Interview: L.Tsetsegsuren “Planning environmental rehabilitation before earthwork commences is crucial”

– The Oyu Tolgoi mine complies with environmental rehabilitation standards –

Interviewed L.Tsetsegsuren, Environmental Supervisor, Oyu Tolgoi LLC.

Earthwork is necessary for any construction, what is Oyu Tolgoi’s management policy on this?
Today, development work at the Oyu Tolgoi mine is 90 per cent complete. A total of 3024.86 hectares of land has been disturbed for this development. We can say this precisely because we have a land management team who accurately register each area to be disturbed for the mine construction. To minimise damage to the land, the team ensure no land beyond that area is disturbed by construction work. This activity is regulated by the internal Land Permit Procedure.

What is a Land Disturbance Permit? Can you clarify this?
The land disturbance permit procedure is conducted by other mining companies. However, specifics of the Land Disturbance Procedure for the Oyu Tolgoi project is different. The Internal land disturbance permit procedure of Oyu Tolgoi ensures that any earthwork related to the mine development complies not only with the relevant laws and standards of Mongolia, but also with the environmental standards of international organisations such as the European Bank of Reconstruction and Development and all requirements set in the Detailed Environmental Impact Assessments of the Oyu Tolgoi project. We made a broad legal study and reviewed the best practices of large global mining companies and included that in the procedure. The procedure is being implemented successfully. According to the procedure, a contractor has to obtain a land permit from our department before disturbing any land. The request must include the size of the area of land required for the given work. Based on this, the environmental department of Oyu Tolgoi LLC inspects the area. We check that the planned earthwork complies with the environmental protection laws and regulations and determine the area’s vegetation groups and top soil types. This is the first and most important stage of the environmental rehabilitation work. This is necessary so we can restore the area back to its original condition once construction work is completed. Land rehabilitation requires the restoration of the original vegetation groups. The original vegetation successfully forms in the top soil with distinctive characteristics. Professional conclusions about the impact on rare flora, soil quality, wildlife and the water reserve is made by the relevant teams. If work is to be conducted outside the mine license area, the Community Relations department of Oyu Tolgoi assesses the impacts on local communities and cultural heritage in the area. This way, based on extensive research and assessment, conditions for the land disturbance permit are written and approved. This ensures that contractors comply with these conditions during work and restricts land disturbance to the permitted areas. This also ensures that top soil protection, dust reduction and rehabilitation of the disturbed land is monitored.

Is stripped soil stored in one place. How it is done? Are there certain standards for this?
There is a common public perception that mining companies disturb land and then leave. At Oyu Tolgoi we have a detailed environmental rehabilitation plan to restore each area that has been disturbed. Rehabilitation work starts with the stripping of top soil by an excavator. Top soil is a strategic and important item in the rehabilitation of land. Planting and watering seeds in an area without top soil does not restore it to its original condition. Therefore, any construction or earthwork starts with the appropriate stripping of top soil. The depth of top soil stripped is included in the land disturbance permit. Where we store the top soil is also indicated in the permit. The location of topsoil storage depends on the time needed for construction. If the given area is to be used for many years, the top soil is transported to long term topsoil storage areas. If the area is needed for a short period of time, the topsoil is stored in the surrounding area. The soil is stored in 3 metres high piles to best preserve its nutrients.

Can you explain how land is rehabilitated after a long period of time?
Rehabilitation must be appropriately planned before the start of earthwork, otherwise there is risk of unsuccessful rehabilitation. At the Oyu Tolgoi project, a preliminary mine closure plan was developed as part of the mine feasibility study. According to this, a detailed mine closure plan will be developed five years after the mine production starts. During the construction phase, Oyu Tolgoi is working to the interim rehabilitation management plan. Implementation of this plan is ensured by the Land Disturbance Permit procedure. Contractors conduct technical rehabilitation in areas where construction activities have taken place and then hand it back when it meets requirements of the relevant laws and standards.

Why is technical rehabilitation is very important? Why is it specifically important for a mining company?
Success of biological rehabilitation work depends on the implementation of technical rehabilitation. In other words, technical rehabilitation work determines whether seeds will grow. We work closely with contractors to ensure the appropriate implementation of technical rehabilitation. We explain the standard requirements of the technical rehabilitation and regularly monitor its implementation and provide timely recommendations. There are basic requirements for technical rehabilitation for re-covering the land according to how it was initially disturbed, assimilating the fill and grade with the surrounding environment and making the area safe for local residents, wildlife and animals. Slopes must be kept to a maximum of 18 degrees, as per the Mongolian standard. Surfaces need to be compacted to prevent wind erosion and covered with topsoil. Lines need to be made in the top soil.

Creating lines in the top soil by combing it against the direction of the wind it is one of our main requirements for the technical rehabilitation.This requirement is not in the rehabilitation standard but it is very important for re-vegetation of the disturbed land. The combed lines allow seeds blown by the wind to sit in the ripped soil. Seed planted in the lines sprout because moisture accumulates in the lines and eventually creates conditions for successful re-vegetation. As the construction phase of the Oyu Tolgoi project is about to be completed, contractors are conducting technical rehabilitation work on construction areas and handing it back. Technical rehabilitation work has already been completed on 845 hectares of land. Let me explain in an easy-to-understand way, why this work is essential for a mining company. Waste rock piles emerge from open pit and underground mining operations. These piles need to be established in a way so they don’t collapse or cause danger to animals and humans. The angles and slopes of these piles need to correct and the surfaces need to be stable.

Were mining companies previously using these procedures in rehabilitation work? There are many companies working on the Oyu Tolgoi Project. How do you ensure compliance with this standard?
We are doing it. Numerous contractors are working on the Oyu Tolgoi project. All these companies are working in permitted areas and they develop top soil management plans before starting road and construction work. We review and approve these plans. These plans include rehabilitation work after the construction work. The companies have a duty to meet all quality standards and requirements for rehabilitation of the areas they worked on. We ensure that rehabilitation work complies with the standards. We regularly monitor implementation of the rehabilitation plan and provide necessary recommendations. When we consider the rehabilitation work is done to a sufficient standard, we close the land disturbance permit and inform the project management unit. Only then is the contractor’s work complete. For the first time in Mongolia, Oyu Tolgoi have introduced a principle of regular, strict monitoring where we provide recommendations and cooperation. It is crucial for companies in their future work, to continue implementing what they have learned from the Oyu Tolgoi project and to act as role models for others.