Barriers to implementing cleaner technologies and cleaner production (CP) practices in the mining industry: A case study of the Americas

Minerals Engineering, Vol. 13, No. 7, pp. 699-717, 2000

Pergamon 0892-6875(00)00055--8

© 2000 Elsevier Science Ltd All rights reserved 0892--6875/00/$ - see front matter

BARRIERS TO IMPLEMENTING CLEANER TECHNOLOGIES AND CLEANER PRODUCTION (CP) PRACTICES IN THE MINING INDUSTRY: A CASE STUDY OF THE AMERICAS

G. HILSON Institute for Environmental Studies, University of Toronto, 33 Willcocks Street, Suite 1016, Toronto, Ontario, Canada, M5S 3E8. Email [email protected] (Received 28 October 1999; accepted 18 April ~000)

ABSTRACT In the Americas, years of unregulated mining and mineral processing activities have not come without high environmental costs. For decades, large volumes of untreated wastes have been discharged into surrounding air, waterbodies, and soils, and since the beginning of the environmenta,t movement and the advent of the first environmental legislation some thirty years ago, only selected mines in this region have experienced noticeable reductions in pollution and achieved marked improvements in environmental management. These properties have been able to integrate a number of cleaner technologies and Cleaner production (CP) practices- defined here as highly efficient environmental equipment, and state-of-the-art environmental management measures-- into a wide-range of operations. The remaining mines, however, face a number of barriers that either individually or collectively prevent implementation of cleaner technologies and CP practices. Using important regional examples, this paper provides an overview of these barriers, which have been identified as legislative, technologic, and economic in nature, and discusses the changes that are needed to overcome them. While ultimately, an environmental improvement is contingent upon what initiatives are taken at individual mines, for these barriers to be removed, and any realistic movement toward industrial CP to occur, regional governments must play an expanded environmental role and make CP an national goal. Once widespread governmental assistance has been provided, and mine employees completely understand the importance of environmental protection, cleaner technologies can then be more readily implemented, and CP plans that are procedurally simple can be sketched. ©2000 Elsevier Science Ltd. All rights reserved.

Keywords Environmental; mining; pollution INTRODUCTION In the Americas, mining has been, and continues to be an important economic activity. Even after decades of continuous extraction, the region still remains a world leader in the production of a number of high quality minerals, including hard coals, iron ore, nonferrous nickel and copper, and gold. Years of unregulated minhlg and mineral-processing activity, however, has not come without high environmental costs. For example, within the mining district of Sudbury, Ontario, Canada, over 100 million tons of gaseous SOs has been released from copper and nickel smelters in the past century (Gunn et al., 1995), leading to the acidification of an estimated 7300 surrounding lakes (Neary et al., 1990). In another important mining district, Amazonia, close to 3000 tons of toxic atmospheric mercury has been emitted

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from gold processing activities since 1979 (Lacerda, 1997), causing heavy contamination to groundwater, soils, and plants. Given that the environmental problems that persist within these and the other important mining districts of the Americas have a serious impact upon people, wildlife, and natural resources, it is critical that, for the benefit of the surrounding environment and its ecological entities, the industry invests in more efficient, pollution abatement technology, and adopts more comprehensive environmental management practices. While the environmental regulations of the past 25-30 years have played a notable role in reducing the amount of pollution and waste being discharged from mines in the Americas, there remains much room for further improvement. This improvement, however, is contingent upon the industry's ability to integrate cleaner technologies and Cleaner production (CP) practices---defined here as highly efficient environmental equipment, and state-of-the-art environmental management measures--into polluting modes of operation. Many academics and industrialists contend that "going green" makes practical business sense, arguing that industrial implementation of cleaner technologies and CP practices is a "win-win" scenario for both the firm and the environment. Most of these discussions, however, are largely theory-based, examining extensively the merits associated with improved environmental measures but failing to identify the potential barriers that must be surpassed in order to implement them. Movement toward pollution prevention and waste minimization, therefore, depends upon an industry's ability to overcome the barriers preventing the integration of cleaner technologies and CP practices into operations. Challenges vary from industrial sector to industrial sector. In the Americas, specifically, three major barriers--which have been identified as legislative, technologic, and economic--are preventing implementation of cleaner technologies and CP practices at mines. The purpose of this paper is to examine in detail these barriers, and to discuss the major changes that are needed to overcome them. The paper opens with a general discussion on cleaner technologies and CP practices, and highlights their importance in the mining industry. Next, the paper outlines the mining industry in the Americas, and discusses why a number of properties are in need of environmental improvement. In the sections to follow, each of the major barriers preventing implementation of cleaner technologies and CP practices is examined, and regional examples are provided to illustrate significance. The concluding section of the paper discusses the important changes that are needed to eliminate these barriers, and identifies the key research areas needing further attention.

CLEANER TECHNOLOGIES AND CP PRAC~'ICES IN THE MINING INDUSTRY What are cleaner technologies and Cleaner Production (CP) practices? The unwanted by-products of all industrial activity are wastes and pollution, which, if mismanaged, pose a threat to environmental quality and human health. For decades, no restrictions were placed upon industry, which operated with minimum environmental safeguards in place. It was not until the 1970s that certain governments, in attempt to cease an ever-intensifying pattern of environmental degradation, began passing strict legislation to control quantities of toxics being discharged to air, water and land. Industry, firmly wedded to their operating systems that had been responsible for the environmental crisis in the fast place, responded by implementing several reactionary end-of-pipe technologies that worked to treat discharges of contaminating waste. Although most conventional end-of-pipe systems are average at best, many companies from a wide range of industrial sectors are still content with employing these remedies to resolve even the most serious of environmental problems. In recent years, however, the more sustainable industries of the world have identified that many conventional end-of-pipe systems are costly to operate and maintain, and ineffective at remediating environmental damage. Further, this group has recognized that their use has not helped them escape scrutiny from many governmental and lobbying environmental groups that perceive the equipment as mere environmental compliance investments, helping to put a firm's operations only in line with regulatory demands and nothing more. Sustainable industries have concluded that the solution to these problems is to replace conventional end-of-pipe equipment with cleaner technologies m equipment that emits little or no hazardous waste materials (Randall, 1996), or that tackles pollution at the source rather than after it is discharged (Luken and Freij, 1995) - - and to integrate improved Cleaner production (CP) practices into

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operations. Cleaner technologies can include newly introduced highly efficient environmental equipment, heavily retrofitted end-of-pipe designs, and improved control systems. Their use enables industry to achieve CP, and results in a simplified win-win scenario for both industry and the environment. Cleaner production (CP) practices are simply management and organizational measures that put a firm in better position to handle, minimize and anticipate problems with waste. Some examples include: • Good housekeeping with materials and energy • Improved environmental auditing • A shift in the emphasis of training programs from pollution control to waste minimization • Implementation of forefront environmental polices • Redesigning of plants to better accommodate wastes • A setting of improved environmental goals CP practices arLd cleaner technologies go hand in hand. While upgraded environmental equipment is entirely responsi[ble for reducing and minimizing pollution from industrial activity, improved management practices serve as valuable guidance and more importantly, help an operation identify additional opportunities for waste minimization. Examples of cleaner technologies in the mining industry

There are a number of cleaner technologies that have emerged to prevent problems with pollution in the mining industry. One area where significant improvement has been made is air pollution prevention equipment. The smelting of metallic ore produces flue gas saturated with noxious SO2 - the principal contributor to acidic deposition. Many countries have formalized air pollution legislation in place, requiring that flue gas be cleansed before it is released into the atmosphere, and to achieve legislative compliance, many mines have, since the 1970s, used a number of different desulphurization units otherwise known as scrubbers (Bell~Ls, 1998). The standard scrubber routinely removes 90% of SO2 from flue gas but the cleaner scrubber technologies, which use magnesium-enhanced lime and operate at appropriate liquid-togas ratios, achieve between 98 and 99% removal efficiency (Harfiot et al., 1993). Flue gases are also loaded with significant amounts of particulate matter, including dust, metallic particles and silica fragments. The standard technologies used to remove particulate matter from flue gas are electrostatic precipitators and bagbouses (Schifftner and Hesketh, 1996). Electrostatic precipitators use an electrostatic field that attracts; particles from flue, and the collection efficiencies of the well designed, well operated, and well-maintained cleaner models are in the order of 99.9% for dust, and 99% for toxic metal particles (UNEP, 1998). Baghouses, on the other hand, collect dust as flue gases pass through a fabric filter. The cleanest of these technologies also remove approximately 99.9% of dust particles, and more than 99% of toxic trace metals (Moore, 1994). The redesign of smelting technology further exemplifies a shift toward cleaner technology. Redesigned models have helped to reduce SO2 emissions by decreasing the number of stages in the smelting process, increasing the concentration of sulphur in the off-gas, and enclosing the process to make the capture of offgases as efficien~tas possible (Warhurst and Bridge, 1996)~ The most significant advances have been the flash smelters, which facilitate sulphuric acid production. INCO, for example, at its operations in Sudbury, invested milliorLs to develop its oxygen flash smelter that reduces SO2 emissions by producing a concentrated SO2-off stream that can be efficiently captured and fixed as sulphuric acid (Warhurst, 1994). Another significant advance has been the Kennecott and Outokumpo Oy flash smelter at Garfield, Utah, heralded as the "cleanest smelter in the world". This new US$800 million smelter and converter complex, which is able to handle 100% of concentrates produced at the Bingham Canyon Mine, replaced an existing facility that was only able to handle 60% of concentrates (Warhurst and Bridge, 1997). Environmental complications also occur with mine wastewater, which must be treated for chemicals, sediment, metals and pH before it is discharged into the natural environment. Among the most challenging water pollution problems is Acid Mine Drainage (AMD), which forms when sulphur-beating rocks are mined and expo,~edto oxygen and moisture, producing an acid that leaches naturally occurring metals from waste rock. These toxic metals then accumulate in the environment, and effluents containing the metals are discharged into waterways from milling and smelting operations, impacting the overall water quality of surrounding waterbodies and threatening wildlife. A number of authors (Gray, 1997; Gazea et. al, 1996; Robb and Robinson, 1995) have reviewed the many different treatment options available for AMD. The

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conventional remedy emphasizes the use of naturally occurring geochemical and biological neutralizing agents (e.g. bicarbonate rocks, wetlands, etc.) but increased levels of mineral production in recent years have rendered these standalone treatment methods ineffective. Today, the AMD abatement technologies that yield the cleanest results are fully automated water treatment facilities and bioremediation processes. At AMD water treatment facilities, lime is added to the contaminated mine water, forming a neutralized sludge, which is then pumped into a pond where it settles, materials separate, and water is decanted (UNEP, 1996). Bioremediation techniques utilize acidophilic microbes on AMD to neutralize wastewater (Johnson, 1995; Umita, 1996). Since acid consuming microbes exist naturally in the environment, the idea here is to use these species to treat the toxic AMD. Bioremediation processes produce detoxified effluents, and wetlands, which feature a number of microbial and biochemical processes, are one of the most practical platforms for performing these techniques. Surprisingly, utilizing wetland technologies does not impact the animals living in them. Albers and Camardese (1993) demonstrated that in wetlands treating AMD, metal concentrations in invertebrates were independent of water chemistry. However, to avoid any ecological problems or concerns, industrial wetlands can be artificially constructed solely for AMD detoxification purposes. A final note on cleaner technologies in the mining industry is that in several refining processes, toxic industrial chemicals are used. Examples include cyanide, mercury, and surfactants, each of which if discharged untreated into the natural environment, would pose a threat to ecological entities. Often, using certain chemical treatment technologies to detoxify these industrial chemicals creates additional environmental cleanup challenges. The cleaner chemical detoxification technologies, however, produce very little waste as a result of treatment, and individually pose very little ecological threat. Examples of CP practices in the mining industry

In the mining context, CP practices are simply those that lead to a reduction in mine wastes, result in an improvement in production efficiency, or put a mine in better position to integrate cleaner technologies into operations. They include everything from a comprehensive environmental management system (EMS), through detailed environmental audits, through environmental monitoring, to technological assessments. Equally important is the restructuring of employee training programs to account for key pollution prevention and waste minimization issues. As Venselaar (1995) notes, CP requires the involvement of all employees in an industry, including those who research, purchase materials, design environmental equipment, make installations, and run and manage the final technological setups. If everyone works toward common CP goals, the likelihood of making environmental progress is greater. Often, practices that lead to improved process control at mining and smelting operations can be as effective as direct cleaner technology implementation. For example, a study conducted by Lara and Resendiz (1998) on a grinding section of a concentrator plant in Mexico projected to treat 10,000 tons per day of a lead-zinc ore showed that optimal operation could be achieved with half the water input, more than half of the circulation load percentage, and a coarser grain than that of a "standard" operation of equivalent size. In another example, Sudholter et al. (1996) used an optimization technique to generate optimal flow sheets for the production of zinc under varying constraints, including operation costs, metal prices and environmental expenses. The authors showed how, using a practical model, processing routes could be created not only for residues from the zinc industry but also for zinc containing residues from other processes. In summary, improved process control cannot only lead to economic savings and marked improvements in operational efficiency, but more importantly, reduced environmental pollution. WHY THE NEED FOR CLEANER TECHNOLOGIES AND CP STRATEGIES AT MINES IN THE AMERICAS?

It is well recognized that important environmental strides have already been made at many mines in the Americas. Since the beginning of the mainstream global environmental movement approximately 30 years ago, these mines have significantly reduced air emissions and effluent discharges, implemented more stringent reclamation plans, and have detoxified and restored a number of damaged landscapes and waterbodies. The most significant corporate environmental changes, however, have occurred in recent years. A combination of governmental pressures, increased societal expectations, and changing regulations have caused many mining operations in the Americas to implement a number of CP practices, and replace

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conventional aba~tementequipment with cleaner technologies. In mining districts such as Sudbury, Ontario, Canada, the installation of cleaner technologies has helped stop a century-long pattern of industrial environmental degradation. Here, as a result of multimillion-dollar industrial pollution abatement programs (Boullion, 1995):, SO2 emissions have been reduced by approximately 90% since 1960 and surrounding landscapes have responded positively to reduced environmental stress. However, environmental improvement thus far has been site-specific, as other mining districts in the Americas continue to release large quantities of toxic pollutants into the natural environment. For example, in Amazonia, ow,~r3000 tons of atmospheric mercury has been released from gold mining activities since 1979, and in the Choco and Narino regions of Columbia, an additional 248 tons has been released since 1987 (Lacerda, 1997). In the United States, a 1995 study conducted by the US Environmental Protection Agency (EPA) revealed that 72% of metal mines and 30% of nonmetal mines had committed at least one legal violation in that year (EPA, 1995). In 1998, Environment Canada, a science-based governmental department, reported in its National Pollutant Release Inventory (NPRI) an equally astonishing fact about Canadian metal raines. The amount of waste (not including national delisted chemicals) managed by these mines had increased 45%, from 2,318,851,086 lbs to 3,365,553,638 lbs between 1991 and 1997 (EC, 1998). Problems with waste could very well worsen considering that regional production of a number of important minerals is increasing annually (Table 1), along with the number of mining operations. For example, in Canada, the number of mining operations, from 1982 to 1996, nearly doubled, increasing from 490 to 727 (NRC:, 1997), and in the US, the number of mines in operation in 1997 totaled 11,600 (Moore, 1998), up from 10,707 in 1987 (US Department of Commerce, 1996). In view of the significant rise in mineral production, and increase in the number of mining developments in the Americas, it is imperative that, to ensure current patterns of environmental degradation are stopped, and that future industrial pollution is kept at a minimum, each site implements a number of highly effective cleaner technologies and CP practices. As already indicated, a number of mines have already made key environmental strides but others lag far behind, the major problem being that these mines face a number of barriers that prewmt direct implementation of cleaner technologies and CP strategies. In most cases, these mines perceive these obstacles as being insurmountable and in turn are discouraged from being environmentally proactive. The barriers are in large part responsible for an uneven pattern of environmental behaviour in the region's mining industry, with some mines performing at high environmental levels, others operating in line with governmental regulations, and the balance simply ignoring environmental issues entirely. The major barriers preventing implementation of cleaner technologies and CP practices at certain mines in the Americas have been identified as legislative, technologic, and economic. Each is examined in detaiil in the discussion to follow. T A B L E 1 Production increase of selected minerals/mineral ores in the Americas, 1986-1995

Mineral/Ore Tin-bearing ore (tons)

1986 total 44,365

1995 total 56,202

% Increase 27

Gold-beating ore (kg)

349,760

743,598

117

Zinc-bearing ore (thousands of tons)

2387

3183

33

Nickel-bearing ore (tons)

245,147

260,960

6.5

Bauxite (thousands of tons)

19,347

31,683

64

Copper-bearing ores (thousands of tons)

3861

5840

51

Iron-bearing ores (thousands of tons)

190,923

209,807

9.9

Lignite coal (thousands of tons)

93,340

114,847

23

Sources,: UN, 1996; World Economic Factbook, 1996)

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LEGISLATIVE BARRIERS Stringent environmental legislation The mining operations in the more industrialized regions of the Americas - Canada and the United States are subject to a diverse set of strict environmental regulations. The first significant national environmental laws affecting mineral operations were passed in the 1970s but a number of stricter mandates have since been implemented at both federal and provincial/state levels. In the United States, most environmental standards exist at the federal level and are set by the EPA. Mines are regulated by number of stringent, overlapping environmental laws, including the Resource Conservation and Recovery Act (RCRA), the Clean Air Act (CAA), the Clean Water Act (CWA), the Endangered Species Act, the Surface Mining Control and Reclamation Act (SMCRA), and, in selected instances, state coal and hardrock requirements. Another significant environmental statute is the National Pollutant Discharge Elimination (NPDES) Program, which was established under Section 402 of the CWA in 1979. The NPDES Program adds another complexity because it requires industry--in this case mines--to obtain permits for all point sources from which pollutants are discharged into navigable waters (Alder et al., 1993). An equally diverse regulatory environment exists in Canada. In 1977, national aquatic environmental standards--the Metal Mining Liquid Effluent Regulations (MMLER)--were established for mines, and were promulgated under the federal Fisheries Act and embodied in the "Consolidated Regulations of Canada", 1978, Chapter S19 (EC, 1988; EC, 1992). Most of the additional environmental legislation pertinent to mining activity in Canada exists at the provincial level. In Ontario, for example, the principal piece of environmental legislation regulating mining activity is the Municipal/Industrial Strategy for Abatement (MISA), a requirement based upon the Ontario Environmental Protection Act that has industry monitor its' wastewater discharges for acute lethality to rainbow trout and Daphnia magna. In 1986, the Ontario Ministry of the Environment (MOE) developed the MISA program in an attempt to reduce the quantity of pollutants being discharged from industrial and municipal sources into Ontario's lakes and rivers. Requirements for toxicity testing are identified in the General Effluent Monitoring Regulation (Ontario Regulation 695/88) and in the Effluent Monitoring Regulation for the Ontario Mineral Industry Sector (Ontario Regulation 491/89). In the case of Quebec, in 1989, the government, under its Environmental Quality Act, issued Directive 019, which addresses the environmental and permitting aspects of all provincial mines. Principally, the Directive requires that final effluent discharges from all mines meet or exceed the MMLER, as well as meet the following limits: 3.0 mg/L total iron, 1.5 mg/L total cyanide, 0.1 mg/L free cyanide, and a pH between 6.5 and 9.5 (GQ, 1989). In BC, the government, in 1979, issued "Pollution Control Objectives for the Mining, Smelting and Related Industries" under the provincial Pollution Control Act, which addresses both effluents and air emissions from mines. Further, as indicated under Section 10 of BC's Mines Act, a mine must apply for, and obtain, a permit from the Chief Inspector of Mines prior to mining or significant ground disturbance. This regulatory philosophy, although strict, appreciates that every mine has a unique set of geological and environmental conditions and is therefore evaluated on a site-specific basis. Table 2 provides a summary of major mining environmental legislation in the US and Canada. The strict environmental regulations in both the US and Canada require mines to have a number of highly effective and sometimes costly environmental safeguards in place in order to achieve compliance. Further, adhering to strict legislative demands often requires mines to develop comprehensive management plans, install expensive environmental technologies, and hire outside expertise. While many of the larger North American mining companies such as INCO, Noranda, Placer Dome Inc., Newmont Gold Company, Homestake Mining Company, Barrick Gold Company, Falconbridge Inc., and Rio Algom Inc., have implemented a wide range of environmentally proactive cleaner technologies and CP strategies at their sites, a number of small- and medium-sized mining operations face enormous economic and technologic challenges in achieving legislative compliance, let alone in being environmentally proactive. In a personal communication with a manger at a Nevadan mine, it was indicated that "economic pressures" led to the abandonment of"cyanide detoxification methods on gold heap leaches", deemed as being the "cleanest" of cyanidation technologies, and subsequent adoption of less-expensive chemical detoxification methods instead, which "are more prone to environmental degradation". In another communication with a manager from a small Californian mine, it was indicated that "overlapping state and national regulations wasted

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TABLE 2 Examples of environmental legislation affecting mining operations in Canada and the US Country/Region

Year

Metal Mining Liquid Effluent Regulations (MMLER)

Canada/National

Implemented 1977

Environmental Quality Act

Canada/Quebec

1989

Municipal and Industrial Strategy for Abatement (MISA) Pollution Control Act

Canada/Ontario

1986-88

Canada/BC

1979

Clean Air Act (CAA) Clean Water Act (CWA)

USA/National USA/National

1970 1979

Resource Conservation and Recovery Act (RCRA)

USA/National

1976

Surface Mining Control and Reclamation Act (SMCRA)

USA/National

1977

Law/Regulation

Description Are the national environmental regulations for water effluent discharges from mines (except cyanideusing operations) Quebec's main provincial environmental mandate (Developed in 1986) Are Ontario's regulations for wastewater discharges Addresses both effluents and air emissions from mines Air pollution control Uses the National Pollutant Discharge Elimination System (NPDES) to regulate direct industrial discharges into navigable waters Addresses problems with the disposal of hazardous and solid wastes Provides a framework for a national regulatory program to prevent environmental damages from surface coal mining

millions of dollars because of an over commitment of funds". The staff of smaller mining operations in these strict regulatory environments, therefore, have limited time to make an inventory of emissions and waste streams, let alone identify possibilities for cleaner technologies and improved CP practices.

The changing regulatory environment A frequently changing regulatory environment can make the selection process for environmental technologies even, more difficult. A mine utilizing cleaner technologies has invested with the purpose of performing at environmental levels beyond the legislation. Most installations require substantial capital investment, which increases financial outlays in the short term (EPA, 1995). The idea behind investing, therefore, is to receive a return on investment over the long term as a result of performing at a higher environmental level. Changing regulations, however, can turn preexisting cleaner technologies into compliance investments (Howes et al., 1997), and a mine, by being anticipatory in the environmental management arena, can end up wasting funds, valuable resources and time.

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G. Hilson

TABLE 3 Examples of major amendments made to North American environmental legislation relevant to mining activity

1977

Amendment US CWA is amendedto address toxic pollutants; NPDES Program established under Section 402 First Amendmentsmade to the US CAA NPDES is revised to include BMPs

1979

US RCRA is revised for the first time

1980

RCRA is modifiedto account more heavily for hazardous wastes

1984

RCRA is modified again: under Section 3004(b)(3), it becomes illegal to dispose of any hazardous liquid waste in temporary disposal areas

1985

Compliance deadlines are modified in the NPDES; RCRA is modified under 3004(d)(2)

1987

Ontario water effluent Regulation 358/88 is replaced with more stringent Regulation 695/88; Quebec's Environmental QualityAct is changedsignificantlyto more heavily regulate gold mines

1988

Ontario MISA Regulation491/89 enacted; Thirty-eight amendments made to BC's Mines ACt

1989

Second group of amendments made to the US CAA

1990

NPDES is modified (under Regulation 55 FR 47990) to address point source discharges of storm water; MISA Regulation 591/89 is amended; US CAA amended for the second time

1992

One amendment(1992-82-165) made to BC's Mines Act; NPDES adds 402(p)(2)(B), which requires point source discharges of storm water from industrial facilities to be permitted

1994

MISA Regulation 560/94 is promulgated, setting new environmentalstandards for gold mines; Two amendments made to BC's Mines Act (1994-43-38 and 1994-43-40)

1995

One amendmentmade to BC's Mines Act (1995-53-26)

1998

Section 38(2) of the Mines Act is modified, making the permitting systemmore strict

Present

MISA regulations and MMLER in process of bein~ modified

Year

In both Canada and the US, which are already the most stringent regulatory environments in the Americas, new mining performance standards are constantly being set because environmental legislation is regularly being amended (See Table 3). A frequently changing regulatory climate, which obstructs long-term environmental plans, can discourage a mine from implementing cleaner technologies and CP strategies. For smaller mines, which already have limited resources, from a business management and economics standpoint, rather than wasting time, energy, capital, and resources to re-establish proactive corporate environmental "position", it makes more sense to simply operate in line with the standard set by the environmental legislation, and to change operations only when necessary.

Absence of strict environmental regulations Conversely, Developing Countries typically do not have strict environmental regulations, nor do they have effective enforcement programs in place. Further, o f the environmental legislation that has been implemented, most is not comprehensive and lacks definition. The principal weaknesses o f Third World environmental legislation have been identified as follows (de Nova, 1996): • • • • •

A lack o f clear, continuous policies to support waste minimization and CP Incomplete regulatory frameworks and uneven enforcement Ignorance o f the characteristics o f industrial production processes No clear understanding o f the difference between compliance investments and cleaner technologies Inefficient coordination among different governmental agencies at different levels

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Poorly developed environmental mandates, along with low levels of community environmental awareness give mines little incentive to implement cleaner technologies and CP strategies in Developing Countries. The Developing Countries of the Americas lag far behind the Industrialized US and Canadian nations as far as national environmental laws and policies are concerned. A survey reported by the World Bank in its 1992 publication Environment and Development in Latin American and the Caribbean found that, in 1992, only 50% of Latin America was in the process of considering implementing general environmental legislation (Jansen, 1993). Even the Developing Countries in the Americas that have already implemented some sort of national environmental pollution plan or strategy have only done so in recent years (Table 4), as compared to tlae US and Canada, where effective environmental legislation has been in place for close to three decades. In addition, many of the regulations that have been implemented tend to be of the blanket type, which specifies maximum levels of emitted substances, minimum levels of environmental quality, and best availablte technology, rather than reflect the propensity of a particular operation - in this case a mine - to pollute (Warhurst, 1994a). This has lead to, more often than not, the development of less stringent national policies and laws. For example, Mexico's General Law for the Ecological Balance and Protection of the Environment, which was passed only in 1988, is a very broad piece of legislation that makes it mandatory to file an environmental impact statement and to obtain governmental approval prior to any industrial activity. Shortly after the passing of this Law, in June of 1988, the Mexican Government published a list of products and substances deemed as hazardous wastes, and the Federal Executive, later in that year, issued regulations on air pollution and these hazardous wastes (Hernandez, 1997). The goal was to regulate all of industry under a broad web of legislation that used best available technology - which, in Developing Cotmtries falls far short of the equipment used in Developed Countries - to set environmental regulations. The legislation, consequently, is not very comprehensive, and has done little to improve environmental conditions in the country. In another example, Chile, environmental protection has only recently gained governmental attention, and as Lagos (1997) reports, although there were some environmental concerns made in the private and public sectors in the mid-1980s, it was not until the 1990s that these concerns led to any actions or investments. Chile's National Commission of the Environment, though established in 1990, was only granted authoritative power in 1994. The Commission identified, between 1991-92 some 2200 environmentallyrelated laws and regulations in Chile, and concluded that most were either out-of-date, not applied, or that their application was subject to the individual decision of some official or regulatory ageney. Some legislation has been passed in recent years, including Decrees 4 and 185 (air pollution), and Law number 19.300 (hazardous waste), but overall, only a small number of environmental laws have been enacted in Chile since the e,,;tablishment of its Commission. If environmental protection is not of national concern, why should mines invest in cleaner technologies and implement CP practices? For the most part, the biggest problem in these and the other Developing Countries of the Americas has not been with the multinationals, which generally operate at the same environmental level throughout the world, but with the small and medium-sized local operations that are competing with these companies. While individually, each is a relatively small polluter, collectively, the group accounts for a disproportionate amount of the environmental pollution produced in a number of countries' mineral and mining sectors. With limited governmental pressure for industry to perform at high environmental levels, and with most governments unfamiliar with such concepts as "waste minimization", "Cleaner production", and "pollution prevention", local mines have little reason, at least from a regulatory standpoint, to install conventional end-of-pipe remedies, let alone implement cleaner technologies and CP strategies. "Loose" environmental legislation is not perceived as being a major problem by these companies but is a major obstacle for selected governmental and environmental groups, international organizations, and independent agencies seeking to improve industrial environmental performance.

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TABLE 4 Governmental environmental commitment in selected developing countries in the Americas

Year Implemented 1992

Environmental Protection Agency or Administerin~ Bod~/ Secretariat for Natural Resources and Human Environment

1994

Congress

1995

Brazilian Institute o f Environment and Renewable Resources

Chile

Environmental Strategy or Action Plan Implemented Sistema Federale Ambiente (SFA), National Environmental System General Environmental Law of Bolivia Amended Sistema Nacional do Meio Ambiente, (SISNAMA) National Environmental System Assorted Laws

1991-91

Columbia

Law No. 99

1993

Mexico

General Law for the Ecological Balance and Protection of the Environment Environmental Penal Law

1988

National Commission of the Environment Columbia's Environmental Ministry Congress

Country Argentina

Bolivia Brazil

Venezuela

1992

Renewable Natural Resources Ministry

Sources: World Bank, 1999; CEC, 1996)

TECHNOLOGIC BARRIERS Technologic and information gaps

In addition to marked legislative differences, there are obvious information and technologic gaps that exist between the Developed and Developing Countries of the Americas. From the standpoint of environmental protection, many South American and Latin American mining companies have an insufficient knowledge of CP, and of the many cleaner technologies available on the international market. More importantly, with many of these countries' governments being virtually inactive in the environmental management arena, there has been very little promotion or dissemination of cleaner technologies and CP. As long as information about waste minimization and pollution prevention does not reach individual mines, industrial environmental performance will remain stagnant. The environmental performance of regional small-scale gold mining operations effectively illustrates how technologic and information gaps have hindered CP in the industry. Although cyanide has been the leach reagent of choice for the extraction of precious metals for over 100 years (Mosher and Figueroa, 1996), in many South American countries such as Brazil, Columbia, and Venezuela, most small artisanal mines opt to use toxic mercury instead in spite of the well-documented environmental problems and health risks associated with its use (Akagi et al., 1995; Maim et al., 1995; Porcella et aL, 1997). Small-seale gold miners typically refine gold very carelessly, allowing mercury to escape undetected into the air, freshwater environments and soils. It is estimated that in Brazil alone, close to 80 tons of atmospheric mercury is emitted from gold mining operations each year, accounting for approximately 67% of national atmospheric releases of mercury (Lacerda and Marins, 1997). Veiga et al. (1995) describes some educational measures - including visual communication media, meetings and courses - that have been implemented in some Brazilian institutions to address environmental concerns associated with mercury emissions but overall, these have been marginally effective in reducing mercury contamination from gold mining simply because effective abatement technology is not readily available. Cyanidation setups are a more environmentally benign alternative that typically features a number of highly efficient environmental safeguards, such as monitoring systems and pad liners but each requires much more technical skill than simple mercury amalgamation techniques (Veiga and Meech, 1999). Although with outside assistance, cyanide plants could

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be built for use in small mining communities, given the current rate of technologic diffusion in many South American countries, it is highly unlikely that cleaner cyanidation technologies will ever fully replace amalgamation techniques. In both Canada eaad the United States, there is a consortium of professionals, researchers, and technical experts employed by mining companies, governmental organizations, academic research units, and environmental organizations that are working toward common environmental goals. This in turn has led to the development and implementation of highly advanced, multimillion-dollar pollution abatement technologies and strategies at many North American mine sites (Table 5). In the Lesser Developed

TABLE 5 Examples of technical pollution abatement apparatuses and comprehensive pollution prevention plans developed by selected North American mining companies Mining Company INCO ltd.

Technical Development or Environmental Plan Smelting Complex

INCO Ltd.

INCO SO2/cyanide destruction process

Homestake Mining Company Falconbridge Ltd.

Mine tailings containment Smelting technology

Noranda

Continuous converter

Noranda

Wastewater treatment facility

Description US$530 million investment to reduce SO2 emissions An expensive method, developed and patented by INCO, to treat industrial waste streams US$70 million facility A total of US$7 million spent in 1995 to modify mills and smelters to better control emissions Copper smelter/ emissions control CANS11 million, constructed in 1998

North American Location Sudbury, Ontario, Canada Used by different mining companies, mostly in Developed Countries Grizzly Gulch, South Dakota, USA Sudbury, Ontario, Canada

Rouyn-Noranda, Quebec, Canada Brenda Mine, BC, Canada

Countries of Latin America and South America, where environmental concerns fall much lower on corporate and governmental agendas, there is an obvious shortage of management and technical expertise, and consequently: fewer highly efficient pollution prevention apparatuses are found at mine sites. Further, many of the treatrnent and control measures that have been installed are replicas of the site-specific models designed for use at North American sites, and have therefore not been nearly as effective.

Technological awareness and expertise The OECD has identified ignorance of the environmental and commercial potential of cleaner technologies, and a lack of necessary expertise as additional barriers to pollution prevention (Irwin and Hooper, 1992). Environmental technologies can be taken for granted, and may continue to operate for decades without being reexamined. Many mines in the Americas do not have the information systems in place to allow them to identify the areas where cleaner technologies can be utilized, and CP strategies implemented. The recent cleaner technological development and CP research in areas such as bioremediation, water treatment, scrubbing, and heap leaching appears very promising but with so many mines lacking effective information systems, it could take years before this environmental information and data even reaches these operations. In the event that possibilities for cleaner technologies and CP have been identified at some of these mines, an additional ob.~tacle faced is a shortage of expertise. Staff must understand the purposes of waste minimization, as well as technical possibilities. Further, changes to conventional technologies could render existing workers and managers obsolete (OECD, 1995), and would require additional investment by mines into training programs for personnel, or a hiring of outside help. Since many cleaner technologies and CP programs are million dollar investments alone, staffing problems pose additional challenges to firms with

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limited budgets and resources, and can therefore permanently sway many operations away from researching and developing pollution prevention practices.

ECONOMIC BARRIERS Shortage of financial incentives

Since many mines have limited knowledge of cleaner technologies, and are quite content with their environmental compliance investments, incentives are needed to help shift the industry into a mode of CP. Specifically, schemes for f'mancial assistance that are procedurally simple and easily accessible (Frijns and van Vliet, 1999) to even the smallest of operations are needed to initiate a movement toward CP. So many regional governments, however, lack knowledge of key pollution prevention issues, and do not have the infrastructure and funds needed to promote waste minimization in industry. As long as financial assistance is unavailable, many mines in the Americas will be unable to implement the cleaner technologies needed to improve environmental performance. Additional economic constraints

Additionally, economic constraints are preventing many mines from installing cleaner technologies, and are the most significant obstacles confronting the properties of the Junior Mining Companies in the Americas. These small-scale operations typically utilize conventional pollution abatement technologies, which require less capital investment, less development, and less disruption to production processes than cleaner technologies (Irwin and Hooper, 1992). A shortage of investment funds restricts the research and development capabilities of Junior Mining Companies, resulting in very little movement toward CP. Installing a water treatment facility of similar efficiency to the US$10 million plants Noranda Inc. has constructed at many of its mines, or implementing a pollution abatement program of similar magnitude to INCO's US$600 million plan of the early 1990s, is completely unrealistic for Junior Mining operations, which simply lack the funds, resources, and flexibility to do so. Without financial assistance, these properties will never come close to installing cleaner technologies, nor will they be able to stay ahead of the environmental compliance curve for extended periods of time. Market pressures also play an important role in a mine's selection of its environmental technologies. This is best exemplified by the recent crash in gold stocks, which in turn has impacted environmental protection at many gold mines in the Americas. In a personal communication with a manager at a Canadian gold mine, it was indicated that severe cash shortages forced the operation to shift into a mode of regulatory compliance because no funds were available to invest in proactive technologies. Three other managers from US sites expressed the same viewpoint. Since the mining industry is unable to control the value of mineral commodities, severe downturns in market prices can affect how mines are managed environmentally.

ANALYSIS Industrial efforts

Although a number of factors can play important roles in influencing industrial environmental improvement, progress made toward waste minimization is entirely dependent upon what initiatives are taken by an industry - - in this case, mining. To date, most of the region's effort toward improved environmental protection in the mining industry has been made in North America. For example, the Mining Association of Canada (MAC), the national organization of the Canadian mining industry, has published a number of practical waste management guides, and has developed several environmental guidelines for its members. For example, the Guide to the Management of Tailings Facilities helps mines integrate environmental and safety considerations in a consistent manner (ARET, 1999). In the US, the EPA's Office of Pollution Prevention and Toxics funds a number of pollution prevention projects related to mining activity. Further, a number of technical documents that detail methods to promote pollution prevention at mines have been produced by the industry with assistance from the US government.

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In certain South American and Latin American countries, some effort is being made to promote CP, although not specific to the mining industry. Von Amsberg (1997) summarizes some of the efforts being made in Argentina, Brazil and Chile. In Argentina, projects with important environmental implications have been undex~mken by INTI, the national industrial technological instittlte, and INCYTH, the national institute for water science and technology. Some important CP initiatives taken include water reuse, waste minimization and non-conventional wastewater treatment. In Brazil, BNDES, the development bank of the national government, has, since 1986, offered credit lines to support industrial pollution control. Among the projects eligible for financing include end-of-pipe technologies, process changes, and recycling/recovery projects. In Chil(;, the INTEC, a government technology research agency, is currently developing a specific project that aims at strengthening national technological capacities for treatment of liquid industrial effluents. The project assists small- and medium-sized enterprises in pollution reduction through either endof-pipe technology or CP solutions. In the case of Mexico, an important regional CP initiative has been the establishment of the Mexican Centre for Cleaner Production, a joint venture between the National Polytechnic Institute of Mexico, the Transformation Industry Chamber of Mexico, UNEP and UNIDO. The main objective c,f the Centre is to promote the dissemination of clean technology schemes throughout the country (Guadan:ama, 1997). A major problem as far as mining is concerned is that these and many of the other regional efforts fail to address the barriers preventing implementation of cleaner technologies and CP strategies. Further, few address the neec[~ of small-scale mining and Junior mining operations. For example, the MAC is comprised of only Senior mining companies that have pledged to improve environmental performance at their sites simply because each has the funds, technology, and personnel - - hence the ability - - to shift into a more proactive mode of environmental management. In another case, Chile, the government has established the Empresa Nacional de Mineria (ENAMI) in an attempt to promote mining activities and contribute to the sustainability of small- and medium-scale mining but as McMahon et al. (1999) indicate, ENAMI has centred its relations with the mines and plants on commercial aspects, while totally ignoring environmental aspects. With so many smaller mining operations in the Americas, for the industry to realistically move into a cleaner mode of production, plans and programs must be developed that emphasize methods for these sites to overcome the legislative, technologic and economic barriers identified in this paper. The need for an expanded governmental role

In the long-term, CP is a win-win scenario for both business and the environment. However, if mines with limited flexibilit2/and resources are not provided any outside assistance, each will be unable to retrofit endof-pipe equipment, install new environmental technologies, and implement improved CP management practices. Since operations, individually, are unable to make the change, there is a need for regional governments to play an expanded role in promoting CP. Initiative must be taken somewhere, and it makes sense for regulatory agencies to assume the leadership role because if an issue is not of national interest, it makes it very difficult to initiate any internal change. Quite simply, unless governments begin sending clear signals that mov,~ment toward CP is a major goal of both economic and environmental policy (Yarowitz, 1997), there will be very little incentive for mines to investigate and implement cleaner technologies and CP practices. IVlany of the barriers identified in this paper could at least be partially removed if governments simply do the following (Yarowitz, 1994): • • • • • • • •

Obtain and disseminate the appropriate information concerning cleaner technologies and strategies, and outline their economic aims Engender strong public support for economic development based on cleaner technologies by providing information and educational materials Provide documented results of successful cases Arrange deraonstration projects Ensure that banks, insurance companies and other lending institutions favour cleaner technologies and CP practice.,; in their investment decisions Develop and implement a CP certification system for products, processes and services Provide technical assistance to firms Work with universities and the private sector to develop managerial accounting systems for CP, pollution prevention and waste minimization

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For mines experiencing cash shortages and budget limitations, governments can develop schemes for financial assistance that are procedurally simple and accessible to even the smallest of operations. Providing financial and technical incentives such as levies, tax breaks, subsidies, and partnerships with educational facilities would further encourage mines to investigate possibilities for cleaner technologies. As von Amsberg (1997) notes, governments already have, among others, the following instruments at their disposal: • • • • •

Pricing policies for inputs such as water and energy, creating incentives to become more efficient Economic instruments such as charges or tradable permits Means of financing for the costs of pollution reduction, such as direct lines of credit, so firms can pursue CP investments Means to provide technical assistance to help companies understand life-cycle impacts, information dissemination, environmental audits and environmental certification Information policy such as mandatory release of plant pollution data.

Putting national CP policies into effect can be complicated and therefore, costly. However, with so many international organizations and agencies such as UNEP, the OECD and the World Bank promoting CP and pollution prevention, the formation of international partnerships are realistic possibilities. Further, seeing as how UNEP and the World Bank have already engaged in CP activity in a number of South American and Latin American countries, it is highly likely that organizational agendas can be modified to make mining more of an environmental priority area. In the US and Canada, both the US EPA, Environment Canada, and various provincial and state regulatory bodies must prioritize improving environmental conditions at mines owned by Junior Mining Companies and medium-sized mining companies. In strict regulatory environments, it is often argued that cleaner technologies and improved management practices pay for themselves over the long-term. For example, managers at Homestake Mining Company's McLaughlin gold mine in California, contend that innovative technologies and "best practices" in environmental management have not resulted in substantial extra costs, because each has helped improve the efficiency of the mine, which in turn has positively affected the economics of overall operation (Warhurst, 1994). Therefore, if "payback" schemes are developed, where governments help smaller mining operations finance cleaner technologies and CP practices, and require each to return portions of the borrowed money over a period of time, both parties benefit: the government from improved environmental performance, and the mine from improved efficiency. A blueprint for success

While governmental activity can serve as a catalyst for environmental change, regional improvement in environmental performance is solely a function of what action is taken at individual mines. Mines must begin planning the development of CP programs that address five major areas of business (adopted from Warhurst, 1999): 1) Policy Development and Institutional Relations -- specifically, working towards setting performance standards, establishing financial arrangements with donor agencies, and implementing efficient environmental management systems at sites. 2) Environmental and Social Impact Assessment -- using social indicators to monitor societal effects over time, and promoting stakeholder participation. 3) Technological Development -- promoting R&D, introducing life-cycle assessment to operations and developing technological solutions. 4) Company Strategy -- continuously improving management systems, monitoring predicted impacts and unexpected events, and designing incentives for employees to engage in environmental practices. 5) Education, Research and Training -- enhancing environmental awareness throughout the educational system and workforce, training for innovative community relationships, and collaborating with independent agencies. Once major weaknesses and opportunities for improvement have been identified within each of these core areas, simple management strategies can be devised that will lead to improved efficiency of operations, and ultimately, CP. Some general examples include (adopted from Fresner, 1998):

:Barriersto implementingcleaner technologiesandcleanerproductionpracticesin miningindustry • • • • • • •

713

Better logistics, and improved data availability of mine pollutants "Good" housekeeping measures, including installation of proper safeguards and implementation of better cleanup practices Substituting raw and auxiliary materials with less harmful ones that can be more efficiently recycled Modifying products and technologies to eliminate unnecessary production steps Making process modifications to minimize mine wastes and noxious emissions Reusing mineral processing materials, including water, antifi'eeze, industrial solvents and chemicals Introducing waste into external recycling networks: indus~a'ialecology

A final step is planning for full technological transformation - - i n this case, cleaner technological transformation - - which requires three broad plans of action. First, existing cleaner technologies need to be identified and assessed. This involves exploiting low-cost practices for pollution, waste and energy reduction. Second, investment options must be analyzed, along with other actions leading to the "next generation" of cleaner technologies. Finally, a plan for monitoring must be developed to ensure that cleaner technologies will play their appropriate role in global development over the long term. Once all of these important steps are taken into consideration, and careful planning is undertaken, an effective CP program can then be developed. Naturally, each CP program will vary slightly depending upon what is being mined and processed simply because each mineral demands the use of different environmental technologies. However, each program will have many similarities, outlining everything ~om organization, ~'ough implementation, to assessment. A plan for implementing a basic CP program for a mining operation is outlined in Figure 1. Select Imiiubon orevention options

EstaMlsh the nolluUon nrevenUon m-omlm | Make executive level decision and present

I Option generation

! Option des~iption

a policy statem,mt I Build consensus

I1kJ

I Technical/environmental I Economic

I Name the task force I Provide employ'.e training I State goals

I I

]~l.pxeJjmina~ as Efs..!.~JLt

Write summary aSSessment reuort(s)

I Collect data I Establish priorities

.l.mp.!m.e__n.t~ ~n

.w~t~tlumm~,m

! Select projects ! Obtain fundin s

I Define objectiw~s I Identify potential obstacles ! Develop a schecLule

Implement P2 opportunities ! Do post implementation

!

1 Mcasqre ~og~l

Do the waste ass~zmeat I Name the waste assessment team(s) t Review e ~ t i n g data I Begin input materials summary and waste stream characte:ristics t Visit the site(s)

I Do material, em;rsy and water balances I Do was~ stream summary

| Collect data | Analy'~ data varialJons I Analyze results

Maintain DoIluUon nreyenUon Droarllm

I Maintain internal communications I Reward employees

Fig. 1 Outline of a basic CP program for a mine.

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G. Hilson

Recommendations for further research

Overall, a number of cleaner technologies and CP options are available to mines in the Americas but as this paper has demonstrated, the process of integrating them into operations is not a simple one. Too many authors, in their discussions about cleaner technologies in industry - - mining operations included - review only the merits resulting from their use. Greatly overlooked are cleaner technology implementation plans, the potential barriers that prevent installation of equipment, and methods to overcome these barriers. Protecting the environment through cleaner technologies and CP practices may make good business sense but in order to do so, an operation must be physically capable of adopting the cleaner technologies in the first place. If research efforts are intensified in a number of key areas, it is likely that even the smallest of mining operations would be able to implement cleaner technologies and CP practices much more simply. The priority research areas are the following: 1) Developing "actions plans" for mines to follow to install cleaner technologies. 2) Developing methods to overcome the barriers identified as the major obstacles preventing implementation of cleaner technologies and CP practices in the mining industry. 3) Developing comprehensive educational programs that provide scope of cleaner technologies, their applications, and the benefits resulting from their use. 4) Developing economic instruments that can motivate both mines and government to implement cleaner technologies. 5) Investigating methods of promoting cleaner technologies in "loose" regulatory environments. 6) Developing CP plans for governmental use, i.e. the blueprints needed to promote cleaner technology utilization at mines, and in similar industries.

CONCLUSION In this paper, legislative issues, technologic constraints and economic limitations have been identified as the three major barriers preventing implementation of cleaner technologies and CP strategies at a number of mines in the Americas. Regional examples have been provided to illustrate the significance of each. In order to remove these barriers, regional governments must play an expanded environmental role, and make CP more of a national priority. At present, mines confronted by these barriers remain heavy polluters, or, at best, stagnant it terms of environmental performance. The paper raises questions about other mining regions of the world. Although in a number of countries, mines have improved substantially and continue to make significant environmental progress, in others, mines face similar legislative, technologic, and economic problems that are severely impeding progress toward CP. In these countries, governments must also play an expanded role in disseminating valuable information and technology to mines, and provide proper training so each property is in a better position to implement cleaner technologies and CP praetices.

ACKNOWLEDGEMENTS This paper builds upon ideas expressed in an article published by the author in Volume 8, Issue 2 of the Journal of Cleaner Production. The author wishes to thank Professor Markus Reuter, Professor Barbara Murck and Dr Barry Wills for their comments on an earlier version of this paper. The author would also like to thank Professor Virginia MacLaren and Professor Sonia Labatt for their valuable input.

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