ENVIRONMENTAL IMPACT ASSESSMENT: RAND URANIUM PROPOSED
REPROCESSING OF TAILINGS FOR GOLD AND URANIUM EXTRACTION IN THE
RANDFONTEIN/WESTONARIA REGION
(DEAT Reference Number: 12/12/20/1285)

SUBMISSIONS ON THE DISCUSSION DOCUMENT PERTAINING TO:
Proposed disposal option(s) – Basis for evaluation of alternatives as input into the
site selection process
INTRODUCTION
The Discussion Document is fairly entitled to the praise of completeness, transparency, clarity,
assiduous attention to detail, and consideration of the concerns of interested and affected parties.
I now refer to the proposed disposal options in terms of your figures 3 to 6.
My submissions pertain primarily to the proposed disposal option in the Geluksdal, Fochville
area within the Leeuwspruit Catchment and are mainly grounded upon the approved
Environmental Management Programme Report of the South Deep Mine1 (please do not pass the
contents of the footnote over, which are considered of appreciable magnitude), which is
currently still in force2, in terms of the Minerals Act of 1999, and the Addendum of the South
Deep Mine’s Environmental Management Programme Report, Report No. 288239/2, dated
December 2001, by SRK Consulting Engineers and Scientists. I respectfully reserve the right,
however, to augment or refine my submissions before the termination of the prescribed time
period on the 3rd of November, 2008.
Notwithstanding the fact that the GDACEL has found: “At the time sufficient information is not available to allow
this Department to recommend approval of this Environmental Management Programme Report. Further more the
information that is provided with respect to water quality is alarming. More detailed information and discussion on
mitigation is required.” There is no documentary evidence that the concerns of GDACEL have been addressed.
1
Of significant concern too is the fact that the there was expansions to the existing sewerage works and the erection
of structures within a wetland without the permission and authorization from the Gauteng DACEL. It was
furthermore submitted that the DME’s acting as lead agent with respect to the extension of the above mining
activities raises the following issues: “The nomination of a lead agent is an indication that the lead agent cannot
make decisions without the involvement of other departments. A key role of the lead agent is therefore to coordinate the comments received from other government departments. Its responsibility will also include drafting
policy, promulgating legislation and securing compliance with its legislation. This does not mean that where a
department is a lead agent for a “business sector’ it automatically assumes responsibility for issuing authorizations,
which fall within the authority of another department. A preferable interpretation is that the EIA regulations include
a list of activities over which it (DME) does not exercise specific control and that EIA regulations will apply where
a mine intends undertaking an activity that is listed in the schedule. This interpretation does not however emphasize
the need for co-ordination between government departments so that work in respect of assessments by the proponent
is not duplicated.”
GDACEL requested further information and the proposal of mitigatory measures since it was stated: “DACEL is
concerned about the information contained on page 41 of the document, which refers to existing water pollution.”
There is no documentary evidence that this request has been complied with.
2
Personal communication, Mr. Phillip Jacobs of GoldFields.
PROPOSED FOCHVILLE/GELUKSDAL DISPOSAL
IMPACT UPON THE LEEUWSPRUIT CATCHMENT
OPTION
AND
FORSEEABLE
The relevancy of the South Deep Mine3 to the site selection of the proposed disposal option lies
in this:
The South Deep mine is situated in the catchments of the Leeuwspruit, Kariegaspruit and
Loopspruit. The Leeuwspruit, which drains the South Shaft area, is a tributary of the Rietspruit
which is a tributary of the Vaal River.
The Leeuwspruit, a small stream, drains the South Shaft area of the South Deep mine in a
southerly direction, via the Rietspruit, towards the Vaal River (the Vaal Barrage is about 55 km
away from the mine). The Leeuwspruit contributes about 5.6% of the flow to the Rietspruit.
Kloof Mine is located upstream of the South Deep Mine in the Loopspruit catchment which
drains southwards. The waste rock dump of South deep Project is located on the watershed
between the catchment areas of the Loopspruit and Kariegaspurit and runoff runs west towards
the Loopspruit (about 1.2 km from the waste rock dump) and east towards the Kariegaspruit.
The Loopspruit joins the Leeuwspruit about 10km away from the mine.
In terms of Figures 3 to 6, it is believed that the Fochville area (Raatskraal area, formerly
belonging to Mr. Ben Rabe) has been selected as an available area as a potential Tailings Storage
Facility site for all different sized TSF footprints, namely a) 250 ha, b) 500 ha and c) 750 ha and
d) 1000 ha. The major water course that will be impacted upon by this potential TDS site will
be, it is assumed, the Leeuwspruit. This potential TDS site falls into the catchment basin of
the Vaal River, which is the most important river in the area and a major water resource
for the most densely populated area of South Africa.
From the aforesaid findings it can be inferred that the surface water courses in the Fochville area
of the potential TFS include:
 The Leeuwspruit;
 The Kariegaspruit; and
 The Loopspruit.
In 2001, the Leeuwspruit catchment, pertaining to surface water quantity, was described as such:
“The Leeuwspruit:



3
Drains the South Shaft area, including the South Shaft gold plant;
Receives overflow from the new return water dams at the tailings dams;
Receives surplus water from underground;
The South Deep Mine is located within both the Westonaria and Emfuleni Muncipalities, and Fochville is 25 km
west of the mine.

Receives storm water runoff from Randfontein Estates Ltd. No 4 shaft (old Western
Areas Gold Mine – North Shaft upstream of PDWAJV South Deep Mine).
It was found that water, contaminated with mine effluent, exits the South Deep Operations’ plant
into the water courses used by the farmers for irrigation purposes.
In terms of the radiological report dated September 2001 by de Beer and Ramlaken of the
Nuclear Energy Corporation of South Africa (NECSA) entitled “A Prospective Assessment of the
Radiological Hazards of the Proposed New Gold Plant at the Placer Dome Western Areas Joint
Venture South Deep Operations” it was found that specific nuclide activities measured on the
waste material emanating from both the old and new processes were for U-238, Ra-226 and Pb210 lie in the range of 0,78Bq/g to 1.02Bq/g indicating that the mine effluent contains
radioactive nuclides with activities in excess of the current legislated limit of 0.5Bq/g.
In terms of the Ecomonitor Report, entitled “Radiation Survey of Farmers’ Properties Adjacent
to South Deep Gold Mine” by Dr. Pieter van Eeden, compiled by Dr. D Cawthorne (Radiation
Protection Officer) and approved by MJ Lalkhan (Radiation Protection Specialist) it was found
that:
“Water contaminated with this mine effluent, exits the plant into the water courses used by the
farmers for irrigation purposes. This is supported by the radioactivity measurements conducted
in the following locations:


On the mine property upstream of bridge number 3603 where activities up to 360cps
(equivalent to ca. 0.36Bq/g) were measured.
On the farmers’ properties where counts in excess of 200cps were measured.”
In general the water being discharged from mine property to the Leeuwspruit and within the
Leeuwspruit does not meet quality guidelines for the specified uses. Comparison of the
Leeuwspruit water quality upstream and downstream indicates possible contamination from
tailings dam seepage. Sulphate, manganese and uranium are the main parameters of
concern.
The current land and associate water usages, within the Leeuwspruit catchment have been
identified in terms of the South Deep EMPR. They are:




Agricultural (farming) activities are taking place in the surrounding areas.
Informal abstraction of water from the watercourses is taking place. The communities
settled along the streams abstract the water for drinking and domestic purposes
Livestock drink from streams on properties where they graze.
Water from the streams is used by farmers downstream of the mine, for irrigation of their
lands.
It has furthermore been found that:

Riparian zones along drainage lines and streams, which are be classified as wetlands have
relevancy to the Leeuwspruit. The Leeuwspruit, to the south of South Shaft and to the
east of the tailings dam, supports an extensive reed bed due to a continuous water
discharge from South Deep Mine. There is a small vlei area west of the existing tailings
dam, in the Kariegaspruit as well.

The range of water quality for 1999 indicates that where the values exceed the
recommended values it can be attributed mainly to the chemical composition of
manganese and migration of surface water contamination (sulphate) (Rison Consulting,
1999).

Major contributors to the total contaminant load of the Leeuwspruit are the seepages
from the slimes dams of Shaft 4 Randfontein Operations and the South Deep Operation.

Excess underground water, from South Shaft is also released into the Leeuwspruit.

From the PDWAJV Water Management System Report (Rison Consulting, African
Environmental Development and Randfontein Estates Limited, 1999) it is concluded that
the total pollution load of the Leeuwspruit downstream from the South Deep Mine is
greater than the combined total of the actual point discharges from the mine. This
indicates that diffuse sources, such as the tailings dams, could be contributing to the
pollution load.

In general, the water being discharged from mine property to the Leeuwspruit and within
the Leeuwspruit does not meet quality guidelines for the specified uses. Sulphate,
manganese and uranium are the main parameters of concern.

The shallow aquifer is the most vulnerable to contamination.

With reference to the deep aquifer it is believed that three dolomitic ground water
compartments are implicated, namely to the east, the Gemsbokfontein compartment is
being dewatered by Harmony Gold Mine – Randfontein No 4 Shaft; to the west, the
Venterspost compartment has been dewatered by Kloof Gold Mine; and the Ventersbok
compartment.

Water is also discharged to the Leeuwspruit from the mine workings of the Randfotein
Estate No. 4 Shaft. Inflows of water occur through the haulages of 50 and 58 levels that
link the mine operations at South Shaft to Randfontein Operations No 4 shaft. This water
is utilized by farmers along the Leeuwspruit (Rison Consulting, 2001). It is believed
that plugs have been constructed to stop this inflow (personal communication: Mr.
Phillips Jacobs of GoldFields).
Grounded upon the aforesaid findings the Gauteng Department of Agriculture, Conservation,
Environment and Land (GDACEL) submitted in a letter, reference number GAUT 003/0102/102/GN/W/ML/ME/A, DME Reference Number PWV 6/2/2/286 &PWV 5/3/2/914:
“The water quality results on page 41 of the document significantly exceed both irrigation and
livestock water quality requirements for a variety of parameters. The cumulative impacts of the
new shaft and plant should be discussed, and the contribution determined. There is no
discussion regarding mitigatory measures to combat the already compromised water. Any
possible further contribution to the water quality in this area should be regarded as
significant. Noting the findings of the document ‘Comparison of the Leeuwspruit water quality
upstream and downstream indicates possible contamination from tailings dam seepage.
Sulphate, manganese and uranium are the main parameters of concern.’ The mitigatory
measures being implemented is concerning, this concern is exacerbated by the fact that this
water is used for crop irrigation as well as for drinking water for livestock. The document also
makes reference to abstraction for drinking and domestic purposes.”
(Emphasis added.)
SULPHATE LOAD AND THE ECOLOGICAL INTEGRITY OF THE LEEUWSPRUIT
I shall now briefly advert to the WRC Report No 800/1/00, entitled “An Economic and Technical
Evaluation of Regional Treatment Options for Point Source Gold Mine Effluents entering the
Vaal Barrage Catchment” by R Pilson; HL van Rensburg; CJ Williams. The relevancy of the
said Report to the proposed disposal options for Rand Uranium’s TSF is in that:
1. Leeuwspruit, flows towards the Rietspruit, and towards the Vaal Barrage.
2. Recent studies have indicated that four gold mines (Grootvlei, DRED, WAGM –
Randfontein No 4 shaft – and ERPM) are contributing as much as 26% of the salt load
entering the Vaal Barrage by way of point source discharges. It has further been
estimated that this salt load is contained in only 5% of the flow.
Since approximately 1998 the farmers within the Fochville area have noticed that the quantity
and quality of their crops, produce and livestock production have deteriorated. There is a strong
assumption that this deterioration is related to the significant salt load and heavy metals from the
mine effluent into the Leeuwspruit Catchment. I refer you in this regard to the case studies of
Prof. Andries Oosthuizen, Prof. Coetzee Badenhorst, and Mr. Pieter Rheeder. Mr. Pieter
Rheeder has been compelled to terminate his farming activities as a direct consequence of the
poor quality of his groundwater. The river bed and flood plains of the Leeuwspruit are visibly
contaminated and the pollution from the mine effluent has had a significant detrimental impact
upon the aquatic biota with a visible absence of freshwater vertebrates, invertebrates and plants.
The borehole water, the only available water source, of Mr. Pieter Rheeder is no longer fit for
human and animal consumption. Furthermore, the water table of Prof. Oosthuizen has been
significantly lowered and there is alleged seepage of polluted water from the Kloof Mine into his
property.
Kempster et al (1991) recommended a median sulphate concentration of 1400 mg/l above which
unacceptable impacts will probably occur to biota in the river. In terms of surface water quality
of the Leeuwspruit I refer the reader to pages 41 and 42 which pertain to the surface water
quality data at South Shaft and South Deep Shaft during January 1998 – December 2000. The
data of the surface water quality of the Leeuwspruit, however, cannot be conceived as a wholly
complete and uncontested set of accurate data.
It can logically be inferred that an additional salt and heavy metal load upon the Leeuwspruit
and consequently upon the Vaal Barrage will have far-reaching, long-term and detrimental
impacts. To protect the ecological integrity of aquatic eco-systems and human health, the current
situation not only has to be addressed with immediacy and urgency but additional pollution of
the Leeuwspruit must be prevented.
CONCLUSION
From the aforesaid it can be logically inferred that an additional pollution load from mining
operations, such as the one specific proposed disposal option for the TSF upon the Leeuwspruit
will compromise the carrying capacity and ecological integrity of the Leeuwspruit.
The following expert opinion has relevancy:
Complex ecological problems have arisen because of the loss of dilution capacity in the
river systems. (Reference: “A South African perspective on a possible benefit‐sharing approach
for transboundary waters in the SADC region”. Water Alternatives 1(2) A. Turton, A. 2008.
CSIR. )
Because the flow in most of our rivers is dependent on rainfall, and the country is prone to
serious droughts, dilution can therefore not be considered as a mitigation measure.
It will be unacceptable for downstream users to carry additional costs as they attempt to cope
with water of lesser quality. Currently pollution, which is not cleaned up at source by
GoldFields and presumably by Harmony Gold, has been passed on to other users within the
Leeuwspruit. The highest cost burden of combating salinity and heavy metals is currently
being carried by the household and agricultural sector and not by the mining industry as might be
expected in terms of the Polluter Pays Principle.
Effective and equitable compensation is not readily put in place and it can hardly be
foreseen that this oppressive and inequitable situation will be corrected within the near
future. I here refer you to the legitimate grievances of inter alia Mr. Dawie Lotter and Mr.
Coetzee, of Randfontein, Prof. Andries Oosthuizen whose property is adjacent to Kloof Mine
and Mr. Pieter Rheeder whose farming operations have been terminated as a result of the alleged
South Deep operations’ pollution of the Leeuwspruit as well as the Potgieters of Pitchers Eden
within the Gerhard Minnebronne, and Messrs Douw and Sas Coetzee from the farm
Blaauwbank. There has been no relief or remedy effected, at the time of writing, for the
significant pecuniary losses, alleged health impacts and sentimental damage which the
aforesaid persons have suffered for a decade or more. The burden of proof or onus has
been very cheaply outsourced to the affected parties notwithstanding the provisions of the
National Water Act, (No 36 of 1998), the Minerals and Petroleum Resources Development
Act, No 28 of 2002 and the National Environmental Management Act, No 107 of 1998 that
it is only necessary to show that the responsible person, that is, the director or directors of
a company, at the time failed to take reasonable measures, which implies a strict, almost
absolute liability since such failure to take reasonable measures, of even if the pollution
impacts were caused inadvertently, automatically invokes the liability.
RECOMMENDATIONS
It is my respectful and modest opinion that the Directorate: Resource Protection & Waste’s Best
Practice Guidelines for Water Resource Protection in the South African Mining Industry,
pertaining to Pollution Control Dams (A4) and Water Treatment (H4), have significant relevancy
to the proposed initiative and must be implemented.
While cognizance has been taken of the reasons why treated tailings cannot be disposed of
underground, it is noted that, in terms of the Best Practice Guideline – H4: Water Treatment,
September 2007 the following was proposed as possible disposal options for waste/residue:
“Settling ponds
Tailings/ Slimes Dams
Dumps
Off-site
Deep mines
This disposal method is not widely implemented but can be considered for large volumes of
waste with low environmental risk and would be subject to the appropriate regulatory approval
process. Benefits include potential reduced risk of subsidence due to filling of mine voids with
solids; potential neutralization of mine water by excess alkaline materials in the sludge;
reduction in surface land space occupied by permanent storage of residues; and potential
isolation of sludges from the near surface environment exposed to rainfall infiltration and
leaching. Feasibility will depend on sludge characteristics, geology, water flow paths and sitespecific conditions.” - Page 28.
SUBMITTED BY: MARIETTE LIEFFERINK.
FOR THE FEDERATION FOR A SUSTAINABLE ENVIRONMENT.
DATED: 5 OCTOBER, 2008.