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     wastewater treatment system could immediately be detected and the flow
of
     effluent to Swamp Creek be stopped.   There is no indication in the
monitoring
 plan presented as to how such remedial action would be implemented either
at
 ethe main discharge site or at other points of discharge.

         The biological and chemical monitoring in Swamp Creek above and
below the
     discharge should be improved. Additional bulk sediment analysis should
be
     incorporated in the plan to monitor the accumulation of metals in the
     sediments. The schedule for collecting benthic organisms from artificial
-     substrates should be specified and be frequent enough to determine
the effects
(319Jof the discharge on the life stages of all species present. In addition,
     benthic organisms must be collected from natural substrates and subjected
to
     elemental analysis to determine the rate of metals incorporation. These
     collections should include plant as well as animal material. The samples
     should not be stored for later analysis, as is stated in the DEIS, but
should
     be analyzed as part of the regular monitoring schedule. The monitoring
of
     biological material for toxics accumulation should also be conducted
near the
     points of mitigation water discharge and where leachate from the MWDF
may
     enter a surface water body.

         Intensive monitoring should be conducted for two to three years
before
    operation and a period of five years after full operation before a reduced
    monitoring schedule is approved. This would be necessary to account for
    natural environmental fluctuations and to allow sufficient time for effects
to
(321)be manifest in organisms with long life cycles.     A control lake-stream
system
'should be established in the vicinity of the project but outside the area
of
     environmental impact to monitor any long-term natural variation which
may
     occur. This would provide essential information to access the effects
caused
     by the mining operation.

         It is stated in the DEIS that if monitoring indicates any adverse
effect,
     the DNR would decide if any steps would be taken to correct a problem.
Some
     definite limits must be established now, and corrective actions defined,
to
     avoid a lengthy debate in the future concerning an "appropriate
action."

                                     ADDITIONAL IMPACTS

         The impact of the project on waterfowl has not been adequately addressed
     in the DEIS. It is noted that 36 species of migrant marsh or waterfowl
use
     the area. Open water is attractive to such birds and the MWDF and reclaim
ponds could draw birds to the ponds. The impact of waterfowl using ponds
e containing highly toxic wastes should be addressed and an appropriate plan
     presented to eliminate any adverse impacts. A similar statement should
be
     developed for other animals which might be attracted to the ponds for
water or
     food if vegetation develops within the dikes.

         Various types of dust suppressants and herbicides will be used over
the
project site. The amounts and types of these chemicals must be specified
and
(322)an approved application plan or alternative measures presented. The
impact of
x.'these chemicals on the environment must be presented in the final EIS.

                                   SUMMARY AND CONCLUSIONS

         Beneath the glossy cover and between the colored art work, the Draft
     Environmental Impact Statement for the Exxon Minerals Company's proposed



zinc-copper mine in Crandon, Wisconsin does little more than to restate data
from the Exxon Environmental Impact Report. Several potentially significant
environmental impacts are not addressed or are considered to have no
detrimental impact on the surface water environment.

    The principal environmental impacts of the project which are not
adequately addressed in the DEIS are as follows:

    (1) The impact of soil erosion and the siltation of streams, lakes and
         wetlands, which if allowed to occur unabated, will destroy valuable
         aquatic habitat and the species residing therein.

    (2) The bioaccumulation of metals by organisms, inhabiting areas near
         contaminated discharges which can lead to altered populations of
         invertebrates and fish.

    (3) The alteration of natural surface water quality conditions by
         groundwater drawdown and mitigation pumping which will lead to
         changes in natural species assemblages in affected lakes and streams.

    (4) The long term impacts of leachate from the MNDF which could
         contaminate ground and surface water with unacceptably high
         concentrations of heavy metals and other pollutants.

    The final EIS should synthesize the total impact of the Project on
surrounding lakes and streams and not concentrate exclusively on those systems
within the site boundaries which will be directly impacted. Lakes and streams
of particular concern are the upper and lower reaches of Swamp Creek, Hemlock
Creek, Rice Lake and Rolling Stone Lake with its northern tributaries. The
effects of all impacts of the mining project must be integrated into a
concluding section of the final EIS. Such a section should consider the
cumulative effects of the impacts discussed here as well as those resulting
from atmospheric inputs and underground activities. Each potential impact
cannot be considered as a separate, isolated effect but must be assessed
in
relation to the total environmental impact of the project.



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