TAGS: International Cyanide Code; CIL Process Risk;Severity Rating Of Tailings Failures;Robert Moran;FrontPageAfricaOnline

CONTACT: Lindsay Newland

DATE: June 25, 2018

kokoyaprefailurtsf                 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 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 tailings ponds. The wastes will be usable product for asphalt and other surfacing.





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

Bowker Associates

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 <> 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.


About lindsaynewlandbowker

Bowker Associates, Science & Research In The Public Interest, is an independent non profit providing self initiated pro bono analysis on key issues with a potential for massive adverse environmental impact . Bowker Associates has been an internationally recognized and cited voice in analysis of the Samarco failure, its consequence, and the possibilties for recovery. In 2017 we partnered with Daveid M. Chambers, a world leader in responsible mining, in our third joint work on the economics of tailings failures. Bowker, L.N.; Chambers, D.M. In the Dark Shadow of the Supercycle Tailings Failure Risk & Public Liability Reach All Time Highs. Environments 2017, 4, 75. A peer reviewed journal published investigation of the cowboy economics of the supercycle and the resulting escalation on the number and magnitude of catastrophic failures. In 2016 we parnered with Dave Chambers in our 2nd joint work together looking at root causes of failures at a conference . Bowker, L.N.; Chambers, D.M. Root Causes of Tailings Management Failures: The Severity of Consequence of Failures Attributed to Overtopping 1915–2015. In Proceedings of the Protections 2016, Fort Collins, CO, USA, 14 June 2016. [Google Scholar] In 2015 Bowker Associates collaborated with geophysicist David M. Chambers to recompile global authoritative accounts of significant TSF failures in recorded history and to analyze these data in the context of global mining economics 1910-2010 ( Risk, Economics and Public Liability of TSF Failures, Bowker/Chambers July 2015) The third annual update of this globally referenced and used compilation was just released at Researchgate. ( In 2014 Bowker Associates commissioned globally respected geophysicist and hydrogeologist Dr. David Chambers to undertake two technical works: (1) development of technical go no go criteria for vetting mine applications tp:// and (2) a case study of Maine's Bald Mountain, an un mined low grade high risk VMS deposit demonstrating the efficacy and accuracy of two risk assessment tools in vetting mine proposals In Maine, Bowker Associates has deeply engaged and been a public voice in the Searsport DCP LPG Tank, The Cianbro proposal for a Private East West Toll Road, JD Irvings rolling pipeline of Bakken crude to its plant in St. John and review of Phase II plans at The Callahan Superfund site in Brooksville, Maine, and Maine's revisitation of mining in statute and regulation... Our only “client”: is always “the pubic interest”. Our model is to focus on only one or two issues at a time so that we have a substantive command of the relevant field as our foundation for ongoing engagement. Our core work is in envirommental risk management, science and technology as well as bringing any available “best practices” models to the fore. The legal and regulatory history/best models are also a major thrust of our work in building and evaluating public policy. Director/Principal Lindsay Newland Bowker, CPCU, ARM is a recognized expert in Environmental Risk Management., Heavy Construction Risk Management and Marine and Transit Risks and has more than 3 decades of engagement in buiding public policy. Appointed by Governor Mario Cuomo to New York State Banking Board (served 1986-1996); President New York Chapter Chartered Property and Casualty Insurers; Environmental Committee, Risk and Insurance Management Society; Director, Convenor/Co-Chair Bermuda Market Briefing "From Captive to Cats" Hamilton Bermuda. Published Articles of Significance The Risk Economics and Public Liability of Tailings Facility Failures, co-authored with David M. Chambers, July 2015 Beyond. Polarization: Superfund Reform in Perspective, Risk & Insurance Managing Risk For Loss Prevention & Cost Control (Jan. 24, 1997). Lead Hazards and Abatement Technologies in Construction: A Risk Management Approach CPCU Journal 1997 Employee Leasing: Liability in Limbo Risk Management June 1 1997 Environmental Audit Privilege and the Public interest Risk & Insurance Managing Risk For Loss Prevention & Cost Control, April 1997 Asbestos:Holes In Abatement Policies Need To Be Plugged, Lloyd’s Environmental Risk International, May 1993 Editor Published Letters Evironmental Risk Management Beware of Facile Policies Like Fetal Protection Business Insurance 1995(?) High Court Review May Increase Sale of Bank Annuities Business Insurances August 8, 1995 Professional Profiles Protecting the Big Apple’s Core Managing Risk For Loss Prevention & Control December 1996 Major Career Highlights First rigorous analysis showing Relationship Between declining ore grades and TSF Failures of increasing consequence ( July 2015) FIrst Documentation that Gentrification Has Same Impacts as Unassisted Displacement from Urban Renewal Sites Direted Court Ordered EIS of FHA Mortgage Scandal Created Nation's First Homeownership Program for Low Income People (SHIP) Created Earliest Geographic Information Systems Using Defense Technology Developed By IBM Designed and Conducted Parallel Census Count to Show Systematic undercount in minority neighborhoods Documented Bias in ISO Territory Rating Plans for Private Passenger Auto Insurance Using ISO's own Rating Techniques Demonstrated Inherent Bias in Mortgage Policies of Banks With Inner City Branches Demonstrated that NY Telephones Plan for Area Code Split To accommodate anticipated cell phone demand was not efficient and would exhaust in 5 years ( which it did) Undertook First Systematic Evaluation of Child Protective Services Caseload Using Multi Variate Analyic Techniques Developed Child Protective Caseload Management and Tracking System (CANTS) and directed implementation in 4 client states including Illinois, Florida and New York Created and Ran Office of Risk Management for NYC DEP the Nations largest Water & Sewer Authority . Designed, Created and Administered Nation's First Owner Controlled Insurance Program (OCIP)for High Risk Tunneling Education Masters NYU Graduate School of Public Administration BSC New School For Social Research Maine Public Schools Deering High School
This entry was posted in Avesoro Holding, CIL Tailings Failures, cyanide risk management, Front Page Africa Online, International Cyanide Code, Kokoya Mine, Robert Moran, Uncategorized. Bookmark the permalink.

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