A Procedure To Evaluate Environmental Rehabilitation In Limestone Quarries

A Procedure to Evaluate Environmental Rehabilitation in Limestone Quarries
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Journal of Environmental Management 91 (2010) 2225e2237 Contents lists available at ScienceDirect Journal of Environmental Management journal homepage: www.elsevier.com/locate/jenvman A procedure to evaluate environmental rehabilitation in limestone quarries Ana Claudia Neri, Luis Enrique Sánchez* Escola Politécnica, University of São Paulo, Av. Prof. Mello Moraes, 2373 São Paulo, SP 05508-900, Brazil a r t i c l e i n f o a b s t r a c t Article history: Received 29 October 2009 Received in revised form 10 May 2010 Accepted 2 June 2010 Available online 13 July 2010 A procedure to evaluate mine rehabilitation practices during the operational phase was developed and validated. It is based on a comparison of actually observed or documented practices with internationally recommended best practices (BP). A set of 150 BP statements was derived from international guides in order to establish the benchmark. The statements are arranged in six rehabilitation programs under three categories: (1) planning (2) operational and (3) management, corresponding to the adoption of the plan-do-check-act management systems model to mine rehabilitation. The procedure consists of (i) performing technical inspections guided by a series of field forms containing BP statements; (ii) classifying evidences in five categories; and (iii) calculating conformity indexes and levels. For testing and calibration purposes, the procedure was applied to nine limestone quarries and conformity indexes were calculated for the rehabilitation programs in each quarry. Most quarries featured poor planning practices, operational practices reached high conformity levels in 50% of the cases and management practices scored moderate conformity. Despite all quarries being ISO 14001 certified, their management systems pay low attention to issues pertaining to land rehabilitation and biodiversity. The best results were achieved by a quarry whose expansion was recently submitted to the environmental impact assessment process, suggesting that public scrutiny may play a positive role in enhancing rehabilitation practices. Conformity indexes and levels can be used to chart the evolution of rehabilitation practices at regular intervals, to establish corporate goals and for communication with stakeholders. Ó 2010 Elsevier Ltd. All rights reserved. Keywords: Mine rehabilitation Best practice Assessment Limestone Cement Mining Quarrying Karst ISO 14001 1. Introduction Land rehabilitation is an essential part of mining and quarrying, aiming at making disturbed areas suitable for new sustainable land uses. Mining is increasingly viewed as a temporary form of land use whose end of life is subject to careful planning. Hence, mine planning should fully consider future land use options, allowing for extractive activities to be carried on balancing the optimal rate and the maximum environmentally and socially feasible ore or rock extraction with the intended post-mining land use. Extensive research has been conducted worldwide on several aspects of mined land rehabilitation. There are recommended practices for soil management, erosion control, slope stabilization, species selection, seed collection, nursery establishment and maintenance, seeding and planting strategies and techniques, weed control, fauna attraction and other aspects of rehabilitation Abbreviations: CSI, Cement sustainability initiative; EIA, Environmental impact assessment; EMS, Environmental management system; WBCSD, World business council for sustainable development. * Corresponding author. Tel.: þ55 11 3091 5186; fax: þ55 11 3091 5721. E-mail addresses: [email protected] (A.C. Neri), [email protected] (L.E. Sánchez). 0301-4797/$ e see front matter Ó 2010 Elsevier Ltd. All rights reserved. doi:10.1016/j.jenvman.2010.06.005 techniques. Furthermore, policy tools to encourage companies to effectively implement suitable technical solutions (such as performance bonds) and to engage with communities in addressing future land use (such as mandatory consultation) have been developed and disseminated. However, comparatively less research effort has been directed to understand the companies’ internal management of the environmental rehabilitation process and the design of effective management programs. Land rehabilitation in mining is not an activity to be carried out at the end of the mine life cycle, nor a service that can successfully be entirely outsourced. On the contrary, mined land rehabilitation is a process that requires time and involves learning. Notwithstanding, in many mining companies efforts towards rehabilitation vary over time due to several reasons, such as changing managers e some being more enthusiastic than others in terms of achieving rehabilitation goals and perhaps exceeding minimum performance standards. It is also known from anecdotal evidence that large companies may show different levels of commitment towards environmental management in different sites not only in different countries but also inside the same jurisdiction. Moreover, staff turnover can jeopardize a company’s organizational memory and undermine its capacity to learn from experience (Argyris and Schön, 1996, among others), arguably essential when 2226 A.C. Neri, L.E. Sánchez / Journal of Environmental Management 91 (2010) 2225e2237 rehabilitation measures are implemented along an extended time span and can take years to show meaningful results. This is particularly important when land rehabilitation is not well integrated into mine core activities or when much of the actual rehabilitation work is carried out by external contractors. This paper focuses on the managerial aspect of land rehabilitation in mining. An evaluation protocol to assess ongoing practices and procedures towards rehabilitation during the operational phase of a mine life-cycle has been developed and validated. The goal is not to assess the results of rehabilitation measures or the achievement of completion criteria, but to evaluate to what extent the practices, procedures and controls adopted by a mining company during a mine’s operational phase are likely to achieve satisfactory results in the future, thus assessing progress towards successful rehabilitation. 2. Limestone quarrying and rehabilitation Cement manufacturing is an industry established in almost all countries. The world cement production reached 2.9 billion tonnes in 2008 (USGS, 2009), placing limestone among the top minerals extracted from the Earth’s crust (Fig. 1). The ratio raw limestone/ cement is variable, depending on the chemical composition of limestone itself and other raw materials used in processing (clay, sand, iron ore), but can be assumed to be around 1.1 as an average, providing an estimate of around 3.2 billion tonnes for total limestone output to support current cement production. Actually, world limestone output is even bigger, as the rock is also used as a source of aggregates and in the manufacturing of lime, whose global output in 2008 reached 290 million tonnes (USGS, 2009), demanding about 350 million tonnes of limestone. Freas et al. (2006) inform the amount of limestone mined in the United States alone at 1.6 billion tonnes, but in this country much of crushed rock is sourced from carbonate rocks. The amount featured in Fig. 1 is, therefore, a conservative estimate of limestone output. In addition to the environmental impacts associated with most mining activities, limestone quarrying has the potential to cause a particular set of impacts due to the karstic nature of the terrains (Van Beynen and Townsend, 2005; North et al., 2009). Karst landscapes feature valued ecological and cultural resources, such as archaeological and paleontological sites, caves and landforms, unique flora species and subterranean fauna, including endemic trogobitic species (Watson et al., 1997). Any quarry or mine rehabilitation requires physical stabilization of pit and waste rock piles slopes, which is usually obtained by setting face angles taking account of the geomechanical characteristics of the rock. The resulting straight lines and the geometrical aspect of the final pit are source of remaining visual impact, only World output of major minerals 16,000 14,000 12,000 Mt 10,000 8,000 6,000 4,000 2,000 0,000 aggregates coal limestone iron ore Fig. 1. World output of major minerals. Sources: USGS (2009) for iron ore, cement and lime, Hetherington (2007) for coal, Langer (2006) for aggregates. Limestone output estimated by authors from cement and lime outputs; limestone used as crushed stone is not considered in this estimate and is accrued as aggregate. partially mitigated by vegetation. Often a large rock outcrop remains, in contrast with the surrounding landforms. Karst landscapes, on the other hand, naturally feature rock outcrops in the forms of cliffs, buttresses and other meso and microscale landforms, but a limestone quarry surrounded by natural karst landforms will still remains in sharp contrast with the surrounding landscape. In order to mitigate such visual intrusion, it has been proposed that rehabilitation of limestone quarries should aim at “replicating” karst landforms, i.e. to mimic natural appearance by replacing straight lines and other engineered features by rock headwalls, buttresses and other karst landscape features (Gagen and Gunn, 1988; Gunn and Bailey, 1993) in areas of outstanding natural beauty or where screening techniques can themselves be intrusive (Walton and Allington, 1994). Establishing suitable wildlife habitats is another concern for mine rehabilitation. Cullen et al. (1998) studied the vegetation communities established in three modern quarry sites in the UK rehabilitated using the landform replication technique. Authors compared the communities established after two years in the three rehabilitated sites with communities occurring on natural dalesides and on seven disused, abandoned quarries after 40e85 years of natural regeneration. They found the vegetation of modern rehabilitating quarries to be more closely related to the natural reference sites than those resulting from spontaneous growth. Studies by Wheater and Cullen (1997) in the same sites had showed that the rehabilitating quarry sites had a relatively high number of plant species (originated from hydroseeding), but featured much more bare ground as compared to older disused quarries and to reference sites. Further studies by Wheater et al. (2000) focused on surveying spider communities in those same areas, founding greater differences than those indicated by the study of vegetation communities developed on limestone quarries rehabilitated by mimicking natural landforms. Additionally, it has been shown that rehabilitated and even abandoned limestone quarries can act as important secondary habitats for a number of animal and plant species, such as bees (Krauss et al., 2009), butterflies (Benes et al., 2003) and spiders (Tropek and Konvicka, 2008). Mine planning in karst landscapes should include pre-mine surveys of environmental and cultural values of caves, small and large scale landforms, underground fauna and archaeological sites (Misra et al., 2002; Vermeulen and Whitten, 1999), as well as studies aiming at understanding the often complex underground water flows (Worthington and Ford, 2009; Worthington and Gunn, 2009). Misra et al. (2002) provide specific guidelines for planning mining activities in karstic regions. In 1999, the world’s ten biggest cement companies created the Cement Sustainability Initiative (CSI), under the umbrella of the World Business Council for Sustainable Development (WBCSD). Albeit reacting later than the metal mining industry to the challenges of sustainability (Sánchez, 1998), the cement industry established codes of conduct and guidelines to address its most important environmental issues, including quarry restoration. A number of cement companies has also been publishing corporate sustainability reports on an annual basis, but started this practice later than the biggest metal mining companies (Pérez and Sánchez, 2009). One of eight major topics on sustainability identified by the CSI is “ecological stewardship: improving land use and landscape management practices”, which includes land rehabilitation. An “agenda for action” launched in 2002 contains six “critical issues”, out of which “local impacts” addresses quarry planning and rehabilitation (WBCSD, 2009a). CSI website features twelve case studies of limestone quarry rehabilitation (WBCSD, 2009b), whereas other case studies featuring good practices are provided by Misra et al. (2002). A.C. Neri, L.E. Sánchez / Journal of Environmental Management 91 (2010) 2225e2237 Despite a number of published studies on limestone quarry rehabilitation, these are far less numerous than the literature on the rehabilitation of other types of mining. Specific guidelines for limestone quarries were developed only recently and remain, to a large extent, untested, despite the large number of such mines worldwide. 3. Approach, methods and research steps Ex-post assessment e a systematic and analytical procedure to form a judgement about what is being evaluated e often requires comparing expected elements with the actual implementation of the evaluated plan, program or project (Weiss, 1998). Thus, the principle of comparison with internationally recommended best practices was used to assess the environmental rehabilitation practices applied in limestone mining. Te research started with a survey of best mine rehabilitation practices in order to set up a benchmark, against which individual mine rehabilitation programs could be evaluated. Fig. 2 shows the research steps. Put simply, environmental management best practices are “the best way to do things” (Australia EPA, 1995a). In environmental management, best practices include, for each step of a production process, a group of procedures or solutions that are recognized by the mainstream companies as both effective and economically viable to avoid or to reduce the adverse environmental impacts of activities, products and services. Best practices correspond to a benchmark, which can be followed or adapted by other companies or organizations. International and Brazilian environmental best practices were surveyed in order to establish the benchmark. The main sources for the compilation of best practices in the mining industry were government, industry-sponsored or joint government-industry publications. Such institutional authors were intentionally retained as more credible sources of best practices, as opposed to either individual academic or professional sources or to individual company best practices. Environmental protection measures endorsed by industry representative bodies have normally been tested and considered as cost-effective. Therefore, they can be employed or adapted by other companies working in the same sector. Best practices mentioned in these sources were (i) compiled, (ii) grouped in categories, (iii) selected using authors’ professional judgement, (iv) transformed into synthetic statements, and (v) validated by submitting a draft list to experts. Survey of international best practices sources Selection of manuals and guidelines Compilation of most appropriate environmental rehabilitation best practices Preparation of draft best practice environmental rehabilitation statements Preparation of field forms grouping statements Consultation with professionals to validate statements Development of a draft qualitative data evaluation protocol Pilot test application in three mines Corrections and adjustments of the field forms and the protocol Development of a set of conformity indexes Calculation of indexes for the pilot cases and adjustment in index calculation formulae 2227 The compiled best practices were grouped in three major categories: (1) planning, (2) operational and (3) management, corresponding to the adoption of the PDCA (plan-do-check-act) management systems model to mine rehabilitation. The operational practices were divided up in (i) soil management practices; (ii) landform stabilization or geotechnical and topographic practices; (iii) water resource protection practices and (iv) vegetation management practices. The recommendations of best practices obtained from the selected sources were transformed in synthetic statements, e.g. “surface soil should be removed separately from subjacent material (waste or ore)” and grouped in a series of field forms. A draft version of the field forms was submitted to four experts from government and academy for the sake of validation. The application of field forms is made by performing technical inspections. Most mine personnel is used to inspections and audits, as many companies have their own management systems e quality, environmental, health and safety or integrated management systems all rely on inspections, tests or audits as control tools (Power, 1997). In performing the technical inspection, the assessors seek to collect objective evidence by means of: (1) obtaining, reading and reviewing documents; (2) undertaking interviews; (3) making field observations. An evaluation protocol was then developed, inspired by procedures used in environmental audits. The protocol involves the classification of inspection findings according to pre-determined categories. The next step was to field test the forms and the evaluation protocol by performing technical inspections in three limestone quarries whose managers were previously contacted and agreed to participate. After this test, both the protocol and the field forms were once again reviewed in order to adjust the terminology and accuracy of the statements, seeking to eliminate ambiguities in order to reduce variations in personal interpretation. The following stage was to develop a set of conformity indexes to derive a synthetic evaluation at the end of the process. The interest and usefulness of quantifiable indicators or indexes were appointed by several industry representatives for the sake of a possible integration with other business key performance indicators. For this purpose, conformity indexes can also be presented as conformity levels, as it will be later explained. The conformity indexes and the corresponding conformity levels allow for the assessment of the effectiveness of each rehabilitation program by transforming qualitative data collected in the field work into performance indexes. A rehabilitation program is here defined as coherent groups of environmental protection and rehabilitation measures, as grouped in the three major categories (i.e. planning, operational and management) and four subcategories, as abovementioned. Conformity indexes were calculated for each one of the three quarries previously inspected and compared with the authors’ perceptions and professional judgement about the quality of each program, considering their experience and knowledge about other limestone or non-limestone mines in Brazil and abroad. Finally, the procedure was applied again, after an adjustment of the formulae to calculate the conformity indexes, to six other quarries for its confirmation, validation and fine tuning. Minor adjustments were carried out during the second campaign of technical inspections and data analysis. The results were fed back to quarry managers. 4. Results Application in six new mines Final adjustment and refinement Fig. 2. Research steps to develop and validate the evaluation procedure. The main purpose of the research was to develop an evaluation procedure. As field tests were conducted to validate and refine the procedure, the actual environmental performance evaluated in 2228 A.C. Neri, L.E. Sánchez / Journal of Environmental Management 91 (2010) 2225e2237 nine quarries constitutes side results of the research. Both outcomes will be presented in this section. First, the following components of the evaluation procedure will be described: (1) the series of best practice statements, (2) the evaluation protocol and (3) the data analysis procedure. Results of the nine case studies will be featured in the final part of this section. 4.1. Best practice statements The following sources were used to establish the benchmark: Abnt (1999, 2006), ANZMEC/MCA (2000), Australia EPA (1995a, 1995b), Brodkom et al. (2000, 2002), Cetesb (2001), Environment Australia (1998), Ibama (1990), SMA (2004), Tasmania (1999), The Environment Council (2004), USFS and Utah FS (no date), Vermeulen and Whitten (1999) and WBCSD (2005a,b). The Australian federal publications (Australia EPA, 1995a, 1995b, Environment Australia, 1998) were prepared in consultation with industry and comprise a series of several booklets, out of which three directly related to rehabilitation were retained. Other booklets in the series also feature relevant guidance to planning, operating and rehabilitating any kind of mine, although most of the examples and best practice cases come from metal and coal mining. The Tasmanian Quarry Guide (Tasmania, 1999) is a government guidance document applicable to all kinds of quarries. The guidebook published by ANZMEC/MCA (2000) is an important reference for planning mine closure. The now well-known “Planning for Integrated Mine Closure Toolkit” (ICMM, 2008) developed by the International Council on Mining and Metals and launched on August 2008 was not available at the time the research was initiated, but much of its closure recommendations are already covered in other guidance documents, although at a less detailed level. Brodkom et al. (2000) is a study carried on for several European mining associations with support of the European Commission and covers several aspects of environmental management, out of which those pertaining to rehabilitation were selected. Brodkom et al. (2002) is a similar guide with examples from Spain. The European Cement Association (Cembureau) was one of the sponsors of these guides. The Environment Council (2004) provides guidance on involving the communities in planning, operating and decommissioning aggregates extraction. USFS and Utah FS (no date) is a field book for mine reclamation practitioners. Vermeulen and Whitten (1999) is a World Bank review about the consideration of karst values in development planning; although mainly discussing the importance of environmental and cultural values associated with karst landscapes for environmental decision-making, the publication provides some guidance on siting limestone quarries and on “reconstructing the landscape”. WBCSD (2005a) is a general guideline for life-cycle planning for the cement industry, including quarrying; it features general guidance and best practice examples from the cement sector. More detailed guidance with further examples from the cement industry is found in Misra et al. (2002). This study, commissioned by the WBCSD in support of the CSI contains recommendations which were largely featured in the abovementioned guidelines. Brazilian technical standards on mining rehabilitation and waste rock disposal (ABNT, 1996, 2006) were included not only because they are national standards pertinent to the country where the case studies were conducted, but also because they provide advice of general interest. Ibama (1990) advises on techniques and approaches to re-establish vegetation in mine affected land. Local guidance on revegetation was included to reflect specific advice as related to Southeast ecosystems, where Atlantic rainforest is the major biome; SMA (2004) was selected out of several scholarly publications because it is available at a government website as practical recommendation for ecological restoration. Local guidance on contaminated soils (Cetesb, 2001) was also included in the survey, as to a large extent it reflects international best practice. Best practices mentioned in the consulted sources were: (i) Compiled to extract recommendations relevant to limestone quarry rehabilitation; (ii) Grouped in categories (planning, management, operational with subcategories); (iii) Selected using authors’ professional judgement; (iv) Transformed into synthetic statements, and (v) Validated by submitting a draft list of best practice statements to experts. This procedure resulted in 150 best practice statements, organized in seven field forms to guide technical inspections and the collection of documented evidence. Table 1 synthesizes the statements, field forms and groups of practices, also called here rehabilitation programs. Although there are six programs, the statements are featured in seven field forms because field inspections of landform stabilization practices are best performed with separate forms for pits and individual waste rock piles. Since a quarry can have more than one waste rock pile, one form is used per pile, for easiness of field work. Fig. 3 shows, as an example, the field form prepared for evaluating planning practices, featuring the best practice statements and the columns to be filled in during field work or document review, as explained in the section below. In each form, blank lines are provided for the assessor to add statements that may result from particular or local conditions, such as legal or regulatory requirements, company internal procedures or recommendations arising from technical studies such as environmental impact statements or rehabilitation and closure plans. 4.2. Evaluation protocol The central element of the assessment procedure is a comparison between practices actually applied in each mine and international best practices. In order to enable the comparison, evidence has to be gathered by means of documents analysis, interviews and technical inspections. Fig. 4 synthesizes in the procedure used for conducting the assessment. The generic model of an environmental audit (ISO, 2002) was used as a basis to organize the tasks which appear on the left-hand side of Fig. 4. It is not claimed, however, that the evaluation procedure here developed is the equivalent of an audit, as audits may have other requirements. A detail of the tasks to be conducted while performing the assessment is shown on the right side of Fig. 4. 4.2.1. Evidence collection Objective evidence is gathered by means of technical inspections and document review. For each best practice statement, the following categories of evidences (modified from Viegas, 2002) are used:  Visual evidence (VE): obtained by direct observation; it can justify a conclusion without any other evidence;  Documental evidence (DE): obtained from document analysis, such as an environmental impact study, a rehabilitation or closure plan, monitoring reports, internal written procedures, registers of an environmental management system or others; documental evidence can be enough to register a non-conformity with best practices, but caution should be exerted, as documents may be poorly written, outdated, factually wrong or simply not reflect actual practices, which may have deviated from planned; A.C. Neri, L.E. Sánchez / Journal of Environmental Management 91 (2010) 2225e2237 2229 Table 1 Structure of field forms and summary of best practice statements. Type of rehabilitation practice Rehabilitation program Name of field form Headings in each field form Planning practices Planning Rehabilitation planning Rehabilitation and closure plan preparation Topsoil removal Internal roads Mine pit design Waste rock piles design Visual impact minimization Site selection Vegetation removal Stakeholder involvement Sub-total Operational practices Sub-total Managerial practices Soil management Topsoil management, erosion control and prevention of contamination Landform stabilization Water management Landform stabilization: rock face stability Landform stabilization: waste rock pile stability Water resources protection Vegetation management Vegetation management Management of the rehabilitation process Management of the rehabilitation process Sub-total Total  Verbal evidence (I): obtained by interviews, forms the least reliable category because the interviewee may say only what he or she thinks the assessor would like to hear or even get confused; this kind of information should be treated with caution, and other (visual or documental) evidences should be found for confirmation; double-checking with other interviewees is a commonly recommended practice for conducting interviews. 4.2.2. Evidence classification Actual practices observed in the field are classified in one of following categories in the appropriate column of the field forms (Fig. 3):  Totally applied (TA): when the described practice is integrally adopted in the quarry;  Satisfactorily adapted (SA): when quarry staff has found an equivalent or better solution to that described in the best practice statement;  Partially applied (PA): when the practice is not integrally adopted;  Non-applied (NA): when staff unjustifiably does not adopt that practice;  Not applicable (NS): when the described practice is not applicable to the actual observed situation. Professional judgement is essential to classify the practices. No guideline or best practice manual can be directly or automatically applied to any mine, without some degree of interpretation. In fact, Number of best practice statements 11 3 2 5 5 2 5 4 2 Topsoil segregation and removal Topsoil storage Surface preparation Topsoil replacement Surface ripping Soil contamination prevention Erosion control Rock face stability 35 6 5 4 4 2 3 7 7 Waste rock pile stability 12 Surface water Underground water Vegetation removal Visual impact minimization Revegetation 11 5 7 3 14 Standardization of procedures Human resources Suppliers capacity-building Environmental monitoring Operational maintenance Quality assurance/quality control 96 1 1 1 6 8 4 19 150 in spite of the common characteristics that most mines feature, each mine is singular, due to particular geological, geomorphological or ecological characteristics or even due to its social surroundings, Local conditions may not only turn a generic best practice statement not directly applicable, but also can turn it as non recommendable. One example is the management of topsoil. In the vast majority of situations, topsoil should be removed separately from subsoil and spread as soon as possible in the surface to be rehabilitated, as the seed bank contained speeds up vegetation cover and can provide quick protection against the erosive potential of runoff. However, the existence of weeds in the topsoil can be a hurdle if the area is to be restored to natural vegetation cover and it could possibly be more advisable to import soil from another locality or to mulch or employ organic matter. One example is the problem faced in the rehabilitation of Jarrahdale bauxite mine in Southwest Western Australia, arguably a global benchmark in mine rehabilitation. In the region, the soil-borne pathogen Phytophtora cinnamomi causes the so-called dieback disease to the dominant tree species jarrah (Eucaplyptus marginata) and many other species. As ore bodies may feature both infested and not infested overlying soil, special care must be exerted to avoid spreading the disease. The mining company, which moves 6 million m3 of soil a year, developed soil management protocols to prevent the spreading the pathogen (Colquhoun and Kerp, 2007). 4.2.3. Data analysis Technical inspections provide for the collection of qualitative data. In order to make sense of the amount of data collected and derive reliable and preferably reproducible conclusions, a data 2230 A.C. Neri, L.E. Sánchez / Journal of Environmental Management 91 (2010) 2225e2237 PLANNING FOR MINE REHABILITATION Mi n e : Dat e: Purpose: To identify and assess mine rehabilitation planning practices Classification: TA (totally applied practice), SA (satisfactorily adapted practice), NA (not applied practice), NS (non-applicable practice). Types of evidence: VE (visual evidence), DE (documental evidence), Benchmarking PA (partially applied practice), I (verbal evidence). Classificat ion Types of evidence Rehabilitation and closure plan 1. The company should prepare a rehabilitation plan 2. The rehabilitation plan should follow the contents recommended in NBR 13030 3. The mine should have a closure plan 4. The closure plan should consider options for the future use of the area 5. The rehabilitation or closure plan should indicate the preferred alternative for the future use of the area. 6. The preparation of the closure plan should be made in consultation with local community and other interested parties 7. Environmental reclamation measures should be planned at the same time of the mining activities 8. A monitoring program should be included in the rehabilitation or closure plan 9. An appropriate group of indicators should be selected to assess the results of rehabilitation 10. The rehabilitation or closure plan should be periodically reviewed and updated, especially in the ten year period before the scheduled closure date 11. Provision of financial resources should be made to cover rehabilitation and closure costs Planning for topsoil removal 12. Topsoil removal should be scheduled as to minimize storage time and maintain soil quality 13. Soil humidity should be characterized to define the best timing for removal 14. The thickness of topsoil to be selectively removed should be estimated Planning of access roads, pit slopes and benches 15. A stormwater collection and transfer network should be calculated using maximum probable rainfall estimated for the region 16. Final pit slope angles should be calculated according to the geological-geotechnical features of the rock, as to determine a stable final pit configuration Planning for implementation of waste rock piles 17. A geotechnical study should be made as a condition to the design of waste rock piles 18. A stormwater drainage network should be calculated based on local or regional hydro-meteorological study 19. Areas featuring natural slopes above 18 o should not be selected to build waste rock piles 20. Waste rock piles should not be placed above natural drainage lines, water courses or springs 21. Waste rock pile should not be sited over instable or colapsible soils, wetlands or areas subject to flooding Planning for reducing visual impact 22. A plan to reduce visual impact should be prepared considering local environmental features, the views over the mine and the quality of the surrounding visual resources Fig. 3. Example of a field form used to collect and register evidence of rehabilitation practices during technical inspections. Notes A.C. Neri, L.E. Sánchez / Journal of Environmental Management 91 (2010) 2225e2237 Classificat ion Benchmarking 2231 Types of evidence Notes 23. Community and interested parties should be consulted about the best forms to reduce the visual impact Studies for pit and waste rock piles planning 24. A hydrogeological study should be carried out before mine opening or expansion projects 25. Karst system studies should include geology, geomorphology, hydrology and biology 26. A speleological survey should be conducted 27. An archaeological and heritage survey should be conducted 28. If the mine can reach the groundwater level, an aquifer lowering study should be conducted, determining lowering cone dimension Planning for the vegetation removal 29. A previous flora study should be conducted whenever native vegetation should be removed 30. Flora studies should be made in neighboring areas that present fragments of native vegetation 31. Vegetation removal should be planned to be phased and scheduled as late as possible in accordance with the mining plan. 32. Fauna studies including cave fauna should be made before native vegetation removal Community and interested parties involvement 33. The company should identify the interested parties and consult with them for the preparation of the rehabilitation or closure plan 34. A community involvement plan should be developed stating methods and approaches for involvement and for assessing the outcomes 35. Community and interested parties consultation should be documented and registers such as presence lists, minutes and pictures kept for easy reference Other planning activities adopted by the company 36. 37. 38. * Additional notes and comments in blue = essential practices in red = important practices in black = accessory practices Fig. 3. (continued). analysis procedure was developed. It is based on a hierarchy of best practices statements and on calculations of conformity indexes weighted by the importance of the practices. The best practice statements were ranked in three classes of importance, thus defining a scale for analysis (DeVellis, 1991) and providing a semantic differentiation (Pereira, 2001) among the categories. The best practices statements are arranged according to the following classes of importance:  Essential practices: those which are usually necessary for a successful quarry rehabilitation program; however, upon firmly grounded justification, an essential practice may not be applied in a particular quarry;  Important practices: those which feature a significant contribution to a successful quarry rehabilitation program;  Accessory practices: those whose implementation may lead to a measurable improvement in the outcomes of a quarry rehabilitation program. As good practice guides usually do not consider which recommended practices are more important, in classifying the best practice statements included in this procedure, a number of criteria 2232 A.C. Neri, L.E. Sánchez / Journal of Environmental Management 91 (2010) 2225e2237 Request of relevant documents Document analysis Technical inspection scheduling Opening meeting Technical inspection Rehabilitation or Closure Plan, Environmental Impact Study, licenses and permits, maps, aerial photos and other technical documents Document review, collection of documental evidence, field forms filling in, identification of gaps Survey of specific conditions from environmental licenses or legal requirements Presentation of work objectives and inspection goals and time table Walk in with experienced staff for evidence collection, interviews, additional information collection Field forms filling in and classification of practices Closing meeting Data treatment Preparation of draft report Review and confirmation of classification of practices; double-check doubtful evidence; calculation of conformity index and level Analysis and recommendations Review by mine management Issuance of the final report Fig. 4. Sequenced tasks in conducting the evaluation. were adopted. Essential practices are those most frequently cited in the reviewed guides, as well as practices often included in regulatory requirements in several countries (such as the preparation and submission of a rehabilitation plan). Important practices include recommendations found less frequently in the reviewed guides, as well as those which stem from technical standards. Practices that should be adopted only if a particular situation is present, such as those related to pumping groundwater to dewater a pit, were classified as accessory, so as not to negatively affect the conformity index; also in this group are those practices which cannot be regarded as universal recommendations, but if applied contribute to the success of rehabilitation. Table 2 shows the distribution of statements according to this hierarchy. The fact that a majority of statements are ranked as accessory practices is a recognition that rehabilitation measures often have to be unique to a mine, thus stressing the importance of Table 2 Distribution of best practices statements according to their hierarchy. Hierarchy Number of statements Essential practices Important practices Accessory practices 25 (16.7%) 41 (27.3%) 84 (56%) planning. Different colours in the field forms indicate the hierarchy of each statement (Fig. 3). In performing the technical inspections, the assessor may identify particular legal or regulatory requirements, such as conditions resulting from licensing and requirements arising from corporate policies or derived from voluntary codes subscribed by the company. When collecting documentary evidence, the evaluator should include those conditions in the proper place of each technical inspection form, in the case they represent additional aspects not described in the statements. Interpretation may be needed as to evaluate whether or not a legal or regulatory condition is already covered by a generic best practice statement, as it is often the case. Any legal or regulatory condition must be classified as essential. A conformity index is calculated for each group of practices: I1 for essential practices; I2 for important practices and I3 for accessory practices. The indexes are expressed as the percentage of practices actually applied in the quarry, but weights are introduced to reflect the differences in the level of application of each best practice statement. Hence, for each group, totally applied or satisfactorily adapted practices are weighted more than partially applied practices, so that the index reflects the semantic differences embedded in these terms employed to describe evidence classification (Section 4.2.2). As rehabilitation measures derived from legal requirements are also considered as essential, the weight assigned is the same as the weight of essential practices. Not applied practices do not contribute to the index, thus zero weight is allocated, whereas not applicable practices have to be deducted from the total of practices as to obtain the percentage of application. The weights used for each type of classification are: 1 for totally applied or satisfactorily adapted practices; 0.5 for partially applied practices and; 0 for practices which are not applied in a mine. Thus, the indexes are calculated according to the following expressions: I1 ¼ PTA þ PSA þ PL þ 0:5ðPPA Þ= I2 ¼ PTA þ PSA þ 0:5ðPPA Þ= X X PESS þ PL  PNS PIMP  PNS I3 ¼ PTA þ PSA þ 0:5ðPPA Þ=PACC  PNS (1) (2) (3) where: I1 ¼ index of essential practices; I2 ¼ index of important practices; I3 ¼ index of accessory practices; PTA ¼ number of totally applied practices; PSA ¼ number of satisfactorily adapted practices; PL ¼ number of practices required by legal requirement; PPA ¼ number of partially applied practices; PNS ¼ number of nonapplicable practices; PESS ¼ total number of essential practices; PIMP ¼ total number of important practices; PACC ¼ total number of accessory practices. The next step is the calculation of a conformity index (CI) for each one of the six rehabilitation programs (Table 1). Maximum conformity was established at 100% and weights distributed for each index according to its relative importance, as follows: I1 ¼ 5, I2 ¼ 3, I3 ¼ 2, thus reflecting again a semantic differential and the regularity of the intervals between classes. The conformity index is calculated as follows: A.C. Neri, L.E. Sánchez / Journal of Environmental Management 91 (2010) 2225e2237 CI ¼ ½5ðI1 Þ þ 3ðI2 Þ þ 2ðI3 Þ=10 (4) A conformity level is adopted to classify the conformity index in one of three performance classes. A traffic light colour scheme was adopted (Table 3), for the sake of facilitating communication. By using such a scheme, mine managers, corporate committees and other internal agents can quickly perceive strengths and weaknesses in their approach to mine rehabilitation. 4.3. Test and validation of the procedure 2233 At the moment of field work, every quarry had a certified environmental management system, according to the ISO 14001 management standard. Only one quarry had an environmental impact study prepared recently due to an expansion project. The conformity indexes obtained by applying the evaluation procedure are shown in Table 4. The results obtained in the nine quarries will be presented alongside the discussion in the next section. 5. Discussion The procedure was applied in nine limestone quarries situated in Southeast Brazil in order to test, validate and refine its components. The field forms were reviewed after the first battery of test in three quarries. Redundant statements were eliminated, as some may be relevant to, say, both landform stabilization and water management practices; in such cases they were placed in only one of the rehabilitation programs. After adjustments, the procedure was applied to six other quarries, leading to the introduction of additional corrections. The findings were reported back to quarry managers, and input was sought as to improve both the field forms and the evaluation protocol. Prior to this second round of field tests, a workshop was held with managers and quarry technical personnel, in order to clarify the objectives and to survey the potential usefulness of such a procedure to quarry staff. A call for quantifiable results which could easily communicate environmental performance was expressed at this workshop. The development of conformity indexes and conformity level classification is the response to such need. All quarries have been in operation for many years or decades. As a consequence, many environmental protection practices which are current today were ignored or unknown during a significant part of the life of these quarries. Under Brazilian law, rehabilitation plans are mandatory for every mine, but no closure plan has to be submitted to regulatory authorities. The quarries were located in three states in the Southeast region of Brazil. State environmental authorities are primarily responsible for licensing new mines or expansion projects, as well as for supervising the implementation of mitigation measures. This section will mainly discuss the empirical results obtained in the quarries. A discussion on the results of the application of the evaluation procedure itself will be presented in the last part. As shown in Table 4, the group of practices featuring the worst performance is planning. Operational practices reached better results, as high conformity level was obtained 18 out of 36 times (50%), moderate conformity level was obtained nine times (25%) and low level was obtained nine times (25%). The predominant conformity level for the management practices was moderate, with only quarry 2 reaching high conformity. This quarry is the same that showed the high conformity level for the planning practices. 5.1. Planning practices Most quarries scored low in rehabilitation planning. All mining companies are legally required to prepare and submit a rehabilitation plan to environmental authorities. Although the quarries are distributed in three States, the administrative requirements are very similar. As all quarries had submitted a plan, copies were requested to perform the evaluation and were reviewed considering both regulatory guidance and the Brazilian technical standard NBR 13030. The good score obtained by quarry 2 can be explained by the recent submission of its expansion project to the environmental impact assessment (EIA) process. The EIA process requires the preparation of an environmental impact study (EIS) containing detailed background information on several aspects including Table 3 Correspondence between conformity level and index. conformity level description conformity index A satisfactory set of adopted practices lead to risk and impact prevention and to the correction of the high most significant degradation processes; there is a 0.75 ≤ CI < 1 high adherence to international best practices and compliance with major legal requirements. A number of best practices are adequately applied, but the rehabilitation approach is in need of moderate 0.40 ≤ CI < 0.75 improvement to reach satisfactory conformity with international best practices in mine rehabilitation. Few or no practices are effectively applied, showing low adherence to international best low practices in mine rehabilitation; the current CI < 0.40 approach may jeopardize the fulfillment of rehabilitation goals. 2234 A.C. Neri, L.E. Sánchez / Journal of Environmental Management 91 (2010) 2225e2237 Table 4 Conformity indexes and levels obtained for the evaluated quarries. quarry 1 (1) 2 (1) 3 4 5 6 7 8 9 (1) year started 1947/1990 1949/2005 1977 1937 1936 1936 1936 1982 1982 ISO practices 14001 operational managecertifi- planning soil landform water vegetation ment management stabilization management management ed? yes yes yes yes yes yes yes yes yes 0.54 0.78 0.24 0.07 0.31 0.28 0.29 0.25 0.20 0.75 0.80 0.65 0.18 1 0.72 0.85 0.78 0.80 0.80 0.54 0.52 0.16 1 1 1 0.32 0.30 0.82 0.42 0.51 0.45 0.80 1 0.61 0.80 0.75 0.52 0.80 0.06 0 0 0 0 0.80 0.80 0.54 0.80 0.57 0.57 0.57 0.57 0.57 0.60 0.55 Quarries 1 and 2 were expanded respectively in 1990 and 2005, having prepared an environmental impact study. groundwater, caves, flora and fauna and greatly contributes to the environmental planning of a mine (Ramcharam and Dey, 2005) as well as to its management (Dias and Sánchez, 2000). The second best score in planning was obtained by the only other quarry in the sample that submitted an EIS due to its expansion in 1990. It was found that only in three quarries (1, 2 and 8) speleological surveys were conducted for the quarry area and surroundings. Not only is undertaking such studies an internationally recognized good practice, but also their absence represents a risk for companies operating in Brazil, since, under Brazilian law, they can face lawsuits if speleological assets are damaged. Notwithstanding, these studies did not seek to unveil the possible influence of the mines on local karst dynamics. Another infrequent study is hydrogeology, which should be prepared whenever a quarry can reach the groundwater level or when karst aquifers can be affected. Although most quarries operated below the natural groundwater level, a comprehensive hydrogeological investigation was conducted only for quarry 2, again as part of the EIA. Although karst can develop in any limestone area, karst is known to be well developed only near quarry 9. However, a comprehensive survey of karst landforms and hydrology was not conducted. Such a study provides inputs for siting waste rock piles and other quarry components. A significant shortcoming of planning is the absence of postmine land use plans, apart from quarries 1 and 2. No quarry has a closure plan, a specific recommendation contained in the CSI guidelines (WBCSD, 2005a) which is becoming standard in the mining industry (ICMM, 2008). Only quarry 2 presented a detailed cost estimate for implementing rehabilitation measures during the operational phase. Initiatives aimed at the involvement of the local community in the planning for rehabilitation or closure were thoroughly absent in all cases, again with the exception of quarry 2, as public hearings are mandatory in the EIA process. Good planning practices were found in quarries 8 and 9, despite their poor overall score in this program. Ecological restoration conducted in these quarries (which featured the highest scores for vegetation management practices) are based on robust planning, which included a detailed survey of physical characteristics of waste rock piles as a basis to recommend species selection, planting and soil improvement approaches. 5.2. Operational practices Soil management practices involve topsoil management, erosion control and prevention of contamination. They ranked high in six out of nine quarries, with only one quarry showing poor practices.. Most quarries installed aboveground fuel storage tanks, decommissioning underground tanks and undertaking soil contamination investigations; three quarries built new workshops for heavy equipment maintenance with impervious flooring and other facilities to prevent soil and water contaminations, as well as fuel stations designed to prevent leaks. Landform stabilization practices featured three quarries showing poor performance. Although most quarries showed evidence of effective geotechnical control of pit slopes, in one quarry a landslide occurred and few quarries paid equivalent attention to waste rock piles. This reflects an outdated mining engineering approach under which the pit is subject to control for safety and operational reasons, but waste rock is considered as rubbish to be discarded at the lowest possible cost. The nature of the material disposed of in waste rock piles varies from coarse rock fragments (such as low grade carbonate rocks or other lithology) to fine grained weathered soils including clays not suitable to cement production. As water is the main disruptive agent in such waste piles, stability is closely dependent on adequate management of runoff. In a region subject to intense concentrated rainfall (up to 100 mm in 1 h), devices built to direct and retain runoff are common practice, some comprising both sedimentation and infiltration ponds. Gutters and other devices collect runoff alongside internal roads and especially over waste rock piles. Notwithstanding, although most inspected mines built drainage systems in waste rock piles, their dimensions were empirically estimated instead of being based on hydrometeorological calculations. In quarry 4, sediment from the waste piles is silting up trees located downhill. In quarry 8, the absence of sediment retention devices is silting up a small alluvial plain situated downstream of a waste pile. Water management practices scored relatively well. They are largely interrelated with soil protection and landform stabilization, as explained above. Runoff and groundwater collected in pits is used for dust suppression, but all quarries have excess water to discard to creeks after sediment retention. Groundwater collected in quarry 1 is used in the cement plant. In quarry 9, a waste rock pile placed near a possible doline (a closed depression in the terrain) could be a source of sediments to clog subterranean conducts and A.C. Neri, L.E. Sánchez / Journal of Environmental Management 91 (2010) 2225e2237 damage fauna; however, the absence of comprehensive studies of the karst system precludes any firm conclusion. The practices related to vegetation handling include procedures for clearing and planting and use of vegetation screens to reduce visual impact during operations. Five out of the nine quarries showed the lowest conformity level, with three quarries presenting no practices related to vegetation management at all (zero score). Those quarries have no register of vegetation removal, as it was carried out decades ago and no further vegetation clearance was necessary in recent years, but no revegetation trials were conducted. In contrast, quarries 8 and 9 implemented several actions towards managing natural vegetation aiming at restoring ecological values in the affected areas. Both quarries commissioned studies to guide planting and implemented the recommended actions, tailored to local climatic and soil conditions. In these quarries, planting native species is preceded by soil preparation, achieved by sowing short-cycle gramineae and leguminous plants adapted to the local conditions. This procedure enables the substrate to quickly acquire physical, chemical and biological features which are favourable for the development of native species seedlings planted in general one year later. A commendable initiative was undertaken in quarry 9, where an internal road was relocated away from a creek, making room for the restoration of the riparian forest; relocating other roads is planned. Restoring riparian vegetation was also implemented in mine 1 and could have been done at least in limited areas of all mines. 5.3. Management practices Only one quarry reached high conformity, the same quarry which featured the highest score in planning practices. On average, management practices are much better than planning practices. It could be expected that the scores for management practices would feature a higher percentage of high conformity, as all quarries have a certified environmental management system. However, those EMSs pay low attention to issues pertaining to land rehabilitation and biodiversity. It has been found that several quarries do not have written procedures applied to rehabilitation. Moreover, in quarries which do have such procedures (e.g. periodical topographical monitoring and control of waste rock piles stability), these are not applied as required in the company documents. Those companies rely extensively on external consultancy and contractors to plan and to undertake rehabilitation activities, especially revegetation. On the other hand, all quarries have ongoing operational procedures for a number of activities related to soil and water protection e such as used oil collection, storage and management, prevention and control of fuel and lubricants leaks and waste management in heavy equipment maintenance workshops e which are important for rehabilitation, but are also relevant to several industrial activities, including cement manufacturing. For these issues, management programs and actions can to a large extent be standardized across several industrial sectors. By contrast, mine rehabilitation often requires tailor-made procedures. As an ISO 14001 EMS needs to be periodically audited, the technical inspections sought to collect evidence on the role of auditors in verifying the rehabilitation programs undertook in the quarries they audit. Interviewees systematically answered that environmental auditors attach a great importance to compliance with regulations and good practices related to waste management in general and to used oil, fuel and lubricant management as to prevent leaks, but do not conduct detailed audit of practices specifically related to land rehabilitation, especially revegetation, nor do auditors usually ask for evidence of vegetation or fauna surveys or monitoring. 2235 The relatively low importance of land rehabilitation in internal management is also reflected in the environmental monitoring programs adopted by the companies. All mines monitored the surface waters, but none systematically monitored vegetation or any other biotical aspects. 5.4. The evaluation procedure For the sake of logical application and in order to limit the amount of best practices statements in each field form to a manageable number, the practices were organized under six rehabilitation programs (Table 1). However, as the practices are interrelated, it is not possible to fill in the forms in the field simply by following the order the statements appear. As going back and forth is inevitable, the assessors have to be familiar with the forms before starting. It was also found, consistently with the practice of environmental auditing, that the evaluation procedure is best applied in teams. All field work was performed by the two authors and would hardly be done by only one professional. As in most kinds of environmental audits, field work is more effective and efficient if preceded by a careful examination of key background documents (Fig. 4). An understanding of the physical setting of each mine is also essential, thus maps and aerial photos are extremely helpful in performing field work. Exerting professional judgement is necessary during all phases of the assessment, but especially in classifying the actual practices in one of the five categories (Section 4.2.2). As the quarries feature certified EMSs as well as safety and health procedures, staff is used to and understands the purposes of audits (Power, 1997). Thus, applying the evaluation procedure was relatively straightforward. It is imperative that in doing field work the assessors are escorted by knowledgeable staff. Sometimes, however, such persons simply cannot be found among current staff, suggesting organizational amnesia, as knowledge owned by individuals is not stored in organization memory (Othman and Hashim, 2004). In reaching conclusions and making recommendations, understanding of the rehabilitation process as made up of six programs is helpful in identifying the root causes of some poor practices. Thus, a number of waste rock piles are not better integrated into the surrounding landscape simply because the stacks were not planned for a final landform. The proposed framework can verify if a quarry meets the key performance indicators agreed by the signatory companies of the CSI (WBCSD, 2005b, 2007). The case studies showed that out of the three key performance indicators of local impacts on land and communities adopted by the CSI, all quarries comply with the first (having a quarry rehabilitation plan), but not with the two other (having community engagement plans in place and to address biodiversity issues). However, these indicators are generic and do not inform on the contents of such plans or about their actual achievements, aspects that can be evaluated by the proposed procedure. 6. Conclusions The proposed procedure for evaluating environmental rehabilitation measures in limestone mines is an analytical tool that can be successfully applied during the operational phase of a quarry. If periodically and systematically applied, the evaluation tool can document the evolution of rehabilitation practices in one particular quarry and show their improvement over time, storing robust evidence to demonstrate achievements. The results of a first evaluation can identify risks and lead to recommendations for improving ongoing practices. It can also identify best practices adapted to local conditions that could be spread to other quarries 2236 A.C. Neri, L.E. Sánchez / Journal of Environmental Management 91 (2010) 2225e2237 operated by the same company or adopted as a benchmark. The use of a predefined scoring system facilitates benchmarking and comparison among companies or mines operated by one company. Usefulness of the conformity index is twofold: a quick view is provided by the traffic lights colours scheme whereas the numerical index allows for nuanced differentiation between sites and for charting the evolution of rehabilitation practices if the procedure is applied at regular intervals. By using such a scheme, quarry managers, corporate committees and other internal agents can quickly perceive strengths and weaknesses in their approach to quarry rehabilitation. The conformity indexes and levels can also be used to establish corporate goals, as to have a certain percentage of sites featuring high conformity level. External and internal communication can also be facilitated as conformity levels can be incorporated into environmental performance or sustainability reports. The case studies showed that out of the three key performance indicators of local impacts on land and communities adopted by the CSI, the quarries only comply with one (having a quarry rehabilitation plan). One shortcoming observed in all quarries is the great reliance on external consultants and contractors to undertake most rehabilitation tasks. By adopting such an approach, the companies do not entail a process of organizational learning, as rehabilitation is not integrated into strategic planning. The best evaluative scores were reached by quarry 2, featuring four programmes at high conformity and two at moderate conformity level. The fact that this mine has recently been submitted to the EIA process suggests that public scrutiny may play a positive role in enhancing rehabilitation practices, what is corroborated by the finding that the second best was also subject to EIA. The appropriate use of the framework requires: (a) the company’s commitment and genuine interest in evaluating its practices in order to improve environmental performance, and (b) that the assessors have professional or academic experience in mine rehabilitation in order to interpret field evidence and reach meaningful conclusions. The procedure can also be applied to other quarries or to mines of industrial minerals, as limestone quarrying shares several characteristics with those other kinds of mines. The procedure can also be adapted to metal mines, provided field forms are adjusted and new best practice statements and field forms related to tailings disposal and issues such as acid mine drainage are added. Acknowledgments The authors thank FAPESP e São Paulo State Research Foundation for its financial support to this work (register n. 2005/58089-0) and the Brazilian cement companies who kindly agreed to participate in this research. Appendix. 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