Fugitive Dust from the Delong Mountain Transportation System

Technically speaking "Fugitive dust" is defined as any dust or particulate matter that enters the environment from activities at the mine, and from transportation of ore concentrate along the Delong Mountain Transportation System (DMTS). The DMTS includes the road, the port facilities, and the barges that transfer the ore concentrates from the port to the ships offshore. The port facility and 19 miles of the road are found within Cape Krusenstern National Monument through which a 100-year transportation easement was granted by Congressional approval in 1985. 

Currently, the State of Alaska has no statues or regulations that protect people or the environment from hazardous fugitive dust.  There must be a significant impact (i.e our children must get sick, or the caribou die) as proven by scientific evidence before hazardous fugitive dust can be regulated.

Metal Dust and Food

The powder-consistency zinc and lead ore concentrates produced at the Red Dog mine can contain between 30%-50% of either metal. In addition to zinc and lead the concentrates contain metals such as aluminum, antimony, arsenic, barium, cadmium, chromium, cobalt, mercury, molybdenum, selenium, thallium, and vanadium. Fugitive metals dust resulting from mining activities is transported into the environment primarily by wind carrying the dust particles onto tundra, streams, ponds, lagoons, and the Chukchi Sea. In these environments, metals from dust may be taken up into plants such as moss, lichen, willow, or berries, and into animals such as muskoxen, caribou, ptarmigan, and fish, some of which may be eaten by people as subsistence foods, or which may be eaten by other animals.

Risks of Fugitive Dust

In 1999 the National Park Service (NPS) started to find that lichen and other nonvascular plants were being affected along the road corridor and around the port facility within the Krusenstern National Monument. In 2001 work began independently by both the NPS and Exponent a consultant hired by Teck Cominco, the owner of Red Dog, to characterize the affects of fugitive dust to the environment and assess environmental and human health risks associated with fugitive dust. In 2007 the final Risk Assessment for Fugitive Dust completed by Exponent was submitted to the Department of Environmental Conservation . In brief, Exponent concluded that the ecological risks associated with transport of ore concentrates along the DMTS were low to aquatic organisms and to area wildlife populations, but in some instances incremental risks could not be discounted for ptarmigan and small mammals nearest the DMTS. Exponent also reported measurable degradation of arctic tundra vegetation communities extending to at least several hundred meters away from the DMTS road and in some instances loss of lichen cover to distances as far as 2000m. However, Exponent suggested that changes in primary vegetation community structure were limited to within 100m of the road and that the cause of the vegetative damage may have been caused more by general road bed dust and calcium chloride used as a palliative on the road to reduce dust emissions. Yet, several deficiencies and uncertainties have been identified in the risk assessment. Some of these include:

1. Lichens, which are particularly sensitive to metals exposure and are important food sources to may organisms, were not appropriately viewed as receptors.

2. Resident Muskoxen in the Krusenstern, who primarily feed on lichens, were not identified as receptors nor were assessed for possible effects.

3. Loss of lichen cover was not measured to species level or at great enough distances from the road to establish the full spatial extent of effects.

4. Uncertainties in assumptions regarding the bioavailability and food chain transfer of metals, particularly with respect to plant uptake, in which metals may concentrate above concomitant levels in soil or dust.

The results of the NPS studies to date indicate the presence of mine-related heavy metal deposition throughout the northern portion of Krusenstern National Monument. Metal levels in moss were highest immediately adjacent to the haul road with analysis suggesting that lead is being deposited in an area that extends at least 15 miles north of the haul road to the Kisimilot/Iyikrok hills, and south of the haul road, airborne deposition appears to be constrained by the Tahinichok Mountains. Based on NPS moss studies, metal bioaccumulation in the Krusenstern ecosystem resulting from mining activites appears to be a significant potential long term threat to the viability of natural habitats and subsistence resources. In addition to the bioaccumulation of metals a major uncertainty exists with regards to the oxidation and fate of metal sulfides, particularly in regard to potential toxic effects of sulfates to non-vascular vegetation.

Fugitive Dust Risk Management Plan

Since the fall of 2001 Teck Cominco has taken several steps to reduce dust emissions. These dust control measures have included both physical and procedural controls. The original concentrate truck fleet has been replaced with trucks that have better handling characteristics, and have hydraulically closed steel covers and solid sides. Efforts to minimize dust from the road surface include physical and procedural controls that were implemented to limit tracking, removal of metals-containing road material, application of dust control agents (palliatives) to road surfaces, and paving of road surfaces. Calcium chloride is the primary palliative use to treat the road. Several additional measures have been taken both at the mine and the port including building enclosures and dust control systems and a seasonal truck washing station.

In March 2008 Teck Cominco held a meeting for all stakeholders interested in the development of a Risk Management Plan to address the adverse impacts and risks to human health and the environment identified in the 2007 Fugitive Dust Risk Assessment. From the contributions of the stakeholders present at the March meeting and the information presented in the Risk Assessment a Risk Management Plan has been developed to address those dust-related issues. The overall goal stated in the fugitive dust risk management plan submitted to DEC this past August is to "minimize risk to human health and the environment in the area surrounding Red Dog Mine and the DMTS road and port, over the life of the mine and post-closure operations".

Click here to download the Fugitive Dust Risk Management Plan, August 2008 Draft.

The plan is very vague and is more of a scoping document that discusses the evaluation process and generally identifies goals and objectives. The plan ends with presenting the need to develop 6 individual risk management plans addressing: communication, dust emissions reduction, remediation, monitoring, uncertainty reduction, and a worker dust protection plan. NAEC participated in the March 2008 stakeholder meeting and submitted comments regarding the Risk Management Plan in October. Metals bioaccumulation in the ecosystem containing the Red Dog Mine and the DMTS resulting from mining activities is a significant potential long term threat to the viability of natural habitats and subsistence resources in the region.

Click here to download NAEC's comments regarding the Red Dog Fugitive Dust Risk Management Plan.

Teck has begun drafting the individual risk management plans, to date has released stakeholder drafts of the communication, remediation, and monitoring plan. The NAEC reviews and comments on these stakeholder drafts as necessary. Check back soon for public copies of these plans.