the SCS report.
SCS also is recommending that a more detailed description of the mining activities be included in the reclamation plan.
For example, wet processing is mentioned, but there is no discussion of the high capacity well that will be needed for wet processing. There also is no discussion on treatment of the process water after it is used, according to the report.
A more detailed description of mining activities in the reclamation plan will help facilitate the evaluation of the final reclamation of the site, according to the SCS report.
Northern Sands/Red Flint Group must have all of the permits needed from Chippewa County and the DNR and must collect the hard data needed before the Howard Town Board will discuss a non-metallic mining license or a developer’s agreement, Koshoshek said.
The township’s mine licensing ordinance has enough leverage that the town board can negotiate fair market value guarantees for properties up to a half mile away, he said.
The advantage of negotiating a developer’s agreement is that it puts the mine license and conditions on a contractual basis with the Town of Howard, Koshoshek said.
If the state legislature were to abolish local control of the frac sand mines, and if a license is issued under the ordinance, the non-metallic mining license would become null and void, he said.
A developer’s agreement is a contract, on the other hand, and the state legislature could not void a valid contract, Koshoshek said.
Margaret Wolf, a Town of Colfax resident who attended the Howard Town Board’s August 4 meeting, wondered about the neighbors on the Dunn County side of the Albertville Valley sand mine.
All of the maps so far show the mining activity within an 800 foot setback from residences, which is the setback established in the township’s mine licensing ordnance, Schindler said.
Private wells within a quarter mile of the sand mine will be protected no matter whether those wells are in Dunn County or Chippewa County, Koshoshek said.
“We will do what we can to help everybody,” Schindler said.
One person in the audience wondered why Town of Colfax residents were being allowed to ask questions when it was a Howard Town Board meeting.
Some residents on the Dunn County side will be closer to the proposed sand mine than residents on the Chippewa County side.
Many of the residents in the Town of Howard in the area of the proposed sand mine have signed leases to allow their property to be mined.