Tommi Kauppila, Geological Survey of Finland, P.O.Box 1237, 70211 Kuopio, Finland; tommi.kauppila(at)gtk.fi
Closure Management Plan is a key document
A key document in managing the mine closure process is the Closure Management Plan (CMP). In many jurisdictions a CMP is required as part of the permitting and licensing process but the mine operator usually has a more detailed, continuously updated and revised CMP to guide the continuous closure efforts during the mining operations. Its evolution starts early in the project, latest during the feasibility phase, with what is commonly a conceptual closure plan, and evolves to a detailed closure plan three to five years before the projected end of the mining operation. With a successful detailed closure plan the facility will know what the outcomes of closure should be and how, when and with which resources these goals will be met in practice. This CMP is also used as a tool for financial planning. This also applies to the post closure period because the CMP also covers the post closure monitoring and maintenance period, either as sections in its Action Plan or as a separate post Closure Management Plan (PCMP).
Benefits of a Closure Management Plan
The greatest benefit of drafting and continuously updating a Closure Management Plan is that it forms a backbone for all closure-related actions during the life of a mining project. This is because it defines a vision of the end result of the closure process and sets concrete objectives to implement that vision (IIED 2002).Therefore, a CMP forms a framework that guides the actions and decisions taken during the mine’s life, provided there is adequate awareness of the CMP and its contents throughout the project.
In many jurisdictions legislation requires a CMP already at the permitting phase so that fulfilling legal obligations becomes a major driver to draft one and to keep it up to date. However, even if formal mine closure plans are not required by the law, they have certain benefits that make them valuable for any mining operation (amended from IIED 2002):
- Public participation: Public participation is essential to successful closure planning. Closure planning usually starts early in the project, at the same time with the EIA process, and relies heavily on the views of the stakeholders on what the post mining uses of the proposed mine site should be and what is their view of the local community after the mine has closed.
- Predictability: Commonly agreed goals for mine closure help in reducing uncertainties about what is expected from the closure process. This, together with appropriate planning and costing of the actions needed to fulfil the goals, helps in estimating the costs of closure and including the costs on balance sheets.
- Continuity: Changes of ownership and management are frequent in mining. A Closure Management Plan helps in maintaining the original goals and focus through these changes all the way until the end of the operations.
- Prevention is better than cure: The CMP defines the physical, chemical and biological conditions of the site that facilitate the agreed post mining land uses. It is usually less expensive to achieve these conditions by preventing pollution and problems of physical stability during planning and operation of the mine than to try to fix the issues at the closure phase.
- Continuous closure: The most common approach to mine closure is that of continuous closure in which closure actions are taken throughout the life of the mine. For instance, individual waste facilities or sections of facilities may be closed years before the cessation of mining.
- Continuous reduction of risks: Perhaps the most common form of continuous closure is reduction of risks and unknowns related to closure during the operation of the mine. For instance, long term weathering tests of tailings materials and cover structures are often made and the facilities that have already been closed are monitored to estimate the performance of the closure methods.
- Financial issues: Many jurisdictions require financial sureties to guarantee that enough funds will be available for mine closure at all times. Mine closure plans and the cost estimates involved can be used to define the amounts of funds required for closure and, with continuous closure, the estimated costs of the remaining closure actions.
- Demonstrating closability: An up to date CMP can be used to demonstrate that the mine can be closed safely at all times during operation. It also serves as a basis for planning the mine’s transition to care and maintenance if that becomes necessary.
Examples of contents and updates of a Closure Management Plan and requirements of Closure Action Plans are presented in the following pages:
IIED, 2002. Breaking New Ground: Mining, Minerals and Sustainable Development. Final Report.450 p. ISBN 1-85383-907-8