Bauxite Monitoring Strategy

Introduction The Chief Executive Officer at the Senior management meeting held on 1 November 2010 selected a team to develop a Monitoring Strategy for the bauxite sector in response to the management of the environmental issues . The Jamaica Bauxite Institute (JBI) and the Water Resources Authority (WRA) have had a much closer working relationship with the sector over the years and have gained a wealth of knowledge and experience from their working relationship, unlike the National Environment and Planning Agency (NEPA). The Natural Resources Conservation Authority (NRCA), in accordance with regulation 6 delegated in 1994 to the JBI its authority to monitor the sector. The environmental regulatory framework has since been strengthened while at the same time the tenets of the 1994 agreement are inadequate to address legal and enforcement issues together with other emerging ones. The NRCA, at its June 2010 meeting, having been made aware of the areas of concern in the bauxite industry, decided that NEPA should take full responsibility for monitoring the sector. The NEPA would maintain a relationship with the JBI to ensure that consultation in the technical areas continues. The NRCA/NEPA has granted environmental permits and licences to the facilities without having a comprehensive overview of the long term plans for the industrysector. The Agency has recognized this as a weakness and that an urgent need in exista order tto bring the industry sector to the point of environmental compliance.

Bauxite Monitoring Strategy

This approach would serve to support the Agency in addressing the existing environmental issues, changes in the environmental regulatory framework and the needs for stringent monitoring of a sector that has legacy issues that need remediation Issues facing the Sector The areas of concern that need to be addressed in the industry, namely: The contraction of the industry and its effect on the environmental management and monitoring capabilities of the industry Unresolved land settlement matters in several areas of the country, The purpose and hence the standard applicable for restoration of mined out lands, Fate of residual disposal areas containing hazardous substances in the event that facilities such as Alumina Partners of Jamaica and WINDALCos Kirkvine Works do not resume operations Cost of clean-up activities where the owners have not returned in light of the absence of environmental performance bonds The capacity of the sector to provide acceptable levels of environmental monitoring during the period of temporary shutdown Underground water quality Expansion strategy in the sector by existing mining and alumina refining companies Air Pollution, monitoring, mitigation and liability

Monitoring Strategy The proposed strategy seeks to address monitoring in 2-phaes:

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1. NEPA leading the monitoring activities in collaboration with the JBI, WRA and MoH 2. NEPA taking full responsibility for monitoring the sector

Phase 1 Four (4) strategies are identified for Phase 1, namely, a. Information gathering (STRATEGY 1), b. Post Audit Report Assessment (STRATEGY 2), and c. Public Awareness Campaign (STRATEGY 3) d. Compliance Monitoring and Enforcement (STRATEGY 4)

STRATEGY 1:

Information Gathering

This strategy involves all the relevant agencies (JBI, NWA, WRA, MGD, NLA, Forestry Department and EHU). It would take into consideration both the legal and monitoring aspects. The strategy would also be focused on not only existing facilities but also new facilities that may be proposed in the future. Information would be gathered on the following aspects: I. II. III. IV. V. VI. VII. Plant Mothballing Maintenance Procedures Restoration Safety Legal Obligations Community Environmental Monitoring Strategy 1 would have two main tasks:
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Desktop, Literature gathering (Task 1)

Review,

File

research

and

data

a) Identification of all data available in the Agency b) Collection of all dis-aggregated data either directly from the facilities or from the JBI c) Groundtruthing of data with reference to all historical data and issues at each facility Audit of Existing Facilities (Task 2) a) Develop Terms of Reference for the Audit that includes the following areas: mining, refining, storage, waste storage, waste disposal, transportation, land management, restoration of lands b) Carry out audit and prepare report c) Initial engagement of community on audits

STRATEGY 2: Post-Audit Report Assessment The strategy includes five major tasks which are listed as follows: Adequacy of Environmental and Planning Legislation Identifying Breaches Indentifying areas of Risk Risk management approach Identify areas and level of exposure

2. Public Awareness Campaign (STRATEGY 3)

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Bauxite Monitoring Strategy

This strategy, to be implemented by the Public Education Branch, includes announcements to the communities and the general public that the NEPA-led activities are being undertaken. Community surveys will be undertaken to assess the likely impact of bauxite operations on their livelihood and record their concerns. STRATEGY 4: Compliance Monitoring and Enforcement This strategy will apply the rule of thumb approach for getting the facilities to operate within the regulatory framework. This will involve the identification of breaches, strict compliance monitoring to identify the need for facilities to obtain relevant environmental permits, licences and approvals. Enforcement activities leading to legal action will be a component where breaches of existing environmental permit and licences occur.

Timelines for the Tasks in Phase 1 The timelines for the various tasks identified for administering the strategies in Phase 1 are as outlined in Table 1 below:

Table 1: Breakdown of Activities Related Responsibilities and Projected Start Time. TASK Responsibilit Completion y date November 2010 December 2010 December 2010 30, 1, 15, Start Date

JOB DESCRIPTION Mrs. Kolbusch FOCAL POINT Identify Focal Point CEO/HR

Identify Working CEO/Focal Group members and Point receive confirmations Desk top, literature Focal Point Review and D and File
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data Gathering Coordinate Audits and Focal Point Preparation of Audit Reports Prepared Post Assessment Audit Working group/focal point April 30 2010

End 2nd 2011

QTR

Compliance ALL Monitoring and Enforcement Actions

Start of 3rd QTR 2011

Human Resources Need for Monitoring The NEPA maydoes not have all the skill-sets that are necessary to administer the effective monitoring of the sector. The rerecommended quired skill-sets are as follows: i. ii. iii. iv. v. vi. vii. Civil Engineer Process Engineer Chemist Community Animator Ecologist Legal Officer Geographical Information Systems Technician

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viii. ix. x. xi.

Data Management Specialist Hydro-Geologist Geologist Dispersion Modeling Technician

In order to implement and administer the strategies identified in Phase 1, the Agency needs to identify a Bauxite Focal Point. If one cannot be identified internally, then the Agency should seek someone externally through funding from the NRCA. The Bauxite Focal Point will: 1. Conduct Task 1 of STRATEGY 1 and collate the historical data gathered 2. Develop TORs for the Audit of the sector (Task 2) A Working Group, to be chaired by the Senior Manager of the Environmental Management Sub-Division, would be formed. This group would that includes the various skill-sets identified above in collaboration with along with the relevant agencies: Environmental Health Unit (EHU), JBI, WRA, National Works Agency (NWA), Mines and Geology Department (MGD), National Land Agency (NLA), and Forestry Department.

The Working Group would review the Draft TORs to conduct the audit and after deliberating on the comments, finalize them for approval. The Focal Point will; lead the Audit, act as a vital member of the Working Group, prepare the Audit Report and present same to the Working Group.
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After accepting the report, the Working Group will be responsible for carrying out the various task listed under STRATEGY 2. During this period, it is intended that there will be transfer of knowledge and necessary skills during the audit and monitoring exercises to enable NEPAs in-house staff to become effective when required to take full responsibility of these activities. Phase 2: NEPA takes full responsibility for Monitoring the Bauxite Industry For NEPA to take full responsibility for monitoring the entire bauxite industry, there are several technical skills that would be in place either from its inhouse staff complement or from cooperative agreements with the sister agencies to provide specialists as required. The Bauxite Focal Point, supported by a Data Management Specialist and a Dispersion Modeling Technician would report to the Manager for Pollution Monitoring and Assessment Branch in the Environmental Management SubDivision. The Chief Executive Officer will chair the Oversight Bauxite Monitoring Committee that has membership from the entire participating sister agencies. Associated Monitoring Costs The cost involved in this venture would largely be for traveling associated with conducting the audit and the remuneration for the lead auditor if this person is being employed solely for this purpose. It is estimated that all the facilities will be visited at least once; these include the peripheral areas such as the waste treatment sites and mining areas. Accommodation will also be made for subsistence and traveling for the team(s). In addition, there will
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miscellaneous costs associated with collation of documents from the literature review phase. Accordingly, the following is the breakdown of associated costs

Table 2: Budget Description of Activities

BAUXITE

Unit Cost Total Recurrent Costs Recurrent MONITORING STRATEGY

External Auditor STRUCTURE $600,000.00 $600,000.00 remuneration over three months Traveling seven two teams; $1500.00 $45,000.00

facilities @ $30 Subsistence team of four $14,000.00 on seven visits @ $500.00 per person per day Total $12,000.00 NRCA

$657, 000.00

Source of Funding

Recommendatio ns

The team would seek funding for travelling, subsistence and salary from the recurrent budget and additional support from the NRCCA.
Working Group

Lit review report TOR Audit Audit report Monitoring reports Recommendations Etc.

Community and Bauxite sector

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Literature Review

Audit of Facility

Bauxite Monitoring Strategy

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