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Journal of Environmental Management 91 (2010) 2225e2237

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Journal of Environmental Management


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A procedure to evaluate environmental rehabilitation in limestone quarries


Ana Claudia Neri, Luis Enrique Snchez*
Escola Politcnica, University of So Paulo, Av. Prof. Mello Moraes, 2373 So Paulo, SP 05508-900, Brazil

a r t i c l e i n f o

a b s t r a c t

Article history:
Received 29 October 2009
Received in revised form
10 May 2010
Accepted 2 June 2010
Available online 13 July 2010

A procedure to evaluate mine rehabilitation practices during the operational phase was developed and
validated. It is based on a comparison of actually observed or documented practices with internationally
recommended best practices (BP). A set of 150 BP statements was derived from international guides in
order to establish the benchmark. The statements are arranged in six rehabilitation programs under
three categories: (1) planning (2) operational and (3) management, corresponding to the adoption of the
plan-do-check-act management systems model to mine rehabilitation. The procedure consists of (i)
performing technical inspections guided by a series of eld forms containing BP statements; (ii) classifying evidences in ve categories; and (iii) calculating conformity indexes and levels. For testing and
calibration purposes, the procedure was applied to nine limestone quarries and conformity indexes were
calculated for the rehabilitation programs in each quarry. Most quarries featured poor planning practices,
operational practices reached high conformity levels in 50% of the cases and management practices
scored moderate conformity. Despite all quarries being ISO 14001 certied, their management systems
pay low attention to issues pertaining to land rehabilitation and biodiversity. The best results were
achieved by a quarry whose expansion was recently submitted to the environmental impact assessment
process, suggesting that public scrutiny may play a positive role in enhancing rehabilitation practices.
Conformity indexes and levels can be used to chart the evolution of rehabilitation practices at regular
intervals, to establish corporate goals and for communication with stakeholders.
2010 Elsevier Ltd. All rights reserved.

Keywords:
Mine rehabilitation
Best practice
Assessment
Limestone
Cement
Mining
Quarrying
Karst
ISO 14001

1. Introduction
Land rehabilitation is an essential part of mining and quarrying,
aiming at making disturbed areas suitable for new sustainable land
uses. Mining is increasingly viewed as a temporary form of land use
whose end of life is subject to careful planning. Hence, mine
planning should fully consider future land use options, allowing for
extractive activities to be carried on balancing the optimal rate and
the maximum environmentally and socially feasible ore or rock
extraction with the intended post-mining land use.
Extensive research has been conducted worldwide on several
aspects of mined land rehabilitation. There are recommended
practices for soil management, erosion control, slope stabilization,
species selection, seed collection, nursery establishment and
maintenance, seeding and planting strategies and techniques, weed
control, fauna attraction and other aspects of rehabilitation

Abbreviations: CSI, Cement sustainability initiative; EIA, Environmental impact


assessment; EMS, Environmental management system; WBCSD, World business
council for sustainable development.
* Corresponding author. Tel.: 55 11 3091 5186; fax: 55 11 3091 5721.
E-mail addresses: anaclaudianeri@yahoo.com.br (A.C. Neri), lsanchez@usp.br
(L.E. Snchez).
0301-4797/$ e see front matter 2010 Elsevier Ltd. All rights reserved.
doi:10.1016/j.jenvman.2010.06.005

techniques. Furthermore, policy tools to encourage companies to


effectively implement suitable technical solutions (such as performance bonds) and to engage with communities in addressing
future land use (such as mandatory consultation) have been
developed and disseminated. However, comparatively less research
effort has been directed to understand the companies internal
management of the environmental rehabilitation process and the
design of effective management programs.
Land rehabilitation in mining is not an activity to be carried out
at the end of the mine life cycle, nor a service that can successfully
be entirely outsourced. On the contrary, mined land rehabilitation
is a process that requires time and involves learning. Notwithstanding, in many mining companies efforts towards rehabilitation
vary over time due to several reasons, such as changing managers e
some being more enthusiastic than others in terms of achieving
rehabilitation goals and perhaps exceeding minimum performance
standards. It is also known from anecdotal evidence that large
companies may show different levels of commitment towards
environmental management in different sites not only in different
countries but also inside the same jurisdiction.
Moreover, staff turnover can jeopardize a companys organizational memory and undermine its capacity to learn from experience
(Argyris and Schn, 1996, among others), arguably essential when

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A.C. Neri, L.E. Snchez / Journal of Environmental Management 91 (2010) 2225e2237

rehabilitation measures are implemented along an extended time


span and can take years to show meaningful results. This is
particularly important when land rehabilitation is not well integrated into mine core activities or when much of the actual rehabilitation work is carried out by external contractors.
This paper focuses on the managerial aspect of land rehabilitation in mining. An evaluation protocol to assess ongoing practices
and procedures towards rehabilitation during the operational
phase of a mine life-cycle has been developed and validated. The
goal is not to assess the results of rehabilitation measures or the
achievement of completion criteria, but to evaluate to what extent
the practices, procedures and controls adopted by a mining
company during a mines operational phase are likely to achieve
satisfactory results in the future, thus assessing progress towards
successful rehabilitation.
2. Limestone quarrying and rehabilitation
Cement manufacturing is an industry established in almost all
countries. The world cement production reached 2.9 billion tonnes
in 2008 (USGS, 2009), placing limestone among the top minerals
extracted from the Earths crust (Fig. 1). The ratio raw limestone/
cement is variable, depending on the chemical composition of
limestone itself and other raw materials used in processing (clay,
sand, iron ore), but can be assumed to be around 1.1 as an average,
providing an estimate of around 3.2 billion tonnes for total limestone output to support current cement production. Actually, world
limestone output is even bigger, as the rock is also used as a source
of aggregates and in the manufacturing of lime, whose global
output in 2008 reached 290 million tonnes (USGS, 2009),
demanding about 350 million tonnes of limestone. Freas et al.
(2006) inform the amount of limestone mined in the United
States alone at 1.6 billion tonnes, but in this country much of
crushed rock is sourced from carbonate rocks. The amount featured
in Fig. 1 is, therefore, a conservative estimate of limestone output.
In addition to the environmental impacts associated with most
mining activities, limestone quarrying has the potential to cause
a particular set of impacts due to the karstic nature of the terrains
(Van Beynen and Townsend, 2005; North et al., 2009). Karst landscapes feature valued ecological and cultural resources, such as
archaeological and paleontological sites, caves and landforms,
unique ora species and subterranean fauna, including endemic
trogobitic species (Watson et al., 1997).
Any quarry or mine rehabilitation requires physical stabilization
of pit and waste rock piles slopes, which is usually obtained by
setting face angles taking account of the geomechanical characteristics of the rock. The resulting straight lines and the geometrical
aspect of the nal pit are source of remaining visual impact, only
World output of major minerals
16,000
14,000
12,000
Mt

10,000
8,000
6,000
4,000
2,000
0,000
aggregates

coal

limestone

iron ore

Fig. 1. World output of major minerals. Sources: USGS (2009) for iron ore, cement and
lime, Hetherington (2007) for coal, Langer (2006) for aggregates. Limestone output
estimated by authors from cement and lime outputs; limestone used as crushed stone
is not considered in this estimate and is accrued as aggregate.

partially mitigated by vegetation. Often a large rock outcrop


remains, in contrast with the surrounding landforms. Karst landscapes, on the other hand, naturally feature rock outcrops in the
forms of cliffs, buttresses and other meso and microscale landforms, but a limestone quarry surrounded by natural karst
landforms will still remains in sharp contrast with the surrounding
landscape. In order to mitigate such visual intrusion, it has been
proposed that rehabilitation of limestone quarries should aim at
replicating karst landforms, i.e. to mimic natural appearance by
replacing straight lines and other engineered features by rock
headwalls, buttresses and other karst landscape features (Gagen
and Gunn, 1988; Gunn and Bailey, 1993) in areas of outstanding
natural beauty or where screening techniques can themselves be
intrusive (Walton and Allington, 1994).
Establishing suitable wildlife habitats is another concern for
mine rehabilitation. Cullen et al. (1998) studied the vegetation
communities established in three modern quarry sites in the UK
rehabilitated using the landform replication technique. Authors
compared the communities established after two years in the three
rehabilitated sites with communities occurring on natural dalesides
and on seven disused, abandoned quarries after 40e85 years of
natural regeneration. They found the vegetation of modern rehabilitating quarries to be more closely related to the natural reference sites than those resulting from spontaneous growth. Studies
by Wheater and Cullen (1997) in the same sites had showed that
the rehabilitating quarry sites had a relatively high number of plant
species (originated from hydroseeding), but featured much more
bare ground as compared to older disused quarries and to reference
sites. Further studies by Wheater et al. (2000) focused on surveying
spider communities in those same areas, founding greater differences than those indicated by the study of vegetation communities
developed on limestone quarries rehabilitated by mimicking
natural landforms.
Additionally, it has been shown that rehabilitated and even
abandoned limestone quarries can act as important secondary
habitats for a number of animal and plant species, such as bees
(Krauss et al., 2009), butteries (Benes et al., 2003) and spiders
(Tropek and Konvicka, 2008).
Mine planning in karst landscapes should include pre-mine
surveys of environmental and cultural values of caves, small and
large scale landforms, underground fauna and archaeological sites
(Misra et al., 2002; Vermeulen and Whitten, 1999), as well as
studies aiming at understanding the often complex underground
water ows (Worthington and Ford, 2009; Worthington and Gunn,
2009). Misra et al. (2002) provide specic guidelines for planning
mining activities in karstic regions.
In 1999, the worlds ten biggest cement companies created the
Cement Sustainability Initiative (CSI), under the umbrella of the
World Business Council for Sustainable Development (WBCSD).
Albeit reacting later than the metal mining industry to the challenges of sustainability (Snchez, 1998), the cement industry
established codes of conduct and guidelines to address its most
important environmental issues, including quarry restoration.
A number of cement companies has also been publishing corporate
sustainability reports on an annual basis, but started this practice
later than the biggest metal mining companies (Prez and Snchez,
2009).
One of eight major topics on sustainability identied by the CSI is
ecological stewardship: improving land use and landscape
management practices, which includes land rehabilitation. An
agenda for action launched in 2002 contains six critical issues, out
of which local impacts addresses quarry planning and rehabilitation (WBCSD, 2009a). CSI website features twelve case studies of
limestone quarry rehabilitation (WBCSD, 2009b), whereas other case
studies featuring good practices are provided by Misra et al. (2002).

A.C. Neri, L.E. Snchez / Journal of Environmental Management 91 (2010) 2225e2237

Despite a number of published studies on limestone quarry


rehabilitation, these are far less numerous than the literature on the
rehabilitation of other types of mining. Specic guidelines for
limestone quarries were developed only recently and remain, to
a large extent, untested, despite the large number of such mines
worldwide.
3. Approach, methods and research steps
Ex-post assessment e a systematic and analytical procedure to
form a judgement about what is being evaluated e often requires
comparing expected elements with the actual implementation of
the evaluated plan, program or project (Weiss, 1998). Thus, the
principle of comparison with internationally recommended best
practices was used to assess the environmental rehabilitation
practices applied in limestone mining. Te research started with
a survey of best mine rehabilitation practices in order to set up
a benchmark, against which individual mine rehabilitation
programs could be evaluated. Fig. 2 shows the research steps.
Put simply, environmental management best practices are the
best way to do things (Australia EPA, 1995a). In environmental
management, best practices include, for each step of a production
process, a group of procedures or solutions that are recognized by
the mainstream companies as both effective and economically
viable to avoid or to reduce the adverse environmental impacts of
activities, products and services. Best practices correspond to
a benchmark, which can be followed or adapted by other companies or organizations.
International and Brazilian environmental best practices were
surveyed in order to establish the benchmark. The main sources for
the compilation of best practices in the mining industry were
government, industry-sponsored or joint government-industry
publications. Such institutional authors were intentionally retained
as more credible sources of best practices, as opposed to either
individual academic or professional sources or to individual company
best practices. Environmental protection measures endorsed by
industry representative bodies have normally been tested and
considered as cost-effective. Therefore, they can be employed or
adapted by other companies working in the same sector.
Best practices mentioned in these sources were (i) compiled,
(ii) grouped in categories, (iii) selected using authors professional
judgement, (iv) transformed into synthetic statements, and
(v) validated by submitting a draft list to experts.

Survey of international best practices sources


Selection of manuals and guidelines
Compilation of most appropriate environmental rehabilitation best practices
Preparation of draft best practice environmental rehabilitation statements
Preparation of field forms grouping statements
Consultation with professionals to validate statements
Development of a draft qualitative data evaluation protocol
Pilot test application in three mines
Corrections and adjustments of the field forms and the protocol
Development of a set of conformity indexes
Calculation of indexes for the pilot cases and adjustment in index calculation formulae

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The compiled best practices were grouped in three major


categories: (1) planning, (2) operational and (3) management,
corresponding to the adoption of the PDCA (plan-do-check-act)
management systems model to mine rehabilitation. The operational practices were divided up in (i) soil management practices;
(ii) landform stabilization or geotechnical and topographic practices; (iii) water resource protection practices and (iv) vegetation
management practices.
The recommendations of best practices obtained from the
selected sources were transformed in synthetic statements, e.g.
surface soil should be removed separately from subjacent material
(waste or ore) and grouped in a series of eld forms. A draft
version of the eld forms was submitted to four experts from
government and academy for the sake of validation.
The application of eld forms is made by performing technical
inspections. Most mine personnel is used to inspections and audits,
as many companies have their own management systems e quality,
environmental, health and safety or integrated management
systems all rely on inspections, tests or audits as control tools
(Power, 1997). In performing the technical inspection, the assessors
seek to collect objective evidence by means of: (1) obtaining,
reading and reviewing documents; (2) undertaking interviews;
(3) making eld observations.
An evaluation protocol was then developed, inspired by procedures used in environmental audits. The protocol involves the
classication of inspection ndings according to pre-determined
categories. The next step was to eld test the forms and the evaluation protocol by performing technical inspections in three
limestone quarries whose managers were previously contacted and
agreed to participate. After this test, both the protocol and the eld
forms were once again reviewed in order to adjust the terminology
and accuracy of the statements, seeking to eliminate ambiguities in
order to reduce variations in personal interpretation.
The following stage was to develop a set of conformity indexes
to derive a synthetic evaluation at the end of the process. The
interest and usefulness of quantiable indicators or indexes were
appointed by several industry representatives for the sake of
a possible integration with other business key performance indicators. For this purpose, conformity indexes can also be presented
as conformity levels, as it will be later explained.
The conformity indexes and the corresponding conformity
levels allow for the assessment of the effectiveness of each rehabilitation program by transforming qualitative data collected in the
eld work into performance indexes. A rehabilitation program is
here dened as coherent groups of environmental protection and
rehabilitation measures, as grouped in the three major categories
(i.e. planning, operational and management) and four subcategories, as abovementioned.
Conformity indexes were calculated for each one of the three
quarries previously inspected and compared with the authors
perceptions and professional judgement about the quality of each
program, considering their experience and knowledge about other
limestone or non-limestone mines in Brazil and abroad.
Finally, the procedure was applied again, after an adjustment of
the formulae to calculate the conformity indexes, to six other
quarries for its conrmation, validation and ne tuning. Minor
adjustments were carried out during the second campaign of
technical inspections and data analysis. The results were fed back to
quarry managers.
4. Results

Application in six new mines


Final adjustment and refinement
Fig. 2. Research steps to develop and validate the evaluation procedure.

The main purpose of the research was to develop an evaluation


procedure. As eld tests were conducted to validate and rene the
procedure, the actual environmental performance evaluated in

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nine quarries constitutes side results of the research. Both


outcomes will be presented in this section. First, the following
components of the evaluation procedure will be described: (1) the
series of best practice statements, (2) the evaluation protocol and
(3) the data analysis procedure. Results of the nine case studies will
be featured in the nal part of this section.
4.1. Best practice statements
The following sources were used to establish the benchmark:
Abnt (1999, 2006), ANZMEC/MCA (2000), Australia EPA (1995a,
1995b), Brodkom et al. (2000, 2002), Cetesb (2001), Environment
Australia (1998), Ibama (1990), SMA (2004), Tasmania (1999), The
Environment Council (2004), USFS and Utah FS (no date),
Vermeulen and Whitten (1999) and WBCSD (2005a,b).
The Australian federal publications (Australia EPA, 1995a, 1995b,
Environment Australia, 1998) were prepared in consultation with
industry and comprise a series of several booklets, out of which
three directly related to rehabilitation were retained. Other booklets in the series also feature relevant guidance to planning, operating and rehabilitating any kind of mine, although most of the
examples and best practice cases come from metal and coal mining.
The Tasmanian Quarry Guide (Tasmania, 1999) is a government
guidance document applicable to all kinds of quarries. The guidebook published by ANZMEC/MCA (2000) is an important reference
for planning mine closure. The now well-known Planning for
Integrated Mine Closure Toolkit (ICMM, 2008) developed by the
International Council on Mining and Metals and launched on
August 2008 was not available at the time the research was initiated, but much of its closure recommendations are already covered
in other guidance documents, although at a less detailed level.
Brodkom et al. (2000) is a study carried on for several European
mining associations with support of the European Commission and
covers several aspects of environmental management, out of which
those pertaining to rehabilitation were selected. Brodkom et al. (2002)
is a similar guide with examples from Spain. The European Cement
Association (Cembureau) was one of the sponsors of these guides.
The Environment Council (2004) provides guidance on
involving the communities in planning, operating and decommissioning aggregates extraction. USFS and Utah FS (no date) is
a eld book for mine reclamation practitioners.
Vermeulen and Whitten (1999) is a World Bank review about
the consideration of karst values in development planning;
although mainly discussing the importance of environmental and
cultural values associated with karst landscapes for environmental
decision-making, the publication provides some guidance on siting
limestone quarries and on reconstructing the landscape.
WBCSD (2005a) is a general guideline for life-cycle planning for
the cement industry, including quarrying; it features general
guidance and best practice examples from the cement sector. More
detailed guidance with further examples from the cement industry
is found in Misra et al. (2002). This study, commissioned by the
WBCSD in support of the CSI contains recommendations which
were largely featured in the abovementioned guidelines.
Brazilian technical standards on mining rehabilitation and
waste rock disposal (ABNT, 1996, 2006) were included not only
because they are national standards pertinent to the country where
the case studies were conducted, but also because they provide
advice of general interest. Ibama (1990) advises on techniques and
approaches to re-establish vegetation in mine affected land. Local
guidance on revegetation was included to reect specic advice as
related to Southeast ecosystems, where Atlantic rainforest is the
major biome; SMA (2004) was selected out of several scholarly
publications because it is available at a government website as
practical recommendation for ecological restoration. Local

guidance on contaminated soils (Cetesb, 2001) was also included in


the survey, as to a large extent it reects international best practice.
Best practices mentioned in the consulted sources were:
(i) Compiled to extract recommendations relevant to limestone
quarry rehabilitation;
(ii) Grouped in categories (planning, management, operational
with subcategories);
(iii) Selected using authors professional judgement;
(iv) Transformed into synthetic statements, and
(v) Validated by submitting a draft list of best practice statements
to experts.
This procedure resulted in 150 best practice statements,
organized in seven eld forms to guide technical inspections and
the collection of documented evidence. Table 1 synthesizes the
statements, eld forms and groups of practices, also called here
rehabilitation programs. Although there are six programs, the
statements are featured in seven eld forms because eld inspections of landform stabilization practices are best performed with
separate forms for pits and individual waste rock piles. Since
a quarry can have more than one waste rock pile, one form is used
per pile, for easiness of eld work.
Fig. 3 shows, as an example, the eld form prepared for evaluating planning practices, featuring the best practice statements and
the columns to be lled in during eld work or document review, as
explained in the section below. In each form, blank lines are
provided for the assessor to add statements that may result from
particular or local conditions, such as legal or regulatory requirements, company internal procedures or recommendations arising
from technical studies such as environmental impact statements or
rehabilitation and closure plans.
4.2. Evaluation protocol
The central element of the assessment procedure is a comparison between practices actually applied in each mine and international best practices. In order to enable the comparison, evidence
has to be gathered by means of documents analysis, interviews and
technical inspections. Fig. 4 synthesizes in the procedure used for
conducting the assessment.
The generic model of an environmental audit (ISO, 2002) was
used as a basis to organize the tasks which appear on the left-hand
side of Fig. 4. It is not claimed, however, that the evaluation
procedure here developed is the equivalent of an audit, as audits
may have other requirements. A detail of the tasks to be conducted
while performing the assessment is shown on the right side of Fig. 4.
4.2.1. Evidence collection
Objective evidence is gathered by means of technical inspections and document review. For each best practice statement, the
following categories of evidences (modied from Viegas, 2002)
are used:
 Visual evidence (VE): obtained by direct observation; it can
justify a conclusion without any other evidence;
 Documental evidence (DE): obtained from document analysis,
such as an environmental impact study, a rehabilitation or
closure plan, monitoring reports, internal written procedures,
registers of an environmental management system or others;
documental evidence can be enough to register a non-conformity with best practices, but caution should be exerted, as
documents may be poorly written, outdated, factually wrong or
simply not reect actual practices, which may have deviated
from planned;

A.C. Neri, L.E. Snchez / Journal of Environmental Management 91 (2010) 2225e2237

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Table 1
Structure of eld forms and summary of best practice statements.
Type of rehabilitation
practice

Rehabilitation program

Name of eld form

Headings in each eld form

Planning practices

Planning

Rehabilitation planning

Rehabilitation and closure plan


preparation
Topsoil removal
Internal roads
Mine pit design
Waste rock piles design
Visual impact minimization
Site selection
Vegetation removal
Stakeholder involvement

Sub-total
Operational practices

Sub-total
Managerial practices

Soil management

Topsoil management, erosion


control and prevention of
contamination

Landform stabilization

Water management

Landform stabilization:
rock face stability
Landform stabilization:
waste rock pile stability
Water resources protection

Vegetation management

Vegetation management

Management of the
rehabilitation process

Management of the
rehabilitation process

Sub-total
Total

 Verbal evidence (I): obtained by interviews, forms the least reliable category because the interviewee may say only what he or
she thinks the assessor would like to hear or even get confused;
this kind of information should be treated with caution, and other
(visual or documental) evidences should be found for conrmation; double-checking with other interviewees is a commonly
recommended practice for conducting interviews.

4.2.2. Evidence classication


Actual practices observed in the eld are classied in one of
following categories in the appropriate column of the eld forms
(Fig. 3):
 Totally applied (TA): when the described practice is integrally
adopted in the quarry;
 Satisfactorily adapted (SA): when quarry staff has found an
equivalent or better solution to that described in the best
practice statement;
 Partially applied (PA): when the practice is not integrally
adopted;
 Non-applied (NA): when staff unjustiably does not adopt that
practice;
 Not applicable (NS): when the described practice is not applicable to the actual observed situation.
Professional judgement is essential to classify the practices. No
guideline or best practice manual can be directly or automatically
applied to any mine, without some degree of interpretation. In fact,

Number of best
practice statements
11
3
2
5
5
2
5
4
2

Topsoil segregation and removal


Topsoil storage
Surface preparation
Topsoil replacement
Surface ripping
Soil contamination prevention
Erosion control
Rock face stability

35
6
5
4
4
2
3
7
7

Waste rock pile stability

12

Surface water
Underground water
Vegetation removal
Visual impact minimization
Revegetation

11
5
7
3
14

Standardization of procedures
Human resources
Suppliers capacity-building
Environmental monitoring
Operational maintenance
Quality assurance/quality control

96
1
1
1
6
8
4
19
150

in spite of the common characteristics that most mines feature,


each mine is singular, due to particular geological, geomorphological or ecological characteristics or even due to its social
surroundings, Local conditions may not only turn a generic best
practice statement not directly applicable, but also can turn it as
non recommendable. One example is the management of topsoil. In
the vast majority of situations, topsoil should be removed separately from subsoil and spread as soon as possible in the surface to
be rehabilitated, as the seed bank contained speeds up vegetation
cover and can provide quick protection against the erosive potential
of runoff. However, the existence of weeds in the topsoil can be
a hurdle if the area is to be restored to natural vegetation cover and
it could possibly be more advisable to import soil from another
locality or to mulch or employ organic matter. One example is the
problem faced in the rehabilitation of Jarrahdale bauxite mine in
Southwest Western Australia, arguably a global benchmark in mine
rehabilitation. In the region, the soil-borne pathogen Phytophtora
cinnamomi causes the so-called dieback disease to the dominant
tree species jarrah (Eucaplyptus marginata) and many other species.
As ore bodies may feature both infested and not infested overlying
soil, special care must be exerted to avoid spreading the disease.
The mining company, which moves 6 million m3 of soil a year,
developed soil management protocols to prevent the spreading the
pathogen (Colquhoun and Kerp, 2007).
4.2.3. Data analysis
Technical inspections provide for the collection of qualitative
data. In order to make sense of the amount of data collected and
derive reliable and preferably reproducible conclusions, a data

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PLANNING FOR MINE REHABILITATION


Mi n e :

Dat e:

Purpose: To identify and assess mine rehabilitation planning practices


Classification: TA (totally applied practice),
SA (satisfactorily adapted practice),
NA (not applied practice),
NS (non-applicable practice).
Types of evidence:

VE (visual evidence),

DE (documental evidence),

Benchmarking

PA (partially applied practice),

I (verbal evidence).
Classificat
ion

Types of
evidence

Rehabilitation and closure plan


1. The company should prepare a rehabilitation plan
2. The rehabilitation plan should follow the contents recommended in
NBR 13030
3. The mine should have a closure plan
4. The closure plan should consider options for the future use of the
area
5. The rehabilitation or closure plan should indicate the
preferred alternative for the future use of the area.
6. The preparation of the closure plan should be made in consultation
with local community and other interested parties
7. Environmental reclamation measures should be planned at the same
time of the mining activities
8. A monitoring program should be included in the rehabilitation or
closure plan
9. An appropriate group of indicators should be selected to assess the
results of rehabilitation
10. The rehabilitation or closure plan should be periodically
reviewed and updated, especially in the ten year period before the
scheduled closure date
11. Provision of financial resources should be made to cover
rehabilitation and closure costs
Planning for topsoil removal
12. Topsoil removal should be scheduled as to minimize storage
time and maintain soil quality
13. Soil humidity should be characterized to define the best timing for
removal
14. The thickness of topsoil to be selectively removed should be
estimated
Planning of access roads, pit slopes and benches
15. A stormwater collection and transfer network should be calculated
using maximum probable rainfall estimated for the region
16. Final pit slope angles should be calculated according to the
geological-geotechnical features of the rock, as to determine a stable
final pit configuration
Planning for implementation of waste rock piles
17. A geotechnical study should be made as a condition to the design of
waste rock piles
18. A stormwater drainage network should be calculated based on local
or regional hydro-meteorological study
19. Areas featuring natural slopes above 18 o should not be selected to
build waste rock piles
20. Waste rock piles should not be placed above natural drainage lines,
water courses or springs
21. Waste rock pile should not be sited over instable or colapsible soils,
wetlands or areas subject to flooding
Planning for reducing visual impact
22. A plan to reduce visual impact should be prepared considering local
environmental features, the views over the mine and the quality of the
surrounding visual resources
Fig. 3. Example of a eld form used to collect and register evidence of rehabilitation practices during technical inspections.

Notes

A.C. Neri, L.E. Snchez / Journal of Environmental Management 91 (2010) 2225e2237

Classificat
ion

Benchmarking

2231

Types of
evidence

Notes

23. Community and interested parties should be consulted about the


best forms to reduce the visual impact
Studies for pit and waste rock piles planning
24. A hydrogeological study should be carried out before mine
opening or expansion projects
25. Karst system studies should include geology, geomorphology,
hydrology and biology
26. A speleological survey should be conducted
27. An archaeological and heritage survey should be conducted
28. If the mine can reach the groundwater level, an aquifer lowering
study should be conducted, determining lowering cone dimension
Planning for the vegetation removal
29. A previous flora study should be conducted whenever native
vegetation should be removed
30. Flora studies should be made in neighboring areas that present
fragments of native vegetation
31. Vegetation removal should be planned to be phased and scheduled
as late as possible in accordance with the mining plan.
32. Fauna studies including cave fauna should be made before native
vegetation removal
Community and interested parties involvement
33. The company should identify the interested parties and consult with
them for the preparation of the rehabilitation or closure plan
34. A community involvement plan should be developed stating
methods and approaches for involvement and for assessing the
outcomes
35. Community and interested parties consultation should be
documented and registers such as presence lists, minutes and pictures
kept for easy reference
Other planning activities adopted by the company
36.
37.
38.

* Additional notes and comments

in blue = essential practices

in red = important practices

in black = accessory practices

Fig. 3. (continued).

analysis procedure was developed. It is based on a hierarchy of best


practices statements and on calculations of conformity indexes
weighted by the importance of the practices. The best practice
statements were ranked in three classes of importance, thus
dening a scale for analysis (DeVellis, 1991) and providing
a semantic differentiation (Pereira, 2001) among the categories.
The best practices statements are arranged according to the
following classes of importance:
 Essential practices: those which are usually necessary for
a successful quarry rehabilitation program; however, upon

rmly grounded justication, an essential practice may not be


applied in a particular quarry;
 Important practices: those which feature a signicant contribution to a successful quarry rehabilitation program;
 Accessory practices: those whose implementation may lead to
a measurable improvement in the outcomes of a quarry rehabilitation program.
As good practice guides usually do not consider which recommended practices are more important, in classifying the best
practice statements included in this procedure, a number of criteria

2232

A.C. Neri, L.E. Snchez / Journal of Environmental Management 91 (2010) 2225e2237

Request of relevant
documents

Document analysis

Technical inspection
scheduling

Opening meeting

Technical inspection

Rehabilitation or Closure
Plan, Environmental Impact
Study, licenses and permits,
maps, aerial photos and
other technical documents
Document review,
collection of documental
evidence, field forms filling
in, identification of gaps

Survey of specific conditions


from environmental licenses
or legal requirements

Presentation of work
objectives and inspection
goals and time table

Walk in with experienced


staff for evidence
collection, interviews,
additional information
collection
Field forms filling in and
classification of practices

Closing meeting

Data treatment

Preparation of draft
report

Review and confirmation of


classification of practices;
double-check doubtful
evidence; calculation of
conformity index and level

Analysis and
recommendations
Review by mine
management

Issuance of the final


report
Fig. 4. Sequenced tasks in conducting the evaluation.

were adopted. Essential practices are those most frequently cited in


the reviewed guides, as well as practices often included in regulatory requirements in several countries (such as the preparation and
submission of a rehabilitation plan). Important practices include
recommendations found less frequently in the reviewed guides, as
well as those which stem from technical standards. Practices that
should be adopted only if a particular situation is present, such as
those related to pumping groundwater to dewater a pit, were
classied as accessory, so as not to negatively affect the conformity
index; also in this group are those practices which cannot be
regarded as universal recommendations, but if applied contribute
to the success of rehabilitation.
Table 2 shows the distribution of statements according to this
hierarchy. The fact that a majority of statements are ranked as
accessory practices is a recognition that rehabilitation measures
often have to be unique to a mine, thus stressing the importance of

Table 2
Distribution of best practices statements according to their hierarchy.
Hierarchy

Number of statements

Essential practices
Important practices
Accessory practices

25 (16.7%)
41 (27.3%)
84 (56%)

planning. Different colours in the eld forms indicate the hierarchy


of each statement (Fig. 3).
In performing the technical inspections, the assessor may
identify particular legal or regulatory requirements, such as
conditions resulting from licensing and requirements arising from
corporate policies or derived from voluntary codes subscribed by
the company. When collecting documentary evidence, the evaluator should include those conditions in the proper place of each
technical inspection form, in the case they represent additional
aspects not described in the statements. Interpretation may be
needed as to evaluate whether or not a legal or regulatory condition
is already covered by a generic best practice statement, as it is often
the case. Any legal or regulatory condition must be classied as
essential.
A conformity index is calculated for each group of practices: I1
for essential practices; I2 for important practices and I3 for accessory practices. The indexes are expressed as the percentage of
practices actually applied in the quarry, but weights are introduced
to reect the differences in the level of application of each best
practice statement. Hence, for each group, totally applied or satisfactorily adapted practices are weighted more than partially
applied practices, so that the index reects the semantic differences
embedded in these terms employed to describe evidence classication (Section 4.2.2). As rehabilitation measures derived from legal
requirements are also considered as essential, the weight assigned
is the same as the weight of essential practices. Not applied practices do not contribute to the index, thus zero weight is allocated,
whereas not applicable practices have to be deducted from the total
of practices as to obtain the percentage of application.
The weights used for each type of classication are:
1 for totally applied or satisfactorily adapted practices;
0.5 for partially applied practices and;
0 for practices which are not applied in a mine.
Thus, the indexes are calculated according to the following
expressions:

I1 PTA PSA PL 0:5PPA =


I2 PTA PSA 0:5PPA =

PESS PL  PNS

PIMP  PNS

I3 PTA PSA 0:5PPA =PACC  PNS

(1)
(2)
(3)

where: I1 index of essential practices; I2 index of important


practices; I3 index of accessory practices; PTA number of totally
applied practices; PSA number of satisfactorily adapted practices;
PL number of practices required by legal requirement;
PPA number of partially applied practices; PNS number of nonapplicable practices; PESS total number of essential practices;
PIMP total number of important practices; PACC total number of
accessory practices.
The next step is the calculation of a conformity index (CI) for
each one of the six rehabilitation programs (Table 1). Maximum
conformity was established at 100% and weights distributed for
each index according to its relative importance, as follows: I1 5,
I2 3, I3 2, thus reecting again a semantic differential and the
regularity of the intervals between classes. The conformity index is
calculated as follows:

A.C. Neri, L.E. Snchez / Journal of Environmental Management 91 (2010) 2225e2237

CI 5I1 3I2 2I3 =10

(4)

A conformity level is adopted to classify the conformity index in


one of three performance classes. A trafc light colour scheme was
adopted (Table 3), for the sake of facilitating communication. By
using such a scheme, mine managers, corporate committees and
other internal agents can quickly perceive strengths and weaknesses in their approach to mine rehabilitation.
4.3. Test and validation of the procedure

2233

At the moment of eld work, every quarry had a certied


environmental management system, according to the ISO 14001
management standard. Only one quarry had an environmental
impact study prepared recently due to an expansion project.
The conformity indexes obtained by applying the evaluation
procedure are shown in Table 4. The results obtained in the nine
quarries will be presented alongside the discussion in the next
section.
5. Discussion

The procedure was applied in nine limestone quarries situated


in Southeast Brazil in order to test, validate and rene its components. The eld forms were reviewed after the rst battery of test in
three quarries. Redundant statements were eliminated, as some
may be relevant to, say, both landform stabilization and water
management practices; in such cases they were placed in only one
of the rehabilitation programs.
After adjustments, the procedure was applied to six other
quarries, leading to the introduction of additional corrections. The
ndings were reported back to quarry managers, and input was
sought as to improve both the eld forms and the evaluation
protocol. Prior to this second round of eld tests, a workshop was
held with managers and quarry technical personnel, in order to
clarify the objectives and to survey the potential usefulness of
such a procedure to quarry staff. A call for quantiable results
which could easily communicate environmental performance was
expressed at this workshop. The development of conformity
indexes and conformity level classication is the response to such
need.
All quarries have been in operation for many years or decades.
As a consequence, many environmental protection practices which
are current today were ignored or unknown during a signicant
part of the life of these quarries. Under Brazilian law, rehabilitation
plans are mandatory for every mine, but no closure plan has to be
submitted to regulatory authorities. The quarries were located in
three states in the Southeast region of Brazil. State environmental
authorities are primarily responsible for licensing new mines or
expansion projects, as well as for supervising the implementation
of mitigation measures.

This section will mainly discuss the empirical results obtained in


the quarries. A discussion on the results of the application of the
evaluation procedure itself will be presented in the last part.
As shown in Table 4, the group of practices featuring the worst
performance is planning. Operational practices reached better
results, as high conformity level was obtained 18 out of 36 times
(50%), moderate conformity level was obtained nine times (25%)
and low level was obtained nine times (25%). The predominant
conformity level for the management practices was moderate,
with only quarry 2 reaching high conformity. This quarry is the
same that showed the high conformity level for the planning
practices.
5.1. Planning practices
Most quarries scored low in rehabilitation planning. All mining
companies are legally required to prepare and submit a rehabilitation plan to environmental authorities. Although the quarries are
distributed in three States, the administrative requirements are
very similar. As all quarries had submitted a plan, copies were
requested to perform the evaluation and were reviewed considering both regulatory guidance and the Brazilian technical standard
NBR 13030.
The good score obtained by quarry 2 can be explained by the
recent submission of its expansion project to the environmental
impact assessment (EIA) process. The EIA process requires the
preparation of an environmental impact study (EIS) containing
detailed background information on several aspects including

Table 3
Correspondence between conformity level and index.

conformity level

description

conformity index

A satisfactory set of adopted practices lead to risk


and impact prevention and to the correction of the
high
most significant degradation processes; there is a
0.75 CI < 1
high adherence to international best practices and
compliance with major legal requirements.
A number of best practices are adequately applied,
but the rehabilitation approach is in need of
moderate
0.40 CI < 0.75
improvement to reach satisfactory conformity with
international best practices in mine rehabilitation.
Few or no practices are effectively applied,
showing low adherence to international best
low
practices in mine rehabilitation; the current
CI < 0.40
approach may jeopardize the fulfillment of
rehabilitation goals.

2234

A.C. Neri, L.E. Snchez / Journal of Environmental Management 91 (2010) 2225e2237

Table 4
Conformity indexes and levels obtained for the evaluated quarries.

quarry

1 (1)
2 (1)
3
4
5
6
7
8
9
(1)

year
started
1947/1990
1949/2005

1977
1937
1936
1936
1936
1982
1982

ISO
practices
14001
operational
managecertifi- planning
soil
landform
water
vegetation
ment
management stabilization management management
ed?

yes
yes
yes
yes
yes
yes
yes
yes
yes

0.54
0.78
0.24
0.07
0.31
0.28
0.29
0.25
0.20

0.75
0.80
0.65
0.18
1
0.72
0.85
0.78
0.80

0.80
0.54
0.52
0.16
1
1
1
0.32
0.30

0.82
0.42
0.51
0.45
0.80
1
0.61
0.80
0.75

0.52
0.80
0.06
0
0
0
0
0.80
0.80

0.54
0.80
0.57
0.57
0.57
0.57
0.57
0.60
0.55

Quarries 1 and 2 were expanded respectively in 1990 and 2005, having prepared an environmental impact study.

groundwater, caves, ora and fauna and greatly contributes to the


environmental planning of a mine (Ramcharam and Dey, 2005)
as well as to its management (Dias and Snchez, 2000). The
second best score in planning was obtained by the only other
quarry in the sample that submitted an EIS due to its expansion
in 1990.
It was found that only in three quarries (1, 2 and 8) speleological
surveys were conducted for the quarry area and surroundings. Not
only is undertaking such studies an internationally recognized
good practice, but also their absence represents a risk for companies operating in Brazil, since, under Brazilian law, they can face
lawsuits if speleological assets are damaged. Notwithstanding,
these studies did not seek to unveil the possible inuence of the
mines on local karst dynamics.
Another infrequent study is hydrogeology, which should be
prepared whenever a quarry can reach the groundwater level or
when karst aquifers can be affected. Although most quarries
operated below the natural groundwater level, a comprehensive
hydrogeological investigation was conducted only for quarry 2,
again as part of the EIA.
Although karst can develop in any limestone area, karst is
known to be well developed only near quarry 9. However,
a comprehensive survey of karst landforms and hydrology was not
conducted. Such a study provides inputs for siting waste rock piles
and other quarry components.
A signicant shortcoming of planning is the absence of postmine land use plans, apart from quarries 1 and 2. No quarry has
a closure plan, a specic recommendation contained in the CSI
guidelines (WBCSD, 2005a) which is becoming standard in the
mining industry (ICMM, 2008). Only quarry 2 presented a detailed
cost estimate for implementing rehabilitation measures during the
operational phase.
Initiatives aimed at the involvement of the local community in
the planning for rehabilitation or closure were thoroughly absent in
all cases, again with the exception of quarry 2, as public hearings
are mandatory in the EIA process.
Good planning practices were found in quarries 8 and 9, despite
their poor overall score in this program. Ecological restoration
conducted in these quarries (which featured the highest scores for
vegetation management practices) are based on robust planning,
which included a detailed survey of physical characteristics of
waste rock piles as a basis to recommend species selection, planting
and soil improvement approaches.

5.2. Operational practices


Soil management practices involve topsoil management,
erosion control and prevention of contamination. They ranked high
in six out of nine quarries, with only one quarry showing poor
practices.. Most quarries installed aboveground fuel storage tanks,
decommissioning underground tanks and undertaking soil
contamination investigations; three quarries built new workshops
for heavy equipment maintenance with impervious ooring and
other facilities to prevent soil and water contaminations, as well as
fuel stations designed to prevent leaks.
Landform stabilization practices featured three quarries
showing poor performance. Although most quarries showed
evidence of effective geotechnical control of pit slopes, in one
quarry a landslide occurred and few quarries paid equivalent
attention to waste rock piles. This reects an outdated mining
engineering approach under which the pit is subject to control for
safety and operational reasons, but waste rock is considered as
rubbish to be discarded at the lowest possible cost. The nature of
the material disposed of in waste rock piles varies from coarse rock
fragments (such as low grade carbonate rocks or other lithology) to
ne grained weathered soils including clays not suitable to cement
production. As water is the main disruptive agent in such waste
piles, stability is closely dependent on adequate management of
runoff. In a region subject to intense concentrated rainfall (up to
100 mm in 1 h), devices built to direct and retain runoff are
common practice, some comprising both sedimentation and inltration ponds. Gutters and other devices collect runoff alongside
internal roads and especially over waste rock piles. Notwithstanding, although most inspected mines built drainage systems in
waste rock piles, their dimensions were empirically estimated
instead of being based on hydrometeorological calculations. In
quarry 4, sediment from the waste piles is silting up trees located
downhill. In quarry 8, the absence of sediment retention devices is
silting up a small alluvial plain situated downstream of a waste pile.
Water management practices scored relatively well. They are
largely interrelated with soil protection and landform stabilization,
as explained above. Runoff and groundwater collected in pits is
used for dust suppression, but all quarries have excess water to
discard to creeks after sediment retention. Groundwater collected
in quarry 1 is used in the cement plant. In quarry 9, a waste rock pile
placed near a possible doline (a closed depression in the terrain)
could be a source of sediments to clog subterranean conducts and

A.C. Neri, L.E. Snchez / Journal of Environmental Management 91 (2010) 2225e2237

damage fauna; however, the absence of comprehensive studies of


the karst system precludes any rm conclusion.
The practices related to vegetation handling include procedures
for clearing and planting and use of vegetation screens to reduce
visual impact during operations. Five out of the nine quarries
showed the lowest conformity level, with three quarries presenting
no practices related to vegetation management at all (zero score).
Those quarries have no register of vegetation removal, as it was
carried out decades ago and no further vegetation clearance was
necessary in recent years, but no revegetation trials were conducted. In contrast, quarries 8 and 9 implemented several actions
towards managing natural vegetation aiming at restoring ecological
values in the affected areas. Both quarries commissioned studies to
guide planting and implemented the recommended actions,
tailored to local climatic and soil conditions. In these quarries,
planting native species is preceded by soil preparation, achieved by
sowing short-cycle gramineae and leguminous plants adapted to
the local conditions. This procedure enables the substrate to quickly
acquire physical, chemical and biological features which are
favourable for the development of native species seedlings planted
in general one year later. A commendable initiative was undertaken
in quarry 9, where an internal road was relocated away from
a creek, making room for the restoration of the riparian forest;
relocating other roads is planned. Restoring riparian vegetation was
also implemented in mine 1 and could have been done at least in
limited areas of all mines.
5.3. Management practices
Only one quarry reached high conformity, the same quarry
which featured the highest score in planning practices. On average,
management practices are much better than planning practices.
It could be expected that the scores for management practices
would feature a higher percentage of high conformity, as all
quarries have a certied environmental management system.
However, those EMSs pay low attention to issues pertaining to land
rehabilitation and biodiversity. It has been found that several
quarries do not have written procedures applied to rehabilitation.
Moreover, in quarries which do have such procedures (e.g. periodical topographical monitoring and control of waste rock piles
stability), these are not applied as required in the company documents. Those companies rely extensively on external consultancy
and contractors to plan and to undertake rehabilitation activities,
especially revegetation.
On the other hand, all quarries have ongoing operational
procedures for a number of activities related to soil and water
protection e such as used oil collection, storage and management,
prevention and control of fuel and lubricants leaks and waste
management in heavy equipment maintenance workshops e which
are important for rehabilitation, but are also relevant to several
industrial activities, including cement manufacturing. For these
issues, management programs and actions can to a large extent be
standardized across several industrial sectors. By contrast, mine
rehabilitation often requires tailor-made procedures.
As an ISO 14001 EMS needs to be periodically audited, the
technical inspections sought to collect evidence on the role of
auditors in verifying the rehabilitation programs undertook in the
quarries they audit. Interviewees systematically answered that
environmental auditors attach a great importance to compliance
with regulations and good practices related to waste management
in general and to used oil, fuel and lubricant management as to
prevent leaks, but do not conduct detailed audit of practices
specically related to land rehabilitation, especially revegetation,
nor do auditors usually ask for evidence of vegetation or fauna
surveys or monitoring.

2235

The relatively low importance of land rehabilitation in internal


management is also reected in the environmental monitoring
programs adopted by the companies. All mines monitored the
surface waters, but none systematically monitored vegetation or
any other biotical aspects.
5.4. The evaluation procedure
For the sake of logical application and in order to limit the
amount of best practices statements in each eld form to
a manageable number, the practices were organized under six
rehabilitation programs (Table 1). However, as the practices are
interrelated, it is not possible to ll in the forms in the eld simply
by following the order the statements appear. As going back and
forth is inevitable, the assessors have to be familiar with the forms
before starting.
It was also found, consistently with the practice of environmental auditing, that the evaluation procedure is best applied in
teams. All eld work was performed by the two authors and would
hardly be done by only one professional. As in most kinds of
environmental audits, eld work is more effective and efcient if
preceded by a careful examination of key background documents
(Fig. 4). An understanding of the physical setting of each mine is
also essential, thus maps and aerial photos are extremely helpful in
performing eld work.
Exerting professional judgement is necessary during all phases
of the assessment, but especially in classifying the actual practices
in one of the ve categories (Section 4.2.2). As the quarries feature
certied EMSs as well as safety and health procedures, staff is used
to and understands the purposes of audits (Power, 1997). Thus,
applying the evaluation procedure was relatively straightforward. It
is imperative that in doing eld work the assessors are escorted by
knowledgeable staff. Sometimes, however, such persons simply
cannot be found among current staff, suggesting organizational
amnesia, as knowledge owned by individuals is not stored in
organization memory (Othman and Hashim, 2004).
In reaching conclusions and making recommendations, understanding of the rehabilitation process as made up of six programs is
helpful in identifying the root causes of some poor practices. Thus,
a number of waste rock piles are not better integrated into the
surrounding landscape simply because the stacks were not planned
for a nal landform.
The proposed framework can verify if a quarry meets the key
performance indicators agreed by the signatory companies of the CSI
(WBCSD, 2005b, 2007). The case studies showed that out of the three
key performance indicators of local impacts on land and communities adopted by the CSI, all quarries comply with the rst (having
a quarry rehabilitation plan), but not with the two other (having
community engagement plans in place and to address biodiversity
issues). However, these indicators are generic and do not inform on
the contents of such plans or about their actual achievements,
aspects that can be evaluated by the proposed procedure.
6. Conclusions
The proposed procedure for evaluating environmental rehabilitation measures in limestone mines is an analytical tool that can be
successfully applied during the operational phase of a quarry. If
periodically and systematically applied, the evaluation tool can
document the evolution of rehabilitation practices in one particular
quarry and show their improvement over time, storing robust
evidence to demonstrate achievements. The results of a rst evaluation can identify risks and lead to recommendations for
improving ongoing practices. It can also identify best practices
adapted to local conditions that could be spread to other quarries

2236

A.C. Neri, L.E. Snchez / Journal of Environmental Management 91 (2010) 2225e2237

operated by the same company or adopted as a benchmark. The use


of a predened scoring system facilitates benchmarking and
comparison among companies or mines operated by one company.
Usefulness of the conformity index is twofold: a quick view is
provided by the trafc lights colours scheme whereas the numerical index allows for nuanced differentiation between sites and for
charting the evolution of rehabilitation practices if the procedure is
applied at regular intervals.
By using such a scheme, quarry managers, corporate committees and other internal agents can quickly perceive strengths and
weaknesses in their approach to quarry rehabilitation. The
conformity indexes and levels can also be used to establish
corporate goals, as to have a certain percentage of sites featuring
high conformity level. External and internal communication can
also be facilitated as conformity levels can be incorporated into
environmental performance or sustainability reports.
The case studies showed that out of the three key performance
indicators of local impacts on land and communities adopted by the
CSI, the quarries only comply with one (having a quarry rehabilitation plan). One shortcoming observed in all quarries is the great
reliance on external consultants and contractors to undertake most
rehabilitation tasks. By adopting such an approach, the companies
do not entail a process of organizational learning, as rehabilitation
is not integrated into strategic planning. The best evaluative scores
were reached by quarry 2, featuring four programmes at high
conformity and two at moderate conformity level. The fact that this
mine has recently been submitted to the EIA process suggests that
public scrutiny may play a positive role in enhancing rehabilitation
practices, what is corroborated by the nding that the second best
was also subject to EIA.
The appropriate use of the framework requires: (a) the companys commitment and genuine interest in evaluating its practices
in order to improve environmental performance, and (b) that the
assessors have professional or academic experience in mine rehabilitation in order to interpret eld evidence and reach meaningful
conclusions.
The procedure can also be applied to other quarries or to mines
of industrial minerals, as limestone quarrying shares several characteristics with those other kinds of mines. The procedure can also
be adapted to metal mines, provided eld forms are adjusted and
new best practice statements and eld forms related to tailings
disposal and issues such as acid mine drainage are added.
Acknowledgments
The authors thank FAPESP e So Paulo State Research Foundation for its nancial support to this work (register n. 2005/58089-0)
and the Brazilian cement companies who kindly agreed to participate in this research.
Appendix. Supplementary material
Supplementary data associated with this article can be found, in
the online version, at doi:10.1016/j.jenvman.2010.06.005.
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