Study supporting the elaboration of guidance on best practices in the extractive waste management plans : final report.
Date: 2019-09-23
Institutions: Directorate-General for Environment
Subjects: EU Member State, circular economy, directive (EU), mining extraction, report, waste disposal, waste management, waste recycling

Study supporting the elaboration of guidance on best 
practices in the Extractive Waste Management Plans 

Final Report 

Eco Efficiency Consulting and Engineering Ltd.  

in collaboration with WEFalck, Pöyry Finland Oy, Botond Kertész & 
CRS Ingenería 

September 2019 

  
 
  
 
 
    
 
           
 
      
 
 
 
 
 
 
070201/2017/768854/ETU/ENV.B.3 

i 

Client 

EUROPEAN COMMISSION 

Directorate-General for Environment 
Directorate B – Circular Economy & Green Growth 
Unit ENV.B.3 – Waste Management & Secondary Materials  

European Commission 

B-1049 Brussels 

Report title 

Date 

Project 

Project team 

Final  Report  -  Development  of  a  guidance  document  on  best 
practices 
the  Extractive  Waste  Management  Plans  – 
Implementation  of  the  Articles  5.2  and  5.3  of  the  Extractive 
Waste Directive (Directive 2006/21/EC) 

in 

September 2019 

Study supporting the elaboration of guidance on best practices in 
the Extractive Waste Management Plans 

Service contract № 070201/2017/768854/ETU/ENV.B.3 

Eco-Efficiency  Consulting  and  Engineering  Ltd  has  performed 
this  project  in  collaboration  with  the  following  subcontractors 
WEFalck (France), Pöyry Finland Oy (Finland), Botond Kertész 
(Hungary), and CRS Ingenería (Spain). 

Contact 

Eco Efficiency Consulting and Engineering Ltd 

G. Papandreou 60Α 
Dasos Haidariou 
12462 Athens 
Greece 

Tel: +30 210 5325110 & 111 

Fax: +30 210 5325112 

http://www.ecoefficiency.gr/en/ 

Disclaimer 

The information and views set out in this study are those of the 
authors and do not necessarily reflect the official opinion of the 
Commission. The Commission does not guarantee the accuracy 
of  the  data  included  in  this  study.  Neither  the  Commission  nor 
any  person  acting  on  the  Commission’s  behalf  may  be  held 
responsible  for  the  use  which  may  be  made  of  the  information 
contained therein. 

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LEGAL NOTICE 

This document has been prepared for the European Commission however it reflects the views only of the 
authors, and the Commission cannot be held responsible for any use which may be made of the 
information contained therein. 

More information on the European Union is available on the Internet (http://www.europa.eu). 

Luxembourg: Publications Office of the European Union, 2019 

PDF  

ISBN 978-92-76-10978-5 

  doi: 10.2779/842100 

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© European Union, 2019 
Reuse is authorised provided the source is acknowledged.  The reuse policy of European Commission 
documents is regulated by Decision 2011/833/EU (OJ L 330, 14.12.2011, p. 39). 

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Abstract 

The  Directive  2006/21/EC  on  the  management  of  waste  from  the  extractive  industries 
(EWD)  provides  measures,  procedures  and  guidance  to  prevent  or  reduce  as  far  as 
possible any adverse effects on the environment and any resultant risks on human health 
from the management of extractive waste. According to Article 5 of the EWD operators 
have  to  submit  an  extractive  waste  management  plan  (EWMP)  as  part  of  their  permit 
applications.  

The present study uses a wide range of information provided by Member States and the 
extractive industries, reflecting many years of experience with EWMPs, to identify best 
practices, as well as to outline a methodology to develop EWMPs.  

The focus is on (a) the prevention or reduction of extractive waste generation and of its 
harmfulness, (b) the recovery of extractive waste (by recycling, re-use or reclaiming), as 
well as (c) the assurance of short- and long-term safe disposal of extractive waste.  

The  study  comprises  two  guidance  documents,  which  were  developed  based  on  risk 
assessment  principles,  focusing  on  the  objectives  of  (a)  achieving  a  Circular  Economy 
throughout  the  whole  life-cycle  of  an  extractive  operation,  and  (b)  the  safety  of  the 
extractive waste at each stage of the life-cycle of an extractive waste facility. 

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Résumé 

La Directive 2006/21/CE sur la gestion des déchets de l’industrie extractive (ci-après ‘la 
directive’) prévoit des mesures, procédures et orientations visant à prévenir ou réduire les 
effets néfastes sur l'environnement et les risques pour la santé résultant de la gestion des 
déchets des industries extractives.  

En  conformité  avec  l’article  5  de  la  directive  sur  les  déchets  extractifs,  pour  l'octroi  de 
l’autorisation, les exploitants doivent soumettre un plan de gestion des déchets.  

Ce rapport utilise un large éventail d’informations fournies par les États membres et par 
les  industries  extractives,  reflétant  de  nombreuses  années  d'expérience  dans  la 
planification  et  la  gestion  des  déchets,  afin  d’identifier  des  exemples  de  meilleures 
pratiques,  tout  en  incluant  une  méthodologie  pour  développer  ces  plans  de  gestion  des 
déchets d'extraction (PGDE).  

L'accent  est  mis  sur  (a)  la  prévention  ou  réduction  de  la  production  des  déchets 
d'extraction  et  des  effets  nocifs  qui  en  résultent,  (b)  l’encouragement  de  la  valorisation 
des déchets d'extraction (la réutilisation et le recyclage), (c)  la certitude de l'élimination 
correcte à court et à long terme des déchets d'extraction.  

Ce  rapport  comprend  deux  documents  d'orientation  destinés  à  aider  (a)  à  réaliser  une 
économie  circulaire  tout  au  long  de  la  vie  d’une  opération  d’extraction  et  (b)  à  assurer 
l'élimination sûre des déchets d'extraction dans les installations de gestion de déchets tout 
au long de leur cycle de vie.  

Pour  établir  ces  guides,  les  informations  sont  analysées  sur  la  base  de  ces  principes 
d’évaluation des risques. 

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Contents 

Abstract ............................................................................................................................... ii 

Résumé ............................................................................................................................... iii 

List of figures ................................................................................................................ vii 

1. Executive summary ......................................................................................................... 1 

1.1 The Circular Economy Action .................................................................................. 2 

1.2 Short- and long-term safe disposal of extractive waste ............................................ 3 

1.3 Workshop with Member States and stakeholders ..................................................... 5 

2. Synthèse .......................................................................................................................... 6 

2.1 Un plan d’action en faveur de l’économie circulaire ................................................ 7 

2.2 Court et long terme élimination sûre des déchets d'extraction ................................. 9 

2.3 La réunion de travail avec les États membres et les parties prenantes ................... 11 

3.  Development  of  a  guidance  document  on  best  practices  in  the  Extractive  Waste 
Management Plans - Circular Economy Action ............................................................... 12 

3.1 General information ................................................................................................ 12 

3.1.1 Introduction .......................................................................................................12 

3.1.2 Background .......................................................................................................12 

3.1.3 Methodology .....................................................................................................14 

3.1.4 Initial assessment of the information gathered .................................................15 

3.1.5 Stakeholder consultation and workshop ...........................................................16 

3.2 Risk based considerations ....................................................................................... 18 

3.2.1 Scope and purpose of risk-based considerations ..............................................18 

3.2.2  Risk  based  considerations  used  in  the  development  and  evaluation  of  the 
EWMPs ......................................................................................................................18 

3.2.3 Risk identification along the life-cycle of an extractive operation ...................19 

3.3 Methodology to develop EWMPs ........................................................................... 24 

3.3.1 Introduction .......................................................................................................24 

3.3.2 The role of the mine life-cycle in drafting EWMP ...........................................25 

3.3.3 Guidelines for the development of an EWMP ..................................................26 

3.4  Best Practices from EWMPs related to Circular Economy................................ 30 

3.4.1 Best Practice 1: Effective exploration and site lay out .....................................30 

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3.4.2 Best Practice 2: Effective rock breaking ...........................................................34 

3.4.3 Best Practice 3: Efficient haulage .....................................................................35 

3.4.4 Best Practice 4: Effective ore sorting and selective ore processing ..................38 

3.4.5 Practice 5: Effective usage of excavated materials ...........................................39 

3.4.6 Best Practice 6: Effective management of topsoil ............................................43 

3.4.7 Best Practice 7: Disposal planning and management for later recovery ..........44 

3.4.8  Best  Practice  8:  Effective  monitoring  of  the  implementation  of  the  EWMPs 
and their review..........................................................................................................46 

3.5 References ............................................................................................................... 49 

4.  Development  of  a  guidance  document  on  best  practices  in  the  Extractive  Waste 
Management  Plans  Best  Practices  for  the  implementation  of  the  provisions  set  out  in 
Article 5(2)(c) and 5(3) of the Extractive Waste Directive .............................................. 51 

4.1 Introduction ............................................................................................................. 51 

4.1.1 Context ..............................................................................................................51 

4.1.2  Objectives of this report ...............................................................................52 

4.1.3 Provisions of the EWD .....................................................................................53 

4.2  Methodological considerations for developing EWMPs to ensure short- and 
long-term safe disposal of extractive waste. ................................................................. 56 

4.2.1 Conceptual framing – the dimension of time ....................................................56 

4.2.2 Integration into the mine planning and licensing process .................................57 

4.2.3 EWMPs and change management .....................................................................58 

4.2.4 Managing the implementation of an EWMP ....................................................59 

4.2.5 Risk Management in EWMPs ...........................................................................59 

4.2.6 The transition from operational to long-term safety .........................................61 

4.2.7 Recommended scope of EWMPs to ensure the short- and long-term safety of 
EWFs..........................................................................................................................68 

4.3 Proposed practices for closure, site rehabilitation, and long-term safety ............... 73 

4.3.1 Mine closure......................................................................................................73 

4.3.2 Site rehabilitation ..............................................................................................74 

4.3.3 Enhancing the long-term stability of EWFs......................................................76 

4.3.4 Securing the long-term stability of extractive wastes .......................................79 

4.3.5 Long-term management and stewardship .........................................................82 

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4.3.6 Record keeping and maintenance. ....................................................................82 

4.4 Proposed practices for special issues to be considered in EWMPs ........................ 84 

4.5 Potential ‘Best Practices’ in the EMWPs reviewed ................................................ 89 

4.6 Assessment of collected EWMPs as per stated objectives ..................................... 97 

4.6.1 Processes that lead to extraction .......................................................................97 

4.6.2 The characterisation and quantification of wastes according to Annex II of the 
EWD over the whole life-cycle. .................................................................................98 

4.6.3 Category A facilities: accident prevention policies, safety management system, 
and internal emergency plans.....................................................................................98 

4.6.4 Non-Category A facilities: information on justification including identification 
of possible accident hazards .......................................................................................99 

4.6.5 Assessments of potential environmental and human health impacts ..............100 

4.6.6 Preventive measures taken to minimise operational and post-closure impacts……………………………………………………………………………101 

4.6.7 Control and monitoring procedures (Articles 10 and 11(2)(c) EWD) ............102 

4.6.8 Surveys of the conditions of the land to be affected by the waste facility......102 

4.7  Conclusions ...................................................................................................... 104 

4.8 References ............................................................................................................. 105 

4.9 Best Practice Examples ......................................................................................... 109 

4.9.1 Best Practice Example A: Safe management of bauxite wastes ........................ 109 

4.9.2 Best Practice Example B: Landscaping for increased erosion resistance .......... 114 

4.9.3 Best Practice Example C: Stabilisation of reactive wastes ................................ 119 

4.9.4 Best Practice Example D: Waste segregation for targeted deposition to reduce 
chemical potentials...................................................................................................... 120 

4.9.5 Best Practice Example F: In situ rehabilitation of EW to remove the source for 
metal contamination .................................................................................................... 121 

4.9.6 Best Practice Example G: Integration into Natura 2000 and World Heritage 
regions ......................................................................................................................... 123 

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List of figures 
Figure 3-1: The mine life cycle ........................................................................................ 13 
Figure 3-2: Percentage distribution of the sectors from which data could be collected. . 16 
Figure 3-3: General Risk Assessment methodology scheme ........................................... 19 
Figure  3-4:  Decision  tree  for  waste  characterisation  under  the  provisions  of  COM 
Decisions ........................................................................................................................... 21 
Figure 3-5: Extractive waste as part of the mine life cycle .............................................. 26 
Figure  3-6:  Parameters  related  to  the  Circular  Economy  as  applied  in  the  extractive 
sector ................................................................................................................................. 30 
Figure 3-7: Typical integrated approach to road design (Thompson, 2010) ................... 36 
Figure 4-1: The phases in a mine life-cycle that will determine the EWM solution ....... 52 
Figure 4-2: The life-cycle of an extractive operation. ..................................................... 57 
Figure 4-3 The principle of continuous improvement (MAC, 2017) .............................. 59 
Figure 4-4: Risk Source-Pathway-Receptor model ......................................................... 60 
Figure 4-5: Different methods of raising tailings dams (WEF) ....................................... 64 
Figure 4-6: Anglo-American Tool-Box for mine closure (2016) .................................... 73 
Figure 4-7  The principal strategies for dealing with contamination (WEF). .................. 75 
Figure  4-8  Strategies  to  reduce  the  potential  (or  relief)  energy  stored  in  waste  dumps 
(WEF). .............................................................................................................................. 78 
Figure 4-9 Three examples for cover construction over tailings from the USA (Source: 
WEF). ................................................................................................................................ 79 
Figure  4-10:  Alumina  producers  across  Europe  (Source:  https://www.european-
aluminium.eu/data/industry-overview/european-overview-aluminium-plants-location/) 95 

List of tables 

Table 3-1 Example contents of an EWMP ....................................................................... 27 
Table 4-1 Scope of an Extractive Waste Management Plan ............................................ 69 
Table  4-2  List  of  industrial  sectors  involving  naturally-occurring  radioactive  material 
(European Council, 2014 – Annex VI). ............................................................................ 85 
Table 4-3 Indicative list of types of building materials considered with regard to their 
emitted gamma radiation as referred to in Article 75 of European Council (2014). ........ 86 
Table 4-4 Extractive operations with a Category A EWF provided factsheets ............... 98 

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1. Executive summary 

The  present  report  constitutes  the  final  output  from  a  Study  commissioned  by  DG 
Environment  under  Contract  No.  070201/2017/768854/ETU/ENV.B.3  with  a  view  to 
support  the  elaboration  of  guidance  on  best  practices  in  the  Extractive  Waste 
Management  Plans  (EWMPs)  according  to  Directive  2006/21/C  on  Extractive  Waste 
(EWD). The study was performed by Eco-Efficiency Consulting and Engineering Ltd. 
in  collaboration  with  the  following  subcontractors:  WEFalck,  Pöyry  Finland  Oy, 
Botond Kertész, and CRS Ingenería. The study resulted in two guidance documents: (1) 
Best  Practices  in  Extractive  Waste  Management  Plans  (EWMPs)  with  regard  to  the 
provisions  of  the  Circular  Economy  Action  Plan,  and  (2)  Best  Practices  for  the  safe 
disposal  of  extractive  waste.  The  present  report  includes  (a)  this  Executive  Summary, 
(b)  the  consolidated  guidance  document  on  Best  Practices  in  EWMPs  supporting  the 
circular  economy  paradigm,  which  considers  Member  States’  and  stakeholders’ 
comments  received  during  a  technical  workshop  held  in  Brussels  on  12  of  September 
2018  (Ch.  3),  and  (c)  a  consolidated  document  on  Best  Practices  implementation 
concerning  the  provisions  set  out  in  Articles  5(2)(c)  and  5(3)  of  the  EWD),  which 
includes comments received from DG ENV (Ch. 4).  

The work undertaken included: 

  Data  collection  and  evaluation  of  the  data  provided  by  the  European  Commission, 
that resulted from a call for input, asking Member States to provide one or more of 
the  following  items:  (a)  their  guidelines  on  how  to  develop  extractive  waste 
management  plans,  (b)  extractive  waste  management  plans  (EWMPs)  submitted  to 
the  competent  national  authorities,  (c)  pre-selected  EWMPs  comprising  candidate 
best  practices,  and  (d)  candidate  best  practices  related  to  the  Circular  Economy 
paradigm. 

  Assessment  of  the  information  provided  and  of  further  data  collated  by  the 
contractors, enriched through country visits to France, Greece, Hungary, Spain, and 
Sweden,  as  well  as  bibliographic  research  in  order  to  propose  a  methodology  to 
develop  EWMP,  under  the  principles  of  risk  analysis,  risk  evaluation  and  risk 
treatment.  

  Identification of Best Practices in Extractive Waste Management Plans in view of: 

o  Article  5(2)(a)  of  the  EWD:  the  prevention  or  reduction  of  extractive  waste 

generation and of its harmfulness 

o  Article  5(2)(b)  of  the  EWD:  the  recovery  of  extractive  waste  by  means  of 

recycling, re-using or reclaiming such waste. 

o  Article 5(2)(c) and Article 5(3) of the EWD: Ensuring the short- and long-term 
safety of the extractive waste, in particular by considering as part of the design 
phase, the management during the operation and after closure of a waste facility 
  A stakeholder workshop on the results that arose from the first phase of the project 
concerning  the  best  practices  that  contribute  to  Circular  Economy  aspects  in  the 
EWMPs. 

These  two  guidance  documents  are  intended  as  legally  non-binding.  They  target 
competent authorities and extractive industry operators, aiming to integrate the Circular 
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Economy principles and key elements of short- and long-term safe waste management 
into EWMPs. The project covers all extractive industries (energy minerals, metal ores, 
industrial  and  construction  minerals).  The  undertaking  was  independent  of  and 
complementary  to  the  work  on  the  Best  Available  Techniques  reference  document  on 
the management of waste from extractive industries (MWEI BREF, 20181). 

1.1 The Circular Economy Action 

The Communication “Closing the loop - An EU action plan for the Circular Economy”2 
describes  the  ‘Circular  Economy’  as  an  economy  wherein  the  value  of  products, 
materials  and  resources  is  maintained  for  as  long  as  possible,  and  the  generation  of 
waste  minimised.  The  circular  economy  aspects,  such  as  prevention  or  reduction  of 
waste  generation  and  of  the  harmfulness  of  wastes,  as  well  as  recovery  of  extractive 
waste by ways of recycling, re-use or reclaiming such waste are stipulated in Article 5 
“Waste Management Plan” of the EWD. The first deliverable of the present study was 
focused on the provisions of Articles 5(2)(a) and 5(2)(b) of the EWD.  

The  EWMPs  from  extractive  industries  across  collated  were  reviewed  with  respect  to 
the criteria set  out  in the Circular Economy Action Plan. It  should be highlighted that 
the EWD and in particular its Article 5 reflected already in  2006 what  is in essence a 
Circular Economy perspective.  

Extractive waste management planning can be a complex process and is influenced by 
the  geological,  geochemical,  climatological,  and  social  conditions  of  the  location  of 
each  deposit.  For  this  reason,  in  the  present  study  a  systemic  life-cycle  approach  was 
chosen.  Specifically,  the  proposed  practices  in  the  field  of  recycling  and  recovery  of 
extractive waste (potential use) may be applied to the first five basic phases in a mining 
life-cycle  (exploration,  design,  construction,  extraction,  and  processing),  and  which 
have direct  consequences on the generation and  management of the  extractive wastes. 
The  study  highlights  that  effective  extractive  material  management  begins  with  the 
design phase of a mine, since extractive waste generation can be reduced by optimising 
mineral  extraction  and  processing.  Depending  on  the  formation  that  is  mined,  an 
optimisation of the mineral extraction and processing can be achieved by strengthening 
the  role  of  the  two  first  steps  of  the  mining  life-cycle  (exploration  and  design). 
Developing  new  strategies  and  technologies  that  address  how  to  increase  recycling  of 
waste will further reduce the amount of such waste to be disposed. 
A  total  of  75  Fact-Sheets  were  prepared,  based  on  the  EWMPs  collected  and  through 
the country visits. The majority of the information available pertained to metal ores and 
construction  or  industrial  minerals.  The  results  from  the  data  collection  process 
demonstrated  that  the  extractive  industry  actively  searches  for  strategies  to  maximise 
resource use and waste  minimisation. In  general, if there is  market,  excavated  ‘waste’ 
materials are sold off. The practices mostly concern: 

1  Garbarino,  E.,  Orveillon,  G.,  Saveyn,  H.G.M.,  Barthe,  P.,  Eder,  P.  (2018):  Best  Available  Techniques  (BAT)  Reference  Document  for  the 
Management of Waste from Extractive Industries in accordance with Directive 2006/21/EC.- JRC Science for Policy Report, EUR 28963 EN: 722 p., 
http://publications.jrc.ec.europa.eu/repository/handle/JRC109657  
2 European Commission. (2015): Communication from the Commission to the European Parliament, the Council, The European Economic and Social 
Committee and the Committee of the Regions. Closing the loop - An EU action plan for the Circular Economy.- COM(2015) 614 final. Brussels. 
https://eur-lex.europa.eu/resource.html?uri=cellar:8a8ef5e8-99a0-11e5-b3b7-01aa75ed71a1.0012.02/DOC_1&format=PDF. 
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  considerations of extractive waste generation and its management at the design phase 
  filling excavation voids with extractive material (Note: in some MSs these excavated 
materials are considered as waste and in some others as secondary raw material; the 
scope of the present guidance is only to present techniques that strengthen the role of 
the Circular Economy and not to discuss what is waste and what not) 

  utilising  waste  rock  in  different  kinds  of  earthworks  on  site  during  active  mining 

operations, as landscaping material during rehabilitation 

  marketing  waste rock as  aggregate, for  general  civil  engineering  applications, or to 

the chemical industry 

  recycling or re-using of historical extractive waste 
  recycling of waste water 
  segregation and re-use of topsoil, either for rehabilitation or as marketable product 

The  assessed  information  was  cast  into  a  Background  Document  that  was  sent  for 
review  to  a  wide  range  of  stakeholders,  such  as  competent  authorities,  the  extractive 
industry, the Expert Group on Waste, the Raw Materials Supply Group, the Technical 
Working  Group  on  the  Best  Available  Techniques  Reference  document  on  the 
management  of  waste  from  extractive  industries,  academia  and  NGOs,  in  order  to  be 
commented on and to solicit additional practices. These experts were also invited to a 
Workshop on ‘Best Practices of Extractive Waste Management Plans’, that was held on 
12 September 2018 in Brussels. 

The  revised  guidance  that  includes  the  comments  received  forms  Chapter  3  of  this 
report. 

The Guidance does not undertake to interpret EU waste legislation, including Article 5 
of the EWD, but aims to link the relevant provisions of Article 5 with the objectives of 
the  Circular  Economy  Action  Plan,  covering  all  facets  of  the  extractive  sectors.  The 
‘practices’  illustrated  are  more  generic  and  focus  on  resource  management  aspects  in 
the extractive sector that can play a central role in the Circular Economy.  

The  guidance  combines  comprehensive  risk-based  considerations  for  the  selection  of 
appropriate  waste  management  options  with  the principles  of  Circular  Economy.  Risk 
based  considerations  contribute  to  setting  priorities  for  environmental  and  societal 
protection in an objective and scientific way. The combination of information on risks 
and  impacts  is  helpful  to  develop  workable  solutions  for  the  specific  context  of  a 
country  and  an  extractive  operation.  Hence,  a  risk-based  methodology  to  develop 
EWMPs  is  proposed,  by  providing  a  selection  of  examples  and  details  from  already 
submitted EWMPs from different extractive industries that are operating in Europe. 

1.2 Short- and long-term safe disposal of extractive waste 

EWMPs should reflect in a structured way the planning of waste management options 
with a view to meet the objectives of Article 5 of the EWD. The key to environmentally 
safe  and  responsible  management  of  tailings  is  an  effective  management  framework 
throughout  the  full  life-cycle  of  an  extractive  waste  facility.  Objectives  such  as  (a) 
protection of public health & safety, (b) mitigation of negative environmental impacts, 
and (c) safe after-closure procedures are the key concepts that have to be incorporated 

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into  the  EWMPs.  This  guidance  document  outlines  the  conceptual  approaches  to 
develop  EWMPs  with  respect  to  the  criteria  set  out  in  Articles  5(2)c  and  5(3)  of  the 
EWD,  and  it  provide  examples  of  best  practices  that  have  been  identified  in  the 
reviewed EWMPs. 

This guidance document forms Chapter 4 of this report.  

Ensuring  short-term  operational  safety  not  only  encompasses  technical  measures  and 
designs,  but  also  management  measures.  The  EWMPs  reviewed  cover  predominantly 
the  operational  aspects  and  are  concerned  with  compliance  with  applicable  rules  and 
regulations.  However, the dimension of time in  the sense of long-term  stability of the 
chosen  management  solutions  for  EW  and  EWFs  mostly  is  not  mentioned  explicitly. 
Hence,  the  guidance  is  particularly  concerned  with  the  dimension  of  time  of  the 
EWMPs, namely with the long-term safety and stability of the selected EWM solutions. 
The long-term manageability of mining residues depends inter alia on their nature and 
quantity,  which  in  turn  depend  on  the  host  geology,  as  well  as  the  mining  and 
processing methods.  

This  exercise  is  independent  of  and  complementary  to  the  work  on  the  revised  Best 
Available  Techniques  reference  for  the  Management  of  Waste  from  Extractive 
Industries  in  accordance  with  the  EWD,  which  is  focusing  on  ensuring  geotechnical, 
environmental  and  human  health  &  safety  of  EWFs  (short-term).  Therefore,  the 
guidance focuses explicitly on the differences between operational and long-term safety 
features and provisions.  A continuum of geotechnical and environmental safety has to 
be assured during the transition from the operational to the post-closure phase. A life-
cycle  perspective  during  planning  ensures  a  smooth  transition  and  an  efficient  use  of 
resources by considering the requirements of the post-closure phase already during the 
operational  phase.  Such  an  approach  also  has  the  advantage  that  the  closure  of 
extractive waste facilities is not left until the mining operation ceases, which reduces the 
phenomenon of abandoned extractive waste facilities. 

The  EWD  requires  the  establishment  of  post-closure  monitoring  procedures.  The 
monitoring  provides  assurance  that  the  EWF  functions  as  designed  and  complements 
the  records  produced  during  the  exploratory  and  operational  phases.  The  respective 
records will also facilitate maintenance and repair during long-term management. 

Recent  events,  such  as  the  tailings  dam  accidents  in  Brazil,  have  highlighted  the 
importance of comprehensive risk management, including adequate risk identification, 
risk  analysis,  risk  evaluation  and  risk  mitigation.  Risk  and  its  management  are  major 
drivers  behind  extractive  waste  management  concepts  and  solutions.  Risk-based 
decision-finding  helps  to  focus  the  EWMP  on  the  essential  aspects  and,  hence,  to  use 
resources efficiently, while maximising the levels of protection of the environment and 
human health.  

One  issue  that  became  apparent  during  the  evaluation  of  the  EWMPs  was  (potential) 
conflicts between the objectives for the safe disposal of extractive waste and the circular 
economy  policies.  Decisions  to  declare  some  extracted  materials  as  waste  and  to 
proceed to disposal are made, when no beneficial use for the waste can be found, which 
in turn often depends on the economic context at the time. In consequence, such wastes 
may  still  contain  components  that  could  become  valuable  at  some  later  point  in  time. 
Whether these materials can be recovered later depends on the chosen disposal method. 
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Near-surface repositories, such as waste-rock dumps or tailings ponds may be relatively 
easily accessed and reworked. The situation is different for materials placed into deep 
mines, where re-entering after closure is difficult and can be dangerous. This dilemma 
between long-term safe extractive waste management solutions and maintaining access 
to potentially valuable resources needs to be carefully weighed, during the development 
of an EWMP. 

Although radiation protection aspects are not subject of the EWD, the guidance tries to 
shed  a  light  on  the  issue  of  Naturally-Occurring  Radioactive  Materials  (NORM),  by 
providing a comprehensive overview according to Directive 2013/59/EURATOM3, also 
known as the EU Basic Safety Standards for Radiation Protection (BSS). 

It was noted that long-term stability as postulated in the EWD has not been reflected in 
the EWMPs that could be evaluated for the purposes of this project. For this reason, the 
proposed  Best  Practices  mainly  concern  rehabilitation  examples.  The  perceived  gaps 
were  filled  by  referring  to  information  and  a  wide  range  of  guidance  documents 
produced by the industry itself, its associations, and international bodies. 

1.3 Workshop with Member States and stakeholders 

To  promote  the  exchange  of  information  on  best  practices  a  Workshop  on  ‘Best 
Practices  in  Extractive  Waste  Management  Plans  with  relevance  to  the  Circular 
Economy  Action  Plan’  was  held  on  12  September  2018  in  Brussels.  The  participants 
were  experts  from  Member  States  (Finland,  Ireland,  Netherlands,  Spain,  France  and 
Sweden),  stakeholders  from  associations  and  extractive 
industries  (Euromines, 
Euracoal,  IMA-Europe,  Federation  of  Norwegian  Industries,  and  The  Global  Oil  and 
Gas  Industry  Trade  Association),  from  the  Commission  (DG  Environment  and  DG 
Grow), as well as the project consortium. The experts and other stakeholders provided 
insights on the perspectives that should be considered during the drafting of EWMPs, as 
well as comments on specific topics of particular concern for the industry.  

3 Directive 2013/59/EURATOM of 5 December 2013 laying down basic safety standards for protection against the dangers arising from 
exposure  to  ionising  radiation,  and  repealing  Directives  89/618/Euratom,  90/641/Euratom,  96/29/Euratom,  97/43/Euratom  and 
2003/122/Euratom.- OJ of the European Union of 17.01.2014: L13/1-L13/73  
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2. Synthèse 

6 

Le 

Ce rapport est le rapport final d’une étude commandée par la DG Environnement  afin 
en vue de soutenir l'élaboration d'orientations sur les meilleures pratiques dans le cadre 
des  plans  de  gestion  des  déchets  extractives  (PGDE),  en  conformité  avec  la  Directive 
2006/21/EC  (ci-après  ‘la  Directive’)  concernant  la  gestion  des  déchets  de  l'industrie 
extractive. 
référence 
070201/2017/768854/ETU/ENV.B.3.  L'étude  a  été  réalisée  par  Eco-Efficiency 
Consulting  and  Engineering  Ltd.  en  collaboration  avec  WEFalck,  Pöyry  Finland  Oy, 
Botond Kertész et CRS Ingenería. Ce rapport comprend deux documents d’orientation : 
(1) Les meilleures pratiques dans le cadre des plans de gestion des déchets concernant 
les  dispositions  d’un  plan  d’action  en  faveur  de  l’économie  circulaire  et  (2)  les 
meilleures pratiques pour l'élimination sûre des déchets d'extraction.  

en  œuvre 

de  mise 

contrat 

porte 

la 

Ce  rapport  comprend:  (a)  cette  synthèse,  (b)  la  version  consolidée  du  document 
d'orientation sur les meilleures pratiques dans le cadre des plans de gestion des déchets 
extractives  en  faveur  de  l’économie  circulaire,  en  tenant  compte  des  commentaires 
reçus lors d’une réunion de travail qui s’est tenue à Bruxelles le 12 septembre 2018 (ch. 
3),  et  (c)  un  document  consolidé  sur  la  mise  en  œuvre  des  meilleures  pratiques 
concernant  les  dispositions  énoncées  à  l'article  5,  paragraphe  2,  points  c)  et  5, 
paragraphe  3,  de  la  Directive),  qui  comprend  les  commentaires  reçus  de  la  DG  ENV 
(ch. 4). 

Les travaux entrepris incluent :  

 

la  collecte  de  données  et  l'évaluation  des  données  fournies  par  la  Commission 
Européenne,  résultant  d'un  appel  à  contribution,  invitant  les  États  membres  à 
fournir  un  ou  plusieurs  des  éléments  suivants  (a)  leurs  lignes  directrices  sur  la 
manière de développer des plans de gestion des déchets de l'industrie extractive, 
b)  plans  de  gestion  des  déchets  de  l'industrie  extractive  soumis  aux  autorités 
nationales  compétentes,  c)  des  plans  présélectionnés  concernant  la  gestion  des 
déchets  d'extraction  incluant  les  potentielle  meilleures  pratiques  d)  les 
potentielle meilleures pratiques liées au paradigme de l'économie circulaire. 
  Evaluation des informations fournies et des autres données rassemblées par les 
contractants,  enrichies  par  des  visites  en  France,  en  Grèce,  en  Hongrie,  en 
Espagne  et  en  Suède,  ainsi  que  par  une  recherche  bibliographique  afin  de 
proposer une méthodologie de développement de PGDE, selon les principes de 
l’analyse du risque, évaluation des risques et traitement des risques. 
Identification  des  meilleures  pratiques  dans  les  plans  de  gestion  des  déchets 
d’extraction en vue de : 

 

o  L'article  5(2)(a)  de  la  Directive :  prévenir  ou  réduire  la  production  de 

déchets et les effets nocifs qui en résultent 

o  L'article  5(2)(b)  de  la  Directive :  la  récupération  des  déchets  de 
l'industrie extractive par des moyens de recyclage, de réutilisation ou de 
valorisation de ces déchets.  

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o  Les  articles5(2)(c)  et  5(3)  de  la  Directive :  assurer  l'élimination  sûre  à 
court et à long terme des déchets d'extraction, particulièrement en tenant 
compte,  durant 
la  gestion  pendant 
l'exploitation et après la fermeture de l'installation de gestion de déchets.  
  Une  réunion  de  travail  des  parties  prenantes  sur  les  résultats  de  la  première 
phase  du  projet  concernant  les  meilleures  pratiques  contribuant  aux  aspects 
d'économie circulaire dans les PGE. 

la  phase  de  conception,  de 

  Ces  deux  documents  servent  de  guide  et  ne  sont  pas 

juridiquement 
contraignants.  Ils  ciblent  les  autorités  compétentes  et  les  exploitants  des 
industries  extractives,  afin  d’intégrer  dans  les  plans  de  contrôle  des  déchets 
d’extractions  les  principes  de  l’économie  circulaire  et  des  éléments-clés  de  la 
gestion  sûre  des  déchets  à  court  et  à  long  terme.  Le  projet  couvre  toutes  les 
industries  extractives  (les  minéraux  industriels,  les  combustibles  minéraux 
solides, les minéraux de construction, les minerais métalliques).  Ce projet a eu 
lieu  indépendamment  et  en  complément  du  document  de  référence  sur  les 
meilleures  techniques  disponibles  (BREF)  relatif  à  la  gestion  des  déchets  de 
l'industrie extractive (MWEI BREF, 20184). 

2.1 Un plan d’action en faveur de l’économie circulaire 

La  Communication  “Boucler  la  boucle  -  Un  plan  d'action  de  l'Union  Européenne  en 
faveur de l'économie circulaire”5 décrit l’économie circulaire dans laquelle la valeur des 
produits, des matières et des ressources est maintenue aussi longtemps que possible et la 
production  des  déchets  est  réduite  au  minimum.  Les  aspects  de  l’économie  circulaire, 
tel que prévenir ou réduire la production des déchets et les effets nocifs qui en résultent 
et encourager la valorisation des déchets d'extraction en les recyclant, en les réutilisant 
ou  en  les  valorisant  sont  stipulés  à  l'article  5  “Plan  de  gestion  des  déchets”  de  la 
Directive  sur  les  déchets  extractifs.  Le  premier  livrable  de  cette  étude  s’est  concentré 
sur les dispositions de l’article 5 (2) (a) et 5 (2) (b) de la Directive. 

Les  plans  de  gestion  des  déchets  de  l'industrie  extractive  sont  évalués  conformément 
aux principes de l'économie circulaire. Il faut souligner que, la Directive sur les déchets 
extratifs, en particulier son article 5, reflétait déjà en 2006 ce qui était l’essence d’une 
transition vers une économie circulaire. 

La planification de la gestion des déchets d'extraction est un processus complexe et est 
influencée par les conditions géologiques, géochimiques, climatologiques et sociales du 
dépôt naturel. Pour cette raison, une approche systémique du cycle de vie a été choisie. 
Plus précisément, les meilleures pratiques proposées concernent principalement les cinq 
premières  phases  du  cycle  de  vie  minier  (prospection,  conception/aménagement, 
construction, extraction et traitement des minéraux) puisque ces étapes sont directement 
liées à la génération et à la gestion des déchets d'extraction.  

4 Garbarino, E., Orveillon, G., Saveyn, H.G.M., Barthe, P., Eder, P. (2018): Best Available Techniques (BAT) Reference Document for the 
Management of Waste from Extractive Industries in accordance with Directive 2006/21/EC.-  JRC Science for Policy Report, EUR 28963 
EN: 722 p., http://publications.jrc.ec.europa.eu/repository/handle/JRC109657  
5 Commission Européen (2015): Communication de la Commission au Parlement Européen, au Conseil, au Comité Économique et 
Social Européen et au Comité des Régions. Boucler la boucle - Un plan d’action de l’Union européenne en faveur de l’économie 
circulaire.- COM(2015) 614 final. Brussels. https://eur-lex.europa.eu/resource.html?uri=cellar:8a8ef5e8-99a0-11e5-b3b7-
01aa75ed71a1.0003.02/DOC_1&format=PDF. 
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L'étude  souligne  qu'une  gestion  efficace  des  matières  extractives  commence  dès  la 
phase  de  conception  de  la  mine,  car  la  production  de  déchets  d'extraction  peut  être 
réduite  en  optimisant  l'extraction  et  le  traitement  des  minéraux.  En  fonction  de  la 
formation extraite, il est possible d'optimiser l'extraction et le traitement du minerai en 
renforçant  le  rôle  des  deux  premières  étapes  du  cycle  de  vie  de  l'exploitation  minière 
(exploration  et  conception).  La  mise  au  point  de  nouvelles  stratégies  et  technologies 
visant à accroître le recyclage des déchets permettra de réduire davantage la quantité de 
ces déchets à éliminer. 

Au total, 75 fiches d’information ont été préparées, sur la base des plans de gestion des 
déchets  extractifs  collectés  et  lors  des  visites  dans  les  pays.  La  majorité  des 
informations  disponibles  concernait  les  minerais  métalliques  et  les  minéraux  de 
construction ou industriels. Les résultats du processus de collecte de données ont montré 
que  l'industrie  extractive  recherchait  activement  des  stratégies  pour  maximiser 
l'utilisation des  ressources et  minimiser les déchets.  En général,  s’il  existe un  marché, 
les «déchets» de fouilles sont commercialisés. Les pratiques concernent principalement 
: 

  Les  considérations  sur  la  production  de  déchets  des  industries  extractives  et  de  la 

gestion de ces déchets dès la phase de conception 

  Replacer  les  déchets  d'extraction  dans  les  trous  d'excavation  après  l'extraction  des 
minéraux (Remarque : certains États membres considèrent ces matériaux comme des 
déchets  et  d’autres  comme  des  matières  premières  secondaires.  Ce  document 
présente  des  techniques  en  faveur  de  l'économie  circulaire ;  son  but  n'est  pas  de 
discuter de ce qui est déchet et de ce qui ne l'est pas.) 

  Encourager la valorisation des stériles pendant les opérations minières actives pour la 
réalisation  des  terrassements  et  à  des  fins  de  remise  en  état  comme  matériau 
d'aménagement ;  

  Commercialiser  des  stériles  en  tant  qu’agrégats,  pour  des  applications  générales  de 

génie civil ou pour l’industrie chimique ;  

  Encourager  la  valorisation  des  déchets  d'extraction  en  les  recyclant  les  déchets 

historiques ;  

  La réutilisation ou recyclage des eaux usées ;  
  La  ségrégation  et  la  réutilisation  la  couche  arable  pour  la  réhabilitation  après  la 

fermeture de l'installation ou en tant que produit commercialisable ;  

Les  informations  évaluées  ont  été  intégrées  dans  un  document  de  travail  qui  a  été 
envoyé à un large éventail de parties prenantes pour révision ; y étaient impliquées : des 
autorités  compétentes,  l'industrie,  le  groupe  d'experts  sur  les  déchets,  le  groupe 
l'approvisionnement  en  matières  premières,  les  membres  du  Groupe  de  Travail 
Technique du document de référence sur les meilleures techniques disponibles (BREF) 
relatif  à  la  gestion  des  déchets  de  l'industrie  extractive,  le  milieu  universitaire  et  les 
organisations non-gouvernementales (ONG). Ces experts ont été invités à la réunion de 
travail “Les  meilleures pratiques dans les plans de  gestion des déchets  en faveur d’un 

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plan  d’action  pour  l’économie  circulaire”  qui  s’est  tenue  à  Bruxelles  le  12  septembre 
2018. 

La  version  consolidée  du  document  d'orientation  sur  les  meilleures  pratiques  dans  les 
plans de gestion des déchets en faveur de l’économie circulaire est joint au chapitre 3 de 
ce rapport. 

Ce document n'interprète pas la législation de l'UE concernant la gestion des déchets de 
l'industrie  extractive  et  l’Article  5  de  la  Directive,  mais  l'accent  est  mis  sur  le 
rattachement  des  dispositions  de  l'Article  5  aux  objectifs  du  plan  d'action  pour 
l'économie  circulaire  dans  toutes  les  industries  extractives.  Les  “  pratiques”  illustrées 
sont plus génériques et se concentrent sur les aspects de la gestion des ressources dans 
le secteur extractif qui peuvent jouer un rôle central dans l’économie circulaire. 

Le  document  d’orientation  combine  des  considérations  de  l'analyse  des  risques  et  du 
traitement des risques pour la sélection d'options de gestion des déchets appropriée en 
faveur de l'économie circulaire. Les considérations fondées sur les risques contribuent à 
établir  des  priorités  pour  la  protection  de  l'environnement  et  de  la  société  de  manière 
objective  et  scientifique.  La  gestion  des  risques  aidera  à  développer  des  solutions 
spécifiques et viables en conformité avec le contexte spécifique d'un pays, au cours de 
l'extraction  de  minéraux  ou  des  opérations  de  traitement.  Par  conséquent,  une 
méthodologie  fondée  sur  les  risques  pour  élaborer  des  plans  de  gestion  des  déchets 
d'extraction est proposée, en fournissant une sélection d'exemples et de détails des plans 
de  gestion  des  déchets  d'extraction  déjà  soumis  par  différentes  industries  extractives 
opérant en Europe. 

2.2 Court et long terme élimination sûre des déchets d'extraction 
Les  plans  de  gestion  des  déchets  devraient  être  structurés  de  manière  à  permettre  une 
planification  adéquate  des  options  en  matière  de  gestion  des  déchets  d’extraction,  en 
conformité  avec  les  dispositions  de  l'article  5  de  la  Directive.  La  clé  visant  à  garantir 
une  gestion  environnementale  sûre  et  responsable  des  résidus  miniers  s’avère  être  un 
cadre  de  gestion  efficace  tout  au  long  cycle  de  vie  des  installations  de  gestion  de 
déchets.  Les  objectifs  tels  que  (a)  la  protection  de  la  santé  publique  et  de  la  sécurité 
publique,  (b)  l'atténuation  les  effets  nocifs  pour  l'environnement  et  (c)  procédures 
sécuritaires après la fermeture de l'installation sont les concepts clés à intégrer dans les 
plans  de  gestion  des  déchets.  Ce  document  d'orientation  décrit  les  approches 
conceptuelles pour développer les plans de gestion des déchets en respectant les critères 
de l’Article 5(2)c et l’Article 5(3) de la Directive et fournit des exemples de meilleures 
pratiques qui ont été identifiées dans les plans de gestion des déchets examinés.  

Le document d'orientation est joint au chapitre 4 de ce rapport. 

Les  exploitants  des  industries  extractives  doivent  garantir  la  sécurité  opérationnelle  à 
court terme non seulement  en  incluant les mesures  techniques et  les  conceptions  mais 
aussi en mettant en oeuvre les mesures prises pour la gestion des déchets. Les plans de 
gestion  de  déchets  d'extraction  qui  sont  évalués  couvrent  principalement  les  aspects 
opérationnels  et  s’attachent  à  respecter  la  réglementation  en  vigueur.  Cependant,  la 

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dimension  du  temps  dans  le  sens  de  garantie  de  la  stabilité  (physique  et  chimique)  à 
long terme des solutions choisies pour le management des déchets extractifs et pour le 
management  des  installations  d'extraction  de  déchets,  la  plupart  du  temps  n'est  pas 
mentionnée explicitement.  

Par  conséquence,  le  document  d'orientation  est  particulièrement  concerné  par  la 
dimension du temps dans les plans de gestion de déchets extractifs, en particulier par la 
garantie de la stabilité à long terme des solutions de management des déchets extractifs.  

La nature et la quantité des déchets d'extraction, qui dépendent du contexte géologique 
du gisement, ainsi que de l'extraction des minéraux et les opérations de traitement sont 
des paramètres qui influencent la capacité de gestion à long terme des résidus. 

Cet exercice a eu lieu indépendamment et en complément du document de référence sur 
les  meilleures  techniques  disponibles  (BREF)  relatif  à  la  gestion  des  déchets  de 
l'industrie extractive, qui se concentre à assurer la stabilité géotechnique à court terme et 
prévenir  les  effets  néfastes,  sur  l'environnement  ou  sur  la  santé  des  personnes.  Par 
conséquent,  ce  document  se  concentre  explicitement  sur  les  différences  entre  les 
dispositions  de  la  directive,  mesures  de  sécurité  opérationnelle  et  les  paramétrés  de 
sécurités  pour  déposer  des  déchets  à  long  terme.  Pendant  la  transition  de  la  phase 
opérationnelle  à  la  phase  après  la  fermeture  les  exploitants  des  industries  extractives 
prennent  toutes  les  mesures  nécessaires  pour  assurer  une  continuité  de  sécurité 
géotechnique  et  environnementale.  La  perspective  du  cycle  de  vie  lors  de  la 
planification  assure  l’utilisation  efficace  des  ressources  en  considérant  les  exigences 
dans  la  phase  après  la  fermeture,  pendant  la  phase  opérationnelle.  Une  telle  approche 
présente également  l’avantage  que la fermeture  des installations  de gestion de déchets 
des industries extractives, n’a pas lieu jusqu'à ce que les opérations minières aient cessé. 
Cette approche réduit le phénomène d’installations de gestion de déchets abandonnées. 

La  Directive  exige  d'assurer  la  stabilité  des  déchets  et  de  garantir  un  monitoring 
approprié après  la cessation  des opérations.  Le  monitoring  des  installations de gestion 
de  déchets  fournit  l'assurance  que  l’installation  fonctionne  comme  prévu.  Cette 
procédure  complète  également  la  documentation  des  produits  au  cours  des  phases 
exploratoires et opérationnelles. Cette documentation est censée faciliter la maintenance 
et  les  réparations  et  vise  à  garantir  la  stabilité  à  long  terme  de  la  structure  de 
l'installation. 

La rupture d'un barrage minier au Brésil a souligné l’importance d’une gestion globale 
des risques y compris l’identification, l’analyse, l’évaluation et l’atténuation des risques. 
Le risque et sa gestion sont les principaux moteurs derrière les concepts et les solutions 
de  gestion  des  déchets  d'extraction.  La  prise  de  décision  basée  sur  le  risque  aide  à 
focaliser  les  plans  de  gestion  des  déchets  sur  les  aspects  essentiels  et  permet  ainsi 
d’utiliser  efficacement  les  ressources,  tout  en  maximisant  le  niveau  de  protection  de 
l'environnement et de la santé humaine. 

Un  problème  apparu  pendant  l’évaluation  des  plans  de  gestion  des  déchets  concernait 
les conflits (potentiels) entre les objectifs d'élimination sûre des déchets d'extraction et 
les  politiques  de  l'économie  circulaire.  La  décision  de  déclarer  un  matériel  extrais 

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comme déchet et de procéder à son élimination est prise quand aucune utilité bénéfique 
ne peut être trouvée pour ce matériel, ce qui, en soi, dépends du contexte économique à 
ce  moment-là.  Par  conséquence,  ce  déchet  peut  contenir  des  éléments  qui  peuvent 
gagner  en  valeur  plus  tard.  La  possibilité  de  collecter  ces  éléments  dépend  de  la 
méthode de d’élimination de ces déchets. Les dépôts situés près de la surface, tels que 
les décharges de stériles ou les bassins de résidus, peuvent être relativement facilement 
accessibles  et  relativement  simples  à  retravailler.  La  situation  est  différente  pour  des 
minéraux replacés dans les trous d'excavation après l'extraction des minéraux, parce que 
non  seulement  il  est  difficile  d’y  avoir  accès  après  la  fermeture,  mais  c’est  aussi 
dangereux. Ce dilemme entre les solutions  sûres de gestion des  déchets  d’extraction à 
long terme et le maintien de l'accès à des ressources potentiellement précieuses doit être 
soigneusement pesé pendant le développement d’un plan de gestion des déchets. 

Les dangers résultant de l'exposition aux rayonnements ionisants sont exclus du champ 
d'application de la Directive. Cependant,  ce document d’orientation traite du sujet des 
matières radioactives naturelles conformément à la Directive 2013/59/EURATOM6.  

Il a été noté que la stabilité à long terme telle que postulée dans la Directive n’était pas 
reflétée  dans  les  plans  de  gestion  des  déchets  évalués  pendant  ce  projet.  Pour  cette 
raison,  les  meilleures  pratiques  proposées  concernent  principalement  la  remise  en  état 
d'installations  fermées.  Pour  combler  ces  lacunes,  le  document  d’orientation  a  été 
enrichi en utilisant des informations fournies par l'industrie extractive, ses Associations 
et des organismes internationaux. 

2.3 La réunion de travail avec les États membres et les parties prenantes  

L’échange d’information sur les meilleures pratiques a eu lieu pendant la réunion de travail 
“Les meilleures pratiques dans les plans de gestion des déchets en faveur d’un plan d’action 
pour l’économie circulaire” ayant eu lieu à Bruxelles le 12 septembre 2018. Les participants 
étaient  des  experts  des  États  membres  (Finlande,  Irlande,  Pays-Bas,  Espagne,  France  et 
Suède),  parties  prenantes  des  associations  et  des  industries  extractives  (Euromines, 
Euracoal,  IMA-Europe,  Federation  of  Norwegian  Industries,  and  The  Global  Oil  and  Gas 
Industry Trade Association), la Commission (DG Environnement et la DG GROW), ainsi 
que  le  consortium  du  projet.  Parties  prenantes  et  spécialistes  ont  offert  leur  vision  sur  les 
perspectives  dont  il  devait  être  tenu  compte  pour  la  rédaction  d’un  plan  de  gestion  des 
déchets,  mais  ils  ont  également  commenté  sur  des  sujets  spécifiques  de  préoccupation  et 
d’intérêt particulier pour l’industrie.  

6 Directive 2013/59/EURATOM du 5 décembre 2013 fixant les normes de base relatives à la protection sanitaire contre les dangers résultant 
de l'exposition aux rayonnements ionisants et abrogeant les directives 89/618/Euratom, 90/641/Euratom, 96/29/Euratom, 97/43/Euratom et 
2003/122/Euratom 

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3. Development  of  a  guidance  document  on  best  practices  in 
the  Extractive  Waste  Management  Plans  -  Circular 
Economy Action 

3.1 General information 

3.1.1 Introduction 

The Communication "Closing the loop - An EU action plan for the Circular Economy" 
describes  the  'Circular  Economy'  as  an  economy  wherein  the  value  of  products, 
materials  and  resources  is  maintained  for  as  long  as  possible,  and  the  generation  of 
waste  minimised.  The  Communication  announced  that  the  Commission  will  develop 
guidance  and  promote  best  practices  in  the  extractive  waste  management  plans 
(EWMPs)  by  2018.  The  Commission  requested  information  from  public  authorities, 
industry,  environmental  NGOs,  knowledgeable  experts  and  civil  society.  This  report 
presents  the  results  of  the  assessed  received  information  and  additional  gathered  data 
that  identifies  best  practice  in  extractive  waste  management  plans,  placing  a  focus  on 
those aspects related to Circular Economy.  

3.1.2 Background 
The present guidance is part of a study7 pertaining in particular to (a) the integration of 
Circular  Economy  aspects  into  an  Extractive  Waste  Management  Plans  and  (b)  the 
identification  of  Best  Practices  in  Extractive  Waste  Management  Plans  (EWMPs)  for 
aspects related to the Circular Economy. The scope of the present guidance is to explore 
approaches  beyond  minimum  requirements  of  the  Directive  2006/21/EC  (Extractive  – 
EWD) in order to promote Circular Economy concepts in the mining sector. According 
to  Article  5  (“Waste  management  plans”)  of  the 
Extractive  Waste  Directive  2006/21/EC  (EWD),  the 
Member States have to ensure that operators draw up an 
extractive  waste  management 
(EWMP). 
Specifically,  Articles  5(2)(a)  and  5(2)(b)  of  the  EWD 
specify  objectives  of 
the 
prevention  or  reduction  of  waste  production  and  its 
harmfulness as well as the recovery of extractive waste 
by means of recycling, reusing or reclaiming such waste 
where  this  is  environmentally  sound.  Thus,  the  EWD 
and in  particular its Article 5 reflected already  in 2006 
what is in essence a Circular Economy perspective.  

“Optimisation of the ore 
extraction can be 
achieved by 
strengthening the role of 
the exploration and 
design phase, aiming 
the prevention of waste 
generation within the 
possible extent” 

the  EWMP  related 

plan 

to 

The  mining  sector  is  especially  complex  due  to 
geological,  geochemical,  climatological,  and  social 
conditions of the location of each deposit, but also because of the breadth and range of 
the  mining  life-cycle,  which  is  presented  in  Figure  3-1.  According  to  the  Swedish 
Guidance  for  the  handling  of  the  extractive  waste,  extractive  waste  generation  can  be 

7Service contract № 070201/2017/768854/ETU/ENV.B.3 
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prevented by optimising mineral extraction and processing taking into account the ore 
that is mined (developing new knowledge and technologies that address how to increase 
recycling of waste) (Swedish Environmental Protection Agency, 2016). An optimisation 
of  the  mineral  extraction  and  processing  can  be  achieved  by  strengthening  the  role  of 
the  two  first  steps  of  the  mining  life-cycle  (exploration  and  design).  The  present 
guidance  describes  practices  in  the field  of recycling and recovery of extractive waste 
(potential use) that may be applied to the first five  basic phases in a mining life-cycle 
(exploration,  design,  construction,  extraction,  and  processing),  and  which  have  direct 
consequences on the generation and management of the extractive wastes. 

Figure 3-1: The mine life cycle 

From the beginning of the implementation of the EWD, some experience with EWMPs 
has been accumulated. Mine operators have to plan their operations in such a way as to 
ensure  efficient  use  of  resources  by  minimising  extractive  waste  generation  and  are 
encouraged  to  promote  the  use  of  secondary  raw  materials  and  their  accessibility  as 
future  resources.  The  extractive  industry  actively  searches  for  circularity  aspects  that 
can  be  included  in  the  mining  operations,  which  may  be  summarised  in  EWMPs  or 
EIAs. Therefore, for the development of the present guidance, an investigation on best 
practices  from  submitted  EWMPs  and  EIA  studies  of  the  extractive  industries  was 
conducted, focusing mainly on those that reflect  the essence of the Circular  Economy 
perspective.  In  any  case, it should be emphasised that the decision on the selection of 
best  practices  should  take  into  consideration  always  the  local  geotechnical,  geological 
and economic conditions.  

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3.1.3 Methodology 
In  July  2017,  the  Commission  called  on  relevant  stakeholders  in  the  Member  States’ 
(MS) extractive industry, public authorities, industry, environmental NGOs and the civil 
society,  to  contribute  their  expertise  and  experience  by  providing  one  or  more  of  the 
following: 

  Guidelines on how to develop EWMPs  
  Sample Extractive waste management plans (EWMPs)  
  Pre-selected EWMPs containing candidate best practices  
  Candidate best practices  
  Hosting a visit to investigate the Circular Economy aspects within the EWMPs 

In total 64 data items were gathered by the European Commission initiative in various 
forms,  such  as  common  industrial  practices,  national  projects  for  extractive  waste 
management, MS guidance documents, etc.  

Following the European Commission’s initiative, a further data collection process was 
conducted by  a team  of consultants in  order to  obtain more details  on the practices in 
EWMPs  that  cannot  be  obtained  through  desk  research  alone.  This  project  has  also 
included  country  visits  in  order  to  collect  relevant  technical  information.  This  further 
research via country visits was conducted in France, Germany, Hungary, Greece, Spain 
and Sweden. 

The  information  collected  supported  the  first  milestone  of  the  project,  namely,  to 
identify  candidate  best  practices  with  respect  to  their  provisions  towards  the  Circular 
Economy Action Plan. This project has a strong reliance on the information provided to 
the  Commission  and  the  further  data  collection  process  by  the  consultant  relying  on 
publicly accessible information. Therefore, the best practices presented in this guidance 
are not necessarily comprehensive.  

The EWMPs have been assessed, taking into account the following aspects: 

  processes to prevent or reduce extractive waste generation and its harmfulness  
  extractive  waste  management  in  the  design  phase  and  in  the  choice  of  the 

 

method used for mineral extraction and treatment 
the changes that the extractive waste may undergo in relation to an increase in 
surface area and exposure to conditions above ground 
  placing extractive waste back into the excavation void 
  putting  topsoil  back  in  place  after  the  closure  of  the  waste  facility  or  re-using 

topsoil elsewhere 

  using less dangerous substances for the treatment of extracted minerals 
 

recovery of extractive waste by means of recycling, re-use or reclaiming of such 
waste 

  approaches for monitoring the implementation of EWMPs and their review 

Furthermore,  best  practice  identified  should  be  considered  in  EIA  and  EWMPs,  but 
local circumstances might not allow applying it in a given geological context. Similarly, 
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the  examples  of  best  practice  from  a  subsector  might  not  be  applicable  for  all 
installation of this subsector due to a given geological context. 

In addition to highlighting best practices for extractive waste management, it is equally 
important to develop a methodology that describes how EWMPs can be produced. The 
role risk-based considerations  play in choosing appropriate solutions is a useful guide 
to  understanding  the  development  of  EWMPs.  Most  of  the  Risk  based  considerations 
would have been already undertaken as part of the Environmental  Impact Assessment. 
The  EWMP  acts  as  a  vehicle  to  describe  the  chosen  extractive  waste  management 
activities and to communicate these to regulators and the interested public alike. 

3.1.4 Initial assessment of the information gathered 

Overall,  a  total  of  75  Fact-Sheets  were  prepared,  based  on  the  EWMPs  collected  and 
through  the  country  visits.  As  is  shown  in  Figure  3-2,  the  majority  of  the  collected 
practices are related to the metal ores and construction minerals. The collection process 
revealed  a  number  of  relevant  practices,  which  prove  that  the  extractive  industry 
actively  searches  for  strategies  to  maximise  resource  use  that  can  be  included  in  the 
mining and processing operations. The practices are mostly related to: 

  Considerations of extractive waste production and its management in the design 

 

phase 
following  strategies  and  techniques  to  fill  excavation  voids  with  extractive 
material  (Note: in  some  MS these excavated materials  are considered  as  waste 
and in some others as secondary raw material; the scope of the present guidance 
is  only  to  present  techniques  that  strengthen  the  role  of  the  Circular  Economy 
and not to discuss what is waste and what not) 

  utilising waste rock in different kinds of earthworks on site during active mining 
operations,  as  landscaping  material,  or  it  may  be  sold  outside  for  use  as 
aggregate 

  utilising  extracted  material  that  would  otherwise  be  waste  in  various  ways 
outside the mine environment, in earthworks, and even in the chemical industry 

  Recycling or re-using of historical extractive waste 
  Recycling of waste water 
  Segregation and re-use of topsoil 

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Industrial 
Minerals 
12% 

Meral Ores 
[PERCENTAGE
] 

Enegy Minerals 
28% 

[CATEGORY 
NAME] 
[PERCENTAGE
] 

Figure 3-2: Percentage distribution of the sectors from which data could be collected. 

3.1.5 Stakeholder consultation and workshop 

The assessed information was cast into a Background Document (BD) that was sent to a 
wide  range  of  stakeholders,  such  as  competent  authorities,  the  extractive  industry, 
Expert  Group  on  Waste,  the  Raw  Materials  Supply  Group,  the  Technical  Working 
Group  on  the  Best  Available  Techniques  Reference  document  on  the  management  of 
waste from extractive industries, academia and NGOs, in order to be commented on and 
to solicit additional practices. These experts were also invited to a Workshop on ‘Best 
Practices  of  Extractive  Waste  Management  Plans’,  which  was  held  on  12  September 
2018 in Brussels.  

Although the investigation of the practices was mainly focused on the EWMPs, the pre-
licensing  design  phase  for  extraction  is  in  most  cases  based  on  the  Environmental 
Impact  Assessments  (EIAs),  which  covers  the  whole  life-cycle  of  operations.  In  most 
cases the final EIA is the outcome of an iterative procedure that begins with the original 
proposal  for  extraction, processing of the extracted material,  and the  eventual (re-)use 
and  disposal  of  materials  for  which  no  economically  beneficial  use  can  be  found. 
Different extraction methods, processing techniques, and disposal options will result in 
different  impacts  on  different  environmental  compartments.  This  iterative  procedure 
ideally yields a process design and disposal solution for EW that provide the maximum 
economic  benefits,  while  entailing  environmental  impacts  deemed  acceptable.  In 
contrast to the EIA, the EWD requires a review of the EWMP every five years in order 
to take into account any substantial changes to the operation of the waste facility or to 
the  waste  deposited.  The  objective  of  the  EWMP  is  to  summarise  these  findings  with 
respect to the actual extractive waste management options to be implemented. Article 5 
of the EWD already contains provisions with respect to what later became known as the 
Circular  Economy  Action  Plan.  It  has  to  be  understood,  however,  that  the 
(environmental,  geotechnical,  health)  safety  of  the  disposal  option is  a  very  important 
parameter  and  must  always  be  considered  in  relation  to  environmental  and  Circular 

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Economy aspects. To this end the EWMP will demonstrate that the necessary steps had 
been  taken  to  prevent  waste  generation  where  it  is  possible  and  to  encourage  the 
recovery of extractive waste by means of recycling, re-using or reclaiming such waste, 
where this is environmentally sound and economically feasible. 

This Guidance does not aim to interpret EU waste legislation including Article 5 of the 
EWD  but  aims  to  link  the  relevant  provisions  of  Article  5  with  the  objectives  of  the 
Circular Economy Action Plan, covering all the extractive sectors’ minerals.  It  is  thus 
independent  of  and  complementary  to  the  work  on  the  Best  Available  Techniques 
reference  document  on  the  management  of  waste  from  extractive  industries  (MWEI 
BREF). It is intended as legally non-binding guidance, targeted at competent authorities 
and  extractive  industry  operators  for  the  purpose  of  promoting  the  Circular  Economy 
principles.  

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18 

3.2.1 Scope and purpose of risk-based considerations  
Risk  Assessment  is  a  technical-scientific  methodology  to  estimate  quantitatively  and 
qualitatively  environmental  and  social  risks  arising  from  the  technical  options  of 
extractive  waste  management.  As  noted  before,  in  most  cases  such  assessment  would 
have been carried out as part of the EIA that is usually the basis of an operating license. 
However,  scope  and  detail  of  the  EIAs  may  vary  from  MS  to  MS  and  the  following 
serves as a tool to cross-check, whether the Risk Assessment undertaken under the EIA 
is sufficient to support the development of the EWMP. 

One  of  the  aims  of  the  risk-based  considerations  and  choices  in  extractive  waste 
management  is  to  predict  from  the  very  beginning  (design  phase)  potential  impacts 
resulting  from  the  generation  and  the  management  of  the  extractive  waste  and 
investigate  possible  solutions  to  avoid  them.  Any  significant  change  that  may  arise  at 
some point during the mining life-cycle may lead to proportional evaluation of the risk 
assessment.  Risk  management  indeed  is  a  procedure  that  iterates  with  operational 
planning and needs to be adapted progressively to changing operational conditions.  

3.2.2  Risk  based  considerations  used  in  the  development  and  evaluation  of  the 
EWMPs 
 Risk based considerations contribute to setting  priorities for environmental and social 
protection in an objective and scientific way. EWMPs reflect the risk-based selection of 
appropriate  extractive  waste  management  options,  taking  into  account  the  waste 
hierarchy: 

1.  to prevent or reduce waste generation and its harmfulness; 
2.  to encourage the recovery of extractive waste; and 
3.  to  ensure  short  and  long-term  safe  disposal  of  the  extractive  waste.  Risk 
management  for  this  activity  is  elaborated  in  BAT  5  of  the  MWEI  BREF 
(European Commission, 2018c) 

The  combination  of  information  on  risks  and  impacts  is  helpful  to  develop  workable 
solutions  for  the  specific  context  of  a  country  and  a  company.  Each  of  these  possible 
solutions  is  reviewed  with  respect  to  the  risk  reduction  strategy  applied  (based  on 
relevant  engineering  principles)  considering  risks,  impacts,  as  well  as  economic  and 
social aspects. Typically, this stepwise process of risk management planning includes: 
establishing  the  design  context,  impact  identification  and  failure  risk  identification, 
designs for risk elimination or reduction, and monitoring for efficacy (see Figure  3-3). 
Impact is a predicted (potentially prolonged) effect of the operation. On the other hand, 
risk is the probability that an unplanned event might occur multiplied by its impact. 

Extractive waste risk evaluation is a complex procedure and may be associated with a 
wide range of failure scenarios. Site specific conditions (including for example geology 
and  surrounding  land-use)  should  always  be  considered.  Sources,  pathways  and 
receptors should be adequately identified. 

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EWMPs are reviewed both internally and externally. Internal review is typically carried 
out  on  a  regular  basis  to  identify  updating  requirements.  External  review  is  typically 
carried  out  by  competent  authorities  –  for  both,  new  and  updated  EWMPs.  When 
reviewing  an  already  submitted  EWMP,  one  may  follow  the  principles  of  risk 
assessment  in  order  to  identify  potential  risks  to  environment  and  human  health.  The 
review  should  also  assess  whether  sufficient  information  is  provided  to  enable  the 
competent authority to evaluate the operator's ability to meet the three objectives listed 
above  (prevent/reduce,  recover,  safely  dispose).  Moreover,  it  should  ensure  that  the 
updated  plan  explains, 
the  extractive  waste  management 
considerations  from  the  design  phase,  and  the  choice  of  method  used  for  mineral 
extraction and treatment, will still fulfil its objectives.  

in  particular,  how 

Step 1: 
Information Collection and definition of the content 

Step 2: 
Risk Identification and determination of potential 
failure modes  

Step 3: 
Assessing risk arising from hazards: estimation of probability 
and severity of consequences, tolerance of risk 

Step 3: 
Planning actions to eliminate or reduce risk  

Step 4: 
Documentaion and review of risk assessment 

Figure 3-3: General Risk Assessment methodology scheme 

3.2.3 Risk identification along the life-cycle of an extractive operation 

The characterisation of extracted material that may become waste should be the starting 
point of the Risk Assessment, which also takes into the consideration the chosen waste 
management option. It should be noted that the scope of the present guidance is only to 
present  the  key  considerations  of  the  Risk  Assessment  and  not  to  discuss  whether 
specific elements of the whole methodology will be covered by the EIA of the operation 
or by the preparations of the EWMP.  

The  purpose  of  this  characterisation  is  to  determine  the  nature  of  the  extractive  waste 
and  steer  possible  management  options,  based  on  its  geological  and  mineralogical 
characteristics, its geotechnical behaviour and geochemical characteristics. Commission 
Decision 2009/360/EC completing the technical requirements for waste characterisation 
laid  down  by  Directive  2006/21/EC  specifies  technical  requirements  for  extractive 
waste  characterisation.  Since  the  first  EWMP  is  submitted  at  a  project  phase,  where 

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operation  has  not  yet  started,  information  obtained  from  the  characterisation  of 
extractive waste is relevant for the (periodic) reviews of these management plans.  

Extractive  industries  provide  mineral  raw  materials  that  are  essential  to  downstream 
industries and economic sectors. Extractive industries provide, first of all, primary raw 
materials. However, the processing often targets only one or a few constituents. Hence, 
what  would become extractive waste  can actually  be  a potential source  of further raw 
materials.  Therefore,  extracted  material  characterisation  should  include  all  parameters 
necessary  to  inform  about  potentially  valuable  constituents  or  properties  that  can  be 
utilised in order to avoid the material becoming waste. 

The  design  phase  in  many  extractive  industries  is  complex  and  may  identify  a  wide 
variety of potential hazards, as they are given in detail in the MWEI BREF. The overall 
evaluation  of  risks  may  require  some  kind  of  aggregation  to  make  different  practices 
and scenarios comparable when selecting the final design. 

The  design  phase  of  any  particular  extractive  installation  necessarily  relies  on  several 
key  input  parameters  related  to  the  main  purpose  of  the  project,  namely  sustainable 
development  of  the  mineral  deposit.  However,  opportunities  to  consider  extractive 
waste management and/or recovery may be found in the following areas: 

1.  Exploration phase 
2.  Selection of the most appropriate extraction methods 
3.  Extraction process planning 
4.  Design of the site layout 
5.  Selection of mining equipment 
6.  Optimisation of the process plant 
7.  Development of a commercial plan 

Figure 3-4 illustrates the complexity of waste management in the extractive sector since 
parameters such as site-specific conditions, including the technical characteristics of the 
Extractive Waste Facility (EWF), its geographical location and the local environmental 
conditions,  behaviour  and  characteristics  of  the  extractive  waste  and  geological 
background  of  deposit  are  only  some  issues  that  are  described  in  Commission 
Decisions, such as: 

  Commission  Decision  2009/360/EC  completing  the  technical  requirements  for 

waste characterisation laid down by Directive 2006/21/EC 

  Commission  Decision 2009/359/EC  completing  the definition of inert  waste in 

implementation of Article 22(1)(f) of Directive 2006/21/EC 

  Commission Decision 2014/955/EC amending Decision 2000/532/EC on the list 

of waste pursuant to Directive 2008/98/EC 

  Commission  Decision  2009/337/EC  on  the  definition  of  the  criteria  for  the 
classification  of  waste  facilities  in  accordance  with  Annex  III  of  Directive 
2006/21/EC 

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Figure 3-4: Decision tree for waste characterisation under the provisions of COM Decisions  

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In order to establish the necessary scope of the Risk Assessment, one needs to identify 
where, when and why these risks arise. Risks can then be quantified and management 
measures proposed. It is important to appreciate that risks can be managed as and when 
they arise (‘end-of-the-pipe’ treatment paradigm) or the root-cause can be identified and 
eliminated,  thus  also  eliminating  the  risk.  This  may  require  a  wider  scope  than  what 
would normally be covered by the EWMP. Normally, the EWMP may be considered as 
a reporting platform of work that has already been done for either feasibility studies or 
licensing purposes.  

The  following  non-exhaustive  list  shows  examples  of  aspects  that  would  need  to  be 
considered in order to establish the content of the Risk Assessment along the life-cycle 
phases of an extractive operation. It is known that in some cases, changing the processes 
in mining and subsequent treatment of the excavated material may result in wastes that 
are easier to manage and in EW management solutions with fewer inherent risks.  

1.  Exploration  phase:  the  more  thoroughly  the  resource  has  been  explored,  the  more 
targeted  and  efficient  the  extraction  can  be,  meeting  the  objectives  of  Art.  5§2  (a) 
and  (b)  of  the  EWD.  A  good  knowledge  of  the  mineral  deposit  allows  for 
optimisation of the extraction, resulting in less extractive waste. 

2.  Selection  of  the  most  appropriate  mining  methods:  the  selection  of  the  mining 
method,  e.g.  underground  vs.  open-cast,  and  mining  technology  is  governed  by  a 
multitude  of  factors.  While  it  is  understood  that  CAPEX  and  OPEX  in  a  given 
market  environment  are  critical  variables,  today  aspects  of  resource  efficiency  and 
minimisation  of  extractive  waste  generation  also  need  to  be  taken  into  account. 
Modern at-the-face rock characterisation methods, selective extraction, utilisation of 
waste rock (in pit or for filling excavation voids) reduces the generation of extractive 
waste. For example, in room-and-pillar methods the utilisation of waste rock my not 
only reduce the amount of EW to be managed at the surface, but also increases the 
recovery of the target mineral. 

3.  Site  design  and  scheduling:  Good  mining  planning  and  scheduling  based  on  good 
exploration  and  data  handling  is  the  basis  for  a  targeted  and  efficient  extraction, 
avoiding  unnecessary  extraction  and  thus  excessive  extractive  waste  generation. 
(This phase is continuously being developed.) 

4.  Choice  of  mining  equipment:  the  choice  of  mining  equipment  may  not  only  be 
determined  by  the  needs,  but  also  by  the  availability  of  and  limitation  to  CAPEX. 
Operators  will  need  to  be  aware  that  inadequate  mining  equipment  may  result  in 
unnecessary generation of waste rock that may need to be managed as EW. 

5.  Process  planning  and  optimisation.  While  one  can  assume  that  operators  have  a 
vested  interest  in  effective  processing  of  marketable  products  for  a  given  market 
situation,  the  manageability  of  the  resulting  extractive  wastes  may  not  always  be  a 
design  criterion.  Within  the  limits  of  CAPEX  available,  operators  may  consider 
reducing risks and associated risk management costs (including insurance premiums) 
by selecting processing methods that result in less waste that needs to be managed in 
Category A facilities. 

6.  Periodic review of material streams: The valorisation of each element of the material 
streams  generated  in  a  mine  and  subsequent  processing  changes  as  a  function  of 
market conditions. Hence, it is in the interest of the operator to periodically review 

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these streams and how they arise with  a view to maximising this valorisation. This 
review will to include materials that previously were considered EW in the sense of 
the  EWD.  It  makes  economic  sense  to  explore  possible  markets  for  materials  that 
otherwise would have to be deposited as EW and for which EWMPs would have to 
be developed. 

7.  Planning for the long-term safety of EWFs. All EWFs not only have to fulfil criteria 
for operational  safety and minimisation of impacts,  but  their closure  and  long-term 
management need to be provided for as well. 

It  should  be  kept  in  mind  that  these  are  multi-dimensional  optimisation  problems  and 
one  always  needs  to  be  aware  of  risk  and  impact  displacement  effects.  A  risk  and 
impact  analysis will help  to  underline the economic, social,  and environmental effects 
of the  extracted material.  In this sense, the risk  assessment and resulting management 
solutions  as  presented  in  an  EWMP  can  serve  to  demonstrate  to  regulators  and  other 
(public) stakeholders that risks have been minimised and benefits, including those in the 
sense of a Circular Economy, have been maximised. 

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3.3 Methodology to develop EWMPs  

24 

3.3.1 Introduction 
Extractive  waste  management  planning  can  be  a  complex  process,  requiring 
environmental, social, engineering and economic inputs. It is an integrated part of good 
operational management and EWMPs can be seen not only as a permitting tool, but also 
as a communication tool. Developing EWMPs is a systematic way to assess availability 
and adequacy of all essential components of extractive waste management. 

EWMPs  present  measures  for  prevention  or  reduction  of  extractive  waste  generation 
and its harmfulness, as well as the recovery of extractive waste by means of recycling, 
re-using such waste where this is environmentally sound and economically feasible, and 
without disregarding the needs for short and long-term safety and stability of extractive 
waste  management  solutions.  Such  actions  imply  that  EWMPs  are  based  on  the 
understanding  that  waste  management  imply  proactive  measures  to  avoid  or  reduce 
waste generation per se.  

Some  key  elements  that  need  to  be  determined  before  the  drafting  of  an  EWMP  are 
questions  such  as:  which  material  should  be  evaluated?  who  should  draft  the  EWMP 
and when? This information is discussed in the following boxes. 

Question 1: What is extractive waste? 

 ‘Extractive  waste’  means  “the  waste  resulting  from  the  prospecting,  extraction, 
treatment  and  storage  of  mineral  resources  and  the  working  of  quarries”  but 
excluding: 

  waste  that  is  generated  by  the  prospecting,  extraction  and  treatment  of 
mineral  resources  and  the  working  of  quarries,  but  that  does  not  directly 
result from those operations; 

  waste  resulting  from  the  off-shore  prospecting,  extraction  and  treatment  of 

 

mineral resources; 
injection of water and re-injection of pumped groundwater as defined in the 
first  and second indents  of Article 11(3)(j) of Directive 2000/60/EC,  to  the 
extent authorised by that Article. 

Question 2: What materials are evaluated in an EWMP? 

Taking  into  consideration  the  EWMPs  that  were  selected  through  the  gathering  of 
relevant  data,  the  following  approaches  related  to  the  term  “management  of 
extractive waste” have been identified: 

  Some  EWMPs  address  the  management  of  excavated  material  after  it  has 

been classified as extractive waste 

  Other  EWMPs  develop  a  wider  perspective  and  address  all  streams  of 
excavated material explaining the material streams considered as (by)product 
and those classified as (extractive) waste. 

It has to be understood that material that is defined as “extractive waste” is subject 
to the EWD, while other types of waste that are beyond the term “extractive waste” 

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are  subject  to  the  Waste  Framework  Directive,  or  Directive  2008/98/EC  of  the 
European  Parliament,  and  consequently  these  wastes  are  out  of  the  scope  of  the 
present guidance. 

Question 3: Who is responsible for drafting an EWMP? 

The  “operator”  is  the  natural  or  legal  person  responsible  for  the  management  of 
extractive waste, in accordance with the national law of the Member State (MS). It 
is  known  that  some jurisdictions  require  an  EWMP  from  all  extractive  operations, 
while  other  jurisdictions  are  satisfied  if  the  EIA  and  the  license  application 
demonstrate that no EWs arise, thus obviating the submission of an EWMP.  

Question 4: When should an EWMP be drafted and how often shall an operator review 
it? 

According  to  the  national  laws  of  MSs,  an  EWMP  can  be  submitted  as  part  of  an 
application  for  planning  permission,  forming  a  component  of  the  application 
documentation or being contained within an environmental impact assessment (EPA 
Ireland, 2012).   

According  to  the  EWD,  the  waste  management  plan  shall  be  reviewed  every  five 
years and/or amended, if substantial changes have taken place in the EWF or in the 
extractive  waste  itself.  It  should  be  noted  that  the  EWMP  is  not  necessarily  a 
document  that  is  only  submitted  once  in  the  first  permit  application.  Competent 
authorities may need to be notified of amendments. 

3.3.2  The role of the mine life-cycle in drafting EWMP 

Every mine is unique and, therefore, the type, the amounts and the characteristics of the 
extractive  waste  differ,  depending  on  the  deposit,  the  geology  and  the  process 
technology  applied  at  the  site.  The  extractive  waste  originates  mainly  from  two 
production stages: mining (extraction) and mineral processing (Lèbre, 2016). 

Although  the  generation  of  extractive  waste  starts  mainly  at  the  construction  stage, 
extractive waste management should be taken into consideration along all the stages of 
the  mining  project  life-cycle,  including  the  exploration  and  design  phase.  Figure  3-5 
illustrates the phases, where extractive waste can be generated during the life-cycle of a 
mine.  Better  advance  planning  of  the  operation  improves  the  efficiency  of  extraction, 
reducing  the  amount  of  unwanted  extraction  that  may  become  extractive  waste, 
minimising the environmental footprint.  

A  well-developed  EWMP  should  be  based  on  the  best  available  technical  knowledge 
and the substantial experience established across the mining sector in order to achieve 
(a)  optimisation  of  extraction,  (b)  reduction  of  environmental  impacts  until  deemed 
acceptable, and (c) strengthening of recycling. 

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Figure 3-5: Extractive waste as part of the mine life cycle 

3.3.3 Guidelines for the development of an EWMP 
To  assist  the  reader,  Table  3-1  provides  a  selection  of  details  from  already  submitted 
EWMPs from different parts of Europe. This list is neither exhaustive nor tailor-made 
for  every  extractive  industry  or  for  any  location,  but  it  includes  a  useful  selection  of 
issues that should be considered during the drafting of an EWMP. 

The  actual  scope  depends  on  the  local  circumstances  and  also  on  individual  MSs 
requirements, if MSs have formulated such. The EWMP presents (a) a description of the 
operation  generating  extractive  waste,  (b)  extractive  waste  characteristics,  (c)  quantity 
of  extractive  waste  generated,  and  (d)  the  proposed  classification  for  the  extractive 
waste facility. 

A  considerable  amount  of  the  information  is  usually  generated  and/or  collated  during 
the  different  stage  feasibility  studies  and  drafting  of  the  initial  EIA  for  the  extractive 
operation.  The  EWMP  provides  information  on  possible  adverse  effects  on  the 
environment  and  human  health,  resulting  from  the  disposal  of  the  EW  and  the 
mitigation measures, in particular from contaminated run-offs and leachates, water and 
wind erosion. The time frame to be considered covers construction, operation and post-
closure  phases,  taking  into  account  the  geological,  hydrological  and  hydrogeological, 
seismic and geotechnical characteristics of the site or of the EWF. 

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Table 3-1 Example contents of an EWMP  

Issues covered in the EWMPs 

Examples of parameters 

27 

Name of the company 

Site location (coordinates) 

Site manager 

Administrative information 

Officer responsible for extractive waste area 

Contact details 

Emergency contact details 

Date 

Geological  description  of  the  mineral 
deposit  

Rock  type  and  mineralogy  description  of  the  mineral 
resource to be used 

Size and geometry of the mineral deposit 

Description  of  materials 
(supported by flow-diagrams) 

streams 

List  of  each  type  of  material,  including  quantities  and 
destination 

Excavation 

Crushing and grinding 

Waste  produced 
processes 

from 

individual 

Flotation,  magnetic  separation  or  other  separation 
processes 

Exploration works  

Other processes  

Rock type  

Mineral assembly 

Mineralogical 
characterisation per material/waste 

and 

geochemical 

chemical 

least) 
Bulk 
components of potential concern, such as As, Cd, Co, Cr, 
Cu, Hg, Mo, Ni, Pb, V and Zn 

composition 

including 

(at 

Acid generation potential and neutralization potential 

Presence of (fibrous) minerals of concern (e.g. asbestos) 

Potential chemical processing residues 

Waste(s)  code  according  to  Decision  2014/955  (Waste 
Catalogue) 

  Assessment  whether  the  EW  is  inert  is  based  on  the 
technical  requirements  that  are  presented  in  the 
Decision 2009/359/EC  

  Assessment whether the EW is inert, based on method 
EN  15875:  Sulfide  sulfur  content  %  (<0,1%  or  <1% 
and NTP (normal, temperature, pressure) > 3 

Hazardous 
Properties 
1357/2014/EC  -  properties  of  waste 
hazardous 

according 

to  Regulation 
it 
that  render 

Solubility of metals, oxyanions and salts   

Geotechnical 

characterisation 

and  Grain size distribution 

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Issues covered in the EWMPs 

Examples of parameters 

material  geotechnical  behaviour  per 
material/EW 

(dominant 

mineralogical 

Density  

Porosity  

Permeability  

Fraction 
composition) 

composition 

Water content  

Plasticity indices 

Degree of compaction  

Shear strength  

Friction angle 

Compactability  

Compressive strength  

Waste  class  according 
to  COM 
Decisions  2009/359/EC,  2009/360/EC 
and 2014/955/EU  

Hazardous  waste  /  Non-hazardous  non-inert  waste  /  Inert 
waste 

Category of EWF  

Category A / Non-Category A (Decision 2009/337/EC) 

Facility  structures  (all  EWFs  on  the 
site) 

Design and constructional details of the EWF 

Management of excavated material 

depending 

Note: though not explicitly covered by 
the 
the  EWD, 
operational  and  market  conditions, 
some  of  these  wastes  can  become  EW 
at any given moment 

on 

Management  of  EW 
(per  waste, 
supported  by  detailed  maps  of  the 
deposition areas) 

Risk assessment 

Excavated materials (quantities as function of time) 

Quantities  and  types  of  excavated  materials  used  for 
construction  purposes  in  the  mine/quarry  (as  function  of 
time) 

Quantities  and  types  of  excavated  materials  used  for 
filling  mine  voids  for  engineering  or  resource  recovery 
reasons (as function of time) 

Top-soils removed and stored (as function of time) 

Quantities  of  non-EW  and  their  management  routes  (as 
function of time) 

Quantity of EW deposited (as function of time)  

Planned quantity to be deposited EW (as function of time) 

Total  quantity  of  extractive  waste  to  be  deposited  during 
the life-cycle  

Quantities of EW recovered and re-utilised (as function of 
time) 

Summary  of  risk  assessment  carried  out  under  the  initial 
EIA, any updates, or specifically for the EWMP 

Specific conditions contributing to risks: 

  Climatic  conditions  (e.g.  rainfall 

frequencies)  as  drivers 
contaminants 

for 

intensities  and 
the  migration  of 

  Description  of  possible  natural 

(e.g. 
earthquakes,  vulcanism,  etc.)  that  may  compromise 

events 

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Issues covered in the EWMPs 

Examples of parameters 

the EWF 

Risk elimination or risk reduction measure 

Emergency plans for Category A EWFs 

Emergency plans  for other EWFs 

Geotechnical stability (dams, slopes) 

Groundwater: levels, quality 

Surface waters:  quantity, quality 

Air quality 

Erosion control (turbidity in surface waters) 

Radiological monitoring (where required) 

Provisional plans (to be updated periodically together with 
the EWMP) 

Financial provisions to ensure orderly closure 

Preliminary  plans  for  the  after  use  of  the  extraction  site 
and  the  EWFs  (to  be  updated  periodically  together  with 
the EWMP) 

Emergency  plans  (detailing  actions 
and responsible persons) 

Operational monitoring 

Closure plans 

Long-term management plans 

Supporting documentation 

1. Geology: nature shape, size and typology of the resource  

2. Mineral deposit area: type, final shape, structure of filling and transport type  

3. Study of the state of soil and water at deposit area (baseline study)  

4. Information of environmental impacts caused by extracted waste and deposit area  

5. Information of preventive actions taken to minimize environmental impacts  

6. Report of current and post-action control and follow-up  

7. Acid rock drainage and metal leaching assessment report 

8. Closure plan 

Note:  the  majority  of  the  above  documentation  would  have  been  already  produced  as  part  of  the 
baseline survey and the EIA licensing procedure.  

The scope of the EWMP is steered by the nature of the mining operation and extractive 
waste generated on the site. EWMP describes how both impacts and risks arising from 
the EW or the EWFs are managed. 

Certain extractive operations are likely to produce only inert wastes owing to the types 
of geological materials excavated. Such operations may include aggregates, ornamental 
stones  or  certain  industrial  minerals,  and  operations  extracting  peat.  These  operations 
may  be  required  to  produce  only  simplified  EWMPs,  not  covering  the  whole  suite  of 
variables as outlined in Table 3-1. 

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3.4  Best Practices from EWMPs related to Circular Economy 

The following practices focus on resource management applied in the extractive sector 
that can play a central role in the Circular Economy. 

 3.4.1 Best Practice 1: Effective exploration and site lay out 
Extractive  materials  management  (including  waste)  practices  start  at  the  design  phase 
for  the  mine  operation.  Optimisation  of  ore  extraction  and  minimisation  of  waste 
generation  can  be  accomplished  by  strengthening  the  first  steps  of  the  extractive 
industries life-cycle, such as exploration, characterisation and operation design, taking 
also into consideration the commercial environment. 

Waste 
Characterisation 

Efficient 
use of 
resources 

Minimising the 
extraction of  
non-marketable 
materials 

Figure 3-6: Parameters related to the Circular Economy as applied in the extractive sector 

The  exploration  efforts  are  the  basis  for  a  mining  project.  Non-invasive  exploration 
methods, namely various types of geoelectrics and seismics, can be used to enable more 
targeted extraction. Geophysical techniques, such as Electrical Resistivity Tomography 
(ERT), Ground Penetrating Radar (GPR) or different forms of seismics are used with a 
view to: 

  optimising subsequent use of invasive investigation (drilling) 
 

improving the quality  and marketability of the product,  learning in  advance its 
characteristics 

  optimising the mineral extraction through localisation of areas to be avoided or 

targeted 

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Modelling  of  the  deposit  and  careful  characterisation  of  the  resource  can  result  in 
minimising the extraction of unwanted and non-marketable materials - thus minimising 
the generation of extractive waste. 

Furthermore,  advance planning  of the operation  improves the efficiency  of extraction, 
avoiding  sterilisation  of  resources  and  reducing  the  amount  of  unnecessary  extraction 
(efficient  use  of  resources).  The  EWMPs  collated  for  this  guidance  provide  a 
considerable  amount  of  information  with  regard  to  practices  involving  a  detailed 
modelling  of  the  deposit  and  choice  of  mining  strategy  by  selecting  underground  or 
open-pit mining techniques.  However, any choice of mining strategy depends on a wide 
range of factors, including the depth of the target mineral below ground, the extent of its 
occurrence,  the  characteristics  and  tectonics  of  the  host  rocks,  the  groundwater 
hydrology,  permissible  footprint,  available  mining  technology,  and  human  resources 
available.  In  general,  near-surface  occurrences  may  be  extracted  in  open-pit  mines, 
while deeper deposits are extracted in underground mines. 

Another parameter that it is evaluated during the design phase (pre-licensing process) of 
an extractive operation are the likely characteristics of the extractive waste. At EU level, 
the  most  relevant  standards  applicable  to  investigating  the  expected  behaviour  and 
characteristics of future extractive wastes are:  

  CEN/TR  16365:2012  Characterisation  of  waste.  Sampling  of  waste  from 

extractive industries 

  CEN/TR 16376:2012 Characterisation of waste. Overall guidance document for 

characterisation of waste from the extractive industries 

  CEN/TR 16363:2012 Characterization of waste. Kinetic testing for assessing  

acid generation potential of sulphidic waste from extractive industries 

  CEN/TS 16229:2011 Characterization of waste. Sampling and analysis of weak 

acid dissociable cyanide discharged into tailings ponds 

  EN 15875:2011 Characterization of waste. Static test for determination of acid 

potential and neutralisation potential of sulphidic waste 

Relevance for Circular Economy:  

Integrated  planning  based  on  the  following  waste  management  objectives: 
prevention,  re-use  and  recycling,  highlighting  the  design  phase  as  a  basic  step  to 
achieve the Circular Economy principles contribute to the social acceptance of an 
extractive operation.  

Effective  characterisation  of  the  resource  and  extractive  waste  and  advance 
planning of the operation improves the efficiency of extraction, avoids sterilisation 
of resources (i.e. helps future generations to have access to virgin raw materials), 
ensuring a continued, steady and adequate supply of the raw materials needed by 
society  and  minimises  the  amount  of  unnecessary  extraction  and  thus  reduces 
waste.  

The  decision  between  underground  mining  and  open-pit  is  a  key  decision  during 
the  planning  phase  and  is  taken  with  consideration  of  the  implications  for  the 

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Circular  Economy  in  relation  to  environmental,  economic  and  social  benefits. 
Careful  planning  to  reduce  the  need  for  materials  handling  and  to  allow 
progressive  rehabilitation  can  help  to  prevent  or  reduce  waste  production  and  its 
harmfulness, 
technical,  economic  and 
environmental  possibilities  for  placing  materials  back  into  the  excavation  void 
after extraction. 

in  particular  by  considering 

the 

. 

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Case studies: 

According  to  EWMPs  from  bauxite  mines in  Greece  (ELMIN  (now  Imerys) 
and  Delphi-Distomon  SA  (now  MYTILINEOS),  bauxite  extraction  is  based 
on  detailed  modelling  of  the  deposit,  which  in  turn  is  based  on  integrated 
geotechnical  research  from  the  planning  phase  onwards.  The  deposit  is 
selectively extracted with the aim of minimising as efficiently as possible the 
generation of extractive waste. 

Data  for  the  integrated  planning  were  also  mentioned  in  the  EWMP  from 
Colas  Északkő  Kft.  (Construction  Sector)  in  Hungary.  Specifically,  Colas 
Északkő Kft has been planning a complex life-cycle assessment, considering 
the  available  raw  material  reserve  and  the  generation  and  management  of 
extractive waste. An  extensive exploration programme (around 1,250 meters 
of  drilling  and  large  surface  geophysical  study)  helped  to  estimate  the  total 
quantities of product and extractive waste.  

The  “Lujar”  underground  mine  (Minera  de  Órgiva,  Spain)  is  located  in  an 
impressive  valley  between  the  Sierra  Nevada  and  the  Sierra  Lujar,  whose 
beauty entices tourists to come to the Alpujarra region. To make it easier for 
mining  and  tourism  to  coexist,  the  Minera  de  Orgiva´s  objective  was  to  be 
completely unnoticeable in the surrounding villages, reducing to almost zero 
the  environmental  impacts.  Firstly,  Minera  de  Orgiva  installed  the  mineral 
processing plant underground, so the ore does not have to be brought to the 
surface  before  it  has  become  the  final  product.  Doing  so  affects  a  total 
reduction  of  noise,  dust,  land  occupation,  etc.  The  company  also  decided  to 
eliminate the visual impact of the extractive activities by using the extractive 
waste as material for filling the excavation voids inside its own mine, but also 
for  reclamation  purposes  outside  the  boundaries  of  the  mine  site  (details  in 
chapter 4.5). 

In  Greece  the  bauxite  mining  near  Mount  Parnassos  ten  years  ago  was 
undertaken  partially  from  an  open  pit  mine  and  partially  underground. 
According to the EWMP by Delphi-Distomon SA (now MYTILINEOS), the 
company  decided  to  turn  exclusively  to  underground  mining  in  order  to 
minimise the extractive waste that would have to be deposited on the surface 
by  filling  the  excavation  voids.  This  decision  is  also  part  of  the  corporate 
social responsibility policy. 

Another example from Greece is the marble quarry of DIONYSSOMARBLE. 
According to the company, the demand for decorative/ornamental stones has 
been steadily rising due to their use in modern architecture. Increased demand 
has  led  to  intensive  extraction  in  existing  marble  quarries.  The  immediate 
consequence of this extraction is the gradual depletion of surface deposits. In 
addition,  strict  environmental  restrictions  already  impose  the  underground 
extraction of decorative stone deposits. 

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34 

Rock loosening is traditionally effected either by mechanical excavators or by drilling 
and  blasting.  An  optimal  selection  of  mechanised  wall-casings  and  mining  machines 
depends  on  the  expected  geological  and  geotechnical  conditions,  leading  to  more 
targeted extraction and, as a consequence, to efficient production and waste reduction. 
The same principle applies to the blasting strategy and technique. The variation of the 
rock properties and their different mechanical behaviour affects the excavation by drill-
and-blasting.  The  optimisation  of  the  process  of  drill‐and‐blast  in  the  design  and  the 
operation phase of the  mine leads to the reduction  of extractive waste and wastage of 
drill-time  and  explosives.  For  both  approaches,  either  with  the  selection  of  the 
appropriate equipment or a blasting design, the key is (a) to investigate the deposit via 
an in-pit exploration, and (b) to try to minimise the mineral/sterile ratio with computer 
simulations in order to conduct a more targeted extraction. It should be noted that these 
strategies  may  be  constrained  by  technical  limitations,  such  as  the  minimum  tunnel 
cross-section  required  for  equipment  or  ventilation.  There  may  also  be  minimum 
requirements in a MS’s respective mining code.  

Relevance for Circular Economy:  

The  optimisation  of  the  process  of  drilling  and  blasting  and  the  selection  of  the 
appropriate extraction equipment leads to the reduction of drill time (energy efficiency), 
consumption of explosives and of waste generation. Furthermore, this practice enables 
efficient  ore  excavation  and  helps  to  prevent  sterilisation  of  unextracted  mineral 
material on site.  

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Case studies: 

Examples  of  selective  ore  extraction  by  choosing  the  appropriate  extraction 
equipment  were  chosen 
four  operations:  Readymix-Lesence  Kft. 
(construction  minerals)  in  Hungary,  Delphi-Distomon  SA  (bauxite)  in  Greece, 
JSW S.A. (energy mineral) and Bogdanka Coal Mine, both operating in Poland.  

from 

The construction mineral company noted that extraction planning is based on the 
selection  of  proper  machinery  and  equipment  (for  the  most  part  earth-moving 
machines), primarily with a view to prevent waste generation.  

The bauxite mining company mentions that choosing the proper size underground 
machines  necessary  for  mining  and  tunnelling  works  is  made  according  to  the 
shape and the type of the ore leads to the optimum ore recovery.  

JSW  S.A.  Poland  limits  the  extraction  of  material  that  would  become  waste  by 
selecting less contaminated coal (without interlayers) through precise adjustment 
of the extraction machinery and by considering:  

  an  optimal  selection  of  mechanised  wall  casings  and  mining  machines, 

depending on the expected mining-geological conditions, 

  proper longwall projection accounting for the presence of larger geological 

disorders (faults, horseback etc.). 

Lubelski  Węgiel  “Bogdanka”  S.A.  (“Bogdanka”  Lublin  Coal)  in  Poland  noted 
that  rational  extractive  waste  management  begins  at  the  design  of  the  extractive 
operation, while being flexible during the extraction phase. Limiting the amount 
of mining and processing waste is achieved by use of: 

  adequate machinery and equipment for extraction of the ore 
  sorting machinery to separate coal from gangue, 
  gangue for underground construction works 

Baumit  Kft  (construction  minerals)  in  Hungary  noted  that  the  planning  of  the 
drilling  and  blasting  phase  is  one  of  the  most  important  steps  since  the 
optimisation  of  this  phase  leads  to  the  prevention  of  waste  generation  and 
efficient use of resources.  

Additionally,  some  operators  reported  that  maximisation  of  the  ore  extraction 
reduces  the  likelihood  of  the  remaining  ore  being  sterilised,  weathered  or 
oxidised, so that no unextracted material can come into contact with mine waters, 
this  contact  producing  AMD  and  contributing  to  the  discharges  of  dissolved 
metals. 

3.4.3 Best Practice 3: Efficient haulage 

The  mine  access  and  transport  network  and  choosing  an  adequate  hauling  equipment 
and technique is a multi-dimensional optimisation problem that has to be considered at 
the design phase and may be regulated under national or sub-national mining laws in the 
Member  States.  In  some  cases,  extractive  materials  are  transported  or  pumped  many 

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kilometres  to  an  appropriate  site  for  treatment  or  deposition.  Optimising  the  way 
(underground or surface transportation, using trucks or conveyor belts, or transported as 
slurry) usually leads to efficient use of energy, less disturbance of the surroundings and 
in some cases reduces the amount of rock to be excavated. The costs of using extractive 
materials  that  in  principle  qualify  as  by-products/products  are  influenced  by  the 
transportation distances and the haulage systems. 

A  well  designed  and  maintained  haulage  network  is  the  key  to  minimising  haulage 
hazards  and  costs  and  increasing  productivity.  However,  the  design  of  the  network 
should also take into consideration local  conditions and safety. Efficient haulage is an 
essential part of the  whole mineral  extractive project  since no amount of  maintenance 
will fix a poorly designed network.  

A  life-cycle  emission  and  energy  balance  of  the  hauling  equipment  may  lead  to  the 
proper  decision  being  made  whether  maintaining  and  repairing  existing  equipment  at 
the bottom  line leads  to  higher emissions and/or  energy  requirements  than using new, 
more energy-efficient equipment. 

A poorly designed and constructed road infrastructure may need repeated maintenance 
(consumption of raw materials) and may lead to accidents. Each component of the road 
infrastructure should therefore be adequately addressed at the design stage (Thompson, 
2010). 

Figure 3-7: Typical integrated approach to road design (Thompson, 2010) 

Relevance for Circular Economy:  

Optimising  the  access  to  the  operational  site  and  transport  network  and  choosing  an 
adequate hauling equipment and technique usually leads to efficient use of energy, less 

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disturbance  to  surroundings  and  in  some  cases  reduces  the  amount  of  rock  to  be 
excavated.  

Case study: 

Two examples highlighting the importance of effective haulage have been chosen, 
one  from  Greece,  from  the  metal  ore  sector,  and  one  from  Hungary  (construction 
minerals). Both argue that the benefit of optimising the transportation network and 
the  selection  of  modern  equipment  achieve  a  reduction  in  CO2  emissions  and 
improved energy efficiency.  

One should be aware, however, that replacing existing mining equipment with more 
modern equipment may lead to operational energy savings, but  a life-cycle energy 
balance has to show that this replacement leads to overall energy savings and thus 
reduced  environmental  impacts.  Maintaining  and  repairing  older  equipment  may 
consume  less  virgin  materials  and  energy  and  thus  be  more  in  the  spirit  of  the 
Circular Economy. 

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3.4.4  Best Practice 4: Effective ore sorting and selective ore processing 
Separation of processing fractions maximises beneficiation efficiency and may, in some 
cases, reduce the harmfulness of the extractive waste produced.  

Better in situ separation of ore from extractive waste occasionally means prevention of 
waste  generation  and  better  extractive  waste  management.  For  example,  better 
distinction  between  ore  and  waste  rock  may  reduce  wear  and  tear  of  machines  by 
avoiding excavating unnecessary quantities of harder rock.  

In  certain  instances,  separation  practices  may  create  opportunities  to  identify  and 
commercialise  by-products.  Furthermore,  this  practice  prevents  leaving  unextracted 
mineralised material on site (resource sterilisation).  

Relevance for Circular Economy:  

Waste management objectives regarding prevention, re-use, and recycling highlight 
that  the  distinction  between  ore  and  waste  rock  may  strengthen  the  application  of 
Circular Economy principles by producing secondary raw material and by reducing 
the environmental footprint of extractive waste.  

Case studies: 

Selective  ore  processing  at  Aitik  mine  in  Sweden  consists  of  desulphurization  and 
reducing  the  amount  of  hazardous  waste.  Desulphurisation  offers  an  interesting 
integrated approach to tailings management and control of acid mine drainage (AMD) 
(e.g. Benzaazoua et al. 2000, Benzaazoua & Kongolo 2003, Bois et al. 2004, Hesketh 
et  al.  2010).  In  desulphurisation,  acid  forming  sulphide  mineral  fraction  is  either 
partly or fully separated from the tailings by froth flotation before the final deposition 
into the mine waste area (Kongolo et al. 2004, Kauppila et al. 2011). The application 
of selective ore processing in the mine closure phase at Aitik mine offers an integrated 
approach to both tailings management and control of seepage water quality.  

This practice is applied during the pre-processing of Greek diasporic bauxite, which 
contains  approximately  2-3  %  of  CaCO3.  In  order  to  reduce  the  consumption  of 
caustic soda and to reduce the amount of bauxite residues (=dewatered red mud) the 
Company removes the CaCO3 using heavy media separation. The separated CaCO3 is 
sold  as  a  secondary  material  for  construction  purposes  and  as  a  raw  material  in  the 
cement industry. 

(Source http://wiki.gtk.fi/) 

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3.4.5 Practice 5: Effective usage of excavated materials  

Filling excavation voids with excavated material 
Certain  mining,  remediation  and  construction  methods  require  the  placing  back  of 
extracted materials into excavation voids. Application of these strategies - as far as they 
are  technically  and  economically  feasible  and  environmentally  sound  -  requires  due 
consideration  of  the  requirements  of  equipment  access,  costs,  productivity,  stability 
and/or  ventilation,  which  are  investigated  in  the  design  phase  and  regulated  under 
national or sub-national mining laws in the Member States. 

In  many  EWMPs  submitted  to  the  European  Commission,  the  application  of  placing 
back  extracted  materials  into  excavation  voids  is  presented  as  best  practice  since  it 
contributes  to  the  prevention  and/or  reduction  of  extractive  waste  generation, 
simultaneously contributes to site remediation, and avoids occupying new land for the 
collection, storage and disposal of extractive waste. At the same time, instead of using 
virgin construction materials for rehabilitation purposes, the extractive industry utilises 
its  own  waste.  Furthermore,  in  some  cases,  this  practice  allows  for  the  exploiting  of 
secondary stopes once the backfill of the primary stopes has structurally consolidated, 
resulting in resource efficiency. 

In  EWMPs  related  to  tailings,  reference  is  made  to  Cemented  Tailing  Backfill  (CTB) 
technology.  Its  components (cement, tailings  and water) are combined and mixed in a 
plant usually located on the ground of the mine. CTB, according to the mining sector, 
helps  to  alleviate  the  environmental  impact  of  potentially  hazardous  mill  tailings  and 
extends the life-time of the tailings management facility since less volume is required. 
Instead  of  cement,  material  with  hydraulic  properties,  such  as  fly-ash,  are  commonly 
used  as  binder.  Potential  and  actual  environmental  impacts  from  CTB  need  to  be 
balanced against safety gains by less surface disposal of tailings.  

Whilst  this  often  means  that  the  material  placed  back  into  excavation  voids  becomes 
inaccessible  itself  for  future  use  or  re-processing,  it  usually  also  avoids  leaving  more 
valuable mineralised material on site (sterilisation of resources). 

Relevance for Circular Economy:  

Placing  of  excavated  materials  back  into  excavation  voids  contributes  to  the 
prevention/reduction of space needed for the disposal of extractive wastes and their 
harmfulness. The extractive material is not deposited or stored at the surface and at 
the same time contributes to the remediation purposes.  

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Cases studies: 

The practice of filling excavation voids with extractive material was mentioned by 
all the mineral sectors and almost one third of the practice examples received were 
related  to  strategies  and  techniques  for  (back-)filling  EWs  into  mined-out  voids. 
Some examples are: 

a)  Lafarge,  35771  Vern-sur-Seiche  from  France:  Backfilling  of  EW  in 
order to raise the pit floor above the groundwater level in order to reduce 
the volume of water to be pumped out of the pit. 

b)  JSW S.A. (energy mineral sector) from Poland argues that the usage of 
EW as material for filling excavation voids achieves the goal “zero waste 
generation and using waste as resources” (usage of EW instead of virgin 
aggregates). 

c)  Mina  Lujar  (Minera  de  Órgiva),  Spain  (industrial  minerals)  uses 
extractive  waste  not  only  to  fill  excavation  voids  in  the  underground 
mine  “Lujar”,  but  also  uses  the  extractive  materials    for  reclamation 
purposes outside the boundaries of the mine site.  

d)  Minas de Aguas Teñidas S.A.U. from Spain (metallic mineral sector): 
Use  of  thickened  and  cemented  tailings  for  the  filling  of  underground 
stopes.  Backfilling  the  primary  stopes  with  paste  tailings  could  be 
considered  as  a  best  practice,  taking  into  account  the  practical  reasons 
below: 

  Filling  excavated  stopes  with  CTB  that  achieve  sufficient  structural 
strength allows mining of the space in between them, thus increasing 
resource efficiency by more extraction from the same mine. 

  The  tailings  are  cemented  in  paste  processing  plants  such  that  the 
resulting material  has the required quality to  backfill  the  excavation 
stopes. 

  Approximately  50%  of  the  total  amount  of  tailings  are  finally 
disposed  into  the  mine.  This  practice  prevents  ARD  generation 
through buffering. The cement used in the paste preparation results in 
an ARD inert backfill. From a geochemical point of view, the paste is 
stable, which minimises the generation of ARD. 

e)  Agnico Eagle, Finland, Kittilä Mine: Their EWMP also refers to the paste 

backfill with tailings in underground mining.  

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f)  Chaux  et  Dolomie  Francaises,  Neau  (53)  Chaux  de  Provence  SACAM, 
Châteauneuf -Les-Martigues (13) in France: The dolomite quarry produces 
various Ca-Mg-oxides, lime and dolomites for a wide range of applications. 
The dolomite is subject to thermal treatment to obtain the oxide and residues 
are  returned  to  the  quarry.  The  various  residues  are  mixed  and  backfilled 
into  the  mined-out  part  of  the  quarry.  The  mixing  of  the  various  types  of 
extractive and processing wastes leads to an inertisation of the quicklime and 
the  mixtures  can  be  used  for  backfilling  and  remediation  purposes.  The 
benefit is an inertisation of reactive processing residues by mixing them with 
EWs (saving virgin raw materials). 

g)  Boliden  Mineral  AB,  mine  Garpenberg,  Sweden:  The  mining  strategy  is  to 
backfill waste rock and, according to the conditions in the permit, the tailings 
as well. The tailings that are not used for backfilling are transported wet in a 
pipe-line  (a  backup  line  is  installed  to  make  the  maintenance  easier)  to  the 
tailing pond that is water-saturated. 

h)  The  Swedish  EWMPs  from  LKAB,  Malmberget  Mine  (EWMP  2012)  and 
Zinkgruvan,Nya  Enemossen  (EWMP  2015)  also  apply  the  practice  of 
filling excavation voids with excavated material. 

Construction minerals as marketable materials from extractive wastes 
Overburden and waste rock may be recovered for the production of aggregates and lead 
to a reduction of volumes of extractive wastes that need to be managed in EWFs.  The 
viability  of  producing  construction  minerals  depends  strongly  on  the  local  market 
demand for material of defined properties (e.g. meeting respective norms and acceptable 
transport  costs).  Aggregates  are  used  in  building,  road  construction,  civil  engineering, 
coastal  protection, and for construction purposes in  the mines themselves. While inert 
residues by definition do not pose a problem with respect to environmental acceptance, 
under  national  or  sub-national  laws  in  the  Member  States,  non-inert  non-hazardous 
excavated  material  may  be  acceptable  for  certain  applications,  e.g.  road  foundations. 
technical,  economic  and 
This  depends  on 
environmental  requirements.  Some  EWMPs,  mainly  from  the  construction  minerals 
sector,  declare  that  (certain)  waste  materials  can  become  materials  marketable  to  the 
chemical industry, where it can be justified in environmental terms in accordance with 
binding environmental standards at Community level.  

their  specific  properties,  and 

the 

Relevance for Circular Economy:  

Using extracted by-product or waste as construction minerals – as far as it is technically 
feasible and environmentally sound – leads to less extractive waste being generated and 
offsets primary production of construction minerals elsewhere. 

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Cases studies: 

The  extractive  sector  places  importance  on  the  use  of  construction  minerals  as 
marketable  materials  from  extractive  wastes  since  one  third  of  the  collected 
practices (27%) are methods related to recycling or re-use strategies. 

Most of the companies that belong to the construction sector make a reference to 
the  practice  “use  (recovery)  extractive  waste  for  the  production  of  mineral 
aggregates”  in  their  EWMPs.  Specifically,  the  majority  of  EWMP  collected  in 
France (EWMPs from 43 quarries) show a common practice of: 

  setting  aside  top-soils  for  building  (temporary)  vegetated  dams  around  the 

extraction operation; the top-soil will be later used in remediation; 

  separating  storage  of  overburden  to  back-filled  at  closure  and  for 

landscaping the excavated area; 

  using suitable and non-marketable materials for construction purposes in the 

extractive operation; 

  quarries  and  pits  tending  to  market  as  much  as  possible  of  the  extracted 

material but depending on (local) demand and market conditions. 

Swedish  EWMPs  mention  the  utilisation  of  extractive  waste  for  construction 
purposes  inside  and  outside  the  site  or  facility  (e.g.  LKAB  Kirunavaara  Mine, 
LKAB,  Malmberget  Mine,  LKAB  Mertainen  Mine).  Specifically,  LKAB’s 
Mertainen  mine  re-uses  waste  rock  for 
the  construction  of  roads  and 
impoundments outside the mine site (a notification to the authorities is needed and 
the  material  needs  to  be  characterised  so  it  is  safe  to  use  for  the  construction 
purpose). Waste rocks that are suitable for construction work are utilised by many 
quarries  in  Finland  (e.g.  Nordkalk  Oy  Ab’s  Mustio  limestone  quarry,  Mondo 
minerals  B.V.  Uutela’s  talc  mine,  SMA  Mineral,  Kalkkimaa  factory,  and  the 
Rantamaa and Ristimaa limestone quarries). 

For  the  industrial  mineral  sector,  companies  such  as  Interbeton  Construction 
Materials S.A (kaolin quarry in Greece) propose that part of the extractive waste 
(sterile  material)  is  used  inside  the  site  for  earthworks  and  maintenance  of  the 
road  network.  This  practice  helps  to  reduce  the  amount  of  waste  that  needs 
management as well as replaces virgin construction raw materials. 

Many  companies  in  Poland  (JSW  S.A.,  Bogdanka  S.A.  (Lublin  Coal  Mine), 
Polska Grupa Górnicza S.A., TAURON Wydobycie S.A. (ZG Sobieski and ZG 
Janina)  show  that  aggregates  production  technology  is  simple  and  possible  for 
use  in  construction  works,  among  others,  as  filling,  land  levelling  as  well  as 
aggregate  in  concrete.  Specifically,  JSW  S.A.  follows  recovery  approaches  for 
waste management, such as the following: 

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1.  "The  use  (recovery)  of  extractive  waste  for  the  production  of  mineral 
aggregates":  Use  of  extractive  waste  from  mechanical  coal  sorting  (waste 
code  01  04  12)  for  the  production  of  aggregates,  according  to  technical 
approval and systematic quality control by 

  the  Roads  and  Bridges  Research  Institute  in  Warsaw  for  a 
construction  material  named  "Mineral  and  mine  aggregate  of  JSW" 
and 

  the  Technological-Natural  Institute  in  Falenty  for  a  product  named 

"Hydrotechnical aggregate of coal mine slate of JSW" 

2.  "Sales and use of extractive waste in not-processed form": Waste under the 
waste codes 01 01 02 and 01 04 12 produced by the mining industry of hard 
(earthworks, 
coal  mining  may  be  used  as  construction  material 
hydrotechnical  embankments)  or  some  generated  waste  from  the  flotation 
procedure may be used as raw material for the ceramic industry 

In  Hungary,  Colas  Északkő  Kft.  (construction  minerals)  managed  a  large-scale 
landscaping project at the Tállya Andesite Quarry, which is inside a Natura2000 
area  and  UNESCO  Tokaj  Wine  Region  Historic  Cultural  Landscape  World 
Heritage  protection  zone,  until  2014.  A  total  of  170,000  m3  mining  waste  was 
used for the landscaping project.  

From  the  ore  mining  sector,  the  EWMPs  by  Rosia  Montana  Gold  Corporation 
S.A. and Hellas Gold S.A. (mixed sulfides) note that overburden and waste rock, 
due  to  the  suitability  of  their  geotechnical  and  geochemical  characteristics,    will 
be  used  particularly  for  the  construction  of  the  waste  facility,  but  also  for  other 
uses  (e.g.  road  construction).  The  Swedish  EWMP  from  Zinkgruvan,  Nya 
Enemossen mentions utilisation of tailings in dam constructions. 

3.4.6 Best Practice 6: Effective management of topsoil 
Topsoils are mineral-organic materials that provide the growing substrate for the plant 
cover.  Topsoils  are  ecosystems  of  their  own,  depending  on  a  set  of  environmental 
conditions,  such  as  rainfall  distribution  and  temperature  ranges.  This  means  that  the 
functionality  of  topsoils  can  be  easily  impaired  or  destroyed.  Rebuilding  this 
functionality takes years, if not decades.  

Putting  topsoil  back  in  place  after  the  closure  of  the  waste  facility  or,  if  this  is  not 
practically  feasible,  reusing  topsoil  elsewhere  (for  example,  landscaping  and  re-
vegetation  purposes)  may  strengthen  the  application  of  Circular  Economy  principles. 
Therefore, all topsoil removed during construction and preparation for mining should be 
stored at separate locations and under conditions that impair their functionality as little 
as possible. For the same reason, their reuse is encouraged as expeditiously as possible. 
During  the  operational  phase,  the  soil  heaps  will  vegetate  by  free  succession,  which 

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provides  a  protection  against  their  erosion  and  dust  generation  and  also  helps  to 
maintain their fertility. 

Relevance for Circular Economy:  

The  use  of  local  topsoil  works  best  for  fast  re-vegetation  with  local  plant  species  and 
avoids extraction and transport of topsoil from elsewhere. 

Case Studies: 

Rosia Montana Gold Corporation S.A. in Romania: The topsoil stockpiles and the 
overburden  stockpiles  are  expected  to  cover  some  40  ha  of  land  altogether.  The 
total area of these stockpiles is relatively small, as about 30% of the soil  stripped 
during the operational phase can be re-used during the same phase and only 70% 
need to be stored for later re-use during the closure phase. Temporary land-use at 
the stockpile sites is primarily agricultural with cattle and sheep grazing, fields for 
forage and some woodland. Sterilisation of the soil resource under the topsoil piles 
will  be  temporary  for  the  life  of  the  Project.  Following  removal  of  the  topsoil 
stockpiles the soils are expected to return to their original use, supporting pastures 
for grazing and forage. 

Readymix-Lesence Kft. in Hungary: The management of stripped topsoil is based 
on a careful analysis and planning of the material flows of the extractable mineral 
raw materials. Topsoils are stored for later use in re-cultivation and reconstitution 
of  arable  lands.    It  is  important  to  return  and  spread  the  topsoil  over  the  original 
area as soon as possible, possibly within three years, in order to retain fertility. If 
this is impossible within the three-year time frame, the topsoils are treated as inert 
waste, and are taken into account in the waste management plan.  

The use of local topsoil for landscaping and covering purposes is also mentioned in 
Finish EWMPs (Agnico Eagle Finland Oy, Kittilä Mine (gold), Mondo Minerals 
B.V,  Uutela  Mine  (talc),  Yara  Suomi  Oy,  the  Sokli  project  (phosphate)).  An 
important aspect is to keep organic and inorganic material separate when stripping 
the  ground,  in  order  to  keep  the  material  characteristics  for  the  landscaping 
purposes.  

3.4.7 Best Practice 7: Disposal planning and management for later recovery 

Re-processing of historical  extractive waste is  a long-standing practice that is  adopted 
for  all  kinds  of  minerals:  energy,  metal  ores,  industrial  and  construction.  Residues  of 
low value originally, which are readily available in tailings or heaps, undergo processes 
of recovery in order to obtain fully qualified products, such as metals, aggregates, coal 
(energy  products)  etc.  Technological  advances  make  it  economically  feasible  to  use 

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historical  extractive  waste  as  a  resource  –  especially  in  combination  with  newly 
discovered ore-bodies and/or site clean-up and river restoration projects. 

The EWMPs may consider such reworking of  extractive waste from  the outset, at the 
planning  stage,  by  segregated  emplacement  where  this  is  operationally  and  spatially 
feasible. 

Relevance for Circular Economy: Re-processing of historical extractive waste:  
The  utilisation  of  historical  waste  as  raw  material  increases  the  long-term  value 
obtained  from  the  original  extraction,  offsets  primary  production  elsewhere  and 
simultaneously  contributes 
improves 
environmental conditions locally by removing non-inert components, it seldom reduces 
the total amount of extractive waste to be subsequently managed. 

to  site  rehabilitation.  Whilst  this  usually 

Case studies: 

EWMP from Penouta mine in Spain: The Penouta Mine was closed in 1985 without 
any rehabilitation of the site. Strategic Minerals Spain has carried out several studies 
to  find  ways  to  exploit  the  tailings  ponds  containing  tantalum  and  niobium.  The 
processing of tailings from the old Penouta mine produces around 1% of tin, tantalum 
and  niobium  metals,  and  99%  remain  tailings.  The  latter  are  mainly  composed  of 
silicate minerals that can be reprocessed, obtaining around 70% of industrial minerals, 
namely  quartz,  mica,  feldspar  and  kaolin.  The  overall  process  aims  to  achieve  a 
reduction of mining wastes by around 80%. The final residue will be used as material 
for environmental rehabilitation. 

Hellas  Gold  S.A.  in  Greece:  Re-processing  of  historical  waste  (tailings  from  the 
enrichment of pyrites) to produce concentrates of galena, sphalerite and arsenopyrite. 
The historical waste is the residue of the ore treatment (since 2000) after recovery of 
these  minerals.  The  re-working  uses  more  efficient  extraction  and  thus  reduces  the 
amount of ARD generating minerals in the tailings. 

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Canteras de Santullan S.A. in Spain (aggregates and production of calcium 
carbonate): Under the pressure of a very difficult situation due to the economic 
crisis  at  the  end  of  the  2000s,  the  company  decided  to  reconsider 
fundamentally and from a mining-technical point of view all existing processes 
and, with relevant investments, to increase drastically the recovery of reserves 
and recycle large stocks of old wastes. 
The decision reduced mining costs, improved the quality of and added value to 
the  final  mineral  products,  transforming  the  company  from  a  small  local 
supplier  of  low-value  construction  aggregates  to  one  of  the  biggest  European 
exporters  of  high-quality  industrial  and  chemical  limestone  products  by  sea 
transport from Bilbao port. 

Interbeton S.A. (Titan Group) in Greece: Company owns a heap of low-grade 
kaolin  (as  old  historical  residue),  which  is  mixed  with  high-grade  kaolin 
(according  to  the  trade  specifications),  targeting    use  of  the  total  of  the 
historical extracted material. This historical residue was not mixed with other 
waste (like overburden) during the production phase, thus  it can be used now 
as  raw  material  due  to  new  lower  grade  marketing  needs.  This  illustrates  the 
benefit of segregated disposal in view of later re-working. 

3.4.8  Best Practice 8: Effective monitoring of the implementation of the EWMPs 

and their review 

Each Extractive Waste Management Plan is reviewed by the operator every five years 
and/or amended, as appropriate, in the event of substantial changes to the operation of 
the  waste  facility  or  to  the  waste  deposited.  Monitoring  is  an  important  tool  to  verify 
that an EWMP meets  its objectives. The monitoring of  an EWMP should be dynamic 
and  provide  records  that  can  be  utilised  as  a  basis  for  the  continuous  optimisation  of 
resources use and minimisation of the residual material that will end up in an extractive 
waste facility.  

Typically,  the  operator  develops  a  monitoring  plan  that  also  includes  parameters 
relevant  to  the  EWMP.  The  details  of  the  proposed  monitoring  actions  may  include 
water  and  soil  sampling  and  on-site  or  in  situ  measurements,  geotechnical  tests, 
topographical surveys, and surveys using remote sensing techniques. 

An  EWMP’s  monitoring  records  not  only  demonstrate  compliance  with  the  initial 
permit, but also may provide useful information for: 

research for minimisation of hazardous properties of extractive wastes 

  decisions related to waste minimisation 
 
  prevention  or  at  least  minimisation  of  any  long-term  negative  effects,  for 
example attributable to  migration of airborne or aquatic contaminants from the 
waste facility 

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  Assurance  long-term  geotechnical  stability  of  any  EWF  exists  in  the  ground 

surface 

EWMP is reviewed by the operator every five years and/or amended, as appropriate, in 
the  event  of  substantial  changes  to  the  operation  of  the  waste  facility  or  to  the  waste 
deposited, supported by monitoring techniques, in order to prevent or reduce as far as 
possible  any  negative  effects  -  actual  or  potential  -  on  the  environment  or  on  human 
health, and lead to fast corrective actions, if needed. 

Relevance for Circular Economy:  

Starting from the design phase of a mining site, the EWD emphasises the concept that 
effective design will reduce the generation of extractive waste, encourage its recovery 
and  minimise  short-  and  long-term  liabilities.  Indeed,  the  ultimate  goal  would  be  to 
ensure  that,  where  possible,  a  closed  site  can  be  left  without  the  need  for  on-going 
monitoring. Therefore, keeping regular records of the all the quantities and composition 
of extractive waste generated at a site will aid decision-making on its fate and ensure its 
optimal management. 

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Case study: 

According to the EWMP from Rosia Montana Gold Corporation S.A. (Romania) the 
EWMP is subject to periodic review and update over the life of the mining operation, in 
response  to  internal  and  external  reviewer  comments,  regulatory  changes,  changes  in 
mining operations, stakeholder communications, internal audit and management review 
results,  and  other  factors.  The  implementation  of  the  Extractive  Waste  Management 
Plan  is  also  supported  by  a  number  of  detailed,  lower-tier  Standard  Operating 
Procedures.  The  Structural  Relationship  of  lower-tier  Management  Plans  in  the 
Environmental and Social Management System is presented in the following figure. 

Figure 3-8: Environmental and social management system (Source: EWMP from S.C. Rosia 
Montana Gold Corporation S.A. 

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3.5 References 

49 

Barthel L.-P., Wolf M.-A., Will M., Eyerer P. (2007). Life cycle engineering of mining 
and industrial sites. Life cycle engineering of mining and industrial sites. (K. 
J. In Hebestreit C., Ed.), A sustainable supply of minerals for Europe - from 
waste to resources (pp. 9–15). WrocÅ‚aw: KGHM Cuprum. 

Bian, Z., Miao, X., Lei, S., Chen, S.-e., Wang, W., Struthers, S. (2012). The challenges 
of reusing mining  and  mineral-processing wastes. Science 337  (6095),  702–
703 

DHI, Cantab Consulting Ltd, University of Tartu, Mecsek-Öko, Miskolc University and 
VTT.  (2012).  Guidelines  for  the  inspection  of  mining  waste  facilities. 
http://ec.europa.eu/environment/waste/mining/pdf/Annex2_guidelines_inspec
tion.pdf  

EPA Ireland. (2012). Guidance on the Waste Management (Management of Waste from 
the  Extractive  Industries)  Regulations  2009.  Retrieved  01.04.18,  from: 
http://www.epa.ie/pubs/advice/waste/extractive/  

European Commission. (2015). Communication from the Commission to the European 
Parliament, the Council, The European Economic and Social Committee and 
the Committee of the Regions. Closing the loop - An EU action plan for the 
Circular Economy. Brussels 

European Commission. (2017). Communication from the Commission to the European 
Parliament, the Council, the European Economic and Social Committee and 
the Committee of the Regions on the 2017 list of Critical Raw Materials for 
the 
from: 
https://ec.europa.eu/transparency/regdoc/rep/1/2017/EN/COM-2017-490-F1-
EN-MAIN-PART-1.PDF  

Retrieved 

06.04.18 

EU. 

European  Commission  (2018).  Commission  notice  on  technical  guidance  on  the 
classification  of  waste  (2018/C  124/01).  Official  Journal  of  the  European 
Union. 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?toc=OJ:C:2018:124:TOC&uri=uriserv:OJ.C_.2018.124.01.
0001.01.ENG  

Retrieved 

11.06.18 

from: 

European Commission (2018). Communication from The Commission to the European 
Parliament, the Council, The European Economic and Social Committee and 
The  Committee  of  the  Regions  on  a  monitoring  framework  for  the  Circular 
Economy. 
from 
17 
https://ec.europa.eu/commission/priorities/jobs-growth-and-
investment/towards-circular-economy_en  

.  Retrieved 

{SWD(2018) 

13.04.18, 

final} 

European  Commission  (2018).  Best  available  techniques  (BAT)  Reference  Document 
for the Management of Waste from Extractive Industries in accordance with 
2006/21/EC. 
Directive 
http://publications.jrc.ec.europa.eu/repository/handle/JRC109657 

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Hansen  Bailey  (2015).  Revised  Environmental  Risk  Assessment.  Bylong  Coal  Project- 
(01/05/2018) 
Statement. 
Environmental 
http://www.hansenbailey.com.au/documents/bylong/Bylong_App_G_Revised
_Environmental_Risk_Assessment.pdf 

Retrieved 

Impact 

Hennebert,  P.,  Papin,  A.,  Padox,  JM.,  Hasebrouck,  B.  (2013).  The  evaluation  of  an 
analytical  protocol  for  the  determination  of  substances  in  waste  for  hazard 
classification. Waste Management, Vol. 33(7), pp. 1577-1588. 

ICMM. (2011). The role of mining and metals in land use and adaptation. International 
from: 

Council 
and  Metals.  Retrieved 
https://www.extractiveshub.org/servefile/getFile/id/2296  

on  Mining 

06.04.18, 

ICMM.  (2016).  Mining  and  metals  and  Circular  Economy.  Retrieved  April  2018, 
from:https://www.icmm.com/website/publications/pdfs/responsible-
sourcing/icmm-circular-economy-1-.pdf  

KGHM  Ajax  Mining  Inc.  (2013).  Application  for  an  environmental  Assessment 
Certificate and Environmental Impact  Statement  for  a comprehensive study. 
Kamloops Canada: KGHM Ajax Mining Inc. – AJAX PROJECT. 

Lèbre  E.,  Corder  G.D.,  Golev  A.  (2016).  Sustainable  practices  in  the  management  of 
mining  waste:  A  focus  on  the  mineral  resource.  Minerals  Engineering,  107, 
34–42. 

Lottermoser, B. (2012). Mine Wastes: Characterization, Treatment and Environmental 

Impacts. New York: Springer. 

Ministry of Employment and the Economy Finland. (2013). Making Finland a leader in 
the sustainable extractive industry - action plan. Retrieved June 2018, from: 
https://tem.fi/documents/1410877/3437254/Making+Finland+a+leader+in+th
e+sustainable+extractive+industry+04072013.pdf  

RioTinto.  (2011).  HSEQ  Management  System-Iron  Ore  (WA)  Mineral  Waste 

Management Work Practice. 

Swedish  Environmental  Protection  Agency.  (2016).  Proposal  for  a  strategy  for 
Extractive  Waste  Management.  Stockholm  och  Uppsala:  Accounting  for  a 
government  mission  Letter  2017-09-14  Cases:  NV-03195-16  SGU:  311-
888/2016. 

Thompson, R. (2010). Mine Haul Road Design and Management Best Practices for Safe 
and Cost-Efficient Truck Haulage. In Proceedings of the Society for Mining, 
Metallurgy and Exploration Annual Meeting & Exhibit, Phoenix, AZ, USA, 
28  February–3  March  2010;  Society  for  Mining,  Metallurgy  and 
Exploration (SME): Littleton, CO, USA, 2010; pp. 1–10. 

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4. Development  of  a  guidance  document  on  best  practices  in 
the Extractive Waste Management Plans Best Practices for 
the  implementation  of  the  provisions  set  out  in  Article 
5(2)(c) and 5(3) of the Extractive Waste Directive  

4.1 Introduction  

4.1.1 Context 
The  management  of  extractive  wastes  is  regulated  by  Directive  2006/21/EC,  the 
Extractive Waste Directive (EWD, 2006).  

The Communication “Closing the loop - An EU action plan for the Circular Economy” 
(COM/2015/0614 final) by the European Commission describes the 'Circular Economy' 
as an  economy, where the value of products,  materials and resources is  maintained in 
the economy for as long as possible, and the generation of waste minimised (European 
Commission, 2015). This Communication announced that the Commission will develop 
guidance  and  promote  best  practices  in  the  extractive  waste  management  plans 
(EWMPs) by 2018 in order to foster the implementation of the stipulations of the EWD. 
To this end the Commission requested information from national authorities, industry, 
environmental  NGOs,  knowledgeable  experts  and  civil  society  on  pertinent  EWMPs. 
This  report  presents  the  results  of  an  assessment  of  the  information  received  and 
additional  data  gathered  with  a  view  to  identify  practices  that  can  be  considered  as 
examples for best practice. In chapter 3 the related companion report, “Development of 
a  guidance  document  on  best  practices  in  the  Extractive  Waste  Management  Plans  - 
Circular  Economy  Action”  (Eco  Efficiency  et  al.,  2019)  considered  the  circular 
economy  aspects  whereas  this  report  focuses  on  the  aspects  related  to  ensuring  the 
short- and long-term safety of disposal of extractive waste. This encompasses the whole 
life-cycle,  from  the  design  phase,  the  management  during  the  operation,  to  the  after–
closure phase of an extractive waste facility (EWF).  

The mining sector is particularly complex due to the specific geological, geochemical, 
geotechnical,  geomorphological,  climatological,  ecological,  and  socio-economic 
conditions of each site. Also, the mining life-cycle (cf. Figure 4-1) encompasses many 
phases that may span years or even decades. As a matter of fact, the ultimate phase after 
closure  extends  in  time  due  to  the  fact  that  all  remaining  extractive  waste  (EW)  will 
remain at the site for ever.  

While the chosen technical waste management solution must ensure the short-term and 
long-term protection of human health and the environment, it also needs to ensure the 
short  and  long-term  after-closure  stability  with  as  little  maintenance  as  possible.  The 
EWMP has to  detail the respective strategies and rationales for selecting the technical 
solutions. 

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Figure 4-1: The phases in a mine life-cycle that will determine the EWM solution 

As has been pointed out in the related report on the Circular Economy aspects in EWM 
(Eco  Efficiency  et  al,  2019),  waste  minimisation through  optimised  extraction  and  re-
use is the key. It will also be shown that the choice of processes and the resulting waste-
type  can  significantly  influence  the  manageability  of  the  waste  and,  hence,  short-  and 
long-term  safety  of  the  EWF.  Therefore,  a  systemic  life-cycle  approach  is  likely  to 
result in more long-term stable EWM solutions, i.e. solutions that have minimal impact 
on the surrounding environment and remain physically intact.  

4.1.2  Objectives of this report 

The  present  report  is  part  of  a  study  to  support  the  European  Commission  in  the 
elaboration of guidance on best practices in developing EWMPs with a view to improve 
the  implementation  of  the  EWD.  It  addresses  in  particular  to  (a)  the  integration  of 
Circular Economy aspects into Extractive Waste Management Plans (Eco Efficiency et 
al, 2019)), and (b) the identification of Best Practices in Extractive Waste Management 
Plans  (EWMPs)  to  ensure  the  short-  and  long-term  safety  of  EWFs.  This  report  only 
covers activities that are under the scope of the EWD. 

According  to  Article  5  (“Waste  management  plans”)  of  the  EWD,  the  Member  States 
have to ensure that operators draw up an EWMP. Specifically, Articles 5 (2) c and 5 (3) 
of the EWD outline objectives of the EWMP related to the prevention of short and long-
term environmental impacts.  

This  report  will  outline  a  methodology  to  develop  EWMP  with  respect  to  the  criteria 
listed below. It will discuss the desirable scope and contents of EWMPs with a view to 
ensuring  the  short-  and  long-term  safe  disposal  of  extractive  waste,  in  particular  by 
considering,  during  the  design  phase,  the  management  during  operation  and  after  the 
closure of an EWF and by choosing a design that 

  requires minimal and, if possible, ultimately no monitoring, control and management 

of the closed waste facility (minimise long-term stewardship needs); 

  prevents  or  at  least  minimises  any  long-term  effects,  for  example  attributable  to 

migration of airborne or aquatic pollutants from the waste facility; and 

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  ensures  the  long-term  geotechnical  stability  of  any  dams  or  heaps  rising  above  the 

pre-existing ground surface.  

  for  Category  A  facilities:  major  accident  prevention  policies  and  related  safety 

management system, internal emergency plans; 

  for  facilities  not  categorised  as  Category  A,  information  on  justification  including 

identification of possible accident hazards; 

  extractive  waste  characterisation  in  accordance  with  Annex  II  of  the  EWD  and 
approaches to estimate total quantities of extractive waste to be produced during the 
operational phase; 

  description of operations generating extractive waste;  
  assessments of how environment and human health may be adversely affected by the 

deposition of extractive waste; 

  preventive  measures  taken  to  minimise  environmental  impact  during  operation  and 

after closure; 

  control  and  monitoring  procedures  pursuant  to  Articles  10,  when  applicable,  and 

11(2)(c); 

  plans for closure, including rehabilitation, after closure procedures and monitoring as 

provided for in Article 12 of the EWD; 

  measures  for  the  prevention  of  water  status  deterioration  in  accordance  with 
Directive  2000/60/EC  and  the  prevention  or  minimisation  of  air  and  soil  pollution 
pursuant to Article 13 of the EWD;  

  surveys of the conditions of the land to be affected by the waste facility. 

There  will  be,  in  many  cases,  a  gradual  transition  from  the  operational  phase  to  the 
closure, post-closure and long-term management phase. The foundations for safe long-
term management will be laid during the operational phase, so that there will be a close 
the 
relationship  between 
recommendation  of  the  Best  Available  Techniques  reference  document  on  the 
management of waste from extractive industries (MWEI-BREF, 2018). This report will 
point out the particular long-term aspects in extractive waste management. 

the  recommendations  given 

this  document  and 

in 

The  scope  and  contents  of  the  EWMPs  collected  as  part  of  this  study  were  reviewed 
with respect to the above criteria. From these a number of cases were selected that can 
be considered as examples for ‘best practice’. 

4.1.3 Provisions of the EWD 
For  easy  reference,  the  provisions  of  the  relevant  Article  5  of  the  Extractive  Waste 
Directive (EWD, 2006) are given below. Article 5 of the EWD sets out the requirements 
for  Extractive  Waste  Management  Plans  (EWMPs)8.  The  present  report  focuses  on 
aspects related to Article 5 (2) c and 5 (3) of EWD.  

8 Relevant definitions are provided in Article 3 of the EWD. 
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Article 5 

Waste Management Plan 

1.  Member States shall ensure that the operator draws up a  waste management plan for the 
minimisation, treatment, recovery and disposal of extractive waste, taking account of the 
principle of sustainable development. 

2.  The objectives of the waste management plan shall be: 

(a) to prevent or reduce waste production and its harmfulness, in particular by considering: 

(i)  waste management in the design phase and in the choice of the method used for 

mineral extraction and treatment; 

(ii)  the  changes  that  the  extractive  waste  may  undergo  in  relation  to  an  increase  in 

surface area and exposure to conditions above ground; 

(iii)  placing  extractive  waste  back  into  the  excavation  void  after  extraction  of  the 
mineral,  as  far  as  is  technically  and  economically  feasible  and  environmentally 
sound  in  accordance  with  existing  environmental  standards  at  Community  level 
and with the requirements of this Directive where relevant; 

(iv)  putting topsoil back in place after the closure of the waste facility or, if this is not 

practically feasible, reusing topsoil elsewhere; 

(v)  using less dangerous substances for the treatment of mineral resources; 

(b)  to  encourage  the  recovery  of  extractive  waste  by  means  of  recycling,  reusing  or 
reclaiming such waste, where this is environmentally sound in accordance with existing 
environmental  standards  at  Community  level  and  with  the  requirements  of  this 
Directive where relevant; 

(c)  to  ensure  short  and  long-term  safe  disposal  of  the  extractive  waste,  in  particular  by 
considering,  during  the  design  phase,  management  during  the  operation  and  after-
closure of a waste facility and by choosing a design which: 

(i) 

requires  minimal  and,  if  possible,  ultimately  no  monitoring,  control  and 
management of the closed waste facility; 

(ii)  prevents  or  at  least  minimises  any  long-term  negative  effects,  for  example 
attributable to migration of airborne or aquatic pollutants from the waste facility; 
and 

(iii)  ensures the long-term geotechnical stability of any dams or heaps rising above the 

pre-existing ground surface. 

3.  The waste management plan shall contain at least the following elements: 

(a) where applicable, the proposed classification for the waste facility in accordance with 

the criteria laid down in Annex III: 

—  where  a  Category  A  waste  facility  is  required,  a  document  demonstrating  that  a 
major-accident prevention policy, a safety management system for implementing 
it and an internal emergency plan will be put into effect in accordance with Article 

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—  when  the  operator  considers  that  a  Category  A  waste  facility  is  not  required, 
sufficient  information  justifying  this,  including  an  identification  of  possible 
accident hazards; 

(b)  waste  characterisation  in  accordance  with  Annex II  and  a  statement  of the estimated 
total quantities of extractive waste to be produced during the operational phase; 

(c) a description of the operation generating such waste and of any subsequent treatment to 

which it is subject; 

(d) a description of how the environment and human health may be adversely affected by 
the deposit of such waste and the preventive measures to be taken in order to minimise 
environmental impact during operation and after closure, including the aspects referred 
to in Article 11(2) (a), (b), (d) and (e); 

(e)  the  proposed  control  and  monitoring  procedures  pursuant  to  Articles  10,  when 

applicable, and 11(2)(c); 

(f) the  proposed  plan  for  closure,  including  rehabilitation,  after-closure  procedures  and 

monitoring as provided for in Article 12; 

(g)  measures for the prevention of water status deterioration in accordance with Directive 
2000/60/EC and for the prevention or minimisation of air and soil pollution pursuant to 
Article 13; 

(h)  a survey of the condition of the land to be affected by the waste facility. 

The waste management plan shall provide sufficient information to enable the competent 
authority to evaluate the operator's ability to meet the objectives of the waste management 
plan  as  set  out  in  paragraph  2  and  his  obligations  under  this  Directive.  The  plan  shall 
explain, in particular, how the option and method chosen as mentioned in paragraph 2(a)(i) 
will fulfil the objectives of the waste management plan as laid down in paragraph 2(a). 

4.  The  waste  management  plan  shall  be  reviewed  every  five  years  and/or  amended,  as 
appropriate, in the event of substantial changes to the operation of the waste facility or to 
the waste deposited. Any amendments shall be notified to the competent authority. 

5.  Plans  produced  pursuant  to  other  national  or  Community  legislation  and  containing  the 
information  specified  in  paragraph  3  may  be  used  where  this  obviates  the  unnecessary 
duplication of information and the repetition of work by the operator, on condition that all 
requirements under paragraphs 1 to 4 are met. 

6.  The  competent  authority  shall  approve  the  waste  management  plan  on  the  basis  of 
procedures to be decided by the Member States and shall monitor its implementation. 

4.2  Methodological considerations for developing EWMPs to ensure short- 

and long-term safe disposal of extractive waste.  

4.2.1  Conceptual framing – the dimension of time 
A  continuum  of  geotechnical  and  environmental  safety  has  to  be  assured  during  the 
transition from the operational to the post-closure phase. Conditions and parameters will 
differ  somewhat  for  assuring  the  short-term  operational  safety  and  long-term  safety. 

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From  a  conceptual  point,  the  main  difference  between  the  two  is  that  during  the 
operational  phase,  safety  is  assured  by  continuous  maintenance  of  the  EWF.  To  the 
contrary, after closure only periodic monitoring and maintenance will be undertaken, if 
at all. The best solution will be, of course, a maintenance-free solution. Both situations 
may result in differing designs and parameters for the EW facility. However, as will be 
pointed  out  subsequently,  the  operational  design  is  best  chosen  so  as  to  facilitate 
transition into the closure and post-closure phase. 

In  order  to  better  understand  the  relationship  between  short-  and  long-term  risk  and 
safety aspects, short-term and operational safety are briefly reviewed in the following. 

Ensuring short-term operational safety not only encompasses technical measures, design 
criteria  and  designs,  but  also  management  measures,  or  in  other  words  governance 
issues. Mining operations evolve over time. This may include changing staff as well as 
changes  in  ownership  and  economic  boundary  conditions.  In  order  to  preserve 
institutional  knowledge  of  the  EW  facility,  adequate  records  management  provisions 
have to be put into place. EWMPs need to spell out, how the records are to be managed 
and  by  whom  (e.g.  IAEA,  2006).  EWMPs  would  identify  the  responsible  individuals 
and how responsibility is to be handed over in the case of change (MAC, 2017). 

A wide range of EWMPs have been collected for this project from Member States, as 
well  as  industry  associations  (Eco  Efficiency  et  al,  2019).  These  EWMPs  cover 
predominantly  the  operational  aspects  and  those  concerned  with  compliance  with 
applicable rules and regulations. Strategic considerations beyond the economic scope of 
the  operation  do  not  normally  play  a  role.  Particularly,  the  dimension  of  time  in  the 
sense  of  long-term  stability  of  the  chosen  management  solutions  for  EW  and  EWFs 
mostly is not mentioned explicitly. It is tacitly assumed that someone will monitor and 
maintain  EWFs,  particularly  those  containing  materials  that  may  cause  impacts  to  the 
environment and human health. However, it is very likely that a few hundred years after 
their construction the knowledge of their contents and even their existence will become 
lost. Designing for long-term stability has to keep this in mind.  

Hence,  this  guidance  is  particularly  concerned  with  the  dimension  of  time  of  the 
EWMPs, namely with the long-term safety and stability of the selected EWM solutions. 
The long-term manageability of mining residues depends inter alia on their nature and 
quantity,  which  in  turn  depend  on  the  host  geology,  as  well  as  the  mining  and 
processing methods. For this reason, the long-term safety and stability of EWs have to 
be seen in a life-cycle context as it is schematically presented in Figure 4-2. 

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Figure 4-2: The life-cycle of an extractive operation. 

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Extractive  wastes  and  their  retaining  structures  (e.g.  dams,  liners)  constitute  a 
potentially alien body of geological material in a given landscape or geological setting. 
For instance, slopes may be steeper than the natural ones, the material is sterile due to 
the absence of top-soil, the material is less cohesive than the surrounding materials, the 
wastes  may  contain  constituents  (e.g.  sulfide  minerals)  that  are  unstable  from  the 
geochemical  point  of  view  when  exposed  to  the  atmosphere,  wastes  from  processed 
minerals  contain  a  certain  chemical  potential  with  respect  to  their  surroundings,  etc. 
Therefore, it is likely that natural processes will alter the wastes themselves and/or any 
man-made  retaining  structures.  Such  alterations  may  compromise  the  stability  or 
functionality and, hence, the safety of the disposal site. The classification of extractive 
wastes  into  “inert”,  “non-inert  non-hazardous”,  or  “hazardous”  (see  European 
Commission, 2009) reflects the risk associated with such processes. 

It  needs  to  be  noted  that  natural  geological  systems  are  highly  variable  and  may  be 
known only to a limited extent until the actual excavation takes place. Therefore, only 
guidance on desirable objectives can be given and decisions need to be made on a case-
by-case  and  site-by-site  basis.  The  socio-economic  and  geographical  context  will  also 
have a decisive influence on the actual design of mines and their associated EWMPs.  

Any EWMP is the result of an optimisation between addressing identified risks, the pre-
existing  natural  conditions,  MWEI-BREF  (2018),  technical  feasibility  of  mitigation 
measures,  economic  opportunities,  and  cost.  EWMPs  will  need  to  be  adjusted  to 
changing circumstances. 

4.2.2  Integration into the mine planning and licensing process 
EWM should not be an end-of-the-pipe process but integrated into the overall planning 
of the extractive activity. Thus, assessment of what would constitute a best practice in 
EWMPs has to be undertaken using a systemic and life-cycle approach. This allows to 
identify where in a system one can interfere to either reduce wastes or to re-use/re-cycle 
them. Managing wastes alone is not “good” practice. Good practice addresses the waste 
at their originating process (c.f. also Eco Efficiency et al, 2019). To this end, a material 
flow  analysis  for  a  particular  operation  will  have  to  be  undertaken.  Changing  mining 
and milling processes might lead to residues that have a better potential for utilisation. 
However, a change in procedures/processes will only be accepted by mining companies, 
if they entail economic benefits or, if other, external incentives are provided. In any case 
it  is  desirable  that  such  changes  in  processes  do  not  lead  to  wastes  that  pose  greater 
challenges with respect to their long-term management. 

As  has  been  pointed  out  in  European  Commission  et  al.  (2019),  the  development  of 
EWMPs  is  an  iterative  process,  taking  into  consideration  mining  and  processing 
technology  aspects  as  well  as  resulting  potential  environmental  and  human  health 
impacts  that  would  be  addressed  in  the  related  Environmental  Impact  Assessment 
(EIA). When considering the long-term aspects in an EWMP, one may need to revisit 
certain aspects of the EIA from a long-term perspective. 

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A  life-cycle  approach  helps  to  ensure  both,  the  short  and  long-term  safe  disposal  of 
extractive  waste,  in  particular  by  considering  already  during  the  design  phase  the 
management  during  the  operation  and  after  closure  of  a  waste  facility.  This  approach 
ensures that EWM does not merely operate following the “end-of-the-pipe” paradigm, 
but tries to create synergies between the design of the operation of a mine and mill and 
the disposal of its wastes. A life-cycle approach also has the advantage that the closure 
of  extractive  waste  facilities  is  not  left  until  the  mining  operation  ceases,  but  can  be 
undertaken,  while  the  mine  and  its  infrastructure  and  staff  still  exist  (c.f.  Falck  et  al., 
2009;  Falck  &  Fernandes,  2009  –  though  addressing  nuclear  operations,  the  same 
concepts  apply  to  mines  and  mills;  Falck,  2016b).  This  reduces  the  likelihood  of 
abandoned  and  not  orderly  closed  mine  waste  sites  in  case  the  mine  ceases  operation 
prematurely. A life-cycle approach to EWMPs may consider the following aspects: 

•  EWMPs would be drawn up at the start on the basis of the initial extraction plan and 

the EIA for the overall operation 

•  EWMPs need to be continuously updated as processes and markets evolve 

•  Designs for mining and processing, the EIA, and the EWMP development need to be 

iterative processes 

•  Good process design aims to minimise materials moved and materials used 

•  Processes and EWM need to be optimised for the economic circumstances 
•  Energy requirements and CO2-footprints need to be considered and balanced against 

other potential impacts 

•  All  material  moved  would  be  processed  for  valuable  constituents,  if  the  economic 

circumstances permit it 

•  Processing may need to be delayed depending on market conditions -> stockpiling 

•  Mine and process wastes are best returned to the mined out voids, whenever possible 
and if it can be done safely and without impacts to the underground environment 
•  However, such ‘back-filling’ should not  preclude eventual access  to any  remaining 

resources 

•  Contingency plans for premature closure need to be developed 

4.2.3  EWMPs and change management 
Continuous  improvement  is  one  aspect  of  change  management,  which  also  ensures 
continuity in the case of changing personnel, ownership, designs, operations, as well as 
policy  and  regulatory  requirements.  Adequate  records  management  facilitates  change 
management.  For  instance,  good  records  of  what  kind  of  waste  has  been  deposited 
where,  will  facilitate  later  retrieval,  if  a  beneficial  use  has  been  found.  The  periodic 
updating of the EWMPs according to Article 5(4) of the EWD (EWD, 2006) allows to 
follow the principle of continuous improvement (Fig. 4-3). 

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Figure 4-3 The principle of continuous improvement (MAC, 2017) 

4.2.4 Managing the implementation of an EWMP 
Appropriate governance structures (see e.g. MAC, 2017) will provide clear management 
routes and accountabilities. Their description in the EWMPs is a good practice and can 
serve as a valuable communication instrument with a wide range of stakeholders. 

Periodic independent  reviews of EWMPs is  an instrument to  ensure that the plans are 
adequate,  up-to-date,  emulate  current  BAT/BAP  (MAC,  2017;  MWEI-BREF,  2018) 
and policy frameworks, such as the Circular Economy Plan. These reviews are part of 
the  governance  structures,  as  they  provide  the  basis  for  executive  decisions  by  the 
management. The reviews also provide assurance to the regulatory bodies. 

A quality management plan (QMP) that follows the relevant ISO 9001 guidelines would 
encompass  not  only  quality  control  (QC),  but  also  forward-looking  quality  assurance 
(QA) measures, that would be put into place as an overarching management instrument. 
The aspect discussed in the following all contribute to this QMP. 

It is recommendable to subject the QMP and its (technical and governance) components 
to an independent, periodic review by competent individuals or organisations. 

4.2.5 Risk Management in EWMPs 

Conceptual considerations 
As noted before, the management of extractive wastes is not a purely technical matter, 
but has to be undertaken in a context of global risk reduction, which includes secondary 
risks and impacts, such as the release of CO2 from the various types of operations. Risk 
displacement resulting from specific risk management actions has to be also taken into 
consideration. 

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the 

Risk  and  its  management  are  major  drivers 
behind EWM concepts und solutions. Risk-based 
decision-finding helps to focus the EWMP on the 
essential  aspects  and  hence  to  use  resources 
level  of 
efficiently  while  maximising 
protection of the environment and human health. 
Risk  and  safety  are  complementary  concepts, 
saying  that  by  managing  and  reducing  risks,  the 
safety of an operation or installation is increased. 
In  general,  risk  assessment  is  concerned  with 
features,  properties,  and  events  that  can  lead  to 
undesirable  out-comes  in  the  shorter  or  longer 
term. Risk is a human-defined concept and based 
on  

Figure 4-4: Risk Source-Pathway-
Receptor model 

values that individuals or societies would like to see protected, namely lives, health, and 
property.  It  is  helpful  to  visualise  risk  in  a  source-pathway/vector-receptor  model 
(Figure 4-4). A risk is only present, when all three factors are present or inversely the 
risk can be removed by removing either of the three factors. 

The objective of risk management is to reduce or eliminate impacts on the receptors, i.e. 
effects  on  the  values  to  be  protected.  Figure  4-4  indicates  that  there  can  be  three 
fundamental  strategies  in  risk  management,  namely  the  elimination  of  the  source,  the 
elimination of the pathway, or the removal of the receptor. The removal of the receptor, 
e.g. of people by evacuation, in many cases is neither desirable nor feasible. As a matter 
of fact, the main motivation for risk assessment and ensuing risk management measures 
is to avoid the removal of receptors, as this may entail considerable inconveniences and 
social or economic impacts. A classical example for removing a source of risk would be 
the  removal  of  a  soil  contamination.  If  the  contaminant  cannot  be  destroyed,  e.g.  by 
incineration  as  for  organic  contaminants,  it  has  to  be  placed  into  a  safe,  engineered 
repository.  Engineered  waste  disposal  facilities  are  also  an  example  for  removing 
pathways, as the containment of the facility is designed to inhibit pathways by which a 
contaminant  could  effect  its  surrounding  environment.  All  management  measures  for 
extractive  wastes  can  be  viewed  conceptually  as  following  one  of  the  above  risk 
management strategies. 

One  has  to  be  aware  of  risk  displacement  effects.  For  instance,  the  removal  of  a 
contaminant  at  one  place,  perhaps  on  the  instigation  of  potential  receptors  (e.g.  the 
‚public’),  will  have  the  effect  that  around  the  chosen  disposal  location  other  potential 
receptors  might  be  exposed  to  an  albeit  hopefully  much  lower  risk.  For  this  reason  a 
chosen EWM option always has to be carefully vetted for risk displacement effects.  

Risk management from the operators perspective 
From the perspective of the operator the various environmental and geotechnical risks 
in  the  first  instance  constitute  a  business  risk  that  may  entail  costs.  Risk  management 
activities entail costs, so-called opportunity costs, as the money spent either reduce the 

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profit  or  are  not  available  for  further  investment.  Therefore,  there  is  an  economic 
incentive  to  keep  risk  management  and  thus  EWM  costs  to  the  minimum  required  in 
order  to  comply  with  the  various  applicable  regulations.  There  is  often  a  limited 
awareness  among operators of the various business  risks associated  with  minimal  risk 
management.  The  breach  of  a  tailings  management  facility  will  have  impacts  beyond 
the  health  and  safety  of  the  workforce  and  the  downstream  communities  and 
environments.  To the cost  of rehabilitation and rebuilding the facility, the opportunity 
costs of loss of business, loss of reputation and trust among investors, business partners 
and last not least the local population will have to be added. Loss of social acceptance to 
operate can constitute a fatal business risk (Falck, 2016a). 

4.2.6  The transition from operational to long-term safety 
Most of the features and provisions that ensure geotechnical, environmental and human 
health  safety  of  EWFs  have  been  covered  in  the  MWEI-BREF  (2018).  The  following 
discussion focuses on the differences between operational and long-term safety features 
and  provisions.  Again,  a  life-cycle  perspective  during  planning  ensures  a  smooth 
transition  from  the  operational  to  the  post-closure  phase  and  an  efficient  use  of 
resources by considering the requirements of the post-closure phase already during the 
operational phase. 

Solid waste dumps 
Operational geotechnical safety of solid waste dumps. Good engineering practice and 
the  requirements  by  the  competent  authority  determine  the  controlling  parameters  for 
the  emplacement  of  residues,  such  as  grade  of  slope,  required  levels  of  compaction, 
maximum height of emplacement, and maximum height of each berm. The construction 
permission would normally also ensure that the underlying strata have been adequately 
characterised  in  order  to  ensure  their  stability  when  loaded.  Grades  of  slope  are  often 
chosen as steep as possible in order to save space, or according to the natural angle of 
deposition.  However,  in  order  to  avoid  re-grading  of  slopes  during  closure  and 
rehabilitation, it will be of advantage to mimic the surrounding natural geomorphology 
(see Best Practice Example A). 

Compacted waste is more geotechnically stable and has higher erosion resistance. It will 
be of advantage to foresee in the EWMP a strategy to consolidate the materials as early 
as possible. Thus, when vehicles are used to dump the waste, it will be of advantage to 
choose a strategy of emplacement whereby the vehicles run repeatedly over the waste, 
which will compact it without additional effort and energy expenditure.  

Non-cohesive material has its highest degree of geotechnical safety around the so-called 
optimal water content. Higher water contents reduce the stability of slopes. Therefore, it 
is good practice to reduce the meteoric water input at the earliest stage possible and to 
foresee in EWMPs re-vegetating the dumps and/or covering them with material of low 
permeability. This also eliminates or reduces a key vector in the risk of generating acid 
drainage (see below). 

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When residue dumps are created in natural depressions (e.g. valleys), any pre-existing 
water  courses  must  be  permanently  diverted  to  avoid  saturating  the  waste  and  thus 
destabilise it. The diversion channels must be designed to cope with at least 100 year-
rainfall events, or whatever national legislation may prescribe.  

For a variety of (practical) reasons in civil engineering ‚as built’ is not necessarily the 
same  ‚as  designed’.  Regular  project  reviews  and  on-site  monitoring  are  required  to 
detect  possible  deviations  from  construction  permissions  and  the  EWMP.  These 
deviations have to be assessed with respect to their significance and, if needed, remedial 
action has to be taken. This requires a strong and competent regulatory oversight. 

Operational  environmental  safety  of  solid  waste  dumps.  Ensuring  the  geotechnical 
stability  also  reduces  the  risk  from  eroded  or  spilled  materials  that  may  impact  e.g. 
water courses or cover valuable land with slumps and land-slides. Measures to reduce 
water ingress and gas exchange reduce the generation of acid drainage and leaching of 
contaminants by eliminating the vector water. Covering with cohesive material and re-
vegetation further reduces infiltration and the risk of dust generation, that may impact 
the surrounding environment. EWMPs, therefore, may want to foresee an early (partial) 
coverage  of  waste  dumps.  In  the  case  of  materials  particularly  prone  to  erosion  when 
dry  spraying  with  a  binding  agent,  for  instance  acrylic  emulsions  or  water  glass,  will 
supress dust generation in dry climates until the proper one can be constructed.  

While  geological  materials  are  normally  stable  on  a  secular  scale  in  their  natural 
environment,  excavation  changes  the  boundary  conditions,  e.g.  with  respect  to  redox 
conditions, driving the materials towards new equilibria. Such re-equilibrations manifest 
themselves,  for  instance,  in  the  generation  of  acid  drainage,  but  also  in  form  of 
processes  that  would  be  described  as  ‚early  diagenesis’  in  natural  geological 
environments.  It  is,  therefore,  wise  to  try  to  re-establish  conditions  in  emplaced 
materials that are close to those originally found. For this reason it is good practice to 
emplace, as far as possible, excavated materials in the same sequence as they occurred 
naturally and in contact with the source material where they came from. Segregation of 
extracted  materials,  particularly  overburden,  for  this  purpose,  therefore,  is  considered 
good  practice.  Depending  on  the  size  of  the  dump,  material  properties,  and  economic 
circumstances,  it  may  also  be  possible  to  introduce  solidifying  agents  that  aid  the 
diagenetic processes mentioned earlier. 

Tailings management facilities 
Operational  geotechnical  safety  of  tailings  management  facilities.  A  tailings 
management  facility  (TMF)  comprises  two  main  critical  components,  the  retaining 
structures, such as dams, and the impounded tailings themselves. 

A large amount of good practice for design and construction criteria for dams has been 
accumulated over the past decades. Those drafting EWMPs are well advised to take into 
consideration  the  guidance  given  e.g.  in  UNECE  (2014)  and  the  International 
Commission  on  Large  Dams  (http://www.icold-cigb.net/)  inter  alia.  Critical  factors 
include the internal structure of the dams (materials used, grain-size distribution, mode 

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and  level  of  compaction,  etc.),  the  way  how  they  are  ‘keyed’  into  the  surrounding 
geology  (e.g.  slope  of  the  terrain  on  which  the  dam  is  built,  drainage  properties), 
avoidance of ‚high-energy’ points (e.g. sharp corners, precise levelling of the crown to 
avoid  singular  points,  where  overtopping  may  occur,  etc.),  lining  of  dams  to  prevent 
excessive  soaking,  porewater  pressure  built-up  and  thus  piping  and  suffusion,  and 
protection  of  the  crown  against  the  effects  of  overtopping  and  erosion  to  avoid 
catastrophic failure due to regressive erosion. 

Where infiltrating porewaters can lead to the contamination of underlying strata a liner 
may be required. In such cases a bottom drainage will need to be foreseen in order to 
avoid undue accumulation of waters. Such drainage at the inside toe of the dam or at the 
lowest  point  in  the  impoundment  also  prevents  excessive  porewater  pressure  built-up 
that can lead to the failure of the dam. 

Practical  experience  shows  that  dams  often  are  not  built  as  designed.  The  actual 
construction  has  to  be  closely  monitored  to  ensure  that  the  design  and  its  materials 
parameters  are  followed.  This,  in  principle,  is  a  construction  licensing  issue  to  be 
monitored by the competent authorities, rather than the subject of the EWMP as such. In 
consequence, the regulatory control of the competent authorities over civil engineering 
project in a mine and the regulatory control over the EWMPs have to be integrated to 
ensure adequate safety. 

While applicable national civil engineering and mining regulations provide the licensing 
framework  for  dam  projects,  the  EWMPs  needs  to  look  at  the  development  of  the 
retaining  dams  over  the  life-cycle  of  the  mine.  For  cost  reasons,  a  tailings  dam  is  not 
normally constructed right away to take up all the tailings that expected to arise over the 
life-time of the mine, but it is enlarged or more typically raised as time progresses. The 
EWMP would outline the likely development and the envisaged method of raising as a 
function  of  the  kind  of  tailings  to  be  deposited  (Figure  4-5).  Upstream  raises  require 
little  material  for  dam  construction,  but  rely  on  the  successful  consolidation  of  the 
tailings.  Other  methods  are  likely  to  be  safer  options.  Since  a  tailings  management 
facility  almost  invariable  becomes  a  permanent  installation,  the  EWMP  should  also 
make  outline  provisions  for  the  closure  and  post-closure  developments.  This  includes 
strategies for the final capping as well as drainage and surface water diversion systems. 
Dewatering of liquid tailings can take decades, so that temporary capping to reduce the 
addition of meteoric waters needs to be considered. This applies also  to  TMFs, where 
thickened tailings are deposited (see below). 

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Figure 4-5: Different methods of raising tailings dams (WEF) 

The second critical component, the tailings themselves, are a key aspect in the EWMP. 
The  form  in  which  the  tailings  arise  depends  on  the  geological  material,  the 
comminution  technique,  the  process  technique  and  any  subsequent  conditioning. 
Normally,  tailings  arise  in  form  of  slurries  with  a  significant  water  content.  The 
comminution  tries  to  achieve  a  small  and  uniform  grain-size  with  a  view  to  enhance 
leaching. This makes the material unstable and difficult to handle from a geotechnical 
point of view. The major process, when tailings are consolidating upon emplacement, is 
the expulsion of the water. The fine, even colloidal nature of many tailings make this a 
slow  process  under  natural  conditions.  Tailings  are  usually  also  thixotropic,  meaning 
their viscosity changes dramatically, if shear forces are applied. This is one reason for 
the dramatic effects of dam failures: as soon as they begin to creep through the breach, 
they become liquefied with a cascading effect into the tailings mass. EWMPs therefore 
may  foresee  measures  to  accelerate  dewatering  or  better  the  emplacement  of  largely 
dewatered  (‚paste’)  tailings.  Paste  tailings  have  a  number  of  benefits,  including  better 
geotechnical stability, smaller volumes, shorter times to final closure, and the possibility 
to  recycle  process  waters.  The  MWEI-BREF  (2018)  recommend  thickened  tailings  as 
best  practice.  These  advantages  are  bought  at  the  expense  of  possible  less  convenient 
handling,  i.e.  transport  on  conveyer  belts  rather  than  pumping,  and  higher  energy 
expenditure  and  thus  larger  CO2-footprint.  However,  ensuing  risk  reduction  will  also 
result 
insurance,  emergency  preparedness,  and 
rehabilitation costs in the case of an incident. The EWMPs for TMF would take these 
benefits from risk-reduction measures into consideration. 

lower  costs  for 

third-party 

in 

A  tailings  pond  in  operation  will  also  interact  with  the  surrounding  environment.  For 
instance, it can change the stability of slopes on which it is built and the water balance 
in the adjacent geological strata. This can lead to instabilities, such as hydraulic heave, 
and  collapse  of  slopes  into  the  ponds,  which  due  to  the  displaced  tailings  masses  can 
lead  to  overtopping  and  the  failure  of  the  dam.  Although  such  scenarios  should  have 
been investigated as part of the licensing procedure, the EWMPs may need to  foresee 

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regular monitoring in order to detect early any detrimental changes in the surrounding 
geology.  

Operational  environmental  safety  of  tailings  management  facilities.  The  operational 
environmental  safety  of  tailings  management  facilities  is  largely  linked  to  their 
geotechnical safety, but not exclusively. While the geotechnical safety concerns mainly 
catastrophic failures, there may be also chronic effects from tailings ponds.  

In  the  past  tailings  ponds  where  typically  constructed  without  liners.  This  aids  in  the 
dewatering  of  the  tailings,  but  also  provides  a  pathway/vector  for  contaminant 
dispersion. Modern tailings ponds are often constructed with liners and drainage water 
collection  systems.  Any  drainage  water  is  then  treated  before  being  released  into  the 
environment. Similarly, there must be a system to collect surface decant waters. These 
are waters expelled from the compacting tailings and need to be treated before release 
into  the  environment.  Due  to  the  slow  dewatering  of  liquid  tailings,  drainage  water 
collection and treatment  may need to  continue for decades after the  closure of a mine 
and  mill.  In  consequence,  the  final  closure  of  a  tailings  pond  typically  can  only 
performed long after mining has ceased. This requires that adequate financial provisions 
are  provided  to  ensure  that  these  activities  can  be  performed  long  after  mining  has 
ceased. 

The  surface  area  of  a  tailings  pond  collects  the  atmospheric  precipitation  that  mixes 
with  the  decant  waters.  Further,  if  the  pond  is  constructed  in  a  natural  depression,  it 
forms  part  of  the  natural  watershed,  collecting  the  run-off  from  the  surrounding  area. 
Ideally  a  diversion  system  collecting  such  run-off  has  to  be  constructed  in  order  to 
minimise the input of clean precipitation that would mix with potentially contaminated 
decant  waters.  All  water  collection  and  treatment  systems  have  to  dimensioned  to  be 
able to cope with at least 100-year-rain-events, as noted above for the waste dumps. 

Uncovered tailings that dry out are prone to wind erosion and dispersal of contaminated 
dust, particularly in arid and semi-arid areas. Covering the tailings will also reduce the 
input of atmospheric precipitation, if the respective run-off is collected. 

Depositing the tailings as a paste will reduce the amount of seepage and decant waters 
that have to be handled thus reducing the associated risks. It will also reduce the amount 
of time until the tailings can be covered, thus reducing the risk associated with an open 
tailings pond. 

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Monitoring of tailings management facilities. Due to the geotechnical and water-borne 
risks  discussed  above,  an  adequate  monitoring  and  surveillance  programme  has  to  be 
put into place until final closure. A number of direct and indirect methods have become 
available,  particularly  in  recent  years.  The  main  hazard  associated  with  tailings 
management  facilities  is  that  of  catastrophic  containment  failure.  Nevertheless,  there 
may be also chronic failures, such as the leakage of contaminants into aquifers beneath 
the tailings. 

The  monitoring  of  the  containment  mainly  concerns  the  stability  of  dams  and  the 
functioning of constructed drainage systems to divert excess waters. Excess waters can 
lead to catastrophic failure of dams due to overtopping and ensuring retrograde erosion, 
which in  a self-enhancing mode can lead to  a complete failure of a dam. The EWMP 
needs to provide for periodic inspection of these drainage systems, e.g. with respect to 
silting up. 

Dams  can  fail  by  a  variety  of  mechanisms  including  suffusion,  excess  porewater 
pressure and toe failure. Modern geophysics and remote-sensing offers various tools to 
continuously  monitor  the  conditions  of  a  dam.  Air-borne  LIDAR  geo-referenced  with 
high-resolution satellite-supported positioning (e.g. GPS) allows to monitor the shape of 
an  earth-dam  and  to  detect  early  movements  or  distortions.  3D-resistance  tomography 
allows  to  map  porewater  contents  in  real-time  within  a  dam  and  to  send  respective 
warnings. The more traditional method would be a network of piezometers. 

Chronic  failure  of  dams  can  be  also  monitored  by  assessing  the  sediment  load 
downstream. Due to low loads and likely significant fluctuations as a function of flow-
rates, integrative methods would be better suited than sporadic sampling. 

The tailings themselves would also be observed in order to assess, whether dewatering 
progresses as predicted, e.g. by geotechnical modelling. Again airborne LIDAR would 
be a modern choice to map the settling periodically. 

The  monitoring  programme  would  also  need  to  include  the  waters  collected  in  the 
various drainage systems. In most cases these drainage and supernatand water will need 
to  be  treated  before  they  can  be  released  into  the  environment.  Regular  monitoring 
would be part of the operation of such treatment plants. 

For large-scale tailings ponds that for operational reasons remain uncovered and that are 
located  in  (semi-)arid  areas  several  air-monitoring  stations  down-wind  of  major  wind 
directions may be needed in order to detect dust problems. 

These  monitoring  programmes  would  be  integrated  into  a  formal  management  system 
for the site. This requires also a data management system that ensures the safe handling 
of the data and through which monitoring data can be made available to regulators and 
the  public,  the  latter  with  a  view  to  gain  confidence  and  thus  support  the  social 
acceptance to operate.  

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Emergency Preparedness and Response Plans (EPRP) 
According to Article 5 of the EWD in cases of Category A waste facility it is required, 
that the EWMP has to include an internal emergency plan. The emergency plans have to 
fulfil the following objectives according to Article 6(3) of the EWD: 

  to  contain  and  control  major  accidents  and  other  incidents  so  as  to  minimise  their 

effects and in particular to limit damage to human health and the environment, 

  to  implement  the measures  necessary  to  protect  human health  and the environment 

from the effects of major accidents and other incidents 

  to communicate the necessary information to the public and to the relevant services 

or authorities in the area 

  to  provide  for  the  rehabilitation,  restoration  and  clean-up  of  the  environment 

following a major accident 

Article  6  of  the  EWD  applies  to  Category  A  waste  facilities,  save  for  those  waste 
facilities falling within the scope of Directive 96/82/EC (‘Seveso Directive’, European 
Council, 1996). 

Examples  of  possible  emergencies  that  need  to  be  addressed  in  EPRPs  include: 
structural failures of the facility; rising water levels within a facility; cracking of a dam; 
a  sudden  loss  of  environmental  containment  of  the  facility;  or  other  events  typically 
linked to the loss of one or more critical controls (MAC, 2017). 

The  EPRPs  rely  on  the  monitoring  programmes  to  supply  the  data  for  the  necessary 
(real-time)  assessments.  EPRPs  can  be  drawn  up,  for  instance,  on  the  basis  of  FEP 
(Features,  Events,  Processes)  catalogues  (e.g.  Mazurek  et  al.,  2003)  and  related 
scenario analyses. Features here means e.g. engineering designs, natural landscapes etc. 
while  Events  may  include  e.g.  earthquakes,  storms,  etc.,  and  Processes  include 
categories such as erosion, dispersion, contaminant migration, etc. FEP catalogues are a 
kind  of  score-board  against  which  a  facility  can  be  assessed  with  respect  to  potential 
failure  modes  and  scenarios,  taking  into  account  also  common-mode  and  common-
cause failures. Pre-developed scenarios are helpful to identify possible event chains that 
can threaten the safety of waste management facilities, particularly tailings dams. 

The EIAs that have been developed during the licensing phase of an operation will also 
inform  the EPRPs.  Additional  assessments  may  be required.  For instance, these could 
include  numerical  simulations  of  the  flood  waves  that  would  develop  in  the  case  of  a 
tailings-dam  failure.  Such  simulations  allow  to  predict  the  areas  potentially  affected, 
which  in  consequence  may  need  to  be  evacuated.  In  turn,  this  allows  to  assess  which 
essential  services  (roads,  bridges,  telecommunication,  water  supply,  etc.)  might  be 
under threat, so that alternative routes for emergency services can be worked out. The 
simulations will also indicate the time-frame within which a flood is likely to proceed 
and, hence, how much time for initiating emergency response measures will remain. 

Informing  the  potentially  affected  parties,  including  the  general  public,  is  part  of 
emergency preparedness. In this way the people will know what to do (or not to do) in 
case  of  an  emergency.  This  may  be,  indeed,  a  difficult  subject,  because  adequate 
emergency  management  is  likely  to  be  a  key  subject  for  discourses  over  the  social 
acceptance to operate. Modes of informing potentially affected people of an imminent 
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emergency  have  to  be  pre-established  and  these  people  informed  about  these  modes. 
Likewise communication channels with the relevant authorities need to be established. 
In  collaboration  with  the  relevant  authorities  emergency  plans  for  rescue  services, 
hospitals,  etc.  have  to  be  drawn  up.  Utilities,  such  as  waterworks  and  electricity 
companies, in the potentially affected areas have to brought into the discussions, so that 
plans  for  shutting  down  their  operations  (temporarily)  in  order  to  avoid  secondary 
impacts (contamination of water supplies, power surges, etc.) and hazards (e.g. cut, but 
life electric cables) can be minimised. 

EPRPs have to remain in force after mining and milling have ceased and while tailings 
impoundments  are  not  yet  in  a  safe  closure  state.  They  are  part  of  the  long-term 
management plans. 

4.2.7 Recommended scope of EWMPs to ensure the short- and long-term safety of 
EWFs 
In  the  following  Table  a  number  of  elements  and  topics  are  listed  that  are  deemed 
necessary or useful to be covered by EWMPs, particularly also with respect to Articles 
5  (2)  c  and  5  (3)  of  the  EWD.  Potential  environmental  and  human  health  impacts 
addressed  in  the  Environmental  Impact  Assessment  (EIA)  need  also  to  be  taken  into 
account  in  EWMPs  as  part  of  an  iterative  process.  It  is  understood,  that  MSs  would 
define  the  scope  and  contents  of  the  EWMPs  and  EIAs  under  their  respective 
jurisdiction. For this reason the following are non-binding recommendations. 

A question to be resolved is, whether the EWMPs are to be submitted per EWF or per 
operation/mine.  There  is  not  necessarily  a  one-to-one  relationship  between  mines/ 
quarries and EWFs, some mine may have several EWFs or one EWF could be used by 
several  mines/quarries.  In  the  following  it  is  assumed,  for  convenience  sake,  that  an 
EWMP is prepared for a single EWF. Table 4-1 gives a comprehensive overview over 
the elements that would need to be presented in an EWMP. However, depending on the 
risk  originating  in  the  EWF  or  the  EW  therein,  certain  details  may  be  omitted  in  line 
with the requirements of the EWD. 

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Table 4-1 Scope of an Extractive Waste Management Plan 

Issues covered in the EWMPs 

Examples of parameters910 

Name of the company 

Site location (coordinates) 

Site manager 

Administrative information 

Officer responsible for extractive waste area 

Contact details 

Emergency contact details 

Date 

Geological  description  of  the  mineral 
deposit 

Rock  type  and  mineralogy  description  of  the  mineral 
resource to be used 

Size and geometry of the mineral deposit 

Description  of  materials 
(supported by flow-diagrams) 

streams 

List  of  each  type  of  material,  including  quantities  and 
destination 

Excavation 

Crushing and grinding 

Waste  produced 
processes 

from 

individual 

Flotation,  magnetic  separation  or  other  separation 
processes 

Exploration works  

Other processes  

Rock type  

Mineral assembly 

chemical 

Bulk 
least) 
components of potential concern, such as As, Cd, Co, Cr, 
Cu, Hg, Mo, Ni, Pb, V and Zn 

composition 

including 

(at 

Mineralogical  and  geochemical 
per 
characterisation 
material/waste 

Acid generation potential and neutralization potential 

Presence of (fibrous) minerals of concern (e.g. asbestos) 

Potential chemical processing residues 

Waste(s)  code  according  to  Decision  2014/955  (Waste 
Catalogue) 

  Assessment  whether  the  EW  is  inert  is  based  on  the 
technical  requirements  that  are  presented  in  the 
Decision 2009/359/EC  

  Assessment whether the EW is inert, based on method 
EN  15875:  Sulfide  sulfur  content  %  (<0,1%  or  <1% 
and NTP (normal, temperature, pressure) > 3 

9 Relevant information may also be addressed in the related Environmental Impact Assessment (EIA) as 
well as under specific legislation at EU or MS level (see e.g. Annex IV of EIA Directive, Annex V of the 
WFD or EQSD).  
10 INSPIRE Directive Data Specification for the spatial data theme "Geology", "Mineral resources" can 
be used as reference (see https://inspire.ec.europa.eu/Themes/Data-Specifications/2892) 

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Issues covered in the EWMPs 

Examples of parameters910 

Properties 
Hazardous 
1357/2014/EC  -  properties  of  waste 
hazardous 

according 

to  Regulation 
it 
that  render 

Solubility of metals, oxyanions and salts  

Grain size distribution 

characterisation 

and 
Geotechnical 
material  geotechnical  behaviour  per 
material/EW 

(dominant 

mineralogical 

Density  

Porosity  

Permeability  

Fraction 
composition) 

composition 

Water content  

Plasticity indices 

Degree of compaction  

Shear strength  

Friction angle 

Compactability  

Compressive strength  

Waste  class  according 
to  COM 
Decisions  2009/359/EC,  2009/360/EC 
and 2014/955/EU  

Hazardous  waste  /  Non-hazardous  non-inert  waste  /  Inert 
waste 

Category of EWF  

Category A / Non-Category A (Decision 2009/337/EC) 

Facility  structures  (all  EWFs  on  the 
site) 

Design and constructional details of the EWF 

Management of excavated material 

depending 

Note: though not explicitly  covered by 
the 
the  EWD, 
operational  and  market  conditions, 
some  of  these  wastes  can  become  EW 
at any given moment 

on 

(per  waste, 
Management  of  EW 
supported  by  detailed  maps  of  the 
deposition areas) 

Excavated materials (quantities as function of time) 

Quantities  and  types  of  excavated  materials  used  for 
construction  purposes  in  the  mine/quarry  (as  function  of 
time) 

Quantities  and  types  of  excavated  materials  used  for 
filling  mine  voids  for  engineering  or  resource  recovery 
reasons (as function of time) 

Top-soils removed and stored (as function of time) 

Quantities  of  non-EW  and  their  management  routes  (as 
function of time) 

Quantity of EW deposited (as function of time)  

Planned quantity to be deposited EW (as function of time) 

Total  quantity  of  extractive  waste  to  be  deposited  during 
the life-cycle  

Quantities of EW recovered and re-utilised (as function of 
time) 

Summary  of  risk  assessment  carried  out  under  the  initial 
EIA, any updates, or specifically for the EWMP 

Risk assessment 

Specific conditions contributing to risks: 

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frequencies)  as  drivers 

for 

  Climatic  conditions  (e.g.  rainfall 

intensities  and 
the  migration  of 

 
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Issues covered in the EWMPs 

Examples of parameters910 

contaminants 

  Description  of  possible  natural 

(e.g. 
earthquakes,  volcanism,  etc.)  that  may  compromise 
the EWF 

events 

Emergency  plans  (detailing  actions 
and responsible persons) 

Operational monitoring 

Risk elimination or risk reduction measure 

Emergency plans for Category A EWFs 

Emergency plans for other EWFs 

Geotechnical stability (dams, slopes) 

Groundwater: levels, quality 

Surface waters: quantity, quality 

Air quality 

Erosion control (turbidity in surface waters) 

Radiological monitoring (where required) 

Criteria for when closure is achieved 

Closure plans 

Long-term management plans 

Supporting documentation 

Provisional plans (to be updated periodically together with 
the EWMP) 

Financial provisions to ensure orderly closure of EWFs 

Preliminary  plans  for  the  after  use  of  the  extraction  site 
and  the  EWFs  (to  be  updated  periodically  together  with 
the EWMP) 

1. Geology: nature, shape, size and typology of the resource  

2. Mineral deposit area: type, final shape, structure of filling and transport type  

3. Study of the state of soil and water at deposit area (baseline study)  

4. Information of environmental impacts caused by extracted waste and deposit area  

5. Information of preventive actions taken to minimize environmental impacts  

6. Report of current and post-action control and follow-up  

7. Acid rock drainage and metal leaching assessment report 

8. Closure plan 

Note:  the  majority  of  the  above  documentation  would  have  been  already  produced  as  part  of  the 
baseline survey and the EIA licensing procedure.  

The above list looks at the life-cycle of an EWF from a more technical side. As will be 
discussed in the following chapter, the closure of a mine and its associated EWF(s) will 
have  wider  ramifications  that  may  need  to  be  taken  into  consideration.  This  is 
particularly  important  also  with  a  view  to  ensuring  the  long-term  integrity  through 
building a lasting relationship between the communities hosting mining and the EWFs 
that  will  remain  a  feature  of  the  landscape  for  ever.  Therefore,  the  closure  and 
rehabilitation aspect in the EWMP should also consider the following aspects: 

o  Regional state of the environment at closure 
o  Mine site baseline environment 
o  Closure objectives with respect to the environmental conditions 
o  Socio-economic context 

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o  Post closure vision for the site 
o  Final-land  use  and  processes  for  agreement  with  stakeholders  and  competent 

authorities 

o  Summary of residual environmental risks/impacts 
o  Information gaps and required studies to achieve an accepted closure plan 

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4.3 Proposed practices for closure, site rehabilitation, and long-term safety 

4.3.1 Mine closure 
Mine  closure  encompasses  all  activities  that  ensures  a  safe  transition  from  an 
operational mine with operational EWFs towards an end-state that renders all deposited 
extractive  wastes  safe.  It  also  covers  the  decommissioning  and  rehabilitation  of  the 
actual  mining  (and  milling)  facilities.  While  the  latter  are  not  subject  of  the  EWD  as 
such, facility decommissioning and site rehabilitation ideally are co-ordinated activities, 
so that rehabilitation can utilise the existing mine and mill infrastructure (e.g. Falck & 
Fernandes,  2009;  Falck  et  al.,  2009).  Final  closure  of  a  mine  and  mill  involves  the 
decommissioning  of  surface  and  subsurface  facilities.  Both  activities  will  give  rise  to 
wastes, including EWs that will need to be managed in an EWF. This aspect needs to be 
considered in the EWMP and provisions being made for the disposal of these wastes. 

Figure 4-6: Anglo-American Tool-Box for mine closure (2016) 

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While  decommissioning  and  rehabilitation  wastes  are  not  covered  by  the  EWD,  they 
may  actually  be  used  in  the  construction  or  rehabilitation  of  EWFs.  It  would  of 
advantage during mine closure to re-use on site as much of those materials that cannot 
be  marketed,  but  do  not  require  management  as  other  (e.g.  hazardous)  waste.  When 
deciding on the use of materials, one has to take into consideration the monetary and the 
environmental cost of bringing in new materials from the outside. Although it might be 
possible to market certain materials, it may be at the bottom line more environmentally 
and economically efficient to use these materials during closure and rehabilitation. 

Mine  closure  and  rehabilitation  have  been  the  focus  of  considerable  attention  and  a 
number of guidance documents have been developed across the world. For instance, the 
Anglo-American  Tool-Box  for  mine  closure  (Anglo-American,  2016)  provides  a 
comprehensive  spread-sheet  that  guides  mine  operators  through  the  closure  planning 
that ideally begins at the design phase (Figure 4-6) and covers the whole life-cycle of a 
mine.  The  spread-sheet  guides  the  operators  through  the  process  and  allows  them  to 
objectively assess their readiness levels and indicates the way for improvement. 

Although  closure  may  be  years  or  even  decades  away,  Article  5  3(f)  of  the  EWD 
requires closure plans to be part of the EWMPs. However, the EWD does not give any 
requirements on the scope and level of detail of such closure plans within the EWMP. 
The closure of mines and EWFs are separate and distinct steps in their life-cycle and the 
associated  licensing  procedures.  Therefore,  usually  comprehensive  closure  plans  are 
produced  as  separate  documents.  These  would  not  only  cover  the  technical  and 
environmental impact prevention aspects, but also the future site use that is compatible 
with  the  chosen  technical  solution,  e.g.  the  grading  and  capping  of  EWFs.  Future  site 
use is best developed in a deliberative procedure with the stakeholders concerned. As a 
matter of fact, this after-use can become an important element of the overall acceptance 
of  mineral  extraction  and,  therefore,  should  be  an  important  element  of  the  life-cycle 
management of extractive operations (see Figure 4-2). 

The EWD (2006) stipulates that financial  arrangements are being made to  have funds 
for  closure  and  rehabilitation  of  an  EWF  available.  This  financial  management  plan 
must  also  contain  provisions  for  early  and  unexpected  closure  or  temporary  ‚care  and 
maintenance’  status,  which  may  arise  due  to  market  conditions.  Actual  arrangements 
will depend on the Member States’ legislation for mine licensing. A companion report 
to this report under development is expected to address this issue in more detail. 

Following the design criteria discussed in the previous section will facilitate the closure 
of  the  mine  and  the  associated  EWFs.  The  step  from  operation  to  closure  and  post-
operation  will  be  less  steep,  requiring  less  work,  compared  to  a  situation  when 
everything is only designed with operational aspects in mind. 

4.3.2  Site rehabilitation 
Timing.  As  indicated  before,  closure,  decommissioning  and  rehabilitation  are  actions 
that  are  best  developed  concurrently  and  that  may  not  be  clearly  distinguishable  from 
each  other  in  practice.  Rehabilitation  is  concerned  with  the  removal  of  contamination 
that may pose a hazard to the environment or human health, with rendering structures 
geotechnically  safe,  and  in  a  wider  sense  also  concerns  the  rebuilding  of  the 

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(environmental, societal, economic) functions of areas that are not needed anymore by 
the  operations.  Thus,  rehabilitation  is  concerned  with  rendering  EWFs  stable  over  the 
long-term.  

It needs to be understood that return to original conditions at a site affected by mining 
and milling activities is not always possible. It only will be possible to partially rebuild 
pre-mining  features  and  functions.  In  most  cases  the  EWFs  will  form  a  permanent 
legacy and new features in the landscape. 

The objectives of site rehabilitation are largely determined by the envisaged after-use of 
the  former  mining  and  milling  site,  including  their  EWFs.  This  after-use  needs  to  be 
determined  in  collaboration  with  the  host-community.  Concepts  for  re-use  need  to 
satisfy a variety of technical and other requirements: the need to ensure the integrity of 
an EWF, regulatory requirements (environmental protection, Natura 2000 compatibility, 
land-use  planning,  etc.),  as  well  as  the  economic,  environmental,  social  and  aesthetic 
needs  of  the  host-communities.  Typically,  the  site  re-use  has  to  be  integrated  into 
regional  land-use  and  development  plans.  This  requires  a  multi-stakeholder  dialogue 
that  commences  at  the  planning  stage  of  a  mine.  This  dialogue  must  be  maintained 
throughout  the  life-time  of  a  mine  in  order  to  reflect  the  development  of  the  mine, 
which may operate for several decades, and the changing public stakeholders and their 
changing  needs.  A  deliberative  approach  to  defining  site  re-use  ensures  that  use 
restrictions that have to be imposed for technical reasons are accepted and adhered to. A 
deliberative  approach  helps  stakeholders  to  better  understand  the  technical  and  safety 
motivations for such restrictions. 

Rehabilitation  is  inter  alia  concerned  with  rendering  safe  any  environmental 
contamination  that  has  arisen  from  the  extractive  activities.  Contaminants  can  be 
constituents of the mined geological materials, such as heavy metals or arsenic, but also 
derive from materials used during the operation, particularly also processing chemicals. 
While  it  would  have  been  advisable  to  deal  with  spills  etc.  as  soon  as  they  have 
occurred, this may have not been done at the time. 

There are various strategies for dealing with contamination, as is outlined in Figure 4-7. 

Figure 4-7  The principal strategies for dealing with contamination (WEF). 
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Depending on the strategy and technology chosen, rehabilitation wastes will arise that 
usually  are  deposited  in  the  EWFs.  These  wastes  will  have  to  be  assessed  in  order  to 
decide on the subsequent management route and for any valuable constituents that may 
be  recovered  and  marketed.  In  some  instances  the  sale  of  such  constituents  can  cover 
some of the rehabilitation costs. Rehabilitation may involve the reworking of materials 
in  EWFs  in  order  to  recover  marketable  materials  and  to  render  the  EWF  safer.  This 
may  give  the  opportunity  to  segregate  materials  (see  below)  for  more  efficient 
management. 

In  any  case,  the  materials  will  need  to  be  carefully  segregated  into  the  different 
categories  of  EWs  in  order  to  minimise  the  arisings  of  Category  A  waste,  if  at  all 
possible.  The  EWMP  should  forecast  the  likely  arisings  of  the  different  categories  of 
rehabilitation  wastes  and  indicate  adequate  management  routes.  Where  only  small 
amounts of organic or hazardous wastes arise, such as some soil contaminated by a spill 
of machinery oils, it will be of advantage to find an off-site management route, rather 
than to build a Category A facility on-site. 

Acid  mines  or  rock  drainage  are  common  problems  and  rehabilitation  may  also  be 
concerned  with  the  groundwaters  adjacent  to  the  mines.  While  such  activities  are  not 
covered  by  the  EWD,  groundwater  treatment  may  result  in  sludges  that  usually  are 
managed together with EWs from the operation or rehabilitation. The time-profile of the 
various  mine-closure  operations,  such  as  sealing  of  tunnels,  flooding,  etc.,  will 
determine  the  time-profile  of  the  groundwater  treatment  waste  arisings.  Volumes  and 
time-profiles with which they arise need to be integrated into the EWMPs. 

4.3.3 Enhancing the long-term stability of EWFs 
The  EWD  implicitly  refers  to  the  long-term  stability  of  the  wastes  to  be  deposited  by 
distinguishing  between  ‚inert’  and  ‚non-inert’  wastes.  Waste  classified  as  ‚inert’  by 
definition means that it does not undergo (significant) changes after deposition, in other 
words that little potential energy is stored in them. In consequence, inert wastes do not 
require significant measures to isolate them from the surrounding environment. To the 
contrary,  non-inert  wastes  need  to  be  isolated  from  their  surroundings  by  engineering 
measures.  The  level  to  which  this  needs  to  be  done  depends  on  the  degree  of 
hazardousness and the projected time evolution of the associated risk. MSs may waive 
certain requirements, when the absence of risk can be demonstrated. 

These EWFs themselves, i.e. any retaining structures, cappings or liners, will be subject 
to change, alterations or degradation, such as erosion.  In the following  paragraphs the 
processes and forces that will alter EWFs over time and may compromise their function 
are discussed together with strategies to counteract and delay these alterations. 

Physical and chemical potentials - Based on thermodynamic considerations  (2nd Law 
of Thermodynamics), one notes that engineering  structures are inherently  instable and 
require the input of energy in order to remain in their desired state. Translated into more 
practical terms  this  means that engineered structures and other  features  of a mine and 
the  associated  EWF  require  constant  maintenance  in  order  to  retain  their  shape  and 
function. While engineered structures may be stable over a human time-scale, this is not 
likely to remain so over the extended time-scales we expect EWFs to function. Due to 

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natural  weathering and related processes man-made slopes, dams,  and similar features 
or  retaining  structures  will  slowly  erode  and  collapse.  This  is  generally  due  to  high 
relief  energy  or  chemical  potentials  stored  in  them  and  that  have  the  tendency  to 
dissipate according to the 2nd Law of Thermodynamics. Closure, site rehabilitation and 
preparations  for  long-term  safety  have  to,  therefore,  aim  to  minimise  these  potentials 
with respect to the surrounding environment. In this sense, the classification of a waste 
as ‚inert’ means that it contains little physical or chemical potential with respect to the 
surrounding  environment,  or  that  the  activation  energy  would  be  too  high  for  any 
reactions leading to change. 

Resistance vs. resilience - Many engineering features are designed for ‚resistance’, i.e. 
resisting change due to external forces. As was noted above, this only works, when such 
facilities are actively maintained. However, such maintenance cannot be expected over 
time-scales  that  exceed  hundreds  of  years.  Thus,  facilities  have  to  be  designed  as 
maintenance-free as possible. The key criterion here is to reduce unnecessary potential 
energy  stored  in  them.  The  guiding  principle  ideally  is  ‚engineering  with  nature,  not 
against  it’.  A  ‚good  practice’  approach  would  review  a  given  situation  in  this  respect 
and try to minimise these effects. 

Design for closure  – The EWD stipulates that the eventual closure of EWF has to  be 
kept in mind and that adequate provisions for this have to be made. In order to minimise 
such  closure  efforts,  it  is  advisable,  within  operational  constraints,  to  design  mine 
operations and EWFs  with  the closure measures  in  mind. This  applies in particular  to 
tailings management facilities that are unlikely to be relocated or otherwise redesigned. 
While  some  EWFs  eventually  may  be  re-mined  to  recover  additional  commodities  of 
value,  they  are  best  conceived,  designed,  constructed,  operated,  and  closed  on  the 
assumption that they will become permanent facilities to ensure an optimum long-term 
safety and to not leave unresolved problems to future generations in case of premature 
closure  of  the  operations.  Tailings  facilities,  designed  for  closure,  are  true  future 
engineered landforms, intended to remain physically and chemically stable for the long-
term. The same concept applies to other types of residue management, such as dumps. 

Landscaping  -  Features  and  shapes  of  mines  and  EWFs  are  typically  designed  with 
operational  convenience  in  mind.  This  means  that,  for  instance,  quarry  faces  are 
designed as steep as the material properties and the geology permits, or that the slopes 
of  residue  dumps  are  made  as  steep  as  possible  to  reduce  the  footprint  of  the  dump. 
While such designs might find favour with regulators and other stakeholders alike due 
to the apparently small impacted area, they will not be stable without maintenance. At 
the moment of closure, such slopes will need to be re-graded to a near natural angle in 
order  to  ensure  long-term  stability  (see  Best  Practice  Example  B).  It  is,  therefore, 
adamant  that  the  EWMP  foresees  such  adjustments.  In  order  to  minimise  the  relief 
energy  with  respect  to  the  surroundings  the  engineered  landforms  of  EWFs  should 
mimic the surrounding topography.  

Figure 4-8 below gives examples for how the potential energy in waste dumps can be 
minimised.  It  is  obvious  that  placing  waste  underground  or  into  geomorphological 
depressions would increase the long-term stability of such facilities. However, one was 
to consider the overall relief energy in the surrounding environment. Steep slopes and 

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high surface run-off may compromise the long-term safety of a dump even though it has 
been  put  below  the  average  surface  elevation  of  the  surrounding  landscape.It  is 
important to understand the function and evolution of the surrounding landscape and to 
integrate  the  man-made  features  into  them.  Modern  surveying  (e.g.  air-borne 
photogrammetry,  LIDAR)  and  modelling  techniques  allow  to  develop  a  detailed 
geomorphological analysis of the surrounding landscape. This in turn allows to analyse 
the  surface  drainage  patterns.  These  analyses  then  form  the  basis  for  developing  a 
model of a most stable contour of the waste heaps, including the small-scale drainage 
patterns that mimic the adjacent landscape. Together with the re-vegetation this would 
lead to a stable, erosion-resistant geomorphology of the constructed EWF. 

Figure 4-8 Strategies to reduce the potential (or relief) energy stored in waste dumps (WEF). 

Capping  and  vector  reduction  -  The  concept  of  ‚engineering  with  nature’  must  be 
extended  also  to  the  cover  design  for  waste  management  facilities.  The  profile  must 
mimic  the  local  soil  profile  in  order  to  have  comparable  infiltration  and  run-off 
properties, which will counteract the erosive forces of surface precipitation. Figure 4-9 
shows examples for arid and semi-arid areas in the USA, but analogue profiles can be 
drawn  for  local  soils  in  Europe.  One  should  note  that  in  all  cases  there  will  be  a 
drainage layer above the waste in order to divert infiltrating water away from the waste. 
Under natural conditions this water would eventually reach the groundwater table. 

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As even inert wastes can impact the environment, for instance as wind-blown dust or as 
turbidity  in  surface  waters  after  being  eroded  from  their  impoundments,  they  will 
require some form of capping to reduce the vectors wind and water. 

Figure 4-9 Three examples for cover construction over tailings from the USA (Source: WEF). 

Re-vegetation  –  These  efforts  will  be  more  successful,  if  modelled  after  the  natural 
vegetation of the surrounding landscape. It is understood, however, that in Europe most 
landscapes  have  been  significantly  altered  by  human  activities,  in  particular  turning 
forests  into  agricultural  land.  Nevertheless,  one  can  strive  to  establish  a  biodiversity 
appropriate  for  the  prevailing  soil  and  climatic  conditions.  While  reforestation  with 
local  tree  species  is  a  viable  strategy  for  EWFs  containing  inert  wastes,  this  is 
problematic  for  other  wastes  due  to  deep  roots  that  can  penetrate  cappings  and  liners 
and in this way compromise the isolation of these wastes. 

Cost profiles - It is important to ensure that short-term financial or operational priorities 
do not prevail over better design and operational practices that would have lower long-
term impacts, complexity or risks. It has to be repeated that designing and operating for 
closure has to be a systemic approach, and takes all aspects of the extractive operation 
into account, not just, say, a tailings facility itself. For example, design and operational 
decisions  related  to  mining  and  ore  processing  can  impact  both  the  quantity,  and 
physical and chemical characteristics of tailings and associated drainage water, and can 
have  long-term  implications  for  the  management  of  tailings:  management  of  tailings 
begins upstream in the operation – in the mine planning and in the ore processing plant 
(MAC, 2017). 

4.3.4 Securing the long-term stability of extractive wastes 
Excavating  geological  materials  and  emplacing  them  into  an  EWF  will  disturb  the 
natural  secular  geochemical  equilibria  with  respect  to  their  surrounding  environment. 
The  EWD  (2006)  distinguishes  EWs  that  react  (very)  slowly  upon  such  disturbances, 
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i.e. they are inert, from those that react faster, i.e. those that are not inert. Certain wastes 
would be inherently inert,  for instance because certain  minerals  contained in  them  are 
not  stable  under  atmospheric  conditions,  others  have  become  inert  as  a  result  of  the 
milling  processes.  Hence,  the  upstream  processes  in  mining  and  (ore)  processing  can 
have  a  significant  effect  on  the  manageability  of  the  resulting  wastes.  As  part  of  an 
overall life-cycle materials  management, it may  be, therefore, beneficial to  investigate 
whether and how processes can be changed so that the resulting wastes become (more) 
inert.  The  exact  strategies  will  have  to  be  defined  on  a  case  by  case  basis,  but  some 
principal strategies can be considered. Likewise, it will be important to understand the 
natural processes that control the evolution of EWs once deposited. 

Diagenetic  evolution  -  An  understanding  of  the  natural  processes  of  weathering  and 
diagenesis  for  the  given  landscape  help  to  predict  the  geochemical  and  mineralogical 
evolution  of  the  disposed  wastes  over  long  time-scales.  This  in  turn  will  help  to 
understand  e.g.  the  potential  for  the  generation  of  acid  rock  drainage  and  to  design 
measures  to  combat  it  within  the  EWF,  rather  than  to  collect  and  treat  it.  A  possible 
strategy is to mix or interlayer EWs with acid generation potential with EWs that have 
an acidity or redox buffering capacity (source reduction). Secondary mineral formation 
will  clog  existing  pore-spaces  (forming  an  ‘engineered’  hard-pan)  and  in  this  way 
reduce  the  action  of  the  vector  porewater  (pathway  reduction).  As  the  necessary 
assessments  and  predictive  modelling  are  complex  undertakings,  they  would  only  be 
warranted (and affordable) for larger scale EWFs.  

Segregation  –  It  is  often  only  one  component  in  the  waste  that  give  rise  to  it  being 
classified as ‘non-inert’. Removing this component can lead to a considerable reduction 
of  the  volumes  of  waste  that  need  to  be  managed  as  ‘inert  waste’  and  frees  the 
remainder  for  potential  beneficial  use  or  for  simplified  disposal  options.  All  steps  in 
mineral  processing  may  need  to  be  reviewed  in  order  to  decide  on  where  segregation 
would be applied best. It may be that an early segregation step, e.g. froth floatation, not 
only  is  beneficial  for  later  waste  management,  but  reduces  the  quantities  of  raw 
materials that need to be processed for the target mineral. Hence, beneficiation and pre-
concentration steps are ideally designed keeping later disposal requirements in mind. A 
good EWMP would reflect such integrated process design. 

Segregation  of  different  types  of  overburden  so  that  it  can  be  placed  back  into  the 
mined-out  voids  ensures  the  compatibility  and  reduces  the  creation  of  geochemical 
anomalies (potentials). In this way it can also be ensured that sulfide-bearing materials, 
where it is possible, are below the water table, in order to reduce their acid-generation 
potential  after  the  closure  of  the  mine.  This  is  now  common  practice  in  e.g.  lignite 
mining  (see  Best  Practice  Example  D).  While  this  reduces  the  access  of  oxygen  from 
the  ambient  air,  the  main  driver  for  the  generation  of  ARD,  it  cannot  completely 
preclude  the  possibility  of  sulfides  being  oxidised.  A  hydraulic  flow-model  or  a 
combined flow-reaction model may have to demonstrate that oxydation rates are slow, 
leading to negligible generation of ARD. 

Removal  of  process  chemicals  –  Wastes  otherwise  ‘inert’  become  ‘non-inert’  when 
they  contain  residues  of  process  chemicals  that  are  hazardous  and/or  reactive  above 
certain threshold concentration. A good example is the cyanide used in gold extraction 
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that can be recovered for further use or destroyed by oxygenation and exposure to UV-
light  before  tailings  are  impounded.  Neutralising  acidic  or  alkaline  wastes  is  another 
example  but  will  typically  increase  the  volume  of  the  residual  waste  due  to  the 
precipitates forming. The long-term stability of the neutralisation products in the view 
of changing conditions in the impoundment or the possible influx of acid rock drainage 
also needs to be considered. With a view to resources and energy conservation, recovery 
normally would be given preference over destruction or neutralisation.  

Acceleration of alteration processes – A number of minerals, notably sulfidic ones, are 
unstable  under  atmospheric  conditions.  The  presence  of  such  minerals  can  lead  to  the 
prolonged emission of reaction products, for instance acid rock drainage. If such wastes 
have to be deposited in near-surface impoundments, it may be worthwhile to investigate 
the  artificial  acceleration  of  these  processes  before  disposal.  Sulfidic  material  can  be 
‚roasted’, i.e. the sulfides are thermally oxidised, or the sulfides can be leached on heap-
leach  pads.  Roasting,  on  the  other  hand,  will  lead  to  gaseous  reaction  products  (SOx) 
that need to be captured and managed (see below). As such processes are likely to be 
endothermic,  one  needs 
life-cycle  energy 
requirements  and  associated  CO2-footprints  and  balance  these  against  the  risks  from 
other management options.  

to  carefully  assess 

their  additional 

Acid rock drainage formation and leaching processes can also be enhanced in situ, after 
deposition, if the area of disposal is sealed against infiltration of leachates into deeper 
strata,  either  naturally  or  by  an  engineered  barrier  (see  Best  Practice  Example  F). 
Contaminated leachates have to be collected and treated. The process is similar to heap-
leaching used in the recovery of metals from low-grade ores. 

Extraction of ‚problematic’ components as by-products – Some waste components that 
can  result  in  extractive  waste  to  be  destined  for  a  Class  A  facility  can  actually  be 
extracted as by-product, e.g. sulfur from sulfidic minerals. This means that the sulfidic 
sulfur  is  converted  into  a  marketable  form,  rather  being  deposited  as  sulfate.  The 
energetics  and  market  conditions  have  to  be  investigated  carefully  in  order  to  assess, 
whether such approach would be economically viable for the given circumstances. 

tailings  are  pumped 

Accelerated  dewatering  of 
into 
tailings  -  Traditionally, 
topographical  depressions or constructed ponds.  Some of the  water will  exfiltrate into 
the underlying geological strata, if these ponds are not lined. During the settling process 
excess water accumulates on the pond surface and either evaporates (in arid conditions) 
or must be drained away. The collected drainage water is pumped back into the plant for 
residual  metal  and  process  chemicals  recovery.  Drainage  ditches  can  be  dug  into  the 
surface of the ponds to accelerate drainage, but amphibious machines are needed due to 
the  thixotropic  behaviour  of  the  muds.  Wick  drainages  may  also  be  inserted  and 
connected to surface drainage mats that allow earlier capping of tailings. In the process 
of  ‘wet  stacking’  partially  dewatered  (ca.  30%  solids)  muds  are  discharged  into  the 
ponds.  This  denser  mud  will  not  re-suspend  by  atmospheric  precipitation  and  rainfall 
run-off can be collected from the surface. ‘Dry stacking’ can be achieved by mechanical 
dewatering  up  to  77%  solids  (IAI,  2015;  recommended  by  the  MWMI  BREF,  2006), 
but  requires  transportation  to  the  disposal  site  by  conveyor  belt,  rather  than  pumping. 
Dry stacked tailings constitute a lesser risk in case of dam failures, as they will not flow 
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out.  Dewatering  allows  earlier  closure  and  capping  of  tailings  ponds.  However, 
accelerated dewatering and solidification entail materials (e.g. flocculants, neutralising 
agents)  and  energy  expenditures  that  will  reduce  the  overall  energy  efficiency  of  the 
metal production. 

4.3.5 Long-term management and stewardship 
Extractive  waste  management  facilities,  such  as  waste  heaps  and  tailings  ponds,  will 
remain features in the landscape for ever. As noted earlier, their design should be such 
that maintenance needs are minimised as far as possible, mimicking the geomorphology 
and vegetation of the surrounding landscape. 

There  may  be  an  interest  in  using  waste  heaps  for  other  purposes  than  just  bush-  or 
woodland.  These  uses  have  to  be  compatible  with  the  integrity  of  the  covers,  which 
means  that  certain  restrictions  have  to  put  into  place,  for  instance,  via  zoning 
regulations.  For  instance,  excavations  for  building  foundations  may  not  permitted  or 
restricted  to  a  certain  depth.  These  restrictions  have  to  be  considered  in  the  land-use 
planning  and  a  regulatory  instruments  to  be  put  into  place  to  enforce  the  restrictions. 
Finding a beneficial and compatible after-use of such EWFs is likely to foster the long-
term maintenance of retaining structures and covers (e.g. IAEA, 2006). Ideally, such use 
is  found  already  during  the  closure  phase  or  even  before,  so  that  closure  and 
rehabilitation  options  can  be  tailored  to  this  use  and  vice  versa.  Such  plans  can  be 
foreseen  in  the  EWMP  as  strategic  outlook,  though  a  specific  after-use  may  not  be 
foreseeable, particularly  for mining operations that continue for decades. Nevertheless 
an after-use would be an element in a life-cycle planning that keeps also the sustainable 
development of a region in mind. The provisions in the EWMP may need to be flexible 
with  respect  to  landscaping  and  cover  design  in  order  to  be  able  to  accommodate 
different types of after-uses. 

Long-term  management  and  stewardship  will  also  have  to  make  provisions  for  the 
monitoring of EWFs with respect to their integrity and functionality. The problem here 
is to identify an organisation that can be charged with this task. If there is a beneficial 
after-use, the new owners of the site may be charged with this, as it is likely to be also 
in their interest.  

Integration of the rehabilitation planning into the long-term regional planning is likely 
to reduce impacts  as well as fostering the a compatible after-use of the sites of EWFs 
(see Example Best Practice E). 

4.3.6 Record keeping and maintenance. 
Closure,  decommissioning  and  rehabilitation  will  produce  records  in  addition  to  those 
generated during the exploratory and operational phases. Having such records available 
will facilitate each subsequent step in the life-cycle of a mining and milling facility, as it 
avoids or reduces costly and time-consuming site assessment procedures. Records will 
also facilitate maintenance and repair during long-term management. 

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There are no clear guidelines on how and where such records should be kept beyond the 
active life of an extractive facility. The situation is exacerbated by the fact that in some 
Member  States  the  regulatory  oversight  over  closed  sites  passes  to  another  regulatory 
body from  the one that regulates active mines.  If a site is released freely, with  no use 
restrictions and maintenance requirements, there may be no legal mechanism to retain 
any records, as no further legal requirements are attached to the land. In some Member 
States  such  records  would  be  collected  by  the  competent  authorities  or  the  (national) 
geological surveys. For instance, the British Geological Survey has extensive records on 
past deep mining activities due to a statutory requirement to submit such records. In the 
case of EWFs it is not clear, what kind of records would be available and what kind of 
records  would  be  needed.  Another  place  for  such  records  would  be  land  registers  or 
cadastres, where information on each piece of land is stored. However, the cadastres are 
not  normally  prepared  to  store  such  information.  The  issues  around  preserving 
knowledge  about  sites  and  record  keeping  have  been  extensively  researched  and 
discussed in the context of the long-term management of radioactive waste disposal and 
uranium  mining  and  milling  sites.  A  summary  of  these  discussions  can  be  found  for 
instance in IAEA (2006, p. 77ff.)  

Record keeping is also important with respect to any land-use restrictions that may have 
to be imposed (see discussion above of stewardship issues). Such restrictions may need 
to be reflected in the cadastre. 

Records,  particularly  those  on  how  and  where  specific  extractive  wastes  have  been 
deposited,  may  be  also  of  value,  if  at  later  stage  these  wastes  may  be  considered  for 
reworking.  Thus  record  keeping  about  the  deposition  of  extractive  wastes  will 
contribute  to  the  implementation  of  Circular  Economy  policies.  Thus  good  record-
keeping as part of the EWMP would contribute to the spirit of the Circular Economy. 

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4.4  Proposed practices for special issues to be considered in EWMPs 

4.4.1 Resolving conflicts between policy objectives 
Particularly  designs  to  ensure  the  long-term  safety  of  extractive  wastes  and  circular 
economy  policies  may  give  rise  to  conflicts  of  objectives.  Decisions  to  declare  some 
extracted  materials  as  waste  and  to  proceed  to  disposal  are  made,  when  no  beneficial 
use for the waste can be found, which in turn often depends on the economic context at 
the time. In consequence, such wastes may still contain components that could become 
valuable at some later point in  time. Whether these materials  can be recovered  at  this 
later  point  depends  on  the  chosen  disposal  method.  Near-surface  repositories,  such  as 
waste-rock  dumps  or  tailings  ponds  may  be  relatively  easily  accessed  and  reworked. 
The situation is different for materials placed into deep mines. Emplacing waste into a 
deep mine in general will make these material difficult to retrieve, as re-entering a mine 
after closure is dangerous due to difficult to predict rock-stress situations. Any cements 
added may also result in a matrix that is difficult to break up for further processing. This 
usually means that any remaining resources in the deposited waste become sterilised. 

It is  recognised that  the  (long-term) safety  of  a disposal  option may be compromised, 
when  access  routes  are  provided  to  ensure  retrievability  for  re-use.  Providing  easy 
access  may  compromise  the  functions  of  barriers,  such  as  liners  and  cappings.  In  the 
case of wastes deposited underground, access  routes would also  need to be constantly 
maintained in order to be safe, being in contradiction to the objective of long-term low-
maintenance  or  maintenance-free  solutions.  It  may  be  interesting  to  review  in  this 
context  the conceptual  work undertaken in  the  context  of deep disposal  of radioactive 
waste,  where  the  safety  implications  of  a  retrievability  of  spent  fuel  for  reprocessing 
have been investigated intensively (OECD-NEA, 2001).  

This  dilemma  between  long-term  safe  extractive  waste  management  solutions  and 
maintaining  access  to  potentially  valuable  resources  needs  to  be  carefully  weighed, 
when drawing up EWMPs. One conclusion could be to destine for disposal back in an 
underground  mine  only  those  materials  for  which  conceivably  also  in  the  future  no 
beneficial  use  can  be  found.  This  means  to  base  the  decision  not  only  on  the  current 
economic  situation.  Further  guidance  on  cut-off  criteria  for  accepting  materials  for 
returning into deep mines may need to be developed. 

Conversely, material backfilled into open-cast mines, or material in near-surface EWFs 
remains more accessible to  reworking, as recent  interest  in  re-working old  dumps and 
tailings show. In these instances the material becomes less likely permanently sterilised. 

Stabilising  materials  for  disposal,  as  discussed  above,  entails  additional  energy 
expenditure  and  additional,  often  virgin,  materials.  One  has  to  carefully  balance 
probabilistic  and  delayed  safety  gains  and  geotechnical/environmental  risk  reduction 
against actual and deterministic impacts from these measures to increase safety. 

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4.4.2 NORM-issues in the extractive industries 
While radiological issues and radiation protection aspects are not subject of the EWD, 
the  presence  of  Naturally-Occurring  Radioactive  Materials  (NORM)  may  need  to  be 
considered in the EWMPs so that appropriate management routes and end-points can be 
defined.  The  difficulty  is  that  many  operators  are  not  be  aware  of  any  radiological 
issues, as their operation is not a ‚practice’ in the radiation protection sense. 

Radiation  protection is  covered by Directive 2013/59/EURATOM (European Council, 
2014), also known as the EU Basic Safety Standards for Radiation Protection (BSS).  

NORMs  are present  in  many  geological  materials  and can become relevant  in  various 
raw  materials-based  activities.  With  the  exception  of  e.g.  uranium,  thorium  or  radium 
ores,  concentrations  are  usually  low  and  of  no  concern.  However,  the  processing  of 
NORM-containing  geological  materials  can  lead  to  their  concentration  in  products, 
intermediates,  by-products  or  wastes.  A  comprehensive  overview  over  the  extractive 
industries, where  NORM-issues may  arise is  given in  IAEA  (2003). The  International 
Atomic Energy Agency  (IAEA) subsequently also published a range of documents on 
NORMs  in  specific extractive industries.  In the  European context,  the BSS (European 
Council,  2014)  lists  in  its  Annex  VII  those  industries  that  potentially  have  to  face 
NORM-issues (Table 4-2). 

Table  4-2  List  of  industrial  sectors  involving  naturally-occurring  radioactive  material 
(European Council, 2014 – Annex VI). 

  Extraction  of 

rare 

earths 

from 

  Production  of  Th  compounds  and 

monazite 

of Th-containing products 

  Processing of niobium/tantalum ore 

  TiO2 pigment production 

  Oil and gas production 

  Geothermal energy production 

  Thermal phosphorus production 

  Production of phosphate fertilisers 

  Zircon and zirconium industry 

  Phosphoric acid production, 

  Cement  production,  maintenance  of 

clinker ovens 

  Coal-fired 

power 
maintenance of boilers 

plants, 

  Primary iron production, 

  Tin/lead/copper smelting, 

  Mining of ores other than uranium ore 

  Ground water filtration facilities, 

Annex  XIII  of  the  BSS  (European  Council,  2014)  gives  a  list  of  building  materials, 
some  of  which  are  derived  from  extractive  wastes,  that  may  results  in  radiation 
exposures (Table 4-3).  

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Table 4-3 Indicative list of types of building materials considered with regard to their emitted 
gamma radiation as referred to in Article 75 of European Council (2014). 

1. Natural materials 

(a) Alum-shale. 

(b) Building materials or additives of natural igneous origin, such as: 

  granitoides (such as granite, syenite and orthogneiss), 
  porphyries; 
 
  pozzolana (pozzolanic ash); 
  lava. 

tuff; 

2. Materials incorporating residues from industries processing NORM, such as: 

fly ash; 

 
  phosphogypsum; 
  phosphorus slag; 
 
tin slag; 
  copper slag; 
 
  residues from steel production 

red mud (residue from aluminium production); 

Given  that  the  respective  extractive  industries  may  have  to  face  NORM-issues,  the 
competent national radiation protection agency may need to be consulted in addition to 
the  usual  environmental  protection  agencies  and  competent  authorities,  when  drafting 
EWMPs.  Article  23  of  the  BSS  (European  Council,  2014),  however,  states  that 
“Member States shall ensure the identification of classes or types of practice involving 
naturally–occurring  radioactive  material  and  leading  to  exposure  of  workers  or 
members of the public which cannot be disregarded from a radiation protection point of 
view. Such identification shall be carried out by appropriate means taking into account 
industrial  sectors  listed  in  Annex  VI”.  This  puts  the  onus  of  identifying  potential 
NORM-issues on the MSs’ authorities, rather than on individual operations. 

Box: Definitions according to the BSS, Article 4 (European Council, 2014) 

clearance  levels  means  values  established  by  the  competent  authority  or  in  national  legislation,  and 
expressed  in  terms  of  activity  concentrations,  at  or  below  which  materials  arising  from  any  practice 
subject to notification or authorisation may be released from the requirements of this Directive; 

exemption  level  means  a  value  established  by  a  competent  authority  or  in  legislation  and  expressed  in 
terms  of  activity  concentration  or  total  activity  at  or  below  which  a  radiation  source  is  not  subject  to 
notification or authorisation. 

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The  BSS  (European  Council,  2014)  provides  exemption  and  clearances  levels  for  all 
radionuclides (including natural ones) for solid materials (Table A and B of Annex VII). 
These  are  given  as  activity  concentrations,  i.e.  kBq/kg.  Raw  materials  that  contain 
radionuclides below or at these activity concentrations are of no concern, but products 
intermediates,  by-products  and  residues  may  have  to  be  checked  that  any  processing 
does not lead to enhanced concentrations, i.e. to technologically enhanced NORM (TE-
NORM), which then may require management according to radiation protection criteria. 
IAEA (2003) gives an overview over potential concentrating processes per industry. 

If a potential problem with NORM has been identified, EWMPs will need to be drafted 
such that occupational  doses are minimised and exposure pathways  for critical  groups 
and  the  general  public  be  removed.  Doses  would  have  to  assessed  with  respect  to  the 
references levels stipulated by the BSS (European Council, 2014). 

When  exemption  or  clearance  level  are  exceeded  by  products,  intermediates,  by-
products  or  residues,  management  options  have  to  be  developed  together  with  the 
competent  radiation  protection  authorities.  In  some  cases,  processes  can  be  changed 
such  that  no  concentration  increases  above  exemption  and  clearance  levels  are 
generated.  Article  30  of  the  BSS  (European  Council,  2014)  stipulates  that  „Member 
States shall not permit the deliberate dilution of radioactive materials for the purpose of 
them being released from regulatory control. The mixing of materials that takes place in 
normal  operations  where  radioactivity  is  not  a  consideration  is  not  subject  to  this 
prohibition.  The  Competent  Authority  may  authorise,  in  specific  circumstances,  the 
mixing  of  radioactive  and  non-radioactive  materials  for  the  purposes  of  re-use  or 
recycling.“  It  appears  that  this  provision  would  allow  the  mixing  of  different  by-
products  or  residues  derived  from  raw  materials  with  specific  activity  levels  below 
exemption and clearances levels in order to revert their overall specific activity below 
these  levels,  for  instance  for  the  purpose  of  disposal  or  re-use  within  the  extractive 
operation.  It  would  certainly  be  undesirable  to  have  to  manage  such  by-products  or 
wastes as ‚radioactive waste’. 

Based  on  the  known  concentration  routes  in  certain  industries  and  approximative 
concentration  factors  per  process,  a  simple  screening  of  critical  members  in  the  value 
chain  will  suffice  to  decide,  whether  in  a  given  case  there  may  be  any  NORM  issue 
previously undetected. 

IAEA (2003) and other guidance documents recommend an avoidance strategy in order 
to pre-empt the arising of NORM-containing waste. While certainly a viable strategy, it 
may lead to supply issues when ‘critical’ raw materials are concerned. Such avoidance 
strategy  is  also  applied,  for  instance,  with  respect  to  certain  phosphate  rocks  for 
fertiliser  production  that  contain  high  levels  of  heavy  metals.  In  the  future  adequate 
waste  management  plans  may  need  to  be  developed  or  beneficial  uses  for  the 
constituents in question may need to be found. One such example are REE-ores that can 
be also rich in thorium, which is currently not used. 

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Internalisation of the costs and the funding of long-term EWM 
It  has  to  be  understood  that  the  implementation  of  best  practices  depends  on  a  wide 
variety of factors and boundary conditions. A key criterion for an operator will be the 
cost  profile  of  implementing  the  best  practice,  i.e.  when  which  costs  arise  and  which 
return on investment can be reaped when. A challenge for adopting many best practice 
measures is that benefits may be intangible, indirect, or delayed. Many benefits of long-
term  management  measures  aim  to  protect  future  generations.  Many  benefits,  in  fact, 
will be indirect,  as the  respective best  practice  aims at  risk reduction, which may/will 
result  in  a  reduction  of  mitigation  and/or  rehabilitation  costs,  improved  stakeholder 
acceptance, as well as reduced insurance premiums. It is important that the management 
of extractive operations understands well this indirect nature of benefits and introduces 
them appropriately into their financial and business management. 

Thus, a key aspect in promoting best practices will be that their application results in an 
internalisation  of  costs  associated  with  certain  business  risks.  For  instance,  the 
application  of  paste  technology  for  the  conditioning  and  disposal  of  tailings,  will 
significantly  reduce the  risks associated with  large tailings ponds and thus can reduce 
the premiums for liability insurances. It also reduces the business risk of loosing social 
acceptance to operate following a possible incident at the tailings pond. 

A difficult issue are the long-term monitoring and maintenance cost, following closure 
and  rehabilitation,  that  arise  due  to  stewardship  needs.  It  is  clear  that  they  would  fall 
into the responsibility of operators as long as they continue to exist and as long as the 
operator is the owner of the site. Legislation is not clear and uniform across the EU on 
this point. The problem  is  also  intertwined with  that of the safety of  closed mines for 
which the operator has ceased to exist. 

The  financing  of  such  costs  that  can  continue  into  eternity  will  be  the  subject  of  a 
separate study initiated by the European Commission.  

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4.5 Potential ‘Best Practices’ in the EMWPs reviewed 
A wide range of EWMPs have been collected for this project from Member States, as 
well  as  industry  associations  (see  European  Commission  et  al.,  2019).  These  EWMPs 
have  been  reviewed  with  respect  to  their  coverage  of  the  relevant  requirements 
stipulated in Article 5 and how these requirements will be fulfilled. 

Depending on the understanding and care of those, who drafted the reviewed EWMPs, 
their  scope  and  detail  may  vary  considerably.  However,  not  only  components  may  be 
missing, but some EWMPs actually exceeded the expectations according to Article 5 of 
the EWD. The review took note of such cases and lists them as potential best practices. 
Conversely,  missing  components  were  noted,  particularly,  when  this  was  a  recurrent 
problem.  The  reasons  for  the  respective  omissions  or  inclusions  was  elucidated,  if 
possible.  Only  a  small  number  of  EWMPs  concerning  Category  A  facilities  and  in 
particular  tailings  ponds  were  collected,  though  a  number  of  active  tailings  ponds  are 
known to exist in the European Union. 

In the following a summary of the collected EWMPs is given per country. 

Czech Republic - The Czech competent authorities stated that there is no metal mining 
and lignite mining is in decline. Therefore, there would be no need to develop EWMPs. 
They also noted that the EWD duplicated already existing Czech legislation dating from 
the 1980s that already covered the relevant aspects. 

Cyprus - The EWMP submitted concerns a copper/gold mine. The production of copper 
cathode is based on  a triptych Heap  Leaching  –  Solvent Extraction  –  Electro-winning 
process. There are seven basic steps in the production process at the Skouriotissa plant: 
(1)  crushing,  (2)  addition  of  cement  to  pelletise  the  material,  (3)  adjustion  of  pH  by 
addition  of  lime  water  (this  leads  to  the  precipitation  of  metals  (copper,  iron)  as 
hydroxides  which  will  consume  CN  forming  complexes,  (4)  heap  leaching  with  100-
300  mg  /  l  NaCN  solution  at  high  pH  (pH  10-11),  (5)  adsorption  of  gold  from  the 
pregnant  solution  to  activated  carbon,  (6)  transfer  of  the  gold  and  silver  from  the 
activated carbon into doré containing  gold  and silver (7) cyanide destruction to below 
10  ppm  of  weak  acid  dissociable  cyanide  in  the  tailings  as  stipulated  by  the  EWD. 
According  to  the  EWMP  the  detoxification  methods  employed  are  (a)  treatment  with 
sodium  meta-bisulfite  (Na2S2O5)  for  the  destruction  of  cyanide  (INCO  Method  as 
presented  in  the  MTWR-BREF,  2018),  (b)  neutralisation  with  lime  or  caustic  soda  of 
the resulting sulfuric acid, and (c) further stabilisation by mixing with bentonite.  

The EWMP notes that the location was chosen because: 

  it  is  situated  in  the  immediate  vicinity  of  extraction  by  minimising  the  distance  of 

transport of waste; 

  the area is already disturbed by previous mining activities; 

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  it is in the vicinity of an existing spoil heap, so that this heap can be used as fall-back 

option in an emergency; 

  it is a mined-out void that can filled in that way; 
  it is remote from other activities, except mining. 

The area of waste emplacement is sealed with a double liner of bentonite and HDPE and 
graded  so  that  any  drainage  can  be  collected.  Downstream  of  the  emplacement  area  a 
storm-water overflow retention basin was constructed. 

Overall,  the  use  of  pelletised  ore  on  heap-leach  pads  avoids  the  need  to  manage  fine-
grain liquid tailings and the associated risks of ponds for such tailings. 

The EWMP also comprises emergency and contingency plans. Rehabilitation plans are 
mentioned,  but  not  elaborated  in  detail.  The  sites  will  eventually  be  re-vegetated  to 
provide erosion resistance. 

Finland  -  Eight  EWMPs  were  reviewed,  four  of  these  concerning  metal  mining  and 
four industrial minerals. Two of the EWMPs concern mines that are not yet constructed 
and the EWMPs  were permitting-stage EWMPs. Metal  mining  covered  gold  and base 
metals and industry minerals covered lime, talc and phosphate.  

Characteristic  for  Finnish  EWMPs  –  particularly  for  metal  mines  -  is  the  extensive 
description of the chemical properties of the waste. This includes the descriptions of the 
continuous  extractive  waste  chemical  quality  monitoring  programmes.  While  the 
methodology  for the classification of the EW is rather uniform,  as it is  determined by 
the legislation, but methods for definition of long term behaviour vary to some extent. 
Also the actual scope of EWMPs vary considerably, particularly between metal mines 
and industrial mineral mines. 

The  long-term  stability  and  safety  management  is  primarily  described  in  EWMPs  of 
Category  A  tailings  disposal  facilities.  Dam  safety  risks  are  mainly  covered  by  dam 
break  hazard  analysis  documents,  site  operation  manuals  and  rescue  plans.  In  the 
EWMPs  of  all  four  Finnish  metal  mines  these  documents  are  referred  to  or  even 
appended  to  the  EWMPs.  In  some  cases  their  role  in  safety  management  is  also 
summarised in the EWMPs.  

It  should  be  noted  that  the  absence  of  safety  details  in  an  EWMP  does not  mean  that 
these issues have not addressed. Considering the purpose of an EWMP, describing the 
relationship of EWMP and other related documents seems important. 

France - France currently does not have any metal or energy mineral mining. The only 
mineral raw materials exploited are various industrial minerals and aggregate. The basic 
provisions for EWM are reflected in the ‘Arrêté du 22/09/94 relative aux exploitations 
de carrières et aux installations de premier traitement des matériaux de carrières’, which 
has  been  amended  at  various  occasions  over  the  years.  A  key  provision  is  the 
classification of the wastes according the risk they pose. 

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Article 16 bis of the ‘Arrêté du 22 septembre 1994’ demands that “[t]he operator has to 
set up an EWMP before operations begin. This plan has to include at least 
-  a  characterisation  of  the  EWs  and  an  estimation  of  their  total  quantities  that  will 

arise during the operation; 

-  a  description  of  which  operations  produce  these  EWs  and  what  kind  of  treatment 

they will be subjected to; 

- 

if necessary, a description of potential impacts of these EWs on the environment and 
human health, including a description of the measures taken to reduce these impacts; 
-  a description of what steps have been taken to avoid or to re-use/re-cycle these EWs; 

-  a proposal for a rehabilitation plan for EW disposal sites; 
-  proposed monitoring and control measures; 

-  description  of  measures  taken  to  prevent  surface  and  groundwater  contamination 

and contamination of soils and the air; 

-  an environmental impact study for the areas on which EWs will be deposited; 
-  a  risk  assessment  according  to  the  Arrêté  of  19  April  2010  concerning  licensed 

‘Class A’ facilities.” 

EWMPs  has  to  be  revised  and  updated  every  five  years  or  when  there  have  been  any 
significant  changes  to  the  operational  plans.  The  EWMP  has  to  be  submitted  to  the 
Prefect.  Many  planning  permissions  reviewed  simply  state  that  EW  follows  the 
stipulations  of  the  ‘Arrêté  du  22  septembre  1994’.  The  EWMPs  reviewed  shows 
common practices of 

-  setting aside top-soils for building (temporary) vegetated dams around the extraction 

operation; the top-soil will be later used in rehabilitation; 

-  separate  storage  of  overburden  to  be  back-filled  at  closure  and  for  landscaping  the 

excavated area; 

-  washing-fines are collected in settling ponds and deposited for later backfilling; 

-  suitable  and  non-marketable  materials  are  used  for  construction  purposes  in  the 

extractive operation; 

-  washing plants operate in a closed cycle; 

- 

inert flocculation agents at low concentrations are used; 

-  crushing plants are enclosed and fitted with dust-extractors; 

-  quarries  and  pits  tend  to  market  as  much  as  possible  of  the  extracted  material,  but 

depend on (local) demand and market conditions. 

The  French  Union  Nationale  des  Industries  de  Carrières  Et  Matériaux  (UNICEM, 
https://www.unicem.fr/)  has  developed  in  2011  a  guidance  document  for  developing 
EWMPs  according  to  the  ‘Arrêté  du  22  septembre  1994’  (=  EWD).  This  guidance 
document  lays  out  the  format  and  the  content  of  EWMPs  to  be  submitted  to  the 
‚Prefecture’ as the competent authorities. All EWMPs above drafted after 2011 follow 
this  uniform  scheme.  A  key  element  in  the  guidance  document  are  flow-diagrams  as 
decision  aiding  tool  for  attributing  extracted  materials  to  a  specific  waste  class  and 
hence management route. 

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Germany  -  EWMPs  are  the  subject  of  Article  22a  of  the  German  Mining  Code 
(Allgemeine  Bundesbergverordnung  –  ABBergV;  BRD,  1995)  and  their  scope  is 
detailed in its Appendix 5. This appendix largely transposes the stipulations of the EWD 
into national legislation. 

For the purpose of this report it has been attempted to collect information directly from 
some relevant mining industries, such as the potash, aluminium, gypsum, and some new 
metal  mining  industries.  Information  only  from  the  potash  industry  was  received.  No 
concrete EWMPs for Germany could be collected.  

It is common practice in the open-cast lignite mines to put back into the excavated voids 
virtually  all  overburden.  It  is  also  attempted  to  emplace  the  materials  in  their  natural 
geological  sequence.  Top-soils  are  set  aside  for  later  re-cultivation.  Fly-ashes  from 
burning the lignite in power-stations are returned to the excavated voids as well, while 
the  flue-gas  desulfurication  gypsum  enters  the  market  for  gypsum  products  to  a  large 
degree (see also EUROGYPSUM).  

Mining for energy minerals (hard coal and lignite) resulted in a variety of legacies that 
need to be addressed in long-term stewardship programmes. Hard coal mining ended in 
December 2018. The last main operator, Ruhrkohle AG (RAG) has set up a foundation 
(RAG  Stiftung,  https://www.rag-stiftung.de/)  that  will  fund  the  water  management 
measures that are required for eternity.  

Greece  –  The  country  is  one  of  the  major  producers  of  perlite,  bentonite,  bauxite, 
magnesite, lignite and nickel. The legislative framework concerning the management of 
extractive  waste  is  based  on  the  Joint  Ministerial  Decision  39624/2209/Ε103/2009  on 
measures,  conditions  and  limitations  for  the  management  of  waste  from  extractive 
industries, in compliance with the provisions of the EWD. The EWMPs, that have been 
collected allowed to draw the following main conclusions: 

  The majority of the EWMPs are structured according to Article 5 3(c). Specifically, 
all assessed EWMPs describe the operations that generate extractive waste, contain 
elements concerning the waste characterisation and respectively the classification of 
the  waste  facility.  For  non-inert  waste  the  evaluated  EWMPs  also  include:  (a) 
identification  of  extractive  waste  site  options  (b)  assessment  of  the  stability  of  the 
EWF,  (c)  control  and  monitoring  procedures  and  (d)  plan  for  closure.  Specifically, 
the EWMP from Hellas Gold S.A. provide an extensive risk assessment not only to 
identify possible extractive waste site options but also to estimate the potential risks, 
concerning the construction of the facility as part of the classification of the EWF.  

  The information that is provided in the EWMPs is linked to the classification of the 
EW. If the EW is classified as inert, the level of detail is less than the one presented 
for non-hazardous-non-inert or hazardous EW.  

  The  EWMPs  for  metal  ores  include  a  full  mineralogical  analysis  in  order  to 
characterise the extractive waste, in contrast with the EWMPs for the industrial and 
construction  minerals,  where  the  classification  of  waste  is  based  mainly  on  the 
content of heavy metals.  

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An assessment of the stability of the EWF is included in the EWMPs that concern metal 
ores  or  industrial  minerals.  In  particular,  the  EWMPs  from  Elmin  S.A.  (now  Imerys) 
and Interbeton S.A. (Titan Group), that produce industrial minerals, include the stability 
analysis concerning the depositing of extractive waste. On the contrary, the EWMPs for 
construction  minerals,  where  the  extractive  waste  is  characterized  as  inert,  do  not 
provide information on stability issues.  

Hungary - The reviewed EWMPs mostly concern the aggregate or cut-stone industry. It 
is  common practice to maximise the marketable amounts by segregation and selective 
extraction on the basis of careful exploration. Non-marketable residues are returned to 
the mined-out voids and used for landscaping. 

Top-soils are also segregated and retained for later landscaping. 

Hungary has also some coal mining, where all the mining residues are returned to the 
mined-out voids, resulting in nearly no waste at the surface. This is also conducive to a 
rapid change of the land-use class and to minimise the tax burden for industrially used 
land - agricultural lands do not attract land-use taxes. 

Malta  -  Essentially  transposed  the  EWD  into  Maltese  law  1:1.  No  best  practice 
documents available. 

Poland - Provided a list of the relevant laws and regulations and one EWMP fact-sheet 
(concerning the objective of safe disposal) for (best) practice for efficient tailings dam 
construction. In addition, a statement on the EWM practices at the Maritsa Iztok lignite 
field was provided. 

Wastes  (slag,  bottom-  and  fly-ash)  from  lignite-burning  in  power-stations  are  mixed 
with mine-wastes to solidify these and are deposited in out-of-pit dumps. These dumps 
also  receive flue-gas desulfurication  gypsum (FGDG) for this purpose. While gypsum 
as  such  is  soluble,  the  binder  reduces  the  permeable  pore-space  and  thus  the  vector 
drainage water for the migration of contaminants. The binder increases the geotechnical 
stability and reduces the risk of dust generation. Due to the high sulfur content of many 
Polish lignites the quantities of FGDG are too large to be utilised in marketable gypsum 
products. The mines claim this as good EWM practices, as it results in an ‘inertisation’ 
of  the  wastes.  No  details  on  the  chemical  and  mineralogical  processes  given,  but  fly-
ashes are presumably acting as a hydraulic binder. 

Spain - Developments in Spain illustrate the economic effects on resources utilisation. 
The  economic  downturn  in  the  mid-2000s  forced  quarries  to  reconsider  the  way  how 
they  exploit  their  existing  resources  in  order  to  maximise  benefits.  This  included  the 
minimisation of waste and re-working of materials previously considered waste. 

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The  Royal  Decree  975/2009  provides  detailed  information  on  EWMPs  (Chapter  IV, 
Articles 16 to 40) including characterization (according to the methodologies in Annex 
I),  description  of  the  activity,  impacts  on  human  health  and  environment,  etc.  It  also 
stablishes  detailed  information  on  the  minimum  content  to  be  included  in  extractive 
waste facility project descriptions, including their post closure phase. 

A Spanish company developed a software to analyse characteristic patterns (gradients, 
sizes of small-scale catchment areas, etc.) in the geomorphology surrounding extraction 
sites.  Mimicking  these  patterns  during  (re-)grading  and  landscaping  of  EWFs  blends 
to  create  high-energy 
them 
abnormalities.  In  this  way,  the  long-term  evolution  of  EWFs  will  be  similar  to  the 
surrounding landscape (see Best Practice Example B). 

the  surrounding  environment  and  prevents 

into 

Sweden  -  Eleven  EWMPs  were  reviewed,  which  included  iron,  gold,  silver  and  base 
metal mines. All of these are currently operating mines. In Swedish EWMPs it is usual 
to  summarise,  where  in  the  document  the  different  legislation-based  requirements  are 
addressed. This, in principle, functions as a quality control for the scope of EWMPs. 

While  the  risk  identification  is  presented  in  Swedish  EWMPs,  the  detail  level  varies. 
Risk  management,  monitoring  and  accident  preparation  level  are  presented  in  more 
detail for Category A extractive waste facilities. 

Dam safety plays a significant role in Swedish EWMPs. Usually a reference is made to 
the Swedish mining dam safety guideline GruvRIDAS. GruvRIDAS defines the general 
dam  safety  principles,  consequence  classification,  organisational  and  competence 
requirements, as well as dam operation and risk preparation. The permit condition-based 
monitoring,  failure  reporting  and  maintenance  requirements  are  described 
in 
GruvRIDAS.  There  is  even  information  about  dam  constructions  and  dam  safety 
revisions.  

The  mine  sites’  own  ‘DTU-manuals’  (dam  operation,  monitoring  and  maintenance 
manuals) are generally referred to, when there are dams in the mine sites (not ‘satellite 
mines’).  In some cases,  key  points from  the DTU-manuals  are presented in  the actual 
EWMP  documents.  For example  results  of  stability  monitoring  and  a  summary  of  the 
consequence classification of each dam raise are summarised in the EWMP.  

EUROGYPSUM  -  All  EUROGYPSUM  members  for  which  a  response  has  been 
reported,  stated  that  they  do  not  generate  waste.  Top-soils  are  either  stored  for  later 
rehabilitation measures  or sold  off to  farmers and gardeners. Overburden is  stored for 
later use in re-contouring the mined-out areas. 

It  was  also  stated  that  the  difficulty  to  obtain  extraction  licenses  or  to  extend  existing 
ones provides a strong incentive to  utilise  all extracted materials. As the situation has 
become more difficult over the last few  years, there is a strong incentive to rework to 
extract  value  from  materials  that  previously  had  been  dumped  as  non-marketable  in 
order. An example of mechanical separation of clay fines from gypsum rock was given, 
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that  allows  the  utilisation  of  materials  that  would  have  been  dumped  as  waste 
previously. 

As was noted in European Commission et al. (2019), natural, mined gypsum has been 
replaced to a considerable degree by flue-gas desulfurication gypsum from coal-burning 
power-stations. In the longer term, an increase in gypsum mining might be exspected, as 
the use of coal is gradually being phased out in Europe. 

European  Aluminium  (Producers  Association)  -  There  are  seven  alumina  producing 
plants  in  EU27  (Figure  4-10  below).  All  employ  the  Bayer-process  on  imported  ore, 
which results in large quantities of the so-called ‘red mud’, a caustic slurry containing 
the  accessorial  minerals  and  metals.  The  caustic  property  (high  pH)  is  mainly  due  to 
NaAlO2,  Na2CO3,  and  some  NaOH  that  escapes  its  recovery  process.  These  ‘tailings’ 
are deposited in pond-like structures. Due to the fine-grained nature of the solids after 
the  milling  process,  these  muds  dewater  very  slowly.  Most  R&TD  and  management 
efforts  have  been  directed  at  making  the  ‚red-muds’  less  hazardous  and  easier  to 
manage. 

Figure  4-10:  Alumina  producers 
aluminium.eu/data/industry-overview/european-overview-aluminium-plants-location/) 

across  Europe 

(Source:  https://www.european-

Alternative processes are used in some parts of the world (China, Russia), but depend 
on the type of ore. Alternative processes that could use other aluminium ores with less 
accessories, thus resulting in less tailings, and that are less energy consuming are also 
being  explored  (Rhamdhani  et  al.,  2013).  Most  of  the  alternatives  investigated  do  not 
offer  energetic  advantages  and/or  have  other  plant  and/or  health&safety  and/or 
environmental impact implications. While industry continues to pursue alternatives, the 
time  horizon  for  any  results  is  beyond  20  years  (http://bauxite.world-aluminium.org/ 
uploads/media/fl0000422.pdf). 

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The industry, hence, focused on improvements to the Bayer process with the objective 
to “Develop[e] methods to achieve a 1,000-year ecologically sustainable storage of red 
mud  and  other  solid  wastes  in  existing  storages,  and  make  substantial  progress  in 
storage for  later  reuse as well as achieve substantial  progress in  the reuse of  the red 
mud”  (AMIRA,  2001).  Research  on  stabilisation  (inorganic  polymers  or  other  new 
chemistries; use of sea water) and alternative uses (metal recovery, absorbent for CO2, 
road  base/levee  construction,  soil  amendment  treatment  for  acid-generating  materials/ 
acid  mine drainage,  cement  kiln additive, effluent  treatment,  bricks/building products) 
was  to  be  undertaken  according  to  this  road-map.  The  sheer  volume  of  red-mud  that 
arises  each  year,  however,  makes  it  difficult  to  find  sufficient  alternative  uses  in  the 
effort to increase recycling and re-use rates. There also remains the problem of existing 
stockpiles.  Improving  the  Bayer  process  by  looking  into  options  to  reduce  the  NaOH 
consumption  and  its  loss  into  the  red-mud  would  reduce  to  some  degree  the  potential 
environmental impacts of these highly alkaline muds. 

Research  on  improving  the  manageability  of  red  mud  focuses  on  an  accelerated 
dewatering, which would render tailings-ponds less hazardous and prone to catastrophic 
failure  (IAI,  2015).  Bauxite  residues  initially  contain  around  15%  solids  and  can  be 
pumped. When solid contents rise above 28%, the muds exhibit thixotropic behaviour, 
meaning that they begin to flow, when agitated mechanically. When solid contents rise 
above  75%,  the  muds  can  be  handled  with  excavating  machinery.  Filter  presses  and 
centrifugal separators can be employed for dewatering. Reducing the water content will 
also reduce the initial disposal volume, albeit at a considerable energy expenditure, thus 
increasing the carbon-footprint. MWEI-BREF  (2018) advocates to  dewater tailings by 
filtering and then dry-stacking them. 

Various methods to  neutralise tailings, e.g. by accelerated CO2-uptake or  mixing with 
seawater,  have  been  tested.  Enhanced  exposure  to  atmospheric  CO2  will  (partially) 
neutralise the residual alkalinity, which otherwise may hamper re-vegetation.  

Mindful of the large quantities of ‚red mud’ produced, the industry has been for a long 
time  looking  into  adding  value  to  this  waste  by  utilising  it  in  marketable  products. 
However, the market volume of possible applications is much smaller than the amounts 
produced.  There  is  also  some  potential  to  extract  other  metals  from  ‚red  mud’.  While 
there  are  many  technical  options,  their  commercial  viability  is  difficult  to  assure  and 
overall  energy  footprints  also  provide  a  challenge.  The  overall  environmental  etc. 
impacts from utilisation options have to be lower than those from the disposal option.  

Recently  a  European  Innovation  Partnership  (EIP)  on  the  issue  of  bauxite  processing 
waste has been started: http://bravoeip.eu. 

The risks associated with ‚red mud’ management and disposal and pertinent mitigation 
measures,  including  good  governance  are  the  subject  of  a  ‚good  practice’  guide 
prepared for European Aluminium (EA, 2015). 

EA  (2015)  gives  a  range  of  ‘best  practice’  recommendations  for  the  management  of 
bauxite  residues.  The  respective  recommendations  are  summarised  in  Best  Practice 
Example A. These good practices recommendations largely tally with those of the MAC 
(2017) for tailings management. 
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Summary observations 

The  reviews  in  the  preceding  sections  showed  that  very  few  of  the  EWMPs  take  the 
broad view envisaged by the EWD and as broadened in scope by the Circular Economy 
Plans. Long-term and rehabilitation aspects in particular are rarely explicitly addressed 
in the EWMPs that were available for review. 

4.6 Assessment of collected EWMPs as per stated objectives 
The EWMPs available for review were assessed with respect to the objectives stated in 
Section 1.3. 

4.6.1 Processes that lead to extraction 
The relationship between the choices of extraction method and the EWM strategies and 
methods have already been discussed in the companion report, in particular with respect 
to  the  Circular  Economy  paradigm  (European  Commission  et  al.,  2019).  As  has  been 
discussed  above  for  the  bauxite/red-mud  example,  such  operational  choices  can 
significantly influence the way EW have to be managed and the long-term stability of 
EWFs.  Article  5(2)(c)  of  the  EWD  (2006)  stipulates  that  during  the  design  phase  and 
the  operation  (process)  designs  should  be  selected  that  lead  to  a  situation,  where 
minimal  and,  if  possible,  ultimately  no  monitoring,  control  and  management  of  the 
closed  waste  facility  are  required.  By  appropriate  choices  of  processes  also  the  long-
term negative effects due to water- or airborne releases can be minimised, together with 
the  long-term  geotechnical  stability  of  any  engineered  EWF.  There  may  be  various 
constraints on the selection of processes, such as the actual treatability of the extracted 
material (rock matrix), the availability of a particular technology at a particular time and 
location,  and  the  commercial  viability  (with  respect  to  CAPEX  and  OPEX)  of 
employing a particular technology. However, with a view to facilitate the safe long-term 
management of EW, the available technical process options should be explored as part 
of  a  systemic  design  of  the  extractive  operation.  EWMPs  will  have  to  be  reviewed  in 
this respect. The EWMPs available for review to this study do not explicitly treat this 
conceptual aspect. There can be a number of reasons for this. The main reason probably 
is that most operations already existed, when the EWD came into force. In consequence, 
the  EWMP  are  considered  as  add-on  to  existing  obligations  under  the  national 
implementation  of  the  EWD.  The  potential  of  the  EWMP  as  an  instrument  to  guide 
operations strategically and as an instrument of communication with the public has not 
been  realised  in  most  of  the  cases  reviewed.  However,  the  difficulty  of  extending 
existing licenses and obtaining new licenses has  lead to  the optimisation of extraction 
processes  with  a  view  to  maximise  resources  use  and  economic  benefits.  With  a  few 
exceptions  also,  the  reviewed  EWMPs  did  not  concern  Category  A  facilities,  where 
such operational choices can have more profound impacts on the long-term performance 
of EWFs. 

The EWMP could be used as an instrument to make these considerations more explicit, 
as has already pointed out in European Commission et al. (2019). 

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4.6.2 The characterisation and quantification of wastes according to Annex II of 
the EWD over the whole life-cycle. 
The EWMPs available for review reported the amounts of waste to a varying degree. As 
operations  in  most  cases  existed  before  the  EWD  came  into  force,  EWMPs  typically 
cover only forthcoming  quantities, but  do not  give retrospectively quantities that have 
arisen in the past. 

Materials arising from the operations were mainly assessed with two purposed in mind: 
1)  whether  any  market  for  the  extracted  material  exists,  and  2)  whether  „  ...  the 
extractive  waste  may  undergo  [any  changes]  in  relation  to  an  increase  in  surface  area 
and  exposure  to  conditions  above  ground;  ...“,  i.e.  mainly  with  respect  to  its  acid-
generation potential. Point 1 reflects the economic interest in marketing as much of the 
extracted material as possible and to have to dispose of it as waste as little as possible. 
Point 2 determines, whether any material considered waste is inert, which simplifies its 
management,  or  is  expected  to  react  in  some  way,  which  will  require  a  specifically 
engineered EWF, or even a Category A facility, with the associated higher costs. Some 
EWMPs state that a classification according to Point 1 may change as market conditions 
change.  This  results  in  a  changing  attributions  with  time  of  extracted  materials  to  the 
categories (by)products, materials returned to the excavated voids e.g. for rehabilitation 
purposes, and waste respectively. 

4.6.3 Category A facilities: accident prevention policies, safety management 
system, and internal emergency plans 
The EWMPs for Category A facilities received through the questionnaires or retrieved 
from the literature are discussed in the following.  

Eleven  extractive  operations  that  have  Category  A  Facility  have  sent  factsheets  with 
candidate  best  practices  and  another  two  extractive  operations  have  sent  the  entire 
EWMP (in total 13 extractive operations with a Category A EWF). 

Table 4-4 Extractive operations with a Category A EWF provided factsheets 

Country 
Cyprus 
Finland 

Spain 
Sweden 

Greece 

Extractive operations with a Category A EWF 
Skouriotissa EWMP 
Pyhäsalmi Mine Oy 
Boliden Kevitsa mine 
Terrafame Oy 
Dragon Mining-Svartliden Mine 
Zinkgruvan-Nya Enemossen 
Agnico Eagle Finland Oy Kittilä mine 
Minas de Aguas Teñidas S.A.U 
Boliden Mineral AB for the Garpenberg 
Boliden Mineral AB for the Maurliden  
Boliden Mineral AB for the Aitik mines  
LKAB for the Malmberget Mine 
Hellas Gold S.A. EWMP 

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As  was  noted  above,  dam  safety  plays  a  significant  role  in  Swedish  and  Finnish 
EWMPs  for  Category  A  facilities.  In  Sweden  usually  a  reference  is  made  to  the 
comprehensive  mining  dam  safety  guideline  GruvRIDAS.  GruvRIDAS  defines  the 
general  dam  safety  principles,  consequence  classification,  organisational  and 
competence  requirements,  as  well  as  dam  operation  and  risk  preparation.  The  permit 
condition-based  monitoring,  failure  reporting  and  maintenance  requirements  are 
described  in  GruvRIDAS.  However,  the  relevant  safety  information  is  often  not 
contained  in  the  EWMPs  themselves,  but  in  companion  documents  to  which  then 
reference is made. 

In  the  EWMP  of  2017  for  the  Boliden  Garpenberg  Mine  in  Sweden  an  extract  of  the 
‘DTU-manual’ (the manual  for operation, monitoring  and maintenance of dams) is an 
appendix to the EWMP and some key points of it are summarised in the actual EWMP. 
The  manual  uses  a  structured  approach,  documenting 
legislative 
requirements and how they are met in during the operation, monitoring and maintenance 
of  the  dams.  Also  preparatory  plans  for  exceptional  situations  are  included.  For 
instance, the following points are covered by the Garpenberg Mine EWMP: 

the  current 

  What is the purpose of the DTU-manual. 
  Key contents of the DTU manual. 
  How the DTU-manual is made available to the staff. 
  Consequence classification according to Swedish GruvRIDAS (mine dam guideline). 
  Updating routines for the DTU manual. 
  Archiving system for the relevant documents. 
In the Garpenberg EWMP, the dam stability monitoring programmes for the dam raises 
are described. Generally dam safety monitoring covers these six different aspects: 

  Operational monitoring 
  Measurements 
  Function proving 
 
  Detailed inspection 
  Detailed dam safety evaluation 

Inspection 

In addition, the safety reporting procedure for a Category A facility is shortly explained 
in the Garpenberg Mine EWMP. 

The EWMP for the Boliden Kevitsa Mine of 2015 includes a detailed description of the 
tailings  storage  facility  dam  safety  monitoring  instrumentation,  including  instrument 
types (e.g. inclinometers and piezometers) and locations. 

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4.6.4 Non-Category A facilities: information on justification including 
identification of possible accident hazards 
The EWD and the various Commission Decision amending it lay down the criteria for 
the determination, whether a facility belongs into Category A or not. The determination 
is based on the contents of hazardous materials, the reactivitiy of the waste itself, and is 
to  be supported by a risk assessment. The two main criteria to  be investigated, hence, 
are 1) whether the waste itself is inert and its possible content of hazardous substances, 
and  2)  whether  the  envisaged/actual  mode  of  disposal  can  give  rise  to  any  hazards. 
Criterion  1  was  satisfied  in  all  EWMPs  reviewed  by  appropriate  mineralogical  and 
(geo)chemical  investigations,  i.e.  a  waste  characterisation.  Criterion  2  depends  on  a 
range  of  factors,  including  the  mode  of  extraction,  the  processing  technique,  and  the 
chosen  mode  of  disposal.  In  most  cases  the  dominant  risk  is  that  of  geotechnical 
instability, but in most cases the risks are more chronic (erosion) than acute (collapse of 
impoundments), so that no particular accident scenarios beyond what would be needed 
to obtain the construction permission by the competent authorities were investigated. 

It  appears  that  in  most  cases  some  sort  of  ‘differential  diagnosis’  approach  is  used  in 
order  to  determine,  whether  a  waste  facility  belongs  into  Category  A  or  not.  In  other 
words, if none of the criteria is fulfilled that justifies categorisation into Category A, the 
facility must be outside this category. A good practice in this context are the decision-
making  flow-diagrams  as  employed  in  France  for  instance.  This  should  be  based  not 
only on a risk analysis, but also a consequence analysis, e.g. for dam failures. If there 
are no significant consequences to be expected, even tailings management facilities may 
not  need  to  be  classified  into  Category  A,  as  some  Finnish  examples  show.  Best 
Practice  example  E  illustrates  another  approach  by  which  the  in  situ  treatment  of 
historical wastes can avoid the need to construct a Category A facility.  

4.6.5 Assessments of potential environmental and human health impacts 
Per  definition  this  assessment  would  pertain  mainly  to  Category  A  facilities,  but  inert 
wastes  can  also  cause  impacts  due  to  e.g.  turbidity  in  surface  waters  from  eroded 
material. Typically, an assessment of potential environmental and human health impacts 
is  the  subject  of  the  environmental  impact  assessment  (EIA),  which  would  have  been 
carried out as part of the licensing application. The EIA is one of the bases on which the 
decision will be made into which category a future EWF would belongs. 

Typically, an operator chooses excavation and processing methods based on preliminary 
studies  of  the  deposit  and  the  materials  properties.  The  EIA  is  then  based  on  this 
proposed  mode  of  extraction  and  processing.  An  optimisation  is  undertaken, 
considering  the  respective  CAPEX  and  OPEX,  which  would  include  the  costs  of 
disposal  and  ancillary  costs,  such  as  environmental  insurances.  Whether  further 
optimisations,  as  stipulated  by  the  EWD,  are  undertaken  depends  on  the  economic 
context,  as  well  as  the  expected  benefits  vs.  costs  of  the  optimisation.  The  decision-
finding  process  during  the  planning  phase  is  likely  to  be  an  iterative  one,  i.e.  if  a 
practice  would  lead  to  unacceptable  environmental  or  human  health  impacts,  this 
practice needs to be adapted until (actual and potential) impacts are removed or below 
limits of concern. 

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Non-hazardous  non-inert  EWs  can  also  cause  environmental  impacts.  Acid  Rock 
Drainage (ARD) from the oxidation of sulfide minerals is the main concern. Even small 
quantities  of  such  minerals  can  give  rise  to  significant  mobilisation  of  potential 
contaminants  in  the waste. Sulfide minerals  and their ARD  formation  potential  would 
be assessed during the chemical and mineralogical characterisation of the wastes. 

EWs undergo transformation processes akin to natural (early) diagenesis, which change 
the  pore-structure  and  mineralogy  of  the  excavated  materials.  These  changes  can  be 
both,  beneficial  and  detrimental  from  the  point  of  view  of  mobilisation  of  various 
constituents. The main driver of such processes with be infiltrating meteoric or surfaces 
waters. With a view to assess the long-term impacts, the development of such processes 
and their driving forces could be investigated, also using predictive tools. 

It would be also useful to develop a flow model that predicts the affected areas in the 
case of the collapse of a tailings dam, so that protection and early warning measures can 
be taken. However, this also should be done at the licensing, rather than at the closure 
stage, when little can be done about it. 

Neither of the EWMPs made explicit reference to the EIAs of the operations to which 
they belong or to any impacts that may arise from the failure of the EWFs. 

4.6.6  Preventive measures taken to minimise operational and post-closure 

impacts 

The  EWMPs  reviewed  focused  on  the  minimisation  of  impacts  during  operation  and 
less so explicitly on the post-closure phase. There may be a number of reasons for this. 
One  reason  probably  is  that  most  EWMPs  received  for  this  study  concern  operations 
that are far away from closure or closure of their EWFs. The main concern of operators 
is  to  ensure  operational  safety  and  compliance  with  applicable  (national  and  EU) 
regulations  in  this  respect.  There  is  also  a  tendency  to  imply  that  operational  safety 
ensures long-term post-closure safety. Many national jurisdictions distinguish between 
the  operational  and  the  post-operational  phase,  requiring  different  licenses  for  each. 
This  may  lead  to  the  post-closure  phase  not  being  reflected  in  current  EWMPs.  The 
Nordic countries, however, take more of a life-cycle perspective and the after-use and 
any  necessary  monitoring  programmes  are  discussed  in  the  EWMPs.  As  closure  is  a 
separate licensing step with potential long-term consequences and uncertainties, closure 
plans  are  presented  usually  in  separate  documents  that  have  not  been  reviewed  in  the 
context of this study. EWMP may make reference to these (draft) documents though. It 
appears  that  the  closure  aspects  are  neither  treated  thoroughly  enough  in  the  EWMPs 
nor in the MWEI-BREF (2018). 

Airborne impacts during the operational phase are originating in dusts raised, which are 
routinely  supressed  by  water-spraying,  which  is  not  explicitly  mentioned  in  EWMPs. 
Today, covering EWFs with top-soil and re-vegetation are standard procedures during 
closure  to  minimise  erosion  and  dust  dispersal.  Top-soil  covers  also  reduce  the 
infiltration  of  meteoric  water  as  the  main  driving  force  of  water-borne  impacts, 
including ARD formation. Such measures are almost always mentioned in the EWMPs. 
The  capping  would  be  commensurate  with  the  type  of  EWF  and  for  Category  A 
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facilities or those with wastes of high ARD formation potential usually have to be more 
elaborate (see Ch. 3) to  ensure the long-term erosion  stability and to  more effectively 
prevent infiltration.  

Some EWMPs pertaining to industrial and construction mineral extraction also mention 
as good practice during operation the infilling of excavated voids with non-marketable 
inert material from the operation in order to reduce the exposure of aquifers to impacts 
from atmospheric contamination.  

In some cases it was noted that slopes of EWFs were graded at an angle reflecting the 
natural  angles  in  the  surrounding  landscapes.  Also,  re-vegetation  is  usually  oriented 
towards the natural vegetation in the vicinity. 

Impacts  during  the  operational  phase  are  subject  of  the  EIAs  that  are  the  basis  for 
licenses to operate. For this reason, the reviewed EWMPs seem to make rarely reference 
to impacts as such and focus on operational practices. 

4.6.7  Control and monitoring procedures (Articles 10 and 11(2)(c) EWD) 
Control and monitoring procedures are mainly undertaken in the context of complying 
with  environmental  and  other  permits  on  the  basis  of  EIAs  and  periodic  geotechnical 
stability  surveys  as  stipulated  by  the  mining  or  construction  laws.  They  are  not 
mentioned explicitly in any of the reviewed EWMPs. 

the  following  categories:  operation  control,  emissions  monitoring, 

Control  programmes  are  commonly  detailed  separate  documents,  but  are  usually 
referred  to  e.g.  in  Swedish  and  Finnish  EWMPs.  For  instance,  in  the  EWMP  for 
Terrafame  Sotkamo  Mine,  details  of  the  actual  (mine  site)  monitoring  programme  are 
not included, but monitoring is described in general and monitoring objectives are listed 
impact 
for 
monitoring,  waste  quality  monitoring  and  waste  facility  internal  circumstances 
monitoring (including seepage). Therefore, the EWMP is extended to cover also other 
types  of  waste  than  EW.  In  the  EWMP  for  the  Boliden  Kevitsa  Mine,  EW  chemical 
quality monitoring procedures are presented in  detail  and chemical  quality  monitoring 
results for the EW for the previous two years are presented in EWMP, in order to justify 
the  EW  classification.  Generally,  in  Finland  it  is  common  in  EWMPs,  to  refer  to 
monitoring  programmes  as  separate  documents  and  to  identify  the  exact  authority 
decision  that  approves  these  programs.  In  Swedish  EWMPs  dam  safety  monitoring  is 
often  a  main  focus  and  DTU-manuals  (dam  operation,  monitoring  and  maintenance 
manual) are provided. 

After-closure  monitoring  and  surveillance  measures  as  part  of  measure  to  assure  the 
long-term integrity of EWFs have not been mentioned in any of the EWMPs reviewed. 
One  must  assume  that  the  closure  of  EWFs  is  a  separate  regulatory  and  licensing 
procedure  under  most  national  jurisdictions.  Therefore,  post-closure  control  and 
monitoring provisions were not part of the EWMPs. 

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4.6.8 Surveys of the conditions of the land to be affected by the waste facility 
Article 5(3)(h) of the EWD is not explicit as to the scope and purpose of these surveys 
and what ‘land’ actually means in this context. 

The  various  EIAs  that  are  usually  required  at  the  different  stages  of  a  licensing 
procedure  would  cover  the  environmental  aspects  including  possible  contamination  of 
underlying  groundwater  resources.  The  EWMPs  reviewed  usually  make  reference  to 
these  EIAs  and  also  explain  why  and  how  the  chosen  management  options  and 
techniques address points raised in the EIAs. 

It is not clear, whether Article 5(3)(h) would also refer to the geotechnical situation at 
the  site  of  a  planned  EWF.  Normally,  these  site  conditions  would  have  been 
investigated  as  part  of  the  construction  permission  procedures  by  the  competent 
authorities.  EWMPs  usually  make  reference  to  the  related  documents  without 
reproducing  any  details.  In  the  Nordic  countries  more  details  may  be  included, 
particularly for Category A facilities, though the main documents are separate. 

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4.7  Conclusions 
The ambitions of long-term stability as formulated in the EWD have not been reflected 
in  the available EWMPs.  It  appears that there is  a tacit assumption that measures that 
assure  operational  safety  also  will  assure  long-term  post-closure  safety.  Except  for 
references  to  setting  aside  top-soils  for  later  landscaping  and  re-vegetation  purposes, 
closure and post-closure activities and aims are generally not mentioned in the EWMPs 
available for review. 

Therefore, guidance for best practices in assuring long-term stability of EWFs and the 
EWs  contained  therein  had  to  be  derived  from  a  small  range  of  EWMPs,  where  such 
issue  have  been  addressed  explicitly,  and  from  a  wide  range  of  guidance  documents 
produced by the industry itself, its associations, and international bodies. 

A number of key messages can be deducted from this: 

  a  life-cycle  approach  ensures  a  comprehensive  view  of  waste  arisings  and  their 

management over time: 

  integration  of  operation  and  preparation  for  the  closure  and  post-closure  phase 

facilitates the transition and makes it more efficient; 

  EWFs should be designed with closure and rehabilitation in mind; 

  contouring  and  re-vegetation  should  mimic  the  surrounding  landscape  in  order  to 

reduce the likelihood of erosion and re-vegetation success; 

  segregation  and  (possibly)  pre-treatment  of  wastes  helps  to  reduce  the  amount  of 

difficult to manage wastes; 

  dewatered tailings ensure operational and long-term safety; 

  current EWMPs are drafted with operational aspects in mind, but rarely take a long-

term and post-closure view, albeit EWFs are going to be permanent features. 

The  ambitions  formulated  in  the  EWD,  particularly  those  with  respect  to  achieving 
more sustainability and a circular economy, often go beyond what individual operations 
would want to achieve. Commercial operations work within a given economic context 
and have to  be profitable. Additional  104ptimization  measures  are only undertaken, if 
there  is  an  economic  benefit  or  in  order  to  comply  with  regulatory  requirements.  A 
differing economic context also means that each operation has to be treated individually 
and  ‚best  practices’,  whether  from  an  operational  or  technical  point  of  view,  often 
cannot be applied uniformly. Thus, for instance, one operation may be able to market a 
certain  fraction  of  the  extracted  material  as  by-product,  while  another  operation 
extracting  the  same  kind  of  mineral  may  not  find  a  market  this  and,  therefore,  would 
need to dispose of it as waste. This may also change with time and EWMPs have to be 
flexible in order to accommodate such changes. 

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4.8 References 
ANGLO-AMERICAN  PLC (2013): Mine Closure Toolbox, Version 2.- 44 p., Johannesburg, 

http://www.angloamerican.com/~/media/Files/A/Anglo-American-PLC-
V2/documents/approach-and-policies/environment/toolbox-main-brochure-lr.PDF 
(accessed 16.05.19) 

Ingenería, Directorate-General 

Eco Efficiency  Consulting  and  Engineering  Ltd.,  WEFalck,  Kertész,  B.,  Pöyry 
(European 
Finland Oy,  CRS 
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the  extractive  waste management  plans.  Circular  economy  action  –  Study.-  59 
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36aa-11e9-8d04-01aa75ed71a1/language-en/format-PDF/source-
87989698 (accessed 1.07.19) 

for Environment 

BRD  BUNDESREPUBLIK  DEUTSCHLAND  (1995):  Allgemeine  Bundesbergverordnung  vom 
23.  Oktober  1995  (BGBl.  I  S.  1466),  die  zuletzt  durch  Artikel  4  der  Verordnung 
vom 18. Oktober 2017 (BGBl. I S. 3584) geändert worden ist.- http://www.gesetze-
im-internet.de/abbergv/ABBergV.pdf (accessed 16.05.19) 

CZECH  REPUBLIC 

(2013):  Mining 

Laws 

and  Regulations  Handbook.- 

https://books.google.fr/books?id=dW-8AAAAQBAJ&printsec=frontcover&hl= 
source=gbs_ge_summary_r&cad=0#v=onepage&q&f=false 
de& 
16.05.19) 

(accessed 

EA EUROPEAN ALUMINIUM (2015): Bauxite Residue Management: Best Practice.- 31 p., 

https://european-aluminium.eu/media/1340/201507_bauxite-residue-management-
best-practice.pdf (accessed 16.05.19). 

EUROPEAN  COMMISION  (2009):  Commission  Decision  2009/359/EC  of  30  April  2009 
completing  the  definition  of  inert  waste  in  implementation  of  Article  22(1)(f)  of 
Directive 2006/21/EC of the European Parliament and the Council concerning the 
management  of  waste  from  extractive  industries.-  OJ  of  the  European  Union  of 
01.05.2009:  L110/46-47,  https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/ 
?uri= CELEX:32009D0359&from=EN (accessed 16.05.19).  

EUROPEAN  COMMISION  (2015):  Communication  from  the  Commission  to  the  European 
Parliament,  the  Council,  The  European  Economic  and  Social  Committee  and  the 
Committee of the Regions: Closing the loop  - An EU action plan for the Circular 
Brussels, 
Economy.- 
https://ec.europa.eu/transparency/regdoc/rep/1/2015/EN/1-2015-614-EN-F1-1.PDF 
(accessed 16.05.19). 

COM(2015)614 

final: 

21 

p., 

EUROPEAN  COUNCIL  (1996):  Directive  96/82/EC  of  9  December  1996  on  the  control  of 
major-accident hazards involving dangerous substances.- OJ of the European Union 

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14.01.1996:  L10/13/-L10/33, 

of 
TXT/PDF/?uri=CELEX:31996L0082&from=EN (accessed 16.05.19). 

https://eur-lex.europa.eu/legal-content/EN/ 

EUROPEAN COUNCIL (2014): Directive 2013/59/EURATOM of 5 December 2013 laying 
down  basic  safety  standards  for  protection  against  the  dangers  arising  from 
exposure 
ionising  radiation,  and  repealing  Directives  89/618/Euratom, 
90/641/Euratom, 96/29/Euratom, 97/43/Euratom and 2003/122/Euratom.- OJ of the 
European  Union  of  17.01.2014:  L13/1-L13/73,  https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/ ?uri=CELEX:32013L0059&from=en (accessed 16.05.19). 

to 

EWD European Parliament and Council (2006): Directive 2006/21/EC of 15 March 2006 
on  the  management  of  waste  from  extractive  industries  and  amending  Directive 
2004/35/EC.-  OJ  of  the  European  Union  of  11.4.2006,  L102:15-33,  https://eur-
lex.europa.eu/resource.html?uri=cellar:c370006a-063e-4dc7-9b05-
52c37720740c.0005.02/DOC_1&format=PDF (accessed 16.05.19).  

Falck,  W.E.  (2016a):  Social  Licensing  in  Mining  -  Between  Ethical  Dilemmas  and 
Economic  Risk  Management.-  Mineral  Economics,  29(2):  97-104,  DOI: 
10.1007/s13563-016-0089-0. 

Falck, W.E. (2016b): Integrating Decommissioning and Environmental Remediation into 
the  Life-Cycle  Management  of  Mining  and  Milling  Sites.-  Euromines  Newsletter, 
3/2016: 
integrating-
decommissioning-and-environmental-remediation-into-the-life.  

http://www.euromines.org/news/newsletters/3-2016/ 

FALCK,  W.E.,  FERNANDES,  H.M.  [EDS.]  (2009):  Integrated  Approach  to  Planning  the 
Remediation of Sites Undergoing Decommissioning.- International Atomic Energy 
Agency,  Vienna,  Nuclear  Energy  Series  Report  NW-T-3.3,  http://www-
pub.iaea.org/MTCD/publications/PDF/Pub1385_web.pdf (accessed 16.05.19). 

FALCK, W.E., SEITZ, R. , PEARL, M., AUDET, M., SCHMIDT, P., FERNANDES, H.M. (2009): 
Remediation as Part of the Decommissioning of Nuclear Facilities.- Ch. 6 in: Voigt, 
G., Fesenko, S. [Eds.]: Remediation of Contaminated Environments, Radioactivity 
in the Environment, 14: 263-342, Elsevier. 

GOVERNMENT OF CANADA (2011): Guidelines for the assessment of alternatives for mine 
https://www.canada.ca/en/environment-climate-change/ 

waste 
services/managing-pollution/publications/guidelines-alternatives-mine-waste-
disposal.html (accessed 16.05.19). 

disposal.- 

ICMM  (2016):  Position  statement  on  preventing  catastrophic  failure  of  tailings  storage 
facilities.-  6  p.,  https://www.icmm.com/website/publications/pdfs/commitments/ 
2016_icmm-ps_tailings-governance.pdf (accessed 16.05.19). 

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IAEA  INTERNATIONAL  ATOMIC  ENERGY  AGENCY  (2003):  The  Extent  of  Environmental 
Contamination  by  Naturally  Occurring  Radioactive  Material  (NORM)  and 
Technological  Options  for  Mitigation.-  IAEA,  Vienna,  Report  IAEA-TRS-419, 
(accessed 
http://www-pub.iaea.org/MTCD/publications/PDF/TRS419_web.pdf 
16.05.19). 

IAEA  INTERNATIONAL  ATOMIC  ENERGY  AGENCY  (2006):  Management  of  Long-Term 
Radiological  Liabilities:  Stewardship  Challenges.-  International  Atomic  Energy 
Agency,  Vienna,  Report  IAEA-TRS-450:  224  p.,  http://www-pub.iaea.org/ 
MTCD/publications/PDF/ TRS450_web.pdf (accessed 16.05.19). 

MAC MINING ASSOCIATION OF CANADA (2017): A Guide to the Management of Tailings 
Facilities, 3rd Edition.- 86 p., http://mining.ca/sites/default/files/ documents/MAC-
Guide-to-the-Management-of-Tailings-Facilities-2017.pdf 

MAZUREK,  M.,  PEARSON,  F.J.,  VOLCKAERT,  G.,  BOCK,  H.  (2003).  Features,  Events  and 
Processes  evaluation  catalogue  for  argillaceous  media  (PDF).-  Nuclear  Energy 
Agency,  Report  NEA4437:  379  p.,  Paris  (OECD-NEA)  http://db.nea.fr/rwm/ 
reports/2003/nea4437-FEP.pdf (accessed 16.05.19).  

MWEI-BREF  GARBARINO,  E.,  ORVEILLON,  G.,  SAVEYN,  H.G.M.,  BARTHE,  P.,  EDER,  P. 
the 
(2018):  Best  Available  Techniques  (BAT)  Reference  Document  for 
Management  of  Waste  from  Extractive  Industries  in  accordance  with  Directive 
2006/21/EC.-  JRC  Science  for  Policy  Report,  EUR  28963  EN:  722  p., 
(accessed 
http://publications.jrc.ec.europa.eu/repository/handle/JRC109657 
16.05.19) 

OECD-NUCLEAR  ENERGY  AGENCY  (2001):  Reversibility  and  Retrievability  in  Geologic 
Disposal of Radioactive Waste - Reflections at the International Level.- 49 p., Paris 
(OECD-NEA),  https://www.oecd-nea.org/rwm/reports/2001/nea3140.pdf  (accessed 
16.05.19). 

REPUBLIQUE DE FRANCE (1994): Arrêté du 22 septembre 1994 relatif aux exploitations de 
carrières et aux installations de premier traitement des matériaux de carrières. NOR: 
2018, 
consolidée 
ENVP9430348A. 
https://www.legifrance.gouv.fr/affichTexte.do?cidTexte=JORFTEXT00000034784
5 (accessed 16.05.19). 

Version 

janvier 

29 

au 

UNECE United Nations Economic Commission for Europe (2014): Safety guidelines and 
good  practices  for  tailings  management  facilities.-  42  p.,  New  York/Geneva, 
https://www.unece.org/fileadmin/DAM/env/documents/2014/TEIA/Publications/13
26665_ECE_TMF_Publication.pdf (accessed 16.05.19). 

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Zapico, I., Martín Duque, J.F., Bugosh, N., Laronne, J.B., Ortega, A., Molina, A., Martín-
Moreno,  C.,  Nicolau,  N.,  Sánchez,  L.  (2017):  Geomorphic  Reclamation  for 
reestablishment of landform  stability  at  a watershed scale in  mined sites: the Alto 
Tajo Natural Park, Spain.- Ecological Engineering, 111: 110-116. 

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4.9 Best Practice Examples 
4.9.1 Best Practice Example A: Safe management of bauxite wastes 
1. Description 

European Aluminium has published a guidance book on the safe management of bauxite 
tailings  (EA,  2015).  The  summary  table  of  this  report  is  included  here,  as  the  scope  of 
this guidance is exemplary and very exhaustive. 

Long-term Planning and Design 

Integrated planning 

 

residue  planning  designers,  facility  management  and  closure  group  must  work  together  and 
communicate to achieve key performance indicators (KPIs). 

  accountability and designated co-ordinator important. 

Storage design 

  capacity should be based on performance and align with risk assessment. 

Water Balance 

integrate a life cycle plan. 

 
  establish standards for ground and surface water management. 

Space 

  space  should  be  adequate  to  match  refinery  life/production  expectations.  Residue  storage  plan 
(include drying time, area needed) needs to be linked/aligned to operations plan (e.g. increase in 
capacity). 

Governance 

Governance should cover full facility life-cycle including; 

  operation design, 
  construction, 
  operation and, 
  closure and post-closure 

Governance should encompass the following high level processes; 

  know what to do - responsibility assessment matrix (RACI), know full range of activities 
  know how to do it - standard work methods and procedures, clear performance indicators 
  audit at all levels against clear goals 

Change Management System 

  clearly  defined  change  management  process  -  particular  focus  on  the  management  of  small 

changes 

  clear and simple change management process 

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Emergency Response Plan 

  emergency response plan based on risk assessment is in place and rehearsed 

Senior Management Accountability 

  ensure clear link between hazards and senior management overview 
  well defined management structures and accountability for facility management 

Integrated Production and Residue Management 

refinery and residue process closely linked 

 
  decisions made at the correct level in the organisation 
  scenario analysis and training 
  clearly defined action triggers 

Records Management 

  maintain history of records 
  put records management procedure in place 
  put records auditing and archive process in place 

Performance Tracking 

Policy and planning - 

  ensure  the  structure  of  the  organisation  and  available  resources  align  with  and  compliment  its 

ability to sustain the long-term plan. 

Training and accountability 

  clearly  defined  to  ensure  all  levels  of  the  organisation  are  adequately  qualified  to  undertake 
performance tracking responsibilities; information collected and collated in a meaningful way to 
ensure the intent of performance tracking activities are met to support both short- and long-term 
goals and consistent with the long-term plan that is in place. 

Data management 

  data to be collected in a manner that is appropriate (thorough and representative) and  managed to 

ensure effective communication between all levels (transparent and readily accessible). 

Budget 

  ensure  justification  of  expenditure  is  undertaken  to  implement  and  maintain  Performance 

Tracking tools and equipment 

Performance auditing 

  undertaken  at  an  appropriate  frequency  by  an  independent  third  party  to  ensure  sustained 
operational  alignment  with  long-term  plan  and  continued  validation  of  key  underlying 
assumptions. 

  on-going  internal  auditing  of  all  aspects  of  residue  management  performance  is  required  with 
external audits undertaken at least annually by a suitably qualified third party, who is not part of 
the usual operational support group to avoid possible conflict of interest issues. 

Forward planning 

  best-practice  goals  should  be  developed  to  drive  a  culture  of  continuous  improvement.  Inter-

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operational  benchmarking  should  be  undertaken  using  agreed,  standardised  measures  (such  as 
annual  deposition  intensity  within  active  disposal  area)  to  ensure  alignment  of  similar  disposal 
techniques with state of the art performance capabilities. 

Storage and Disposal 

Despite the  improvements in  technology, it  must be accepted that it is often extremely  difficult  for a 
plant  to  change  the  method  of  bauxite  disposal.  Factors  such  as  proximity  to  the  sea;  availability  of 
sufficient suitable land area; nature and characteristics of the residue; amount of annual rainfall; the sun 
and wind evaporative characteristics of the climate where the plant is located; availability of economic 
pH  reduction  sources  such  as  carbon  dioxide,  sulfur  dioxide,  sea  water,  acid  all  effect  the  decision 
making.  Some  of  these  are  impossible  to  change  whilst  others  could  lead  to  the  plant  becoming 
uneconomic. It is essential for each plant to undertake a risk assessment taking into account the solid 
liquid  characteristics  of  the  residue,  the  quantity  stored,  the  hazardous  nature  of  the  stored  material 
(especially pH), the height and type of dam/dyke used to impound the material, the risk in that area for 
the possibility of earth tremors, heavy rain, hurricanes, cyclones, tsunamis, sabotage etc. 

The nature of bauxite residue 

 

there should be an overarching goal to reduce and/or stabilise the residual soda content in residue 
(and associated stored liquors). 

  where  possible  a  site  should  neutralise  residue  to  prevent  classification  as  a  hazardous 

material/waste. 

Residue Transportation 

  where possible separate site transport roads and active residue pipelines. 
  control,  contain  or  isolate  residue  pipelines  through  burst  discs,  bunding  or  removal  from 

trafficked areas. 

  establish a benchmark for monitoring of distribution/transportation system 
  prepare and test pipeline spill plans and all response to failures/incidents. 

Discharge Control & Deposition Management 

  define optimal deposition controls for each operation. 
  document and justify tasks required for sustained BRSA performance. 

Remediation 

Factors to be considered when planning the  closure, decommissioning and rehabilitation of a bauxite 
residue storage facility are: 

  environment and climate in which the residue storage facility is located 
  post-closure land use 
 
long-term landform stability, including geotechnical and erosional stability 
  managing surface runoff and ponding, and the need for a closure spillway 
 
long-term seepage to the environment of potentially contaminated water 
  potential for dust generation both before and after rehabilitation 
  surface treatment and vegetation of the top of the residue storage facility 
  profiling, surface treatment and vegetation of outer batter slopes. 
  post  closure  land  use  e.g.  restored  to  original  flora,  maximum  biodiversity,  productive  crops, 

 

recreation 
if  deemed  necessary,  collection  and  treatment  of  leachate  (e.g.  neutralisation,  constructed 
wetlands) 

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  on-going  testing  and  monitoring  of  surface  and  ground  water  regimes  to  meet  regulatory 

requirements 

  on-going management, security and controls of sites when the refinery no longer exists. 

Plan 

  defined closure plan developed with community input 
  closure costs identified and allocated 
  clear closure plan owner identified 
  defined community engagement process 

Cost 

  need  to  consider  residue  as  a  potential  resource:  both  for  direct  uses,  eg  soil  amelioration,  land 

 

capping, and uses for the closed residue sites. 
transparent  accounting  of  resources  for  closure  required  so  that  the  best  low  cost  sustainable 
regime can be implemented. 

Education 

  successful examples of closed facilities 

Residue Composition 

 
 

recovery of as much sodium as possible 
list all constituents; where possible convert them into harmless stable form. 

2. Rationale for selecting as Best Practice 

This  catalogue  of  issues  to  be  covered  for  tailings  management  is  exemplary  in  its 
comprehensiveness.  These recommendations are  applicable not  only to bauxite tailings, 
but to any kind of tailings management facilities. 

3. Environmental benefits achieved 

If  the  recommendations  in  the  guidelines  are  followed,  this  should  greatly  reduce  the 
risks from tailings ponds.  

4. Economical aspects 

The guidelines call for the management and closure cost to be explicitly accounted for in 
the  planning.  They  also  consider  the  re-use  aspect  of  wastes  in  other  economic 
applications with a view to reduce the volumes to be deposited. 

5. Examples of application 

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n/a 

6. Bibliographic reference 

EA EUROPEAN ALUMINIUM (2015): Bauxite Residue Management: Best Practice.- 31 p., 
https://european-aluminium.eu/media/1340/201507_bauxite-residue-management-best-
practice.pdf (accessed 16.05.19). 

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4.9.2 Best Practice Example B: Landscaping for increased erosion resistance 
1. Description 

Achieving  maintenance  erosion  resistance  is  a  major  pre-occupation  during  the  closure 
and rehabilitation of EWFs. For a given set of climatological conditions the pre-mining 
landscape is likely a situation of low erosional losses. Hence, it should be the aim of the 
rehabilitation to reconstitute contours of waste dumps and mine sites that are compatible 
with the surrounding geomorphology. This Best Practice Example describes a software-
based assessment of the surrounding geomorphology that can be used as the paradigm for 
the  waste  contouring.  The  method  is  called  GeoFluv  and  implemented  for  instance 
through a proprietary software. The method is described for the example of El Machorro 
kaolin mine in Spain (Figure 1; Balaguer et al., 2014).  

Figure 1: Assessment of the Natural Capital and Ecosystem Goods and Services (EGS) 
over the past milennium as the basis for a geomorphology-based rehablitation of the El 
Machorro  kaolin  mine  site  in  Spain.  The  evolution  of  Natural  Capital  and  EGS  are 
projected  into  the  21st  century.  Each  ‘star’  or  group  of  concentric  circles  represents  a 
historical ecosystem configuration; the inner circle represents the ecosystem itself, while 
the  two  outer  circles  represent  the  landscape  (biophysical  matrix)  and  the  socio-
economic  matrix  in  which  the  ecosystem  is  embedded;  the  triangular  appendages 
represent the main EGSs. The rehabilitated ecosystems will provide new EGSs (Balaguer 
et al., 2014). 

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A multiannual monitoring has demonstrated its success in terms of erosional stability and 
ecological  recovery.  A  detailed  description  of  the  method  and  of  the  evidences  of  its 
success  have  been  published  by  Zapico  et  al.  (2018).  Geomorphological  re-grading  is 
complemented  with  a  geomorphological  approach  for  re-establishing  subsoils  (surficial 
deposits, carbonatic colluvium) and top-soils. Its benefits have been also demonstrated in 
an experimental spoil heap at the Machorro mine (Martín Moreno et al., 2016). 

At  the  example  site,  the  objective  was  to  build  stable  (steady  state)  natural  landforms 
through  geomorphological  re-contouring  of  the  sand  and  clay  wastes  with  a  view  to 
maximize  the  natural  capital  and  Ecosystem  Goods  and  Services  (EGS).  This  fits 
perfectly with the Circular Economy paradigm of the European Commission, where the 
value  of  products,  materials  and  resources  is  maintained  in  the  economy  for  as  long  as 
possible, and the quantity of waste facilities is eliminated or minimised.  

2. Rationale for selecting as Best Practice 

From a legal perspective, the proposed solution is considered a best practise because the 
El  Machorro  mine  is  an  approved  rehabilitation  project  according  to  the  Spanish  Real 
Decreto 975/2009, de 12 de junio, in accordance with the EWD. 

From  a  technical  perspective,  the  proposed  solution  is  considered  as  best  practise 
because the monitoring of its performance over a 5-year period (2012-2017) has shown 
that  the  sand  and  clay  wastes  are  in  a  permanent  steady-state  way,  with  minimising 
sediment yield, runoff and suspended sediment concentration downstream (Zapico et al., 
2018).  All  this  was  achieved  without  the  use  any  external  capping  material.  This  was 
achieved by making an expert geomorphological design for recontouring the wastes with 
GeoFluv–Natural  Regrade  and  rebuilding  a  landscape  that  replicate  the  mathematical 
algorithms  of  natural  landforms.  On  top  of  the  re-shaped  natural  landforms,  topsoil 
removed from active areas of the same mine were transferred and spread. Re-vegetation 
was also carried out, based on an ecological  assessment. Therefore, as demonstrated by 
Zapico et al. (2018), this is an efficient alternative rehabilitation solution compared to the 
traditional  approach  of  graded  terraces  and  down-drains,  which  require  costly 
maintenance.  The  viability  of  this  practise  was  demonstrated  for  the  highly  erodible 
settings  of  slopes  in  Eastern  and  Central  Spain  (see  Martín  Moreno  et  al.,  2018),  but 
would be applicable to other setting across Europe. 

3. Environmental benefits achieved 

The main environmental benefits demonstrated for the El Machorro site are: 

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1) The need of constructing waste heaps at the mine is largely obviated. Such heaps have 
a  lower  stability  and  higher  visual  impact  than  the  re-contouring  in  the  mine  of  the 
waste materials. 

2) Safe  disposal  of  EW  is  ensured  from  short  to  long  term.  Not  only  the  geotechnical 
stability is  ensured in  this way, but  also  the stability against erosion by runoff water 
(the most common cause of instability at mine wastes heaps). 

3) Having  a  permanent  reduction  in  runoff  and  sediment  yield  from  the  rehabilitated 
areas, to levels equivalent to the baseline, minimises maintenance needs and impacts 
from turbidity and the dispersal of contaminants into soils and water. 

4) High visual integration into hill slopes and stream landforms that mimic the look and 

the functionality of nature. 

5) Maximising  biodiversity  and  natural  capital  and  EGS.  Geomorphological  restoration 
provides  diverse  and  complex  landforms,  that  become  diverse  micro-habitats.  At  El 
Machorro  many  seedlings  of  Pinus  nigra  subsp.  salzmannii  (priority  habitat  for  the 
European Union) and Genista scorpius have spontaneously colonised the recontoured 
surfaces.  The  evolution  of  this  landscape  will  allow  its  use  for  wildlife,  timber, 
mushroom harvesting or ecotourism, among others.  

6) Gaining  acceptance  by  the  public  and  regulators.  At  El  Machorro,  geomorphology-
based rehabilitation is strongly supported by the managers of the Natural Park and by 
the Environmental and Mining regulators of the Guadalajara province and the Castile-
La Mancha region. 

4. Economical aspects 

Re-grading  and  reshaping  existing  conventional  flat-toped  or  terraced  waste  dumps  to 
geomorphological  GeoFluv-derived  landforms,  plus  the  spreading  of  top-soils  and 
seeding, cost around 10.000 to 30.000 € per hectare. However, if this strategy is adopted 
right  from  the  beginning  of  mine  operations  by  progressive  rehabilitation,  placing  the 
extractive waste back into the excavated voids, so as to partially covering the highwalls, 
the reduction is  cost  can be considerable.  In fact,  if the the progressive rehabilitation is 
integrated  into  traditional  waste  management  operations  the  costs  will  be  close  to  the 
latter, but there is a clear saving in maintenance costs. The economic value of ecosystem 
goods and services  may  also  be considered, although they may be a value added to  the 
mine operation or off-set other detriments.  

Sediment  yields at un-rehabilitated areas within the same El Machorro mine are around 
292 Mg ha-1 yr-1 (Martín-Moreno, 2013). 

Sediment  yields  for  the  traditional  approach  of  graded  terraces  and  down-drains  at  the 
same mine are in a range of 10-20 Mg ha-1 yr-1. However, it is important to keep in mind 
that these terraces are recurrently damaged by gullying, showing that they constitute an 
unstable  landform  in  the  long  term.  The  reasons  for  gullying  are  either  run-off  from 

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active hauling roads or slope inversion due to sediment accumulation in the internal part 
of the berm. 

The  sediment  yield  after  the  geomorphological  rehabilitation  is  around  4  Mg  ha-1  yr-1 
(Zapico et al., 2018). 

The costs in terms of euros per hectare have not been calculated, but the mining company 
(CAOBAR)  has  reported  savings  in  the  order  of  of  55.000  €  per  year  compared  to  the 
costs of maintaining the graded terraces and the necessary sediment catchment ponds. 

5. Example of application 

El Machorro kaolin mine (operator CAOBAR), the María José mine (CAOBAR) and the 
Nuria  mines  at  Poveda  de  la  Sierra  Municipality  (Guadalajara  Province,  Spain)  and 
Somolinos  (Guadalajara,  Spain).  These  four  mines  have  the  same  typology:  contour 
mining  in  sand  and  clay  materials  located  at  the  slopes  of  the  ‘mesa  and  cuesta’ 
landforms of Central Spain. 

Figure  2:  Oblique  aerial  photographs  showing  the  geomorphological  restoration  of  El 
Machorro: A) at the beginning of the works, September 2012; B) once the first phase of 
the recontouring was completed (May 2014). Photos by Paisajes Españoles. 

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Figure  3:  Sequence  of  the  Geomorphology-based  restoration  at  El  Machorro.  Left, 
before rehabilitation (August 2012). Centre, after the geomorphological re-grading and 
top-soil spreading. Right, initial vegetation growing. Earthworks by Excavaciones Félix 
Moya, subcontracted by CAOBAR. 

6. Bibliographic references 

BALAGUER, L., ESCUDERO, A., MARTÍN DUQUE, J.F., MOLA, I., ARONSON, J. (2014): The 
historical  reference  in  restoration  ecology:  Redefining  a  cornerstone  concept.- 
Biological Conservation, 176: 12–20.  

MARTÍN-MORENO,  C.,  MARTÍN  DUQUE,  J.F.,  NICOLAU  IBARRA,  J.M.,  HERNANDO 
RODRÍGUEZ,  N.,  SANZ  SANTOS,  M.A.,  SÁNCHEZ  CASTILLO,  L.  (2016):  Effects  of 
topography  and  surface  soil  cover  on  erosion  for  mining  reclamation:  The 
experimental  spoil  heap  at  El  Machorro  Mine  (Central  Spain).-  Land  Degrad.  Dev., 
27: 145–159. 

MARTÍN-MORENO,  C.,  MARTÍN  DUQUE,  J.F.,  NICOLAU,  J.M.,  MUÑOZ,  A.,  ZAPICO,  I. 
(2018):  Waste  dump  erosional  landform  stability  –  a  critical  issue  for  mountain 
mining.- Earth Surface Processes and Landforms (accepted) 

ZAPICO, I., MARTÍN DUQUE, J.F., BUGOSH, N., LARONNE, J.B., ORTEGA, A., MOLINA, A., 
MARTÍN-MORENO,  C.,  NICOLAU,  N.,  SÁNCHEZ,  L.  (2017):  Geomorphic  Reclamation 
for reestablishment of landform stability at a watershed scale in mined sites: the Alto 
Tajo Natural Park, Spain.- Ecological Engineering, 111: 110-116. 

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4.9.3 Best Practice Example C: Stabilisation of reactive wastes 
1. Description 

Dolomite quarry and plant that produces various Ca-Mg-oxides, lime and dolomites for a 
wide  range  of  applications.  The  dolomite  is  subject  to  thermal  treatment  to  obtain  the 
oxide and residues are returned to the quarry. 

-  The processing of the dolomite into lime results in dusts of CaO, which are not inert, 

they react with water to give quicklime. 

-  Similarly, the settling basins from rainwater and surface run-off collection systems can 

contain quicklime and flue-gas dusts and are also not to be considered inert. 

-  The mixing of the various types of EWs and processing wastes leads to an stabilisation 
of the quicklime and the mixtures can be used for backfilling into the mined-out part 
of the quarry and other remediation purposes. 

-  The conversion process  of quicklime to  calcium-carbonate will cement the EWs and 

increases their stability. 

-  Top-soils and overburden are set aside for later use in remediation. EWs include also 

clays that occur in karst pockets. 

2. Rationale for selecting as Best Practice 

Stabilisation of reactive processing residues by mixing them with EWs. 

3. Achieved environmental benefits 

Long-term stabilisation of backfilled and heaped EW due to cementation by conversion 
of quicklime into calcium-carbonate. 

4. Economical aspects 

No information available.  

5. Example of application 

Lhoist, Usine de Neau (53) and Usine Châteauneuf -Les-Martigues (13) 

6. Bibliographic references 

LHOIST - CHAUX ET DOLOMIE FRANCAISES (2011): Plan de gestion des dechets inertes et 

des terres non poluées. Usine Neau (53) – Fiche PGD 20. 

LHOIST - CHAUX DE PROVENCE SACAM (2011): Plan de gestion des dechets inertes et des 

terres non poluées. Usine Châteauneuf-Les-Martigues (13) – Fiche PGD 27. 

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4.9.4 Best Practice Example D: Waste segregation for targeted deposition to 
reduce chemical potentials 
1. Description 

Careful mapping of the 3D-distribution of acid generating materials in overburden allows 
the  targeted  extraction  and  segregated  disposal  of  such  materials.  Materials  are 
preferentially  emplaced  so  that  they  are  below  the  water  table  once  the  mine  has  been 
flooded. 

Less pervious materials are used to cover potentially acid-generating materials during the 
operational  phase  in  order  to  reduce  the  ingress  of  meteoric  waters  and  atmospheric 
oxygen. Quick re-vegetation supports this process. 

Where available, calcareous material are mixed into potentially acid-generating materials 
before emplacement in order to add buffering capacity. 

Segregation and storage for later use is also routinely applied to top-soils. The storage has 
to be in a form that does not compromise the fertility of the material, e.g. the maximum 
height of layers should not exceed 3 m. 

2. Rationale for selecting as Best Practice 

The material-management measures address the acid-generation problem at the root and 
try to suppress it. 

3. Achieved environmental benefits 

Reduced groundwater contamination issues from acid rock drainage. 

4. Economical aspects 

n/a 

5. Example of application 

MIBRAG lignite mines in Saxony and Saxony-Anhalt 

6. Bibliographic references 

JOLAS,  P.  (2012):  Abbaustrategien  und  Ablagerungstechnologien 

laufenden 
Tagebaubetrieb.-  Presentation  at  Fachveranstaltung  VODAMIN/TPG/Pillnitz,  17. 
Oktober 
https://www.umwelt.sachsen.de/umwelt/download/MIBRAG_ 
Verkippungsmanagement.pdf 

2012, 

im 

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4.9.5 Best Practice Example F: In situ rehabilitation of EW to remove the 
source for metal contamination 
1. Description 

The Dalälven river basin was a major source for metal contamination entering the Baltic 
sea. As the major source mine wastes in the Falun area were identified. The pyrite cinder 
disposal heap, resulting from the sulfuric acid production plant in operation from 1850 to 
1993, was identified as the main source of Zn contamination in the Faluàn River. While 
large quantities of the cinder were sold as byproduct to the steel industry or used to fill 
mined-out voids, around 6 Mt were deposited on the surface.  

Cinders had been deposited over a deposition of slags, which provided a good drainage 
layer. The underlying geological strata of glacial till had a low hydraulic conductivity, so 
that a leachate capturing system could be installed in the downstream slags. The cinders 
were irrigated and the leachate pumped to a treatment plant at the surface. Excess clean 
waters could be released into the river. The treatment sludges with the metals precipitated 
in a low-solubility form were deposited back onto the cinder heap. Approximately 1500 t 
zinc, 26 t copper and 2 t cadmium were washed out of the pyrite cinder disposal site and 
captured between 1995 and 2006. The flushing resulted in a reduction of metal discharges 
by 94 % for Zn, 96 % for Cd, and 97 % for Cu. 

The cinder disposal site then was covered with a low-permeability multi-layer engineered 
capping  to  prevent  further  water  ingress  and  remobilisation  of  contaminants  in  the 
precipitated sludges. The glacial till cover reflects the natural soils in the area. 

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2. Rationale for selecting as Best Practice 

Long-term source term and vector/pathway supression. 

3. Achieved environmental benefits 

Reduction of contaminant discharges to the Faluàn river and the Baltic Sea.  

4. Economical aspects 

The in situ flushing and capping construction costed 6.2 M€ and 1.1 M€ respectively over 
the period from 1993 to 2008. This is equivalent to a rehabilitation cost of 6.4 €/t or 11 
€/m3. 

 5. Example of application 

Falun historic mine site and World Heritage Site. 

6. Bibliographic references 

f.d. 

HANÆUS, Å., LEDIN, B. (2010): In situ tvättning av kisbränderdeponin i Falun.  Åtgärder 
svavelsyrafabriken.-  Rapport  6400  Naturvårdsverket,  Stockholm, 

vid 
http://www.utslappshandel.se/Documents/publikationer6400/978-91-620-6400-6.pdf 
(accessed 16.05.19). 

HANÆUS,  Å.,  MATTSSON, E. (2009): Remedial  Measures Taken at  the  Falun Mine Site, 
Sweden.-  Proc.  8th  International  Conference  on  Acid  Rock  Drainage  (ICARD)  and 
Securing  the  Future:  Mining,  Metals  &  the  Environment  in  a  Sustainable  Society 
2009, Skelleftea, Sweden, 22-26 June 2009: 1617-1628. 

WESTERSTRAND,  M.  (2009):  Remedial  Measures  Taken  at  the  Falun  Mine  Site.  A 
Summary  of  “the  Falun  Project”  1992-2008.-  https://tinyurl.com/y4hdyo7f  (accessed 
16.05.19). 

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4.9.6 Best Practice Example G: Integration into Natura 2000 and World 
Heritage regions 

1. Description 

The  proposed  Best  Practice  concerns  to  the  Tállya  Andesite  Quarry,  which  is  located 
within  a  Natura  2000  area  and  the  UNESCO  Tokaj  Wine  Region  Historic  Cultural 
Landscape  World  Heritage  protection  area.  The  estimated  reserves  are  around  50  Mm3 
andesite  (of  which  about  450,000  m3  will  become  EW)  in  a  mining  concesssion  of  ca. 
100 hectares. 

Since  2014,  the  quarrying  company  undertook  a  large  scale  landscaping  project.  More 
than 170,000 m3 of EW waste were moved and more than 4,000 trees and 6,800 bushes 
were planted to landscaped two big waste dumps next to the quarry and near a village. A 
specialist firm was consulted due to the Cultural World Heritage protection status of the 
region.  The  EWFs  were  contoured  to  match  the  surrounding  landscape  (hills,  valleys, 
slopes, etc.) in order to match the World Heritage expectations, because the landscape is 
one  of  the  most  interesting  attribute  of  the  region.  Selection  of  tree  species  and  bushes 
was  carried  out  in  consultation  with  the  national  park  and  the  nature  conservation  and 
heritage conservation authorities.  

Under the current authorisation processes, the quarrying company undertook a complex, 
life-cycle  assessment,  taking  into  consideration  the  available  raw  material  reserves,  the 
mode of production and the handling of the EW. The planning horizon went beyond 15 
years though the maximum permit period in Hungary is 15 years. 

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With a significant investment into exploration (about 1,250 meters of drilling and a large-
scale geophysical study) the company was able to delineate the marketable material and 
to  determine  which  part  would  become  EW.  This  exploration  allowed  to  estimate  total 
the life-time quantities of operational EW. An extension licensing Process is under way 
that  also  encompasses  procedure  to  achieve  consensus  with  the  relevant  stakeholders, 
such  as  the  municipality,  the  national  park,  environmental  authorities,  the  nature 
conversation  authority  and  certainly  the  World  Heritage  Centre.  As  for  the  two  other 
EWFs a compatible landscape will be created including specific lean meadows on silicic 
rocks (silicate swards). A specialised consultant was commissioned to prepare these plans 
to be compatible with the World Heritage Centre requirements. 

2. Rationale for selecting as Best Practice 

This  practice  is  considered  a  Candidate  Best  Practice,  because  it  specifically  addresses 
the following points from the EWD: 

  Article  5  2.(a)(i):  During  the  design  phase  an  EWM  strategy  with  a  life-cycle 

management perspective was developed; 

  Article 5 2.(a): With the help of geological exploration the total life-time quantities of 

EW could be estimated; 

  Article 5 2.(a)(iii): The landscaping activity implemented and planned can be seen as a 

special form of back-filling; 

  Article 11 2.(b): The waste facility will be constructed such as to ensure its physical 
stability and to minimise damage to landscape. The implemented and also the planned 
landscape construction activites are supervised by geotechnical experts and will meet 
with the requirement of World Heritage Centre. This is also in line with the provisions 
of Article 1. However, after the integration into the landscape and the completion of 
the re-vegetation, the site will not be considered an EWF anymore; 

  The  sum  of  the  above  activities  ensures  the  long-term  minimisation  of  negative 

environmental and landscape effects. 

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3. Achieved environmental benefits 

The benefits achieved include: 

  The landscaping project is expected to increase the acceptance of the continuation of 

quarrying by local stakeholders; 

  The amount of EW produced could be reduced and, hence, the volume of the EWF; 
  The landscaping will include the creation of look-outs  and view-points  in support of 

the regional tourism industry; 

  Revegation with indigenous tree and bush species will help to maintain the ecosystem 

value of the surrounding area; 

  By  going  beyond  what  is  the  minimum  regulatory  requirement  it  is  hoped  that  the 
quarrying  project  will  find  a  more  positive  reception  by  regulators  and  the  public 
alike. 

4. Economical aspects 

Since 2014 more than 400,000 EUR have been spent on the landscaping project (works 
and design fees). The savings are not directly measurable in monetary terms, but due to 
the  higher  acceptance  by  the  public,  the  regulators  and  the  Word  Heritage  Centre  will 
help to extend the life-time of the quarry. 

5. Bibliographic references 

n/a 

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