Crawford Stewardship Project works to protect the environment of Crawford County and neighboring regions from threats of polluting and extractive industries, to promote sustainable land use, environmental justice, and local control of natural resources



Crawford Stewardship Project is a nonprofit organization.
Donations are tax deductible.

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Crawford Stewardship Project
P.O. Box 284
Gays Mills, WI 54631
csp.county@gmail.com

 



Crawford Stewardship Project is grateful for the generous support of RESIST, Inc. RESIST funds and supports grassroots groups organizing on the frontlines of the peace, economic, social, and environmental justice movements.

“We abuse land because we regard it as a commodity belonging to us. When we see land as a community to which we belong, we may begin to use it with love and respect.” ~Aldo Leopold, A Sand County Almanac

"CAFOs are only profitable because so much of the cost and damage is externalized onto the environment, neighbors and wildlife. The monitoring, supervision, clean-up, restitution, fines are not happening, thus the true cost of CAFOs never find the way onto the balance books." Talking point from the CAFO Conference.

“A thing is right when it tends to preserve the integrity, stability, and beauty of the biotic community. It is wrong when it tends otherwise.”
~Aldo Leopold, 1948. A Sand County Almanac.


Monitoring Analysis of Air Surrounding a Chippewa Falls, WI Frac Sand Processing Plant

Summary

Concerned Chippewa Citizens (CCC) of Chippewa Falls, WI, now part of the Save the Hills Alliance (STHA), were concerned that the EOG RESOURCES sand processing plant located in Chippewa Falls would adversely affect air quality in the area. Particulate matter and respirable crystalline silica, a particulate produced when working sand, are known to have adverse health effects.

An air monitoring system was set up using inexpensive monitors Two of the monitors, called “Jo” and “Up”, were positioned on opposite sides of the site such that the line between them would cross the EOG site. This would allow, under appropriate wind conditions, the best opportunity for “Jo”, for example, to measure particulate matter in the air downwind of the EOG site and for “Up” to measure particulate matter in the air immediately upwind of the site, and conversely. When the wind blew in the direction of the line between the two monitors, the difference in the amount of particulate matter measured by the one upwind when compared to the amount measured by the one downwind could be used to determine how much particulate matter was contributed by the plant. See pages 5-6 of the full report for an explanation and image of the monitor and site locations.

Three questions are explored and answered:

1. Is there reason to believe there are other sources of particulates that might affect either of the Up or Jo sites more than the other?
If there were other large sources of particulates this could affect the analysis. Sites with such differing large sources of particulates would not be expected to change particulate concentrations in a corresponding manner and a regression of one such site on the other should show sizable error. Sites which are very large distances apart, and therefore without the same large associated sources of particulates, should not show high correlation. The correlation of Jo and Up with a distant site, Menomonie, are about 0.70; the correlation between the Jo and Up sites is about 0.94. Using regression and graphical data examination it is shown that there is much greater variability with the Menomonie site than between the Jo and Up sites. The conclusion is that there is evidence that there are no other large sources of particulates affecting either Jo or Up and not the other.

2. Is there reason to believe the EOG site is producing off site particulate pollution?
Differences in particle counts between the two sites when the wind was blowing from one to the other, can be used to demonstrate whether it is likely there is particulate pollution emanating from the EOG plant. Comparing the measurements at the two sites when the wind was blowing from the Up site towards the Jo site, 97% of the data points indicate greater concentration of particulate matter at Jo than at Up. Conversely when the wind was blowing from Jo towards Up, 78% of the data points indicate greater concentration of particulate matter at Up than at Jo. The conclusion is there is good reason to believe there is particulate pollution emanating from the EOG plant.

3. Is the particulate matter of sufficient quantity and/or quality to be a health hazard?
In order to answer this question, the adjusted difference in small particle counts between the site at Up and the site at Jo for appropriate wind directions must be converted into a form comparable to standards, i.e. a concentration of weight per unit volume. This analysis brackets the concentration between an estimated minimal and maximal concentration. Of 57 days with wind conditions and humidity appropriate, using the maximal concentration:
• 3.5% show possible exceedances of the EPA PM2.5 standard on a 24 hour basis
• 37% show possible exceedances of this standard on an average hourly basis
• 51% have at least one hour which possibly exceeds the standard.
In addition each of the above exceedances would also, assuming a 10% silica content, exceed various state benchmark levels for silicosis. The data behind these numbers were from monitors about a mile from the facility. It is a safe assumption that as one gets closer to the facility the exceedances would increase.

A particulate monitor required by the Wisconsin Department of Natural Resources (WDNR) and operated by EOG is located onsite. However, it is a single PM10 monitor and the use of a single monitor is inadequate for the determination of concentrations of particulate matter emanating from a site and affecting nearby populations. For Analysis of Inadequacy of WDNR air monitoring requirements at sand mines and sand processing plants: See APPENDIX A full report..

The overall conclusion must be that the Wisconsin DNR has been negligent in regulating this site and its continued operation may be hazardous