Rio Tinto has applied to the Division of Air Quality (DAQ) for an increase in their pollution emissions of between 54% and 65% to expand their mining operations.  Salt Lake County is already in violation of the EPA’s air quality standards and this proposed expansion will make it harder, if not impossible to achieve compliance.  If approved, Rio Tinto’s expansion will further jeopardize public health and make it more likely that Utah will be sanctioned and penalized by the EPA and that other businesses will have to be curtailed.  Rio Tinto’s contribution to the state’s economy is less than they claim and not sufficient to warrant this kind of special treatment by the DAQ or offset the economic and public health consequences of their proposed pollution increase.

The urban areas of the Wasatch Front consistently rank in the top ten worst cities in the country for acute spikes in air pollution.  The American Lung Association gives us the rank of “F” for the two most important components of air pollution, ozone and particulate matter (PM2.5).  It is not surprising that Salt Lake County is officially classified by the EPA as “non-attainment” with National Ambient Air Quality Standards (NAAQS) for PM10, PM2.5, SO2, and soon to be for ozone, of which NOx is a primary contributor.

Rio Tinto is by far the largest single source of air pollution in the urban Wasatch Front, emitting  ten times more pollution over all than the next largest industrial source, the Chevron oil refinery.  The combined Rio Tinto mining, power plant/tailings, and smelting operations release over 18,000 tons of air pollution per year.  In addition, the mine by itself is the largest single source of particulate emissions (both PM10 and PM2.5) in the entire state.

By federal law, the DAQ must create special air quality plans, called “State Implementation Plans”, or “SIPs”, for non-attainment areas, which describe the strategies by which the non-attainment areas will be brought into attainment with the NAAQS. State rules for air permitting of industrial sources, transportation emissions planning, and other sources of air quality impacts are then created or modified in order to meet the goals of the SIPs.  Obviously, an air pollution source in an area of non-attainment will have more stringent air emission requirements than a source located in an area of attainment.  Currently, DAQ has Salt Lake County SIPs in place for PM10 and SO2; the PM2.5 SIP is currently being written and must be submitted to the EPA in 2012.  The EPA is also currently reviewing the DAQ’s proposal to classifySaltLakeCounty(as well as Weber andDavisCounties) as non-attainment for ozone.

In press conferences and in a Salt Lake Tribune Op-Ed, Rio Tinto’s Utah Operations President Kelly Sanders has made the statement that Rio Tinto’s proposed change of electrical generating capacity at their Salt Lake County power plant, involving trading three coal-burning units for natural gas-burning units, would reduce their facility emissions by 20%, and would be the equivalent of taking one in ten cars off the road in Salt Lake and Utah Counties.  Taking them at their word, by simple algebra, this is an acknowledgement by Rio Tinto that their power plant alone is responsible for half as much emissions as from all vehicles combined in those two counties.  The DAQ has stated in the past that motor vehicles account for as much as one half to two thirds of our total air pollution.  If that is the case, then by extension, Rio Tinto is arguably responsible for 25 to 33% ofSaltCountyair pollution.

President Sander’s statement on emissions reduction, however, is also misleading and disingenuous.  Due to an existing air permit requirement that Rio Tinto may not currently operate their coal-burning power generation units during the four-month winter inversion period inSaltLakeCounty, Rio Tinto must purchase their power from the western power grid.  The emissions related to purchased power are not being created or emitted into the Salt Lake County airshed, rather, they are created and emitted by power plants in outlying counties off of the Wasatch Front, and have minimal impact on existing airshed issues. However, by replacing the coal burning units with natural gas burning units, Rio Tinto would no longer be required to purchase power off the grid, meaning that new, additional emissions will now be released into Salt Lake County’s airshed during the worst possible time (i.e. the inversion months) when the county is already struggling with non-attainment events.

Consider also that Rio Tinto’s power plant is only one of their four currently permitted operations inSaltLakeCounty.  Their mine alone dominates industrial emissions in the valley, and the combined emissions from all of their operations are startling. The DAQ requires all permitted sources to self report their emissions every third year.  An examination of the last complete year of emission inventory data (2008) collected from all permitted industrial sources in the State ofUtah, reveals that from all emissions from all industrial sources inSaltLakeCounty, Rio Tinto emits 77% of all NOx, 66% of PM2.5, and 79% of all SO2. It is important to note that since both NOx species and SO2 are capable of forming chemical particulates in the atmosphere, the DAQ considers PM 2.5, NOx, and SO2 to be “interchangeable” as particulates under current air permitting rules.  Rio Tinto annually emits 12,600 of those pollutants and the total for SL County is 39,119.  Rio Tinto then is responsible for 32% of PM 2.5 and its precursors.

The DAQ is also required to conduct continuous air monitoring to see how these emissions are impacting the air quality standards.  For PM2.5 the three year running averages of all the monitoring sites inSaltLakeCounty(Hawthorne, N. Salt Lake,WestValley, Herriman, Magna andCottonwoodHeights) is an average of 11.5 ug/m3.  If Rio Tinto is responsible for 32% of that then they contribute 3.8 ug/m3 of PM2.5.

This PM2.5 contribution is particularly relevant in light of a recent important study demonstrating that chronic exposure to PM2.5 of just 3ug/m3 correlated with retinal arteriole narrowing (presumably representative of arterioles throughout the body) equivalent to seven years of aging or a 3 mmHg chronic increase in diastolic blood pressure1.  When this study was discussed at the last UMA Board meeting we found it presumptuous and inappropriate that Rio Tinto’s attorney felt qualified to interpret and trivialize that study in front of the physicians of the UMA Board.  According to a formula published by the American Heart Association, a chronic increase in PM2.5 of 3.8ug/m3 increases community mortality rates  3-4% 2.

Rio Tinto has repeatedly defended theirUtahoperations by making statements concerning the number ofUtahworkers they employ.  These numbers appear to be exaggerated.  Several months ago Rio Tinto stated they employed 1,900 people.  They now claim 2,400.  The latest figures from the Utah Department of Work Force Services does not list Rio Tinto or Kennecott in the top 44 employers in the state for 2009, which would indicate that they employ less than 2,000 persons.  If so they have fewer employees than Sizzler Steak Houses.  This certainly diminishes Rio Tinto’s claim about being an indispensable economic force.

Even dismissing public health considerations, the fact that Rio Tinto creates far more pollution per job (~14,500 tons per employee per year) than any other business along the Wasatch Front, makes it economically counterproductive to the community at large and unfair to other businesses to grant Rio Tinto an even greater share of the pollution permits.

Looking at it from another angle, Rio Tinto’s proposed expansion only offers substantial economic benefit to a relatively small number of their prospective and future employees.   In order to realize that benefit, approximately 1.8 million people must be forced to make significant health (and therefore economic) sacrifices.  The number of victims is several thousand times greater than the number of potential beneficiaries.  Public policy should not allow such a distorted risk benefit ratio.

The details of Rio Tinto’s plans to increase the size and scope of their Utahmining and smelting operations have just been made public and they are indeed alarming.  Specifically, they are intending to increase their total tonnage of material mined from the current 197,000,000 tons per year to 260,000,000 tons per year –nearly a 32% increase. From Rio Tinto’s own modeling technical support document submitted to the DAQ in Dec. 2010, Rio Tinto is seeking an increase in their overall NOx emissions of 54% and of PM 10, 65%.

What is even more alarming is the DAQ’s apparent intent to grant this emissions increase.  How this extensive increase can be accommodated within an already unacceptably polluted, and “officially non-attainment” airshed defies simple logic, and it is reasonable to ask pointed questions related to this business decision on Rio Tinto’s part.

In order for Rio Tinto to gain ultimate approval for their increase, the State ofUtahmust first amend the PM10 SIP, which is a federally-enforceable document and must be approved by the EPA.  Interestingly enough, in December of 2009, the EPA published in the Federal Register their intent to disapprove most elements contained within the latest version of the Salt Lake County SIP, as they felt that it is already substantially flawed in several of the technical analyses it presents as part of its attainment strategy.  Ultimately, the EPA believes that the current SIP as prepared by the DAQ will not be effective in achieving attainment with the NAAQS. UPHE is concerned that by consideration of this proposal, the DAQ is demonstrating an agency mindset that does not give public health priority as they are mandated to do.

Because several counties along the Wasatch Front are already failing to meet the NAAQS, it is very possible that the EPA will not approve of a SIP that allows such an increase unless emissions from other businesses are reduced or restricted.  Unfortunately, history suggests it is very possible that the EPA might not rule on the required change in the SIP until long after Rio Tinto has been given the green light by the DAQ, which could create a difficult if not impossible enforcement dilemma.

UPHE is not an “anti-industry” organization.  We fully understand the economic necessity of extractive and manufacturing industries.  We are aware that the balancing of economic necessity and public health impacts often results in an interplay of decisions that do not always benefit the health or the well-being of society.  We all require and use products made from mined metals.

Unfortunately, mining is one of the industries that carry with it intrinsically large and disproportionate impacts to public health and the environment.  Typically, these impacts are reduced by the fact that most mines operate in geographically isolated portions of the world, well-away from large populations.  However, Rio Tinto is operating the world’s largest copper mine in the immediate neighborhood of a population base of nearly two million people. Rio Tinto admits there is no comparable juxtaposition anywhere else in the world. Therefore the impacts from this operation must be scrutinized carefully, as the emission impacts directly affect a far greater population base.

UPHE and our network of professionals have spent months studying the documents relevant to Rio Tinto’s proposal and have spent numerous hours in multiple meetings with company officials.  We feel that they are hiding behind a false front of economic necessity (preserving local jobs) for their  proposed expansion.  This corporation has placed greater inhouse profits squarely before public health and the well-being of Wasatch Front communities. What emission reductions Rio Tinto has planned, i.e. the replacement of coal-burning power units with natural gas-fired power units as mentioned above, are proposed primarily to enhance their profitability (the avoidance of purchased power at higher rates), and ironically will actually increase the air quality non-attainment predicament that Salt Lake County continues to find itself mired in.

Rio Tinto’s expansion proposal demonstrates an extremely narrow corporate self-interest. If granted by the DAQ, the expansion will confound attempts to regain compliance with clean air standards, and will create decades of irreparable damage to the long-term health and well being of millions of people. As physicians and public health advocates, UPHE asks the UMA to join us and help redirect a process that is destined to make our air pollution worse for decades to come.  UPHE asks the UMA to endorse the statement below so that we might use it publicly, for example during DAQ hearings on Feb. 22.

“The UMA recognizes the significant health and mortality burden that air pollution places on our community and our patients.  Therefore, in the name of public health protection the UMA asks our largest industry sources of pollution not to increases their emissions beyond current levels and furthermore asks that our state agencies not allow Wasatch Front overall industry pollution to increase.”

1.  Adar SD, Klein R, Klein BE, Szpiro AA, Cotch MF, Wong TY, O’Neill MS, Shrager S, Barr RG, Siscovick DS, Daviglus ML, Sampson PD, Kaufman JD.  Air Pollution and the Microvasculature: A Cross-Sectional Assessment of In Vivo Retinal Images in the Population-Based Multi-Ethnic Study of Atherosclerosis (MESA).  PLoS Med. 2010 Nov 30;7(11):e1000372

2.  Brook R, Rajagopalan S,PopeCA, Brook J, Bhatnagar A, et al.  AHA Scientific Statement: Particulate Matter Air Pollution and Cardiovascular Disease; An Update to the Scientific Statement From the American Heart Association.  Circulation. 2010;121:2331-2378.

SUMMARY OF RIO TINTO EXPANSION ISSUES

1.  During a typical winter the Wasatch Front has the worst air pollution in the country for several days and we consistently rank in the top ten worst cities in the country for acute spikes in air pollution.  In 2010 we exceeded the EPA’s standards for PM 2.5 on 51 days.
2. The American Lung Association gives us the rank of “F” for ozone and PM2.5.
3. The American Heart Association’s suggested formula for calculating community mortality indicates that 1,000-2,000 deaths in Utah are caused by air pollution.
4. SL County is already in violation of the EPA’s national air quality standards.
5. The EPA has put the Utah DAQ on notice that they are proposing to disallow the state implementation plan (SIP) for achieving compliance on PM10.   Nonetheless RT is trying to increase mine activity 32% to 260 million tons within a state SIP that has already been rejected with their current mining activity at 197 million tons.  In fact, the only currently enforceable SIP dates back to 1994 which only allowed 150 million tons to be mined.
6. The history of RT shows a clear pattern of repeatedly asking to increase mine activity.  We can anticipate that this latest increase request will not be the last.  This would be in fact a 73% increase since 1994.
7. Rio Tinto (RT) is already by far the largest industrial source of pollution along the Wasatch Front, responsible for about one third of the overall pollution in SL County,  ten times more than the next industrial source, the Chevron refinery.
8. RT is the largest source of heavy metal contamination to Wasatch Front air, water and soil.  For example, their smelter emissions of lead alone are 6,235 lbs per year.   The waste rock piles, fugitive dust and tailings emissions further increase the community’s overall exposure to toxic heavy metals, and an increase in mining activity will certainly increase their heavy metal releases.  In fact, the coal power plants currently operated by RT continuously emit mercury, and radioactive elements like uranium and thorium into our airshed.  None of these toxic and radioactive metals break down over time.  Our exposure to them steadily increases year after year.  The Great Salt Lake already has the highest levels of mercury of any water body in the US (although the sources include many more than RT).
9. The increased mining activity RT is asking for will increase their overall NOx emissions 54% and their PM10 emissions 66%.   This will cause an increase in overall NOx emissions in SL County of 14% and PM10 12%.  Data on the change in other pollutants is not yet available.  NOx is a precursor (an essential ingredient) in the formation of ozone ‘smog’ in summer. Salt Lake County is soon to be in non-attainment for ozone.
10. No data have been released yet on the pollution impact of RT’s proposal to offset some of this pollution increase by changing three coal burners to natural gas.  RT’s claim that this will reduce emissions, claimed to be equal to one in ten cars being taken off the road in Utah and SL Counties, is likely exaggerated, and even then would not offset the increased emissions from the mine.
11. RT is not allowed to run any of their coal plants in the winter.  However, they are asking to run these new natural gas plants during the winter.  Therefore, during our worst inversion/pollution season, RT’s proposal will increase their pollution from both their increased mining activity and their new natural gas power plants, especially in winter months.
12. As of 2009, according to the Utah Department of Workforce Services, RT does not rank in the top 44 employers in the state which indicates they have less than 2,000 employees.
13. RT emits about 14,500 lbs of air pollutants per employee, far more than any other business.  Currently RT provides less than one fourth of 1% (0.25%) of the jobs in SL and Utah Counties, but about 30% of the pollution.
14. The RT expansion would provide jobs for only a few hundred employees at best.  Meanwhile the air pollution impacts would be felt by about 1.8 million people and would curtail other economic and business activity, costing jobs with other potential employers.  That is a grossly distorted risk/benefit ratio.
15. RT made a profit of 14.3 billion dollars last year, despite a still depressed worldwide economy, and metal prices are projected to continue a steady rise.  They can afford to make their entire operations much cleaner and live within their current pollution limits.
16. The Bingham Pit is the largest mine in the world.  There is no other mine anywhere near this large that is this close to this many people, as RT has acknowledged.  Therefore, RT should be required to control their pollution much better than anywhere else, and again, live within their current pollution limits.
17. The Bingham Canyon Mine’s 23,000 acres, has $0 attached to its bond.  Research indicates that the reclamation of these types of mines cost an average of $50,000/acres.  At that cost the Utah and national taxpayers could be left with a $1.2B liability.  RT’s other bonds are also underfunded The potential liability for taxpayers is about $1, 310,000,000.
18. Since the Kennecott Charitable Foundation was established in 1992, they’ve donated $2,400,000 to area charities.  This while at the same time devaluating the western 20-mile flank of Salt Lake Valley including creating the largest toxic groundwater plume in the nation, more waste dumps, more acid generation inevitability, and more toxic tailings. At the same time they could install technology and apply best management practices to their operation that would actually reduce emissions but instead feed crumbs to the community in donations.