Risk Assessment Considerations in the Donetsk Basin



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ENVSEC: GRID Arendal



Risk Assessment Considerations in the Donetsk Basin

Mine Closure and Spoil Dumps










For UNEP GRID Arendal

January 2009

In support of the Environment & Security (ENVSEC) Initiative work with the Ukrainian Coal Mining Sector, 2008

© UNEP Grid Arendal




Executive Summary

The coal industry of Ukraine is a vital component of the national industrial infrastructure and economy. Among other things, it underpins the metallurgical industry of the country with coking coals, the thermal power generation sector with steaming coals, and it also supplies both energy carrier and feedstock to the chemicals sector. Ukrainian coal reserves are enormous, at some 25-30 billion metric tonnes, roughly half of which is anthracite and bituminous coals, half lignite and sub-bituminous coals (IEA 2003; EIA 2007).

Despite this importance, the cost of mining activities to the country in environmental and social terms has also been large. As a prime example, the mining areas surrounding Donetsk constitute one of the most environmentally damaged regions of the Ukraine. The many hundreds of coal mine sites have been key contributors to this degradation. In the past 15 years or so pursuant to economic restructuring, many mines have ceased activities or have been targeted for closure. For most of these sites, closure is premature and is taking place both before coal reserves are exhausted and before development of proper plans for safe, environmentally responsible and socially robust closure.

As such, the Ukraine has been faced with an unprecedented occurrence of premature mine closures that have the potential to cause significant adverse impacts on the environment and community. The Ukraine is struggling to manage the process of mine closure in an appropriate manner and society and the environment are suffering.

This document seeks to present a structured overview of risks that are associated with mine operations and closure, and options for the conduct of work towards the reduction of such risks. It has the intent to both support, and generate new ideas for, the ongoing coalmine closure programme in the Donetsk region of Ukraine.

While there are numerous environmental and social effects related to the mining of coal in Ukraine, this document addresses one key category – that of the ongoing environmental effects of the many mine spoil dumps that litter the Ukrainian landscape. Because of their makeup, positioning and condition, these dumps affect society and all the natural media (air, water, subsurface) negatively. This work is a response from the ENVSEC Initiative to these challenges. Thus, Risk Assessment Considerations in the Donetsk Basin: Mine Closure and Spoil Dumps provides insights into how to improve processes to reduce environmental and social risks associated with mine closure in the region with a particular focus on mine spoil dumps.

It has also been formulated in such a way that it can support work that must conducted in the country to revise, improve and enforce regulatory frameworks for mining if the industry is to yield the benefits that it could. In this light, the work carried out by the ENVSEC initiative has had a point of departure that Ukrainian regulation will evolve so that it is more in line with the forms of practice that are maintained in the world’s leading mining countries.

Moreover, generation of the text reflects recognition that a significant proportion of the spoil dumps in the country (perhaps 2-5% of them)1 also have economic value that may be leveraged. Where this is the case, opportunities exist to both remove the risks they entail, and regain the land they occupy for alternative uses, at very low cost – or even at a profit. However, the task of risk reduction and rehabilitation at dumps is undeniably complex and presently beyond the capacity of the Ukrainian institutions. In addition to the evolution of mining policy, such work will require innovation and commitment from all stakeholders. All of this is to be achieved in a difficult economic and institutional environment where the Ukrainian coal sector remains in crisis.

In this light, industry production has fallen to less than half of historical highs and the country is now a net coal importer. Moreover, the restructuring process has essentially been one-way. Rather than a combination of unprofitable enterprise closure; revitalisation of mines with profit potential, and opening of new modern mines operating in a transparent manner and largely market economy, apparently ad hoc mine shutdown has dominated and progress has been slow with revitalisation and market formation. The dominant proportion of mines remains old with low productivity and many are dangerous and unprofitable. Moreover, national plans to open new mines have gone slowly or have failed.

Contributing to the complexity of mine closure and the flow on effects of closure are difficulties in general economic and market structures, and the nature of the privatization process. Privatization of the coal industry in Ukraine has faced a variety of challenges, including financial instability and common bankruptcy proceedings, a lack of transparency, and even (alleged chronic corruption). All of these have also contributed to both a lack of funds for addressing the social and environmental problems associated with mine closures, and a lack of focus on achieving such goals. It is clear that technical excellence and institutional dedication is required to improve the situation.

In recognition of these issues, the ENVSEC project has commissioned this document. It is to be constitute the basis for ongoing work, and as such should be considered a foundation for “living document” that can be revised and updated in parallel with data gathering on the ground in Ukraine. This version of the document has been produced after two field missions to the mining areas surrounding Donetsk and desk-top research. The first data-gathering mission was in the Autumn of 2007, when a wide range of technical expert groups dealing with mining and mining/environment issues were consulted. The second was conducted in the Summer of 2008; here, a smaller group of informants were consulted and a site visits were conducted to some 15 mine sites.

As such, this work has the following aim and objectives.



Aim: to map the relevant issues for mine closure in the region with a particular focus on mine spoil dumps.

Moreover, it should also provide a basis for ongoing work by National partners that involves:

a) adaptation and application of relevant concepts of mining best practice to the Ukrainian context;

b) adaptation and application of best practice mine closure planning processes to the Ukrainian context;

c) examination of the completeness and reflection of “best practice” in Ukrainian closure legislation;

d) examining the effectiveness of how the existing legislation has been implemented;

e) generating proposals for improvement of some policy measures (e.g. to the Ministry of coal and eventually to the Ukrainian parliament).

While the prime focus in this work is spoil dumps and pathways that can be taken to ameliorate their negative environmental effects, this is not to imply that other issues are not of great importance. To the contrary, it is simply that in line with the desires of the participating Ukrainian Ministries, the focus of this work is upon spoil heaps and their effects. Other key areas of environmental damage are addressed to a much lesser extent here but they are not ignored. Such categories include land subsidence, coal bed methane, and the impacts of pumped mine waters.

Moreover, it is recognised that structured mine closure risk consideration should be a part of mine design and mine operational planning. As this is not the case in the Donetsk region, only a portion of “best practice” is possible to apply. However, this work will fit into the broad suite of work that needs to be performed in coming years and decades in the mining regions of Ukraine – if indeed the unacceptable environmental, health and safety impacts caused by operational and closed coal mines are to be dealt with effectively. As such, best practice principles applied elsewhere in the world underpin the content of this report. This document addresses a number of topics relevant to the challenges and opportunities outlined above – as indicated in the statement of aim, the major task is to map the relevant issues for mine closure with a particular focus on mine spoil dumps and then provide guidance upon where ongoing and future work needs to focus.

In the opening part of this document, it is explained that while best environmental and social practice in mine planning and closure and better management of closure related risks may not be solutions for the broad set of difficulties of the coal sector in Ukraine, they are vital components of such solutions. In this context, an introduction to the growth of public and institutional expectations of mining organisations all around the world, and the role of planning for mine closure in meeting such expectations is provided. The text then introduces a number of important environmental and social problems in the Donetsk region. These include a number problems associated with mine spoil heaps (the prime focus of this document) then land subsidence, mine waters and coal bed methane. In closing Section 1, the concepts of “integrated mine planning”, “best practice mine closure” and the utilisation of risk management and prioritisation techniques focused on mine closure are introduced. These are demanding concepts, and delineate approaches that are very different from how such tasks are perceived and performed in Ukraine. As such, these concepts are to form an important springboard for the rest of the report.

The second, and most substantive ‘risk-related’ part of the report, provides details of six different categories of risk relevant to mining and mine closure. The items addressed include environmental risks, health and safety risks, community and social risks, final land use risks, legal and financial risks and technical risks. Due to factors such as the nature of the ENVSEC initiative itself (where environment is a key parameter), and due to the high environmental profile of spoil heaps in the Ukraine, the major focus is placed upon matters of environment. For each of the six categories of risk, examples are provided of how risks can be classified. Three generic categories are applied for this: broad closure risks, sub-issues and specific events or options. For each sub-issue, examples are provided that apply to the coal mines in the Donbas. This section provides a fundamental foundation for the identification of pressing issues surrounding mine closure – and the manner in which they relate back to risk. The data, observations and discussions collected/conducted during missions to the field by United Nations Environment Programme (UNEP) GRID Arendal personnel, and the supporting work of the partner organisations in Ukraine, have been utilised to populate the tables in this part of the document with examples.

In the third section of the document, an important side-track is taken. This provides details of international developments helping to drive the uptake of improved mining practices around the world. Importantly, these topics link the issues of coal mining and mine closure in Ukraine to the outside world of international finance (both for mining and for closure of mines) as well as evolving EU regulatory frameworks for mining. The first topic taken up is financial assurance for mine closure and reclamation, an important emerging requirement from governments of leading mining countries. This is followed by discussions of the Seveso II Directive enacted by the EU to help prevent and control major accidents involving dangerous substances and the so-called “extractive industry waste directive” again put in place within the EU system. The focus then shifts to project financing with discussion of the Equator Principles for socially responsible project investment – the result of an initiative started by the International Finance Corporation and the World Bank. Finally, this section introduces a second set of investment principles developed by the ENVSEC partner, the Regional Environment Center for Central and Eastern Europe that explicitly target jurisdictions such as Ukraine.

Following these external issues, the content returns firmly to mine spoil dumps, focusing in on the environmental aspects and potential environmental impacts of mine dumps and infrastructure, and activities co-located with dumps or relevant to their operation. Guidance for ongoing field work is also provided in the form of an indicative listing of information requirements and potential information collection modes for spoil dump risk assessment. Examples are given for three forms of data collection: historical document/interview methods, scanning field assessments, and detail field assessments. Having established the broader content of such interactions with the environment and society, and how one might collect data, the fifth section then introduces simple methods for the process of prioritising risks. In the light of the large number of activities and the broad nature of some issues, such methods are vital for focusing on those issues most critical for risk amelioration associated with closure activities.

The final content orientated section of the report provides a suite of seven case studies that are intended to place the terms best practice or “good practice” used in this document in a clearer context. Despite the fact that the works outlined have taken place in a different set of climates to that found in the Donbas, and with differing social and economic contexts, each of them has a number of learning points that are valid for the coal mining areas of Ukraine. The Australian Government generated these cases within the auspices of a programme involving considerable collaboration with UNEP (principally during the 1990s). Two cases address dump fire control, three address revegetation and management of micro-topography, and two are focused upon the utilisation of computer aided analysis to guide cost and time effective mine site and dump rehabilitation.

The final sections of the report turn from content and description of tools to findings of investigative work. The final chapter delineates a number of key items for closure and closure risk consideration.
The content here consists of general comments with some limited recommendations. They are largely directed towards the Ukrainian mining stakeholders that could pursue and perform such works in the future. In this light, the report generally avoids pointed recommendations directed towards specific sites, specific pieces of legislation or specific actors.

Liability and ownership issues

A clear message delivered by this study is that a lack of adequate legislative structures for the sale of mine lands, mine spoil dumps etc., is a significant barrier to progress in the rehabilitation of mine lands. It is also a barrier to the extraction of value from mine wastes. This barrier relates to both the potential for extraction of value from the materials and the potential value of the land itself for alternative uses once a dump is removed, or made safe.

Informants indicated that while the Ukraine does have a “law on environmental audit” that to some extent addresses accountability for risks associated with changes in industrial land use, the transfer or sale of mine lands is difficult. Pointedly, there is no legal framework for a “trade in dumps”. From the viewpoints of land sellers, buyers and the public, delineation of liability for risks is clearly important. Moreover, examples were given of dumps that apparently have no specified legal owner, and of (generally old) dumps where land ownership has been passed to local authorities that appear to have little capacity to manage associated risks or to effectively valorize materials within the dumps. While this challenge has not been researched in detail, it appears clear that improvement of legal frameworks for liability and site ownership are vital to the process of reducing mine related risks in the region.

Extracting value from spoil dumps

Essentially all stakeholders in the Ukrainian mining sector indicate that extraction of value from mine legacies (in this instance spoil heaps) is desirable. Four dominant approaches are discussed:



  • recovery of coal for sale to power stations, or for value adding into coal briquettes for private sale;

  • extraction of aggregates for the building industry, for road building, or for fill,

  • processing for the recovery of rare earth elements, germanium, aluminium rich minerals, and iron ore;

  • dump removal or reshaping so that land is suitable for alternative uses and/or can be sold.

Despite broad interest, limited progress appears to have been made. Indeed, only one formal large scale coal recovery operation exists in the region. An abundance of simple, mobile informal operations for coal recovery however, indicates that there is potential for more dumps to be rehabilitated in this manner. Similarly, the recovery of aggregates – and in some cases precious metals or minerals – does appear feasible.

Challenges to progress in the above areas are generally indicated to relate to lack of finance; lack of examples to follow; inexperience with technologies and markets, and problems with legislative structures such as ownership/liability listed above.



Site security and informal coal-related activities

Site security and informal mining activities carried out on mining leases are a problem in the region when viewed from a risk perspective. Informal activities witnessed or mentioned during the ENVSEC missions and aspects of risks associated with them include:



Unlicensed and informal mining activities – these small scale mines are apparently run with a minimum, or primitive consideration of, health and safety standards. As such, they pose a risk to the miners that engage in them. Moreover, worked out areas are highly likely to constitute risks (gas leakage, subsidence, void hazard etc.) for future (or present) land users or owners. It is also presumably very unclear how liability for accidents or damage, or environmental problems associated with these operations, would be managed. As formal records are not kept of operations, such difficulties can be expected to compound as time passes.

Unlicensed and informal coal recovery operations – again, these operations are apparently conducted with limited consideration of health and safety standards. In this case however, inspection of operations during the ENVSEC mission of 2008, indicate that these are unlikely to be particularly hazardous. Nuisance in the form of dust, noise and heavy goods traffic is evident however. As with informal mining, liability concerns also clearly exist, albeit of an apparently lesser degree.

While the comments above have highlighted weaknesses and threats, another important consideration for these issues is the value that the activities yield. They provide employment and economic benefit to those that engage in them. Indeed, anecdotal evidence indicates that unlicensed mining operations pay considerably higher wages than are awarded by state operations. Moreover, they contribute to National coal production thus reducing the net production/import deficit. Dump reprocessing is also contributing to the removal of dumps that take up land and have potential to burn – in itself a form of rehabilitation. In this light, it is considered that examination of possibilities to bring such activities into the formal economy is worthy of attention.



Revegetation and dump rehabilitation

The missions to the Donbas region have observed that the existing planning and goals for site (environmental) rehabilitation and risk reduction are inadequate. Moreover, the methods designs and methods utilised appear to differ markedly from those applied in leading mining nations and also appear to yield markedly inferior results. In this regard it is considered that new approaches have an important role to play in Ukraine if tangible progress is to be made. It is deemed that initial topics to be addressed should include, but not be limited to: landform management, dump reshaping, dump fire prevention techniques, fire management techniques, management of acidic and saline wastes, topsoil management, soil amendment, water management, revegetation techniques and final land use considerations.



Information on mining objects

Critical to achievement of improvement in all of the areas mentioned above, is access to up-to-date knowledge describing mining objects. Such information is relevant to mine closure, mine risk and mining operations. This study has indicated that effective application of computerised geographical informations systems (GIS) will be invaluable in the management of such information in the Ukrainian context. While very considerable data does exist, it is widely spread and only very limited quantities are available in digital form. Moreover, this study has revealed that there are many types of information that simply have not been collected, or where even the capacity to collect them is limited.

The issue of collecting and centralising information will doubtless be a huge task, but this research indicates that it must be started and given priority if progress is to be made effectively on risk amelioration. Due to the large number of sites and objects that have significant environmental aspects – a key task for data managers will be the prioritisation of risks. In this light, the content of Chapters 4 and 5 in this report provide details of how such processes may be started.

Moreover, and very strongly linked to previous items mentioned in this summary, is the issue of ownership and liability. Accurate and up-to-date information for such parameters is vital for the support of all mine closure and risk reduction work, and as such it must be a key component of any data management system.



Closing remarks and general recommendations

The report closes with a number of general recommendations for future works.



1. Adaptation and application of relevant concepts of mining best practice and best practice mine closure-planning processes to the Ukrainian context

In this area, it is considered that the work has clearly established a large gap between practices applied in Ukraine and those applied in countries deemed to have “best practice”. However, it is doubtful that practice can simply be transposed. Many of the technical conditions and most of the socio-economic conditions in Ukraine do not have direct parallels elsewhere. As such, this study concludes that there is a clear need to conduct work to both adapt and apply best practices for the Ukraine.

Further, it seems logical that external parties with extensive experience of such practices abroad should participate with Ukrainian actors in the pursuit of better practice for mining and mine closure.

2. Examination of the completeness and reflection of “best practice” in Ukrainian closure legislation AND the effectiveness of how the existing legislation has been implemented

This work has found strong indications that Ukrainian practice and legal frameworks do not support good practice. It appears that work is required to analyse national regulations in the light of sound practices elsewhere and delineate those items that are addressed and those that are not. Legislation surrounding transfer of site ownership and liability is one critical area for initial examination.

Moreover, the work conducted within this project has indicated that implementation of existing rules and regulations are not taking place as prescribed. Examination of enforcement in areas where health, safety or environmental risks are high, also appears worthy of immediate attention.

3. Generating proposals for improvement of the some policy measures

A number of areas where proposals for policy improvement appear relevant have been identified within this study (e.g. clear delineation of ownership of sites, clarification of transfer and/or sharing of liability, examination of financial assurance/bonding schemes for new mining operations, examination of liability for hazardous “historical sites”, etc.). However, it is considered premature to pursue such work at this juncture. Work on the two items listed above will need to precede such action – or at least be advanced to some degree before sufficient delineation of policy weaknesses is achieved.

In closing this summary text, it is reiterated that many important risk concerns were found in this work. However, it was also found that the structured approaches to risk documentation and analysis can help prioritize work on reduction of such risks.
Acknowledgments

The development of this document has been an undertaking of The Environment & Security (ENVSEC) initiative.2 As such, the document was prepared under the direction of the initiative partners. These include the United Nations Environment Programme (UNEP), the United Nations Development Programme (UNDP), the Organization for Security and Co-operation in Europe (OSCE), the United Nations Economic Commission for Europe (UNECE), the Regional Environment Centre for Central and Eastern Europe (REC) with the North Atlantic Treaty Organization (NATO) as an associate partner.

This report was prepared on behalf of these organisations by Philip Peck (Extractive Industries Specialist) with the close support of Elena Santer-Veligosh (Capacity Building Programme Officer) of UNEP/Grid-Arendal.

Any errors and/or omissions of this document remain the fault of the author.



Table of Contents

List of Figures

List of Tables


1 Introduction 5

1.1 Higher expectations for mine closure and remediation 7

1.2 Some key environmental and social problems in the Donbas 9

1.3 Understanding mine closure risks to facilitate closure 13



2 Classification of risks 17

2.1 Environmental Risks 17

2.2 Health and Safety Risks 21

2.3 Community and Social Risks 23

2.4 Final land use risks 26

2.5 Legal and financial risks 28

2.6 Technical Risks 32

3 Emerging trends for best environmental practice mining 34

3.1 Financial Assurance for Mine Closure & Reclamation 34

3.2 Seveso II 44

3.3 The EU mine waste directive 46

3.4 The Equator principles 49

3.5 Governance Principles for Foreign Direct Investment in Hazardous Activities 51

3.6 Real or perceived financial barriers 52

4 Mine spoil dumps: a key closure issue in the Donbas 55

4.1 Environmental Aspects associated with coal mine spoil dumps and adjacent mine activities/facilities 55

4.2 Information requirements for creating risk profiles for spoil dumps 56

5 Prioritising risks 61

5.1 Workplace risk and control 61

5.2 A closure risk example – Uranium Mine 63

6 Good practice case studies 66

6.1 Case Study 1: Recognition, prevention and management of self heating in coal mine spoil 67

6.2 Case Study 2: Top Soil Grafting Averts Self Heating 69

6.3 Case Study 3: Progressive revegetation and water body protection 72

6.4 Case Study 4: Basin Listing—An Alternative To Contour Ripping 74

6.5 Case Study 5: Innovative revegetation methods 75

6.6 Case Study 6: Mine scheduling and Computer aided techniques for mine rehabilitation 79

6.7 Case study 7: Computer Assisted Design for Mine Rehabilitation 81



7 Concluding discussion and recommendations 85

7.1 Recapitulation 85

7.2 Key items for closure and closure risk consideration 87

7.3 Closing remarks and general recommendations 92

Glossary of mining terms 94

Appendix A – Acid Base Accounting references 103

Appendix B: Draft field procedures field scanning survey of Donbas coalmine spoil dumps 104

Appendix C: Draft Report from Ukrainian partner organisation: UGLEMASH 106

Appendix D: MINE DUMP INVENTORY ( Donuglerestrukturizatsia) 118

Appendix E – Governance Principles for Foreign Direct Investment in Hazardous Activities 139



Bibliography 147

List of Figures

Figure 4 1 Concept diagram: planned encapsulation of acid generating mine wastes in spoil dumps/tailings dumps 57

Figure 5 2 Calculation of risk using the risk matrix (after Thompson, 1999) 61

Figure 5 3 Mine Closure Risk Assessment Matrix (Laurence 2006) 62

Figure 5 4 Example of an application of the Closure Risk Model in an Australian mine (Laurence 2006) 65

Figure 6 5 Final rehabilitation cover coalmine spoil dump 67

Figure 6 6 Reshaping dumps – coalmine spoil 69

Figure 6 7 Spoil heaps prior to rehabilitation 70

Figure 6 8 Dragline adjusting dump slopes and cover with topsoil 71

Figure 6 9 Vegetation establishment on spoil dump 72

Figure 6 10 Mine pits reshaped to capture site run-off 74

Figure 6 11 View over rehabilitated mine land 74

Figure 6 12 Site prior to rehabilitation 77

Figure 6 13 Site 3-4 years after rehabilitation works commenced 78

Figure 6 14 Vegetation growth on former pit 78

Figure 6 15 General layout of operation at Nabarlek 78

Figure 6 16 Nabarlek: as designed (after Riley 1994) 79

Figure 6 17 Nabarlek: as constructed showing final landform (after Riley 1994) 79

Figure 6 18 CAD mine design operator 80

Figure 6 19 An example of computer aided design used to give a three dimensional model of a proposed mine site 83

List of Tables

Table 2 1 Classification of environmental risks – part A (after Laurence 2006) 18

Table 2 2 Classification of environmental risks – part B (after Laurence 2006) 19

Table 2 3 Classification of environmental risks – part C (after Laurence 2006) 20

Table 2 4 Classification of health and safety risks 21

Table 2 5 Classification of community and social risks 24

Table 2 6 Classification of final land use risks 27

Table 2 7 Classification of legal and financial risks (part A) 29

Table 2 8 Classification of legal and financial risks (part B) 31

Table 2 9 Classification of technical risks 32

Table 3 10 Differing types of Financial Assurance 36

Table 3 11 Advantages and disadvantages of Financial Assurance through bonding 39

Table 3 12 Guidelines for framework policies. 41

Table 4 13 Indicative listing of environmental issues: coal spoil dumps in the Donbas 55

Table 4 14 Indicative listing of information requirements and potential collection modes for spoil dump risk assessment 58



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