Wild Rice Research Briefing Iron Mining Association Presentations - - PowerPoint PPT Presentation

Wild Rice Research Briefing

Iron Mining Association Presentations to Range Cities

October 1 and 2, 2014

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MN CHAMBER ANALYSIS OF MPCA RESEARCH & PRELIMINARY DETERMINATIONS

Wild Rice Research Briefing

2

Minnesota Chamber Review Team

ENVIRON International Corporation

– Scott Hall, Senior Manager, specializing in

aquatic criteria development, served as hydroponics testing project manager

– Robin Richards, REM, Principal –

biochemist and plant physiologist, served in toxicity assessments and rulemaking guidance

– Mike Bock, Ph.D. Senior Manager –

environmental statistician

Barr Engineering Co.

– Rachel Walker, Ph.D., Senior

Environmental Scientist – wild rice biology and nutrient dynamics, wild rice surveys, project management

– Mike Hansel, Senior Chemical Engineer

and Vice President – water quality rulemaking, environmental permitting

– John Borovsky, Senior Environmental

Scientist and Vice President – soils and groundwater interaction, environmental permitting

– Lindsey Tuominen, Ph.D., Biostatistician

– statistical analyses

University of Minnesota

– David Grigal, Ph.D., Professor Emeritus

Soil Water and Climate

University of California Davis

– Steve Grattan, Ph.D. Department of Soil

Science, plant-water specialist

Fort Environmental Labs

– Douglas Fort, Ph.D. President, aquatic

and terrestrial toxicology, developmental toxicology, toxicology/pharmacology

ALLETE/Minnesota Power

– Kurt Andersen, Environmental Audit

Manager, aquatic toxicity assessment

3

Overview & Implication of NOT adjusting the current wild rice standard

• 1. Agreement: MPCA and Chamber hydroponic

studies both confirm that sulfate does not directly affect wild rice up to 1,600 – 5,000 mg/L

• 2. Different view on toxicity of sulfide
• 3. Implications to cities & businesses if current

standard is NOT adjusted

4

Toxicity Testing

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Fort Environmental Labs: Wild Rice Sulfate Toxicity Testing

MN Chamber’s Analysis of MPCA’s Research & Preliminary Determination

From “TOXICITY OF SULFATE AND CHLORIDE TO EARLY LIFE-STAGES OF WILD RICE (ZIZANIA PALUSTRIS)” Journal

• f Environmental Toxicology and Chemistry, DOI

10.1002/etc.2744, September 2014

“Overall, results from this study suggest that sulfate did not adversely affect germination and early development of wild rice at concentrations below 5,000 mg /L over the 21-day hydroponic exposure. Some effects induced at high sulfate concentrations were also observed in osmotically equivalent chloride treatments, and some sulfate-specific stimulatory effects may be attributable to the effects of sulfate as a plant nutrient.”

6

MN Chamber’s Analysis of MPCA’s Research & Preliminary Determination

Results agree with those of Dr. Pastor’s hydroponics test: direct toxicity of sulfate to wild rice occurs at sulfate concentrations far greater than 10 mg/L sulfate

• Dr. Pastor saw no adverse affects at 1,600

mg/L sulfate for rice germination and growth (maximum level tested)

7

MN Chamber’s Analysis of MPCA’s Research & Preliminary Determination

MPCA developed two hypotheses on how sulfate may affect wild rice:

– wild rice can be impacted by sulfate via the conversion of sulfate to sulfide in the rooting zone

• f the plants and

– iron may mitigate the effects of sulfide production in the rooting zone of the sediment (emphasis added)

8

MN Chamber’s Analysis

• f MPCA Research & Preliminary Determination

Unfortunately, MPCA research did not test the first hypothesis Only those portions NOT “in the rooting zone” were affected by low sulfide concentrations:

“in all experiments, stem plus leaf lengths and total weights of juvenile seedlings declined significantly (p < 0.05) at all nominal exposure concentrations greater than 9 μM sulfide “

9

MN Chamber’s Analysis

• f MPCA Research & Preliminary Determination

Portions of the plants “in the rooting zone”:

– Roots; – Germinating Seeds; and – Mesocotyl Growth

were unaffected by sulfide at concentrations of 90 µM (2,400 µg/L)

10

MN Chamber’s Technical Analysis

• f MPCA Hypotheses

Field Survey found:

– only 4 lakes with concentrations of porewater sulfide greater 90 µM (2,400 µg/L) and – only where naturally

• ccurring iron concentrations

are very low (e.g., less than 2 μM or 1,000 µg/L)

These lakes are located in the Des Moines glacial lobe, which brought down high sulfur, low iron material from Canada

11

MN Chamber’s Technical Analysis

• f MPCA Hypotheses

The relationships from the field surveys amply demonstrate that the MPCA’s hypothesis was well founded with respect to the role of naturally occurring iron mitigating the presence of free sulfide. The field surveys and the hydroponic studies demonstrate that the hypothesis that total sulfide in the rooting zone impacts rice is not supported. The relationships from the field surveys demonstrate that the hypothesis that surface water sulfate is a key determinant in the formation of sediment porewater free sulfide is not supported.

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Sulfate & iron in groundwater, not surface water, determine sulfide formation

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Iron Sulfate

O x y g e n

Iron

Sulfate

Most of Minnesota

Des Moines Lobe Areas

O x y g e n

If iron is present, it prevents porewater sulfide formation If iron is not present, porewater sulfide can form

Sediment

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MN Chamber’s Technical Analysis

• f MPCA Preliminary Determination

The MPCA has attempted to show a correlation between porewater sulfide, surface water sulfate and wild rice growth. However, federal guidance and MPCA’s own rules require that the MPCA show with 95% confidence that there is causation – a dose-response relationship where sulfate, and not some other factor, affects wild rice. The MPCA must also have high confidence that reducing sulfate concentrations will result in the improvement and restoration of wild rice.

MPCA needs to consider ALL factors which affect wild rice

The MPCA, MN DNR, WI DNR, WI Ag Extension Service, and tribal experts all note the following key factors most affect growth and restoration of wild rice:

– Changes in natural hydrology – Invasive species – Competitive (native) species – Genetic engineering – Climate change – Shoreland development

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HOW SHOULD RULEMAKING INCORPORATE RESEARCH?

• A sulfate wild rice water quality standard does

not appear necessary, given the high concentration of sulfate necessary to adversely affect the growth of wild rice, the weak correlation with porewater sulfide and the role which iron plays in mitigating sulfide.

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HOW SHOULD RULEMAKING INCORPORATE RESEARCH? If a sulfide wild rice water quality standard is pursued by MPCA, all water and sediment factors influencing sulfide toxicity to wild rice have to be considered.

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HOW SHOULD RULEMAKING INCORPORATE RESEARCH? Protecting wild rice waters

To protect wild rice producing waters, a water quality standard really should address all key factors that negatively impact wild rice.

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WHAT DOES THIS MEAN TO MN CITIES AND INDUSTRIES?

Wild Rice Research Briefing

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WHAT DOES THIS MEAN TO MN CITIES AND INDUSTRIES?

If MPCA retains 10 mg/L standard, two things will happen:

1. Wild rice will not be better protected 2. Cities and industries will go bankrupt attempting to meet the 10 mg/L standard

20

Cost to comply with existing standard

According to MPCA:

– 150 cities & businesses have monitored for sulfate – 144 cities & businesses have sulfate > 10 mg/L

Many cities and industries will need to provide additional treatment to meet the current standard Not just mines – data centers, food processors, manufacturers, refiners

21

Cost for cities to meet 10 mg sulfate/L standard

The only technology which can meet the standard is reverse osmosis. City of St. Peter has built an RO system for their drinking water system (2,300 gpm, 3.3 MGD). Capital costs: $10.5 million. Annual O&M Costs: $0.5 million/year. Cost per household: $4.89/month, or $100/year

22

Cost for cities to meet 10 mg sulfate/L standard

But system discharges brine to the river. To meet a 10 mg/L sulfate standard, one needs to evaporate & crystallize the brine. Additional Capital Costs: $19 million Additional O&M Costs: $5.7 million/year Additional Cost per household:

$26.91/month or $323/year

23

Cost for cities to meet 10 mg sulfate/L standard

Total cost for system to treat 2,300 gpm (3.3 MGD) =

$31.83/month, or $382/year per household

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Cost for cities to meet 10 mg sulfate/L standard

Another example, for a Midwest city, including pre-treatment to protect membranes. Estimated costs for membrane reverse osmosis (with evaporation & crystallization of brine) for a large municipal plant (to reduce salt):

$138.60/month per household, or $1,663/year per household.

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Cost for cities to meet 10 mg sulfate/L standard

Minnesota Public Facilities Authority (PFA) uses 1.4% of median household income as a wastewater costs affordability index for Minnesota communities.

US Census Bureau says median household income (2008-2012) is $59,126. Monthly affordable cost would be $69/month

26

Cost for cities to meet 10 mg sulfate/L standard

Can your residents afford an additional

$400 - $1,600 per year

On top of their current water and sewer charges?

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Cost for industry to meet 10 mg sulfate/L standard

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• Taconite industries

– Much higher flows, higher sulfate content

One estimate (2009) ONE discharge at ONE facility 7,000 gpm flow rate to meet 350 mg/L sulfate (not 10) was:

– $110 million capital costs – Today’s costs: $120 million (BLS inflation calculator) – Estimated O&M Costs are in the tens of millions of dollars per year

Meeting 10 mg/L will have no impact on growth of wild rice

If all discharges to “waters used for the production

• f wild rice” meet 10 mg/L, waters won’t meet 10

mg/L (USGS survey)

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Water Body Upstream (background)

Pelican River

11.3

Sauk River

19.4

• S. Fork Crow R.

91

Redwood River

309

Mississippi R. (St. Paul)

50.6

• S. Fork Zumbro R.

32.9

Conclusions

Research demonstrates sulfate is not toxic to wild rice Research demonstrates sulfide in the root zone is not toxic to wild rice where sufficient iron is present and where waters are otherwise suitable for wild rice Research and experience demonstrate that other factors, particularly water hydrology, play a bigger factor where rice does not grow, or does not grow well.

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Conclusions

A wild rice sulfate water quality standard is not necessary and should be eliminated If a wild rice sulfide water quality standard is chosen, it must account for ALL other factors which influence the toxicity of sulfide to wild rice To really protect wild rice, a standard needs to take into account ALL factors which impact wild rice, including, changes in natural hydrology, invasive species, competitive (native) species, genetic engineering, climate change, shoreland development

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Conclusions

Failure to eliminate or adjust the current standard will result in devastating impacts to cities and businesses throughout the state.

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Chamber Members will do their part to protect wild rice

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Hay Lake (August/September 2014) (upstream from Swan Lake) Sulfate concentration >23 mg/L Second Creek (August/ September 2014) (upstream from Partridge River) Sulfate concentration > 800 mg/L

THANK YOU!

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QUESTIONS?

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