Letter to the Editor

To whom it may concern,

It appears that the rare earth element demonstration processing plant envisioned to be placed in Upton, WY is well funded with a commitment from the Department of Energy (DOE) of $21.9 million and $25 million from shares. The rush to opening up a new processing plant is of course motivated by the need for rare earth elements to sustain the green revolution in the form of wind mills, solar panels and batteries (it takes about a ton of rare earths to make one wind charger).

But, in the process of retooling for that necessity the history of mining and processing rare earths should be carefully reviewed; i.e., past failures should be carefully considered before mining and processing companies be allowed to proceed.

Due to the laxity of enforcement imposed by the Mining Act of 1872, little has been observed in former mining operations at Mountain Pass, CA, which ultimately caused its 2002 closure because of the environmental disaster it had created. The lack of environmental and worker safety concerns in China have been equally disastrous.

Given the ultimate order of magnitude of operations at the Upton site it should behoove the EPA, NRC, OSHA, DOE and even the Dept. of Health to scrutinize every aspect of the proposed operation in order to prevent what had ultimately happened at Mountain Pass and what is happening at the Chinese operations as well.

The sheer enormity of the volumes of nitric acid and to a lesser extent hydrochloric acid employed in the rare earth (15 lanthanum element series + 2 more) separation phase demands very careful oversight. Because of proprietary rights that corporations enjoy they are afforded the right to conceal the details of that process from the public, which, as a consequence, is not being apprised of the hazardous chemicals used in the processing of these ores.

The regulators, on the other hand, should be fully informed and have the power to control the situation, but unfortunately the Mining Act of 1872 imposes many restrictions that limit such regulation. And another concern is what is called regulatory capture by the industry being regulated.

It is clear that politics and economics are driving factors in this rush to produce rare earth elements. At present China is processing about 85% of all rare earth ores that is arriving from different parts of the world.

And in fact, the ore from the Mountain Pass had been shipped to China for processing. The United States now finds it to be in its national interest to become independent of China’s hegemony on this issue by establishing its own mining and processing facilities.

But, at the same time, it is inviting the same problems that its predecessors have failed to deal with adequately. Ignorance of that history will only invite its repetition.

Focusing briefly on the sources of rare earth ores for the plant to be located in Upton, it is obvious that the location of the plant will be next to a railroad line on which ore from many places can be shipped to this plant. What is also envisioned is a mine located only 50 miles from Upton just north of Sundance, which will be an open pit mine about 400 feet deep encompassing up to 9000 acres or 14 square miles (3.5 miles X 4 miles).

It is anticipated that some 15 million tons of ore will be mined here over a 40-year period (the life expectancy of the mine). And it also happens to possess the richest source of rare earths in the U.S.

Like all such pits though, there would be acid mine drainage, and in this case water contaminated with radioactive elements; such as thorium and, to a lesser extent, uranium, along with a couple dozen of their daughter radioactive decay radionuclides with half-lives of milliseconds, minutes, hours, days, years and thousands of years.

Their emissions are in the form of gamma rays (very penetrating), alpha (helium nucleus) and beta (electrons) particles, which are capable of cellular damage. These radioactive nuclides conceivably have biological impacts when they contaminate the water that seeps into fissures/fractures in the rock exposed in the process of mining leading to aquifers people use for drinking, supplying their livestock and for irrigation purposes.

Similarly, in the processing phase of the 100s of tons of ore at the Upton plant, the enormous quantities of nitric acid hydrochloric acid replete with these radioactive elements has to be contained and stored FOREVER. The piles of tailings would be another source of contamination as these toxic elements and others would leech into sources of water.

Recently, the Mountain Pass mine in CA has been reopened and a processing plant constructed at the mine site, which is not as yet operational. It would behoove all the regulatory agencies now in charge to subject this new operation in CA to a more rigorous regulatory framework and in the process deal with the contamination that is already there.

This should necessarily precede the developments envisioned at the mine north of Sundance and the construction of a new processing plant at Upton to make sure that both the mining and processing of rare earths can be done safely.

What is at stake here beyond what has already been described? As a resident of Hulett, WY, I and many others benefit from the Belle Fourche River into which the Beaver Creek watershed empties into.

The Upton plant would be located in that watershed and the tons of chemicals used daily in the processing of rare earth ores have a great potential for irreparable contamination as it has invariably occurred at other similar processing plants. Cancers of various kinds would be the consequence along with an expendable population and sacrifice zone in the service of a careless industry governed by the 1872 Mining Act.

This consequence is something that should be avoided at all cost.

Who is Rodney Knudson: I am a former science teacher having taught chemistry, physics, biology, geology (earth science), mathematics, and German. I also ran the joint school (K-12) library and public library in Hulett for 26 years before retirement in 2001. My Master’s paper was written in 1972 as a graduation requirement from the University of Wyoming on the subject of environmental education at the high school level.

I had previously graduated with a BA in zoology/chemistry and a BS in botany and teacher training from the U of Minnesota (1964 & 1966). The sources of information for this paper were mostly derived from the websites of Rare Earth Resources and the Clean Water Alliance located in Rapid City, South Dakota.

Rodney Knudson