As the appointed convener (albeit, at the time of writing, the impotent convener, since members of the Mining Interest Group, that is, the historic polluters, have not approved the budget for the public participation process) of the public involvement and participation component of the remediation of the Wonderfonteinspruit Catchment area, I deem it my moral and social duty to provide the Remediation Action Plan for the Wonderfonteinspruit Catchment Area to you.
The final draft of the said Plan was supplied to representatives of the public, (Dr. Koos Pretorius and I) on Friday, the 8th instant during a meeting with the regulatory authorities (DWAF and the NNR, reporting to the Department of Minerals and Energy). Representatives of the Mining Interest Group and the Chamber of Mines were invited to the meeting as well. Regrettably, representatives of the MIG and the Chamber of Mines failed to attend the meeting hence are not in possession, I think, of the document, which is now in the public domain.
From the foreword of the document you will infer that the purpose of this noble and laudable initiative was to determine a logical process to start the clean up action for the Wonderfonteinspruit Catchment. The approach was that any radioactive material that is not properly disposed of on a licensed disposal area, or that has been dispersed from such an area, must be cleaned up due to its potential to pose a health hazard to members of the public.
Identified areas from previous investigations were used as a starting point, and the list is not intended to be exhaustive or final.
The overriding intention is to start with the clean up action as soon as possible, and not to wait until everything is known. The polluter pays principle will be applied. The internalization of negative externalities is a paradigm shift from an environmental and mining perspective and worthy of high praise.
Of particular value is Appendix C, entitled “Identification and Classification of Areas of Intervention which was compiled by Prof. Dr. Frank Winde. We are informed that the scope of the areas of intervention was defined by the following limitations:
In accordance with the core mandate of the DWAF only sites contaminated through water-borne pollution are to be considered (i.e. no airborne pollution, radon exhalations, use of tailings as construction material, people living on or near tailings deposits etc.);
- In accordance with the mandate of the NNR only mining-related radioactive pollution will be addressed, i.e. ignoring possible non-radioactive, toxic contaminants such as heavy metals, organic compounds or bacteriological pollution;
- Only sites are to be considered which may pose a risk to members of the general public;
- Only sites within the boundaries of the Wonderfonteinspruit catchment are to be included in the map.
- Three reports were used in identifying the intervention sites. In accordance with the three selected reports the scope of the map (areas of intervention) is confined to two principle environmental media of concern:
- Water (including surface water, groundwater, mine effluents); and
- Sediment (mainly fluvial sediments from streams and dams but partly also including soils and eroded tailings material)
Possibly existing data relating to sites at which elevated levels of radioactivity were found in organisms (e.g. aquatic animals, plants, algae, etc) or elements of the food chain (crops, vegetables, live stock, milk, eggs etc.) are excluded. Excluded are also all other possibly existing data on radioactive pollution not covered in the three listed studies.
The reason why the decision was taken to remediate the areas of radiological risk, notwithstanding the fact that the chemical toxicity risks of U dominates over the radiological risks, is found in the statement:“The presence of naturally occurring radioactive materials (NORM) in the WCA have received much media attention in recent months which has escalated the perception of radiological contamination. There is now a greater degree of awareness and concern in the catchment of the presence of elevated levels of naturally occurring radioactive materials associated with past and ongoing mining activities.
I do not call for a response to the contents of the appended document, however, your expert opinions will be of significant value to the ordinary members of the public or the so-called “man in the street,” particularly the “vulnerable and disadvantaged” and indigent members of affected communities (please see Section 4(f) of the National Environmental Management Act, 107 of 1998).
Mariette Liefferink.
FEDERATION FOR A SUSTAINABLE ENVIRONMENT.
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