Anthony Greenaway | Environmental impact of bauxite-alumina industry: legislation and its implementation

Bauxite was discovered in Jamaica in the 1940s while processing to alumina began in the early 1950s. Based on currently known bauxite deposits, the Mines and Geology Division predicts that Jamaica’s bauxite-alumina industry could last for another 50-100 years. While the industry contributes positively to the livelihoods of many individuals and communities, it has serious negative environmental impacts.

LEGISLATION

In the early years of the industry, relevant environmental protection legislation was minimal. Significant advances were made with the passing of the Natural Resources Conservation Authority Act (1991) and associated regulations (1996). However, “grandfather” clauses, which largely exempted the industry from the ambit of same, continued and instead protected the industry until 2015. Even after 70 years, gaps persist in the current legal framework.

Jamaica has a Draft National Minerals Policy (2017-2030). This policy, once adopted and passed into law, will require minerals industries to “comply with internationally and locally recognised codes of practices, guidelines, standards, regulations and legislations for the maintenance and improvement of the environment”. To be effective, the policy will need to be supported by an act and regulations, and the relevant authorities must ensure implementation and enforcement. If this is done, the bauxite-alumina industry will finally be required to operate in a sustainable manner.

Lack of appropriate implementation and enforcement of environmental law is a long-standing problem in this industry. For instance, some industry operating licences and associated permits to discharge effluent are seriously flawed. In one particularly egregious example, an environmental permit issued to UC Rusal’s Ewarton processing plant in 2017 seemed more relevant to a coastal power station, even requiring a fence to be erected to prevent crocodiles from entering the plant! In 2020, after the errors in the permit were pointed out to the National Environmental and Planning Agency (NEPA), the permit was reissued. However, the plant had been “operating” according to the initial permit for three years, and the permit “reviewed” four times as part of industrial audits by the Jamaica Bauxite Institute (JBI). The flaws should have been detected and corrected.

ATMOSPHERIC MONITORING

Another concern is the ineffective monitoring of the industry’s impacts on the atmosphere. The monitoring done at the Ewarton bauxite processing plant and at least two of Noranda’s lease areas are based on inappropriately located monitoring stations.

The NRCA (Air Quality) Regulations (2006) requires applicants for permits to discharge to the atmosphere to calculate the expected emissions from all relevant sources. The calculated discharges are used in a dispersion model to determine their impact on areas outside of the perimeter of the plant. The model’s calculations identify where the maximum ground-level impacts are likely to be. The guidelines to the regulations state that each source will generally have at minimum two compliance stations near where maximum ground-level concentrations are expected, one population-exposure station, and one background station. Special-interest sites can also be included. The actual sites used are agreed upon by the regulators (NEPA, JBI) and the company.

For the Ewarton processing plant and the associated Swallenburg mining areas, the monitoring sites in use, presumably in agreement with authorities, have very little to do with the model’s predictions. They may be sites of special interest but are not compliant or significant public-exposure sites if the model’s results are to be believed. The sites seem to be the ones that were used in the years prior to the requirement to model. If companies are required to go to considerable expense to do modelling, then the results should not be ignored.

A worse example is the modelling for Noranda’s mining in special mining lease (SML) areas 165 (since 2004) and 172 (since 2017) in St Ann, where the model has been inappropriately applied. The mining area for the recently issued SML-173 is to the west of the SML-165 area. Bauxite mined from these areas has been, is, or will be, trucked to railheads at Tobolski and Water Valley, both north of Brown’s Town and near the centre of the SML-165 area, and then by train to Discovery Bay. The model predicts the impacts of these operations to areas outside the boundaries and downwind of the facility with the caveat that the model should also consider areas within the facility that are accessible to the general public. The applications of the model to the areas of SMLs 165 and 172 considered the boundaries of the facilities to be the boundaries of the lease areas and hence ignored areas close to actual mining pits, the railheads and the haul-roads. The model application to the SML-173 area did correctly include the area within the lease area boundary but did not consider the railheads and haul roads within area 165. The model’s predictions therefore have little or no relevance to the mining and haulage activities.

The three actual monitoring sites being used for the areas of SMLs 165 and 172 are in the central to eastern side of SML-165, all upwind of the two + the majority of mining pits in SML-165 and all of the mining pits in SML-172 and so bear little or no relevance to the actual impact of mining activities.

AIR QUALITY STANDARD

The existing Air Quality Standard lacks a specification for the smallest atmospheric particulates, called PM2.5. This is a significant omission because these sized particulates, which are generated by mining and processing, have been shown to possibly affect respiratory health while the larger particles (called PM10 and TSP) that are specified in the standard have not. The industry should be required to monitor for PM2.5.

In conclusion, with some updating (at least the requirement for PM2.5 monitoring), the current laws, regulations, and policies could be appropriate for the industry. However, if the implementation and enforcement continue along past and present lines, the negative impacts of the bauxite-alumina industry will continue unabated.

Anthony Greenaway, PhD, formerly of the Department of Chemistry, UWI, Mona, and now managing director of Greenaway and Associates, is a laboratory management and data (chemical/environmental) interpretation consultant. This is the second in a series of articles by the authors of RED DIRT, a review of the bauxite-alumina industry, which was commissioned by the JET. Send feedback to columns@gleanerjm.com.