3rd AMIREG International Conference (2009): Assessing the Footprint of 152

Resource Utilization and Hazardous Waste Management, Athens, Greece

New regulations for the production of silver and gold metals in Greece

A. Gryllia
Ministry for the Environment, Physical Planning and Public Words, Greece

ABSTRACT of the potential sites in Greece and the key envi-

ronmental issues. It discusses the basic obliga-
In Greece, since last decade, a lot of attempts
tions for the silver and gold metals extractive
have been made by potential operators, in order
plants in the framework of the abovementioned
to produce silver and gold metals in Thraki and
legislative provisions concerning Best Available
Halkidiki. Although strict environmental permit
Techniques as well as the Directive on the man-
conditions had been laid down, none of these
agement of waste from extractive industries in
activities have been launched so far mostly due
order to meet the essential sustainable develop-
to the opposition of local residents.
ment requirements.
Since then, new legislation has been taken in-
to force focusing on such kind of activities. Fol-
lowing the Communication from the European 1. INTRODUCTION
Commission COM(2000) on the “Safe Opera-
The mining industry faces some of the most dif-
tion of mining activities” the elaboration of Best
ficult challenges of any industrial sector and is
Available Techniques Reference Document has
currently distrusted by many of the people it
taken place concerning the management of tail-
deals with day to day. However, the best mod-
ings and waste rock in mining activities under
ern mining operations represent a great im-
the auspices of the 96/61/EU Directive about the
provement over past practice and most major
Integrated Pollution Prevention and Control
mining companies are committed to continuous
(IPPC). This document based on an exchange of
progress on environmental performance (Com-
information between Member States, the mining
mission of the European Communities, 2003).
industries and the NGOs. Furthermore, the
Significant improvement has also been achieved
2006/21/EC Directive on the management of
concerning the legislative framework, permit-
waste from extractive industries as well as the
ting requirements and control.
Directive 2000/60/EC in the field of water pol-
In northern of Greece, in the regions of Thra-
icy establish a constructive legislative frame-
ki (Perama and Sappes) and Halkidiki (Stratoni
work at a Community level in order to prevent
and Olympiada) potential operators have tried to
or reduce as far as possible any adverse effects
invest in the extraction and processing of aurif-
on the environment or on human health and to
erous ores in order to produce silver and gold
prevent or mitigate accidents in the extractive
metals. These projects mainly involved open pit
industry.
mining and/or underground mining; production
Following this legislative environmental evo-
facilities for processing of ore to produce Dore
lution, potential operators have to improve op-
gold (alloy of gold and silver); infrastructure in-
erating conditions to meet the new requirements
cluding waste rock, low-grade ore and soil
and may involve important costs and commit-
stockpiles; tailing management facilities for sto-
ments in order to adapt through costly invest-
rage of ore processing waste and construction of
ments to a higher environmental performance
dams to retain slurried tailings or supply “fresh”
level.
water to the plant. The ore processing in most of
This paper presents an overview of the nature
3rd AMIREG International Conference (2009): Assessing the Footprint of
Resource Utilization and Hazardous Waste Management, Athens, Greece
the cases included cyanide leaching and genera-
tion of tailings, which were supposed to have
been disposed of in tailings ponds after cyanide
destruction.
The permitting procedure for these activities
was based on national legislation, which was
harmonized with Council Directive 97/11/EC
amending Directive 85/337/EEC on the assess-
ment of the effects of certain public and private
projects on the environment as well as Directive
96/61/EC on Integrated pollution prevention and
control. Sectoral Directives were also used to
set environmental conditions concerning air,
waste and water. Specifically for the manage-
ment of tailings Landfill Directive 99/31/EC
was used, although it was not tailored for such
kind of activities.
Environmental conditions laid down under
the permitting procedure included measures
concerning the emissions to air, water, soil,
landscape, fauna and flora as well as archaeo-
logical sites. Also specific conditions were laid
down concerning site remediation requirements
and monitoring during the operational lifetime
of the installation as well as for the post-
operational phase. Additionally, a financial
guarantee was set ensuring that sufficient funds
will be available to leave waste sites in a satis-
factory state after closure. However, although
the environmental issues of tailings ponds were
a priority area in the permit, safety issues, such
as the stability of tailings dams or the preven-
tion of accidents, were not. This was due to the
lack of proper legislation at national or Euro-
pean Union levels.
Nevertheless, these projects have not been
implemented so far, mainly due to the resistance
of the local population. It is true that in the past
when environmental legislation and the relevant
inspections were of less importance in the coun-
try, practices of a lot of operators were often
quite bad. Hence, the abandonment, dumping or
uncontrolled depositing of extractive waste con-
tributed to significant environmental impacts.
As a result, local residents lack confidence in
these operations, although they could play a
valuable role in the development of their region.
Moreover, the burst or collapses of tailings
dams at operations in Aznalcollar (Spain, 1998)
and Baia Mare (Romania, 2000) have attracted
negative public reaction to the management of
tailings and the safety of dams. These accidents
153
prompted the development of a new legal
framework at the European level, which in-
cludes Directive 2006/21/EC on the manage-
ment of waste from extractive industries and the
determination of Best Available Techniques
(BAT) under the auspices of Directive 96/61/EC
on the Integrated Pollution Prevention and Con-
trol, although the extractive activities were not
specifically addressed by this Directive. This
framework has its origins in a Communication
issued in the year 2000 by the European Com-
mission on safe operation of mining activities.
2. ENVIRONMENTAL IMPUCTS
Waste management facilities of the extraction
and treatment of auriferous ore have significant
environmental impacts due to huge volumes of
waste, which have normally high waste-to-
product ratios. Gold ore contains only a few
grams of gold (Au) per ton of mined material.
For example a gold content of 5 g/t means that
in order to extract a ton of gold about 200,000 t
of ore have to be mined with it that will end up
as tailings in a pond (Commission of the Euro-
pean Communities, 2003).
The environmentally relevant parameters of
waste management facilities can be subdivided
into two categories: (1) operational and (2) ac-
cidental (European Commission, 2004).
2.1 Operational impacts
Environmental impacts include issues related to
land-take, surface and ground water quality,
emissions to soil and air, erosion and terrestrial
and aquatic habitat / ecosystem quality. Emis-
sions to land can occur via settled dust or via the
seepage of liquids from tailings and or waste-
rock management facilities into the ground. Ef-
fluents and dust emitted from tailings manage-
ment facilities controlled or uncontrolled may
be toxic in varying degrees to humans, animals
and plants (European Commission, 2004).
However, the major issue is emissions to wa-
ter, which can include reagents from mineral
processing such as cyanide, solid or dissolved
metals or metalliferous compounds and sus-
pended solids. Water pollution may appear at
different stages in the management of waste
from such industries. For example, rain and wa-
ter resulting from the extractive process may
create leachates when seeping through tailings.
3rd AMIREG International Conference (2009): Assessing the Footprint of
Resource Utilization and Hazardous Waste Management, Athens, Greece
These can also result from seepage through and
below impoundment walls, percolation to the
subsoil and groundwater or overflow of the dam
walls or spillways.
The most serious environmental problem re-
lated to such activities is “Acid Drainage” (AD).
Acid generation occurs when sulphide-rich ma-
terial in waste rock and tailings are exposed to
and react with oxygen and water to form sul-
phuric acids. This is a slow generating process,
which is promoted by high oxygen concentra-
tion, high temperature, low Ph and bacterial ac-
tivity. This can also be a natural process but, by
exposing these materials and breaking them up,
mining can greatly accelerate the rate at which
these reactions take place. AD is characterized
by depressed Ph values and elevated metals
such as iron, copper, aluminum and lead. One of
the most serious aspects of AD is its persistence
in the environment. An acid-generating mining
waste facility has the potential for long-term,
severe impacts on surface and ground water and
aquatic life. The combination of acidity and dis-
solved contaminations is known to kill most
forms of aquatic life, rendering streams nearly
sterile and making water unfit for human con-
sumption (Commission of the European Com-
munities, 2003).
2.2 Accidental impacts
Tailings dams are built to retain slurried tail-
ings. In some cases material extracted from the
tailings themselves is used for their construc-
tion. Actually, tailings dams, which have many
common features with water retention dams, in
many cases are built as water retaining dams,
particularly where there is a need for the storage
of water over the tailings. The collapse of any
type of tailings management facility can have
short-term and long-term effects. Typical short-
term consequences include flooding, blanketing
/ suffocating, crushing and destruction, cut-off
of infrastructure and poisoning. Potential long-
term effects include metal accumulation in
plants and animals, contamination of soil and
loss of animal life (European Commission,
2004).
154
3. LEGAL FRAMEWORK
3.1 Best Available Techniques
The Reference Document on Best Available
Techniques (BAT) for management of tailings
and waste - rock in mining activities includes
environmental and safety performance of the
sector bearing in mind the inherent balance of
costs and advantages. It must be noted that this
document does not set legally binding standards,
but simply gives information for the guidance of
industry, permit issuing authorities and the pub-
lic on achievable performances, emissions and
consumption levels when using specified tech-
niques (European Commission, 2004). BATs
are based on environmental performance, risk
and economic viability and mostly include gen-
eral principles, the overall management, emis-
sions to water, design, construction and opera-
tion of the tailings dam, the operation of the tail-
ings pond, tailings management, monitoring
stability, mitigation of accidents and the use of
cyanide, as briefly described below.
3.1.1 General principles
BAT deal with proper management of tailings
and waste-rock including evaluation of alterna-
tive options for:
- minimizing the volume of tailings and waste-
rock generated in the first place, for example
by proper selection of the mining method
- maximizing opportunities for the alternative
use of tailings and waste-rock, such as use as
aggregate, use in the restoration of other
mine sites, use in back filling or conditioning
the tailings and waste-rock within the process
to minimize any environmental or safety ha-
zards, such as addition of buffering material.
Any tailings and waste-rock that cannot be
avoided and that are not suitable for alternative
uses require a suitable management strategy,
which aims to assure the:
- safe, stable and effective management of tail-
ings and waste-rock with a minimized risk
for accidental discharges into the environ-
ment in the short, medium and long term
- minimization of quantity and toxicity of any
contaminated release/seepage from the man-
agement facility
- progressive reduction of risk over time.
3rd AMIREG International Conference (2009): Assessing the Footprint of
Resource Utilization and Hazardous Waste Management, Athens, Greece
BAT should implement life cycle manage-
ment in all phases of a site’s life, including: de-
sign, construction, operation, closure and after-
care. Furthermore, the implementation of BAT
reduces reagent consumption, prevents water
erosion and dusting, carries out a water balance
to develop a water management plan and apply
free water management and monitors groundwa-
ter around all tailings and waste-rock areas (Eu-
ropean Commission, 2004).
3.1.2 Technical issues
Regarding seepage management BAT may as-
sist in the selection of the location of a tailings
or waste-rock management facility so that no
liner is required. However if this is not possible
and the seepage quality is detrimental and or the
seepage flow rate is high, then seepage needs to
be prevented, reduced or controlled (European
Commission, 2004).
For emissions to water BAT deal with issues
such as:
- re-use process water,
- mix process water with other effluents con-
taining dissolved metals,
- install sedimentation ponds to capture eroded
fines,
- remove suspended solids and dissolved met-
als prior to discharge of the effluent to re-
ceiving watercourses,
- neutralize alkaline effluents with sulphuric
acid or carbon dioxide,
- remove arsenic from mining effluents by the
addition of ferric salts.
In the stage of a tailing dam design BAT
consider the use of the once in a 100-year flood
probability for the sizing of the emergency dis-
charge capacity of a low hazard dam or the once
in a 5000-10000 year flood probability of a high
risk dam (European Commission, 2004).
During the construction phase of a tailings
dam BAT examine stripping of the natural
ground below the retaining dam of all vegeta-
tion and huminous soils and selection of an ap-
propriate dam construction material, which will
not weaken under operational or climatic condi-
tions (European Commission, 2004).
During the constructional and operational
phases of a tailings dam BAT evaluate the risk
of an extremely high pore pressure, monitor the
pore pressure before and during each raise (the
155
evaluation should be done by an independent
expert) and use the proper type dams (conven-
tional, upstream, downstream or centerline me-
thod) under certain conditions (European Com-
mission, 2004).
During the operational phase of a tailings
pond BAT aim to:
- monitor stability,
- provide for diversion of any discharge into
the pond away from the pond in the event of
difficulties,
- provide alternative discharge facilities possi-
bly into another impoundment,
- provide second decant facilities and or stand-
by pump barges for emergencies if the level
of the free water in the pond reaches the pre-
determined minimum freeboard,
- measure ground movements with deep incli-
nometers and know the pore pressure condi-
tions,
- provide adequate drainage,
- maintain records of design and construction
and any updates/changes in the design/con-
struction,
- maintain a dam safety manual in combination
with independent audits,
- educate and provide adequate training for
staff.
For the removal of free water from the pond
BAT consider the use of a spillway in natural
ground for valley site and off valley site ponds
or a decant tower / decant well according to
climatic conditions (European Commission,
2004).
For tailings management BAT consider dry
tailings, thickened tailings or slurried tailings
management. The choice of the above options
depends mainly on an evaluation of cost, envi-
ronmental performance and risk of failure (Eu-
ropean Commission, 2004).
During the operational phase of any tailings
and waste-rock management facility BAT may
consider to divert natural external run-off, man-
age tailings or waste-rock in pits, apply a safety
factor of at least 1.3 to all heaps and dams dur-
ing operation or carry out progressive restora-
tion/revegetation (European Commission,
2004).
For mitigation of accidents BAT is to carry
out emergency planning, evaluate and follow-up
incidents and monitor the pipelines (European
3rd AMIREG International Conference (2009): Assessing the Footprint of
Resource Utilization and Hazardous Waste Management, Athens, Greece
Commission, 2004).
During the closure and after-care phase of
tailings and waste-rock management facility
BAT is to develop closure and after-care plans
during the planning phase, including cost esti-
mates, and then to update them over time and to
apply a safety factor of at least 1.3 for dams and
heaps after closure (European Commission,
2004).
For the closure and after-care phase of tail-
ings ponds BAT consider the construction of
dams so that they are stable in the long term if a
water cover scheme is chosen after closure (Eu-
ropean Commission, 2004).
For gold leaching using cyanide BAT aim to:
- reduce the use of CN by applying operational
strategies to minimize cyanide addition, au-
tomatic cyanide control and peroxide pre-
treatment (if applicable)
- destroy the remaining free CN prior to dis-
charge in the pond
- apply the safety measures, such as to size the
cyanide destruction circuit with a capacity
twice the actual requirement, to install a
backup system for lime addition and to install
backup power generators.
3.2 Directive 2006/21/EC
Directive 2006/21/EC on the management of
waste from extractive industries provides for
measures, procedures and guidance to prevent
or reduce as far as possible any adverse effects
on the environment, in particular water, air, soil,
fauna and flora and landscape and any resultant
risks to human health (European Union, 2006).
It is a sectoral Directive, which sets out operat-
ing conditions and other technical requirements
and supplements the provisions of the waste
Framework Directive (75/442/EEC) as amended
by Directive 91/156/EEC.
The Directive focuses on the aspects of op-
erational issues connected with waste manage-
ment, prevention of soil and water pollution and
ensuring stability of waste management facili-
ties in particular tailings ponds (Commission of
the European Communities, 2003).
Specifically the Directive contains:
- a range of conditions to be included for the
issuance of environmental permits, allowing
for sufficient environmental and safety
measures when authorizing waste manage-
156
ment facilities,
- a range of obligations covering waste man-
agement by drawing up a waste management
plan by the operator for the minimization,
treatment, recovery and disposal of extractive
waste,
- the obligation to characterize waste before
treating it or disposing of it,
- measures to ensure the safety of waste man-
agement facilities; these provisions are simi-
lar to the relevant measures contained in the
Seveso II Directive such as major- accident
prevention policy, compilation of safety re-
ports and providing adequate information to
the public,
- a requirement to draw up closure plans for
waste management facilities,
- measures concerning the presence of cyanide
in a pond ensuring that the concentration of
weak acid dissociable cyanide in the pond is
reduced to the lowest possible level using
BAT,
- a requirement for inspection of the waste fa-
cilities by the competent authority in order to
ensure that they comply with the relevant
conditions of the permit,
- a requirement concerning the management of
the waste facilities to be conducted by a
competent person,
- an obligation to provide for an appropriate
level of financial security aiming at reinforc-
ing the “polluter-pays” principle.
The detailed technical requirements are not
included in the Directive because it is foreseen
that it will be determined in the future by the
European Commission using the BAT.
3.3 Directive 2000/60/EC
The Water Framework Directive 2000/60/EC
establishes a general framework for the protec-
tion of all waters (rivers, lakes, coastal waters
and ground waters). It aims to prevent pollution
at source and sets out control mechanisms to sa-
feguard that all pollution sources are managed
in a sustainable way (European Union, 2000). A
key requirement of the Directive is the setting
up of river basin management plans, which spe-
cify how the objectives set for the river basin
are to be reached within the timescale set.
Moreover, the Directive requires the charac-
terization of pressures and impacts in a river ba-
3rd AMIREG International Conference (2009): Assessing the Footprint of 157
Resource Utilization and Hazardous Waste Management, Athens, Greece

sin and provides for the establishment of a mon-
itoring network. Although not explicitly men-
tioned, point sources of water pollution, such as
any acid drainage generated by tailings ponds,
will have to be included in the characterization
of pressures and impacts in a river basin (Com-
mission of the European Communities, 2003).
2000/60/EC and 2006/21/EC. Hence, the legal
framework for tailings management facilities is
becoming more and more strict, integrated and
tailored-made for them. Great concern is given
to all the life cycle design, construction, opera-
tion, monitoring, closure and after-closure phas-
es.

4. CONCLUSIONS REFERENCES
A new approach was adopted by the European Commission of the European Communities, 2003. Pro-
Commission for the particular sector of extrac- posal of the European Parliament and the Council on
the management of waste from the extractive indus-
tive industries, which is predominant source of tries.
waste generation with attendant environmental European Union, 1996. Directive 96/61. The Integrated
protection challenges. By the new legislative pollution prevention and control.
framework covering the management of waste European Commission, 2000. Communication on safe op-
of installations, such as in the production of eration of mining activities: a follow-up to recent min-
gold and silver metals, environmental issues are ing accidents
European Union, 2000. Directive 2000/60 establishing a
addressed together with safety issue relating to framework for Community action in the field of water
adverse environmental effects. Hence, this policy.
framework is the appropriate tool, setting mini- European Commission, 2004. Joint Research Center, In-
mum requirements to secure much needed im- stitute for Prospective Technological Studies, Euro-
provements in terms of its environmental and pean IPPC Bureau, (July 2004). Reference Document
on best Available Techniques for Management of tail-
safety performance. ings and waste-Rock in Mining Activities.
Directive 2006/21/EC in combination with European Union, 2006. Directive 2006/21. The Manage-
BAT ensure the minimizing of the adverse ef- ment of waste from extractive industries and amend-
fects of acid and alkaline drainage from waste ing Directive 2004/35/EC.
management facilities during the production of
silver and gold metals, which have the potential
to create long-term environmental impacts per-
sisting well after both the facility and the asso-
ciated mine have been closed (Commission of
the European Communities, 2003).
Furthermore, this legal framework aims at
preventing or minimizing the impacts of acci-
dents and in particular ensuring the long-term
stability of tailings dams and ponds, given that
dam bursts have the potential to create wide-
spread environmental damage, including threats
to human life (Commission of the European
Communities, 2003).
The new obligations create additional costs
to potential investors, since they need one-off
costs arising directly from the need to adapt the
proposed facility to the new regulatory and op-
erating regime, as well as additional annual
costs applicable during the operational and af-
ter-care phase of the facility.
The legal framework for permitting such ac-
tivities hasn’t changed but the conditions under
which the permit is granted have been modified,
as they must to be based on BAT and Directives