**DEATH VALLEY NATIONAL PARK**

**AML**

**ABANDONED MINERAL LANDS MANAGEMENT PLAN**

**and Environmental Assessment**

**2003**

![](media/image1.jpeg){width="5.820138888888889in"
height="5.176388888888889in"}

**DEATH VALLEY NATIONAL PARK**

**AML**

**ABANDONED MINERAL LANDS MANAGEMENT PLAN**

**and Environmental Assessment**

**2003**

Submitted by:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_

> Mining Engineer Date

Recommended by:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_

> Chief, Resources Management Division Date

Recommended by:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_

> Superintendent, Death Valley NP Date

Approved by:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_

> Regional Director, PWRO Date

**TABLE OF CONTENTS**

INTRODUCTION [1](#introduction)

Purpose [1](#purpose)

Management Authorities [1](#management-authorities)

Secretarial Standards [4](#secretarial-standards)

NPS Management Policies 2001 provides the following additional
instruction:
[4](#nps-management-policies-2001-provides-the-following-additional-instruction)

NPS Draft Director's Order DO-13 Environmental Leadership
[4](#nps-draft-directors-order-do-13-environmental-leadership)

NPS Director's Order DO-50: Abandoned Mine Safety
[4](#nps-directors-order-do-50-abandoned-mine-safety)

NPS-77: Natural Resources Management Guidelines
[5](#nps-77-natural-resources-management-guidelines)

WRO-085 Management of Abandoned Mineral Lands (AML)
[5](#wro-085-management-of-abandoned-mineral-lands-aml)

29 CRF Parts 1910 and 1926 - OSHA [5](#crf-parts-1910-and-1926---osha)

California Desert Protection Act (PL 103-433).
[5](#california-desert-protection-act-pl-103-433.)

National Historic Preservation Act, Section 106
[5](#national-historic-preservation-act-section-106)

National Park Service National Wilderness Steering Committee, Finding 1,
Recommendation 1
[6](#national-park-service-national-wilderness-steering-committee-finding-1-recommendation-1)

Other Land Management Agency Policies and Procedures
[7](#other-land-management-agency-policies-and-procedures)

AML Program Background [7](#aml-program-background)

AML Program [10](#aml-program)

AML Survey [10](#aml-survey)

AML Safety/Health Hazard Categories
[11](#aml-safetyhealth-hazard-categories)

Definition of AML Hazards [11](#definition-of-aml-hazards)

Surface Hazards [12](#surface-hazards)

Underground Hazards [12](#underground-hazards)

Shafts and Inclines [13](#shafts-and-inclines)

Adits and Tunnels [13](#adits-and-tunnels)

Stopes [13](#stopes)

Winzes [13](#winzes)

Mitigation of Health and Safety Hazards
[14](#mitigation-of-health-and-safety-hazards)

Definition of issues [14](#definition-of-issues)

Authorized Underground Mine Entry
[14](#authorized-underground-mine-entry)

AML Mine Safing (Closure) Procedures
[16](#aml-mine-safing-closure-procedures)

Irreversible Methods [16](#irreversible-methods)

Back-Filling [16](#back-filling)

Polyurethane Foam Plugs [16](#polyurethane-foam-plugs)

Blasting [16](#blasting)

Reversible Methods [17](#reversible-methods)

Bulkheads and walls [17](#bulkheads-and-walls)

Fencing [17](#fencing)

Safety Nets [17](#safety-cable-nets)

Rigid Metal Frame Exclosures [24](#rigid-metal-frame-exclosures)

Mine Closure Adaptations for Wildlife
[26](#mine-closure-adaptations-for-wildlife)

Species of Special Concern [26](#species-of-special-concern)

Desert Tortoise [26](#desert-tortoise)

Bats [26](#bats)

Other Wildlife [32](#other-wildlife)

Barn Owls [32](#barn-owls)

Small mammals, birds, and reptiles
[33](#small-mammals-birds-and-reptiles)

AML Related Activities in park Wilderness
[34](#aml-related-activities-in-park-wilderness)

Historic structures and mine closures
[35](#historic-structures-and-mine-closures)

Stabilization of Historic Mine Buildings, Structures, and residences.
[37](#stabilization-of-historic-mine-buildings-structures-and-residences.)

Mitigation of impacts to the park's resources where appropriate
[42](#mitigation-of-impacts-to-the-parks-resources-where-appropriate)

**LIST OF APPENDICES**

Appendix A Definitions

Appendix B Job Hazard Analysis

Appendix C Abandoned mine entry protocol and required PPE

Appendix D AML Site Survey Form

Appendix E AML Emergency Plan

Appendix F Environmental Assessment

**LIST OF FIGURES**

> Page

FIGURE 1: Underground mine features

[3](#__RefHeading___Toc21847117)

FIGURE 2: Collapsed miners cabin [9](#__RefHeading___Toc21847118)

FIGURE 3: Typical safety net installation
[19](#__RefHeading___Toc21847119)

FIGURE 4: Saftey net installed within historic structure
[20](#__RefHeading___Toc21847120)

FIGURE 5: Net construction detail [21](#__RefHeading___Toc21847121)

FIGURE 6: Split set rock bolts [22](#__RefHeading___Toc21847122)

FIGURE 7: Rock drill and associated accessories
[23](#__RefHeading___Toc21847123)

FIGURE 8: Ridged safety exclosure 22

FIGURE 9: Bat gate with square tubing [27](#__RefHeading___Toc21847125)

FIGURE 10: Angle-iron bat gate [28](#__RefHeading___Toc21847126)5

FIGURE 11: Bat gate construction detail
[29](#__RefHeading___Toc21847127)6

FIGURE 12: Cupula style bat gate [31](#__RefHeading___Toc21847128)

FIGURE 13: Owl compatible fence [34](#__RefHeading___Toc21847129)

FIGURE 14: Saftey net in historic setting
[36](#__RefHeading___Toc21847130)

FIGURE 15: Historic mine structures [39](#__RefHeading___Toc21847131)

FIGURE 16: Aerial tramway, Keane Wonder mine
[43](#__RefHeading___Toc21847132)

**EXECUTIVE SUMMARY**

This plan and Environmental Assessment lays out the anticipated future
of the Abandoned Mineral Lands (AML) program in Death Valley National
Park. The AML plan consists of five parts:

1\. Inventory of AML sites

2\. Hazard Safety treatment

3\. Cultural resource preservation

4\. Wildlife resource preservation

5\. Mitigation of impacts to park resources where appropriate

An environmental assessment of this plan is included in Appendix F

**DEATH VALLEY NATIONAL PARK**

**ABANDONED MINERAL LANDS MANAGEMENT PLAN**

**2003**

# INTRODUCTION

This plan and Environmental Assessment (EA) are designed to document the
park Abandoned Mineral Land (AML) Program and to subject it to NEPA
evaluation. This plan and EA address the long-term management of the AML
program. The plan represents the park's proposal for the continuation of
the existing program and, if approved, it will be implemented. The no
action alternative, the description of the affected environment, the
analysis of possible impacts, and other portions of the EA are contained
in the Appendices.

## Purpose

The purpose of this plan is to describe measures for managing AML sites
and their associated features. This includes the mitigation of health
and safety issues associated with the sites as well as the stabilization
of historic structures within the boundaries of Death Valley National
Park, insuring compliance with NPS regulations, and establishing uniform
planning and management procedures for the remedial treatment of these
sites. This plan is further designed to achieve compliance with other
federal safety regulations and policies. The goal of this AML Plan is to
describe and provide for the execution of NPS administrative
responsibilities and to allow park managers to systematically address
these issues.

This plan is part of an evolutionary process. It will continue to be
revised as issues, conditions, technology, available information, and
regulations warrant. Whenever substantial changes or improvements are
made to this plan or to the park's AML program that would substantially
affect the environment, a supplemental EA will be prepared, and
subjected to the NEPA process.

For the purpose of this document, abandoned mineral lands are defined as
those mineral (mining) lands or sites for which no responsible party can
be identified. Subsequently management responsibility falls to the NPS
for mitigating health and safety hazards and remediating environmental
impacts associated with them to a practicable extent. AML sites are
defined as any physical mining feature (e.g. prospect pit, shaft, adit,
tunnel, quarry or open pit, including abandoned sand and gravel
operations; highwalls; mine waste dumps, hazardous waste sites
associated with mining; and appurtenant structures, equipment, and
access roads). Due to the descriptive nature of this document
definitions of mining terms are illustrated in Figure 1 and listed in
Appendix A.

## Management Authorities

NPS and other management authorities governing the administration and
management of AML lands are located in The Secretarial Standards, NPS
Management Policies (2001), NPS Draft DO-13, DO-41, DO-50, NPS-77
(Disturbed Land Restoration and AML Section *in draft*), WR-085, 29 CFR
parts 1910 and 1926, conformance with other federal land management
agency (BLM and USFS) prescribed AML policies and procedures, the
California Desert Protection Act (PL 103-433), the Wilderness Act (PL
88-577), Section 106 of the National Historic Preservation Act, Advisory
Council on Historic Preservation Statement of Policy, NPS National
Wilderness Steering Committee Finding 1 and Recommendation 1.

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### Secretarial Standards

The Secretary of the Interior's *Standards for Rehabilitation and
Guidelines for Rehabilitating Historic Buildings* contains information
and guidelines for advising Federal agencies on the preservation of
historic properties. These guidelines were drafted for historic
properties listed, or eligible for listing, in the National Register of
Historic Places. Although most of the historic mining structures in
Death Valley National Park have not been evaluated for the criteria for
listing in the Register, they to do have an elevated local historical
significance in the context of recording the mining history of the area
and the West. Therefore, these structures are accorded similar
management consideration as if having listed status regarding
stabilization work or any emergency stabilization they may require. For
the purpose of this planning document, the term historical mining
structure is in reference to its ***local*** historic significance
within the context of the park's mining history and not in reference to
its **National Register status or eligibility**.

### NPS Management Policies 2001 provides the following additional instruction:

## 

The NPS Management Policies 2001 provides the following additional
instruction. All bracketed \[ \] citations refer to NPS Management
Policies 2001.

> "NPS managers must always seek ways to avoid, or to minimize to the
> greatest degree practicable, adverse impacts on park resources and
> values." \[1.4.3\]
>
> "The 'park resources and values' that are subject to the no-impairment
> standard include: The park's scenery, natural and historic objects,
> and wildlife; . . . scenic features, natural visibility, both in
> daytime and at night; natural landscapes; natural soundscapes and
> smells; water and air resources; soils; geological resources;
> paleontological resources; archeological resources; cultural
> landscapes; ethnographic resources; historic and prehistoric sites,
> structures, and objects; museum collections; and native plants and
> animals." \[1.4.6\]

### NPS Draft Director's Order DO-13 Environmental Leadership

The draft Director's Order 13 on Environmental Leadership offers a broad
vision of comprehensive resource protection:

> "Landscapes will be managed with biodiversity and environmental
> stewardship as primary goals. The NPS will protect and restore, where
> feasible, natural and cultural resources under its stewardship through
> comprehensive environmental compliance and the use of ecologically
> protective resource management and planning strategies." \[Draft D.O.
> 13 Environmental Leadership\]

### NPS Director's Order DO-50: Abandoned Mine Safety

Chapter 30 of NPS-50, "Loss Control Management Guideline," provides
directions for the mitigation or elimination of public health and safety
hazards associated with AML features and sites, and for the protection
of park employees who come into contact with them. N PS-50 AML program
requirements include the completion of inventory of all AM Ls, the
development of an AM L mitigation plan, soil and groundwater sampling,
rescue contingency planning, monitoring, and interpretation. NPS-50
delineates the responsibilities of various divisions and park personnel
to ensure adequate safety at these sites.

### NPS-77: Natural Resources Management Guidelines

NPS-77 is a comprehensive guideline on natural resources management,
providing guidance to ensure that natural resource management activities
comply with federal laws and regulations and Department of the Interior
and NPS policy. NPS-77 also provides the information necessary to
design, implement, and evaluate a comprehensive natural resources
management program.

The management of natural resources and values, resource uses, planning,
and program administration and management are covered in NPS-77. The
section entitled "Mineral Management" states: "...the NPS must, to the
extent possible, mitigate or eliminate safety and environmental hazards
associated with abandoned mineral lands. Each park should maintain an
inventory of AML sites, including safety hazards and impacts to natural
and cultural resources which will provide the basis for decisions and
treatment priorities and corrective actions."

### WRO-085 Management of Abandoned Mineral Lands (AML)

WRO-085 requires the completion of an AML Management Plan to establish
uniform planning and management procedures for remedial treatment of
AMLs. According to WRO-085, under Phase I, AML sites should be
inventoried or surveyed and classified in Categories ranked 1-5, which
rate degree of risk, accessibility, biotic factors, and safety features.
Under Phase II, the sites should be ranked according to the degree of
hazard posed. Under Phase III, an action plan should be developed along
with an implementation schedule.

### 29 CRF Parts 1910 and 1926 - OSHA

These laws, the Occupational Health and Safety Act (OSHA), define
occupational safety and health programs required of employers who are
engaged in general industry and construction activities. AML activities
within Death Valley National Park will comply with those standards and
requirements. This plan addresses the AML specific requirements of
underground mine entry protocols and the required use of personal
protective equipment (PPE). Additional OSHA and Departmental
requirements are addressed in separate Death Valley National Park plans
for Health & Safety, Hazard Communication, Hazardous Waste Management,
Hearing Conservation, and Respiratory Protection.

### California Desert Protection Act (PL 103-433).

The California Desert Protection Act of 1994 (CDPA) enlarged the
reservation boundaries by 1.3 million acres, abolished the former
National Monument status, established the National Park, and designed
approximately 96% of its lands as wilderness. The Law further declares
it to be the policy of the Congress that these lands are set aside ***to
protect and preserve*** historical and cultural values of the California
Desert associated with ancient Indian cultures, patterns of western
exploration and settlement, and sites exemplifying ***the***
***mining***, ***ranching and railroading*** ***history of the Old
West***.

### National Historic Preservation Act, Section 106

Section 106 of the Act mandates that federal agencies take into account
the effects of their actions on properties listed or eligible for
listing in the National Register and give the Advisory Council on
Historic Preservation a reasonable opportunity to comment. It does not
specify the preservation of such properties. It does require that their
historic or prehistoric values, whether they are of local or national
significance, be considered in weighing the benefits and costs of
federal undertakings, in order to best serve the public interest.

### National Park Service National Wilderness Steering Committee, Finding 1, Recommendation 1 

This document provides guidance for the management of historic
structures in Wilderness areas. By way of illustration, the following
information has been extracted from that document:

> **Question:** Does the Wilderness Act supercede or override historic
> preservation laws, such as the National Historic Preservation Act and
> the Archeological Resources Protection Act?
>
> **Answer:** No. Section 4 of the Act makes this very clear. Section 4
> (a) states "The purposes of this Act are hereby declared to be within
> and supplemental to the purposes for which national forests and units
> of the national park and wildlife refuge systems are established and
> administered . . ." As declared in the 1916 Organic Act "the purpose
> \[of national park system units\] is to conserve the scenery and the
> natural and historic objects and the wild life therein . . ." As
> stated above, for units of the national park system this idea of being
> "within and supplemental" was reinforced in Section 4.(a)(3) and the
> historic preservation laws were specifically cited.

**Question:** Do cultural resource laws supercede or override the
Wilderness Act?

> **Answer:** No. Managers must comply with all of the cultural resource
> laws on all areas in all units of the National Park System, whether
> they are Wilderness or not. If the cultural resources are in a
> Wilderness area, however, the provisions of the Wilderness Act must
> also be complied with when conducting cultural resource activities,
> such as inventory, monitoring, treatment, and research.
>
> **Question:** Do historic structures and other cultural resources need
> to be removed from Wilderness areas to protect Wilderness values?
>
> **Answer:** No. As stated above, Congress specifically included
> cultural resources as part of Wilderness. In Section 2 (c), Definition
> of Wilderness, Congress stated "an area of wilderness is further
> defined to mean in this Act an area of undeveloped Federal land . . .
> which (1) *generally appears* to have been affected *primarily* by the
> forces of nature, with the imprint of man's work *substantially*
> unnoticeable \[italics added\];". The qualifiers in this portion of
> the sentence are significant. The area does not have to be "pristine"
> or "pure." It does not have to have no imprint from human activities.
> Simply put, it only needs to *appear* that way with the human imprint
> *substantially* unnoticeable. A landscape can have hundreds of
> prehistoric and historic archeological sites on it and still appear to
> have been affected primarily by the forces of nature. Even a
> maintained historic structure could be substantially unnoticeable if
> it were surrounded by many acres of land that did not contain other
> structures.
>
> In addition, as declared in Section 2(a) of the Act the intent of
> Congress was to stop the "increasing population, accompanied by
> expanding settlement and growing mechanization" from "occupy\[ing\]
> and modify\[ing\] all areas within the United States". As noted above,
> Congress also clearly included historic resources within Wilderness
> areas. With this understanding, the prohibition on structures and
> installations in wilderness areas in Section 4(c) clearly refers to
> modern, not historic, structures. This does not mean that all historic
> structures in Wilderness areas have to be maintained; but it also does
> not justify the assertion they all have to be removed.

### Other Land Management Agency Policies and Procedures

Information acquired from interagency mine safety training courses
provide insight and direction relative to compliance measures within
those organizations, specifically the BLM and USFS. This plan and the
measures it outlines assure compliance with similar measures developed
by those organizations as well as the aforementioned directives.

## AML Program Background 

Death Valley National Park is a unique and diverse landscape in many
ways. Among those is its singular distinction as the most significant
exposed geology unit within the National Park Service. It's highly
complex, extensively altered, well-exposed geology has contributed to
the formation, exploration, and discovery of a large number of mineral
occurrences. Those mineral occurrences have attracted the attention of
prospectors, miners, and mining interests dating back to 1848.

Early Euro-American emigrants first discovered gold and silver in the
Death Valley area in 1848. From then until 1872, an informal, generic
"Miners Law" governed the development of minerals. It was applied by
Euro-Americans familiar with the administration of mineral claims and
mining in Europe and other parts of the rapidly expanding United States
of America. Similar local laws were adopted in other parts of the
American West. The Miners Law provided for the organization and
protection of freelance miners. It provided for the establishment and
recognition of defined mining districts and a definition of acceptable
forms of mining claims and activities. It provided a method of recording
claim ownership, protection, and law enforcement at rudimentary levels.

The General Mining Law of 1872 established the first federal regulation
of mining in the American West. Under provisions contained in that
legislation, "Mineral Entry," the staking of new mining claims was
permitted on public lands. The Mining Law of 1872 further governed the
administration of lands included within Death Valley National Monument
from its establishment in 1933, until passage of the Mining in the Parks
Act in 1976 (PL 94-429). After passage of that act, further mineral
entry was denied and mining was permitted only on prior, existing, valid
claims through a regulatory permitting process (called the Plan of
Operations) and only after appropriate plan review and NEPA
documentation.

The legacy of Death Valley's extensive mining history comprises an
estimated 6,000 individual abandoned prospect pits, exploratory shafts,
adits, both open pit and underground mines herein collectively referred
to as AML sites. These historic mining features have associated with
them various forms of associated and often redundant access routes, mine
support surface structures such as mine shaft collar supports, adit
(tunnel) portal sets, windlasses, headframes, ore bins, rail tramlines,
aerial tramways, a variety of ore processing structures and mills,
assorted buildings/structures, and residences. The current park
inventory lists 174 cabins (including sites), 14 aerial tramways, 31
mills (including arrastras), and 41 miscellaneous mine structures
including but not limited to headframes, ore bins, a monorail, forges,
collar sets, and corrals). Collectively, these features preserve the
history of the evolution of mining technology, occupation, and
development of the West and Death Valley, as noted in the California
Desert Protection Act and park enabling legislation. Both individually
and collectively, these features constitute the fabric of the history
and evolution of mining in the Death Valley area and provide for the
enjoyment and appreciation of visitors.

The majority of these historic structures are of wood, all of which are
now greater than 50 years old, and many are approaching 100 years of age
or more. Much of that wooden construction material has weathered and
deteriorated to the point it can no longer perform its intended purpose,
much less continue to support its own weight. Unfortunately, a large
percentage of these historical mining structures in the park, and
elsewhere in the West, have been scavenged, salvaged, relocated,
removed, vandalized, destroyed, or simply collapsed (Figure 2).
Therefore, the few remaining standing structures have an **elevated
local historical significance**, providing a record of the mining
history of Death Valley, and are accorded such recognition by park
management.

One of the expressed long-term objectives of the park's resources
management plan is to protect and preserve those few remaining historic
structures and features for the continued enjoyment of park visitors.
This management goal has been further emphasized and enforced by passage
of the California Desert Protection Act (CDPA) of 1994, Public Law
103-433. The CDPA also designated certain lands in the California Desert
as wilderness and established Death Valley and Joshua Tree National
Parks and the Mojave National Preserve.

The CDPA states that its intention is to secure these lands for the
American people of this and future generations as an enduring heritage
of wilderness, parks, and public land values in the California Desert.
The law declares that these lands are to be set aside to protect and
preserve **historical and cultural values** of the California Desert
associated with ancient Indian cultures, **patterns of western
exploration and settlement, and** **sites exemplifying the mining,
ranching and railroading** **history of the Old West**. The abandoned
mine sites contained in Death Valley National Park comprise a
significant portion of that mining heritage and historic value, and are
accordingly provided preservation status.

The presence of these remains of mineral exploration and development in
Death Valley constitutes both a record of the history of that period for
visitor enjoyment and presents clear and identifiable hazards to the
health and safety of visitors and staff. The open, unguarded prospects
and mine openings provide unusual attractions that are frequently
investigated by rapidly increasing numbers of park visitors. The AML
features present varying levels of **safety hazards** ranging from
minimal to life threatening. Responsibility for the mitigation of the
hazards posed by these sites along with the preservation of their
structural attributes now resides with the NPS.

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# 

## AML Program 

The NPS established a formalized Abandoned Minerals Lands (AML) program
at Death Valley National Park (formerly Monument) in 1984. The program,
then know as Mine Safing, was created to provide for the management and
mitigation of the health and safety hazards and to address other issues
arising from the presence of the abandoned historical mining features,
while assuring their preservation. The program has continued to develop
and evolve over time.

The expressed purpose of the current program is fivefold. These five
items correspond to the five main sections of the plan to follow. Its
multiple purposes are to:

> **I.** Complete a park-wide survey of AML sites, including
> categorizing safety hazards and compiling planning and treatment cost
> estimates,
>
> **II.** Provide a satisfactory level of continuing treatment or
> mitigation of the health and safety hazards presented by those
> historic mining features while the survey work is being conducted,
>
> **III.** Stabilize, and thereby preserve, the few surviving mining
> related structural features, following approved Historic Structure
> Preservation Guides or equivalent guidance for continued visitor
> enjoyment and appreciation,
>
> **IV.** Provide for the continued occupation of these sites by
> wildlife, both species of special concern (notably certain bat
> species, and desert tortoise) as well as more common animal species to
> the best of our ability,
>
> **V.** Mitigate impacts to the park's natural, scenic, and wilderness
> resources, including site restoration activities, where appropriate
> and feasible.

# AML Survey

A pre-survey inventory of AML sites within the boundaries of the
National Monument was completed in 1992. That project involved
extracting available information on AML sites identified on USGS
topographic maps. A parallel survey was completed by the state of
California in 2001.

An earlier pilot project was conducted by NPS GRD personnel along with
that inventory work. The test project was conducted over the "Nevada
Triangle" area of the park, where a field survey was made of all of the
AML sites that could be physically identified. That survey indicated
that approximately 80% of the total AML sites could be identified by the
data available from the topographic maps. That work also resulted in an
estimation of nearly 5,000 AML sites within the former national monument
boundaries.

Approximately 1.3 million acres of new lands were added to the former
monument in 1994 to create Death Valley National Park. Those new lands
were of similar character in regard to the nature and extent of AML
sites. Thus the enlarged park area is estimated to contain in excess of
6,000 individual AML sites.

This extreme number of AML sites is virtually unmatched within the
National Park Service and creates an unparalleled management difficulty
for Death Valley National Park. Given this extraordinary number of AML
sites, it has previously been beyond the park's ability to perform a
systematic physical survey, of each of those sites. While the inventory
was seen as an effective precursor to completing a formal survey, the
park's ability to address this issue has been restricted by funding and
personnel limitations. Nevertheless, formal AML survey work was
completed for the Skidoo Mining District on Tucki Mountain, the largest
concentration of AML sites in the park. AML survey work will be further
advanced through the Physical Sciences (Minerals Management/Geology)
Technician staff position filled in late 2001 and be augmented by the
park AML crew and VIPs. It is anticipated that completion of the project
will require many years.

An AML site field survey form (see Appendix B) has been generated for
use in the park. The forms incorporate guidelines generated in NPS-50
and WRO-085 and those generic ones recommended by GRD which were adapted
for Death Valley specific applications and issues. The forms prompt
field survey personnel for descriptive information necessary to
describe, evaluate, categorize, and document each of the AML sites. The
survey form is designed to obtain physical site descriptive data and
photo documentation. Biological and cultural data is obtained by those
subject matter specialists and appended to the AML survey. The form has
recently been revised to include information for input into the FMSS
program.

The safety hazard categories for the AML sites are classified as
follows.

## AML Safety/Health Hazard Categories

> **Category 1**: AML sites easily accessible by visitors and staff that
> present a serious or life threatening hazard to public health and
> safety in the form of hazards from falls, falling objects, highwalls,
> explosives, or pollution, etc.
>
> **Category 2**: AML sites easily accessible by visitors and staff that
> contain unique cultural or natural resources requiring protection.
>
> **Category 3**: AML sites presenting serious hazards to the visiting
> public that are not readily accessible.
>
> **Category 4**: AML Category 1 or 2 sites that have had remedial
> action completed. Sites that need to be monitored on a regular,
> probably annual, basis to ensure that the closure remedies have not
> been compromised.

**Category 5**: All other AML sites.

## Definition of AML Hazards

The AML hazards are divided into principal two categories: surface (open
pit and quarry) and underground. This division is based on the type of
mining activity or methodology that produced the feature. For Example,
although shaft collars, glory holes, and adit portals appear at the
surface their construction arose from the pursuit of underground mining
methodologies.

### Surface Hazards

Open Pit or quarry mine workings located at the surface may have
dangerous high walls, cuts, fills, and or weakened rock that present
safety hazards to visitors and park staff. Such hazards may involve
persons falling off steep slopes or debris falling from the slope, thus
endangering people below. Other surface hazards at mines include
potentially unstable structures, such as buildings, headframes,
millsites, and ore-loading facilities.

A preferred method of minimizing hazards from highwalls and cuts
involves reducing the degree of the resultant artificial slope to a
gradient where falls would not cause serious injury, or where slope
materials are stable and not prone to failure. Determination of the
gradient\'s \"stability\" requires specialized rock mechanic skills. The
park's resident mining engineer is responsible for conducting or
insuring the completion of such determinations.

Slope gradients may be reduced by: (1) backfilling (placing material at
the base of the slope); (2) cutting (pushing material from the top to
the bottom of the slope); or (3) benching (creating a series of steps
across the slope). Site conditions or availability of working materials
may warrant combinations of these techniques. Blasting and heavy
equipment are tools typically employed for reducing highwalls and
slopes. Environmental damage resulting from the employment of such
equipment generally precludes its application within the park.

During the planning for slope reduction work, the effects of other
surface processes need to be considered, such as fluvial processes, on
the reconfigured slopes and on surrounding undisturbed areas. For
example, appropriately designed channels or diversions may be required
to ensure that surface erosion is not a significant factor in the
post-work recovery of the site.

Slope reduction projects are normally costly undertakings requiring
advanced mining knowledge and skills. These types of projects generally
exceed park funding and technical capabilities, and for the most part,
are not considered environmentally or economically viable alternatives.
At some AML sites there are areas that have naturally been reclaimed
through time, and heavy equipment access and operations, for instance,
would undo a century or more of natural reclamation.

Other measures to reduce surface mine hazards include fencing and
signing. However these are generally considered to constitute
temporary/stopgap measures. They are generally initially less expensive;
however, fences and signs require periodic maintenance, are prone to
vandalism, and do not reduce or mitigate the actual hazard. They do
however, reduce or eliminate justification for awarding substantive
punitive damages during court proceedings, should they arise.

### Underground Hazards

Hazards associated with underground mines may include persons falling
into glory holes, pits, shafts, stopes, or winzes; cave-ins from
unstable rock or rotten mine support timbers; deadly gases, oxygen
deficiency; explosives; unstable underground structures (e.g., timbers,
ladders, and winze covers), wildlife occupants, and others (Figure 1).
Underground mine features such as stopes, winzes, and glory holes may
have significant associated collapse or subsidence hazards. Even
relatively shallow workings may have hazards similar to those that are
described above.

Appropriate mitigation measures must be applied to these hazardous
abandoned mine features. Selection of the most appropriate mitigation
option for underground mines depends on three important considerations:
visitor safety, historical significance, and wildlife adaptations.

### Shafts and Inclines

Shafts and inclined shafts are vertical or steeply inclined mine
features constructed to provide access from the ground surface to buried
ore deposits. Shafts and inclines constitute the most hazardous of mine
openings because they draw a visitor's attention and generate the desire
to investigate. People frequently approach the edge of the openings to
inspect them more closely being curious about their depth. Accidents
associated with them generally result in serious injury or death.
Responding emergency personnel are exposed to the same levels of risk.
Surface ground/rock conditions associated with these features are often
deceiving and lure unfamiliar and untrained visitors and staff into
dangerous, unstable conditions. The surface opening may be undercut from
rock falls within the shaft. When a person's weight is added to the
undercut surface it can fail, dropping them into the shaft. Frequently
the surface surrounding the opening has "sluffed off" into the shaft,
forming a steep funnel-shaped depression or ant lion trap-like feature.
Individuals approaching too close to such features can be dragged into
the shaft by sliding down the steep slope.

These surface expressions of underground mine features are often fitted
with timber, surface collar, ground supports that have now deteriorated
and no longer provide support or protection. Similarly, interior
timbers, supports, and ladders create a false sense of security and lure
the unsuspecting individual into dangerous unstable conditions.

### Adits and Tunnels

Adits and tunnels are horizontal mine openings providing access to
buried ore deposits or constitute exploratory mine features. They are
the most common features and provide the bulk of hazardous conditions
listed in the Underground Hazards section above. They may have unstable
openings, timber supports, and internal hazardous features such as
winzes, stopes, ladders, and ore chutes.

### Stopes

Stopes are the open voids left in underground mine works where ore
(mineral) bodies have been removed. Stopes may be overhand (upward) or
underhand (downward) constructed underground excavations (Figure 1).
Their size may vary considerably depending on the nature and extent of
the ore deposit or ore shoot and intended purpose. Over-hand stopes that
breach the ground surface are generally identified as glory holes. Large
stopes that have been mined near the surface or that have actually
breached the surface to form a glory hole are highly deceptive as they
generally are associated with undercut and weakened surface conditions.

### 

### Winzes

Winzes are internal mine shafts providing man-way and or materials
hoisting connections between working levels. They are commonly equipped
with wooden ladders that often have deteriorated over time. The ladders
commonly appear sturdy but fail when a person's weight is placed upon
them. They constitute one of the worst underground hazards, attracting
unsuspecting persons who climb up or down them and then fall when the
rungs collapse. Winzes were often fitted with wooden covers that
provided safety for personnel working around their openings when the
mine was operating. Those covers deteriorate over time and are often
obscured by other debris. Unsuspecting persons walking on them are
subject to falling through them and down the winze with catastrophic
results.

All of these mine features require specialized knowledge and skill to
enter them with relative safety.

# Mitigation of Health and Safety Hazards

## Definition of issues

Mitigation of the health and safety hazards and problems associated with
AML sites can be more systematically addressed after completion of the
AML survey. Completion of the survey, its assessment, and determination
of scope and budget requirements will permit preparation of funding
requests to more systematically address the issue. Given the scope of
the problem and the park's ability to address it, it will be many years,
if ever, before all health and safety issues can be addressed. In the
interim, the program will continue to systematically address the more
hazardous AML sites while simultaneously dealing with cultural and
wildlife habitat issues.

Initially, a determination of the relative historical value of each site
or a programmatic decision will be generated. For most Death Valley AML
sites, it is assumed that their relative historical significance will
result in their protection and stabilization rather than their removal
and reclamation. Mitigation techniques applied to underground mine
closures often require special adaptations to preserve the character of
locally significant cultural resources. A best effort will be made to
determination of the wildlife habitat value of the sites scheduled for
hazard mitigation fieldwork will be made or a programmatic decision
rendered as deemed appropriate, particularly for federal or state-listed
threatened and endangered wildlife species such as the desert tortoise
and several listed or sensitive bat species. Ultimately, the planning
process will result in applying the most appropriate mitigation strategy
in the context of achieving the park's management goals. The program
will not delayed or interrupted solely due to wildlife considerations.

The execution of this portion of the AML program at DEVA has
necessitated the full-time services of dedicated personnel, resulting in
the establishment of a park AML Crew. The crew and its activities are
administered by the park's mining engineer and are located in the
Resources Management Division. Death Valley NP, unique within the
National Park Service field units, is authorized to staff the
professional services of a qualified, experienced, mining engineer. This
position was established to provide advice, recommendation, and
assistance to the Superintendent on mining, minerals management, and
related issues. Supervision and direction of the park AML program has
been vested in this position.

## Authorized Underground Mine Entry 

# 

Entry into both underground and open pit abandoned mine features
presents personnel safety issues not otherwise encountered in other NPS
programs. Personal and personnel safety is of the utmost importance in
this program and **will** precede all other factors and considerations.
Park policy permits only appropriately trained, equipped, and certified
personnel to conduct underground activities. The park AML crew consists
of qualified, experienced underground miners or specially trained
personnel. Specially trained personnel may be certified for this work by
virtue of their approved training, apprenticeship, and ability.

The AML crew and the mining engineer are additionally experienced in
working in abandoned mines. The mining/geology physical science
technician is especially trained in underground safety and entry
procedures to participate in this work. These individuals are the only
certified park staff members authorized to regularly enter abandoned
mines in groups of two or more, to lead non-qualified individuals on
biological, historical resource surveys, or group tours of selected mine
facilities, with the exception of the Eureka Mine at Providence Hill,
Harrisburg Flats. The Eureka Mine has been especially adapted and
safeguarded to permit safe visitation. It is open to public inspection
during non-hibernation periods for resident bat populations.

The mining engineer is the designated park AML Field Operations Manager
(FOM) and approves all personnel underground qualifications and mine
entries in the park through completion of the Job Hazard Analysis (JHA)
form (Appendix C). The AML staff members, under that supervision,
constitute park-approved Qualified Safety Leaders (QSL) who can lead
approved underground mine entry projects in the park by untrained,
inexperienced, an uncertified individuals. The mining engineer/FOM will
also provide park certification for other experienced and qualified
individuals for underground mine entry and as QSLs within DEVA, such as
mining or geologic specialists from the NPS Geologic Resources Division,
other NPS units, universities, non-governmental agencies, and
organizations.

Underground entry by non-NPS personnel will be administered by a
revocable, time limited research permit process and or under direct
contract services to the park. Permit approval will be based on
submission, review, and approval of individual abandoned underground
mine entry training and or experience provided by the applicants. As a
general rule in Death Valley National Park, vertical mine shafts are
never entered by any NPS personnel due to significant numbers of
overlapping hazardous conditions. Authorization for non-NPS personnel to
engage in those high-risk activities will not be granted lightly. While
biological (bat), botanical, and cultural surveys provide desirable
research data, personnel safety is paramount and will remain the
deciding factor. These types of surveys will be conducted only when they
can be completed relatively safely and they will necessarily be forgone
when the risk to personal safety is determined to be excessive. In
general, bat surveys will be conducted externally and no underground
surveys will be done except in sites with a high probability of having
significant use by hibernating bats and then only with the assistance of
an approved QSL. As the bat gate will be the preferred method of mine
closure, bat surveys may not always precede mine closures if personnel
and scheduling conflicts exist.

In nature, every mineral occurrence or deposit is unique although
similar types of deposits may share some commonalties. The mines
associated with these mineral deposits are similarly distinctive,
although they too may share common features. This premise is true of ore
deposits and mines in a particular region such as that of Death Valley.
Importantly, the Death Valley National Park mining engineer and AML crew
are familiar with the types of mines located in the park. This
familiarity and knowledge of the type and nature of local mines is
important to the safety of the AML staff. Under this AML program the
mining engineer and crew follow prescribed abandoned mine entry
protocols that have been developed, approved, and subscribed to by other
federal land management agencies dealing with similar AML issues. The
Death Valley National Park abandoned mine entry protocols are provided
in Appendix D.

## AML Mine Safing (Closure) Procedures

## 

## The following provides a discussion of methodologies commonly employed to mitigate hazards posed by AML features and dialog of their possible application in Death Valley NP. 

## Irreversible Methods

### Back-Filling

Back-filling generally requires either mechanical or manual labor
earth-moving processes although hand methods can be employed in some
limited instances. Sufficient back-fill materials must be present or be
imported to complete the work. Importation of materials can result in
additional environmental impacts and added costs. If they are to be
utilized, a determination is required as to the suitability of their
use. Importation of backfill materials can result in the undesirable
introduction of exotic plant species, rock or soil types. Preservation
of mine historic features may preclude their use. When manual labor is
inadequate to perform the necessary work, mechanized equipment is
required. Ingress, egress, and operation of such equipment may result in
unacceptable environmental impacts. As 96% of the park is designated
wilderness, mechanically supported installation methodologies are
unsuitable in many instances.

### Polyurethane Foam Plugs

For deeper shafts where hand backfilling is impractical, polyurethane
foam (PUF) plugs can be formed near the collar of the shaft and the
remainder of the shaft backfilled with waste rock available from the
site or imported to the site. PUF plugs are formed from two (hazardous)
liquid chemical components that, when combined, undergo a catalytic
(exothermic) reaction, causing a materials expansion 30 times their
original volume. This chemically expanded material then sets into a
rigid mass or plug within minutes having a considerable weight-bearing
capacity. When properly constructed, a PUF shaft closure can easily
support the weight of a large vehicle. The construction materials can be
backpacked into a site or transported by truck or helicopter, having
virtually no adverse impacts on the site or the access to it. PUF is
considered to be irreversible in that it is almost impossible to remove
the foam, which adheres directly to the surrounding rock. If removal is
attempted some evidence of its use will always remain at the site. The
PUF is inert and has a closed cell structure that makes it impervious to
acid mine drainage. Where drainage is possible, a drain system must be
incorporated into the closure design to prevent hydrostatic pressure
buildup that could compromise the plug. PUF is subject to ultraviolet
light deterioration and vandalism. Covering or backfilling is required
to protect it from those conditions. If ignited the PUF material will
generate extremely hazardous and toxic gases. If improperly mixed the
component chemicals can auto-ignite.

### Blasting

Although blasting has been used to close some mine openings, generally
this method is unacceptable for numerous reasons, i.e. incomplete
closures, over break, or additional surface disturbance and it is not
further discussed herein.

## Reversible Methods

### Bulkheads and walls

Bulkheads are wall-like constructs that result in physical barriers to
human entry into adits and tunnels (horizontal openings). In the mining
industry they are commonly made of timbers and dimensional lumber
materials. Native rock is a common construction material for this
purpose at AML sites; either dry set or mortared. Bulkheads can also be
constructed of steel or other construction materials. Unprotected or
disguised, they are subject to vandalism. Often they are obscured by
coverings designed to appear as mine collapses.

### Fencing

Fencing was an early exclosure methodology employed in various AML
management programs. Either barbed wire or chain link fencing was used
to establish barriers to human entry, generally to mine shafts. History
has subsequently proven these devices are highly subject to vandalism,
are difficult to maintain, and constitute less effective deterrents.
From a purely legal standpoint, they do draw an individual's attention
to the site that prevents unintentional entry to a hazardous condition
and constitute a physical barrier that must be physically defeated or
negotiated by an intruder. Hence, they are usually effective in limiting
the award of compensatory damages. Generally, the usefulness of these
devices is minimal and will no longer be employed except in exceptional
circumstances, such as adaptations for barn owls (see wildlife
adaptations section below) or as provisional measures.

### Safety Cable Nets

The park's current AML program represents the evolution of earlier
concepts of installing a variety of mine closure devices. Those devices
reduced or eliminated injury or the death of park visitors resulting
from their inspection and visitation of the thousands of abandoned mine
openings left in the park. The unfortunate death of a park visitor in
one part of the Keane Wonder Mine complex in 1984 resulted in the
formulation and application of a hazard abatement methodology to
preclude visitor entry into mine openings. The early concept was based
on a seed idea developed by staff from Harper's Ferry on assignment in
the park to assist with historic mine structure stabilization work.
Their idea was to employ a steel net-type device to prohibit human entry
into abandoned mines. The concept lead to the construction of woven
steel cable net devices, in-park, that were subsequently installed in
mine openings (Figure 3). The concept was to continue to allow visitor
appreciation of the mine feature, provide for uninterrupted air passage
in the opening, and allow for the continued passage of small animals
that might use the openings for habitat or shelter, knowledge of bat
occupation of mines had not arisen at that time. The process is
nondestructive, reversible, and compatible with historic structures
(Figure 4).

The process for the construction of the steel cable nets and their
installation passed through several stages of evolution and continues to
be improved through periodic modification. This process currently
involves the weaving of 7/32nds-inch, woven, seven-strand, galvanized
steel cable over a heavy-duty steel frame jig, resulting in a 7-½-foot
by 7-½-foot net with six-inch-square openings. The galvanized steel
cable has an extensive life in the dry desert climate and should last
considerably more than 100 years. The intersections of the cable strands
are joined together by two-part cable intersection clips secured with a
hydraulic press (Figure 5). These cable materials and associated
specialized tools are commercially available.

The completed cable nets can easily be adapted to fit a wide range of
mine opening dimensions. They can be cut to fit smaller and irregularly
shaped openings or they can be joined to form larger assemblages. When
properly installed, the net structures are extremely strong. When
properly anchored over a vertical mine shaft opening, they can safely
support considerable weight.

The nets are installed at the mine openings employing mining industry
split-set rock bolts (Figure 6). The rock bolts are designed for
underground rock support and lend themselves well to this application.
The rock bolts consist of tubes of high-quality, long-life, spring steel
of varying lengths, equipped with collar rings and tapered ends on the
opposite ends. The tubes are constructed with a slot along their entire
length that permits their compression. A 1 3/8^th^ inch hole of a
slightly smaller diameter than that of the tubes is drilled into the
rock at the mine opening. This is accomplished by using mine industry
standard, underground rock-drilling equipment (Figure7).

The operation of this equipment requires specialized training because
drilling into unsound or unsafe rock can result in disastrous rock
falls. The AML crew must perform careful location inspections and site
selections before initiating drilling operations. When warranted, the
mining engineer will pre-approve the drilling site after conducting a
site inspection. A square metal base plate with a circular hole opening
is inserted along the tube and is held in place by a collar ring. The
rock bolts are driven into place with the rock drill. The "tube" is
compressed as it is driven into the smaller diameter hole. The tube then
exerts a strong continuous outward force against the sides of the hole
over its length, making the split set bolt virtually impossible to
remove.

The rock bolts are positioned around the sides of the mine openings so
that they both stretch and hold the cable net firmly in place against
the rock. The position of any mine closure device is, without exception,
dictated by the prevailing rock conditions, and these siting
determinations will be made solely by the mining engineer or AML crew.

It is an operational parameter of the program to install any closure
device recessed or inset in the mine opening to access more suitable
rock drilling conditions, provide shade shelter for anyone requiring it
during periods of summer heat, and render the installation less visible
and intrusive. Mines having multiple openings and air circulation can
emit cool refreshing air during periods of intense summer desert heat.
Combined with the shade provided by the recessed nets or gates these
constructs can provide emergency heat relief for humans and animals.
Drilling will be discontinued immediately and a suitable alternative
site selected if unanticipated or unacceptable rock conditions are
encountered. Once properly installed in solid rock, the rock bolts
cannot be removed without badly deforming or cutting them. More often
than not they cannot be removed at all. However, when cut off at the
rock surface for removal purposes little evidence can be detected of
their presence. They can be adapted to provide solid purchase in softer
ground or moderately fractured rock.

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The mine safety nets were employed widely throughout the former national
monument prior to the unit's elevation to National Park status in 1994.
The nets while strong and effective are subject to various forms of
vandalism. While the cable cannot be cut with standard bolt cutters, it
is possible to breach a net with other lesser-known techniques. Vandals
discovered the cable intersection clips could be forced to slide in
small increments along the smooth surface of the cable by exerting
excessive force upon them. Thus some nets, especially in adits, have
been stretched to allow forced entry through the deformed net aperture.

This situation can be overcome or corrected by brazing the net clips in
place with an oxygen-acetylene torch, thus preventing such distortion.
Nets tend to work well and escape vandalism where access is only by
foot. If they are installed where vehicular access is possible and tools
are readily available, they tend to be systematically vandalized and may
ultimately be defeated. Nets over shafts tend not to be vandalized.

### Rigid Metal Frame Exclosures

Nets are replaced with rigid metal frame exclosure devices when
systematic vandalism is probable or evident (Figure 8). These devices
have, in the past, been pre-manufactured under contract by commercial
steel fabricators. Future installations will predominately be fabricated
on-site, in the AML shop, or a combination of the two. On occasion it
may be desirable to utilize outside metal fabricators in some
specialized instances. Each device is individually tailored to fit its
intended site. The devices can be constructed of several types of metal
products including square or rectangular steel tubing or round rod
material. They will most often be constructed of angle iron, and
infrequently combined with extruded expanded mesh construction as in the
tops of cupolas. Much more has been written and is available on the
subject of bat gate construction, construction materials, and
methodologies than is appropriate for inclusion in this document. The
interested reader is directed to the web sites of: Bat Conservation
International, American Cave Conservation Association, Office of Surface
Mining -- Mid Continent Region, Colorado Division of Wildlife, New
Mexico Abandoned Mine Land Bureau, U.S. Fish and Wildlife Service, U.S.
Forest Service, and NPS Geologic Resources Division for additional
information and links to other informative sites.

![](media/image9.png)

These devices are currently being constructed of heavy-duty angle iron
constituting an adaptation of the American Cave Conservation
Association/Bat Conservation International, Inc. bat gate design. Strong
recommendation from biologists, low materials cost, and relative ease of
construction have contributed to the selection and current incorporation
of this design. Future variations based on technological advances are
probable.

These devices are installed using the same rock bolt technique as the
nets or steel pins can also be used. The frames are constructed with
protruding "wing" plates equipped with holes designed to accept the rock
bolts or pins. These types of devices have proven much more effective
against systematic vandalism. However with the development of more
powerful cordless electric tools and smaller more effective pneumatic
devices, they can become subject to intense vandalism as well. Means of
countering that vandalism are constantly being devised.

# Mine Closure Adaptations for Wildlife

*The primary objective of abandoned mine closures is to provide for the
safety of park visitors and staff*. A secondary objective of the mine
closure devices is to provide for the continued use of the openings by
small animals by maintaining unobstructed ingress, egress, and airflow.
Since early ventures with AML closures it has become increasingly
evident that design parameters to provide for wildlife require greater
attention and accommodation in the program. This has been underscored by
the increasing realization that large numbers of bat species are being
denied the use of their traditional roosting areas and are seeking these
artificial ground openings as alternative roosting sites.

The earliest net closures were not designed with the species in mind and
were not conducive to the unobstructed flight of bat inhabitants. Over
the years, a variety of modifications and alternative devices have
attempted to satisfy the bat's flight and roosting requirements. While
bats are currently the species of greatest concern, other often less
common, animal species also adopt mines as their habitats. It is the
objective of this program to provide reasonable accommodation for as
many wildlife species as possible. Every effort will be made to install
bat friendly closures on all abandoned mine adit and tunnel portals
scheduled for closure. The abandoned mine safety program will remain
sensitive and responsive to these wildlife management issues while its
primary focus remains visitor safety.

## Species of Special Concern

### Desert Tortoise

Desert tortoise use of abandoned mine openings has been noted in areas
of the southern California desert. However, no observations of this type
have been made at Death Valley NP. Nevertheless, special adaptations of
mine closure devices will be made in areas of suspected tortoise
habitat. These adaptations will consist of a flat metal plate at the
ground surface and a small gate aperture to facilitate tortoise passage.
Alternatively, the lowermost angle iron bar can be flush mounted or
recessed in the floor if conditions permit.

### Bats

A number of years ago it was recognized by specialized biologists,
concerned individuals, and organizations that increasing numbers of bat
populations demonstrated a preference for using selected abandoned mine
workings as roosting sites. The abandoned mines provide usable roosting
areas for bat populations otherwise displaced from their natural sites.
Although some sites tend to be used as either hibernacula or maternity
roosts, bats can use some mines, especially mines of more complexity, as
both. The biological and environmental significance of those occurrences
is obvious. Bats tend to be highly selective in the mine openings they
elect to use. The mine must meet apparently rigid standards for
temperature and air flow required by the bats.

Some controversy exists between biologists concerning the desirability
of bats using these man-made structures as artificial roosts.
Consideration of that controversy is beyond the scope of this plan. A
series of "bat gate" devices have been developed and evolved to both
preclude human entry into those sites and provide for continued use by
bat populations. As with the early net closures, these more bat-friendly
devices are in an evolutionary development stage.

Prototype bat gates developed early in the evolutionary process lacked
aesthetic features deemed desirable for application in the park. Thus a
pre-manufactured square tubing construction variation of a bat gate was
first employed at Death Valley National Monument now a national park
(Figure 9). The bat gates were built to locally prepared design
specifications under contact services and were transported as a
completed unit for field installation greatly reducing on-site labor
requirements and cost.

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The first installation met with reasonable success. Bat biologists
documented a 300% increase in the occupation by bats of the test site
after the first bat gate was installed in comparison to the pre-closure
survey data. Whatever the reason for the increase, the test project was
viewed as a success.

Following that experience, similar gates were installed in the park at
mines where bat habitat was documented and where bat gates were
recommended by the biologists. The completion of pre-closure bat surveys
at mine openings scheduled for closure often presents conflicts. At
times it has not been possible to accommodate the full expectations of
all parties. The early model bat gates employed a smaller man-way gate
in their design that permitted access by authorized personnel for
biological research. Current variations employ a removable bar to permit
authorized entry. Some later variations of design and installation
procedures were necessary to overcome observed design deficiencies when
the gates were subject to extreme vandalism.

Bat gate designs have evolved through time, both for improved vandal
resistance as well as to promote improved acceptance by bats. A widely
preferred design using heavy angle iron, developed by the American Cave
Conservation Association and endorsed by BCI, is most often used at this
time (Figures 10 and 11). Other designs also have merit. No doubt new
designs will emerge in time.

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When bats are observed using mine shafts, cupola-type construction is
employed to facilitate ingress and egress (Figure 12)**.** In the open
vistas of desert environment of Death Valley, the cupolas can constitute
undesirable visual intrusions in an otherwise open, unbroken landscape.
The State Historic Preservation Officers (SHPOs) have voiced objection
to using cupolas at historic sites where bats have not been documented
to use mineshafts. Thus unless bat occupation can be documented at a
particular site cupolas may not be as widely used in Death Valley as in
other areas. When bat occupation cannot be documented at an individual
site it is probable that a less visible, net type closure that is more
compatible with the historic features will be employed.

Preceding the advent of the bat gates at Death Valley National Park
adaptations of the earlier safety nets attempted to accommodate roosting
bats in Death Valley. It was originally observed that some more
aggressive individual bats would pass through the standard six-inch net
aperture. Bat biologists then under contract to the park noted that the
local native bats showed a preference for a minimum 12-inch horizontal
and six-inch vertical opening for flyway passage. That recommendation
has subsequently been revised to 24 inches horizontally and 5-¾ inches
vertically. Some of the nets installed in mines where bats were known to
occur were adapted to provide this size aperture. The adaptations met
with varying degrees of success. While some increase in bat habitation
was observed, the percentages were low. However, repeat biological
surveys were not conducted to fully document those casual observations.

Some success in increasing bat populations by installing just the safety
nets was evident. After Death Valley style mine safety nets were
installed at Coronado National Monument for visitor safety issues, an
unofficially estimated 1,200 bats used one site during their migratory
cycle. At the time of net installation, the monument was unaware of bat
use of the mines and no pre-closure biological surveys had been
completed, a situation common at that time. Those particular bats were
cactus pollinators capable of hovering flight and were uniquely adept at
negotiating the net openings. As knowledge of bat use of mines has
advanced, so has the technology to assist their occupation.

It has been determined that future (until other technological advances
are made) mine closure devices installed in Death Valley at adit and
tunnel abandoned mine openings will be of the angle iron, bat gate type
whenever possible. Where mine shafts provide significant habitat for
bats, the elevated/raised angle iron, or square tubing steel grate
closures (cupolas) may be used. Pending biological surveys have yet to
determine if or to what extent such mine shaft occupation by bats at
Death Valley may exist. When possible biological surveys will proceed
mine closure safety installations.

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##  Other Wildlife

While additional effort will be provided to accommodate species of
special concern, park staff will also be sensitive to use of abandoned
mine openings by more common wildlife species. In those instances where
such habitation is observed innovative technologies will be developed to
accommodate those species as well.

### Barn Owls 

It has been observed that nesting barn owls, among the more common
species, demonstrate a preference for utilizing mine shafts in some
parts of the park. Hitherto, the only known site that the owls had been
using for nesting purposes was at the Devils Hole detached management
unit. The owls for many years have used the openings provided by faults
and fractures of the rocks at Devil Hole as a location for their nests.
Increased observation of several mineshafts within the historic Bullfrog
Mining District in the Nevada Triangle portion of the park seemed to
verify that type of owl occupation. As the area was more frequently
visited during the planning phase for mine safing activities, it became
apparent that barn owls occupied most of the shafts in that area.

Constraints related to the installation of nets over those specific
openings precluded accommodation of the resident owls and the animals
were evicted from the sites prior to installations. However, nearby
shafts have been observed to now host owls; it is presumed the animals
migrated to these other mine openings. Plans to install safety nets over
recently acquired patented mining claims in the Greenwater Valley led to
a similar observation. Again numerous mineshafts in the area were
observed as being occupied by owls.

It was further observed the owls employed a zigzag inclined flight
pattern to move up and down the mine shafts. The birds stop or rest at
points of convenience on the walls of the shaft. They stop and rest on
several of these "steps" until they reach a point in the mine shaft
where a nest can be constructed. It was also observed that upon exiting
the shaft at the ground surface, the birds maintained a relatively low
flight path.

It was obvious that any consideration for the continued use of those
mine openings by owls would require a widely spaced open topped device.
It was decided that reinforced cyclone fencing might lend itself to this
application. Thus experimentation with such fencing is being attempted
(Figure 13). It is probable some level of vandalism will be visited upon
these features and increased periodic maintenance of the structures will
be required. The fences are set back from the openings to permit a low
approach and departure flight path for the birds. Wooden rails or
perches are attached to the top fence rails to allow the birds to perch
on them and break their angle of flight. A "hitching post" type perch is
constructed near the shaft collar to further facilitate their approach
to the shaft openings in an effort to approximate and extend their
vertical zig-zag flight patterns within the shafts.

The exclosure fences are made of heavier than normal fencing materials;
several grades or weights of fencing material are commercially
available. The posts are set in cement. Mounting devices (fencing to
post) have been adapted and enhanced against vandalism. The top rail of
the fence is set above the uppermost part of the fencing thereby
reducing the chance that the bird's claws will become entangled in the
wire. One young owl was observed to be serious injured on the exclosure
fence protecting the endangered pupfish at Devils Hole. The cantilevered
barbed wire tops are also set below the top rail to reduce the
possibility of entanglement. The top rails are equipped with wooden
perches to accommodate the owl's natural movements.

Construction of the adapted fence closures for owls is not a highly
preferred management option. The fences may constitute visual intrusions
and require higher levels of maintenance. However, in order to maintain
some reasonable level of owl population, two mineshafts in each area
where they are observed will be set aside for their continued use if
serious visual intrusion can be avoided.

### Small mammals, birds, and reptiles

The original safety net mine closure device was designed with the
passage of small mammal and reptile residents in mind. The rigid or bat
gate type exclosures also lend themselves to that concept. Thus pack
rats, small birds, and other species may continue their residencies
uninterrupted.

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## 

## AML Related Activities in park Wilderness

AML sites in wilderness areas provide safety hazards of elevated
significance for the visiting public and park personnel. The remote
locations; reduced or non-existent communications; lack of vehicular
access, first aid supplies, and support facilities; and the distance
from trained emergency response personnel dramatically escalate the
seriousness of wilderness accidents. Precious time lost in notification,
EMT personnel response, and extraction of the victim often deprive
trained medical personnel the reduced response time required to meet
serious medical conditions. This lost time can contribute to the
extended medical treatment or death of more seriously injured victims.
Because 95% (3.2 million acres) of the park is designated wilderness,
the mitigation or reduction of wilderness safety hazards posed by AML
sites becomes a high priority management goal.

Before AML related work is planned or implemented in wilderness, a
review of the requirements of the Wilderness Act and the park wilderness
plan is required. The "minimum tool requirement" decision tree,
described in Director's Order #41, provides guidelines on the
appropriateness of mechanized AML project work in wilderness. If such
work is determined to be necessary, decisions regarding methods of
implementation must consider the most appropriate tools for
accomplishing the work.

Section 1133(c) of the Wilderness Act provides as follows:

> \"***\[E\]xcept as necessary to meet minimum requirements for the
> administration of the area for the purpose of this Act*** ([including
> measures required in emergencies involving the health and safety of
> persons within the area]{.underline}), there shall be no temporary
> road, no use of motor vehicles, motorized equipment or motorboats, no
> landing of aircraft, no other form of mechanical transport, and no
> structure or installation within any such area." (Italics added for
> emphasis).

This is understood to mean the Wilderness Act can allow the NPS to use
motorized equipment [when necessary to administer]{.underline} a
wilderness area. This could include conducting AML hazard mitigation
work within wilderness lands following minimum tool requirements, but
the decision would be made on a case-by-case basis or through the
generation of a programmatic agreement.

The installation of any mine closure device depends upon providing a
solid means of rigidly attaching or anchoring the device to the walls of
the mine opening. Adhesives are inappropriate for this application and
results in a non-reversible alteration unless the rock surface
containing the adhesive is also removed. Thus the drilling of holes to
accommodate pins or anchor devices is required to accomplish the task.
Hand drilling techniques, formerly used in historic mining operations,
are unacceptable safety risks for field personnel. Therefore, minimum
tool requirements for this work may require the temporary and limited
use of some form of mechanized equipment. The type of tools required
will vary from site to site. Generally the site work will be supported
by the temporary use of a portable electric arc welder/generator and
power hand tools. Pack animals will be used to the maximum extent to
carry supplies and materials to a work site.

### 

### Historic structures and mine closures

The permanent closure of abandoned mines over 50 years of age is not
currently contemplated at Death Valley National Park. The methodology of
choice for providing for the safety of visitors and staff at these sites
is the installation of reversible safety features that will produce
little noticeable change or modification to the site. This type of
non-intrusive, reversible work preserving the historic character of the
sites can be done without prior NPS/SHPO consultation. Whenever mine
closure devices are installed at mine openings, steps will be taken to
insure the preservation of any historic fabric that may still be in
place including the mine workings. The safety devices will be worked
into and around historic structures such that their presence is
substantially minimized (Figure 14). If any historic fabric remains at
the site, a professional historical archeologist will examine the site.
The archeologist will direct what steps must be taken to insure the
preservation of the site.

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In adit and tunnel portals, the devices will always be recessed so that
its presence is unnoticed until the opening is entered. In shafts they
will be recessed into the opening unless wildlife considerations
preclude such installation. In the case of shafts, such installations
cannot be observed until a person steps near the edge of the opening. In
some cases the historic timbering will be removed, the device installed,
and the timber replaced in its former position. Great lengths will be
taken to minimize the presence of the devices and make them blend with
the historic structures.

The park will maintain a comprehensive AML database. The database will
document the locations of AML sites in the park. It will contain AML
survey data on the sites. The AML survey is a work in progress and will
take many years to complete although considerable progress has already
been made. The survey will document a wide range of physical conditions
at the individual AML sites including providing photographic records.
The survey will rank the relative safety hazards of the site and will
determine the sequencing of AML safing work to be preformed. Any mine
safing work preformed at an AML site will be photo documented before and
after the work. The pictures will sufficiently illustrate the historic
construction/engineering features and techniques of each site as well as
providing an overview depicting its setting within the general
landscape. The site location will be digitally recorded in the park's
AML database. Such recording will provide the location on a digital 7.5
" USGS topographic maps. Updated copies of those digital files will be
provided to the SHPO annually.

# Stabilization of Historic Mine Buildings, Structures, and residences.

The individual historic mine features, surface support structures,
miner's residences, found within Death Valley National Park are
important historical mining artifacts that contribute significantly to
visitor enjoyment, appreciation of the mining history, and of the life
styles of early settlers. There are also historic ranches within the
park that provide similar historic records of early occupation and life
styles. These features provide a unique physical record of the history
of mining, ranching, and early occupation of the area. Initial
Euro-American interest in the area was generated by the search for
valuable mineral deposits that could be developed for profit and many of
the local ranching/farming that supported those efforts. Much of the
occupation and development of the Death Valley area has been directly
related to this mineral interest and mining activity. These historic
mining features have significance under industrial, mining,
entertainment, and recreational themes related to National Register of
Historic Place eligibility. In addition, these sites have the potential
to provide information on the cultural shift from that earlier
industrial emphasis to current, greater intensity recreational use of
desert lands.

The evolution of the area's mining history can be observed and
appreciated through these remaining features. Unfortunately the vast
majority of these sites have not survived the ravages of time, weather,
and vandalism. This is true not only in Death Valley, but is evident
throughout the West. Increasing 4X4-vehicle ownership and backcountry
travel has resulted in the rapidly escalating loss of historic mining
features throughout the West. Surviving structural features therefore
have an elevated local historical significance in recording and
portraying the history of mining not only in Death Valley and throughout
the West.

The remaining sparsely distributed sites are, for the most part, located
in remote parts of the park. Thus, visitors traveling the remote by-ways
of the park are rewarded by chance encounters of one of these
interesting sites. These encounters constitute enjoyable "discoveries"
for inspection and contemplation. Visitors are able to inspect the sites
for evidence of the type of materials, technology, and equipment used in
early prospecting and mining ventures (Figure 15). In addition, visitors
have an opportunity, in a setting of unequaled desert solitude, to
reflect on the harsh lifestyles of the prospectors, miners, ranchers,
and their families in this seemingly inhospitable climate. It is that
history and these features that attract many first-time visitors. Others
return time and again to repeat and expand their exploration and
discovery of the park and these hidden historic features. This
appreciation is effectively and affectionately demonstrated in the
visitor logs installed at several of the sites. These features increase
visitor enjoyment and appreciation of park and thereby serve the public
interest. Thus the park is dedicated to the preservation of these sites.

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It is the expressed intent of the AML program to actively manage both
evaluated and unevaluated historic structures as potentially eligible
for listing in the National Register of Historic Places. NPS historic
structure preservation specialists have recognized that "virtually all
of the standing \[historic Mining and Ranching\] structures require
maintenance." Those structures logically fall into two distinct
categories: National Register listed, nominated, or eligible for
nomination structures, and all others.

It is herein proposed to manage these features by a two-tiered approach
relative to their obvious maintenance and stabilization requirements.
This type of management approach will provide a reasonable level of care
for the maximum number of historic mine sites in the park in fulfillment
of the NPS' legal mandate under the California Desert Protection Act of
1994. The park will adopt a **first tier** site classification that will
provide for formal, project funded, stabilization and preservation work
on the evaluated, significant sites identified in the park such as the
historic Skidoo Stamp Mill, Keane Wonder Tramway, Gold Hill Mill, etc.
Historic Structure Reports (HSRs), condition assessments, site
management recommendations, approved individual work plans would guide
this elevated level of work, and project oversight will be provided by
experienced, on-site, preservation specialists and **be subject to SHPO
review** and approval. Second tier historic structure stabilization
work, herein described, would be applied to as many of the other
unsurveyed, and perhaps lesser significant structures and sites in the
park as can reasonably be accommodated within the scope and funding
limitations of the program. Significant modifications contemplated for
first tier sites, would be reviewed under formal Section 106 compliance
procedures, and include review by a historical architect or preservation
specialist.

The **second tier** category of work would represent a park level "best
effort" to stabilize and thus maintain structures not otherwise eligible
for more elevated historic status and substantially greater project
funding.

Structure stabilization projects undertaken by the park AML crew on
second tier sites will be limited to emergency stabilization and minimal
preservation maintenance, including routine maintenance and
stabilization measures. This work will be limited to actions for
stabilizing, preserving, protecting, and maintaining these structures.
The work will be limited to repairing and replacing in kind materials
and features consistent with the Secretary of Interior's Standards for
Rehabilitation and the accompanying guidelines. This level of work will
be common to each of the structures treated dealing only with the outer
shell security, structural integrity, mitigation of safety hazards,
control of encroaching vegetation, and maintenance of drainage. Because
of this commonality it is more appropriate to govern this level of
effort under a programmatic agreement than individual site clearances
and approvals. This level of work will be fully documented, and can be
preformed under this park-wide, **programmatic agreement without other
prior NPS/SHPO consultation or notification**. Park maintained
documentation will consist of condition assessment and report, site
photographs (before and after) and preparation of a descriptive work
plan.

The actual stabilization efforts for the second tier structures will
fall into three general categories: to protect the structures from
general environmental conditions; to stabilize or repair specific
structural features; and to protect the public from health or safety
conditions. The work will primarily consist of securing and maintaining
the protective shell (roof, siding, doors, and windows) and assuring the
stability of structural frame work features (rafters, walls, etc.). The
structures will be inspected for the presence of encroaching vegetation
that could constitute a fire fuel load thereby establishing a definable
fire hazard to the structure. In consultation with the park botanist and
archeologist vegetation reduction or control of adequate scope will be
established around the buildings where required. Hazardous tree limbs
and or trees endangering the structures will be removed and exotic
vegetation will be controlled or removed as recommended and or approved
by the botanist and archeologist.

The roof, exterior coverings, and surface finishes will be inspected for
damage, deterioration, and leaks, and will be stabilized or repaired.
Exterior wooden construction materials will be considered for treatment
with a suitable preservative as is appropriate under established
guidelines. The structures will be inspected, reinforced, stabilized,
and repaired as necessary to prevent imminent collapse. Stone
foundations at the base of walls will be re-stacked as dry set or
re-mortared if necessary. When appropriate assistance or training can be
acquired, the walls of stone cabins will be repaired to the extent
possible under the approval and direction of the archeologist. The
buildings and sites will be cleaned through removal of modern trash and
or hazardous materials. The sites will be inspected and re-graded where
required to provide for the lowering of any grades that may have filled
in against the buildings and establish adequate drainage away from the
building foundations.

Due to their relative age the physical condition of all of these
historic structures demonstrate significant and advanced stages of
deterioration. By far the largest percentage of former historic mining
structures in the park have been lost due to salvage, destruction,
collapse, souvenir hunting, and vandalism. A stabilization program
addressing the structural deficiencies of the remaining features is
essential if they are to be retained for continued enjoyment and
appreciation by park visitors and future generations. Collapsed
structures impart little information for appreciation by or to visitors.
They constitute significant safety hazards, and are used as a source of
firewood thus losing all their historic value and causing additional
management problems. Experience has shown that historic structures that
do not demonstrate sufficient integrity and obvious care are subject to
increased vandalism.

The primary purposes of these basic stabilization efforts are
conservation of the historic structures and the mitigation of safety
hazards associated with them. The sites will be inspected for the
presence of hazardous conditions which will then be systematically
addressed. Primary attention will be paid to insuring the integrity of
the main weight bearing, structural members, framework, and outer shell
members (roof, siding, doors, and windows). This work will generally
consist of the careful addition of metal or wood braces, sister members,
and possible member replacement. The work will incorporate replacement
with the original materials when possible or replacement in kind. New
construction materials will be employed only when the original historic
fabric cannot be utilized or closely approximated. All new material will
be suitably and noticeably stamped as installed by the NPS and provide
the date of installation.

Any work beyond assuring the basic structural integrity and outer shell
security of the structures will be conducted only under an approved
historic structure work plan. In conjunction with the park archeologist,
cultural resources specialist, division chief, and historic preservation
specialists as required, site surveys of the historic structures will be
conducted and advanced stabilization plans will be generated for review
and approval. Emergency stabilization measures will be applied to
structures subject to apparent imminent failure.

Mill, ore bin, headframe, collar set, and aerial tramway structures will
also be assessed and stabilized as required. The historic fabric will be
retained to the greatest degree possible. Sister members will be added
alongside historic ones where appropriate. In some cases internal
support frames may need to be constructed. In other instances individual
historic member splicing or replacement may be necessary (Figure 16).
All new materials employed will be of the same original dimensions and
type, and treated to match the color and appearance of the original as
closely as possible. All replacement materials added by the NPS will be
stamped with the date of their installation and indicate installation by
the NPS.

Preservation of the historic character and appearance of the site will
be an important aspect of the work. The structures will never be brought
to a state of being fully functional but will be retained in their
naturally aged, abandoned, historic condition. An important purpose of
this work is to convey to visitors the message that the site is being
provided care, attention, and protection under NPS management. This will
be necessary to help deter random vandalism that frequently occurs at
these sites. The AML crew has received, and will continue to participate
in, historic structure stabilization and preservation training.

# 

# Mitigation of impacts to the park's resources where appropriate

Part of Death Valley's charm to park visitors stem from its unique
geology, resultant geography, and extreme climate. Of nearly equal
importance is the lore of its extensive mining and ranching history.
Because of its importance to the park, mitigation through surface
reclamation of impacts from historic mining operations and mineral
exploration is viewed somewhat differently than in units where such a
strong relationship does not exist. Park compliance with the terms of
the California Desert Protection Act (CDPA) to preserve the history of
mining and ranching of the Death Valley area will be reflected in less
site and surface restoration work than other park units and wilderness
areas.

Mitigation will receive its greatest expression in the mine closure
safety and stabilization programs described above. The retention of
historic mine features, in order to preserve their history, is deemed
desirable in light of its extensive mining history. Mitigation of
impacts to the park's natural, scenic, and wilderness resources from
historic mining features under this program will be determined on a case
by case basis and be driven by funding and personnel limitations.

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The wilderness overlay of 96% of the park created by Congress, through
passage of the CDPA, isolated the vast majority of the AML sites. That
isolation, coupled with wilderness prohibitions, limits the type of
operations that can effectively be completed in the field.
Realistically, it is unlikely that anticipated levels of funding would
ever be available to address the magnitude of the AML issue. Absent
additional funding support to address this issue, park financial
resources will not provide for substantive progress in this area. The
result of these conditions is that the majority of AML sites will remain
in their current state. It is probable that some periodic progress will
be made on the reclamation of non-historic, unrecognized road features
crossing wilderness to the sites. It is further probable that some
individual site reclamation may occur when planning and funding provide
for such activity.

## Monitoring and Maintenance

Monitoring and maintenance are essential elements of the AML program.
Annually each of the sites of previous work will be revisited,
inspected, recorded, and documented to the extent possible. Necessary
maintenance work on existing installations will be performed during the
inspections. All of the AML annual survey data will be retained in a GIS
database subject to ready retrieval and use. The database will includes
site locations, site survey and inspection information, photo
documentation, mine closure information, results of annual surveys,
stabilization plan information, narrative and photo documentation of
stabilization work completed, and other pertinent data. The site
inspections will check for the integrity of the previous AML work,
evidence of vandalism, and any additional signs of deterioration. Any
defects or vandalism will be scheduled for repair. Further deterioration
will be noted and evaluated. If additional site work is identified
during inspections it will be proposed in revised work plans for
consideration, evaluation, and approval.

## Training

The park will maintain an aggressive training program for the AML staff
in general construction safety (OSHA), and underground mining safety
(MSHA), bat gate construction technology, as well as in Historic
Structure Stabilization and Preservation Techniques and Technology. The
knowledge and understanding of the crewmembers of the philosophy, as
well as the application of this type of work, is essential to achieving
the goals of this program and reaching NPS management objectives. It is
anticipated their continued training will result in the establishment of
a fully trained and qualified core team that is capable of executing all
forms of mine closures and historic structure stabilization and
preservation work at a fully functional level. It is visualized that the
Death Valley NP AML crew will become accepted authorities on the
execution of mining-related historic preservation work as well as with
mine safety closures.

**Appendix A**

**Definitions**

***Adit*** A horizontal or nearly horizontal passage mined from the
ground surface for development of an underground mine.

***Arrastra*** A constructed, circular, stone device with center pivot
for a tethered drag stone designed to permit the crude crushing of ore
to permit mineral recovery. Generally attributed to an early Mexican
design for low cost ore processing.

***Collar*** The aperture or surface opening at the top of a shaft,
often reinforced or stabilized with timber or other materials.

***Glory hole*** The area where an underground stope breaks through to
the surface creating a new surface opening. Typically, the edges of a
glory hole are undermined, weakened, and susceptible to collapse under
unsuspecting visitors.

***Highwall*** The cliff-like feature in a surface or open pit mine left
when rock has been removed.

***Incline* shaft** A steeply inclined passage mined dug upward or
downward from the surface for developing an underground mine. Typically
one refers to an incline as steeper than an adit, which can easily be
walked, but less steep than a shaft, which would require ropes or some
sort of hoisting mechanism to access.

***Ore*** ***Deposit*** A naturally occurring mineral concentration.

***Portal*** The entry to an adit or a tunnel.

***Shaft*** A vertical or near vertical passage mined from the surface
for developing an underground mine.

***Stope*** A broad open underground mine feature where a large mass of
ore and ore waste rock has been removed. Having so much rock removed
from these areas, stopes are typically one of the more hazardous areas
underground due to inadequate ground support, often leading to rock
falls and ground collapse.

***Tailings*** Waste material by product from an ore processing mill;
the remnant ground rock material left after the desired mineral
commodity has been separated from the ore. Typically, this material is
homogenous and fine-grained

***Tunnel*** A horizontal or nearly horizontal passage mined from the
surface through a hill or mountain to the surface on the other side
(having two entrances or ends as does a Rail Road tunnel).

***Waste Rock, Spoils, Dump*** Barren, non-mineralized, or sub-economic
grade rock that was mined to gain access to the ore body. In the case of
an open pit, waste material that must be stripped away in order to
expose an otherwise buried orebody is called "overburden." Since this
material is not sent to the mill, it is typically discarded near the
mine entrance. It is typically non-homogenous varying between coarse and
fine-grained rock materials.

**Winze** A vertical or inclined shaft dug within an underground mine
used to provide connections between various working levels. Usually
mounted with a wooden ladder, may also have rock hoisting equipment, and
commonly will have a wooden cover.

###### Appendix B

**AML Site Survey Form**

**NATIONAL PARK SERVICE ABANDONED MINE LANDS FIELD INVENTORY DATA
SHEET**

###### DEATH VALLEY NATIONAL PARK

Park Unit \_\_\_\_\_\_\_\_\_\_\_\_\_ Inspected by
\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Date\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

A. Site/mine name \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Location: State \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ County
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Watershed
Name\_\_\_\_\_\_\_\_\_\_\_\_\_\_

USGS Quadrangle \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

UTM Coordinates\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_X
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_Y (NAD83, MSL) GPS
Filename\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

B. Operation Type: pit or quarry\_\_\_\_\_ underground\_\_\_\_\_
mill\_\_\_\_\_ placer\_\_\_\_\_
other\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Commodity \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Operation status: abandoned\_\_\_\_\_ active\_\_\_\_\_ administrative
use (NPS sand/gravel, staging area, equipment storage, etc.)\_\_

C. Size of surface disturbance:\_\_\_\_\_\_acres, \_\_\_\_\_\_\_length
(m) x \_\_\_\_\_\_\_width (m); waste rock pile\_\_\_\_\_\_\_\_(metric
tons)

D. ID#\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ opening
type\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ dimensions
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ depth\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

E. *HAZARDS*

\_\_\_\_\_ not hazardous to careful visitor

If the following exist, place a check mark next to the item.

1\. \_\_\_ structures (describe number, type,
condition)\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

2\. \_\_\_ debris (describe type,
extent)\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

3\. \_\_\_ highwall - average length\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_,
height\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ benches?
(y/n)\_\_\_\_\_\_\_\_\_\_\_

describe\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

4\. \_\_\_ unstable rock (describe rock
type)\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

5\. \_\_\_ pools (describe size, number,
location)\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

6\. \_\_\_ explosives **DO NOT TOUCH** (describe type if
known)\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

7\. \_\_\_ machinery (describe type,
number)\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

> 8\. \_\_\_ hazardous substances - **DO NOT OPEN CONTAINERS**
> (describe, e.g., fuels, lubricants, chemicals, transformers; drums,
> containers, storage tanks; altered soil, vegetation, water; dumps,
> fill areas)\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

9\. \_\_\_ subsidence features
(describe)\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

10\. \_\_\_ fall hazard (i.e., down shafts, etc.)

11\. \_\_\_ tailings or waste rock piles \[describe number, location,
and approximate dimensions (lxwxh)\]\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

12\. \_\_\_
other\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Notes on hazards:

F. *RESOURCE IMPACTS:* Include all areas associated with the mine, such
as access roads, waste rock piles, refuse piles, etc.

Place check marks next to the items that apply.

1\. Water

1\. \_\_\_ Water is flowing out of mine workings (adits, shafts, pits,
etc.). pH\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

2\. \_\_\_ Water is standing in mine workings (adits, shafts, pits,
etc.). pH\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

3\. \_\_\_ Water is flowing through or over the tailings/waste rock pile
(if it exists).

4\. \_\_\_ The ground or stream bottom is discolored around the site.

5\. \_\_\_ There is evidence of aquatic life in the drainages near the
site.

6\. Estimate the distance to the nearest
drainage:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

2\. Sediment

1\. \_\_\_ During runoff, sediment from the site is transported by water
into a nearby drainage or stream channel.

2\. \_\_\_ Other evidence of erosion (specify, e.g., gullies, scarps,
cracks)\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

3\. Vegetation

1\. \_\_\_ Characerize the vegetation: healthy\_\_\_\_\_\_,
struggling\_\_\_\_\_\_, dead\_\_\_\_\_\_, nonexistent\_\_\_\_\_\_

> 2\. \_\_\_ If there is vegetation damage, state why you think it is
> damaged, and try to quantify the amount of
> damage.\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

4\. Wildlife

1\. \_\_\_ Wildlife inhabit or visit the site. (Look for droppings,
tracks, and nests. This is especially important in underground sites
since evidence of animal habitation is a good clue about the air
quality. Specify types of wildlife, paying special attention to
endangered species, e.g., bats,
rodents)\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

2\. \_\_\_ No wildlife use detected.

5\. Visual

1\. Characterize the visibility of the site: easily seen\_\_\_\_\_\_,
seen when pointed out or sought\_\_\_\_\_\_, hidden\_\_\_\_\_\_\_

2\. \_\_\_ Site is visible from visitor facilities, or well-visited
roads, trails, or viewpoints.

From what distance is the sight easily
visible?\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

3\. Distance to nearest
road\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

G. Cultural resource potential? (y/n)\_\_\_\_\_\_\_
(describe)\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

If applicable, describe interpretive
potential\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

H. Visitor/staff use? (y/n)\_\_\_\_\_\_\_

1\. Frequency of visitation/use
(high/medium/low)\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Describe
evidence\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

2\. Rescue
information\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

I. Potential mitigation/reclamation methods:

1\. If you were to design a reclamation plan for this site, what would
you do? Check the appropriate boxes and describe below if necessary.

\_\_\_cable nets (bolted over entrances) \_\_\_install warning signs

\_\_\_bulkheads (e.g., rock and mortar or formed \_\_\_recontour

concrete installed in entrances) \_\_\_topsoil or other soil amendments

\_\_\_[p]{.underline}oly[u]{.underline}rethane [f]{.underline}oam (PUF)
(expands 30X \_\_\_revegetate, either by seeding or transplanting

when installed; earthen backfill at surface) \_\_\_stabilize
deteriorating structures

\_\_\_gates \_\_\_destroy deteriorating structures

\_\_\_explosives (blast openings closed) \_\_\_no action - (The site is
naturally reclaiming and

\_\_\_backfill shafts, pits, entrances \_\_\_poses no resource impacts
or safety hazards.)

\_\_\_fences
\_\_\_other\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Describe
details\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

2\. Mitigation status: none\_\_\_\_; temporary measures - fence\_\_\_\_,
sign\_\_\_\_,
other\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

hazards adequately mitigated (y/n)\_\_\_\_\_\_\_ reclamation complete
(y/n)\_\_\_\_\_\_\_\_.

Comments\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

J.  Geologic Characteristics

> 1\. Rock
> Type:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
>
> 2\. Structures (description and orientation):
> \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

K. General Notes:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

L. Hazard rating (0-6)(Lo-Hi)\_\_\_\_\_ Access rating
(0-10)(hard-easy)\_\_\_\_\_\_ Natural resource rating(H/M/L)\_\_\_\_\_

###### Appendix C

**Job Hazard Analysis**

# Example

  ------------------ ---------------------------------- ------------------
                     **DEATH VALLEY NATIONAL PARK**     NO. XXX

                     **JOB HAZARD ANALYSIS**            
  ------------------ ---------------------------------- ------------------

+--------+------------------------------+-----------+-----------------+
| **     | Hazardous Mine Safety        | **Date:** | xx/xx/xx        |
| Job:** | Closure                      |           |                 |
+--------+------------------------------+-----------+-----------------+
|        |                              |           |                 |
+--------+------------------------------+-----------+-----------------+
| **Pr   | Mining Engineer or           | *         | AML Field       |
| epared |                              | *Approved | Operations      |
| By:**  | Physical Sciences            | by:**     | Manager         |
|        | Technician, Mining/Geology   |           |                 |
|        | or                           |           |                 |
|        |                              |           |                 |
|        | AML crew members             |           |                 |
+--------+------------------------------+-----------+-----------------+

+-----------------+-----------------+-----------------+-----------------+
| **TASK**        | **SUPPLIES**    | **HAZARDS**     | **SAFEGUARDS**  |
+-----------------+-----------------+-----------------+-----------------+
| 1.  Install Bat | ¼ inch steel 2  | A.  Traversing  | 1.  Observance  |
|     Gate        | inch angle iron |     uneven      |     of all park |
|     closure of  |                 |     ground      |     abandoned   |
|     the Eureka  | 8 -- 10 foot    |     surface,    |     mine entry  |
|     Mine        | pieces          |     possible    |     protocols.  |
|                 |                 |     twisted     |                 |
| Harrisburg      |                 |     ankle       | 2.  Use of all  |
| Flats           |                 |     injury.     |     appropriate |
|                 |                 |                 |     PPE.        |
|                 |                 | B.  Trip        |                 |
|                 |                 |     Hazards.    | 3.  Exercising  |
|                 |                 |                 |     proper      |
|                 |                 | C.  Lifting and |     technique   |
|                 |                 |     carrying    |     in lifting  |
|                 |                 |     heavy       |     heavy       |
|                 |                 |     steel.      |     objects.    |
|                 |                 |                 |                 |
|                 |                 | D.  Lifting and | 4.  Exercising  |
|                 |                 |     carrying    |     care in     |
|                 |                 |     heavy       |     traversing  |
|                 |                 |     equipment.  |     uneven      |
|                 |                 |                 |     terrain     |
|                 |                 | E.  Use of      |     with heavy  |
|                 |                 |     flammable   |     loads.      |
|                 |                 |     materials.  |                 |
|                 |                 |                 | 5.  Resting     |
|                 |                 | F.  Use of arc  |     when        |
|                 |                 |     wielder.    |                 |
|                 |                 |                 |    appropriate. |
|                 |                 | G.  Use of      |                 |
|                 |                 |     cut-off     | 6.  Observing   |
|                 |                 |     saw.        |     proper      |
|                 |                 |                 |     safety      |
|                 |                 | H.  Exposure to |     techniques  |
|                 |                 |     sharp metal |     in          |
|                 |                 |     edges.      |     operating   |
|                 |                 |                 |     hand and    |
|                 |                 | I.  Use of hand |     power       |
|                 |                 |     tools.      |     equipment.  |
|                 |                 |                 |                 |
|                 |                 | J.  Work in     | 7.  Carefully   |
|                 |                 |     mine        |     inspecting  |
|                 |                 |     opening.    |     work site   |
|                 |                 |                 |     and         |
|                 |                 | K.  Exposure to |     preparing   |
|                 |                 |     rock fall.  |     it          |
|                 |                 |                 |     properly.   |
|                 |                 | L.  Possibility |                 |
|                 |                 |     of head     | 8.  Carefully   |
|                 |                 |     injury      |     inspecting  |
|                 |                 |     against low |     and         |
|                 |                 |     mine roof.  |     assessing   |
|                 |                 |                 |     rock        |
|                 |                 | M.              |     conditions  |
|                 |                 |                 |                 |
|                 |                 |                 | 9.  Selecting   |
|                 |                 |                 |     appropriate |
|                 |                 |                 |                 |
|                 |                 |                 |    installation |
|                 |                 |                 |     site.       |
|                 |                 |                 |                 |
|                 |                 |                 | 10. In case of  |
|                 |                 |                 |     doubt or    |
|                 |                 |                 |     question    |
|                 |                 |                 |     check with  |
|                 |                 |                 |     supervisor. |
|                 |                 |                 |                 |
|                 |                 |                 | 11. Observe     |
|                 |                 |                 |     proper      |
|                 |                 |                 |     operating   |
|                 |                 |                 |     techniques  |
|                 |                 |                 |     for         |
|                 |                 |                 |     compressor  |
|                 |                 |                 |     and rock    |
|                 |                 |                 |     drill.      |
|                 |                 |                 |                 |
|                 |                 |                 | 12. Use         |
|                 |                 |                 |     appropriate |
|                 |                 |                 |     PPE when    |
|                 |                 |                 |     drilling    |
|                 |                 |                 |     and setting |
|                 |                 |                 |     rock bolts. |
|                 |                 |                 |                 |
|                 |                 |                 | 13. Resting     |
|                 |                 |                 |     frequently. |
|                 |                 |                 |                 |
|                 |                 |                 | 14. Continually |
|                 |                 |                 |     monitoring  |
|                 |                 |                 |     mine        |
|                 |                 |                 |     opening for |
|                 |                 |                 |     adverse     |
|                 |                 |                 |     changes     |
|                 |                 |                 |     resulting   |
|                 |                 |                 |     from        |
|                 |                 |                 |     operations. |
+-----------------+-----------------+-----------------+-----------------+
|                 | Wielding Rod    |                 |                 |
+-----------------+-----------------+-----------------+-----------------+
|                 |                 |                 |                 |
+-----------------+-----------------+-----------------+-----------------+

**Appendix D**

**Death Valley National Park**

**Qualified Staff Underground Mine Entry Protocol**

The single most significant element insuring the safety of personnel
engaged in AML work is the application of their personal knowledge and
application of the Underground Mine Entry Protocol. The Mine Entry
Protocol is based on assuring the highest degree of personal safety for
personnel entering an underground or open pit mine. The protocol
includes a combined training, authorization, notification, and
communications plan including the JHA and radio link to the park
communications center. The protocol further incorporates an individual
site assessment to be carried out by the AML crew prior to underground
entry. The Protocol includes adherence to an approved emergency plan
contained in separate documentation (Appendix E) immediately available
to the AML crew, communications center, and park emergency response
personnel.

In Death Valley National Park the combined
authorization/notification/communication plan and completed/signed Job
Hazard Analysis (JHA) constitute the permit for approved underground
abandoned mine entry. Posting of the completed permit is accomplished by
placing it in a vehicle at the mine entry site. A 3-person team (2
persons going underground and 1 surface or mine portal safety attendant)
is preferable, but not always possible at Death Valley NP due to
staffing limitations. However, the function of a 3-person crew is
effectively achieved by communications verification with the park
Communications Center where the Dispatch Link becomes the "portal
attendant" through use of radios of mobile phones.

In those areas of the park where radio communications with the park
Communications Center do not exist the crew will rely on satellite
telephones or radio contact with the San Bernardino Interagency
Communications Center, BLM dispatch center, or local sheriff's office.
Underground mine entry without the communications link will not be
effected unless under obvious life threatening emergency conditions.

The protocol involves the utilization of underground safety procedures
such as diligent inspection of rock/ground conditions and ground
supports of the mine opening every time it is entered. The crew makes
this inspection prior to any forward movement within the immediate range
of their visual inspection. The inspection can only be effectively
completed for a short section of the mine opening immediately preceding
the crew at any one time. The inspection process is repeated for each
observable interval to be transversed prior to moving through it. The
crew will conduct testing of all suspect rock and ground supports for
stability with a "scaling bar" prior to directly approaching them.

The crew will utilize the "Miners Walk" by maintaining adequate
individual separation, placing feet carefully on solid, pre-tested
footing, avoiding situations, as much as possible, where loss of balance
or tripping may occur, and not leaning on or touching suspect rock,
timbers, or structures, while using of all appropriate personal
protective equipment. As a general rule areas of caving (roof falls)
will not be entered. The crew is equipped with atmosphere or gas
monitoring equipment and will investigate all underground workings for
lack of oxygen and presence of hazardous gases at all times.

**Prescribed Personal Protective Equipment for use on AML Projects**

The AML crew is equipped with and will have immediately available for
use in the AML vehicle an appropriate array of Personal Protective
Equipment (PPE) which minimally consists of the following items:

Dedicated 4X4 AML vehicle in which their PPE and dedicated AML

equipment can be kept ready for immediate use.

Communications -- mobile vehicle mounted and hand held radios,

satellite telephones

First Aid materials -- standard issue

Safety hard hats - standard construction industry and climbing

Lights -- standard miners cap lamps, headlights, flashlights

Foot protection -- Standard steel-toed safety boots, leather

boots,

Eye protection - safety glasses, goggles, face shields

Kneeling protection -- knee pads

Hearing protection -- ear plugs or over the ear muffs

Fall protection -- miners or shaft belt, safety harness,

lanyards, climbing rope, assorted climbing

hardware

Mine self-rescue devices - standard mining industry self-

contained rescue units, as required

Mine Gas (atmospheric) Testing equipment -- gas meters

Gloves -- various, industrial grade.

Respirators -- standard issue safety type with appropriate filters

Substance isolation equipment -- clothing, raingear, tyvek

Coveralls, rubber gloves

Hot-work protection -- leather gloves, coats, vests, chaps,

aprons, wielding hood and goggles, and

appropriate eye protection

Scaling bars -- standard mine industry

Water containers/beverage coolers

**Appendix E.**

###### AML Emergency Plan

**Death Valley National Park**

###### AML (Mine Safing) Program

**Field Staff Emergency Procedures**

**Procedures to follow in the event of personal injury to one or both
AML team members or in the event of a third party accident or incident
encountered in transit.**

**Note: Always provide or call for assistance for the visiting public
when it is required. Do not leave an injured or stranded visitor
unattended or without assured follow up by a Ranger, tow truck, or other
form of assistance.**

1.  **Assess nature and seriousness of injury.**

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A.  Death

B.  Life Threatening injury (Bleeding/breathing/poisoning)

C.  Victim unconscious

D.  Victim conscious but unresponsive

E.  Victim conscious and responsive

F.  Victim trapped (Possible crushing injuries)

G.  Serious injury but non-life threatening

H.  Presence of the Symptoms of Shock (Assume presence)

I.  Minor injury treatable with assistance

J.  Minor injury treatable without assistance

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```
2.  Provide appropriate immediate first aid. Insure well

> Stocked first aid kit and materials are kept in vehicle.

3.  Determine if transportation in park vehicle is practicable and
    possible. Chose (ask for direction if needed) appropriate
    destination (Park HQ, Shoshone, Beatty, Ridgecrest, Lone Pine,
    Bishop, Pahrump) and route to be used. Meet ambulance/flight for
    Life aircraft at another location as possible.

4.  Determine if ambulance or flight for Life (Fixed wing or helicopter)
    is required. If a helicopter not available try to determine nearest
    suitable landing location for fixed wing aircraft. If in doubt ask
    for advice over the radio/phone. **No one expects you to make life
    or death decisions just to do the best you can. That's all anyone
    expects. That's all you should expect of yourself.**

5.  Call in injury accident report on park radio/satellite phone using
    appropriate radio procedures (Radio Shadows, appropriate
    channel/repeater, use San Bernardino, BLM, and sheriff Office's
    channels as needed). Try to control your emotions, keep as calm as
    possible, speak normally and distinctly. Try to provide the
    following information to the best of your ability:

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```
A.  Report accident, place, time, numbers of persons injured, estimated
    age and sex.

B.  Describe the injury as well as possible.

C.  Request ambulance or flight for life as is appropriate -- **ask for
    advice if in doubt.**

D.  Indicate if transportation with park vehicle is possible and
    indicate route to be taken and estimated time of arrival at the
    given destination only for NPS employees (unless exceptional
    circumstances prevail does not transport a visitor and then
    [always]{.underline} call in what you are doing). Except for dire
    circumstances never transport a park visitor or the general public.
    If you think you need to transport someone get proper authorization
    first and notify the communications center of the conditions, time,
    and beginning vehicle mileage. Always call in the end of the
    transport with time and ending mileage.

E.  Request advice/direction over the radio/phone if any doubt exists on
    any point.

F.  Insure proper, prompt medical attention is acquired. Remember the
    time to get the victim to medical attention is essential in the case
    of serious injury.

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6.  If on site assistance is needed get that information out

> as soon as possible. Let people know what help is needed and get it
> started as soon as possible. If a mine rescue team is needed it will
> take a long time to arrive. Get people notified as soon as possible so
> the proper help can be arranged. Remember that good communications are
> essential to smooth, efficient emergency operations.

7.  In the event of a fatality do not attempt to move the body. It's out
    of your hands at that point. Someone else will take care of what
    needs to be done. Just stand by and maintain good on-site
    communications until help arrives.

**Above All Stay calm!**

**Appendix F.**

######## Environmental Assessment

Introduction

Purpose and Need for the AML Program

Scope of the EA

Significant Issues

Safety

Recreation

Historic Cultural Resources

Wildlife

Wilderness

Proposal and Alternatives

The AML Plan is the Proposed Action

Alternatives are no action.

Summary of Actions proposed in the plan

1\. AML Inventory

2\. Safety Closures

Netting

Bat Gates and Cupolas

3\. Historic Structure Preservation

4\. Wildlife Preservation

5\. Mitigation of impacts to natural resources

No Action

Other Alternatives

Affected Environment

Historic Resources

Recreation & Safety

Wildlife

Tortoise

Bats

Other Wildlife

Wilderness

Balancing Wilderness Restoration with Cultural Preservation

AML Treatment Techniques in Wilderness

Minimum Requirements Analysis

Other Natural Resources

Environmental Impacts Analysis

Impacts from the Proposed Action -

Impacts from No Action

Impacts from Other Alternatives

Cumulative Impacts

Non-Impairment

Consultation and Coordination