Rio Tinto has redesigned its QIT Minerals Madagascar (QMM) mine following almost two years of criticism and questions from Andrew Lees Trust about its Mandena site operations in Madagascar.
The change reverses QMM’s 2014-2018 plan, which had reduced by 30 metres a legally required 80-metre environmental buffer zone designed to protect “sensitive zones,” such as water bodies, from any harmful impacts of the mine.
However, the new plan fails to reinstate the statutory 80 metre buffer zone for all water bodies near the site. Nor does it address the serious problem that Rio Tinto’s QMM mine has no confinement of radionuclide-enriched waters from its mine tailings.
The QMM mine has no dam or lake protection feature to protect the local waterways where local people fish and collect water.
The new plan, which reinstates the legally required 80-metre environmental buffer zone along the estuary side of the mine site was announced on the QMM website in January 2019.
This is a significant reversal, and a decision that will cost the company 82,000 tons of ore.
The company has yet to comment or admit that the changes are a result of an internal investigation, triggered by a study of QMM’s breach of the buffer zone by mining expert Dr. Steven Emerman, commissioned by the Andrew Lees Trust.
Dr. Emerman’s 2018 study found that, not satisfied with reducing the 80m buffer by 30 metres under an agreement with the Malagasy government, QMM went on to breach the agreed 50-metre limit and encroached 117 metres onto the bed of Lake Besaroy.
At the time, Emerman concluded that QMM’s buffer breach and management of mine tailings presented an “unacceptable risk” of seepage or overtopping of radionuclide-rich waters from the mining basins into the adjacent estuary.
Reviewing the situation today, Dr Emerman warned: “There is nothing that prevents flooding of the estuary with radionuclide-enriched water except for Rio Tinto hoping that it doesn't rain too much.”
Over the last year, Rio Tinto has failed to provide an explanation for how QMM is containing potentially toxic waste-water from its mining basin from seeping or flooding into the adjacent estuary.
First, Rio Tinto refused to acknowledge that the QMM operated a dam to contain mine tailings; they referred to stacked materials on site as a “berm”. The function of this structure - to stop the flow of waste from the mining basins into the estuary, is precisely the definition of a dam.
Then, following more questions, Rio Tinto’s engineering advisers SRK Consulting defined the “ berm” as “a temporary embankment” (SRK Memo August 2018).
The company finally answered the question this month when publishing its tailings and storage facilities notice, in which QMM mine is now rated as having “no embankment.”
By according a status of “no embankment” the company is concluding there is no lake protection feature separating the mining basin and its potentially toxic waste from the local estuary.
No dam, no berm, no embankment. Nothing.
Ironically, the information comes as part of a press release stating Rio Tinto’s commitment to lead improved standards around the management of mine tailings following the tragic Brumadinho mine dam disaster in Brazil last month.
QMM’s Social and Environmental Management Plan (SEMP 2014-2018), on which mine operations were based and approved, shows a requirement for a lake protection structure.
The government approved plan demands: "The height of the berm should be at least 4m higher than the level of the (mining) pond"; and a 2017 Rio Tinto memo (2017) confirms "a lake protection berm will be constructed."
The company is now saying that this minimum 4m high x 30m wide structure, which it was legally required to erect in order to prevent potentially toxic water flowing from the mine basin into the estuary and lakes – a ‘dam’ by any other name - does not exist as such.
If it did, it would be subject to international dam safety regulations; also an “independent expert review,” pledged by the Rio Tinto CEO Jean-Sébastien Jacques in his call for an industry-wide bid “to do better” at mine tailings.
Last year, when Rio Tinto/QMM were still calling their mine tailing storage facility a “berm,” its design provided for a factor of safety of 1.3 in a 50-year storm. This was critiqued by Dr. Emerman as the criterion used to design storm drains in a parking lot for a US shopping mall .
According to Dr. Emerman’s recent calculations, based on the updated information that there is no dam, the current probabilities of overtopping the QMM mining basin were found to be 0.71 - 3.04 percent, for water level rises of 2-4 meters.
Emerman explained: “The radionuclide-enriched waters only need to rise to the top of the mining basin. This is an accident waiting to happen.”
Perimeters of change
QMM claims that its new plan “minimises the impact on the environment and the community.” However, in addition to the concerns raised above, the new plan does not provide the statutory 80m buffer zone for the inland Lake Ambondrombe, next to the mine site.
There is no explanation for this decision. QMM simply states that local people “rarely use” the lake.
One possibility is that the lost exploitation from reinstating the 80m buffer on the estuary side of the site will be compensated by dredging closer to Lake Ambondrombe, with the cost of QMM’s shifting perimeters pushed back on to local villagers once again.
Will QMM always negotiate its mining requirements at the cost of local people’s access to and protection of their natural resources?
Importantly, can it be counted on to respect the 80-metre legal buffer zone where it plans to expand across two more sites in sensitive zones along the coastline over the next thirty years?
Is Rio Tinto able to adequately assess, rate, and manage mine tailings at the QMM site in order to protect the surrounding environment?
Can QMM responsibly ensure the safety of its operations in Madagascar – not only for its staff, but also for impacted communities?
Time to end voluntary standards for mine tailings management by a self-regulating industry and provide real change in the form of robust independent monitoring, international regulations and law enforcement to protect local citizens’ rights and entitlements.
Yvonne Orengo is an independent communications practitioner and a Director of the Andrew Lees Trust. She has followed the evolution of the QMM mine for over twenty years, having lived and worked in the South of Madagascar to develop the Trust's social and environmental programmes.
ALT UK has been advised by Dr. Steven H. Emerman, owner of Malach Consulting, who specialises in evaluating the environmental impacts of mining on behalf of mining companies, as well as governmental and nongovernmental organisations. He is also the environmental compiler and vice-chair of the board of directors of the World Mine Tailings Failure Database.
Image: Antanosy woman on the estuary system next to the QMM mine at Mandena. © Antonie Kraemer.
 The report of this investigation is still being “consolidated” according to Rio Tonto and will be shared with Andrew Lees Trust at the end of March.
 Ref: Basic Environmental Technology.