Efficient Permanent Closure of Abandoned Mine Safety Hazards on BLM-Managed Lands

By Christopher Ross, Natural Resource Specialist, BLM, Nevada State Office

Background
Abandoned mine land (AML) sites are a significant threat to public safety throughout the western United States. Although fencing and posting signs may provide temporary remediation of this threat, permanent closure is the only positive method for eliminating hazards. Nevada has an estimated 50,000 AML sites on land managed by the Bureau of Land Management (BLM) that pose significant threats. The BLM staff has embarked on a mission to deal with this on a large scale.

To do so as efficiently as possible, staff first prepared a statewide programmatic Environmental Assessment (EA) for the Remediation of Abandoned Mine Safety Hazards. This eliminated the considerable task of preparing a separate EA for each closure. The EA followed the standard format for National Environmental Policy Act (NEPA) analysis. Widespread public notification and public meetings were held to identify issues for analysis during the scoping process. A special effort was made to get input from small miners, bat conservationists, and archaeological interests.

Discussion
The Programmatic EA supports a “formal finding of no significant impact” (FONSI) for mine closure sites that are properly analyzed and cleared under the EA. The result of this NEPA process is that a Documentation of NEPA Adequacy form can be quickly and efficiently completed for AML sites scheduled for closure under the programmatic EA. This process reduces both staff time and paperwork.

Information and processing procedures for mine closure were developed as follows (for more information on each procedure, contact the author):

• Conduct site ranking
• Determine site ownership and responsibility
• Carry out procedures for archaeological and cultural surveys and requirements for monitoring and documentation
• Conduct wildlife surveys in accordance with State and Federal guidelines
• Conduct threatened and endangered (T&E) species surveys and clearances
• Monitor other sensitive species
• Issue special notifications for wilderness and wilderness study areas
• Consider Visual Resource Management so that closure activities do not adversely affect the landscape
• Specify performance measures for conducting and documenting procedures

The order in which tasks are accomplished greatly affects efficiency. First, land status and responsibility are determined to eliminate sites for which the BLM is not responsible. Next, topographic quads are annotated and copied for future use. Finally, a site visit is made to determine hazard ranking and assign a unique site tag identifier.

A major lesson learned from our experiences is that the geologists, archaeologists, botanists, and biologists should visit the sites together, preferably in the same vehicle. This spares various specialists from conducting detailed survey work if another specialist finds issues that would preclude permanent closure in any situation. Examples might include a cultural site that cannot be disturbed, terrain that precludes access by heavy equipment, or a site that has wildlife habitat value and requires gating rather than backfilling. A simultaneous site visit by all specialists also saves time and confusion on remote or hard-to-access sites.

Once these initial surveys are completed, sites that require more intensive clearance can be listed. These may include detailed archaeological and cultural documentation, T&E clearances, or bat surveys. In some instances, it may be important to notify local law enforcement agencies of the intent to close sites, since AMLs are popular disposal sites for various criminal activities.

A major challenge in the clearance process is tracking the status of the various surveys. Nevada State Office surveyors use an Excel spreadsheet, which includes the site name, number, legal status, geographic coordinates, hazard ranking, topographic quad, and other information. Cells are included for notes on the various surveys, and as each survey is completed, the information is summarized in the cell, along with the date and initials of the surveyor. An example of a portion of a spreadsheet is shown in the Table. The recorder includes a note on whether the site can be closed, with or without further work. It has proven best to have one person responsible for these data, so that multiple versions do not evolve. As each update is made, the sheet is given a new version number so that the most up-to-date information is clearly indicated. As the spreadsheet is completed, the decision on whether the site should be backfilled, gated, or ignored becomes easy to make. At the same time, any remaining work to be done is clear. Scheduling is also facilitated, since sites can be easily grouped by access route or jurisdiction, and limitations are noted.

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Contact
Christopher Ross, Ph.D.
Natural Resource Specialist
Bureau of Land Management
Nevada State Office
P.O. Box 12000
Reno, NV 89520
Phone: 775-861-6571
Email: c1ross@nv.blm.gov

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