Acid Mine Drainage -the Eastern basin is currently experiencing an ingress of 120-million litres of water and only has the capacity to treat about 80-million litres of water

If relevant to your concerns and environmental issues,  kindly raise your concerns regarding Mine Waste Solutions’ (MWS) Water Use License authorisation and positive environmental authorization for its Centralised Tailings Storage Facility (super dump) within the KOSH goldfields, one kilometer from the highly compromised Vaal Barrage River system. MWS is of the intention to reprocess 15 uraniferous tailings dams, to reprocess 1.9 million tons per month of uraniferous tailings (producing 922,000 lb/yr U₃O₈ in yellowcake) and to establish a new centralized tailings storage facility of about 1 400 ha, one kilometer from the Vaal River.  The properties adjacent to the proposed super dump are game farms and conservancies.

Your concerns and objections (please see subjoined “gaps in information”) should be submitted to:

Mr. Scot Sobey (scot@firsturanium.com)

Mr. Tshepo Moremi (Tshepo@nwpg.gov.za)

Ms. Deborah Mochotlhi (mochotlhi@dwaf.gov.za)

Mr. Willem Grobler (groblerw@dwaf.gov.za )

Mr. Piet Theron (PietT@nda.agric.za)

Mr. David Klein (DavidKl@nda.agic.za )

In terms of Mine Waste Solutions’ Environmental Management Report, it was submitted that the following gaps in the environmental impact assessment exist:

1. The existing groundwater monitoring network at MWS, Buffelsfontein and Hartebeestfontein does not meet all the requirements of [an effective ] monitoring network. (The purpose of groundwater monitoring network is to provide an early warning of possible adverse effects of the activities in the vicinity of the tailings complex, on both yield and quality of the shallow groundwater system.) No dedicated monitoring boreholes are available for the existing MWS plant site and the proposed extension site. The leachate from the proposed TSF will lead to long-term groundwater pollution.
2. A detailed geochemical assessment was not incorporated; only static laboratory test work was included on available tailings samples for the purpose of the geochemical assessment because of the limited time frame.
3. A  geophysical assessment must be done to confirm the structural geology to the east of the proposed site.
4. Certain areas were excluded re aquifer related flow parameters.
5. The status of groundwater users and uses was not confirmed.
6. The proposed reclamation sites (existing TSFs) are mostly located on dolomite/chert formations.  Ground water characteristics for these sites are unknown and NO site specific aquifer data exist.  MWS solutions will take responsibility for existing contamination plumes BUT these are not clearly  identified.  Future positive impacts of the proposed reclamation activities can therefore not be demonstrated.
7. After closure, the mine workings will flood and the dolomite aquifers will largely recover to pre-mining levels.  There are currently no management options in place to cope with contaminated decant water.
8. The flora assessment was incomplete since most of the investigations were conducted during the winter period, and no investigations were conducted during or after the high rainfall seasons.
9. The wetland assessment was incomplete since the investigation was undertaken at the end of the dry season which made plant species identification very difficult.

In view of the aforesaid gaps it perplexes how a water use licence and a positive environmental authorisation could have been issued by the Department of Water Affairs and the North West Department of Agriculture and Rural Development respectively.

The impacts of mining on the environment is current and the long term impacts from Acid Mine Drainage (AMD) and heavy metal accumulation, including Uranium,  in the vicinity of the CTSF, Tailings Storage Facilities and reprocessed footprints within the KOSH goldfields have been acknowledged.  (Please see the DMR’s Regional Mine Closure Strategy for the KOSH goldfields and the Environmental Management Report of Mine Waste Solutions, March, 2009.)

In terms of MWS’s  Environmental Management Report “Mine Waste Solutions will be responsible for the existing pollution plume and zone of influence.  The anticipated zone of influence (SO₄ plume) falls within The Koekemoerspruit# and Vaal River Catchment* areas.”

#(The Koekemoerspruit, is a tributary of the Vaal River.  The Koekemoerspruit catchment is already compromised.  The transport of dissolved uranium from slimes dams is a major pathway for environmental contamination of the Koekemoerspruit. Reference:  “Gold tailings as a source of waterborne uranium contamination of streams –  The Koekemoerspruit (Klerksdorp goldfield, South Africa) as a case study.  Part I of III: Uranium migration along the aqueous pathway”. Frank Winde, Peter Wade and Izak Jacobus van der Walt)

*( In terms of the Water Research Commission Report No. 1397/1/07, entitled “Monitoring Environmental Water for the Presence of Toxic Agents:  A Pilot Study in the Vaal Barrage Catchment” it was found that “mining operations, even after they have been discontinued, are still having a major impact on the water quality in the Vaal Barrage catchment to the extent that it can no longer be compared with other natural water systems…only 21% of the sites showed no evidence of cytotoxicity at any time.  This suggests a failure on the part of those agencies responsible for the enforcement of existing  regulations and is an unacceptable situation, bearing in mind that source water from this survey area impacts directly upon the Vaal Barrage, a national water resource….Substantial deposits of immobilized toxicants could have accumulated in the southern Gauteng river silts over a prolonged periods.  Experience elsewhere suggest that such deposits pose long-term health and environmental risks”.)

With gratitude,

Mariette Liefferink.
CEO:  FEDERATION FOR A SUSTAINABLE ENVIRONMENT

On 1 September the Federation for a Sustainable Environment submitted the following request for information in terms of the Promotion of Access to Information Act:

Dear Mr. Sobey,

In terms of the Constitution of the Republic of South Africa, Section 32 (1) of the Bill of Rights “everyone has the right of access to any information that is held by another person and that is required for the exercise or protection of any rights”.

In the context of Mine Waste Solutions’ establishment of a Tailings Disposal Facility, 1 (one) kilometer from the Vaal River, the rights that interested and affected parties wish to exercise and protect are:

1. Everyone has the right to life (Section 11);
2. Everyone has the right to an environment that is not harmful to their health and wellbeing; and to have the environment protected for the benefit of present and future generations, through reasonable legislative and other measures that prevent pollution and ecological degradation; promote conservation; and secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development (Section 24);
3. Everyone has the right to have access to sufficient water (Section 27).

I am of the intention, in the public interest and on behalf of members of affected communities, and the Federation for a Sustainable Environment, to submit my request for access to public documents such as the Water Use Licence, the Social and Labour Plan, the amended Environmental Management Programme and Environmental Impact Assessment Report, etc. to Mine Waste Solutions, in terms of the provisions of the Promotion of Access to Information Act, No 2 of 2000 (PAIA).  Please advise me what Mine Waste Solutions’ prescribed format is.

I shall appreciate your response before  the 5^th of September, 2010 since your response will ripen my judgment.

Sincerely,

Mariette Liefferink.

CEO:  FEDERATION FOR A SUSTAINABLE ENVIRONMENT