Académique Documents
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By
Dr. Kaushik Dey
INTRODUCTION
According to Mudder and Harvey (1998), Proper planning for closure should come
during the feasibility study, design and permitting phases of a mine, and be upgraded
during operational life. This approach has become the standard or is a required
practice today. The lack of a proper or updated mine closure plan can result in
severe environmental and economic consequences. Inadequate closure activities,
water management, and waste rock disposal plans have prompted unexpected and,
in some instances, unwarranted secondary environmental impact statements or
assessments.
According to Nazeri (1999), the objective of mine closure is to provide long-term
stabilisation of the geochemical and geotechnical conditions of the disturbed mining
areas to protect public health, and minimise and prevent any additional or on-going
environmental degradation. Mine closure is, typically, required at a time when the
operation is no longer economically viable, when cash flow is often severely
restricted or negative, and when the value of assets is below the expenditures
required to achieve the environmental objective of mine closure. The objective of
securing mine closure funding at an early stage is to mitigate against the risk that an
enterprise may either be unwilling or unable to undertake mine closure due to lack of
funding. According to Mudder and Harvey (1998), the objectives for closure of a
typical hard rock mine include minimising 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, tailings impoundment, open pit, surface waste rock dumps
and spent leach pads.
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. 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 programme has
been initiated.
OBJECTIVES OF MINE CLOSURE PLANNING
The development of a Closure Plan needs to take into account both the legal
requirements and the unique environmental, economic and social aspects of the
operation. Outlined below are the typical contents of a Closure Plan, which will vary
depending on individual circumstances. In developing the Closure Plan, the following
four key objectives should be kept in mind:
To protect the environment and public health and safety by using safe and
responsible closure practices;
To reduce or eliminate environmental effects once the mine operations are
ceased;
All mines should have a closure plan and the combined set of activities should
comply with existing regulations.
The competent authority must approve the closure plan.
The aforementioned competent authority shall verify regulatory compliance for
all or part of the actions or commitments of such a closure plan.
The implementation of a closure plan maybe carried out gradually beginning
with the closure start-up.
Should there be any changes in regulations governing these matters, or any
other technological or operational alterations, the mine closure plan may be
modified.
Once the plan is put into operation, the competent authority shall issue a
recognition of the same that, in certain cases, may be only partial.
Each closure plan will address specific requirements according to the
particular features of each mine.
The closure plan should set out the financial means for ensuring its
subsequent execution.
Purpose:
To be able to count on a body of systematic regulations that approach mine
closure in an integral manner.
To be able to count on a modern and efficient governmental administration
and supervision of the entire policy regime affecting mine closure.
To achieve harmonization of all such policy regimes in the country.
The Indian Scenario:
The Central Government vide Notification No. GSR 329 (E) dated 10.04.2003 and
No. GSR 330 (E) dated 10.04.2003 amended the Mineral Concession Rules, 1960
and Mineral Conservation and Development Rules, 1988 respectively. As per these
amendments all the existing mining lessees are required to submit the "Progressive
Mine Closure Plan" along with prescribed financial sureties within 180 days from
date of notification. Further, the mining lessee is required to submit "Final Mine
Closure Plan" one year prior to the proposed closure of the mine. In the notification it
has been enumerated that the "Progressive Closure Plan" and "Final Closure Plan"
should be in the format and as per the guidelines issued by the Indian Bureau of
Mines [5]
Every mine shall have a Mine Closure Plan which shall be of two types:
Progressive Mine Closure Plan
Final Mine Closure Plan
The Plans have to be approved by IBM or State government. The plans shall
cover protective, reclamation and rehabilitation activities
The lease holder shall furnish financial assurance for implementation of plan,
which could be in the form of letter of credit from a Scheduled Bank, Security
Bond etc.
Future Legislative requirements
Taking note of the MCDR & latest amendment, the following changes are needed for
coal sector:
1. Incorporate requirements of reclamation of land into coal mines (conservation
& development) rules.
2. Establish some form of Reclamation Trust Fund/Financial Guarantee. This
should be a pre-requisite before the grant of a mining lease.
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An assessment of the effect of all mine openings on the stability of the surface
areas above and adjacent to areas of mining activity to determine whether the
surface areas are likely to be disturbed;
A description and schedule of any development work that could cause
disturbances or hazards at the project site or land adjoining the site;
The nature and location of systems for the treatment, management or
disposal of waste and for storage of petroleum products, chemicals,
hazardous substances and toxic substances;
Expected conditions of and uses for the project site following permanent
closure of the project and rehabilitation of the site;
The stages by which the project will be temporarily or permanently closed, a
schedule of the practices and procedures by which progressive rehabilitation
of the project site will be carried out during the life of the project and at each
stage of closure;
The monitoring to be carried out at the project site during the life of the project
and at each stage of closure;
The procedures to be used to evaluate and verify compliance with the plan
during the life of the project and at each stage of closure;
Documentation/reporting/records
Tenement Relinquishment
4.11 Care and maintenance during temporary discontinuance: For every five yearly
review (as given in the mining scheme), an emergency plan for the situation of
temporary discontinuance or incomplete programme due to court order or due to
statutory requirements or any other unforeseen circumstances, should include a plan
indicating measures of care, maintenance and monitoring of status of unplanned
discontinued mining operations expected to re-open in near future. This should detail
item wise status monitoring and maintenance with periodicity and objective.
5. Economic Repercussions of closure of mine and manpower retrenchments:
Manpower retrenchment, compensation to be given, socio-economic repercussions
and remedial measures consequent to the closure of mines should be described,
specifically stating the following.
5.1 Number of local residents employed in the mine, status of the continuation of
family occupation and scope of joining the occupation back.
5.2 Compensation given or to be given to the employees connecting with sustenance
of himself and their family members.
5.3 Satellite occupations connected to the mining industry - number of persons
engaged therein - continuance of such business after mine closes.
5.4 Continued engagement of employees in the rehabilitated status of mining lease
area and any other remnant activities.
5.5 Envisaged repercussions on the expectation of the society around due to closure
of mine.
6. Time Scheduling for abandonment: The details of time schedule of all
abandonment operations as proposed in para-4 should be described here. The
manpower and other resources required for completion of proposed job should be
described. The schedule of such operations should also be supplemented by PERT
(Programme Evaluation & Review Technique), Bar-chart etc.
7. Abandonment Cost: Cost to be estimated based on the activities required for
implementing the protective and rehabilitation measures including their maintenance
and monitoring programme.
8. Financial Assurance: The financial assurance can be submitted in different forms
as stated in Rule 23(F)(2) of Mineral Conservation and Development (amendment)
Rules, 2003. In the mine closure plan, the manner in which financial assurance has
been submitted and its particulars have to be indicated.
9. Certificate: The above mentioned actions have been taken to be stated clearly in
the mine closure plan. A certificate duly signed by the lessee to the effect that said
closure plan complies all statutory rules, regulations, orders made by the Central or
State Government, statutory organisations, court etc. have been taken into
consideration and wherever any specific permission is required the lessee will
approach the concerned authorities. The lessee should also give an undertaking to
the effect that all the measures proposed in this closure plan will be implemented in
a time bound manner as proposed.
10. Plans, Sections etc.: The chapter 1, 2, 3 and 4 should be supported with Plans
and Sections. The Closure Plan may also be submitted depicting photographs,
satellite images on compact disc etc. wherever possible.
PROCEDURAL STEPS OF MINE CLOSURE [7]
The sequence of Mine closure planning and implementation could be as follows:
Closure Feasibility
problem can not be established. However, a site-specific guideline should have been
established for the mines in future.
References:
[1] Anon (2000), Strategic Frame Work for Mine Closure, Publication by Australian
and New Zealand Minerals and Energy Council and Minerals Council of Australia.
[2] Mudder, T. & Harvey, K. (1998), Closure Concepts Mining Environmental
Management, November, 1998.
[3] Miller, C. G. (1998) Use of Financial Surety for Environmental Purposes, ICME
Limited, Edition Publications (available from www.icme.com), 54 pp.
[4] Morrey, D.R. (1999), Principles of Economic Mine Closure, Reclamation & Cost
Management, Remediation and Management of Degraded Lands. M.H. Wong et
al. (eds). Lewis, New York.
[5] Anon (1988) Mineral Concession and Development Rules.
[6] Anon (2005) down loaded from Indian Bureau of Mines website.
[7] Anon (2000), down loaded from SRK News, issue no. 26, July 2000, P10.