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Comment:Proposed Classes of Water Resources

Written by  Thursday, 06 November 2014 20:18
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Comments on the Proposed Classes of Water Resource for Catchments of the Crocodile (West), Marico, Mokolo And Matlabas in terms of  Section 13(1) (A) of the the National Water Act, 1998, Act No 36 Of 1998


In view of the key water challenges, which were identified in the Business Case for the Limpopo Catchment Management Area, namely:

  • "Water resources nearly fully developed with all available water being highly utilised
  • Limited options for further resource development exists - attributable to the arid climate, unfavourable topography, sandy rivers as well as important conservation areas
  • Resources and requirements approximately in balance at present
  • Implementation of the Reserve is expected to result in serious deficits in some of the main river catchments
  • Planning has been made for large new mining developments in the Mokapane-Mogoto area for which additional water will be required
  • Urban and industrial growth will mainly be concentrated in the Johannesburg, Tswane and Polokwane areas, where local water resources already are in short supply and need to be augmented by transfers from other WMAs.
  • There are severe eutrophication problems at dams in the WMA.
  • Possibility for new power stations and/or petrochemical industries to be developed around the coalfields in the Lephalale area
  • Water pollution owing to large quantities of effluent discharged into the rivers in urban and industrial areas in the WMA

We are of the considered opinion that it would be of vital importance to, prior to the issuing of the proposed classes under section 13(4) of the National Water Act (NWA), that the Resource Quality Objectives for the Catchment be determined.

It is our understanding that the Resource Water Quality Objectives (RWQOs) provide a mechanism through which the balance between sustainable and optimal water use and protection of the water resource can be achieved and to establish clear goals relating to the quality of the relevant water resources. The RWQOs will provide the basis for determining the allocable water quality and the water quality stress and are based on the designated users of the water resources. The classification of proposed classes of water resources should be aligned with the RWQOs.

Please download the entire comment. 

Comments and Request for Information Pertaining to the Determination of Resource Quality Objectives in the Upper Vaal Water Management Area Draft Resource Quality Objectives Report (Draft 2) Resource Quality Objectives And Numerical Limits Report

....civil society is fully competent to fully conceive the risks of:

  • sulphate, chloride, metal and TENORM contamination of soils and sediments, surface water bodies, ground water,
  • the contamination of crop soils irrigated with contaminated surface water or contaminated groundwater,
  • the concomitant loss of genetic/biodiversity and potentially ecosystem goods and services on disturbed, fragmented or polluted properties
  • bioaccumulation of some metals and TENORM by flora and fauna
  • the exposure of fauna and humans to bioaccumulated pollutants
  • acute and latent toxicity impacts of bioaccumulated pollutants on humans and the potential for radioactivity impacts from TENORMs on humans

as a result of gold mining. The gold deposits on the Witwatersrand Basin naturally co-occur with uranium, other NORMs and metals such as Mg, Cu, Zn, Mn, As, Ni, Cr, Co and Pb. In addition, long-lived cyanide-metal complexes persist in tailing storage facilities. The latent impacts on biota, including humans, of bioaccumulation and exposure to elevated levels of metals and TENORMS are well established in the international scientific literature.

In view of the above-mentioned we strongly recommend that a precautionary or risk averse approach be adopted in the determination of RQOs for the Upper Vaal.

Suikerbosrand River

We have a perplexing difficulty which we are trying to solve.  Such is the difficulty:   Why were the values for sulphate and U not determined in the RQOs for this IUA?  And, what is the numerical value of sulphate within a D category – 200mg/l, 500mg/l or more?  Will the sulphate levels within a D category render the water fit for use for its users?  We respectfully request you to please assist us in this regard.

Kliprivier (Gauteng)

The short- and medium term treatment of AMD is currently releasing approximately 40ML/d highly saline water into the Elsburgspruit which flows into the Natalspruit and eventually into the Klip River.  Sulphate concentrations will therefore increase dramatically as a result of the discharge of neutralised AMD but also as a result of the added mine drainage seepages from surface mine residue deposits.


Partially treated mine water was discharged into the Blesbokspruit system and indirectly into the Rietspruit thus polluting the water in this river system and changing its ecology.

With the flooding of the Grootvlei Mine, the pumping stopped and pre-mining flow patterns and volumes were restored. The short and medium term treatment of AMD within the Eastern and Central Basins involves pumping and the discharge of approximately 60 – 80 ML/d and approximately 40ML/d of highly saline water into the Blesbokspruit and the Klipriver.

Please download the complete document. 


Chris Dickens of the Institute of Natural Resources NPC responded:
The Klip River (Gauteng) (UJ), the Mooi River (UL), Blesbokspruit River, the Boskop Dam, Donaldson Dam, and the Gerhard Minnebron (considered as a wetland in the study) have indeed all been prioritised/have RU’s. Erroneously we did not link the name of some of these rivers to the prioritised RU correctly in some versions of the report (Suikerbosrand, Blesbokspruit and Klip River) for which many of the salt and toxicant RQOs were already determined. This has now been corrected in the report.
Where recommendations were made (and justified with literature) we have added appropriate RQOs to address your comments for all of these ecosystems. Some of the variables that may pose a threat of toxicity to human health through direct contact and consumption of fish (excluding consumption of water) have not been included in prioritised RUs as very little information is available to propose a numerical limit for these toxicants. However the following regional requirement for the IUA has been included that should cater for this concern: “The consumption of fish harvested from rivers in the IUA must not pose a threat to human health. The water quality in the rivers of the IUA must not pose a threat to human health through direct contact (excludes consumption of water)”.
In consideration of the dam RQOs we have added Uranium as a toxicant where applicable and the narrative that: “There is potential of toxicity of heavy metals associated with AMD and radioactive nucleotides. The water quality in the rivers/dams of the IUA must not pose a threat to human health through direct contact (excludes consumption of water)”. This addresses the requirement for toxicity consideration for the dams. This includes the wetland ecosystem “Gerhard Minnebron”. Finally although we acknowledge that sediment plays an important role in the storage of toxicants we have only considered the threat of toxicity in water which is more in contact with the ecosystem and people. Monitoring of sediments is a possibility but has not been included for practical reasons.
The advantage of making use of a “D EcoStatus” category is that this refers to the minimum allowable integrity state of an ecosystem which is still in a sustainable state. What this means in terms of WQ concentrations, is that no matter how good or bad the science is, it still needs to be demonstrated that the ecosystem is in a sustainable state. Thus this protects us against bad science. Having said that, this EcoStatus of a D does not determine acceptability for human use, however it is the general situation that the two are aligned. Things like radioactivity are in fact more easily tested against the ecosystem as the biota are exposed 24 hours per day, and if they do not show excessive negative impacts, then it could be concluded that the water is safe for humans.



THE DAILY VOX: ‘Jozi Gold’ Documentary Examines The Dark Heart Of Mining In SA

ORIGINAL ARTICLE AVAILABLE HERE.   Article By Fatima Moosa - June 13, 2019   Mining activities have wreaked havoc across South Africa, in a variety of communities. Big companies come to the communities, mine the land, and then leave. This leaves the community to deal with the aftereffects of the mining. These include polluted water sources, dirty air, and an unsafe living environment. Jozi Gold is a documentary that wants to raise awareness about this. Jozi Gold is a film-documentary made by Sylvia Vollenhoven & Fredrik Gertten. Gerten is a Swedish director and journalist while Vollenhoven is a South African writer, journalist, playwright and filmmaker. The doccie took seven years to make and “required a lot more resources and a lot of energy to manage the story process,” said Vollenhoven. The documentary showed at the Encounters South Africa, an international documentary festival. The festival took place from 6-16 June in Cape Town and Johannesburg. “It’s the premier industry event for documentary filmmakers,” said Vollenhoven about Encounters adding that it’s a great platform to watch documentaries from around the world. Vollenhoven says Encounters fills in the gaps sometimes left by local broadcasters where the focus in on “quantity and not quality.” The documentary looks at the environmental and political picture of South Africa’s abandoned mines. Vollenhoven told The Daily Vox that the documentary looks at the huge environmental impact of mining. “They are leaving behind an environmental mess that is not being cleaned up. People like Mariette are working tirelessly to raise awareness and force mining companies and the government to clean up,” she said. Jozi Gold follows Mariette Liefferink, an advisory committee member of the South African Human Rights Commission. The documentary deals with issues that investigative reporter Adam Welz has written about for years through following the work of Liefferink. Welz began working on a documentary film about the mining industry. He then made contact  with Gertten’s film company WG Film. Gertten contacted Vollenhoven and thus began the project. “It’s a remarkable co-production between Norway, Sweden, and South Africa,” Vollenhoven told The Daily Vox about how the project developed. In 2018, The Daily Vox team visited the Snake Park community in Soweto. The community lives in the shadow of a mining dump. Just like the many communities in South Africa the mine severely affects the health of the people living there. Many of the children in the community have cerebral palsy which experts have linked to the effects of the abandoned mine. It is communities like this that Jozi Gold aims to shine a spotlight on. Liefferink who is the central figure of the documentary is widely recognised as a prominent environmental activist in the mining industry. Vollenhoven said they decided to center the documentary on Liefferink because “of her style of activism and how effective it is.” Vollenhoven said Welz have been following Liefferink’s work and when they saw the footage he had gathered “we agreed undoubtedly that Mariette is any filmmakers’ dream.” To continue showing the film beyond the festival, Vollenhoven says they’ve designed a six-month outreach programme to show the film to communities around South Africa, especially “mining-affected communities.” “It’s about taking the film out there and not just showing the film but using the film as a way to create awareness to assist activists and NGOs to combat this huge environmental disaster,” said Vollenhoven. To get in touch with Vollenhoven and organise a screening and discussion of the documentary, you can contact her via email. (This email address is being protected from spambots. You need JavaScript enabled to view it.).   ORIGINAL ARTICLE AVAILABLE HERE.

CITY PRESS: Jozi Gold reveals shocking truths about mining pollution

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Mintails placed into final liquidation

BUSINESS DAY Mintails placed into final liquidation Department of Mineral Resources will join long line of creditors hoping to recoup money 20 September 2018 - 17:27 Lisa Steyn

BUSINESS DAY EXCLUSIVE: Liquidation allows Mintails to shirk environmental liabilities

21 August 2018 - 05:04 Mark Olalde   Pollution: Water resource management consultant Anthony Turton, with the Mintails gold plants and water treatment tanks in the background. Picture: BUSINESS DAY/FREDDY MAVUNDA Mintails Mining and several related companies have announced their liquidation, throwing into question the environmental rehabilitation of highly polluting operations near Johannesburg. Mintails mines and processes gold from a sprawling 1,715ha complex of waste piles and open pits in Krugersdorp and has for years been flagged for noncompliance. Its operations are bordered by informal settlements and suburbs housing thousands of residents, many of whom have complained of health effects, which they blame on radioactive dust and water pollution from Mintails’ mines. Records show that the cost to clean up the environment would be about R330m, but there is only R25.6m available. Observers fear that the situation could deteriorate further, as happened at the Blyvooruitzicht Gold Mine, an abandoned large-scale operation on the West Rand. A case study in the country’s deeply flawed mine closure system, Mintails teetered on the verge of collapse for years and entered business rescue in October 2015. Mariette Liefferink, the activist CEO of the Federation for a Sustainable Environment, tracked Mintails for more than a decade and is now working to intercede in the liquidation proceedings as the legal voice for what she labels the "mute environment". "There was poor planning. [Mintails’] due diligence was flawed. They overestimated the gold grade and the resource that could be reclaimed. "They continued to exploit the resource, to reclaim only the profitable parts and never top up the financial provisions," Liefferink says. As the company slips into liquidation, it passes the brunt of its environmental liability to taxpayers and, to an extent, to other mining companies. After Mintails fought for nearly three years to save the company, business rescue practitioner Dave Lake notified the Johannesburg high court in early August of his intention to liquidate the company. Provisional liquidation was granted on August 17 and a liquidator is expected to be appointed soon. THERE IS NO LONGER A REASONABLE PROSPECT OF RESCUING THE COMPANY. The business rescue plan called for the refurbishment of a gold ore processing plant but, according to a memo dated August 1 that Lake sent to the court and to affected parties, it failed when multiple investors ceased funding Mintails. "There is no longer a reasonable prospect of rescuing the company," the memo read. The liquidator will now decide how to pay back creditors with the remaining assets. Environmentalists fear this process could leave environmental liabilities low on the list of what deserves money. According to the business rescue plan, written in December 2016, Mintails owed various creditors more than R1bn, including a shortfall of about R300m in reclamation funding. Due to a web of involved companies, it remains unclear if a large portion of the already insufficient financial provisions can be accessed for environmental cleanup. DRDGold formerly held one of the mining rights and the corresponding trust fund, which are now in the Mintails group. DRDGold CEO Niël Pretorius says he believes that the trust fund contained R18m but he did not identify the trustees, whose consent is vital to unlocking the money. Documents show the Mintails group acknowledged that rehabilitation would probably cost between R300m and R336.5m, but it declined to top up financial provisions. According to the environmental management programme from one of Mintails’ mining rights: "These liabilities are also historic and predate Mintails’ involvement and should thus not be for Mintails’ account." Experts debate this narrow interpretation of the law. Lake wrote in the business rescue plan: "The Mintails group’s rehabilitation liabilities have remained largely unfunded for some time, and there are simply no free funds available to the [business rescue practitioner] to enable him to immediately provide such funding." Legal Resources Centre attorney Lucien Limacher is representing the Federation for a Sustainable Environment. "This is a trend that has been occurring for a couple of years where mining companies have undertaken a business rescue plan or have applied for liquidation because they have failed to really look after the rehabilitation fund," he says. The Legal Resources Centre sent letters to several government agencies, including the department of mineral resources, the department of water & sanitation and the department of energy, asking them to intervene in the situation and threatening to pursue legal action if the department of mineral resources fails to act. Department of water & sanitation spokesperson Sputnik Ratau says they are "engaging Mintails so that the immediate measures can be put into place to ensure water resources protection. A longer-term plan is required to ensure rehabilitation of the mining-impacted areas." Lake declines to answer questions about the failed business rescue and the liquidation but he wrote for Moneyweb in January 2017 and laid out his argument for Mintails’ use of business rescue: "Mintails was sick – but it wasn’t terminal." Now the situation has become what Liefferink calls "pass the parcel", with Mintails playing the part of a "scavenger company", a term coined by researchers to describe under-resourced outfits that buy the scraps left over from larger mining companies and ultimately abandon them. Large gold, coal and platinum mines rarely, if ever, properly close in SA and there wasn’t one large-scale mine in Gauteng that achieved full, legal closure between 2011 and 2016. Mintails’ case will not affect the law that ring-fences financial assurances for reclamation, Limacher says. "But it is precedent-setting in that mines might now start applying for liquidation to avoid paying the cost of rehabilitation." Mintails’ West Rand concessions came in part from DRDGold, which also remines waste piles, and from Mogale Gold, which was in judicial management when Mintails acquired it in 2006. Since then, Mintails engaged in a pattern of environmental degradation. For example, the department of water & sanitation found in an August 2014 inspection that Mintails transported "slurry/sludge" in unlined trenches, completed insufficient monitoring, spilled slurry from pipelines and implemented no storm water management system at a pollution control dam. In December 2016, polluted runoff from waste piles was found to be seeping through a dam wall into the Wonderfonteinspruit, which has immediate downstream agricultural uses in the community of Kagiso. Now it will largely be up to the liquidator and regulators to protect the environment and public health. "That is the pattern that seems to be followed in the gold mining industry, and, I assume, would be followed in the coal and platinum mining industries, as well. "As soon as a mine is no longer very profitable, it transfers its assets," Liefferink says. "That seems to have the tacit support of the department of mineral resources." However, the department of mineral resources sent a statement that reads: "The department will engage with the appointed provisional liquidators with the intention to safeguard the environmental and social responsibilities." Mintails former CEO Johan Moolman declined to comment except to say he quit on June 26 when he learned a new investor had bought the company. Mvest Capital agreed to purchase Mintails from Paige, a vehicle of the UK-based Harbour family, with the understanding that Mvest would inject R30m into the beleaguered company to stimulate the business rescue plan. Mvest decided against handing over the full amount, paying only R5.5m. Mvest director Matthew Moodley acknowledges the initial agreement and the R5.5m. He says that after a month it became apparent the deal would require more investment to succeed. "With the increased need for working capital in July, Mvest took a decision to withdraw from the transaction," Moodley says, adding that Mvest did not "conclude a transaction with Paige". Liefferink says these companies are all "jumping from a sinking ship". She fears Mintails will go the way of the abandoned Blyvooruitzicht Gold Mine, which was once one of the country’s most productive gold operations and is now a source of pollution, violent illegal mining gangs and headaches for adjacent mines. Mintails has followed a strikingly similar pattern. In the Blyvooruitzicht case, two companies, DRDGold and Village Main Reef, almost completed a business deal to sell the nearly exhausted mine and both walked away, claiming the other carried responsibility. "That whole area, just like Blyvooruitzicht, will be left like it is," Liefferink said. While neighbouring mining companies will probably have to pump water from the void in Mintails’ absence, the consequences of "the dust fallout and the toxic water in the river systems" will be carried by communities and by the municipality. Additional reporting by #MineAlert manager Tholakele Nene


2019 Status Report: Continuation of the Integrated Vaal River System Reconciliation strategy Study (Phase 2)

The report by the Department of Water and Sanitation is attached for download.  


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