More Bulk Sampling Permit Questions sent 09.08.13

Thanks to the Midwest Environmental Activists and the Sierra Club for their assistance.

Good Morning:

On behalf of the Penokee Hills Education Project (PHEP) and I want to submit the following comments regarding the GTac Sample Permit. PHEP and truly appreciates the efforts of the DNR staff to respond to the many issues that have raised and we acknowledge and appreciate the many experts and organizations that have contributed to these requests for base line studies. 

Surface Water

Location, names and baseline water quality and aquatic habitat data for all surface waters (streams, rivers, wetlands) within 1,000 feet of site footprint

Location of any springs within 1,000 feet of site footprint

Location of any drainage divide

Details of any wetland mitigation proposed

Provisions for erosion prevention and drainage control

Plans for collection, treatment and discharge of any water resulting from mining

Map demonstrating water sources, flow paths, flow rates, storage volumes, and release points

Identification of aquatic and terrestrial ecosystems such as stream orders and classifications

Surface water hydrological computer modeling including contaminant transport


Elevation of the water table

Groundwater flow net, including horizontal and vertical groundwater flow patterns

Any groundwater divides

Groundwater recharge and discharge areas

Groundwater management techniques

Baseline groundwater quality 

Identification of all aquifers used by all public and private wells within at least 1,200 feet of the proposed mining waste site

Groundwater modeling including contaminant transport 

Air qualiy

Plans for protecting air quality under ch. 285

Background air quality

Regional air quality modeling that includes mine sources such as processing, energy use and wastes


Present socioeconomic conditions in the area

Anitcipated socioeconomic impacts of the proposed mining project

Include tourism, employment, schools and medical care facilities, private and public social services, the tax base, and the local economy



Precipitation chemistry from outside sources and from ore processing, energy use and wastes

Mining Site

Surface topography

Soil types

Depth to bedrock

Geology of underlying bedrock and unconsolidated deposits

Existing land uses with emphasis on known recreational, historic, archaeological, scientific, cultural or scenic significance

Nature, extent, and final configuration of the proposed excavation and mining site

Total estimated production of tailings, waste rock, other refuse

Nature and depth of overburden

Sequence of mining operations

Handling of overburden

Production, handling, and final disposition of tailings

Milling, concentrating, refining and other processing of ferrous minerals

Storage, transportation and loading of final product

Surface facilities associated with the mining site

Geological and geotechnical investigation including geochemical characterization of wastes both short and long term

Contaminant transport modeling for both surface and groundwater

Plan for monitoring environmental changes at the mining site

Risk assessment for accidental health or environmental hazard at mining site

Where blasting is proposed and how it will be done 

Characterize and asses risk of reagents, mine mill chemicals, and processing reagent wastes

Central location for collection and treatment of all liquid effluents for treatment and discharge

Reclamation plan, including economic analysis of total cost and any ongoing costs

Proposed changes to forest designations 

Alternatives to the proposed mining project and to proposal for waste disposal

Archaeological sites

Identification of adjacent landowners

Proposed methods of leachate control

Potential area to be affected in event of failure, considering land use and surrounding environment

Impacts to consider

Air:  air pollution impacts, direct and indirect (from processing) – both contaminants and visibility impacts;

Water:  supply issues, impacts on surface water, ground water quality and quantity, wetlands, navigable waters

Land:  impacts on agricultural uses, on forest production (and secondary or indirect impacts of changes to land use – deforestation, erosion, flashiness of waters, impacts on fisheries, etc)

Impacts on tourist land uses, etc.

Transportation infrastructure needs and impacts

Energy:  infrastructure needs and impacts, infrastructure (gas pipelines, transmission lines, corridors related to both)

Indirect  and Cumulative impacts

Economic impacts – jobs, discouraging tourism, discouraging more sustainable development, etc.  

Socioeconomic impacts  - including Title VI Civil Rights issues - who benefits and who is harmed; disproportionate adverse impacts on minority and low income communities

Tribal rights – on reservation, off reservation; consultation

Cultural, historical, archeological impacts

Wildlife, endangered species

Impacts on public lands, recreational resources, other unique features – impact on prior state and federal spending to preserve some of these and other resources

Noise What will be the decibel range for the explosives that may be used during the Bulk Sampling process? How will these compare to the actual mining if it is permitted?

Visual impacts  What are the plans to restore the Bulk Sample sites? If GTac uses older Bulk Sample sites, will GTac be required to restore these sites?

Meteorological impacts – (Penokee hills may alter the temperate fog forest nature and extremely high forest productivity of the lower forestlands north of the hills)

Thank you,

Frank Koehn