Bauxite Monitoring Strategy 16 Nov 2010.doc

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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 forthe 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.


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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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Bauxite Monitoring Working GroupNovember 2010 Confirmed By: Page 2


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1. NEPA leading the monitoring activities in collaboration with theJBI, 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. Plant Mothballing

II. Maintenance Procedures

III. Restoration

IV. Safety

V. Legal Obligations

VI. Community

VII. Environmental Monitoring

Strategy 1 would have two main tasks:

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Desktop, Literature Review, File research and data

gathering (Task 1)

a) Identification of all data available in the Agency

b) Collection of all dis-aggregated data either directly fromthe 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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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 Responsibility

Completiondate

Start Date

JOB DESCRIPTION

FOCAL POINT

Mrs. Kolbusch November 30,

2010

Identify Focal Point CEO/HR December 1,

2010

Identify Working

Group members and

receive confirmations

CEO/Focal

Point

December 15,

2010

Desk top, literature

Review and D and File

Focal Point January 31 2010

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data Gathering

Coordinate Audits and

Preparation of Audit

Reports Prepared

Focal Point April 30 2010

Post Audit

Assessment

Working

group/focal

point

End 2nd QTR

2011

Compliance

Monitoring and

Enforcement Actions

ALL 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 rerecommendedquired skill-sets are as follows:

i. Civil Engineer

ii. Process Engineer

iii. Chemist

iv. Community Animator

v. Ecologist

vi. Legal Officer

vii. Geographical Information Systems Technician

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viii. Data Management Specialist

ix. Hydro-Geologist

x. Geologist

xi. 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 andafter 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 BauxiteIndustry

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 in-

house 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 Sub-

Division.

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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9/11LiteratureReview Audit of Facility

Working Group

Lit review report

TOR AuditAudit reportMonitoring reportsRecommendationsEtc.

Community

and Bauxite

sector

Recommendations

NRCA

BAUXITE MONITORING STRATEGY

STRUCTURE


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 Unit Cost

Recurrent

Total Recurrent Costs

External Auditor

remuneration over three

months

$600,000.00 $600,000.00

Traveling two teams;

seven

facilities @ $30

$1500.00 $45,000.00

Subsistence team of four

on seven visits @ $500.00

per person per day

$14,000.00 $12,000.00

Total $657, 000.00

Source of Funding

The team would seek funding for travelling, subsistence and salary from the

recurrent budgetand additional support from the NRCCA.

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Documents

Bauxite Monitoring Strategy 16 Nov 2010.doc