_:               'W 'a 'a 1 *: " Its )@ 1 -



rIkonC Should be done of clean-up costs on
amount to be collected by these fees to
sufficient money available for Possible



" problems.

         The whole issue of the groundwater standards beneath the
    MWDF is neatly sidestepped in the DEIS (p. 117).       NR 182.075,
@ Wis. Admin. Code, says federal levels are a minimum, but the DNR
    can set standards to protect the resource.     The impacts of the
    standards to be used are not addressed.      The baseline aquifer
    quality is very good    (p. 53-54).    Will the standards permit
    degradation of the aquifer?

         After the groundwater recovers to pre-mining levels, an
estimated thirty years, what contamination may result from the
(174)soils that were dewatered being saturated again (p. 115)?     This
_  'problem  is  not  evaluated  and  is  important   since  Exxon's
    responsibility ceases at that time.

         The  surface   water   bodies   which   will   receive   these
    contaminants are Hemlock Creek, Creek 11-4, and Creek 12-9. No
N  impact  analysis  is done   on  the  effect of  the contaminated
(175)groundwater discharge into these streams (p. 142). Swamp Creek
-will also receive a portion of the flow once baseline gradients
    are re-established. No analysis is done on these effects.

                         SANITARY LANDFILL (MRDF)

         The disposal of non-tailings mine waste gets scant attention
    with most of the analysis focusing on why tailings disposal is a
    bigger issue (p. 113). A design seepage of 500 gpm which could
,-~ be several  times  larger  is not a no-impact scenario.      More
e-analysis   is   needed  on   the   special  problems   of  control,
    monitoring, design life, etc.      If the landfill were proposed
    alone, it would receive much more attention than the DEIS
    provides.  Just because other dangers are a greater threat, the
    MRDF cannot be ignored.

                              WETLAND IMPACTS

         Wetlands are an integral part of the water system in the
    project area, yet their role in the natural water system is
    virtually ignored in the DEIS. The project area includes 1.5% of
@ the total wetlands in the Upper Wolf River watershed (p. 68), and
    the DEIS, without substantiation,    says the "majority' of the
    wetlands are perched.   This conclusion is crucial in evaluating
    drawdown impacts so the authority for it must be stated (p. 68).

         -The DEIS never clearly differentiates the drawdown impacts
aon wetlands and proposes no mitigation for any effects. Without
W51.mitigation,   some   wetlands    will  be   completely    dewatered



    (P. 121).   While changes in vegetation and water quality are
    generally mentioned, the changes are not described (p. 121).

         Further confusion is added when it is stated 600 acres of
    stream-side wetlands will be affected by gradual shifts in
    vegetation but no analysis is undertaken      (p. 130-131).    How
(~\important are these wetlands to the streams? Will they recover
e after drawdown?     What about the effects of drawdown on the
    wetland north of the mine near Swamp Creek? Until the different
    types of wetlands are identified along with their role in the
    water system, the impacts of drawdown cannot be known.

~ Erosion impacts on wetlands are not evaluated in any way in
    the DEIS.

         Another omission in regard to wetlands is possible quality
, impacts from the mitigation water which will be added to the
    'lakes and streams.

         Several of the special natural areas to be impacted are
wetland areas (p. 69).        What will be the effect on the Swamp
    Creek Cedars, the Burr Oak Swamp, and the Upper Pickerel Creek
    Cedars and Pines from drawdown and other project effects? These
    areas are omitted from the impact analysis.

                                AIR QUALITY

         The air quality impact analysis is incomplete in several
important respects.       At several points it is mentioned that
(ig3chemical stabilizers or water would be used to control dust (p.
\....27, 30). What chemicals would be used and what are their
    effects?   Are these measures voluntary or will they be permit
    requirements?

         The major operations air problem would be heavy metals dust
from  the  operations  and  the  tailings   ponds  (p.  34).    The
possibility that asbestiform minerals or asbestiform particles
'could be emitted has not been analyzed (p. 51, 32).    Since these
    substances pose serious health concerns, an impact analysis
    should be conducted.

         The tailings dust contains several human carcinogens so that
    it is crucial for emissions to be kept to a minimum (p. 156).
The DEIS discounts tailings dust as a source of these emissions,
    but does not state how DNR will guarantee there will be no
    tailings dust (p. 146).    This is a significant problem at many
    tailings disposal sites.

         The DEIS concludes air emissions will have no effect on the
E  quality of lake water (p. 139).    Skunk Lake is omitted from this
(186)analysis. Further, these effects are not analyzed in conjunction
\./with water quality effects from mitigation pumping.        What are
    those combined effects?



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