9 March 2012
Earthlife Africa Johannesburg(ELA Jhb) and the Federation for a Sustainable Environment (FSE) commends the South African Human Rights Commission for their organisation and facilitation of the two-day workshop: “Exploring options for treatment of acid mine drainage (AMD).” The initiative resulted in a way forward to address some key concerns relating to the AMD action plan for the Witwatersrand and the way in which it is being implemented.
For the first time since the Inter-ministerial Committee’s “Team of Experts” report was made public in February 2011[i], representatives of non-governmental organisations, people living in areas directly affected by acid mine drainage, mining companies, engineers and scientists had the opportunity to present and discuss their concerns with senior officials from the Department of Water Affairs and senior staff of the Trans Caledon Tunnel Authority (TCTA)[ii].
By the end of the workshop, there was consensus on three key issues:
The lack of a desalination process in the short-term action plan: The current plans are to remove most of the metals from the acid mine water[iii] but not the sulphate salts[iv]. Civil society groups such as ELA Jhb and the FSE have raised concerns about this in the past. Our concerns are not unfounded and it was agreed by all in the workshop that discharging huge volumes of water with such a high salt load will severely impact our future water supplies, and affect natural ecosystems. The Department of Water Affairs already predict that by 2014 the Vaal River will have so much salt in it that it will have to be diluted with fresh water discharged from the Vaal Dam.
Why not include desalination in the short-term plans? TCTA and DWA say it is too costly. But FSE have information that suggests otherwise. It was agreed that these parties would meet to explore this option further.
The potential lack of alignment between the immediate and short-term plans currently being implemented and the long-term plan that is still being developed and details of which have yet to be disclosed to the public is of concern. In the absence of a clear vision of a sustainable plan for managing AMD in the long-term, there is a danger that work conducted now may either need to be undone or inhibit the implementation of more effective processes at a later stage. It was agreed that this was something that needs to be discussed and resolved by senior officials of DWA.
Non-compliances in the current Environmental Impact Assessment (EIA) process. It was acknowledged that due to the urgency of the AMD crisis on the Witwatersrand, construction work was proceeding in parallel to the EIA. This has legal ramifications. There is also a danger that it will set a precedent for future development projects deemed to be related to “emergency” situations. It was agreed that a legal way to resolve this problem would be to undertake the impact assessment under a section 24G application for rectification.[v]
The inadequate public participation process so far. ELA Jhb’s concerns about this were raised at the end of February[vi]. TCTA have agreed to review their public participation and stakeholder engagement strategy.
Other concerns: ELA Jhb and FSE will be engaging with the current EIA process and submitting a list of questions to be investigated during the EIA over the next few months. These include issues related to the disposal of the toxic sludge and the radioactive elements in the acid mine water.
ELA Jhb and FSE remain deeply concerned that an issue of such potentially enormous consequences for the environment, public health and the economy continues to receive less attention and resources than it requires.
TCTA has made documents related to the immediate and short-term implementation plans available on the website: www.amdshort.co.za
Earthlife Africa Johannesburg, Branch Co-ordinator: Judith Taylor Tel: 082 389 3481
Federation for a Sustainable Environment: Mariette Liefferink: Tel: 011 787 7965 cell: 073 231 4893
[i] For a copy of the report, and initial comments of it, see: http://earthlife.org.za/?p=1543
[ii] TCTA is the organisation that has been directed to implement the government’s intermediate and short-term AMD action plan for the Witwatersrand.
[iii] Metal removal will be done through neutralisation – a process of adding lime to the acid mine water so the metals fall out (precipitate) of the water, forming a sludge at the bottom of the settling tank.
[iv] According to current plans the water discharged into streams would contain about 2000mg/l to 2500mg/l of sulphate salts. Water with over 600mg/l (current SANS 241 regulatory limit in Class II potable (drinkable) water) can cause diarrhoea in sensitive people.
[v] Refers to Section 24G of the National Environmental Management Act (NEMA)
[vi] See ELA Jhb media release of 24 February: http://earthlife.org.za/?p=1772