Iron Mountain Mine

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Iron Mountain Mine

T.W. Arman has owned Iron Mountain since 1976.

Iron Mountain Mines, Inc.was formed in 1976 when T.W. Arman purchased Iron Mountain Mine from Stauffer Chemical Co. There are 36 patented mining claims on approximately 4400 acres zoned for mining. Iron Mountain was the 10th largest copper mine in the world and the largest in California.

On July 28, 2008, Iron Mountain Mines, Inc. transmitted the following letter to President Bush:

The Honorable George W. Bush, President of the United States of America

Dear Mr. President,

I am corresponding to you again concerning my property known as Iron Mountain Mines, Inc., located in Shasta County , California .

I am again seeking your executive authority to resolve the status of my liability for “unrecovered past response costs” that the EPA claims justify their liens against my properties.

I believe that you should provide this administrative order because:

(A) I am not a contributor to the hazardous substances at my facility or the toxic affects of the hazardous substances found at my facility, and

(B) I am the owner of the real property on which the facility is located and I did not conduct or permit the generation, transportation, storage, treatment, or disposal of any hazardous substance at the facility; and I did not contribute to the release or threat of release of a hazardous substance at the facility through any action or omission.

I believe I have not received a fair deal from the EPA, and I have persevered in proclaiming my innocence and my entitlement to the innocent land owner defense despite the incredible hardship that I have had to endure for the last 22 years protesting the allegation that I have contributed to or caused the pollution that is the subject of this Superfund site.

I was denied the innocent landowner defense of 9601 (35) (A) (i) in a partial summary judgment proceeding in October of 2002 that incorrectly alleges that the innocent landowner defense is unavailable to me. The EPA stated to the Court that “This defense, however, is only available to PRPs who, at the time of purchase, “did not know, or had no reason to know that any hazardous substance which is the subject of the release or threatened release is disposed of on, in, or at the facility.” The EPA then incorrectly states that “Because IMMI purchased the property with knowledge of – indeed, at least in part, because of – the presence of hazardous materials, the innocent landowner defense is not available to IMMI.

I try to be understanding about how these things get confusing after all these years, and I hope that this was simply an error and was not perpetrated out of malice or ill will, and I can certainly understand how the Court would defer to the experts at the EPA in determining such matters, however, the fact is that when I purchased the property in October of 1976 Copper, Cadmium, and Zinc were not considered “hazardous substances” in storm water run-off. This determination did not occur until July, 1977 of the following year, when the Congress Transportation Subcommittee approved new regulations for the Clean Water Act regulating these metals in storm run-off as “hazardous substances”. Indeed, the Copper in the storm drainage, or Acid Mine Drainage as it is now called, was represented as a valuable asset by the sellers of the property to me at the time, and whatever they knew about pending legislation or other environmental matters they concealed from me (as was latter proven by the EPA and DOJ counsel when they subpoenaed the seller's records), and after the purchase the principle occupation of my company along with the sales of mine tailings was operating the cementation plant, which recovered the Copper from the drainage before it got to the river.

Mr. Pedri of the Central Valley Regional Water Quality Control Board (CVRWQCB) met with me when I was purchasing the property and informed me that it was important to the State of California that I should operate the Copper cementation plants to help keep the river clean, and I assured him that it was my intention to do so, but at the time I had no idea that soon the State would be fining me millions of dollars because of the storm water run-off.

After the State issued their NPDES permit things got bad really fast, and I was getting fined thousands and thousands of dollars for an operation using ancient equipment that wasn't even really profitable to begin with, and very soon I felt like I had become a slave or some kind of indentured servant to the State of California, and eventually I just couldn't keep up with the costs of the work plus the fines and the legal fees.

The EPA also alleged that I did not “exercise due care” concerning the “hazardous substances”. This is also unfair because I kept the cementation plants working the best I could, and any failures of the old equipment, the faulty work of employees, the delivery of improper materials, or other failures was beyond my control.

In fact the Administrative Record of Superfund shows that the State knew the equipment I inherited when I bought the property was not up to the job of adequately removing the “hazardous substances” from the drainage since before I acquired the property, and that the State had been considering providing adequate equipment long before the EPA got involved. The EPA further claims that I violated State and EPA orders concerning the Site, but fails to clarify that those orders required the expenditure of over $200 million dollars in equipment and operational costs, and that I told them from the very beginning that I could not afford to perform the work they were ordering me to do.

I recently read an EPA web page that refers to the Iron Mountain Mines Superfund site, which the EPA published back in 2000, entitled the “Superfund 20 th Anniversary Report”.

The link is: http://www.epa.gov/superfund/20years/ch4pg12.htm

Making the Program Faster, Fairer, and More Efficient (Continued)

Resolving Disputes Outside of Court
Some of the most complex and contested cases can be settled using an outside mediator -- allowing all the parties to spend their time and resources cleaning up sites rather than litigating cases in court.

For example, at the Landfill & Resource Recovery site in Rhode Island , the parties included 18 PRPs, along with the United States and the State of Rhode Island . Both the Federal and State claims were resolved with the help of a Federal district court judge with a settlement that reimbursed the government for 97 percent of its expected costs. The mediated settlement also provided funds to purchase wetlands to expand the Blackstone River Valley National Heritage Center .

At the Auburn Road Landfill site in New Hampshire , a voluntary mediation led to a consent decree that resolved the government's claims against 31 PRPs. The settlers agreed to perform the remedy and to reimburse the United States for its past cleanup costs and future oversight costs. In addition, the settlers are reimbursing the State of New Hampshire and the Town of Londonderry for past cleanup costs and future oversight costs.

Protecting the "Little Guy"
Some Superfund sites have hundreds of PRPs, including small companies (or even individuals) who have contributed only a minor portion of the waste. These small contributors may be dragged into burdensome litigation by the PRPs which were primarily responsible for the contamination. EPA attempts to identify and resolve the liability of these small party contributors early in the process, leading to de micromis and de minimis settlements.

A de micromis party is someone whose contribution of waste is minimal. In fact, the costs of hiring a lawyer, and negotiating a settlement, would dwarf any amount the party could reasonably be expected to contribute to cleanup costs. Many times, the PRPs who contributed a major portion of the waste to a site sue the de micromis parties for contribution. EPA enters into a de micromis settlement with these parties to protect them from such suits.

For example, 47 homeowners who lived around the Raymark Industries site in Connecticut could be seen as de micromis parties since they only contributed household wastes to the site. EPA and the State of Connecticut protected these homeowners from being sued by entering into a settlement where each homeowner paid $1 to be protected from "third party" law suits brought by the major contributors.

A de minimis party has contributed more waste than a de micromis party, but the amount is still insignificant when compared with what has been contributed by some of the major PRPs -- for example, less than 1 percent of the waste at a site. With de minimis parties, EPA has placed a priority on achieving a quick, efficient resolution of their liability to protect them from burdensome litigation.

At the Tulalip Landfill in Washington , EPA settled with 207 de minimis parties very early in the process, resulting in the recovery of approximately $10 million and the identification of PRPs who made major contributions of waste to the site. At the Cherokee Oil Resources site in North Carolina , EPA entered into an early de minimis settlement with over 200 small contributors. Both the de minimis and the major contributors agreed not to sue over 1,000 de micromis parties.

EPA gets the "little guys out" of the Superfund enforcement. Over the years, 460 de minimis settlements have been reached with nearly 23,000 small waste contributors.

$1 Billion Settlement Reached at Iron Mountain Mine Site Redding, California (October 19, 2000) -- The United States and the State of California announced a settlement today with Aventis Crop Sciences USA, Inc. to fund future cleanup costs that could approach $1 billion at the Iron Mountain Mine site . The settlement is one of the largest to be reached with a single private party in the history of the Superfund Program. The agreement will ensure long-term control of more than 95 percent of the releases from the site. This 4,400-acre site, which operated from the 1860s through 1963, is historically the largest point source of toxic metals in the country, and the source of the most acidic mine drainage in the world. Prior to remediation, the mine discharged an average of a ton of toxic metals a day into the Upper Sacramento River, a critical salmon spawning habitat and central feature in the State's water system. Approximately 70,000 people used surface water within 3 miles of the site as their source of drinking water. In 1983, EPA listed the site on the NPL at the State's request. Since then, numerous Federal and State agencies have worked together on this site which has been addressed in six stages starting with a series of emergency actions. In 1994, a high density sludge treatment plant was installed that removes 99.99 percent of metals from the site's toxic runoff. The settlement pays for natural resource restoration projects, provides for operation and maintenance for 30 years, and guarantees additional funding for site costs incurred after the year 2030.

It seems somewhat ironic to me that the EPA is touting how they are “ Resolving Disputes Outside of Court” and “ Protecting the "Little Guy"” proclaiming the benefits of de micromis and de minimis settlements and apparently claiming that their dealings with Iron Mountain Mines is a good example of this.

Once again I respectfully submit that I am entitled to an innocent land owner defense.

The EPA treatment program has resulted so far in the accumulation of some 460,000 tons of toxic and hazardous sludge upon my property, and since the EPA apparently plans to continue making this sludge for another 3000 years, I am also asking for your assistance pursuant to Executive Order No. 13352, 42 U.S.C. 6901 et seq (a)(4), (b)(1 thru 8), and (c)(1 thru 3), and 6902 et seq (a)(1 thru 11) and (b), and 9622 (a), (b)(1 thru 4) to help me to correct this problem.

This is the fifth letter I have transmitted to you this year, and each reply has been from counsel for the EPA. I am wondering if you are even receiving these correspondences.

I am also seeking your assistance in promoting “cooperative conservation”, as provided for in your Executive Order No. 13352, and in accordance with the purposes expressed therein.

As used in this order, the term ``cooperative conservation'' means actions that relate to use, enhancement, and enjoyment of natural resources, protection of the environment, or both, and that involve collaborative activity among Federal, State, local, and tribal governments, private for-profit and nonprofit institutions, other nongovernmental entities and individuals.

The last reply to my request, dated May 1, 2008, and signed by Kathleen Salyer , Chief of the Site Cleanup Branch of Region IX of the EPA, states that “businesses and individuals are not eligible for EPA technical assistance under the provisions of 6913 of RCRA.”

Clearly my request has been entirely misunderstood, as I believe that it is the EPA that is in need of assistance under the provisions of 6913 of RCRA.

I provide for your convenience the relevant text of 6901 of the Solid Waste Act.

b) Environment and health   The Congress finds with respect to the environment and health, that-- (1) although land is too valuable a national resource to be needlessly polluted by discarded materials, most solid waste is disposed of on land in open dumps and sanitary landfills; (2) disposal of solid waste and hazardous waste in or on the land without careful planning and management can present a danger to human health and the environment; (3) as a result of the Clean Air Act [42 U.S.C. 7401 et seq.], the Water Pollution Control Act [33 U.S.C. 1251 et seq.], and other Federal and State laws respecting public health and the environment, greater amounts of solid waste (in the form of sludge and other pollution treatment residues) have been created. Similarly, inadequate and environmentally unsound practices for the disposal or use of solid waste have created greater amounts of air and water pollution and other problems for the environment and for health; (4) open dumping is particularly harmful to health, contaminates drinking water from underground and surface supplies, and pollutes the air and the land; (5) the placement of inadequate controls on hazardous waste management will result in substantial risks to human health and the environment; (6) if hazardous waste management is improperly performed in the first instance, corrective action is likely to be expensive, complex, and time consuming; (7) certain classes of land disposal facilities are not capable of assuring long-term containment of certain hazardous wastes, and to avoid substantial risk to human health and the environment, reliance on land disposal should be minimized or eliminated, and land disposal, particularly landfill and surface impoundment, should be the least favored method for managing hazardous wastes; and (8) alternatives to existing methods of land disposal must be developed since many of the cities in the United States will be running out of suitable solid waste disposal sites within five years unless immediate action is taken.   (c) Materials   The Congress finds with respect to materials, that-- (1) millions of tons of recoverable material which could be used are needlessly buried each year; (2) methods are available to separate usable materials from solid waste; and (3) the recovery and conservation of such materials can reduce the dependence of the United States on foreign resources and reduce the deficit in its balance of payments.   (d) Energy   The Congress finds with respect to energy, that-- (1) solid waste represents a potential source of solid fuel, oil, or gas that can be converted into energy; (2) the need exists to develop alternative energy sources for public and private consumption in order to reduce our dependence on such sources as petroleum products, natural gas, nuclear and hydroelectric generation; and (3) technology exists to produce usable energy from solid waste.   Since the EPA is administering the cleanup of the Acid Mine Drainage under the provisions of CERCLA, it is therefore a federal activity, as described in your Executive Order No. 13352.   “Sec. 3. Federal Activities. To carry out the purpose of this order, the Secretaries of the Interior, Agriculture, Commerce, and Defense and the Administrator of the Environmental Protection Agency shall, to the extent permitted by law and subject to the availability of appropriations and in coordination with each other as appropriate: (a) carry out the programs, projects, and activities of the agency that they respectively head that implement laws relating to the environment and natural resources in a manner that: (i) facilitates cooperative conservation; (ii) takes appropriate account of and respects the interests of persons with ownership or other legally recognized interests in land and other natural resources; (iii) properly accommodates local participation in Federal decisionmaking; and (iv) provides that the programs, projects, and activities are consistent with protecting public health and safety; (b) report annually to the Chairman of the Council on Environmental Quality on actions taken to implement this order; and (c) provide funding to the Office of Environmental Quality Management Fund (42 U.S.C. 4375) for the Conference for which section 4 of this order provides.”

As Iron Mountain Mines, Inc. is a private for-profit organization, and Iron Mountain Mines, Inc. has ownership and other legally recognized interests in land and other natural resources, I believe I am entitled to the benefit of these provisions, and deserve to have the EPA take and show “appropriate account of and respects the interests of persons with ownership or other legally recognized interests in land and other natural resources.”

I offer these further observations:

Since the EPA undertook cleanup of Iron Mountain Mines, Inc. under the provisions of CERCLA and my designation on the National Priority List (NPL) in 1983, a great deal of research has been conducted by private, government, and academic experts.

It is now recognized and understood that the cause of the Acid Mine Drainage is due to the activity of a biological community of micro-organisms inhabiting the rock formations underground, and that these bacterium have shown us their remarkable ability to extract from the earth with ease those very metals which miners have struggled and toiled to extract for the benefit of mankind.

Industry has quickly recognized this talent, and now employs these biological communities to great advantage in the economical extraction of minerals.

Similarly it has been shown, and is now being commercially implemented, that biological communities of micro-organisms can be employed to remedy the Acid Mine Drainage, and remove metal contaminants from water resources before entering the waterways of the United States more effectively and economically, and in more environmentally sound ways, than the conventional chemical methods.

These biological processes and their commercial adaptation in the form of biotechnology or “bio-mining”, offer the potential to transform what is presently regarded as an environmental disaster by the EPA, (by last account the EPA reported that AMD remediation would cost $72 billion dollars) into a manageable problem

In light of the new understanding of the biological processes involved in the formation of Acid Mine Drainage and its consequent effect upon the environment, we would like to offer a suggestion for a reinterpretation by the EPA of the legislation that currently regulates AMD.

Pursuant to the provisions of CERCLA, the Comprehensive Environmental Response, Compensation, and Liability Act, and the definitions contained therein, that henceforth AMD should be recognized as an “Act of God”, because it is a “natural phenomenon of an exceptional, inevitable, and irresistible character, the effects of which could not have been prevented or avoided by the exercise of due care or foresight.”   Also we would suggest that mines do not fit within the description of a “facility”, which requires that a site is: “any site or area where a hazardous substance has been deposited, stored, disposed of, or placed.”   In as much as the presence of any “hazardous substance” that is a naturally occurring element whose source is located in the earth must necessarily be acknowledged as an “Act of God” for such an expression to have any meaning, and since no person is responsible for it having been “deposited, stored, disposed of, or placed”, it should therefore be understood that persons may no longer be blamed for AMD, and the “cooperative conservation” of such resources may proceed without the acrimonious litigation and waste which has heretofore been the hallmark of this debate.  

We offer our vision of a permanent solution to this problem which will benefit all of society, the environment, and promote the economical recovery of valuable minerals in accordance with public law and private property rights in a sustainable way.

Thank You for your consideration of this matter,

Very Best Regards,

T.W. (Ted) Arman Date: July 27, 2008

President, Iron Mountain Mines, Inc.

T.W. Arman on the Brick Flat mine near the summit of Iron Mountain

T.W. Arman is Chairman, CEO, and President of Iron Mountain Mines, Inc. and its' single stockholder.

Since 1976, T.W. Arman and Iron Mountain Mines, Inc., and their trusts, have owned approximately 2800 acres of Real Property and 37 mining claims in the vicinity of Iron Mountain, which is mining property for the development of commercial products from mining, timber, and related products located in the City of Redding, Shasta County, California.

The proposed statue and spiritual retreat

The proposed statue and the IMMI development plan

Original IMMI Mining Plan

Artesian Mineral Development & Consolidated Sludge, Inc.

EXECUTIVE SUMMARY TO OPERATING AGREEMENT

This executive summary is prepared according to the provisions of the preliminary joint venture operating agreement and amendments of the HU/MOUNTAIN joint venture between T.W. Arman and John Hutchens, for the operation, administration, and maintenance of the Iron Mountain Mine site on behalf of Iron Mountain Mines, Inc. (who is the sole owner of Iron Mountain Mines and the mineral resources since 1976). The HU/MOUNTAIN joint venture has assigned primary contractor responsibilities for this project to Artesian Mineral Development & Consolidated Sludge, Inc. (AMD&CSI).

AMD&CSI has submitted a proposal for a final remedial action plan to the EPA Site at Iron Mountain Mines. The proposal incorporates the initial analysis of ROD 1, which describes 12 alternatives for remedial actions at IMM. Of the 12 proposed remedies, only CA-10, which involved removal of the ore, was found to be fully protective of human health and the environment, and permanently eliminated the source of the pollution. The IMM proposal, CA-1, was the insitu mining proposal prepared by Davey McKee corp. This proposal was found to be reliable and offered the potential to eliminate the source of the pollution, but was ruled out as too experimental, with to many unresolved concerns such as the mountains hydrology and the impact on the aquifer, and uncertainties about some of the products marketability.

The AMD&CSI proposal merges CA-1 into CA-10. The proposal demonstrates that since ROD1, the EPA has installed monitoring wells around the ore bodies, and conducted hydrology tests that demonstrate that the mines effectively function as a natural drain of the mountain, and that no AMD penetrates to the aquifer below. The proposal further demonstrates that while the proposed mining method was highly experimental at the time of its proposal, it is now a widely accepted technology, variously referred to as bio-mining, solution mining, and insitu mining. The Consent Decree provides $862 million in settlement funding.

The proposed remedy provides for resource conservation and recovery technologies, which begin with the bio-remediation of the AMD using sulfide reducing bacteria. This technology, which has achieved commercial success around the world under the expertise of Pacques NL, a Dutch company, and BioteQ, a Canadian company, precipitates much of the more valuable precious, semi-precious, and base metals using hydrogen sulfide generated by sulfur reducing bacteria in bio-reactors.

After the bio-precipitation, the AMD is conveyed to a conventional lime treatment, which removes most of the remaining metals, such as residual Iron, Zinc and Aluminum. Finally the AMD receives a polishing treatment to prepare it for commercial uses or for discharge. (Pacques NL and BioteQ have cross licensing agreements)

The proposal also includes resource conservation and recovery of the toxic sludge disposed upon the Brick Flat mine. This technology (also from Pacques NL), uses sulfur reducing bacteria to break down the gypsum matrix of the sludge, after which the metal is transmitted to the AMD cycle for processing.

The proposal also includes resource conservation and recovery of the toxic sludge disposed in the pit along Spring Creek filled with the dredging spoils from the Matheson Reservoir.

The processes utilized are now well established and commercially viable methods for recovering metals from AMD and producing cleaner water than the current technology employed at IMM.

The metals recovery facilities, including pyro-metallurgy and hydro-metallurgy will be optimized to accommodate daily production that will first be derived from processing the sludges, and then as solution mining production accelerates, sludge processing will be adjusted to balance the most efficient use of the facilities with processing of mining extraction and recovery. The facilities will also be designed in anticipation of reprocessing spent tailing from previous mining operations.

The anticipated production will be focused on maximizing the values from the sludge during the first 3 years of operation, and will gradually shift to a mining focus, with total elimination of long term sludge storage (storage beyond one season) scheduled for completion after 7 years. The primary recovery values are estimated according to the following production levels based on high density sludge assays.

Daily Metals and Minerals recoveries from sludge and AMD:

Iron 1,320,000 lbs.

Calcium 1,270,000 lbs.

Sulfur 1,040,000 lbs.

Aluminum 180,000 lbs.

Zinc 95,000 lbs

Magnesium 38,000 lbs.

Copper 20,000 lbs.

Silica 16,000 lbs

Potassium 3,500 lbs.

Arsenic 2,400 lbs

Manganese 2,300 lbs.

Sodium 1,000 lbs.

Phosphorus 600 lbs.

Cadmium 600 lbs.

Titanium 500 lbs.

Uranium 400 lbs.

Thorium 400 lbs.

Lead 400 lbs.

Boron 300 lbs.

Gallium 300 lbs.

Vanadium 200 lbs.

Cobalt 200 lbs.

Antimony 200 lbs.

Chromium 100 lbs.

Nickel 100 lbs.

Tantalum 100 lbs.

Tungsten 100 lbs.

Tellurium 100 lbs.

Yttrium 100 lbs.

Ytterbium 100 lbs.

Gadolinium 100 lbs.

Indium 90 lbs.

Strontium 70 lbs.

Scandium 50 lbs.

Molybdenum 50 lbs.

Zirconium 50 lbs.

IMMI and AMD&CSI proposes to manufacture and market several key value added products manufactured from the aforementioned materials, the most significant of which are hi-technology products derived from acutely toxic hazardous wastes, particularly cadmium sulfide and cadmium telluride for photo voltaic cells and gallium arsenide for integrated circuits. AMD&CSI is currently investigating potential strategic alliances with technology owners for on site fabrication. Facilities for hydrometallurgy, pyrometallurgy, bio-metallurgy, and refining, manufacturing, and re-processing plants will be built on site.

IMMI and AMD&CSI proposes to construct and operate an IGCC coal gasification plant for the production of power, carbon and hydrogen, ammonia, and select hydrocarbons. Low grade coals are available in the Shasta area, but have not been mined since the 1920s. The power generating turbines will sell excess power back to the grid after providing all of Iron Mountain Mines electrical needs.

Estimated costs: IGCC with LURGI ammonia, CLAUS acid, GE turbine, process and calcine plant: $950M

Ammonia products for processing and leaching will be prepared onsite, eliminating any shipping of hazardous ammonia. Ammonia products will be marketed in fertilizer products.

IMMI and AMD&CSI proposes to construct and operate an ethanol bio-fuels plant with production from rice straw.

A portion of the ethanol production will be used to feed the bioreactors for the sludge digesting micro-organisms. Excess production will be processed with hydro-carbon feed stocks or sold as fuel.

Estimated cost of ethanol bio-fuels and bioreactors: $50 M

Fertilizers:

IMMI and AMD&CSI proposes to construct and operate a fertilizer production plant for engineered time release fertilizers. The major agricultural fertilizer will be formulated for rice production, incorporating a slow release IBDU (Isobutylene Di-urea) core for late stage growth with a mixed Urea, Ammonium sulfate, Ammonium thiosulfate, Melamine, Humic Acid shell. This fertilizer will be available in assorted macro-nutrient ratios with varying amounts of potassium, phosphorus, zinc, and additional sulfur, along with a full compliment of trace elements that are recognized micro-nutrients. (The majority of the presently available fertilizers are made at natural gas or naphtha refineries in Texas . IGCC coal gasification with LURGI ammonia synthesis is a disruptive technology that makes ammonia for less than conventional methods.)

With the rising costs of oil and gas has come a significant increase in the cost of fertilizer, more than doubling from 2006 to 2008, or between 20 and 25 percent of the cost of rice production in California . Northern California has about 500,000 acres of rice production, which require on average over 150 lbs. of nitrogen fertilizer per acre per year. With the other major and minor nutrients in a time release application that will provide entire crop nutrition, about 400 lbs. of fertilizer (as Urea) per acre is needed with each crop, or about 200 million lbs. (100,000 tons, 80% Urea). The current price of Urea fertilizers is about $450 per ton.

In other words, California rice farmers will spend about $45 million on fertilizer this year.

IMMI and AMD&CSI proposes to manufacture and deliver the fertilizer that the rice farmers of California need for a current equivalent of about $30 million per year, including free removal and recycling of all rice straw.

IMMI and AMD&CSI propose to promote this partnership through an alliance with rice farmers, universities, the dept. of agriculture, the dept. of energy, the dept. of conservation, and local co-operatives, and finance this endeavor through the sale of industrial revenue bonds backed by long-term contracts with rice farmers.

IMMI and AMD&CSI proposes to manufacture at least 200 K tons ammonia as Urea and/or IBDU annually, with ample facilities for expansion and for the development of new markets, focusing especially on other major California farm crops such as grapes, fruits and nuts, corn, ornamentals, and for retail lawn and garden.

Estimated annual sales: $50 million to specialty fertilizer markets, $30 million to rice farmers

Annual Gross Fertilizer sales: $80 million

Net:$20 million

Iron Oxides:

AMD&CSI proposes to refine the Iron oxides to extract and purify a range of pigments and chemicals.

The primary patents for these technologies have expired. Spinnel Ferrite is a magnetic crystalline form of Iron Oxides known to exist in the AMD; these hi-tech products will receive ongoing product research.

Annual Gross Iron Pigments and other specialty Oxides: 30,000 tons (equivalent to U.S. annual imports)

Annual Gross @ $1000 per ton: $30 million

Net $10 million

IMMI and AMD&CSI proposes to construct and operate a specialty alloys electric arc furnace, with wire, rod, and casting of specialty building materials.

Annual Gross specialty alloy production 70 K tons.

Annual Gross @ $560 per ton (estimated after royalties): $40 million

Annual Net $10 million

Calcium

IMMI and AMD&CSI proposes to construct and operate a calcining plant for specialty cements and grouts, and to recycle calcium hydroxide for lime treatment.

Annual gross specialty cements and grouts @ 400 K tons @ $100 =$40 million

Annual Net $20 million

Sulfur:

Sulfur has recently soared to over $500/ ton

Annual gross sulfur 100 K tons @ $500 =$50 million

Annual Net $30 million

Copper, Aluminum, Zinc, Magnesium, Manganese, Titanium, Uranium, Thorium, Lead, Boron, Gallium, Vanadium, Cobalt, Antimony, Chromium, Nickel, Tantalum, Tungsten, Yttrium, Ytterbium.

Current aluminum price over $1.20 @ 180,000 lbs. = $64 million

Current Zinc price over $1.00 @ 95,000 lbs = $35 million

Current Magnesium over $1.00 @ 38,000 lbs. = $14 million

Current Copper over $4.00 @ 20,000 lbs. = $30 million

Estimated lanthanides, strategic and rare earth metals: = $37 million

Annual Gross, Base Metals = $180 million

Annual Net approx. $120 million

Annual Gross Specialty and strategic metal products =$80 million

Annual Net approx. $60 million

Annual Gross from IGCC plant power, chemicals and fuels = $500 million

Annual Net from IGCC $40 million

Annual Net from EPA $5 million, for site maintenance

Plus speculative ventures: nano-technology, pharmaceuticals, facilities to U.C.; extraction of PGM metals?

Potential value unknown

Total cash investment in facilities and infrastructure $1Billion

Annual gross sales $1 Billion

Annual net approx $300 million

Annual operations, debt service, insurance, environmental contributions, closure fund: $120 million

Annual profit to IMM, joint venturers, stockholders, etc. $180 million

Mine Closure, Garden of Eden, Spiritual Center , Christ Statue and Visitor center.

Mine reclamation, landscape restoration

$1B (half from EPA and State in 2030)?

Life of Mine, about 40 years

Closure, restoration, about 10 years

Ore Reserves

Using the results of assays and information developed during drilling, drifting and mining of the various segments of the Iron Mountain ore body, geological ore reserves were developed for both the massive sulfide and disseminated ores by Mountain Copper Company. Reserves of the gossan ore were developed through the cooperation between engineers of Mountain Copper Company and Stauffer Chemical Company. Subsequent checks of these reserve figures have been made by Southwestern Engineering Company and Iron Mountain Mines, Inc. In addition, various Mountain Copper Company internal checks are evident. The result of the calculations and checks is the general agreement that there presently exists at Iron Mountain Mine roughly 12,000,000 tons of proven sulfide ore with minimum average grades of 1% copper, 2% zinc, 0.02 gold and 1.5 oz. silver. Probable gossan ore is estimated at 3,000,000 tons. The combined proven geological reserves amount to 15,050,000 tons of proven sulfide and gossan ore contained within an area of roughly 300 acres. These reserves represent tonnages presently remaining in the Hornet, Mattil, Richmond Extension and the unmined Brick Flat ore bodies. No recent reserve figures have been developed for the three magnetite bodies. Remaining in place tonnages for the Old Mine, Number 8, Confidence-Complex, Camden , busy Bee, Lone Star and Okosh massive sulfide bodies are listed in various data and reports received from Iron Mountain Mines. However, no reserve calculations for these deposits are available as backup. Limited backup assay data are available for the Camden and Okosh bodies. According to this information average copper grades for the Camden and Okosh are 1.01 percent and 3.43 percent respectively. No overall averages are readily available for the Old Mine, Number 8 and Confidence-Complex but general extension of adjacent data indicates average grades may approach one percent.

Tons of proven sulfide ore in place: 14,183,000; probable reserves 1,050,000

Tons of proven gossan in place 3,050,000; probable reserves 3,795,000

Grand Total in place 17,233,000; probable reserves 4,845,000

During 1950 and 1951, a 1,798 exploration drill hole was put down by the U.S.G.S. in the vicinity of a syncline on the southeast side of the Iron Mountain mine. Located at the approximate mine coordinates 2900 north, 3650 east passed through numerous rhyolite intervals of Balaklala formation throughout its entire length. Intermittent, broad to narrow bands of disseminated sulfides were present throughout the drill hole with some intervals containing slightly greater than one percent copper. Kaiser Engineers, 1981

Possible sources of funding

1. Green Venture Capital.
2. Private, State, and Federal loans and/or grants.
3. Industrial Bonds, Cooperative Bonds
4. State and Federal Bonds
5. Joint Ventures
6. Private Placement, (Capital Stock)
7. IPO

Political

The proposal revolutionizes the environmental response to inactive mines and the preferred approach to acid mine drainage mitigation by the EPA, and will transform what is presently regarded as a $72 billion environmental disaster by the EPA into a manageable resource for the public benefit.

The present proposal will make the IMM team the largest employers in Shasta County .

The bulk of these jobs will be high skilled, high paying jobs, which will have an overall transformative effect in rejuvenating the economy of the Shasta/ Trinity region.

The proposal includes provisions for the constructive and effective salvation and rescue of rice farming in the central valley of Northern California , and will create a recipe for a mutual political and economic alliance between the agricultural base of the northern central valley and Iron Mountain Mines.

While it will be harshly criticized as a form of socialized farming, in fact California rice farmers have historically received disproportionately fewer subsidies than many other types of farms, and around the world rice farms are generally protected from free trade pressures with tariffs and subsidies.

The company is currently preparing evaluations of remedial investigations and feasibility studies to grow the organization with a proposal to encompass the ultimate remediation of all inactive massive sulfide mines in the Shasta Copper Belt, which would perhaps triple the material recovery, revenue, and life of mines.

The organization will simultaneously evaluate the potential for expanding this work to encompass other inactive or abandoned coal and metal mining facilities in the nation and around the world to implement a synergistic resource conservation and recovery approach to acid mine drainage, help to solve the high cost of fertilizers for farmers, and help advance the revolutionary power and chemical technologies from IGCC coal gasification in combination with LURGI ammonia synthesis, CLAUS acid recovery, high performance cement composites and building materials, and other related technologies.

Balance of Trade:

The proposal forecasts the elimination of imports of at least 60,000 tons of metals annually, half from iron oxides and half from strategic metals, resulting in a net adjustment to the current trade deficit of over $150 million dollars annually.

Current market and employment impact

The proposal is estimated to create approx. 1200 direct jobs and 2000 indirect jobs for life of mine.

The proposal is forecast to generate $40 billion in revenue and $12 billion profits for life of mine.

Cautionary Disclosure: This is "forward-looking information about prospective results of operations, financial position or cash flows that is based on assumptions about future economic conditions and courses of action and that is not presented in the format of a historical balance sheet, income statement or cash flow statement ." Examples of financial outlooks include expected revenues, net income, earnings per share and R&D spending. Material facts have not been verified. Actual results may vary. These results are highly speculative. Readers should establish their own reasonable basis for these assumptions.

T.W. Arman

Ted & John

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