bc-mountpolleyspill2014
bc-mountpolleyspill2014

Are Catastrophic Failures & Mining Spills Preventable?

Here's a set of key recommendations from various industry experts, practionners and analysts that believe catostrophic failures of mining waste facilities can be avoided if regulators take the following actions (NOT EXHAUSTIVE - additional comments welcome):

Governance:

  1. Safety is the priority, not costs.
  2. Vet out financially risky mining projects likely to cut corners and unable to afford the safest measures.
  3. Immediately assess all existing mining wastes facilities and dams for potential failures and financial risk analysis.
  4. Maintain a detailed mining waste facilities and dams inventory database accessible to public.
  5. End self-inspection and regulatory capture: divide the compliance and enforcement programs from the promotion programs.
  6. End incremental permitting by governments; one integrated analysis, all at once.
  7. Enforce laws when they are violated.
  8. Respect inherent, constitutional and international Indigenous rights, including the right to free, prior and informed consent.

Financial:

  1. Require detailed bankable feasibility studies prior to Environmental Assessment and/or permitting, with detailed costs analysis of failures. 
  2. Require adequate securities paid up-front to safeguard taxpayers and communities for clean-up costs at closure and for perpetual care of site. 
  3. Establish a national or international insurance pool paid by the industry for catastrophic failures.
  4. Require proper reddress mechanisms for the environment and the victims of a failure.

Technical:

  1. Ban dangerous mining waste facilities located upstream from communities and sensitive areas.
  2. Ban dangerous ‘upstream-type’ and cascading dams in favour of safer centreline (not modified-centreline) and downstream dams (better) to retain wastes (e.g. Chile) 
  3. Ban large water covers at closure (dry closure, with dry covers).
  4. Ban mining waste facilities requiring perpetual (or long-term) water treatment. 
  5. Ban subaqueous disposal of mining wastes into rivers, lakes or oceans.
  6. Ban clay foundation and slime deposits in or near dams' structures.
  7. Ban penstocks and pipes through tailings and dams.
  8. Require Best Available Technology (BAT), shifting away from conventional, wet slurry mining wastes disposal with water covers to safer, drier methods.
  9. Require integrated approaches to mining waste management, such as desulfurization, co-disposal, underground filling, in-pit filling, smaller mining waste cells restored quickly, etc.
  10. Require a qualified 'talings manager' and a 'water manager' on-site accountable to the regulator and the public.
  11. Require an Independent Engineer of Records accountable to the regulator and the public. 
  12. Require Independent Tailings Review Boards (ITRB) accountable to the regulator and the public.
  13. Require a 'security factor' of at least 1.5 for the mining waste facility operation.  
  14. Require dam slopes of at least 2 to 1 (2:1) or 3 to 1 (3:1), and possibly even flatter at closure or in high risk zones.
  15. Require dam design for a Probable Maximum Flood (PMF), particularly in the context of climate change and increased uncertainty 
  16. Require dam design for a Maximum Credible Earthquake (MCE), generally 1 in 10,000 years or more 
  17. Require detailed site characterization prior to design and construction (e.g. APEGBC Guidelines) 

United Nation Environment Programme Report (UNEP 2017)

Growing trends of serious and catastrophic mining waste failures worldwide (Bowker & Chambers 2016 & 2017):

DIAC Compilatio of Engineering Practice References for Dam Safety Best Practices (DIAC 2017): https://miningwatch.ca/sites/default/files/2017-diac-engineering-practice-references_0.pdf

Canadian Dam Association Safety Guidelines (CDA 2013, currently being reviewed, not yet released): https://www.cda.ca/  

Site Characterization for Dam Foundations of the Association of Professional Engineers and Geoscientists of BC (APEGBC 2016): https://www.egbc.ca/News/Articles/Site-Characterization-Guidelines-Improve-Dam-Safet or https://miningwatch.ca/sites/default/files/2016-apegbc-site-characterization-dam-foundations.pdf

Tailings Management Protocol of the Mining Association of Canada (2017): http://mining.ca/towards-sustainable-mining/protocols-frameworks/tailings-management-protocol

Recommendations from the Mount Polley Expert Review Panel (2015): www.mountpolleyreviewpanel.ca/final-report

Recommendations from the BC Chief Inspector of Mines (2015): http://mssi.nrs.gov.bc.ca/1_CIMMountPolley/BCMEM-report-3_04-web.pdf

Recommendations from the BC Auditor General (2016): www.bcauditor.com/pubs/2016/audit-compliance-and-enforcement-mining-sector

Recommendations from economist Robyn Allan on financial assurance for failures & spills (2016): https://miningwatch.ca/sites/default/files/toward_financial_responsibilty.pdf

Recommendations from Jack A. Caldwell, Robertson Geoconsultants (2016): https://miningwatch.ca/sites/default/files/2016-12-caldwell-tailings-failures-how-avoid.pdf

Recommendations from Amnesty International Canada (2017): www.amnesty.ca/news/breach-human-rights-human-rights-impact-mount-polley-mines-disaster-british-columbia