Grade .

95/1 Excellent-minor errors

What Does “Perpetual” Management and Treatment Mean? Toward a Framework for Determining an
Appropriate Period-of-Performance for Management of Reactive, Sulfide-Bearing Mine Wastes.

As high-grade mineral deposits become more depleted, the shift towards the mining of low grade
minerals at a high volume changes the scale at which we must deal with mine waste, which in the latter
case is on the order of millions to billions of metric tonnes, covering hundreds of square kilometers of
geographical area. This necessitates a more critical look into current practices of initiating the
excavation, and mine closure at the end of excavation. Typically a mining license is issued with a start
plan and a design basis analysis. Remarkably, no plan for closure is required. The design basis takes into
account the likelihood of an occurrence operation? over a period of time (20-50 years) of postulated
extreme events that the industry must be able to withstand. The temporal element of the design basis is
crucial, since extreme events become more likely, given a longer timeframe, and the mine wastes in
question are reactive sulfides, which remain reactive for a very long time. I propose that, given the
longevity of the reactive wastes, the design basis should consider a timeframe of ideally 1000 years, but
certainly no shorter than 200 years. Also, a closure execution strategy should be required, in which it is
spelled out how, and by whom the mine closure obligations will be carried out, rather than the current
practice of returning the land back to the owners, who usually do not understand the burdens of closure
of the mine.