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Response to Recent Criticism and
Hazardous Arsenic Soil Data Information 
 

Do you believe the slag dust from Re-Processing Operations in the center of Cottonwood has caused harm to your heath, your business or the blasting has damaged your home?  If so, click HERE to learn how to write a statement of impact that will help us involve the Attorney General in this matter. 

Located at the center of Cottonwood, lies approximately 3 million tons of copper mining waste called “slag.”  In 2008, a company called Mineral Research, expressed interest in reprocessing the slag by crushing it into a fine particulate dust and selling it.

 

Numerous City Council Meetings and planning and Zoning meetings took place where the proposed Slag Crushing Operation was discussed.  The main citizen concerns were over toxicity of the slag when crushed into a dust and breathed in. 

 

Minerals Research owner and authorized representative responded to citizen concerns at these meetings by stating:

-Their company had been conducting a similar operation in Ajo for the past 15 years.

-They have had no complaints from property owners because they collect and sell the dust, so the operation does NOT create a dust issue for neighbors.”     

-the safety was proven and copper slag dust poses no health risks. 

-They had never received a citation from the Department of Environmental Quality in their 15 years of operating in Ajo. 

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After my child began experiencing rashes and asthma after playing at the Cottonwood Childrens park, I began a citizens investigation into Minerals Research and the toxicity of slag particulate I noticed at the playground. 

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A records request from Ajo revealed that at the time Minerals research claimed on record that they had never received a dust complaint in Ajo, that 14 complaints and a town meeting relating to toxic slag dust blanketing the town were submitted to the Department of Environmental Quality and forwarded to Minerals research.  So Council was lied to when Minerals Research said on record that no complaints had ever been filed against them.

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A records request from the Pima Department of Environmental Quality reveals approximately 9 notices of environmental violations, so much so that the PDEQ actually sued Minerals Research several times for dust emissions in which they were required to pay large fines and were distinguished as a “high priority violator”   So the Commission was lied to, again, on record, AT the meeting where Minerals Reserarch's Conditional Use Permit was granted by the City of Cottonwood, when Minerals Research stated they had never received a single violation from PDEQ. 

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Multiple Studies in the national library of medicine, linked below, prove that copper slag dust can permanently damage lungs after a single inhalation and cause lung tumors and cancers.

Minerals research own Materials Data Safety Sheet states that a health hazard may occur through inhalation of dust, that exposure levels of harmful chemicals like arsenic, barium, lead, mercury, and more could exceed regulations.  It recommends anyone using the slag particulate use respirator protection.  It notes that arsenic is found in the slag particulate in levels that exceed allowable limits.  There is a warning that “This product contains chemicals known in the State of California to cause cancer and birth defects or other reproductive harm.”  

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Slag dust is black and strongly magnetic while our native soil is light colored clay and not magnetic.  There is no other source for strongly magnetic black dust in Cottonwood that has been identified other than the slag processing facilities fugitive slag dust.  

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So far, the Cottonwood City Council, City Management, and Planning and Zoning Commission have:

- Declined to allow open public discussions on the environmental disaster.

-Declined the opportunity to stop the contamination.

-Declined to enforce their own codes, stipulations, and agreements in this matter.

-Declined to require MRI to produce the agreed upon Phase 2 Environmental Testing.

-Declined to provide the public records about the private payments the City is Receiving from MRI (Which is illegal).

-Declined to allow a CUP revocation hearing as required by law.  

  And more...​

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It is interesting to note that the City Council worked out a private agreement where the slag processing plant pays hundreds of thousands of dollars to the City, paid in quarterly installments, for as long as the operation is allowed to continue.  In all, it is estimated the City of Cottonwood will privately receive close to $1,500,000, so long as they allow this operation and its resulting contamination to continue for the next 15-20 years. 

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Many of us feel it is completely unacceptable to put financial gain over the health and safety of our community and especially our children who are at greatest risk of potential lifelong illness.​

Is Copper Slag Dust Toxic??

If you ask those who financially benefit from the slag re-processing, they will tell you with a smile that the slag and its dust is completely non-toxic.  City records are littered with complaints from citizens complaining about the health effects from the slag dust.  Every time, those complaining are reassured there is no significant dust contaminating the town and that the slag dust is totally safe to human health. 

Copper Slag and the resulting dust these operations create is high in Arsenic and Arsenic can and does harm human health. 

​For more information about arsenic and its dangers please visit Arsenic Exposure (aap.org)

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Below are some published scientific studies on Copper Slag for you to view.  

The Science of Slag Dust Toxicity and its harmful effects on human health.
 

The specific heavy metals and toxic substances identified in the copper slag in Cottonwood are:

Arsenic, Barium, Beryllium, Cadmium, Chromium, Cobalt, Copper, Lead, Mercury, Molybdenum, Nickel, Selenium, Silver, Thallium, Vanadium, Zinc, Crystaline Silica, Iron Oxide, Silicates, Alpha-Alumina, Calcium Oxide, Magnesium Oxide, Potassium Oxide.

This information can be found on the MRI Materials Data Safety Sheet found HERE.

This study comes from the National Library of Medicine, please click on the title above to be linked directly to the study to read it yourself.   This is perhaps the most comprehensive study and compilation of information on the toxicity of Copper Slag Dust. 

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"Carcinogens, suspect carcinogens, and other toxic elements were detected in all bulk samples, and area and personal air samples. "

When an intratracheal installation of copper slag dust was given to rats, significantly elevated levels of pulmonary fibrosis was reported.  Pulmonary fibrosis is a lung disease that occurs when lung tissue becomes damaged and scarred. This thickened, stiff tissue makes it more difficult for your lungs to work properly. As pulmonary fibrosis worsens, you become progressively more short of breath. The lung damage caused by pulmonary fibrosis can't be repaired or reversed.

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"Fe (Iron) was measured greater than 240 μg/m3 in all personal air samples (excluding plant manager). It is known that iron oxide exposure is associated with “siderosis”, a type of pneumoconiosis.   Exposure to both iron oxide and silica or silicates is associated with mixed dust pneumoconiosis (MDP) or “siderosilicosis.”"

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 "As (Arsenic) is a known carcinogen and exposure to As is associated with skin, lung, liver, and kidney cancers. In fact, recent evidence suggests that lung cancer is the most common cause of arsenic-related fatality."

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"We observed strong correlations between personal respirable dust levels and respirable silica, as well as moderate correlations between personal total dust levels and the metals As (Arsenic) and Fe (Iron.) These correlations signify the importance of controlling overall dust levels to reduce human exposure to harmful elements that contribute to lung disease, such as As and Fe."   Slag dust, containing these known toxins, are being dispersed into the community day and night, shown by video evidence collected, testimony from people living and working in the area of slag dust fallout, and is being substantiated through scientific testing.  We have children living in the areas that are being exposed constantly 24 hours a day, 7 days a week, 365 days a year.  Evidence has been gathered showing this fine slag dust is covering the inside of homes (where children live), offices, storage units and more in that vicinity. 

 

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This abstract comes to use from Oxford Academic, please click on the title above to be linked directly to the study to read it yourself.  

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Copper slag is commonly used as a substitute for silica sand. These slags have been reported to contain heavy metals.

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Our research aims were to identify exposure-related differences between slag sources, quantify health-related aerosol fractions for comparison with occupational exposure limits and correlate total and inhalable aerosol with metal concentrations. Two commercially available copper slags were used to perform indoor and outdoor abrasive blasting. Personal samples were collected using 37 mm cassettes and a Respicon sampler and analyzed for total, inhalable, thoracic and respirable aerosol and heavy metals. Lead and arsenic concentrations exceeded applicable OELs in 37 and 15 min, respectively. Inhalable and respirable aerosol concentrations exceeded applicable OELs in 15 min. Statistically significant differences between slag sources were found for arsenic, lead, chromium and titanium concentrations in the total, inhalable, thoracic and respirable fractions. Total and inhalable aerosol regressions with selected metals showed r2 values of 0.91–0.98. The results of this study raise questions concerning the efficacy of using copper slag as a substitute abrasive based solely on the premise that it contains <1% free silica.

This study comes from the National Library of Medicine, please click on the title above to be linked directly to the study to read it yourself.  

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In this study, rats were given A SINGLE does of copper slag dust into the lungs and were tracked after for health effects.  The results show that "significant numbers of primary lung tumors, principally adenocarcinomas and adenomas, were seen in the copper slag" rats.  "On the basis of the tumor incidence data, one must conclude that both copper slags tested in this study are carcinogenic to rats."   The reason we test on rats is because we know if its harmful and carcinogenic to them, its harmful and carcinogenic to humans.  

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And remember this is after a single exposure of slag dust to the lungs!

Minerals research own Materials Data Safety Sheet states that:

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- a health hazard may occur through inhalation of dust.

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 - Exposure levels of harmful chemicals like arsenic, barium, lead, mercury, and more could exceed regulations. 

 

- Recommends anyone using the slag particulate use respirator protection. 

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- It notes that arsenic is found in the slag particulate in levels that exceed allowable limits. 

 

There is a warning that “This product contains chemicals known in the State of California to cause cancer and birth defects or other reproductive harm.”  

 

Despite MRI making on the record assertions at the meetings to gain approval for the necessary Conditional Use Permit that the crushed slag dust is completely safe and poses no health risks, their own safety documentations states differently.  Please click the link above to view their safety documentation yourself.   MRI specifically states on their safety data sheet that:  

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"Supplier makes no express or implied warranty that the Material conforms with any applicable safety or environmental statutes, rules, or regulations. Supplier furnishes this information and its Material on the conditions that the person or legal entity purchasing and receiving it makes his, her, or its own determination as to the suitability of the Material for a particular purpose and assumes the risk of the use of the Material, including, but not limited to, the risks that arise from any environmental restrictions or prohibitions that may apply thereto."

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Does this Toxic Copper Slag dust travel off the MRI Facility??

For years, residents and businesses downwind from the MRI Facility have complained about the toxic slag dust infiltrating their homes, businesses, vehicles, and properties.  There is extensive documentation (and growing) on the slag dust infiltration and the negative effects it is having on our community.

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The OCS Child Safety Group Founder, Jennifer Richards visited the area just two times, and captured the video below.  She was only exposed to inhalation of the blowing slag dust for approximately 30 minutes total, but her lungs burned so bad for the three days after that she will not likely be returning to the site, especially considering the study that showed rats got lung tumors after just a single exposure to the lungs of copper slag dust.  If you are a citizen who has videos, pictures or other documentation of slag dust blowing, slag dust accumulation on your business or property, please email them to sedonahotyoga@hotmail.com and we will include them in future videos to inform the public.

Likely Slag dust at the Cottonwood Kids Park in 12th street.
 Our local "dust" is comprised mostly of caliche, is white to blonde in color and is not magnetic.  The slag dust is primarily Iron (with aluminum, arsenic, barium, and other elements) is dark black and is highly magnetic.  The only point source for prolific black magnetic dust identified in Cottonwood is from the slag crushing operation and as a result, Residents can do simple tests at home with a magnet to see if likely slag contamination has occurred in or around their homes and can express their concerns to the Mayor, ADEQ, and Planning and Zoning Commission.  Note: if you know of another source for strongly magnetic black dust in Cottonwood, we would love to hear any other potential sources for this type of dust.

Likely Slag dust at the Rec Center, Library, Community Health Facility Compound. 
 

What can we do now??

What Can We Do Now?

None of the many complaints submitted to the over the years have created any solutions or lowered the impact of this cancer-causing environmental disaster.  Jennifer Richards own son is a victim of this disaster which is why she was inspired to take action.  He son developed an unexplainable long-lasting cough and asthma after regularly playing at the Cottonwood Kids Park.  Her sons flag football team had practices in the fields of the Cottonwood Children's Park and her son began developing rashes after practicing there.  The rash has since become dark brown and the skin keratinized, So even though the rash is gone, the dark mark and the raised skin still exist.  The darkening and change in texture of skin is a known effect of arsenic exposure.  The primary concern is if these exposures and resulting changes in skin can lead to skin cancer, another know effect of arsenic exposure. 

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It appears the City of Cottonwood has a clear and legal path to stop the copper slag dust contamination, immediately, by revoking the "Conditional Use Permit" the City has granted to Minerals Research for violations of section 302 of that permit. 

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Below is a list of alleged violations you can forward to any of the officials below to demand the law be followed and the violations be prosecuted.  You can simply copy and paste to your email and add your name to the bottom, or you can customize  how you like.  Email to:

Mayor Elinski at telinski@cottonwoodaz.gov or call him at 928-340-2747.

-Community Development Director, Scott Ellis , sellis@cottonwoodaz.gov  or call him at 928-634-5505 

ADEQ (AZ Department of Environmental Quality)- Balaji Vaidyanathan, vaidyanathan.balaji@azdeq.gov

Below are links to email our Planning and Zoning Commission and officials to request they enforce their own stipulations.

mduvernay@cottonwoodaz.gov; ggehlert@cottonwoodaz.gov; jglascott@cottonwoodaz.gov; sklinge@cottonwoodaz.gov; rgarrisson@cottonwoodaz.gov; lmasten@cottonwoodaz.gov; aapodaca@cottonwoodaz.gov

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Below is a list of alleged violations of Minerals Research.  So far our governmental agencies have failed to adequately investigate and enforce the law as it relates to these violations.  There are many more violations to be found in the official complaints page, there is just far to many to list here.  

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  • It appears MRI is in open violation of their Conditional Use Permit granted by the City of Cottonwood Planning and Zoning Commission.  This Conditional Use Permit has specific stipulations that must be met in order for MRI to legally operate, a violation of any stipulations can and should result in the revocation of their Conditional Use Permit.  Stipulation number 10 states that ADEQ permits must be obtained BEFORE MRI plant operations begin.  On October 12th, 2023, MRI was issued a consent order from ADEQ: Docket Number A-12-23.  The consent order states that the Crushing and Screening plant permit that MRI has been operating under (since approximately 2014), does not legally apply to their operations, and as such is invalid.  

    • This means that MRI has never had an applicable permit for their operations and as a result, all emissions of fugitive toxic slag dust into the community have been unlawful.  ​

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  •  Stipulation 13 of MR's Conditional Use Permit states that all drainage is contained within the retention areas on site.   As seen in this video (CLICK HERE), direct evidence shows stormwater is likely discharging off site as there is a downhill slop from the facility into the fairgrounds and there is significant evidence to suggest the off-site drainage is distributing toxic slag particulate into our community and ultimately our river.   â€‹â€‹

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  • As a result of MRI never obtaining a valid and applicable environmental permit from ADEQ, it appears all fugitive copper slag dust emissions into our community has been unlawful.   This would mean the City of Cottonwood can issue violations and fines for every day they have operated without a valid ADEQ permit since 2014.   It also could imply that MRI could be compelled to clean up all contamination of fugitive copper slag dust emissions within our city, businesses, homes, parks, children’s facilities, VFW, police station, fire station, elementary schools, churches and more.

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  • MRI has never performed and submitted the required phase 2 environmental study prior to operations beginning as guaranteed in at least five public meetings and correspondence between the City and MRI.  You can see the documentation of these agreements made between our Planning and Zoning Commission in an official complaint seen HERE.

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  • It appears MRI gave purposeful and material negligent misrepresentations to the citizens, Planning and Zoning and City Council in obtaining their CUP and original approvals and subjects them to a revocation hearing to be held before the entire Planning and Zoning Commission for them to consider revoking their CUP as provided for by law.  We request this hearing take place ASAP.  The overview of these violations can be seen by going to the Official Complaints page and viewing the August 29th complaint submitted to the City of Cottonwood. 

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  • Click here to view a flyer for a copper mining superfund site.  Notice how it states that the dust can be toxic and notice how on page 3 it states children should not handle the slag dust.  Yet in Cottonwood, we are actively crushing the slag into a dust that is covering our children's facilities and children's homes, bedrooms, blankets and more.  

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  • These matters are of extreme consequence to our community and must be addressed immediately.  

  

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You can also contact the Arizona Department of Environmental Quality at 602-771-2300 or you can submit a complaint with them by clicking HERE.

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