Manual for Environmental Procedures

and Implementation of EMS in the

Mining Sector

December 2006
Manual for Environmental Procedures
and Implementation of EMS in the Mining Sector
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CONTENTS

INTRODUCTION
IMPLEMENTATION OF AN EMS IN THE MINING SECTOR
BEST PRACTICE IMPLEMENTATION IN THE MINING SECTOR

MANUAL - PART 1 – Environmental Management System

1. Introduction
1.1. Principles, objectives, key steps in the mining sector
1.2. Benefits to implement a mining EMS
1.3. Integration into strategic planning
2. Implementation of an EMS in the mining sector
2.1. The generic steps:
Organisational Commitment

Environmental Policy

Planning Elements
- Environmental Aspects
- Legal & Other Requirements
- Community Consultation
- Objectives & Targets
- Environmental Management Programme

Implementation Elements
- Structure & Responsibilities
- Training, Awareness & Competence
- Communication
- EMS Documentation
- Document Control
- Operational Control
- Emergency Preparedness and Response

Checking & Corrective Actions

- Monitoring & Measurement
- Non-conformance and Corrective/Preventive Action
- Control of Records
- Internal Audit

Management Review

2.2. Operational Procedures

Annex 1 – Responses to questionnaires submitted to the mining companies

Annex 2 – Example of Legislation Register
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MANUAL - PART 2 – Best Practices for the mining sector

1. Introduction to the Topic

2. Best Practices in the different mining sectors

2.1. SEA outcomes on mining sector issues in Romania

2.2. Selected Best Practices for the Romanian mining sector

2.3. Water management

- Water Management Plan
- Erosion & sediment control plan
- Flood risk management

2.4. Acid Mine Drainage

- Acid drainage prevention
- Acid drainage control & treatment

2.5. Waste Rock Management

- Waste management plan
- Backfilling
- Tip construction design / location
- Waste rocks recycling

2.6. Tailings Management

- A tailing management plan
- A risk assessment of tailings facilities
- Emergency planning for tailings & facilities
- Dry cover for tailings closure management

2.7. Hazardous materials management

- A comprehensive management plan
- Cyanide management

2.8. Air & Dust management

- Air quality management plan
- Gas monitoring strategies during or following closure of coal mines

2.9. Subsidence management

- Subsidence management plan

2.10. Community involvement

- Public participation
- Stakeholder dialogue during rehabilitation and closure

2.11. Closure and rehabilitation management

- The closure management plan
- Closure and remediation measures for Uranium mines
- Specific measures for salt mine closure & remediation
- Progressive rehabilitation
- Closure and biodiversity
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INTRODUCTION

Restructuring of the Romanian mining sector is a complex process, which involves economic,
social and environmental aspects. The Romanian legislation, together with the radical
changes that these activities face, also undergoes an improvement process for a better
correspondence with the EU legislation. In this line, the mining companies are facing
increasing difficulties in identifying, accessing and understanding all the legal and other
requirements to which they subscribe, directly applicable to the environmental aspects
associated with their activities, products and services.

Given the perspective of the close EU accession, Romania must ensure a better quality of
the environment. Romania has adopted new laws and standards by transposing the
environmental EU Directives. Although costly and demanding, implementation of these
Directives represents a radical change of the national policy and approach regarding
environmental protection. One of the above mentioned Directives is Directive 96/91/CE
concerning Integrated Pollution Prevention and Control (IPPC). The purpose of the Directive
is to create an integrated system to prevent and control pollution caused by activities
included in Annex I to the Directive.

The specific requirements concerning integrated approach, according to the provisions of

the Directive 96/91/CE, have been entirely transposed into Romanian legislation by
Governmental Emergency Ordinance (GEO) no 152/2005 concerning integrated pollution
prevention and control, approved by Law no 84/2006. Also, several direct legal instruments
have been issued for Directive implementation.

The Directive, as well as the legislation transposing it, provides for a permitting system
applicable to certain categories of industrial activities, imposing both on the operators and
regulators to use a global, integrated approach to the potential polluter of an activity. The
overall purpose of this approach must be management improvement and control of the
industrial processes so as to achieve a high level of protection of the environment taken as a
whole. The essence of this approach is the general principle according to which operators
must take all the appropriate measures for pollution prevention, particularly by implementing
the Best Available Techniques (BAT) that enable improvement of their environmental
performances.

In order to support the economic operators, as well as the regulators, the European IPPC
Bureau has published the BAT Reference documents (BREF notes) for the sectors of activity
included in Annex I to the Directive. These documents, based on the exchange of information
between Member States and the respective industries, contain detailed technical and
economic information for the sector being analysed.

In this line, Reference Document of Best Available Techniques for Management of Tailings
and waste Rock in Mining Activities was prepared for mining techniques and industry. The
document covers issues related to tailings and waste rock management that have the
potential for a significant environmental impact. In particular, the work sought out activities
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that can be considered as examples of “good practice”, with the intention to raise awareness
of such practices and promote their use across all specific phases of the mining sector.

To present, only a few BAT Reference documents have been adapted to the Romanian
specific conditions and approved by legal acts (cement and lime, pulp and paper). All the
other BAT reference documents (BREF) corresponding to activities/installations, as approved
by Annex 1 to GEO no 152/2005 and adopted as final documents by EU, are currently
approved through direct confirmation method by Ministry of Environment and Water
Management (MEWM) Order no 169/2.03.2004.

Use of management techniques, including preparation and implementation of an

Environmental Management System (EMS) by the mining companies – certified or not under
an international standard, is the basic approach within the Reference Document of Best
Available Techniques for Management of Tailings and waste Rock in Mining Activities.
International standards regarding environmental protection support companies throughout
the systematic approach of the environmental aspects they face, synthesising all the
advantages of an efficient management in a unitary structure. These are internationally
agreed standards, based on voluntary action – they are not compulsory in any country or
geographic area of the world. In this regard, there is no single, unique way of designing an
implementing an EMS in conformity with an international standard.

There are basically two internationally applied certification schemes for a company’s EMS,
ISO 14001 and EMAS - EU Eco-Management and Audit Scheme, which are being used by
more and more companies as a recognition that the EMSs they have implemented meet the
generally accepted requirements of these schemes.

These international EMS certification schemes, ISO 14001 and EMAS, have the role of
guiding companies on the path of attaining their goals and objectives, and are designed in
such a way as to offer sufficient flexibility in implementation for any size of business.

In Romania, this activity is regulated by Order no 50/2004 (amended by Order no 444/2006)

regarding defining the procedure for establishing and co-ordinating the environmental
management and audit schemes (EMAS) with a view to organisations’ voluntary participation
to these schemes. The role of such scheme includes:

- implementation of EMAS for organisations developing activities with an

environmental impact

- assessing and improving the organisations’ environmental performances

- supplying relevant environmental information to public and other stakeholders.

As regards the mining sector, all mining operations, both large and small scale, are
associated with environmental and human health impacts throughout the entire life cycle of
the operation, from the exploration phase to the closure and post-closure stages. Following
the increased public awareness and public pressure upon the mining industry with respect to
its environmental impacts, mining companies have started to give enhanced consideration to
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environmental issues. Furthermore, permitting for waste dumps and tailings disposal facilities
is a complex process, based on knowledge of the best practices in the field.

The recent developments in environmental management, including new management tools and
instruments for planning and operation, have demonstrated that significant improvements are
possible in the environmental performance of industries, including the mining industry, and that
its impacts can be significantly reduced.

It is now generally accepted that with effective planning, modern technology and careful
management, much of the degradation historically associated with mining can be avoided
and mining can be pursued at an acceptable environmental cost.

Today, more than ever, it is recognised that effective pollution control cannot be achieved
based exclusively on technological solutions, but it has to be addressed within an
environmental management system, integrated into the company’s general management.

Environmental Management is a systematic and holistic approach to environmental aspects

of an operation, which brings companies enhanced advantages, both in terms of operation
and public image. Although a voluntary action, mining and other companies are increasingly
assessing the benefits of adopting environmental management as well as the risks of not
adequately addressing environmental issues such as accidents, inability to obtain bank credits
and other investment money and loss of markets.

This is why, the Manual for Environmental Procedures and Implementation of

Environmental Management System in the Mining Sector is designed to establish a
framework within which the mining companies can promote adequate environmental
management systems throughout their mining project’s life, while incorporating the best
international practices, in order to:
· minimise the environment-related risks
· achieve good environmental performance
· minimise conflicts with other land users
· maintain ecological values in surrounding areas, and
· restore or enhance the land use capability of the areas affected by their activities.
The Manual defines how to integrate an environmental management system - EMS into
mining and related operations, how it can contribute to Best Practice in the field, and
provides guidelines to facilitate implementation.

In this line, the purpose of this Manual is to provide guidance to facilitate an EMS
implementation that systematically addresses the environmental effects of mining operations.
Apart of these, in the current continuous changes in the legislative framework in Romania
and more and more legislative requirements, the mining sector faces many challenges that
can be solved by integrating the environmental aspects in the company’s general
management. In this context, this Manual represents a tool resource that should help the
various mines to meet these challenges more effectively.
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Furthermore, the Manual provides explanations with the help of examples and best
practices case studies applicable in the field, allowing for an easy understanding of the
Reference Document of Best Available Techniques for Management of Tailings and waste
Rock in Mining Activities, which must be accounted for during the permitting process.

The preparation of this Manual has taken into consideration provisions of Romanian
legislation and EU legislation (in particular the IPCC Directive, the Mining Waste and the
Water Framework Directives). It has been developed by approaching each of the following
sub-sectors, both for open pit and underground mining:
· coal (hard coal, lignite);
· metallic and non-metallic;
· uranium;
· salt.

Manual Structure

The Manual is organised in two parts which cover the environmental management system
and the technical issues as follows:

The first part of the manual is a tool to contribute to the implementation of an

Environmental Management System in the mining sector by :

· explaining the principles of environmental management system and how they can
be applied in practice
· outlining the role and key components of the system.
The Manual Part 1 was develop with the main objective to provide a guide to develop
within each Mining Company an environmental management system as a means to
improve the current environmental condition, to comply with the relevant
environmental legislation and meet the applicable standards as well as for ensuring
that the best practices relevant to the mine industry are voluntary undertaken.

The Part 1 includes instruments for ensuring that the Mining Company meets these
environmental requirements and voluntary undertakings, once they have been
identified and included in the management system. Also, a set of forms is provided in
order to be used by Mining Companies to develop their own EMS.

Moreover in order to properly develop, implement and maintain a system, operations

are required to document “how” individual elements of the system function at their
site. The Operational Procedures that form part of the Mine Environmental
Management System define “what” needs to be developed and implemented and a
few examples of these procedures have been included.

The second part of the manual (Manual Part 2) describes best operational
practices that if implemented and maintained in place will assist mining companies in
reducing and/or eliminating adverse environmental impacts. A total of 25 best
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practices have been described and illustrated in the Part 2 by worldwide mining case
studies. The examples provided address all spectrums of environmental aspects
relevant to the mining sector, with a view to encourage the mining companies to use
them to prevent pollution, even before it is created. At the same time, Best Practice
emphasises not only on achieving continuous environmental improvement, but also
on keeping the costs of environmental protection as low as possible.

Taking into account the number of potential topics and the size of the Manual, a large
number of information sources have been appropriately acknowledged together with
a previous extensive relevant experience of the project team members in the mining
sector. Other potential references in the field of the project topics are also indicated
for further use.

As best practice in environmental protection is not a fixed standard, it can change

with developments in technology and vary with the local environment, and the local
economic context. It is the reason why best practice needs to be tailored for the site
to ensure that effective environment protection is compatible with efficient production.
In the context of specific types of operation and mine sites, it is possible to introduce
the concept of Best Available Techniques (BAT), which at a specific time produce the
minimum environmental pollution and degradation that can be reasonably achieved.

What are the links between Part 1 and Part 2 of the Manual?

An environmental management system (EMS) is a set of management tools and principles

designed to guide the allocation of resources, assignment of responsibilities and ongoing
evaluation of practices, procedures, and processes that a Mining Company needs to
integrate environmental concerns into its daily business practices.

Best practice can simply be explained as "the best way of doing things", but in others
words, the term “best practice” describes a management approach involving a commitment
to achieve outcomes beyond those expected for regulatory compliance. To achieve best
practice, a Mine operator would be expected to have developed management systems that
ensure the identification of opportunities for improvement and to see that change is
implemented, monitored and evaluated. Best practice environmental management in mining
thus demands a continuing, integrated process through all phases of a resource project from
the initial exploration to construction, operation and closure.

In the approach designed by the consultants, the EMS as presented in Part 1 of the Manual
is the core of the process. Within this process, Best Practices (presented in Part 2) that can
be supported by environmental guidelines that relate to specific technical issues will play a
key role as references at different levels of the EMS, such as:

· Within the initial step of the EMS, during the Initial Environmental Review in
particular for setting objectives and targets and environmental management
programmes that should be set within the context of how best to meet the aims of
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the Environmental Policy (establish priorities for action in relation with those
operations and activities associated with the identified significant environmental
aspects)

· Within the Operational Control step which provides the mechanisms by which
the environmental policy, objectives and targets are converted into action. At that
level it is important to develop procedures for controlling key activities and
operations that are associated with significant environmental aspects.

The structure and relationships between the two parts of the manual are illustrated by the
following diagram:
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Manual Part 1

SYSTEM PROCEDURES

Policy
Planning
Implementation /Operation Manual Part 2
Monitoring / Corrective action
BEST PRACTICES on:
Review
Water Management

Waste rocks
Management

Tailings Management
Environmental
Management Hazardous substances
System Air/Dust Management

Acid Mine Drainage

Subsidence
Management

OPERATIONAL Community involvement

PROCEDURES
Closure/Rehabilitation
Management
Hazardous substances
management
Waste management
Land management
Water management
Air & noise management
Flora & fauna management
Closure & rehabilitation
Energy management
Etc.
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IMPLEMENTATION OF AN EMS IN THE MINING

SECTOR

The Manual with the two mentioned Parts – 1 and 2 – was designed for use by the mining
companies interested to implement its own EMS. In addition to EMS elements and the
associated related tools described in details in Manual Part 1, we developed based upon our
companies previous experience an Implementation Plan.

This Implementation Plan consists in a step-by-step guidance to develop, document, and

implement an environmental management system (EMS), including operational procedures
based on the best practices specific for a Mining Company. This will lead to the completion of
an EMS specific to each Mining Company.

However, in practice it is likely that these steps will overlap or run in parallel according to the
size of the Mining Company, scope of the environmental procedures and EMS being created,
existing management systems etc.

Similarly, each step will not necessarily require the same level of input or time to complete. In
this reason, the Implementation Plan should be used as the basis of a Mining Company
specific project plan. The timescales within this plan will be entirely dependant on Mining
Company circumstances.

It is essential that this Implementation Plan to be used in conjunction with the other two parts
of the Manual which offer useful information in effectively assisting the Mine Companies in
their environmental performance improvement.
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STEP
Gain Management Commitment & Appoint EMS Team
1

Purpose This is the most important component of any Environmental

Management System. All levels within the Mining Company will
need to be committed to the EMS process. The commitment is
important from the chief executives down to the line managers.
This commitment is often referred to as a change in the Mining
Company’s culture with respect to the environment. Such cultural
change is possibly the greatest task faced in the successful
implementation of an EMS. Without such a commitment the
potential benefits to a company from the EMS will not be realised.

Recommended Identify any reasons for implementation e.g. customer

Steps pressure, corporate policy etc.

List the benefits that you can obtain for your Mining Company
through the implementation of EMS

Use an Implementation Plan (Flow Sheet) to describe to the

Management Team / Board how implementation will be achieved

Draft a Team who you consider will be central to the

implementation process. The Team should include
representatives from the key departments on site

Draft a list of persons who will have roles and responsibilities

within the EMS (can be summarised as an organogram or
structure chart)

Estimate how much time and effort (and costs) will be involved
in gaining certification

Submit your proposals for the implementation plan, roles and

responsibilities, resources and timescales to the top
management for approval

Top management to issue memo appointing the EMS

Coordinator and EMS Team
Top management to issue an internal notice describing why
the Mining Company is implementing an EMS, the key roles and
responsibilities and target dates. This notice should describe the
need for all staff to cooperate with and become involved in
implementing the EMS.
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Documents ü Memo from top management appointing the EMS

generated Coordinator and EMS Team and giving instruction to
proceed with EMS implementation
ü Staff notice describing the Mining Company’s’ intention to
implement an EMS
ü Mining Company chart showing environmental roles and
responsibilities across the Mining Company

STEP
Undertake Initial Environmental Review or Gap Analysis
2

Purpose A fundamental concept of the EMS is continual improvement of

environmental performance. Before the Mining Company can
plan for improvement, it must first determine the current state of
the organization's environmental programs.
The purpose of the Initial Environmental Review (IER) is to
provide a starting point for the development of the EMS and to
identify the main issues that the EMS will need to address.
An Initial Review is also important in ensuring that EMS design is
compatible with all current organizational management structures
and operations wherever possible. The focus will be to achieve
operational efficiencies that ensure environmental improvements
and maximize cost reductions.
The Gap Analysis allows for a quick but comprehensive
assessment of the Mining Company’s existing environmental
management practices and procedures, and compares them with
the requirements of the Standard.

Recommended The Initial Review should cover the tasks listed below:
Steps
- identify if there have been any previous environmental
incidents on site and find out what was done about them
- assess how you can utilise any existing management
systems to help build the EMS
- summarise your initial thoughts on what are the key
environmental impacts at your Mining Company

Convene a meeting of the EMS Team to discuss the findings

from the above task and outline the initial scope of the EMS (this
will include consideration of the Mining Company’s “sphere of
influence”). Minute the meeting to form a record of the IER
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Recommended Top Management to convene a meeting of management and

Steps EMS Team to discuss the findings of the Initial Environmental
Review and to agree the initial scope of the EMS. Minute the
meeting

Prepare a draft summary of the EMS; begin with a description

of company activities, scope of the EMS, general responsibilities,
process flow diagram

Documents ü An EMS Gap Analysis Design that details where existing

generated environmental management procedures must be further
investigated to determine conformance with the Standard
ü A review of the site's overall environmental management
strengths/weaknesses
ü A schedule of events for the Gap Analysis.

STEP
Draft and Agree the Environmental Policy
3

Purpose The Mine corporate environmental policy is a concise public

statement of the Mining Company’s intentions with respect to the
environment. A Mining Company’s environmental policy tells the
community, and its own employees, the environmental goals and
level of performance the Mining Company intends to maintain.
The Mining Company should ensure that all proposed actions are
consistent with the intent of the environmental policy. The policy
should also provide a framework whereby a company can set
objectives and future actions, which allow compliance with the
environmental policy objectives.

Recommended Draft the Policy, include positive statements regarding the

Steps management and control of significant impacts.

v An example of Environmental Policy for mining sector is presented

in FORM 2, Manual Part 1

Convene an EMS Team meeting with Top management

and/or Board of Directors
- Discuss, amend and agree the Policy
- Discuss how the identified significant impacts may be
improved or controlled
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Recommended - Agree how to communicate the Policy externally (decide

Steps who the “interested parties” will be)
- Minute the meeting

Prepare final Environmental Policy (top management to sign

and date)

Prepare written procedure for setting and agreeing the Policy

(describe how the Policy will be set and subsequently reviewed;
describe how the Policy will be communicated /publicised)

Prepare written procedures for internal and external

communication. Include a description on how the views of
interested parties will be received, analysed and responded to.

v An example of such procedure is presented in FORM 11, Manual

Part 1.

Communicate the Policy internally and make the Policy

available to the public

Documents ü A schedule of events for the Gap Analysis

generated
ü EMS Procedure for setting and agreeing the Environmental
Policy
ü Environmental Policy
ü EMS Procedure for internal and external communication.

STEP
Identify Environmental Aspects
4

Purpose Aspects identification is an important step, since it is from this

identification of the potential to impact the environment that the
rest of the system is built. This stage in EMS implementation
should reveal the potential impacts which Mining Company will
make on the environment and the community during its lifetime. It
is the vital element in working up strategies to control these
effects.
Identification of aspects is a continual process under any EMS
system. The aspects identification process includes all past,
present and future impacts that the mining activities have had,
are having, and will have on the environment. Impacts may occur
from mining itself or from ancillary operations such as transport,
laboratories, etc. Some of these impacts may occur far from the
mine itself.
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Purpose mine itself.

The main relevant environmental aspects associated with mining
operations in Romania are summarised in the Table 1 below.
Without adequate preventive measures mining can greatly alter
the environment around the site. There may be changes in
landscapes, water tables, and animal habitats, as well as air and
water pollution, and permanent degradation of land. Toxic
chemicals, dusts, heat and noise can also seriously affect the
health of workers, and sometimes their families.

Table 1: Environmental aspects by mining sector in Romania (SEA, 2001)

Non-
Base Precious Ferrous
Issue Coal Sulphur metal U Salt
metals metals metals
s
Tailings disposal facilities ñ éé éé ñ ñ éé ñ
Spoil tip construction éé éé éé ñ é é ñ é

Backfilling and restoration of pits éé éé éé éé éé éé éé

Water management éé éé éé é é éé éé éé
Hazardous materials é éé é

Mine closure & reclamation éé éé éé éé éé éé é éé

Emissions, dust & noise é éé éé é é é ñ é

Housekeeping é é é é é é é é
Emergency response éé éé éé éé éé éé éé éé
Key: éé very high priority; é high priority; ñ moderate priority.

While the major issues above are well known by most miners, a
number of more recent environmental issues have also arisen in
recent years. Because their impacts are often less immediate or
less visible they are frequently overlooked. These newer issues
include:
- transport and recovery of hazardous mine waste
- hazardous chemical residues, and their disposal
- chemical safety
- use of ozone depleting substances at a mine site
- emissions of greenhouse gases, (including carbon dioxide
from energy use)
- protection of natural habitats (biodiversity)
Recommended Prepare process flow diagrams for the main activities of your
Steps Mining Company. Quantify the major inputs and outputs at each
process stage. Don’t forget support activities such as site
services and waste storage
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services and waste storage

Consider the “indirect” aspects of company activities such as

transport, purchasing, contractors etc.

Record the aspects identified (preferably as a Spreadsheet) in

the Aspects Register

Prepare the written procedure describing the methodology

used to identify environmental aspects.

v An example of Procedure for identifying Environmental Aspects and

Impacts is presented in FORM 3, Manual Part 1

Documents ü EMS Procedure to identify Environmental Aspects

generated
ü Aspects Register

STEP
Determine Significant Impacts
5

Purpose Once environmental Aspects have been determined, the aspects

are judged for their significance. A measurement system is
developed to separate those aspects which are Significant (and
thus will require “Targets and Objectives” and “Operational
Control” and those that are not. Since a Registrar auditor must
review the procedures for this step, it is suggested that it be
written down and quantified.
The determination of Aspects, and the declaration of those that
are Significant, is the basis on which the rest of EMS
development rests.

Recommended Using the long list of aspects generated in the Aspects

Steps Register, apply the screening criteria to determine which will be
subjected to significance evaluation

Agree what criteria will be used to determine significance for

your Mining Company and describe how each criteria will be
scored i.e. the basis of the evaluation.

Describe each aspect passing the screening and the

circumstances under which the impact might arise (i.e. normal,
abnormal, emergency) and allocate scores

Complete the Aspects Register by filling in the scores for each

Aspect
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Recommended Rank the Register by significance score

Steps
Decide what level of score will determine significance and
therefore identify your significant impacts

Prepare the written procedure for the methodology used to

evaluate and determine your significant impacts.
v As an example, in FORM 4 – Manual Part 1 is presented a
Procedure for ranking all identified environmental aspects and
impacts, based on the Environmental Risk Assessment
methodology

Documents ü EMS Procedure for the evaluation of Significant Impact

generated
ü Completed Aspects register

STEP
Setting the Legal framework for the Mining EMS
6

Purpose Similarly to other countries, Romania imposes environment

protection requirements through comprehensive and specific
environment protection legislation. This are applicable also to the
mining sector, comprising:
- Environmental impact assessment or other environmental
planning provisions
- Nature conservation, national park protection, flora and
fauna protection, cultural and natural heritage
- Water quality protection laws
- Air emissions regulated under “clean air” laws
- Control of soil contamination by wastes and hazardous
chemicals
- Other environmental issues, such as noise, vibration,
subsidence emergency response procedures; hazardous
chemicals and wastes control
After the Mining Company has defined where it can control the
environmental results of its operations, products and services, a
procedure to identify legal requirements that apply to the mining
activities should be established and maintained. This includes all
laws and self-imposed requirements. The requirements can be
partially established by reviewing the competed aspects and
impacts.
The purpose of identifying these items is to ensure that all
operations take into account not only the law, but also the self
imposed and non-legal practices. Many legal and contractual
violations are a direct result of the lack of awareness generated
by the lack of knowledge.
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Purpose operations take into account not only the law, but also the self
imposed and non-legal practices. Many legal and contractual
violations are a direct result of the lack of awareness generated
by the lack of knowledge.
The process of identifying, registering, and evaluating legislative,
regulatory, and policy requirements pertinent to the environmental
aspects of operations begins with the initial review. In the review,
all legislative requirements should be identified. Staying current
with any legislative and regulatory changes achieves
maintenance of these requirements.

Recommended Prepare a table showing the key items of environmental

Steps legislation and other requirements (e.g. corporate policy, codes
of practices) affection your Mining Company and explaining
briefly how you manage compliance with these (Summary of key
legislation).
v An example of Register of Regulations detailing the legal and other
requirements that a Mining Company must comply with, is
presented in Annex 1, Manual Part 1.

Write a procedure for how you identified legal and other

requirements and how the summary of key legislation will be
updated.
v An example of procedure for legal and other requirements is
presented in FORM 5, Manual Part 1.

Documents ü Summary of key legislation

generated
ü EMS Procedure to identify legal and other requirements

STEP
Set Objectives and Targets
7

Purpose The significant environmental aspects identifications,

environmental audit recommendations and regulatory
requirements will result in a series of actions which the Mining
Company will need to carry out.
The Mining Company should develop a series of targets and long
term objectives to achieve these requirements.
Aiming for Best Practice will mean progressively establishing
more stringent targets in order to improve environmental
performance, or anticipate potential changes to regulatory
requirements.
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Purpose requirements.
When the objectives and targets are set, the Mining Company
should consider establishing measurable environmental Key
Performance Indicators (KPIs). In Table 2 below, is presented an
example the KPI for mining sector.

Table 2 – Key Environmental Performance Indicators for Mining Sector

Responsible
No Objective Targets KPI’s
Person(s)
1. More effective water · Ensure any direct · Water sampling & flow Environmental
management and discharge water is of monitoring results Responsible, Mine
disposal (i.e silt pond required quality · 20m buffer maintained in pit Director,
and collection pond · 2.2m minimum freeboard at Embankment
water). · Maximise direct dam Construction
discharge from silt ponds · Data management Supervisor
· Compliance with all water
rights discharge consents

2. Seek continuous · Implement noise · Noise monitoring results Environmental

improvement in further reduction measures · Complete 3 night- time Officers,
reducing operational across the site noise reading per month. Environmental
noise. · Downward trend in noise Technician.
flux at control locations.
·
3. Rehabilitate disturbed · Rehabilitate an additional · 4ha of rehab by end Q4 Environmental
areas as soon as 4ha of disturbed areas 2006 Responsible
practicably possible. during 2001
· Complete 20% of pit rim · Pit rim walkway 20%
walkway construction complete by Q4 2006

4. Ensure closure planning · Prepare plans for site · Produce annual General Manager,
is progressed. closure. rehabilitation and closure Environmental
plan Responsible
5. Minimise energy · Track trends and improve · Energy consumed Environmental
consumption and the records on energy Officers
associated greenhouse consumption history by
gas emissions Q4 2006
· Investigate possibility of
entering into voluntary
agreement for reduction
of CO2 emissions

6. Improve environmental · Improve Environmental All staff

performance. performance from 79% to
at least 82% by Q4 2006

…. ……………………..

Recommended EMS Coordinator to draft the EMS Objectives in line with the
Steps general commitments made with the Policy

Convene a meeting of the full top management team to:

- Explain the relationship between the Policy commitments
and the suggested Objectives
- Obtain agreement on the Objectives, their “owner” and
their suggested completion date
- Brief the top management team on the purpose of the
EMS Management Programmes and describe their roles
in setting targets and allocating responsibilities
Manual for Environmental Procedures
and Implementation of EMS in the Mining Sector
- 20 -

Recommended Minute the top management team meeting

Steps
Write a procedure to ensure that documented environmental
objectives and targets are established and maintained.
v A sample of fully-documented procedure to explain how objectives
and targets are set, is presented in FORM 6, Manual Part 1.

Documents ü Minutes from the top management team meeting which list
generated the agreed Objectives
ü A separate list of Objectives may be produced for
communication purposes
ü EMS Procedure to set Objectives and Targets

STEP
Set and Commence the Management Programmes
8

Purpose The Environment Management Programme (EMP) is to ensure

that within the Mining Company the policy goals, objectives and
targets are supported by a realistic programme for
implementation. This Program should be integrated into the
existing environmental management practices at the Mining
Company wherever possible, and should be tied into the strategic
plan of the Mining Company as well.
While an EMS defines how issues are managed, an
environmental management programme sets out what will be
done, i.e. the operational programme.
The purpose of an EMP is to ensure that environmental impacts
are well managed, i.e. to ensure that adverse impacts are
avoided or minimised and positive impacts maximised. It is
comprehensive, though not exhaustive, in its coverage of the
activities of the mine, and sets out in a structured manner how the
mining operations will be managed with respect to the
environment, from the project development stage through to
closure and post-closure.
By assessing and monitoring the company’s environmental
management programme, regulators are able to ensure that
proper environmental management practices and standards are
observed, and thus the public are better informed as well.
Increasingly, regulators will monitor and inspect the EMS and
environmental management programmes, rather than the mine
itself.
Manual for Environmental Procedures
and Implementation of EMS in the Mining Sector
- 21 -

Purpose To achieve the purpose mentioned above, it is clear that an EMP

must take into account the best practices in the field. To support
the users of this Manual, in Manual Part 2 are presented
examples of the best practices selected for the environmental
aspects identified as a priority issue for the Romanian mining
sector, namely :

ü Water Management ü Air / Dust Management

ü Acid Mine Drainage ü Subsidence
ü Waste rocks Management ü Community Management
ü Tailings management ü Closure
ü Hazardous substances ü Rehabilitation

For each above issue, the Manual Part 2 provides:

- a description of the best practices, including the scope in
terms of mining sectors and mine project life cycle (from
exploration to closure and rehabilitation phase)
- a development of checklists which summarize what
should be done for a mine-site to be managed in
accordance with best environmental practice principles
- a description of a number of illustrated worldwide mining
case studies which demonstrate the application of best
practice techniques to address different environmental
issues across the different mine sectors, geographic and
environmental settings
These examples could be used during the development of the
EMP and tailored in relation with the specific aspects of each
Mining Company, the local possibilities and the associated
implementation costs.

Recommended The designated “owner” of each Objective should prepare a

Steps formal Management Programme to complete each Objective.
Each Programme must describe the Objective and subsequent
Targets, responsibility, completion date, performance
measurement and records. Performance indicators should be
used where possible.

Convene a first Management Review meeting to agree the

Management Programmes. This will include acceptance of
suggested Targets as well as the management allocation of
resources (staff and financial). Minute the meeting.
Manual for Environmental Procedures
and Implementation of EMS in the Mining Sector
- 22 -

resources (staff and financial). Minute the meeting.

Communicate the agreed Objectives and targets internally

(using Procedure Internal Communication)

Prepare the written procedure for setting and reviewing

Objectives and Targets. Include a description of how Objectives
and Targets are to be achieved via the Management
Programmes, how they will be reviewed and how new Objectives
and Targets are set (cross reference the Management Review).
v In FORM 7, Manual Part 1 is presented a procedure describing how
an organization will establish and review its environmental
management programs and the associated action plans.

Environmental responsible to monitor progress of the

Management programme for each agreed Objective. Progress of
each management Programme to be reported to the EMS Team
and top management.

Documents ü EMS Procedure for agreeing and reviewing the Management

generated Programmes
ü Minutes from the first management Review meeting
Management Programmes

STEP
Documentation, EMS Procedures Manual and Document Control
9

Purpose All environmental strategies, policies, responsibilities and

procedures should be clearly documented. A Mining Company
should also document and retain details of the various programs
and initiatives carried out as art of the EMS programme. EMS
documents are often compiled and stored in an Environmental
Manual, which is a convenient form to collate and record the
various components making up the EMS.
Documentation is a useful reference for both management and
staff and is preferable in a form which may be provided to
external parties, such as regulators, concerned citizen, or even
company shareholders, as proof of the company’s commitment to
environmental management.

Recommended With regard to the scope of your EMS and your significant
Steps environmental impacts, ensure that relevant procedures are
communicated to your suppliers and contractors
Manual for Environmental Procedures
and Implementation of EMS in the Mining Sector
- 23 -

communicated to your suppliers and contractors

Draft the Table of Contents for the Environmental Procedures

Manual (see an example in FORM 12, Manual Part 1) and begin to
collate EMS Procedures to create the Manual.

Determine the links with any existing Quality Assurance and

Health&Safety Management Systems. Describe these links within
the Manual. If there is no QA Management System, write the
procedure for EMS Document Control including:
- Identification and layout
- Review, authorisation and distribution
- Document availability at relevant locations
- Responsibility for removal of obsolete documents and
archiving
v In FORM 13, Manual Part 1, is presented an example of procedure
to establish and maintain document control of the EMS
documentation.

Prepare a Communication Log. This will include a record of

any external communication regarding environmental issues (e.g.
request for information, letters from local residents, visits from
regulators, suppliers and customers)

Decide what records need to kept, who will be keep them (and
for how long) and their format.

Documents ü EMS Manual

generated
ü Communication Log
ü EMS Procedure for Control of EMS Documents

STEP
Operational and Emergency Procedures
10

Purpose As part of the Mine EMS, appropriate control and verification

procedures are required to cover all functions, activities and
processes which may have a significant impact on the
environment.
On the other side, all mines should make provision for dealing
with unexpected incidents, whether natural phenomena or due to
equipment failures. Collapse of mines or tailings structures is an
everpresent risk, and worst-event scenarios can help the
management plan for such eventualities. The possibility of
chemical accidents during transport or storage (or indeed use)
also needs to be given some attention. The same is of course
Manual for Environmental Procedures
and Implementation of EMS in the Mining Sector
- 24 -

everpresent risk, and worst-event scenarios can help the

management plan for such eventualities. The possibility of
chemical accidents during transport or storage (or indeed use)
also needs to be given some attention. The same is of course
true of hazards from fuels or explosives. Where a neighbouring
community is close by, liaison with community leaders and civil
defence authorities is essential.
Operational Control is required to ensure that activities
associated with potential significant environmental impacts are
conducted under controlled conditions. An effective Operational
Control program includes the development of operational and
emergency procedures for controlling key activities and
operations that are associated with significant aspects.
In this line for this Manual we have chosen as relevant for the
Romanian mining sector the following Operational Procedures
(see Section 2.2, Manual Part 1):
ü Procedure for Acid Rock Drainage
ü Procedure for Baseline Surveys
ü Procedure for Dust Management
ü Procedure for Hydrocarbon Management
ü Procedure for Stormwater Management
ü Procedure for Tailings Storage Facility Management
ü Procedure for Waste Management
ü Procedure for Water Quality Monitoring & Sampling

Recommended Ensure that there are effective physical and/or management

Steps controls to demonstrate compliance with legal and other
requirements (see the Summary of key legislation) and to cover
each significant impact. In particular, ensure that the physical
and/or management controls:
- Address abnormal conditions (e.g. planned maintenance
and mine activities shut-down or start-up) and reasonably
foreseeable incidents
- Incorporate methods and/or criteria for monitoring and
measuring performance (specify quantifiable
environmental key performances indicators – KPI, where
possible) and therefore identify when a non-conformance
arises and a corrective action is required
v In FORM 14, Manual Part 1 is shown an example of procedure for
environmental operational procedures control.
Manual for Environmental Procedures
and Implementation of EMS in the Mining Sector
- 25 -

Make reference to existing procedure as appropriate (e.g.

quality control procedures for calibration of key instrumentation,
data control and storage etc.) and develop additional Operational
Control Procedures

Draft the procedure for identifying who is responsible for

investigating non-conformance. The procedure should ensure
that action is taken to mitigate any environmental impacts and
correct the physical and/or management controls to prevent the
non-conformance in future.
v See FORM 17, Manual Part 1 - where is presented an example of
procedure(s) to address and to correct non-conformances and to
prevent future recurrences.

Using the Initial Review and Aspects Register, ensure that site
Emergency plan addresses environmental issues.

Write the procedure for the preparation and maintenance of

the Emergency Plan.
v An example Procedure for Emergency Preparedness and
Response is presented in FORM 15, Manual Part 1.

Documents ü Operational Control Procedures

generated ü List of Operational Control Procedures
ü EMS Procedure for Operational Control
ü Draft EMS Procedure for Preparation and Maintenance of the
Emergency plan
ü EMS Procedure for Non-conformance, Corrective and
Prevention Action
ü Emergency Plan
ü Corrective Action Pro-forma

STEP
Training
11

Purpose Staff and operational personnel from the Mining Company should
be trained in their specific environmental responsibilities that are
directly related to Significant Aspects, Targets and Objectives in
the EMS. If they do not have significant roles, then they should
receive awareness training on EMS content and purpose.
Manual for Environmental Procedures
and Implementation of EMS in the Mining Sector
- 26 -

Recommended Provide environmental awareness training and description of

Steps the EMS for all staff. Describe the Objectives of the EMS and
generally how they will be met. Set out the possible
consequences of failing to comply with EMS requirements.
Describes roles and responsibilities

Undertake Training Needs Analysis to establish job specific

training requirements (for those whose job relates t the significant
impacts and EMS auditing). This should include contractors.

Prepare the written procedure for Training Needs Analysis.

Describe how general training requirements will be identified and
reviewed (who is responsible ?); how will the training “packs” be
reviewed and updated; who is responsible or maintaining the
training records; where are the training records held.
v An example of environmental training and awareness procedure is
presented in FORM 10, Manual Part 1.

Provide job specific training to staff whose jobs are involved

with significant environmental impacts / EMS audits. Describe the
Operational Control Procedure to control the significant impacts,
their role and responsibility, what records should be kept and the
possible consequences of deviation from the procedure.

Maintain personnel records of training given.

Provide training to contractors.

Documents ü EMS Procedure for training Needs Analysis

generated
ü Environmental Awareness Training “pack”
ü Job specific training “pack
ü Contractors training “pack”

STEP
Audit the EMS
12

Purpose Environmental audits identify existing and potential problems,

assess the impacts of waste discharges on the environment and
the community to measure the level of environmental
management on the site, and determine what action is needed to
comply with regulatory requirements and Mining Company
targets. Areas of concern are then prioritised and solutions
formulated.
Manual for Environmental Procedures
and Implementation of EMS in the Mining Sector
- 27 -

These audits are a crucial element in the development of a

competent and effective EMS. The quality of such an audit
determines the quality of the environmental objectives and hence
the desired environmental outcomes of an EMS.

Recommended Prepare an overall audit schedule based on the environmental

Steps importance of activities (e.g. EMS Procedures, Significant
Impacts and Operational Control Procedures).
Prepare separate audit plans based, as required, on pro-
formas, checklists, aide memoirs etc. for each area to be audited
Draft and agree a format for reporting the EMS audits.
v An example of procedure to conduct periodic EMS audits and to
document the results of the EMS audits is presented in FORM 19,
Manual Part 1

Draft and agree a format for rectifying non-conformance

identified by the EMS audits
Record corrective and preventive actions and modify
procedures as necessary
Invite Certification body to undertake the Phase One
assessment (documentation review and agree scope)

Documents ü EMS Procedure for EMS Audits

generated ü Audit Report Pro-Forma
ü EMS Procedure for Non conformance and Corrective Action
ü Corrective Action Pro Forma
ü Record of Non Conformances and associated Corrective
Actions
ü Audit Reports
ü Corrective Action Records

STEP
Undertake the Management Review
13

Purpose The Mining Company top management has to review the EMS at
planned intervals to ensure its continuing suitability, adequacy
and effectiveness. This review shall include the assessment of
opportunities for the improvement and the possible need for
changes to the environmental policy, objective and targets and
other elements of the environmental management system.
Manual for Environmental Procedures
and Implementation of EMS in the Mining Sector
- 28 -

Recommended Agree date and agenda of the Management Review meeting.

Steps Key staff must attend, individuals with either executive
responsibility or specialized responsibility.

Prepare reports on progress in developing EMS and

completion of Management programs. Review the aspects
register (update if necessary), draft new objective and/or a revise
Policy if necessary.

Convene the Management Review meeting. Write minute of

the discussions held and keep them as records. Agree the
objectives for the next year and allocate responsibility for their
completion.

Prepare the written procedure for undertaking and reporting

the Management Review (cross reference to the EMS procedure
for preparing and reviewing Aspects, Objectives and the Policy).
v An example of Procedure for Management Review is presented in
FORM 20, Manual Part 1.

Communicate progress to staff. Publicise new Environmental

Policy and the related new objectives.

In case that the final goal is to obtain an EMS certification then

this is the stage to invite a certification Body to undertake final
EMS Audit.

Obtain certification.

Documents ü EMS procedure for undertaking Management Review.

generated
ü Summary report on Audits and EMS status.
ü Report on progress of Management Programs
ü Report on Internal and External Communication.
ü Report on training needs assessment and provision.
ü Report on Environmental Performance Improvements and
Financial savings.
ü Minute of the Management Review meetings.
ü Summary of EMS success story for internal and/or external
communication.
ü Revised Policy, if the case
ü New Objectives.
Manual for Environmental Procedures
and Implementation of EMS in the Mining Sector
- 29 -

BEST PRACTICE IMPLEMENTATION IN THE MINING

SECTOR

The concept of Best Practice aims at improving environmental performance in the mining
industry. Best Practice may be defined as the methods and techniques that have proved
to lead to successful outcomes through their application.

Best Practice should be described as a process rather than specific design elements. This is
because the optimal decisions will be established on a site specific basis, using a consistent
process, and will result in design elements that differ from site to site but it is most important
that the same process has been followed in each case.

To achieve best practice, a Mine operator would be expected to have developed

management systems that ensure the identification of opportunities for improvement and to
see that change is implemented, monitored and evaluated. Best practice environmental
management in mining thus demands a continuing, integrated process through all phases of
a resource project from the initial exploration to construction, operation and closure.

The following issues are considered as the best practices priorities and for each issue the
necessary actions to be taken are briefly described:

Tailings management

This theme will address tailings management through the life of the project (including
planning, design, operation and closure of tailings storage facilities). The physical and
chemical composition varies with the nature of the material being processed, and the
process itself along with the location of the operation, will dictate the level of management
required for the tailings and for the tailings storage facility.

To develop a Tailings management plan is an essential prerequisite for sound storage

practice as most failures of tailings storages around the world result from inadequate
management of the storages.

To develop a risk assessment of tailings facility which involves an examination of the

individual risks of operations linked closely to the tailings characteristics, the physical and
chemical features, as well as other key features such as the nature of the ore and the site
characteristics.

To develop an Emergency planning for tailings facilities Emergency preparedness

includes preparation both for on-site incidents and for incidents having off-site implications,
including dam breaches.
Manual for Environmental Procedures
and Implementation of EMS in the Mining Sector
- 30 -

Closure and rehabilitation

Mine closure ultimately determines what is left behind as a benefit or legacy for future
generations. It is important that mine closure is undertaken in a planned and effective
manner, to avoid hazards and pollution in the future.

The overall objective of mine closure is to prevent or minimise adverse long-term

environmental (physical, social and economic) impacts, and to create a stable landform
suitable for some agreed subsequent land use. If mining is to positively contribute to
sustainable development, it is imperative that reclamation efforts result in stable and
productive lands, expanded land use opportunities, and increased recreational and habitat
value. Public participation is a key component of a mine closure strategy.

Appropriate mine decommissioning outcomes need to be determined on a site-specific basis

taking into account the nature of the project in the context of regional factors such as climate,
land capability, landform, water resources and ongoing land uses.

Closure planning must integrate all aspects of sustainable development, i.e. environmental,
economic and social issues must be addressed in integrated closure plans. Such integrated
thinking must become standard operating procedures throughout the mine life.

To develop a mine closure plan that will outline the principles and practices of mine
rehabilitation, with emphasis on landform design and revegetation. The principles described
should apply to any land disturbed by mining. Topics covered include rehabilitation
objectives, soil handling, earthworks, revegetation, soil nutrients, fauna return, maintenance,
success criteria and monitoring:

developing designs for appropriate landforms for the minesite;

creating landforms that will behave and evolve in a predictable manner, according to
the design principles established; and

establishing appropriate sustainable ecosystems.

Acid mine drainage

This theme addresses management issues related to the environmental impacts and
remediation of acid drainage in the mining industry. The oxidation of sulphidic mine wastes
and the consequent release of acid mine drainage (AMD) and acid rock drainage is one of
the main strategic environmental issues facing the mining industry. AMD can be a major long-
term environmental problem for many mines where wastes contain pyrite or other sulphidic
minerals.

To develop a management for sulphidic mine wastes that requires a risk management
approach. While the primary focus is to prevent acid generation, there is a hierarchy of
appropriate management strategies as follows:
Manual for Environmental Procedures
and Implementation of EMS in the Mining Sector
- 31 -

minimise oxidation rate and isolate higher risk materials from exposure;

minimise potential for transport of oxidation products from source to receiving

environment; and

contain and treat acid drainage to minimise risk of significant off-site impacts.

Hazardous material

Mining activities use a variety of chemicals for the extraction, ore processing, water treatment
and many other supporting activities. Additionally, some potentially hazardous chemicals or
wastes are generated by the mining process - acid mine drainage and radioactive wastes are
examples. There is a need to develop a hazardous substances management plan.

Leading practice hazardous material management involves developing the following:

knowing which hazardous materials are on site and allocating clear responsibility for
managing hazardous materials;

understanding the actual or potential hazards and environmental impacts in

transporting, storing, using and disposing of these materials;

minimising the use and/or generation of hazardous materials and seeking alternatives
to disposal such as reducing, reusing and recycling products;

constructing storage facilities that contain the materials in all foreseen circumstances;

disposing of waste materials in a way that eliminates or minimises environmental

impacts;

having emergency response plans in place to ensure immediate action to minimise

environmental effects should accidental or unplanned releases occur;

Air/dust management

This theme addresses issues related to emissions of particulates (dust, diesel and silica),
noise and vibration control at mining operations. These issues can have a significant impact
on local communities and contribute to concerns about ongoing environment and health
risks.

To develop a Management Plan for noise, vibration and airblast emissions that
demonstrates the mining company’s commitment to achieving environmental goals. The
detailed design of noise and blast mitigation measures arises from implementing the
Management Plan.
Manual for Environmental Procedures
and Implementation of EMS in the Mining Sector
- 32 -

Water

Developing water management systems for a mine must account for site-specific physical,
chemical and climatic characteristics as well as mine process factors. Total company
commitment is fundamental to ensuring water management minimises potential
environmental impacts.

The fundamental prerequisite for best practice mine site water management is recognising
the need to develop and implement a comprehensive and coordinated mine site water
management plan:

Ensuring that abstraction of water for mineral extraction does not result in a significant
reduction of flow in rivers or decrease of groundwater levels, which might affect
downstream wetland areas or supplies of drinking water

Decreasing the physical impact of mineral extraction on the ecology of the water
environment, by ensuring that any water returned to the environment following use is free
from suspended solids.

Reducing the risk of long-term chemical contamination of groundwater and surface

water from mine drainage by careful monitoring and implementing measures to mitigate
against sudden outflow, such as the mechanical failure of dam waste water.

To develop and implement a comprehensive erosion and sediment control plan is a

fundamental best practice approach for responsible mine site water management.

The plan must define a co-ordinated approach to sediment and erosion control throughout
the life of the mine:

include standard techniques to control the risk of sediment loss from disturbed areas,
e.g. silt fencing and the construction of sediment dams.

the plan also needs to address rehabilitation and revegetation options. A properly
designed and implemented sediment and erosion control plan minimises the amount and
mass of suspended sediment washed into streams and the associated problems of
environmental degradation in the streams and downstream receiving waters.

Community

Community development should be an integral component of mining and ore processing

activity from exploration through to closure and beyond.

To develop a community development strategic plan which will provide (to be effective
and sustainable) the following information:

Capacity building to equip communities and stakeholders to effectively engage;

Manual for Environmental Procedures
and Implementation of EMS in the Mining Sector
- 33 -

Listening and responding to community and stakeholder concerns;

Including communities and stakeholders in relevant decision-making processes;

Developing goodwill and a better understanding of objectives and priorities leading to

confidence in decisions; and

Establishing a realistic understanding of potential outcomes.

Subsidence

The subsidence risks in several mining sectors will be managed through the design of a
subsidence management plan.

To develop a Subsidence Management Plan that will present the proposed management
solutions or action plans developed as a result of the subsidence impact characterisation and
risk assessment undertaken.

Waste rocks management

Waste rocks consist of a wide variety of rock and soil materials, depending on the geology
and type of mining, that are left at the surface during the extraction process. Waste dumps
are out-of-pit structures used for disposal of dry solid mine and process wastes.

The management of waste from the extractive industries should provide for measures,
procedures and guidance to prevent or reduce as far as possible any adverse effects on the
environment, and any resultant risks to human health. There is a need to design a waste
management plan to ensure that all waste is responsibly managed and environmental risks
are minimised. A waste management plan can cover waste rocks, as well as others types of
wastes.

This plan will include waste rocks characterisation and classification, waste management
strategy, recycling, protection of waters. As a consequence it is necessary to make an
assessment of the:

Physical stability – mine waste facilities should not erode or move from their intended
location under extreme events or perpetual disruptive forces and should not endanger
public health and safety

Chemical stability – the consequences of chemical instability and leaching of

chemicals into the environment should not endanger public health or safety

Land use – compatible with that of the surrounding lands, to the extent possible