To: Coronado Forest Service
From: Nancy Freeman
Concerned Citizen

Date: March 18, 2008

Subject: Dust pollution in mining operations

We all know that Pima County is full of underground metals. It's a matter of who is first when it comes to our public forest land— people or metals? There are 145 mines listed in Pima County, covering thousands acres of manufactured wastelands. This list includes the five gigantic operations of Twin Buttes, Ajo, Mission , Silverbell and Sierrita. I think that Pima County has given its share of metals to the planet.

See Attachment One: List of mines in Pima County from Home Town Locator

The truth is there are plenty of wastelands in the Southwest, including in Arizona that have undiscovered metals. These wastelands are appropriate for modern-day mining. For modern mining has created a plethora of environmental problems, and all of them exist here in Pima County. Water depletion, water pollution, vast expanses of wastelands, huge pits that will become toxic lakes, blowing dust violations, high wire grids, thousands of acres filled with mining sludge, open ponds of sulfuric acid, noise of trucks, modern dynamite—ANFO—blasts, and milling operations. In short, because of technical advances, hardrock mining is no longer compatible with urban regions—especially in an area that people use for recreation and essential watershed. Watershed was one of the principal reasons that forest lands were set aside in the West.

Augusta Resource personnel think they are going to have a “dry” tailings impoundment. [Rosemont Project: Mine Plan of Operations; Augusta Resource, July 11, 2007] Even wet tailings impoundments in this region are subject to air quality violations because of blowing tailings dust. A major event occurred in 2006 in Green Valley when over 300 homes had to be cleaned of a “snow storm” of tailings dust.

See Attachment Two: Records of Notice of Air Quality of Violation for Phelps Dodge Sierrita
                                         Incidents on August 28, August 30, September 2-3, 2006

In 2009, the Pima County Department of Environmental Quality fined ASARCO, LLC, for air quality violations. ASARCO will pay a $100,000 civil penalty and pay $350,000 to fund supplemental environmental projects at  Canoa Ranch Conservation Park.
Excerpt from Pima County Memo describing the incident:

November and December 2009 ASARCO Air Quality Violations

In the fall of 2009, ASARCO began a berm building project to increase the height of Tailings Dam B localed at Helmut Peak Road on the ASARCO Mission Mine facility near Green Valley. ASARCO ceased depositing wet tailings to this tailings dam as part of this construction project. By November 2009, a large part of the tailings dam had become dry, which resulted in wind blown emissions of fine tailings material from the top of the dam. PDEQ issues two Notices of Violation (NOVs) to ASARCO for excess emissions and opacity standard violations. The December 22 event was so severe numerous residents in Sahuarita and Green Valley had fine gray tailings material deposited on the homes and yards.

See Attachment Three: PDEQ Report on ASARCO for air quality violation
                                          Incidents on November 12 and December 22, 2009

The proof that the Canadians don't know anything about the dust reality in the Southwest occurred on November 9, 2007. When they drilled a test well on Alvernon Way , in a rural residential area in Sahuarita. They were so negligent in dealing with potential dust issues that they received a violation of air quality citation from Department of Environmental Quality.

At that time, they also demonstrated their lack of transparency. When the Dept. of Environmental Quality sent a notice of violation to the registered owner of the property, Kenarco Company, it was “returned to sender.” It is common practice among mining companies to have others buy the lands they want for water rights or wells, so that the owners do not know they are selling to a mining company. Phelps Dodge elucidated their using this method in their sanctioned “history”: Vision and Enterprise .

See Attachment Four: Notice of Air Violation, including report, photos, and copy of returned mail.

We are dealing with a forest habitat. Regular dust from mining operations will cover plant foliage that animals have to consume for their survival. This gritty forage could apply to stock animals as well as wildlife. Further, the dust could stunt the plant growth curtailing its growth cycle since the leaves are cut off from sun and fresh air to emit oxygen to the fresh air supply, we certainly need in the land of cement and asphalt.

Dust is produced in every step of the mining operations, the ammonium nitrate and fuel oil explosions to loosen the ore, the pulverizing and milling operations of the ore, and the tailings impoundment. In fact, just the moon-scaping of the mining site produces potential for dust.

Photos of dust produced in various mining operations

Dust from the milling process (Morinci , Arizona)

Dust from ANFO explosions

Dust from waste piles ( Moab, Utah )

 Dust from a “wet” tailings impoundment (Mission mine, Pima County, Arizona)

The dust can cause various skin and respiratory problems. The greatest threat of dust is the prevalence of a fungus that causes Valley Fever in the Southwest, particularly in Arizona . The spores are extremely small, so they can be carried hundreds of miles by the wind. Once inside the lungs, the spores reproduce, perpetuating the cycle of the disease. The disease is particularly deadly to the elderly, young, and those with compromised immune systems. In 2007, there were 4,000 cases reported in Arizona , 870 cases in Pima County , principally attributed to the construction industry. I am including two studies of the danger of Valley Fever in disturbed dust, one by the Infectious Diseases Department of Mayo Clinic and one from U.S. Geological Survey.

See Attachment Five: Studies of Mayo Clinic and U.S. Geological Survey.

On March 5, 2008, the Forest Service signed a Memorandum of Understanding with Rosemont Copper Company (aka Augusta Resource). The Forest Service's proposed action, which is administrative in nature, is “to approve the MPO [Mine Plan of Operations], which would, in turn, grant permission to the Proponent to build and operate specific mine-related facilities on NFS land.”

I challenge the Forest Service. You have outlined 16 pages of commitments to the mining company. What is your responsibility to the public who are the owners of the forest and the taxpayers who maintain these the lands and pay your salaries?


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