Mine Closure

1 Introduction and Basic Concepts

Introduction
What This Course is About
In theory, mine closure is simple; in practice, it is difficult. In this course, we will start with the
simple and then move to the more difficult, which will be explained in terms that will enable
you to deal with the many issues that arise as you plan and implement mine closure.
The simple part of mine closure consists of three objectives:

remove equipment and structures;

stabilize waste piles; and
control the spread of pollutants from the closed site.

As we shall see, these three simple objectives quickly give rise to many questions and knotty
issues.

Who pays?
Who says enough is enough?
What is to become of the site in the long term?

Many more related and difficult issues arise. Reading only this course will not enable you to
solve all the problems. Each mine site is unique and demands a unique closure plan and
approach. You will undoubtedly have to formulate the specifics of the closure plan for your
mine by way of many studies, meetings, reports, and deep deliberations. This course will
attempt to set down the current state of ideas, practice, and possibilities, so that you are
empowered to move forward to success as part of a team charged with mine closure.

Personal Perspectives
I write this course from a personal perspective based on many years of
involvement in designing, helping operate, and closing mines and mine
facilities, particularly tailings
impoundments. For five years I was
actively involved in the engineering of a major US project to close
twenty-four uranium mill tailings impoundments. That experience
gave me the opportunity to think deeply about the issues of mine
closure. In addition to an active consulting job, I have spent the past
five years reading and writing about all aspects of mines and mining.

Thus, I prepare this course as an introduction to a subject that is vast and sprawling, involving
social, technical, and financial issues. In the final section of this course I list and comment on
many e-documents readily available on the web, and likely to remain available over time. I
recommend these for your perusal once you have made your way through this course. For the
most part, I purposely avoid providing links in the body of the course. Links break, go out of
date, and are superceeded by new information and comment. Thus if a topic, idea, or specific
site mentioned in the body of the course interests you, simply undertake a Google search and
you will undoubtedly find more information related to it.
Be advised that the science, art, or philosophy of mine closure is still in a state of flux. There are
no generally accepted or implemented standards or procedures in any aspect of mine closure.
There is considerable debate about all of them, and in particular about closure standards, postclosure site use, funding for closure, and the social responsibility of the mining company in the
event of premature and even final closure of a mine.

For Whom is this Course Written?

Many people and many disciplines are needed to successfully plan and implement mine
closure. Here are some, in alphabetical order. This course is intended to introduce all of the
following to mine closure concepts and practice and to help them better close mines.
Accountants and financial folk are going to have to find the money to pay for closure. Good
accountants will make adequate provision for closure costs starting at the beginning of mine
life. Bad accountants will postpone the inevitable, and then very skilled accountants are
needed to find money in a non-profit-generating company.
Backwoodsmen and all the people who love and enjoy nature want to see the site returned
its natural state so they may go hunting, fishing, riding, camping and dreaming in an area free
of human intervention. These folk may be the locals, the community, the ancient owners of
the site, or they may be fleeing the city for nature and a bit of peace.
Civil engineers and other engineers have to design, construct, and ultimately maintain the
civil works that are part of a well-executed mine closure. Ironically, closure of a worked-out
mine is primarily a great civil engineering undertaking. The mining engineers have generally
moved on to a new mine to extract more coal, gold, silver, and other metals and minerals on
which society depends for its wellbeing. The civil engineer is left behind to clean up and
make the landscape stable.
Designers will have to formulate the closure landscape, locate the mounds and berms, set
the courses for new streams and wetlands, specify where the vegetation will go and hence
formulate a natural-like landscape. This has been done at the Wapisaw Lookout site, the first
closed oil sands tailings impoundment in Fort McMurray, Alberta.

Environmentalists are the highly trained specialists who have to compile the environmental
studies and write the closure environmental impact statements to justify the chosen closure
approach. Included in this group of specialists are the risk assessors, the health and safety
specialists, the vegetation folk who have to make grass and trees grow where they would not
naturally do so, and so on.
Fish and fowl specialists have to decide how best to reclaim the site so that fish and fowl are
not affected, and may even come to once again inhabit the site.
Geologists and geomorphologists define the geology of the site and surrounding region so
that we may apply the best principles of science to make a site stable in the long term.
Geomorphologists are key to successful mine closure, for if we do not invoke and emulate
natural geomorphic processes, we will soon be back to re-close the site.
Hydrologists and other hydro folk deal with water from the time it falls as rain to when it runs
across the surface, infiltrates to groundwater, and becomes polluted at ill-closed mines.
Inspectors must come to check on closure construction works and confirm that the site is
performing as intended in the many years after closure.
Journalists will have to be kept informed, and are charged with writing about closure in a
responsible manner so as to keep the public informed and hopefully supportive of closure
operations.
Knowledgeable NGOs will have opinions, arguments, and rationalizations for ever-moreexpensive solutions. It is best to know them, communicate with them, and reach a
compromise wherever possible.
Lawyers find and interpret the rules and regulations and tell us how they affect closure
planning and construction now and in the long-term future.
Miners involved include the mine planners, the mine managers, the mine community
relations staff charged with dealing with affected local communities, and the mine engineers
and technical staff who undertake the hard work of physically closing the mine and
constructing the necessary closure works.
Managers of all types and levels of authority manage the many teams that will plan, design,
approve, and implement mine closure works.
Native peoples are those who feel a claim to the site; the length of time they have been in
the area will vary. They may have a treaty from the Crown, a legal title, or they may be the
possessors of the land around the mine. Whatever the case, you should deal with them, for

they will be there when you are long gone.

Operations technicians will be required to do the hands-on work at the site - from
groundwater well monitoring to control of water treatment plants.
Permitting specialists will have their hands full identifying the many permits that have to be
obtained to proceed. Theirs is a job of patience, skill, and necessity; for every mine being
closed is sure to be where many permits are required to do everything from digging and
planting to diverting streams and rivers.
Quality control and quality assurance practitioners must make sure we do what we say we
will do and that we do it in accordance with pre-formulated plans and procedures.
Regulators have the most difficult job of all: make sure the closure works are done properly,
for if they fail, you can be sure the taxpayer will end up paying in the long term.
Specialists in disciplines too many to list will be involved, from the anthropologist to the
zoologist - you will be introduced to most of them as you proceed through this course.
Treatment specialists include those who design, build, and operate the water treatment
plants that are so often needed to clean-up polluted runoff and seepage from the closed
mine site. This ensures that downstream waters are not contaminated but instead return to
pristine conditions where wildlife may once again flourish.
Underground miners plan closure of the underground mine workings so that they are not
accessible in the long-term, so that they do not subside to disrupt the surface, and so that
they do not become a source of polluted water.
Visionaries look into the future to tell us what may occur so that we may choose to provide
for postulated future events or to leave those problems to future generations. In this
category fall those advocates of global warming who are even now demanding more and
more of mine closure works to deal with speculated global warming scenarios of serious
proportions.
Workers of all types and skills will come with the contractors to demolish old buildings,
remove equipment, regrade slopes, and construct surface water management structures.
X, Y, and Z stand in for all the rest who we will meet in this course, from labor union bosses to
capitalists seeking to develop wind farms, from bloggers (like me) to zealots of all
persuasions; and do not forget the politicians, without whom nothing would succeed in
difficult circumstances.

From this list we can quickly see that mine closure is multi-disciplinary
and demanding. The success of mine closure depends on how these
diverse skills and talents are brought together to form a whole, and to
cost-effectively do what has to be done. This course is intended to set
out some of the things the team will have to consider, plan for, and act
on.

Why Mines Close

Why do mines close? Laurence (2006), notes the following reasons.

economic, due to either low commodity prices or high operating costs

geologic, due, for example, to an unanticipated decrease in grade or
size of the orebody
technical, due to adverse geotechnical conditions or mechanical or
equipment failure
regulatory, due to safety or environmental breaches
policy changes, which occur from time to time, particularly when governments change
social or community pressures, particularly from NGOs
closure of downstream industries or markets
flooding or inrush of groundwater

Closed mines may sometimes reopen when the metal price increases - consider recent
increases in the price of gold and copper. More intelligent exploration may lead to the
discovery of additional ore. The technical issues may be solved and the regulators placated.
Social pressures may change as those who formerly earned a good mining income are faced
with unemployment and hard times. And so on. It is worthwhile to consider the possibility of
re-opening the mine in future while planning its closure.

Basic Technical Concepts and Issues

General
Now that we have a basic idea of the people involved in mine closure and we understand why
mines may close, we can set down the basic issues that arise in planning and undertaking mine
closure. In the remainder of this course we will explore each of these issues in some detail, so
consider the following an introduction to the remainder of this course and its contents.

Closure Standards
The laws and regulations that govern mine closure vary from place to place. Clearly you have to
obey the law. But laws and regulations are seldom such that they mandate simple and obvious
closure design criteria and standards. In a separate section of this course, we will explore the
great diversity of mine closure criteria derived from laws, regulations, and current practice.

Tread carefully in establishing clear and unequivocal closure criteria - but you must do it,
otherwise you are embarking on a never-ending trek of ever-increasing demands to do more
and more. In establishing mine closure criteria and in planning their practical implementation,
you need a concept of the post-closure use of your mine site.

Post-Closure Land Use

The mine on which I grew up closed after nearly fifty years of operation. Now the site is covered
with buildings where artificial diamonds are manufactured. A mine for which I designed the
tailings impoundment closed after twelve years of profitable operation. Now the old buildings
house horse stables and the impoundment is part of the area where people go horseback riding
in the clean air and rugged mountains. Some old mines become museums, some are turned
into nurseries producing baby plants for new forests and farms, and some become schools or
religious retreats.
Too many closed mines are a burden, and are surrounded by high fences to keep trespassers
out. It need not be thus, and in this course we will explore innovative ideas for post-closure use
of the mine site.

Phases of Mine Closure Planning

In the past, mine closure planning was undertaken as the mine approached closure, or worse,
once it closed sooner than intended. Mine closure implementation was undertaken once the
mine shut down and mining operation ceased.
In more and more jurisdictions, laws and regulations require that you prepare a mine closure
plan as part of the basic process of evaluating the feasibility of opening a new mine and seeking
mining permits. Some jurisdictions mandate regular updates of the mine closure plan during
mining operations. Many jurisdictions now require posting of a bond or other form of financial
security equal to the estimated cost of mine closure.
Therefore, prudent and comprehensive mine closure planning now should occur at all stages of
mine planning and operation. Depending on how you break up the phases of mining, it all boils
down to consideration of mine closure engineering and financing as you evaluate the feasibility
of the mine, proceed to detailed studies, open the mine, operate the mine, and approach
closure.

Thinking through mine closure as part of initial mine evaluation and planning has led to the
concept of designing and operating the mine for closure - namely doing things from the very
start in such a way as to make it easier and less costly to close the mine when mining
operations cease. We shall discuss this issue in more detail as we proceed with the course.

The Mine Closure Plan

It is never too late to prepare a plan to close your mine. Most existing mines do not have a
closure plan. The mine may have been in operation for many years and may have so long a
remaining life that the idea of planning for closure is not an issue. Most mines begin operation
well before the idea of preparing a mine closure plan as part of the mine's feasibility study,
became necessary or fashionable.
In recent times, however, the following and other realities have led to an increase in the early
preparation of mine closure plans.

An increasing number of jurisdictions have begun to demand a closure plan as part of an

application to start mining.
Shareholders have grown wary of the ever-increasing costs of mine closure and the impact of
these costs on the profitability of the mining company. Prudent investors now seek information
on the closure cost liabilities of a company in which they are considering investing.
Taxpayers, burdened with the enormous costs of closing mines that have been abandoned by
their owners, now demand that provision be made for bonds and other financial provision to be
made, at the expense of the mining company, to close the mine.

There is an increasing demand that mines prepare mine closure plans as part of the initial
evaluation of the feasibility of the mine, part of the permitting process, part of ongoing
operation, and of course as actual mine closure approaches. In later sections of this course we
will consider the contents of a mine closure plan.

Financing Mine Closure

Somebody has to pay to close the mine. Real dollars will have to be expended to pay the
consultants, the contractors, and the mining company staff who will plan, manage, and
implement closure. The issue is: where is this money to come from? If your mining company is
large and successful, with other profitable mines, then you may simply draw on the overall
company profits (reducing them, of course.) But if you work for a small company and the mine
about to be closed is the company's sole or major resource, you may be severely cash-strapped.
You may find yourself asking:

Should you have provided a nest egg for closure?

Can you draw on closure insurance?
Should you go bankrupt and pass the cost to the taxpayer?

If you are the regulator of a new mine about to go into production, should you demand an upfront closure bond equal to the estimated cost of future closure?

Engineering and Technical Approaches

There is an enormous body of engineering and technical literature on
the details of mine closure. How do you select rock that will endure for
the planned mine closure life? How do you regrade the site to resist
erosion and subsequent geomorphic change? What vegetation should
be planted, and how will this vegetation be replaced naturally by the
climax vegetation of the region? This is where the specialists come in.
In this course, we will not make you an engineering or technical expert
in any of these areas, but we will set out the basics and the standards
of practice that have been used at other closed mine sites.

Social Issues
Mines have been opening and closing for thousands of years. Some mines have opened, closed,
opened, and closed a number of times as the price of gold, platinum, or silver has fluctuated
along with economic fortune.
Like taxes and death, mine closure is inevitable. People have flowed to new
mines and left when the mines were forced into temporary closure or the
resources were totally depleted. Temporary or premature closure is perhaps
hardest on local communities: there is, so to speak, no final closure and lives
and careers may be put on hold in the hope of the mine reopening. Folk
working on and dependent on the mine in the event of mine closure are always asking: will the
mine reopen? When will it start up again? And, should we stay or go? This is true if the mine is
"temporarily" shut because of either a prolonged strike or a genuine fall in commodity prices.
On permanent, final mine closure, people know and can plan and act with some degree of
certainty. Most will move to new jobs, new mines, or new cities. Hopefully there will be other
sources of employment in the area and they can do what we would all rather do: stay in their
homes, keep the kids in the same schools, and continue to be part of an established community
of friends and family.
In all instances in which a mine closes, temporarily or permanently, the mining company has a
large obligation to those affected and we discuss this in some detail in later sections of this
course.
It is not reasonable to demand that every closing mine leave behind a thriving industrial base. It
is reasonable to demand that every closing mine leave behind a landscape where people may
continue to live if they so choose - even if the money to live in the selected place comes from far
away. In this course, we recognize the social implications of mine closure and the moral

imperative that the mine provide assistance and guidance to those left behind. So we will spend
some time in later sections of this course on the issues of social interaction, sustainable mining,
and the community relations techniques that are part of mine opening, operation, and closure.
I base my approach to the social dimension of mine closure and the mining company's
obligations in that regard on the following.

It is good business practice for a mining company to do the right thing in regards to
social obligations when it closes a mine.
It is the right and moral thing to do to look to social justice when closing a mine - hence
society is well within its rights to demand by way of law, regulation, and contract that a
mine prepare for and implement its social obligations on mine closure.
Most mining companies will not be able to pay for the social aspects of mine closure
mitigation. Thus, society must demand and secure performance bonds adequate to
cover the costs of those aspects of mine closure and its impacts.

2 Types of Laws and Regulations

General
This section looks at some of the many laws, regulations, and
standards that govern mine closure in a number of places. The
following is not intended to be definitive or exhaustive; it simply
describes and discusses some of the laws, regulations, and standards in
order to expose you to the diversity of approach to mine closure
current in the industry.
You will have to establish what the governing laws and regulations are
that set the standard for closure of your mine. If there are no established laws and regulations
you will have to decide which, if any, laws and regulations may be potentially appropriate. Only
in extreme cases are you likely to be able to propose and implement closure standards of your
own formulation. A mine in a location where there are no set requirements for mine closure is
a mine in a distant, lawless place, and many other difficulties besides mine closure planning will
be at the forefront.

Types of Laws and Regulations

A good law, rule, or regulation (the word regulation will be used in the
remainder of this section) is easy to understand and enforce. Even
better is a regulation that does not have to be enforced: people simply
act in accordance with the spirit and letter of the regulation because it
is so obviously the sensible thing to do.

A good regulation sets noble and achievable goals and leaves it to the person complying with
the regulation to find the best way to achieve those goals.
Regulations may be prescriptive or performance-based. For example, a prescriptive regulation
tells you to put three-feet of clay with a hydraulic conductivity of less than 10-6 cm/sec as the
liner beneath your impoundment. By comparison, a performance-based regulation says:
operate the impoundment so that is does not affect water quality - you prove to us that you are
protecting groundwater quality.
Prescriptive regulations inevitably fail to achieve the desired outcome. Prescriptive regulations
fail because they stifle human ingenuity and technical innovation. At worst, a prescriptive
regulation eliminates innovation and stops progress, leading to a net loss for stakeholders and
the environment.

UMTRA, INAC and Australian Standards

UMTRA
The Uranium Mill Tailings Remedial Action (UMTRA) Project was undertaken
to remediate inactive uranium mill tailings piles and the remnants of
the mines and mills from which the tailings came. The sites, in excess of
about fifty, are spread across the United States from Oregon to
Pennsylvania, from Texas to the Dakotas. The Title I sites were closed by the
Federal Government as the mines had produced product for the Manhattan Project. The Title II
sites were closed by the private companies that had operated the mines to produce product for
nuclear power plants.
Closure was undertaken in accordance with a Federal law that established the following closure
criterion: the closure works are to remain stable for 1000 years, to the extent reasonably
achievable, and at any rate for 200 years.
During the late 1980s and early 1990s, the engineering details that led to compliance with this
criterion were worked out and implemented. We have now been able to observe the
performance and examine the design of the closure works, which differed for Title I and Title II
sites. The following conclusions were made.

Admittedly, there is vegetation in many areas where vegetation was not anticipated. Admittedly, the pote
infiltration barrier is greater than was initially estimated. But there have been no observations to indicate that
are susceptible to erosion, or that intrusion to or dispersal of the tailings is likely now or through the design
1000 years the covers will be well-vegetated as the climax vegetation flourishes in a rocky soil that has been s
areas and covered with windblown sand in other areas.

The UMTRA closure standards are probably the most demanding. It costs a great deal to
implement these standards, but they do lead to safe and effective closure - not walk-away
closure, however. In Grand Junction, Colorado, there is a whole group of folk who regularly
monitor the sites and undertake maintenance if required. The point is that even for such
stringent closure criteria, there is no walking away. Somebody, some organization, some
company, or the taxpayer will forever have to be there spending money to monitor and
maintain these sites.

INAC
INAC (Indian and Native Affairs Canada) is charged with closing two
mines in Canada, namely the Faro Mine and the Giant Mine. Both
represent terrible failures by the regulators and the industry in
preparing for closure. Both are costing the taxpayer infinitely more to
close than they ever generated for the country and they are about to
get only more costly. I was informed in late 2010 that a select
committee of experts is about to propose the following closure criteria for these two mines:

prove that closure will be effective for 100 years;

describe what will happen 1000 years after closure; and
determine what will happen if global warming results in an average four degrees of warming
post-closure.

This set of closure criteria is tantamount to adoption of the criteria that governed the Uranium
Mill Tailings Remedial Action (UMTRA) Project: namely, closure to be stable for 1000 years, to
the extent reasonably achievable, and at any rate for 200 years.
In engineering practice, it is impossible to distinguish between the performances of a closed
mine after 100 versus 200 years. The implication of the 1000 years post-closure period is that
you have to provide for extreme events.
We are now going to have to "prove" to the regulators that mine closure plans for mines in the
cold parts of Canada will work and will be good for 100/200 years and for 1000 in the presence
of four degrees of warming.

Western Australia
The Western Australia Department of Mines and Petroleum and the Environmental Protection
Authority issued draft mine closure criteria in mid-2010. If adopted, these criteria will govern
mine closure in Western Australia. The basic requirements are:

reinstate natural ecosystems as similar as possible to the original ecosystem;

develop an alternative land use with higher beneficial uses than the pre-mining land use;
reinstate the pre-mining land use; and

develop an alternative land use with other beneficial uses than the pre-mining land use.

In addition, site-specific criteria are required to:

be specific enough to reflect a unique set of environmental, social and economic

circumstances;
be flexible enough to adapt to changing circumstances without compromising
objectives;
include environmental indicators suitable for demonstrating that rehabilitation trends
are heading in the right direction;
undergo periodic review resulting in modification if required due to changed
circumstances or improved knowledge; and
be based on targeted research which results in more informed decisions.

This all sounds well and good, but is very vague and flexible. Maybe that is exactly
what is intended: provide the mining industry with the chance to select and do the
right thing unencumbered by stringent regulations.

Australia
At this link is a document on mine closure put out by the Australians. Here is what they say
about mine closure.

Plan, design, operate and close operations in a manner that enhances sustainable development.
Consult with interested and affected parties in the identification, assessment and management
of all significant social, health, safety, environmental and economic impacts associated with
your activities.
Inform potentially affected parties of significant risks from mining, minerals and metals
operations and of the measures that will be taken to manage the potential risks effectively.
Contribute to community development from project development through closure in
collaboration with host communities and their representatives.

State and Provicial Standards

Ontario
In Ontario the requirements for mine closure include "consideration" of four key
objectives:

protect public health and safety;

alleviate or eliminate environmental damage;
achieve a productive use of the land, or a return to its original condition, or an acceptable
alternative; and

to the extent achievable, provide for sustainability of social and economic benefits resulting
from mine development and operations.

In undertaking your "consideration" you are required to think of the following

issues.

Physical stability - buildings, structures, workings, pit slopes, underground openings, etc.
must be stable and not move so as to eliminate any hazard to public health and safety,
and to prevent material erosion of the terrestrial or aquatic environment. Engineered
structures must not deteriorate and fail.
Geochemical stability - minerals, metals and "other" contaminants must be stable - that
is, must not leach and/or migrate into the receiving environment at concentrations that
are harmful. Weathering, oxidation and leaching processes must not transport
contaminants, in excessive concentrations, into the environment.
Surface waters and groundwater must be protected against adverse environmental
impacts resulting from mining and processing activities.
Land use - the closed mine site should be rehabilitated to pre-mining conditions or
conditions that are compatible with the surrounding lands, or achieve an agreed-upon
alternative productive land use. Generally, the former requires the land to be
aesthetically similar to the surroundings and capable of supporting a self-sustaining
ecosystem typical of the area.
Sustainable development - elements of mine development that contribute to (impact)
the sustainability of social and economic benefit, post mining, should be maintained and
transferred to succeeding custodians.
Again, this sounds positive, but it is so vague as to be susceptible to manipulation by
lawyers and corporate interests.

Nevada
The following are from the Nevada mine closure regulations and guidance
document.

When faced with hardrock mining reclamation, including closure, the authorized officer must
ensure decisions will not result in unnecessary or undue degradation of the public lands.
All actions must comply with the appropriate federal and state laws, and be consistent with
BLM's multiple use responsibilities under the Federal Land Policy and Management Act (FLPMA).
Reclamation decisions need to be coordinated and made in collaboration with the state
regulatory agencies responsible for the permitting and oversight of mine reclamation, including
closure activities.
The BLM must ensure that activities such as long-term or perpetual maintenance of vegetation
and/or wetlands, including monitoring, are provided for when these elements are part of fluid
management or site stabilization. Fence maintenance, grazing management, weed invasion or
increased salinity all impact vegetation at reclamation sites; consequently, these elements must
all be considered in the long-term planning.

The BLM field specialists and managers need to understand and consider all the technical issues
associated with hardrock mine reclamation, including closure activities and the long-term
implications of closure, while ensuring that reclamation, including closure activities, is
conducted in a timely and effective manner.

California
All we need note about mine closure regulations in California is that they mandate backfilling of
the open pit at closure. This seems reasonable if the objective is to eliminate above-grade piles
that could erode. But backfilling of a pit is by no means a foolproof way to limit the generation
and spread of contaminants, particularly in groundwater.

Oil Sands
The Alberta Energy Resource Conservation Board (ERCB) regulation for oil sands tailings
disposal says that within one year of placement, the tailings should have a strength greater
than 5 kPa, and ultimately the strength should be greater than 10 kPa. If the strength falls
below those limits, you will have to scoop them up, take them back to the plant, and rework
them.
The underlying objective of the proposed ERCB regulations is noble: do not leave behind an oil
sands tailings impoundment that consists of a well-engineered earth dike holding back fluid
tailings. Presumably the regulators who wrote this proposed regulation want to avoid dike
failure and flow of the impounded fluid-like tailings down the Athabasca River any time in the
future.

Wisconsin Mine Reclamation

The Wisconsin Mining Information Fact Sheet: Reclamation and Long-Term Care
Requirements for Metallic Mining Sites in Wisconsin begins as follows.

"Successful reclamation means the restoration of all areas disturbed by mining activities
including aspects of the mine itself, waste disposal areas, buildings, roads and utility
corridors. It is the product of thorough planning and execution of a well-conceived
reclamation plan. Restoration means returning the site to a condition that minimizes
erosion and sedimentation, supports productive and diverse plant and animal
communities and allows for the desired post-mining land use."

Impending Regulations
Impending Regulations
In late 2005, the Montana Environmental Quality Council proposed the following requirement
for a mine reclamation plan.
The reclamation plan must conclusively demonstrate that, after... [two years] ...no
treatment of surface or ground water for carcinogens or toxins will be required to meet
water quality standards at the point of discharge.
In early 2006, the Board of Environmental Review amended the language of the proposed rule
to lower the standard of proof that water treatment would not be required beyond two years
by changing the wording from "conclusively demonstrate" to "demonstrate by clear and
convincing evidence." This was considered to reduce the 100 percent guarantee to a 70 percent
probability.
In a study of the economic impact of this regulation, this conclusion was reached.
As a result of adopting the proposed rule as amended in January 2006, an estimated 50 to 90
percent of future metal mining economic output and 10 to 25 percent of future industrial
mineral mining economic output in Montana would be prevented from developing... Overall,
these two mining sectors comprise less than 1.5 percent of Montana's total economy in
terms of jobs, wages, economic output and tax revenue. Therefore, the state economy as a
whole would not be significantly affected by the proposed rule. However, mining's
prominent history in Montana culture, its concentration in select counties, and the fact that
mining jobs are high-paying, would ensure that localized, significant effects would occur.
The proposal was tabled indefinitely when the Montana Department of Environmental Quality
came out against it. The bill in Idaho has been referred to a committee for further study.

Some General Observations

The brief, previously discussed survey of the great variety of mine closure criteria illustrates
that there is no one generally accepted approach, either in law or practice, to mine closure. As
we noted in the introduction to this section, find out what is applicable to your mine, do it, and
adjust to get a cost-effective approach.

3 Post-Closure Mine Use

Sustainable Mining
General
Most laws and regulations on mine closure provide sufficient flexibility to formulate a sitespecific post-closure use of the closed site. Obviously, closing the site by surrounding it with a
high security fence is the easiest, cheapest, and least liability-prone approach. However, with a
bit of ingenuity and thought, better uses may be found for closed mine sites. In this section we
will discuss some options in the hope that this approach may become a little more common
than it is.

Sustainable Mining
If the concept of "sustainable mining" has any utility, it is surely with
regard to the planning and implementation of a productive postclosure use of a mined-out site. It is superfluous to invoke the concept
of sustainable mining as the basis for saying the mine should not
pollute the surrounding region after closure. It is redundant to invoke
concepts of sustainable mining to plead that there should be
employment post-mining for the miners whose jobs disappear when
the mine closes.
Only a productive use of the closed mine site can be said to constitute "sustainable" mining.
Even that statement fails to pass the parsimonious test: it is enough to simply say that it is good
and proper to put the closed mine site to beneficial use.
What constitutes "beneficial use" is a site-specific matter. In the middle of a distant desert, the
closed mine may be best left to go back to dry wilderness. A mine close to a densely populated
area may open up space for recreation. Let us consider some of the options, primarily by way of
a review of case histories.

Case Histories and Landfills

Case Histories
East Geduld (South Africa)
One of the many deep gold mines on the East Rand of South Africa,
East Geduld operated for over fifty years. When I was growing up, my
father, who was Mine Captain on the mine, often spoke of his concern
that the mine would close and we would have to move on. But more
and more gold was found, and technology advanced to enable the
miners to go deeper and further. The mine endured for many years
after we moved away. Only a few years ago did I read that the mine
had finally been closed.
A quick search via Google Earth showed that the mine houses where we grew up were still
there. The area where there had been a shaft and mill is completely changed: now there are
big, secure buildings - a plant that makes artificial diamonds. The slimes dams are gone:
reworked to recover residual gold and uranium left behind in the first processing. The area is
green, taken back to fields.
The Witwatersrand (South Africa)
Much the same has happened to many of the old gold mines of the
Witwatersrand. This mining area gave rise to a dense urban
concentration. Some sixty percent of the population of South Africa is
said to live along the Witwatersrand gold belt. Johannesburg is the
major city that was founded to support the mines and which grew to
financial dominance serving the mining industry.
With closure of so many mines in this part of the world, the regional groundwater table is rising
to its former level. Mining over more than one hundred years resulted in a significant
depression of the groundwater level. As the mines went as deep as 6000 feet, the miners
pumped out the water that flowed into their mines. The water table dropped, and sinkholes
developed.

Now the water level is rising and much of the water is contaminated; some is acidic and may
one day flow into surface creeks and streams. What to do? This is under study, and represents
as great a mine closure challenge as any anywhere in the world.
In theory, the issue of groundwater fall and rise as mining rose and fell could have been
addressed as just another project in mine closure planning. In practice, the history and course
of mining along the Witwatersrand did not allow this to be. The mines began well before
modern theories of mine closure were formulated. The mines were owned by many competing
mining companies. The effects were cumulative and additive. The focus of the times was on
technology and maintenance of white supremacy.
Yet, perusal of this case history alerts us to the benefits of comprehensive planning by the
mines and by the regulators of these areas in which many mines occur. Comprehensive
planning should include detailed consideration of closure of the individual mines and the total
effect on the areas in which the mines congregate. Similar situations occur today in the coal
fields of America, in the copper mines of Chile, and the oil sands of Alberta. Let us hope that
focus on closure of individual mine components, here an impoundment, there a waste rock
dump, over there a disturbed creek, do not distract attention from the bigger, regional-wide
issues of mine closure.
For this course, all we can do is bring your attention to the issues, and advise that in planning
closure of your single mine, you give at least a passing thought to the bigger issues of closure of
all the mines that occur in the region of your mine. You may not succeed, even when achieving
your best, if others in the region fail.
Cannon Mine, Wenatchee, Washington
The Cannon Mine was a gold mine that opened in the early 1980s southwest of Wenatchee,
WA. The tailings
impoundment included an initial 100-m-high rock-fill embankment,
diversion channels, and hydraulically discharged tailings. With time, the embankment was
increased to 140 m high. The impoundment was operated successfully for the life of the mine,
and when mining stopped, the impoundment was reclaimed.
Today the reclaimed site is fully integrated into the surroundings and a good example of mine
closure that can be successfully undertaken close to urban areas. By 2001, county and stateheld bonds were released and in 2003 the impoundment (or at least those who undertook its
closure) was/were the recipient(s) of the Washington Department of Natural Resources
"Recognition for Reclamation Award."
Here is what you can read at this link on the current use of the site:
It's been called many things over the years: the Cannon Gold Mine, the Asamera Mine, the
holdings of Conoco Phillips, the property purchased by the Appleatche Riders. Now the land

that borders Saddle Rock to the south and that was part of a mining operation until 1994 is
known as the Dry Gulch Preserve. The property, which was once part of the second largest
gold operation in the United States, was purchased from Conoco Phillips in 2007 with the
provision that the Land Trust would hold a conservation easement to it. This provision
prevents this 700-acre parcel from ever being developed and will keep the heavy-metal,
hazardous-waste nasties leftover from the mining days permanently buried.
The Appleatche Riders wanted this property adjacent to their riding club for obvious reasons:
it gives their 650 members immediate access to a tremendous amount of terrain for riding
horses. After acquiring the property, the riding club quickly created a limited partnership,
called the Dry Gulch Preserve LLC, which holds and manages the property.
Despite the jokes about the toxic residues that are capped off and buried here, having so
much open space that is so easily accessible is a tremendous asset to Wenatchee residents.
About 8 miles of dirt roads and trails on the property provide places where you can walk, jog,
run the dog, and horseback ride (no motorized vehicles or mountain bikes allowed). The area
still shows the scars from its mining past, but there are surprisingly pretty places on the
property. Some of the high ridges and slopes are thick with blooming flowers in spring. And
many overlooks provide solid-gold views of the Columbia River Valley.
Let me end this story simpy by posting several pictures of the tailings impoundment after
closure, and one of the area which is now a riding stable.

Britannia Beach, British Columbia

A short drive up the coastal road from Vancouver is the Britannia Mine. When the mine first
started, it took a twelve-hour boat ride up rough seas to get there. But it was worth the trip, for
this was one of the largest copper mines in the world. Here is the basic story.

In 1888, Alexander Forbes, an enterprising doctor from Scotland, arrived in Vancouver. Eager
to make his fortune in the local area, he met with prospector Granger who showed him some
promising rock samples. On a trip to the Howe Sound area to research further, Forbes shot at
a buck deer and the deer's flailing hooves exposed some mineralized rock below the moss. As
they cleared away the undergrowth, Forbes and Granger discovered what was soon to
become one of the largest deposits of copper in the world.
The miners drove tunnels deep into the towering hills beside the sea. They brought the ore out,
crushed the rocks, and dumped the tailings into the inlet to form the flat area where the
highway now goes. But the copper ran out, mining costs increased, and the mine was shut.
Low copper prices and the lure of the city life soon saw the Britannia Mining & Smelting
Company reduced to seven employees, and in 1959 it went into liquidation. In 1963 the
Anaconda Mining Company bought the property. A new ore zone and a new contract for the
miners saw increased production for the next eleven years. Operating costs and taxes rose
and eventually the mine was shut down on November 1, 1974. Fifty-five men went
underground on the last shift as the whistle blew a three-minute requiem for the Britannia
Mines.
Now the site is a museum where tourists stop to enjoy a trip down mining memory lane. The
area has been well reclaimed. The old mill has been restored. This is a good example of what
can be done on mine closure, although the water treatment plant will probably have to be
operated forever. That is not, however, what the museum's publicity proclaims; instead they
say this:
During the seventy-year life of Britannia Mines, 60,000 people of many races, languages and
religions, worked and made their homes in the area. In 1975, the Britannia Mine Museum
was opened to the public, and in 1988, Mill 3 was designated as a National Historic Site. The
following year, the Museum site was designated a British Columbia Historic Landmark.
Leadville, Colorado et al.
Leadville, Colorado is an example of an old mining town that turned itself into a mining
museum. Need more be said?

Half the towns in the Colorado Rockies are the remnants of mining. They, like Britannia Beach,
are fortunate to be in beautiful mountains, but the fact remains that the towns are there
because of mining; call it sustainable development if you will.

Indiana
The old Victory mine site in Indiana was reclaimed to productive use. Here is part of a press
release on the closure.
"What other abandoned mined land site can boast of being an operating landfill, a growing
community recreational center, the site of a world championship racing event, and the site of an
NCAA Championship event? The reclaimed Victory Mine Site was once a barren and eroded
abandoned mine refuse area that created sedimentation and acid mine drainage problems in an
adjacent stream. The site was also used as a trash disposal area for years and an open mine
entry presented a hazard to human safety. Today the site is a major community recreation area
and the location for local, national, and world sports events. The site has come a long way in the
last few years and the story is remarkable."

Landfills
In Huntington Beach, one of those beach cities hugging the coast of Orange County, California,
there was once an old quarry just outside of town. It supplied the rocks, gravel, and sand to
build the town which grew to surround the quarry. The city fathers decided to fill the quarry in
by using it as a landfill and so for many years the Gothard Street landfill was a stinky part of
town. Today the filled landfill is landscaped and covered with playing fields where every day
and evening there are contests of basketball, soccer, and baseball. It is now in the center of a
wealthy urban area and a nice place to recreate.
Eagle Mountain is an old mine on the eastern border of California. A large company sought to
turn it into a landfill. For years, they did the right things politically, including talking to the
locals. They failed however, for local opposition was too strong.

Then there is the Mesquite Mine in south-east California. Los Angeles is running out of landfill
space. So they have built a huge landfill on the old Mesquite mine property and truck the waste
many hundreds of miles to the landfill. In due course, the waste will be transported there by
rail, and for the next thousand years the old mine will be the landfill of Los Angeles and
surrounding communities. They are not filling the pit with waste; the mining company still has
hopes of re-opening the open pit and going back into production.

4 Mine Closure Phases, Planning and Implemetation

Phases of Mine Closure
General
Different philosophies and hence technical approaches to mine
closure are applicable depending on both:

the reason for and the nature of mine closure; and

the stage of mining when you are undertaking mine closure
planning.

In this section we discuss the various stages or reasons for mine closure. We distinguish
between interim mine closure, temporary mine closure, premature mine closure, and closure at
the end of mine life. We spend a bit of time on the reasons for undertaking such closure and
give some guidelines on the main things to be done in the event of such closure.

Interim Mine Closure: Design and Operate for Closure

Interim mine closure is also sometimes called: design and operate for closure. Or: undertake
operations in such a way that you close facilities as operation proceeds. The idea is best
described with reference to mine development and the operation of mine waste facilities, as
follows.

Reclaim disturbed areas as soon as possible after disturbance.

Establish new wetlands and permanent ponds as soon as you can.
Operate the waste rock dump in such a way that you can close those parts of the dump that are
no longer needed.
Revegetate tailings impoundment slopes as the height of the slopes increases.
Place soil covers over parts of the impoundment surface that will no longer receive deposition.
Close heap leach pads once used, and as you move on to new heap leach pads.

The basic idea is simple: lay out the mine and the waste disposal facilities so that they are
quickly, easily, and cheaply closed. Thus, place acid-generating rock in the middle of vast piles
of neutralizing rock; create flat slopes on waste rock dumps; and progressively construct covers

on the tailings impoundment. Ideally, filter press and hence dry stack your tailings even if you
have lots of water available.
Design and operation for closure and the attendant implementation of interim closure may
save shareholders and taxpayers lots of money. It makes for fine conference presentations. In
practice, it is seldom used. The sad fact is that it is generally more profitable to use the
cheapest approach to mining, to maximize present profits, and defer the costs of closure to
later.

Temporary Mine Closure

The reasons for temporary mine closure are many. A bitter strike has led to temporary closure
on many mines. The economic crashes of the early 1980s and of 2008 caused mines to close.
The price of gold, silver, and other metals fluctuates in response to market forces. The ore
grade may fall below the profitable mining grade. The mining technologies of the time may be
inadequate to extract the ore. So the mine closes. But prudent folk know the mine could be
reopened if conditions change. The mining company that owns the mine may decide not to go
for full closure and all that that means, including construction of the final closure works.
A comprehensive mine closure plan will provide for temporary mine closure. The work
undertaken in the event of temporary mine closure varies depending on the anticipated interim
closure period and the reasons for temporary closure.
Obviously there are some things that have to be done during a temporary closure, such as:

maintenance of security facilities;

upkeep of offices and plants that will be needed on reopening;
operation of water treatment plans and other facilities to ensure compliance with
environmental protection needs;
ongoing monitoring of air and surface and groundwater quality as part of permit
stipulations;
liaising with the regulators to keep them informed and supportive of ongoing efforts to
maintain the mine and to reopen it as soon as is practical;
supporting affected workers who may be retained, relocated, or otherwise helped to
find other jobs at other mines; and
integrating with the community so that they understand what is going on and what your
intentions are. As for any aspect of mining, the community relations folk on the mine
should be fast and proactive in telling community leaders and all potentially affected
that the mine is about to be temporarily closed, explaining why this is necessary, and
seeking to impress on them that the mine will be cared for and kept in a condition that
promotes and facilitates reopening when times improve.

Premature Mine Closure

Temporary mine closure implies a commitment to reopen the mine as soon as reasonable and
cost-effective. Closure at the end of mine life is usually an event that is well anticipated and
which may be planned for over a long time. Conversely, we define premature mine closure as
that most unfortunate event when a mine is humming along and all of a sudden, out of the
blue, something happens and it is necessary to shut the mine down knowing that it is not
intended to be reopened.
The "somethings" that lead to premature mine closure can include;

world-wide economic crashes as occurred in the early 1980s and in 2008;

a collapse in the demand for the product mined; resulting, for example, from a regulation that
discourages use of the product, such as some grades of coal;
a flood, such as the one that occurred in Australia in late 2010 and early 2011;
breaching of a geological dike and a sudden rush of water into the underground mine workings
such as happened at Cigar Lake in 2006;
a fire in the mine or the plant resulting in the realization that it is just not cost-effective to
rebuild the fire-destroyed works; or
a change in the government, with the new government seizing the mine as part of political
change - this happens too often in Africa.

Regardless of the root cause, premature mine closure usually happens rather suddenly; closure
planning may not be in place to address the issues, and the money is just not there to pay for
full closure.
A good and comprehensive mine closure plan should include consideration of premature mine
closure. But it is not always possible to identify the myriad of things that may lead to this event.
It is unlikely that even comprehensive mine closure planning will be able to anticipate the
infinite variety of conditions at the mine that may be associated with premature mine closure.
Those left behind will undoubtedly have to scramble. Here are a few things they may need to
focus on.

First: take action to help the employees who are affected. Actions may include helping them
find new jobs, letting them remain on the payroll just a little longer, and providing for closure of
their careers on this mine.
Second: communicate with the community affected. Let them know what you know; reassure
them that you are planning to close the mine responsibly; help them to adjust where you can.
Third: work with the regulators to ensure orderly and rational closure works construction, even
though this may mean a substantial change of approved closure plans and designs.

There will be instances where this cannot or will not be done. The closure is too sudden; the
causative event too disruptive; and the money is just not there. This is the tragedy of mine
closure that bonds and financial assurance is intended to deal with. (These topics are discussed
later in this course.)

Somebody somewhere will dust off the Closure Plan, if there is one, curse their luck at having to
implement the plan with zero budget, and wonder about multiple trips to haggle with fussy
regulators unwilling to free up closure bonds.
Some lawyers and accountants will meet in secret to deliberate the benefits of going bankrupt.
The outcome will depend on the size and reputation of the owning mining company. If a small
company, there is a good chance that bankruptcy will be the better course. If the company is
large and well-known, they will swallow hard and seek to delay closure costs for as long as
possible.
As a regulator, you will have to recognize that you have the nigh-impossible task of forcing
implementation of the approved Closure Plan, if indeed there is one.

Temporary Closure Case History

Here is a rather sad story of temporary closure of an Australian mine.
Unionists say the temporary closure of Tasmania's Mt. Lyell copper mine has forced many
workers onto social security benefits. Copper Mines of Tasmania shut down its underground
mine at Queenstown a month ago, after heavy rain caused a mudslide. It initially expected to
have the problem fixed within days but the company now says it has no clear timetable.
About 180 Barminco underground mining contractors were required to take paid leave while
remedial work is carried out, but Rob Flanagan from the Australian Workers Union says many
of those have already used up all their leave. "Within weeks, 140 will be on social security
payments. There have been substantial royalties that the people of Tasmania have had as a
benefit of Mt. Lyell, and it's at this point in time when the employees who have contributed
to that need the help of the people of Tasmania," Mr Flanagan said.

Closure at End of Mine Life

The end of mine life inevitably happens; there simply is nothing left to mine. The event may
have been long-anticipated and long-planned-for. An orderly process of interim closure may
have been going on for some time. All that remains is to implement the final phases of closure
as well as described in the approved Mine Closure Plan.
This is the happy, orderly situation. There is time for the following, all of which should be
spelled out in the Closure Plan.

orderly reduction of staff to meet the reducing and changing needs for mining, processing,
monitoring, and construction of closure works
constructive interaction with the community, which has become used to the idea of mine
closure and had had time to prepare and adjust
calm and professional interaction with the regulators who have approved what you now set
about doing - there are no surprises, no pleas for last minute changes, and no agony over
promises made and broken
the accountants are quiet, for there is money to close the mine, bonds are adequate, and upper
company management is not breathing fire down innocent necks
constructing the promised new golf course, community center, recreation facilities, riding
stables, and hunting grounds
tours by journalists around the closing and closed site, who come away with lots of good press,
and the mine receives awards for a good job done thoroughly

Post Closure Care and Maintenance

Once the closure works are constructed, post-closure care, monitoring,
and maintenance begin. It goes almost without saying that such
activities are undertaken in accordance with an approved plan.
Sometimes the plan is called the Post-Closure Monitoring and
Maintenance Plan; sometimes it is called the Surveillance and Monitoring Plan. Regardless of its
name, the plan will set out roles and responsibilities, standard operating procedures, reporting
obligations, and funding provisions.
To my knowledge, at most closed mines, a small team of people remain to undertake these
activities. The need for on-site staff post-closure is generally a result of the need for ongoing
water treatment. On-site staff may be needed to mow the grass, keep planting trees, maintain
fences, fix erosion gullies, and undertake groundwater-well monitoring and reporting.
If the site has truly been closed to remain stable in the long term and water treatment is not
involved, post-closure work may be undertaken by folk living far from the mine. On the UMTRA
Project, those charged with post-closure surveillance and maintenance operate from Grand
Junction, Colorado; they visit sites at regular intervals to observe general conditions and to
decide if any maintenance is required.

In practice and in theory, post-closure surveillance and maintenance will be required forever at
sites that are not turned over to another group for beneficial use. Only if the closed site is
transferred to another group who makes beneficial use of the site, may we talk of "walk-away"
by the mining company. Thus, the rights to use the site as a race-track, riding stable, or hunting
ground may include the responsibility to maintain the site.

Closure Plans
General
Now that we have a good idea of the possible types of mine closure, or at least the reasons why
mines close, let us proceed to the issue of mine closure planning. My approach is based on the
simple rule of good management: plan the work, and work the plan. Ideally, you will prepare a
mine closure plan at the earliest possible time in mine evaluation and planning. Hopefully you
will update the closure plan as you advance to start of operations, and you will definitely
continuously update the plan as mining is undertaken.

Mine Closure Plans

Some mine closure plans are required by law, some are prepared as a matter of good planning
and management, some are prepared as part of evaluating and permitting a new mine, some
are prepared while the mine is in full-scale operation, and some are prepared long after actual
mining has ceased.
There is no such thing as a generic mine closure plan. As we have seen, mine closure practice
varies immensely: a new playing field on the flattened site of a mountaintop mine in Virginia is
very different from a new diamond plant on a mine in South Africa, which is very different from
a restored arboreal forest in the coldest part of Northern Canada.
Some jurisdictions mandate the contents of a mine closure plan. Examples include Nevada and
Western Australia. Some regulators come to expect a certain format from the consultants
working in the area. Regardless, here are the minimum contents of a mine closure plan:

roles and responsibilities;

mine description: region, site, mine, plant, and waste facilities;
closure engineering and technical plans: interim, temporary, premature, and final;
post-closure surveillance and maintenance;
financial mechanisms and assurance;
employee impact mitigation; and
community engagement.

Here is a different take on the contents. It is from a paper by D.R. Welsh (Welsh (2007)) (bullets
added).

The key elements of a mine closure plan that should be specified in regulations include:

a project description;
details of the operator and mining tenement holder;
background information about the existing environment;
actions for making the site safe including the decommissioning and dismantling of the
plant and buildings and closure of underground works;
rehabilitation of all disturbed areas;
arrangements for the workforce;
proposals for community engagement;
proposed research to drive improvement;
closure implementation including schedules, review process and environmental
monitoring; and
cost estimates.

A mine closure plan may be part of - or an adjunct to - one or more of the

following:

a mine feasibility study;

an environmental impact statement preceeding opening of the mine;
a Mine Operating Permit;
an application to a bank or other lending institution for funding to open or expand
the mine;
the NI 43-101 (or equivalent) documents as issued to support company listing or
other stock exchange regulations and requirements; and
a Record of Decision on closing a mine.

Clearly, the amount of detail in the plan will vary depending on the phase of mine planning
and/or operation and the primary purpose for which the plan is intended.
On the basis of the good management principle of Continuous Improvement, we recommend
that the mine closure plan be updated regularly. Times change, circumstances change, mine
operations advance, monitoring reveals new truths about impacts, and people come and go. It
is necessary and prudent to update the closure plan at least every two years and whenever
there is a significant change in operations or impacts.
We will now consider some of those phases of mining that influence the nature and extent of a
mine's closure plan.

Closure Planning
Here are recommendations by Dave Bentel included in a presentation at the University of
Nevada (Bentel (2007)).

Step 1: Closure planning database - develop a site closure database/library (i.e. existing,
technically valid data that characterizes site conditions potentially influencing, or potentially
influenced by, mine closure). Initial planning is performed using available data only (i.e. no
additional characterization until it can be justified by the process).
Step 2: Identification and preliminary classification of site facilities - identify and
document all site facilities. Based on available operational data and physical inspection,
classify into facility types that may require similar closure actions, e.g. gold heap leach
facilities, waste rock dumps consisting of similar waste rock types, tailings disposal facilities,
pits with lakes, dry pen pits, crushing and milling process plant facilities, buildings,
infrastructure, etc.
Step 3: Documentation of site conditions affecting closure - document known and baseline
site conditions based on data research and physical inspections for: existing facilities;
anticipated facility status at closure; groundwater resources; surface water resources; air
quality; physical and geochemical characteristics of process and waste materials; chemical
characteristics and flow rates of site waters requiring management; climatological
conditions; site soil and erosion potential; potential closure borrow sources; site vegetation;
and avian and terrestrial wildlife.
Step 4: Site regulatory analysis - identify regulatory closure criteria. Analysis must cover all
pertinent regulatory bodies and regulations.
Steps 1 to 4 are the least you should do. Steps 5, 6, 7, and 8 may be undertaken depending
on corporate policy.
Step 5: Stakeholder analysis - identify existing and potential stakeholders and perform a
site stakeholder analysis to document potential and existing stakeholder issues. Develop
criteria to address these issues.
Step 6: Corporate and site management criteria - identify corporate and site management
goals (overarching goals) for closure, including financial and cash flow reporting
requirements and asset preservation strategies.
Step 7: Closure impact assessment - use criteria previously identified to assess potential
impacts of closure to health, safety, environment, and community.
Step 8: Risk assessment - develop a site closure risk register that: identifies and ranks risk
issues resulting from potential impacts; identifies risk issues that require risk management
to appropriately reduce the zero-base ranking; and develops risk management criteria.
Step 9: Conceptual closure design - develop conceptual engineering options that provide
solutions that, at a minimum, address conceptual design criteria and risk management

criteria.
Step 10: Basis of cost estimate - develop a basis of cost estimate that provides detail of how
quantities are measured and how unit rates are obtained.
Step 11: Cost estimate - develop cost estimates that meet corporate financial reporting
criteria. Compare capital and operating costs for each conceptual option.
Step 12: Residual risk assessment - use the risk register to demonstrate that the closure
options selected provide appropriate risk reduction. Evaluate the relative risk reduction
benefits for each option.
Step 13: Optimization of conceptual design - select and cost the conceptual closure design
options that are judged to best meet criteria and risk reduction goals.

Design and Operation

Site and Region Characterization
An early activity associated with most modern mining is characterization of the site and region
of the mine. This is not the place to go into the details - they are well addressed in other
EduMine courses such as Geotechnical Engineering for Mine GeoWaste Facilities,
Groundwater in Mining, Surface Water Management at Mines, and Mine Water and Chemical
Balance Analysis. At this stage of mine evaluation you should collect as much information as
possible about the pre-mining conditions at the site and in the surrounding area. Gather data
about geology, geomorphology, stream flow, groundwater, naturally occurring constituents
that later regulators may brand as contaminants, and the lives and histories of those who have
and do now live around the area of the proposed mine.
To emphasize this advice, here is a case history. Some forty miles east of San Francisco is an old
mine. It operated for about five years and never made a profit. Then it was closed.
The site is beautiful: green grasses covering rolling hills, contented cattle and deer roaming the
golden rises, a lake of tranquil waters behind a solid embankment, views of the distant hills and
fields, and flowers in full bloom. You can see why the wealthy come to snap up the surrounding
properties and commute to well-paying jobs in San Francisco.
The mine has been "in closure" ever since it ceased mining. Millions have been spent on
lawyers, lobbyists, consultants, and actual works to make dilution the solution. It will never be
"closed" in the sense that people can never walk away and the area will never "perform" as
part of nature and not affect downstream folk.

The early history of the site is well documented in Brian Fagan's book Before California: an
Archaeologist Looks as Our Earliest Inhabitants. He chronicles the inhabitants of the area who
came to gather acorns and salt. Before the mine was developed, massive graves had to be
excavated and moved. This provided the archaeologists with the information set out in Fagan's
book: the ancients came for salt because a fault which contained gold forced salty water to the
surface. The ancients gathered the salt and the acorns of the surrounding woods.
The miners failed to adequately characterize background conditions before mining. Salt
continues to emerge and flow from the site. The mine's claim that this is background has never
succeeded with the regulators, who see salt turning downstream golf courses white and crusty
and respond to the folk who commute to San Francisco and demand only pristine, salt-free
water from the site.
Thus, for decades since mine closure, more has been spent than ever was earned by the mine.
Expenditure in pursuit of clean water releases will be a never-ending goal of regulators and
wealthy downstream land-owners. The original mining company has been taken over by a
foreign company and they grow tired of such expenditure. They have engaged new consultants
to evaluate the long history of high post-closure expenses and to tell them how to stem this
never-ending bleed of money.
The simple answer is to put about $12 million in an interest-bearing account at, say, three
percent, and continue forever to manage the site and send water downstream that does not
affect local golf courses, rivers, farms, and ultimately the ocean.

Feasibility Stage Evaluation

If you are evaluating the feasibility of opening a new mine, you will surely have to prepare an NI
43-101 or equivalent document. Such documents are required these days by almost all stock
exchanges where shares in mines and mining companies are traded. The details of such
documents vary from jurisdiction to jurisdiction, but they all have a common aim: tell potential
investors why this may be a viable and profitable mine. So, set out the data, including costs,
thus enabling prospective investors to make up their own minds about the risks and rewards of
buying shares.
Obviously there is a real cost associated with closure of the mine. It is going to cost you to post
closure bonds and make other financial provisions for closure. These closure-related costs may
well affect the financial viability of the mine. Potential investors must be told, for otherwise
they may have a valid claim for fraud or suppression of information.
Formulate at least a preliminary closure approach and make at least a preliminary assessment
of potential closure costs.

If you are a consultant engaged to do this, my best advice is to overestimate closure costs. Such
costs never seem to go down, but always increase and increase. No point in having to go back
later and admit you underestimated costs.
If you are working for the mining company, you may choose to minimize closure cost estimates.
You will probably have retired by the time the true, higher cost is confirmed. The lower cost
estimate will reduce the cost of the project, thus pushing up the value of the project and hence
share prices.
If you are a potential buyer of shares, the previous advice, different depending on who
prepares cost estimates, should be sufficient to warn you to be skeptical about closure cost
estimates in NI 43-101s and similar. The estimates are probably all way off. What you have to
decide as a potential investor is: which way does the inaccuracy lie, and how does this bias
affect the value of shares now and in the future? In brief, you should ask: can I sell the shares
before the implications of closure costs drive share prices down?

Design and Operation

You are the engineer charged with preparing mine design and operations plans. In the spirit
that you can and should plan and operate for closure, we recommend that you persist through
this course to the section of the technical aspects of mine closure. Be aware of them,
understand them, and seek to avoid or mitigate the impacts of the negatives and emphasize
the benefits of the positive. How you plan and operate the mine may make for successful, costeffective closure. Failure to take experience of mine closure into account may result in overly
costly and technically ineffective mine closure.
Now is the time to consider and deal with at least the following issues that come into play in
best practice mine closure see the details in later sections on technical aspects of closure:

access transport roads and how they may be maintained during and after mine
operations;
acid rock drainage;
backfilling of stopes;
backfilling of pits;
erosion potential of design storms and floods and measure required to mitigate
impacts;
groundwater protection;
pit lakes and the optimum shaping and filling of the pits;
structures and their foundations and how they may be beneficially used at mine
closure - or demolished and removed;
surface water management and provisions for control of erosion;
subsidence due to unfilled mine workings;
tailings impoundment slopes and benches and their geometry;
topographic shaping of waste rock dumps and tailings impoundments; and
wetlands.

Regardless of which of these or other site-specific issues you elect to deal with, the mine
closure plan should address them in detail and spell out what to do when mine closure
happens.

Case Study: Wismut

Before the Second World War, Chemnitz was a thriving textile center. Rich Jewish merchants
built beautiful homes from the profits of cloth and clothes. Then came the war. The Nazis
moved into the houses and claimed the riches for themselves.
The Russians came from the east and displaced the Nazis. The Russians needed the uranium in
the local strata. They fenced off an area big enough to surround the uranium deposits and they
began to mine. The area was a total Russian enclave: it had its own cars, phone system, medical
services, and mining operations. They mined with no regard for the environment: underground
workings beneath houses and huge tailings impoundments right above villages. I have stood on
the crest of one of these impoundments and looked down into the kitchen of a cute, old house.
With time, this empire too crumbled and the east joined with the west. To stimulate the
economy of the east, reclamation programs were put in place. The Canadian government paid
for Canadian consultants to engage in mine restoration. I went with an American company to
market our services, but we were no match for those with Canadian grants. Later I went with
my Spanish clients to see what they were doing as a possible way to close a uranium mill
tailings pile in Andujar, Southern Spain.
To put covers on the many tailings impoundments and their soft surfaces, this is what they did.
They carefully advanced geotextiles and geogrids out over the soft tailings. Then they placed
sheets of plywood and other planks, and out along these they advanced a small rig to install
wick drains. The wick drains caused some dewatering of the upper layer of tailings and hence a
gain of strength. As the strengths of the upper tailings increased, they were able to advance a
thin layer of sand out over the geosynthetics. Then more wick drains, more dewatering, more
strength gain, and another lift of sand. This process continued until the tailings were strong
enough and the sand layer thick enough to support the passage of big trucks and other
equipment used to sculpt and revegetated the final cover.
What was done at Wismut was the basis of what was done at the Suncor Energy oil sand
tailings impoundment Pond 5, except there we were able to let the upper zone of the tailings
freeze and advance strong geotextile and geogrids out over the frozen surface. Then we placed
a layer of lightweight coke, which has so low a density that it in effect floats on the tailings.
Therefore, we had no need to install wick drains to promote consolidation and strength gain of
the tailings in order to support the heavy construction equipment.
Meanwhile remediation continues at Wismut. Ponds are still being covered, mines backfilled,
and groundwater dealt with. The work will never end.

5 Financing Mine Closure

Estimating the Cost
General
Somebody has to pay to close the mine and somebody has to pay for the inevitable postclosure surveillance and maintenance. Logic tells us this should be the mining company that
operated the mine. Payments of the costs associated with closure are a cost burden to the mine
and to its shareholders.
Sadly, there are many inoperative mines abandoned by their former owners and operators. The
shareholders have received their dividends and now the costs of closure accrue to the taxpayer.
In an attempt to avoid future undue burdens to the taxpayer arising from mine closure, many
jurisdictions have passed laws and formulated regulations that mandate responsible estimation
of closure costs and provision for payment of these costs when they accrue. There is now about
$1.2 billion in Nevada in trust to pay for the closure of mines.
Some of the larger international mining companies are voluntarily providing for the costs of
closure at the individual mines in their portfolios. This makes sense; failure to provide for such
costs will simply result in an unplanned burden to the big mining company and the costs will
have to be paid from overall operating profits - this is not good for profits or share value.
In this section, we will discuss some of the issues involved with estimating the cost of mine
closure and making adequate provisions for paying these costs.

Case History: Summitville

The Summitville mine in Colorado is the classic case of a mine closing
without having the money to construct closure works. The US
Department of Environmental Protection (EPA) eventually closed the
mine and is still financing its post-closure upkeep.
The story is well told on many web sites, the best and least emotive of
them being the EPA site. They tell us that gold and silver mining began
at the site around 1870. Open pit mining began in 1984. The mine

operator used cyanide heap leaching. In 1986, a leak was detected in the liner beneath the
heap leach pad. Mining stopped; the mine operator left the site and declared bankruptcy. In
1994, the site was placed on the National Priorities List of Superfund sites.
In 2009, the site received $17 million in remedial action funding from the American Recovery
and Reinvestment Act of 2009. The money is being used to construct a water treatment plant
that will remove contaminants from acid-metal-contaminated mine drainage before the water
leaves the site and enters the headwaters of the Alamosa River, which flows to the Rio Grande.

Estimating the Cost of Closure

History and background of closure cost estimating
Parshley, et. al (2009) write of the development and the different types of mine closure cost
estimates, specifically in Nevada.
The last two decades have seen a significant evolution in both the methods and purposes of
closure cost estimating. As part of this evolution, changes in the use of closure cost estimates
have resulted in coincident changes in the scope, methods employed, and level of detail
required.
Prior to the development of regulatory requirements for their preparation, closure cost
estimates were typically intended for planning, design and construction of the actual closure,
and were often developed late in the mining life cycle. The level of detail required was largely
determined by the number of years remaining in the operational life of the mine at that time.
The nearer to the time of closure, the more detailed the closure design and cost estimate
became. These closure designs became the basis for construction contract bidding and
tracking purposes.
As mining laws changed and the need to provide financial surety for closure activities became
a priority, the focus of closure cost estimating in many countries was to reduce the liability of
the government that would assume responsibility should the operator abandon the site prior
to planned closure.
The latest evolution of closure cost estimating techniques focuses on improving closure cost
estimating for the purpose of accurate reporting of financial liabilities to shareholders,
lending institutions, and governments. Requirements for reporting mine closure liabilities
have added a new dimension to the scope and detail of closure cost estimating.
Now that the issue of closure cost estimates has made it to the corporate boardroom, the
availability of resources and the need to standardize estimation methods is likely to push
closure cost estimating technology forward faster than any time in the past thirty years.

The basics
At its simplest, estimating the cost of mine closure involves exactly the same approach as any
cost-estimating activity for any mining or civil works: list the items, calculate the quantities,
establish the unit rates, and calculate the total.
A useful checklist of items to consider when estimating the cost of closure of a mine is provided
by Nevada in their Mine Plan of Operations Reclamation Bond Checklist. Items listed include:

reclamation plans and specifications;

drill hole abandonment;
access roads and drill pads;
waste and development rock piles;
dams for tailings ponds;
impoundments for tailings;
heaps from leaching;
solution ponds, settling ponds, and other non-tailings impoundments;
building foundations, facilities, structures, and other equipment;
open pit mines;
underground mines;
revegetation;
supervision;
site maintenance and site monitoring;
contractor administrative overhead;
contractor profit; and
lead agency overhead.

Caveats in closure cost estimating

Here are a few of the important issues that Parshley, et. al. address and the guidelines they
emphasize in preparing a closure cost estimate.

There is no substitute for a proper closure plan.

Cost estimate methods based on average cost per area only work on average projects.
Beware of having inadequate short-term funds available to manage the site prior to the closure
period.
Hourly equipment rates should reflect the entity doing the work - consultants and governments
cost more than mines and their contractors.
The most suitable equipment may not be the equipment at the site.
The equipment productivities used should match the activity types - the ideal use or even the
design use of the plant.
The cost and timing of process fluid management must be based on reasonable data - not on
wishes and desires.
Additional permitting costs may be required prior to the site closure.
Include adequate costs for long-term site management and monitoring.
Miscellaneous costs can add up.

An accurate estimate of the cost to mobilize and demobilize from the site must be included.
Unit rates should be current.

Types of closure cost estimates

Again on this topic, we refer to Parshley, et. al., who list these three types of closure cost
estimates.
Financial Assurance Cost Estimates (FACE)
This type of estimate defines costs that the jurisdictional government agency would incur to
perform all of the actions required to fulfill an approved closure plan, should the company
abandon the site without implementing closure. FACEs are usually used to determine that
amount of financial assurance required under governing laws and regulations, and social
commitments.
Life of Mine (LOM) closure cost estimates
This is the estimated cost for the mine operator to perform all of the actions required to fulfill
the closure portion of their current mine plan in the context of operations. LOM estimates
are usually used for planning, budgeting, and cost tracking. Common uses for LOM closure
cost estimates include prefeasibility and feasibility studies, due diligence audits, accrual
allocations, annual planning and budgeting, and cost tracking.
Asset Retirement Obligation (ARO) cost estimate
This is a legally defined term used for financial reporting by the US and some other
jurisdictions. ARO cost estimates must be prepared each year as part of the annual financial
reporting requirements and must be adjusted to reflect any increases due to new
development work or reductions resulting from completed closure work that occurred in the
financial year.

Financing Closure Costs

Financial Instruments
The following are some current ways that mining companies provide some degree of certainty
that money will be available to pay for closure costs. These are simplistic descriptions of
complex financial instruments; please consult your company account or lawyer, or read more
on the web to get a complete picture of topics not covered here.

Third party guarantees: the mine pays or persuades some company or entity, maybe even the
holding company of the small mine, to guarantee in writing to the regulators that closure cost

can and will be paid when necessary. This may work when the guaranteeing, holding mining
company has a good financial rating.
Cash deposits: the mine simply puts into a back account - from which they cannot draw - a sum
of money sufficient to pay the cost of closure. Alternatively, the money may be lodged with a
government agency. There is always an issue of how much money to deposit or lodge: should it
be sufficient only for closure a short time hence, or for the full estimated cost of closure in fifty
years? Obviously mining companies do not like this approach as it robs them of working capital.
They do earn some interest from a bank; however, when was the last time you checked longterm interest rates at your bank? And if lodged with a government, it is galling to see the
government use the money for other purposes.
Trust fund: each year as the mine makes money, it pays a certain part of its profits into a trust
fund set aside specifically to provide for mine closure.
Insurance policy: before the 2008 crash, AIG issuied many insurance policies for mine closure. In
essence, the mine estimated the cost of closure and then paid AIG to issue an insurance policy
that they would pay in the event the cost exceeded a set amount or was incurred before a set
date. The crash of AIG means that the American taxpayer is now paying off these obligations to
incompetent mine closure projects.
Self funding: this includes parent company guarantees.

It would take us far from the focus of this course to discuss each in detail. To learn more,
consult with accountants and financial advisors or read the ICMM literature, which is
reasonably accessible.

Manitoba Closure Financial Requirements

As an extreme example, consider this list of financial instruments acceptable to the Manitoba,
Canada provincial government as security for mine closure:

a cheque made payable to the "Minister of Finance of Manitoba" with the funds to be held in
trust for the proponent;
bonds issued by the Province of Manitoba ("the Province") or another Canadian province, by
Canada or by a Canadian municipality;
a guaranteed investment certificate or term deposit certificate, in Canadian dollars, issued to
the Province by a bank, savings and credit union or trust company. The certificate must have a
12-month minimum term and be automatically renewable until the closure plan is completed;
an irrevocable, unconditional letter of credit issued to the Province by a bank, savings or credit
union or trust company;
a security or guarantee policy issued to the Province by a company legally authorized to do so;
a security provided by a third party to the Province in a form acceptable to the Director;
security interests in unencumbered assets, goods, documents of title, securities, chattel papers,
instruments, moneys, intangibles or interests that arise from assignment of accounts including a
pledge of assets;
any other form of security or any other guarantee or protection that is acceptable to the
Director;
any combination of things mentioned in clauses (a) to (h).

Coal Mine Closure Bonding

The Surface Mining Control and Reclamation Act of 1977 deals in part with financial assurances
that US coal mine sites will be reclaimed. The act authorizes the Office of Surface Mining
Reclamation and Enforcement to collect fees from operators of active mining operations and to
deposit the fees in a fund that is used to reclaim abandoned mine lands disturbed prior to 1977.
The act conditioned issuance of new coal mine permits upon the posting of a reclamation
performance bond.
A variety of bonds are permitted. Again, the details are complicated. Here are some - if you find
this daunting, be assured it is - and the following is provided just to give you some idea of why
this topic needs input from the financial specialists.

In a Surety Bond, the permittee acts as the principal, performance is guaranteed by surety, the
bond is non-cancelable, and the cost reflects the permittees' financial strength.
In a Collateral Bond, indemnity is provided by the permittee as principal and the amount is
guaranteed by cash, negotiable bonds, certificates of deposit, letters of credit, deeds of trust, or
a stock pledge.
Self-bonding is permitted if the permittee is financially sound, for example: has over $20 million
in fixed assets or has a net worth of at least $410 million.
Bond Pools are funded by fees and taxes on the industry.

A good discussion of the details is provided in the Rocky Mountain Mineral Law Foundation
publication "Mine Closure, Financial Assurance, and Final Reclamation." It can be ordered from
their website.

Complex Issues
Net Present Value
Assume for the sake of argument that we have just calculated that, if undertaken this year, the
cost of mine closure would be one million dollars. We believe our mine will operate for 100
years, although we acknowledge that we may be forced at any time to close the mine if the
price of the mined commodity drops.
Should we put a million dollars into an interest-bearing bank account? Or worse, do we have to
hand over one million dollars to the regulators for safe keeping and use in the event of an
unfortunate early closing of the mine?
Either of these actions would be simple to do. Except, the accountants will remind us that the
interest rate is abysmally low and that if we spent the million dollars on a more efficient
process plant, we could earn a lot more than we ever would from a bank.

Then the financial analysts arrive and calculate that if we are going to need one million dollars
in one hundred years, we need in practice to put a much smaller sum into an interest bearing
account; compound interest over one hundred years will do amazing things to even a small
amount saved today.
One of my colleagues noted that he had recently been at a meeting of the folk who run the
INAP site. They had bemoaned the tendency for miners compiling feasibility studies to ignore
mine closure costs - and in particular closure costs associated with acid drainage. When asked
why, he replied:
"because with standard accounting practices, it makes little difference what you estimate for
closure. By the time you work out the Net Present Value, the sum is small. The pressure is to get
the mine open. You will never have to face the closure costs as a factor of career advancement.
You are supported in the myth by the numbers."
To which one must simply reply: there are many things in life which cold logic says we should
do or not do. That is why we have morality, religion, company policies, laws, and regulations.
We sometimes just have to set standards of behavior that go against cold logic and its cruel
conclusions. It may be perfectly logical on the basis of an NPV calculation to ignore future
perpetual water treatment costs to deal with acid drainage. But that may not be prudent, right,
or even permissible. That is why we need environmental impact statements, public review and
input, and regulatory scrutiny. A bad decision made today by a narrow-perspective NPV-based
miner will impose burdens and costs on the future public and regulators. They deserve their say
in the decision. This is basically what happened with the decision to deny the right to expand
the Kemess Mine, as mentioned in other sections of this course.

For What Do You Provide?

ICMM literature presents the following list of issues associated with estimating
closure costs, now, in the event of premature mine closure, and at the very end
of planned mine life:

the application of a wide range of safety factors, including protection against highly unlikely
events;
cost calculations based on closure execution managed by a third-party rather than internally,
regardless of the likelihood that a third-party will be required;
calculations based on the ultimate development (maximum footprint) of the mine site rather
than the costs of reclamation at a given stage of the mine life;
lack of recognition of liability reduction as a result of progressive reclamation;
failure to consider the remaining operating life of the mine;
inadequate flexibility to consider innovative closure technologies that might reduce costs; and
the use of blanket formulae that do not give adequate consideration of site-specific features
that affect the cost of closure and reclamation.

Thus the stage is set for the arguments over making provision for financing future mine
closure.

The Danger of Demanding Too Much

The ICMM report "Financial Assurance for Mine Closure and Reclamation" espouses the
following philosophy.
ICMM recognizes that it is the responsibility of mining companies to provide assurance to
governments and the public that closure of facilities will be protective of health, safety,
communities and the environment. Financial assurance must be applied in a manner that
ensures proper protection but does not place an unnecessary financial burden on the
operator which could discourage investment that would stimulate socio-economic
development. It is important that the mechanisms put in place serve as far as possible to
promote the efficient exploitation of mineral resources and their associated economic
benefits while achieving levels of environmental protection and future land use that are
acceptable to society.

As an industry advocacy group, ICMM is saying: don't make us pay now or incur any financial
burdens that today make the mine potentially unprofitable to open. Rather let us work out a
way to promise that we have the money, or will at least have the money for closure when it is
needed.
There are many similar pleas floating around to lighten the burden on the mining industry to
provide up-front assurance that money will be there to pay for closure, unplanned, interim, or
final. The threat implicit in all these pleas is that if government makes too heavy a demand,
mines may not open as the cost of proving for closure funding may render the mine otherwise
uneconomic. To which one can say: so be it - if you cannot afford to open the mine, do not. You
cannot forever expect to make a profit, and then turn the cost of closure over to the taxpayer.
Nevada has this issue under control and mines still seek to open there.

6 The Engineering of Closure

Acid Drainage to Dewatering
General
This section describes some of the engineering and technical aspects of mine closure. Topics
are arranged alphabetically. All topics are relevant to successful mine closure and you will have
to involve specialists in all the disciplines discussed if you want a stable, environmentally
protective closed site.
This section focusses on those aspects that are particularly relevant to mine closure and the
performance in the long term of a closed site. For more general information, refer to other
EduMine courses where the basics of the engineering and technology are well set out.

Acid Drainage
The EduMine course Global Acid Rock Drainage deals with this subject
in more detail. Acid drainage is one of the most serious and potentially
enduring environmental problems for the mining industry. Left
unchecked, it can result in such long-term water quality impacts that it
could well be this industrys most harmful legacy. Effectively dealing
with acid drainage is a formidable challenge for which no global
solutions currently exist.
If you cannot formulate an effective strategy for dealing with acid drainage post closure, you
should not open the mine. It is simply unconscionable to dump such an intractable long-term
problem on society.
One thing you can do to ameliorate acid drainage is to place the acid-generating wastes in the
pit below water. Alternatively, encapsulate the acid generating wastes in other neutralizing
wastes. If you cannot do this, you will have to face the reality of perpetual water treatment and
leave behind enough money for future generations to deal with it.

Cold Region Closure

Closure of mines in cold places presents particular engineering
challenges, including the possibility that global warming may turn
these sites into warm, frost-free environments. The tailings
may
have frozen as they were placed. The waste rock piles will be a frozen
mass. As long as temperatures remain low and the permafrost
endures, the waste rock dumps and tailings piles remain stable and
essentially erosion resistant.

However, freeze-thaw occurs in the upper reaches of the soil profile. Pingos form; rocks
move up and down; and spring freshettes give rise to gushes of water running over the
landscape. At one site in the far north, the landscape is rolling and covered with boulders and
cobbles; there is water seeping slowly through these boulder beds in summer. In winter the site
is covered with snow and all water movement ceases.
The experts say that if we route spring flows across the closed and frozen tailings, we will
induce thawing of the tailings. This will render them susceptible to excessive erosion and
uncontrollable settlement as they consolidate.
There is little vegetation in the landscape, and what little there is grows exceedingly slowly. We
cannot rely on vegetation for erosion control. Obviously the design and post-closure
surveillance and maintenance of such sites are a challenge yet to be faced and won.

Covers
Inevitably some part of the site will require a cover. Covers for closure
is detailed in the EduMine course Geotechnical Engineering for Mine
GeoWaste Facilities and in TechnoMine. In summary, the cover will
have to endure for a long time, otherwise do not bother to construct it.
Here are two examples.
The first is Rum Jungle near Darwin in Australia. A quote from Wikipedia:
"In 2003, a government survey of the tailings piles at Rum Jungle found that capping which was
supposed to help contain this radioactive waste for at least 100 years, had failed in less than 20
years. The Territory and Federal Governments continue to argue over responsibility for funding
rehabilitation on the polluted East Finniss River. Contamination of local groundwater has yet to
be addressed."
The second is the San Manuel mine closure project where the soil cover was washed away
during closure construction by a one-hundred year recurrence interval storm. The cover was
redesigned and rebuilt to incorporate the principles for long-term covers that we adopted on
the UMTRA Project. I would note that in the thirty years I have known Tucson, there have been
three so-called one-hundred year storms in the area. I am told that since they occurred in
different parts of the area, they do not constitute thirty-year or ten-year storms. Be wary of the
statistics of intense precipitation.

Dewatering
In time, geomorphological change will occur. The closed mine site will be
subjected to topographic change. Erosion will occur in spite of our best
engineering works. We have to face the possibility of breach of the
containment dikes, berms, and dams we build to close the site.
We must ensure that there are no liquid wastes at the closed site, which, if
exposed, will flow from the site and negate our best efforts to secure the downstream
environment. The best way to avoid such potential future failure is to ensure that on closure all
liquid wastes are dewatered and solid. This, in the final analysis, is the objective set for the oil
sands tailings in Alberta: make sure the strength of the tailings is at least 5 kPa one year after
disposal and at least 10 kPa thereafter.
The best approach to addressing this problem is placement of filter-pressed, dry-stack tailings.
This approach is increasingly being adopted at mines world-wide. The first mine where this was
done is the Greens Creek mine on Admiralty Island in the pan-handle of Alaska. For over thirty
years the mine has been filter pressing the tailings. Some are used underground as stope
backfill. The remainder is placed in a stable dry stack that will be easily reclaimed and closed.
If it is not practical to place dewatered solid tailings, you may have to undertake a program to
dewater the tailings. I have been involved in a project to install wick drains into the oil sands
tailings of Pond 5 at the Suncor operations. While ongoing, this project shows promise that it
may be possible to effectively dewater the fluid-like tailings and at closure leave behind a solid,
essentially non-flowable material.

Earthquakes to Landscaping
Earthquakes
If your mine is in a region subject to earthquakes, you must evaluate
the potential impact of "the big one" on the facilities of the closed
mine. We can argue about the design criteria for long-term seismic
stability. It is best to provide for the maximum credible earthquake, for
it will occur sometime during the post-closure period.
The science of earthquake prediction is well advanced. The engineering
of evaluating the impact of earthquakes on tailings impoundments and waste rock dumps is
well established. At the very least you should calculate the potential deformation of the waste
piles at the closed mine in the event of the maximum credible earthquake, and you should
make provision for predicted deformations. At closure projects with which I have been
associated, we have calculated up to 500 mm deformation and we have provided for this.

Erosion Control
Long-term control of erosion at the site is paramount in planning and implementing mine
closure. The technologies to do this are well established. The engineering and technical
approaches to erosion control at mines are described in the EduMine course on Surface Water
Management at Mines.
Again we can argue about the criteria to be applied in the design of mine closure erosion
control works. You should provide for the probable maximum precipitation and flow; anything
less is a good bet that failure will occur sooner rather than later.
If you apply a risk assessment process to closure of your mine, you can make failure of the
erosion control works one of the risks and provide funding to deal with the failure when it
occurs. This may be cost-effective for the paying mining company. In practice, it will probably
result in transference of the true costs to the taxpayer.

Filter Pressed, Dry Stack Tailings

Greens Creek Mine in Alaska was one of the first mines to implement filter pressed, dry stack
tailings disposal. The idea is simple: pass the fluid tailings through a filter that presses out the
water; this produces a relatively dry mass of soil-like material; transport the dry materials to a
suitable site and stack them. This approach was adopted at Greens Creek because of the high
rainfall and the big earthquakes that could affect the site.

Some mines today are implementing filter pressed, dry stack tailings as a way to reduce water
consumption. But the best part about filter pressed, dry stack tailings is the ease with which the
dry stack may be shaped and reclaimed during operation and at closure. My prediction is that in
future we will - and should - see more such dry stacks, for they are the best possible way to
place tailings with an eye to closure and good long-term, post-closure stability and integrity.
Rosemount Copper in Arizona is the latest to propose dry stacking. There are many links on the
web to what they are proposing and doing.

Geomorphology
At this link is a long article on the importance of geomorphology in mine closure. Please read
it as part of this course. In summary: unless you provide for predictable geomorphic change,
your mine closure works will fail in the long term.
There is a school of thought that argues that the best approach to dealing with the inevitability
of geomorphic processes at closed mine sites is to provide for movement of the constituents to
the receiving environment at a rate that does not exceed the capacity of the receiving
environment to safely accept such inputs. Thus, provide for dilution of pollution in the long run.
As unacceptable as it sounds, this might be the only way to go. To my knowledge, the only site
at which this approach is being attempted is the Royal Mountain King Mine in central California.
We will see how this transpires.

Groundwater
I have written on groundwater at mines in the EduMine course Groundwater in Mining. If you
cannot guarantee long-term, post-closure protection of the groundwater, do not open the
mine. You should be able to achieve such long-term, post-closure groundwater protection by
calling on natural geologic and groundwater conditions. You should not invoke geomembranes they may last a long time, but will not function for as long a time as the closed mine is a reality
in the landscape.
If you are unfortunate enough to have to close an existing mine where groundwater pollution is
a reality, you will have to reconcile yourself (or your client) to perpetual groundwater capture
and treatment. Put aside a large financial endowment to pay for this.

Landscaping
A good landscape engineer is essential to the formulation of a plan for a closed mine. This is the
person to advise on replication of natural landscape forms replete with topographic relief,
streams, wetlands, and ponds.

Mine Geowaste Facilities to Open Pit Lakes

Mine Geowaste Facilities
The many aspects of tailings impoundments, waste rock dumps, and old heap leach pads
(HLPs) that enter into the planning and implementation of mine closure are discussed in detail
in the EduMine course Geotechnical Engineering for Mine GeoWaste Facilities. Some of what I
have previously said about closure of heap leach pads is equally applicable to the closure of
tailings impoundments and waste rocks dumps, as follows.
The following are the most general goals for heap leach pad closure:

protect public safety;

protect sensitive environments;
reduce or eliminate long-term management requirements; and
achieve closure in an efficient and cost-effective way.

The following specific goals should apply:

mininimize infiltration of meteoric waters;

provide suitable surface for cover and vegetation;
provide landform with a natural appearance that is compatible with existing topographic
landforms; and
minimize erosional losses.

A heap leach pad should be closed so that it becomes a new long-term geomorphic entity in the
surrounding environment. To the extent possible, the heap leach pad should be closed so that it
is an essentially self-sustaining entity that requires the least conceivable post-closure care
and/or maintenance. Achieving this objective may involve, among other things:

regrading to enhance surface water control, runoff, and erosion control;

constructing a cover to limit infiltration, air entry, and erosion; and
replacing and/or upgrading surrounding surface water management facilities to control
upgrading runoff, direct heap leach pad seepage, manage heap leach pad runoff, and generally
provide topographic expressions that replicate natural geomorphic features and forms.

It may be possible to rinse the heap leach pad prior to closure by flushing large quantities of
clean water through the materials on the pad. The objective of such rinsing is to wash out any
remaining chemicals or leachable constituents prior to closure. If successful, rinsing leaves you
with only clean water seeping from the base of the heap leach pad, and no issues of water
quality management post-closure arise.
If cyanide was used in the heap leach operation, the pad cannot be said to be "closed" until
the cyanide is "gone." In practice, cyanide degradation occurs in unused heap leach pads as a
result of cyanide reaction with bacteria, sunlight, and the materials of the heap leach pad.

These processes may take many years to totally degrade the majority of cyanide in a typical
heap leach pad.
In most instances, leachate will continue to seep from the heap leach pad drains at rates
approaching operational period rates for a significant period after cessation of operations. If
you are unable to keep the process plant operational to receive and treat this longer-term,
decreasing seepage, it may be necessary to install spray evaporation systems on the top of the
heap leach pad and to use these sprayers to enhance evaporation of seepage waters.
With time, the seepage rate will decrease after closure. At some point the seepage rate may
reduce to the point where you can dispose of the seepage by land application. You will need to
locate a suitable soil formation on site: one where the soil is of sufficient permeability to accept
the predicted seepage quantities - where the soil is such that adsorption , bacterial
metabolization, volitalizations, plant uptake, and/or storage of solution in vadose zone pore
space will occur. If such a soil deposit exists, then take the excess seepage to the field, and
spray it around at a rate that does not lead to surface ponding, contaminated seepage
downgradient, or pollution of surface waters or groundwater.
To the extent that the ore is too fine for an erosion-resistant layer to develop, it may be
necessary to plough a series of troughs or furrows to limit runoff, hence erosion. Alternatively,
the benches or setbacks between lifts may be arranged to intercept downslope runoff flow and
direct such runoff laterally to erosion resistant down-swales, or to pond the water long enough
to let it seep into the heap leach pad itself.
After closure of the HLP, control of erosion is crucial to the long-term performance of the
closed site. Generally, control of gully erosion is the primary consideration. This may be
achieved by one or more of the following approaches:

using vegetation, which may be preferable in a moist climate;

placing rocky soil, which may be preferable in a dry climate;
contouring to limit runoff lengths - benches at 20- to 50-ft vertical intervals are commonly used;
and
disking to create paddocks, i.e. a series of vertical and horizontal surfaces on the otherwise
overall sloping sideslope.

The fact is that the closed heap leach pad is a new, and often very large, geomorphic form in
the environment; neither the best intentions nor the best engineering will prevent it from being
eroded away. The trick is not to mislead yourself, your client, the regulators, or the
stakeholders to believe that erosion will not happen. Contour the closed heap leach pad to limit
erosion so that the quantity of solids moved along each year does not detrimentally affect onsite and particularly off-site surface water quality.

Open Pit Backfilling

Note the following.
Where feasible, backfilling of pits should be considered as an element of reclamation.
Advantages of backfilling include improved visual resources and public safety, increased postmining land productivity, and, in some cases, the elimination of dangerous and/or potentially
toxic pit lakes. Where pits are not backfilled, the operator should present adequate
documentation to show that backfilling is not feasible, including discussion of the options
that allow independent evaluation of the decision not to backfill. Where backfilling is not
performed, consideration should be given to highwall modification to enhance wildlife
habitat. In addition, large pits require safety berming and fencing, which require perpetual
maintenance and may not adequately deter access by humans and wildlife.
We have noted that California demands backfilling of open pits on closure. To my knowledge,
this has not been done at any mine as part of closure. At the Royal Mountain King Mine near
Copperopolis, a mined-out open pit was backfilled with waste generated by the mining of an
adjacent open pit. This has not necessarily been a success. Groundwater seeps uncontrolled
through the high permeability waste and the contaminants continue on downgradient in the
groundwater.
At a uranium mine in Saskatchewan, an open pit was backfilled with tailings. The tailings are
surrounded by a high permeability sand drain that was placed as the tailings level increased.
The idea is that groundwater will flow around and not through the drain, thereby protecting
long-term groundwater quality.
A significant issue with pits backfilled with tailings is the long-term consolidation of the tailings.
As the tailings consolidate, the surface will settle. If a mound of sufficient dimensions has not
been constructed, a depression may result, a pond will form, and infiltration and exfiltration to
groundwater may affect the success of closure. Finite strain consolidation theories abound, are
incorporated into many computer codes, and may be used successfully to model and design for
such post-closure settlement of the tailings that fill the pit.

Open Pit Lakes

In those parts of the world where there is lots of surface water, closed mines may include a pit
lake. The book Mine Pit Lakes: Characteristics, Predictive Modeling, and Sustainability is a
good source of further information on this topic and its application to mine closure.

Here is the abstract of a paper that gives a glimpse of what has to be addressed on this topic if
you are closing a mine with an open pit lake:
Closure of an open pit gold mine in central Nevada, USA, will result in cessation of dewatering
at the mine and formation of a pit lake. The future pit lake will occur in a desert shrub
community and have no surface water inflows or outflows. An ecological risk assessment far
the pit lake was conducted as part of an environmental impact statement required for
expansion of mine facilities. Because the pit lake does not yet exist, ecological risks were
estimated from the results of predictive water quality models and measurement of chemical
concentrations in the rock wall of the pit. The exposure of birds and mammals to individual
metals through food and water ingestion was estimated on the basis of concentrations of
metals in water and bioconcentration factors, and sediment ingestion was estimated from
concentrations of metals in wall rock. Exposure estimates, which were expressed as daily
rates of intake of individual metals, were compared to no-effects and lowest-effects doses
reported in the literature for those metals. Results of the risk assessment demonstrated
minimal risks to dabbling ducks from exposure to zinc and no risk to other wildlife from
chemical exposures.
In summary, these are the main issues that arise when planning an open pit lake as part of the
closure plan for a mine.

The long-term stability of the slopes of the pit: will they fail in time and fall into the pit causing
undesirable water movement?
The safety of the pit walls: people and animals may access the site and fall off the edge.
The water balance of the pit: how much precipitation, runoff from the surrounding area,
groundwater inflow and outflow, evaporation, and spilling will occur?

Time to fill: this could be rapid in wet areas and many decades in arid climates.
Pit lake water quality: this is determined by the nature of the rocks of the pit sidewalls. Often
acid formation is an issue.
Fish in the lake: will fish be able to survive and will the lake be able to be used as a fishing hole?
Birds: will the water be clean and will birds be able to safely land, swim on, and drink the water?

Penstocks to Structure Demolition

Penstocks
Penstocks
or decant structures are used on many tailings
impoundments to aid in water management. The pool size and
elevation on the top of the tailings facility is controlled by allowing
water to enter and flow out through the penstocks. The size of
penstocks can be large, as shown in Figure 1. Closing them on mine
closure is vital. The best plan is to grout them up, but then you have to
make alternative arrangements to route precipitation off the
impoundment. It will probably be necessary to reshape the top, changing it from a bowl into a
mound covered with erosion-resistant rock or well-vegetated soil.

Post-Closure Maintenance
Post-closure maintenance should be undertaken in accordance with a Post-Closure
Maintenance Plan that should incorporate a Post-Closure Emergency Response Plan. Postclosure maintenance should include at least:

vegetation irrigation, fertilizing, and mowing;

revegetation to augment dead, burnt, or eaten vegetation;
control and repair of erosion damage resulting from runoff;
regrading to address slope creep, mass movement induced by earthquakes and high
precipitation events, or slope instability;
access road maintenance including regarding, dust control, etc.;
maintenance of surface water management facilities and components including vegetation
removal, sediment cleanup, liner repair, replacement of damaged erosion-control riprap, etc.;
and
monitoring of groundwater to observe reducing or developing groundwater pollution resulting
from possible liner deterioration and/or failure.

Risk Assessment
You may elect to address mine closure in terms of risk identification and management. The
basic idea is that you undertake a risk assessment of the proposed closed mine: identify the
risks, and act to mitigate and/or control them. There are as many procedures for undertaking a
post-closure mine risk assessment as there are proponents of the approach. Choose any

procedure; they ultimately all give the same result. See Risk Assessment in Mining for a long
discussion on alternative risk assessment procedures and software. See Decision Making, Risk
Evaluation and Comparisons in Mining on decision making.
The problem is that in the long time that the mine will be closed, all the risks will occur. The big
earthquake will come; the extreme precipitation will occur; the flood will wash through the site;
and erosion will happen. As we saw with the BP oil rig, extreme risks have a way of occurring
when you least expect or are able to deal with them.
As a regulator, I would be prepared to accept a risk-based closure approach if I knew the mining
company would be there in the long term and would be willing and able to manage the riskreality consequences. Otherwise, I would demand that the mining company post a very large
and very secure bond to pay for the necessary works that would otherwise have to be paid for
by the taxpayer.
Here is a list of things to include in a mine closure risk assessment.

water: surface waters, sedimentation, chemical pollution, drainage, AMD/heavy metals, salinity
groundwater: contamination, drawdown
environmental values (downstream use): agriculture, drinking, ecosystem
dust: tailings, stockpiles, rehabilitated areas
infrastructure: buildings, equipment, camps, roads, stockpiles, dumps, dams, sumps, borrow pits
soils: contamination, topsoil availability/suitability, erosion potential, reshaping/earthworks
flora reestablishment: simple, complex, rare/significant
fauna reestablishment: terrestrial, avian, aquatic
voids: open, backfilled, subsidence
dumps: reshaping, covers, AMD, topography, seismicity, climate
tailings: reshaping, covers, AMD, toxicity, stability, land-based, riverine, submarine, radiation
hazardous: chemicals including cyanide, fuels, lubricants
other: sanitation, tyres, machinery, garbage
heritage: indigenous, non-indigenous

Site Selection
In 1983, I wrote a paper on the selection of sites for tailings
impoundments. That paper is still available and still valid. But what I
did not address in the paper was the ease and efficacy with which an

impoundment constructed at the sites considered could be closed. Today I would include that
topic, for it is now clear that ease and efficacy of closure is a significant factor in the selection of
sites for mine waste disposal facilities.

Structure Demolition
If you cannot arrange for productive use by others of the mine buildings on closure, you will
probably have to demolish the structures. Equipment that is not sold and removed from the
site will have to be included in the demolition debris. If not severely contaminated, the
demolition debris may be taken to a local landfill or sold as scrap metal.

If the demolition debris is too contaminated for cost-effective off-site disposal, you may be able
to dump the debris into the soft tailings before placing the closure cover. Alternatively you may
have to construct an on-site encapsulation cell and place the affected materials within it. This
was done with radioactively contaminated building debris at the Weldon Spring site. The metals
were placed inside a secure encapsulation cell, concrete was pumped into the voids, and the
whole solid mass was covered.

Subsidence to Vegetation
Subsidence
If you do not, or cannot, backfill the mine workings, long-term subsidence should be addressed
in your closure plan. At a new mine, such an assessment will usually support a decision to
backfill as part of mining to preclude long-term surface impact. In many mines it is good and
necessary practice to backfill stopes as you mine, so this decision may have no significant
impact on closure planning.
If it is not practical to backfill the underground mine workings and analyses indicate that there
is a possibility of long-term surface impact - the appearance of sinkholes, ground settlement,

and damage to surface structures - then you have no alternative but to preclude future use or
even access to potentially affected areas forever. Deed controls are invoked to make this legal.

Surface Water
The EduMine course Surface Water Management at Mines extensively details surface water at
mines. In short, you will be well advised to design and construct post-closure surface water
management facilities that are able to accommodate extreme precipitation, runoff, and floods.
As far as possible, such surface water management facilities should replicate natural waterways
and respond in the long term to geomorphological forces.

Vegetation
In the old days, revegetation of the mine and its waste disposal facilities was the primary goal
and metric of success of mine closure programs. The successes of the past are still as good a
goal of mine closure as ever.
This advice is as valid today as it was way back then: as soon as you open your mine, hire a soil
and vegetation expert and provide them with the means to establish a nursery and test plots.
Encourage them to try different species in different soils, local and manufactured. Let them

start the vegetation of disturbed areas as soon as you can free up these areas. Involve them in
every detail of mine closure planning. If the site is not vegetated, it can never be considered
closed.

7 Social Issues of Mine Closure

Case Histories
Section Overview
The socio-economic issue discussed in this section is: how does (or
should) a mine interact with the stakeholders of a new or existing mine
to ensure that upon mine closure there is a stable, maybe even
sustainable, community and economy in what was once, but no longer
will be, a place dependent on mining?
We will explore this thesis: most mining companies do not and will not
address the socio-economic issues of mine closure unless:

they are forced to by law or a politically strong and sophisticated group of stakeholders to do so;
or
they see it as in their best interests, prompted by a desire to maintain a social license to mine, to
keep stock price high with ethical investors, or to get a reputation that will enable them to open
new mines in other places in the future.

We will see the following patterns, by examining case histories and the writings of the experts.

Small mining companies, such as those with only one mine, generally don't care about socioeconomic activities, for they don't need to build a reputation that will enable them to mine
again elsewhere.
Many large and responsible mining companies are doing great work in contributing to the socioeconomic continuity of areas affected by their closing mines.
Most jurisdictions do not have any laws or regulations that require attention to the socioeconomic aspect of mine planning, operation, or closure.
There is a significant disconnect between the theory, morality, and practice of mine closure for
sustainable post-closure community survival.

Because mines occur in so many different places, in so many different communities, and in so
many stages of planning, development, and operation, it is nigh on impossible to set out a small
set of general rules for how the issues of socio-economics for mine closure should be addressed.

Historical Perspectives
Mines open and exist to provide society with the minerals, metals, and
materials that it needs to grow. As far as societal resources go, you
either farm it or mine it. But there is always a conflict between those
who own, live on, or love the land and those who seek to mine it.
Society and mining companies have to address this conflict if we are to
get the resources our modern world needs and/or consumes.
There is always somebody living on or near the resource some mining company seeks to mine.
My own paternal great grandparents owned a farm in the Transvaal that they lost to the
invading British that came to mine gold. It is no different today. We can read daily of tribes,
villages, and even nations opposing new mines.
In the context of this course, we maintain that if you cannot close the mine with the
concurrence of those who own, live on, or love the land, you probably will not and should not
start mining. There are simply some places where we should not mine and do not need to mine
- places where we cannot safely close the mine with the concurrence of locals are amongst
those places that should be off-limits to new mines.

A Brief Case History

In early 2008, I rented an office from a junior mining company which was doing well. They
owned and operated a 500-tonne-a-day uranium mine in Colorado and employed thirty staff on
site. Then the bubble burst: over a few days, the scope of the disaster became apparent. The
next week, they laid off all the staff and closed the mine.
Over the months that followed, they sold off the equipment and dealt with creditors and the
big mining company that had a significant stake in the small company. Eventually the site (dare
we call it a mine?) reverted to the big company, who promised to reopen it one day.
What happened here is by far and away what happens at the majority of mines that close.
There is seldom time or money for the social aspects of mine closure theory.

Best Case Practice

In the best possible case, you will have time to plan and money to implement orderly mine
closure. Here are a few brief comments on people you may want to talk to about impending
mine closure.

Employees: inform them and help them retrain and relocate to other operating mines.
Management: work really hard to keep key personnel around as long as possible to manage
closure and keep up health and safety standards.
Contractors: it may cost to engage them, but it may be convenient to retain contractors to close
the mine while your key personnel flee or relocate.
Unions: union members have great difficulty in accepting that mines will close. You will have to
negotiate, conciliate, and compromise, and probably pay extra to settle.
Local folk: whether they are indigenous or newly arrived, it won't hurt to meet with them and
let them know you are closing, for their businesses and communities will be affected.
Government: let the local politicians know, contribute to their re-election fund, and help them
deliver speeches promising tough action and new jobs.
Regulators: these are the folk you really have to placate, particularly if your closure fund is
deficient. It is up to you to work out the details of interaction in such cases.

The Very Best Case

Proactive mine closure planning is described by Hockley and Coulter
(2010). Teck Alaska operates the Red Dog Mine in north-west Alaska.
The mine is on lands owned by NANA, an Alaskan Native corporation
that is wholly owned by the local Inupiat people. More than half of the
mine's employees are of local Inupiat heritage and live in nearby
communities or elsewhere in Alaska. Although the ore reserves are
estimated to last through 2031 or longer, concern arose about
comprehensive closure and reclamation.
A closure planning team was formed. The team prepared reports describing the technically
viable closure options which were then presented at a series of regional public meetings.
Workshops were held with stakeholders to discuss options, and hence a closure and
reclamation plan was prepared.
Hockley and Coulter list the following elements that lead to the success of the undertaking:

a clear commitment to open consultation by the project proponents;

a willingness to change plans as stakeholder needs became clear;
a lengthy process of information sharing and stakeholder education, including creative use of
visual materials;
definition of the primary issues based on polling of stakeholders and issue mapping;
allowing stakeholders to address the issues of primary importance to them;
respecting the differences in communication styles;
careful note-taking to provide explanations of stakeholder recommendations;
confirmation of group inputs by polling individual participants.

It won't be until 2030 that there will be confirmation of the success of this approach. For now
though, it stands as an example that all mines should consider implementing. However, the
following costs may deter some: total costs for the closure activities are estimated at $63.5 M.

Annual post-closure costs are estimated to be $10.5 M. A financial security of $305 M was
posted to cover the closure costs and the net present value of post-closure costs.

The Plans
A comprehensive closure plan should include consideration of the social aspects of closure.
Alternatively, or in addition, you may decide to prepare a Socio-Economic Closure Plan, a Social
Management Plan, or an Integrated Development Action Plan that addresses pre-closure,
closure, and post-closure issues. Pollett (2009) writes as follows.
There is increasing recognition that there is a need for socio-economic closure planning at
the outset, similar to that currently required for environmental management and
rehabilitation. Stakeholder engagement and social management plans are key tools to
ensure that adequate attention is given throughout the mine life cycle to the long-term
effects of mine closure on affected communities and their socio-economic environment.
Public consultation and transparency throughout the planning and implementation process
are pre-requisites for building mutually beneficial partnerships to deal with social change
associated with mine development and eventual closure, and for ensuring sustainable
community development in the context of an uncertain future.
Pollett describes application of these principles at a mine in Mali. The sad facts and fears of
Africa are captured in his concluding remarks.
"The two role players that most directly bear the consequences of mine closure in the longer
term are members of the local community (including local businesses) and the local
government. Their roles in building community sustainability must be nurtured throughout all
stages of the mine life by regional and national governments, the mining company, and NGOs.
This is essential to prepare for shifts in responsibility and accountability (for maintenance and
operation of remaining mine resources, services, and facilities) to occur before mine closure and
so to promote ongoing community sustainability. "

Media and Moral Issues

Social Media
Z. Mullard's master's thesis (2010) discusses how stakeholders in the mining industry are using
social media for communication both internally and externally. The thesis draws on ideas from
communication theory, corporate social responsibility practices, studies on social capital, and
data analysis and is framed around key themes of transparency, authenticity and credibility.
Case studies outline the opportunities and risks of using these communication tools. Strategic
considerations are included to guide stakeholders towards effective use of social media. Here is
the abstract:

The current discourse on public engagement in the mining industry revolves around legislated
processes that drive communication and information sharing with interested parties. This
discourse neither aligns with modern tools for communication nor with the reality of a highly
networked society that uses social media to facilitate dialogue. This thesis addresses the gap
between traditional communication processes in the mining industry and social media tools
that create opportunities for dialogue and information sharing.
The research used a qualitative and mixed method approach to data collection. Twelve social
media websites were observed to assess the extent of mining-related dialogue, and 41
interviews were conducted with representatives from the public, private, academic and civil
sectors to learn about the challenges and opportunities of using social media. The interviews
found that 62% of respondents were using social media tools; the most popular applications
were blogs, followed by social networking platforms.
These platforms are being used for outreach to established supporters and networks.
Industry's use of these platforms mimics their public relations and marketing messaging
approaches, whereas civil society is able to generate dialogue on a number of topics through
authentic disclosure of information. Government departments have been hesitant to
incorporate social media tools as they struggle to align them with regulatory structures while
also presenting an authentic and credible voice. Many respondents were using a trial and
error approach to implement social media, despite having identified the risks of using them.
Risks and challenges include the possibility of losing control of messaging and wasting time on
unproven communications technology.
While some mining companies are adopting social media applications to conduct public
outreach, these tools have not been explicitly used for stakeholder engagement. Case studies
show how mining stakeholders use social media tools and their experience provides a
foundation for strategic recommendations. This research demonstrates that social media is
being used for specific purposes by mining stakeholders, although there is hesitancy around
perceived risks of online dialogue.

Vandals or Entrepreneurs
The closed mine may have no economic value to the company closing the mine. However, in
third world countries the closed mine may be a source of valuable materials and a possible
subsistence livelihood.
I recall a visit made many years ago to a diamond mine in Botswana. There the rule was simple:
once a piece of equipment entered the double security fence, it never came out. This made
sense as a way to control the temptation to smuggle diamonds out of the secured area. The
result was that around the perimeter of the tailings impoundment there was a vast junk yard of
old cars, trucks, office equipment, mining debris, and paper which did not deteriorate in the dry
desert. It was a venerable cornucopia of metals, wood, plastic, and paper... and maybe even a

carelessly discarded diamond. One wonders if the mine will ever "close" this part of their waste
disposal facilities or if they will allow the locals in at closure to mine what may, for them, still be
a resource. Those two security fences will not last long.
Consider what Reichardt and Reichardt (2007) say regarding mine closure in Africa.
Accept the reality of trespassing by humans and animal and consider this in the identification,
assessment and implementation of effective closure methodologies.
Accept that ultimately, barriers such as fences and bunds, while potentially helpful in the
short-term, are not effective in preventing human and animal access over the medium to
long-term.
Identify physically and socially effective mechanisms of access control (other than physical
barriers) to ensure that rehabilitated areas remain undisturbed during critical periods of
rehabilitation and closure.
Manage waste and waste disposal in a manner that extracts recyclable materials during the
operational phase, leaving nothing of residual value that might attract scavengers. Generally
involving the community in the separation and recycling of such materials will reduce the risk
of subsequent scavenger activity, as the community calculation will have already been
applied to the materials that will be left behind.
Create and communicate an operational reality on site that dispels any myths among
employees concerning the benefits of subsequent trespassing, scavenging, and scavenger
mining for scrap and other items of potential resale value, particularly in a setting of limited
economic opportunity and poverty.
Implementing effective access control to prevent illegal miners accessing closed mines or
worked out sections of operational mines remains an intractable problem for which there is
no obvious solution. Heightened security may help restrict illegal access in the operational
phase, but it is unlikely to be either practical or effective in the post-closure phase,
particularly where the community perceives that potentially economic ore has been left
behind.

Philosophy
The art, or science, of mine closure is still young. There is no agreed-upon fundamental
philosophy or even technical approach. This is strange when you consider that mining has been
around for a long time and many mines have been worked out. Most have been abandoned as
the many abandoned mine remediation programs attest. Only in the past few years have we
seen vigorous debate on the need for planning and conscientious mine closure. Much of this
debate has been documented in the proceedings of the Mine Closure Conferences organized by

the Australian Center for Geomechanics. Spend some time paging through the past conference
proceedings. The most telling case for addressing community concerns on mine closure is made
by R.J. Lambeck (2009).
"While mine closure has traditionally been seen as the cleaning up job at the end of the
extraction process, community expectations of industries that significantly impact the
environment and society are changing. Meeting these expectations requires a change of
mindset: mine closure is seen as one component of a whole life-cycle obligation to maximize the
positive environmental and social consequences of the mining endeavor. This involves a shift
from models of trade-off to ones of net benefit across the three pillars of sustainability:
environment; society; and the economy. Can companies legitimately claim that, as a
consequence of their existence, the world is environmentally, socially, and economically better
off? Aspirations to be able to make such claims requires managing the company's footprint avoiding, minimizing, or offsetting social and environmental impacts across the whole of its
operations and life cycle, not simply cleaning up the mess at the mine. "

This argument and many more like it make a powerful case for laws, regulations, enforcement,
and practice that lead to the opening of only those mines that can be closed in such a way that
they leave behind a better environment, society, and economy than existed when the mine was
opened.

8 Common Mistakes of Mine Closure

Money, Laws and Technical Inadequacy
General
The title of this section comes from a promised plenary session of the Mine Closure Conference
planned for September 2011. The material in this section is in no way drawn from the
anticipated presentation of the session speaker; this is my own take on the most common
mistakes of mine closure.

Lip Service
Lip service is the act of saying you will close the mine, but actually doing nothing tangible. It is
the practice of subscribing to the tenets of good mine closure planning and practice, but
avoiding action whenever possible.
Too often this plaintive plea is heard: "why can't we just say we will do it? We don't really have
to do anything until actual closure."
Thus you may prepare closure plans and buy bonds to cover the estimated costs, but you fail to
implement the plan during operations. It is all too easy to dump the waste at its angle of repose
in spite of the fact that the closure plan promises lifts, benches, and a flat overall slope
inclination.
You may fail to update the plan on a regular basis or to keep it current as operations change
and standards of practice advance. You may fail to employ skilled people or put one dedicated
employee in charge of mine closure planning and implementation.
Lip service is bad practice and ultimately ends up costing somebody more money than it should.
The sad part is that all too often it is a temporarily successful strategy as you postpone effort
and expense to the future, to managers who follow, and new owners who take over the
declining mining company.

Not Enough Money

Too many mines and mining companies fail to make adequate provisions for the high costs of
mine closure. There is a good reason for this: the bottom line looks better if the true cost of
closure is not made public. The cost of closure bonds is reduced and the balance sheet is
improved.
Regulators who approve closure plans and their updates are seldom sufficiently informed to
catch underestimation of closure costs. Regulators are human beings and, after all, most tend
to optimism or at least a level of blindness when it comes to admitting that they will ask for
more when closure is ongoing than they ever admitted to in the past.
Auditors may know numbers, but they are for the most part dismally ignorant of the true costs
of closure. At any rate, they are in the employ of the mining company - many recent cases
prove they may not be independent.

Bad Laws and Regulations

Laws and regulations that mandate responsible closure are the only way to ensure that closure
is done and done well. In the absence of laws, miners will do what they used to do: mine the

ore and when it is mined out, walk away. That is human nature and the way of companies left
free to act without constraint.
Equally as bad as no law, is bad law. In a preceding section of this course we surveyed some of
the relevant laws and the resulting closure criteria to which they give rise. As we saw, some are
clear and specific, allowing for human ingenuity and innovation. Some just stifle human smarts
and lead to platitudes of closure.
All too often the laws and regulations mirror societal prejudice and greed, allowing too much
latitude to the miner. I have been soundly criticized on this point by those who believe in the
innate goodness of human nature and propose that congenial communication between the
miner and the local should be the sole criterion for how you close your mine. I must reject that
proposition out of hand.

Technical Inadequacy
The engineering and technical details of closure are hard, even though they are well known. For
the most part you are asked to design and construct engineering works that will have to endure
for a long time. The only examples we have of long-lived engineering works are the pyramids, a
few ruined Greek & Roman temples, some old bridges and viaducts, and the headstones in old
grave-yards.
The only example we have of earth mounds that are reasonably similar to mine geowaste
facilities are near East St. Louis, Illinois, called the Cahokia Mounds. About 1000 years ago,
people built earth mounds. Atop the larger mounds were the dwellings of the rich and
powerful. In some of the smaller ones, the important dead were interred.
If you go to visit them now, you may observe the effects of a thousand years of weathering and
erosion. For the most part, the mounds are still intact, although there are deep gullies incised
into them. Had they had covers, they would long since have washed away. Had they
encapsulated waste, the waste would have long since been exposed.
We have multiple examples of the long-term performance of soil and rock in the landscape if
we look around us. In South Africa, millions of years of erosion have rendered the landscape
around the mines a flat desert. Thus it will be too with the gold mine slimes dams one day.
In the USA we can still discern the impact of glaciers and vast storms that swept the land a
mere 10 000 years ago. It is not hard to imagine what 10 000 years of similar weather will do to
our closed geofacilities.
As engineers and scientists - technical folk, we have data points, observations, maybe a feeble
computer program. However, at the end of the day, we are forced to make judgment-based
decisions to support our closure works designs. It is sometimes very difficult to justify our

judgment to the client or to a skeptical regulator, and thus too often technical inadequacy is the
hallmark of the closure works.

Water and Sustainable Development

Ignore the Groundwater
If ever proof were needed that a mine closure plan is necessary and that this plan should
include some form of post-closure care, the following story provides it. This is from an EPA
announcement.
The Ringwood Mines/Landfill site is located in an historic iron mining district in Passaic
County, New Jersey. The site spans 500 acres and includes abandoned mine shafts, pits,
inactive landfills, and open waste dumps. During the late 1960s and early 1970s, the site was
used for various periods of time by the Borough of Ringwood, Ford and others (including
illegal third-party dumpers) for the disposal of a large variety of waste materials including
commercial and municipal wastes, abandoned cars, appliances, paint sludge and other
miscellaneous debris.
Furthering the progress toward cleaning up the Ringwood Mines and protecting the
surrounding community, EPA today has restored the Ringwood Mines/Landfill site in New
Jersey to its Superfund National Priorities List of the country's most contaminated sites. EPA
restored the site to the list because contaminated material was discovered since the site was
originally taken off the list. EPA has since directed the Ford Motor Company to renew the
cleanup and this has led to investigations of the ground water, surface water and sediment,
and the removal of over 17 000 tons of waste. The Agency continues to direct and oversee
cleanup activities at and around the site.
This is not the only mine site closure project where consideration of the long-term implications
of closure on the groundwater was not done properly. Keeping confidentiality in mind, what
can be said is that it is imperative to undertake a full and comprehensive evaluation of the longterm impact of the wastes remaining at closure on the site and regional groundwater. Standard
science and engineering will do the trick.

Perpetual Water Treatment

At many closed mines, it has become obvious that perpetual treatment of mine-affected waters
will be necessary. Consider the debate over the Kemess North Mine, BC. A three-person expert
panel rejected proposals to open the mine. I conclude that the panel rejects the mine for this
basic reason: at best the mine will last about a decade. Thereafter for thousands of years, the
government will have to pay to treat water from the lake, now contaminated by the tailings .

Here is a quote from the Executive Summary of the expert panel report to support my
conclusion.
The Panel notes that the Project's benefits accrue for only a relatively short period (two years
of construction and 11 years of mining production). This period could be reduced if the
Project, which is not economically robust, were to close prematurely. Key adverse effects
include... the creation of a long-term legacy of environmental management obligations at the
minesite to protect downstream water quality and public safety. These obligations may
continue for several thousand years, and include ongoing treatment of poor quality water
from the open pit (the "North Pit"), and regular monitoring and maintenance of the waste
disposal impoundment (the "Duncan Impoundment") and its three dams, to preserve the
desired water balance and water chemistry in the Impoundment and to ensure the health of
its aquatic ecosystem.
Critics of the expert panel report claimed that if Kemess North had
been able to mine for one hundred years, the panel would have
concluded that perpetual lake-water treatment would have been
acceptable. Let us assume that they are right. Such an assumption
gives rise to an interesting economic problem, which can be stated in
any one of the following ways.

How long must a mine operate to justify perpetual contaminated water treatment?
How long should a mine operate to justify a given number of post-mining years of water
treatment?
How much money should a mine pump into the local economy to justify dumping long-term
mine-water treatment onto local taxpayers?
How do you quantify long-term (i.e. a hundred, a thousand, perpetual) mine-water treatment
costs using Net Present Value or any other equation?
How much money should a mine put into trust at various stages of mine operation to provide
for perpetual mine-water treatment by the government?

The Sustainable Development Propaganda

Sustainable mine development, operation, closure, reclamation, and long-term maintenance
are ideals. However, the concept of sustainability is vague; the word and its meaning have been
used, misused, and abused by countless advocates of a simple concept. To address this
confusion as it relates to sustainable mining, I have compiled an e-book: Sustainable Mine
Development: Stories & Perspectives, freely available in the InfoMine publications database.
The book starts with the premise that you can develop and run a mine in such a way that when
the ore is worked out, there is a way to put the land back together so that the people who
worked on the mine, and who come to the area thereafter, can continue to lead a decent life.

The book asks and answers the question: can the mined-out area sustain continued use once
the mine is closed and the area reclaimed? It tells stories of mines that have succeeded and
failed, and stories of mines where sustainability happened by serendipity and where
sustainability happened by dint of hard work. It tells stories of mines where ineptitude, greed,
and callousness have squashed any hope of sustaining a good life, and the area is now no more
than a national sacrifice zone.
You may like some of these stories, and some will make you angry. But regardless of your
response, I hope you will be convinced that mines are central to human progress and that
mines can, if done properly, be an integral part of a long-lasting decent environment and
lifestyle.
I wrote the e-book by collating many of my short articles and postings. I bring them together in
this e-book for ease of reference and to make it possible for those who have not had the
chance to access them all to do so. I can (and will) update it and improve it, so if you disagree
with me, or want to add your story, let me know and I will act.

The Walk-Away Fallacy

In South Africa, most of the mines that started in the late 1800s and throughout the 1900s are
still owned by one of the large mining companies that dominates the industry. To my
knowledge, not one mining company in South Africa has closed a mine and walked away leaving
the site to nature and the vagaries of time.
In the United States, most of the mines of the early days of mining were simply abandoned,
hence the many abandoned mine closure programs. None of these early mines have been, to
my knowledge, closed in a formal sense, and were instead left to nature.
In Canada there are all too many terrible examples of mines, once productive and profitable,
that are now in the perpetual care of the federal or affected provincial government. None of
these mines, I venture, will ever be closed in a way that it will make it possible to "walk away."
I once sat for three days in a luxury conference center on the edge of the Grand Canyon as we
deliberated how to walk away from the uranium mill tailings impoundments upon which we
eventually spent upwards of a billion dollars on closure works. We concluded that we could not
walk away, ever. There was some talk of establishing a "priesthood" or hereditary class of
people endowed with the time and money to look after our closure works forever. A short
history lesson in religion soon convinced us that this was fantasy.
I was delegated the task of writing recommendations for a way to ensure perpetual monitoring
and maintenance of our closed piles. I cannot find my report on the UMTRA website, but I know
it is somewhere in the library of the group that resulted from implementation of our
recommendations: establish in Grand Junction a center for the management, monitoring, and

maintenance of the Title I piles, and also the Title II piles once they were licensed as closed by
the US Nuclear Regulatory Commission.
Some of the writings coming out of Australia on mine closure are predicated on the idea that
once the miners have closed the mine in accordance with set standards, the government will
take responsibility for the site. This is realistic, even if unfortunate. If the government does not
insist on the highest standard of closure, the costs of perpetual care will ultimately fall on the
public.
The point is this: there is no such thing as walk-away closure of a mine site. Somebody,
somewhere, for time eternal (at least in human terms) will have to be around to take a look and
to act when things change or fail to go as hoped or predicted.

The Short-Term Perspective

This observation is from a Spanish client that I helped many years ago to close a uranium mill
tailings pile near Andujar, Spain: "America is a young society; you have no concept of what
happens in 1000, 2000, or even 3000 years. That is your tragedy. But in Spain, we know that
these long periods occur and society endures. Your adoption of short time frames for closure of
your mines proves your newness and the short-sighted perspective that makes you think 1000
years is a long time. It is not, as we know too well in Spain."
He reminded me that the bridge on which we stood talking had been constructed in 400 AD. A
fast car sped by; the bridge moved not a jolt. It is made of solid, durable rock.
My host pointed to a castle atop a nearby hill and told me: "that tower was built in 500 AD. In
600 AD, the knight who owned the castle locked his wife in the tower over some infidelity. She
endured for years and finally jumped to her death in despair from that window there. The local
villagers still consider the castle owners crazy, for they are the direct descendants of that
unhappy couple."
I could not argue with him on this point: to those of us brought up in the new colonies of the
British Empire and in the newly founded United States and provinces of North America, 200
years is a long time. A thousand years is a very long, almost unimaginable time, and 10 000
years is forever.
But, as any decent geologist will attest, the earth is old. The Holocene began "yesterday" in
geological times. We can readily observe and comprehend what 10 000 years of wind and
water do to soil and rock - just leave the city and go look at the hills and mountains, the valleys
and rivers, the farms that plough the rich black clay of Iowa, and you can see for yourself. It is
for that long that closed mines will be there. There is no such thing as a short-term post-closure
period.

9 Appendices
Additional Reading
General
There is an enormous and ever-increasing body of literature on mine closure. Some is good; a
great deal consists of platitudes and empty promises. Below I link to and describe a few of my
favorites. I recommend them as adjuncts to this course. These references expand on the few
links I have provided in the body of the text. In the text and here, I try to be selective and link
only to resources that are likely to endure. If a link is broken when you try it, please let me
know so that I may fix it.

The Big Guns

Here are the big documents on mine closure - as some would call them: the authoritative
documents. They have, for the greater part, been prepared by representatives of the mining
industry. Thus, there may be some bias in their approach. Nevertheless, they are worth the
time spent seeking them out and glancing through them. Focus on the parts that provide
checklists, and guidance on real technical and engineering approaches.
The Planning for Integrated Mine Closure: Toolkit is available at this link from the International
Council for Mining & Minerals (ICMM). It is well-written, easy to read, and practical. It is
intended primarily for use and implementation by the big mining companies. Thus it focuses on
how to keep the best interests of the big mining company foremost. But in spite of this focus, it
covers all the issues, albeit some superficially. If you fail to implement its recommendations,
you will probably fail to close the mine cost-effectively.
Strategic Framework for Mine Closure is available at this link from the Australian and New
Zealand Minerals and Energy Council. This document is a brief, quick and convenient read and
introduction to the topic of mine closure. It is a trifle romantic and sentimental and reflective of
the easy-going approach to mine closure in these former British colonies: basically, don't
demand too much, don't spend too much, placate the locals, and hope you can reopen the
mine. There is an over-emphasis on planning for mine closure, but if you ignore that part, you
will find some ideas of value in preparing to close your own mine or participating in closure of a
mine in which you have an interest.
The Mine Closure Handbook is available at this link from a European consortium of industry and
government. Its 170 pages are heavy with detail, a great deal of it relevant to a crowded land
like Europe. The participation of industry results in a much forgiveness for industry burdens. But
that said, it is comprehensive and worthy of reading by all likely to be involved in closing a mine
anywhere in the world.

Finally, for a fun-to-read 28-page document that puts mine closure in perspective, see It's Not
Over When It's Over: MINE CLOSURE AROUND THE WORLD. This volume is from the World
Bank and International Finance Corporation.

Technical Approaches
This volume is the best primer on Mine Reclamation I have yet come across: The Practical
Guide to Reclamation in Utah. No date is found on the e-file at the link; the guide talks of "at
the start of the new millennium" and the latest reference date is 1998, so maybe it comes from
the early 2000s. Regardless of when it was written, it should be your first stop on a tour of mine
reclamation reading, even if your mine is not in Utah.
With over 160 pages of well-written, clear and logical text, this guide covers mine-reclamation
topics including: shaping the land (visual considerations), reclaiming waterways (drainage
reclamation and streambank bioengineering), handling soils, and revegetation. That is just Part
1 of the guide; Part 2 includes fifteen Technique Sheets that provide practical guidelines to
reclamation activities including surface roughening, erosion control, check dams, and sediment
ponds.

Draft and Proposed

From 2001 and still in draft form is the Draft Solid Minerals Reclamation Handbook, put out by
the United States Bureau of Land Management (BLM). The purpose of the manual is "to provide
consistent guidelines and performance standards for reclamation of and closure of non-coal
solid mineral activities on Federal and Indian Lands." The purpose of reclamation as envisaged
in the manual is "to shape, stabilize, revegetate or otherwise treat disturbed areas in order to
provide a self-sustaining and productive use of the land in conformance with the land-use plan.
Short-term reclamation goals are to stabilize disturbed areas and to protect both disturbed and
adjacent areas from unnecessary or undue degradation."
The manual spends time on the authority and administrative procedures to follow in reclaiming
mine-disturbed lands - these may be relevant if you have a mine that falls within the purview of
the BLM. If your mine is not regulated by BLM, you can skip these sections and proceed to the
sections on reclamation of site access, surface water management, groundwater protection, pit
lakes, waste dump design, covers, leachate and acid rock drainage treatment, pit backfill,
underground closure, radionuclide reclamation, and revegetation.
From 2005 and still in draft is: DRAFT Yukon Mine Site Reclamation and Closure Policy for New
Mines. These policies are lightweight, but they are law, so be aware of them.
Draft Guidelines for Preparing Mine Closure Plans are available from the Western Australia
Department of Mines and Petroleum and the Environmental Protection Authority. The volume
contains some nice diagrams that illustrate the many aspects of mine closure. Also, there is a
useful set of checklists for planning and managing mine closure. Note the section that describes

the required contents of a mine closure plan; you would do well to consult this section when
establishing the table of contents of your mine closure plan.

Mine Closure Records of Decision

Here are two RODs on mine closure that are recommended, as they deal extensively
with real-time mine closure.
Record of Decision-Molycorp, Questa, New Mexico is available from the US Environmental
Protection Agency (EPA) at this link. Not a handbook, not a text book, but a real, recent record
of what is to be done to close a mine now and in the future. If you think planning and
implementing mine closure is or will be easy, it is recommended to at least glance or flip
through its more than one thousand pages. You will quickly see why planning and a large
budget is necessary.
The Midnite Mine Superfund Site, Spokane Indian Reservation, Washington, Record of
Decision is issued by the US Environmental Protection Agency (EPA). If your interests run to the
very difficult issues involved in mine reclamation, the legal process in the United States,
uranium mine and mill closure, and aboriginal relations, this document is a "must-read case
history."
Not a ROD, but in fact the design documents, at this link you can access the design reports and
other documents for closure on the Moab, Utah tailings pile in accordance with the UMTRA
standards. These documents were prepared in 2008, so we can conclude that our earlier
technical approaches are still viable.

InfoMine
There are nearly one hundred publications on mine closure in the InfoMine Library. Access the
site, type "mine closure" in the Search Box, and the list will appear. You can select what
interests you or what is relevant to your project and call up a PDF of the paper.
One of the e-books in the InfoMine Library is called Mine Closure. It is a collation of writings by
Andy Robertson and Shannon Shaw on mine closure. It is a trifle out-of-date and concentrates
on risk analyses as tool for deciding how to close a mine. Nevertheless, it still captures the
genius that resides in these two extraordinary people. For here they write based solidly on
consulting practice and service to companies seeking to close their mines responsibly.

Closure Financing
ICMM has the Guidance Paper: Financial Assurance for Mine Closure and
Reclamation. Then there is the paper by Jeffrey Parshley and Debra Struhsacker
The Evolution of Federal and Nevada State Reclamation Bonding Requirement for
Hardrock Exploration and Mining Projects.

See also these EduMine Courses:

An Introduction to Modeling Metal Project Finance
An Introduction to Modeling Coal Project Finance

Conferences
For the past five years, the Australian Center for Geomechanics (ACG)
has organized an annual conference on mine closure. It is worthwhile
getting them; as with any conference, the quality and merit of the
individual papers varies enormously. Nevertheless, you are likely to
find many papers, particularly those on case histories that will provide
insight and helpful advice on your mine and its closure.
Here is a list of the papers that are quoted in this course:
Mine Closure 2007
D.R. Welsh. "Mine Closure - A Regulators Guide to the Things That Matter."
M.T. Reichardt and C. L. Reichardt. "Vandals or Enterpreneurs? Acknowledging and Managing
the Human Factors During Mine Closure in the Developing World Context."
Mine Closure 2009
R. J. Lambeck. "Mine closure or mind closure are mining companies meeting their whole of
life cycle, triple bottom line obligations?"
J.V. Parshley, W. Bauman, and D. Blaxland. "An evolution of the methods for and purposes of
mine closure cost estimating."
Mine Closure 2010
S.J. Finucane and T.C. Santini "Corporate (ir)responsibility: what is it really worth when times
are tough?"
D.E. Hockley and G.A. Coulter. "Many voices, one plan: eliciting and integrating stakeholder
feedback."
E.A. Pollett. "Mine closure - participatory stakeholder engagement and socio-economic closure
for community sustainability in the context of an uncertain future."

There is also an admirable series of conferences on Tailings and Mine Waste. Many papers may
be found in the proceedings on the closure of tailings impoundments and waste rock dumps.
The papers are not generally available on the web, so you may have to seek out hard copies in
libraries.

The Quirky
Take a look at Mining for Closure, Policies and Guidelines for Sustainable Mining Practice and
Closure of Mines. The document describes itself as follows.
This document aims to present a basis for action within South Eastern Europe (SEE) and
within the Tisza River Basin (TRB) towards the development of corporate practice,
regulatory frameworks, governance guidelines and/or financial and insurance markets
suitable for the support of a modern mining industry. In particular, this document wishes to
present a number of options and ideas that can be applied to address the funding and
execution of mine closure and mine rehabilitation while still achieving conditions suitable
for new and ongoing mining activities. Further, the document provides details of many
important information sources and is intended to constitute a reference source.
It succeeds, but the reading is heavy and the philosophy is strange. Nevertheless, it a
fascinating document as it presents so different a perspective from that of the Western
European tradition.

The Restricted
The International Society for Rock Mechanics has a volume called Mine Closure and PostMining Management, International State-of-the-Art. You need to be a member of the society to
download it free, but otherwise you can purchase it. Here is how they describe the contents of
the report.
This work concentrated on the physical, rock-related aspects of mine closure and did not,
for instance, include social aspects. The main problems arising from the closed mines relate
to time dependent failure of old pillars or even overburdens spanning old works, resulting in
surface subsidence. The subsidence problems can be severe in certain cases, like the
unexpected and sudden appearance of sinkholes on the surface. In other cases, the
subsidence occurs over large areas over long periods of time and is easier to manage.
The report recommends a comprehensive risk management approach to handle the
problem. Differentiation is made between gradual subsidence and sudden events.
Depending on the nature of the expected effects, different reactions can be identified,
ranging from doing nothing except to handle minor effects as they appear, to back filling old

mines or even evacuation of villages in extreme cases.

Personal
In 1993, Charles Reith and I wrote a book called Principles and Practice of Waste
Encapsulation, which is still available from Amazon.com. The book flowed from our work
together on the UMTRA Project and on closure of the Weldon Spring Site in St. Charles,
Missouri. We set out to describe the fundamentals and details of closure or radioactively
affected waste in disposal facilities built to last a very long time. Much of what we wrote is still
valid today.

Case Histories
Oil Sands: Wapisiw Lookout
Our first case history is the 2010 closure of Pond 1 at the Suncor Oil
Sands operation north of Fort McMurray, Alberta, Canada.
For years the bulldozers and backhoes have labored to fill in and shape
the topography. Today they are done and the landscape is rolling and
green, with small creeks meandering amongst boulder clusters and
bird-nesting sites. Pond 1 at the Suncor oil sands mine is officially
reclaimed and the Alberta Premier attended the official opening ceremony. He said it makes
him proud to be an Albertan to see what has been achieved.
Brave the security desk, get a sticker that signifies you are approved to enter the site and drive
up the road from the entrance and you are greeted on the left by a vast lake, a tailings pond
awaiting reclamation, and on the right by a green landscape that is a reclaimed tailings
impoundment. Drive past the pond and to the east bank to gaze back on the long-vegetated
slopes of the perimeter dikes of the impoundment. They are beautiful as they rise from the
river flowing broad and slow to the north.
The final words belong to Suncor.
"We said we would be first to complete surface reclamation of a tailings pond and we have
delivered on this important commitment," said Rick George, president and chief executive
officer. "We know we still have a lot of work to do, but today's achievement is a significant
step towards reducing our environmental footprint related to our operations - something we
can all be extremely proud of."

Suncor has renamed the area Wapisiw Lookout to pay tribute to the history of the region, and
to honor its Aboriginal peoples.

Faro
The Faro Mine is arguably the most polluted closed mine in Canada.
From the information available, it seems they did just about everything
wrong, and there is really no way to fix it. The official web site won't
tell you that; it is a masterpiece of propaganda that makes the mine
sound like a make-work opportunity for locals. And for those taking the
water quality samples it is.
In fact, most of the money spent on the mine each year probably flows back to Vancouver,
Toronto, and other Canadian capitals. For that is where they deliberate and decide on possible
solutions. As there are no final perpetual solutions in the offering, there is a lot of lucrative
deliberation yet to undertake.
Back to the locals and their work opportunities: in a news report, we learn that Denison
Environmental Services, a division of Denison Mines Inc., has been awarded a three-year
contract for care and maintenance of the Faro Mine Complex in the Yukon. For the locals, there
is this solace at the tail end of the report.
Denison Mines noted that the contract also includes provisions for training and employment
opportunities for affected Yukon First Nations and Yukoners. The contract is worth about $7.2
million annually. For that sum, Denison will do at least the following.
The three-year, $7.2 million per annum contract will provide care and maintenance services
at the Faro Mine Complex. This will include the ongoing collection and treatment of
contaminated water, management of uncontaminated runoff, inspection and maintenance of
dams and diversion channels, water quality monitoring, general maintenance, and site
security.
Funny thing about the many reports on the web about the Faro Mine is how even the
politicians make it seem like this is a good thing; and it is if you are committed to cleaning up
mining sites with public money as a way to make work for otherwise unemployed locals.

Island Copper

In a paper, Planning for In-Perpetuity Mine Closure Costs, G.L. Pierce of

BHP Billiton and M.E. Wen of Rescan Environmental Services Ltd. note
that the now-closed Island Copper Mine on Vancouver Island created 16

500 person years of employment with a payroll of over C$700 million, spending on supplies and
services in British Columbia of over C$1.2 billion, and out-of-province spending of almost C$1
billion. Then they tell a sad tale of miscalculated closure cost estimating and finally admit that
perpetual care is needed to deal with acid mine drainage. They conclude: "for most existing
acid-generating mines, we believe that planning for in-perpetuity costs is essential and that the
concept of financial closure for these mines is unrealistic."
What this otherwise informative paper fails to tell us is what perpetual care will cost and who
will pay. Was this information edited out of the paper before its publication? It seems such an
obvious bit of information to provide, particularly when the abstract includes the following
promise.
"The closure plan was reassessed for post-closure residual risks, which are those risks that
remain after closure and reclamation activities have been executed. For each risk, the timing
and probability of the risk eventuating were evaluated. The consequence of each risk, should it
eventuate, was considered and the associated activities and cost were estimated... A discounted
cash flow model captured the estimated costs for closure, with any cash-flows after 50 years
assumed to be incurred in-perpetuity. This in-perpetuity cost estimate is fully risked and can help
estimate long-term liability at the site."

Mountaintop Mine Closure

Many criticize mountaintop mining. Here is a "Readers-Digest" version of a story on beneficial
use of post-mountaintop mining:
A short drive up a side road through dense Appalachian forest ends at a vast, flat clearing
where a mountaintop used to be. The peak that stood for an eon is gone, replaced by a giant
recreation area that was built after a coal company scraped away thousands of tons of earth,
lowering the mountain by 200 feet. Coal industry supporters say the Knott County Sportsplex in
eastern Kentucky is one of many examples of economic opportunity created by strip mining
techniques that include the often-vilified method known as mountaintop removal.
"A lot of people through the years ask why Appalachia is so poor. One of the biggest reasons is
we were land poor - we didn't have any place to build," a Floyd County Democrat said. The
West Virginia Department of Commerce issued a press release earlier this month that said
developments on former mining sites have created more than 13 000 jobs in 12 counties.
Since October 2001, West Virginia has granted 218 surface mining permits, covering 84 793
acres. Of that acreage, 6035 acres (about 7 percent) have been designated for
industrial/commercial, public service or residential development, according to data provided by
the West Virginia Department of Environmental Protection's Division of Mining Reclamation.
The developed land includes an athletic complex, livestock fields and a subdivision.

Industry supporters also said not all former mining sites are prime for development, especially
on the often remote and rural terrain of Appalachia. "The further you get away from a
community or an infrastructure where you have gas and water and sewer lines... you can't
develop out in the middle of nowhere without the proper utility structure," said Phil Osborne,
Kentucky executive director of the Federation for American Coal, Energy and Security, known as
FACES of Coal. Osborne said there are other economic uses for post-mining lands, such as
grazing land for cattle, or ATV or other recreation trails.
Osborne says post-mining lands have also provided places for elk herds to roam in eastern
Kentucky. The animals were reintroduced in 1997 after being gone from the state for 150 years.
State officials say they now number 11 000.
Hamilton said mining critics should consider the jobs created when mines are operating, long
before the land gets developed for other uses. "The part of that whole story that doesn't really
get highlighted is that however long that mining operation existed... that company is providing
gainful employment, and just creating employment opportunities for workers to provide for
their families for years," Hamilton said.
Just goes to show that some mines can be closed and the land put to sustainable use
thereafter. Indeed, the topography is different; still, this is an encouraging story.

Newmonts Idarado Project

Here is, in the words of Newmont, a heartening story of mine closure
(heavily edited).
In 1939, Idarado consolidated a number of mines in the area of the San
Juan Mountains, some of which had been operating since the 1860s.
Idarado continued to operate for another four decades and served a
vital role in providing base metals for the Allies' efforts during World War II. The mine and mill
were closed by 1979.
Beginning in the early 1980s, the mine closure process was very contentious with both the local
communities and with the Colorado's regulatory agencies. After several years of litigation, the
disputing parties agreed to meet to determine the appropriate closure scenario. Idarado
worked collaboratively with the State of Colorado, local county and town governments, and
with local communities to develop a plan that would improve the water quality in the region's
streams and rivers, and would reclaim Idarado's facilities as well as numerous historic mining
sites not operated by Idarado.
In addition to addressing tailing storage areas, the company implemented innovative strategies
to control impacts to surface water from the historic mine rock and tailing, some of which were
mined in the mid-1800s. An extensive network of water collection and diversion channels was
constructed to prevent surface water from forming around mine rock piles. A labyrinth of pipes

and diversion structures were installed within the mine underground workings to direct mine
water rapidly through these preferred paths and ultimately out of the mine. These source
control water-management systems have significantly improved the water quality in the area's
streams, and at the same time, were able to preserve the historic integrity of the old mine
camps and facilities.
Once the closure and reclamation of the many mines were complete, the focus shifted to the
final disposition of 10 000 acres of Idarado-owned and controlled land. From 2001 through
2004, Idarado preserved 5500 acres of land as public open space through its sale to the nonprofit organization, Trust for Public Land, which transferred the land to the Red Mountain
Project and the US Forest Service. The land transfer to public ownership ensures the land will
continue to be available for the broader public's use and will support sustainable livelihoods
into the future based on tourism and recreation.

Suncor Pond 5
Pond 5 at the Suncor oil sands mine in northern Alberta is in the process of being closed.
Closure work currently underway includes placement of geosynthetics over the frozen tailings
and then placement of up to 2 m of coke. This provides a safe trafficable surface from which to
install wick drains that will, in time, dewater the tailings. Once the coke is in place, a layer of
sand and soil will be placed and the area landscaped. Work is planned to be complete by 2019,
so follow progress on the web.