Efficient Permanent Closure of 

Abandoned Mine 

Safety Hazards on 

BLM-Managed 

Lands

By Christopher Ross, Natural 

Resource Specialist

BLM, Nevada State Office

Background

Abandoned mine land (AML) sites 

are a significant threat to public 

safety throughout the western 

United States. Although fencing 

and posting signs may provide 

temporary remediation of this 

threat, permanent closure is the 

only positive method for eliminating hazards. Nevada has an estimated 50,000 AML sites on land 

managed by the Bureau of Land 

Management (BLM) that pose significant threats. The BLM staff has 

embarked on a mission to deal with 

this on a large scale. 

To do so as efficiently as possible, 

staff first prepared a statewide programmatic Environmental Assessment (EA) for the Remediation of 

Abandoned Mine Safety Hazards. 

This eliminated the considerable 

task of preparing a separate EA for 

each closure. The EA followed the 

standard format for National Environmental Policy Act (NEPA) analysis. Widespread public notification 

and public meetings were held to 

identify issues for analysis during 

the scoping process. A special effort 

was made to get input from small 

miners, bat conservationists, and 

archaeological interests.

Discussion

The Programmatic EA supports a 

“formal finding of no significant 

impact” (FONSI) for mine closure 

sites that are properly analyzed and 

cleared under the EA. The result of 

this NEPA process is that a Documentation of NEPA Adequacy 

form can be quickly and efficiently 

completed for AML sites scheduled 

for closure under the programmatic 

EA. This process reduces both staff 

time and paperwork. 

Information and processing procedures for mine closure were 

developed as follows (for more 

information on each procedure, 

contact the author): 

• Conduct site ranking 

• Determine site ownership and 

responsibility 

• Carry out procedures for archaeological and cultural surveys 

and requirements for monitoring and documentation 

• Conduct wildlife surveys in 

accordance with State and Federal guidelines

• Conduct threatened and endangered (T&E) species surveys 

and clearances

• Monitor other sensitive species 

• Issue special notifications for 

wilderness and wilderness study 

areas 

• Consider Visual Resource Management so that closure activities do not adversely affect the 

landscape

• Specify performance measures 

for conducting and documenting procedures

The order in which tasks are accomplished greatly affects efficiency. 

First, land status and responsibility 

are determined to eliminate sites for 

which the BLM is not responsible. 

Next, topographic quads are annotated and copied for future use. 

Finally, a site visit is made to determine hazard ranking and assign a 

unique site tag identifier. 

A major lesson learned from our 

experiences is that the geologists, 

archaeologists, botanists, and biologists should visit the sites together, 

preferably in the same vehicle. 

This spares various specialists from 

conducting detailed survey work if 

another specialist finds issues that 

would preclude permanent closure 

in any situation. Examples might 

include a cultural site that cannot 

be disturbed, terrain that precludes 

access by heavy equipment, or a site 

that has wildlife habitat value and 

requires gating rather than backfilling. A simultaneous site visit by 

all specialists also saves time and 

confusion on remote or hard-toaccess sites. 

Once these initial surveys are completed, sites that require more intensive clearance can be listed. These 

may include detailed archaeological 

and cultural documentation, T&E 

clearances, or bat surveys. In some 

instances, it may be important to 

notify local law enforcement agencies of the intent to close sites, since 

AMLs are popular disposal sites for 

various criminal activities. 

A major challenge in the clearance process is tracking the status 

of the various surveys. Nevada 

State Office surveyors use an Excel 

spreadsheet, which includes the site 

name, number, legal status, geographic coordinates, hazard ranking, topographic quad, and other 

information. Cells are included for 

notes on the various surveys, and as 

each survey is completed, the information is summarized in the cell, 

along with the date and initials of 

the surveyor. An example of a portion of a spreadsheet is shown in the 

Table. The recorder includes a note 

on whether the site can be closed, 

with or without further work. It 

has proven best to have one person 

NO. 73 DATE 08/27/04

Range

HazardousMaterials

Resource Note 73

Page 1
responsible for these data, so that 

multiple versions do not evolve. As 

each update is made, the sheet is 

given a new version number so that 

the most up-to-date information 

is clearly indicated. As the spreadsheet is completed, the decision on 

whether the site should be backfilled, gated, or ignored becomes 

easy to make. At the same time, any 

remaining work to be done is clear. 

Scheduling is also facilitated, since 

sites can be easily grouped by access 

route or jurisdiction, and limitations are noted.

Contact

Christopher Ross, Ph.D.

Natural Resource Specialist

Bureau of Land Management

Nevada State Office

P.O. Box 12000

Reno, NV 89520

Phone: 775-861-6571

Email: c1ross@nv.blm.gov

Resource Note 73

Page 2

The Bureau of Land Management Resource Notes, which are 

posted on this Web site 

(http://www.blm.gov/nstc/resourcenotes/resnotes.html),

are early announcements of technical and informational topics for 

BLM personnel and their customers. Information contained in this 

Resource Note has not been peer-reviewed. Conclusions and 

opinions expressed herein do not necessarily represent those of BLM. 

Use of trade names does not imply U.S. government endorsement of 

commercial products.

Technical Editor - Deborah Harris (Debbie_Harris@blm.gov)

Science Editor - Brian St. George (Brian_St_George@blm.gov)

Graphic Designer - Ethel Coontz (Ethel_Coontz@blm.gov)

If you would like to prepare a Resource Note for electronic 

distribution, or if you have an idea or can suggest an author for a 

Resource Note, contact the Science Editor 

(e-mail: Brian_St_George@blm.gov; phone: 303-236-1930) with the 

topic and the name of the writer, including mailing address, 

phone number, and e-mail address.

Thank you for your interest in Resource Notes.

Range

Table. Clark County Orphan Hazards Proposed for Backfill—2003—Searchlight/Nelson Area.

Searchlight Area

HAZ 

ID 

NO

Cultural Survey results,

 date, initials

Tortoise/Biological Survey, 

results, date, initials

Bat Survey results, 

date, initials Closure method

 

CL-210 Cleared; 3/28/03; SR OK BT. owl nest w/3 eggs; 5/6/03; BB 1 Townsend’s big-eared bat; EP 5/6/03, BB A: Bat/owl-compatible 

closure (fence)

CL-936 Cleared; 3/28/03; SR OK BT. Say’s phoebe nest; 5/6/03; BB No bat habitat; SL 5/6/03; BB C: Close after doing wildlife check 

CL-1545 No info; 6/30/03; SR No wildlife habitat; 5/6/03; PB D: Backfill

CL-171 If backfilling, will require photodocumentation; 6/30/03; SR OK BT. Road access. Transplant cacti. Woodrats; 5/6/03; PB Bat activity on video; guano throughout 

mine; EA and V 5/6/03; PB A: Bat gate

CL-229 Cleared; 3/28/03; SR OK BT. Possible tortoise turds; large woodrat nest; SL 

5/7/03; PB

Probably not bat habitat; need to watch 

or dig out portal to enter.

B: Survey again before 

closing E

CL-230 Cleared; 3/28/03; SR OK BT. Avoid cacti and yucca. No wildlife seen; 5/7/03; PB Possible bat habitat behind boards; SL 

5/7/03; PB

B: Survey again before 

closing and net first

CL-231 Cleared; 3/28/03; SR OK BT. Road Access. Rehab road in Fall. Tortoise bone fragments. Tortoise turds; Say’s phoebe nest; EA 5/7/03; PB No bats present; 5/7/03; PB A: Not hazardous; keep 

open NA

CL-982 If backfilling, will require photodocumentation; 6/30/03; SR OK BT. Road access. No wildlife habitat; 5/6/03; PB D: Backfill

CL-224 No info; 6/30/03; SR Chris saw cushion cacti nearby Phoebes present, OK to close, 4/11/03; CR B: Survey before closing?

CL-932 If backfilling, will require photodocumentation; 6/30/03; SR

OK No tortoise. Access issues 180’ cross country BT. Say’s 

phoebe nest; 5/5/03; PB

Issues with bats again and locals delete 

from consideration video-taped: no bats 

seen; V 5/5/03; PB

B: Survey again before 

closing

CL-933

Cultural issues; If backfilling will 

require complete documentation; 

6/30/03; SR

OK BT. Road access. woodrats; 5/5/03; PB Bat activity on video: Townsend’s and 

myotis; V and W 5/5/03; PB A: Bat gate

CL-934 If backfilling, will require photodocumentation; 6/30/03; SR OK BT. Road access No wildlife habitat; 5/5/03; PB D: Backfill

CL-935 If backfilling, will require photodocumentation; 6/30/03; SR OK BT. Road access. No wildife seen;5/5/03; PB One myotis entered after dark; W 

5/5/03; PB

C: Close after doing wildlife check

CL-1491

If backfilling, will require photodocumentation; 6/30/03; SR Would require 

SHPO consult SR 7/21/03

FENCE ONLY. Access issues and active burrow No wildife 

seen;5/8/03; BB D: Backfill

CL-172 If backfilling, will require photodocumentation; 6/30/03; SR

OK tortoise but access issues 300’ cross country No wildife 

seen; 5/5/03; PB D: Backfill

CL-105 If backfilling, will require photodocumentation; 6/30/03; SR

Tortoise turds; woodrat nest; 5/7/03; PB Kristin will move 

tortoises before filling nearby, but leave this one open No bat sign; EA 5/7/03; PB B: Survey again before closing E