British Columbia Mine Reclamation Symposium

Impact of contaminated sites legislation on closure of an acid generating mine site in British Columbia Mchaina, David Mhina; Willmer, Bruce A.

Abstract

In the past few years, numerous mine closure and reclamation projects have been subjected to the provincial Contaminated Sites Regulation (CSR) in British Columbia. A mine decommissioning and closure plan should contain among other things a Detailed Site Investigation report, a Remedial Action Plan and the necessary financial security to ensure funds are available to carry out the remediation work. The intent of the CSR has been to facilitate the complete sign off of long-term environmental liability to a company by government from a particular site through requiring a company to meet all the requirements defined in the regulation. This sign off can be in the form of a Certificate of Compliance, Conditional Certificate of Compliance or Letter of Comfort. Contaminated Sites Regulations have been developed predominantly for industrial or commercial sites usually in an urban environment with clearly defined contaminants associated with the particular industry. Problems associated with acid rock drainage and acid generating sulphide waste contamination are not clearly defined in these regulations. Complications arise when applying the CSR to the mining sector. In particular, the interpretation of a regulation which defines "contaminated site" based on concentrations of naturally occurring inorganic substances (metals) in soil and groundwater In addition, the CSR bureaucratic process has not been generally structured to blend with more traditional mine closure plans required under the Mines Act even though the regulations are somewhat linked. While the intent of government has been to link and harmonize the CSR with the mine closure regulations, in BC, the harmonization of the regulations and various ministries has yet to be tested fully and it is anticipated will require modification to the regulations. This paper will give an overview of the environmental regulatory context in British Columbia with particular reference to CSR requirements at acid generating mine sites. In addition, technical and administrative requirements will be given together with a discussion of the impacts of these regulations on the mining industry and ways to plan and manage associated liabilities.

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Attribution-NonCommercial-NoDerivatives 4.0 International