framework of the proposed mine and infrastructure closure...

Nimba Western Range Iron Ore Project, Liberia Environmental and Social Studies, 2008-2015

Project Phase 2: Concentrator Environmental and Social Impact Assessment

Volume 7: Framework of the Proposed Mine and Infrastructure Closure Plan

March 2013

Framework of the Proposed

Mine and Infrastructure Closure Plan

for Project Phase 2, 2015 to 2034

VERSION DATE: 6 FEBRUARY 2013

ArcelorMittal Liberia Ltd.

P.O. Box 1275 Tubman Boulevard at 15

th Street

Sinkor, Monrovia Liberia

T +231 77 018 056

www.arcelormittal.com

Nimba Western Range Iron Ore Project, Liberia

Environmental and Social Studies, 2008-2015 Framework of the Proposed Mine and Infrastructure Closure Plan for Phase 2, 2015 to 2034

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Contents

1. OVERVIEW OF APPROACH .......................................................................................................... 4

1.1 Requirement of a Mine Closure Plan ...................................................................................... 4

1.2 Standard Practice in Mine Closure Planning .......................................................................... 5

1.3 Closure of the Nimba Western Range Mines .......................................................................... 6

1.4 Experience from the LAMCO Nimba Mine .............................................................................. 7

2. MDA COMMITMENT TO ASSET DISPOSAL .............................................................................. 10

3. OPERATIONAL CLOSURE APPROACH ..................................................................................... 12

3.1 Progressive Closure of Project Elements ............................................................................. 12

3.2 Introduction to the Rehabilitation of Mined and Infrastructure Areas .................................... 15

3.3 Mine Closure Procedure ....................................................................................................... 15

4. OPERATIONAL CLOSURE OF EQUIPMENT AND INSTALLATIONS ........................................ 18

4.1 Decommissioning of the Mine and Rail Fleets ...................................................................... 18

4.2 Decommissioning of Stores and Workshops ........................................................................ 18

4.3 Closure of the Railway .......................................................................................................... 18

4.4 Closure of Quarries ............................................................................................................... 19

4.5 Closure of the Port of Buchanan ........................................................................................... 19

4.6 Decommissioning of Company Townships ........................................................................... 20

4.7 Final Disposal of Waste Materials ......................................................................................... 21

5. OPERATIONAL CLOSURE OF MINE AND INFRASTRUCTURE SITES .................................... 22

5.1 Re-profiling of Mine Pits ........................................................................................................ 22

5.2 Stabilisation of Waste Dumps ............................................................................................... 22

5.3 Re-soiling of Mine and Dump Sites ....................................................................................... 23

5.4 Revegetation of Mine and Dump Sites ................................................................................. 24

5.5 Tailings Management Facility ................................................................................................ 26

6. RAINFOREST HABITAT RESTORATION ON THE MINE SITES ............................................... 29

6.1 Potential Landscape at Completion of Mining ....................................................................... 29

6.2 Landscape Rehabilitation ...................................................................................................... 29

6.3 Skills and Resources for Rainforest Restoration .................................................................. 31

7. EARLY AND EMERGENCY CLOSURE SCENARIOS ................................................................. 32

7.1 Contexts of Early or Emergency Closures ............................................................................ 32

7.2 Short Term Voluntary Closure ............................................................................................... 32

7.3 Short Notice Emergency Closure .......................................................................................... 32

7.4 Emergency Sudden Abandonment ....................................................................................... 33

8. DEVELOPMENT AND EVOLUTION OF THE MINE CLOSURE PLAN ....................................... 34

9. ENSURING THE SUCCESS OF THE CLOSURE PLAN ............................................................. 35

9.1 Financing of the Closure Plan ............................................................................................... 35

9.2 Evaluation of the Implementation of the Closure Plan .......................................................... 35

9.3 Post-closure Environmental Monitoring ................................................................................ 35



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List of Abbreviations AML ArcelorMittal Liberia

BCP Biodiversity Conservation Programme (AML‟s Phase 1 pilot for an offset programme)

CLO Community Liaison Officer

CF Community Forest

CFMB Community Forest Management Body

DSO Direct Shipping Ore

EIA Environmental Impact Assessment

EMP Environmental Management Plan

ENNR East Nimba Nature Reserve

EPA Environmental Protection Agency

EPML Environmental Protection and Management Law

ESIA Environmental and Social Impact Assessment

FDA Forestry Development Authority

HSE Health, Safety and Environment

IAIA International Association of Impact Assessment

ICMM International Council on Mining and Metals

IFC International Finance Corporation

LEITI Liberian Extractive Industries Transparency Initiative

MDA Mineral Development Agreement

NTFP Non-timber Forest Product

PA Protected Area

SHE Safety, Health and Environment (a department of ArcelorMittal Liberia)

V:h Vertical:horizontal



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1. OVERVIEW OF APPROACH

1.1 Requirement of a Mine Closure Plan ArcelorMittal undertakes to close its operations in a controlled and responsible manner, and to leave its concession in as clean, sound and prosperous a condition as possible. This document explains how a Mine Closure Plan will be developed and evolved as the project is set up and implemented. Liberian law also requires that a company must have a formal closure to its mining business. In accordance with the requirements of the Mineral and Mining Law (MML), the Environmental Protection Management Law (EPML) and international best practice, following completion of mining activity, the land will be restored to its “prior state, or where this is not feasible to do so, then to undertake such reclamation as will render the land useful for economically and socially desirable purposes”. The Feasibility Study for the project stated that the reclamation plan for final mine closure after concentrate mining would be devised as part of the ESIA for that phase. It pointed out that mining is expected to lead to major re-shaping of the mountain topography and stripping down in some places to fresh, unweathered gneiss. It will not therefore be possible to restore the site to its former standard, so the plan will be to close it in such a way that enables it to blend back into the landscape as far as possible. This would typically involve re-profiling the slopes wherever practicable and forming stable permanent drainage systems. Following this, the main actions required would be the restoration of vegetation cover and re-creation of habitats around the fringes to the greatest extent permitted by the resulting geology and the availability of spoil material (which includes excavated material required to be stockpiled for mine closure landscaping) and topsoil. The Feasibility Study also stated that, in addition to the plans for programmed mine closure, emergency shutdown procedures would be devised as part of the Environmental Management Plans (as they were for the DSO project). These would be invoked in the event of force majeure causing a sudden cessation of mining, and would be aimed at minimising environmental damage that might otherwise occur as a result of rapid abandonment. Elements of mine reclamation form elements of the Environmental Management Plans that are the key implementation elements of the ESIAs for both project phases. Nevertheless, it is clear that post-mining withdrawal will need to be a lengthy process to ensure completion of the following main issues.

Making the areas safe for the resumed use of the land by people and animals.

Decommissioning of all facilities (workshops, crusher plants, stockpile yards, concentration and tailings management) into conditions that ensure minimal subsequent maintenance and the greatest possible, non-polluting, long term stability.

Restoration of slopes and drainage channels so that the production of runoff and sediment are reduced to the ambient levels of the surrounding natural landscape

Installation of permanent drainage systems to ensure long term stability of gullies and valley bottoms. These may need to be over-designed for the short term to ensure that potential adaptations to climate change are catered for in the longer term.

Restoration of habitat, as far as is practicable, particularly with the expansion of plants and smaller animals back into the restored land from the retained forest refuges on the peripheries of the sites.

Development of sustainable forest management systems, which would typically be through a Community Forest Management Body or similar organisation established in a nearby community.

It is anticipated that the housing, railway and port facilities will be retained by the Government of Liberia as national assets, and converted to other uses. The mine closure plan will include provision for the transfer of ownership to ensure that this occurs smoothly.



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1.2 Standard Practice in Mine Closure Planning International best practice of mine closure is currently evolving, but a number of guidelines are available. Those published by the International Council on Mining and Metals (ICMM) have been consulted by ArcelorMittal Liberia in the preparation of this conceptual framework document. This stresses the importance of building detail on to the closure planning process from the exploration stage onwards, so that the post-mining situation can be envisaged from the very beginning of the process and embedded into the long term strategy. Figure 1 shows the conceptual diagram used by ICMM to illustrate this. Figure 1. Indicative timeframe for mine closure planning. Source: International Council on Mining and Metals (ICMM), Planning for Integrated Mine Closure: Toolkit, 2008.

Key features advocated by the ICMM are as follows.

Community stakeholder involvement in the process should be proactively ensured rather than focussing entirely on environmental issues. It is the community that needs to take ownership and be enabled to create a post-mining environment.



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Beyond the physical decommissioning of mine and infrastructure elements, it is important to have a clear vision for the post-mining environment. This is particularly important for the socio-economic and biological environments.

Goals should be set for achievement of closure activities, to ensure appropriate, high standard and timely results.

Cost estimates need to be devised in good time, even if there is still a large range variability, to ensure that adequate financial resources are made available.

The ICMM approach also involves an assessment of risk and opportunities, for the following reasons:

To minimise the negative consequences of closure;

To maximise the positive benefits of closure;

To minimise the likelihood that closure goals are not met; and

To maximise the likelihood that opportunities for lasting benefits are captured. In addressing this, it is recommended to cover six main categories of risk: health and safety; natural environment; social; reputational; legal; and financial risk. The framework provided in this document sets the scene for the ICMM approach to be followed, and for these key elements to be adequately covered. In summary, the approach of ArcelorMittal Liberia is to ensure that closure encompasses both:

the decommissioning and environmental rehabilitation of physical installations; and

the creation of a healthy and sustainable post-mining socio-economic environment.

1.3 Closure of the Nimba Western Range Mines As described later in this document, the Company is obliged to involve the Government of Liberia in the disposal of assets at mine closure. Beyond that there are no legal requirements for the process of closure, but the Company is committed to leaving the sites in as healthy a condition as possible. This means that it is important to address both the physical and the human side of closure. At this stage, it is anticipated that closure of the Tokadeh, Gangra and Yuelliton mines would involve the following main physical activities.

Standard asset disposal (by transfer to other sites, sale or scrapping) of all equipment, including excavators, bulldozers, payloaders, trucks, shipping containers, vehicles, buses etc.

Decommissioning and cleaning of all workshop and stores areas, and fuel and oil handling facilities.

Removal of all crushers, buildings, workshops, concentrator facilities, mobile and fixed plant, structures etc, including foundations, maximising recycling of all materials.

Filling and sealing of all underground tanks and pipework.

Rounding of mine bench edges.

Final grading of mine benches to ensure drainage is fully to specification.

Final grading and stabilisation, including topsoiling and replanting? of spoil tips.

Ripping, removal and replanting of roads.

Installation of permanent drainage systems on all disturbed areas, plus safe, properly engineered discharge structures into large existing waterways.

Replacement and grading of topsoil.

Revegetation with a wide range of plant types, as permitted by ground conditions, to develop a wide diversity of vegetation communities.

Additional conservation works, as necessary, to encourage habitat restoration.

Particular long term post-mining rehabilitation of the tailings dam and water impoundment areas according to the Operating, Maintenance and Surveillance Manual for the Tailings Management Facility.

Mine closure will involve the following community-based activities, most of which will start earlier and last much longer than the physical decommissioning activities.



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Implementation of the Company‟s community engagement strategy from the construction period onwards, throughout the operations period and the mine closure phase.

Development at Yekepa and the nearby rural towns of a combined vision of the Company, the communities and the County authorities, of the desired nature of northern Nimba in the post-mining period; and a strategic plan to allow that vision to be realised.

Promotion of alternative livelihoods and infrastructure development to help move Yekepa and the neighbouring rural towns towards a sustainable economy once mining activities have ceased.

Implementation of the proposed environmental Offset Programme, which focuses on the development of a Northern Nimba Conservation Area which co-ordinates land zoning and other activities, in the interests of developing sustainable management of the Nimba forests. This will include community-based forest management, conservation agreements and a long term sustainable financing mechanism. The proposed Offset Programme is described in a separate document.

Development of community initiatives to re-occupy usable areas of the former mine, dumps and TMF for productive sustainable management. These would typically be devised in partnership with the appropriate Community Forest Management Bodies, which already exist, who would then be the implementers.

It is anticipated that the proposed Offset Programme would terminate at about the time that mining is completed. Its experience and resources would be re-focussed to provide support to the communities involved in the various activities described above, over a post-mining phase-out period of perhaps five years.

1.4 Experience from the LAMCO Nimba Mine The former mined areas at Tokadeh and Nimba give a good indication of the landscape profiles that mining areas can have without restoration. In the 20 years since the abandonment of the former mines, the slopes have been subject to weathering, small scale landsliding, erosion and partial revegetation. No rehabilitation work has been carried out. Thus these former mine sites remain visually intrusive within the landscape, and the contrast with the adjacent un-mined areas is stark (Figure 2, photographs A and B). The Nimba Mine sites are dominated by very strong, uniform, horizontal lines of regularly spaced benches and steep (45-60

o) cut slope batters, with only rare vertical crest to toe elements associated

with gullies or stream channels in Weathering Grade III and IV materials1. At Tokadeh, these slopes

are developed in Weathering Grade V materials (occasionally Weathering Grade IV). If materials at Tokadeh are more weathered then they may blend more easily with the landscape, but will also be more prone to erosion. However, the Phase 2 mine benches, or the vast majority of them, will be in hard rock of Weathering Grades II to IV, and so presumably will not blend without intervention. In places surface erosion and minor slips have occurred at both Tokadeh and Nimba on the abandoned batter slopes, resulting in the formation of small debris cones at the back of the benches (Figure 2, photograph C). These debris cones are probably weak Weathering Grade V or VI material. Revegetation at both the Tokadeh and Nimba sites is largely restricted to grasses on the benches and parts of the batter slopes. These grasses probably represent the early-succession vegetation communities, though it is generally difficult to distinguish between slopes that have been in existence for 20 to 40 years. Patches of bare weathered rock are frequent on the steep slopes. Occasional shrubs and rare trees are generally restricted to the debris cones formed by failure of the batter slopes (Figure 2, photographs D and E) or along gully channels (Figure 2, photograph F). In general, the mosaic of habitats is poor and there is limited structural variation in the vegetation. The main lesson to be learnt is that simple abandonment of mine benches in the Nimba mountains will lead to eventual revegetation through natural processes – but not to the pre-existing condition

1 Weathering Grade (WG) I: fresh, unweathered rock; WG II: slightly weathered rock; WG III: moderately

weathered rock; WG IV: highly weathered rock; WG V: completely weathered rock; WG VI: residual soil.



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since it is just grass and occasional trees. However, while on these surfaces there is very little erosion once the vegetation has established, over a period of 20 years little has established in the way of woody vegetation. This is quite different from the surrounding unmined areas of forest. Abandoned slash-and-burn agricultural land in surrounding forest areas returns to fallow quite quickly and after 20 years has a broad mix of shrubs and small trees even on relatively poor soils. It is therefore clear that on mine sites cut down into rock, simple abandonment will not restore good forest cover in a reasonable timeframe, and that active re-afforestation work is necessary to achieve this. While there is a certain biological interest in the grasslands of the former LAMCO mines, as demonstrated by the grassland assessment in the biological section of the Phase 2 ESIA report, these areas are much less valuable in terms of ecological interest than secondary forest. Hence it is necessary to take active measures to restore the landscape to a much broader mix of species as would be the case following shifting cultivation than following mining. The only exception to this rule is areas of grassland above 1200 metres above sea level on the main Nimba ridge, which in certain pockets provide the habitat for a population of Nimba viviparous toads. Spoil tips are highly erodible if not constructed to a stable profile and provided with surface protection measures. This is amply illustrated by the photographs in Figure 3, of some of the old LAMCO spoil tips at the former Nimba mine. After 20 years, large scale erosion is still active, with significant consequences to the ecology of the Dayea River into which the mine areas drain. This demonstrates the importance of complete engineering and bio-engineering solutions to all spoil tips and man-made slopes. Figure 2. Photographs of naturally re-vegetated surfaces at the former LAMCO mines.

Photograph A: Nimba mine: uniform, strong horizontal lines with limited vertical elements associated with landslide scars, gullies and drainage lines

Photograph B: Tokadeh mine: strong horizontal lines and areas of gully erosion and landslip

Photograph C: Tokadeh mine: small debris cone formed by failure of the batter slope (as revealed by the bare slip scarp)

Photograph D: Tokadeh mine: almost uniform revegetation by grasses, with occasional shrubs restricted largely to the debris at the base of the batter slopes.

Debris cone

Vegetated debris cones



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Figure 2 (continued). Photographs of naturally re-vegetated surfaces at the former LAMCO mines.

Photograph E: Nimba mine: almost uniform low growing vegetation generally restricted to the debris cones at the base of the batter slopes. Occasional shrubs on larger debris cones.

Photograph F: Nimba mine: shrubs and small trees confined to a gully channel

Figure 3. Photographs of LAMCO spoil tip erosion and downstream sedimentation.

Photographs A and B: Views of the eroding LAMCO spoil tips on the north-western side of the old Nimba mine (still active after 20 years, and therefore a significant environmental issue).

Photographs C and D: Active (after 20 years) deposition of eroded material from the LAMCO spoil tips, in the headwaters of the Dayea River below the former Nimba mine.

Shrub vegetation on debris cone Shrub vegetation

within small gully



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2. MDA COMMITMENT TO ASSET DISPOSAL The Minerals Development Agreement (MDA) between the Government of Liberia and ArcelorMittal includes provisions for the disposal of fixed and movable assets at the completion of mining (see box below). SECTION 1 – IMMOVABLE ASSETS

Upon a regular termination of this Agreement for any cause whatsoever, occasioned by the expiration of its term(s), except for termination resulting from a breach of this Agreement by the GOVERNMENT, or termination pursuant to Article XXIX, Section 1, all lien free permanent immovable assets of the CONCESSIONAIRE in the Concession Area that are not otherwise the property of the GOVERNMENT shall become the property of the

GOVERNMENT without charge. In the event of a breach by either Party hereto, the value of the non-movable assets shall be taken into account in any award of damages under Article XXXI, Section 6. Notwithstanding the preceding paragraph, prior to the termination of this Agreement, the CONCESSIONAIRE shall have the right to control all its property and assets, whether or not the same are to revert to and become the property of the GOVERNMENT upon such termination and to freely dispose of any property not required for the conduct of the Operations and pledge or otherwise encumber such properties to secure financings. SECTION 2 – MOVABLE ASSETS

At any time after termination of this Agreement and with respect to each movable asset of the CONCESSIONAIRE in the Republic, which the CONCESSIONAIRE desires to sell (other than to an Affiliate at market price), the GOVERNMENT shall have the first option to purchase such asset at the fair market price thereof, such price to be paid in Dollars. If the GOVERNMENT does not exercise such option within thirty (30)

days after being informed by the CONCESSIONAIRE that it desires to sell such asset, then the CONCESSIONAIRE may sell such asset to any Person, including the GOVERNMENT, for such price as it may

be able to obtain therefore, or remove such asset from the Republic without Taxes and Duties or other liability to the GOVERNMENT. If, however, the GOVERNMENT purchases any such asset, it shall pay the purchase price

within sixty (60) days after such price has been agreed upon or determined, unless the Parties hereto otherwise agree. SECTION 3- REMOVAL OF MOVABLE ASSETS

The GOVERNMENT, by Notice to the CONCESSIONAIRE within a reasonable period but not to exceed one (1)

year after a regular termination of this Agreement occasioned by the expiry of its term(s), and except for termination resulting from a breach by the GOVERNMENT, may require reasonable disposal or removal, in

accordance with Law, of any or all assets, including unusable assets, remaining within the Concession Area after total disposition of assets in accordance with this Article XXX, and if the CONCESSIONAIRE does not reasonably dispose of or remove such asset or assets within a reasonable period after said Notice, the GOVERNMENT may effect such reasonable disposal or removal at the expense of the CONCESSIONAIRE, but the CONCESSIONAIRE shall be entitled to any income realized from the salvage value of such assets, except for assets existing at the Effective Date.

The MDA does not define what constitutes a movable or immovable asset. For the purposes of this plan, therefore, the following definitions are applied. An “Asset” is any material, equipment or fixture that has a definable commercial or financial value. “Movable” means anything that can be taken from its current location and used for its intended purpose elsewhere, whether it is fixed to the ground or already mobile. “Immovable” means anything that cannot be used for its intended purpose elsewhere, because moving it would involve irreparable destructive action. The strategies to be adopted by the Company are therefore as follows.



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Immovable assets.

Create a full inventory of immovable assets.

Initiate a discussion with the Government, with the aim of assisting the Government to take over the assets should it desire to do so.

Should the Government not express an interest in taking over the immovable assets, then they will be removed, disposed of in an appropriate manner and the land rehabilitated to the greatest extent possible.

Movable assets.

Create a full inventory of movable assets.

Send usable assets to other Company mine sites, where it is appropriate for them to be used productively.

Transmit the inventory to the Government and request an expression of interest in the purchasing of any or all of the assets, as per the provisions of the MDA.

Should the Government wish to purchase certain assets, the Company will arrange an independent valuation of those assets, by a specialist that is mutually acceptable to the Government and the Company.

Any remaining assets will be auctioned according to Company asset disposal rules.

Any assets that do not sell at auction will be scrapped according to Company asset disposal rules and following the guidelines for waste disposal in the ArcelorMittal Liberia Environmental Standards Manual.



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3. OPERATIONAL CLOSURE APPROACH

3.1 Progressive Closure of Project Elements It is intended to close and restore any element of the project as soon as it is finished with, rather than to wait until mining and ore processing ceases before addressing closure, and this includes mine surfaces that have become „worked out‟. At the time of development of this Framework of the Mine Closure Plan, the actual mining plan and sequencing of ore extraction are still being modelled. It is therefore not possible to say how far it will be possible to close some sections of the mines while other sections are still being worked. This should certainly be possible at Tokadeh, which has three distinct sections of ore resource (Tokadeh Main, Area A and Area F). As far as it is possible to do so, then, the mining plan will endeavour to allow progressive closure of worked-out sections of the mine well before the final closure. Figure 4 shows a draft model of the ultimate pit for the largest of the Western Range ore resources, Mount Tokadeh, demonstrating the final anticipated mine benching in relation to the surrounding natural contours. Models for the ultimate pits at Mounts Gangra and Yuelliton are given in Figures 5 and 6 respectively. Figure 4. Modelled layout for the ultimate pit for the Tokadeh ore resource, the largest of the three resource areas in the Western Range.



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Figure 5. Modelled layout for the ultimate pit for the Gangra ore resource.

The design of the mines involves working in scheduled phases through each mine pit, and from the bottom upwards in the development of waste dumps. This approach allows for concurrent closure while the operations are still going on, and also helps to develop the peripheral buffer zones: these are incorporated into the plan throughout the mine life as both safety exclusion zones and environmental protection zones, particularly around water bodies. The mine design adopts strict criteria for stream protection and specifications for erosion control and revegetation works that must



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be incorporated in the development of the mine and its associated infrastructure, based on the guidelines provided in the Company‟s Environmental Standards Manual. These are ultimately controlled by the need to meet international standards for water discharges at the site periphery, and so the extent of upstream works is dictated by the likelihood of sediment being generated. The closure of infrastructure elements in advance of the final closure of the mines is more problematic, since the ore processing facilities are required to be in service until the very last shipment leaves the site. However, it should be possible to close and initiate restoration of some of the access roads, haul roads and waste dumps once they become redundant. Beyond the mine, the ore processing facilities and the transport infrastructure, the Company‟s community engagement strategy throughout the mine life is intended to help develop a healthy post-mine environment and society. Figure 6. Modelled layout for the ultimate pit for the Yuelliton ore resource.



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The Company‟s community engagement strategy is driven by the four pillars of its approach to corporate responsibility. These are:

Investing in our people;

Making steel sustainable;

Enriching our communities; and

Transparent governance. Of these, the first and third are most important in this context. The first, investing in our people, involves the creation and sustaining of a skilled, contented workforce who, with their dependents, are well cared for and lead secure, rewarding lives. The third, enriching our communities, requires the company to have a vision as to how the release of the natural wealth through exploitation of iron ore can provide substantial and sustainable social and economic benefits to the communities in the areas affected by mining. The intention is to work throughout the mine life to help develop a society that has sustainable future livelihoods beyond mining. This is a particular challenge in northern Nimba County, where spin-offs and revenue from mining will dominate the economy for twenty years. These two pillars are designed to address the need to use the wealth unlocked from the mineral resource to develop sustainable systems to manage and conserve the other natural capitals that will necessarily be the resource base of the post-mining economy. Further details of these initiatives are given in the following two documents.

The ArcelorMittal Liberia Community Engagement Strategy. This is published separately from the ESIA and is updated at intervals as the Company‟s work and role in society evolve.

The Framework of the Proposed Offset Programme for Project Phase 2, which forms Volume 8 of this ESIA submission.

3.2 Introduction to the Rehabilitation of Mined and Infrastructure Areas Most of the mine and infrastructure sites are in areas that are currently within the forest-agricultural landscape of rural northern Nimba County. This landscape and the importance of its setting locally for rural people‟s livelihoods on the one hand, and regionally and internationally for ecosystems services and biodiversity conservation on the other hand, are described in considerable detail in the Framework of the Proposed Offset Programme. The Company‟s integrated environmental approach to rehabilitation requires that these sites be restored as far as possible to their former uses. Achieving restoration will not be a simple or quick process, but it is one that the Company understands through its environmental research in Liberia, and through the expertise that it has brought to address the subject. It is clear that the long-standing slash-and-burn agricultural system, which appears to have been practised by the Mandingo peoples in the overall trans-border Nimba region of Liberia, Guinea and Ivory Coast for four to five hundred years, can lead to the restoration of forest to significant levels of plant and animal diversity. In most cases it seems to take at least forty years for cleared land to return to botanical assemblages that reflect the natural forest if there are no interventions. Shifting cultivation does not involve topsoil removal, as mining will, but it does involve the loss of volatile major soil nutrients in ways that should not occur in careful soil storage and management. The fallow period after shifting cultivation does not include any active re-afforestation, as will be the case after mining. So although the disturbance through mining and other related activities will be more profound, active land restoration works should be able to achieve restoration of damaged sites within a forty-year period, similar to that experienced through the shifting cultivation cycle.

3.3 Mine Closure Procedure Through this evolving Mine Closure Plan, ArcelorMittal is preparing for closure from before the start of operations, taking actions that will reduce the need for clean-up and reclamation at the end of the Phase. The Company will prepare the procedures to be taken with regard to advising both its personnel and local community leaders of the intent to cease mine operations and the methods in which continuing social commitments (e.g. resettlement compensatory programmes for livelihoods



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restoration) will be handled. A long-term land-use plan will also be developed for the area in consultation with all the stakeholders as part of the proposed Environmental Offset Programme. Key decisions to be made include which parts of the reclaimed area will be returned to agriculture and which areas will be reserved for forestry-only uses, especially conservation. The Company will also prepare, and review and update annually, a risk assessment to identify situations of potential environmental hazard which may occur on the mine and infrastructure sites during operation, during restoration, and once restoration has been completed. This process will include development of an emergency plan, including safety measures, which will detail the measures to be applied in the event of an accident such as a major landslip. These are likely to follow the format of the existing emergency response plans given in each Environmental Management Plan. The mines themselves, being on mountains in a high rainfall area, will always be of the greatest concern in the Plan. Particular control measures for the mines include the following.

Careful planning and strict procedures are to be in place to reduce the number of situations where clean-up is necessary at the end of the project. For example, the avoidance of side tipping from roadways, turning or storage areas and benches as these tend to cause the most severe erosion at abandoned mine sites and are likely to result in the largest problems if the site has to be abandoned quickly. Immediate cleaning up of hazardous material spills is also required, is the regular removal of redundant equipment and other recyclable scrap and waste.

Remedial and reclamation actions should be an on-going process of restoring redundant infrastructure and land areas (e.g. reshaping or levelling of temporary waste dumps and stockpiles) as and when they become redundant to project activities, rather than reclamation left until mine closure. Ore extraction will be planned so that reclamation work will follow close behind excavation. This is primarily to reduce erosion from the mine surfaces into the streams, but will also reduce the amount of reclamation to be done on mine closure.

Care must be taken not to introduce non-native or invasive species in the restoration of ecosystems.

Shaping of waste dumps and stockpiles must be done so that side slopes are stable and not at risk of failure as they are constructed. This will also aid natural revegetation that will reduce erosion of the surface, thus minimising the resources needed to keep the sediment traps operating effectively.

The factors to be addressed to ensure that the Company is ready to implement this process include the further development of the Company‟s existing understanding of revegetation and re-afforestation in the rainforest setting of northern Nimba. This will be enhanced by international specialists working with the Company as well as through furthering the co-operation already in place with the Forestry Development Authority‟s Afforestation Division. In addition, it is necessary to improve understanding of appropriate pioneer tree species and sources of their seeds in the local forests, and establish tree nurseries to grow them for use in site trials and, later, in full-scale rehabilitation efforts. The photographs in Figure 7 show early work in relation to these aspects of land restoration. The Company will undertake a series of long term trials of mine site rehabilitation in the area. An outline agreement is already in place with the management of the East Nimba Nature Reserve to undertake trials at the former LAMCO Nimba Mine, which is located in the Reserve but still showing only scant evidence of forest revegetation. Based on this experience, practical and effective guidelines will be devised on the rehabilitation of mine and other infrastructure sites in this environment. Actual disturbed site rehabilitation will be initiated as soon as areas of project-disturbed land are free for restoration. At the same time, the Company will develop arrangements with community groups, particularly the Community Forest Management Bodies, to undertake the rehabilitation work. This will most likely be on a community contract basis, leading into long term forest management plans whereby the support from the Company decreases as the benefits to the community increase from utilisation of forest products.



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The actual work to be addressed in achieving the desired results on the mine and infrastructure sites will be as follows.

Softening of unnatural landscape features (i.e. cut benches, waste dumps) to appear as natural as possible. This will mean the removal of benches where it is possible to do so without prejudicing stability.

If not already completed, batter all excavated slopes to stable angles for the materials and geological structure exposed.

Make safe all landslip areas and insecure bench walls.

Restore or develop natural land drainage within the reclamation areas, leading to sediment ponds. This would typically involve a large number of small drainage channels and ponds rather than a small number of large ones.

Ensure that sediment ponds and check dams are in good order so as to continue to function properly indefinitely, and arrange for these to be monitored until no longer needed (i.e. until erosion is remedied and bare surfaces protected). These structures should be left in place to develop as natural wetland areas as part of the rehabilitated drainage system

Revegetation of all areas of bare soil, mine benches, access roads and other infrastructure using a combination of grasses and woody vegetation. This should be guided by the results of the trials described above and developed as the Mine Closure Plan progresses.

While the aim should be to encourage and assist natural revegetation there will be a requirement for planting, particularly in the larger cleared areas. The minimum to be achieved is complete natural or planted ground cover. The aim will be to reach this goal by the end of the second rainy season, although the subsequent management to ensure that the correct vegetation community develops will take many more years. Second level succession should be evident if not well established as early as year 5 after closure, but may take much longer. When there is assurance that this process is well established, it should be possible to consider the reclamation programme complete, even though many of the species may require longer to reach maturity. Figure 7. Photographs of ArcelorMittal Liberia activities towards site rehabilitation.

Photograph A. Planting grass slips during the 2009 wet season, to control erosion on bare surfaces created during the rehabilitation of the Tokadeh-Buchanan railway.

Photograph B. Preparation of a tree nursery at Yekepa in early 2012. Initial site re-afforestation trials commenced in the 2012 wet season, in collaboration with the Co-management Committee of the East Nimba Nature Reserve.



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4. OPERATIONAL CLOSURE OF EQUIPMENT AND INSTALLATIONS

4.1 Decommissioning of the Mine and Rail Fleets The mine fleet will consist of excavators, payloaders, heavy-haul trucks, tankers, buses and light vehicles. Under normal fleet management procedures, it would be expected that these machines would reach the end of their serviceable lives at the time that the mine is closed. Should fleet management become desynchronised from mine life and some mobile equipment still have a residual life, it would normally be taken to another Company mine for use there. However, since ArcelorMittal may not have any other mines in the region, the option of selling it to another operating iron ore mine in Liberia would be pursued in this situation. Should the equipment have reached the end of its productive life, it will be exported from Liberia as scrap. ArcelorMittal in fact has a number of steel mills that are fed only with scrap iron and steel, which are likely destinations for these materials. The rail fleet will consist of locomotives, rail wagons, flat-bed rail cars and rail tankers. The fate of these depends again on their serviceability at the end of mining. Items with no further economic use will be sent for scrap. If the Government of Liberia intends to operate the railway for non-mining uses, then the Company would attempt to negotiate a fair handover arrangement for any stock that is required. Otherwise it will be sold for use on other railways in Liberia or elsewhere, or scrapped.

4.2 Decommissioning of Stores and Workshops The decommissioning of industrial service buildings will be agreed with the Government of Liberia, and may lead to the handover of complete buildings, or complete demolition, or some other arrangement such as a conversion. Where there is a clear useful remaining life for a sound existing structure, then the Company will favour retention of the structure for an alternative use. In the event of demolition, the steel structure of a building would normally be sent for recycling, and the concrete blockwork from the walls used for low grade fill or other works as far as possible, to avoid it going into landfill. In the decommissioning of stores and workshops, the removal and final cleaning of fuel and waste oil facilities is the single biggest activity. Where possible, the removal of fuel storage tanks and fuelling facilities will be arranged with the petroleum supplier as this requires suitably qualified technicians to carry out the work according to strict procedures. After decommissioning or removal, tank areas need to be checked to ensure the process has not caused soil or groundwater contamination (this includes taking soil and groundwater samples). If contamination is found that has somehow escaped detection during the operational period (throughout which monitoring procedures will be in place, remediation action must be taken as soon as possible to remove the pollution: this would typically follow the guidelines given in the ArcelorMittal Liberia Environmental Standards Manual (section 11, on fuel handling and pollution prevention). The Company‟s Environmental Standards Manual and the Hazardous Materials and Waste Management Plan also provide guidelines on the disposal of waste oil and other hazardous waste from workshops. These will be used in the final clean-up of these facilities.

4.3 Closure of the Railway When the Nimba Western Range mines are approaching closure, the Government will need to make a decision regarding the future of the railway between Tokadeh and Buchanan. At this stage it is difficult to speculate what the scenario might be in twenty years from now, but the following possible options should be among those considered from about 2020 onwards, if the requirements are not known by that time.

Continue operating the railway for the transportation of iron ore from other resources in Nimba County.

Use the railway for the transportation of iron ore from resources in south-east Guinea to the sea at Buchanan.



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Develop the border crossing with Guinea at Yekepa and rehabilitate the railway from Tokadeh to Yekepa, to give a passenger and freight route from the south-eastern side of Guinea to the Port of Buchanan.

Close the railway between Tokadeh and Sanniquellie, and create a passenger and freight terminus at Sanniquellie, to use the railway for non-mining uses between there and Buchanan. This option might be enhanced by the construction of a rail spur to Ganta, and its existing busy border crossing into Guinea.

Removal of the railway itself, and adaptation of the formation and bridges to carry road traffic along certain sections.

Moth-balling of the railway to allow it to be kept at minimal cost for possible later re-opening.

Complete removal of the railway, the engineered formation and bridges, and rehabilitation of the disturbed land.

As per the stipulations of the MDA for immovable assets described in section 2 of this document, the Company and the Government will need to reach agreement on the way forward in the handover of the railway according to the Government‟s intentions for its future use.

4.4 Closure of Quarries It is expected that three abandoned LAMCO-era quarries are to be used in the Phase 2 construction phase. These are at Neekreen near Buchanan, Greenhill, close to the middle point of the railway, and Glaton Hill, near Yekepa. Of these, only Greenhill is expected to be kept open through the operational phase of the project, to supply ballast for railway maintenance. The other two will be closed once construction aggregate has been obtained. Once quarry operations are complete, the first stage of closure will be the removal of all equipment. This will include the crusher and screening plant, the explosives magazine and any other semi-fixed items. The ground will be restored to the original surface levels as far as possible. Any areas found to be contaminated (for example any previously undetected hydrocarbon leakages) will be remediated. All mobile equipment will also be removed, including anything that is broken down and has only scrap value. The quarry faces will be stabilised by the removal of any loose rocks and the slopes formed to a stable long-term angle. Any topsoil scraped off the benches at the start of operation will be spread back on to the benches. Drainage will be fixed as a permanent protected system to ensure that there is no uncontrolled runoff and erosion. All bare surfaces that can support vegetation (i.e. everywhere except hard rock faces) will be planted in line with the Company‟s revegetation procedures using transplanted grass slips or tree seedlings from the nursery that is being established at Yekepa. This will be the contractor‟s responsibility, but it must be undertaken at the appropriate time of year (the start of the wet season) and under the close supervision of the company‟s Environmental Department.

4.5 Closure of the Port of Buchanan The Company has rehabilitated the former LAMCO iron ore quay at the Port of Buchanan. As part of Project Phase 2 closure it will also rehabilitate the fuel quay. These will both be used for the duration of the project, and the iron ore quay may also be used during the closure phase to export re-usable movable assets or scrap. After this its use will be determined by the Government. If the railway continues to be used for transporting iron ore, then the quay will need to remain operational. Otherwise the Company will remove the conveyors and shiploader, to make it more flexible as a general cargo quay. Even if the National Ports Authority does not require use of the quay at that time, the removal of a national asset of this nature might not be justifiable in the long term. It can be moth-balled very easily and refurbished in the future once a new need has been identified.



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Similarly it would be logical for the fuel quay to be left intact, even if it were not required for future landing of fuel. Should this be the case, then the Company would either remove the fuel handling facilities, or instruct the operator to do so, to clean the quay and make it suitable for general cargo handling or moth-balling. The harbour at the Port of Buchanan comes under the remit of the National Ports Authority. It is not an asset of the Company but belongs to the Government of Liberia. Hence there is no question of ArcelorMittal dismantling the breakwaters or filling in the harbour basin. The onshore facilities will be dismantled and cleaned by the Company as agreed with the Government under the provisions of the MDA as described in section 2 of this document. If the site is no longer to be used for iron ore handling, then the following general decommissioning is expected to take place.

The rail car dumper will be dismantled and either sent for re-use at another location or scrapped. The vault would be filled in and the conveyor system dismantled.

The stacker and reclaimer and their associated gantries and conveyors will be dismantled and either sent for re-use at another location or scrapped.

The rail loop and rail sidings will be removed and the rails taken, as agreed with the Government, for re-use elsewhere.

The rail workshops, stores and fuelling facilities will be decommissioned as described in section 4.2.

The stockpile yards and laydown areas, as well as the former LAMCO tailings and settling ponds, are already too extensively damaged to be capable of restoration back to the pre-LAMCO landscape. The areas used by the Company will be modified as appropriate to ensure that there is no erosion and that all runoff drainage goes into suitable settlement ponds. Wherever possible, grass will be planted over the surfaces to protect against any future soil loss, and to re-create at least some improvement in the habitat.

Any scrap material will either be recycled in Liberia or exported. Scrap iron and steel will be sent to an ArcelorMittal steel plant equipped to handle it.

4.6 Decommissioning of Company Townships At the end of mining the Company townships of Yekepa and Buchanan will revert to the Government. It is too early for their future uses to be considered, but they might be valuable resources for another concession, or perhaps for a university or training centre campus. Because the occupants of the housing used by the company will all be skilled in some way and occupying tied housing (i.e. housing provided as part of an employment package), on termination of contracts as the operation closes, they would be expected to vacate the accommodation and move back to their own homes or to other work locations. The Government can therefore expect to take vacant possession of the housing areas, apart from any squatters who choose to settle (as when the site was handed from the Government to the Company). While the Company will aim to help establish functioning communities in the areas around its work sites (see section 3.1), the Company townships will not be in this category. It is expected that the township utilities will be handed over to management by the Government as immovable assets. These will consist mainly of the power stations and power reticulation grids, the water supply and treatment systems, the sewage treatment plants and the landfill sites. These would all be equipped with procedural manuals for operation, and the Government will have the option of employing the technicians that the Company is training to operate these installations. The handover of schools and hospitals to the Government as fixed physical assets is straightforward. Handing over their management will not be as simple because the staff are all employed by the Company. The ways in which these are to be managed will therefore need to be the subject of detailed discussions and agreements between the Government, the Company and any appropriate staff associations or trade unions. As skilled workers, the staff of both can be considered relatively



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mobile members of the national workforce, but complete dispersal and replacement with other Government staff may not be in the best interests of maintaining standards in either type of institution. After 20 years there will presumably be a range of secondary, mining- and non-mining-related enterprises, and of course an extension to the permanent population beyond that of the Company. It is expected that these people will remain in the area, having benefited from the Company‟s community engagement strategy (see section 3.1). The section of the Greenhill Camp utilised by the Company comprises entirely of temporary structures. These will be removed, the foundations broken up and the site provided with permanent drainage systems and re-vegetated.

4.7 Final Disposal of Waste Materials The Project‟s Hazardous Materials and Waste Management Plan gives considerable detail on the ways in which waste materials are to be disposed of by the Company. This is underlain by the ArcelorMittal Liberia Environmental Standards Manual, which gives additional guidelines. These are updated as necessary to take into account the increasing availability of recycling facilities in Liberia. The environmental management system used by ArcelorMittal Liberia ensures that waste materials are disposed of according to standard procedures as soon as there is a big enough accumulation to make transport worthwhile. At operational closure there would not therefore be very large stocks and it would be a matter of clearing and disposing of any remaining items in the way used throughout the project.



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5. OPERATIONAL CLOSURE OF MINE AND INFRASTRUCTURE SITES

5.1 Re-profiling of Mine Pits Mine pits will be re-profiled to the greatest extent possible. The mines are all opencast and will be worked in a standard bench system with vertical spacing of approximately 10 metres. These give an unnatural landscape which needs to be softened. In order to reduce the visual intrusion and improve the physical rooting conditions for plants, and hence the speed of revegetation of the three mine sites (Tokadeh, Gangra and Yuelliton), the post-closure rehabilitation work should include some or all of the following options.

Disrupting the strong uniform horizontal lines of benches and batter slopes by creating downslope drainage lines and gullies.

Creating a range of sizes of debris cones at the back of the benches, by excavating the upper parts of the batter slopes and placing the material at the base of the slope. Large arcuate scars and “v”-shaped notches could be created at the batter crests to disrupt the strong horizontal lines further. A diversity of batter slope angles could be formed, though possible risks of uncontrolled run-off, induced erosion or instability need to be considered.

Creating ponds and wet areas on the benches by either digging into the benches or creating bermed areas.

Back-sloping the terraces so the water and sediment are retained on site.

Reversing the effects of compaction from heavy machinery will be necessary (this might be part of the reason that recovery at the old LAMCO mine has been so poor) by ripping (or in extreme cases blasting) the terrace surface to create fractures and loose materials to facilitate plant rooting.

Where topsoil is inadequate, spreading of fine materials from the waste dumps and settlement ponds to provide a seedbed;

Scarifying to leave a “rough” surface that will allow soil and water to collect in pockets, and to percolate the surface rather than running off it.

Re-seeding and re-planting of the slopes with appropriate local plant species to accelerate revegetation (see below).

It is likely that much of the excavation and landscaping could probably be achieved with a bucket excavator, if the materials are Weathering Grade IV and V. Blasting would probably be necessary only in areas of Weathering Grade I and II rock, and possibly III.

5.2 Stabilisation of Waste Dumps The mine design is being developed so as to locate waste dumps in sites that do not have impacts on the surrounding environment more than necessary. These tend to be on the interfluves: that is, the higher ground between the water courses and swamps. The reasons for this are to ensure that the mountains are fully drained along the natural water courses, and because the aquatic and riparian ecology tends to be of more importance than the areas away from the stream lines. The disadvantage of this siting lies in the technical work required in stabilisation of the dumps, which are consequently founded on convex topography with the steepest sections at their toes. Consequently, all waste dumps will need to be placed and compacted on levelled sites with a peripheral margin to control runoff and sediment. Detailed locations have been selected to avoid landslide areas, and areas of previous erosion. Waste dumps will be generated throughout the life of the mine and will be located and formed to a stable design.. The activities at closure are therefore to ensure that the waste dumps are fully stable and revegetated, and in a form that can be abandoned safely, effectively stable in perpetuity. Particular attention needs to be paid to the stabilisation of dump lifts and slopes. Waste dump slopes will need to be at stable angles, which must be based on geotechnical assessments. Waste dump slopes will typically be in lifts of perhaps 10 metres in height, with benches in between. The benches should not be quite level, but should have a gentle outward slope to shed water: this will ensure that



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there is neither erosion through uncontrolled runoff on the one hand, or a build-up of pore water that leads to a mass failure on the other hand. Since the waste dumps will be unconsolidated and some settlement can be expected over time, drainage systems will need to be flexible to ensure that they remain functional. All surfaces of the waste dumps will be revegetated using local species (see section 5.4). This is to protect the slopes against erosion, restore the ecology as far as possible, and help to blend them into the landscape as far as this can be done with artificial landforms. There is an inherent risk in any mountain environment that slopes, whether natural or man-made, can be subject to erosion or mass failure. While absolute stability cannot be guaranteed in a humid tropical climate, it can be safeguarded by monitoring the conditions of the slopes for a significant period of time. In this context regular monitoring of the waste dumps for five years after closure will be required, and any signs of erosion or instability rectified with appropriate engineering measures. If there is no evidence of problems by the end of this time, then it can be assumed that the dumps will remain secure.

5.3 Re-soiling of Mine and Dump Sites The extent to which mine and dump sites can be re-soiled depends to a large extent on the availability of topsoil and subsoil. Over the areas of the pre-existing DSO surfaces there is very little surface material that can be classified as soil in the sense of a growing medium for plants, because the ore outcrops on the surface over quite extensive areas. Elsewhere the depths of biologically active soil are generally very shallow on the mountains as a whole, as shown by the ESIA soil surveys. Rapid decomposition of organic matter, and rapid mineralisation of plant nutrients, in the iron-rich tropical soils found in Nimba mean that topsoils are poor and subsoils have relatively little biological activity. Nevertheless, soils will be reclaimed from many areas of clearance, especially in depressions, and retained in stockpiles for subsequent restoration works. Re-laying of soil on slopes greater than about 27 degrees or 1:2 (v:h) is problematic in areas prone to heavy rainfall and can be counter-productive. This is because, in the first few years, there tends to be a plane of weakness between the re-laid soil and the in situ, more compacted substrate on which it is laid. Different material densities mean that heavy rain can saturate the soil and cause it to flow off the slope. It then becomes a sediment problem in rivers and causes more harm than good. In the context of Nimba, therefore, it may well be better to restore soil only to the mine and dump benches and other areas with only gentle slopes, and not to try to restore it to steeper areas. Certainly it is not possible to restore soil to mine bench slopes, which will be cut at around 63 degrees or 2:1 (v:h). Re-soiling waste dump slopes, which will be graded at perhaps 35 degrees or 1:1.5 (v:h) is technically possible, but likely to result in unacceptable levels of soil loss. Revegetation of these steeper slopes will therefore be done using pioneer species that can grow in nutrient-poor substrates and establish the conditions for soil formation required for a mixed vegetation canopy. These sites will be interspersed with different mixtures of plants growing on the more level terrace benches where soil has been restored. Re-creating soil profiles is also not easy in the context of a mountain environment in the humid tropics. In a natural situation of in situ soil formation, there is normally a continuum between unweathered rock, weathered rock and completely weathered rock (residual soil), subsoil and topsoil. Topsoil is usually stained a darker colour by incorporated decomposing organic material, and has an altered structure and lower density resulting from the effects of plants and surface exposure. Subsoil may also be a different colour due to exposure to greater aeration or conversely, in waterlogged areas, to hydrostagnic processes leading to reducing conditions that give rise to characteristic grey soils. Both topsoil and subsoil tend to be less dense and to have greater nutrient fluxes than the underlying residual soil. Simply replacing soil in layers on top of an inert mineral substrate will not re-create a proper soil profile, but it might initiate a long term process through which a soil profile is restored to a point where it can support biological assemblages that eventually become similar to what was present under natural conditions. Following the completion of Phase 2 mining, there may



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be areas of exposed hard gneiss basement rocks where soil cannot be laid at all, because it will simply wash off. Drainage issues must also be considered carefully. Where soil is laid on to a previously prepared surface, there is a discontinuity that may not be freely drained. Before laying soil, it will be necessary to assess the permeability and infiltration rates of the substrate. If these are low, ripping with a tine should be considered to increase infiltration. Failure to ensure drainage below the soil layers will lead to waterlogging of the soil above the substrate; this in turn will limit the biological activity in the soil and restrict plant growth. It will also make the soil more prone to erosion and, in certain circumstances, liable to form small saturated flows, either of which will lead to the stripping of the re-laid topsoil and to problems of soil loss and sedimentation. There is a need for experimentation. It is clear from the outline above that re-soiling disturbed areas is nowhere near a simple process in a mountain environment in the humid tropics. There is very limited experience in Liberia on which to call, but a good deal of international experience can be used. However, this is not enough on its own without experimentation of different approaches to solve the needs of different site characteristics. Mine closure at the end of Phase 2 will be strongly informed by trials carried out from 2012 onwards. Under Phase 1, ArcelorMittal Liberia has undertaken revegetation works with grasses, and also initiated trials of tree plantations on abandoned LAMCO mine terraces on the main Nimba ridge, in consultation with the Forestry Development Authority and using native species grown in the Company‟s nursery at Yekepa from seed collected in the Nimba forests. It is proposed to expand these trials in subsequent years, and to build up a menu of land restoration methods ready for Phase 2 mine closure works.

5.4 Revegetation of Mine and Dump Sites Following completion of surface profiling and improvements to slope stability measures, slopes are frequently left in a highly erodible condition. In order to prevent further environmental damage, it is essential that they are protected as soon as possible. Surface protection of large sites is only feasible through the development of a suitable vegetation cover. Revegetation on the scale required to rehabilitate the mines and infrastructure of the Phase 2 Project involves bio-engineering: the use of plants to perform surface protection and shallow soil strengthening. Bio-engineering techniques should therefore be used to control erosion or help to prevent or stabilise shallow slope movements where the depth to the sliding surface is up to 0.5 metre. If the depth to the sliding surface is greater than 0.5 metre, then bio-engineering techniques should only be carried out in conjunction with other slope stabilisation techniques, typically with earthworks or, if those are inadequate, retaining walls. Bio-engineering emulates nature in some respects, particularly in its aim to develop a mixture of plant types and sizes, and therefore also of different rooting characteristics. This is important because it is the roots that serve the engineering functions in protecting and stabilising the surface and the slope. In general the aim is to achieve a grass cover of dense, shallow, fibrous roots that will make the soil resistant to erosion. In addition to grasses need to be woody shrubs with medium-deep roots providing reinforcement against soil deformation, and occasional large trees with large, deeply-penetrating roots that serve anchorage functions. In practice it takes considerable time and management to reach the ideal arrangement of plant types. Most grasses are quick to establish but require full sunlight and can be suppressed by too dense an overstorey of shrubs and trees. Larger plants can take some years to become sufficiently established to contribute to the strength of the slope. In practice the most straightforward approach to revegetation is to start by planting grasses. These can either be sprayed on to the surface as seeds or planted as slips (cuttings made by splitting out large clumps). Seeding can be done by hand, but usually involves hydroseeding, whereby the seeds are sprayed on to the soil surface in a mixture with mulch, fertiliser and binding materials. This approach gives a rapid coverage, but has a number of shortcomings: it requires specialist equipment; seeds usually come from large scale commercial sources and so are usually alien to the environment



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where they are sown; and plant roots can be slow to penetrate below the nutrient-rich material with which they are sown, and to anchor soundly into the substrate below. Also the hydroseed mix will tend to slip off or wash off from steep slopes In most land restoration sites, the materials being covered are usually of a poor nutritional quality and this will certainly be the case for the Nimba mine and waste dump sites. In Liberia, where there is no domestic hydroseeding industry but an abundance of rural labour, the establishment of grasses through hand planting of grass slips is a greatly preferred approach. This has already been used extensively by ArcelorMittal Liberia (see Figure 7, Photograph A, for example) and can have significant results even on skeletal, iron-rich soils (see Figure 8). Figure 8. An example of ArcelorMittal Liberia’s work in erosion prevention using locally sourced large grass planted by community labour contracts: this is on former LAMCO mine workings on Mount Tokadeh. The grass was planted in August 2009 and the photograph taken in October 2010.

Revegetation using trees is a standard practice understood worldwide. In the context of restoring former mine sites in Liberia, there is so far not much specialist knowledge, but ArcelorMittal has initiated trials using indigenous species (see previous section). For those that will be planted out as seedlings, a nursery has been established for a sufficient supply of planting material to be available for trials: Figure 9 shows the first batch of seeds germinating in a seed bed in early 2012, and Figure 10 shows photographs of one of the early trials at the LAMCO Nimba mine. The ArcelorMittal Liberia standards for establishing erosion control on slopes through planting are given in the Company‟s Environmental Standards Manual. More consideration is given to habitat re-creation in section 6.2. The trial procedures and protocols will be developed over the coming years, and linked as appropriate with this Mine Closure Plan.



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Figure 9. Photographs of ArcelorMittal Liberia’s Yekepa Tree Nursery in early 2012.

Photograph A. An adviser from the Forestry Development Authority checks the quality of work at a tree seed bed in a recently established nursery at Yekepa in February 2012.

Photograph B. Healthy tree seedlings are visible in the same seed bed as shown in Photograph A, in March 2012. These are species of pioneer trees selected by a joint Company and FDA botanical team.

Figure 10. Photographs of ArcelorMittal Liberia’s initial re-afforestation trials at the former LAMCO Nimba mine in the wet season of 2012.

Photograph A. Sign board listing the species planted in a particular trial plot.

Photograph B. Overview of the trial plots on an old mine bench.

5.5 Tailings Management Facility Closure of the tailings management facility (TMF) will be an activity requiring its own skills and management systems. The TMF has been designed by a separate specialised team and will be constructed, maintained and monitored by a section of the Company dedicated entirely to this activity. The following facts are important to note.

The TMF is recognised as being one of the biggest environmental concerns of the whole project. Its design has therefore been subject to special scrutiny as to the stability of the dam and its methods of construction and operation.

Because of the potential risks implicit in any TMF, particular care to ensure full stability will be taken in the progressive construction of the dam and tailings as they are formed. In this respect, permanent stability during operation and after closure are built into the design from the beginning.



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During operation, the active decanting pond will be against a natural slope that forms the side of a ridge, so that drainage will always be away from the earth dam. At closure, the tailings dam will have a lined spillway. This will ensure that, as water builds up within the dam during the wet season, overflows can occur with no damage to the earthworks.

From the start of construction, seepage drains and boreholes to monitor pore water ressures will be installed at all points where they are needed. At closure these will be retained as necessary to allow for subsequent monitoring.

At the time of completing this draft of the Mine and Infrastructure Closure Plan, the TMF had been designed. However, the Operations, Maintenance and Surveillance Manual was still at an early draft. Once this has been completed it will be possible to update and expand this section of the Plan. This is scheduled to be done in 2014. The main principles for the closure of the TMF can be outlined at this stage, however. These are as follows, and an illustrative layout of the site is given in Figure 11.

The final protected spillway will be on the northern side of the TMF, leading to the nearby Dayea River.

Pipelines and pumping systems will be removed.

The existing seepage drains and settling basins will be retained. Monitoring of seepage water will continue until it is established that there is a constant acceptable condition that will permit permanent discharge into the environment without any deleterious effects.

Access roads will be maintained for monitoring, for at least the first five years. If it is agreed that further monitoring is not required, and once ne further significant tree planting programme is required, these are expected to be removed.

The pre-existing vegetation is of mixed lowland rainforest. Once closed, it is intended that the surface of the tailings and the faces of the earthen dams will be restored to this vegetation mix through a progressive planting and seeding programme. This will eventually be handed over to the Community Forest Management Body with an agreed management plan and such arrangements as might be necessary to support the plan‟s implementation if the available products cannot support the management activities.



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Figure 11. Layout of the final tailings management facility superimposed on a LiDAR map showing vegetation cover. The overall footprint is shown in red and the earthen dam is in black. Seepage drain systems are shown in yellow. Pipelines, which will be removed at closure, are green and access roads are pink: these will be maintained for monitoring access.



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6. RAINFOREST HABITAT RESTORATION ON THE MINE SITES

6.1 Potential Landscape at Completion of Mining The former mined areas at Tokadeh and Nimba give a good indication of the profiles that mining areas may have at the end of mining. As already described above, in the 18 years since the abandonment of the former mines, the slopes have been subject to weathering, small scale landsliding, erosion and partial revegetation. No rehabilitation work has been carried out, and thus these former mine sites remain visually intrusive within the landscape and the contrast with the adjacent un-mined areas is stark. Illustrations and observations are contained in Figure 2. The post-mining landscape will be similar at the end of this project, except that it will not have had 18 years for vegetation to colonise. It will therefore have an artificial terraced configuration but will be bare and dark-coloured in the landscape, with high rates of runoff controlled by active management of the drainage system and sediment ponds. As described above, a number of physical measures will be required before the sites can be re-vegetated and the long term process begun, of moving it back into rainforest. In terms of biology, few places are totally sterile. Since the project sites will not contain excessively acid or otherwise toxic soils, and sine the surrounding forests have an impressive seedbank of natural pioneer plants, the worked-out areas will soon start to show the first signs of habitat re-creation. As soon as herbaceous plants start growing, insects begin to appear, and birds and reptiles follow. Yet this will be far from the rainforest landscape that exists in these sites now. The aim of this document will be to transform disturbed sites as far along the dynamic continuum of rainforest re-colonisation and development as the resulting soils are able to sustain.

6.2 Landscape Rehabilitation Over time the vegetation can be expected to succeed to more permanent communities such as grassland, scrub or woodland. However, in most industrially disturbed areas succession processes will be very slow (as illustrated in Figure 2) due to a combination of the extreme physical conditions imposed by the limited soils and the low fertility and limited water-holding capacity of the weathered materials that form the surfaces after mining and related activities. In industrial wastelands where future sustainable management is not being addressed, grazing animals and activities such as the burning of grass also tend to retard the rehabilitation process. Proactive measures for revegetation are therefore required. At a better-developed vegetation site on the side of the Blue Lake (i.e. the old flooded pit at the LAMCO Nimba mine), approximately 15 cm of gravelly sandy loam had formed on the mine bench over a period of about 15 years. The gravel fragments were generally platy rather than angular and were rich in iron. There was a notable quantity of leaf litter over approximately 10 cm of organic-rich loose material with a dense network of fine to medium roots. While this site may be seen as an indication of what can be achieved naturally, it should be possible to arrive at a better and quicker result through actions that assist plant germination and rooting, rather than relying on unaided natural colonisation as has been the case at Nimba and Tokadeh. Hence more knowledge is needed of indigenous larger plants to act as pioneers in the harsh conditions of very iron-rich and organically sterile material left from the mining operation. The factors limiting growth also need to be identified: the most likely are the compaction of the material, limiting water-holding capacity and root penetration; and phosphate deficiency, a common problem on iron-rich soils, where available phosphorus is frequently bound as insoluble iron phosphate. For this reason ArcelorMittal Liberia initiated a research programme in 2012 to undertake land restoration trials to determine the most effective and efficient methods of accelerating natural revegetation of cleared land areas to be implemented as part of this Mine Closure Plan. At present, little is known about the nature and rate of the revegetation process and thus restoration efforts would benefit greatly from a better understanding of the constraints on habitat recovery on



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Mount Nimba. Negotiations are underway with the Forestry Development Authority and community members of the Joint Management Committee of the East Nimba Nature Reserve, for the Company to set up sample plots at selected sites in the abandoned Nimba mine – for example one or two on the benches on the harder ore near the Blue Lake, and others on the DSO areas near the CellCom Tower on Mount Gbahm – where the natural ongoing revegetation process can be monitored. While the focus of the trials is on assisting natural regeneration, adjacent to these sites experimentation will be carried out with the planting of a range of local grasses, shrubs and trees on a range of surfaces. Various fertiliser applications could also be trialled. Later, similar trials should be established on non-mined areas such as waste dumps, abandoned access roads and other areas to be vegetated. At all sites, natural or prepared, annual audits will need to be completed to note changes in species number (both flora and fauna) and health. These reports should include photographs as well as species descriptions. Trials should include:

natural unaided revegetation on DSO and hard ore terraces;

natural unaided revegetation on non-mined surfaces (i.e. natural sites with shallow surface soils);

natural revegetation after disturbing the land surface by scarifying or otherwise loosening the surface;

natural revegetation after spreading a layer of finer material taken from the waste dumps and sediment removed from settlement ponds; and

planting (both seeds and seedlings) of a range of local grasses, shrubs and trees on scarified surfaces, with and without applications of fertiliser.

In the planted trials, the species selected should be a mix of colonisers (grasses or shrubs) and succeeding generation trees. At all sites precautions must be taken against fire and for that reason a fire brake should be constructed by clearing vegetation (particularly very flammable species like the invasive Chromolaena odorata (Assam or Doe weed) which invades and dominates disturbed areas. Suggested trial species include:

A number of not very flammable fleshy climbers, including Adenia lobata, A. cissampeloides and Crossostema laurifolia.

Common legume climbers of secondary vegetation in the area, such as Adenopia scelerata, Dalbergia rufa, Desmodium adscendens, Aganope leucobotrya, and various Leptoderris spp., depending on the dampness of sites.

Three locally common fast-growing pioneer trees: Ceiba pentandra (kapok, silk cotton), Harungana madagascariensis (very pioneering) and Milicia regia (timber tree).

Three locally common fast-growing leguminous trees: Albizia adianthifolia, Albizia zygia, and Piptadeniastrum africanum (Dahoma, a trade name).

Since there appears to be little to no propagation information on most of these species, it might be best to do multi-species mixtures with Adenia spp. Ficus species could be separately researched for the mine sites as they tend to favour rocky areas and have an added advantage in that they encourage bats and other fauna. Many common Ficus species grow in north Nimba, including F. exasperata, F. kamerunensis, F. mucuso, and especially F. saussureana. These species can generally be very easily propagated by cuttings. In this respect Dracaena mannii, Newbouldia laevis and Erythrina spp. can also be recommended. Further work is needed to develop the understanding of both pioneer and climax community associations of indigenous rainforest species in Nimba, and how these might be encouraged to develop most effectively. To achieve this first requires more analysis of the botanical information collected as part of the ESIA which this Plan accompanies. Once that has been done, it needs to be discussed with both local communities and field experts in the Forestry Development Authority and other agencies, to ensure that the accumulated knowledge encompasses local and national expertise as well as international science. This will allow a more sophisticated set of trials to be designed than is currently possible. Future iterations of this Mine Closure Plan need to encompass this work and state how the interpretations of the results can best be used.



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6.3 Skills and Resources for Rainforest Restoration ArcelorMittal proposes to run an environmental Offset Programme that focuses on providing compensation for project impacts that cannot be otherwise mitigated, through the promotion of long term systems for forest conservation based on community management. It is expected that this programme will be operated by the company throughout the period of the mine. By the time of closure, it will have developed in-depth skills in the management of natural resources in Nimba, as well as having developed strong, long term working relationships with the communities around the mine sites. Once the need for offsetting ends with mine closure, the team that has run this programme will be ideally suited to undertake the land restoration part of the Mine Closure Plan in close collaboration with the relevant communities. It is therefore proposed that these staff will be redeployed to use their skills and resources to manage this aspect of the plan. It is envisaged, however, that the main implementation work will be done by the communities themselves. One-off surface protection repair activities will be undertaken using the Company‟s standard community contract system, as has been the case with revegetation works in the past. More substantive and longer term activities will be arranged through a memorandum of understanding agreed with either the appropriate Town or Clan Chief, or with a Community Forest Management Body responsible for an area. These would typically be where it is intended to undertake a long term restoration programme to bring a damaged site back into forest of conservation or productive interest. The agreement reached would include financial support from the Company to the community for the works required to bring the forest up to a standard where the desired long term management can start; from then on there would be diminishing support until the community is able to manage the resource sustainably along the agreed lines. This process would be facilitated by the ex-Offset Programme team.



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7. EARLY AND EMERGENCY CLOSURE SCENARIOS

7.1 Contexts of Early or Emergency Closures Early closure is most likely to be temporary and to come about as a response to a downturn in market conditions. This is not uncommon in iron ore mining, and occurred several times during the LAMCO tenureship of the Nimba concession. Steel consumption is closely linked to the health of the global economy, and is strongly influenced by downturns in construction and manufacturing. The major downturn in the global economy in 2009 saw a major slump in the prices and sales of steel, with the result that there was a big decline in demand for iron ore. Emergency closure may be a very different scenario. Depending on the reason and speed with which sudden closure is necessitated, there may be little or no time to implement the rehabilitation plan for mined and non-mined locations, nor for the removal of movable assets, scrap or waste. For this reason, strict implementation of the ESMP and establishment of „best practice‟ procedures for all activities should reduce the amount of clean-up required at mine closure, and thus the legacy that could have significant environmental impacts. As with all emergency situations, careful planning and rehearsed procedures should apply. For each situation a reaction plan should be detailed. Factors to consider include:

Type of emergency – civil unrest interrupting operations; resumption of civil war threatening Company personnel; natural disaster; other

Potential length of closure (days, weeks, years). The sections below give initial outlines of the measures that will be necessary in these different scenarios.

7.2 Short Term Voluntary Closure As stated above, voluntary closure of the iron ore mines is most likely to come about as a result of an economic decline that makes iron ore production unprofitable. This is difficult to predict more than six months ahead at the most, because of the complicated global economic conditions that lead to such an event. Although it may be clear at head office that such an event is approaching, it can be difficult for this information to be transmitted to site in advance because of the worry and alarm caused to staff. Hence although there may be some warning, it is usual to stage a fairly rapid closure once a decision is made. Voluntary closure normally involves a process of moth-balling an operation and the retention of a skeleton staff complement to manage it. Attention must be given to safeguarding drainage systems, preventing erosion and ensuring the stability of spoil dumps and the tailings management facility. Each of these would need to be assessed on its own merits on the basis of conditions prevailing at the time of closure. When the last economic downturn, in 2009, caused a cessation of project activities during the pre-mining rehabilitation phase of the Western Range Iron Ore Project, priority was given to the revegetation of bare soil areas around the railway and exploratory drill sites, and the establishment of drainage and filtration systems around stockpile areas. The Company therefore already has experience of this situation, therefore, and while this part of the Mine Closure Plan needs further development as the project moves forward, it is an area that ArcelorMittal Liberia already understands. It is also not possible to say how long a closure of this nature might last. Experience in the past suggests that it is not normally for more than a year, but this might change in future situations.

7.3 Short Notice Emergency Closure The most difficult emergency to plan for will be civil unrest or natural disaster which, as in the past, may occur suddenly and destructively.



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A priority list of activities (in order of precedence and depending on length of notice – hours, days or weeks) to be undertaken in the event of civil unrest should be as follows.

1. First priority will be the security of personnel. In the case of violent civil unrest the mine closure plan would take second place to evacuation of staff – as outlined in the Company security action plan.

2. Assemble all equipment at storage sites in each of the main footprint areas (i.e. mine site workshops, office areas, port, etc), secure buildings and transfer files and essential documents to safe storage. Assure that all hazardous materials are securely stored or removed.

3. Arrange for the emptying and removal of contents from fuel storage tanks and other hazardous materials to safe locations.

4. Undertake rapid earthworks to stabilise active mine benches and waste dumps, such as by reducing slope angles, creating berms or filling drainage points with rocks to prevent scour.

5. Undertake rapid de-watering of the tailings management facility and ensure that the emergency spillway can cope with a worst-case flood event.

6. Activate the emergency closure plan for the concentrator and power plants.

7. Scarify or otherwise loosen bare ore and rock surfaces to assist natural revegetation of the mine areas (in the event that return to normal activities is not likely in the foreseeable future).

8. On secession of the emergency, recommence mining or arrange for reclamation of the mine footprint as outlined in other parts of this Plan.

7.4 Emergency Sudden Abandonment An emergency sudden abandonment is an extreme form of the short notice emergency closure, and would probably only occur in the event of an unexpected hostile rebel action or invasion. The list of priority actions given in section 7.3 should be followed, as far as it is possible to do so.



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8. DEVELOPMENT AND EVOLUTION OF THE MINE CLOSURE PLAN This Framework describes the outline of a Mine and Infrastructure Closure Plan that needs to be developed over both the construction and operation period of the project. At this stage the development timeframe can be summarised in the table below. Year Project status Mine Closure Plan Status

2013 Finalisation of design and ESIA; start construction Framework for Plan drafted, reviewed and enhanced

2014 Main construction period TMF details added; financing strategy agreed

2015 Complete construction; commission concentrator Plan updated as informed by construction

2016 Commence production Detailed Closure Plan finalised, including financing

2017 Full production

2018 Full production Closure Plan reviewed and updated













2031 Full production Post-mining community arrangements consulted

2032 Full production Post-mining community arrangements agreed

2033 Full production Community structures put in place and trained

2034 Production ends and decommissioning starts Offset Programme switches to Mine Closure works

2035 Physical decommissioning and land restoration Main period of Plan implementation

2036 All project works cease Land restoration and revegetation

2037 Further revegetation and re-afforestation works

2038 Handover to community management

2039 Complete support and withdraw

2040 Evaluation of Plan effectiveness and remedial action





The allocation of responsibilities for the development and implementation of the Mine Closure Plan needs to be addressed during the next iteration of the Plan. This is because decommissioning needs to be based on skilled assessments by specialist departmental staff, and also because it is inevitably the responsibility of each operational department to decommission its own equipment and facilities. Moving beyond this Framework will therefore involve the establishment of a working group of senior managers to take forward all parts of the Plan in a co-ordinated fashion. The budget and financing schedule for the Mine Closure Plan need to be developed so that the implications are clear before operations start. This aspect of the Plan must therefore be substantially agreed by the end of the construction period.



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9. ENSURING THE SUCCESS OF THE CLOSURE PLAN

9.1 Financing of the Closure Plan The financing strategy for the Mine and Infrastructure Closure Plan has not yet been determined in detail although an outline has been estimated under ArcelorMittal‟s policy of determining the Assets Retirement Obligations of all of its steel plants, mines and other facilities. As shown in the timetable in section 8, the financing strategy will be determined as part of plan development in 2014, and finalised in 2016.

9.2 Evaluation of the Implementation of the Closure Plan The Mine and Infrastructure Closure Plan for the Nimba Western Range Iron Ore Project is complex on account of the multiple sites and types of infrastructure that need to be decommissioned and rehabilitated. Some of the infrastructure is relatively complex – such as the concentrator – and some require careful de-contamination – such as the fuelling points and workshops. Each element of the Plan therefore needs to be evaluated once it has been completed, to ensure that the closure activities have achieved the agreed standard. The evaluation schedule must be developed alongside the schedule of actual closure activities. Each of these must have target standards for post-closure assessment that are measurable to ensure that an adequate level of implementation has been achieved. Some may require recurring evaluation, to ensure that effectiveness is not short-lived: an example of this is site revegetation, which may thrive for a few seasons and then decline due to limited soil nutrition or an ineffectual management system. Future iterations of this Plan therefore need to include not just statements of closure activities to be undertaken, but also the quantifiable and time-based targets that need to be met to ensure confidence that a high standard of rehabilitation has been achieved.

9.3 Post-closure Environmental Monitoring ArcelorMittal will need to implement a programme of post-closure environmental inspection and monitoring to ensure mine reclamation is satisfactory. It will also verify that the various components of the closed mine are not adversely impacting the environment, and do not pose a potential health risk and/or danger to the public. This monitoring programme will be required to be in place for an appreciable length of time (a minimum of 5 years, but perhaps 10 or 15 years if necessary) after closure to ascertain whether ecosystem functions and/or ecological value have sufficiently been restored for the restoration plan to be considered a success. This might be handled by a contract with a consulting firm or by the Department of Forestry or by an appropriate department at the University of Liberia as a research programme. As a minimum, post-closure environmental inspections should focus on:

the cleanliness of former infrastructure areas, particularly those that utilised hazardous materials or generated hazardous wastes;

the level of sedimentation in streams immediately below former mine sites, waste dumps and other potentially erosive surfaces;

any activity that may adversely affect the stability of disused mine structures, and therefore result in environmental degradation or pose a danger to communities;

the revegetation processes, particularly signs of succession in terms of species;

the changes in plant and animal populations at selected sample sites; and

any local concerns pertaining to the closed project site. It will also be necessary to monitor the performance of social provisions, livelihood regeneration, community development and skills development initiatives under the community engagement strategy, plus the performance of the Offset Programme. In particular it will be essential to monitor the outcome of the bullet point social actions listed in section 1.3.

framework of the proposed mine and infrastructure closure...

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