Stop G-Tac's Bulk Sampling Permit!

On June 17, along with a Pre-Application Notice, Gogebic Taconite applied for a permit to do bulk sampling, a 'mini-mining' process of taking thousands of tons of rock as a sample to characterize the iron deposit before the main G-Tac mine is begun. The application described clear-cutting, removing topsoil, and blasting 10,000 tons of rock total at five sites, totaling about four acres; yet claimed that "there are no known adverse environmental impacts that are likely to be caused by the bulk sampling activity." Two of the five site maps were also misleading, showing sample sites that are located on a ridge as lying instead on a terrace. On July 2, the DNR responded with a letter requesting a wide range of more information, including measures that would be taken to control acid runoff and dust containing asbestos-like mineral fibers found in some of the iron deposit. On July 28, G-Tac submitted its response. There are a number of items of concern in the new bulk sampling application, addressed below.

  • The bulk sampling itself, according to G-Tac, would only be conducted to determine how a grinding mill to crush the ore should be built. There is no scientific value to bulk sampling; it is just a step toward the full mining operation.
  • G-Tac claims they can avoid blasting any rock by using leftover rock from previous bulk sampling conducted by U.S. Steel in 1960. But they need 800 tons of rock from each of the four previous sample sites, totalling 3,200 tons (instead of 10,000). Given that U.S. Steel only removed 100 tons from each site, and presumably left behind unwanted material, is it likely that there are 800 tons of usable sample left on the surface?
  • The company says that a professional geologist and consultant gave them the opinion that a no-blasting option was viable and estimated the tonnage of rock left behind at each site, but does not name this consultant so their opinion can be independently verified.
  • Heavy machinery, noise, and truck traffic will abound as the rock is loaded from the site onto highway trucks to be taken for processing. The company has already shown they are careless about erosion of access roads in the hills; what happens when off-road trucks are running up and down the dirt access road loaded with tons of rock?
  • In response to the DNR's request for details of dust control measures that would be implemented if blasting occurs, the company responded that, "Dust control measures will not occur for the blasting activity." They claim that blasting will create an amount of dust that is below the pollution threshold that triggers the need for an air emissions permit, and include emissions estimates from the EPA document AP 42, Compilation of Air Pollutant Emission Factors: Volume 1: Stationary Point and Area Sources. The section of the document that is cited is 11.9, Western Surface Coal Mining (table 11.9-1), which discusses the activity closest to what G-Tac's bulk sampling process would entail. Both the bedrock and climate of the areas these estimates pertain to are very different from northern Wisconsin, and the reliability of the estimates themselves is rated below average to poor for areas with conditions different from the coal mines sampled to get the ratings1.
  • The DNR raised concerns about asbestos-like fibers documented in the rocks of the Penokee Hills causing a special air pollution problem and health risk for workers at the site. G-Tac responded by claiming that the asbestos-like fibers don't exist: "Based on our due diligence, the geologic conditions in the Gogebic Iron Range do not support the formation of asbestos." DNR professionals have said that the mineral grunerite, which can contain the fibers, is common in the Penokees. The company goes further, claiming that they "are not aware of any documented occurance of asbestiform minerals in ore bodies in Minnesota," where Iron Range workers suffer from mesothelioma (a lung cancer from asbestos) at three times the rate of the general population. Finally, the company claims that DNR rules would not regulate any asbestos emissions they produced anyway.
  • The company failed to address what precautions would be taken against acid mine drainage if the sampling disturbed "rock with visible or known quantities of sulfide mineralization." The company did not answer the DNR's question, but only responded that it would not disturb the Yale member, which contains a layer that is rich in pyrite (a sulfide mineral). The overlying Tyler slate also contains pyrite.
  • The DNR required a wetland delineation for the sites, which G-Tac hired a consultant to do. The maps provided with the delineation report do not show drainage direction for runoff or any of the downstream wetlands that may be impacted. The wetland and soils overview maps provided with the report are illegible screenshots of online viewers provided by the DNR. 
"In Tables 11.9-1 and 11.9-2, the assigned quality ratings apply within the ranges of source conditions that were tested in developing the equations given in Table 11.9-3. However, the equations should be derated 1 letter value (e. g., A to B) if applied to eastern surface coal mines." AP 42, page 11.9-4.