SRK China has conducted numerous environmental due diligence projects in China’s mining industry. Based on our site observations, some major environmental issues are either not covered by current Chinese Environmental regulations or not dealt with properly due to a lack of law enforcement.
Site contamination assessment has not been required in China, yet poor materials handling, leakage and spills, which would potentially contaminate groundwater and soils if not properly contained, is widely observed on projects. Without any regulations to restrict pollution, groundwater and soil contamination will continue and the remediation costs for site cleanup will be high.
Acid Mine Drainage (AMD) is not covered by any regulations. A simplified test conducted by a certified lab generates some test leachate from the waste rock or tailings samples. Depending on the analysis of the leachate (mostly heavy metals), the waste rock or tailings are considered hazardous or general waste. In some mines, tailings are considered general waste and no anti-infiltration measures are installed; however, AMD is often observed at the toe of tailings storage facilities (TSFs).
According to Chinese regulations, any TSF discharging waste water shall have a discharge point with various controls installed – real time water quality monitors, alarm systems, emergency back-up ponds. SRK China has observed only very few TSF’s with properly installed controls at the discharge points.
Bond payments for mine site rehabilitation are necessary to obtain a mining license in China. During environmental due diligence studies, SRK is provided with bond payment receipts, however the amount of payment is often insufficient to complete rehabilitation – most of the time being 60% to 80% short.
Usually, Chinese mine sites lack a comprehensive stormwater management system to control surface runoff, and soil erosion is a big problem. There are no regulatory guidelines in China for sedimentation pond design and swale design (sizing, spacing, slopes, and lining types). In most cases, poorly maintained and under-sized swale systems are observed on sites.
A land disturbance registry was established by Chinese Land Reclamation Regulation in 2011. This live documentation system records any land disturbance areas during the mine operation. However, at most mine sites, no operational data is collected at all.
In 2013, China’s election year, the new government announced that environmental protection will be a higher priority on the political agenda, and therefore, we look forward to more regulations and efforts to mitigate these environmental problems.
