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Public comment sought on two frac mine EAWs (10/17/2012)
By Sarah Squires
The first Environmental Assessment Worksheets (EAWs) to examine the potential effects of frac sand mines in Winona County have been released to the public. State leaders are now accepting citizen and state agency comments for one month, and then the documents will be voted on by the Winona County Board. The board will consider whether the environmental reviews are sufficient for the two proposed mines to move ahead, or whether more comprehensive analyses are necessary.

The thick EAW reports outline specific plans for the two mines proposed in Saratoga Township, and also answer questions about the potential health and safety effects for the projects.

The two mines have been proposed on property owned by Roger Dabelstein, and William and Ida Yoder. The Dabelstein quarry is planned for a 36.5 acre site and the Yoder quarry is on 38.2 acres, both adjacent to County Road 6. The EAWs for the mines are very similar, reading nearly identically for the bulk of the environmental documents.

Each mine would haul 300 truckloads daily from the sites, the trucks traveling from County Road 6 to County Road 29, from there on Interstate 90 to Highway 43 and finally to a sand processing site in the city of Winona. The documents calculate that during operating hours from 6 a.m. until 10 p.m., the mines together would add 76 semitrailer trips per hour to the roadways. It is estimated that, combined, the semitrailers used by the mines would use more than one million gallons of diesel fuel each year to transport the sand.

The Dabelstein mine is proposed to move four million cubic yards of material, and the Yoder mine would extract about 3.7 million. Neither operation would include permanent buildings, but truck staging areas, berms, ditches, stockpiling areas and access roads would be added under the proposals.

Both proposed mine sites are currently used as cropland and pasture, with some stubby cedar forest land along the steeper hillsides. According to the EAWs, there would not likely be enough topsoil to return the land to row crop production, so reclamation plans would turn the entire area into pastureland. For the Dabelstein site, 21 acres of cropland would be lost; for the Yoder site, 12.7 acres would not be returned to row crop production.

Depending on demand for frac sand, the EAWs indicate that mining activities could last between five and 20 years. About 10 acres—what planners anticipate could be mined within two seasons—would be opened for excavation at a time, before rock and topsoil would be returned for reclamation. Miners would then move to an adjacent 10 acres and restart the process.


Dust mitigation, including watering of gravel roadways and open pit areas, is included in the plans. Mine workers and truckers would follow protective procedures as required by the Mine Safety and Health Administration, including the use of respirators. As for ambient air quality—or the potential for silica dust to travel onto adjacent property—the report indicates that silica sand particles are not likely to leave the mine site.

“Silica sand excavated out of the mine is not easily airborne and the round sand grains are not easily suspended in the air for prolonged periods,” state both reports. “Therefore, the dust from the mine is expected to be confined to the [Dabelstein/Yoder] property. Dust supressants such as misting around equipment, enclosed equipment, watering or treatments of the haul roads, covered truck loads, clean-up of spilled sand, limiting the exposed working face to the minimum necessary for mining and following MSHA best management practices for dust control in silica mines are the primary tools for minimizing dust.”

The EAWs indicate that exposed areas and stockpiles that are not moved for more than 14 days will be seeded with a vegetative cover to help reduce wind-blown dust or erosion at the sites.


The two proposed mines would not include processing facilities, so no large amounts of water or chemicals are planned to be used at the operations. Plans will include ditches and berms to route stormwater to appropriate filtration areas and to ensure neighboring agricultural runoff does not flow to uncovered areas being actively mined.

The report addresses concerns about whether enough sand and soil would be present during and after mining activities to properly filter stormwater and other runoff before it makes its way to the groundwater table. Under the plan, both mines would excavate to no deeper than 40 feet of the estimated groundwater elevation. The EAW says it will be enough to provide adequate filtration of water entering the groundwater. “The removal of sand will remove sand that is currently filtering water from the surface and this infiltration will continue to function effectively,” read both reports, which state that only five feet of sand is needed to filter solids from storm and surface water.

The reports both say it would be difficult to monitor nearby private wells, since the only potentially hazardous materials that will be used at the site are the same as those used by neighboring agricultural operations. “Because the mine[s] will continue to filter suspended solids and will reduce the use of nitrogen fertilizers and pesticides while using the same fuels and lubricants as farming, the county mandate to monitor wells in close proximity to the mine cannot be used to differentiate water quality impacts from mining versus farming,” the EAWs say. “Therefore the application proposes to conduct only a standard nitrate and bacteria test for nearby wells with one sample before mining exits [sic] and one sample per year until the mine is restored.” If a landowner can prove his private well has been negatively affected, state the EAWs, the mine owner will “mitigate” the impact.

The closest residence to the Dabelstein site is 1,000 feet away; the closest residence to the Yoder site (aside from the Yoder home) is about 750 feet away.

Both sites are 2.5 miles away from the nearest protected waterway. The Yoder site is 2.5 miles from Pine Creek and the Dabelstein site is 2.5 miles from Money Creek. The report concludes that neither protected waterway would be impacted by mining activities.


Traffic levels were not a central point in the EAWs, although each proposed mine has completed a traffic impact study. The studies concluded that the haul route from the mines would not require upgrades to accommodate the higher traffic levels, and that none of the intersections on the route would reach capacity under the development plans. Each of the traffic reports does indicate that the line of sight at Highway 29 at the I-90 entrance is not acceptable with the current speed limit of 55 mph (no limit is posted, so the default limit is 55). The reports suggest that a sign be posted with a speed limit of 45 mph, which would increase visibility at the entrance and exit ramps to an acceptable level.

Any roadway improvements needed would be paid for with a road use agreement between the county and the applicants.

Cumulative impact

Several questions and answers included in the EAWs address the cumulative effect of the mines. Both reports indicate that there is more frac sand on the properties and on adjacent land. The reports state that expansion may be warranted, based pm future demand for the sand, but note that any expansion would require county approval.

Each plan also indicates that the truck-to-rail transportation and sand processing center proposed on land near St. Charles could be an alternate destination for the sand mined at the sites, rather than bringing it by truck to the city of Winona. The proposed St. Charles transfer facility has attracted heavy opposition, and has been described by project planners as one of the largest such sand facilities proposed in the country.

With regard to the cumulative effect of related or anticipated future development, each EAW response refers to the proposed St. Charles transfer development, but says that neither project is a “combined effort." It also notes that the St. Charles project should not be a "detriment to the review, approval and start of this project…. This project is seeking approval on its own without influence or infrastructure required by these other potential projects,” it concludes.

Keep reading the Winona Post for more on the proposed mines in Saratoga Township.



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