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Posts Tagged ‘Mining association of canada’

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The five pictures in this posting, were taken (by me) at the Getty Center in Los Angeles.  This place is surely a testament to genius and attention to detail.

Yesterday I was asked if Canadian guidelines are adequate to deal with the Mt Polley situation. More specifically, the questions continued: if the current Canadian guidelines regarding tailings dam safety had been implemented, would the failure have been avoided. Before I answer these questions, let us first take a look at the guidelines that are out there.

APEGBC, the Association of Professional Engineers and Geologists, of British Columbia on their website say this:

APEGBC recently published professional practice guidelines for dam safety reviews: the Professional Practice Guidelines – Legislated Dam Safety Reviews in BC, which were commissioned by the BC Ministry of Forests, Lands and Natural Resource Operations. The Guidelines define the professional services, standard of care and specific tasks to be provided by APEGBC members conducting this type of work; provide descriptions of the roles and responsibilities of the various participants/stakeholders involved in a dam safety review; and set out expectations for the appropriate knowledge, skill sets and experience to be held by APEGBC members working in this field. The Guidelines also aim to address consistency in the reporting prepared by APEGBC members providing professional services in the field of dam safety reviews.

The Mining Association of Canada has published two guidelines for tailings facilities. These are described well at this link in the following terms:

In 1998 the Mining Association of Canada (MAC) published A Guide to the Management of Tailings Facilities. This guide was prepared by the Canadian mining community and is designed to assist mine operators in developing a successful management system for their tailings facilities. It covers each stage of tailings management from design through construction, operation and then closure and reinforces the integrated nature of each element. Its purpose is to provide information on safe and environmentally responsible management of tailings facilities, to help mine operators develop tailings management systems that include environmental and safety criteria, and to improve the consistency of application of sound engineering and management principles to tailings facilities.

MAC published a follow up manual in 2003 entitled, Developing an Operation, Maintenance and Surveillance Manual for Tailings and Water Management Facilities. This manual was developed to compliment the 1998 guide with a view to focusing on the day to day operations of a tailings facility. The need for this manual became apparent in 2000 when mining companies were demonstrating a significant progress in adopting and implementing tailings management systems. The manual draws on sound industrial practice and procedures and was prepared by tailings experts within the Canadian mining community.

In 1999 the Canadian Dam Association (CDA) revised its Dam Safety Guidelines to include tailings dams. MAC and other contributors helped to develop and incorporate tailings facilities into CDA’s guidelines meaning they now have the same level of respect as conventional dams. Martin et al. (2002) report that the revised guidelines focus on the responsibility for dam safety, scope and frequency of dam safety reviews, the need for an operating manual and emergency planning.

The MAC guide and manual and the CDA guidelines are intended to complement government regulations and promote due diligence of a mineral operator. The overall goal is to protect the environment and the public from the hazards associated with tailings storage.

The MAC guide and manual and the CDA guidelines are intended to complement government regulations and promote due diligence of a mineral operator. The overall goal is to protect the environment and the public from the hazards associated with tailings storage.

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Then there are documents on the same subject from the Canadian Dam Association. Their website notes as follows:

 CDA has developed Dam Safety Guidelines and related technical bulletins that have become primary  references for dam owners, operators and regulators. The CDA Mining Dams committee has developed  additional guidance on dam safety for tailing dams and other mining dams, following a three-year period  of input, review and comment. The new publication – Technical Bulletin, Application of Dam Safety  Guidelines to Mining Dams – addresses technical aspects of mining dam safety. This Bulletin will be  released at the annual CDA conference to be held from Oct. 6 to 9, 2014. Further guidance on  management and operation of tailing dams is available from the Mining Association of Canada.
There has been some confusion in the media with respect to CDA’s role in the regulation of dams. CDA  publishes guidance on the design, construction and safe operation of all dams including tailings dams. In  Canada, the licensing and regulation of dams is under provincial or territorial jurisdiction. While our Dam  Safety Guidelines and technical bulletins provide valuable assistance to regulators, dam owners and dam  managers, they are neither standards nor regulations. The Canadian Dam Association has no regulatory  authority.   The Mount Polley tailings dam failure illustrates the need for continual vigilance among mine owners,  dam safety engineers, operators, and regulators. The Canadian Dam Association supports efforts to  advance understanding and practices to improve safety at all dams.

In the past year I have done dam safety inspections for eleven tailings facilities from northern Quebec through the USA and Central America to South America. Obviously I read the guidelines noted above in detail before undertaking this task, and many times during the work.

My opinion: the guidelines are all good and informative, but they are timid. They were written by those sympathetic and beholden to the mining industry and thus they were written so as not to offend anybody in mining. They were written to encourage miners to do better. But they make no demands that involve too great an effort or expenditure.

Another opinion: if you need these guidelines to tell you how to undertake a dam safety inspection, you better not undertake the dam safety inspection, for the guidelines are far below the degree of experience and expertise needed to undertake a professional, thorough, and competent dam safety inspection.

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To take one example. There is a call in the APEGBC document for peer review. This is how it is stated:

An independent peer review is an additional level of review beyond the minimum requirements of Bylaw 14(b)(2) that may be undertaken for a variety of reasons (such as those listed in section 4.3) by an independent Qualified Professional Engineer not previously involved in the project. At the discretion of the Qualified Professional Engineer, in consultation with the reviewer(s) involved in the regular checking/review process outlined above, such an additional level of review may be deemed appropriate.

Alternatively, a local government or other approving authority may request an independent peer review to support project approval. An independent peer review may be undertaken by another Qualified Professional Engineer within the same firm, or an external Qualified Professional Engineer.

The independent peer review process should be more formal than the checking/review process carried out under Bylaw 14(b)(2). An independent peer reviewer should submit a signed, sealed and dated letter or report, to be either included with the dam safety review report or put on file, which includes the following:

  • limitations and qualifications with regard to the independent peer review; and
  • results of the independent peer review.

When an independent peer review is carried out, the Qualified Professional Engineer who signed the dam safety review report remains the Engineer of Record.

The independent peer review discussed above is not the same as an independent review or advisory service provided by a Qualified Professional Engineer who is retained by the Regulatory Authority, or sometimes a client.

Pusillanimous, is all I can conclude.

So sadly, I must conclude that even if the guidelines had been fully implemented at Mt Polley, which I am sure they were not, the failure probably would not have been avoided.

Fact is folk, that the best standards of practice internationally on big and important tailings dams involves at least the following:

  • An annual report by the Engineer of Record on what was done at the dam by way of design, construction, deposition, and instrumentation during the preceding year.
  • A report by an independent and different engineering firm of the status of the dam. In South Africa as a result of the Bafokeng and Merrispruit failures, this is done every three months.
  • Annual or more frequent meetings by an independent panel of three senior peer reviewers. All the oil sands tailings impoundments have peer review boards. Nordie Morgenstern, to my knowledge, sits on those of Suncor and Syncrude.

I bet you none of this (these?) are done on any BC tailings dams. Certainly they were not done at Mt Polley. And none of the guidelines I mention above mandate these actions. Why? As I noted, to do so would offend the mining industry and result in rejection of the guidelines.

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Sad but true. Thus I must conclude that the new independent review panel must find that the international standards of review were not followed, that Canadian guidelines do not mandate the same, and that if we are to preclude future failures of Canadian tailings facilities (four in the past two years) we are going to have to make major changes to the way we work.

This is not a matter or one in a million as Dirk van Zyl says. It is a matter of one in five thousand—each and every year and thus worthy of major attention and change.

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Late evening in Santiago, but still I must post this information.  At this link you will find a fascinating book put out by the Mining Association of Canada and the PDAC.  It is called 100 Innovations in the Mining Industry. It takes a while to download, but be patient.  The resultant product is well worth the wait.  (more…)

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