PRESENT STATUS OF MINE CLOSURE PLANNING

By
Dr. Kaushik Dey
INTRODUCTION
According to Mudder and Harvey (1998), Proper planning for closure should come
during the feasibility study, design and permitting phases of a mine, and be upgraded
during operational life. This approach has become the standard or is a required
practice today. The lack of a proper or updated mine closure plan can result in
severe environmental and economic consequences. Inadequate closure activities,
water management, and waste rock disposal plans have prompted unexpected and,
in some instances, unwarranted secondary environmental impact statements or
assessments.
According to Nazeri (1999), the objective of mine closure is to provide long-term
stabilisation of the geochemical and geotechnical conditions of the disturbed mining
areas to protect public health, and minimise and prevent any additional or on-going
environmental degradation. Mine closure is, typically, required at a time when the
operation is no longer economically viable, when cash flow is often severely
restricted or negative, and when the value of assets is below the expenditures
required to achieve the environmental objective of mine closure. The objective of
securing mine closure funding at an early stage is to mitigate against the risk that an
enterprise may either be unwilling or unable to undertake mine closure due to lack of
funding. According to Mudder and Harvey (1998), the objectives for closure of a
typical hard rock mine include minimising long-term environmental liability, attaining
regulatory compliance and maintaining geotechnical stability, while closing as quickly
and cost effectively as possible - in a manner that returns the land to a safe and
stable configuration for post-mining uses. Some of the key features that must be
considered during decommissioning and closure of a mine could include any
underground workings, tailings impoundment, open pit, surface waste rock dumps
and spent leach pads.
There are many different words used to describe closure including decommissioning,
reclamation, rehabilitation, and post-closure. In this paper, decommissioning is
referred to as the transitional period between cessation of operations and final
closure. Reclamation refers to the physical aspects of earth moving, regrading and
revegetation. Rehabilitation is another word for closure used primarily in countries
other than the United States. Closure is a term reserved for the point in time at which
revegetation has been completed, excess solutions have been eliminated to the
extent practical, the maximum degree of passive management has been
implemented, and a final surface and/or ground water monitoring programme has
been initiated.
OBJECTIVES OF MINE CLOSURE PLANNING
The development of a Closure Plan needs to take into account both the legal
requirements and the unique environmental, economic and social aspects of the
operation. Outlined below are the typical contents of a Closure Plan, which will vary
depending on individual circumstances. In developing the Closure Plan, the following
four key objectives should be kept in mind:
To protect the environment and public health and safety by using safe and
responsible closure practices;
To reduce or eliminate environmental effects once the mine operations are
ceased;

 To establish conditions which are consistent with the pre-determined land-use

objectives at the end of mining operations;
To reduce the need for long-term monitoring and maintenance by establishing
effective physical and chemical stability of disturbed areas.
So, in essence, the objective of mine closure planning is To ensure that the process
of closure occurs in an orderly, cost-effective and timely manner [1].
GENERAL PRINCIPLES
This part brings together a number of ideas central to public policy and which may be
used to structure a mine closure policy regime.
There should be a plan for mine closure.
Legislation governing mine closure should be followed.
There should be a search for more appropriate technological alternatives
for implementing a mine closure plan.
There should be a search for more economically appropriate alternatives
for carrying out mine closure.
Governments should take into account the interest and opinions of civil
society, especially those communities directly affected by mining
enterprises.
The experiences of those countries which have a well developed mine
closure policy regime should be taken into account.
Specific standards or closure requirements should reflect a careful
balancing of the benefits and costs of the standards or requirements.
Policies should be designed to encourage mine owners to achieve a
specific standard or requirement at lowest cost.
Policies should be designed to encourage or provide incentives for
technological innovation in mine closure, to reduce costs of compliance
(economic incentives tend to provide greater incentives for innovation than
technology or performance standards).
Or in short:
1.
Mine closure should be integral to the whole of mine life plan.
2.
A risk-based approach to planning should reduce both cost and
uncertainty.
3.
Closure plans should be developed to reflect the status of the
project or operation.
4.
Closure planning is required to ensure that closure is technically,
economically and socially feasible.
5.
The dynamic nature of closure planning requires regular and
critical review to reflect changing circumstances. [1]
LEGISLATIVE REQUIREMENTS
Wanda Hoskin, from UNEP, has declared while current policy and legislative
frameworks vary widely around the world, it is increasingly important that countries
formulate clear, stable and predictable policies for industry to follow. These policies
can evolve but should not fluctuate nor be unequally applied. It is equally important
to recognize that each mine is unique, that some flexibility will be required as the
mine operates and that artisan, hard rock and coalmines and aggregate operations
are different.
Guiding Principles:

 All mines should have a closure plan and the combined set of activities should
comply with existing regulations.
The competent authority must approve the closure plan.
The aforementioned competent authority shall verify regulatory compliance for
all or part of the actions or commitments of such a closure plan.
The implementation of a closure plan maybe carried out gradually beginning
with the closure start-up.
Should there be any changes in regulations governing these matters, or any
other technological or operational alterations, the mine closure plan may be
modified.
Once the plan is put into operation, the competent authority shall issue a
recognition of the same that, in certain cases, may be only partial.
Each closure plan will address specific requirements according to the
particular features of each mine.
The closure plan should set out the financial means for ensuring its
subsequent execution.
Purpose:
To be able to count on a body of systematic regulations that approach mine
closure in an integral manner.
To be able to count on a modern and efficient governmental administration
and supervision of the entire policy regime affecting mine closure.
To achieve harmonization of all such policy regimes in the country.
The Indian Scenario:
The Central Government vide Notification No. GSR 329 (E) dated 10.04.2003 and
No. GSR 330 (E) dated 10.04.2003 amended the Mineral Concession Rules, 1960
and Mineral Conservation and Development Rules, 1988 respectively. As per these
amendments all the existing mining lessees are required to submit the "Progressive
Mine Closure Plan" along with prescribed financial sureties within 180 days from
date of notification. Further, the mining lessee is required to submit "Final Mine
Closure Plan" one year prior to the proposed closure of the mine. In the notification it
has been enumerated that the "Progressive Closure Plan" and "Final Closure Plan"
should be in the format and as per the guidelines issued by the Indian Bureau of
Mines [5]
Every mine shall have a Mine Closure Plan which shall be of two types:
Progressive Mine Closure Plan
Final Mine Closure Plan
The Plans have to be approved by IBM or State government. The plans shall
cover protective, reclamation and rehabilitation activities
The lease holder shall furnish financial assurance for implementation of plan,
which could be in the form of letter of credit from a Scheduled Bank, Security
Bond etc.
Future Legislative requirements
Taking note of the MCDR & latest amendment, the following changes are needed for
coal sector:
1. Incorporate requirements of reclamation of land into coal mines (conservation
& development) rules.
2. Establish some form of Reclamation Trust Fund/Financial Guarantee. This
should be a pre-requisite before the grant of a mining lease.

3. MoEF should bring out detailed guidelines on decommissioning of a mine site

and post closure monitoring.
4. Ensure planning for closure as under MCDR
METHODOLOGY OF MINE CLOSURE PLANNING
Proper planning for closure should come during the feasibility study, design and
permitting phase of a mine, and be upgraded during operational life. The lack of an
up-to-date mine closure plan can result in severe environmental and economic
consequences (Mudder & Harvey, 1998).
The broad aims of closure planning are to:
Protect the environment and public health and safety by using safe and
responsible closure practices;
Reduce or eliminate adverse environmental effects once the mine ceases
operations;
Establish conditions which are consistent with the pre-determined end land
use objectives; and
Reduce the need for long-term monitoring and maintenance by establishing
effective physical and chemical stability of disturbed areas.
Integration:
Closure should be integral to the whole of mine life plan. Mine closure should not be
an end of mine life process, but should be integral to whole of mine life if it is to be
successful. Planning for closure should commence at the feasibility phase of an
operation. In this way, future constraints on, and costs of, mine closure can be
minimised, post-mining land use options can be maximised and innovative strategies
have the greatest chance of being realised. The mine closure planning should be an
integral part of mine planning to ensure the process of closure occurs in an orderly,
cost-effective and timely manner.
Risk-based Approach:
A risk-based approach to planning should reduce both cost and uncertainty. Current
trends in closure planning involve technical review and analysis of risk and cost
benefit in both engineering and environmental terms. The advantages of a riskbased approach to closure planning lie in the quantification of subjective factors and
the analysis of uncertainty related to both design performance and cost (Morrey,
1999). The objective of a risk-based approach is to reduce both cost and uncertainty.
CLOSURE PLANS
Closure plans should be developed to reflect the status of the project or operation. At
least two types of closure plan will be required through the life of a mine; a
Conceptual Closure Plan (project phase) and the Actual Closure Plan (operations
phase):
A Conceptual Closure Plan for use during feasibility, development and detailed
design; and
An Actual Closure Plan for use during construction, operation and post-operation
Conceptual Closure Plan: A Conceptual Closure Plan identifies the key objectives
for mine closure to guide project development and design. It should include broad
land use objectives and indicative closure costs.(This does not preclude land use
objectives being varied during the mine life to reflect changes in both knowledge and
technology).

Actual Closure Plan: Closure planning includes a commitment to progressive

rehabilitation and detailed plan development and implementation. A number of
subsidiary plans need to be developed as the Closure Plan evolves. These typically
include: a rehabilitation plan, a decommissioning plan and a maintenance and
monitoring plan.
Rehabilitation plan: A key component of the Closure Plan is a commitment to
progressive rehabilitation. In conjunction with an active research and trial
programmes, this may assist in minimising ongoing contamination and reduce final
costs by confirming or modifying completion criteria and demonstrating that they can
be met. Progressive rehabilitation allows best use of available personnel and
equipment and should assist in minimising required security deposits.
Decommissioning plan: As a detailed component of the Closure Plan, a
decommissioning plan should be developed towards the final stages of an operation.
(As the exact date for ceasing production is rarely known, it is suggested that the
decommissioning plan be developed 2 to 4 years prior to estimated cessation). Once
established it should be updated annually. The decommissioning plan includes such
things as: details of the demolition and removal or burial of all structures not required
for other uses; removal, remediation or encapsulation of contaminated materials; and
the procedures for making safe and sealing, openings to underground workings.
Maintenance and monitoring plan: The last aspect of the Closure Plan is
performance monitoring, which should be designed to demonstrate that the
completion criteria have been met. This period should also plan for remedial action
where monitoring demonstrates completion criteria are unlikely to be met. If
progressive rehabilitation has been successful, with stabilisation and revegetation
meeting completion criteria this last phase of closure may be shortened. It is,
however, unlikely to be less than 5 years in duration.
Content of Closure Plans (Canadian Views)
A closure plan must include the following:
(a) The name and address of the proponent or operator of the project;
(b) The name of the project;
(c) The legal description of the project site;
(d) The name, address and telephone number of any person authorized to act on
behalf of the proponent or operator in respect of the plan;
(e) The surface rights, mineral rights or mineral access rights held by the
proponent or operator in respect of the project site;
(f) The previous use of the project site;
(g) A description of any previous disturbance or other activity that has, or could
have, resulted contamination of the project site or land adjoining the site;
(h) Current conditions and activities on the site and security measures employed;
(i) A plan showing the location and use of equipment, machinery, buildings and
other structures on the project site or in the area in which the site is located;
(j) A plan of the project site or the area in which the site is located, drawn to
scale and showing the boundaries of the proponent's surface rights and the
areas within those boundaries that will or could be subject to disturbance,
alteration or contamination as a result of the project;
(k) Mining and milling processes to be employed in the operation of the project
and the planned production levels expressed in tonnes per day;
(l) The expected life of the project expressed in months or years;
(m) The nature, location and expected size of areas for the storage of tailings,
including associated structures and treatment systems;
(n) Dams and other drainage control structures and details of watercourses;
(o) Crown pillars and mine openings to the surface;

(p)
(q)
(r)
(s)
(t)

(u)
(v)

An assessment of the effect of all mine openings on the stability of the surface
areas above and adjacent to areas of mining activity to determine whether the
surface areas are likely to be disturbed;
A description and schedule of any development work that could cause
disturbances or hazards at the project site or land adjoining the site;
The nature and location of systems for the treatment, management or
disposal of waste and for storage of petroleum products, chemicals,
hazardous substances and toxic substances;
Expected conditions of and uses for the project site following permanent
closure of the project and rehabilitation of the site;
The stages by which the project will be temporarily or permanently closed, a
schedule of the practices and procedures by which progressive rehabilitation
of the project site will be carried out during the life of the project and at each
stage of closure;
The monitoring to be carried out at the project site during the life of the project
and at each stage of closure;
The procedures to be used to evaluate and verify compliance with the plan
during the life of the project and at each stage of closure;

Content of Closure Plans (Australian Views) [1]

Typical contents of a Closure Plan (not a minimum requirement or template):
Introduction & Project Description
Land tenure
Objectives of Closure
Baseline Environmental Data
Legal & Other Obligations
Key statutes & regulations
Responsible Authority
Regulatory instruments
Stakeholder Involvement
Stakeholder identification
Community consultation
Risk Assessment
Existing legacies
Future risks
Cost/benefit analysis
Closure Criteria
Closure Costs
Provisions
Securities
Closure Action Plan
Human resources/responsibilities
Progressive rehabilitation
Decommissioning
Remediation
Geotechnical assessment
Landform establishment
Revegetation
Aesthetics
Heritage
Health & safety
Post-closure maintenance & monitoring
Survey (remaining structures & areas of contamination)

 Documentation/reporting/records
Tenement Relinquishment

Content of Closure Plans (Indian Views) [6]

1. Introduction:
The name of the lessee, the location and extent of lease area, the type of lease area
(forest, non-forest etc), the present land use pattern, the method of mining and
mineral processing operations, should be given.
1.1 Reasons for closure: The reasons for closure of mining operations in relation to
exhaustion of mineral, lack of demand, uneconomic operations, natural calamity,
directives from statutory organisation or court etc. should be specified.
1.2 Statutory obligations : The legal obligations, if any which the lessee is bound to
implement like special conditions imposed while execution of lease deed, approval of
mining plan, directives issued by the Indian Bureau of Mines, conditions imposed by
the Ministry of Environment and Forests, State of Central Pollution Control Board or
by any other organisation describing the nature of conditions and compliance
position thereof should be indicated here (the copies of relevant documents may be
attached as Annexure).
1.3 Closure plan preparation: The names and addresses of the applicant and
recognised qualified person who prepared the Mine Closure Plan and the name of
the existing agency should be furnished. A copy of the resolution of the Board of
Directors or any other appropriate administrative authority as the case may be on the
decision of closure of mine should be submitted.
2. Mine Description:
2.1 Geology: Briefly describe the topography and general geology indicating rock
types available, the chemical constituents of the rocks / minerals including toxic
elements if any, at the mine site.
2.2 Reserves: Indicate the mineral reserves available category wise in the lease area
estimated in the last mining plan / mining scheme approved along with the balance
mineral reserves at the proposed mine closure including its quality available ( for
final mine closure plan only).
2.3 Mining Method: Describe in brief the mining method followed to win the mineral,
extent of mechanisation, mining machinery deployed, production level etc.
2.4 Mineral Beneficiation: Describe in brief the mineral beneficiation practice if any
indicating the process description in short. Indicate discharge details of any
tailings/middlings and their disposal/utilisation practice followed.
3. Review of Implementation of Mining Plan / Scheme of Mining including five years
Progressive Closure Plan upto final closure of mine:
Indicate in detail the various proposals committed with special emphasis on the
proposals for protection of environment in the approved Mining Plan / Scheme of
Mining including five years Progressive Closure Plan upto the closure of mine vis-vis their status of implementation. Highlight the areas, which might have been
contaminated by mining activities and type of contaminants that might be found
there. The reasons for deviation from the proposals if any with corrective measures
taken should also be given.
4. Closure Plan:
4.1 Mined-Out Land: Describe the proposals to be implemented for reclamation and
rehabilitation of mined-out land including the manner in which the actual site of the
pit will be restored for future use. The proposals should be supported with relevant

plans and sections depicting the method of land restoration / reclamation /

rehabilitation.
4.2 Water Quality Management: Describe in detail the existing surface and ground
water bodies available in the lease areas and the measures to be taken for
protection of the same including control of erosion, sedimentation, siltation, water
treatment, diversion of water courses , if any, measures for protection of
contamination of ground water from leaching etc. Quantity and quality of surface
water bodies should also be indicated and corrective measures proposed to meet
the water quality conforming the permissible limits should also be described. Report
of hydrological study carried out in the area may also be submitted. The water
balance chart should be given. If there is potential of Acid Mine Drainage the
treatment method should be given.
4.3 Air Quality Management: Describe the existing air quality status. The corrective
measures to be taken for prevention of pollution of air should be described.
4.4. Waste Management: Describe the type, quality and quantity of overburden,
mineral reject etc. available and their disposal practice. If no utilisation of waste
material is proposed, the manner in which the waste material will be stabilised
should be described. The protective measures to be taken for prevention of siltation,
erosion and dust generation from these waste materials should also be described. If
toxic and hazardous elements are present in the waste material the protective
measures to be taken for prevention of their dispersal in the air environment,
leaching in the surface and ground water etc, should be described.
4.5 Top Soil Management: The top soil available at the site and its utilisation should
be described.
4.6 Tailing Dam Management: The steps to be taken for protection and stability of
tailing dam, stabilisation of tailing material and its utilisation, periodic de-silting,
measures to prevent water pollution from tailings etc., arrangement for surplus water
overflow along with detail design, structural stability studies, the embankment
seepage loss into the receiving environment and ground water contaminant if any
should be given.
4.7 Infrastructure: The existing infrastructural facilities available such as roads, aerial
ropeways, conveyer belts, railways, power lines, buildings & structures, water
treatment plant, transport, water supply sources in the area etc. and their future
utilisation should be evaluated on case to case basis. If retained, the measures to be
taken for their physical stability and maintenance should be described. If
decommissioning proposed, dismantling and disposal of building structures, support
facilities and other infrastructure like electric transmission line, water line, gas
pipeline, water works, sewer line, telephone cables, underground tanks,
transportation infrastructure like roads, rails, bridges, culverts etc., electrical
equipments and infrastructures like electric cables, transformers to be described in
connection with restoring land for further use.
4.8 Disposal of Mining Machinery: The decommissioning of mining machineries and
their possible post mining utilisation, if any, to be described.
4.9 Safety and Security: Explain the safety measures implemented to prevent access
to surface openings, excavations etc., and arrangements proposed during the mine
abandonment plan and upto the site being opened for general public should be
described.
4.10 Disaster Management and Risk Assessment : This should deal with action plan
for high risk accidents like landslides, subsidence flood, inundation in underground
mines, fire, seismic activities, tailing dam failure etc. and emergency plan proposed
for quick evacuation, ameliorative measures to be taken etc. The capability of lessee
to meet such eventualities and the assistance to be required from the local authority
should also be described.

4.11 Care and maintenance during temporary discontinuance: For every five yearly
review (as given in the mining scheme), an emergency plan for the situation of
temporary discontinuance or incomplete programme due to court order or due to
statutory requirements or any other unforeseen circumstances, should include a plan
indicating measures of care, maintenance and monitoring of status of unplanned
discontinued mining operations expected to re-open in near future. This should detail
item wise status monitoring and maintenance with periodicity and objective.
5. Economic Repercussions of closure of mine and manpower retrenchments:
Manpower retrenchment, compensation to be given, socio-economic repercussions
and remedial measures consequent to the closure of mines should be described,
specifically stating the following.
5.1 Number of local residents employed in the mine, status of the continuation of
family occupation and scope of joining the occupation back.
5.2 Compensation given or to be given to the employees connecting with sustenance
of himself and their family members.
5.3 Satellite occupations connected to the mining industry - number of persons
engaged therein - continuance of such business after mine closes.
5.4 Continued engagement of employees in the rehabilitated status of mining lease
area and any other remnant activities.
5.5 Envisaged repercussions on the expectation of the society around due to closure
of mine.
6. Time Scheduling for abandonment: The details of time schedule of all
abandonment operations as proposed in para-4 should be described here. The
manpower and other resources required for completion of proposed job should be
described. The schedule of such operations should also be supplemented by PERT
(Programme Evaluation & Review Technique), Bar-chart etc.
7. Abandonment Cost: Cost to be estimated based on the activities required for
implementing the protective and rehabilitation measures including their maintenance
and monitoring programme.
8. Financial Assurance: The financial assurance can be submitted in different forms
as stated in Rule 23(F)(2) of Mineral Conservation and Development (amendment)
Rules, 2003. In the mine closure plan, the manner in which financial assurance has
been submitted and its particulars have to be indicated.
9. Certificate: The above mentioned actions have been taken to be stated clearly in
the mine closure plan. A certificate duly signed by the lessee to the effect that said
closure plan complies all statutory rules, regulations, orders made by the Central or
State Government, statutory organisations, court etc. have been taken into
consideration and wherever any specific permission is required the lessee will
approach the concerned authorities. The lessee should also give an undertaking to
the effect that all the measures proposed in this closure plan will be implemented in
a time bound manner as proposed.
10. Plans, Sections etc.: The chapter 1, 2, 3 and 4 should be supported with Plans
and Sections. The Closure Plan may also be submitted depicting photographs,
satellite images on compact disc etc. wherever possible.
PROCEDURAL STEPS OF MINE CLOSURE [7]
The sequence of Mine closure planning and implementation could be as follows:
Closure Feasibility

Closure planning is required to ensure that closure is technically, economically and

socially feasible. Being able to successfully close a mine, is critical to project
approval. It is necessary to ensure that closure is technically, economically and
socially feasible without incurring long-term liabilities. These issues are initially
addressed in the Conceptual Closure Plan, which should include preliminary land
use objectives to ensure that closure concepts are factored into final project design.
Regular and Critical Review
The dynamic nature of closure planning requires regular and critical review to reflect
changing circumstances. The Closure Plan should be modified as a result of any
operational change, new regulations or new technology, and should be
comprehensively reviewed on a regular and pre-determined cycle (e.g. every 3 to 5
years). It should always remain flexible enough to cope with unexpected events. The
Plan should include the management of social as well as environmental issues.

Fig. 1 Procedural steps of mine closure [7]

CONCLUSIONS
There are basically two main aspects of mine closure planning firstly,
environmental stabilisation and secondly, the economic repercussions. Among these,
economic repercussion demands judicial planning with especial consideration of the
sentiments of the local residents. It is evident that alternate resource generation in
terms of cultivation is almost impossible. In fact, post mine land profile permits set up
neither of industries nor of other long term resource generation activities. This leads
to migration of the local residents in search of food. A common solution to this

problem can not be established. However, a site-specific guideline should have been
established for the mines in future.

References:
[1] Anon (2000), Strategic Frame Work for Mine Closure, Publication by Australian
and New Zealand Minerals and Energy Council and Minerals Council of Australia.
[2] Mudder, T. & Harvey, K. (1998), Closure Concepts Mining Environmental
Management, November, 1998.
[3] Miller, C. G. (1998) Use of Financial Surety for Environmental Purposes, ICME
Limited, Edition Publications (available from www.icme.com), 54 pp.
[4] Morrey, D.R. (1999), Principles of Economic Mine Closure, Reclamation & Cost
Management, Remediation and Management of Degraded Lands. M.H. Wong et
al. (eds). Lewis, New York.
[5] Anon (1988) Mineral Concession and Development Rules.
[6] Anon (2005) down loaded from Indian Bureau of Mines website.
[7] Anon (2000), down loaded from SRK News, issue no. 26, July 2000, P10.