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6 Justifying the Need for New Approaches
Technical dam reviews on a periodic basis are generally required by governments
and are also essential parts of a comprehensive corporate assurance program. One feature of the Legislated Dam Safety Reviews guideline published in British Columbia
(APEGBC 2014) is its recognition that the level of assurance should depend on a
number of site specific circumstances such as consequence rating, dam type and
use. It also requires an assessment of “the operations, maintenance and surveillance
practices at the dam including the assessment of the overall dam safety management
system and identification of any non-conformances;” without providing any guidance relating the conduct this part of the dam review. This is just one example of the
need to examine all assurance activities test for overlap and gaps as well as to the
suitability of the supporting protocols and guidance’s.
The main challenge for all companies in the establishment of a comprehensive
and effective assurance program is to ensure a high level of technical and operating
expertise is available, internally or externally, to assist in the development of the
scope, terms of reference and the selection of suitably qualified professionals for
each assurance activity. The second challenge is to ensure that adequate assurance
protocols and guidance’s are available to meet the objectives of the assurance activity.
The third challenge is to ensure that their assurance activities also assess the quality of site-specific operating, monitoring, surveillance, maintenance and reporting
procedures as described in the operating manual and audit their implementation and
conformance in practice.
6.5.3 Monitoring
When and if a permit is approved it must be granted with the requirement that critical
design operating parameters and risk mitigating strategies are strictly adhered to.
One example is the requirement, as stated in the B.C. Guide (2016), to include
measurable monitoring parameters that are identified and required to be maintained
within predetermined limits for a tailings storage facility. This subject was also
addressed in a report by the Auditor General of B.C. (BC AG 2016) that stated that
permits should be written with enforceable language.
Companies should be required to provide notification of any proposed changes
to the permitted deposition method, dam design or operating conditions for government review and approval. Such notifications and supporting material should be
accompanied by the results of a quantitative risk assessment that clearly identifies
any consequence or likelihood changes. The risk assessment should be carried out by
a third party and should be drillable in such a way that risk comparisons are possible.
If there is any doubt as to the acceptability of the revised risk profile, governments
should require a public review as part of its approval process. Governments, at any
time, should also establish the right to compel companies to provide an independent opinion on any proposed changes based on terms of reference approved by
government, including appointing a third party independent risk review.
6 Justifying the Need for New Approaches
Technical dam reviews on a periodic basis are generally required by governments
and are also essential parts of a comprehensive corporate assurance program. One feature of the Legislated Dam Safety Reviews guideline published in British Columbia
(APEGBC 2014) is its recognition that the level of assurance should depend on a
number of site specific circumstances such as consequence rating, dam type and
use. It also requires an assessment of “the operations, maintenance and surveillance
practices at the dam including the assessment of the overall dam safety management
system and identification of any non-conformances;” without providing any guidance relating the conduct this part of the dam review. This is just one example of the
need to examine all assurance activities test for overlap and gaps as well as to the
suitability of the supporting protocols and guidance’s.
The main challenge for all companies in the establishment of a comprehensive
and effective assurance program is to ensure a high level of technical and operating
expertise is available, internally or externally, to assist in the development of the
scope, terms of reference and the selection of suitably qualified professionals for
each assurance activity. The second challenge is to ensure that adequate assurance
protocols and guidance’s are available to meet the objectives of the assurance activity.
The third challenge is to ensure that their assurance activities also assess the quality of site-specific operating, monitoring, surveillance, maintenance and reporting
procedures as described in the operating manual and audit their implementation and
conformance in practice.
6.5.3 Monitoring
When and if a permit is approved it must be granted with the requirement that critical
design operating parameters and risk mitigating strategies are strictly adhered to.
One example is the requirement, as stated in the B.C. Guide (2016), to include
measurable monitoring parameters that are identified and required to be maintained
within predetermined limits for a tailings storage facility. This subject was also
addressed in a report by the Auditor General of B.C. (BC AG 2016) that stated that
permits should be written with enforceable language.
Companies should be required to provide notification of any proposed changes
to the permitted deposition method, dam design or operating conditions for government review and approval. Such notifications and supporting material should be
accompanied by the results of a quantitative risk assessment that clearly identifies
any consequence or likelihood changes. The risk assessment should be carried out by
a third party and should be drillable in such a way that risk comparisons are possible.
If there is any doubt as to the acceptability of the revised risk profile, governments
should require a public review as part of its approval process. Governments, at any
time, should also establish the right to compel companies to provide an independent opinion on any proposed changes based on terms of reference approved by
government, including appointing a third party independent risk review.