Mines

Reclamation of Abandoned Mining Sites

Some mining sites in Québec are considered abandoned because they do not have a known or a solvent owner. Others that have been transferred back to the State or released by means of a certificate pursuant to section 232.10 of the Mining Act .

In 2007, a program for contaminated sites (called Passif au titre des sites contaminés [PTSC]) was entered into the public accounts by the gouvernement du Québec. Among other things, the program contains a list of abandoned mining sites.

On March 31, 2021, the ministère de l’Énergie et des Ressources naturelles (MERN) entered an amount of $ 1.05 billion into the public accounts as its environmental liability related to mining sites. The amount includes $ 761.3 million for abandoned mining sites and $ 290.9 million for mining sites in respect of which the MERN may have to take action in the future due to the precarious financial state of the companies that are currently responsible for them. As of March 31, 2021, the MERN has invested $ 206.7 million since 2006 for reclamation, security, maintenance and monitoring of abandoned mining sites.

As of March 31, 2021, there are in Québec’s PTSC :

  • 223 abandoned mineral exploration sites;
  • 174 abandoned mining sites including:
    • 9 undergoing legal validation;
    • 25 undergoing characterization;
    • 20 to be reclaimed;
    • 7 undergoing reclamation;
    • 109 that have been reclaimed or secured and in respect of which the MERN is responsible for monitoring and maintenance;
    • 4 to be secured.
  • 3 quarries and sand pits.

In addition, 56 abandoned mining sites not found to be contaminated have been removed from the PTSC, but are still under the responsibility of the MERN.

The MERN has introduced a work plan that plan to reduce the environmental liability from abandoned mining sites under its authority, in compliance with its undertakings following the recommendations made by the Auditor General of Québec in a report dated June 2018.

The MERN publishes annually a report of reclamation work resulting from the work plan for reclamation of abandoned mining sites:

Moreover, the MERN publishes annually the list of contracts awarded for the reclamation of abandoned mining sites.

Reclamation Process

In most cases, past mining activities at the abandoned sites took place several decades ago and generated tailings that were uncontained (without tailings storage facilities). As a result, the potential for impacts on human health and the environment is high. In some cases, site reclamation is a significant challenge, first because of problems such as acid mine drainage, contaminated neutral mine drainage, contamination from related industrial activity and ore concentration, equipment and machinery maintenance, security of underground openings and so on, and second because of the size of the areas concerned, their remote locations and the context in which the work must be carried out.

The MERN’s reclamation process for abandoned mining sites is divided into eight steps:

  1. Preliminary studies/Characterization: regroups together actions to determine the presence and extent of contamination and the ensuing risks and impacts, and to assess issues associated with non-environmental fields such as geotechnics;
  2. Design of reclamation scenarios: consists in selecting and presenting restoration scenarios for the mining site;
  3. Validation of the reclamation scenario: the chosen reclamation scenario must be based on the best available reclamation techniques and must be technically and economically achievable;
  4. Preparation of a reclamation plan: presents the concepts of the scenario, and preliminary engineering;
  5. Obtaining fieldworks authorizations and permits: obtain permits and authorizations from provincial and federal departments or agencies, municipalities, etc., for each work phase;
  6. Preparation of plans and specifications for construction: the final plans and specifications are technical documents describing the work so that it can be carried out by a contractor;
  7. Carrying out of reclamation work: awarding of contracts to one or more contractors for execution and monitoring of the work;
  8. Post-reclamation monitoring and maintenance: activities carried out to ensure that the work has achieved its environmental, agronomic and geotechnical aims. Infrastructure maintenance.

What Next?

The gouvernement du Québec has tightened the rules governing mine closure plan, to ensure that it will no longer inherit sites for reclamation without also receiving the money required to perform the work. The closure plan must be approved before a mining lease is issued, and the lease holder must provide a financial guarantee covering 100% of the reclamation cost for the entire site. The guarantee money must be deposited in the two years following approval of the plan. These two measures will significantly reduce the likelihood that the State will have to pay the cost of mine reclamation work.