Copyright 1999 by SME 1

SME Annual Meeting

March 1-3, 1999, Denver, Colorado
Preprint 99-47
THE STATE OF MINE CLOSURE: CONCEPTS,
COMMITMENTS, AND COOPERATION
T. Mudder
TIMES Ltd.
Bozeman, MT
K. Harvey
Bozeman, MT
ABSTRACT
The objectives for closure of a hard rock mine
include minimizing long term environmental liability,
attaining regulatory compliance, and maintaining
geotechnical stability, while closing as cost-effectively
as possible. Proper planning for closure should
come during the feasibility study, design and
permitting phases, and during operations as updates.
The lack of a proper or updated closure plan can
result in severe environmental and economic
consequences. Effective mine closure is the result of
a combination of innovative concepts, long-term
commitments, and multi-party cooperation. The
purpose of this paper is to discuss concepts,
commitments, and cooperation as they relate to an
effective closure plan.
INTRODUCTION
The objectives for closure of a typical hard rock
mine include minimizing long term environmental
liability, attaining regulatory compliance, and
maintaining geotechnical stability, while closing as
quickly and cost effectively as possible in a manner
that returns the land to a safe and stable
configuration for post-mining uses. Some of the key
features that must be considered during
decommissioning and closure of a mine could
include any underground workings, a tailings
impoundment, an open pit, surface waste rock piles,
and spent leach pads.
The environmental concerns surrounding each of
these features have changed dramatically over the
years with varying economic consequences to mine
closure. Of particular interest is the heap leach
operation and the related features of an open pit,
waste rock piles, and the spent leach pads. The
open pit has become a center of controversy due to
its physical aspects and the potential for becoming a
temporary or permanent water impoundment. The
resultant quality of the pit lake and its subsequent
classification becomes important as to "waters of the
state. The primary concern with waste rock piles is
the potential for oxidation of reduced sulfides and the
release of acid and metals contained in the drainage.
Lastly, there is the spent leach pad and its draindown
solution which contains cyanide, metals, and other
inorganic constituents. Although the fear of cyanide
prompted the initial regulations related to rinsing of
spent leach pads, it is the potential release of metals
and other inorganic constituents that have become
the major regulatory focus over the years. The
environmental issues related to closure of
underground workings, tailings impoundments, and
conventional milling operations present similar
challenges but appear to be less of an issue to the
public and the regulatory agencies.
Proper planning for closure should come during the
feasibility study, design and permitting phases of a
mine, and during operations as upgrades. This
approach has become the standard or is a required
practice today. The lack of a proper or updated
closure plan for a mine can result in severe
environmental and economic consequences.
Copyright 1999 by SME 2
Inadequate closure activities, water management,
and waste rock disposal plans have prompted
unexpected and, in some instances, unwarranted
secondary environmental impact statements or
assessments.
In other cases, the lack of proper planning for
closure has resulted in major changes to the required
reclamation bonding for a mine. More emphasis is
being placed upon the initial and ongoing bonding of
mining operations due to concerns arising from the
financial status of a company and the potential for
long term environmental damage from acid mine
drainage. The examples of improper management
and the related consequences are well documented
and are too numerous.
Beyond the direct economic aspects of inadequate
closure plans and bonding, are the indirect impacts
being felt by the mining industry. For example, the
State of Wisconsin recently passed legislation that
stopped further hard rock mining until an example
could be identified that had operated for ten years
and had been closed for ten years without any
environmental impacts to ground or surface waters.
In the State of Montana various referenda have been
put forth over the last two years, with the most recent
one calling for a ban on further open pit mines that
use cyanide. A few years ago there was a
referendum in South Dakota calling for complete
backfill of open pits to original contours. These types
of legislation are not generally prompted by concerns
over improper mine permitting or operation; they are
the direct result of issues related to improper mine
closure and abandonment.
Proper mine closure is the result of a combination
of innovative concepts, long term commitments, and
multi-party cooperation. Public education, in addition
to participation, is a major factor because in the
absence of knowledge, fear resides. The purpose of
this paper is to discuss concepts, commitments, and
cooperation which can be blended into an effective
and implementable closure plan.
CONCEPTS
There are many different words used to describe
closure including decommissioning, reclamation,
rehabilitation, and post-closure. In this paper,
decommissioning is referred to as the transitional
period between cessation of operations and final
closure. Reclamation refers to the physical aspects
of earth moving, regrading, and revegetation.
Rehabilitation is another word for closure used
primarily in countries other than the United States, for
example Australia. Closure is a term reserved for the
point in time at which revegetation has been
completed, excess solutions have been eliminated to
the extent practical, the maximum degree of passive
management has been implemented, and a final
surface and/or ground water monitoring program has
been initiated. The ability to "walk away" from a mine
site at closure is dependent upon the degree of
passive management that can be implemented, as
compared with long term operation of a mechanical
water treatment plant. Post-closure, a term often
used improperly, is the point in time beyond which no
further monitoring or passive management is needed
or required. The same basic concepts and terms
apply to the different types of mining operations at
any location.
The inability to "walk away" from a mine site at
closure has related primarily to the two issues of
water management and waste rock disposal. The
environmental and economic aspects of water
management and waste rock disposal during
decommissioning and following closure of a hard
rock mine have not always received the level of
attention warranted during project development and
operation. Historically, the focus of decommissioning
and closure has been on physical reclamation and
revegetation. In coal mining, these issues are of less
concern than for hard rock mines, due to the practice
of continuous reclamation. Both open pit and
underground hard rock mines have incurred
unexpected and increased levels of expenditures and
environmental liability at the end of active operations,
at a time when revenues can be declining. The
single most important issue which directly affects all
other aspects of closure is water management.
Often a mining operation, and in particular an open
pit heap leach facility, can operate with a "zero" water
balance due to evaporative losses and the wetting of
ore. As a result, there is initially no need for a
discharge permit and a major regulatory issue is
circumvented. But as decommissioning and closure
approach, the site water balance remains as before,
but the entire water management system is replaced
by the need to eliminate large stored inventories. A
common misconception regarding the mine site water
balance stems from the belief that water
management is automatically successful if annual
evaporation exceeds precipitation.
In wetter climates, the management and elimination
of the relatively large solution inventories present a
number of challenges due to the continued
accumulation of runoff within underground workings,
open pits, and tailings impoundments; infiltration
through surface waste rock; and long-term draindown
from spent leach pads. Although the historical
Copyright 1999 by SME 3
approaches of continuous fresh water rinsing or
recycle of treated water through a spent leach pad
adequately addressed the standards associated with
WAD cyanide or pH, they did not always satisfy the
regulatory requirements for metals or other inorganic
constituents. Each open pit heap leach mining
operation presents a unique set of circumstances for
consideration during decommissioning and closure.
Based upon a thorough understanding of the quantity
and quality of remaining solutions and application of
proven water management and treatment concepts,
a suitable closure scenario can be designed and
implemented. The water management and
treatment concepts range from enhanced
evaporation, to land application, to passive and
mechanical treatment. An excellent handbook for
minesite water management has been recently
published in Australia (Minerals Council of Australia,
1997). Of equal importance and concern is the water
balance situation created at temporarily shutdown
mines.
In addition to solution and water management,
long-term commitments are needed with respect to
reducing infiltration through surface waste rock piles,
spent heap leach pads, and tailings impoundments
through design and construction of appropriate
synthetic or natural barriers and revegetative covers.
Depending upon the site water balance and the
management of sulfide containing waste rock during
operations, unnecessary and expensive long-term
commitments to water treatment may occur during
decommissioning and following closure.
The direct impacts of treating acid mine drainage
and indirect negative publicity associated with it are
substantial. In a recent report prepared by the Office
of the Supervising Scientist and the Australian Centre
for Minesite Rehabilitation Research, an in-depth
evaluation of the anticipated cost of treating acid mine
drainage was presented. The total economic liability
could reach $A80,000,000 per year with an overall
liability to the industry nationwide of about
$A1,000,000,000 over the next fifteen years (Harries,
1997). The economic estimate to deal with acid mine
drainage for the Canadian mining industry has been
placed at $C2,000,000,000-$C5,000,000,000
(Feasby and Jones, 1994; MEND, 1995; and MEND,
1996). Although comparable values are not available
for the United States, the Bureau of Mines estimated
that several thousand miles of surface waters had
been impacted by acid mine drainage, the treatment
of which was costing the mining industry over
$US1,000,000 per day nationwide (Kleinmann, 1991).
This cost of treatment translates into
$US365,000,000 per year, or nearly
$US4,000,000,000 over the last decade of this
century.
From a short term perspective, the prediction and
evaluation of pit lake chemistry and the associated
risks has resulted in substantial and unexpected
expenditures ranging from several hundreds of
thousands of dollars to over a million dollars. The
concern over pit lake chemistry stems from the need
to define its ultimate beneficial use and
corresponding standards. In many instances the
regulatory requirements are not well defined.
The traditional approach to closure of spent heap
leach pads has been to rinse continuously with fresh
water. Unfortunately, this approach has worked
acceptably for run-of-mine (ROM) materials, but not
so well for agglomerated pads. The cost of pumping
and recirculation of solution onto the pad has
become excessive as many more pore volumes of
rinsing are required than anticipated to achieve
standards for constituents other than WAD cyanide
and pH.
Another approach involves the recirculation of
treated solution to minimize pumping costs, but it has
become apparent that WAD cyanide and pH are not
the only constituents of concern, and that metals
standards are difficult to achieve with recirculation of
treated solution alone. In order to reduce the solution
inventory for closure, enhanced evaporation has
been a favored approach coupled with land
application and passive in-situ treatment.
A variety of technical concepts are available to aid
in the efficient and cost-effective closure of a heap
leach facility. A summary of the basic closure
approach for heap leach facilities is presented in a
literature publication (Mudder and Miller, 1998). The
major point to be noted relates to the unique and
varying situations that exist at different mining
operations and the fact that environmental concerns
change with time. As a result, closure concepts must
be modified periodically to reflect technological
advancements, to account for current regulatory
requirements, and to allow development of the most
cost-effective closure plan.
COMMITMENT
Although consideration of closure in association
with mine design and permitting is often required
today, there are some existing operations that do not
even have a conceptual closure plan, let alone a plan
that can be reviewed and updated on a periodic
basis. Without a closure plan, a new environmental
Copyright 1999 by SME Copyright 1999 by SME 4
assessment or the promulgation of a discharge
permit may be initiated. It is in the best interest of an
active mining operation to develop and periodically
review and update the closure plan and to modify its
internal accrual process so that unexpected
economic surprises do not occur at the beginning of
decommissioning. More emphasis is being placed on
not only the internal accrual process but the external
bonding requirements. In order to circumvent further
public intervention into the accrual and bonding
aspects of a mining operation, there needs to be a
commitment to conduct these periodic assessments
in a realistic manner. Commitments to an outdated
closure concept may actually cost the operation more
than necessary.
Commitments must also be kept with respect to
ongoing reclamation projects and waste rock
management programs during operations in order to
minimize long term environmental and economic
liability. Deviations from waste rock management
programs over time, with less solid sampling and
acid/base accounting, inadequate field classification
systems, and reduced in-place disposal methods can
result in increased costs at closure. There needs to
be a commitment not only to the overall closure
approach or concept, but also the individual
components of that approach, some of which involve
ongoing programs during operations.
With respect to physical reclamation there needs to
be ongoing revegetation studies and a commitment to
maintain topsoil stockpiles, and not inadvertent use of
this material for other purposes. There must be a
commitment to continued evaluation of closure
alternatives and continued education of
environmental personnel regarding the potentially
changing closure requirements. In some instances,
different phases of a single mining operation can be
permitted under different sets of regulations. The
industry as a whole must be open-minded to new
ideas, because without innovation there will be
stagnation.
From experience, the overall cost of closure based
upon total disturbed surface area of a mine site
typically ranges from about $US5,000-$US15,000
per acre. At coal mines the ongoing reclamation
costs generally range between about $US10,000-
$US15,000 per acre. At hard rock mines, the lower
range of closure costs is usually associated with arid
sites with rainfalls of only a few inches per year and
minimal waste rock issues. Depending upon the level
of water management and treatment required, along
with waste rock encapsulation and generation of acid
mine drainage, the overall closure costs raise toward
the upper range. In an annual company
environment, health, and safety report published by
Homestake Mining Company, the average company-
wide reclamation costs were reported to be about
$US13,600 per acre (Homestake Mining Company,
1996). A total of 136 abandoned coal mine sites
were reclaimed in Pennsylvania between 1980 and
1992 at a cost of about $US9,500 acre (Bogovich,
1992). An in-depth study conducted in Australia
revealed that the cost of managing sulfide wastes at
historical mine sites was easily double the cost
compared to if managed during operations. Based
upon the Summitville experience, leaving the cleanup
of historical mine sites to the government may not be
the most economical approach. In the absence of
ongoing commitment, there will likely be additional
costs.
The best approach toward maintaining a
commitment to closure, accrual, and bonding is
through the use of the environmental audit. Most
companies have some form of audit program, with
some being quite outstanding by involving both
internal and external technical and legal experts.
There is a need to commit to ongoing air and water
quality monitoring programs at a mining operation
without the tendency to modify the monitoring
programs for the sake of reducing costs. Monitoring
plans should be conducted for the purpose of
gathering the information necessary to make long-
term predictions. Monitoring requirements may
change over time, for example when analytical
detection limits get lower and lower.
If the mining industry does not commit to the
conceptual and cash requirements of closure, some
other entity will likely do it through either litigation
and/or regulation, with the potential promulgation of
more stringent bonding requirements. This
commitment must be accompanied by the continued
education of the public, replacing fear with
knowledge. Unfortunately, fear is often more
marketable than knowledge. In conjunction with the
closure of the Golden Cross Mine in New Zealand,
Coeur is publishing periodic updates to help the
public understand the rehabilitation process (Coeur
Gold NZ Ltd., 1998). The mining company
publication aids the decommissioning process during
a time when employees and local business people
have legitimate economic concerns about their future.
Often the resulting anxiety and stress expresses itself
as anger and resentfulness. Often, the economic
and emotional states of people are overlooked as
environmental issues are emphasized.
Copyright 1999 by SME Copyright 1999 by SME 5
COOPERATION
Above all, there must be both internal and external
cooperation and understanding between participating
stakeholders in the closure process. Consistent
cooperation, coordination, and communication results
in good corporations. There must be internal
understanding of concerns and cooperation between
the daily operational staff and the corporate
personnel. There also must be coordination and
cooperation among the mining, metallurgical, health
and safety, and environmental staff within the
individual operation. When there is a lack of
communication between management and the
workers, then the sag mill is replaced by the rumor
mill, with a reduction in productivity.
As decommissioning and closure of a mine
approaches after years of operation, the emotional
aspects become as important as both the economic
and environmental issues. Through a combination of
cooperation, communication, and coordination, a
transitional team should be assembled to
accommodate all aspects of decommissioning and
closure. Being humans, we tend to be more
comfortable with stability and routine; we have
difficulty during transitional periods.
From an external viewpoint, there must be
cooperation among the mining operation, the
community, and the regulatory agencies. Permitting,
operations, and closure often becomes time-
consuming due to mistrust, inflexibility,
misinterpretation, and a lack of closure concepts and
goals. The regulatory process has not kept pace with
the changing times. When cooperation fails, litigation
can prevail. Prolonged legal confrontations are not
productive and do not serve the purpose of protecting
the environment. Although lawsuits may benefit
certain personal agendas, they usually do not resolve
the long-term issues, and the environment and most
everyone else involved suffers as a result. There is a
tendency in the mining industry to not upgrade or
modernize a closure plan, since the need for a
simple technical revision has often resulted in a full
scale environmental impact assessment or
statement. Such a situation recently occurred at a
mining operation regarding its management plan for
sulfide waste rock. In addition, there is the impact of
other regulatory requirements (for example, from
Biological Opinions which are prepared regarding
endangered species at minesites).
Over the next decade, scores of mining operations
throughout North America and the world will begin
the decommissioning and closure processes. It is
important for politicians and the regulatory agencies
to consider the consequences of rigid and
prescriptive regulations. A cornerstone of our
modern society has been accepting and reducing
risks through innovation and imagination.
There is frustration within many different groups of
stakeholders and stockholders regarding the mining
industry as a whole. A conflict has arisen between
the need for the industry and the desire for its
products. Each year there is a growing demand for
the products of mining, with more reliance on foreign
suppliers of those products as the industry in the
United States declines. There is an economic,
environmental, and emotional price to pay for
increasing our reliance on foreign metals and
minerals.
The consulting industry must do a better job of
responding to the future needs of the industry through
development and implementation of innovative
approaches. There is no single approach that can
resolve all of the closure issues. Consulting must go
beyond simply responding to the Request for
Proposal (RFP) and the mining industry must go
beyond thinking of closure as merely engineering and
earth-moving. There are many interrelated issues
that must be integrated into a comprehensive closure
plan.
It is recommended that about three years before
decommissioning begins, a closure strategy team,
comprised of both internal and external personnel, be
formed. The closure strategy team should then meet
on an annual basis to identify issues early in the
process with sufficient time for resolution to avoid
crisis management. Initially, a closure audit should
be conducted to determine the status and success of
the ongoing operational environmental management
systems. About a year before the decommissioning
process begins, a final or revised closure plan should
be submitted to all involved entities.
These time frames are variable due to the
regulatory requirements that exist from state to state.
An educational program should be initiated for the
public and the mine personnel as the transition period
approaches. From a cooperation, coordination, and
communication standpoint, there is a need for the
global mining community to share ideas and closure
plans. In this era of electronic and instantaneous
communications, there is no excuse for the lack of
information exchange. In addition, there is a need for
a major mining closure conference to discuss current
thinking and present the state-of-the-art information.
The success and future of mining will not be tied to
the promises made during permitting or to the actual
Copyright 1999 by SME Copyright 1999 by SME 6
environmental, health, and safety record compiled
during operations; it will, however, be tied to the
condition of the mining site after closure.
REFERENCES
Bogovich, W., 1992. "Twelve Years of Abandoned
Mineland Reclamation Activities by the U.S. Dept. of
Agriculture and Soil Conservation Service in
Southwest Pennsylvania, Land Reclamation:
Advances in Research and Technology, American
Society of Agricultural Engineers Publication 14-92.
Coeur The Precious Metal Company, 1998.
Golden Cross REHAB. News, Edition 1, Waihi, New
Zealand, April.
Feasby D. and Jones, R., 1994. Report of Results
of a Workshop on Mine Reclamation, Canadian
Centre for Mineral and Energy Technology, Ottawa,
Ontario, March 10-11.
Harries, J., 1997. Acid Mine Drainage in Australia:
Its Extent and Potential Future Liability, Supervising
Scientist Report 125, Office of the Supervising
Scientist, Environment Australia, and Australian
Centre for Minesite Rehabilitation Research
(ACMRR), Canberra, Australia.
Homestake Mining Company, 1996. Environment,
Health, and Safety Report, San Francisco,
California.
Kleinmann, R., 1991. "Acid Mine Drainage: An
Overview, Proceedings of a Specialty Conference
Sponsored by the Energy Division of the American
Society of Civil Engineers, American Society of Civil
Engineers, Pittsburgh, Pennsylvania, March 10-13.
MEND, 1995. Economic Evaluation of Acid Mine
Drainage Technologies, MEND Report 5.8.1, Energy
Mines and Resources Canada, Ottawa, Ontario,
Canada, January.
MEND, 1996. "What is MEND? Mine Environment
Neutral Drainage, Natural Resources Canada,
www.nrcan.gc/mets/mend, September 6.
Minerals Council of Australia, 1997. Minesite Water
Management Handbook, ISBN 0909276730, 125 pp.
Mudder, T. and Miller, S., 1998. "Closure
Alternatives for Heap-Leach Facilities, Mining
Environmental Management, Volume 6, Number 1,
January.