At this link is an announcement that the BC regulators are seeking proposals from consultants to help them evaluate the independent dam safety analyses they have ordered be done by independent folk on all the tailings facilities in BC.
Dam Safety Inspection Review is the heading. Here is the full announcement — it is fascinating for what it tells and what it does not tell.
The Ministry of Energy and Mines has issued a Request for Proposal (RFP) for a qualified contractor to assist with the oversight of the process for independent third-party reviews of Dam Safety inspections for every permitted mine tailings storage facility in British Columbia.
Permitted mines are required to conduct a dam safety inspection each year. As part of the response to the tailings storage facility breach at the Mount Polley Mine, the Chief Inspector of Mines accelerated the deadline for this year’s inspections to Dec. 1, 2014, and added a requirement for these inspections to be reviewed by an independent qualified third-party professional engineer from a firm not associated with the tailings facility.
The order also includes a requirement for a third-party review of the dam consequence classifications by Dec. 1, 2014. A dam’s consequence classification is based on the potential impact to population, the environment, cultural values and infrastructure should it fail, and is set according to the Canadian Dam Association Dam Safety Guidelines. Under the order, mines with high, very high or extreme consequence classifications will be required to have their Emergency Preparedness and Response Plans reviewed by an independent third-party.
The successful proponent will be required to have geotechnical expertise and will assist the Ministry of Energy and Mines with reviewing submissions to ensure consistency and compliance, working with First Nations throughout the process and producing a report on the information collected, including the release of all submissions to the public.
Once the inspections and the independent reviews of those inspections have been received, the review and analysis of those reports is expected to take a minimum of eight weeks to complete. Once the review is complete, all information will be made public.
There are currently 98 permitted tailings impoundments at 60 operating and closed metal and coal mines in B.C.
Here is the link to the official call for proposals. One limitation:
Proposals will not be evaluated if the Proponent’s current or past corporate or other interests may, in the Province’s opinion, give rise to a conflict of interest in connection with the project described in this Request for Proposals.
More specifically, the proposer should be prepared to do the following:
1) Establish a platform and protocols for the public release of all submissions that is publically
accessible and user friendly. Develop and implement a strategy to respond to public inquiries
surrounding the content of the released documents.
2) Develop and implement, with the Ministry and First Nations Energy and Mining Council and
other First Nations groups as appropriate and determined by the Ministry, a mechanism to
engage First Nations with regard to the dam safety inspection reports.
3) Consistent high-level review of all submissions:
a. Dam Safety Inspection (DSI) Reports – to be reviewed for consistency with the Dam
Safety Inspection Guidelines (the Ministry’s Internal Document) and good engineering
b. Third-party review of DSI Reports – to be reviewed for consistency with the spirit of the
Order and good engineering practice.
c. Commitment from Mine Manager to complete recommended works, and proposed
schedule for these works – to be reviewed for consistency with the DSI and third-party
review recommendations. May require follow-up with the engineers who conducted the
reviews to gauge the “reasonableness” of the proposed mitigation schedule for any
d. Dam Break Inundation Study – to be reviewed for consistency with good engineering
e. Emergency Preparedness and Response Plan – to be reviewed for consistency with the
Canadian Dam Association Dam Safety Guidelines and good engineering practice.
f. Summary of the Emergency Preparedness and Response Plan Test – to be reviewed for
consistency with standard industry practice. Tests may range from table top exercises to
full mock emergency exercises.
4) Synthesis Report – to include factual data surrounding the review process, number of
submissions, any outstanding reports (with proposed submission dates), common themes or
recommendations, anticipated questions and answers (Q & A) to assist the public in absorbing
the vast quantity of material, and any other significant factors relevant to the Order and Industry Response.
5) Data-entry of all report submissions to the Ministry’s report inventory spreadsheet.
6) Follow-up with mining companies to ensure compliance with all submission requirements. This would have two components:
a. Phase 1 – to ensure that submission requirements are satisfied and to communicate to the
mine that follow-up will occur to ensure mine commitments resulting from report
recommendations are satisfied
7) Provide a summary of activities undertaken as part of the contract mandate and recommend a
cost and resource effective approach to making future dam safety inspection reports publicly
available including a framework for receipt, filing, review, synthesis, and managing public and
First Nations engagement.
All good ideas. But why do we need private consultants to do what is essentially a government responsibility? Maybe this is the ultimate in commercialization of the regulatory oversight function.
As a blogger I am probably automatically excluded. But you can be sure the big out-of-province and out-of-country consultants are sharpening their pencils.
PS. Above is a pretty awful reproduction of the 2009 cross section of the embankment that failed at Mt Polley. I showed it to Andy Robertson this evening without telling him where it is. His response: “That is the so-called modified center-line section. For years I have said it is the wrong thing to do. I have said it will fail and besmirch the name of center-line embankments.” When I told him it was of Mt Polley, he shook his head in despair.
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