spent designing their mining projects. The bulk of the development cost is expended upon basic exploration, extraction and
processing plus engineering, planning and procurement. The methods of mining and processing sulfide ores are advanced
globally and applied locally. Environmental review costs consist of modifying the project designs to meet local pollution
standards. The lower the standards, the lower the additional cost.
The sulfide ore bodies in northeastern Minnesota are very low grade. The copper equivalent metal content is roughly 1%. This
means that 99% of the hard rock is waste and left behind at the mine site as mine and process waste. Well-defined metal
deposits are distributed as specks in billions of tons of hard sulfide ore. Dealing with the billions of tons of waste is a project
cost and not assignable to environmental review. The waste contains inherently reactive, toxic material. Exposing the crushed
rock to air and water produces sulfuric acid, sulfates and iron pyrite among many other compounds. The acid and sulfates in turn
leach toxic minerals such as copper, nickel, cobalt and manganese out of mine waste at dangerously high levels. The sulfate
becomes part of the mercury methylation process which eventually poisons fish and children.

So, in order to generate maximum profits the cost associated with moving and disposing of crushed hard sulfide ore must be
“controlled”. From the environmental perspective these mining project plans must be designed to fail. The waste is reactive and
the leaching process perpetual. The surface area of the reactive material becomes infinite during the crushing process.
Acidification, leaching and resulting water pollution then becomes perpetual. There are no relevant examples of this process
ever being prevented. Thus pollution must be mitigated and reduced to local environmental standard levels for as long as the
mining and processing continue. Then the mitigations will begin failing and water pollution will increase.

“Mitigation” means to lessen in force or intensity. It does not mean “prevention”. Federal and state government sets limits on the
discharge of elements and compounds that are toxic to humans and their environment. Historically, these limits have been
determined by trial and error. Limits are now set by a process called “science based risk management”. Generally, if analysis
shows that less than a statistically based number in 10,000 would die from exposure to the pollutant, a pollution permit may be
granted. Here science, mathematics, health studies and subjectivity become tools of economics and politics. Mitigation
becomes a permitting tool and compliments the process of “risk analysis”.

“Mitigation” has multiple meanings. It also means “to mollify” which in turn means “to pacify or appease”. In order for pollution
mitigation to be “cost effective”, risk analysis must show that pollution at a preferred level will not cause excessive human or
environmental damage. The methods of reducing pollution to this level will then allow projects to be permitted by the state and
satisfy federal standards as well. The “majority” of the population must be psychologically mollified to accept cost effective
mitigation schemes.

The process of softening up the “majority” of the target population begins early and is intentional. Of the things concerning the
“majority” in most prospective mining districts water pollution does not rank high on the list. The financial benefits of the mining
projects are headlined in all communications sources and most outlets become dependent upon income from this corporate
advertising. The potential cost of implementing mitigation schemes, both social and environmental, is underestimated, back
loaded and becomes a huge public liability. This population is “captured” by a process consisting of political influence,
jurisdictional control, management of regulator concerns and harmonizing messages with local constituents who will speak for
the company.
Even though the concepts are not mutually exclusive, there is a difference between mollification of the public concern about water
pollution and mitigation of the water pollution sources. The public is first convinced that the environmental review process is too
cumbersome and must be “streamlined”. This is a pseudonym for weakening water quality standards which in most cases are
already sufficiently weak to permit harmful pollution. Key agencies are vilified to the extent that politicians secure concessions in
permits or have statutes written or changed to make the mitigation process even more affordable. Those who do not cooperate
are not rewarded.

In northeastern Minnesota a major threat from copper-nickel (sulfide) mining is known to be a fundamental chemical process
called acid leaching or acid mine drainage. Past experience with sulfide ore waste from the old Dunka Pit and other exploration
projects has demonstrated that water and air react with iron-sulfide waste material to produce sulfuric acid, sulfates and iron
pyrite. The acid and sulfates either leach toxic elements out of the surrounding material or methylate elemental mercury in water
to create a compound harmful to fish and human fetuses. The limits for sulfates is set at 10 mg per liter of water in Minnesota
and is routinely ignored by state agencies and mining companies in permitting. Elemental copper, nickel, cobalt, manganese,
etc. also have federal discharge limits that are often exceeded or excused through the state permit variance process.

Over the past few years, in some cases decades, the chemical dissolution process of sulfide waste has been studied
extensively. A series of mitigation processes to either neutralize or prevent chemical reaction from sulfides has been developed.
These mitigation processes are being offered as means of controlling the release of the toxins from mining and processing
waste at sulfide mining project sites. As previously described, these mitigations are mainly tactics used to delay pollution and
obtain permits to mine and pollute. Millions of tons of crushed waste rock and ore processing slime would be disposed of in on-
land piles, underwater in old mine pits or underground in depleted mine shafts. The closer the dump areas to the mine and
plant, the better for profits. The MNDNR has studied the environmental dissolution of Duluth Complex Rock since the 1980s.
Their studies have shown that the ph of drainage from on-land disposal piles has decreased from 7.5 to 5 over a period of 15
years. Limestone and iron oxide can be used to neutralize waste piles to prevent total leaching and also to treat drainage waste
water. These methods of treatment are expensive as well as being ineffective in the long run.
A great deal of attention has been focused on sub-aqueous disposal of waste in old mine pits and ponds. Results have shown
that the reaction of FeS waste is slowed dramatically under water and that the water could be in “pristine” condition after a century
“without significant disturbances” to the storage pond! The ph stayed at 7.5 in accelerated tests and the release of toxic metals
was reduced. Sub-aqueous disposal is eerily similar to the process of disposing of nuclear waste. Immerse it in water and
forget it! Unfortunately elements such as nickel and cobalt and manganese are still released and need to be treated regularly.
The bulk of the reactive material is left at the bottom of the pit. This would be a pollution mitigation tactic with unknown
consequences and with the potential for massive pollution in the future. Pond leakage, ground faults, project failures and
corporate bankruptcies introduce incalculable risks into “science-based risk management”. It’s a real “Monte Carlo” process.

State agencies and corporations are also developing overall strategies for “managing” sulfate discharges from current taconite
processing waste ponds. Subsequent application to discharges from copper-nickel disposal sites is also an objective. The
objective is to show that mercury methylation and wild rice destruction cannot be directly correlated with sulfate levels in wild rice
waters. This work is being compressed into the current mine permitting schedule requirement of two years. A former agency
employee, John Moyle, spent 30 years demonstrating that water polluted with more than 10 mg per liter of sulfates does not
support normal wild rice production. The same agencies have given up trying to reduce the emission of elemental mercury into
the St. Louis River. Sulfates have a statutory limit which is being attacked (streamlined) through the impressive array of science-
based methods. This is avoidance methodology rather than precautionary methodology and a misuse of science.

Now that mercury remediation (MPCA decision) is of off of the table, sulfates can be more easily “managed”. The goal is to show
that sulfate discharges can be controlled through seasonal or controlled releases and that sulfates are not the primary cause of
mercury methylation and wild rice root destruction. The MNDNR Mine Water Research Advisory Panel will make the final
recommendation on sulfate discharge management. If not Orwellian, this study is becoming very selective scientifically. Wild rice
production waters are being “redefined”. A revised sulfate standard may only apply to “designated waters”. Laboratory “dose
response” methodology is being applied to wild rice growing in a complex natural setting! The Moyle studies were “not good
enough” according to those that did not like the results. Even if the waters were judged to be impaired for wild rice by sulfates
they would be placed on the Clean Water Act 303d list for remediation with the TMDL process which does not include
enforcement or penalties. Mitigation would effectively and purposefully never be achieved.

Other direct methods of removing sulfates and dissolved metals from copper-nickel mining and processing waste are being
proposed. Many have been tested at sites such as the Eagle River Project in Michigan’s Upper Peninsula. Reverse osmosis
modular processing units are used to remove the pollutants from low volume leakage from either waste piles or sub-aqueous
storage ponds that in most cases were designed to leak. This is obviously a short-term, expensive method used to remove
sulfates, iron, total suspended solids, manganese and other toxins. Membranes must be changed, water quality monitored and
adjusted and modules added for seasonal and weather affected flows. Normally the mines are given variance to release
pollutants above statutory limits if “costs” become “burdensome”. For example the sulfates in taconite pits and metals in retired
mines sites are released by permit variance above permit requirements. This is where local politicians either change the
standards in “non-transparent” actions or encourage “delays” in enforcement.
Other more crude means of mitigating dissolved metals in Duluth Complex-impacted water include the use of taconite waste to
“attenuate” dissolved minerals. The tailings are rich in iron-oxide which acts as a sorption material. They are also close to the
copper-nickel projects in many cases making them cost effective with respect to transportation. Mixing the two waste streams is
the main problem. Copper, nickel and cobalt are removed from solution in varying amounts. PH control is difficult. Also, the iron-
oxide tailings have been shown to draw metals out of the upper levels of the storage ponds.
Another waste management technique involves removing smaller particles from the course tailings to reduce the reactivity of the
on-land piles of lower sulfur content. This could be combined with engineered liners and leakage water treatment for on-site
runoff mitigation.

In all cases the mitigation of dissolved metals and sulfates in solution due to precipitation, processing, sub-aqueous storage,
natural fractures or earth movement is expensive and an inexact science at best. Science-based risk management is a
misnomer. The process is really financially-based risk management. Mining the Duluth complex is seen as being inevitable. The
mantra is “when, not if”. The wishful thinkers and those heavily financially or intellectually involved call it a “stewardship question”.
This redefinition of conservation concepts is part of the “population capture” methodology sweeping the globe.
If permits to mine and pollute were issued based upon the “mitigation concepts” being proposed, the St. Louis River would
deteriorate into a drainage ditch and Lake Superior into a polluted shipping canal. Northeastern Minnesota would truly become a
mining district glowing in unison with the metropolis to the south. And the Boundary Waters Canoe Area Wilderness has similar
sad prospects. Tall pines would protrude out of a smoky haze with canoes slicing through lifeless waters, a macabre setting for
a mystery novel; who done it?

The pollution mitigation methods proposed for the control of water pollution from sulfide mining processing and extraction are
unproven schemes to assure the public that copper-nickel and related mining will not harm public health or the environment.
This has never been accomplished anywhere in an environment equivalent to that of northeastern Minnesota. After the Flambeau
Mine environmental failure in Wisconsin, the state passed a law requiring that a moratorium be placed on sulfide mining until it
could be shown that at least one similar mine did not discharge polluted water after 10 years of closure. That mine is still leaking
pollutants into the Flambeau River. The earth is covered with waters polluted by abandoned sulfide mines. Check out Ghana.
The Environmental Protection Agency has determined that this type of pollution poses the greatest threat to our waters of any
industrial activity. Minnesota needs a moratorium on sulfide mining so our ingenious entrepreneurs can demonstrate effective
acid mine drainage control that would be effective and affordable for centuries.

LeRoger Lind   06/10/2013
Save Lake Superior Association
Sulfide Mining Plans Designed To Fail Environmentally