Editorial: Jim Voss’s Letter

On November 9th. 2015, the Detroit Free Press reported on the findings of the Center for Public Integrity, a nonprofit organization that promotes government transparency and ethics.  State governments were ranked using criteria like: accessibility, responsiveness, and accountability.  This national study concluded that Michigan ranked last in laws on ethics and transparency.

Those of you that worked on the committee that developed part 632 know the effect that businesses can
have on interpreting and developing the rules for laws in the State of Michigan.   The result is a document that, in some opinions, makes Michigan a “Most Mining Friendly” state.

The process for developing the rules for part 632 did involve citizen accessibility through input, but did it demonstrate governmental responsiveness and accountability?  Was there a level playing field for all participants?  Were ethics involved?

At the January meeting in  Stephenson, the DEQ took questions concerning the application process for Aquila Resources’ application regarding their Back Forty project.  Joe Maki, the DEQ spokesperson that presided at the meeting, said the process was going to be as transparent as possible.  There would be public meetings and opportunities for public input and suggestions.  We were assured that questions would be considered, each suggestion evaluated and, when appropriate, acted on.  A first small step indicating that Joe Maki was going to live up to his word was, after many requests, the granting of a two week  extension of the deadline for submitting questions to the DEQ.

Listening to concerns, considering requests and acting on behalf of the people are all things any governmental unit should be doing.  Especially a department that is ultimately responsible to the people of the State of Michigan, and not to the people that appointed them.

If the DEQ’s loyalty is to their bosses and not to the people, disasters can occur.  A recent example where this happened is the Flint water crisis, which is under investigation in Michigan today.  It appears that appointed city officials and appointed DEQ members were more interested in saving money and saving face than serving the constituents they were charged to protect.

A local doctor, an independent scientist, and local residents were ignored and discounted while the citizens of Flint continued to drink tainted water.  Ironically, bottled water was being supplied (as an alternative) to state employees working in government buildings while local citizens were being assured their drinking water was safe to drink.

Something went wrong there.  Somebody (more than one somebody) lost sight of the reason they were appointed to their position.  That reason, in a nutshell, should be to preserve and protect the health and well-being of their constituents.  The health and well-being of the people they serve.

They have no obligation  higher than that.  Not to business, not to lobbyists, not to the “bottom line”, and not to their bosses.  Their obligation is not to circle the wagons and protect the well-being of the puppet-masters that appointed them.  Their obligation is to us!

As this permitting process for Aquila Resources Back Forty Project continues to unfold, as we look at the time lines, as we worry about governmental expertise, as we fret over the influence of cronyism and money and lobbyists, let’s constantly remind the people that are reviewing these documents that their loyalty is to us,  that their loyalty is to the health and well-being of future generations, that their loyalty is to this great place we call the Upper Peninsula of Michigan.

Thank you.
Jim Voss
Lake Township Resident

To Cyanide, or Not to Cyanide – That is the question.

Quoting from a 1999 paper The Management of Cyanide in Gold Extraction by Logsdon, Hagelstein, and Mudder and released by the International Council on Metals and the Environment, “Cyanide is a general term for a group of chemicals containing carbon and nitrogen.  Cyanide compounds include both naturally occurring and human-made (anthropogenic) chemicals….”    Some naturally occurring sources of cyanide compounds are found in apricots, bean sprouts, cashews, cherries, peanuts, potatoes, lima beans, sorghum, and many, many more common items we see, often touch, and occasionally eat, including common table salt.  This brief report will focus not on the natural sources of cyanide but on human-made cyanide and its uses, particularly in mining and the extraction of precious metals.

In their 1999 paper, Logsdon, et.al., reported the 1996 annual production of HCN (hydrogen cyanide) gas was approximately 1.4 million tonnes, with the bulk of production coming from 3 companies, one of which is Dupont in the U.S.   A tonne is 1000 kilograms or approximately 2204.6 pounds, which means the 1996 production was around 3,086,440,000 pounds of HCN.  Of this production, it is estimated somewhere between 13% to 20% is used to produce sodium cyanide (NaCN), usually shipped to users in the form of solid briquettes in sealed containers, although sometimes it is shipped in liquid form in “specially designed tanker trucks.” (p.11, Logsdon, et.al.)   Included in any shipment of NaCN is a Material Safety Data Sheet listing the chemistry, toxicity, accident instructions, emergency contact information, and other information deemed appropriate by the manufacturer.  In addition to mining companies using NaCN in the extraction of precious metals, numerous other industrial uses for cyanide compounds abound:  nylon and acrylic plastic production, electroplating, steel hardening, synthetic rubber  production, anti-caking additives (such as in road salt), rodent control (with HCN), and at least one anti-cancer drug.

Even though twenty-first century humanity evidently needs products produced by using cyanide compounds, the word itself causes fear. This is because cyanide can be lethal for humans – and  deer, and fish and ….   In humans, ingestion, absorption, or inhalation can be deadly.   Logsdon, et.al., list the 1998 “Threshold Limit Values for Chemical Substances and Physical Agents” (published by the American Conference of Governmental Industrial Hygienists).  The lethal inhalation dose for humans is 250 parts per million of HCN gas in air.   The lethal skin absorption and mouth ingestion values are somewhat dependent on body weight.

Our concern as residents of Michigan and Wisconsin is the use of cyanide by Aquila in its Back 40 Project along the Menominee River.

In its November 12, 2015, application[2] (page 5) Aquila states:  “During full production combined annual production of gold and silver at the oxide plant will be approximately 1.4 million ounce ( oz. ).  The precious metals are recovered from the ore through use of a cyanide leach process to produce a precious metal bearing solution (pregnant liquor).  The cyanide leach process occurs within contained vessels located inside the mill buildings.  Further processing occurs to recover gold and silver from the pregnant liquor using a zinc dust precipitation process to produce a dore product for refining off-site.”

How much NaCN will be used? Table 5-6 in Aquila’s application lists an estimate of 166 tonnes per year for the oxide plant, for the 7 years ( from page 8 of the application) the mine is expected to be in production.  That’s slightly under 366,000 pounds of NaCN per year that will have to be brought to the mine site, unloaded, stored, used, and then eventually “destroyed” – for each of the years the mine is in operation.

In Section 8 of the Logsdon, et.al. paper, evaluating and managing the risks of cyanide include:  (1) Hazard Indentification (What physical, health, and ecological areas could be adversely affected by cyanide exposure); (2 ) Dose – Response (How much?  What will happen now?); (3) Exposure Assessment (How did this happen?); and (4) Risk Characterization (How can we prevent this from happening again?).  According to the paper Risk Assessment must include not only possible impacts on the general population and the environment, but especially for the workers who are “most likely to be exposed to the hazard.”  Transporting, receiving, unloading, handling, storing, and using NaCN are each possible exposure points.   A quick survey of the table of contents of the application and an admittedly quick reading of the 45 pages of Volume 1 of the application did not reveal any mention of worker training.  The only mention is a short paragraph on page 44 stating:  “Possible HSE (health, safety, environment) risks to on-site workers will be addressed by Aquila through a health and safety plan which is (sic.) complies with Occupational Safety and Health Administration (OSHA) and Mine Safety and Health Administration (MSHA) requirements.” Also, there is a bullet point on page 20 stating that MSHA safety standards during mine operations will be met.

Let us all hope that the systems engineering is accurate, that the systems function correctly, and that all stated requirements and standards for safety are followed and will indeed protect the workers, the environment, and all of us from contamination and worse.

Mark J. Lagsdon, MSc; Karen Halelstein, PhD, CIH; Terry I. Mudder, PhD, The Management of Cyanide in Gold Extraction, International Council on Metals and the Environment, 294 Albert Street, Suite 506, Ottawa, Ontario, Canada  K1P 6E6., 1999.  It should be noted that a search for ICME will be redirected to the International Council on Mining and Metals (ICMM) and that the web site for ICME will display the word “Obsolete.”

DEQ-OOGM D 2015 22054 2015-11-12 Aquila Resources Mining Permit Application – Volume I.pdf


Mining Its Own Business

Ron in RiverRon Henriksen (standing in the river), of the citizens group The Front 40, shares with River Alliance members during a 2008 paddling trip his concerns about an open-pit metallic mine with mine within sight of the Menominee River, in Michigan but just across the river from Wisconsin.

Just when the collective sigh of relief from all across the state from people opposed to the proposed Penokee Hills iron mine dissipated, there’s reason to take another deep breath, and gulp, about mining.

There’s no relief in knowing a metallic (copper, zinc, gold) mine is proposed for Michigan, not Wisconsin, because this open-pit mine would sit astride the Menominee River, a superb bass fishery and recreational gem that provides the border between Wisconsin and Michigan’s Upper Peninsula. Whatever happens to the mine in Michigan will wash downstream; it’s our river, and our Lake Michigan too.

With a metallic mine (called the “Back 40” project by the developer, Aquila Resources, of Canada) come the usual concerns and fears:  mine tailings containing sulfides that could leach into the river, cyanide being used to separate the minerals from the slag, and a public review process already exposed for its flaws.


We have some unique concerns about this mining project.  The River Alliance has been a partner in a project spanning 12 years and involving a public and private investment nearly $8 million to build up the depleted sturgeon population of Lake Michigan.  Young sturgeon need access to good habitat in the Menominee River to survive to adulthood, so devices to move adult sturgeon around two hydroelectric dams at Marinette have been built to get breeding sturgeon to that good habitat in the river.

As River Alliance executive director Denny Caneff told the Milwaukee Journal Sentinel, one stupid mistake by that mining operation could wipe out all the sturgeon, young and old, whose survival this “fish passage” project is intended to improve.  And it wouldn’t be just sturgeon harmed, of course:  all life, and human use of the river, could be fouled for years.

We won’t be turning our sigh of relief about the Penokee iron mine into a sigh of resignation about the Back 40 project.  We intend to communicate our concerns about this mine and its possible impacts to the Michigan Dept. of Environmental Quality, which is reviewing 20,000+ pages of documentation, and work with our friends in Michigan to make sure this mine gets serious scrutiny.

Here’s the story in the Milwaukee Journal Sentinel: