Registration Number: 2006/217972/23

NPO NUMBER: 062986-NPO

ABSTRACT

As early as 1987, the US Environmental Protection Agency recognised that “.....problems related to mining waste may be rated as second only to global warming and stratospheric ozone depletion in terms of ecological risk. The release to the environment of mining waste can result in profound, generally irreversible destruction of ecosystems1.”

Gold tailings dams from the Witwatersrand Basin usually contain elevated amounts of heavy metals and radionuclides. With slimes dams in the goldfields of the Witwatersrand Basin 2 covering an area of about 400 km and containing some 430 000 tons of U3O8, and 6 billion tons of iron pyrite tailings, they constitute an environmental problem of extraordinary spatial dimensions. Due to inadequate design, poor management and neglect, these tailings dams have

1 CSIR. Briefing Note August 2009. Acid Mine Drainage in South Africa. Dr. Pat Manders. Director, Natural Resources and the Environment. European Environmental Bureau (EEB). 2000. The environmental performance of the mining industry and the action necessary to strengthen European legislation in the wake of the Tisza-Danube pollution. EEB Document no 2000/016. 32 p

1 been subject to varying degrees of water and wind erosion. Effects range from water pollution, the result of acid mine drainage, and air pollution in the form of airborne dust from unrehabilitated or partially rehabilitated and reprocessed tailings dams.

As a result of acid mine drainage (AMD), from point discharges and seepage uranium is released into the groundwater and fluvial systems. (Figure 1)

Figure 1

2

West Wits Pit

Figure 2

Recent public domain official and scientific studies indicate that there is active leaching of uranium from the tailings, transport of soluble uranium species through water systems, with subsequent deposition of insoluble uranium species in sediments of fluvial systems. Sequential extractions showed that these radionuclides are distributed in multiple phases within the sediments and that they may be remobilised by environmentally plausible chemical processes2.

The Witwatersrand is densely populated. The subpopulation groups particularly at risk, are the indigent residents of informal settlements. Pollution related to the Witwatersrand gold mining industry poses a number of serious risks to surrounding communities. The major primary pathways by which contamination can enter the environment from a mine site are the airborne pathway, where radon gas and windblown dust disperse outwards from the mine sites, the waterborne pathway either via ground or surface water or due to direct access, or by living in settlements directly adjacent to mines or in some cases, living in settlements on the contaminated footprints of abandoned mines.

2 Coetzee et al. 2002. Council for Geoscience.

3

A recent study of radiological risk has identified significant risks to the public in the Wonderfonteinspruit Catchment (West and Far West Rand goldfields) due to irrigation, stock watering and other pathways3. Together with uranium, a number of other metals present in the gold ores are found in the waste streams and may pose a threat to public health. At the time of writing little information is available regarding the health risk to humans due to radionuclides, particularly at low levels. At the time of writing, there has been no public domain epidemiological or toxicological studies commissioned to determine or assess the chronic effects such as mutagenicity, teratogenicity and estrogenicity upon affected communities.

The most important lesson learnt from the studies in the Wonderfonteinspruit is that no short- cuts exist which would allow certain pathways to be ignored in a study of radioactive contamination within these mining areas4.

INTRODUCTION

The Witwatersrand5 has been mined for more than a century. It is the world’s largest gold and uranium mining basin with the extraction, from more than 120 mines, of 43 500 tons of gold in one century and 73 000 tons of uranium between 1953 and 1995. The basin covers an area of 1600 km2, and led to a legacy of some 400 km2 of mine tailings dams and 6 billion tons of pyrite tailings containing low-grade uranium6.

120 Years of gold mining activity within the gold mining areas of the West Rand and Far West Rand (Wonderfonteinspruit Catchment Area – Figure 1) and the non-internalisation of negative externalities, have resulted in "…the mean values for the Wonderfonteinspruit samples … to exceed not only natural background concentrations, but also levels of regulatory concern for cobalt, zinc, arsenic, cadmium and uranium, with uranium and cadmium exhibiting the highest risk coefficients.”

3 National Nuclear Regulator. 2007.

4 Draft Regional Closure Strategies for the Witwatersrand Goldfields. Department of Minerals and Energy. 2008.

5 *The Witwatersrand Mining Basin is composed of the Far East Basin, Central Rand Basin, Western Basin, Far Western Basin, KOSH and the Free State gold mines.

6 “A Remote-Sensing and GIS-Based Integrated Approach for Risk Based Prioritization of Gold Tailings Facilities – Witwatersrand, South Africa” by H. Coetzee. Mine Closure 2008, Johannesburg.

4

The Wonderfonteinspruit valley is densely populated because of its agricultural value and presence of gold mines. The majority of the inhabitants live in informal settlements, using contaminated ground- and stream water for personal hygiene and drinking. With above-average infection rates of HIV/AIDS and chronic and acute malnutrition, this subpopulation is particularly vulnerable to additional stress of the immune system by contaminants such as uranium.

RADIOACTIVE HAZARDS

Uranium is generally associated with the gold ores of the Witwatersrand. Uranium and its radiogenic progeny are therefore found in many of the residues and wastes produced in the mining and processing of gold7.

Uranium is identified as the principal contaminant of concern within the gold mining areas of the West Rand and Far West Rand (Wonderfonteinspruit Catchment Area). (Figure 3) Uranium is emitted by a single industry namely the gold mining industry. Uranium is radioactive and chemically toxic with an extremely long half-life. It has been shown that the risk posed by uranium, an important by-product of gold mining in the West Rand and Far West Rand and an identified hazardous component of the wastes and effluents from gold mining activities, occurs due to both radiotoxicity and chemical toxicity with, in some cases, the chemical toxicity dominating over the radiotoxicity8.

7 “Radiometric Surveying in the Vicinity of Witwatersrand Gold Mines” by H. Coetzee. 2008.

8 “South Africa’s Challenges Pertaining to Mine Closure – The Concept of Regional Mining and Closure Strategies” by D.M. van Tonder et al; “Establishing a Framework for Intervention and Remediation of Radioactive Contamination from Gold Mining – Learning from the Past” by J.F. Ellis. 2008.

5

•Tailings Dams contain 100 000 tons of U •50 Tons of U discharged annually •Seepage/Percolation: 24 tons U (1 000 to 1 million higher than the background U concentrations)

Technolgically Enhanced Naturally Occurring Radioactive Material

•Point Discharges: 12 tons of U •Stormwater: 10 tons of U •Sinkholes: Secondary Sources of U contamination

Figure 3: West and Far West Rand Goldfield

The documents that hold the history of the Wonderfonteinspruit would exceed 5m if stacked. The bibliography of relevant literature that has been compiled would, if printed, extend to nearly 120 pages. In this submission copious reference will be made to the following official public domain Reports:

 An Assessment of Sources, Pathways, Mechanisms and Risks of Current and Potential Future Pollution of Water and Sediments in Gold-Mining Areas of the Wonderfonteinspruit Catchment - Report to the Water Research Commission. Compiled by Henk Coetzee, Council for Geosience - WRC Report No 1214/1/06 ; ISBN No 1- 77005-419-7 – March 2006.

 Contamination of wetlands by Witwatersrand gold mines – processes and the economic potential of gold in wetlands - Henk Coetzee, Jaco Venter & Gabriel Ntsume - Council for Geoscience Report No. 2005-0106

6

 A comprehensive radiological risk assessment performed by German physicists on behalf the National Nuclear Regulator, the radiological risks to the public was published in the Report, entitled: Radiological Impacts of the Mining Activities to the Public in the Wonderfonteinspruit Catchment Area.

The impacts of mining in the West Rand and Far West Rand on the surface and ground water system, in particular impacts related to uranium, with elevated levels of radioactivity are well documented. It was found that tailings dams within the Wonderfonteinspruit Catchment Area contain 100 000 tons of U. Groundwater pollution arise as a result of the poorly designed and managed tailings dams, which allow leachate to seep into the underlying aquifers and due to the lateral migration of water from the shallow portions of flooded mine voids into the surrounding aquifers. An important local groundwater issue has arisen in the Far West Rand, where mine tailings dams were established in sinkhole prone areas, with the stated aim of encouraging drainage of the tailings, and where tailings were used as a fill material after the development of sinkholes in the dolomite which covers large parts of the area. In both of these cases, uraniferous tailings can have a severe impact on water quality were deliberately introduced into a major aquifer9. It was found that:

 50 Tons of U are discharged annually into the Wonderfonteinspruit.

 Through seepage/percolation 24 tons U, with concentrations1 000 to 1 million higher than the background U concentrations, enter the Wonderfonteinspruit annually.

 From point sources 12 tons of U are discharged annually into the Wonderfonteinspruit.

 Stormwater discharges10 tons of U annually into the Wonderfonteinspruit.

 Sinkholes, historically filled with uraniferous tailings, will become secondary sources of U contamination, when mines close and pre-mining flow patterns and volumes are restored.

9 “South Africa’s Challenges Pertaining to Mine Closure – The Concept of Regional Mining and Closure Strategies” by D.M. van Tonder et al. 2008.

7

It was found that the chemical risk quotient associated with drinking river water is 6,67, and the radiological risk quotient is 2,22. Both the numbers are above 1,00, meaning that there is a risk of ill-health effects by drinking water from contaminated streams in the Wonderfonteinspruit.

In terms of the NNR’s Report “Radiological Impacts of the Mining Activities to the Public in the Wonderfonteinspruit Catchment Area” it was found that:

 The measured uranium content of many of the fluvial sediments in the Wonderfonteinspruit, including those off mine properties and therefore outside the boundaries of licensed sites, exceeds the exclusion limit for regulation by the National Nuclear Regulator.

 For approximately 50% of the 47 sampling sites, the calculated incremental doses of the respective critical group are above 1 mSv per annum up to 100 mSv pa

 The radioactive contamination of surface water bodies in the Wonderfonteinspruit catchment area caused by the long-lasting mine water discharges and diffuse emissions of seepage and runoff from slimes dams poses radiological risks to the public resulting from the usage of polluted environmental media;

 The pathway sediment→SPM →cattle→milk/meat→person (“SeCa”) can cause radioactive contamination of livestock products (milk, meat) resulting in effective doses of the public in some orders of magnitude above those resulting via the pathway “WaCa.

Mining has resulted in the dispersal of radioactive material into the environment via windblown dust, (Figure 4) waterborne sediment and the sorption and precipitation of radioactivity from water into sediment bodies.

8

Air Pollution

.

Figure 4

The health effects of uranium particles inhaled are: • Small particles are carried by the inhaled air stream all the way into the alveoli. Here the particles can remain for periods from weeks up to years depending on their solubility. • Highly insoluble uranium compounds may remain in the alveoli, whereas soluble uranium compounds may dissolve and pass across the alveolar membranes into the bloodstream, where they may exert systemic toxic effects. • In some cases, insoluble particles are absorbed into the body from the alveoli by phagocytosis into the associated lymph nodes. • “Insoluble” particles may reside in the lungs for years, causing chronic radiotoxicity to be expressed in the alveoli.

The use of contaminated material and mine residues in construction has also been identified as a means of dispersal of radioactive material into the environment. Contaminated areas have been identified and the need for comprehensive monitoring and study as well as epidemiological

9 studies in affected communities are recommended. Figure 5 shows the surface distribution of radioactive material for the West Rand goldfield.

Figure 5

An airborne radiometric survey of the West Rand and Far West Rand was done for the Department of Water Affairs by the Council of GeoScience. Interpretation of the data show many of the residential areas (Carletonville, Westonarea, Khutsong,) fall within areas of high risk of radioactivity contamination. (Department of Minerals and Energy. Draft Regional Closure Strategy for the Far West Rand Goldfield. 2008.)

Direct access to mine sites and radioactive land may expose the public to risk due to direct external gamma radiation, inhalation and ingestion of radionuclides and chemotoxic metals, as well as the physical dangers inherent to mining sites, such as open shafts and sinkholes. The

10 health impact of mine residue dust is also of concern10. Witwatersrand gold residue dust has historically been perceived as a nuisance. However, the effect of silica quartz nanoparticles in the lungs is not properly understood and to what extent gold tailings dust contributes to human mental ingestion and absorption has not been investigated in South Africa11. To limit the risk due to external gamma radiation, the Chamber of Mines uses a guideline that each tailings deposit should have a 500m buffer zone surrounding it, where no human settlement is allowed. In many cases, however, this guideline has not been adhered to in the development of new settlements. RDP houses, informal settlements and a retirement village have been erected on contaminated mined land within the Randfontein and Kagiso Areas (West Rand). (Figure 6)

Figure 6. Tudor Shaft Informal Settlement which has been established upon uraniferous tailings.

The concentrations of sulphur, toxic and radioactive heavy metals are in consequence becoming enriched in sink areas and wetland sediments. Food plants are grown in the wetlands areas,

10 GDACE, 2005; Department of Environmental Affairs and Tourism, 2006.

11 “Land-Use After Mine Closure – Risk Assessment of Gold and Uranium Mine Residue Deposits on the Eastern Witwatersrand, South Africa” by M.W. Sutton et al. Mine Closure 2008, Johannesburg.

11 nearby sediments or in home gardens of the poor and there is uptake of contaminants by some vegetable species in these gardens.

The stay on contaminated sites and Mining Residue Deposits (a generic term used for waste rock dumps, sand dumps and/or slimes dams) is however not limited to the West Rand but inappropriate developments, such as RDP houses, are routinely being developed on Gold and Uranium Mine Residue Deposits on the entire Witwatersrand.

Children and the poor are most at risk and least able to cope with pollution threats.

In terms of the NNR’s “Status report on the actions arising from the study of radiological contamination of the Wonderfonteinspruit Catchment Area (WCA)” it was found:

 The study undertaken by the NNR has confirmed the presence of radioactive contamination in the WCA.  Preliminary results of analyses conducted on produce grown in the area have indicated that the dose levels are of radiological concern to the regulator.  The study has also highlighted the need for all the regulators to work closely together since the contamination includes non radiological contaminants such as heavy metals and salts.  The issues involved in the contamination in the Wonderfontein Catchment Area are complex.

In terms of the WRC Report 1095/1/02 and the WRC Report 1214/1/06:

• Andries Coetzee Dam has U concentrations of 900mg/kg

• Upper Wonderfonteinspruit has U concentrations of 1 100 mg/kg

• Klerkskraal Dam, a dam which has not received any mine effluent has U concentrations of 1 mg/kg

• The radioactivity in the Tudor Dam was found to be 10 000 – 100 000 Bq/kg12 (Figure 7)

12 Regulatory Limit: 500 Bq/kg

12

Tudor Dam -Elevated levels of radioactivity

10 000 – 100 000 Bq/kg

Regulatory Limits: 500Bq/kg

Figure 7

• The radioactivity in the Sluice was found to be 1 000 – 10 000 Bq/kg

• The radioactivity in the Andries Coetzee Dam was found to be 1 000 – 10 000 Bq/kg

• The radioactivity in the Attenuation Dam was found to be 100 – 1 000 Bq/kg

• The radioactivity in the Donaldson Dam was found to be 100 – 1 000 Bq/kg

An airborne radiometric survey of the West Rand and Far West Rand was done for DWAF.

Interpretation of the data show many of the residential areas (Carletonville, Westonarea, Khutsong, Kagiso, Randfontein) fall within areas of high risk of radioactivity contamination13.

ACID MINE DRAINAGE

At present the U and other heavy metals, such as cadmium, copper, zinc, arsenic and cobalt are adsorbed in the sediment. Plausible environmental conditions such:

13 Draft Regional Closure Strategy for the Far West Rand Goldfield. Department of Minerals and Energy. 2008.

13

• Acid mine drainage

• Acid rain

• Drying out of the sediment and influx of water

• Dredging operations

• Tailings spillages

• Turbulence caused by cattle drinking the water or children playing in the water can cause the mobilization or transport of uranium in the Wonderfonteinspruit.

In 2002 in the Krugersdorp-Randfontein area water has started to decant from a number of shafts into the Tweelopiespruit and the Wonderfonteinspruit. The water has a pH of 2.2. It is commonly known as Acid Mine Drainage (AMD).

The combination of the pH and redox driven reactions resulted in a measured uranium concentration of 16mg/l of the Robinson Lake, and resulted in the NNR declaring the lake a radiation area. The background U concentration in water is 0,0004mg/l. In terms of the DWAF regulations for drinking water, the U concentration should not exceed 0.07mg/l and for irrigation, 0.01mg/l. (Figure 8)

14

Pollution Plume

Figure 8

The uncontrolled flow of untreated and partially treated AMD into the Tweelopiespruit has resulted in radioactive toxic dams. (Figure 9) The Tweelopiespruit is a classified Class V River, that is a high acute toxic river system. All aquatic biota has been wiped out.

15

Figure 9. Hippopotami coated with toxic and radioactive sludge. Hippo Dam, Krugersdorp Game Reserve

Acid Mine Drainage (AMD) is responsible for the most costly environmental and socio- economic impacts. Production of AMD may continue for many years after mines are closed and tailings dams decommissioned. AMD is not only associated with surface and groundwater pollution, degradation of soil quality, for harming aquatic sediments and fauna, and for allowing heavy metals to seep into the environment but ong-term exposure to AMD polluted drinking water may lead to increased rates of cancer, decreased cognitive function and appearance of skin lesions. Heavy metals in drinking water could compromise the neural development of the fetus which can result in mental retardation. (Figure 10)

16

Precipitated Heavy Metals

Figure 10

The impacts of the mine void water on the surface water system, in particular the increased salt loads, can be inferred from the subjoined figure (Figure 9).

Volumes and loads 2005 - Jan. 2010 • Polluted water is discharged into a receiving environment – Volume = ~25Ml/d – Salt content = ~4g/l – Salt load = ~100 tons per da

20t 20t 20t 20t 20t

Photo: Courtesy Dr. Henk Coetzee

17

Figure 9

In terms of “A hydrogeological assessment of acid mine drainage impacts in the West Rand Basin Gauteng Province” it was found that the:

 Decanting Volumes are currently between 18 and 36 ML/per day14  An unqualified volume escapes downstream.  The decant takes place at the north/south intercontinental water divide with impacts to both the Tweelopiespruit (to the North) and the seepage of AMD into the Wonderfonteinspruit during heavy rainfall events (to the South)

In terms of the Harmony Gold EIA Report, entitled: “ Hydrological/Chemical aspects of the Tweelopie-/Riet-/Blaaubankspruit, with specific reference to the impact water, decanting from the Western Basin Mine Void, has on the system” it was found:

• The AMD causes accelerated void formation in the dolomite of the Zwartkrans compartment.

• The void created by the mine void water is 8 960 m3 and was formed in only 2.5 years. The Wondercave was formed over a period of millions of years.

• There are people living and operating businesses in the area and these people should be warned about the potential ground instability in their area. 11 492 persons use the stream and borehole water for drinking purposes and irrigation.

• The potential greatest disaster could occur if part of the N14 Roadway collapses. This road carries a high traffic load, as it is the main arterials between Johannesburg and Botswana.

At present there are no mitigation or remediation measures in place for the amelioration of the discharge of toxic water into the Tweelopiespruit (Limpopo Catchment) and seepage into the Wonderfonteinspruit (Vaal River Catchment).

14 During heavy rainfaill events the volumes of uncontrolled decant of untreated AMD are 56 million litres per day.

18

Results indicate that U-levels in water resources of the Wonderfonteinspruit catchment increased markedly since 1997 even though U-loads emitted by some large gold mines in the Far West Rand were reduced. This apparent contradiction is explained by the contribution of highly polluted water decanting from the flooded mine void in the West Rand.

800kg of U per year flowing into Boskop Dam as Potchefstroom’s main water reservoir. Of particular concern is the fact that U-levels in the Wonderfonteinspruit Catchment are comparable to those detected in the Northern Cape which had been geostatistically linked to abonormal haematological values related to increased incidences of leukaemia observed in residents of the area15.

The potential volume of AMD for the Witwatersrand Goldfield alone amounts to an estimated 350ML/day (1ML = 1000m3). (Figure 10) This represents 10% of the potable water supplied daily by Rand Water to municipal authorities for urban distribution in Gauteng province and surrounding areas, at a cost of R3000/ML.

15 Uranium Pollution of Water resources in Mined-Out and Active Goldfields of South Africa – A Case Study in the Wonderfonteinspruit Catchment on Extent and Sources of U- Contamination and Associated Health Risks. Prof.Dr. Frank Winde. 2009.

19

Figure 10. Western Basin – Flooded and decanting since 2002; Central Basin – flooding, decant anticipated in 2012; Eastern Basin – flooding, decant anticipated in 5 years

The gold mining industry in South Africa (principally the Witwatersrand Goldfield) is in decline, but the post-closure decant of AMD is an enormous threat, and this could become worse if remedial activities are delayed or not implemented.

LATENT OR RESIDUAL RISKS

Latent impacts may take decades, or even centuries, to manifest themselves. Tailings dams and waste rock dumps can never be maintained in completely reducing environment hence water quality risks will remain for centuries.

Even though a large number of the world’s rivers are contaminated by heavy metals released from present day and historic mining operations, relatively little is known about the effects on communities that live beside and rely on these rivers for food and livelihood. One of the complications is that the toxicity of many metals is a function of such conditions as redox, pH and water hardness.

20

Elevated salts and metals can also negatively affect the health of animals in many different ways, depending on the species, age, sensitivity, general health and diet of the consumer, among other factors.

Some metals, when consumed in excess, can affect organs and the central nervous system, cause reproductive failure or birth defects, and act as cofactors in many other diseases.

Certain receptors may be more sensitive than others, depending upon species, age, sex, season, body mass, metabolic rate, general health, diet, behaviour, etc, with younger animals and children being generally more at risk than adults under the same conditions of exposure (WHO).

The potential for trans-generational (genetic) impacts of bioaccumulated metals and NORMs (Naturally Occurring Radiactive Materials) on biota exposed above certain thresh-holds.

The probability is that such latent impacts will only be identified and assessed over the next 100 to 500 year16s.

SUBMITTED BY:

Mariette Liefferink.

CEO: FEDERATION FOR A SUSTAINABLE ENVIRONMENT.

16 AngloGold Ashanti Draft Environmental Impact Assessment Report and Environmental Management Programme Report. 2008. West Wits Operations.

21