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Ruth M. King DNR Nonpoint Source Coordinator/Storm Water Specialist Thomas E.Woletz, P.

E Senior Manager, Special Projects Coordinator

February 14, 2013

Dear Tom Woletz and Ruth King, The issues related to the Mckeesey Marsh and Beaver Creek pollution have been raised and discussed. However there are unresolved issues that must be brought to light. Having grown up with the opportunity to intimately observe and interact with the marsh and creek for sixty years, our knowledge level of the area and how it functions throughout the year is extensive. If we add to that intimate interaction, our combined scientific and practical experiences and skills in chemistry, physics, hydrology, geology, mining & metallurgy, thermodynamics, statics & dynamics, research, project investigation, design of experiment and other higher level problem solving abilities, we are confident that independent scientists would affirm our findings. We must ask: Does the DNR have a Standard Operating Procedure (SOP) for researching and investigating any project such as Beaver Creek? If they dont, the DNR needs to get a good one; if they do and it was followed, the DNR needs to improve it. The missteps, missed opportunities and the unfounded assumptions in this investigation are to say the least, very disappointing. Our assessments of your findings are discussed below: 1. Let us consider the report of muddy water in the median of US Hwy 53 on November 5, 2012. Regardless of who reported this discharge and how overloaded the DNR staff is, priority has to be given to events that have the potential to do irreparable damage. Even two days could make all the difference in the health of the creek and marsh. When the conservation officer was taking pictures, why did he not employ a proper sampling procedure and take 2 or 3 gallons of the muddy water for analysis? Had that been done the DNR would have had a blue print of that waste water discharge; and when Great Northern admitted that it was theirs, you then could check any future discharges against that analysis to prove it was water discharge from industrial sand production. Guessing as to whether the slush was stained by creek water or wet-plant waste water would not be necessary. 2. Why did those that looked at the muddy water in the median come to the conclusion that this muddy water had not entered Beaver Creek? Did not any of the investigators understand the area and why the invasive species canary grass was there? (This canary grass has destroyed the native marsh grass and other native plants throughout the marsh.) The canary grass by itself should have been a clue that they were looking at Beaver Creek. We do not see any discussion as to whether at any time the investigators examined Beaver Creek down stream from the processing plants until January 23, 2013. 3. The statement made by Great Northern that they forgot to calculate the drain water in their sand piles may pass as an excuse, but Great Northern Management was told by us that the storm pond was not sufficient to contain all the spilling and draining water lost from the washing process. Regardless of the rationale expressed, the discharges have happened. These last two discharges (Jan. 9 and 23-26, 2013) seem to be smaller than the two discharges on or before December 7, 2012. We believe the last two discharges to be the result of Great Northern breaking into one or more piles of sand where the water inside of the pile was not frozen and flowed out into Beaver Creek. Regardless of the origin of the water, there were two additional discharges. Whether or not

they quit washing on December 7, 2012, is not evidence to say that Great Northern was not responsible for the last two discharges. 4. For whatever reasons, the discharge of December 6 & 7, 2012, has not been addressed. The DNR has jumped from the discharge that was observed on November 2, 2012, (remnants photographed by Mark and Denise Ziperski on November 3, 2012 - see last page) to the out flows of January 9 & 26, 2012. The photographs taken of not-yet-frozen muddy water at the bridge on 29th Street have been ignored, and no explanation of why the muddy water looks exactly like the muddy water in the median of US 53 has been offered. John took great care to document that the discharged waste water seen at the 29th Street bridge flowed beyond the County Line Road bridge (Ref. December 6 & 7). 5. Several people have observed that when these discharges cease, the creek clears up in 1 to 5 days at the most. On November 2, 2012, John and one other witness clearly saw the creamed coffee-colored water flowing at County Road SS. On November 3, 2012, Mark and Denise Ziperski took photos of the creek that was nearly clear except for the remnants of flocked white sand. These photographs and observation by others clearly prove that tannic acid was not the cause of the muddy water going down Beaver Creek. The fact is that tannic acid staining of the creek water, in a stagnant beaver pond, at the height of the summer-organic decomposition is translucent, not opaque as this muddy water is. Adding this to the fact that organic decomposition in marshes nearly ceases by early November, makes the hypothesis that this colored water coming up over the ice at 29th Street and the ice at County SS is just normal tannic coloring (and not fine clay and silica silt) is simply not true and not supported by the facts. In sixty years of observation we have seen overflows of water on top of the ice at various places along the creek, but they all appeared as just that, creek water on top of the ice with no real color in the water so that you think nothing of it. This is the first time in 60 years that we have ever observed this coffee-colored muddy water on top of the ice. The only change is that contaminated water has been discharged into Beaver Creek. 6. Freezing a bottle of muddy slush over night does not prove anything as to what the water contains. It does not prove that tannic coloring, chemicals or other materials are, or are not, in the water. What does happen, (if you let the water thaw in a clear container) is that the clay and ultrafine silica sand will settle to the bottom of the glass. While the muddy water in the median of US 53 does not seem to settle out, but the particles in the thawed glass of water do, can be explained. The process of freezing the muddy water nullifies the zeta potential (or charges) of the particles, allowing them to drop to the bottom of the glass. Both freezing and boiling do strange things to materials contained in water. Another anomaly that demonstrates the effects of cold would be its effect on the pure aluminum metal. Pure aluminum becomes more ductile as you cool it down to absolute zero (-460 F). Most other metals become more brittle. 7. When you are investigating an entity, you should rarely ask them a question that you dont already know the answer to. It was a good piece of investigation when you asked Great Northern When did they last wash sand? However, their answer of December 7, 2012 should have triggered you to think of the discharge documented by John. That was the last piece of information that was needed. Now you had their admission that they were producing waste water on the 7 th of December, and if you exclude Chieftain, the muddy water documented at 29th Street and near the County Line Road could have only come from Great Northern. This was a second discharging of

waste water into the creek. When Great Northern stated that they terminated washing on December 7, 2012, you had an opportunity to ask many pointed questions about the December 6th & 7th discharge. Were there questions on this topic? And if so, what were the answers? 8. If samples of water had been taken on November 7th and tested properly, markers or identifying characteristics of Great Northerns sand would have been established. If sufficient quantities of slush had been taken, proper tests would have determined if the discoloration was caused by a discharge from Great Northerns processing site. Sufficient ice chips from the discolored flow occurring on January 9th, now frozen on top of the ice over Beaver Creek, should have been collected for testing as well. The January 9th flow travelled downstream farther than the eye could see. It is unlikely that ground water seepage could be that voluminous. Since the water from January 9, 2013, remains frozen on top of the ice, one can still obtain samples. One would also need a sample from Great Northerns storm pond (or possibly from the median of Hwy. 53). 9. How pumping the waste water back to the clarifier was going to solve the problem escapes us. Obviously, their pond and recycle water system was, and probably still is, over loaded. It is our opinion that the cold weather brought an end to the discharges until they were working with the sand piles again. What part of the operation the water came from is not important. (Note that hypotheses, theories, conjectures and opinions do not prove or disprove anything.) 10. Conclusions based on the fact that natural phenomenon could, or did, cause the water to be the color that we are seeing on or through the top of the ice simply does not hold up to scrutiny. We will agree that hydrostatic pressure forces the seepage water to flow under the culverts via the gravel that is below the frost line, but we must add that the same mechanism will also force the muddy water under the culverts as well. We already have observed that the creek is cleaned up by ground water seepage in 1 to 5 days after the plant site quits discharging muddy water into the creek. What you are seeing in the ice, in your photographs, is diluted muddy silt. If you had taken an ice axe and collected some of the overflow ice of January 9, 2012, or allowed the slush and water in the bottle that froze over night to melt and settle out, you would have seen fine clay and silt in the bottom of the bottle. I am assuming that you allowed the water in the bottle to melt; did you look at it before you threw it out? Was there enough water to test? 11. Even now, one could probably cut a hole in the ice where the muddy water is in the median of US Hwy. 53. If the cold water has not de-activated the ions, a DNR agent could probably collect muddy water samples. (We addressed some of this in #8.) In summary: We respectfully and strongly suggest that you start over, taking samples where it is possible and process them in a controlled manner, generate answers from what you know to be true, and address the event documented on December 6 & 7, 2012. The conclusions drawn from this investigation are questionable. Because time and equipment was not available, the time that was spent resulted in erroneous conclusions. Sincerely,
John P. Drost Ph.D Professor Emeritus Mathematics, University of Wisconsin, Eau Claire James J. Drost BS, MS Mining and Metallurgical Engineering, University of Wisconsin, Madison

Photo #1 November 3, 2012

Photo #2 November 3, 2012

The above photographs were taken at the crossing of Beaver Creak and Cty. Road SS by Mark and Denise Ziperski on November 3, 2012. This was the day after ( November 2, 2012) John Drost and another witness observed muddy water at the crossing of Beaver Creek and Cty. Road SS. Please note in Photo #1 that there is flocked fine silica sand. This indicates that Great Northern is probably using polyacrylamide as they said they would. Please note that Photo #2 shows some flocked fine silica and foam. The white foam indicates that Beaver Creeks flow rate was recently higher as was witnessed on November 2, 2012. Note that neither photo shows any staining from organic material decomposition.