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Summary: Frac-Sand in MN A moratorium on new or expanded frac-sand mining (FSM) is needed because:

Millions of tons of valuable, accessible frac-sand is found in SE MN;

County and Township moratoriums are expiring with key issues unresolved;

Applicants are bullying jurisdictions with threats of litigation;

Industrial-sized FSM sites threaten to fundamentally change the character of communities in southeastern MN (Goodhue, Wabasha, Winona, Houston, Fillmore, and Olmsted Counties); and

Time is needed to complete a Generic Environmental Impact Statement (GEIS); the Moratorium would remain in effect ONLY until the GEIS is complete and its recommendations are acted upon.

A GEIS will provide a comprehensive, in-depth study of how FSM affects the following aspects:

Water usage. FSM threatens groundwater reserves. “Local aquifers are not sufficient to provide this demand.”1 MN DNR has warned of drought conditions,2 which impact trout streams, river levels for barge traffic, and water for crops and livestock. Extent has not been determined.

Water quality. Chemicals used to wash sand break down into acrylamide (a neurotoxin). The effect on soil and groundwater not yet determined.3 In addition, removing the protective cover of an aquifer may cause severe pollution of the groundwater.4

Silica dust. Invisible particles cause silicosis (fatal, incurable) and lung cancer.5 Workers are protected, but NO state or fed standards protect residents against particulate matter 2.5-4.0 microns in size. Ambient dust kills.6 California and Texas have standards.7

Diesel exhaust. The health of SE MN is currently in jeopardy because of diesel exhaust.8 As a solution, Feyereisn, a MD at Mayo Clinic, recommends no road transportation of sand (rail car only).9

Tourism. In 2010, tourism in the six counties of SE MN generated $555,509,807 in sales, $37,268,717 in taxes and 12,762 jobs.10 The industrial nature of FSM could greatly reduce these numbers.

Agriculture. Mining (NAICS code 212322) and agriculture (NAICS code 212311) compete for land resources. The area netted 9,586 agricultural production jobs during Q1 of 2010.11 Converting agricultural land to mining will affect jobs and exports.

Tax structure. Gravel and sand for construction and roads (NAICS code 212321) are taxed at a low rate—it is a raw product with minimal profit. Frac-sand (NAICS code 212322), by contrast, can yield a pure profit of $46.70/ton, or $1868/truck load.12

Property taxes. Properties within 3 miles of a mining site will lose 5-30% of their property values.13 A study applying this research in Richland, MI, found property values decreased by over $31.5 million.14

Traffic, safety. FSM trucks turn 20-year road into 2-year road. One mine can generate 100’s of trucks daily.15 Slow pullouts onto roads, difficulty stopping.

We need regulations designed to protect our air, water and current economic engines against

the new-style, industrial-scale frac-sand mines like those in Wisconsin. 1 Christenson (Oct 14, 2012). Conference looks at big picture of sand mining. Winona Daily News. 2 MN DNR (Oct 18, 2012). Drought Conditions Straining Water Resources. 3 Chalker-Scott (n.d.). The Myth of Polyacrylamide Hydrogels. Puyallup Research and Extension Center, Washington State University 4 Ekmekçi (1993). Impact of quarries on karst groundwater systems. IAHS Publ. no. 207, 1993. 5 Crystalline silica classified as a carcinogen by: IARC, National Toxicology Program, California Proposition 65, OSHA, NIOSH and others. 6 Bridge (2009). Crystalline silica: a review of the dose response relationship and environmental risk. Air quality & climate change, v43 p17-23. 7 Pierce (2010). Health Consequences of Energy Choices: Risks from Frac-sand Mining for Oil and Gas Extraction. Department of

Environmental Public Health, University of Wisconsin-Eau Claire. 8 Clean Air Taskforce (2005). Diesel soot health impacts. Retrieved 2/20/13 from: http://www.catf.us/diesel/dieselhealth/state.php?site=0&s=27 9 Wayne Feyereisn, MD. Silica sand mining and processing: Medical risks, facts and fallacies. Caledonia, MN, 1/17/13. 10 Explore MN (2012). Tourism and Minnesota’s Economy. Data from MN Dept of Employment and Economic Development 11 Pearson (2012). Positively MN. More than plowing the fields- farming jobs in SE MN. MN Dept of Employment and Economic Development. 12 Stein Vs Wesch (2013). Testimony given by Plaintiff in Goodhue County, MN, court on February 15. 13 Hite (2006). Property Value Impacts of Gravel Pits in Delaware County, Ohio. Report for Upjohn Institute, Kalamazoo, MI. 14 Erickcek (2006). An Assessment of the Economic Impact of the Proposed Stoneco Gravel Mine Operation on Richland. Upjohn Institute. 15 Prengaman (2012). Frac-sand boom creates thousands of jobs. Wisconsin Center for Investigative Journalism. 

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Frac-sand Facts Frac-sand is an industrial sand, not construction sand. The U.S. Department of Commerce uses the North American Industrial Classification System (NAICS) to define industries. The code for “Industrial Sand Mining” is 212322. The code for “Construction Sand and Gravel Mining” is 212321. Minnesota Statute 6125.8100 defines “Industrial Minerals” as “apatite, diamonds, dimension stone, feldspar, gemstones, graphite, kaolin, marl, quartz, silica sand, and other similar minerals of a nonmetalliferous nature.” It goes onto say: “The term industrial minerals does not include,…peat and construction sand and gravel…”. The code for “Agriculture, Forestry, Fishing and Hunting” is 212311.

Price is also different. Concrete sand = $17/ton, mason sand = $30/ton, and beach sand = $42/ton (Westbrook Sand & Gravel). The frac-sand in SE MN, by contrast, is expected to yield a pure profit of $46.70/ton.1

Silica sand deposits are commonly mined for use in glass making, filtration media, blasting media, ceramic products, and fillers in a variety of other applications.2

So, if a frac sand deposit is primarily quartz, what separates it from simply being good quality glass sand? The answer may be nothing. Some processing facilities have deposits of sufficient quality to meet the demands of both markets; hence, the same processing steps used to produce frac sand are often the same for glass sand, with the end results for both being similar….The frac sand industry has more stringent size distribution specifications than glass sands. This can result in more “waste” product than in a glass sand process…3

It is this waste that represents the health issue. The American Petroleum Institute (API) sets standards for size, as well as sphericity and roundness of a quartz grain. A size of .84-.42mm is required for fracking. That is 1/4 of the possible proppant sizes (see Figure 1). (Proppant is a term used because the grains prop open a crack.)

Waste further increases because only “round” particles are appropriate. The comparison chart below was devised by Krumbein and Sloss in 1955. API recommends sphericity and roundness of 0.6 or larger, so 1/5 of the samples shown are suitable (see Figure 2).

If 1/4 of particle sizes are suitable and 1/5 of the shapes of that size are suitable, then only 1/20 of a deposit may be suitable. The rest is waste.

To obtain the size and shape wanted, processing is required. Dust is a byproduct and the health hazard.

One of the mind-boggling things about this issue is fracking does not require sand! A ceramic alternative actually performs up to 30%

better.4 Then why not use them? Because the profit is greater on sand. 1 Stein Vs Wesch (2013). Testimony given by Plaintiff in Goodhue County, MN, court on February 15. 2 Zdunczyk (Jan 2007). The facts of frac. Drilling Minerals, pp58-61. 3 Outotec (July 2008). Processing for proppants. Physical Separation Technology External Newsletter. Issue 1. 4 O’Driscoll (Mar 2012). Frac-sand frenzy: Focus on supply & demand for hydraulic fracturing sand. Silica Arabia 2012. Images: top from MN DNR (2012), middle and bottom from Outotec—see footnote 3.

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Air quality The process of obtaining silica (quartz) of the size and shape suitable for gas or oil fracking requires digging, crushing, washing/scrubbing, desliming, separating, drying, screening (sifting) and transporting, according to a 2008 industry newsletter from Outotec. The cementing dust that holds all the grains of sand together in sandstone is released into the air by mining and blasting. Freshly fractured crystalline silica dust is more harmful to lungs than weathered silica dust stirred up by normal daily activities or by agricultural tilling.1

Several agencies classify crystalline silica as a carcinogen, including the International Agency for Research on Cancer (IARC) and the Occupational Safety and Health Administration (OSHA).

The increase in black lung disease among younger coal miners in recent years has been linked to silica dust released when machines cut through coal laced with silica-bearing quartz and sandstone. “…The increase in silica is more toxic than the coal dust itself.” 2

NIOSH, the research arm of OSHA, issued an alert after they found dangerous levels of silica dust at the fracking sites far away from mines. Esswein, Senior Industrial Hygienist for NIOSH, 79% of frac-site workers were exposed to more silica dust than recommended, with 31% being faced with 10x more than the recommended limit. The dust was coming from the trucks hauling the sand and every portion of the operation the sand touched. Risk is therefore not limited to the area near a mine or processing site, but instead travels every where the trucks and train cars carry the frac-sand.

Although none of this correlates directly to ambient, non-occupational exposure, it does not mean those of us not working with the silica are safe. Several studies establish a link between elevated levels of airborne crystalline silica a lung disease:3

Five epidemiological and animal inhalation studies which demonstrate the risk of silicosis is related to both the concentration and the duration of exposure;

Five separate studies in which non-occupational silicosis was linked to ambient exposures to silica particulate; and

Two additional studies in which lung disease was found in animals (in one case, four 1-year-old pigs) downwind of significant quarries.

Dr. Crispin Pierce (UW-EauClaire) measured particulates in the air around sand mines and processing plants on six occasions.4 The multiple 1-5 minute samples found, among other things that the measured levels of PM 2.5 were 1.7 - 22 micrograms/m3 higher than concurrent DNR regional levels at two plants. An ambient air quality study completed in May near the Chippewa Falls mine found a failure to meet the EPA’s National Ambient Air Quality Standard (NAAQS) 1 mile upwind and 1½ miles downwind of the mine.5

Workers are protected, but no state or fed standards protect residents. California and Texas have standards. Texas has set a value of 2 microns of particulates per cubic meter to prevent against silicosis and California has set a value of 3 microns/meter3.

“If we fail to respond to this, we will have, in my opinion, clear cut health risks that would be a problem for workers and for these rural communities.” (David Goldsmith, Professor of Environmental and Occupational Health, George Washington University).

1 Kirkhorn & Garry (Aug, 2000). Agricultural Lung Diseases. Environmental Health Perspectives Supplements, 108 (S4):705 2 Berkes (July 9, 2012). As Mine Protections Fail, Black Lung Cases Surge. All Things Considered, National Public Radio. 3 Bridge (2009). Crystalline silica: a review of the dose response relationship and environmental risk. Air quality & climate change, 43, pp17-23. 4 Pierce (2013). Particulate and Silica Health Risk Research. Department of Environmental Public Health, University of Wisconsin-Eau Claire. 5 Chippewa Concerned Citizens (2012). Monitoring analysis of air surrounding a Chippewa Falls frac-sand processing plant.

"As much as the companies say there are no worries, I've travelled around the state and keep hearing stories about people living fairly close to mines having lung issues." Jim Tittle, Film maker (Huffington Post, 12/7/2012)

“May cause eye and respiratory irritation,” “Breathing crystalline silica can cause lung disease, including silicosis and lung cancer. Crystalline silica has also been associated with scleroderma and kidney disease…. may become airborne without a visible cloud. Avoid breathing dust. Avoid creating dusty conditions.” Halliburton Energy Services, MSDS

“We are over five years into the massive shale gas development boom and the top public health officials in the country are still newly learning of astounding risks to human health.” Sass, Natural Resources Defense Council (NRDC Staff Blog, 11/17/2011)

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Water Frac-sand mining can affect both water quality and water quantity.

Water Quality The natural filtration of our drinking water relies on the layers of rock under our soils. Limestone deposits are found in southeastern Minnesota from the Twin Cities south to Iowa and west to Mankato. Ground water in these areas can convey water as rapidly as surface streams, so the potential for deterioration of water levels and quality is high.1 The Jordan Sandstone is the layer used for frac-sand.

Mining disturbs soil and rock. Erosion of the exposed earth may carry substantial amounts of sediment into streams, rivers and lakes prevention and control strategies are inadequate. Excessive sediment can clog riverbeds and smother watershed vegetation, wildlife habitat and aquatic organisms.

A spill into the St. Croix River was discovered on April 22, 2012 by a hiker. DNR investigators used a plane to survey the area 4 days later. They traced the murky water back to a 72-acre sand mining facility operated by Maple Grove-based Tiller Corporation, where they located a leak in one of the facility's holding ponds.2

In addition, most frac-sand processing requires the use of flocculants (polyacrylamide) to speed the separation of unwanted particulates from the refined silica frac-sand. The solid “cakes” of waste particulates containing the flocculants are put back into the pit as part the reclamation process. Treated silica sand is stockpiled and transported in large quantities. The effect on soil and groundwater not yet determined.3 Since chemical breakdown of polyacrylamide is acrylamide, a neurotoxin. It is under study at the MPCA.

Water Quantity High volumes of water are a necessary part of frac-sand processing, washing and settling ponds. Unamin’s Maiden Rock sand mine in Wisconsin, for example, is permitted to consume 3 million gallons of water per day. “Local aquifers are not sufficient to provide this demand.”4

In October of 2012, the MN DNR asked agricultural, commercial and industrial water users to stop outdoor irrigation and implement conservation measures because nearly ½ of the state was in severe drought or worse (severe drought is a 1 in 10-year event; extreme drought is a 1 in 20-year event).5 Water conflicts between users and uses, they stated, are emerging in more places. A drought will impact lake levels (e.g., White Bear Lake), trout streams, river levels for barge traffic, and water for crops and livestock.

1 MN DNR (2005). Hydraulic Impacts of Quarries and Gravel Pits. Section 1: Research. 2 Baran (May 18, 2012). Frac sand sediment spills into St. Croix River. Minnesota Public Radio. 3 Chalker-Scott (n.d.). The Myth of Polyacrylamide Hydrogels. Puyallup Research and Extension Center, Washington State University 4 Christenson (Oct 14, 2012). Conference looks at big picture of sand mining. Winona Daily News. 5 MN DNR (Oct 18, 2012). Drought Conditions Straining Water Resources. 6 Data from article in Colfax Messenger by Ralph, May 11, 2011. Millions of gallons of sand mine water could affect streams, wetlands & wells.

“It is often difficult to see the long-term impact a drought has on the state’s groundwater supplies. It can take many years for groundwater levels to bounce back after a drought, even when the state’s surface waters appear to have recovered.” MN DNR, 10/28/2012

"I'm sure there were things living there that are going to have difficulty living there now that they're covered with sand," Tom Woletz, Senior Manager, WI DNR

Chippewa Falls washing plant (example)6

5 high capacity wells permitted 1 well pumps 3,000 gallons/minute (g/m) 5/6 recycled (estimated use is 500g/m/well) 200 million gallons per year per well 1 billion gallons/year total consumption

Comparisons

2350-acre irrigated field (dry growing season) 500-cow dairy farm

Note: more water is needed to mitigate ambient dust

Frac‐sand layer

Water Table 

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Socio-economics The industrial nature of frac-sand mining has the potential of changing the economics of SE MN permanently.

Tourism The Blufflands of Southeastern Minnesota and its Great River Road (HWY 61) is a tourist attraction year round. The region provides a critical migratory corridor for forest songbirds, raptors and waterfowl. The rolling bluffs, winding river valleys, trails, trout streams, State forests, campgrounds, agricultural setting, Lake Pepin, and wildlife offer residents and tourists a plethora of enjoyment.

The industrial nature of sand mining reduces air quality1 , trout stream health2 and river water levels3, and increases traffic (trucks every 2-3 minutes) and noise (a minor blast can be felt a mile away—as testified by several local residents).

Agriculture Mining and agriculture compete for land resources. The six-county area of SE MN netted 9,586 agricultural production jobs during Q1 of 2010.5 Converting agricultural land to mining will affect jobs and exports. Reclaimed agricultural land loses a significant nutrient base during the mining process; it is rendered useless as productive farmland according to Minnesota Land Stewardship.

Property Values/Taxes Dr. Hite’s research (Auburn University) discovered properties within a 3-mile radius of a mining operation experience a permanent reduction in sale price: up to 30% for those properties adjacent to the mine site, 14.5% for those 1 mile away, 8.9% for those 2 miles away, and 4.9% for those 3 miles away.6 A study applying this research in Richland, MI, found property values decreased by over $31.5 million.7

Jobs According to Workforce Connections (WCI), approximately 1/8 of 1% of Wisconsin’s workforce works in the sand mining industry. In the 8-county western area of Wisconsin where frac-sand mining is growing, the industry generated 77 jobs in 2011. Average earnings ranged from $22.81 for operating engineers to $11.87/hr for laborers.8

Economic Stability Deller, from UW Madison has researched frac-sand mining from an economic perspective. He says mines are susceptible to a flickering effect. Depending on the price of the commodity being excavated, mines will shut down or restart. When gas prices drop, the need for sand has drops, which slows production. He found the ownership structure of mines also plays a factor. Locally owned mines tend to be better for the community than out-of-state companies with no ties to the area because local mines keep profits in the community.9

1 Kirkhorn & Garry (Aug, 2000). Agricultural Lung Diseases. Environmental Health Perspectives Supplements, 108 (S4):705 2 Baran (May 18, 2012). Frac sand sediment spills into St. Croix River. Minnesota Public Radio. 3 MN DNR (Oct 18, 2012). Drought Conditions Straining Water Resources. 4 Explore MN (2012). Tourism and Minnesota’s Economy. 5 Pearson (2012). Positively MN. More than plowing the fields- farming jobs in SE MN. MN Dept of Employment and Economic Development. 6 Hite (2006). Property Value Impacts of Gravel Pits in Delaware County, Ohio. Report for Upjohn Institute, Kalamazoo, MI. 7 Erickcek (2006). An Assessment of the Economic Impact of the Proposed Stoneco Gravel Mine Operation on Richland. Upjohn Institute. 8 Workforce Connections, Inc. (2011). Frac-sand mining industry report. 9 Schuldt (Jan 23, 2013). Experts detail health, economic impact of sand. Houston County News. 10 Tevlin (Sep 22, 2012). Roaring trucks, frac sand dust disrupt a river town's rhythm. Star Tribune, Minneapolis, MN.

SE MN Leisure & Hospitality Industry, 2010 

County  Gross Sales  Sales Tax  Private Sector 

Fillmore  $18,789,637  $1,320,112  559

Goodhue  $69,471,251  $4,774,964  1,799

Houston  $9,867,417  $696,978  293

Olmsted  $357,407,170  $23,699,324  7,436

Wabasha  $21,715,530  $1,434,334  634

Winona  $78,258,802  $5,343,005  2,041

$555,509,807  $37,268,717  12,762Data from MN Dept of Revenue & DEED

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“If you look at the community before the mine and then look at the community after the mine shutdown, the community is worse off after the mine has shut down.” Steven Deller, UW Madison

“…we were greeted with huge trucks roaring through town 24 hours a day. The simple act of crossing the street became a safety hazard, and a normal night's sleep [was] impossible. We cannot emphasize enough the effect this has on our considering McGregor for future stays."10