.--L South Pocific Regionol Environm€nf Progromme ft -- Ittltt-'r'tl SPREP Reports ond Studies Series no, 95 WJ:
Environmental lmPact Hffi Assessment Guidelines for Mine DeveloPment and ffi Tailings Disposal at Tropical Coastal Mines
ar'' -il
South Pocific Reglonol Environment Progromrre
Environmental lmpact Assessment Guidelines for Mine Development and Tailings Disposal at Tropical Coastal Mines
Prepared by Derek Ellls Assisted by Jacquellne Connolly SPREP Librry Cataloguing-in-Publication Dara
Ellis,Dcsck Erwironmental impact ascsmcot guiddinca fq minc dcrrclopment 2ad t.ilingr dispod et topicel costal rnincs / grcprrcd \ p6d Ellir ard **itt"d bJ.cqudinc Connolly. - Apie,Vftstcrn Samoa : SPREB 1996.
viii,26p. : 69., placcs, ublcs : 29 can-
ISBN:982-04-0150-X
1. Environncntal impact rtetcmens.2. Mincs and rnincrrl rrsouroae - Erndrronmcnal aspccs, 3. Erwironmcnal monitori.g- I. C.onnolly, Jacquclinc. II. South Pacific Rcgiond Environmcnt Prognmmc. IV Tida
333.765 kcprrcd for putilication by thc South Pacifc Rcgionel Ernironmcot kogrlmmc, PO Bc 24o,Apb,Wcrtcrn Samoa
@ South PacificRcgiorrl Environmcnt Plogrannc, 1996
Thc South Pecifc Rcgional En'ironncnt Plogrililnc authcbcs thc rcproduction of tcmud netcrid, wholc or parq in any form, providcd approprbtc acknorlcdgcmcot b gi\r€o.
Original 3srt; F'ngfirh
Editor Barbare Hcason
Production Pctcr Erans
Photographs Plare I (covcr and p.4) reproduced with permission of Island Copper Mine, BHP Minerals Canada Ltd; platc 6 (cover and p.6) and plate 5 reproduced with permission of Placcr Pacific Limited,
Typeset in I l/13 Bembo and UR\7 Casde Printed on I l0gsm Tudor RP. (100% recyded) by ABC Printing, Brisbane, Australia Printed with finaocial assistance from AusAID
Covcr photographs Top:The seale of uwu produaionfmm ninitg and milling prouses an be enotmorn, Hererun see the *uste mck dunry anil their redamation at klanil Coppa Mine, Canada. Tlrc tailings aft undcrunta. Bottom: A seaunter-mk de-aention tank for submarinc tailings dischatge. . Contents
Acknowledgements v List of participants, mining wot*.shop, Solomon Islands, March 1992 vi Executive surnmary vii Part One Mine development and ailings disposal I 1 Introduction 3 1.1 Overview 3 1.2 Production of teilings: the mining-milling prccess 3 1.3 Environmentd risks 7 1.4 Regulation and these Guidelines 8 2 Description ofprocedures 10 2.1 Orrerview 10 2.2 Exploration 10 2.3 Development: Feasibility essessrnent 11 2.4 Development:Blueprinring 12 2.5 Development: Construction and commissioning 13 2.6 Operations 13 2.7 Closwe 14 3 Numericd guidelines 16 ReGrences 20 fart Tlvo Environmental questionnairres 2l keliminary information to be compiled by the Regulatory Agency for a mine development 22 Preliminary information to be compiled by an applicrnt for a mining licence n Tables 3.1 Guideline vdues for trace metals (ppm, dry wt) and per cent incidence of biological effects in concenrradon ranges defined by the values,ERL and ERM 16 3.2 DnIt Canadian Guidelines, and incidence ofadverse biologicd effects in concentration ranges defined by values for marine sediments,TEL end PEL 18 3.3 Draft Canadian Guidelines and incidence of adverse biological effece in concentration ranges defined for fresh water sediments 18 3.4 Sediment criteria for six elemental conteminants derived from water qualiry criteria and equilibrium partirioning coefticients 18 3.5 Guidelines for marine sediments comparing vdues from Thbles 3.1,3.2 and 3.4 19 FiSre 1..[ Un#prodmodfrsntrrntihg 4 5.il ffie pomthl ftir bicilqeic{ldbm of sfinwt+-odra-d erohmibns, rcgtt'dinshc US. hlAdonct$st-{s,$ndftrdslhogreru tl?
! te'hnlll-9ffi6r,@a,er+qt Heq&,iE&r €dualoi*G*udh il 2 lfrinepitb uimeriormlley 5 t Imprct oftriling dbcbrryo m e rirer rnnlky 5 *'EdlfugF,erfr.Eggattheialcdg$ 6 5 Anincp"-irmgrtncdfiar:rEdi6 E 6 6 :Seam[Gr-frirde-@sion grnlsfor G tdlhgFri :6 Acknowledgements
The development of these Guidelines was funded initidly by the Canadian Inrernational Development Agency (CIDA) througb the medium of a grant for a Tiaining Programme in Marine Pollution Assesment and Control to the Univetsiry ofVictoria, Canada and the Universiry of the South Paci6c, Suva, Fiji. This grant allorved presentation of a workshop on the marinc impact of coastd urd island mines rt Honiua, Solomon Islands,2{ March 1992.The workshop was facilitated by cooperation with the Gwernment of the Solomon tslands and the South Pacific Regional Environment Programme (SPREP)- Subsequencly, SPREP was able to fund the updating and formalising of these Guidelines byJ. Connolly.This was ca6ied out under the supervision of D. Ellis, made available by the University of Victoria. The authors are pleased to acknowledge this agency support in dlowing derrelopment of these Guidelines. The authors are also very grateful for the cooperation of parcicular individuals. We acknowledge first Mr Komeri OnoriqEnvironmental Impact Assesment Ofrcer of the South Pacific Regional Environment Programme (SPRXP)' who coordinated arrangements for the Honiua workshop and facilitated arrangements for completion of the Guidelines. We dso thank the puticipants of the workshop, and the Solomon Islands public s€rvants who assisted in the organisation. Several of D. Ellist asociates and correspondents have conributed over the years much background information which has been incorporated into these Guidelines. These asocietes include a series of environmental managers at coastal mines, particularly C. Pelletier, R. Hillis end [. Horne at Island Copper Mine, Canada and G. Murray of Placer Pacfic Ltd. E. Long of the US Nationd Oceanographic and Atrnospheric Adminisnation (NOAA) has provided end updated information about numerical guidelines under development in the United States. Profesor G. W Poling of the University ofBritish Columbia, Vancourrer, Canada has been a frequent source of mine-milling informetion over the past tw€nty-five years. List of Participants, Minlng Workshop, Solomon lslands, March 1992
Narua Lorni, Departnent of Environment and Conserrntion, Papua New Guinea Venasio Nasara, Department of Mineral Resources, Fiii Kolinio Bula, Department of Mineral Resources, Fiji Charles Vatu, Environmentd Unit, Ministry of Natunl Resources, Vanuatu Simon Koke, Ministry of Agriculture and Lands, Solomon tslands $I) Bernard Telei, Environm€nt and Conservation Division, SI Rosemary Kinne, College of Higher Education, SI John Warden, College of Higher Education,Sl Alex Makini, College of Higher Education, Sl Robinson Fugui, Chief, Environmental Hedth Division, SI John Korinihana, Environmentd Hedth Division, SI Ped Shanel, Gold zudgg Landowners Representatirc,Sl Nicholas Biliki, Geology Division, Ministy of Natunl Resources, SI Don H. Tolia, Geology Division,Ministry of Natural Resources, SI Moses Biliki, Minisny of Education and Human Resources,SI Henry Isa, Erwironment rnd Conservation Division, SI Instructors Dr. D. V Ellis, Univesity of Vicoria, Canada Dr. P Hupbes, Kinhill Engineering, Darwin, Australia Executive Summary
Disposal of tailings constitutes one of the most are: Exploration, Development (Feasibility signiEcant areas of potential environmental risk Asessment, Blueprinting, Construction and associated with coastal end island mine Commisioning), Operations and Closure. development. These Guidelines provide These Guidelines proride checklists of action nerrative and numericd targets ficr ficr each stage. environmenrd protection during the Numerical guidelines are prorided for a suite of development and operation of coastd and island cornmon metd contaminants. These are based mines that may discharge tailings to the sea. on values cdculated from case histories in both The Guidelines are targes in the sense that the United States and Canada, and &om a mine developers and operators should aim at theoretical procedure, Equilibrium Partitioning their achievement. They ate not standards and (EP) rney not be attainable under all circumstances. The Canadian and US date provide nvo sets of lt is recognised that site-specific, environmentd, values:(1) below which toxic impace are mining and other technical or socio-economic unlilcely; and (2) above which such impacts are factors may require adjustments at particular likely. The EP method cdculates a sediment sites, and that these rnay be either more or les vdue in equilibrium with the pore water so constraining on operations. These adjustments that water qualiry criteria are not contravened. must be supported by detailed information. There can be substantial differences in the values calculated by the different Mine tailings can be disposed on land, to rivers, Guideline methods. The rnlues to be used at a particular and to the sea. Discharging deep into the sea site must be decided by the Regulatory Agency. cen,at some locations,minimise some of the environmental risks, particularly los of land, Tho other questionnaires are also provided. displacement of people, and the threat of One is for administrative information and conamination of productive land and river should be compiled by the relevant Regulatory fisheries.Impacts on marine fisheries and other Agency. This list includes information such as marine resource use can be minimised by releramt regulations, per miaing procedures, site-specific placement of a tailings outfall. This other involved government agencies, and locd will be designed to gener:rte a coherent densiry resource owners and users. The second current flow of tailingt to a final deposition site questionnaire details the kinds of specific from which there will be no reactivation into informadon which a Regulatory Agency will the water column. require from a developer in the preliminary stages of a posible mine development. This In the development of a mine,the developers, can also be modi6ed, and go/ernment regulators and involved citizens questionnaire completed by mines dready operating' so that must be prepared to obtain and review a series Regulatory Agency files can be periodicdly of sets of information, end to proceed updated. sequentially in a series of stages. These stages
Part One
Mine Development and Tallings Disposnl
1 lntroduction
1.1 Overview
The objectives of this document are to Chapter 3 (Numerical guideline$ provides summarise knowledge about tailings disposd in copies of environmentd guidelines for the tropical coastd areas,provide key technical mining industry compiled from several sources. references, and prwide checklists of appropriate These tables should be used as checklists action for mine development in the South indicating environmental risks about which Pacific region. informarion is needed prior to decisions permining r mine to proceed This manual is divided into two parts, with Part One conteining the *ree main chapters. Part Tbo consists of wo environmental Chapter 1 (lntroduaion) oudines the basic questionnaires. One details edministrati\re mining and milling processes and the associated information to be compiled by the relevant production of wxte rock and tailings.lt also Regulatory Agency.The other details the kinds provides a broad oudine of environmentd risks of specific informetion which a Regulatory commonly associrted with tailings disposal; Agenry will require from a developer in the licensing procedures and the gathering of p'reliminary stages of a posible mine environmentd data; and other regulatory issues. development. As noted in the e:ccutirre this questionnaire can dso be Chapter 2 (Description of procedtnes) describes surrunary, modiEed for use by operating mines. che sequence of actions to be taken by a mine developer and a Regulatory Agency at each of the main stages of mine development ftom exploradon to closure.
1.2 Production of tailin$s: the mlning-mllllng process
The mining process for metd exuaction usually called tailinp, and must also bc placed consists of two parts: mining and milling. The somewhere nearby or otherwise disposed of. mining component is the extraction of The scale of rhese two types of waste metal-bearing ore from rock. The nilling production can be enormous and is illustrated component genenlly crushes, grinds and by tsland Copper Mine in Canada (Plate 1). For extracts a concentrate in a series of mechanical every tonne ofcopper concentrate produced, and/or chemical processes. ebout 50 tonnes each of waste rock and tailinp
Figure 1 .1 illustrates these two processes. It also have to be moved away from the shows that at both suges waste is produced mining-milling proces.Island Copper et peak Mining dmost always involves the extraction of operation exracted about 90,000 tonnes per unwanted non-metal-loaded rock in order to day ofrock and ore, to Produce about reach the ore. Such waste rock has rc be placed 1000 tonnes per day ofconcentrate and somewhere nearby. 48,000 tonnes per day of tailings. The bdance 41,000 tonnes per day was waste rock- Milling produces large amounn of finely of about Plate 1 shows the waste rock dumps and their ground waste from which the metd reclamation. The tailings erc underwater- concentfirte has been separated This waste is EIA Mlnlng cuidelines
jr ,'l,r
Plate 1 Island Copper Mine, Rupert Inlet, Bitkh Columbia, Canada
MILL
TAILINCS CONCENTRATOR t_r_
Figure 1.1 Wate produeedfrom mining lntroductlfri 5
Plates 2 to 4 show hov the Pit at Key reference Boupinville Copper Mine The process of milling and triling production is dacribed by (PNG) is situated within a rnlleY, G.\[I Poling in an ar-ticle within a 1995 review of taihngs with ailings discharged to a disposal at coasal and island metal mines' The whole rerdew river. The Bougainville mine Submaine Thikngs Dispoul, is referenced throughout these produced 80,000 tonnes of weste as (1995). It compriscs vol' 13, combined Guidelines MG&G rcck rnd 120,000 tonnes of issues land 2 of Mwine C*oresourcs ud C*otahwlogy,andis tailinp each day. Plates 5 and 6 arnilable ft,om the pubtishen Thylor and Frurcis, Suite 101, 1900 shornr a smdler mine, extracting Frost Rd, Bristol, PA, USA 19007,Fa:c 215785 5515. All gold and silver, producing agencies interested in mine derclopment should obuin a copy of tonnes of ailings daY. this rcview and use it as a rcference docurnent in associadon 15,000 Per with these Guidelines,
I{ate 2 A nitnpilin an i*riuulleylus mwcillandfom otha nsowu nse at least toryoraily.
Plate 3 A river hahm useilfor uilings disrharye,and tlu Ioil,cod.Wflb he wlley. 6 EIA Minlng Culdelhes
PIae 4 At the sea edge. Without on engineerd outJall dkharging n depk (see Plat 6),uilings will spread and have a signijtant inryaa on tfu cawtline.
Plate 5 A mine pit engineetedfu rqLamation.
F-_
PIue 6 A seauaur-mix de-aetation unk Jor subtnarine uilings discharge. T t Dr, fntroductlqr 7
1.3 Environmental risks
Overvlew Guidelines concentrate on the environmentd risks in tailinp disposal. The environmental risks associated with the disposal of mine tailings are considerable. Placing rast quantities of waste rock or tailinp Common methods of tallln0s dlsposal in the envirorunent smothers habitat, changes and assoclated envllonmental llsl$ wetercourses and displaces people. It can Tirilings are usually disposed of in contaminate air, land and water, and otherwise the following weys: affect neighbouring and especidly downstream uses. Low-grade margind ore may be 1. Raurrcil to pit,or undagnunil.With this stockpiled for eventud use but at 6nd closure method, tailings are retwned to their source. may remain unused, hence wasted and also However, as the volume of rock increases occupying land. following milling, not dl of the teilings can be returned to the pit or underground. These and other erwironmental risks must be eliminated by good engineering, or at least Impouwlment behind a dam on land. With this minimised (mitigated) to levels acceptable method, useble land is covered, and in areas socially-to the local people and to the nation. with high earthquake risk and torrentid rain there is high risk of collapse. Generally it needs a weter cover to minimise Acid Rock prlnclples of Guldellnes undertylng Drainage (ARD), that is, engineering into The mitigation principle adopted in these an rtificial lake or reserrroir (see MG&G Guidelines is that any social costs must be 199s). minimal. They must be minimd in the short term, while the mine is being developed, built Engineering asociated with drm impoun&nent end operrted. They must be minimd in the is described by Caldwell and Vblsh 0982) in changes long term, in the sense of cosdy social the book, Marine ToilingsDfsposal. Although this continuing after closure of the mine. The book is now out of print, a limited numbcr of Guidelines accept a number of operadonal copies are arailable ftom the South Pacific principles: Regional Environment Prcgnmme (SPREP), interested parties on 1. The mine will exist fot a predicted period and can be obtained by The u-ticle describes engineering for of time, efter which land may be reclaimed, rcquest. ailinp diryosal in "rugged,high prccipitation although not necessarily for the srme use as environments" in the United Sates and Canada, before. and modifcation has to be made for application 2. Financial compensation to affected persons to the tropical conditions of the South Pacific. may be able to ofBet distuption of people's use of land, and/or their displacement. with unontrolleil ilkpersal 3. The costs of government action through its 3. Discharge to a river, has Regulatory Agency can be borne by the dounstream.This disposal method usually due to industry concerned by taxation, fees or the greatest environmentd impact, during levies through an appropriate 6scal channel' lack of control of evenrud spread downscream flooding, and the highest risk of Environmental risk and mitigation procedures ARD due to weathering. Bougainville in the disposal of waste rock are well known to Copper Mine prorides an example, from the the mining industry. Essentially, the risks consist South Pacific region, of the envLonmentd of smothering habitat, changing watercourses, risks associated with river disposal of tailinp loss of other resources, and contamination. The (see Plates 2 ro 4). scde of habitat smothering,hence miugacive lalee . a lake of sufEcient engineering and/or compensation needed, can 4. Discharge to a tf can be considered as be readily identiEed. The scale and nature of volume is a',railable, this design contamination and loss of resources are far les a means of ailings disposal. Outfall effects of readily idenriEed, but must be attempted. These can minimise the almost inevitable I EIA Mhhg Guldellnes
water turbidity and loss of uses during gmvity (as a submarine river) to a discharge. Long-term contamination may be designated final, stable deposition site. reducible so that uses can be restored after In generd, this site will be deep underwater, mine closure. below the shallow water producrive fisheries zone. The point, 5. Dscharge to the sea. Dispoul of teilinp to the discharge the llow of sea from island and coastal mines can tailings and the 6nd deposition site must minimise environmental impact, provided have minimal risk of being disturbed by an outfall is suitably engineered to discharge turbulence, resuspension of teilings, and (see tailings as a densiry current llowing by upwelling to surface Plate 6).
1.4 Regulatlon and these Guidellnes
Overvlew environmental data gathering (in bluepr inting phase),leading to a 6nal licensing decision. Guidelines are statements of desinble actions and targets. They are not objectives, strndards or I regulations to be enforced They are stetements With thk sequetring, mine darclopers un bring which proride information to any interested readily awilable irformation togethufor the parties about environmentd risks. prelimircry decision (approval in principle). IJ this is then the more time-ansuming This manual prwides guidelines for use in the Jawunble, anil expensive procedure of gathuing site-specific South Pacific region by Regulatory Agencies environmental data gathuing un proueil. and the -ioirg indusny.It is orpected that they will also be read and used by interested citizens Environmentel Impact Assessments @Ifu) are as checklists ofpotentid actions. The Guidelines to be undertalan by the mine developers (for are ficr use in the following: mine proposals and during explorarion) or by r Developing and reviewing applicxions for their consultants. Before development is finally mining exploration licenses licensed, a formd and comprehensive o Developrng and reviewing both prelimirury Environmentd Impact Assessment @IA) should and detailed proposals for new mine have been compiled and made available to the dwelopment Regulatory Age.rry and to the public. Each nation's Regulatory Agenry can decide how to r Writing and reviewing Environmental use the information prwided at any stage in the Impact Assessments (EIA$ at operaring mine development. mines Environmentd data are also needed from mines in operation. This may be available already from procedures Sequence of the mines, or more may be needed. Extra for mlne derrclopment informarion may be available on a voluntary basis, or may require appropriate new legislation The principle is accepted here that or regulations. environmentd protection procedures should be sequenced. Following approvd of an e:rploration license, dwelopers of new mines uslnll these Guldellnes should collate arailable environmental Copies of this manud and the asociated information (feasibiliry report) for a factsheet are arailable from SPREP to: preliminary decision by the Regulatory Agency whether the development is environmentally . applicants for e:iploration licences viable in principle. o mine developers and operators Second, if the preliminary collation indicates . all government agencies with an that environmentd impacts arc potentially involvement in the licensing process acceptable and able to be mitigated, e the public, especially representatives or requirements can then be set for detailed, new landowning or land-using communities. lntroducilm 9
At any mine deralopment, representatirres of the meet Regulatory Agency costs for appraising industry, the Regulatory Agencies, and user the development. It may be necessary to communities should expect to meet routinely introduce new legislation or regulations to for discussion of the rarious items and of require this. The ftrnds prordded may be by a progress in their implementation. gant directly to the Regulatory Agency, or by some other procedure following government accounting practice. The Regulatory Agency other rellulatory tssues can then dispense the funds to nrcet strffcosB, Separation oJ responsibilirres. In generd, it is or the costs of contrecting out the reviews and desirable to have the environmentel Regulatory site visits to their reained erwironmentd Agency in a ministry seperate from the ministry consultants,or some combination of these two responsible for mining development and worket procedures. safety. This is so that the balance between Expaiena in mirc ilewbpment anil regulation.lt economic development and long-term should be noted thet there is considerable environmental damage with costs to the nation experience with mining derrelopment and may be considered at the ministerial lerrel. regulations in Papua New Guinea, and within Expmise in rqulatory raiant, anil arilr,ciateil asts. the umbrella organisation of the South Pacific The Regulatory Agency may wish to retain Regiond Environment Programmc (SPREP). environmentel consultants to conduct a part or Countries with litdc prior experience in mine all of its reviews. The consultants retained development can &aw on this experience by should have prior experience with mining EIAs having their Regulatory Agencies contxct in the tropics. experienced officids from Pepua New Guinea Note that a mine derieloper can be required to end SPRXP 2 Description of Procedures
2.1 Overvlew
The development and operacion of a mine has 5. Operations six stages: 6. Closure 1. E4ploration The procedures and responsibilities relernnt to 2. Development Feuibility asses$nent the dweloper and the - Regulatory Agency rt 3. Derrclopment Blueprinting each stage ofthe process are described in the - following sections. 4. Development Construction and commisioning-
2.2 Exploration
Responslbllltles of the Oeveloper Responslbllltles of the Regulalory Agency 1. Applies for an erploration licence, and provides preliminary information on 1. Receives application for the explorarion existing landonrners and resource users in licence. the area under rpplication. 7 Provides applicant with copy of mining 2. Receives copy of mining ervironmentd envilonmentd guidelines. guidelines. Approves or rejects application for an 3. Cooperates with the Regulatory Agency in exploration license following established consultation with landowners and resource procedures, including consultation with and us€rs. approral from (with compensacion if 4. Receives or is refused exploration licence. necessary) any affected land users. 5. Complies with requirements if the licence is 4. If approral is given, applies usual nationd received. licensing conditions, including requirement (if appropriate) not to disturb specific wetercourses or downstre,un users. -Note: Contrawntion of an acploration litcnn will give a poor impression reganling the holderl commitment to following guidelines for a @nsequent mine. Desslptlon of Proedures tt
2.3 Development: Feasi bllity assessment
weather daa, relevant hyddogical daa, Production of a feasibility report, contairung - marine current and tidal data, and a conceptud mining plan and a preliminary identfies sources of information g ernrironmental screenin preliminary models ofwaste disposal, - including dilution, dispersion and assimilation of liquid wastes, identifying Responslbllliles of the Developer e'.'entud regions of final deposition (for 1. Develops,r conceptual mine plan and a - inventory of other local resources preliminary Environmental I mpact example , other minerals,fisheries, gardens, identifies are Assesment (EIA) for a feasibiliry report, sago stands, etc.) and which risk identifying sources of previously available at information and any new data obtained. The basic ecoryEtem parameten including - plant feasibility report: relevant envir,onmenul propenies, and animal communities, and endangered describes ore body; its extent and chemical species composition inventory ofsites of tnditiond imporance describes expected milling and - to locd residens concentration processes, idendfying process 2. Provides initial funds for needed actions by chemicals in general tetrns, and mill location the Regulatory Agency. identifies sources of water for mine use and 3. Explores with communiry representatives rates of remoral, and provides relevant the form of a commwrity review group to hydrologicd data on the water sources meet routinely during development and identifies power demands and energy operations. sotrrces (for example, hydropower, oil 4. Prepares the feasibiliry report and submits it generation, etc.) to the Regulatory Agency. This is to include V identifies general location ofaccess roads, an o
2.4 Developffi eflt: Blueprinting
pre-operational data from each sampling Development of detailed min-g plan with station ern'ironmentd tisks identified rnd remedial action proposed ? provides a detailed monitoring plan, describing parameters to be measured, methods of measuring, and personnel to Responslbllltles of the Deilrcloper undertake the monitoring. Estimates costs based on documented cost experience, De"'elops a detailed mine plan; gpthers, l. including costs to the Regulatory Agency information assembles and reports deailed for its review of monitoring data to support the design. This deteiled mine ? details environmentd constraints to be plan: implemented during corutruction and plant identifies wxstes based on pilot ore commissioning processing tess (including chemical provides remedid plan for socid impacts, composition and rates of p,roduction),total including relocation proposals and waste production during mine lifetime, rnd compens:rtion if appropriate expected major changes in type and rate during mine lifetime describes concept for eventual closure plan, including the types of habitat and resource details water e:ftraction systems specifying use as reclemation objectirres sources, e)draction procedures, pipelines, rates of use with expected changes during identifies plans for reclamation of impacted mine lifetime. Updates initid try&ologicd areas, with details of start-up timing and data previously provided procedures V deteils uaste disposal systems including Conducts initid community group design of pipelines, out'alls, tailings dams meetinp. Documents meeting proceedinp, and emergency ponds resource uses, and formal social impact esses$nent $rveys where conducted. details energy demands through mine lifetime, and provides deteiled plans for 3. Reports environmental &ta in the form of meeting energy demands,including a comprehensive EIA one year prior to necesary construction. desired start-up date. details receiving areas for wastes, and updates 4. Provides further funds to meet costs of weather and tidd/current data Regulatory Agency reviews. describes ARD generation potentid and Responslbllltles of the mitigation meesures Regulatory Agency provides detailed model ofwaste dilution, dispcrsion and assimilation, identifying final 1, Reviews all documents provided, and may deposicion of wastes, relative amounts in request fitther information for final different locations, environmentd decision whether mine may proceed or not. ., destinetion of toxins, and risks of De6nes impacts of concern and specilies resuspension and reactirntion environmental conEols (for example, provides detailed pre-operationd inventory location, rates and composition of waste of resources at risk, with appropriately timed discharge$. measures of seasonal variability. This 3. Reviews and approves details of tailinp monitoring of variabiliry is to be initiated disposal system (for example, to sea by two or more years in advance of pipeline, or to land with a tailings dam). construction. Results are to be presented in 4. Identifies remedid action needed and a form which allows subsequent comparable compensation costs, and estimates own costs monitorin g dur ing operacions for action. demonstrates comparison procedures by 5. Idenrifies any further assessrnents needed showing changes between sets of Descrlptlon of Procedures l3
6. Identfies environmentd constreints during frequency. Normally, only toxins of concern construction and commisioning. will need monitoring on the initial day of Corctruaion orstraints. Sneams and river discharge, and thereafter weekly. Bioassays disturbances to be minimised. Where may be required if toxins exceed operationd tempofilry diversions and turbidiry increases limits. are inevitable from construction, then 7. Approves the detailed design plan, or makes licensed timing of such disturbances should find decision to deny the development. be specified. (Any permanent diversions, Approval provides for authoriry for the turbidiry increases, etc. need downstream Regulatory Ager.y to suspend operations user approval, and compensation as part of immediately if constraints are violated, with the approval process.) appropriate apped procedures. Commissioning onstraints. Defines toxin monitoring and bioassays, and specifies
2.5 Development: Construction and commissionin!i
3. If constreints are violated, uses authority to Construdion risk include changing flows of stop construction immediately. streerru and rivers, hence causing downstream impacts. Commissioning risks include release of wastes at levels in excess Commlsslonln!l of those permitted during operation Responslbllltles of the Developer Constructlon 1. Undertakes liquid waste toxin monitoring as required Responslbllltles of the Der,elopel Responslbllltles of rhe 1. Ensures that the contractor follows Reoulatory Agency erwironmental constreints imposed. 1. Makes site visits and documents by Responslblllrles of the photographic record, etc. Regulatory Agency Checks for 6sh kills or other resotuce loses 1. Makes site visits and documents by and social consequences. photographic record, etc. If constraints are violated, uses authority to 2. Checks for watershed changes or other stop commissionin g immediately. resource losses, and social consequences.
2.6 Operations
solids content (weekly), specified dissolrrcd The mine operator monirors the toxins (monthly). Monitos tailinp ernrironmental impact of operarions. The disposition (monthly) by chemicd suggested frequencies initid below should parameters, cores, sonar, etc. be modified after experience of operations. Waste ruk (marginal ore) Records deposition rates (daily),maps Responslbllltles of the Operator - locations (quarterly), tests ficr ARD and 1. Undertakes all monitoring and reports. sources (monthly).
Thilings Resowce impacts Undertakes 6sh bioasuys (monthly), Habitat.Measures dispersion and dilution - qf tailings - measures flovv rates (dailv), suspended plume, turbidity, dissolved t4 EIA Mlnlng Guldellnes
metals, r'ilinS resuspension treps Rqoiling and raiars (querterl9 - Reports quarterly, plus immediate reporb Spills. Immedirtely assesses extent of spill of any contravention of controls. Mees - of any process chcmicals and repora to the annudly with rcgulaton to discuss RegulatoryAgenry environmenul concerns and negodate Fisheries.Documens yields, numbers, size, annud funding for Regulatory Agency - tisue bioaccumularion of trace toxiru. for selected species (quarterly) Responslbllltles of the Reguldory Aoency - knsystem. Benthos and plankton: measures standing crops, primary production rates, 1. Reviews reports, and acknowledges receipt sediment toxin lerrcls, bioass:ry/s, of reporting. bioaccumulation of trace toxins for 2. Undertakes spot tess of any monitoring selected populations, at selected sites and parerneter. times 3. Underukes spot checks of any monitoring Reclamation procedure. Documents ongoing reclamadon, 4. Requires reviews of operational, monitoring - including new arleas initiated, and monitors regrowth (quanerly). or reporting procedures. 5. Requires changes in operational, Community ra) iat) group monitoring or reporting procedures, Holds meetings as agreed,hears comments, including changes in their frequenry. - documents proceedings and negotiates setdement of issues raised
2.7 Closure
Temporary closules Provides closure plan to Regulatory Agency for review and negotiation of closure bond. May be required for maintenance, The closure plan has as objective the inraentory reduction, etc. reclamation of land and waste deposits to productive resource use. The bond is to Responslbllltles of the opentor cover costs of eny remediation subsequendy needed. 1. Monitors relennt ernrironmentd changes Monitors recovery daily. 3. Habitat. lbrbidity, disolrred menls, ailing 2. Monitors appropriate resource measures (see - resuspension traps previous) especidly turbidiry. Fisheria.Yields, numbers, size, tissue Assembles information on ecosystem 3. - bioaccumularion of trace toxiru recovery in a form which is usefi,rl for knsystem. Benthos and plankton derrelopment of final closure plan. - populadorx and sanding crops, primary production rates, bioaccumularion of trace Responslbl lltles of the toxins Reoularory Allency 4. Monitors socid response to environmentd 1. Makes site visits, and obtains photographic rcco/ery by continuing communiry group records. meetings and other social assessments. ). Posts bond for implementation. Flnal closule 6. Reports annudly. Responslbllltles of the Operator 1. lnitiates development of closure plan five years in advance of intended closure. t'ef(luust of Flocadrcs 15
Re3ponrlblftles of the nceu|aloryAeency l. Rerrierrrc closure plan, nequires eddidond infbtnrgdom if needed,and sgcloa,ure bo.sd. 2. ,Rcvierys, mnrratr rc.Foltl, rnd requir* le:,ircdflstr meaout-Gs chqrpd to bond.if nsedcd- 3. Approrcs eventual tctmiuotion of nonitoring. 3 Numerical Guidelines
Overvlerv metds of concern at perticular sites. Once such a table has been developed, then the rnlues can The documents referenced here, with selected be put into the context of site geochemistry, tebles reprinted, provide recent numericd and other resource use. From this guidelines developed by various Regulatory context, Agencies. limiting values for release to the enviroffnent, and to environmental sinks such as seabed The tables are provided as a summary of deposits and fishery species" can be developed. information. Values for pollution control purposes should be determined for each specific site, based on such factors as the need Ihe uS NOAA fl[ures for a high ufety factor due to population The US Nationd Oceanic and Atmospheric densiry the trace metd composition of the ore Administration (NOAA) distributed a report body, and ambient levels within soils and ser (Lottg & Morgan 1991) documenting an sediments. accumulation of sediment trace metal h should be noted that there are differences concenradons with and without biologicd between the various source documents in the effects. These have been condensed and signiEcance of the vdues liste d, and actud modified slighdy by Long et al. (1995). vdues for similar situations. These differences Thble 3.1 prwides the data on race metds in repres€nt different risk-reduction concerns of sediments as published in 1995. Values are based different Regulatory Agencies, varying data on sediment dry weights, mg kg t, that is, ppm. sources, and varying approaches to data andysis. Figure 3.1 illustrates the meaning of the The operationd principle in the use of these acronyms used. ERI, is the concentration below data is to obtain and compare the values for the which there is litde likelihood of biological
Guidelines Per cent (ratio$ incidence ofeffecm 1 Chemical ERI2 ERM3
arseilc 8.2 70.0 s.0 (2/40) 11.r (8/73) 63.0 (17 /27) cadmium 1.2 9.6 6.6 (7/106) 36.6 (32/87) 6s.7 (44/67) chromium 81.0 370 2.e Q/102) 21.1 (rs/71) es.o (19/20) copper 34.0 270 9.4 (6/64) 29.1 Q2/110) 83.7 (36/43) lead 46.7 2r8 8.0 (7/8n 3s.8 Q9/81) e0.2 (37/41) mercury 0.15 0.71 8.3 (4/48) ?35 (16/68) 42.3 (22/s2) nickel 20.9' 51.6 1.e (r/s4) 16.7 (8/48) 16.9 (r0/s9) silver 1.0 3.7 2.6 (r/3e) 32.3 (11/34) e2.8 (r3/14) zinc 150.0 410 6.r (6/ee) 47.0 Q1/66) 6e.8 (37 /s3)
Saurca; Long et d. 1995 I Nursa oJdah mlis u*hin ach omhatioa rutge ia whteh biologiul efias we obsard dividcd q the total numbcr oJ atria vithin eath ragc. 2 ERL = Efeds Rarge (Low); Iatd bdow u*ich efleas rody ottut 3 ERM = Efeas P.tryc Mcdi*m):bd abow whkh c.fds ui[ ptubably otan
TaHe 3 .1 Gui&bne wlues for tn& ,tutak (ppn, dry wt) and po ant itridetue of biologial efeas in coneentrction ranges defned by tlu wlws,ERL and ERM Numerlcalculdellnes l7
EFFECI-S RANGE
bIIJ lJ- IJJ
o Io 6
CONIM/II NANI CONCENTRATI ON
Source: Modificd from Long & Mor88 (1991)
Rgure j,1 The pountialfor hiologiul e[e* oJsedinent-torbeil contan inonts usted in the US Natbnal Suus andTien* hogram effects. ERM is the concentration abcrye which concentration of a chemical in surficid biologicd effects are probable.Between ERL sediment (that is, upper few cencimetres) on a and ERM values there is some possibiliry of &y weight basis. They are based on standardised biological effecs.It should be noted that these cdculation procedtres from a data set, are not absolute values. Below ERL values apparendy entirely Canadian. Values are based biological effects sometime occur, although on sediment dry weights, mg ktrl PPm. rarely (see column headed < ERL in Table 3.1). For comparative purposes, the Canadian TEL Above ERM values, biological effects by no appears to be similar to the US NOAA ERL, meens dways occur (see column headed and the PEL similar to the ERM. Note that a > ERM). The ERM is a median value. Half the further set of guidelines developed in the cases considered above the ERM did not show semi-rropical state of Florida uses the TEL and effects. Also, the &ta are Fom mainland United PEL terminology based on US and Canadian States, not world wide. cases (MacDonald 1994).
The Envlronment Canada fl{ures The Equlllbrlum PartltlonlnE approach
Environment Canada has disnibuted a draft Webster and Ridgway (1994) have refined an report on trace metal sediment concentrations approach to s€tting sediment guidelines based @nvironment Canada 1994).Tables 3.2 md3.3 on w6ter qualiry criteria. This approach is called from the report provide values for marine and equilibrium partirioning (EP). The argument is fresh water respectively. They are quite similar. that there is much more information available There are two indicator values: TEL and PEL. on weter qudiry than for sediment qualiry. The TEL is the Threshold Effect Level below which sediment standard is therefore taken as the adverse effects are expected to occur rarely. PEL concentration in the sediment, in equilibrium is the Probable Effect Level which like the with the interstitial water, that does not give ERM is a median value and defines the level rise to a concentration in the water that would above which adverse effects are predicted to breach the water quality criterion ficr that occur frequently. The'ralues refer to the total contaminant. 18 EIA Mhlng Guldellnes
nile i.2 Chemicd TELl PEL2 ITELo/o 1>o/o >JELo/o Draft C arudian Guifu lines, arseruc 7.24 41.6 3 13 47 andiwiilena oJadwne cadmium 0.68 4.21 6 20 77 hiologiul efats in mnentration rangu fufned chromium 52.3 160 4 l5 53 by wlueslornarine 18.7 108 9 22 56 copper sediments,TELand PEL lead 30.2 712 6 26 58 (Valua in nAWl;Wm) mercury 0.13 0.7 8 24 37 nickel 15.9 42.8 3 8 9 silver 0.73 7.77 10 60 zinc 124 271 + 27 65
Source Ern'ironmcnt Canda I 994 I TEL = Thrcholil Qfcd lzvel;Ictd bdow uttith a&msc {6s an apdctl to mtt ndy 2 PEL = hoSablc Qfea l*vel; lad ahve whkh {&r arc pndiaed b oaut fcqwntly
Chemicd TEL PEL 3TELo/o 1)o/o 2PELo/o (mg kf1; ppm)
arsenic 5.9 17.0 5 25 12 cadmium 0.596 3.s3 11 12 47 chromium 37.3 90.0 2 79 49 coppef 35.7 196.6 4 38 43 lead 3s.0 91.3 5 23 42 mercury 0.774 0.486 8 34 36 nickel 18.0 35.9 4 18 44 irlnc 123.1 314.8 5 32 36
Source: Envircomerrt Canr& I 994
TaAe 3.3 Draft Cawdian Guidchna and inridmn oJ ahnne biologiul efiux in corcenfra{mi rarges defnedJuftah untet seili'rrct tt
Tlble 3.4 prwides tr:rce metal sediment values Chemical EPA water Sediment derirred from the extensive set of US qudity criteria Erwironmental Protection Agency @PA) water (mg krt qualiry citeria. The claim is that these vdues carbon) can be accepted as guidelines since they imply a usenlc 6.3 819.0 theoretically "safe" sediment concentration. The cadmium 12.0 768.0 authors state that this concept has to be used copper 2.0 3400.0 ceutiously. Values are based on a diffetent unit lead 8.6 3268.0 than the two above systems, that is, on mg kg-l (pp-) carbon. mercury 0.1 0.8 zinc 58.0 19140.0
Sorrre:Webstcr & Ridway 1995
nile 3.4 9dinent uiwiafor six elennnlal contaminants dnivedJton unur quality oiktia and
e quilibrium partitioning cwfviens NrmerlcalGuldellnes 19
Comparlson of Yalues
Tbble 3.5 compates the three sets of vrlues in the previous tables. Note thet the EP rnlues are for r 1 per cent catbon level, assumed to be a comparable lerrel betlveen sediments in this context.
Chemical ERL TEt ERM PEL EP Criteria lrseluc 8.2 7.24 70 41.6 8.19 cadmium 1.2 0.68 9-6 4.21 7.68 chromitrm 81 52.3 370 160 copper 34 18.7 n0 108 u lead 46.7 30.2 218 112 32.68 mercruy 0.15 0.13 0.7r 0.7 0.008 nickel 20.9 15.9 51.6 42.8 silvet 1 0.73 3.7 1.77 rinc 150 124 410 nr 197.4
Sourcc: Ervironmcnt Ceaedr I 994
Tablr t.5 Guilhlincsfunmine sediruascmryaringwlusfiontnil$ 3.1,i.2 awl3.4 (apnseilu l panttafuon) References
Caldwell,J.A. & Welsh,J.D. 1982. Tiflings Memorandum, NOS OMA 52, Seatde. disposd in rugged, high precipitation 175 pp. * appendices. ernrironments: An overview and comparatirrc Long, E.R., Macdonald, D.D., Smith, S.C. & assesment. Chrpter 7, pp. 542,in Marine Calder, F.D. 1995. Incidence of advetse Thilings Disposal, ed. D.V Ellis, Ann Arbor biological effects within ranges of chemical Science, Ann Arbor, USA, 368 pp concentrations in marine and estuarine Ellis, D.V 1989. Ervironments at Risk Case sediments. Environmental Management, Histories of Impact fusessment. vol. 19, no. 1, pp. 8l-97. Springer-Verlag, Berlin. 329 pp. MacDonald Environmentd Sciences Ltd. 1994. Ellis, D.V, Pedersen, TE, Poling, G.W, Pelletier, Approach to the Assesment of Sediment C. & Horne,I. 1995. Review of 23 years of Qualiry in Florida Coastal Waters,4 vols. STD: Island Copper Mine, Canada. Marine Florida Departrnent of Environmencd Georesources & Geotechnology, vol. 13, Protection, Tallahasse, Florida, USA.
pp.59-99. MG&G. 1 995. Submarine Tirilinp Disposal. Environment Cenada. 1994. Draft interim Marine Georesources and Geotechnology, rediment quality assessrnent ralues. vol.13,nos1 &2,233pp. Manuscript report, no ECD,p.4. Webster,J. & Ridgwry, 1. 1994.The application Long,E.R & Morgan,L.G. 1991. The Potential of the equilibrium partitioning approach for for Biologicd Effects of Sediment-Sorbed establishing sediment quality criteria at rwo Contaminants Gsted in the National Status UK sea disposd and oufall sites. Marine and Tiends PrognrnNOAA Technicd Pollution Bulletin,vol. 28, no. 11, pp.653{61. Part Two
Environmental Questionnaires Preliminary Information to be Compiled by The Regulatory Agency for a Mine Development
1 List any legislation that a.ffects the mine development urd operations. Obtain copies and file.
2 List any regulations derreloped under the legislation. Obtain copies and file.
3 List other ministries and divisions which will be involved, with contact ofrcers.
4 Assemble or write up descriptions of the petmimng procedures necessary for: - a. exploration - b. acrud rnining - c. final closure
5 Does any new legislation, or se t of regulations appear to be needed? If yes, write up in draft forrn
6 Who are, or will likely be, the representatives of local landowners and resource users alfected by the mine? Provide name(s) and address(es). Preliminary Information to be Compiled by an Applicant for a Mining Licence Questionnaire can be modified for use with mines currendy in operation.
Please respond to the following questions with information currendy arailable within 30 days of receiving this questionnaire.
This questionnaire was meiled on (date)
(aane and aildress oJthe minc d*rw)
Attention of (aanc,posilin)
Your response should be addresed
(aanc aad aildnss of ofuial b tueivc lhc rcspotts)
Please attach extra pages as necessary, indicating where additiond matetid, maPs etc harre been prwided. I Name of the proposed
2 Contacts x. Developing company b. local senior ofEcid
Neme Namc
Locd ad&css
Phone / Fa:r / Intcrnct,etc.
c. Senior environmentd ofEcial d. Shereholders (Jd!fucatfum IuaI smiot oficial) (lisr najor aatioul anilfueign sharcholders ail gnteatagc orner ship)
O{Iicid position
Addrcss for funhcr correspon&ncc
Phonc / Fax / Internet,etc. EIA Mhhg Guldellnes
3 M|ne slte a. Generd location within the nation (oblah national map and mark to show island and luatioa) b. Specific location (ux propeQ dcsignation, obtaia copy ofbcst available topogtaphL nag aad aaial photograpls, thca nrrh lxation) c. New roads needed (*ate oa ihe map pwilld, aotittg rfuer ctossiags) d. Worker facilities needed (will thete be a lownsite,ot tdmg wilh single-mml quotas only,ctt.)
4 flmde, geograplry and geology e. Rainfall data, and sunnxuy of seasonal variation
b. Topography and &ainage patterns
c. Seismic activity and earthquake history
d. Geology and fauking (obtain best available map)
5 Ore body t. Extent ofore body in hectares (estinau land sutJae nea orn the ore bdy, snatk oa tlt best auilabb map, and ywiile a tbee-ilimersioaal diagam showing ihilliag deptk to fulc,ek.) b. Chemical composirion (gotide latcst awilable date, noling dao) Major ore body minenls Residual valuable minerals Heavy metel contens (assayd ARD (Acid Rock Dreinage) potential Levels of potentially tocic trace elements fJaot &tectcd,state typc of analsis rced and give lornst levd olsensitivity)
lcad cadmium - mc(cury arscnic othcrs
6 Mlnlng operatlons a. Typ., opefl pit tr undagrounil D If both, in what sequence? b. Totd tonnages Ore Waste rock: hard rock soft rocb Low-grade ore (temporary stockpile) c. Mining rate: initial ntficiflunt iluring mine lfAime d. Expected lifetime of mine in years Rellmlnary Appllcatlm Infionndlon
7 Mlll processes a. Type ofmrll proposed b. \Ilater source (show on nap,wilhpipdiu rouk lo mill) c. Water use rete (in lires/dey):fnt year daily acpected ilaily maximum d. Energy soruce: lrydropattu otha Location of electrical generation facilities (prwide map) Proces chemicals used -
Typca Ratcs of usc /&y
e. Tonnage of tailings for disposal solids: first year tonnes/ilay etcpeckil matc. nte / day liquids: frs yearJlout rate/day expeaed mu.ratelday [. T?rilinp gr ind specifi cations Erpeaed chemical composition of wastes $datifi test plant pwidhg tlu n*lts)
Liquid waste &action ilkslved metal values reiilual reageflts Solid waste fraction ma maal leuek
potentialfor aid mine uaste genaation (obtein supprtivc da umtlatioa)
I Arca(s) to rccelve l?irste rock (orcrbuden, etc.) (provi& infonnafion oa all opllory nolittg that plaennt of v*E rxb mcy nqtbe diversim of riva) Location(s) of proposed weste rock dumps ^. (ndicatc oa nup, dtowhg psitioa(s) nhtive to thc miac/mill corqila; piaritise by n*atba f appopriau) b. Estimate land area covered hectares c. Chemical composition (note powtia$ot uiil urcE gaualin,vlo pwiileil ilu asqqaail latcb ot*sitivity Jot taa clmtettts) d. Describe general plans for reclamation of waste rock
(ilewibc plant ryecies to be seeded, ilu habitat taget to be rthimd Jor use by IuaI pcople, anil tfu tmget usu of ulaimed habitat)
9 Areas lo recelve stockplles of low{rade ore (f stoclqiling k likeQ,grovidc his inJornailon oa map, shou'itq poitians rclativc to llu minc /mill compla; aou that none dpulil rcmain ajet elosut) t. Cut-offgrade b. Locations and areas in hectares
c. Chemicd composirions and ARD potenrial EIA Mlnlng culdelhes l0 Areas to recelve mlll talllngs a. Options being considered: lmpoundment by dam on land, or return to pit (underground) Discharge to river or lake Pipeline to coast with outfall for marine discharge b. Locations of options (ywide a napfit euh optiol kitrg coasiilad, sluwing rouu of any uilings pipdine, aad lor.atioa o! dixlurgc poiats) c. Area to be covered hectares (shout otr a map; iJ disposal is uadoua, a hyttographic chnt showing tlcpths musl bc rced) ll sewa$e facllltles (denibe s*'age ftilities lo towtrsite, single-mcn's qurrlr's, anil on-tlv-job toilet pilidcs; sanitatl tecbfleat ficilities; antl lualioa, typc and jw tau oJinal di*lwga)
12 Local land rce and resources (desibe lual laad use and rcrcnrcs wihin a napatblc disuscc oJ minc site , mtlJ nk, laJft tgs piplincs, onJand tailiags impunilmants, access roads and tailings a$all $ sfinninc uiliags ilispwl). Reasoaaile ilistarce in dz'is coilal ,aecrrs lo a distance w$ith might bc afuted by'tlu ninhg opetaticas Marh lrr'atim and */rllt oJ uses atd rcsuttrs on maps) a. Villages and isolated groups b. On-land resources: gardens, plurtations, sago stands,other minenls, etc.
c. Fishery resources identifying cornmercid, market and subsistence (rluib rivafshnies antl n*inc jsluits if ll.r,brr,a'i'lr tailiags dkpsal is an optioa. Fkhaies indudes ja-fsh ad sk0fth)
d. Is there any relevant documentation of local resources? SJso,obtain copia) 13 Potentlal sochl lmpacrs (adiceE iuatiotts oa map, atd aplain rcasons) a. Note types of rights of traditional landowners andlor users (ftr aamfle, uatpatin, or usc only)
b. Show those areas subject to trrditiond use end inheriance that will be irrcversibly dtered by the mine (o'fuin)
c. Locate and describe archaeological sites, and sites of traditional importance
14 Publlc Informalon l. Has information about the development been made available to the public? (f yldesibe low infanutiotr ptwidcd ond list doru'rlclrs)
b. List of public meetings held and attendance
c. Has any schedule been developed for routine meeringr with the public or representative groups? (prwide details) 15 other lelevant Informatlon