Closure planning to comply with the International Cyanide Code

Closure planning to comply with the International Cyanide Code

About 10 years ago, a multi-stakeholder group created a system that demonstrates a company’s voluntary commitment to environmental standards under the International Cyanide Code. Companies certified under the Code (referred to as Signatories) have publically committed to comply with its requirements and have demonstrated that their business is environmentally responsible. Principle 5 of the Code concerns decommissioning and addresses the issue of closure, which was often overlooked or underfunded by the mining industry in the past. The Code focuses exclusively on cyanide-related activities, and excludes some other typical closure activities, such as physical stabilisation and reclamation.

The Code objective regarding closure states: “Protect communities and the environment from cyanide through development and implementation of decommissioning plans for cyanide facilities.” There are two Standards of Practice associated with the decommissioning principle. The first states that Signatory companies must “Plan and implement procedures for effective decommissioning of cyanide facilities to protect human health, wildlife and livestock.” The second states that Signatory companies must “Establish an assurance mechanism capable of fully funding cyanide related decommissioning activities.” The Code places the burden on the company to demonstrate compliance with broad objectives and goals, but does not address technical methods to achieve compliance.

The Code requires a written decommissioning plan that includes three key parts: (1) the methodology to be used to decommission at each cyanide-related facility; (2) a schedule of closure activities; and (3) a cost estimate. The closure methodology should address decontaminating equipment and facilities, such as rinsing equipment‚ removing residual cyanide reagents‚ and neutralising heap leach pads. The schedule need not be based on calendar dates; a better method is sequencing the tasks involved. The company must establish a financial assurance mechanism based upon the cost of a third-party contractor implementing the decommissioning activities.

The Code does not specify when the closure plan should be updated, but if changes occur, the closure plan will need to be current and up-to-date to pass periodic audits required to maintain certification.

By complying with the closure requirements, companies show their stockholders, lending institutions, the public and other stakeholders that their operations are environmentally responsible. Long-term benefits include better support from stakeholders; lower risk operations; reduced liabilities; and easier financial funding.

Dawn Garcia: dgarcia@srk.com

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