BRUMADINHO:WHO KNEW WHAT WHEN?WAS ITS FRAIL CONDITION RECOGNIZED BY VALE OR BY GOVERNMENT?

All in the 4th estate have done an absolutely fantastic job unpacking the bits and pieces that are now in the public domain and trying to say the right things about them.  Our work here at World Mine Tailings Failures is dedicated to compiling and vetting all the relevant information, having it presented and interpreted by experts as to cause of failure, early signs of failure, consequence of failure and what information was available pre failure that could have prevented the loss.

We have been working non stop translating, reading everything available to us  which may or may not include whatever document  Reuters is referring to.  Reuters has not sent us that document.  In my large sphere of global experts, none of them have seen the document Reuters is referring to.

What we can say so far is there is no question that the facility was in  fact in  a discoverable pre failure/extremely vulnerable  state for sometime.  What is not clear is whether  that was appropriately measured and identified  in what was required by law to satisfy required audit and stability reports or what  was developed by Vale’s own engineers or consulting engineering staff.

What is clear in the first instance is that the government classified this dam as ” high hazard”  in the event of failure using a pretty much universally  used classification  system intended to assess the potential “mining affected area” and the nature of adverse  effects in the event of failure. A more refined severity measure developed by the Columbia Water Center puts the Brumadinho at #5 in terms of scale of impact in the  event of failure.  That fact(of brumadinhos hazard class and the degree of severity by  Larrauri & Lall  has been sitting in my computer files for almost two years. 

My impression from the bits and pieces we have is that Vale has been actively assessing the adequacy and capacity of its entire tailings portfolio  for about 9 years.  Mainly, it seems,  they were looking for the lowest cost path to creating tailings capacity  for a planned 50% output in production by 2023. The oft referenced document that may have been Reuters document and which is reported to estimate the cost of a failure at  $1.5bn potential damage is likely Vale’s effort to prioritize financial risk to them in the event of failure and not a stability analysis of assessment of likelihood of failure. ( interestingly $1.5 b is what government officials demanded Vale put aside.  Could be coincidence?)

We know that  Vale says no depositions were made to Dam 1 for 4 years ( but aren’t clear when mineral production at Corrego d Faijao ceased).

That kind of assessment is not a risk assessment..it is not an assessment of risk of failure or present stability nor does it normally refer to specific failure conditions or problems known when the possible cost of a “worst case scenario” failure is calculated.

We are just beginning to post what we see at our web page specifically for the Corrego do Feijao Dam 1 failure. and we have formed no conclusion as to what Vale’s Board, its engineers, its consultants or the Government of Minas Gerais actually understood about the extreme vulnerability of this dam some time before its final collapse.

What would make that clear is the actual factor of safety measured for the dam over the last 10 years and an assessment of the quality of that analysis by experts.  To my knowledge, the government of Minas Gerais has not made public any of what it has apparently accepted as evidence of satisfactory stability.

Whatever it may have said in Brazil’s or Minas Gerais’ law there is a universal standard that a high hazard dam should be designed and maintained to minimum factor of  safety of 1.5.   On the part of any engineer  whether Vale’s or consultants there is a due diligence duty beyond  law to know that and apply that.  So far we don’t see that that happened.    An engineer who holds a license  and expects to keep it could never assert stability for a high hazard dam if they could not confirm a factor of safety of 1.5 or greater.

Brazils Law has since 1993 required that as a minimum standard.  Both the TUV SUD 2017 and 2018 confidential reprt to Vale on Dam1 stability conirmed FS >1.5 in udrained condition.  The law then in effect in Brazil as revised 2017 required thatthe FS consider both drained and undrained conditions.  TUV SUD in both reports found undrained  FS <1.3 but asserted that the dam was not susceptible to failure by static liquefaction.  These were both confdential reports, not the public reports filed as required declarations of stability.

It is very likely , and seemingly apparent, that neither TUL SUD nor Vale’s inhouse geotechnical staff are up to date on what currently constitutes best knowledge on static liquefaction.  Neither is Brazilian Law as of 2018.

I have copied all press who have been reporting on Brumadinho as a caution not to cite that Reuters claim as fact until people of  authority and knowledge  have vetted what that document actually was and what it means.

A 2010 thesis by Vale Engineer Washington Pirete and a later version of that in a published paper were both about using Dam1 as a case study to develop an estimate of static liquefaction trigger.  Their finding of complete resilience to failure , per their trigger, is not in fact the same thing as an accepted stability analysis but it appears Vale’s technical staff  and perhaps the Board itself may have believed  this was a certification of stability. That is not clear.

We  are posting at our web page what is authoritative and clear an describing what is not yet clear. I hope as you  continue to over the Brumahindo  you will check in there and see where things are.

February 15, 2019 Stonington Maine ( Revised  March 15,2019)

Lindsay Newland Bowker, Executive Director

World Mine Tailings Failures

compiler@WorldMineTailingsFailures.org

http://www.worldminetailingsfailures.org

01 207 367 5145

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. http://www.mdpi.com/2076-3298/4/4/75 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. (https://www.researchgate.net/publication/324594429_World_Tailings_Dam_Failures_From_1915_-_as_of_Mar_31_2018) 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://lindsaynewlandbowker.wordpress.com/2014/01/05/a-new-statutory-regulatory-framework-for-responble-sulfide-mining-should-this-mine-be-built/ 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 https://lindsaynewlandbowker.wordpress.com/2014/02/28/mountain-x-would-you-issue-a-permit-to-this-mine/ 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 Brazil Tailings Dam Failure Risk, Brazilian Mining Law, Brumahindo Dam Failure, Catastrophic Tailings Failures, financial risk and public liability, Linhares Civil Action Against Samarco, Minas Gerais Mining Oversight, Mining Regulation, mining resident engineer qualifications, Mining Risk Management, Public Liability & Financial Risk, Tailings Dam Risk Management, tailings dewatering, Tailings Failure Public Consequence Index, Uncategorized, Vale SA.. Bookmark the permalink.

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