TAGS: International Cyanide Code; CIL Process Risk;Severity Rating Of Tailings Failures;Robert Moran;FrontPageAfricaOnline
CONTACT: Lindsay Newland BowkerLNBowker@BowkerAssociates.org
DATE: June 25, 2018
KOKOYA Tailings Facility Pre-Failure (Source Miner Annual Report)
Although it must have been widely known in mining circles, a liner failure releasing 11,500 cubic meters of cyanide tainted CIL tailings at the the Kokoya gold mine in Liberia on September 27, 017 was not reported in mainstream mining media or at WISE, the “official” world chronicler of “serious tailings incidents post 1960”. It came to us via a google alert through a recent article in FRONTPAGEAFRICAONLINE summarizing the Liberian government’s legal findings of “public harm” related to measured evidence of consequence attributable to the cyanide levels in the tailings. Although the journalist was allowed to apparently read the full report in situ he/she was not , presumably allowed to make a copy and the government is now refusing to release the full report.
On reviewing the World Mine Tailings Failures data base from 1915 it became apparent that the absence of scieitfic assessment of the persistence and effects o cyanide tainted releases had not been taken into account in any of the of the narrartives and therefore any of the the severity classifications of prior tailings releases from gold mine leach facilities. All but a few had been rated “minor failures” due to the absence of any science or examination of the actual cyanide consequences.
The following was shared with the international tailings working Group, a multi stakeholder mult disciplinary roundtable convened by Minng Watch Canada.to bring forward the intentional obfuscation and avoidance of cyanide effects . Citing this presentation to UNEP and the European Commisison by hydrogeologist Robert Moran we are removing all severity codes for failures of gold leach tailongs facilities that do present authoritative science on cyanide related consequence and presently rated as “minor failures”.
Kokoya Mine Plan ( Source Miner Annual Report)
Following the Baia Mare spill and several other environmental incidents involving cyanide, a mining industry-funded research association, the International Council on Metals and the Environment (ICME), together with the United Nations Environment Programme (UNEP) organized a series of meetings in an effort to prepare a cyanide “code”, with the objective of describing “best use” practices. Unfortunately, this process has been funded primarily by the industry, and is largely controlled by it. Even the participants from the UNEP staff come largely from industry-sponsored positions. Therefore, the “code” draft (UNEP/ICME, 2002) reflects, predominantly, what is best for industry, not the interest of the environment or the public. The author is concerned that the outcomes of the flawed UNEP sponsored process, will impact decision-making in the EU. (Note: ICME is now defunct and has been replaced by a new industry trade association, the International Council for Mining and Metals—ICMM.)
To be sure, there are some positive practices recommended in the draft UNEP report. However, the draft document continues to recommend environmental monitoring that focuses only on WAD CN, thereby neglecting to evaluate many other toxic forms of CN. Incredibly, the draft (Section: Standard of Practice 4.5, pg. 15) states that direct or indirect discharges to surface waters can contain up to 0.50mg/L WAD CN. Aside from recommending an analytical procedure (WAD) that fails to detect many of the toxic CN species, such a concentration would be lethal to most of the aquatic life in many settings. This is hardly protective and amounts to a UNEP/ICME sanction for the destruction of aquatic systems.
Robert Moran 2002 ( emphasis added)
Where a beneficiation or extraction process that is wide spread practice and considered indispensable for the production of a certain mineral or mineral group presents very high potential risks to human and environmental security, and where there are no known effective alternatives to those methods,industry avoids any visitation of science & reality that may lead to extra costs or preclude some deposits from being mined at all.
With respect to cyanide released with the <12,000 cubic meters of tailings at Kokoya, a full understanding of consequence, or a finding of no consequence , must be science based and if it is good science will be in line with what Dr.Moran had always urged and what we must urge now. International Cyanide code is not good practice not good science.
What standard did the Kokoya miner employ? What standard did the Liberian government employ in its statute and in its findings of impacts report that the journalists has been trying to get released.
Tailings Failures begin in pre feasibility and take a step forward when a miner advances a plan that does not control risks and a government agency approves that plan.
What standards were set by government on cyanide, what test procedures were specified? What measurements of cyanide level were required by the government or initated by the miner?
the Code makes recommendations regarding Free CN (again in Standard of Practice 4.5), where they state that a Free CN concentration less than 0.022 mg/L downstream of any established mixing zone is acceptable. In some environments this concentration would be toxic to many sensitive species. More importantly, most objective experts would agree that there is no reliable analytical method to analyze Free CN (C. Johnson, US Geological Survey; G. Miller, U. of Nevada). The authors then add a very self-serving phrase, that “the lower quantification limit (LQL) for free cyanide analysis achievable by most laboratories is 1 mg/l.” Most high quality commercial labs can, in fact, reproducibly report to the nearest 5 to 10 mg/L (0.005 to 0.01 mg/L). Thus the report is misleading in its assertion that “most laboratories” cannot achieve this standard. Clearly the Code is not being particularly protective or accurate when it recommends (Standard of Practice 4.4, pg 14) that WAD CN concentrations up to 50 mg/L in open waters are acceptable regarding safety to wildlife and livestock. There are many examples where numerous birds and other animals have been killed by lower concentrations Several Code statements regarding Emergency Response are extremely relevant to the present EU purposes. For example, in Standard of Practice 7.5, pg. 29, if read carefully, one concludes correctly “that there are no safe and effective options to treat cyanide once it has entered natural surface waters such as streams and lakes.”
Robert Moran Op Cit 2002
Can we even assess how much cyanide was in that small release at Kokoya from data required by law and regulation and independently measured and maintained by Government.?
The publicly available data from the Baia Mare spill reported only total cyanide, and selected determinations of copper, manganese, iron, lead, and zinc—for river samples. No detailed analyses of the actual gold-process waste liquids were made public. No field measurements (temperature, specific conductance, or pH) were reported. Such measurements are, in some ways, the most useful data for understanding such a spill.
Robert Moran Op.Cit 2002
A recent report sponsored by the mining and cyanide manufacturing industries (Logsdon, M.J., et. al., 1999) states: “Since cyanide oxidizes when exposed to air or other oxidants, it decomposes and does not persist. While it is a deadly poison when ingested in a sufficiently high dose, it does not give rise to chronic health or environmental problems when present in low concentrations.” This statement is misleading and presents a falsely benign picture. Robert Moran Op.Cit 2002
The UNEP Baia Mare report indicates that elevated total cyanide concentrations were detected for, as a minimum, hundreds of kilometers downstream, for up to four weeks after the Baia Mare spill. Clearly the total cyanide in the Tisza River did not decompose quickly. Robert Moran Op.Cit 2002
Baia Mare was a release of 100,000 cubic meters, 10 times the Kokoya suggesting that the Kokya 11,000 cubic meters could also have had cyanide concentrations affecting possibly 10 km of running water for up to a month after release on 09/27/2017/.
Dr Moran says of vat leaching of which CIL is an advanced ore process form:
From an environmental point of view, there may be some 13 preference for vat-leach approaches, mostly because there are no open process solution ponds, and some of the tailings liquids may be treated. However, higher concentration cyanide solutions are often used in vat-leach facilities. Vat-leach approaches could be improved through requiring that tailings be deposited essentially dry. Robert Moran Op.Cit 2002
Of the many many AU tailings failures in the data base, the Kokoya is the first that had sufficient data available on harm (a government legal finding viewed and relayed by the journalist) after release attributable to cyanide to include the cyanide toxicity as part of the consideration severity code. All the others are based on release runout and deaths only and most are presently rated 3, “minor failure”‘–that can’t be right...I am removing any severity code rating for all AU tailings failures presently rated “minor”. The absence of data or the use of false science to minimize harm and long term risk should not result in a severity classification of “minor failure”. Henceforth any AU tailings release without specific good science assessment o cyanide effects will cite this Moran report to explain why no severity rating can be assigned. To do otherwise may lead to misleading use of the database stating that 100% of cyanide containing releases were found to be “minor”
Tailings waste risks begin in pre feasibility when the beneficiation process determined
by grade and mineral type is identified.
The advances in beneficiation and extraction technology that accompanied the push to mine lower grades of mineral ores cost effectively and brought us bulk mining and its main asset open pit mining. These technologies enabling low grade mining also brought us:
(1) higher volumes of ore processing per unit of mineral produced and greatly pushed margins
(2) Robert Moran Op Cit 2002 effects and implications for closure for wet tailings resulting from CIL, Bayer, and even hard rock floatation slurries in which a recent report in Spain found 80% of very old tailings didn’t dry out and still liquefy.
(3 un examined effects and implications for zero public consequence management of the wastes of these wet disposal, wet permanent state technologies
An exceptional high grade deposit brings more options, lower risks, and more value per tonne. Higher grades make it possible to maintain solid margins and actually can put public and environmental safety first and still produce within market price.
At Bill Williams Zero One Zinc deposit in Peru, good vetting work on the deposit itself ( by Bill) redefined it from a small marginal low grade deposit of no economic interest to an exceptionally high grade deposit of much larger size than previously hurried not as competent analysis revealed. This will allow beneficiation with.no tailings ponds. The wastes will be usable product for asphalt and other surfacing.
THE WORLDS NEEDS FOR METALS & MINERALS DO NOT REQUIRE A LOCAL SACRIFICE ZONE AS AGRICOLA LAMENTED
Writing at the same time of Dr. Moran’s iconic message to the European Commission and UNEP on Sustainability mine economist David Humphreys concluded that there is no inherent conflict between sustainable mining of the minerals the worlds needs and community/environmental security. Where technology is available and proven to reduce risks to a “no public consequence level” ( my framing not Dr. Humphreys) he opined that the tighter controls required would actually improve overall productivity and thus be largely funded through revenue and that what results in increased non recoverable costs of production will raise prices and thus become funded. He counseled wisely that any deposit that can’t attain community and environmental security within the known efficacy of existing technology shouldn’t be mined. When we ignore this wisdom we end up with catastrophic non remediable tailings failures and giant write offs and losses to investors impairing the flow of private capital needed to actually supply the minerals the world needs..
Tailings failures are germinated in pre-feasibility.
That this hasn’t been the standard of resource governance globally leaves us with the following serious unexamined unaddressed tailings issues for the coming decade
(1A)The accrued liability in existing tailings is world problem #1A..these faciities have to be assessed and prioritized for treatment and closure as Dragana Nilsic is doing in Serbia and Roberto Pacheco is doing in Spain. This work of realistic science based independent risk assessment of existing in use tailings facilities must be a top funding priority for every nation, every permitting jurisdiction. We can’t defer or ignore that just because existing and planned production needs tailings storage capacity that does nor presently exist.
1B) world problem 1B the bulk of the mineral production this decade will come from the same beneficiation and extraction technologies.designed for lower grade ores at all new low ore grades presenting more challenges to processing and to safe retention and they will look to these existing tailings facilities globally to accommodate ever higher volumes of tailings waste per tonne of mineral produced.
(2) Tailings storage that can be safely managed and closed with zero public consequence depends not just on leak & release proof containment but on new technologies for extraction and beneficiation. It makes no sense just to continue to produce metals and minerals outside the known limits of existing technology to realistically aim at zero public consequece. It isn’t necessary to do this to produce the minerals and metals the world actually needs.
Lindsay Newland Bowker, CPCU, ARM Environmental Risk Manager
Science & Research In The Public Interest
15 Cove Meadow Rd.
Stonington, Maine 04681
207 367 5145
On Fri, Jun 22, 2018 at 8:19 AM, Lindsay Newland Bowker <firstname.lastname@example.org> wrote:
This kind of intentional always present fuzziness about the actual details of “consequence” of failure attends all catastrophic failures.
This reporters original story cited excerpts from the governments own official findings and used the text from those findings which included specifically the words “catastrophic” and “failure to follow best practice as required by law”. This follow up report by the same journalist now explains that the government has refused to make its investigative report and findings public.
We are still classifying this as a 2 , “serious failure” based on the toxicity of the release despite its small volume (<12,000 cubic meters). With no specific disclosure on the composition of tailings in publicly available inventories of the portfolio of tailings facilities globally we have only post failure texts f varying reliability and quality to rely on to properly describe severity and consequences of a given release. We consider legal findings authoritative. Our 2, “serious” trusts the veracity of this journalists excerpts from the governments legal findings.
Bill Williams, who added the data we have in the World Mine Tailings Failures data base included a column”toxic elements in the deposit’ which gives us a start on distinguishing the toxicity and persistence of adverse effect from a given release.
There is a scale of “inherent risk”, inherent human and natural security risks by type of deposit which Bill Williams also added as a descriptor for as many deposits as he had from his own database.
Many years ago NRCAN’s YT John Kwong classified degree of risk by deposit type.( see attached) We will look into adding Dr. Kwomgs “inherent risk’ scale to the database. Through our planned lat/lon addition and the addition of USGS deposit id we should have 100% data on depsitt classification and be able to assign Dr. Kwongs inherent risk classifications to 100% of all failure records.
Beneficiation processes and “most common practices” for different minerals also have differing inherent risks for which we do not have and need to develop a coherent mathematically clear risk classficatons.
Lower grades across thee board create higher risks in many ways.
Grade drives process for a given mineral.
The CIL process used at Kokoya is applicable only to higher grades of gold ( and much safer than the heap leach process which is still the only viable method for very low grade gold) produces a completely liquid tailings slurry which will contain cyanide residuals in the same way that the floatation slurry contains the chemical additive for that beneficiation process. The BAYER Process an ancient never improved on technology is still the most common fr for Alumina and also produces high risk very liquid tailings requiring much higher standards fr secure retention and more back up system to capture any releases. Phosphates and fertilizers use a water blasted extraction process that produces a permamently wet tailings residue that is extremely toxic . Common practce is that process. CIL tailings wastes require a much higher standard of construction for safe retention and that includes not just the need for water dam like standards for containment walls but permanently secure leak proof loners. A complete failure after only two years indicates either a wrong spec on the llne or its improper installation. This facility employed a completely rock fill dam ( I believe I previously shared the pre failure photo)
Th degree of harms a measurable reality.
The degree of rsk pre failre s a measurable reality.
We just aren’t properly measuring it yet in a fully transparent way.
Still need info on the dimensions of this dam and its intended useful life, factor safety etc.and obviously need a lot of information on thisl lner and on protocols for liners of CIL tailings wastes.