Hardrock Mining and Beneficiation Environmental Management System Guide

September 2012

Contents
1. EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 A. Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3 B. Overview of an Environmental Management System. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3 C. Overview of This Guide . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3 2. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 A. Purpose of This Guide . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4 B. Overview of an Environmental Management System. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4 C. Implementation Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5 3. INITIAL IMPLEMENTATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 A. Plan Project . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5 B. Set Policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8 C. Identify Environmental Aspects and Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9 D. Identify Applicable Environmental Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10 E. Assess Environmental Aspects, Impacts, and Existing Operational Controls . . . . . . . . . . . . . . . . . . . . . .14 F. Improve Operational Controls. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22 4. CONTINUAL IMPROVEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 A. Monitor Programs and Assess Performance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27 B. Conduct Management Review and Establish Improvement Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .28 5. THIRD-PARTY CERTIFICATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 Appendix 1: Overview of ISO 14001 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 Appendix 2: Overview of U.S. Federal Environmental Laws and Regulations Potentially Applicable to Hardrock Mining Operations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 Appendix 3: Assessment of Significant Environmental AspectsExample . . . . . . . . . . . . . . . . . . . . . 37 Appendix 4: Assessment of Controls and Residual RiskExample . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 Appendix 5: Operational Control Tables for Common Significant Environmental Aspects for Mining Operations OnlyExample . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50

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1. EXECUTIVE SUMMARY
A. Background
This Hardrock Mining and Beneficiation Environmental Management System Guide (EMS Guide) was developed to assist hardrock mining companies in developing and implementing environmental management systems (EMSs) that can be customized to a companys unique operating circumstance and management culture. Although this guide is specifically intended for small- to medium-sized operators, larger operators may also benefit from using this guide, even if they have already implemented an EMS. The guide includes several tools and examples to help companies get started quickly and avoid common pitfalls. This guide does not focus on third-party certification of an ISO 14001 EMS; however, ISO 14001 and certification is covered.

B. Overview of an Environmental Management System

An EMS provides a clearly defined and structured approach to managing environmental performanceit includes all of the procedures, practices, people, equipment, and technology at a facility. An EMS typically follows a plan-do-check-act continuous improvement process. Although many models and structures are used for an EMS, they all essentially address the following items: Identifying applicable legal requirements, impacts, and risks; Implementing controls to manage those requirements, impacts, and risks (controls are broadly defined to include procedures, training, inspections, equipment, etc.); Monitoring the implementation of the controls and resulting performance over time; and Setting goals and taking action to ensure continuous improvement. Most EMSs are focused on delivering reliable regulatory compliance and reducing adverse impacts to the environment, though reductions in costs and risks as well as improved reputation and access to markets are also important outcomes for many.

C. Overview of This Guide

This EMS Guide describes a process for implementing an EMS at hardrock mining and beneficiation operations. The process is supported by specific tools and examples to assist with EMS implementation. Specifically, this guide provides:

1. 2. 3. 4. 5. 6. 7. 8. 9. 10.

An example of an EMS task force charter and kickoff meeting agenda; An example of an environmental policy; Typical environmental aspects and potential impacts for a mining and beneficiation operation; Example of a compliance calendar; A tool for assessing the significance of environmental aspects for mining operations; A tool for assessing controls and residual risk for mining operations; An example of a training needs assessment matrix; Example of a list of EMS documents and records that facilities should maintain and control; Example of operational controls for significant environmental aspects for mining operations; and An example of an action plan format.

In addition, this EMS guide provides a process for monitoring and assessing performance through management review and presents an overview of U.S. federal environmental laws and regulations that are potentially applicable to hardrock mining operations.

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2. INTRODUCTION
A. Purpose of This Guide
The purpose of this EMS Guide is to assist hardrock mining companies in developing and implementing an effective EMS. The guide is specifically intended for small- to medium-sized operators and employees of the hardrock mining sector who have decided to implement an EMS for their facility or company. Large-sized operators who have already designed and implemented an EMS for their facility or company may also benefit from using this guide. By providing guidance and tools, this guide will help companies get started quickly, avoid common pitfalls in designing and implementing an effective EMS, and effectively manage the costs associated with EMS design, development, and implementation. The guide is specifically designed to provide useful tools that will improve a companys environmental stewardship by addressing environmental impacts uniquely associated with the hardrock mining sector. Companies or facilities may realize other benefits from implementing an EMS, including improved regulatory compliance, reduced regulatory compliance costs, reduced future environmental liabilities, improved access to new markets, and improved community reputation. This guide does not focus on third-party certification of an ISO 14001 EMS. Its focus is on value-added EMS implementation at a typical hardrock mining operation. The guide does, however, reference ISO 14001 as the basic EMS framework, though variations on the ISO EMS model are discussed. For those interested in certification, please see Section 5.

B. Overview of an Environmental Management System

Simply stated, an EMS is how you manage environmental performance. The essence of the EMS concept is straightforward: 1. Identify which aspects of your operations need to be controlled to achieve your environmental objectives (e.g., compliance with environmental permits and regulations, reducing environmental impacts, and controlling long-term and short-term environmental risks). 2. Ensure that processes are in place to effectively manage those aspects. 3. Monitor the implementation of those processes and controls as well as the resulting environmental performance. 4. Set goals and take actions to continually improve. If you have structured processes to identify applicable legal and other requirements, identify and assess risks that arise from your operations, implement controls to mitigate risks to an acceptable level, and monitor and improve your programs and performance over time, then you have a solid EMS. However, for the EMS to succeed, all levels of management and the workforce must know their specific roles and responsibilities. Every company has an approach to managing environmental performance, and those approaches may vary in their formality and effectiveness. To maximize effectiveness, questions that must be asked are listed here: How comprehensive is it? Do you have controls in place for all of your known regulatory requirements? Do you have controls in place to manage potentially significant environmental risks, even if they are not regulated?

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 How well are the regulatory requirements, risks, controls, and overall environmental compliance approach understood throughout your organization? Does everyone know their roles and responsibilities, and are they competent to carry them out? How efficient is it (i.e., the cost/investment for the results achieved)? How effective is your approach to environmental compliance as people, operational and management processes, and business circumstances change? It is important to note that the EMS is not just the documentation of your environmental program; it is the people, processes, and technology that deliver the results. Care should be taken to avoid focusing on the documentation at the expense of actual practices and implementation. The international standard ISO 14001:2004 from the International Organization for Standardization (ISO) defines an explicit 17-element EMS framework that is described in Appendix 1. It is a flexible, risk-based, plan-do-check-act continual improvement approach that requires formal documented processes for many of its elements. The EMS implementation process described in this guide is consistent with the intent of ISO 14001.

C. Implementation Process
This guide will take you through a proven EMS implementation approach, which is illustrated in Figure1. Each step of the process shown in Figure 1 is described in more detail in the sections that follow.

3. INITIAL IMPLEMENTATION
A. Plan Project
What and Why
As with any important initiative or project, the EMS implementation must be well planned to help ensure its success. The scope must be specifically defined, a project plan should be developed and approved by appropriate management, and an implementation team should be formed. Engagement and involvement of relevant staff early in the process will help with implementation down the road. Visible support from senior executives down through local site management is also critical for an initiative such as this, ensuring the EMS is properly resourced and given appropriate priority among the many projects and initiatives typically occurring at an operating mine. For the purposes of this guide, we have assumed that you already have management agreement to improve your EMS and therefore no significant discussion of the advantages of drafting and implementing an EMS is provided.

How and Who

i. Define EMS project objectives and scope: A fundamental first step in the implementation of an EMS is establishing the objectives and scope of the EMS. Management typically assigns someone to lead the overall effort, referred to as the EMS Coordinator in this guide. The EMS Coordinator is responsible for developing the overall plan, presenting and obtaining necessary approvals from management, and leading the implementation effort. ObjectivesCompanies implement an EMS for different reasons. In all cases, improving the consistency and quality of regulatory compliance and reducing environmental risks are primary objectives. Additional objectives may include
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Figure 1. EMS Implementation Process

1 Plan Project

Start by de ning the scope of your EMS (which activities and organizations) and obtaining management support to proceed. Form a cross-functional team, develop a project plan, and proceed! The policy de nes managements expectations and commitments with respect to environmental management. It helps guide day-to-day and long-term decision making and lays the foundation for implementing the EMS. Aspects are elements of your operations that impact or have the potential to impact the environment (e.g., from air emissions, wastewater discharges, land disturbance, waste generation, natural resource consumption). In this step, an assessment is done to identify which activities and parts of your operations have the potential to create adverse environmental impacts. The identi cation of aspects supports the identi cation of legal requirements (#4) and assessment of controls (#5). Which aspects of your operations are subject to legal or other requirements? Applicable requirements include federal, state, and local laws and regulations, as well as any internal company requirements and other commitments made to stakeholders e.g., Cyanide Code, Global Acid Rock Drainage Guide (GARD Guide), speci c agreements with neighbors or local agencies. Which aspects have the potential to create signi cant impacts? What controls are in place to manage the risks posed by those signi cant environmental aspects? Controls are broadly de ned to include procedures, equipment, training, inspections, sampling and analysis, and other management practices used to ensure compliance and prevent adverse environmental impacts. Based on the assessment of the controls in place to manage the applicable requirements and risks, actions may need to be taken to strengthen environmental management (improved procedures, training, inspections, equipment, etc.). Action plans should be developed and implemented as needed. Once the system is established, the implementation of EMS and resulting performance should be monitored on an ongoing basis. This includes establishing key performance indicators to track performance, conducting compliance and EMS audits, and identifying and reporting non-conformances as they arise (including spills, releases, and other incidents). Corrective and preventive actions should be taken in response to non-conformances as needed. On a periodic basis (commonly annually), top management should review the overall design and effectiveness of the EMS, including setting formal improvement objectives and targets. Action plans to achieve the objectives and targets are developed and incorporated into business plans to ensure their resourcing and implementation.

2 Set Policy Set Policy

Initial Implementation

Identify Environmental Aspects and Impacts

4 Identify Applicable Environmental Requirements

Assess Environmental Aspects, Impacts, and Existing Operational Controls

Improve Improve Operational Controls

Continual Improvement

7 Monitor Programs and Assess Performance

Conduct Management Review and Establish Improvement Plan

Reducing environmental impacts (i.e., preventing pollution, reducing consumption of and protecting natural resources); Obtaining third-party certification to ISO 14001; and/or Improving a companys reputation with external stakeholders. These objectives will impact your implementation approach. Since the primary goal is improving compliance, companies will need to take a rigorous approach in documenting applicable legal requirements and developing compliance calendars as well as inspection and audit programs. However, if reducing your environmental impact is an important objective, you will also need to focus on establishing programs to monitor and measure the impacts and take actions to reduce those impacts. If your objective is to obtain ISO 14001 certification, your company will need to concentrate more on the documented part of its program, since that is what the registrars will focus on. And if an objective 6
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is improving your companys reputation with external stakeholders, external communications and outreach will be an important part of the EMS program. Some operations may have all these objectives in mind when they implement an EMS program. When developing the objectives, consider your organizations overall business climate and core business objectives. How can this EMS initiative create value for the company? How can it help your company achieve its business goals? Aligning the EMS objectives with the businesss objectives will help build support for the EMS initiative and facilitate implementation. ScopeThe organizational/operational scope defines which specific sites, operations, departments, or process operations the EMS will address. Does the EMS cover only the extraction and beneficiation operations of the mine (i.e., ore extraction, leaching, crushing and grinding, flotation, electrowinning, and waste rock and tailings management)? Is there a need to include downstream activities such as smelting and refining? Should the EMS cover the upstream activities such as exploration and development? When dealing with an individual site, it is common for the EMS to address all on-site operations rather than parsing out specific parts of the mine and process. There is no right or wrong way to characterize the organizational/operational scope, but it must be defined. In fact, the very first clause of the ISO 14001 specification (Section 4.1) requires that the organization define and document the scope of its EMS. For the purposes of this EMS guide, the scope is assumed to be solely mining extraction and beneficiation operations as illustrated in Figure 2. ii. Develop a project plan: A good project plan can help ensure the success of any initiative. For an EMS implementation, the project plan should document your objectives, major steps in the process, responsibilities, timeline, and resource requirements (e.g., personnel and financial). The project plan

Figure 2. Generalized Hardrock Mining and Beneficiation Process

Planning and Permitting Power Haulage Stockpiles (Low-Grade Ore, Overburden, and Waste Rock)

Outside EMS Scope (for this Guide)

Metal-Bearing Solution Secondary Products Metal Product

Mining Metals Recovery

Leaching Ore Stockpiles

Metallurgical Waste

Ore Crushing

Maintenance

Grinding

Metals Concentrate

Administration

Concentrating

Tailings

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is useful for communications with key internal staff and for obtaining approval from management for the budget and other resources to support implementation. This guide provides direction regarding the steps in the process and typical roles. The timeline will vary depending on the urgency and level of resources committed (considering both internal staff and consultants). An EMS can typically be implemented over a six-to-nine-month period. The level of resources required will vary primarily based on the extent and quality of existing environmental programs and systems. Experience has shown that the full-time equivalent (FTE) effort to implement an EMS is typically in the range of 0.5 to 1.0 FTE (~100200 person-days, internal and external resources) for a medium-sized operation that has little in the way of formally defined systems. iii. Obtain management support: It is critical to obtain top managements explicit support for EMS implementation during the initial planning phase, as they need to provide strategic direction and can help facilitate key actions, including formation of the team and allocation of resources. Given the typical complexity and level of activities at an operating mine, top management support is critical for ensuring the EMS initiative gets adequate priority in light of constrained budgets and competing initiatives. iv. Form a team: Two key parts of the team are typical: (1) an EMS Coordinator (sometimes termed the Management Representative); and (2) an EMS Task Force or implementation team. The EMS Coordinator will have lead responsibility for planning and managing EMS implementation. This includes developing the project plan, forming and leading the task force, monitoring execution of the project plan and individual EMS tasks, and reporting to management on EMS implementation progress. The EMS Coordinator should be an experienced project manager who has adequate authority and credibility with management and staff to carry out the role. A task force should be formed to help plan and implement the EMS. The team can help ensure the quality of the implementation by ensuring that the perspectives of all relevant departments are factored into the implementation process. Participation in the team also helps build buy-in through staff members direct involvement in managing the project and carrying out specific tasks. Team members should be assigned from all of the major departments, including operations, maintenance, engineering, shipping/receiving, facilities, and so forth, and should have detailed process knowledge of their respective area. Other departments that may participate in the team include health and safety, procurement, human resources, and external/community affairs. An example charter and kickoff meeting agenda is shown in Figure 3.

B. Set Policy
What and Why
The environmental policy states an organizations overall environmental commitments and guides the actions of employees and top management. The policy also represents a commitment to employees, the community, customers, and other stakeholders.

How and Who

i. Develop a policy: The policy is typically drafted by the EMS Coordinator in collaboration with the EMS Task Force for approval by senior management. However, the policy can also be drafted directly by senior site management, as it reflects their direction and expectations for environmental programs and performance. Other management and staff at the mine will be held accountable for acting in a manner consistent with those expectations. A simple, generic example of an environmental policy is shown in Figure 4. Most environmental policies are one page in length. At a minimum, they should 8
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Figure 3. Example of an EMS Task Force Charter and Kickoff Meeting Agenda
EMS TASK FORCE CHARTER Purpose: To implement an effective environmental management system (EMS) that supports the achievement of our business goals, meets ISO 14001 [if applicable], and drives continual improvement in environmental performance. Membership: The EMS Task Force includes representatives from each of the operating areas at the site, as well as key support functions such as procurement, human resources, safety and occupational health, and engineering. Member Roles: The EMS Task Force members are expected to provide their perspectives on and constructively contribute to EMS planning and implementation, including the aspect assessment, establishment of operational controls, training, and setting of objectives and targets. They should also be visibly supportive of the initiative, particularly, bringing back messages to their departments. Meeting Frequency: The EMS Task Force will meet monthly, with additional meetings scheduled as needed during critical times throughout the implementation. EMS TASK FORCE KICKOFF MEETING AGENGA Project overview, scope, and objectives Draft work plan Team charter and team member roles Detailed project planning EMS model Gap analysis Existing systems to leverage Legal registry Aspects and impacts Project management Wrap-up Agreements Short-term next steps Next meeting

include clear commitments to (1) compliance with applicable legal requirements and any other requirements or commitments made (e.g., Cyanide Code and GARD Guide); (2) prevention of pollution; and (3) continual improvement of environmental programs and performance. ii. Issue the policy: Senior management is responsible for issuing the policy and ensuring its implementation. The policy should be effectively communicated to all employees, as well as others working on behalf of the organization (e.g., contractors working on-site). Approaches for rolling out and communicating the policy internally include in-person briefings at staff meetings and other ongoing meeting venues, e-mail notification, posting on electronic and physical bulletin boards, and articles in company newsletters. Many companies reinforce the policy by including it in refresher training and other ongoing communications. The policy is commonly incorporated into new employee orientation training. The policy should also be made available to external stakeholders, either on request or by posting it on the companys Internet site.

C. Identify Environmental Aspects and Impacts

What and Why
Environmental aspects are the elements of your facilitys activities that can impact environmental performance, that is, impact the environment or regulatory compliance status. By identifying your environmental aspects, you identify what activities and associated impacts need to be controlled to achieve your environmental performance objectives. More significant aspects require more significant controls, helping to manage environmental risk.

How and Who

The EMS Task Force should take the lead in identifying your environmental aspects and associated impacts. Consider the following recommended steps:

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Figure 4. Example of an Environmental Policy

ABC Environmental Policy At ABC, we believe good environmental performance is fundamental to our business success. We are committed to the following: Compliance with applicable legal requirements Prevention of pollution, with an emphasis on source reduction and managing long-term risks Reduction in the use of natural resources, including through energy and water conservation Implementation of formal management systems to drive consistent and continually improving programs and performance Communication with internal and external stakeholders regarding our environmental programs and performance All employees are responsible for understanding this policy and incorporating its intent into day-to-day activities and decision making.

i. List or map out activities: The first step is to identify the activities and operations that are within the scope of your management system. This typically includes core production activities such as mining, ore crushing and grinding, leaching, metals recovery, concentrating, and tailings management, as well as supporting activities such as permitting and planning, conveyance, maintenance, and construction. Refer to Figure 2 for a simplified schematic of a typical hardrock mines operations. ii. Determine aspects and impacts associated with the activities: Next, identify all of the environmental aspects associated with those activities and operations and the actual and potential impacts they can have on the environment. Refer to the example in Figure 5. As previously mentioned, this activity should be carried out with the input of the cross-functional task force, ensuring that a complete view of your operations has been considered and that no relevant aspects are missed.

D. Identify Applicable Environmental Requirements

What and Why
Since reliable and consistent regulatory compliance is a primary objective of the EMS, staying current on applicable environmental requirements and ensuring specific tasks to achieve compliance with those requirements are defined and communicated to relevant staff is core to the EMS. Applicable requirements include both legal requirements and other commitments made to stakeholders. Legal requirements include those coming from federal, state, and local regulatory agencies. They could include requirements from permits, regulations, laws, ordinances, and any enforcement agreements. They can also cover topics such as monitoring and reporting, training, inspections, maintenance, and other activities. Some of the requirements may recur on a regular basis (e.g., annual training, monthly reporting, and daily sampling), and others may be triggered by an event or activity (e.g., reporting spills, maintaining manifests when shipping hazardous wastes). Non-compliance could result in significant fines, additional regulatory scrutiny, and negative media coverage depending on the nature and severity of the non-compliance. If severe, regulatory non-compliance can directly affect your license to operate.

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Figure 5. Typical Environmental Aspects and Potential Impacts for a Mining and Beneficiation Operation
Activity/Operation Environmental Aspects Land disturbance Land disturbance Planning and Permitting Land disturbance Land disturbanceReclamation and closure Stormwater runoff Greenhouse gas (GHG)/combustion byproducts from equipment Water and wastewater disposition from mine dewatering and/or mine water disposal Mining Water use in drilling Land disturbance Fugitive dust emissions (blasting, loading) Blasting: noise and vibration Blasting: waste explosives packaging materials Fugitive dust emissions (transfer locations, road traffic, dumping) Anti-tampering devices on large off-road vehicles Truck hitting wildlife Noise GHG/combustion byproducts from mobile sources Infiltration and stormwater runoff Stockpiles (Ore, Low-Grade Ore, Overburden) Slope stability Ore stockpile: fugitive dust emissions (dumping, wind erosion) Crushing: fugitive dust emissions Ore Crushing Environmental Impacts Disturbances of floodways and river ways Potential degradation of sensitive areas: archeological, cultural, aquatic, terrestrial; threatened and endangered species Property boundaries, stockpile height restrictions, visual impacts Terrestrial habitat (flora and fauna) and aquatic habitat recovery; mitigating impacts to surface aquatic habitat and groundwater Acid rock, alkaline, or saline drainage impact on soil, surface water, and groundwater Deposition of particulates, climate change, acid rain, air quality degradation Surface or underground miningWater table reduction/ depletion: acid rock, alkaline, or saline drainage impact on soil, surface water, and groundwater degradation Water usage in drilling operations Cutting new haul roads, mine portal or surface mine development, haul road development: potential disturbance of terrestrial and/or aquatic habitat Deposition of particulates, air quality degradation Nuisance to neighbors and fauna Potential fire or explosive hazard, potential release to water or soils Deposition of particulates, air quality degradation Deposition of particulates, air quality degradation Fauna Noise from operation of trucks Deposition of particulates, climate change, acid rain, air quality degradation Acid rock, alkaline, or saline drainage impact on soil, surface water, and groundwater Potential impact to human health and to soil, surface water, and groundwater Deposition of particulates, air quality degradation Deposition of particulates, air quality degradation

Power Haulage

Air pollutant emissions from energy Deposition of particulates, climate change, acid rain, air use (electricity) and equipment quality degradation combustion sources (continues)

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Figure 5. Typical Environmental Aspects and Potential Impacts for a Mining and Beneficiation Operation (continued)
Activity/Operation Environmental Aspects Leachate potential to escape pad containment systems Leach pad slope stability Stormwater runoff from pad Leaching Spills/leakage or waste generation from process chemicals (cyanide, acid, or pregnant leach solution [PLS]) PLS collection and holding ponds PLS collection and holding ponds Process wastewater discharge Spills from tanks or pipes or waste generation from process chemicals mismanagement SX plant volatile organic compound (VOC) Solvent Extraction/ emissions Electrowinning EW tankhouse acid mist emissions (SX/EW) Air pollutant emissions from energy use (electricity) Generation and management of lead flake and lead anodes Spills Grinding Generation of dust Air pollutant emissions from energy use (electricity) Process wastewater disposition Concentrating Spills or waste generation from metallic mineral concentrate mishandling Concentrate storage Flotation reagents: fugitive VOC air emissions Tailings conveyance/pipingspills Fugitive dust emissions Leakage to groundwater Tailings Seepage collection, management, and disposition Stormwater runoff Dam slope stability Pond water quality Maintenance Activities Generation of used tires Generation of used oil and grease Environmental Impacts Groundwater contamination Potential impact to human health and to soil, surface water, and groundwater Surface water contamination Soil, surface water, and groundwater Groundwater and/or surface water contamination Wildlife Soil, surface water, groundwater, air emissions Soil, surface water, groundwater, air emissions Air quality Air quality Deposition of particulates, climate change, acid rain, air quality degradation Potential impact on soil, surface water, and groundwater Potential impact on surface water and groundwater Air quality Deposition of particulates, climate change, acid rain, air quality degradation, mercury volatilization Soil, surface water, and groundwater Acid rock drainage and metals leaching impact on soil, surface water, and groundwater Potential migration from wind erosion or stormwater Air quality Potential impact on surface water and groundwater Deposition of particulates, air quality degradation Degradation of groundwater quality Degradation of surface water and groundwater quality Surface water contamination Potential impact to human health and to soil, surface water, and groundwater Wildlife through ingestion and/or contact Waste disposal/land use Waste disposal (continues)

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Figure 5. Typical Environmental Aspects and Potential Impacts for a Mining and Beneficiation Operation (continued)
Activity/Operation Environmental Aspects Generation of used lead acid batteries Parts washer management Polychlorinated biphenyls (PCBs) equipment Maintenance Activities (continued) Spray painting Impacted stormwater runoff (maintenance areas) Wastewater generation (wash racks, oilwater separators, sewage treatment systems, wastewater treatment systems) Chemical management/inventory Waste disposal Waste disposal and potential air emissions Potential impact to human health and to soil, surface water, and groundwater Air quality Surface water contamination Environmental Impacts

Soil, surface water, and groundwater Potential impact to human health (spills, fire, explosion); waste disposal

Generation of potentially hazardous Waste disposal wastes (e.g., aerosol cans, paint) Fuel storage/dispensing Drinking water supply (water quality) Contact stormwater ponds Non-contact stormwater runoff Asbestos-containing materials Equipment storage/laydown yards potential leakage (ozone-depleting substances, PCBs, oil, and grease) Building demolition Housekeeping Waste disposal (proper segregation of wastes and management of landfills) Waste managementoff-site recycling Petroleum-contaminated soils management Open burning Legacy environmental issues Water usage Office and food waste generation and disposal Office/Administration Resource use (paper, plastic, toner, etc.) Air pollutant emissions from energy use (electricity) and HVAC sources Spills and leakspotential impact to soil, surface water, and groundwater Human health Soil, surface water, and groundwater Potential impact on soil, surface water, and groundwater Potential impact to human health; waste disposal Potential impact on soil, surface water, and groundwater Waste disposal Visual impacts, potential impacts to groundwater Potential impact to human health and groundwater Waste disposal Waste disposal Air quality degradation Surface water/groundwater contamination Depletion of natural resources/exceed allowable water withdrawals Soil, surface water, groundwater, nuisance litter, vector (rodent) management Reduction in non-renewable resources Deposition of particulates, climate change, acid rain, air quality degradation

Sitewide

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 Other commitments to stakeholders could include agreements with neighbors, industry associations (e.g., Cyanide Code and GARD Guide), or local emergency planning and response organizations, as well as self-imposed corporate or site requirements (e.g., banning the use of chlorinated solvents).

How and Who

Typically, the site environmental department is responsible for identifying all legal and other requirements. The process consists of developing an inventory or register of all environmental permits, regulations, commitments, and so on, and then defining all of the individual compliance tasks associated with these requirements. These tasks can then be put into a compliance calendar or other management tool that can be used to manage compliance on a day-to-day basis. i. Create and maintain a register of requirements: Applicable legal and other requirements (as previously described) should be documented in a register or similar document. The intent is not to restate the Code of Federal Regulations, but rather to ensure that the key laws and regulations that apply (in addition to the other commitments) are explicitly identified. Appendix 2 provides an overview of the major federal laws and regulations that may apply to a typical hardrock mining and beneficiation operation. However, this must be an ongoing process, as legal requirements change over time. This can be achieved by subscribing to newsletters, contracting with third-party services, monitoring agency Websites, and so on. Note: Refer to the environmental aspects identified in the previous step to confirm that you have considered any regulations pertaining to those activities and aspects. ii. Create and maintain a compliance calendar: The applicable requirements should then be translated into specific actions assigned and communicated to specific individuals and managed through a compliance calendar or similar tool. An example tool is shown in Figure 6. Increasingly, companies are using information technology to manage the compliance calendar, whether it be a simple spreadsheet or database, or part of a larger enterprise EMIS (environmental management information system) application. Regardless of the tool used, compliance-related actions should be defined, assigned, communicated, and tracked through closure. Companies starting new mining projects may also want to meet with local and state regulators early in the process to identify the staff members who will be involved in permitting the project, to understand the sequence of permitting activities, to learn the specifics of what may be required beyond what is provided in the regulations, and to determine how various agencies work together.

E. Assess Environmental Aspects, Impacts, and Existing Operational Controls

What and Why
In Section 3.C of this EMS Guide, a comprehensive list of activities and aspects that can impact environmental performance was developed. In Section 3.D, applicable legal and other requirements were identified. In this step, the environmental aspects are assessed to determine which aspects are significant and warrant formal operational controls to ensure regulatory compliance, prevent adverse impacts, and manage risk. A two-step process is used: 1. Assess the relative significance of the aspects based on actual or potential impacts. 2. Determine the residual risk associated with each of the significant aspects based on the operational controls currently in place to manage them. This will help to identify where improvements to controls may be needed.

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Figure 6. Example of a Compliance Calendar

Topic/Action Discharge Monitoring Report (DMR) Wastewater sampling per NPDES permit Wastewater sampling per NPDES permit NPDES Permit Fee Etc. Atmospheric Emissions Annual Emissions Statement Semi-Annual Certification Fuel consumed (6 regulated combustion units) Annual Emissions Fee Fugitive emissions visual inspections Etc. Containment Area Inspection for Rain Bulk Storage Container Inspections Five-Year Plan Renewal SPCC Training (Oil Briefing) Etc. Visual inspections during rainfall event Collection of stormwater samples (for TSS) DMR required for quarterly sampling results Annual Comprehensive Facility Audit Etc. Tier II Reporting (SARA 312) Form R Reporting (SARA 313) Etc. ICP = Integrated Contingency Plan LEPC = Local Emergency Planning Committee NPDES = National Pollutant Discharge Elimination System SARA = Superfund Amendments and Reauthorization Act of 1986 SPCC = Spill Prevention, Control, and Countermeasure TSS = total suspended solids A = annually; D = daily; M = monthly; Q = quarterly; S = semi-annually; W = weekly. Start at least one month before due date Log book to be completed Should receive invoice from State Must complete inspection form Sue S. Sue S. Sue S. Tanya R. Sue S. D D D D 31st D D D D D A D D D D D D D D D 1st 31st D D D D D D Comments Monthly, by 28th of following month Monthly requirement See permit for analyses $8,700 payable to State of Nevada Owner Jan Wastewater Bill J. Bill J. Bill J. Tanya R. M M S Timing Feb Mar Apr May Jun Jul M M M M M M M M M M M M S 1st Aug Sep Oct Nov Dec M M M M M M M M M M

Spills (SPCC, ICP) Document when precipitaBill J. W tion is drained Use designated inspection Bill J. M form Next due by April 2011 Bill J. Only oil-handling employees Bill J. Stormwater Can be any point in each quarter Must be a qualifying rain event March 31 of year following monitoring period Not submittedfiled on-site Bill J. Bill J. Bill J. Bill J. 31st

W M

W M

W M

W M

W M

W M A

W M

W M

W M

W M

W M

Q A 31st

31st A

31st

Emergency Planning and Community Right-to-Know Act (EPCRA) Submit to State, LEPC, and Tom N. 1st local fire department Start at least one month Tom N. before due date

1st

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Figure 7. Conceptual Model for Assessing Aspects and Risk

High

Signi cance of Potential Impact (Inherent Risk)

RE

SI

A DU

S RI

Low Strong

Controls in Place

Weak

This process is illustrated in Figure 7 and described in more detail, with specific examples, in the text that follows.

How and Who

The EMS Task Force is responsible for developing the list of significant aspects and assessing the adequacy of controls in place to manage them. Many ways can be used to determine significance, but whatever approach is selected, you need to document the process so it can be repeated consistently. The objective is to review all the aspects in a methodical, common-sense way to determine what aspects are critical to environmental performance (regulatory compliance and control of environmental risks/impacts) and therefore need to be managed and/or controlled to ensure that you are achieving your objectives consistent with the environmental policy. An example of a proposed process is described here, consistent with the conceptual model shown in Figure 7. i. Assess the relative significance of your environmental aspects: A range of tools are available for making this determination, including detailed quantitative risk assessment methodologies. However, simpler and less data-intensive approaches can be used. For example, using the table shown in Figure 8, rate each aspect based on (1) its potential impacts to people and the environment (in both the short and long term); (2) whether it is regulated and the level of regulatory scrutiny; and (3) other potential business impacts (e.g., damage to reputation, creation of financial liability). A simple 0, 1, 2, and 3 or low/medium/high scoring system can be used. Figure 8a describes the scoring scheme used in this specific example. Figure 8 focuses on the mining operations only. See Appendix 3 for a more complete tool that assesses significant environmental aspects for mining and beneficiation operations. When rating the aspects, consider the impacts assuming that any existing controls are not in place or are not effectivethis allows you to determine the inherent risk associated with the aspect, its potential to create adverse impacts, and the need for formal operational controls. The adequacy of existing controls will be factored in during the next step. Please note that this tool is just that, a tool. It is important to apply common sense and professional judgment to this process and not let the tool constrain you. Other approaches can also be used. 16
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Figure 8. Tool for Assessing the Significance of Environmental AspectsExample for Mining Operations Only
(See Appendix 3 for a complete example that addresses all aspects in Figure 5.) Significance Ratings Activity/ Operation Environmental Aspects (from Figure 5) Stormwater runoff Greenhouse gas (GHG)/ combustion byproducts from equipment Water and wastewater disposition from mine dewatering and/or mine water disposal Mining Water use in drilling Land disturbance Fugitive dust emissions (blasting, loading) Blasting: noise and vibration Environmental Impacts (from Figure 5) Acid rock, alkaline, or saline drainage impact on soil, surface water, and groundwater Deposition of particulates, climate change, acid rain, air quality degradation People and the Environment Compliance 2 3 Other Business Significant Impacts Total* [Y/N] 2 7 Y

Surface or underground miningWater table reduction/ depletion: acid rock, alkaline, or saline drainage impact on soil, surface water, and groundwater degradation Water usage in drilling operations Cutting new haul roads, mine portal or surface mine development, haul road development: potential disturbance of terrestrial and/or aquatic habitat Deposition of particulates, air quality degradation Nuisance to neighbors and fauna

Blasting: waste Potential fire or explosive hazard, explosives packaging potential release to water or soils materials

*The total significance score is the sum of the three individual significance ratings. Guidance for scoring is described in Figure 8a. For the purposes of this example, any aspect with a score of 6 or higher is deemed significant aspect.

ii. Assess the controls in place to manage the aspects and identify opportunities to improve them: All significant aspects need to have formal controls to ensure they are properly managed. In this step, controls are assessed to ensure acceptable environmental performance outcomes and to identify opportunities to improve consistency/robustness of controls (which can be incorporated into the action plan described later in Section 3.F). The process includes documenting the controls in place and assessing their adequacy. Controls are broadly defined to include administrative controls such as standard operating procedures, training, inspections, preventive maintenance programs, monitoring and measurement activities, emergency plans, and document/records management, as well as engineered controls such as pollution control equipment, containment structures, alarm systems, and so on. Refer to
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Figure 8a. Significance Rating Scoring Guidance for Figure 8

Rating 0 Potential Impacts to People and the Environment No measurable effect on people (those working on-site or neighbors/other stakeholders) and/or the environment. Potential for localized and limited effect that is quickly reversed. Environmental: Limited impacts to the environment that have limited and relatively quickly reversible effects. Health & Safety: Minor employee or neighbor illness or injury; would not likely result in any significant lost time. Potential for more widespread and significant impact that is not quickly or easily reversed. Environmental: Off-site environmental impacts that are not quickly or easily reversed. Health & Safety: Lost-time injuries or credible third-party health claims. Potential for very serious and sustained damage. Environmental: Sustained or catastrophic impacts causing widespread and irreversible environmental damage. Health & Safety: Potential for fatalities among employees and/or neighbors. Compliance Not regulated, no potential for non-compliance. Other Potential Impacts to the Business (e.g., cost, reputation) No cost impact. No effect on reputation.

Not regulated, no potential for non-compliance.

Cost impact, but not material or disruptive to business. Reputation impacts to a few local and relatively low-priority stakeholders.

Material cost impact; minor business loss due to delay, stoppage, or damage to property. Regulated, potential for non-compliance. Local and national reputation impacts to local and national stakeholders and will likely impact their decision making; causes adverse media attention. Material cost impact; major loss due to delay, stoppage, or damage to property Regulated, potential that will seriously impact business results. for non-compliance, Serious damage to reputation of local, a focus area for national, and international stakeholders; regulators. directly impacts license to operate and commercial performance; causes adverse international media attention.

Figure9, which ties-in with Figure 8. As with the significance ratings, this can be done in a qualitative or quantitative fashion. Note that in Figure 9, this analysis is only done for the significant aspectsthe others are shown as not applicable (NA). Over time, this same analysis can be applied to all of the aspects, but it is important to start with the significant ones, since they have the greatest inherent risk and should have the most robust controls in place. As with the aspect assessment process and tool shown in Figure 8, common sense and professional judgment should be applied in the use of the process and tool for the assessment of controls and residual risk illustrated in Figure 9. Consider the following guidance on each type of control, recognizing that the effective management of environmental compliance, impact, and risk will likely require combinations of most of these types of controls. a. Procedures: Formal procedures should be in place to manage the significant environmental aspects. These need not be discrete procedures for the aspect itself. They may take the form of standard operating procedures and work instructions for specific equipment, activities, or process operations 18
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Figure 9. Tool for Assessing Controls and Residual RiskExample for Mining OperationsOnly
(See Appendix 4 for a complete example that addresses all aspects in Figure 5.) Significant Aspects Activity/ Operation Environmental Aspects Score Y/N Controls in Place Stormwater Pollution Prevention Plan (SWPPP), potentially acid generating (PAG) waste containment cells, diversion ditches, collection ponds, stormwater reuse, training, procedures, excess water treatment, stormwater discharge permit Controls Rating* Residual Risk Improvement Actions Annual review and update of SWPPP along with monitoring results to drive improvements to applicable engineering and administrative controls.

Stormwater runoff

3.5

Greenhouse gas (GHG)/combustion byproducts from equipment Water and wastewater disposition from mine dewatering and/or mine water disposal Water use in drilling Land disturbance Fugitive dust emissions (blasting, loading) Blasting: noise and vibration Blasting: waste explosives packaging materials

NA

NA

NA

NA

Mining

Dewater water reuse, excess water treatment, water discharge permit, water quality monitoring NA NA Dust mitigation plan, including water truck spraying, chemical suppressants, no blasting in strong winds, air monitoring at facility perimeter NA NA

Develop and maintain a water use/reuse program and treatment of excess dewater and/or process water as required. NA NA

3 5

N N

NA NA

NA NA

Develop and maintain a Fugitive Dust Plan.

5 4

N N

NA NA

NA NA

NA NA

* The controls rating scheme is described in Figure 9a. In this example tool, the residual risk score is the significance (inherent risk) score divided by the controls score.

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Figure 9a. Controls Rating Scoring Guidance for Figure 9

Rating Quality and Effectiveness of Controls No controls in place. No engineered controls in place (such as containment devices, spill response equipment, tank leak detection, etc.). People not aware of or trained to manage aspects, no procedures, etc. History of non-compliance and frequent incidents or near misses. Some administrative and engineered controls in place; however, extent is limited (e.g., there are no redundant controls) and they are not consistently maintained or applied. Some engineered controls in place. Awareness of aspects, some simple procedures (inconsistently applied), basic training of employees. Limited control of pollution and higher ratio of resource consumption and waste given work activity level than rest of company/industry. Incident history (including near misses), inspection/audit results, or stakeholder actions demonstrate shortcomings in performance. Administrative and engineered controls in place and are generally effective. A single failure in a control unlikely to lead to an incident. Procedures, pollution control equipment, technology, prevention plans, and monitoring in place. Good awareness, procedures defined and generally followed for all hazards, advanced training for employees and contractors. However, incident history (including near misses), inspection/audit results, or stakeholder actions indicate some ongoing exposures and modest gaps in performance. Engineered controls in place and well-maintained, well-established standard operating procedures, high level of awareness among employees and contractors. Best available technology to physically prevent adverse impacts, frequent monitoring, programs/investments in eco-efficiency or industrial ecology to minimize resource consumption and waste. Excellent training programs in place for employees and contractors, strong evidence of an environmental culture among employees and contractors, rigorous application of comprehensive and welldefined procedures. Sustained history of demonstrated control based on lack of incidents and near misses.

in which the environmental aspects are explicitly addressed. In addition, procedures should be in place to address management of change, ensuring potential environmental issues (compliance, impact, risk) are factored into new projects and operational changes. Employees, contractors, and visitors should be trained in relevant procedures. Procedures should be periodically reviewed and updated as needed. b. Engineered controls: Engineered controls include pollution control equipment such as baghouses, electrostatic precipitators, and water and wastewater treatment equipment, as well as containment structures for fuel and chemical storage, and drainage systems to control the flow of stormwater. Engineered controls need to be properly operated and maintained to remain effective and should be incorporated into a mine and beneficiation plants preventive maintenance program. c. Training: Employees, contractors, and visitors whose activities have the potential to impact environmental performance must be competent to carry out their assigned roles (e.g., as defined in procedures, job descriptions) based on experience, education, or training. Many organizations develop a training requirements matrix to define who needs what type of training. This is most commonly done on a position-by-position basis. An example of a training requirements matrix is shown in Figure 10. Training needs can be met through classroom training, toolbox talks, computer-based training, or other means as appropriate.

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Figure 10. Example of a Training Needs Assessment

Lab Technicians Environmental Staff Contractor Management x x x x x x NA NA NA NA NA NA NA x NA Mine Maintenance Process Maintenance

Warehouse

Processing Operations

Miners

Course/Topic Spills Management Regulatory Wastewater Management Emergency Response Training Waste Management Department of Transportation Etc. General Contractor EMS Awareness Employee EMS Awareness Etc. Tailings Management Wastewater Outfall Management Mining, Milling/Processing Job-Specific Fugitive Dust Control Plan Process Water Management Stormwater Management Chemical & Waste Management Wildlife Protection Etc.

Frequency/Timing Annual Annual Annual Annual 3 years Annual Initial+ Initial+ Initial+ Initial+ Initial+ Initial+ Initial+ Initial+ Initial+ 1Q 1Q 1Q 1Q 1Q 1Q NA 3Q 4Q 4Q 3Q 1Q 2Q 2Q 4Q

x x x x x x x x x x x x x x x

x x x x x x x x x x x x x x x

x x x x x x x x x x x x x x x

x x x x NA x x x x x x x NA x x

x x x x NA x x NA x x x x NA x x

x x x x x NA x NA NA NA x NA NA x x

x x x x NA NA x NA NA x x x NA x x

d. Monitoring and measurement: Monitoring and measurement activities can include physical sampling and analysis of emissions, discharges, and other waste streams; process control systems that monitor and control key operational parameters; and visual observations of work activities/operations. Many environmental permits specify sampling and analysis requirements, including the streams that should be sampled, frequency of sampling, sampling technique (e.g., grab, composite), constituents to sample for (acid-base account, metals, pH, acidity, weak and dissociable cyanides, etc.), analytical techniques to use (ASTM standards, GARD Guide, etc.), equipment calibration, and agency reporting requirements. Chain-of-custody procedures should be in place for quality assurance. Routine sampling, equipment calibration, and reporting activities should be incorporated into the compliance calendar discussed in Section 3.D. Many companies establish key performance indicators to measure and track performance in key areas, based on the results of the aspect assessment. These can include measurements of environmental impacts (e.g., energy use, water use, wastewater discharges, and waste generation and disposal on an absolute or productionadjusted basis) and compliance performance (e.g.,completion of compliance calendar activities, reportable spills/releases). Audits are also an important tool in monitoring EMS implementation, compliance, and performance. A formal audit plan should be developed to ensure that all areas of the site and EMS are audited with special emphasis on the areas with higher risk. Finally, routine inspections can be used to monitor operations on a day-to-day basis. Common topics/areas to
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Etc.

address during inspections include waste storage, potentially leaking equipment, visible emissions, slope stability and berm integrity, discoloration of emissions/discharges, and soil and vegetation that might indicate malfunctioning equipment or other problems with operations. e. Emergency response: Plans should be in place to anticipate and respond to emergencies. Plans should address an appropriate range of emergency scenarios, including unplanned and uncontrolled releases (e.g., spills) resulting from accidents, equipment failure, and so forth. Consider the results of the aspect assessment when defining the types of scenarios that should be addressed in the emergency plans (e.g., fuel spill, cyanide or tailings spill, pollution control device failure). Where possible, integrate various environmental-related emergency response plans (ERPs) into one integrated plan (e.g., Spill Prevention Control and Countermeasure Plan, Stormwater Pollution Prevention Plan). All employees should be trained on the basics of the emergency plans and their roles in responding to an emergency. Those with special roles (e.g., first responders, incident commanders) will require special training. The plans should be tested on a regular basis to ensure that equipment is properly deployed and functional and that everyone is aware and competent to carry out their assigned roles in the event of an emergency. Emergency plans should be modified based on the results of those tests and lessons learned from plan deployment in the event of an actual emergency. A table of contents for a typical ERP is shown in Figure 11. f. Documentation and recordkeeping: Documentation of key processes and procedures provides important reference materials and the basis for training activities. Documents need to be controlled to ensure they are reviewed and updated as needed and that only current versions are being used. Records retention is particularly important for regulatory compliance. Some regulations specify records retention requirements. Having ready access to records allows you to easily demonstrate compliance during agency visits. Good records retention practices also allow you to analyze past performance and manage the EMS on an ongoing basis. A listing of typical documents and records that are commonly part of a mines EMS (and that require document control and maintenance) is shown in Figure 12. Figure 13 provides an example approach for documenting the controls in place to manage a significant environmental aspect (in this case, wastewater discharges). Appendix 5 provides two additional tables, using a format similar to the example shown in Figure 13, which describe the types of controls that could be put in place to manage stormwater runoff and fugitive dust emissions from hardrock mining operations. These aspects were identified in Figure 8 as being significant for mining operations. These tables may also prove helpful in assessing your controls and identifying opportunities to improve them, mitigating environmental risk (per the process illustrated in Figure9).

F. Improve Operational Controls

What and Why
Based on the identification of significant environmental aspects (Section 3.C) and applicable legal and other requirements (Section 3.D), and the assessment of controls in place to manage them (Section 3.E), actions should be taken to improve the controls as needed to ensure regulatory compliance and effective management of impacts and risk. It is not uncommon for sites to determine that formal controls do not exist for some of the risks or that they are missing important supporting processes (e.g., document control for procedures; environmental review of operational changes; communications of critical information across shifts, departments, and organizational levels).

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Figure 11. Example of a Table of Contents for an Emergency Response Plan

1.0 Introduction 1.1 Scope/Purpose 1.2 Elements and Format of the ERP 1.2.1 Core Plan 1.2.2 ERP Manual 1.2.3 Appendices 1.3 Requirements Summary 1.3.1 Regulatory Requirements 1.3.2 Internal Requirements 1.3.3 Plan Review and Modification 1.3.4 Plan Distribution 2.0 Hazard Recognition and Risk Assessment 2.1 Facility Information 2.1.1 Facility Description 2.1.2 Material/Waste Inventory 2.1.3 Spill History 2.2 Operational Risks 2.2.1 Facility-wide Risks 2.2.2 Specific Process/Equipment Risks 2.2.3 Potential Off-site Hazards 2.3 Worst Case, Most Likely Scenarios 3.0 Emergency Response Management System 3.1 Organization 3.1.1 Roles and Responsibilities 3.1.2 Response Command Center Security Notification Procedures Communication and Alarm Systems Material Compatibility Preventive Maintenance Program 3.6.1 Specific Process/Equipment 3.6.2 General Process/Facilities 3.7 Housekeeping Program 3.8 Inspection Program 3.9 Emergency Response Equipment 3.10 Employee Training Program, Drills 3.11 Decontamination and Recovery 3.12 Agreements with Outside Responders 4.0 Incident-Specific Response Procedures 4.1 Incident Identification and Assessment 4.2 Health and Medical Emergencies 4.3 Evacuation and Sheltering in Place 4.4 Utility and Support Emergency Systems 4.5 Fire and Explosion 4.6 Hazardous Material Spills or Releases 4.7 Radioactive Spills or Releases 4.8 Security Incidents 4.9 Weather Emergency 4.10 Community Emergencies 4.11 Vehicle Accidents 3.2 3.3 3.4 3.5 3.6

This element focuses on developing and implementing an action plan to improve the controls in place to ensure effective environmental management.

How and Who

i. Develop an action plan: Led by the EMS Task Force and based on the assessment of controls, specific improvement actions should be formalized into a plan for approval by management to ensure resourcing and follow-through. An example of a formal action plan can be found in Figure 14. Key elements of the plan include the following. Action: Describe the action in adequate detail so that a third party not involved in plan development could understand it. Who: Each action should be clearly assigned to an individual (not just a department) with lead responsibility for implementing it. Resources required: Define the level of effort needed to carry out the action, including person-days of internal effort, external consulting support, and capital requirements. Timing: Establish a time frame for each action. Actions may need to be staggered based on priorities, dependencies, the overall capacity of the organization to absorb change (i.e., you may not be able to do everything at once without overwhelming people given their existing day-to-day operational responsibilities), and other considerations (e.g., cash flow/capital constraints).

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Figure 12. Example of EMS Documents and Records to Maintain and Control
Environmental Management Systems Environmental policy and records demonstrating its dissemination Emergency management systems manual Environmental aspects assessment process and results Objectives, targets, and improvement plan and status reports Inspection and audit reports Incident (and investigation) reports Corrective and preventive action plans and status reports Management review documentation Employee and contractor training records Standard operating procedures Change management reviews Preventive maintenance records Piping and instrumentation diagrams Internal and external communications Emergency planning and response plans and documentation of training and drills Air Emissions Air permits, applications, and emissions inventories Equipment operation and maintenance (O&M) and calibration records Boiler operator training certifications Refrigerant technician training certifications Refrigerant management procedures and records Waste Management Hazardous waste manifests Waste analyses test results (metals, static, leaching and kinetic tests for ore, waste rock, and process wastes) Inspection and training records Contingency plans Biennial/annual reports Recycling records for universal waste Used oil, medical waste, and off-spec disposal records Stormwater Notice of intent or no exposure certification Stormwater permit and pollution prevention plan Training and inspection records Monitoring/testing records Piping/drain diagrams Hazardous Chemicals Toxic release inventory (Forms R or A) Hazardous chemical inventories (Tier II) Release/spill reports Oil Operations/Tanks Spill plan/State spill plan Oil discharge reports/notifications Inspection and training records Tank registrations or closure records Underground and aboveground storage tank records Wastewater Discharges Piping/drain diagrams Permit and application from publicly owned treatment works or letter of authorization Sewer ordinance Discharge permit, application, and monitoring reports Exception reports Laboratory certifications Monitoring/testing records Off-site disposal records Operator training certifications Equipment O&M and calibration records Slug prevention plan Septic tank registration and maintenance records Drinking Water/Groundwater Records on water system repairs Maintenance, changes, and analytical records Backflow prevention inspections Groundwater well installation records Groundwater appropriations permit Note: Many companies establish record retention guidelines for specific records.

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Figure 13. Example of Operational Controls for Significant Environmental Aspects

Significant Environmental Aspects Wastewater Discharges from Mining Operations Only Permit non-compliance of water quality standards or discharge flow rates Exceed water quality standards at treated effluent discharge point in river Adverse impact to aquatic ecology in river Operating cost inefficiencies at wastewater treatment plant (WWTP) Standard design and operating procedures Assigned responsibilities Shift change communications Operating logs and corrective actions Critical ranges of vital operating/compliance indicators Calibration protocols for monitoring and measuring devices Inspection and maintenance procedures Integration of WWTP with site operationscommunications procedures

Potential Impacts

Programs, Procedures, Work Instructions

Engineered Controls (hardware)

PLC (programmable logic controller) systemsintegration with operation systems Flow measurement, pH and conductivity adjustment systems, automated samplers, filtration systems, thickeners, and other tank systems, etc. Automated alarms (out of spec) Standard operating procedures (safety, equipment operating tolerances, flow management, change-outs, shift logs, sampling, housekeeping, and preventive maintenance, etc.) Monitoring and reporting procedures and requirements Learning management system (document who gets training and when, including training records management) Of formal compliance requirements (e.g., flow, pH, total suspended solids, key metals, monitoring schedules) Of internal company requirements (if any in addition to compliance requirements) External and internal communications Out-of-spec reporting Operating logs and responses Failure of critical components action plan (including power failure at WWTP) Spills or breaches response plan Non-routine flows or chemical changes, management plan

Training

Monitoring and Measurement Activities

Emergency Planning and Response

Other considerations when developing your action plan: Design the improvement actions to be integrated with existing business/operational processes where practical. Integrating specific EMS improvements into existing processes saves time and money, and usually enhances the quality and effectiveness of implementation. Some common integration opportunities where improved controls can be layered include existing safety programs, standard operating procedures, inspection programs, training programs, communications programs, job descriptions, procurement processes, capital authorization processes, preventive maintenance programs, management dashboards and routine reporting processes, and document control systems. Engage those directly involved in the relevant operational activities in the improvement action. This also improves the quality of the design of the improvement action and helps ensure buy-in to any planned changes.
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Figure 14. Example of an Action Plan Format

Action No. Description Stormwater management of sulfide waste rock stockpile runoff (acid rock drainage water)Develop a collaborative revision (Mining Department and Environmental Department coordinators) to structural controls (sloping and ditching) to ensure gravity flow only of runoff from Main West Stockpile all the way to the mill makeup water pond. Goal is to eliminate need for the stormwater pump station near south toe of the stockpile. Haul-road fugitive dust reductionMining Department to conduct road watering vs. chemical suppressant cost/benefit analysis. Emphasis to include increasing chemical suppressant application just before summer dry season and before winter season (when freeze drying occurs and water application is an icing hazard). Tailings basin fugitive dust reductionMill Department and Environmental Department coordinators to evaluate causes and mitigation options to prevent winter freeze dry fugitive dust (lift off). Test areas should be developed for monitoring during winter season 2009 with goal of full tailings basin mitigation measure being implemented in 2010. Revise Reclamation PlanMining and Environmental Departments will develop enhanced concurrent reclamation to accelerate replacement of wildlife and vegetation habitats. Revise Tailings Management PlanProcess and Environmental Departments to revise plan to significantly reduce fugitive dust on exposed beach area during high wind, dry heat, and freeze dry weather conditions. Consider interim revegetation that can survive pond footprint fluctuation, chemical suppressants, etc. Develop a plan to reuse process and dewatered water Environmental Department to evaluate potential water reuse sources, what equipment is applicable or necessary to ensure water quality, and where reclaimed water can be applied (e.g., dust suppression). Who Resources Internal Days $ Timing Start End

RM

610

10,000 30,000

15 Apr

30 Jul

RM

35

5,000

15 Apr

30 Jun

RM

610

10,000 30,000

15 May

31 Sep

DG

610

10,000 30,000

1 Feb

30 Apr

DG

10

10,000 30,000

1 Jul

15 Oct

RM

2030

10,000 30,000

1 Apr

30 Jun

ii. Obtain management approval: Once the plan has been developed and reviewed with key internal staff, in particular those who have responsibility for leading the implementation of specific actions and others that may be affected by the plan, it should be taken to senior management for approval. This process of obtaining management approval is important to ensure their support of the planned actions and resourcing of them. iii. Monitor plan implementation: The EMS Task Force should monitor implementation of the action plan. Implementation issues can be brought to the attention of senior management as needed.

4. CONTINUAL IMPROVEMENT
Having issued a policy, identified applicable legal requirements, established a compliance calendar, assessed aspects and controls, and taken action to improve controls, initial implementation of the EMS is complete. However, EMS implementation is an ongoing process. Environmental programs and performance should be continually improved based on the results of inspections and audits, environmental monitoring, incidents and ongoing changes in the organization, operations, and overall business climate. 26
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A. Monitor Programs and Assess Performance

What and Why
Implementation of the EMS and resulting performance must be monitored and assessed on an ongoing basis to ensure the controls are being effectively implemented and that resulting performance is consistent with policy expectations (e.g., in compliance with legal and other requirements, ongoing pollution prevention). Corrective actions can then be taken as needed to improve programs and performance. Key information to collect and review to assess performance includes environmental monitoring of specific media; incident data; tracking of key performance indicators; and results from work observations, inspections, and audits.

How and Who

i. Monitor environmental releases and impacts: Regulations and site-specific permits may dictate specific sampling and monitoring activities (e.g., chemical constituents of wastewater or air emissions). These should be covered in the compliance calendar and carried out by assigned staff using appropriate procedures. However, based on the assessment of controls, additional monitoring actions could be implemented (e.g., of flora, fauna). In particular, it is important to monitor impacts associated with the significant environmental aspects and risks. (Refer to the discussion of monitoring and measurement in Section 3.E.ii.d.) ii. Identify and report incidents: Environmental incidents should be identified, reported to management, and addressed to mitigate impacts and risks associated with them and to implement actions to prevent their recurrence. Incidents can be broadly defined to address a range of potential scenarios including spills, unplanned releases, regulatory notices of violation or other non-compliance notification or action, third-party environmental-related damage claim, and so forth. Procedures should be put in place that define what types of incidents should be reported to what levels of management and in what time frame. The procedures should also address the need to conduct incident investigations and take corrective and preventive actions to address the immediate and underlying causes of incidents. iii. Track and report key performance indicators (KPIs): KPIs should be defined, tracked, and reported to management on a routine basis. This allows management to understand and assess performance and take targeted actions to address performance issues as needed. KPIs can include both lagging and leading indicators. Common lagging indicators include water withdrawal and consumption on a production-adjusted basis; energy consumption on a production-adjusted basis; waste sent off-site for disposal on a production-adjusted basis; hectares affected and reclaimed; notices of violation, spills, permit exceedances, and so forth. Leading indicators typically relate to implementation of your management systems and include items such as training completed, inspections/audit completed, preventive maintenance completed, compliance calendar actions completed, and so on. Depending on the specific KPI, they can be packaged monthly, quarterly, or annually into reports for management. Goals can also be set for these metrics, and performance against those goals can be incorporated into the business planning and performance appraisal and incentive compensation processes. iv. Conduct audits: Audits are used to verify that the mine and process is in compliance with applicable legal requirements and that the EMS (and supporting programs and procedures) is being effectively implemented. Audits are formal processes carried out by individuals that are independent of the site being audited (e.g., corporate environmental staff, consultants), ensuring independence and objectivity. Audit activities typically include the following key activities: Pre-audit planningteam formation, development of protocols, coordination with site management, audit team preparation
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 Opening meetingto explain objectives and activities to site management and review the on-site work schedule Verification activitiesthe core substance of the audit, including document/records review, interviews of site staff, and site/work observations Closing meetingto report findings to site management (some auditors conduct daily debriefings with site management to keep them abreast of progress) Report issuancedraft report, site review and comment, final report, distribution to management Corrective action managementdevelopment of corrective and preventive action plans by site, implementation of the plans, including tracking through closure Formal independent regulatory compliance and EMS audits are typically carried out every two or three years, depending on site size, complexity, and overall risk profile. These independent audits are often complemented by more frequent self-audits and routine inspections (refer to Section 3.E.ii.d). Many resources are available to provide guidance on conducting audits, including the U.S. Environmental Protection Agency, the Department of Justice, ISO 19011, the International Cyanide Code, the GARD Guide, and the Auditing Roundtable.

B. Conduct Management Review and Establish Improvement Plan

What and Why
EMS implementation is an ongoing, continual improvement process. This element includes a formal process for top management to review the adequacy and effectiveness of the EMS and the development of objectives and targets to drive improvement in the EMS and resulting environmental performance.

How and Who

i. Management review: An organizations top management should continue to be involved and at least annually conduct a comprehensive review of its performance to evaluate the EMSs continuing suitability, adequacy, and effectiveness. This is a critical part of the continual improvement process and ensures that management stays engaged with the EMS. Inputs to the management review may include Results of audits and evaluations of compliance with applicable legal and other requirements; Environmental performance of the organization (including incidents and progress in achieving objectives and targets, incidents); Status of corrective and preventive actions; Communications from external interested parties, including complaints; and Changing circumstances within the business climate. The management review should be documented and improvement actions agreed and tracked through implementation. An example management review meeting agenda is shown in Figure 15. ii. Objectives, targets, and action plan: Objectives are typically general, qualitative statements about improvement, whereas targets are typically quantifiable and associated with milestones. The setting of objectives and targets should be linked to the assessment of aspects, impacts, and controls described earlier. The objectives and targets should also be aligned with the organizations core business goals, helping to ensure their acceptance across the organization. Formal action plans specifying responsible individuals and timing should be developed to achieve the objectives and targets. The process of setting the objectives and targets should be integrated with the organizations business planning and

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Figure 15. Example of a Management Review Meeting Agenda

Management Review Meeting Agenda Meeting objectives Review of the EMS Stakeholder/business issues Performance Inspections and audits Objectives and targets Other key performance indicators Incidents, events Improvement opportunities EMS Significant aspects/risks New objectives and targets Agreed next steps

budgeting cycle so the resulting plans are adequately resourced and formally approved by management. Refer to the example in Figure 16. The following considerations should be taken into account when developing objectives and targets: Consider improvements to programs as well as performance. Focus on areas that link to the most significant aspects, where performance is lacking, and where cost reductions can be achieved. Ensure you have a solid baseline of performance data prior to establishing targets. Consider setting stretch targets as appropriate to challenge the organization to achieve significant improvements. Involve key internal stakeholders in the process, especially those who may be impacted by or responsible for taking actions to achieve the objectives and targets. Targets can be annual or multi-year. Align objectives and targets with any higher-level ones (e.g., by corporate). Cascade objectives and targets to lower levels of the organization as appropriate (including individual departments; e.g., the mine, the mill).

5. THIRD-PARTY CERTIFICATION
If you are seeking third-party certification to ISO 14001, you will have to successfully pass an audit completed by an accredited ISO 14001 registrar. This is typically a two-stage processfirst, a desk audit is conducted by the registrar to review the EMS design and site readiness (Stage 1), and then a separate on-site review is performed to verify the effectiveness of EMS implementation (Stage 2). This second stage is a more rigorous review and includes interviews with site staff to verify that the EMS is indeed being implemented and achieving the desired results. To maintain certification, sites need to pass periodic (annual or semi-annual) surveillance audits by the accredited registrar. Sites need to go through a recertification process every three years.

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Figure 16. Example of Objectives, Targets, and Action Plan

Objective Associated Target Plan Conduct formal root-cause analysis on every reportable incident. Have management review and approve every action plan. Put actions into site action tracking system (Douglas, ongoing). Revise inspection program per OpEx recommendations (4/10). Implement new EMIS solution (6/10). Conduct energy audits by process unit (Jones, 4/09). Incorporate recommendations into OpEx process (Smith, 8/09). Convert 12% of fleet to hybrid vehicles (Wilkins, 12/09). Increase use of biodiesel by 30% over 2007 levels (Wilkins, 3/10). Define charter (Smith, 3/09). Identify targeted stakeholders (Collins, 5/09). Individually engage targeted stakeholders (Collins, 7/09). Conduct first meeting (9/09). Develop report design outline and plan (Collins, 3/09). Define data elements and definitions (Wilkins, 5/09). Distribute data collection protocol (Wilkins, 7/09). Collect anecdotes and performance data (Collins, 12/09). Develop first draft for management review (Collins, 4/10). Post report on Website (Collins, 6/10).

Improve compliance performance

Reduce reportable incidents by 20% year over year.

Reduce energy use

Reduce energy use per ton of product by 15% by 2010 using 2007 baseline.

Implement Community Advisory Panel by 3Q 2009.

Improve reputation Publish site-specific environmental report by 2Q 2009.

It is recommended that registrars be selected early in the EMS development and implementation process for several reasons. First, registrars often have different philosophies and interpretations of EMS elements (e.g., what can be excluded from the EMS scope, the level of detail in the aspects evaluation, the extent to which the EMS elements must be documented). It is useful to talk through each of the EMS elements with the registrars so that site personnel understand the registrars expectations. Second, some registrars will contract to conduct a pre-assessment to determine whether a site is ready for certification and identify actions that must be taken to close gaps in the EMS. By selecting the registrar early in the process and contracting for a pre-assessment, the site benefits from an official assessment of the EMS by the registrar with time to address any gaps. As an added benefit, in many cases the registrars will treat the pre-assessment as a Stage 1 assessment if the site EMS is sufficiently mature. Finally, selecting the registrar early in the process gives the site more flexibility in scheduling the assessment dates and, therefore, scheduling the pace of implementation. Sites that delay in choosing a registrar often struggle to meet internal registration milestones.

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Appendix 1 Overview of ISO 14001

International standard ISO 14001:2004 from the International Organization for Standardization (ISO) defines an environmental management system (EMS) as Organization structure, responsibilities, practices, procedures, processes, and resources for implementing and maintaining environmental management. ISO 14001 defines an explicit framework for this, which is illustrated in Figure17. It is a flexible, risk-based, plando-check-act continual improvement approach that requires formal documented processes for many of its elements. Underlying this framework, ISO defines specific requirements for each of the 17 EMS elements. A short, userfriendly summary of each of these 17 elements is provided here. These summary descriptions include some interpretation of the standard based on discussions with numerous registrars and the practical implementation experience of industry. More detail on some of these elements is provided throughout this guide. 1. Environmental Policy: Issue and maintain a publicly available environmental policy that commits to compliance, pollution prevention, and continual improvement. 2. Environmental Aspects: Conduct an assessment of environmental aspects and impacts (actual and potential) of the organizations activities, products, and services to determine where formal controls are needed or performance improvements should be made, and to inform goal-setting. 3. Legal and Other Requirements: Identify, have access to, and track applicable legal requirements, company requirements, and other commitments to stakeholders. Take those into account when implementing the EMS (e.g., through procedures, training, monitoring). 4. Objectives, Targets, and Plans: Set objectives and targets (linked to the aspect assessment, legal requirements, and recognizing business realities) to improve programs and performance. Develop and implement plans to achieve the objectives and targets. 5. Resources, Roles, Responsibility, and Authority: Allocate resources to implement the EMS and appoint a management representative to champion EMS implementation. Document and communicate environmental roles, responsibilities, and authorities. Figure 17. ISO 14001 EMS Framework
Environmental Policy Management Review 1 Environmental Policy 2 Environmental Aspects 3 Legal and Other Requirements 4 Objectives, Targets, and Plans

17 Management Review

Planning

Checking

Implementation and Operation

12 Monitoring and Measurement 13 Evaluation of Compliance 14 Non-Conformance, Corrective and Preventive Action 15 Control of Records 16 Internal Audit

5 Resources, Roles, Responsibility, and Authority 6 Competence, Training, and Awareness 7 Communication 8 Documentation 9 Control of Documents 10 Operational Control 11 Emergency Planning and Response

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6. Competence, Training, and Awareness: Ensure that people (including contractors) are competent to carry out their defined roles. (Note: People can be competent based on experience, education, or training.) Identify training needs, implement a training program to address those needs, and document the training completed. Ensure that people are aware of the policy as well as significant aspects, procedures, and EMS requirements relevant to their jobs. 7. Communication: Communicate relevant environmental information to personnel. Typically this means top-down communication of expectations, bottom-up communication of performance and concerns, and lateral communication of best practices and lessons learned. Public reporting is not required, though a process for managing external inquiries is necessary. 8. Documentation: Document the core elements of the EMS and reference relevant procedures. An EMS manual is not required but is commonly developed. 9. Control of Documents: Implement document control procedures so people have access to the right versions of documents, documents stay current, and documents are protected from damage and inappropriate use. 10. Operational Control: Systematically manage operations associated with significant aspects to minimize impacts. This may be through implementing documented procedures or the use of appropriate engineered controls. Have a management-of-change process to proactively address environmental risks associated with operational changes. Although management-of-change is not explicitly specified in the ISO 14001 standard, it is commonly viewed as an essential component of an EMS. 11. Emergency Planning and Response: Maintain emergency plans and deploy appropriate response resources. Train staff, test procedures and equipment, and make adjustments as needed. 12. Monitoring and Measurement: Monitor operations and controls to anticipate upsets and non-conformances. Maintain and calibrate measurement devices. Measure and document progress in achieving objectives and targets. 13. Evaluation of Compliance: Periodically verify compliance with legal and other requirements. 14. Non-Conformance, Corrective and Preventive Action: Identify and investigate the causes of actual and potential EMS non-conformances, and implement corrective and preventive actions to address them. Review the effectiveness of the actions taken. Non-conformances include, but are not limited to, the findings from audits and inspections, as well as environmental incidents and near misses. 15. Control of Records: Maintain and protect records that demonstrate conformance to the EMS requirements and compliance with legal and other requirements. 16. Internal Audit: Develop and implement an audit program to verify that the EMS is effectively implemented and conforms to the design requirements. Provide information on the results of audits to management. 17. Management Review: Through periodic, planned discussions with senior management, identify potential improvements in the EMS and take action as needed. A few key aspects of the ISO 14001 design are described here: Plan-Do-Check-Act: The ISO 14001 EMS uses this well-established and proven model of continual improvement. It requires you to identify your impacts, risks, and requirements (plan); implement controls/programs to manage those risks and requirements (do); verify they are working (check); and then implement corrective and preventive actions and set goals for continual improvement (act). Risk-Based Methodology: The heart of the ISO 14001 EMS methodology is to identify risks and implement appropriate controls to manage them. The risk-based approach resonates well with business and operations managers who have to effectively manage limited resources. 32

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 Flexibility: ISO 14001 was written to apply to any organization, and a full range of companies have implemented it. ISO 14001 does not dictate how to implement its EMS elements, only what is required. Although the ISO 14001 EMS design is an excellent model for developing and implementing an EMS, many organizations choose to customize the standard to better fit their operations and management culture, improving acceptance of the EMS initiative and increasing the likelihood that the desired outcomes will be achieved. Some of the common adjustments companies make to the ISO 14001 EMS model include the following: Documentation and Recordkeeping: Some companies consolidate the three discrete ISO 14001 elements of Documentation, Control of Documents, and Control of Records into one element. The idea is to de-emphasize what might be perceived to be low value-added or bureaucratic aspects of the system. Change Control: Some companies put additional emphasis on managing change. This is about proactively addressing environmental risks and requirements associated with new equipment, modified process operations, new chemicals, and so forth. It often involves formalizing environmental review of capital projects as part of the capital authorization process. Preventive Maintenance: ISO 14001 is not explicit about ensuring all critical operational and pollution control equipment is subject to preventive maintenance and that repairs to malfunctioning equipment are taken care of in a timely fashion. Properly maintained equipment is critical to regulatory compliance and preventing environmental incidents. Contractor Management: Throughout ISO 14001 text refers to those working on behalf of the organization. For this reason, contractor management is spread throughout the standard. However, some companies have chosen to elevate this as a separate and higher profile EMS element, covering topics such as contractor selection, environmental requirements in contracts, pre-job briefings, and contractor oversight. Employee Involvement: Safety professionals have long advocated that active employee involvement is an important element of an effective safety program. The same can be argued for environmental management. Incorporating environmental topics into safety committees, forming green teams, and developing recycling and community environmental initiatives all help raise awareness and build a supportive environmental culture. Leadership and Commitment: Beyond the requirement that senior management issue a policy and conduct a management review, some EMSs are not explicit about the need for visible, ongoing leadership from senior management. Many people believe this is critical to building a supportive environmental culture and to the long-term success of EMS implementation. Accountability: While ISO 14001 talks about roles, responsibilities, and authorities, it is not explicit about accountability. Some companies have had great success in achieving desired culture change by incorporating environmental factors into accountability processes such as annual performance reviews and incentive compensation schemes. Companies typically formalize their EMS requirements/specifications (including the above examples that go beyond ISO 14001) in a documented EMS standard or manual.

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Appendix 2 Overview of U.S. Federal Environmental Laws and Regulations Potentially Applicable to Hardrock Mining Operations
Clean Air Act (CAA) 42 USC 7401 et seq. [40 CFR Parts 5099] Establishes ambient and source emission standards and permit requirements for conventional and hazardous air pollutants. Specifically, the CAA establishes air pollution prevention and control measures, including National Ambient Air Quality Standards (NAAQS) and New Source Performance Standards (NSPS). Key regulations that may apply to mining and mineral processing facilities: 40 CFR Part 60Standards of Performance for New Stationary Sources (NSPS). Subpart DbStandards of Performance for Industrial-CommercialInstitutional Steam Generating Units. Subpart DcStandards of Performance for Small Industrial-CommercialInstitutional Steam Generating Units. Subpart HStandards of Performance for Sulfuric Acid Plants. Subpart KaStandards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984. Subpart KbStandards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984. Subpart LLStandards of Performance for Metallic Mineral Processing Plants. 40 CFR Part 61Requirements Reference Tables. Subpart OCopper Converter Facilities. 40 CFR Part 63National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Categories. Subpart QQQPrimary Copper Smelting NESHAP.

Key regulations that may apply to mining and mineral processing facilities: Clean Water Act (CWA) 33 USC 1251 et seq. 40 CFR Part 112Oil Pollution Prevention (Spill Prevention Control and Countermeasure Plans) [40 CFR Parts 100149, 220232, 410417] 40 CFR Part 122The National Pollutant Discharge Elimination System (includes Stormwater Regulations) Establishes standards and permit requirements for water pollutants, 40 CFR Part 125Criteria and Standards for the National Pollutant including sources that discharge Discharge Elimination System directly to a water body or to a public 40 CFR Part 440Ore Mining and Dressing Point Source Category sewer system. Also includes stormwater Subpart JCopper, Lead, Zinc, Gold, Silver, and Molybdenum Ores management requirements. Subcategory Subpart MGold Placer Mine Subcategory 33 CFR Part 320U.S. Army Corps of Engineers Regulatory Approach and Forms of Authorizations 33 CFR 321.2Definition of Navigable Waters of the United States 33 CFR Part 323Permits for Discharges of Dredged or Fill Material into Waters of the United States 33 CFR 323.2(f)Defines the term discharge of fill material 33 CFR 323.3Discharges requiring permits 33 CFR 323.4Discharges not requiring permits 33 CFR Part 325Processing of Department of the Army Permits 33 CFR Part 328Definition of Waters of the United States 33 CFR Part 330Nationwide Permit Program (continues)

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Overview of U.S. Federal Environmental Laws and Regulations Potentially Applicable to Hardrock Mining Operations (continued)
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 42 USC 9601 et seq. [40 CFR Parts 300311] Establishes a program for cleaning up contaminated waste sites and establishes liability for cleanup costs. Provides reporting requirements for releases of hazardous substances. Emergency Planning and Community Rightto-Know Act (EPCRA) 42 USC 11001 et seq. [40 CFR Parts 355, 370 & 372] Establishes a program (the Toxics Release Inventory) to inform the public about releases of hazardous and toxic chemicals. Reporting requirements apply to companies that manufacture, process, or otherwise use listed toxic chemicals over a certain quantity. Key regulations that may apply to mining and mineral processing facilities: 40 CFR Part 300National Oil and Hazardous Substances Pollution Contingency Plan 40 CFR Part 302Designation, Reportable Quantities, and Notification

Key regulations that may apply to mining and mineral processing facilities: 40 CFR Part 355Emergency Planning and Notification 40 CFR Part 370Hazardous Chemical Reporting: Community Right-to-Know 40 CFR Part 372Toxic Chemical Release Reporting: Community Right-to-Know Further Guidance: USEPA, EPCRA Section 313 Industry Guidance: Metal Mining Facilities, EPA 745-B-99-001 (Jan. 1999). Pertinent Case Law: NMA v. Browner, 2001 U.S. Dist. LEXIS 915 (D. Colo. 2001). Barrick Goldstrike Mines v. Whitman, 260 F. Supp. 2d 28 (D.D.C. 2003). See 40 CFR Parts 15001508Council on Environmental Quality (CEQ) Regulations for Implementing NEPA CEQ NEPAnet: www.nepa.gov/nepa/nepanet.htm Federal Agency NEPA Procedures: www.nepa.gov/nepa/regs/agency/ agencies.cfm Federal Agency Website: www.nepa.gov/nepa/agencies.cfm

National Environmental Policy Act (NEPA) 42 USC 4321 et seq. [40 CFR Parts 15001508] Defines processes for evaluating major federal actions that significantly affect the environment, including permitting of new mine development on federal lands.

Key regulations that may apply to mining and mineral processing facilities: Resource Conservation and Recovery Act (RCRA)42 USC 6901 et seq. 40 CFR Part 261Identification and Listing of Hazardous Waste [40 CFR Parts 260282] 40 CFR 261.2(c)(3)Unlisted byproducts or sludges that are reclaimed are not solid wastes. Establishes regulations and permit 40 CFR 261.4Solid wastes which are not hazardous wastes: requirements for hazardous waste 40 CFR 261.4(a)(5)In-situ mining exclusion management (transportation, 40 CFR 261.4(a)(7)Spent sulfuric acid exclusion treatment, storage, and disposal). 40 CFR 261.4(a)(8)Secondary materials that are reclaimed and Specifically, RCRA defines what returned to the original process exclusion constitutes a solid waste and requires 40 CFR 261.4(a)(13)Recycled scrap metal exclusion certain methods for treatment, storage, 40 CFR 261.4(a)(14)Shredded circuit boards exclusion and disposal. RCRA also defines what 40 CFR 261.4(a)(17)The exclusion applicable to spent materials a hazardous waste is. A material is generated within the mineral processing industry that are recovered hazardous waste if it meets the definiby mineral processing or beneficiation tion of solid waste (40 CFR 261.2) and 40 CFR 261.4(b)(17)Solid waste from the extraction, beneficiation, exhibits one of the characteristics of a and processing of ores and minerals, except as provided by 266.122 hazardous waste (40 CFR 261.2024) or is listed as a hazardous waste (40 CFR 261.3133). A hazardous waste is subject to Subtitle C generator (40 CFR 262), transporter (40 CFR 263), and treatment, storage, and disposal facility (40 CFR 254 & 265) requirements. (continues) 2012 National Mining Association

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Overview of U.S. Federal Environmental Laws and Regulations Potentially Applicable to Hardrock Mining Operations (continued)
Many mine wastes are exempt from RCRA Subtitle C hazardous waste regulations.

A hazardous waste generator is any person or site whose processes and actions create hazardous waste See 40 CFR 260.10. Generators are divided into three categories based on the quantity of waste they produce: 1. Large Quantity Generators (LQGs) generate 1,000 kg per month or more of hazardous waste, more than 1 kg per month of acutely hazardous waste, or more than 100kg per month of acute spill residue or soil. 2. Small Quantity Generators (SQGs) generate more than 100kg, but less than 1,000kg, of hazardous waste per month. 3. Conditionally Exempt Small Quantity Generators (CESQGs) generate 100g or less per month of hazardous waste, or 1kg or less per month of acutely hazardous waste, or less than 100kg per month of acute spill residue or soil. RCRA also establishes standards for underground storage tanks storing petroleum and other hazardous substances. Toxic Substances Control Act (TSCA) 15 USC 2601 et seq. [40 CFR Parts 700766] Regulates the production, importation, use, and disposal of specific chemicals. Also establishes reporting, recordkeeping and testing requirements, and restrictions relating to chemical substances and/or mixtures.

40 CFR Part 262Standards Applicable to Generators of Hazardous Waste 40 CFR Part 263Standards Applicable to Transporters of Hazardous Waste 40 CFR Part 264Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities 40 CFR Part 265Interim Status Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities 40 CFR Part 266Standards for the Management of Specific Hazardous Wastes and Specific Types of Hazardous Waste Management Facilities 40 CFR 266.70The precious metals exemption 40 CFR 266.100(g)The counterpart to the exemption for precious metals 40 CFR 266.100(d)The smelting, melting, and refining furnace exemption 40 CFR Part 267Standards for Owners and Operators of Hazardous Waste Facilities Operating Under a Standardized Permit 40 CFR Part 268Land Disposal Restrictions 40 CFR Part 270EPA Administered Permit Programs: The Hazardous Waste Permit Program Further Guidance: USEPA, Regulatory Determination on Wastes from Mineral Processing (1986). USEPA, Report to Congress on Special Wastes from Mineral Processing (1990). USEPA, Final Regulatory Determination for Special Wastes from Mineral Processing (Mining Waste Exclusion, established in response to the Bevill Amendment) (1991). Pertinent Case Law: American Mining Congress v. EPA, 824 F.2d 1177 (D.C. Cir. 1987). Association of Battery Recyclers v. EPA, 208 F.3d 1047 (D.C. Cir. 2000). Key regulations that may apply to mining and mineral processing facilities: 40 CFR Part 704Reporting and Recordkeeping Requirements 40 CFR Part 710TSCA Chemical Inventory Regulations 40 CFR Part 761Polychlorinated Biphenyls (PCBs) manufacturing, processing, distribution in commerce, and use prohibitions

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Appendix 3 Assessment of Significant Environmental AspectsExample

(Aligns with and addresses all aspects in Figure 5.)
Significance Ratings Other People Business and the Environment Compliance Impacts 3 3 3

Activity/ Operation

Environmental Aspects Land disturbance

Land disturbance Planning and Permitting

Land disturbance

Land disturbance Reclamation and closure

Stormwater runoff Greenhouse gas (GHG)/combustion byproducts from equipment Water and wastewater disposition from mine dewatering and/or mine water disposal Mining

Environmental Impacts Disturbances of floodways and river ways Potential degradation of sensitive areas: archeological, cultural, aquatic, terrestrial; threatened and endangered species Property boundaries, stockpile height restrictions, visual impacts Terrestrial habitat (flora and fauna) and aquatic habitat recovery; mitigating impacts to surface aquatic habitat and groundwater Acid rock, alkaline, or saline drainage impact on soil, surface water, and groundwater Deposition of particulates, climate change, acid rain, air quality degradation

Total 9

Significant [Y/N] Y

Surface or underground miningWater table reduction/depletion: acid rock, alkaline, or saline drainage impact on soil, surface water, and groundwater degradation Water usage in drilling Water use in drilling operations Cutting new haul roads, mine portal or surface mine development, haul road development: Land disturbance potential disturbance of terrestrial and/or aquatic habitat Fugitive dust emissions Deposition of particulates, air (blasting, loading) quality degradation Blasting: noise and Nuisance to neighbors and vibration fauna Potential fire or explosive Blasting: waste hazard, potential release to explosives packaging water or soils materials

2 3 1

2 1 2

2 1 1

6 5 4

Y N N (continues)

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Assessment of Significant Environmental AspectsExample (continued)

Activity/ Operation Significance Ratings Other People Business and the Environment Compliance Impacts 2 2 2 Significant [Y/N] Y

Power Haulage

Environmental Aspects Fugitive dust emissions (transfer locations, road traffic, dumping) Anti-tampering devices on large offroad vehicles Truck hitting wildlife Noise GHG/combustion byproducts from mobile sources Infiltration and stormwater runoff

Environmental Impacts Deposition of particulates, air quality degradation Deposition of particulates, air quality degradation Fauna Noise from operation of trucks Deposition of particulates, climate change, acid rain, air quality degradation Acid rock, alkaline, or saline drainage impact on soil, surface water, and groundwater Potential impact to human health and to soil, surface water, and groundwater Deposition of particulates, air quality degradation Deposition of particulates, air quality degradation Deposition of particulates, climate change, acid rain, air quality degradation

Total 6

1 1 1 2

1 1 1 1

1 1 1 2

3 3 3 5

N N N N

Stockpiles (Ore, Low-Grade Ore, Overburden)

Slope stability Ore stockpile: fugitive dust emissions (dumping, wind erosion) Crushing: fugitive dust emissions Air pollutant emissions from energy use (electricity) and equipment combustion sources Leachate potential to escape pad containment systems Leach pad slope stability Stormwater runoff from pad Spills/leakage or waste generation from process chemicals (cyanide, acid, or pregnant leach solution [PLS]) PLS collection and holding ponds PLS collection and holding ponds Process wastewater discharge

Ore Crushing

Groundwater contamination Potential impact to human health and to soil, surface water, and groundwater Surface water contamination

2 3

2 2

2 2

6 7

Y Y

Leaching

Soil, surface water, and groundwater

Groundwater and/or surface water contamination Wildlife Soil, surface water, groundwater, air emissions

3 3 2

3 2 3

3 3 2

9 8 7

Y Y Y (continues)

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Assessment of Significant Environmental AspectsExample (continued)

Activity/ Operation Significance Ratings Other People Business and the Environment Compliance Impacts Significant [Y/N]

Environmental Aspects Spills from tanks or pipes or waste generation from process chemicals mismanagement SX plant volatile organic compound Solvent (VOC) emissions Extraction/ Electrowinning EW tankhouse acid mist emissions (SX/EW) Air pollutant emissions from energy use (electricity) Generation and management of lead flake and lead anodes Spills Grinding Generation of dust Air pollutant emissions from energy use (electricity) Process wastewater disposition Spills or waste generation from metallic mineral concentrate mishandling Concentrate storage Flotation reagents: fugitive VOC air emissions Tailings conveyance/ pipingspills

Environmental Impacts Soil, surface water, groundwater, air emissions

Total

Air quality Air quality Deposition of particulates, climate change, acid rain, air quality degradation Potential impact on soil, surface water, and groundwater Potential impact on surface water and groundwater Air quality Deposition of particulates, climate change, acid rain, air quality degradation, mercury volatilization Soil, surface water, and groundwater Acid rock drainage and metals leaching impact on soil, surface water, and groundwater Potential migration from wind erosion or stormwater Air quality

2 2 2

2 2 1

2 2 2

6 6 5

Y Y N

3 1 1 2

2 1 1 1

2 1 1 2

7 3 3 5

Y N N N

Concentrating

2 2 3 2 2 2 2 3 2

2 2 2 2 3 3 2 3 2

2 1 3 2 2 2 2 3 1

6 5 8 6 7 7 6 9 5

Y N Y Y Y Y Y Y N (continues)

Tailings

Potential impact on surface water and groundwater Deposition of particulates, air Fugitive dust emissions quality degradation Leakage to Degradation of groundwater groundwater quality Seepage collection, Degradation of surface water management, and and groundwater quality disposition Stormwater runoff Surface water contamination Potential impact to human Dam slope stability health and to soil, surface water, and groundwater Wildlife through ingestion and/ Pond water quality or contact

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Assessment of Significant Environmental AspectsExample (continued)

Activity/ Operation Significance Ratings Other People Business and the Environment Compliance Impacts 1 1 1 2 3 2 1 2 1 1 1 3 2 2 1 1 1 1 2 1 1 Significant [Y/N] N N N N Y N N

Environmental Aspects Generation of used tires Generation of used oil and grease Generation of used lead acid batteries Parts washer management Polychlorinated biphenyls (PCBs) equipment Spray painting Impacted stormwater runoff (maintenance areas) Wastewater generation (wash racks, oilwater separators, sewage treatment systems, wastewater treatment systems) Chemical management/ inventory Generation of potentially hazardous wastes (e.g., aerosol cans, paint) Fuel storage/ dispensing Drinking water supply (water quality) Contact stormwater ponds Non-contact stormwater runoff Asbestos-containing materials Equipment storage/ laydown yards potential leakage (ozonedepleting substances, PCBs, oil, and grease) Building demolition Housekeeping

Environmental Impacts Waste disposal/land use Waste disposal Waste disposal Waste disposal and potential air emissions Potential impact to human health and to soil, surface water, and groundwater Air quality Surface water contamination

Total 4 3 3 4 8 5 4

Maintenance Activities

Soil, surface water, and groundwater

Potential impact to human health (spills, fire, explosion); waste disposal Waste disposal Spills and leakspotential impact to soil, surface water, and groundwater Human health Soil, surface water, and groundwater Potential impact on soil, surface water, and groundwater Potential impact to human health; waste disposal Potential impact on soil, surface water, and groundwater Waste disposal Visual impacts, potential impacts to groundwater

2 3 3 1 3

2 3 2 1 3

2 3 2 1 2

6 9 7 3 8

Y Y Y N Y

Sitewide

1 1

1 1

1 1

3 3

N N (continues)

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Assessment of Significant Environmental AspectsExample (continued)

Activity/ Operation Significance Ratings Other People Business and the Environment Compliance Impacts 3 3 1 Significant [Y/N] Y

Sitewide (continued)

Environmental Aspects Waste disposal (proper segregation of wastes and management of landfills) Waste management off-site recycling Petroleumcontaminated soils management Open burning Legacy environmental issues Water usage

Environmental Impacts Potential impact to human health and groundwater Waste disposal Waste disposal Air quality degradation Surface water/groundwater contamination Depletion of natural resources/ exceed allowable water withdrawals Soil, surface water, groundwater, nuisance litter, vector (rodent) management Reduction in non-renewable resources Deposition of particulates, climate change, acid rain, air quality degradation

Total 7

1 2 2 3 3

1 2 2 3 2

1 2 1 3 3

3 6 5 9 8

N Y N Y Y

Office and food waste generation and disposal Resource use (paper, Office/ plastic, toner, etc.) Administration Air pollutant emissions from energy use (electricity) and HVAC sources

1 1

0 0

1 0

2 1

N N

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Appendix 4 Assessment of Controls and Residual RiskExample

(Aligns with and addresses all aspects in Figure 5 and Appendix 3.) Residual Risk 3 3.6 3.6 4.5 3.5 NA Controls Rating Significant Aspects Score Y/N Controls in Place Engineered structures to divert water around mine and processing facilities. Current site maps with floodways and river ways clearly noted as restricted areas. Current site maps with sensitive areas clearly noted. Boundaries of sensitive areas marked in the field. Current site maps with boundaries and height restrictions clearly indicated. Management of change process employed to ensure careful review of all changes/ expansions. Mine closure plan with concurrent reclamation Stormwater Pollution Prevention Plan (SWPPP), potentially acid generating (PAG) waste containment cells, diversion ditches, collection ponds, stormwater reuse, training, procedures, excess water treatment, stormwater discharge permit NA

Activity/ Operation

Environmental Aspects

Improvement Actions Develop and implement a written Monitoring and Maintenance Plan for stormwater diversion structures. Annual review of maps and field verification of boundary markings. Document management of change procedure and establish procedure to review any discrepancies noted in the field. Annual review of reclamation target areas and performance of reclaimed areas. Annual review and update of SWPPP along with monitoring results to drive improvements to applicable engineering and administrative controls. NA Develop and maintain a water use/reuse program and treatment of excess dewater and/ or process water as required. NA NA (continues)

Land disturbance

Land disturbance Planning and Permitting Land disturbance

2.5

2.5

Land disturbance Reclamation and closure

Stormwater runoff

Mining

Greenhouse gas (GHG)/combustion byproducts from equipment Water and wastewater disposition from mine dewatering and/or mine water disposal Water use in drilling Land disturbance

NA

Dewater water reuse, excess water treatment, water discharge permit, water quality monitoring

3 5

N N

NA NA

NA NA

NA NA

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2012 National Mining Association

Assessment of Controls and Residual RiskExample (continued)

Activity/ Operation Environmental Aspects Fugitive dust emissions (blasting, loading) Blasting: noise and vibration Blasting: waste explosives packaging materials Fugitive dust emissions (transfer locations, road traffic, dumping) Power Haulage Anti-tampering devices on large off-road vehicles Truck hitting wildlife Noise GHG/combustion byproducts from mobile sources Residual Risk 3 NA NA Controls Rating Significant Aspects Score Y/N Controls in Place Dust mitigation plan, including: water truck spraying, chemical suppressants, no blasting in strong winds, air monitoring at facility perimeter NA NA Dust mitigation plan, including water truck spraying, water bars and sprays, chemical suppressants, air monitoring at facility perimeter NA NA NA NA Characterization of materials and planned placement. SWPPP, PAG waste containment cells, diversion ditches, collection ponds, stormwater reuse, training, procedures, excess water treatment, stormwater discharge permit

Improvement Actions Develop and maintain a Fugitive Dust Plan

Mining (continued)

5 4

N N

NA NA

NA NA

Develop and maintain a Fugitive Dust Plan.

3 3 3 5

N N N N

NA NA NA NA

NA NA NA NA

NA NA NA NA Develop system for monthly review of stormwater controls for PAG stockpile/ cells and quarterly inspections and maintenance of engineered stormwater structures. Develop and implement a program to monitor slope stability of critical stockpiles. Develop and implement a program to minimize ore dropheight; add water sprays to conveyor transfer points. (continues)

Infiltration and stormwater runoff Stockpiles (Ore, Low-Grade Ore, Overburden)

Slope stability

Design and operate stockpiles for slope stability.

Ore Stockpile: fugitive dust emissions (dumping, wind erosion)

Dust mitigation plan, including water truck spraying

2.5

2.4

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Assessment of Controls and Residual RiskExample (continued)

Activity/ Operation Environmental Aspects Residual Risk 3 NA Controls Rating Significant Aspects Score Y/N Controls in Place Dust mitigation plan, including water bars and sprays, chemical suppressants, air monitoring at facility perimeter. Periodic inspections to ensure systems working as designed.

Improvement Actions

Crushing: fugitive dust emissions Ore Crushing

Develop and maintain a Fugitive Dust Plan.

Air pollutant emissions from energy use (electricity) and equipment combustion sources

NA

NA

NA

Leachate potential to escape pad containment systems

Design facilities to minimize potential to discharge to groundwater and surface waterconsider liners. Groundwater monitoring to confirm integrity of containment. Frequent inspections of facilities. Heaps designed for slope stability and frequent inspections to confirm no deformations such as surface cracks, slides, sloughs, or unusual settlement.

4.5

Develop a program to trend groundwater monitoring data to detect any changes in water quality.

Leach pad slope stability

No improvements needed at this time.

Leaching Stormwater runoff from pad 7 Y SWPPP, including run-on and runoff controls designed for the proper storm event. 3 2.3

Develop a program to ensure that designed capacity and controls for stormwater events are available in advance of severe weather conditions. Develop a facilityspecific checklist to ensure that frequent system inspections are conducted to expectations. (continues)

Spills/leakage or waste generation from process chemicals (cyanide, acid, or pregnant leach solution [PLS])

Piping and tank systems should be designed to minimize potential for leakage/ spillage that may include secondary containment and leak detection systems. Emergency response plans for addressing any spills. All systems should be frequently monitored.

3.5

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2012 National Mining Association

Assessment of Controls and Residual RiskExample (continued)

Activity/ Operation Environmental Aspects Residual Risk 3.3 2.7 1.8 2.3 2.1 1.9 NA Controls Rating Significant Aspects Score Y/N Controls in Place Ponds should also be sited and designed to minimize the potential for leakage and have sufficient capacity and pumping to ensure adequate freeboard during the design storm events. Utilize leachate collection and recovery systems. All systems should be frequently monitored/ inspected. If required, wildlife deterrence systems such as fencing, hazing, or covers should be implemented to control wildlife exposure to leach solutions. Treatment, chemical management plan, training, chemical storage locations and equipment, inspections, secondary containment, qualified disposal vendors, waste management plan. Construct tanks and pipes to minimize potential for discharge. Properly designed and operated secondary containment. Periodic inspections for tank/pipe integrity. Construct tanks with provisions to minimize VOC emissions. Tank covers should be considered and in place/closed when installed. Design and operate facilities to minimize air emissions (floating balls, chemical additives). NA Written procedure for the management and storage of lead flake. Use of secondary containment. Waste characterization and proper recycle and/or disposal options.

Improvement Actions

PLS collection and holding ponds

2.7

Develop a preventive maintenance program for PLS pond pumps; evaluate the need for in-line spares.

Leaching (continued)

PLS collection and holding ponds

Develop a program for quarterly inspections on facilities to ensure they are maintained as designed. Develop and maintain chemical and waste management plans. Develop and maintain a water use/ reuse program and treatment of pond and excess water as required. Develop a program for regular inspections of tank covers to ensure they are closed. Develop criteria for replacement of floating balls.

Process wastewater discharge

Spills from tanks or pipes or waste generation from process chemicals mismanagement SX plant volatile organic compound (VOC) emissions Solvent Extraction/ Electrowinning (SX/EW) EW tankhouse acid mist emissions Air pollutant emissions from energy use (electricity) Generation and management of lead flake and lead anodes

2.8

3.2

NA

NA

2.9

2.4

Improve written procedures and training for lead flake handling. (continues)

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Assessment of Controls and Residual RiskExample (continued)

Activity/ Operation Environmental Aspects Spills Generation of dust Air pollutant emissions from energy use (electricity) Residual Risk NA Controls Rating Significant Aspects Score 3 3 Y/N N N Controls in Place NA NA

Improvement Actions NA

NA

Grinding

NA Chemical management plan, training, chemical storage locations and equipment, inspections, secondary containment, qualified disposal vendors, waste management plan. Metallic mineral concentrate management plan, training, storage locations and equipment, inspections, secondary containment, qualified disposal vendors, waste management plan, shipping methods. Emergency response plans to address any spills. Dust management plans, stormwater management plans, and associated engineered controls. NA Secondary containment, leakage/break detection systems, and periodic integrity testing should be considered. Provide frequent inspection and emergency response plans to address spills. Dust mitigation plan considering the following: managing water coverage on tailings disposal area, water spraying, chemical suppressants, air monitoring at facility perimeter, interim revegetation.

NA

NA

NA

Process wastewater disposition

1.8

Develop and maintain chemical and waste management plans. Implement improved housekeeping plan (increased sweeping frequency and maintenance of controls in place) to minimize exposure to the environment. Investigate installation of wind fences in appropriate areas. NA

Concentrating

Spills or waste generation from metallic mineral concentrate mishandling

Concentrate storage Flotation reagents: fugitive VOC air emissions

NA

NA

Tailings conveyance/piping spills Tailings Fugitive dust emissions

1.8

4.4

Improve tailings pipe leak detection to include pressure monitoring and daily inspections. Develop improved Tailings Management Plan to anticipate seasonal variations and demands. (continues)

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2012 National Mining Association

Assessment of Controls and Residual RiskExample (continued)

Activity/ Operation Environmental Aspects Residual Risk 3.5 2.3 2 3.6 NA NA NA Controls Rating Significant Aspects Score Y/N Controls in Place Design to control potential leakage to groundwater. Groundwater monitoring to ensure integrity. Seepage water reuse, water discharge permit, engineered collection system, regular inspections. Run-on and runoff controls capacity for designed storm event. Design for stable slopes. Frequent monitoring for slope stability. Consider revegetation. NA NA NA

Improvement Actions Develop a program to trend groundwater monitoring data to detect any changes in water quality. Develop and maintain a Seepage Management Plan. No improvements needed at this time. Develop criteria/ checklist for a slope inspection program. NA NA NA

Leakage to groundwater

Tailings (continued)

Seepage collection, management, and disposition Stormwater runoff Dam slope stability Pond water quality Generation of used tires Generation of used oil and grease Generation of used lead acid batteries Parts washer management Polychlorinated biphenyls (PCBs) equipment Spray painting Impacted stormwater runoff (maintenance areas) Wastewater generation (wash racks, oil water separators, sewage treatment systems, wastewater treatment systems)

2.5

5 4 3

N N N

NA NA NA

3 4

N N

NA NA PCB management plan, regular inspections; planned elimination of PCB-containing equipment NA NA

NA NA

NA NA

NA NA Develop a program to clearly label all potentially PCB-containing equipment (e.g., transformers). NA NA

2.5

3.2

Maintenance Activities

5 4

N N

NA NA

NA NA

NA

NA

NA

NA

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Assessment of Controls and Residual RiskExample (continued)

Activity/ Operation Environmental Aspects Chemical management/ inventory Generation of potentially hazardous wastes (e.g., aerosol cans, paint) Residual Risk NA Controls Rating Significant Aspects Score 4 Y/N N Controls in Place NA

Improvement Actions NA

NA

NA

NA

NA

NA

Fuel storage/ dispensing

Designed to prevent fuel spillage and leakage from storage facilities to ground. Frequent inspections to ensure spills are cleaned up promptly and controls such as secondary containment, locks, and fill nozzles are working properly. Systems are in place to ensure a safe water supply for the site (water quality monitoring, backflow prevention) Engineered pond which may be lined with synthetic liner, clay or compacted earth. Sized to contain designated storm events and/or controlled with piping or pumps. Periodic inspections NA Management systems in place to identify where friable asbestos exists at the site and that any removal/ remediation is done properly.

2.9

2.1

No improvements needed at this time.

Drinking water supply (water quality)

3.6

2.5

No improvements needed at this time.

Sitewide

Contact stormwater ponds

2.8

2.5

Develop a Maintenance Plan for stormwater diversion structures.

Non-contact stormwater runoff Asbestoscontaining materials Equipment storage/laydown yards potential leakage (ozonedepleting substances, PCBs, oil, and grease) Building demolition Housekeeping

NA

NA

NA Include asbestos review in management of change procedure (demolition projects).

2.8

2.9

NA

NA

NA

NA

3 3

N N

NA NA

NA NA

NA NA

NA NA (continues)

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2012 National Mining Association

Assessment of Controls and Residual RiskExample (continued)

Activity/ Operation Environmental Aspects Waste disposal (proper segregation of wastes and management of landfills) Waste managementoff-site recycling Petroleumcontaminated soils management Open burning Legacy environmental issues Residual Risk 2.5 NA Controls Rating Significant Aspects Score Y/N Controls in Place Management systems in place to ensure that all wastes are segregated at the source, disposed at formally approved facilities. On-site facilities properly designed and operated. NA Management systems are in place to handle, store, remediate, and dispose of petroleum-contaminated soils, as appropriate. NA Management systems in place to address environmental issues associated with any legacy operations at the site.

Improvement Actions Include new waste stream evaluation and characterization in management of change procedure. NA Improve training materials and identify groups that need the training. NA No improvements needed at this time. Develop and implement a plan to install flowmeters to allow for an effective site water balance. NA

2.8

NA

Sitewide (continued)

2.7

2.2

5 9

N Y

NA 3.2

NA 2.8

Water usage

Flow measurement, water balance

2.3

3.5

Office and food waste generation and disposal Office/ Administration Resource use (paper, plastic, toner, etc.) Air pollutant emissions from energy use (electricity) and HVAC sources

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

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Appendix 5 Operational Control Tables for Common Significant Environmental Aspects for Mining Operations OnlyExample
Significant Environmental Aspects Stormwater Runoff from Mining Operations Only Legal Multi-sector General Stormwater Permit Clean Water Act permitted discharge limits Migratory Bird Treaty Act Adjacent landowner adverse actions Transport of contaminants off-site Impacts resulting in impaired waters Mining and Reclamation Plans Stormwater Pollution Prevention Plans (SWPPPs) Site Water Balance Plan Stormwater best management practices (BMPs) Spill Prevention, Control, and Countermeasure (SPCC) for petroleum storage Management of change Environmental management systems and audits

Potential Impacts

Programs, Procedures, Work Instructions

Engineered Controls (hardware)

Stormwater run-on controls, external and internal flow diversions, conveyance mechanisms, storage, pumping Secondary and tertiary containments Stormwater BMPs Environmental management systems Stormwater training Stormwater management team functional training Spill response training

Training

Monitoring and Measurement Activities

Stormwater sampling at outfalls Benchmark monitoring SWPPP inspections BMP inspections SPCC inspections SPCC Plan SWPPP Spill Response Procedures (continues)

Emergency Planning and Response

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2012 National Mining Association

Operational Control Tables for Common Significant Environmental Aspects for Mining Operations OnlyExample (continued)
Significant Environmental Aspects Fugitive Dust Emissions from Mining Operations Only Exceed Clean Air Act Air Operating Permit limits Exceed National Ambient Air Quality Standards Exceed local nuisance ordinances Trigger community relations concerns (aesthetics, quality-of-life, property value) Trigger public health legal filings Mining and Reclamation Plans Standard Operating Procedures Air Operating Permit Fugitive Dust Control Plans Occupational Health Exposure Mitigation Plans Materials supply and management systems (water supply and availability, chemical suppressant supply and availability)

Potential Impacts

Programs, Procedures, Work Instructions

Engineered Controls (hardware)

Haulage Surface Engineered Material Quality Assurance/Quality Control Fugitive Dust Suppression Application Systems Preventive Maintenance Programs (water trucks, water wagons, pressurized sprays, water tankage) Chemical suppressant delivery systems (chemical tankage, chemical transfer systems) Environmental management systems Air Operating Permit task Fugitive Dust Control Plan task Exceptional Events Response Procedures Standard Operating Procedures Operator dust minimization technique provisions (vehicle speed, drop heights) Air Operating Permit reporting and recordkeeping activities Fugitive Dust Control Plan opacity measurements compliance Fugitive Dust Control Plan general provisions compliance Regulatory agency compliance inspections

Training

Monitoring and Measurement Activities Emergency Planning and Response

Exceptional Events Response Procedures Hazardous Materials Release (air) Plan

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