To:      U.S. Forest Service

From: Nancy Freeman, Executive Director
           Groundwater Awareness League, Inc.

Date: May 12, 2008

Subject: Chemical and radioactive waste

Uranium is in the bedrock throughout Arizona, which presents a unique challenge to mining here. The danger is so significant that when the Washington D.C. office of EPA published a report in 1999 on the health hazards of Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM) [Attachment One], they used only Arizona mines as their examples—including Cyprus Sierrita, Twin Buttes and the Cyprus Tohono mines in this region. All three are now under Superfund actions for having polluted the groundwater with heavy metals and/or radioactive chemicals produced in mining operations [Attachment Two]. Freeport-MacMoran has recently submitted to Department of Environmental Quality a 540 page Work Plan regarding the mandated clean-up of heavy metals and radioactive chemicals on the Cyprus/Sierrita site. [Attachment Three] The EPA TENORM report references fourteen assessments of uranium levels in Pima and Santa Cruz Counties. [Attachment Four]

Uranium is practically inert in its natural state. However, when it is ground into powder and treated with chemicals in copper processing—it is converted into Gross Alpha, Gross Beta, radon and other components that are regulated by EPA, as they are known to be carcinogens. [Attachment Five]. We do not know the effects on our bird and animal population that we should be protecting in our National Forests. Even so, it is easy to surmise the consequences of their ingesting chemicals that cause cancer in humans. The Federal Department of Justice cited Morinci , AZ copper mine for bird deaths on the premises. [Attachment Six]

Further, the Rosemont operations will be using sulfuric acid for leaching. [Attachment Seven] Again, the impact of open leach solution ponds on our animal life is perilous. If a critter or bird were to test the waters, the evidence of their demise would be dissolved in the acidic solutions within seconds. How will a mining company prevent this danger to our animal friends who have been habituated to living in this forest for hundreds of years? Furthermore, these solutions are regularly released to the environment, including groundwater, due to breakage of pipes and malfunctioning of equipment. This has been a regular occurrence at Sierrita mine [Attachment Eight] Data indicates that these spills reached two public supply wells causing spikes in the sulfate levels. [Attachment Nine] Further, in 2002, a pond at Silverbell mine near Marana overflowed releasing 242,000 gallons of Sulfuric Acid into the environment. [Attachment Ten]

This danger to human, bird and animal health from radioactive chemicals, heavy metals, sulfuric acid, and other processing chemicals, such as cyanide and xanthates, must be thoroughly investigated and any and all impacts must be avoided The bottom line is that we already have three Superfund sites in Pima County that pollute the water, air and soil with. For the sake of our health, we do not want another one!

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