While the FSE is in support of the re-mining of historical tailings storage facilities and the reclamation of Au, U and sulphur and the consolidation of mine residue in a regional tailings storage facility, the FSE wishes to raise the following issues of concern and call upon the Applicant to address these [an extract from the document which is available to download in full]:
- In the past dump reclamation activities, a number of cases have been identified where the re-mining of dumps was not completed, either due to a lack of funding on the part of the miner or due to the heterogeneity in the dumps which were mined. Any new application to exploit mine residues should only be approved if it involves the removal of an entire residue deposit and the rehabilitation of the remaining footprint. If this is not the case, rather than consolidating contaminated sites, the reprocessing activities result in the creation of two contaminated sites, where one previously existed.
- The past practice of granting rights and authorization for the reprocessing of individual residue deposits may need to be reviewed insofar as it allows the selective extraction of value from portions of a site without ploughing some of that value back into the rehabilitation of the entire mining area. It must be accepted that the reprocessing of some mining residues will never be economically viable and that these will need to be transported to the regional tailings storage facility.
- Radiometric surveys over previously reprocessed mine residue deposit footprints have, in some cases, shown elevated levels of residual radioactivity in soils. In these cases, it must be accepted that some areas will never be suitable for unrestricted development and that these areas will need to be demarcated as such, and appropriated land-uses proposed and implemented.
- The latent impacts on biota, including humans, of bioaccumulation and exposure to elevated levels of metals and NORMs are established in the international scientific literature. The mining industry should have gained enough experience from the asbestosis and silicosis catastrophes in South Africa to justify application of precautionary principles in respect of other suspected latent impacts. We recommend that gold mining operations in South Africa adopt the precautionary approach, and consider the following risks when determining re-mining, rehabilitation, closure and financial provisions for rehabilitation and closure:
- The near certainty of contaminated water, which will require some form of decontamination treatment, decanting from closed underground mines, or from lower-lying interconnected neighbouring mines;
- The near certainty of sulphate, chloride, metal and NORM contamination of soils and sediments by seepage from unlined tailings storage facilities (TSFs), tailings spillages and plant discharges and the potential for contamination of downstream /downwind soils and sediments;
- The near certainty of sulphate, chloride, metal and NORM contamination of surface water bodies and their sediments, and ground water, by seepage from unlined tailings storage facilities, tailings spillages, plant discharges and underground workings. In addition, the potential contamination of surface soils overlying shallow polluted groundwater via evaporative pathways during dry seasons.