Towia of         inning Imat committee
Star Route Box 107BB
Pearson, WI 54462
June 17, 1986


Mr. Howard S. Drucken   er, Director
Bureau of Environmental Analysis and Review
Department of Natural Resources
PO Box 7921
Madison, WI 53707



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Dear Mr. Druckenmiller,

We, the members of the Mining Impact Committee of the Town of Ainsworth,
T34N-Rl2E and T33N-R12E, Langlade County, WI., after reviewing the Draft
Environ-
mental Impact Statement (DEIS) released by the Department of Natural Resources
(DNR)
on May 12, 1986, regarding the Exxon Minerals Company Zinc and Copper Mine
near
Crandon, WI, have many concerns and questions on several issues brought forth
in the DEIS. They are:

1. Groundwater Drawdown.
Groundwater will be lowered due to dewatering of the mine and the use of
mitigation
wells to supplement area lakes and streams. Figure 2-4 and Figure 3-2 (DEIS)
picture existing groundwater flow direction. They indicate that groundwater
to
Sections 1, 2, 3, 11, 12, 13 of the Town of Ainsworth receives its groundwater
supply from the area of the mine and the Mine Waste Disposal Facility (MWDF),
consisting of approximately 15 square miles. Located in the Town of Ainsworth
are Rolling Stone Lake (Sections 11, 12, 13, 14), the southwest corner of
Little
Sand Lake (Section 1), Creek 12-9 (Section 1-12), Martin Springs and Creek
11-4
($ection 11-12), Creek 13-2 (Section 12-13), Creek 13-15 (Section 13) and
Upper
Pickerel Creek (Section 2-3-11), all of which receive surface water and ground-
water from the area that will be impacted from the mine dewatering. Possible
further reductions caused by the installation of mitigation wells is indicated
on page 135 (DEIS):
       This pumping, in turn, causes additional drawdown of the water table
       and additional (secondary) reductions of groundwater discharges to
       the surface waters. Analysis of the secondary impacts of the continious
       pumping of dedicated wells shows that, over the long term, the secondary
       reductions in groundwater discharge to surface waters being mitigated'
       approaches the amount of pumpage. Thuss the dedicated wells proposed
       for Pickerel Creek and Hoffman Springs would not be effective in
       mitigating the projected impacts. A limited analysis indicated the
       well at Martin Springs would be more effective and probably would
be
       capable of mitigating the projected impacts. Water pumped from this
       well would be comprised of mostly groundwater which otherwise would
be
       discharging into Rolling Stone Lake. (Emphasis supplied)



     The next paragraph also states that the pumping on Creok 12-9 would
provide...
     'adequate mitigation water for 1-3 months of pumping..." Longer
than that would
     draw water from the creek and reduce the effectiveness of mitigation
pumping.
     Further statements on pages 136-137 (DEIS), such as...'Without additional
model
     simulations using higher aquifer transmissivities, the maximum potential
increases
     in lake seepage from mitigation pumping are unknown..4 model simulation
assumes
     groundwater beneath the lakes would rise in response to increased lake
seepage...".
     .*.'mitigation pumping would further decrease the amount of groundwater
discharging
     to area streams...e and (page 137, DEIS)...'the effectiveness of the
mitigation
     proposal for impacts worse than the expected case cannot be accurately
evaluated
     without additional analysis..." are of great concern for the Town
Board and
     the Mining Impact Committee of Ainsworth. This is because the Rolling
Stone Lake
     District lies directly south of the Crandon Project, in Sections 10.
l11 129 139 14
     15, 22, 23 and parts of 26 and 27, T34N-R12E, and it comprises 39% of
the Town of
     Ainsworth's tax base. (Source: Wisconsin Department of Revenues, 1985).
This does
     not include Sections 1, 2, and 3 which lie between the ore body and
the Rolling
     Stone Lake District. These sections, also affected by the mining, are
taxable
     lands and could adversely affect the township's revenues. Adverse impacts
from
igroundwater drawdown and potential contamination of the groundwater supply
from
    MWDF leakage would have a devastating impact on the economic stability
of the
    town because of the negative impact on private wells. Wisconsin Statutes
    Chapter 144.855 requires...'towns to supply necessary amounts of water
to replace
    that water formerly obtained from the damaged wall or water supply' ...
until such
    time as the Department of Natural Resources finds that a regulated activity
has
    caused a residential well or water supply to become contaminatedt polluted
or
    unfit for human consumption. This, too, then is an additional adverse
impact on
    the economic stability of the town.

    In view of the fact that mitigation wells for Creek 11-4, Martin Springs,
and
    Upper Pickerel Creek has the potential of further water drawdown, and
contingency
    plans of pumping treated mine water and intercepted mine water into the
above
©named creeks and spring in the Town of Ainsworth has the potential
of water quality
     and quantity changes, all private wells located in Sections 11 and 12
of T34N-R12E
     should be considered in the same way as the private wells in Zone 1
(Fig. 1-19, DEIS).
     Page iv (DEIS) statesp,..."Exxon would deepen or replace affected
wells" .. .These
     private wells should be tested for water quality and water level before
construction
     begins.



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