Pursuant to our telephone communication, may I address one small part of the SuperFund testing, evaluation and remediation activities related to Wind Cloud Suppression using BioFuel producing plants best suited to produce BioDiesel in a Drought persistent climate, i.e., Jatropha, Castor and Karanj, the preferred for Iron King Mine conditions being Jatropha.

This is in addition to Raina Maierand's grasses suggestions, to create long term land productivity, heavy metal removal and sustainable Green Jobs with a cash generating
(non-food) BioFuels crop.

Question 1.
May I ask what actual 'Dust suppression activities' the SuperFund is doing today to proactively protect the well being of people living around the Iron King
Mine that can watch dust clouds emanate from this toxic mine site on a daily basis?

Question 2.
What has actually been done related to 'dust suppression activities' since Iron King has been designated a Super-Fund site since 2008? If none, why?

Question 3.
Since it is impossible for residents to Avoid dust clouds: How can the citizens around the Iron King Dust Clouds accelerate the Super-Fund's 'Dust Suppression Activities'
into a BioFuels, green job producing, reclamation project?

Question 4.
How can local residents begin ASAP in certain Farming practices activity to plant 'Dust Suppression plants' with or without EPA approval to proactively engage in ameliorating the affected unhealthy residences?

Question 5.
What Carbon Credits are taken into consideration regarding Toxic Land Reclamation using BioFuel Crops? If none, why?

Please See Link Here:

Page 11 - Peak Dust Events
               March, April, July, Aug.
               High Wind Speeds
               Picture shows visible dust clouds.

Page 38 - Dust suppression activities
                For Source Area.

Page 39 -  Until CleanUp Occurs
               Avoid dust clouds during windy days ???

Page 58 - Phytostabilization Potential of the
               Iron King Mine Tailings -Raina Maier

Page 59 - Characterization of Wind Blown Dust -Eric Betterton

Yesterday's winds were a serious pain in the butt. Nothing worse than trying to explain to a 3 1/2 year old boy why he can't go outside and play when the sun is shinning, and the tempurature is great. He cried as his mommy told him no, stay inside. This is our life.

Pursuant to my emails sent to Ms. Butler, EPA on 5/20 and telephone communication 5/24,
Here are 3 answers, sent 5/25 but most of the questions have not been answered, as yet.

Perhaps you can monitor http://www.dhironkingsmelter.info/forum.html  and add some corrections comments and/or clarifications ?

I read the comments and am researching the science on lead exposure and effects on chickens/eggs. Chickens are very sensitive to bacteria/mold and other pesticides found in feed so it is important to find out what the chickens are eating. I intend to send an email to the person who posted the comment after I have conducted some research. EPA staff do not post information on people's personal blogs. Instead, we try to make sure the community has access to accurate information through our own means (e.g. EPA factsheets, websites, the library, and the town newsletter). Community members are also always welcome to contact me if they have questions or concerns about the site or about other environmental topics. If I cannot answer specific questions, I will refer them to experts within the organization who can.

If  http://www.dhironkingsmelter.info/forum.html  is not the official site, what official URL can the affected residents use to communicate among each other and for you to directly participate ?

2. My interest is in influencing the community and EPA decision makers to Pilot a BioFuels Crop Planting Project for the multiple of advantages of EPA friendly & Green Job Production.
 
Something I forgot to mention over the phone: You might want to talk to the property owners of the mine and smelter to see if they are interested in pursuing your BioFuel Crop Planting Project. The property owners have thus far not expressed an interest in such a project.

3. Many questions related to affected homes and residents about money & liability of ‘non-disclosure’, home value, equity, appraisal , individual property/home remediation,  sale of property to EPA or others, etc.
 
 Okay, I will try to address these questions in a separate email.
--------------------------------------------------------------------
Here is the email of inquiry in its entirety….

Hello Leah Butler,

Thank you for responding.

I am sure you can understand the urgency of residents
who stand upon their properties, today and many, many
yesterdays to watch dust clouds plume over their homes,
gardens, water sources and children.

I have encountered no disrespect, but anxious and fearful
and, even, angry residents finding themselves more and
more desperate as the extent of the damage unfolds.

They take their children for toxic blood tests.....................today.
They drink from the water sources....................................today.
They are planting their gardens..........................................today.
They are calculating the equity loss to their homes..............today.

So, please, forgive this inquiry being focused upon today's activities,
but as you can see, the questions listed below are taken directly from
resident interviews, some of which have been left in original quotes.


Hello Jeffrey,

I am the EPA Remedial Project Manager for the Iron King Mine - Humboldt Smelter Superfund Site and I am happy to answer your questions about the site. Rusty Harris-Bishop, the EPA Green Remediation and Communication Coordinator, forwarded me the email you sent him on 5/17/10 (copied below). Please find my responses to your questions in blue below.

May I ask if your umbrella authority extends to from Iron King, to the 3 other 'feeder' mines,
i.e. The DeSoto, McCabe and Blue Bell ?
Can these properties be 'folded in' to any part of this process,
including BioFuel Crop production acreage ?


Question 1.
May I ask what actual 'Dust suppression activities' the SuperFund is doing today to proactively protect the well being of people living around the Iron King Mine that can watch dust clouds emanate from this toxic mine site on a daily basis ?

Answer 1.
EPA is working with the property owner of the smelter property to place a soil sealant over the ash pile, which is a source of much of the dust at the site.

How can the community affected be involved in this process of cooperation, today ?

We are currently in the process of selecting a soil sealant product and are planning to have it applied to the site over the next month or so.

How can the community affected be involved in this process of selection, today ?

This sealant is an interim measure to reduce dust and it will be in place until a final remedy is selected for the ash pile as part of the Superfund cleanup process.
 
How can the community affected accelerate this process of remedy application, today ?


The property owner of the mine site is applying wood chips on a portion of the tailings pile that generates the most dust.

Inspections conducted by the affected residents report no on-site wood chip activity or accumulation.

Where exactly on the map, please ?

The property owner also using a water truck to wet the tailings on windy days to keep the dust down.

Photographs are taken by the affected residents on a daily basis and no water truck activity has been
witnessed nor photograph.

How does the property owner 'verify' these efforts to the EPA             ?
Photographs     ?
Receipts        ?
Orally          ?
In written FORM ?

Additionally, the University of Arizona is implementing a phytostabilization field trial on a portion of the tailings. They recently applied compost to the site and planted native seeds.

Is there a preliminary report regarding these efforts of plantings ?

Who may be in charge of anecdotal interview acquisition and archiving
taken from the affected residents ?

     Here is a quote from one affected resident:
     As far as growing things on the smelter or the mine..good luck!!
     I have tried growing a garden for 3 years, and everything gets big,
     and just when you start to think you are going to get something, it all dies.

     I was even hauling fresh water.

    My trees have all started dying.
   We pulled 7 out of the ground a month ago.
   They all get about the same height, then just die.
    The university of Arizona out of Tucson is going to do a
    gardening study of the area....


Question 2.
What has actually been done related to 'dust suppression activities' since Iron King has been designated a Super-Fund site since 2008 ?
If none, why?

Answer 2.
One of the first tasks EPA implemented during the Remedial Investigation/Feasibility Study was the air quality monitoring program. We established 10 air monitoring stations across the site and conducted 11 months of air sampling, that included measurements of total dust particles (TSP), amount of small dust particles (PM-10), and the concentrations of metals in the dust. This air sampling program provided the necessary quantitative information on the sources and nature of the dust that will enable EPA to take cleanup actions.
 
This sounds like a GREAT study, but, unfortunately, was never mentioned
in all the interviews I have conducted, hence, leading me to believe that this
great study is unknown to the affected residents who should know about it, no ?

What is your procedure for notifying the affected community, individually ?


While the air samplers did detect some metals in ambient air above the EPA's residential screening levels (which are designed to be protective of people over a lifetime), the maximum levels detected over the course of 11 months were from 10 to 1,000 times lower than levels developed for prevention against short-term or acute health effects.

So, The conclusion can be paraphrased:  "No risk to residents' ?

Nevertheless, we are working with property owners to implement dust suppression measures in the short-term to reduce dust from the source areas until a permanent cleanup occurs. See response to question 1.

Question 3.
Since it is impossible for residents to Avoid dust clouds: How can the citizens around the Iron King Dust Clouds accelerate the Super-Fund's 'Dust Suppression Activities'  into a BioFuels, green job producing, reclamation project ?

Answer 3.
Community members are welcome to contact me with their questions or concerns about the dust control methods that are being implemented at the site and the additional methods that are being evaluated (application of a soil sealant).

Already, Community members have arranged themselves into a very few 'dedicated' people
doing an awful lot of work (uncompensated) for most of the affected residents, in part, organized
around The Humboldt City Environmental Issues Advisory Committee of the town council.
Please see:
http://www.dhironkingsmelter.info/

The next meeting is the last Thursday of the month, May 27th. at 1:30p.
Who will be representing the EPA at this time ?
Who, of the persons listed in the .PDF document (see CC's), can attend this meeting ?
Can EPA assist in sending out individual mail notices ?
Can you be available for a telephone call during the meeting ?


Community members are also welcome to provide suggestions for alternative methods of dust control, which the EPA and the property owners will consider, as appropriate.
 
It is my understanding that The community of affected residents would like to:
1. Door-to-Door questionnaires, hand delivered by
    volunteers to each home and acquisition of
    affected residents documents related to health
    issues, real estate issues and other remediation
    documents.
    a. Residents may request an epidemiological
        study, based, in part upon the residents
        own documentation.
2. Print a NewsLetter to the respondents of the
    questionaire and other interested and/or affected parties.
    a. Humboldt does not have door-to-door mail delivery.
        A convenient Post Office has every P.O. Box for
        each citizen.
3. Electronify the communications among the Experts
    and to the community via web sites that would include
    video uploading, message boards and List-Serve
     capabilities.
4.  Install an outdoor high-definition video camera on a
     vantage point overlooking the mine from the City Hall
     1 city block from the mine, with a 'wind-set-off'
     capability so that the camera only records at certain
     pre-determined gust levels.
5. Volunteers, electronic equipment, postage, web programming
     are time consuming and expensive.
     a. How can the affected residents be compensated and/or
         apply for compensation for the administration of this
         time, labor equipment and postage ?
6. Affected residents would like to engage in a 'think outside the box'
    approach to remediation with input from the experts now aligned
    by this project.
    a. An in-depth analysis of 'land reclamation' that would supply
        sustainable, green jobs directly to the affected community
        by planting a BioFuels Crop.
    b. Volunteers from the affected community would be engaged
         and paid for ground preparation, plant acquisition, planting,
         maintenance - watering.
         1. How can the affected community organize to accomplish
             this BioFuels Pilot Program.
7. Affected residents would like to speak with Real Estate Professionals
     and uniquely trained Appraisers and Mortgage Companies and/or banks
    who have the unique knowledge of this specific impact to a residence
    affected by a 'super-fund' investigation ?
    a.   Affected residents would like to understand the mechanisms to
          sell the home to the govt. under the Super Fund appropriations.
8. Affected residents would like to get their blood tested and the
    results uploaded for an epidemiological database.
9.  Are there funds available for the affected residents to engage
     private legal counsel for representation in this matter ?

Here are just two excerpts from affected residents to illustrate #7 & #8.

#7.
     As far as the real estate, I sure pray nobody gets (pardon my language) as screwed as we did!
    We bought in 2007 and was not told anything about the mine or smelter.
    I didn't know anything until 2009 when I got a letter form EPA wanting to test my well.
    We then found out that our water tanks are the old boiler tanks from the mine,
    and the bricks that both of my back patios are made of, that make up my fire place backing,
   and line my garden are the same bricks from the smelter.
   We bought our house for $176,00.00 cash, it was listed at $229,00.00
   So we thought we got a great deal.
   We put $17,000 into a new fence around the whole 2.1 acres,
    and a new roof for $18,000.00,
    and last month our house appraised at $106,00.00.

#8
     Today I received my daughters urine tests back, and her arsenic levels are very high,
     her lead levels are okay, and beryllium also showed up, not at high levels, but it's there.
    And it is my understanding that Beryllium is very rare, and shouldn't be in her system
    at all unless there is an obvious contamination source (the smelter and mine).
 


Question 4.
How can local residents begin ASAP in certain Farming practices activity to plant 'Dust Suppression plants' with or without EPA approval to proactively engage in ameliorating the affected unhealthy residences ?

Answer 4.
Residents are empowered to take any precautionary activities they feel are necessary on their properties. EPA will offer to clean up yards that are  impacted by the site at no cost the resident as part of the Superfund process.

How does the affected resident apply for these precautionary activity reimbursements ?

Is a resident allowed to, what is commonly called 'weatherize' their homes,
i.e. doors, windows, caulking, stripping, vents, filters,
to reduce wind and dust protrusion ?
1. Once dust enters the home, over time, the residue may be significantly
     higher than ground or air.
     a. Can residents have their home interiors tested as a precautionary activity ?
     b. Can residents have high-efficiency Reverse Osmosis installed as a precautionary activity ?

EPA has provided educational materials to residents' whose yards EPA sampled on ways residents can protect their health until the cleanup occurs.  

Unfortunately, this is not true.
The two contractors I interviewed had no such 'educational material' to distribute :-(
Who were the two contractor companies ?
How does the SuperFund go about letting such bids ?


Question 5.
What Carbon Credits are taken into consideration regarding Toxic Land Reclamation using BioFuel Crops ? If none, why ?

Answer 5.
EPA evaluates the sustainability of our cleanup actions as part of the feasibility study. This evaluation includes consideration of ways to reduce the carbon footprint of our cleanup actions. I've attached some information you might find useful.

Never before has a BioFuel Crop production been implemented as a Super-Fund pilot project for:
a.  toxic mine land reclamation 
b. the generation of local green, sustainable jobs
c. Rural farm land and economic development
d. Every gallon of BioDiesel reduces the CO2
    footprint 75% as compared to burning a gallon
    of petroleum diesel and is used locally by schools,
    towns and residents under the 'Clean Cities' Program.

Thanks, Jeffery

1) Affected residents would like to speak with Real Estate Professionals and uniquely trained Appraisers and Mortgage Companies and/or banks who have the unique knowledge of this specific impact to a residence affected by a 'super-fund' investigation?

EPA suggests that residents contact the Yavapai County Assessor's Office at (928) 442-5252 for information on property values. You may consult a professional in the community for the most up-to-date information. Real estate agents, banks and other lenders, appraisers, and public and private assessors should be able to provide information. Local government agencies—such as your taxing authority or planning commission—may also be able to give you information on property values.

2) Affected residents would like to understand the mechanisms to sell the home to the govt. under the Super Fund appropriations.
EPA is only authorized to acquire property under Superfund (also known as the Comprehensive Environmental Response, Compensation, and Liability Act, or CERCLA) if it is necessary for the remedial action.  At this point in time, EPA does not anticipate that property acquisition will be part of the remedial action for this Site.

3) Are there funds available for the affected residents to engage private legal counsel for representation in this matter?
CERCLA does not provide funds for residents living near Superfund Sites to procure legal counsel. However, EPA offers a Technical Assistance Grant (TAG) to help the community participate in the cleanup process. An initial grant (up to $50,000) is available to contract with an independent technical advisor to help the community understand technical information.

Included below are answers to commonly asked questions about the effects of Superfund sites on people’s property.

My property values have gone down as a result of being on or near a Superfund site. Can the EPA pay me for the property value I have lost?
The EPA is aware of the potential adverse effects on property value that may result when a Superfund site exists near a community. However, Superfund law does not authorize the EPA to compensate individual homeowners for losses of property value or other potential damages associated with designating an area as a Superfund site. EPA will conduct or oversee the cleanup of the Superfund site, and property values often rebound following completion of these cleanup activities.

What can I do if my property value goes down because of a Superfund site?
You may want to consult with local government officials about the possibility of property tax abatements or adjustments, based on impacts on property values from pollution concerns; however, this is beyond the authority of the federal government. Based on past cleanups, EPA believes that a Superfund cleanup has an overall beneficial impact on the community, including rebounding property values.

Do property values rebound? How long will it take?
Contaminated sites may affect nearby residential property values. Property values typically rebound following completion of cleanup activities. Property values are most appropriately discussed with local authorities who are knowledgeable about the local economy and other local conditions that may influence property values.

Will I be able to refinance my loan due to the devaluation of my property?
This is a question that is best answered by your lending institution.

Will there be an immediate appraisal of my property to adjust my tax status?
Local tax authorities can best answer this question because they are responsible for tax appraisal activities in your community. It is beyond the EPA’s authority to appraise property or adjust tax status, and the EPA does not request tax authorities to reassess properties. Property owners may want to consult with local government officials about the possibility of property tax abatements or adjustments, based on impacts on property values from pollution concerns; however, this is beyond the authority of the federal government.

What information can the EPA provide to potential buyers of property located near a state Superfund site?
The EPA makes a wide variety of information available to the public, including potential buyers. Such information includes background materials on the Superfund program, its activities and responsibilities, as well as opportunities for public participation. Site-specific information can be accessed from the local public information repository (at the Dewey-Humboldt Library) and on EPA's web site: : http://www.epa.gov/region09/ironkingmine

Can a homeowner perform a cleanup to help ensure the sale of their property?
According to EPA policy, residential home-owners will not be required to perform or pay for cleanup actions at Superfund sites, where their own actions have not led to a release or threatened release of hazardous substances requiring a cleanup on their property. However, a homeowner can perform a cleanup action on their own, but the owner must follow the requirements set forth by EPA. Additionally, if a homeowner is not otherwise considered liable for the contamination and takes responsibility for a cleanup, this action may make the owner liable for any future pollution problems (release or threat of release of contaminants) as a result of the cleanup.

6:15 in the evening, and the wind has finally died down enough that I feel a bit more comfortable letting my 3 1/2 year old play outside. Tomorrow's forecast calls for less wind...maybe my boy will get to play outside like any other normal boy would want to.

<snip>    May I ask you to let me know specifically how a BioFuels Crop trial can be  included in the Iron King project ?    - This project is completely community driven, so I will be working with  the vegetables and fruits (like tomatoes) the the local gardener's grow  and eat. If a local gardener is growing a biofuel crop to consume, then of  course it will be part of Gardenroots.    

Jatropha oil is a consumable extraction.

The most frequently asked question is:
"Will the toxic metals taken up by the Jatropha plant be carried in the plant oil
  and then released into the atmosphere when burned as a BioDiesel".

The answer is no.  Heavy metals are 'stored' in 'nodules' in the root system,
and therefore not in the oil or the resulting biodiesel nor, ultimately, in the atmosphere.

I have spoken to Russell Teall, a true world-class expert on BioFuel plants and is
uniquely qualified for this particular location because of his Jatropha plants grown in Santa Barbara
have gone through several freezes, which killed 40% of the crop, which means that
60% are a little more frost tolerant for selection at Iron King, which is in a 'light freeze'
zone. 

There are other BioFuels plants, such as Castor and Karanj, The African Oil Palm (Elaeis Guineensis)
will produce about twice as much oil as Jatropha and The Paradise Tree (Simarouba glauca DC)
produces about 10 times more oil than Jatropha.

Mr. Teall knows Olof  Hansen, of the EPA, Region 9 Office, who can vouch for Mr. Teall's
unique expertise. I have asked him to submit a proposal for this small trial.
(see attached)

I have tried to supply the information I have about the proposed remediation sites,
locations, condition, soils, weather, but may I ask you to supply better answers ?

It seems like your charter would be a perfect match for such a plant  trial, yes ?    -Maybe, if a local gardener is growing a biofuel crop to consume. Again,  this project was, and is currently being designed based on community  feedback. Back in 2008, the community members voiced their concern  regarding whether their garden is contaminated with heavy metals, and if  the vegetable matter is uptaking the metals.  That is the question we will  answer together.    

In 2010 the community is interested in a BioFuels Plant Trial related to several more factors
than a tomato or a grass can supply and that has only been made more urgent in the last 45 days.
Perhaps 'green jobs' has taken on a more urgent interest to the community since 2008.
That is the question we will answer together :o-)

1. Creating Local, Sustainable Green Jobs through
    production, processing & distribution.
2. Environmental protection
    a. Burns 75% less CO2
3. National recognition of a unique trial.
    a. Propagation of trial to expansion locally
        1. Immediate expansion into McCabe BlueBell & DeSoto,
           feeder mines to the Iron King Smelter.
    b. Propagation to other Land Reclamation projects and unused farmland.
        1. Local recognition and instruction among local farmers
            and/or fallow and/or toxic land to grow a Sustainable,
            Renewable BioFuels Crop producing Green Jobs.
4. Attracting other legislated government money through State and Federal:
    The Recovery Act: Alternative Energy, Section II (49 billion dollars).
    DOE - Clean Cities Program
    EPA - Green initiative grants
    DOL- Green Job Incentive money
    USDA - Farm Bureau
                  Rural Economic Development
    Department of Mines & Mineral Resources
5. A long-term monetary annuity from our local investment
      that can be sustained for the next generation(s).
6. Our small contribution to solving the energy problem.

Given the geographical scope of your charter, the other 3 feeder mines,  DeSoto, McCabe, Blue Bell, fall well within your chartered territory.  How  can these 3 potentially contaminated sites, also be put on your 'garden  spots' list ?    - Wow, great question. I need to look up and read about the DeSoto,  McCabe, Blue Bell feeder mines.

What is the total acreage of Iron King site ?
What is the total acreage of Blue Bell site ?
What is the total acreage of DeSoto site ?
What is the total acreage of McCabe site ?

 I welcome all gardeners from the  Dewey-Humboldt, Prescott area and beyond in reasonable distance. I quickly  looked up the DeSoto mine, and that looks to be about 8 miles away from  Humboldt. You bring up an interesting question that I will definitely look  into.    

Thank you.
These feeder mines may expand the initial trial or follow the Iron King trial,
but they must be included.  They were 'feeder mines', so they should have
no difference in toxicity than Iron King Mine. If they are not addressed now,
the local communities cannot be engaged in such a new scheme. And
without the additional acreage of the other mines taken into consideration,
the economy-of-scale may be too small with just Iron King.

Thank you for your interest, you are motivated, and I greatly appreciate  you energy and support.