A planned development on the edge of the city of St. Charles could become the largest frac sand processing and transportation plant in the nation. Minnesota Proppant's plans include a rail spur, sand processing facility, and a six-mile underground pipeline that would bring sand to the site.
The development proposal has drawn sharp criticism from nearby residents, who fear the plant could change the character of the rural setting and create large volumes of semi-truck traffic in the area. While Minnesota Proppant has yet to formally apply for any of the many permits needed to begin construction at the site, it has begun an environmental review called an Environmental Assessment Worksheet (EAW). The company submitted some data for the EAW to Winona County in October, but attempted to redact the information shortly after, asking that the county consider the data to not be public, nor release it to any citizens. After Winona County officials sought an opinion from the state about whether the data should be considered public, it released the information to the Winona Post last week.
The information in the EAW draft in question is incomplete. EAWs require answers to more than 30 questions related to environmental effects, and other project details, and many of the questions in this document are unanswered.
The project includes three major components: the processing facility and rail spur on more than 300 acres; the six-mile pipeline to bring sand to the processing site; and a mine proposed on land adjacent to the entrance of the sand pipeline. The processing facility is expected to process and dry 600 tons of sand per hour.
The plans call for annexation of the property into the city of St. Charles, and the extension of municipal water pipes to the processing facility. According to the draft EAW information, the extension of city pipes would cost $1.3 million.
Details about truck traffic are missing from the draft document. Project officials have said the underground pipeline, which would bring sand mixed with water from the mine to the proposed St. Charles processing location, would significantly decrease the number of semi-trucks that would be needed. The area of the pipe entrance, according to the draft EAW, was chosen because of its proximity to the proposed mine, as well as several other proposed mines in Saratoga Township.
The EAW draft states that sand from other mines will be transported to the pipeline entrance by truck, although the number of trucks is not detailed. “[The pipeline entrance] location to other potential sand sources was deliberate to allow for phased development of other sand mines,” reads the draft EAW. “There has been recent expressed interest in developing silica sand quarries from this same [geologic] formation within a mile of this site and at least two quarry applications are pending and subject to EAW declarations. Other trucks from regional quarries will be hauling material to the site to provide raw material to be transported in the slurry pipeline.” The draft document suggests that trucks from regional mines will travel along County Road 6, and that hauling will be restricted to the hours between 6 a.m. and 10 p.m.
The draft EAW also says that the project will actually reduce truck traffic, since the sooner the sand is loaded onto rail cars, the fewer trucking miles it will take to reach its ultimate destination—oil and gas fields in the Dakotas and the southern U.S. The sand is used in a process called hydraulic fracturing, and is mixed with water and chemicals and then blasted into shale rock formations underground. The sand helps hold open fractures in the rock, allowing oil and natural gas to be extracted. The process has helped draw natural gas prices down, and demand for the kind of sand found in Southeastern Minnesota and Western Wisconsin is up.
Dust control has been a point of contention among local residents critical of the frac sand industry, with many suggesting that fine silica dust particles generated from sand operations could pose health risks for residents.
The draft EAW language admits that the proposed operations will produce air emissions, both from dust and from truck and equipment run on diesel. Dust mitigation measures are planned for all aspects of the operations, from dust collection systems inside the enclosed processing plant, to ensuring that most sand processing and loading activity is done in enclosed buildings.
The details about the amount of particulate emissions anticipated for the operation are incomplete in the draft, but the document states that efforts have been taken to keep the amount under 250 tons per year, a total that would trigger more permitting requirements from the state.
In the screen house, where sand is sorted by size, 30,000 pounds of fine particulate matter per hour is expected to be collected by dust collection systems called “baghouses.”
“The project has multiple sources of stationary source air emissions,” states the draft document. “They range from dust originating from the removal of vegetation, open enclosure transportation of materials within the mine and stockpiling of materials, which are all subject to wind erosion. Other sources are dust stirred up by mining equipment, truck traffic and blasting to remove overburden. The sand drying, screening, storage and loading process also has potential for creation of stationary source air emissions. The potential for each emission has been explored at its source and summed to ensure the project is not subject to EAW requirements under Rule 4410.4300 subpart 15 for air Pollution.”
Moist sand is less likely to create airborne dust, and so once the sand has been processed and dried and is ready to be transported, it will be conveyed to enclosed storage silos from which it is loaded onto rail cars.
However, the document does not state that all rail cars will be covered after the sand is loaded. In most instances, says the EAW, the rail cars will be covered for the purpose of keeping humidity and rainfall from moistening the dry sand.
Air monitors are expected to be installed around the operation, but state and federal laws do not provide many regulations that specify the limits for how much dust, and what size dust particles, can be emitted.
“It is anticipated that the project will be subject to inclusion of [fine particulate] monitors that will collect data at a threshold which has yet to be required by law,” says the draft. “These monitors would collect air emissions specific to sizes attributable to crystalized silica and the data collected would be used for studying the impact, whether it be benign or negative, of silica sand mining and processing. Only after these studies can there be quantified changes to air emission requirements for the industry as a whole. As of the date of this assessment, the operation and processing plans are within the guidelines and requirements of all the county, state and federal rules.”
Minnesota Proppant expects to use 174,000 gallons of water per day at peak production, and the water is planned to be recycled into the operation. Water will be recycled into the slurry pipe after it has been cleaned using a “clarifier” water treatment system.
The clarifier treatment system uses a flocculant chemical called polyacrylamide to help sediment and other materials settle to the bottom of the clarifier tank. Once the materials have settled, they form a hardened cake, and will then be used in mine reclamation plans as fill material.
Some residents have expressed concerns about the use of polyacrylamide due to the potential for the chemical to become de-polymerized to form acrylamide, a known toxin. The draft EAW dismisses those concerns, stating that the U.S. Environmental Protection Agency “has researched these links and found that proper use of polyachrylamide flocculants is safe.”
The polyacrylamide will be stored in the enclosed clarifier, the document says, adding, “The bulk materials are relatively non-toxic but storage and handling protocol will be monitored. Residual material from the use of the flocculants has potential for groundwater contamination.”
The slurry pipeline is expected to cross several intermittent streams—streams that are not always full of water—and pumping stations will be installed very 1.5 miles in order to keep the water and sand mixture flowing to the processing site.
According to the draft EAW, any leaks in the six-mile pipeline would be noticed immediately, “as it would shut down production.” If a leak were to happen, according to the draft, it would likely be contained within the pipeline “sleeve” which will encase the underground pipes. If the sleeve were to be ruptured, the document states that the material is just water and sand, and would not be considered a spill containing hazardous materials. In the event of any leakage, the EAW says the company would shut down the pipe and fix the problem.
The mine proposed at a location adjacent to the sand pipeline entrance is referred to in the EAW as the “Campbell mine,” and would be located on a 280-acre site. The document suggests that after reclamation, the operation would have put about 12 acres of cropland out of production, and turned into pasture land after mining is over. The related processing facility would remove more than 240 acres from cropland production.
The EAW states that blasting with explosives may be necessary to remove hardened rock overburden materials from the mine site, and that neighbors would be notified prior to any use of explosives.
The draft document acknowledges concerns from neighbors about the proposed project, and states that there are 16 homes or farms within a half-mile of the proposed processing facility just outside of the city of St. Charles. But the EAW suggests that the operation would not be very disruptive for those neighbors.
“With the size of the property and the distance the facilities will be from residences, the processing and trans-load facility are adequately spaced to mitigate the nuisances brought by the change of use of the land,” says the EAW. “Any change of use of a property has consequences and development of the site will have consequences similar to as if this property were being converted to single family houses.”
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