IM 2020 September 20 | Page 69

PASTE & TAILINGS 2020 ‘Extreme’ classification criteria every five years for facilities �������� [must be] maintained throughout classified as Very High or ������������������������������������������������������������������ the tailings facility lifecycle.” For existing facilities that do not have the ability to be upgraded to �������� ������������������������������������������������������������������ ����������������������������������������������������������������� ���������� Extreme, and at least every 10 years for all other facilities. The DSR includes governance Responsible • Accountable for the integrity of the tailings facility (Requirement 8.5). Extreme, the Engineer of Record and operational aspects, as Tailings • Responsible for liaising with EOR, operations, planning, regulatory (EOR), with review by the Internal Facility affairs, social performance and environment teams (Requirement 8.5). well as technical review of the Technical Review Board (ITRB) or a Engineer • Responsible for implementation of the design. facility. Additionally, the DSR senior independent technical (RTFE) • Accountable for the establishment of a change management system contractor (not just the (Requirement 6.5). reviewer, if they determine that the individual engineer, but the • Responsible for the monitoring system and communication of the upgrade in design criteria is not results to the EOR, including performance reviews (Requirements entire company) cannot feasible or cannot be retroactively 7.2, 7.3). conduct consecutive DSRs on applied – “In this case, the • Responsible, with the EOR, for the Construction Records Report the same facility. (Requirement 6.3). Accountable Executive shall • Responsible for the OMS Manual (Requirement 6.4). These DSRs are in addition approve and document the implementation of measures to reduce both the probability and the Engineer of Record (EoR) • Responsible for the Design Basis Report (Requirement 4.8). • Responsible for the design (Requirement 9.1). • Responsible for the design report. to the annual (or more frequent) reviews by the EOR, internal audits, regular • Responsible for construction and performance reviews consequences of a tailings facility reviews of the management (Requirement 10.4). failure in order to reduce the risk to • Responsible for the Deviance Accountability Report (Requirement 6.5). systems (every three years for a level as low as reasonably • Responsible, with the RTFE, for the Construction Records Report High, Very High and Extreme) practicable (ALARP).” This is a (Requirement 6.3). and multi-disciplinary risk • Support the RTFE on the OMS Manual (Requirement 6.4). protective measure for future assessments that are done at Accountable • Accountable for the safety of the tailings facility and for environmental community development near a Executive and social performance (Requirements 7.1, 8.2, 8.3, 8.4). a minimum of every three mine. A mine site that is isolated at the start of a project may develop a • Approval of the adopted design criteria and measures to reduce the risk of failure of existing facilities to ALARP (Requirements 4.3, 4.7, 5.7). years. It will be imperative that consultants and engineering • Accountable for tailings management training, emergency substantial population downstream companies carefully track their preparedness and response (Requirement 8.4). of the tailings dam after the project • Selection of the RTFE (Requirements 8.5, 8.6) and the EOR previous DSRs and identify site has been selected. The (Requirements 9.1 to 9.5, 8.6). potential conflicts of interest successful implementation of this • Appointment of the ITRB or a senior independent technical reviewer when taking on this type of (Requirement 8.7). standard will require diligent work because they must • Establishment of a process for addressing concerns attention, by all parties, and (Requirement 12.1). certify in writing that they frequent assessment of the risks to maintain the level of transparency Independent Tailings • Review of the design, construction, risk assessments, governance systems and other risk management matters that can affect the “follow best practices for engineers in avoiding conflicts envisioned by the Standard. Review tailings facility, ensuring that the required expertise and skill sets are of interest.” Board (ITRB) involved. or senior • Review of the adopted external loading design criteria and What does the Standard What are the key roles technical measures to reduce the risk of failure of existing facilities to ALARP mean for the industry? described in the Standard? reviewer (Requirements 4.2, 4.7, 5.7). This is an exciting time for • Review of the alternatives analysis (Requirement 3.2), design, Table 4 summarises the key roles the mining industry and the construction, risk assessments (Requirements 10.1), governance and functions mentioned in the systems and other risk management matters (Requirement 10.6) that engineers and operators who standard. Requirement 9.1 of the can affect the tailings facility. contribute to the tailings Standard explains that the owner • Review the Design Basis Report (Requirement 4.8). practice. The bar has clearly • Determine the frequency of Dam Safety Review (Requirement 10.5). should engage an engineering firm been set high by the coconveners with expertise and experience in the design and construction of Table 4: Summary of Key Roles and Functions mentioned in the Standard of the Global Tailings Review in an effort to tailings facilities of comparable complexity. This is different from some previous debates within the industry about whether the EOR should be defined as a person or a company. The Standard defines the EOR representative as a “senior engineer, approved by the Operator, to represent the firm as the EOR, and verify that the individual has the necessary experience, skills and time to fulfill this role.” No specific requirements for engineering discipline, degree, or number of years of experience have been provided. The Standard also states that “alternatively, the Operator may appoint an in-house engineer with expertise and experience in comparable facilities as the EOR and the EOR may delegate the design to a firm (‘Designer of Record’).” We know that this model is common practice in some regions, such as the Alberta oil sands. It is clear that some flexibility has been built into the Standard to maintain the status-quo of some areas and regions. For example, the Standard also states that “in some highly-regulated jurisdictions, notably Japan, the role of EOR is undertaken by the responsible regulatory authorities.” Frequent reviews are a recurring theme in the Standard, and there is a requirement for Dam Safety Reviews (DSR) which may be new to some projects. A DSR must be carried out by an independent qualified review engineer to evaluate the safety of a tailings facility against failure modes, in order to make a statement of safety of the facility. The requirement states that an independent DSR must be conducted at least protect people from being impacted by the failures. The industry is doing good work and needs to do better across the board to meet the goal of zero harm. This Standard provides a great framework, it can be fit-for purpose. The industry’s technical experts will be stretched thinner than ever before in order to meet the oncoming tidal wave of demand. IM The Standard is available on the Global Tailings Review website: https://globaltailingsreview. org/global-industry-standard/. *Amanda Adams is a Principal Tailings Engineer and Project Manager at Stantec. She is based in Denver, Colorado and can be reached at amanda.adams@stantec.com