Dear Editor,
The proposed expansion by Bosai Mining Company should be viewed with some level of concern given the Company’s history of environmental non-compliance. This concern is further exacerbated by the Minister of Natural Resources and Environment’s admission that “development comes at a cost”. It must be acknowledged that Bosai inherited a wide range of environmental liabilities when it acquired the Linden bauxite operations from Cambior. These liabilities are detailed in a Ground Structures Engineering Consultants report (Adam Smith Institute, 1999). That report identified environmental liabilities related to air emissions, ground and surface water and solid waste among others.
The company has done very little, but promise, to correct these liabilities since its acquisition of the resource. Whatever little has been done has been focused on mitigation of dust emissions from kilns operated by the company. The company secretary is quoted in one of the daily newspapers as stating that only “fine dust” is emitted. This totally ignores the beneficiation utilized for calcination of bauxite ore. A major part of that beneficiation is the firing of bunker C fuel. During beneficiation, additional air toxins include Sulphur dioxide, Sulphur Trioxide, Carbon Monoxide, Nitrogen Oxide, Non Methane Volatile organics and Methane Volatile organics.
It is therefore simplistic to state publicly that only fine dust is emitted. Further all scientific evidence indicates that fine dust is more easily inhaled than coarser dust fractions. In fact, ILO and WHO guidelines state that the danger from silica particles occurs for diameters less than 5 microns and especially those with a diameter between 0.5 and 3 microns since those particles when inhaled can reach the alveoli and lead to lung impregnated disease. The admission by the company of the emission of “fine dust” should therefore present justifiable reasons for a detailed quantitative risk assessment to establish the environmental and occupational health issues related to emissions from Bosai kilns. That risk assessment should incorporate factors such as the concentrations at receptors, exposure pathways and exposure duration to determine the excess risks associated with exposure to kiln emissions. The emission concentrations at receptors should be based on a state of the art air dispersion model. The exposure pathways should at a minimum consider inhalation, dermal contact and ingestion of both dusts and food contaminated by deposition of dust.
The Minister of Natural Resources and Environment’s statement about costs related to development should also encompass the costs to the persons within the area of influence of the project. It has been established that residences in Noitgedacht, Linden are impacted by dust from the unsurfaced road at the top of the bauxite plant tailings pond. That dust has decreased property values in the area and increased property maintenance costs. Consequently the proposed expansion should also establish the environmental costs and benefits of the proposed expansion, as opposed to the economic costs and benefits. Additional environmental costs are costs related to lost days and medical expenses due to respiratory illnesses. Typical guidelines for economic valuation of environmental impacts were developed by the Asian Development Bank. These guidelines should be stringently applied to this project to ensure minimal impacts on the project area.
The Government of Guyana (GoG) has a 30% stake in Bosai. The GoG also exercises control over the Environmental Protection Agency, the regulatory body with responsibility for permitting the proposed expansion. The GoG therefore has a vested interest in ensuring that a permit is granted for the proposed expansion. The GOG has indicated it is in discussions to grant additional mineral resources to Bosai for the proposed expansion. There has been no indication from either Bosai or the GoG that either a prefeasibility or feasibility study has been conducted for the proposed expansion. The EPA, being subject to GoG control, may have significant aversion to providing the degree of technical and regulatory oversight to be expected for a project of this nature. The EPA also has very little capability to review technical data on air dispersion modeling, environmental and occupational health risk assessment and environmental costs/benefit analyses.
The environmental issues related to the expansion are further compounded by the fact that the Linden area is located in one of the primary recharge areas for groundwater used in our coastal plain. Any contaminants discharged to groundwater can, depending on its mobility, impact groundwater quality resulting in significantly increased costs to provide potable groundwater to residents in our coastal plain. This is not an impossible scenario, groundwater contamination from an old aircraft maintenance facility on Long Island, NY has crossed Long Island Sound and contaminated groundwater in Connecticut. The Minister of Natural Resources and Environment should ensure that his ministry’s technical capability allows them to assess the likelihood of groundwater contamination to ensure that the development costs do not impose an unnecessary burden on future generations.
Stakeholders in Linden should also ensure that they are adequately represented at all meetings to discuss mitigatory measures to be employed to address environmental issues related to Bosai’s operations. These issues should be increased to address all the issues identified in the 1999 Adam Smith Institute report. That would present the only acceptable scenario for the project to move forward to benefit both Bosai and persons within the project area of influence.
Yours faithfully,
Charles P Ceres
