There are companies, consultants and regulators around the world that have a high level of commitment to tailings dam safety and have developed practices which have been instrumental in ensuring the safe operation of tailings dams by many companies in many countries. Their experience should be taken advantage of in striving to further improve industry’s performance through the development of a comprehensive Tailings Responsibility Code that will establish well defined standards of practice, provide detailed audit protocols and require third party audits, all of which should be made available to stakeholders in a transparent manner. Henry Brehaut Key Note Address Tailings& Mine Waste 2017 Banff Nov5-8 2017
Though there was too much industry control when the then existing UNEP Metals & Mining division created the cyanide code to address public alarm at the frequency and consequence of cyanide heap leach failures and head off outright cyanide bans, I do believe that a mutually informed all stakeholders code in local/national law that does as the Mt Polley Panel advised and UNEP has endorsed to put safety first is the way to go. Global organizations need some uniformity in code and regulation to function.
The legal model that works best for that is the universally familiar “buildings code” model under a separate enforcement and oversight structure. That is what Tailings Management needs..not just for tailings dams but for all means of deposition. That model works through a legally established building code with checks and balances in its governance and enforcement structure.
Through buildings codes and professionally staffed Buildings Departments urban areas have accommodated ever higher buildings and ever more creative engineering designs for high rises that provide for innovation and advancement and a means of always being in tune with innovation & advancement through code revisions and the statutorily provided process for that.
The Buildings Codes/Building Department model forces accountability to best practice, to the costs of managing tailings to best practice and to a means of insuring that best practice keeps pace with innovation and new research .
The Buildings Code/Buildings Department model also works for investors, insurers , sureties and lenders as it provides a built in “underwriting” process where competence and ongoing professional development of all inspectors and each key position is defined in law.
I recently heard from a research team looking at how to reorient taxation for mines to better capture revenue and fund capacity focused on the public liability center of mining..its waste management practices.
Together these two shifts in public policy would more or less cure the loss prevention dilemma built into almost all the legal code for mining world wide.
The big question, is where is the professional capacity to make this work. ? Does it actually exist presently within top producing companies with major international tailings portfolios, let alone regionally resident in adequate numbers relative to the size of existing and planned tailings facility portfolios?
Jack Cadwell has written that even among the top 40 there are too few qualified tailings management engineers to cover a given company’s global portfolio of tailings facilities and that many, like BHP as of Samarco, have none at all relying completely on consultants . In the long dry time prior the supercycle professional competence was stripped to bare bones everywhere. As we lay out piece by piece in our new paper the industry globally gave us all time highs in consequence by rushing to maximum production from this bare bones place.
I wonder in the agenda or in lunch discussions there at Tailings 2017 whether there is any actual realization of this massive gap in technical competence or any plans afoot on how to build it? Is anyone talking about how to build professional development and competence to enforce and oversee an international tailings code?
For Immediate Release January 24, 2024 Lindsay Newland Bowker on Behalf of World Mine Tailings Failures compiler@worldminetailingsfailures.org
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The absence of unified risk centered or even basic descriptive national inventories of active, inactive and abandoned TSF’s seriously hampers an accurate description of actual risk level in the present world inventory. As all our published predictions since 2014 have proven accurate, we have confidence in our current prediction of 13 catastrophic failures 2025-2029. We also have confidence despite the fragmented authentication of economic consequence of all post-2000 failures that these 13 failures will have a cumulative cost of $US32.5 bn, $US2.5 bn per catastrophe inclusive of public liabilities, stranded debt, lost stock value, court ordered payments and other adjudicated third-party losses. This is without assigning any economic value to loss of public water supply or impairments to subsistence or commercial crops and harvest or loss essential natural habitat.
We have confidence that risk can be resolved or potential failure consequence substantially mitigated at an average cost of about $80M per facility based on a present program in Brazil which confirmed our own previously published estimate based on TSF closure costs. The cost to de risk 13 at risk TSF’s is estimated at $US1.04 bn. We could find no ready-made stat on the average value of world mineral production. World Mining Data puts the world volume of production 2018 at 18bn mt and the world value of that production at $US4,490bn, $249/mt.
At the level of the operator, operator investors and host communities who will absorb the entire physical brunt of preventable flow failure the loss will be devastating and non- remediable. In relation to the total value of world mineral production de risking represents a need that is only 0.04% of total mineral production value for the 5 years, only $US0.01/metric tonne.
The economics of de risking are obvious and compelling and there is technology to de risk every facility with a present risk capable of escalating to catastrophic failure even if the failure itself cannot be averted.
The Global Tailings Standard and the excellent practice manual just released by ICMM and based on Dr. Morgenstern’s 2018 de Mello Lecture do not though directly recognize or take account of the nature and scale of TSF portfolio risk worldwide. The year-long Global Tailings Review never attempted a worldwide estimate of total present TSF inventory or an assessment of TSF failure risk within their own holdings as WMTF had strongly encouraged. As a result, there is no context for assessing whether and at what rate the “one by one” approach they have advocated will actually facilitate risk identification and reduce failure rates.
WMTF estimates that 1/3 of every large portfolio and 1/3 of the world portfolio has unidentified actual risk conditions that require intervention to assure safe continued use to closure. 55% of world tailings are in engineered containments which owner/operators rate as high loss potential.(see chart below)
The possibility of actually de risking the existing portfolio is specifically dismissed in a main geotechnical paper guiding the final “Global Standard”.
“Change is more likely to be achieved in new mining projects than existing operations. Hence, change in tailings management for the industry as a whole will necessarily be generational.”
Without an external impetus to actually identify all high hazard potential facilities and assure present stability, as the Global Tailings review could have done, it is obvious that the slow pace of even identifying actually at-risk facilities can only result in an escalated rate of catastrophic tailings failure which presently stands at 0.10/bn mt of production 2000-2021.The absence of supporting Government mandates for a regularly updated risk centered inventory of all TSFs at all licensed mines further impedes risk assessment in the world inventory.
We have done our stats on the present universe of disclosures, including the COE, which all together, represent only about 10% of the world portfolio. We have hazard potential data only for 7.6% of the world portfolio which does not support adequate identification of possibly at risk facilities.
Applying the estimates of world distribution from these few inventories to authoritative data on world mineral production, WMTF estimates that 267-326bn m3 , 50% to 60% of all existing depositions worldwide, are in high hazard potential facilities.
We know that 27% of the world portfolio has already formed risk that could evolve to failure but without risk centered TSF inventories we cannot identify which are most urgently at need of de- risking to prevent catastrophic failure.
The Global Tailings review institute is not the path to a meaningful world inventory nor are they the appropriate custodians for it.
ICOLD is finally recognizing that tailings dams have nothing in common with water dams and that their present list of registered large TSF’s is pitifully shy of the true count. They are presently trying to develop a tailings specific world inventory and already have a risk centered design for that. But without government doing its job and requiring risk centered inventories of all licensed mines they are running into the same problems Lindsay Newland Bowker and Paulina Concha Larrauri ran into in their separate efforts to create a world TSF inventory. Literally at the stroke of a pen every mining nation, requiring annual disclsoure of all tailings facilities and citing the ICOLD risk centered layout as the standard for elements and definitions, could change that.
The Global Tailings Standards will not effectively or efficiently identify at risk facilities in time to prevent failure.
Lindsay Newland Bowker for World Mine Tailings Failures
Lindsay Newland Bowker for World Mine Tailings Failures, Stonington Maine February 3, 2022 compiler@worldminetailingsfailures.org ( several revisions latest 2/7/2022)
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“. Given the large degree of uncertainty around the impacts of this practice on a wide range of ecological communities, coupled with the high connectivity of both deep- water and pelagic environments, it is imperative that participating countries, the global scientific community, and managing entities act urgently to bridge these knowledge gaps, improve management practices, and take a more precautionary approach to the implementation of STP and DSTP(sic). ” Morello et al
Here we use DSTD “Deep Sea Tailings Disposal” rather “Deep Sea Tailings Placement” which makes a tailings management process that has had 7 failures since 1997 alone seem more benign than it is.
An undetected near shore underwater break in a pipe delivering tailings at Simberi mine to deeper claimed safe depth is the 7th documented actual DEEP SEA TAILINGS DISPOSAL failure (DSTD) at the 16 known sites worldwide since 1997. One occurred at Misima in 1997 and another in Indonesia , due to use of faulty materials, ” freed significant quantities of tailings in shallow water” (Yosbanis et al 2019) . Four other 2019 incidents at Ramu Nickel Mine were from the mix tank on the shore where raw tailings slurry is treated before the deep water discharge.. Only one of these incidents has an estimated release volume ( 200,000 litres) so WMTF cannot classify by severity but neither did we classify any as “minor”.
The images below are from the SVQ ( Alex Mojong) fact sheet on the Ramu mine spills. Figure 1 shows the plume from one of the spills. Figure 2 diagrams the entire DSTD process at Ramu and explains the effects.
FIGURE 1 Plumes from Ramu mix tank spills
Figure 2 The Ramu DSTD process from Tailings Generation to Sub Surface Deposition
An EIA by Alex Mojong commissioned by the Madang government on two other DSTD facilities Lihir and Misima , did document extensive degradation over a much wider area of sea bed than assumed and promised. Evidence is clear that DSTD as authorized in PNG law is neither safe nor possible to keep within territorial waters.
A review of several existing licensed DSTD operations in PNGshows that it does not perform at depth as claimed, that it does spread as far as 20km and that areas with a depth of deposition are virtual dead zones. Other aspects of this study challenge the claims of safety attending PNG’s approval of its use and its specific representations about the behavior of the tailings deposited at the edge of “the abyssal plain”.
“Mining that does not contain and control mine waste and its environmental toxicity simply cannot be considered responsible, let alone meeting best practice standards. This includes Riverine Tailings Disposal, Submarine Tailings Disposal, and the currently proposed Deep Seabed Mining processes ” Catherine Coumans .
“Mean densities of total metazoan meiofauna were significantly higher (α = 0.05) at reference stations in both the 800–850 m and 1715–1750 m depth zones than at the corresponding stations in the tailings “footprint” (Fig. 3a) (Mann-Whitney U-test L1 ≠ L4, U = 28.0, P = 0.0058; L2 ≠ L5, U = 15.0, P = 0.0358). At 2020 m, numbers at tailings and reference stations were not significantly different (Mann-Whitney U-test L3 ≠ L6, U = 25.0, P = 0.1098). Meiofaunal composition differed consistently across the depth range, with harpacticoid copepods accounting for 70–98% of individuals at L1-L3 versus 40–51% at L4-L6 (Supplementary Table S3). Nematodes showed the converse pattern of higher relative abundance (40–53%) at reference stations. The difference between pooled tailings and reference stations was highly statistically significant (Mann-Whitney U-test for percentage Copepoda, Tailings ≠ Reference, U = 349.5, P = 0.0025).”
The Following Excerpted from Dr. Alex Morong’s EIA for the Madang Provincial Government
“Deep-Sea Tailings Placement (DSTP) (sic) from terrestrial mines is one of several large-scale industrial activities now taking place in the deep sea. The scale and persistence of its impacts on seabed biota are unknown. We sampled around the Lihir and Misima island mines in Papua New Guinea to measure the impacts of ongoing DSTP and assess the state of benthic infaunal communities after its conclusion. At Lihir, where DSTP(sic) has operated continuously since 1996, abundance of sediment infauna was substantially reduced across the sampled depth range (800–2020 m), accompanied by changes in higher-taxon community structure, in comparison with unimpacted reference stations. At Misima, where DSTP(sic) took place for 15 years, ending in 2004, effects on community composition persisted 3.5 years after its conclusion. Active tailings deposition has severe impacts on deep-sea infaunal communities and these impacts are detectable at a coarse level of taxonomic resolution.” (emphasis added)
” It is currently used in Indonesia, Papua New Guinea (PNG) and on the Turkish Black Sea at mines which meet the necessary conditions of access to deep (>1000 m) water via a steep (>120) continental or island slope and is being considered as a disposal option at several new or projected mines in south-east Asia and the western Pacific10. The practice is highly controversial, with many local communities and non-governmental organisations voicing concerns about potential environmental impacts”
“There are no published data for trace metal content in tailings-affected sediments off Lihir, but dispersal models ground-truthed by sediment sampling indicate a depositional “footprint” extending across a broad plain up to 20 km east of the outfall and to depths of at least 2000 m19. “(emasis added)
“The gold/silver mine on Misima Island discharged a total of ~90 Mt tailings from 1989 until the end of operations in May 2004. The outfall was located at 112 m depth on a very steep (>450) submarine slope leading into the 1500 m deep Bwagaoia Basin (Fig. 1c). Seismic profiling indicates a tailings layer tens of metres thick in places and covering approximately 20 km2 of the basin floor20. Unlike Lihir, the main deposition zone at Misima is confined by seafloor topography but this does not exclude the possibility of wider dispersal by resuspension. No information is available on trace metal content of the tailings discharged at Misima.”
The Global Tailings Review, formed by ICMM with invited partnership with UNEP and Principles For Responsible investment (PRI), represented by the Church of England Pensions Fund ,took all consideration of marine deposition off the table before it invited and seated the “Independent Advisory Panel”. At the time there was decades of sound science, especially in DSTD, documenting its harm through analysis of existing sites in Canada and Norway.
No explanation was given, Just a naked short announcement by Adam Mathews on behalf of the partners. At the time, although this study ands its documentation of spread of DSTD tailings to range capable of exceeding territorial limits had been undertaken but was not widely known or cited. PNG had already enacted a law allowing DSTD and 16 mining operations world wide were already using it including in the Philippines, Norway,Turkey and France.
In light of the DSTD failure at Simberi and the documentation of how such depositions behave over time, World Mine Tailings Failures has shared this report with UNEP and called on them to at least address and assess the spread or deposition of any mine wastes into international waters
“According to what it is established on protocols and international treaties for protecting the marine environment and the research developed about the impacts caused; the DSTP(sic) should be avoided unless very strict guarantees are given that it will not cause any damages to the environment.” Conclusion Yosbanis et al. 2019
Text of WMTFs Letter UNEP, below
“This documents spread of accumulated and licensed depositions of tailings from various PNG mine operations into the international zone and the absence of all life where these depositions are thick and in more or less permanent suspension.
It is hard to understand how UNEP in its leadership role on the Global Tailings Review could have sanctioned the Global Tailing Review decision to exclude any consideration of marine depositions even before the advisory panel was selected and seated. If it was viewed as a sovereignty issue this scientific documentation shows that is not the case, that tailings and their effects are not being contained within PNGs territorial waters.
I am not clear on UNEP’s ongoing role in the COE “enforcement”/monitoring initiative but I hope as a key member of the original GTR UNEP will speak now. At least to PNG. Publicly
I don’t see the COE/ICMM process and its ongoing “advisory panel” as a meaningful path to the law and policy changes needed to check a tailings waste management problem that is growing in frequency and severity world wide but I hope UNEP’s voice still counts and that UNEP has the funding and support to speak with force for change.
DSTD is a proven trojan horse with inevitable and uncontrollable adverse effects on within and beyond national territorial waters.
With all good wishes,
L”
Evolving from the 17h C the concept of “territorial” waters has generally upheld the principle of “commons” except to assign rights to nations for purposes of military defense and fishing rights. 12nm is the generally recognized limit of “territorial waters” Extending this ancient law to include waste depositions of any kind or even activities within territorial waters which affect the world’s fishery, the life generating , life supporting functions of the worlds oceans is in and of itself a violation of the limits of national sovereignty. Estuaries especially are cradles of life for species and the food they require for peoples of many nations. Marine species in general have a much narrower tolerance to pollution and sedimentation than humans.
The 1982 adoption of EEZ, Exclusive Economic zones, extends exclusive right out to a limit of 200 miles from the 12 mile territorial for use exploration ( including subsurface of the ocean s floor. Waste dumping is unambiguously not a contemplated or included “economic use” of the EEZ.
The act of disposing of tailings wastes into any pathway to the ocean or into the ocean itself whether in the shallows as in STD or in the deep sea as in DSTD the supposedly violates the core mandates of the 1995 accords which affirm the obligation of every nation to protect the world’s oceans. In the preface to the 2013 report he was commissioned to do on mining wastes Craig Vogt summarizes the agreed commitment as follows.
“The UNEP Global Programme of Action for the Protection of the Marine Environment from Land-based Activities (GPA) was adopted by the international community in 1995 and aims at preventing the degradation of the marine environment from land-based activities by facilitating the realization of the duty of States to preserve and protect the marine environment. (emphasis added) It is unique in that it is the only global initiative directly addressing the connectivity between terrestrial, freshwater, coastal and marine ecosystems. The GPA targets major threats to the health, productivity and biodiversity of the marine and coastal environment resulting from human activities on land and proposes an integrated, multisectoral approach based on commitment to action at local, national, regional and global levels.“
Emphasizing that the scale of the work he was commssioned to do did not permit a sufficient examination of unanswered questions,
“Marine disposal smothers everything in its footprint, with associated loss of habitat and benthic life in that footprint. This reduces the species composition/abundance and biodiversity. In addition, risks to humans can be increased from bio accumulation of metals through food webs and ultimately to fish-consuming communities. The question is: is the size of the footprint acceptable and do the impacts reach beyond the intended footprint? Are there currents that move plumes of the material to adjacent marine habitats? Does periodic upwelling bring the contaminants to the shallow water fisheries and habitats?”
These questions were not further explored when The Global Tailings Review, without any public dissent by UNEP, took all consideration of marine dispoal off the table before the expert independent panel was seated.
The global map above of the EEZ shows that its application overlain on the foundational commitment of the GPA creates a large area of sea around southern ocean nations where the drift from DSTD is potentially cumulative given undersea currents and variations in depth and topography of the deposition areas. Further, the few data points on the 7 DSTD failures since 1997 show that the failures of DSTD include on shore and shallow shore un licensed discharges from pipe and other process elements.
The following chart from Craig Vogt’s 2013 report for GPA ( op cit) underscores this collective and possible cumulative effect of Government and operator decsions justifying the use of marine disposal.
This chart does not include Misima or Ramu nor Newmont’s second DSTD operation in Indonesia.( one failure occurred at one of these two Newmont sites)
YT John Kwong et al. ( 2019) offer the reassurance that few operating mines are actively using DSTD, likelihood of proliferation limited by bathrythmic patterns around mining countries.
Their conclusion and their bibliography does not make reference to the data on biota impacts, dispersion at a range greater than the territorial limit documented above or the known drastically higher frequency of DSTD failures. Nor does it consider cumulative effects given the relative proximity southern ocean nations who are the main users of marine deposition of mine wastes in all forms.
This team of scientists does though each the same conclusions all other other teams have independently reached on DSTD.
“Although DSTP (sic)could be locally practical, it has poorly defined environmental impacts. Whether on-land storage or deep-sea placement is preferred for tailings disposal depends on the local settings. Overall, global impacts of DSTP (sic)with respect to sediment load to the ocean are relatively small compared with riverine discharges of sediments by anthropogenic activities. Ultimately, national and local laws dictate whether DSTP (sic)is a waste disposal option worthy of consideration or not.”
Vare et. al Scientific Considerations for the Assessment and Management of Mine Tailings Disposal in the Deep SeaFront. Mar. Sci., 05 February 2018 | https://doi.org/10.3389/fmars.2018.00017
“DSTD can impact ocean ecosystems in addition to other sources of stress, such as from fishing, pollution, energy extraction, tourism, eutrophication, climate change and, potentially in the future, from deep-seabed mining. Environmental management of DSTD may be most effective when placed in a broader context, drawing expertise, data and lessons from multiple sectors (academia, government, society, industry, and regulators) and engaging with international deep-ocean observing programs, databases and stewardship consortia”.
WMTF agrees with this call for deeper more scientifically informed assessment of impacts from the allowed marine mine waste disposal practices of all nations. We agree with NGO’s who conclude that all marine dumping of mine wastes is harmful and not responsible because it contravenes and is not based on actual science. We do not agree with bans and prohibitions not based on clear science but neither do we endorse Government policy or industry practice that avoids best science and best knowledge. Our call is for a deeper study of the actual condition of sea waters informed by an independent panel of the lead authors of the works we cite here (rather than operators and their lobbyists and consultants).
Almost all of the still economically and governmentally evolving nations from which the overwhelming majority of catastrophic tailings failures have arisen since 2000 have populations faced in general with both food security and water security. Governments and corporations seeking reliable sources of essential minerals have a primary non delegable responsibility for accountability to food and water security.
Some of the best science we have on long term impacts of DSTD was commissioned by a tiny provincial Government, Madang, concerned about what people were experiencing. The assessment all these scientists have independently called for is doable. It needs only a commitment and funding which should be provided by the present operators and those proposing new or expanded DSTD operations leaving the assessment to an independent panel of the scientists whose work we present here.
Since 2015,then for Bowker Associates Science & Research In The Public Interest, and as announced as a main conclusion of our message has been clear that the public liability part of catastrophic TSF failures is uninsurable and unfundable. All the work we have done since, now mainly through World Mine Tailings Failures (WMTF), just affirms and further explains why that is. The latest details on Imperial metals $250 million insurance denial and now these details Mining.com has given us on Vale’s $5 billion anticipated and paid out on Samarco and Brumadinho adds flesh to those bones.
Brumadinho Aftermath
Public liability includes both loss or damage to property of others (including public infrastrcture) and bodily injury or death to people, Trying to recover through law suits which imagine deep and unlimited revenue in the coffers of mine opertaors also has to thread the needle of how operator liability is defined in law. Almost without exception “polluter pays” is not , and cannot be, what governs licensing and operation when it comes to what WMTF defines as a “catastrophic failures”.
“In addition, there are risks and hazards associated with the business of mineral exploration, development and mining, including environmental hazards, industrial accidents, unusual or unexpected formations, pressures, cave-ins, flooding and gold bullion, copper cathode or gold or copper concentrate losses (and the risk of inadequate insurance, or inability to obtain insurance, to cover these risks)” Barrick commenting n a recent acqisition in Tanzania.
The magnitude and frequency of catastrophic faiures, as defined by WMTF, post 2000 makes it very clear that the “average loss” of first party and public liability combined is muti $billions. Our estimate based on scant available data in 2014 was $540 million and many, mainly those who look only at physical impairments to continued operations and not more broadly to actual “publc liability”, challenged that as excessive and grossly overstated.
We now see that was in fact grossly under estimated even for losses then known and documented .
An ordinary construction company would insure both components of “public liability” through a commercial general liability policy. Business property , the mills, the TSF , the equipment, adminsitrative buildings would be covered through commercial property insurance (first party) including business interruption due to political risk, war, or property damage ocurring as an “act of god”, i.e not forseeable or prevenetale, beyond the insured’s control. The details of that recently became available on just the frst party ( business property) part of costs of a failure in the context of the Mt Polley $250M on the damage to the TSF itself. It ilustrates that even first party losses to the business property that keeps the mine producing and able to meet its obligations to lenders and shareholders,are not within the definition of “insurable loss”)
Not just the public has to eat the third party costs of tailings catatsrophes. The part that investors and lenders count on to insure their stake in the project is also uninsurable at the scale of catastrophic failure as defined by WMTF.
Sharehholder Reaction to Vales TSF Failures ( by Bill Williams)
Our prediction of 18 catastrophic failures for the current decade, 2015-2024 wil be easiy and within months exceeded. We have already documented 17.
More of the same disparate , conflicting and incomplete versions of “responsible mining” and correctve iterventions will not change that. It just gives a clear and wider path for all to keep moving in the same untenable direction by almost systematically avoiding the main drivers of catastrophic TSF failure.
It is a myth that recovery or remediation is possible afer a catastrophic failure at the level we define it at WMTF.
It has been our deeply informed advocacy that environmental and economic justice for already harmed and at risk host comunities resides not in “polluer pays”, not on “financial assurance” not in operator centered law suits , but in an all stakehoders cooperation in loss prevention.
The Global Tailings standard is not that.
The united NGO platform as expressed in Safety First is not that.
It has been and remains our finding that investors and lenders also face non recoverable non-insurabe losses at a significant level. Samarco eventually defaulted on its $3bn bond obligation when the business insurance limit was exhausted. Vale’s rating fell to “junk”.
There is no viable soucre on earth that can fund the actal public liabilty losses of catastrophic tailngs failures as they continue to occurr at ever increasing levels of magnitude.
Collectively we need to build an entirely new model of public private partnership to isnure an adequate and sustainable suppy of world minerals.
All stakeholders have to pull together and all governments have to do far more than they are doing now to pull in the same direction.
Each stakeholdeer sector has to bring its essntial expertise, economic and politcal power to bear toward the same goal of a reliable adequate green mineral supply .
That is not happening now.
But if we act now we can still achieve that by 2030.
We are not on that path now. 100% attainment of all the Global Standard principles by every single operator will not get us there.
Instant implementation of all that Safety First advocates will not get us there.
Lindsay Newland Bowker, Stonington Maine, January 25,2022
Lindsay Newland Bowker For World Mine Tailings Failures January 19,2022 compiler@www.worldminetailings failures.org Stonington Maine
Mt Polley TSF Failure 2014
A Judge has ruled in favor of Factory Mutual Insurance Company company who insured business interruption losses and business property damage losses on the 2014 catastrophic failure at Mt. Polley on a premium that cost Imperial $545k per year according to an article by Mike Casell, Stockwatch, released today.
Factory Mutual, a domestically regulated “regular” (not a captive) global insurance company and one of very few insurers who insure tailings facilities as business property, denied applicability of the $250M limit on “loss by earth movement”, (e.g. a landslide or earthquake or other natural phenomenon undermining a soundly formed responsibly managed structure and causing its loss or damage( my description not coverage language)). A $10 million limit for business interruption was upheld but with the insurers right to recover its outlay from Imperial’s successful suit of $109 M paid mainly by one of 3 engineering firms with roles under contrat to Imperial over the life of the TSF. All but a small amount was paid by Knight Piesold’s (KP) successor after KP resigned in frustration that Imperial was not following its guidance. The third firm was on duty for only a few months just before the failure after the conditions causing failure were well advanced. As an aside, important to note that the role of the firm held liable by the court in Imperial’s lawsuit against its engineers, was not primary to the underlying causes of failure but limited only to its advice on the stability of the deviation Imperial had already undertaken due to lack of non pag materials in its new pit. That change was already initiated and advanced by Imperial before KP’s successor took over the role. Two employees of that company most directly involved with Imperial have already been stripped of their right to practice in disciplinary hearings. A third venerable engineer who has made endless contributions to best knowledge and best practice is still pending a hearing on disciplinary charges but in my view, charges should have been dismissed long ago.
sketch of failure path
After Knight Piesold’s resignation in 2011, the issue was whether the upstream raises initiated by Imperial due to the unavailability of suitable materials to continue the original centerline design. The engineer whose hearing is still pending opined that continuing the modified design would complicate closure and its cost but could be continued without a substantially elevated risk. The unidentified lacustrine layer under a section of the tsf as originally designed would still have been there and perhaps still have brought down the dam if it had proceeded according to original plan, ( my analysis. not reviewed by any experts)
Ideally every operator should have sufficient insurance to cover the total replacement cost of its largest facility anywhere in the word due to earth movement by natural causes and as no total loss of a facility due to natural unforeseeable causes has so far occurred anywhere ( the knowledge existed in Chile about the vulnerability of upstream structures at the time of the earthquakes in the 60’s) it shuld be ofere at a reasonable premium. I would suggest that $545k was an excessive premium for a portfolio of only two TSFs ( Red Chris and Mt Polley) given the actual history of TSF failures worldwide exclusive of any third part liability coverage. (We know from Imperials own NI43 101 disclosures that it had been going bare on all third party liability insurance due to cost for some time prior to failure). Provided the facility at failure met the same conditions as apply to loss of other business property this insurance should be very cheap for any facility that is designed and operated in accordance with best practice and best knowledge. The risk of loss or damge is considerably higher than a large building of comparable construced volume but it is hard to believe a $545K annual remium was justifed.
Economically Mt Polley Was Always on Shaky Ground
World Mine Tailings Failures has established that the rate of catastrophic TSF failures since 2000 is.09 per bn metric tons of mineral production..and that is all “not by act of god”. I would like to see the premium rating work and loss experience that justified the premium charged to Imperial. Additionally, Canada is very highly rated both by this insurer and by the world bank as safe for investors and insurers.
Tuesday’s decision also came with one other piece of bad news for Imperial Metals. The judge ruled that Factory Mutual was entitled to share in the amounts that Imperial Metals recovers from third parties, such as the engineering firms. It is not clear what this amounts to in dollar figures, but presumably Factory Mutual will recover at least some of the money it paid out. ” ( Mike Cassell, Stockwatch” Market)
Thus, out of Imperials self reported $395M in losses only a max of $10 m is covered by insurance ( business interruption) and the insurer is entitled to receive $108 millin of that. reducing Imperials maximum recovery and resulting in an uninsured loss of $277 M.
Lindsay Newland Bowker For World Mine Tailings Failures, December 2,2021 email compiler@ worldminetailingsfailures.org ( Latest Revisions December 2 on earlier TSF Failure At Same Facility, December 3rd SNMPE Call for Peru to Stop Dragging Its Heels on Widespread Illegal Mining Operations,December 4 Extensive Organized Crime Influence In Peru’s Gold Mining);Revised December 11th with new stats on world mineral production 2000-2021 which show no improvement in the failure rate per bn mt of mineral production.
Part of the Encampment Surrounded By And Strewn With Its Own Long Accumulating Wastes
On November 26th heavy rains caused a field of possibly uncontained highly toxic, arsenic and cyanide tainted mine wastes to be washed down from the mountaintop site of a long established illegal artisinal mining encampment in Ananea Peru. La Rinconada has existed and grown over more than 20 years to a population now estimated by some to be as high as 30,000. Nothing grows or can grow there. The water is long too polluted for consumption so as with all large mine sites the surrounding community has also depended economically on the mine and its needs for water, food, clothing, services and equipment. Conditions at the camp, where workers have no salary but one day a month can take home the ore they harvest, are as bad if not worse than the worst slave and forced labor mines of yesteryear and now. If this mine were operated by an established licensed operator there would be outrage wordwide and a UN Special Rapporteur might be appointed. But until last Monday, the miners and the surrorunding community have resisted any outside interference, including by local and national government. We have no information as yet on the identity or financial capacity of the illegal owner/operator but it seems unlikely they have deep pockets or reachable resources to fix any part of this now recognized huge problem.
According to the Global Initiative Against Transnational Organized Crime almost 1/3 of Peru’s Gold Trade, 60M tonnes, is under control of organized crime.
“According to a report by the Global Initiative Against Transnational Organised Crime, almost a third of Peru’s gold production – some 60 tonnes – is sourced and sold illegally. The value to criminal ventures in the country is thought to be around 2.6 billion US dollars.
Yet some of the most pernicious side effects of this booming trade affect the lives of women in Rinconada and the formerly pristine mountain environment around the city and Lake Titicaca. Woman and girls as young as 12 are brought into La Rinconada to work in the city’s brothels and around 7 tonnes of mercury and cyanide are used each year to process the gold, much of which is dumped in the Rio Ramis which drains into Lake Titicaca on the Peru – Bolivia border. Here it causes extensive damage to natural habitats in and around the lake and threatens the existence of around 3,000 Uru indigenous people who live on floating homes made out of reeds and navigate the lake on reed canoes.”(https://www.rt.com/op-ed/454486-la-rinconada-hell-mining-peru/)
A spokeperson for the mine has said it was not tailings only mud weakened by heavy rains
:”The person in charge of Immediate Attention of Emergency of the Company, of the Cooperativa Minera San Antonio, Pedro Candia Rojas, clarified that the collapse of one of its wells, on Friday, was not mining tailings, but sludge.
According to the representative of the cooperative, the Directorate of Energy and Mines verified the fact, so the population of Ananea should not worry.”
This photo accompanied the article
WMTF is still treating it as a tailings failure based on other documentaion about the mine and the failure event.
Dramatic video and local press story available..13 MB. More details to follow as information becomes available. We will post the revision date in the contact line..
We have also added a second “very serious” tailings flow failure in 2019 to the failures data base. That failure resulted in 1 death and 9 injuries . We are treating the current incident as #2 as it is from the same containment or non containment system.
We don’t have details on the tailings management system at the mine.
Recognizing the human,environmental and reputational risks for Peru ,the National Society of Mining, Oil and Energy (SNMPE) has reaffirmed its long standing call for illimination of the criminally controlled mining sector in Peru.”The collapse of a tailings dam in the hands of cooperatives dedicated to small-scale mining activities, which would have links with organizations that are dedicated to the illegal extraction of minerals, is a very serious consequence of the uncontrolled advance of informal mining in Puno and other regions of the country. warned the National Society of Mining, Oil and Energy (SNMPE), after urging the Government not to lower its guard against the uncontrolled expansion of informal mining, present in more than 13 regions of Peru.”
“Informal and illegal mining are activities that clearly destroy ecosystems and generate serious social, environmental and economic problems; however, to date, our authorities do not show signs of having designed an articulated strategy to formalize them or, failing that, to eradicate them, ” said the SNMPE. The mining and energy union demands that the corresponding authorities initiate an exhaustive investigation into the collapse of the tailings dam that occurred on Friday, November 26, which is located in Ananea, San Antonio de Putina province – Puno”
Energiminas (info@prensagrupo.com) December 3,2021
The two incidents bring the count to 14 of 18 expected catastrophic failures for this decade 2015-2024.
Peru is on WMTF’s High risk profile list of nations along with Brazil, Angola, Kazakhstan, Kyrgyzstan, Congo, Philippines, PNG, Mexico, Myanmar, India, Poland and Serbia. All but 2 of 13 documented catastrophic failures since 2015 have been in these nations. Many Like Stolice, Serbia ( 2014) funded by IFC. We expect that the overwhelming majority of catastrophic failures will also be in these nations most of which have actuarially very high ratios of catastrophic failures to mineral production.
Our published prediction of 13 catastrophic failures actually realized 14 for the decade 2010-2019. Many Like Stolice, Serbia ( 2014) funded by IFC.
Our about to be released report shows tha the failure rate per billion metric tons of ore production has been constant at 0.11 from 2000 to now.
While singly and severally the many TSF and mining reform interventions since 2000 including the creation of ICMM in 2001,the ICOLD UNEP review of tailings failures, and most recently theGlobal Tailings standard have not addressed, let alone committed to assessment and correction of stability issues in large existing facilities with a high potential risk profile, mostly old upstream tailings facilities, this continual focus on compromised host community security has highlighted and is bringing change often exceeding the Global Standard.
We are working our way through the enormous number of documents on the Ananea failure and will be assembling relevant background on the mine and facility with a bearing on the failure. A great deal is in Spanish and we would welcome volunteers to help translate or run translations on the data sources.
As always, we also welcome any technical reports, studies, images, first person narratives.
The narrative the SEC is acting on is the narrative pushed by the Wall Street Journal and NGO’s mostly out of a misunderstanding of the documents in the Brazil Prosecutors records. Principally, the WSJ reporters and the NGO’s didn’t understand that an extreme or high hazard potential is not the same as an extreme or high actual risk.
The dam’s extreme fragility was recognized and the work underway which, according to the new report by Gens and Arroyo, triggered the failure, was part of a stabilizng program that had already achieved small but measurable effects. It was not work undertaken with disregard for the risks of undertaking it.
Nonetheless, the SEC probe is an important step towards laying out what needs to be addressed so that the industry, with support from licensing Governments , investors and insurers, has room to reconfigure itself to better knowledge and better practice on TSF stability and to de risk what cannot be left as is.
Tractebel was fired by Washington Pirete for refusing to certify TSF stability. Pirete, was primary promoter and guardian of Vale’s wrong approach to dam stability assessment and statutorily mandated reporting, Pimenta de Avila before Tractebel had questioned Vale’s geotechnical protocols. Scott Olson as consultant had already told Vale that their Pirete based geotechnical program was an incorrect application of their methodology(based on Olson 2001) resulting in false conclusions.
That was all reaffirmed by Vale’s own in- house cause of failure report by one of the top geotechnical teams in the world.
Vale responded by stopping all depositions at the TSF and was engaged in a multi -year effort to de water and stabilize the facility for a planned major re mining of it.
Could the application of better stability analysis protocols such as those used in the Brazil Prosecutors recently released cause of failure report provided a better basis for decision making on what stabilizing procedures were safe to undertake?
Maybe, yes. That is a question for Gens and Arroyo.
Without question, a finite element run may have definitively identified the dam as hovering on the very edge of failure despite the small signs of progress. Use of finite element analysis as used by Gens and Arroyo after the fact, may have resulted in a shift to first make down stream communities and the hundreds of employees using the administrative building safe before proceeding with further de risking, further stabilization.
Many, many active and abandoned TSF’s all over the world with poor hydraulics are recurringly re-saturated and reside in a vulnerable state of saturation with extreme susceptibility to flow failure until the saturation slowly dissipates. During that time of extreme saturation a very small change exerting very minor stresses or vibrations can set off a flow failure as happened at Brumadinho.
According to the Brazil Prosecutor report by renowned liquefaction experts Gens and Arroyo, the measures Vale was undertaking under TUV SUD’s direction urging extreme caution were beginning to move toward an improved stability condition.
It was just too late.
To move past this present world portfolio wide crisis of too may old upstream dams with poor hydraulics we don’t need law suits we need solutions..workable strategies for managing TSFs which become super saturated We need tools, data and strategies for recognizing when its important to shift to accelerated downstream protections and when it is safe and in what form de risking can be initiated.
Vale is middle of the pack per the Responsible Mining Foundation’s score on responsible mining practices. That is the reality we must all come around to working on together.
Burning Vale at the stake as some sort of aberrant lone bad actor is not going to make the world portfolio of TSF’s any safer and it’s not going to protect those host communities now downstream from dozens of equally vulnerable large dams world wide in a state as vulnerable as Brumadinho was.
The “Global Standard” made a huge huge mistake in not making identification of existing at risk dams and their de-risking a top prioritiy.
There is no such thing as recovery from a catastrophic TSF failure lacking downstream protections , diversions and berms.
No amount of money can make a TSF failure inundated area “clean” for viable life-supporting future use.
We can though afford loss prevention but parking it all at the door of mine operators is not the answer.
Present risk was co-created by investors, insurers, lenders, and most of all governments who chose revenue and jobs over host community security and are still making that choice every day..look at Zelazny Most . Look at Kumtor. Look at the Philippines.
The CIMNE report is not related to the decision to start over on the case against Vale’s former President Fabi Schwarzman and 15 others indicted under criminal charges in connection with the Brumadinho failure. That decision , which did, though, respond to a suit brought by Schwarzman, was not on any merits under Brazilian law. The Federal Prosector ruled only that it was not properly filed in Minas Gerais state court and needs to be refiled in federal court. Though not specifcally clarified, presumably all evidence and testimony material to Brazilian law would be preserved and brought into the case in Federal court.
The CIMNE report, co-authored by two of the world’s leading experts in liquefaction, Antonio Gens and Marcos Arroyo, both of UPC, adds to, rather than contradicts or alters the prior two expert panel reports on the cause of the January 25, 2019 failure of Dam 1, Brumadinho.
The work illustrates the use of a more informative and sensitive stability assessment, finite element, that may have, saved lives if used at Brumadiho, as TUV SUD had suggested in their 2017 report to Vale. The frail status of the Brumadinho dam was well understood going back to before the 2016 decision to stop depositions and focus on dewatering in an effort to get the dam in shape for safe execution of a planned re mining that Vale and Minas Gerais were counting on for a 20 year extension of local jobs.
Plaxis 2D, a finite element modeling tool was used by Gens and Arroyo to show that a drill operation all thought was safe actually triggered the failure. Applying the model to all known about the tailings stack and its history exactly replicated the failure and its sequences. In its 2017 report to Vale TUV SUD using the more prevalent limit equilibrium model also got a very low factor of safety for the modeling condition”unknown trigger”.
While the authors did not assert that that model could have been applied to rule out that drilling operation, they do say, and other experts in liquefaction agree, that a liquefaction susceptible stack should be evaluated by finite element analysis which better models flow dynamics and would have given a much lower factor of safety result than the undrained limit equilibrium more commonly still used.
The authors emphasize in their conclusion how risky it can be to attempt de risking , as had been ongoing at Brumadinho for three years prior to failure, without very complete and accurate data on the whole stack especially when conditions have reached the point they were at Brumadinho. Had a finite element analysis been undertaken much earlier the condition of the stack would have been better understood and perhaps different decisions made both in evaluating the feasibilty of the planned re-mining operation and about the ongoing use of the canteen and adminsitration building where most deaths occurred.
Their modeling work reaffirmed the December 12, 2019 expert panel finding that the failure emanated from the crest with a force that caused the break in the containmnet wall. ( Previously some had opinded that a lower portion of the TSF had failed triggering the flow failure.)
“It seemed likely from the first descriptions and images of the Córrego do Feijão Dam I failure that the cause was static liquefaction, a transformation of the nature of the tailings resulting from over saturation that makes them perform more like water than soil, causing a greater force that propels released tailings much farther than the same volume of compacted tailings would travel in a foundation failure. Initially some experts viewing the video of the actual event opined that, while a liquefaction event clearly occurred, it was not clear whether it followed from or caused the failure. The lower part of the dam had been previously identified as key to overall stability and also a place of vulnerability. The expert panel report released December 12, 2019 confirms that static liquefaction occurred at the crest and was the cause of failure of the outer shell. Static liquefaction was under active consideration by Vale and its engineers in 2017 and 2018 .
“Fundão, Stava, Merriespruitt, Los Frailes, Sullivan Mine and Pinto Valley are a few well-known examples of static liquefaction failures in history. At Merriespruitt, as at Fundao and Brumadinho stability analysis per prevailing methods found the dams safe. That prevailing practice is not, however, best practice/best knowledge is a subject of growing interest and concern that has evolved over at least two decades. It has forced a re-evaluation of what was taught in mining schools and has been best knowledge for a large part of the worldwide community of dedicated mining engineers. It is not now a major focus of education and apprenticeship as the world’s future engineers set to work. A great deal of knowledge has been advanced by Roberto Rodríguez Pacheco, by revered engineers such as our colleague Andrew Fourie , by the venerable Mike Davies and Todd Martin, and by Norbert Morgenstern among many others.
Their insights and urgings have not found their way into government regulations on stability and are not shaping main practice or even main stream discussion. It is just not part of the thought and decision making that has shaped the world’s existing portfolio of some 29,000-35,000 TSFs (Tailings Storage Facilities) and those that are planned to receive the world’s mineral production this decade.”
The CIMNE report is narrowly focused on the “proximate cause” of failure and in no way supercedes, replaces or contradicts the broader more comprehensive failure cause consideration of the prior two reports. It is in these two earlier reports that we are instructed on how and why failure conditions form and grow unnoticed and not fully understood until is too late for “loss prevention” or intervention to de risk as it was at Brumadinho. .
FINITE ELEMENT MODELLING CONFIRMS DRILLING OPERATION AS FAIlURE TRIGGER
The image below illustrates the location of a drilling operation which CIMNE cites as a likely trigger. WMTF’s website banner on the failure does not show this drilling operation but a longer video with higher resolution, possibly from a different camera, does clearly show the drilling operation.
According to the CIMNE report which cites the account of surviving contractors the holes being drilled were the deepest ever penetrating the stack.
LONG STANDING FRAGILITY OF STACK KNOWN
As Roberto Rodriguez’ pioneering work has established, TSF’s with poor hydrulaics, both active and inactive, have recurring saturation events over the life of the facility . The saturation, causing an exteme suceptibility to failure is quick to form and slow to subside but only in some cases does the susceptibility to flow side failure materialize.
All experts charged with cause of failure analysis and many others acknowledge that no trigger ( as trigger is generally understood) was needed to cause the failure at Brumadinho. All, back to even the Pirete thesis acknowledge that there certainly were many peculiarities and variations in the tailings stack and that it had a suceptibility to liquefaction. None question the extreme fragility of the stack not just in the months prior to failure but before the cessation of depositions.
Tractebel was fired (by Washington Pirete) for refusing to certify the TSF as stable. Vale commissioned TUV SUD to verify compliance with new Federal Law. TUV SUD was very clear in its assessment of the extreme fragility of the TSF and in their correct assertion that only undrained conditions was appropriate for stability assessment per limit qulibirum the most widely used sysem for stability assessment prior to the emergence of “Finite Element”on which Plaxis 2d is based.
Pimenta De Avila prior to TUV SUD and Tractebel questioned the required Vale geotechnical procedure which was premised on the Pirete thesis which according to Scott Olson misused his methodology(olson 2001) in concluding that the dam was strong enough to stand aganst a liquefaction flow failure event.
WMTF will note these exceptions to the report in our failure narrative unless anyone reading this in possession of recognized expertise advises that we have erred in our assessment of the CINME.
To briefly review the documentary evidence and background preceding release of CINME report, we offer the following.
Brazilian Law requires that the computation of factor of safety be based on the methodology appropriate to actual conditions. The methodology insisted on by Vale and imposed on all its consulting engineers was, according to the in house Vale review not appropriate. The methodology selected for stability assessment should be specific to the issue at hand and actual conditions, especially drained or undrained.
The dewatering needed to safely allow re-mining was progressing far more slowly than anticipated. There was no known drainage system in the original few raises and the inhouse expert panel reprt noted that an initial error in location of the toe of the dam had blocked a creek which had previously directed groundwater flow further impairing effective hydarulics of the structure. The slower than expected rate of dewatering was noted by both consulting and in-house project members .The record is clear that there was concern that the schedule for the planned re-mining of the tailings would be compromised possibly jeopardizing viability of the remining project.
Vale, TUV SUD and Minas Gerais were counting on 20 more years of jobs in re-mining the tailings which had a never explained extraordinary level of iron. (I am recalling 47%-55%). They couldn’t begin because the dam was not stable enough to withstand the vibration of the heavy construction involved in removal of the deposited contents.
Under Brazilian Law a version of absolute liability applies. It is not a negligence or tort based legal system. There is no defense. That Board members and senior executives chose not to monitor stability does not alter their culpability under Brazilian Law at failure.
Brazilian Law requires that the computation of factor of safety be based on the methodology appropriate to actual conditions. The methodology insisted on by Vale and imposed on all its consulting engineers for statutorily required reports to government was, according to the in house Vale Expert panel review, not appropriate. The methodology selected for stability assessment should be specific to the issue at hand. The Vale in-house report notes that methods appropriate for assessment of a planned raise are not the same as those appropriate for overall stability assessment of the entire structure. Further the methodology for factor of safety must reflect actual conditions, especially whether the stack is in a drained or undrained state. As TUV SUD pointed out in their 2017 reort for Vale the law does not specifically set a factor of safety standard for TSF with a liquefaction susceptibility.
The dewatering was progessing much more slowly than expected perhaps because, as noted in the inhouse Board expert panel report, it was discovered that the toe of the dam was buil which impeded he natural flow thriug of groundwater. The rate of dewatering was noted as way below plans and expectations from the time depositions ceased to failure. The record is clear about concern that the schedule for the planned remining of the tailings would be compromised possibly jeopardizing project viability.
Vale, TUV SUD and Minas Gerais were counting on lots of jobs continuing in re mining the tailings which had a never explained extraordinary level of iron. (I am recalling 47%-55%). They couldn’t begin because the dam was not stable enough to withstand the vibration of the heavy construction involved due to the high water level and state of saturation.
. Under Brazilian Law a version of absolute liability applies. It is not a negligence or tort based legal system. There is no defense. That Board members and senior executives chose not to monitor stability does not alter their culpability under Brazilian Law at failure.
Vale’s Board and Senior Officers deferred completely to its geotechnical staff and neither asked for nor received any reports from the geotechnical team on the warnings of De Avila, Tractebel and Tuv Sud. By the same token, though, I don’t recall that VOGBR, De Avila, or Tractebel wrote to Vale’s Board or senior executives with their concerns.
For all that was wrong with initial vetting of the stack and its management under Vale, Vale was and is “middle of the pack” on how these ultra large older cross valley, side hill upstream tailings dams are managed. Hence my sense of urgency about identifying at risk facilities and placing their assessment under truly expert independent teams as buildings are under the independent authority of buildings inspectors.
Having a separate Prosecutors Office as Brazil has doesn’t quite accomplish the safety corrections that a buildings department does!
One would think, even pray, that $12 Trillion in invested institutional assets could produce more, leverage more, say more, put more in motion after two years of work, to de risk the world portfolio of 29,000 to 35,000 mostly ageing TSF facilities than their recently released “team report”. It’s pitiful bibliography citing the industry preferred poorly informed Azam Li 2010 as the only resource of actual tailings failure history says it all about COE’s beautifully illustrated report of findings.
There was plenty to harvest in the COE disclosures as calls for action for all the duplicates, errors, fuzziness like this very old upstream tailings facility.
The owner had already downplayed ( ducked public scrutiny) on one of the largest TSF failures in recorded history and is presently in non compliance with Canadian Dam Association Safety guidelines. “The team” just didn’t consider it worthy of note, or their data algorithms didn’t have a “hunt” on for exceptions that might indicate risk like “all old upstream TSF’s containing more than 100M cubic meters of tailings”.
The “COE Team” paper, published in Nature and released just this past week follows form with the insistent “interiority” of the portal and past statements on the discslosure. The COE team in general and Grid Arendal in particular, draws conclusions and makes statements as if the disclosures were verified fact about any whole portfolio let alone the world portfolio of TSF’s. It is only a set of survey responses full of duplicates, errors and fuzziness by mostly ICMM members. It is not representative of anything in particular and is only about 12% of the world portfolio by volume of depositions and 6% by number of facilities, biased toward the larger current world operators and to base metals ( ICMM members).
This approach to presenting the discsloures results in the most serious errors of presentation with respect to several statements made about upstream facilities and stability. ICMM, according to one of the major reporting operators ( Glencore???), as part of the disclosure, had advised all its members to include any inspection in answering the stability questions. Stability cannot be ascertained/assured except by stability analysis by competent folk using the correct parameters and methods. Most often, this analysis isn’t undertaken at all even for very large facilities or multi $billion expansions. Where it is undertaken the wrong methods or parameters are used resulting in the wrong conclusions according to the actual texts of the actual cause of failure reports by the world’s top experts.
It is important in everything to do with the COE disclosures to treat them not as “verified data” but as “representations” subject to verification reflecting how ICMM members wanted to present themselves to the world in a gesture of “transparency” that raised no alarms or concerns.
The procedures and algorithms GridArendal has presented with its sexy graphics since first release back n October 2020 are standard survey analysis procedures which should be applied to any survey to vet and interpret and summarize responses. It’s a standard descriptive stats process. They have not employed or sought to assess what the stats say about the state of the world portfolio and the implications of that state to communities, investors, insurers and creditors. That requires putting the responses in a context of world data on mineral production, failures, and what history can be independently verified about the described facilities.
The COE team and Grid Arendal have not done that work.
Their pitiful bibliography on the published paper suggests that the critical work of risk assessment and the truth of failure trends is systematically and intentionally avoided…..again. Seems to happen every time ICOLD, ICMM& UNEP team up to calm jitters arising from highly visible patterns of catastrophic tailings failures.
Apologies all for my customary typos ( never learned how to type and never needed to..always had a secretary and big clerical staff). Here cleaned up..for posterity and for any circulation it may enjoy, my prior email to Helen Reid ( Reuters) on the latest COE Team report.. I re-read the “COE Team” paper with particular attention to its “interiority”, of drawing conclusions and making statements as if the disclosures were verified fact about any whole portfolio let alone the world portfolio of TSF’s. It is only a set of survey responses full of duplicates, errors and fuzziness by mostly ICMM members. It is not representative of anything in particular and is only about 12% of the world portfolio by volume of depositions and 6% by number of facilities, biased toward the larger current world operators and to base metals ( ICMM members). This results in the most serious errors of presentation with respect to several statements made about upstream facilities and stability. ICMM, according to one of the major reporting operators ( Glencore???), as part of the disclosure, had advised all its members to include any inspection in answering the stability questions. Stability cannot be ascertained/assured except by stability analysis by competent folk using the correct parameters and methods. Most often, this analysis isn’t undertaken at all even for very large facilities or multi $billion expansions. Where it is undertaken the wrong methods or parameters are used resulting in the wrong conclusions according to the actual texts of the actual cause of failure reports by the world’s top experts. It is important in everything to do with the COE disclosures to treat them not as “verified data” but as “representations” subject to verification reflecting how ICMM members wanted to present themselves to the world in a gesture of “transparency” that raised no alarms or concerns. The procedures and algorithms GridArendal has presented with its sexy graphics since first release are standard survey analysis procedures which should be applied to any survey to vet and interpret and summarize responses. It’s a standard descriptive stats process. They have not employed or sought to assess what the stats say about the state of the world portfolio and the implications of that state to communities, investors, insurers and creditors. That requires putting the responses in a context of world data on mineral production, failures, and what history can be independently verified about the described facilities. The COE team and Grid Arendal have not done that work. Their pitiful bibliography on the published paper suggests that the critical work of risk assessment and the truth of failure trends is systematically and intentionally avoided…..again. Seems to happen every time ICOLD, ICMM& UNEP team up to calm jitters arising from highly visible patterns of catastrophic tailings failures. Following is text of an email from WMTF Executive Director Lindsay Newland Bowker, to Helen Reid Reuters commenting on on her article on the COE “team report”.It is reproduced here with permission of WMTF.
“We were glad to see the COE folk at least acknowledge that upstream TSF’s are a major component of the world TSF portfolio of 29,000 to 35,000 facilities worldwide and have been writing about that and presenting analysis of the details on that for some time. We have consistently copied all the COE folk, Elaine Baker and the Grid Arendal folk on our analysis of the COE data which we have placed in the context of the entire history of TSF failings ( which I compiled) and in the context of the entire world portfolio of national disclosures.
The “study” cited in your article does not really grasp the nature and scale of the risk within the world portfolio nor does it fully appreciate how deeply co-entangled upstream TSF’s are with World Mineral Production. We will be releasing our Tailings Portfolio Potential Risk (TPPR) index today or Monday which is a failings anchored method for rating potential risk in any facility or portfolio.
Notably, only upstream facilities scored “extreme” or “very high” potential risk and almost all of those were built prior to 2000. Of the 12,000 active TSFs in the entire world portfolio, 900-1000 have present depositions in excess of 100 Mm3. 270-280 of all active TSF’s are classifiable as “extreme potential risk” (index>60) or “very high (index 20-59). The COE survey responses on stability cannot be assumed to constitute stability assurance. ”
WMTF does not support the united NGO call for a ban on all upstream facilities but, at the same time, the Global Tailings Review(GTR) did not address or explore the issue of upstream dam safety adequately. It is an undeniable fact that upstream dams are a main repository of existing and planned depositions and that they have a higher failure potential than other form of tailings facility construction. They represent about 42% of world total portfolio but 68% of catastrophic failures.
COE survey participants, the world’s largest miners and mostly ICMM members, are planning an increase in volume in active upstream facilities from 24% of all current depositions in 2019 to to 29% of total volume by 2024. Planned utilization of upstream facilities for deposition of production tailings in the next 5 years will increase the proportion of depositions in high hazard potential upstream facilities from 92% to 95% .
The overall rate of expansion of depositions in the COE respondent portfolio of active upstream facilities, 79%, is nearly twice the planned overall five year expansion rate of tailings to all respondent facilities, 44%.
Very large upstream facilities with significant planned rates of expansion in the next 5 years include the following all but one of which is more than 20 years old.:
World wide, the expansion in all existing tailings will be 18% over the next 5 years for all mineral production. The overall COE respondent planned expansion in all active TSF’s is more than twice the world rate for all minerals.
This indicates both a higher potential risk profile for the active tailings portfolio of COE survey respondents and a much more aggressive overall planned production relative to world tailings portfolio and world mineral supply expansion rates. ( The COE respondent portfolio of TSF’s represents only about 12% of world tailings portfolio and world minerals production volume)
The average size of active upstream facilities reported by COE survey respondents is more than twice the world average size of all active facilities. As of 2025, COE respondents will nearly double the size of existing upstream facilities. The average size then of COE survey respondent active upstream dams will will be 240% greater than the average size for all TSF’s in the world.
We will shortly separately release a table with analysis of 40 COE respondent active upstream facilities with more than 50 million cubic meters, in fact with an average size of 161M cubic meters and an average year built of 1980. Importantly the concentration of such facilities in the TSF portfolios of some miners suggests a significant total portfolio risk of those companies.
World Mine Tailings Failures (WMTF) has developed a Tailings Portfolio Potential Risk (TPPR) Index for use by investors, insurers, creditors, regulators, mine managers and advocates to score both overall portfolios and individual facilities. The TPPR index utilizes data already available in national disclosures (and would be available as part of any mine application, request for discharge or expansion). Each component is anchored in, and informed by, the world-wide historic record on catastrophic failures. The pilot data set is 59 High Hazard Potential Upstream TSF records from the COE disclosures for which we also had preexisting, computed radius of impact (DMax) and Potential Hazard Severity (HRMEAN) in event of failure. The pilot index established three clear strata of potential risk as shown in Figure 1 and 2.
60 Extremely high (2%)
20-59 Very high (25%)
10 -19 High (39%)
We applied the index to all active facilities in the COE disclosures currently storing 100 Million cubic meters or more ( and included 3 that will attain greater than 100 by 2024 accoridng to the disclosures). 27% , all upstream facilities, scored extreme or very high potential risk.
This scales up to a world estimate of 564 mostly old upstream facilities holding more than 100 M cubic meters of tailings .We can reasonably estimate, first cut, that there more than 150 upstream active facilities worldwide which are “extreme potential risk” and for which we may or may not have adequate stability assurance.
WMTF is a U.S. Tax exempt Charitable Institution conducting pro bono self initiated research exclusively on cause and consequence of tailings facility failures. We do no fund raising but we do incur expenses and need support to cover our data development,data storgae, data analysis software expenses. Donations can be made by wire transfer or by check payable to World Mine Tailings Failures c/o John Steed Esq. Treasurer Law Offices P.O. Box 368 ( physical address 36 Main Street) Blue Hill, Maine 04614. This Project is the “State of World Mine Tailings 2020 “and donations may be ear marked for this project.
lindsaynewlandbowker 