CHAPTER 3 MANAGEMENT STRATEGIES: SCIENTIFIC AND ENGINEERING CONSIDERATIONS

• Jurisdiction: United States

Idle Mining Properties
(Sep 1998)
CHAPTER 3
MANAGEMENT STRATEGIES: SCIENTIFIC AND ENGINEERING CONSIDERATIONS
Charles G. Taylor
BHP Copper Company
Tucson, Arizona

IDLE MINING PROPERTIES

MANAGEMENT STRATEGIES: SCIENTIFIC AND ENGINEERING CONSIDERATIONS

Charles G. Taylor

Group Safety, Health and Environment

BHP Copper

[Page 2]

TYPES OF IDLE MINING PROPERTIES

• Abandoned

• Undergoing Closure or Closed

• Temporary Cessation

[Page 3]

ARIZONA AQUIFER PROTECTION PERMIT

• Closure is defined as intent to cease, without intent to resume, an activity for which the facility was designed or operated prior to ceasing.

• Temporary Cessation means any cessation of operation of a facility for a period of greater than 60 days but which is not intended to be permanent.

[Page 4]

MANAGEMENT STRATEGY

• Planning

— Risk Review

— Establish Goals

— Review Regulatory Commitments

• Public Notification

— Methods of Notification

• Facilities

• Pathways

• Temporary Controls

• Costs

• Other Considerations

[Page 5]

PLANNING

• Environmental Management Must Be Considered Into the Decision to Idle a Property, Not After

• Time Is Critical

— Develop a Critical Path Schedule

— Idle for 1 Year Versus 5 Years

• Perform Risk Review Prior to Idling a Property

Photograph

Omitted From Electronic Version

[Page 6]

RISK REVIEW

• Risk Assessment

— Identify

— Characterize

— Evaluate

• Risk Management

— Accept

— Eliminate

— Reduce

— Transfer

[Page 7]

RISK COMPONENTS

• Source Identification

— Site Review

— Process Review

• Target Identification

— Surrounding Area

• Pathway Identification

— Groundwater Discharges

— Surface Water Discharges

— Air Emissions

— Spills

[Page 8]

GOALS

• Maintain "Start-Up" Capability

• Develop and Implement on a Prioritized Basis Temporary Controls

— Risk Management Plans

• Maintain Permits

• Maintain Compliance

[Page 9]

REVIEW REGULATORY COMMITMENTS

• Distinction Between "Temporary Cessation of Operations" Versus "Final Closure"

• Permit Requirements

• Statutory Requirements

— Federal

— State

— Local Ordinances

[Page 10]

FEDERAL REGULATORY CONSIDERATIONS

• NEPA — EIS

• Plan of Operations

• Special Use Permits

• CWA

— NPDES Point Source/Stormwater

— Section 404 Dredge and Fill

• CAA

• CERCLA

• RCRA

[Page 11]

STATE (ARIZONA) REGULATORY CONSIDERATIONS

• Aquifer Protection Permit

• Dam Safety Permits

• Plan of Operations on State Lands

• Mined Land Reclamation Plan

[Page 12]

AQUIFER PROTECTION PERMIT REQUIRES

"The permittee shall notify the ADEQ Aquifer Protection Permit Program in writing prior to temporary cessation...