IRMA Standard for Responsible Mining (Draft 2.0)
Chapter 3.4 Air Quality

Background

Mining sites can release significant quantities of air pollutants in two main categories: particulate matter, and toxics. By volume, the great majority of contaminants are particulate, such as dust from blasting, large truck and equipment traffic, conveyors, ore crushing, etc. Toxics may represent only a small proportion of a mine’s air emissions, but are important because they can significantly degrade human health and the environment.

Mines may emit contaminants from localized sources such as processing plants or from more diffused activities, such as fugitive dust emitted by blasting or truck traffic, or wind-blown from exposed surfaces such as roads, pits, and waste piles, or from dried surfaces of tailings impoundments.

These releases can generally be controlled with reasonably inexpensive measures. However, a mine’s typically large geographic footprint make control especially important and sometimes difficult. The most common method of dust control is spraying water - such as by truck on roads and near blasting activities. Chemical additives, such as magnesium chloride may be added to increase the effectiveness and durability of sprayed water.

Objectives / Intent of this chapter

To protect and maintain pre-mine air quality conditions.

Scope of Application

Chapter Relevance:  This chapter is relevant to all mining operations that release to air any of the contaminants in Table 3.4.a, or others that may present a risk to human or ecosystem health. Air emissions may be from stationary or mobile equipment, mine waste disposal areas, and other mining-related activities undertaken on the mine site or along transportation routes.

NOTES TO READERS ON MAJOR CHANGES TO THIS CHAPTER

  • Removed requirement to comply with all requirements of EU regulations and implementation protocols, as these provide more guidance to States than companies.
  • Changed the requirement related to air dispesion modeling (3.4.2.2) so that it is required unless a company can demonstrate that there is no significant risk to communities or ecosystems from air pollutants.
  • Added a requirement to measure the mass deposition of dust (3.2.3.4).
  • The means of verification (MOV) have been removed from this version of the draft IRMA Standard. If you would prefer to review and comment on a version of the draft Standard that has the means of verification, you can download a pdf version of the Standard with MOV.
     

Air Quality Requirements

3.4.1.  Air Quality Management Plan

3.4.1.1.  The operating company shall develop, maintain and implement a documented air quality management plan that adjusts to the specific issues and concerns at the mine site and evolves as data becomes available.

3.4.2.  Monitoring and Modeling

3.4.2.1.  The operating company shall monitor and record air quality at the operations associated with the mining project by using personnel trained in air quality monitoring.

3.4.2.2.  The operating company shall employ air dispersion modeling consistent with leading methodologies (e.g., US EPA’s Air Quality Guidelines, technical guidance related to the European Union Air Quality Directive, etc. [1]) to estimate the concentrations, transport and dispersion of mining-related air contaminants, unless the company can demonstrate that emissions of air pollutants from the mining project pose no significant risk of impacts to humans, wildlife or rare, threatened or endangered plant species.[2]

3.4.2.3.  The operating company shall position air collection canisters around the mine site, related operations and transportation routes and the surrounding environment such that they provide a representative sampling of air quality sufficient to demonstrate compliance or non-compliance with the air quality criteria in 3.4.3.1. Air monitoring locations shall be informed by the air dispersion modelling results.

3.4.2.4.  The operating company shall measure mass deposition of dust. Dust deposit gauges should be located between the mine site and nearby communities or properties likely to be affected by dust deposition.

3.4.3.  Air Quality Compliance

3.4.3.1.  The operating company shall comply with the European Union’s Air Quality Standards as amended to its latest form (See Table 3.4.a) at all mine operations, and associated facilities and transportation routes associated with those operations.

3.4.3.2.  Dust deposition shall not exceed 350 mg/m2/day, measured as an annual average.[3]

3.4.4.  Reporting

3.4.4.1.  The operating company shall ensure that its air quality management plan and compliance information is up-to-date and publicly available.[4]

Notes

Air quality standards and requirements were reviewed for various countries, focusing on the most expansive, developed standards. The greatest focus was on the standards of the European Union, Canada, Australia, and United States. With the goal in mind of adopting a standard that would evolve over time the decision was made to adopt the European Union’s (EU) numeric air quality standards. There are many developed standards but the EU’s stands out for its breadth of included contaminants, including contaminants released during mining, and its inclusion of specific metalloid contaminants.[5]  Further, like many developed national standards, the EU’s air quality standards were developed to be comprehensive, transparent (development, review and modification, application, and interpretation in the courts), and enduring.  Finally, the EU’s air quality standards are evolving and therefore predicating IRMA’s air quality standard on them will ensure that IRMA’s standards also evolve.

Cross Reference to Other Chapters

 Chapter

 Issues

1.1—Legal Compliance As per Chapter 1.1, if there are host country laws governing air quality related to mine sites, the company is required to abide by those laws. If IRMA requirements are more stringent than host country law, the company is required to also meet the IRMA requirements, as long as complying with them would not require the operating company to break the host country law.
2.13—Grievance Mechanism and Access to Other Remedies Air quality impacts not anticipated in the ESIA or not adequately mitigated may result in complaints by stakeholders. As per Chapter 2.13, the operating company is required to have an operational-level grievance mechanism available to stakeholders, including procedures for filing complaints, and having complaints recorded, investigated and resolved in a timely manner.
4.1—Environmental and Social Impact Assessment Potential air quality impacts may be identified in the ESIA.  The assessment may help to inform the location of air monitoring sites, as well as potential means of mitigating air quality impacts.

 

Endnotes

1. See US EPA’s Air Quality Guidelines. Appendix W To Part 51—Guideline On Air Quality Models. Pt. 51, App. W, 40 CFR Ch. I (7–1–03 Edition); and European Environment Agency. 2011. The Application of Models under the EU Air Quality Directive.

2. Such a demonstration may be made through air quality analyses conducted as part of an ESIA, risk assessment, and/or based on monitoring data. If, at any later date, monitoring suggests a heightened risk of impacts, modeling shall be conducted.

3. IRMA has added a specific dust criteria because dust is not listed on EU list of contaminants as it is not strictly harmful to health rather it is a “nuisance”, and can be problematic communities and ecosystems located near mine sites. This criteria is based on the German TA Luft (Technical Instructions on Air Quality Control) Regulation. The German dust guidelines have been incorporated here as the minimum requirement, but may require further citation and consideration, notably the potential inclusion of both an annual and a monthly mean. More information will be provided in IRMA Guidance.

4. Compliance information may include air quality monitoring data, air quality reports (to agencies), records related to non-compliance (as per Chapter 1.1) etc.

5. The US EPA’s Air Quality Standards are similar in many ways, however the EU includes contaminants not found in the US standards that may be released by mining and mining-related activities, such as arsenic, cadmium, and nickel.

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