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WCA: Remediation Action Plan

November 2008 Page | 1


April 2009

WONDERFONTEINSPRUIT CATCHMENT AREA

RADIOACTIVE CONTAMINATION SPECIALIST TASK TEAM

REPORT ON SITE VISITS AND RECOMMENDED ACTIONS

Prepared for:

Prepared by:

ILISO Consulting (Pty) Ltd

COPYRIGHT All Rights Reserved. Unauthorized copying is strictly prohibited.

WONDERFONTEINSPRUIT CATCHMENT AREA

REMEDIATION PLAN



AND

National

Nuclear

Regulator

Final Draft Report

REV: 1.2

DATE : 2009-04-30

All Rights Reserved. Unauthorized copying is strictly prohibited.

Page | i




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FOREWORD

The purpose of this investigation 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.

The report is therefore qualitative in nature and does not attempt in any way to quantify risk or

hazard. 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. It is however recognised in some cases, specifically with respect to

wetland areas, the cleaning up can cause more damage than is warranted by the benefit of

removing the contaminated material. In such cases more investigations may be required.


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Report Title: Wonderfonteinspruit Catchment Area: Remediation Action Plan

Author: Dr. Martin van Veelen

Contributors: Dr. Gert de Beer

Prof. Frank Winde

Dr. Don Lush

Prof. Ronald Cohen

Mr. Mogwera Khoathane

Ms. Gugu Mlangeni

Status of Report: Final Draft Report

ILISO Consulting (Pty) Ltd

Approved for ILISO Consulting by:

Dr. M. van Veelen Date

Director: Environmental Management

DEPARTMENT: WATER AFFAIRS AND FORESTRY

Accepted for the DWAF by:

Mr. M. Keet Date

Acting Director: Institutional Establishment

NATIONAL NUCLEAR REGULATOR

Accepted for the NNR by:

Mr. O. Phillips Date

Senior Executive Manager


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EXECUTIVE SUMMARY

The Regulatory Authorities responsible for the regulation of radiological contamination in

the water resources are the Department of Water Affairs and Forestry and the National

Nuclear Regulator reporting to the Department of Minerals and Energy. Based on their

joint responsibility, these Departments have embarked on a co-operative venture to

evaluate the extent of impairment in the Wonderfonteinspruit Catchment and if

impairment exists to determine what remediation is to be implemented.

In order to address these issues a team of specialists was appointed to advise the

authorities on the prioritisation of the Areas of Intervention for which remediation is

required. The Specialists Task Team went through a process of identifying 36 Areas of

Intervention by focusing on sites that could be impacted on by water-borne radioactive

material within the Wonderfonteinspruit catchment and could potentially be a public

health hazard. The remediation methodology to be adopted and also the order of priority

in which these Areas of Intervention should be dealt with will be addressed by the

Implementation Plan which will be compiled by the Implementation Task Team.

In order to categorise a site as a potential public health hazard a hypothesis was used

that states that the probability of exposure to radiation increases proportionally with the

number of people that could potentially gain access to that site. The hypothesis is such

that even if an area has a low level of radiation but is accessible by the public, it would

be included as an Area of Intervention.

Remediation is seen, in the context of this report, as action to be taken by the

responsible parties to remove radioactive contaminated material from a site and

rehabilitate the site. The action of removing material and rehabilitation will have to be

done within the confines and to the standards as set by legislation and the mandated

authorities. This can also be considered as applying to sites which the public can freely

access, at which the levels of specific activity or radionuclides are above clearance

levels, meaning that after cleaning up the site would be suitable for unrestricted use as

relates to its radiological characteristics. Chemical or other types of pollution were not

taken into account for the decision making process of remediation of the site.

The strategic approach adopted for this report involves a categorisation of sites into 5

categories. Category 1 sites are recommended for immediate action and grade through

to category 3 which includes sites that at the present time are recommended to be left as

is since remediation is considered to be more harmful than the alternative. Category 4

includes sites that had in previous studies been identified as areas of concern but for

which mitigatory measures have already been implemented by the responsible parties.


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Category 5 includes those sites for which additional data must be collected and analysed

in order to include them in a longer term remediation plan for the catchment.

Fifteen sites fall into Category 1 where there is no reason to delay immediate action, of

which the Lancaster Dam (MP46) is the most urgent. Other sites such as MP 47, MP18,

MP20, MP29 and MP30 are mostly related to accidental spills from mining infrastructure

and represent relatively small quantities of easily accessible and remediated slimes.

These sites were identified as priority areas requiring immediate clean up. Sites MP23,

MP24, MP25, MP26 and MP40 have been prioritised as Category 1 based on the fact

that stricter regulatory enforcement will address the problem to a large extent. MP34,

MP35, MP38 and MP39 occur within the “greenbelt” canal in Carletonville and are

characterised by pollution due to slime spillage.

Two sites, fall into Category 2 requiring immediate action for clean up. It has been

ascertained that these sites, located at Harry’s Dam, are sources of pollution from a dam

which does not serve any functional purpose. A plan for the remediation of these sites

must be developed in the short to medium term.

Remedial action at the Donaldson Dam and the Padda Dam are included in Category 3,

where the levels of pollution are so low, that the damage that these systems would incur

during a clean-up operation does not appear to be justified at this time based upon the

information available. In these cases natural clean-up could occur if mines comply fully

with their licensed discharges. These sites include MP12, MP13, MP14 and MP36.

Three sites, that had been identified as areas of concern in previous studies, namely

MP5, MP11 and MP37 fall into Category 4 where no remedial action will be required

due to work already been done and or no significant radiological hazard is suggested by

available information.

A total of 10 sites fall into Category 5 and will require some form of further investigation

in order to determine the action which needs to be taken to address the contamination at

these sites. It is envisaged that the remedial action for these sites will form part of a long

term action plan which must be developed. Most of the sites in this category are

wetlands or dams that need more care in the way the clean-up action is conducted.

Remediation activities in wetland areas will be based on a survey to determine the

nature of the wetland and its ability to recover to a fully functioning wetland after the

clean-up. Wetlands are protected by law, and authorisation for the clean-up action will

have to be obtained from the environmental authorities.


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TABLE OF CONTENTS

EXECUTIVE SUMMARY .............................................................................................. vii

ACRONYMS ................................................................................................................ xiii

DEFINITIONS ............................................................................................................... xv

1. INTRODUCTION ...................................................................................................... 1

1.1 Background .......................................................................................................... 1

1.2 Study Area ............................................................................................................ 2

1.3 Purpose of the Study ............................................................................................ 5

1.4 Purpose of this Report .......................................................................................... 7

1.5 Sources of Information for the Report ................................................................... 8

2. INSTITUTIONAL ARRANGEMENTS ....................................................................... 9

2.1 Organisation ......................................................................................................... 9

2.2 History .................................................................................................................10

3. SPECIALIST TASK TEAM ..................................................................................... 11

3.1 Members .............................................................................................................11

3.2 Terms of Reference .............................................................................................11

3.2.1 Principles of the Terms of Reference of WCATPWG ..........................12

3.2.2 Terms of Reference of the WCATPWG ..............................................12

3.3 Programme of Work of STT .................................................................................13

4. MAP OF AREAS OF CONCERN ........................................................................... 15

5. FIELD VISIT ........................................................................................................... 23

5.1 Purpose ...............................................................................................................23

5.2 Participants ..........................................................................................................23

5.3 Briefing Session ...................................................................................................23

5.4 Areas Of Intervention ...........................................................................................25


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6. OBSERVATIONS AND RECOMMENDATIONS .................................................... 27

6.1 Category 1 ...........................................................................................................27

6.1.1 MP1 ....................................................................................................27

6.1.2 MP2 ....................................................................................................29

6.1.3 MP18 ..................................................................................................30

6.1.4 MP20 ..................................................................................................31

6.1.5 MP23 ..................................................................................................32

6.1.6 MP24 and MP25 .................................................................................33

6.1.7 MP26 ..................................................................................................34

6.1.8 MP34 ..................................................................................................35

6.1.9 MP35 ..................................................................................................36

6.1.10 MP38 ..................................................................................................36

6.1.11 MP39 ..................................................................................................37

6.1.12 MP40 ..................................................................................................37

6.1.13 MP46 ..................................................................................................38

6.1.14 MP47 ..................................................................................................40

6.2 Category 2 ...........................................................................................................41

6.2.1 MP29 and MP30 .................................................................................41

6.3 Category 3 ...........................................................................................................43

6.3.1 MP12 ..................................................................................................43

6.3.2 MP13 ..................................................................................................44

6.3.3 MP14 ..................................................................................................44

6.3.4 MP36 ..................................................................................................45

6.4 Category 4 ...........................................................................................................46

6.4.1 MP5 ....................................................................................................46

6.4.2 MP11 ..................................................................................................47

6.4.3 MP37 ..................................................................................................47

6.5 Category 5 ...........................................................................................................48

6.5.1 MP3 ....................................................................................................48

6.5.2 MP4 ....................................................................................................49

6.5.3 MP10 ..................................................................................................50

6.5.4 MP21 ..................................................................................................50

6.5.5 MP22 ..................................................................................................51

6.5.6 MP41 ..................................................................................................51

6.5.7 MP42 ..................................................................................................52

6.5.8 MP43 ..................................................................................................52

6.5.9 MP44 ..................................................................................................53

6.5.10 MP45 ..................................................................................................53


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7. RELEVANT ENVIRONMENTAL LEGISLATION ................................................... 55

8. DISCUSSION.......................................................................................................... 59

8.1 Immediate Intervention ........................................................................................60

8.2 Cleanup ...............................................................................................................60

8.3 No Action .............................................................................................................61

8.4 Remedial Action Complete ..................................................................................61

8.5 Further Investigations ..........................................................................................61

8.5.1 Wetlands ............................................................................................61

8.5.2 Dams ..................................................................................................61

9. REMEDIATION ACTION PLAN ............................................................................. 63

9.1 Next Steps ...........................................................................................................67

9.2 Actions Pertaining to the PIP ...............................................................................67

9.3 Actions Pertaining to the ITT ................................................................................67

10. CONCLUSION ........................................................................................................ 71

REFERENCES .............................................................................................................. 73


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LIST OF APPENDICES

Appendix A: Studies Used in Assessing Areas of Intervention .............................. 75

Appendix B: Project Time Table ................................................................................ 79

Appendix C: Identification and Classification of Areas of Intervention ................. 83

Appendix D: List of Areas of Intervention ............................................................... 107

Appendix E: Overview of Environmental Legislation ............................................ 111

Appendix F: SPECIALISTS REPORTS ..................................................................... 143

LIST OF FIGURES

Figure 1: Catchment Map (1:250 000) ........................................................................................ 3

Figure 2: Catchment Map (Satellite Image) ................................................................................ 4

Figure 3: Institutional Arrangement for Management of Radioactive Contamination ................... 9

Figure 4: Plan of Potential Areas of Intervention as identifed by the STT ..................................18

Figure 5: Areas of Intervention sites visited - Upper Wonderfonteinspruit ..................................19

Figure 6: Areas of Intervention sites visited - Lower Wonderfonteinspruit ..................................20

Figure 7: Areas of Intervention - Reference Sites ......................................................................21

LIST OF TABLES

Table 1: Recommended Specialists ..........................................................................................11

Table 2: Attendees of the Field Investigation .............................................................................23

Table 3: Mine Representatives ..................................................................................................23

Table 4: Areas of Intervention - Sites visited during the field investigation.................................25

Table 5: Remediation Action Plan .............................................................................................63


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ACRONYMS

ALARA As Low As Reasonably Achievable (social and economic factors taken into account)

AoI Area of Intervention CARA Conservation of Agricultural Resources Act CMP Catchment Management Plan D/S Downstream DA Department of Agriculture DEAT Department of Environmental Affairs and Tourism DME Department of Minerals and Energy DoH Department of Health DWAF Department of Water Affairs and Forestry ECA Environmental Conservation Act EIA Environmental Impact Assessment GDACE Gauteng Department of Agriculture, Conservation and Environment GG Government Gazette GN Government Notice GTT Government Task Team ITT Implementation Task Team JCC Joint Coordinating Committee MIG Mining Interest Group NEA Nuclear Energy Act NNEA National Nuclear Energy Act NNR National Nuclear Regulator NORM Naturally Occurring Radioactive Material NWA National Water Act PIP Public Involvement and Participation SCRMRRC Steering Committee for Mining Related Radiation Contamination STT Specialist Task Team ToR Terms of Reference TPWG Technical Professional Working Group U/S Upstream WCA Wonderfonteinspruit Catchment Area WCATPWG Wonderfonteinspruit Catchment Area Technical Project Working Group WG Dept. of Water Affairs & Forestry and National Nuclear Regulator Working

Group WRC Water Research Commission


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DEFINITIONS

Action Level

The level of dose rate or activity concentration above which remedial actions or protective

actions should be carried out in chronic exposure or emergency exposure situations. An action

level can also be expressed in terms of any other measurable quantity as a level above which

intervention should be undertaken.

Characterization

1. Determination of the nature and activity of radionuclides present in a specified place. For

example, determination of the radionuclides present in a bioassay sample or in an area

contaminated with radioactive material (e.g. as a first step in planning remediation). For the

latter example, care should be taken to avoid confusion with the existing, and different, definition

of the term site characterization.

2. Determination of the character of something. This is the standard dictionary definition, and

would not need to be included in an individual glossary. It is included here only to distinguish the

normal usage from the more restricted usage indicated in (1).

Clearance

Removal of radioactive material or radioactive objects within authorized practices from any

further regulatory control by the regulatory body.

Contamination

1. Radioactive substances on surfaces, or within solids, liquids or gases (including the human

body), where their presence is unintended or undesirable, or the process giving rise to their

presence in such places. Also used less formally to refer to a quantity, namely the activity on a

surface (or on a unit area of a surface). Contamination does not include residual radioactive

material remaining at a site after the completion of decommissioning. The term contamination

may have a connotation that is not intended. The term contamination refers only to the presence

of radioactivity, and gives no indication of the magnitude of the hazard involved

2. The presence of a radioactive substance on a surface in quantities in excess of 0.4 Bq/cm2

for beta and gamma emitters and low toxicity alpha emitters, or 0.04 Bq/cm2 for all other alpha

emitters. This is a regulatory definition of contamination, specific to the Transport Regulations.

Levels below 0.4 Bq/cm2 or 0.04 Bq/cm2 would still be considered contamination according to

the scientific definition (1).

Critical Group

A group of members of the public which is reasonably homogeneous with respect to its

exposure for a given radiation source and is typical of individuals receiving the highest effective

dose or equivalent dose (as applicable) from the given source.


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Dose

A measure of the energy deposited by radiation in a target

Environmental Monitoring

The measurement of external dose rates due to sources in the environment or of radionuclide

concentrations in environmental media.

Exclusion

The deliberate exclusion of a particular category of exposure from the scope of an instrument of

regulatory control on the grounds that it is not considered amenable to control through the

regulatory instrument in question. Such exposure is termed excluded exposure.

Exemption

The determination by a regulatory body that a source or practice need not be subject to some or

all aspects of regulatory control on the basis that the exposure (including potential exposure)

due to the source or practice is too small to warrant the application of those aspects or that this

is the optimum option for protection irrespective of the actual level of the doses or risks.

Exposure

The act or condition of being subject to irradiation.

Fixed Contamination

Contamination other than non-fixed contamination.

Intervention

Any action intended to reduce or avert exposure or the likelihood of exposure to sources that

are not part of a controlled practice or that are out of control as a consequence of an accident.

Member of the Public

In a general sense, any individual in the population except, for protection and safety purposes,

when subject to occupational or medical exposure. For the purpose of verifying compliance with

the annual dose limit for public exposure, the representative individual in the relevant critical

group.

Monitoring

The measurement of dose or contamination for reasons related to the assessment or control of

exposure to radiation or radioactive substances, and the interpretation of the results.

Non-fixed Contamination

Contamination that can be removed from a surface during routine conditions of transport.


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Radiation

When used in IAEA publications, the term radiation normally refers only to ionizing radiation.

The IAEA has no statutory responsibilities in relation to non-ionizing radiation. Ionizing radiation

can be divided into low linear energy transfer radiation and high linear energy transfer radiation

(as a guide to its relative biological effectiveness), or into strongly penetrating radiation and

weakly penetrating radiation (as an indication of its ability to penetrate shielding or the human

body).

Radioactive (adjective)

Exhibiting radioactivity; emitting or relating to the emission of ionizing radiation or particles.

Radioactive Material

Material designated in national law or by a regulatory body as being subject to regulatory control

because of its radioactivity.

Remediation

Any measures that may be carried out to reduce the radiation exposurefrom existing

contamination of land areas through actions applied to the contamination itself (the source) or to

the exposure pathways to humans.

Risk

A multi-attribute quantity expressing hazard, danger or chance of harmful or injurious

consequences associated with actual or potential exposures. It relates to quantities such as the

probability that specific deleterious consequences may arise and the magnitude and character

of such consequences.

Scenario

A postulated or assumed set of conditions and/or events.

Screening

A type of analysis aimed at eliminating from further consideration factors that are less significant

for protection or safety in order to concentrate on the more significant factors. This is typically

achieved by consideration of very

pessimistic hypothetical scenarios.

Site Characterization

Detailed surface and subsurface investigations and activities at a site to determine the

radiological conditions at the site or to evaluate candidate disposal sites to obtain information to

determine the suitability of the site for a repository and to evaluate the long term performance of

a repository at the site.


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Site Evaluation

Analysis of those factors at a site that could affect the safety of a facility or activity on that site.

This includes site characterization, consideration of factors that could affect safety features of

the facility or activity so as to result in a release of radioactive material and/or could affect the

dispersion of such material in the environment, as well as population and access issues relevant

to safety (e.g. feasibility of evacuation, location of people and resources).

Source

Anything that may cause radiation exposure — such as by emitting ionizing radiation or by

releasing radioactive substances or material — and can be treated as a single entity for

protection and safety purposes.

Specific Activity

Of a material, for the purposes of the Transport Regulations, the activity per unit mass of the

material in which the radionuclides are essentially uniformly distributed.

Of a radionuclide, the activity per unit mass of that nuclide.

Of a material, the activity per unit mass or volume of the material in which the radionuclides are

essentially uniformly distributed.


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1. INTRODUCTION

1.1 BACKGROUND

The Department of Water Affairs and Forestry (DWAF) started monitoring and

measuring radioactivity in water in the Wonderfonteinspruit Catchment Area (WCA) in

1995. At a later stage sediments were also sampled for radioactivity. This was in

response to numerous concerns raised and increasing evidence that Uranium existed in

the water resources of this catchment.

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.

The authorities responsible for the regulation of radiological contamination in the water

resources are the DWAF, the National Nuclear Regulator (NNR) and the Department of

Minerals and Energy (DME). Based on their joint responsibility, the DWAF and the NNR

have embarked on a co-operative venture to evaluate the extent of impairment in the

WCA and determine if impairment exists what remediation is to be implemented.

A number of different radiological studies, commissioned by different parties and done

by different experts with different focuses have been carried out in the WCA, have

identified a number of areas for intervention. This has brought about conflicting opinions

as to the areas that could be of concern, the extent of impairment and the need for

remediation.

In order to address these issues a team of specialists was appointed to advise the

authorities on prioritisation of the Areas of Intervention (AoI) for which remediation is

required. The Specialists Task Team went through a process of identifying a subset of

36 Areas of Intervention by focusing on sites that could be impacted on by water-borne

radioactive material within the Wonderfonteinspruit catchment. The remediation

methodology to be adopted and also the order of priority in which these Areas of

Intervention should be dealt with will be addressed by the Implementation Plan which will

be compiled by the Implementation Task Team.

In order to identify sites that should be prioritised for a clean up action a hypothesis was

used that states that the probability of exposure to radiation increases proportionally with

the number of people that could potentially gain access to that site. The hypothesis is

such that even if an area has a low level of radiation (that is just above the regulatory

clearance level for soil and sediment of 0.5Bq/g) but is accessible by the public, would

be included as an AoI.


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This selection process of AoIs excluded sites with other forms of transported pollution

(e.g. air-borne pollution), other forms of pollution (e.g. heavy metals, pathogenic

bacteria, organic chemicals), and other hazards (e.g. occupational health hazards or

physical hazards to the public).

The Specialists Task Team (STT) visited all 36 AoIs along the Wonderfonteinspruit. The

extent of and the mitigating action required at each of these sites was determined with a

priority order, in which the intervention should take place at each of the AoIs.

1.2 STUDY AREA

Water Resources - The Mooi River with its two main tributaries, the Wonderfonteinspruit

(sometimes called the Mooirivierloop) and the Loopspruit has a relatively flat topography

with elevations varying from 1520m in the north, to about 1300m in the south-west (See

Figure 1 and Figure 2).

The Mooi River originates at the Bovenste Oog in the Mathopestad area (near

Ventersdorp) and flows into the Vaal River. The Wonderfonteinspruit itself originates in

the southern part of Krugersdorp (Mogale) on the Witwatersrand ridge (Catchment

between the Vaal and Crocodile West/Marico Catchments – two major Water

Management Areas). The Wonderfonteinspruit then flows through the municipal areas of

Westonaria, and Merafong and into the Mooi River upstream of Potchefstroom.

A steep sided rocky ridge, known as the Gatsrand, (catchment divide between the

Wonderfonteinspruit and the Loopspruit, both tributaries of the Mooi River) runs through

most of the mining areas. The area has rocky ridges with large flat areas in between.

The originally gentle undulating topography of the Upper Wonderfonteinspruit catchment

has been significantly modified by the many mine dumps in the area.

A major feature of this multifaceted catchment is that the Wonderfonteinspruit flows over

a number of dolomitic water compartments which hold some of South Africa’s biggest

dolomitic water reserves. Some of these dolomitic areas are underlain by gold-bearing

reefs and are extensively undermined.

The ingress of groundwater from the dolomites presents a risk to the mining operations.

Therefore the dolomites are dewatered as the water flows into the mine workings and

the mines pump and discharge this water to the surface at a great cost.


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As the groundwater infiltrates into the mine workings it comes into contact with the

exposed reef. The water and dissolved oxygen react with the pyrites, forming sulphuric

acid dissolving the heavy metals and radionuclides. These heavy metals and

radionuclides stay in solution when the extraneous underground water is discharged to

the environment (water courses). On the surface due to various physical/chemical

conditions the heavy metals and radionuclides precipitate out and or are redissolved

back into solution and are transported in the water medium further downstream.

Along its course, water in the river finds its way back into the underlaying dolomites and

then has to be pumped out again. This causes a further deterioration in water quality. In

order to mitigate this situation a section of the river is transported through a 1 meter in

diameter pipeline for approximately 30km over three of the de-watered dolomitic

compartments (Oberholzer, Venterspost, and Bank). The pipeline begins downstream of

the Donaldson Dam, running more or less parallel to the Wonderfonteinspruit, and ends

back in the Wonderfonteinspruit, on top of the Boskop-Turffontein dolomitic compartment

in the vicinity of Carletonville. The purpose of the pipeline is also to prevent the formation

of sinkholes in the riverbed.

Figure 1: Catchment Map (1:250 000)


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However, most of the activities on the surface and underground still remain

interconnected due to different mining practices, geological formations, importing of

water from other catchments (Rand Water), the re-use of water and discharging of

water. The catchment has 21 discharge points and numerous non-point discharges from

mines (gold, diamond and peat), sewage works, settlements (formal and informal),

industry and agriculture.

Anthropogenic Impacts on the Water Resources – Mining has taken place in the upper

part of the catchment for more than a hundred years. Mining in the lower part of the

Wonderfonteinspruit has been in operation for approximately 50 years. A number of

mines and industrial activities, especially in the upper part of the catchment, are having a

negative impact on the water resource.

A contributing factor to radiological contamination of the water courses is the disposal of

slimes material onto dams that are situated on top of the dolomites or too close to water

courses. Due to seepage, spills and poor management of these disposal facilities slimes

are washed into the water courses or poor quality water seeps into the environment.

The first major discharger in the catchment is the final effluent discharged from the Flip

Human Wastewater Treatment Works of Mogale Local Municipality. Venterspost Mine

Figure 2: Catchment Map (Satellite Image)


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(Kloof No. 10 shaft) is the next point source which is in the middle Wonderfonteinspruit.

Mine fissure water is discharged directly into the 1m pipeline. The Hannes van Niekerk

Wastewater Treatment Works (Westonaria) also discharges into the 1m pipeline just

downstream of the Kloof discharge.

Driefontein discharges fissure and process water downstream of the outflow of the 1m

pipeline. The quality of the Driefontein fissure water deteriorates due to re-use by the

mine. Deterioration also occurs when water that has been pumped to the surface flows

back through the mine workings, such as process water from Driefontein Mine.

Discharges from Blyvooruitzicht Mine, and a number of smaller Wastewater Treatment

Works, into the Wonderfonteinspruit further negatively impact on the water quality of the

river just before it confluences with the Mooi River.

Uranium (a chemical and radioactive pollutant), sulphates, and heavy metals are some

of the waste load impacts that the mines have on the surface and underground water

resources. Biodegradable organics and potentially harmful bacteria, are some of the

impacts on the catchment resulting from raw sewage from informal settlements, poor

sewage reticulation systems, and poorly operated sewage works.

Based on the uncertain nature of the contamination levels and the hazards associated

with radioactivity in the Wonderfonteinspruit catchment, several investigations have

taken place over the past few years. A summary of the key studies and their relevant

findings which have provided the quantitative data on water and sediment used in the

qualitative assessment of this study are included in Appendix A.

1.3 PURPOSE OF THE STUDY

The purpose of this study was essentially to conduct a qualitative assessment of

available information in order to:

1. Summarise the areas of potential intervention;

2. Conduct a field visit to assess the identified AoI;

3. Based upon the potential for significant public exposure of these areas of

potential intervention, identify areas requiring further study; and

4. Based on the field visit and the qualitative assessment of the data provided in the

reports used for the assessment, prioritise the areas with need for intervention

into 5 categories.

As a result of radiological hazard of the water quality a number of AoIs have been

identified as requiring some form of remedial action. The polluter pays principle applies,

therefore this action is to be taken by the responsible parties.


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The main intent of the study is to evaluate the need for remediation based on a

qualitative assessment of the activity concentrations of Uranium measured in the

catchment. Once the need for remediation has been established, the sites will be

classified in terms of potential hazardous effects. A remediation action plan must be

developed for the remediation action in the WCA, where required, in accordance with the

requirements of the appropriate regulatory authorities. The main aim of this action is to

reduce the potential for radiation exposure as it can occur at the present time and as

may potentially occur in the future. The remediation plan must also prioritise at which of

the AoIs remediation must first be implemented.

In the light of the various and often conflicting sources of information, an objective

appraisal of the situation with respect to radiological hazard and its public health and

environmental significance within the catchment is required. It is accepted that

contamination does exist, in some isolated cases to an unacceptable level in localised

areas. Based on the findings of various studies and investigations, it has been

concluded that while there is no immediate deterministic health hazard related to

radiological contamination, the potential for random effect does exist if no mitigation

measures are taken. Premised on this view, the regulatory authorities have embarked on

this process to identify priority Areas of Intervention for action in the long, medium and

short term.

The study in essence does not differentiate between groundwater and surface water.

The study, however, focuses on areas where analysis revealed the existence of

radiological contamination. These areas are related to surface and also groundwater

where the groundwater has been pumped to the surface. Where remediation of surface

contamination has been addressed it will, in some instances, also have a positive impact

on groundwater. The underground radiological contamination must be addressed in a

separate but related exercise.

Based on the NNR principles, Remediation is seen, in this report as:

• Any measures that may be carried out to reduce the radiation exposure from

existing contamination of land areas through actions applied to the

contamination itself (the source) or to the exposure pathways to humans. The

action of removing material and rehabilitation will have to be done within the

confines and to the standards as set by legislation and the mandated

authorities.

Contamination is seen, in the context of this report, as

• Radioactive substances on surfaces, or within solids, liquids or gases (including the human body), where their presence is unintended or undesirable, or the process giving rise to their presence in such places.


April 2009 Page | 7

The DWAF and the NNR have agreed on the following principles in taking action:

• Immediate remediation of Areas of Intervention (AoI) where practically possible,

• The exact AoIs where the remediation takes place will have to be identified,

• A team of experts should be appointed to determine the priority of AoIs, and

• The Implementation Task Team (ITT) must provide the methodology to be used

for the remedial action to take place.

The proposed remediation measures will be based on international best practice with

suitability to the South African situation as well as local conditions in the WCA taken into

account. The remedial process will be dually authorised in accordance with the

requirements of South African legislation by the applicable Regulatory Authorities and

remediation will comply with conditions of authorisation as set by those Regulatory

Authorities.

The implementation or execution of the proposed remediation action plan will be set in

action by the regulators. The Implementation Plan linked to the Remediation Action Plan

will be developed by the Implementation Task Team (ITT) which will be comprised of the

relevant Government Departments, the Mining Interest Group (MIG) and the Public

Involvement and Participation (PIP) Task Team.

The mining parties will, however, remain financially responsible and accountable for the

liabilities of the AoIs. The remediation action plan is therefore intended to provide the

platform for action from which the regulatory authorities will direct the execution and

implementation of remediation measures.

While a timeframe for the project had been proposed, several delays were experienced

in the execution linked to administrative arrangements for the involvement of overseas

specialists. This resulted in a deviation from the original timeframe a depiction of which

can be found in Appendix B.

1.4 PURPOSE OF THIS REPORT

The purpose of this report is to document the:

• identified AoIs;

• field visit undertaken by the specialists, as a group, to each of the AoIs;

• discussion or findings at each of the identified AoIs;

• inputs by each of the specialists describing specific concerns and

recommendation of possible remediation actions; and

• recommended actions to be taken at each of the AoIs.


April 2009 Page | 8

The outcome of this report is a remediation action plan for the identified AoIs. This action

plan will provide the regulatory authorities with a platform to direct the execution and

implementation of mitigation measures at each of the AoIs. The recommendations of this

report must not be taken in isolation but rather seen as the first step in the development

and implementation of a strategic catchment rehabilitation strategy in which all sources

of contamination within the catchment will be identified, quantified and an integrated plan

put in place to control them.

1.5 SOURCES OF INFORMATION FOR THE REPORT

The following reports by various team members were consulted when compiling this

report:

• NECSA, Assessment Comments and Proposal for the WCA Rehabilitation

Report, PR-VLG-08-16, Draft Report, unpublished October 2008, by G P de

Beer, PhD;

• Field Visit Comments and Recommendations on Identified “Areas of Potential

Concern”, Report, draft report unpublished September 2008, by Don Lush. PhD;

• Report to the Specialist Task Team, September 1-5, 2008, draft report

unpublished October 2008 by Prof. Ronald R. Cohen, PhD;

• Wonderfonteinspruit Catchment Area – Field Investigation on Areas of

Intervention, draft report unpublished October 2008 by Mogwera Khoathane;

• Remediation Plan: Wonderfonteinspruit Catchment Area, Overview of the

Relevant Environmental Legislation, draft report unpublished September 2008 by

Ms. Gugu Mlangeni; and

• Development of a map ranking sites with known radioactive pollution in the

Wonderfonteinspruit Catchment according to the urgency of required intervention

(“Intervention site map”) – Underlying methodology and results by Prof. Frank

Winde.

The identification of the AoIs was based on the following reports:

• IWQS – Institute for Water Quality Studies of the DWAF (1999): Report on the

radioactivity monitoring programme in the Mooi River (Wonderfonteinspruit)

catchment. April 1999, unpublished, Pretoria

• Coetzee et al. (2006) An assessment of sources pathways, mechanisms and

risks of current and future potential pollution of water and sediments in gold

mining areas of the Wonderfonteinspruit catchment

• BSA – BS Associates (Pty.) Ltd.(2007): Assessment of the radiological impact of

the mine water discharges to members of the public living around

Wonderfonteinspruit catchment area. BSA-project-no: 0607-03. Prepared on

behalf of the National Nuclear Regulator (NNR) of South Africa. Unpublished

report, Centurion.


April 2009 Page | 9

2. INSTITUTIONAL ARRANGEMENTS

2.1 ORGANISATION

The remediation of the Wonderfonteinspruit catchment area is being undertaken as a

joint effort between the DWAF and the NNR, but involves other authorities such as the

Department of Minerals and Energy, the Department of Environmental Affairs and

Tourism and Local Authorities within the Wonderfonteinspruit Catchment Area.

In order to ensure participation and cooperation at all levels, a comprehensive

organisational structure (see Figure 3) has been put in place to fit in with existing

governmental structures dealing with mine water management and radioactivity.

It must be stressed that not all of the committees or Task Teams have been constituted

yet. At present the focus is on contamination by radiological substances. However, it is

foreseen that other remediation steering committees will become active in the future in

order to address other issues, while some technical project working groups may address

contamination by radiological substances in other catchments.

Figure 3: Institutional Arrangement for Management of Radioactive Contamination


April 2009 Page | 10

2.2 HISTORY

A Joint Coordinating Committee (JCC) was established between the DWAF and the

NNR by the respective Director-Generals in 2007. The JCC established a National

Working Group comprising of relevant personnel from the DWAF and the NNR with the

technical expertise in the management of water quality and radiological contamination

issues. The DWAF-NNR Working Group (WG) set the WCA radiological contamination

issues as a priority.

The WG agreed that before conducting more studies in the Wonderfonteinspruit,

specialists would be invited to present the studies that had already been done to the

regulators. The regulators then agreed on the following actions to be taken:

• immediate remediation of identified contaminated areas was required where

practically possible;

• exact sites where the remediation must take place will be identified;

• team of experts should be appointed to prioritise the areas and the actions; and,

• the methodology to be used for the remedial action to take place will be

addressed by the ITT.

The Wonderfonteinspruit Catchment Area Technical Project Working Group

(WCATPWG) was established in 2008 to facilitate the strategic as well as cooperative

management of the radiological contamination of the WCA. In order to do this the

WCATPWG recognised that a team of specialists would be required to advise the

regulators on the remediation methodologies to be adopted in identifying sites to be

remediated and setting a priority for action. Eight specialists were identified and a

Specialist Task Team (STT) was established.

The STT’s first action was the development of a list of “AoIs” sites mapped and a

methodology to be used in the selection of sites. The STT’s next action was to visit each

of the 36 AoIs identified and compile a remediation action plan.

It should be noted that this project focuses specifically on surface contamination

by radioactive substances in the water resource, as this represents the common

mandate of the DWAF and the NNR.



3. SPECIALIST TASK TEAM

3.1 MEMBERS

The WCAPTWG approved the composition of the STT and the appointment of the

individual members. Due to the nature of the work required as well as the sensitivity of

the issues, the STT members were selected based on the following specific criteria:

• Strategic;

• Local knowledge and technical expertise of the area;

• Mine remediation expertise;

• Radioactive;

• International expertise; and,

• Environmental.

Based on this premise, the NNR and the DWAF recommended several specialists and

the following were selected as indicated in Table 1:

Table 1: Recommended Specialists

Dr. Martin van Veelen Strategic Specialist Advisor

Mr. Mogwera Khoathane Radiation Protection

Prof. Frank Winde Local and Technical Expert

Dr. Gert de Beer Radiation Risk Assessment

Ms. Gugu Mlangeni Environmental Management Specialist

Dr. Don Lush Mining Remediation - Canada

Prof. Ronald Cohen Mining Remediation - USA

Prof. Leslie Stoch Local and Technical Expert

Initially it was also proposed to include Professor G Basson of the University of

Stellenbosch as a sediment transport specialist. However, his specialist knowledge

would not be required at this stage of the investigation, and he was therefore not

involved in the actions of the STT.

Several delays had been experienced in the process due to the administrative

arrangements required to facilitate the involvement of the international specialists.

Prof. Leslie Stoch also felt it prudent that he should not be part of the STT and resigned

despite requests that he should remain as part of the team.

3.2 TERMS OF REFERENCE

The WCATPWG was established in order to facilitate the strategic as well as

cooperative management of the radiological contamination of the WCA with the following

Terms of Reference (ToR):



3.2.1 Principles of the Terms of Reference of WCATPWG

1. The principles underpinning the application of the relevant provisions in the:

• Minerals and Petroleum Resources Development Act (MPRDA), 2002;

• Mine Health and Safety Act (MHSA), 1996;

• National Water Act (NWA), 1998;

• Water Services Act (WSA), 1997;

• National Nuclear Regulator Act (NNRA),1999,

• National Environmental Management Act (NEMA) 1998; and

• Any other relevant Acts.

2. Application of the polluter-pays principle in solutions pertaining to remediation and

environmental management and protection;

3. The co-operative management and implementation of remediation measures to

address the radioactive contamination issues in the WCA.

3.2.2 Terms of Reference of the WCATPWG

Objectives

1. Coordinate the facilitation and implementation of the integrated approach to the

processes, solutions and decision-making related to the management of the

contamination in the WCA.

2. To facilitate, in cooperation with the Steering Committee for Remediation of Mine

Related Radioactive Contamination (SCRMRRC), the coordination of the legislative

requirements for the pollution/contamination footprints related thereto.

3. To ensure the proper and collective coordination of studies, research, information

and media matters related to cross-cutting regulatory issues.

4. Co-ordinate and manage the activities of the various task teams established to

initiate and implement the remediation measures.

5. Facilitate appropriate public and stakeholder involvement in the remediation process.

Functions

To achieve the above objectives, the WCATPWG will:

1. Facilitate technical decision-making on water management and related problems as

well as the implementation of sustainable remediation options in the WCA.

2. Make recommendations to the SCMRRC pertaining to policy, legislative and or any

other interventions required in this regard.

3. Facilitate the establishment of short, medium and long term goals for the mining

industry in addressing challenges related to the environmental remediation and the

implementation of sustainable solutions and options related to radioactive

contamination.



4. Strengthen communication between the relevant regulatory bodies in this regard,

through existing and/or other communication structures and mechanisms either to be

amended or to be established.

5. Ensure that decisions pertaining to the remediation options and measures to be

implemented are based on applicable legislation.

6. Facilitate the integration of existing and/or new research programmes being

undertaken by the relevant regulatory bodies and share information on matters

relating to radioactive contamination.

Membership

1. The WCATPWG will consist of representatives from:

• The Department of Minerals and Energy (DME)

• The Department of Water Affairs and Forestry (DWAF)

• The Department of Environmental Affairs and Tourism (DEAT) and Provincial

Environmental Departments;

• The National Nuclear Regulator

• The District and Local Municipalities

2. The WCATPWG may co-opt other members from other relevant regulatory bodies as

may be required from time to time.

Administration and Working Procedures

The WCATPWG will be chaired by the Gauteng Regional Office of the DWAF who will

therefore be responsible for the administration of meetings, liaison with members and

the convening of other activities as may be required. DWAF will provide the secretariat

function to WCATPWG.

Organisational Structure

There are currently several cooperative regulatory management structures which have

been established through the management of the relevant government departments. It is

imperative that the different structures communicate with each other in order to avoid

duplication and confusion.

3.3 PROGRAMME OF WORK OF STT

The following programme was followed by the STT (See Appendix B):

• “AoIs” map and motivation report to be completed by end May 2008;

• Familiarised experts on the STT with the WCA (field visit) in September 2008.

The intention was to gather additional information as required in order to be able

to prioritise the sites for remedial action;

• Rank and prioritise “AoIs” by end October 2008;

• Develop first draft of Action Plan by end November 2008; and,



• Decisions on the urgency of remediation were based solely on the radiological

nature of the water and sediments and did not include considerations of chemical

toxicity potential of the radioactive materials.

Some “AoIs” can be dealt with before the action plan is finalized. Such AoIs would

include areas where tailings have escaped and where the action to be undertaken and

the responsibility is clear. Some AoIs may require further study in order to determine the

best plan of action. Examples would be some of the larger dams that would require

draining and where the remedial action may in fact lead to serious environmental

impacts (a perverse outcome of a well-meant action).



4. MAP OF AREAS OF CONCERN

The first task of the STT was to produce a map of Aols defining the exact sites where

remediation is to take place. This map was produced based on the work that was

conducted by Prof. Winde. The methodology for the identification of the sites and the

development of the map can be found in Appendix C.

In order for a site to be identified and listed as an AoI the following criteria had to be

taken into consideration:

1. In terms of the mandate of the DWAF the contaminated site had to be contaminated

based on a process of water-borne pollution. In other words sites contaminated as a

result of air-borne pollution were not included;

2. In terms of the mandate of the NNR only mining related polluted sites were

considered;

3. Only sites that posed a potential hazard to public health were taken into

consideration. Sites where the public had no access to or where there were only

work related to hypothetical exposure issues were not taken into consideration;

4. Only sites within the WCA were considered;

5. The identification of the sites was based on the following reports:

• IWQS (1999) – Radioactivity in water,

• Coetzee et al. (2006) An assessment of sources pathways, mechanisms and

risks of current and future potential pollution of water and sediments in gold

mining areas of the Wonderfonteinspruit catchment, and

• Brenk Report (2007) NNR – Radiological impacts of the mining activities to the

public in the Wonderfonteinspruit Catchment Area;

6. The AoIs had to be classified into different categories based on the hazard to the

public and the access to that site by the public; and,

The map aims to depict all sites in the WCA which in previous studies were found to be

radioactively polluted and rank them according to the urgency of potential intervention

required. The map mainly serves to identify and categorize AoIs by using a hazard

assessment procedure. The pool of data or the base data used for the map and how the

map was complied is discussed in a detailed report attached as Appendix C.

It should be noted that the process of the selection of the AoIs has certain limitations, as

all models or statistical selection processes are circumspect and based on the available

data and mathematical hypothesis. In the same way this model could potentially

dissimulate the selection of certain sites.

There is a high confidence level that the sites with the highest potential for posing an

unacceptable radiological risk to people were selected. The limitation of the selection

process is however, recognised and during the course of the rehabilitation of the



catchment, additional sites may come to light or occur associated with future events

such as a slimes dam failure.

These limitations include:

1. The data sets used are from different time periods and collected for or with different

focuses taken into consideration. The analytical methods were therefore also not

always compatible and therefore required normalisation of the data;

2. The exact location of samples taken in the various studies is not always known;

3. The database used to identify AoIs in the WCA is not exhaustive;

4. The data is not spatially representative as the studies used concentrated on polluted

areas and the WCA as a whole has not been covered;

5. The data has a limited temporal representivity;

6. No biological or epidemiological data is included, although small amounts of such

data is available;

7. Chemical toxicity of radioactive materials was not considered;

8. Other health hazards such as other forms of pollution, work related hazards, etc

were not included;

9. The calculation of hazards and the assumptions concerning pathways of human

exposure varied between reports; and,

10. The hazard determination is influenced by the computation of or the way the limits

are set in the calculation of the hazards.

It is recognized that during the compilation of this report the process involved comparing,

analyzing and interpreting information from studies that were undertaken at different

periods of time under dis-similar seasonal conditions. The respective data sets had to be

correlated in order to make the inter-comparison more relevant. A radiological

quantitative assessment involves deterministic calculations that give rise to dose

determination for specific radiological pathways. Due to the limitations cited in this report

and the implied consequences for a numerically based assessment, it would be onerous

to substantiate this method as ideal for a highly technical assessment. However, it is

also evident that parameter uranium is more closely associated with 238U than with the

acceptable radio-isotopic analysis undertaken in radiological hazard assessments.

Having stated this, the most reasonable way to proceed would be to mention that the

remediation action plan is in essence a qualitative assessment that takes most of the

complexities of the environmental contaminants into account and is also the product of

professional judgment of the specialist task team.

The development of the map, as depicted in Figure 4 comprised of three steps:

1. Compilation of an updated map of the study area;

2. Extraction of data from the above listed studies that was imported into the map; and,

3. Development of a health hazard categorisation carried out by taking into

consideration the contamination level present at a given location, exposure



pathway(s) available and exposure probability based upon population density and

restrictions on potential exposure.

The sites visited by the STT are indicated in Figure 5 to Figure 7.



93

92

88

87

85

84

81

80

7972 67

64

63 59

54

31

30

8

99

98

91

77

76

51

41

40

33

13

100

³0 5 10 15 202,5

Kilometers© Winde (2008)

Internal nr.

Internal nr.

Legend

Sediment hot spots

Water drink hot spots

High risk (sed >2 x NNR limit)

High risk (>2 x DWAF drink water limit)

Figure 4: Plan of Potential Areas of Intervention as identifed by the STT



Figure 5: Areas of Intervention sites visited - Upper Wonderfonteinspruit



Figure 6: Areas of Intervention sites visited - Lower Wonderfonteinspruit



Figure 7: Areas of Intervention - Reference Sites



While all attempts were made to include an assessment of a wide selection of sites, the

possibility exists that certain sites which are known to the public or stakeholders in the

area were not included. A public participation exercise will be embarked upon in order to

provide stakeholders and the public with the opportunity to assess the map generated

and provided input in terms of any potential AoI sites which may have been excluded.

However, while efforts will be made to identify these areas, it would be irresponsible to

hold back action on the known problems until this has been completed. This process will

have identified most of the areas of concern.



5. FIELD VISIT

5.1 PURPOSE

The objective was to visit all identified areas that potentially pose an immediate and

significant public health from the standpoint of radiological protection. The visit was

undertaken with the primary purpose of affording the specialists the opportunity to obtain

a firsthand observation of the identified AoIs and therefore place them within the context

of the remediation assessment.

5.2 PARTICIPANTS

The site visit took place from 2 September 2008 to 4 September 2008 and was attended

by the following:

Table 2: Attendees of the Field Investigation

Dr. Martin van Veelen ILISO Consulting (Pty) Ltd

Mr. Mogwera Khoathane Zimkile Consulting T/A

Ms. Kavita Pema ILISO Consulting (Pty) Ltd

Dr. Gert de Beer NECSA

Mr. Deon Esterhuizen ILISO Consulting (Pty) Ltd

Dr. Don Lush Mining Remediation - Canada

Prof. Ronald Cohen Mining Remediation - USA

Ms. Tshireletso Mataboge Department of Water Affairs and Forestry

Mr. Rudzani Mabogo Department of Water Affairs and Forestry

The Team was met in the field by various persons representing several organisations

and interested parties. These persons accompanied the Team and afforded them

access to areas that are closed to the public.

Table 3: Mine Representatives

Mr. Danny Ramsuchit Gold Fields

Mr. Sarel Keller Harmony Gold Mines

Mr. Doug Jenner Blyvooruitzicht Mine

5.3 BRIEFING SESSION

A briefing session was held in Centurion on 1 September 2008. The team acquainted

themselves with the study area, and agreed on a common approach. It was agreed to

assess each site on the information available and the reigning circumstances.



Each site would then be placed in one of the following categories with further

elaborations provided below:

1. Easy – why not

2. High Priority

3. Too costly for a small benefit (cost does not refer to finances, but the cost in

environmental damage)

4. Completed

5. Uncertain.

Category 1:

This category would apply to sites which may or may not pose an immediate public

health hazard but which have been contaminated to some degree. The clean up of such

sites would be uncomplicated, requiring minimal capital and technical work. Such sites

would be considered as priority sites where remedial action could take place

immediately.

Category 2:

This category is applicable to sites that pose an immediate and significant public health

or environmental concern from the standpoint of radiological and environmental

protection. In the interest protecting the public and or the environment from significant

radiation or toxic material exposure it should be immediately remedied or cleaned up to

a standard acceptable to the regulatory authorities.

Category 3:

Sites which fall into this category will be characterised by some degree of contamination

and would in the longer term require strategic management. However, based on the

nature, location and characteristics of the sites, the remediation of such sites would

entail extensive costs (environmental costs) which would not in essence be justified by

the limited benefits which would be reaped from such action.

Category 4:

In many instances sites which had previously been identified as areas of high priority

requiring intervention have already been dealt with by the responsible party or regulatory

authority. Required action for the remediation of such sites would be considered as

complete without requiring any additional mitigation measures in the immediate future.

Category 5:

Certain sites once again based on the nature, location and characteristics of the sites

would not lend themselves to a quick determination and may require further

investigations to be carried out. Once these investigations have been carried out in order

to address the uncertainty, the site can be re-assessed in terms of the above categories.

This category would apply to long term management options.



5.4 AREAS OF INTERVENTION

The 36 sites listed in Table 4 below were visited by the task team members. It should be

noted that of the 36 sites, two sites (namely MP16 and MP17) were reference sites.

Table 4: Areas of Intervention - Sites visited during the field investigation

No. Code Description of Measurement/Monitoring Point Location

1 MP1 Tudor Dam south side, about 50m distance to wall and bank each Mine

2 MP2 Stream bottom 150m downstream of Tudor Dam Mine

3 MP3 Upstream wetland Kagiso near Kagiso ext 8 turnoff Public

4 MP4 Downstream wetland Kagiso (at bridge of road Azaadville-Kagiso) Public

5 MP5 Private garden Kagiso-SW near MP4 Public

6 MP10 Small dam of van Greuning's farm near road 599 Public

7 MP11 Mine water pipe from Randfontein Estate GM at van Greuning's farm Public

8 MP12 Donaldson Bridge on road R559 Public

9 MP13 Donaldson Dam Northern part fishing station Public

10 MP14 Donaldson Dam southern part, caravan station (at the wall) Public

11 MP16 Wetland Muiskraal at culvert that crosses the sand road Public

12 MP17 Klerkskraal Dam, east side Public

13 MP18 Runoff seepage collection pond at slime dam north of Doornfontein Public

14 MP20 mine water from Doornfontein shaft and runoff water from slime dams Mine

15 MP21 dam NW from Elandsand GM Public

16 MP22 Canal from Blyvooruitzicht GM, bridge on road to Welverdiend Public

17 MP23 Canal from West-Driefontein GM (from SE of Carletonville) Public

18 MP24 Canal from West-Driefontein GM (from E of Carletonville) Public

19 MP25 Storage/sedimentation ponds E of Carletonville (overflow water ) Public

20 MP26 Canal from West-Driefontein GM Public

21 MP29 Harry's Dam, upstream part Public

22 MP30 Harry's Dam, downstream (after crossing the sand road) Public

23 MP34 Water edge Bridge Plot 68 (Paul Matthee) Public

24 MP35 Water edge bridge near Agricultural Holdings Public

25 MP36 Padda Dam (western bank) Public

26 MP37 Furrow at Khutsong bridge Public

27 MP38 Bridge of R501 at Blyvooruitzicht GM (SW of Carletonville) Public

28 MP39 Canal crossing R501 at Blyvoorruitzicht GM (SW of Carletonville) Public

29 MP40 Doornfontein canal from Blyvooruitzicht GM (sand road to Coetzee's farm) Public

30 MP41 Wetland upstream of Coetzee Dam Public

31 MP42 Weir DWAF flow gauging station C2H069 Public

32 MP43 Coetzee Dam (upstream part, stagnant area) Public

33 MP44 Wall of Coetzee Dam (near overflow to Visser Dam) Public

34 MP45 Visser Dam (Southern bank) Public

35 MP46 Former wetland downstream of Lancaster Dam Public

36 MP47 Abandoned dam in Rietvalei (SE of Randfontein) Public



6. OBSERVATIONS AND RECOMMENDATIONS

It should be noted that at this point in time the true extent of the contamination at the

various sites is not known, as in most cases only one grab sample was collected. Even

at the sites (Donaldson Dam, Padda Dam, Coetzee’s Dam, Visser’s Dam) where

multiple samples were collected in a grid pattern, the exact depth of the contamination is

not known, as samples were collected as 0,5m cores. In all cases a thorough survey of

the site should be undertaken to determine the exact area that should be cleaned as well

as the depth to which action will be required.

Where the clearing action could cause irreparable environmental or ecological damage,

the decision to clean up or not should be based on the hazard that the area poses (i.e.

the benefit of cleaning up) as opposed to the environmental damage (the cost of

cleaning up). This is especially true for the wetland areas. It should be noted that the

cost (in monetary terms) of cleaning up does not play a role here.

The following is a listing of the areas that potentially may require intervention to mitigate

potential consequences from radiological contamination in the Wonderfonteinspruit

catchment visited and a summary of the comments made the specialists (See complete

reports by the specialists in Appendix F). The discussion below groups the sites visited

into the five categories which were used for the assessment of each site in terms of

priority for the action.

6.1 CATEGORY 1

6.1.1 MP1

Tudor Dam South Side – About 50m Distance to Wall and Bank Each

Observations

The Tudor dam is located in the south

eastern portion of the headwaters of the

WCA. The dam was build before the

establishment of Rand Water for water

supply to the mine(s) in the area.

The area behind the dam is currently dry

and being mined by a company called

Mintails to recover gold from the

sediments that have accumulated as a

result of past mining practices considered

inefficient by today’s standards.



At the time of the field visit it appeared that the re-mining had ceased. During the

inspection there was no inflow or outflow of water and the dam was dry. There is

however evidence that during rainy periods that water would flow into and out of the

dam.

The soils and sediments at the site are potentially contaminated with radionuclides.

There is evidence of sulphate “evaporates” on the surface of the sediments. The activity

concentration of uranium 238 in the soils and sediments behind the dam are high, 8000-

10000 Bq/kg with radium 226 at 1700-2800 Bq/kg.

Recommendation

Remediation of this site, from a radiological health perspective is required, in order to

meet ALARA levels. (ALARA is the concept to be followed in radiation protection that

states that all practices are to be carried out in a manner in which radiation

exposure/doses are kept As Low As Reasonably Achievable below the dose limits,

social and economic factors taken into account.)

It is recommended that recovery of material containing in excess of 0.5 Bq/g (This is a

South African release level – implying that if all radionuclides are less than this level the

site may be released for unrestricted use) of any radionuclide be the target. It is

suggested that the remediation be completed within the next year and that a complete

rehabilitation plan from the responsible parties, with timelines and rehabilitation

objectives, be submitted to the NNR, DME and DWAF, for approval by the authorities,

within 3 months. If the detailed remediation implementation plan provides evidence that

achieving the 0.5 Bq/g clearance target is not feasible then an ALARA justification for a

higher value must be carried out and approved by the regulator.

The Mine is currently in violation of its Water Use License at the Lancaster Dam site and

the immediate remediation of the Tudor dam site may be considered as a part of an

overall “package”. If the Mine does not agree to do this within this time frame the

regulator could require that all licensed areas be fenced and made off limits to the public

until such time as the site is rehabilitated.

It should be a requirement that this and any surface mining (dams, slimes piles, waste

areas etc.) projects continue uninterrupted until the area is fully remediated and not left

in a contaminated state, in which a potential public health hazard may exist. Currently it

would appear that ALARA is not being achieved and the operations appear to be

discontinued as soon as the profitable material has been removed.

As a condition of its license to mine the old dam sediments the Mine must be required to

mine and remediate as mining takes place. The site can in this way be converted from a

mining site to a rehabilitated site. Once mining is completed, the site should be graded



removing any hazards and re-vegetated. Access roads should be removed following

remediation to prevent illegal dumping in the rehabilitated areas. The site rehabilitation

should be inexpensive and yet yield significant returns as a model reclaimed site.

There must be follow-up inspection by the NNR & the DWAF to confirm if cleanup is

carried out as per the licence requirements. Independent sampling should also be

conducted by the regulators since post-remedial sampling must ensure that residual soil

levels of specified contaminants do not exceed remediation license levels and that the

dose from all residual radionuclides will not exceed 1 mSv/a taking into account

institutional control for the specified land use.

6.1.2 MP2

Stream Bottom 150m Downstream of Tudor Dam

Observations

This site is a dry “wetland” below Tudor

Dam. The channel contained well-sorted

fine sediments, most likely, slimes

deposited from the overflow from Tudor

Dam.

Uranium and radium activity

concentrations were high here, at 2000

Bq/kg for uranium and 1200 Bq/kg for

radium, as would be expected if they

originated from the Tudor Dam. This site

has contamination of radioactive material

exceeding exclusion levels of 0.5 Bq/g per nuclide and will need to be remediated prior

to the site being released from regulatory control.

Recommendation

The site presents medium-high uranium and/or radium levels, exceeding national or

international clearance standards.

Remediation will be inexpensive and easy and should be done soon. Unlike the Tudor

Dam area this area is not within the Mine’s authorised mining area or responsibility.

However, most of the sediments will be disturbed as a result of the poor mining practices

at Tudor Dam and above. During mining the Mine was responsible to contain this

material and should be required to clean up the material.



It will also be a lot less expensive for the Mine to clean it to release levels and receive

mine closure rather than fencing it to keep people out and maintaining the fencing. It is

recommended that this area be cleaned to release levels immediately following the

rehabilitation of Tudor Dam site within the next 3 years or an ALARA justification

provided as to why this should not be carried out.

Any erosion of material from this area will wash down into the Lancaster dam area and

will have to be dealt with the mine at this location. Once this area has been cleaned up

to release levels no significant amounts of materials would be available to wash

downstream into the Lancaster Dam. It would be advisable to implement remediation

action at Tudor Dam before remediation of Lancaster Dam to avoid recontamination of

downstream areas.

However, there are a number of environmental legislative requirements that the Mine

would have to comply to before any operations may be allowed to continue. This site

must be cleaned up as part of the current Tudor dam cleanup operation. The Regulators

must ensure that this requirement is incorporated in the current clean-up plan of the

Tudor Dam.

6.1.3 MP18

Run Off Seepage Collection Pond at Slimes Dam North of Doornfontein

Observations

Slimes appear to have spilled across field and into the canal where it is likely to be

carried through to the Wonderfonteinspruit and discharged near MP40 and MP41 and it

is this spill that may be responsible for the high levels of uranium seen in the Coetzee’s

and Visser dams. The cleanup of the spill is continuing.



Recommendation

This site is essentially characterised by pollution spills from the slimes dam and poor

management and therefore proper pollution control monitoring measures should be in

place.

The primary measure to be implemented for the remediation of this site is related to

stricter regulatory controls. There was clear evidence of a breach in the wall of one of

the containment paddocks resulting in slime spillage. The Mine should be instructed to

repair the breached wall immediately and to embark on a process to remediate the slime

spillages. The work should be complete by the start of the rainy season so that there is

no further potential for slimes discharge to the canal and river.

6.1.4 MP20

Mine water from Doornfontein Shaft and Runoff Water from Slimes Dam

Observations

This area is largely problematic due to the poor housekeeping at the site. There was a

leak at the pump station that was not contained and has not been addressed. There is

evidence of slimes around and downstream of the pump station. There was also

evidence of cattle grazing around the pump station, with relatively fresh manure directly

on top of the escaped slimes. Contamination from water and the slimes was

unacceptable, according to the reports, particularly in the form of radium, at 1750 Bq/kg.

Recommendation

This is a category 1 site and remediation should not be delayed.

Mine personnel indicated that it would be cleaned up in the very near future. The

regulator should encourage this to prevent the slimes from spreading. There is a fence

to keep cattle out, but it must have been built very recently as the manure on and about



the slimes spill was fresh. Regular inspections and audits should be carried out on this

site to monitor the required clean up action as well as ongoing application of good

housekeeping principles.

6.1.5 MP23

Canal from West Driefontein GM (from SE of Carletonville)

Observations

There are a total of 16 settling ponds that

are currently being used for settling of

solids prior to the water being discharged.

These ponds are all on mine controlled

property and are part of a mine water

treatment polishing system and are

fenced off from the public. Canals carry

water from shafts number 8 and 10 into

the group of 16 ponds that ultimately

discharge to a canal that discharges to

the Wonderfonteinspruit.

The water from shaft number 10 is primarily fissure or intercepted groundwater. The

water from shaft number 8 is process water with contamination levels higher than shaft

number 10’s water. Flow typically is 30-35 Ml per day. Thus, the ponds receive about

2 Ml of water per day. There is also treated sewage water coming in from a golf course.

The ponds are approximately 50 x 150 m in size and 1 m depth. So there is a 3-4 day

residence time in each pond. The ponds primarily serve as sedimentation basins. A

farmer has been using process water for irrigation. The mine is attempting to buy out the

farmer to stop the use of the process water for irrigation

Recommendation

Although this area would appear to be of no immediate concern since it is being

controlled by the mine, improvements to the ponds could reduce the waste load even

further. Therefore, the area could be classified as Category 1. The main purpose of

these dams is to reduce the water contaminants through settling and activity distribution

to arrive at acceptable water levels before discharge. In this respect the dams seem to

be insufficient and need attention. The mine is required to comply with discharge

regulations and therefore needs to upgrade the settling dams.

As long as public access is restricted the dams only require proper decommissioning

once their useful life is finished. The farmer should cease using process water for



irrigation as soon as is practical. The ponds are not an area of concern. The ponds could

be configured to remove even more uranium from the water, but that is not of immediate

concern. Once the process water is no longer used for irrigation, these sites are not

areas of concern. The monitoring system at the site should also be upgraded by the

mine.

6.1.6 MP24 and MP25

Canal from West Driefontein GM (from E of Carletonville)

Storage/Sedimentation Ponds E of Carletonville (Overflow Water)

Observations

These sites are on mine property and are part of the operational processes of the mine.

The access to the site is well controlled and managed. The sedimentation ponds consist

of a series of sixteen ponds which are used as storage and sedimentation facilities for

the treatment of the mine water. The ponds are cleaned out in four year cycles with the

sludge being disposed on existing mine facilities. The sludge is therefore not sampled. A

farmer in the vicinity (the Brink family) has been using process water for irrigation.

However, based on information received from mine personnel, the contract facilitating

this use will not be renewed when it expires at the end of 2008.

Recommendations

The area does not pose an immediate health hazard to the public based on the access

to the site itself. However, it is recommended that the regulatory controls pertaining to

the site should be enforced more stringently and that the operational management of the

site be controlled by means of the Water Use License.



6.1.7 MP26

Canal from West Driefontein GM

Observations

This is at the junction of the two canals

that discharge water from the mine and

during the field investigation it was

observed that local inhabitants were

using water for washing clothes. Just

below this point the canal flows past an

informal settlement. The greatest hazard

associated with this area is related to the

easy access to the water in the canal by

the local residents.

Recommendation

Water should be supplied to the local people so that they do not use canal water for

drinking purposes.

The mine must at all times comply with their licence conditions. Water should be

supplied to these people so that they do not use canal water for drinking purposes. The

mine should not be allowed to discharge water unrestrictedly into the public domain if it

does not comply with, at least, the drinking water standards.

It is suspected that there has been significant water (and contaminant) loss to the

dolomites underlying this and the other canals over the long term. At the time of

decommissioning these sources of potential groundwater contamination should be

quantified and their contribution factored into the long-term rehabilitation groundwater

portion of the overall remediation model for the Wonderfonteinspruit



6.1.8 MP34

Water Edge Bridge Plot 68 (Paul Mathee)

Observations

This site is located in the

downstream section of the

“greenbelt” canal that runs through

the Carletonville area. This

“greenbelt” canal is essentially a

dry stream bed that carries storm

flow. Along the flow path of the

stream bed there was evidence of

pockets of slime spills in isolated

areas. It was evident that that

these slime pockets were a result

of a previous slime spill from

Blyvooruitzicht mine which is upstream of the stream bed. The stream bed contains

evidence of tailings having been washed down into it from an upstream slimes spill.

Recommendation

This whole storm water channel bed should be surveyed with a gamma (or scintillation)

survey meter and if significant areas of slimes are found they should be cleaned up

applying ALARA. While doses calculated in this area during previous studies are high

the values are considered very conservative and a re-survey and re-assessment is

recommended justifying the clean-up actions..

This whole storm water channel bed should be surveyed with a gamma (or scintillation)

meter mapping significant areas of slimes as they are identified. The areas where

pockets of slime are identified during the survey must be immediately remediated with

the material being removed to a suitably approved disposal facility.



6.1.9 MP35

Water Edge Bridge near Agricultural Holdings

Observations

This site is located in the upstream

section of the “greenbelt” canal that

runs through the Carletonville area.

As with the observations at MP34,

isolated pockets of slime spills

were evident in the stream bed.

This area would not appear to pose

any immediate radiological hazard,

but the radiation dose presented in

other studies seems high. Based

on this information, this is classified

as a category 1 site.

Recommendation

The “greenbelt” canal and the storm drainage down to the Wonderfonteinspruit should

be surveyed with a gamma (or scintillation) meter and if any significant areas of

contamination are detected they should be cleaned up as mentioned for the downstream

portions of this storm water drainage (MP34).

6.1.10 MP38

Bridge of R501 at Blyvooruitzicht GM (SW of Carletonville)

Observations

This site is located downstream of the

entrance to Blyvooruitzicht Mine on the

R501. There is a slimes dam upstream of

this site. A slime spillage had occurred at

this slimes dam due to the failure of one

of the paddocks. The resultant spill

caused slimes to be deposited in the

channel and this spill was also the cause

for the pockets of slime observed in the

“greenbelt” canal stream bed.

At the time of the field investigation it



was clear that clean up actions had already commenced to address the impacts of the

spill.

Recommendation

Although it was clear that remedial action has already been taken to address the slimes

spill which had occurred upstream of this location, this site has been listed as Category 1

due to the impact on the “greenbelt” canal stream bed which needs to be addressed as a

matter of priority. Furthermore, the remediation of the spill site needs to be monitored

and audited in order to ensure that the corrective measures implemented are adequate.

6.1.11 MP39

Canal Crossing R501 at Blyvooruitzicht GM (SW of Carletonville)

Observations

The site characteristics for this area are the

same as for MP38.

Recommendation

Remedial measures for this site will be the

same as for MP38.

6.1.12 MP40

Doornfontein Canal from Blyvooruitzicht GM (Sand Road to Coetzee’s Farm)

Observations

This canal contains water that is

discharged from the Blyvooruitzicht Mine

into the Wonderfonteinspruit.

Recommendation

Appropriate remediation upon

decommissioning will be required and as

the case with all of the canals its

consideration as a potential source of

groundwater contamination must be



addressed as a part of the overall long term strategic remediation plan for the

catchment. Stricter regulatory controls need to be enforced by the regulatory authorities

in order to mitigate impacts on water quality.

6.1.13 MP46

Lancaster Dam

Observations

The area behind the Lancaster Dam appeared to have filled with slimes that have

recently been mined. The Dam had been breached by heavy equipment so as to allow

acidic slimes water and fine slimes to drain into the pond and wetland immediately below

the dam. On this downstream side of the dam, there is an orange pool of settled slimes,

filled with acid mine drainage water, where there are few plants and signs of dead

wildlife. Dry slimes were observed blowing throughout the Lancaster dam site. Drainage

of water from this area was ongoing at the time of the site visit.

As the site presently exits it is suspected that acutely toxic acidic drainage is currently

draining from the site through the breach in the dam into the pond and wetland

immediately below the dam. Because of the lack of any flow restriction this could

become an extremely serious situation following a heavy rainfall. The main pollutants are

suspected of being acidic water and associated toxic metals arising from oxidation of

sulphides such as iron sulphide, also known as pyrite. The stream presently passes

through the breach in the Lancaster Dam, with visible seepage of slimes from the

Lancaster Dam into the stream which forms the upper Wonderfonteinspruit.

Recommendation

The following action should be taken as a matter of priority:

• The dam be immediately repaired and that all water that collects above the repaired

dam be collected in an engineered sump system and be pumped to a suitable



treatment facility and treated prior to release to the environment so as to meet all

applicable regulatory discharge standards. The dam and treatment facility shall be

maintained in good repair until the site is fully rehabilitated and released from

regulatory control.

• That a mining and rehabilitation plan for the Lancaster dam site be prepared and

submitted to the licensing authority for approval within a year.

• Note that the municipal landfill is also likely contributing contaminated seepage to the

water above the Lancaster Dam. There may be an advantage to the mining company

and the municipality jointly working together to address water quality issues above

the Lancaster Dam.

• The extent of the contamination in the section between Lancaster Dam and the

highway where the flow crosses the highway in a culvert is unknown. In this area

sediment sampling should be carried out to determine the extent of slimes

contamination as a consequence of the breach of the Lancaster Dam and possibly

earlier discharges. This sampling should be comprehensive in both aerial extent and

depth.

• The section between the dam and the highway is classified as a category 2 area that

should be remediated following the rehabilitation of the dam if sampling shows

significant contamination in this area. Remediation will in all likelihood involve

excavation of the contaminated sediments and replanting of the wetland vegetation

and this may require additional permitting depending upon the classification of the

wetland.

• The lower section lies between the highway and the blocked off fill road crossing the

wetland near the high voltage transmission lines. This area should also be surveyed

spatially and with depth, and if found to contain a significant amount of slimes also

be categorized as a category 2 area and be remediated at the same time as the area

above the highway.

• A detailed sampling, analysis plan for both of these areas should be developed and

implemented within the next year and a remediation plan developed within the

following year. Remediation of this area should only be implemented following the

remediation and stabilization of the area above the Lancaster Dam so as to prevent

its recontamination.



6.1.14 MP47

Abandoned Dam in Rietvalei (SE of Randfontein)

Observations

This is an area below one of the Rand Uranium (Harmony) tailings areas into which a

slimes spill occurred following the breach of a small retaining dam. Presently the slimes

are not contained and pose a hazard of moving downstream into the catchment following

heavy rains.

Recommendation

Actions are being taken by the Mine at the site and discussions with a Mine

representative suggest that they are preparing for a cleanup. The Mine should be

required to clean this up as soon as possible so that slimes are not allowed to migrate

further downstream. The area downstream should be cleaned up to <0.5 Bq/g per

nuclide of soil so as to allow the area to be removed from licensing and minimize any

residual slimes that may wash downstream. If this cannot be achieved an ALARA

justification should be presented for approval to the regulator. A gamma survey

correlation with radionuclides and potentially toxic trace elements found in slimes should

be developed such that cleanup efforts at this and other sites can be monitored in “real

time” reducing the potential need for remobilisation of cleanup actions when a

confirmation survey is carried out by the regulator.

The downstream survey at this site should extend as far as where the tributary channel

enters the Wonderfonteinspruit. Following the cleanup the paddocks and the secondary

downstream dam should be inspected to ensure that they are constructed to withstand a

slimes release that may be consistent with up to a 100 year storm if re-mining of the

slimes in the upstream section will take place within the next 10 years.



6.2 CATEGORY 2

6.2.1 MP29 and MP30

Harry’s Dam, Upstream Part and Harry’s Dam, Downstream (after crossing the

sand road)

Observations

This site appears to have relatively high sediment concentrations of uranium and radium

but poses no immediate health hazard. The pond is on the saturated side of the dyke

and may support a natural seasonal static water level. Without mine water flow into the

pond water quality will rapidly deteriorate if cattle are allowed access directly to the pond

for watering. Just above these sites is the discharge point of the 1m pipeline. Some of

the water goes to Harry’s Dam and the rest is transported to the Mooi River in an open

canal. There is considerable uncertainty about the location of the samples taken during

previous studies and why the sediment uranium and radium activity conetrations are as

high as observed, 1500 Bq/kg and 1600 Bq/kg, respectively. The dam is shallow and

easy to drain. A dose constraint of 0.25 mSv/a is applied for a specific source by the

NNR to ensure compliance to the limit of 1 mSv/a by all sources. For dry soil and

sediment contamination it is mostly easier to apply the 0.5 Bq/g per nuclide release

criterion which for the majority of cases will ensure that the underlying dose criteria are

met.

The mine is having an impact on this dam, and it is as a result of the mine non-

compliance or lack of controlling measures (such as the settling dams) that has caused

the high level of radionuclides in the sediment in this dam. The regulators need to

ensure that the mine complies with discharge regulations and therefore the settling dams

need to be upgraded and Harry’s Dam must be cleaned up.



Recommendation

As long as public access is restricted this only requires proper remediation once its

useful life is finished because the dam serves no useful purpose and is on mine owned

land. It is shallow and easy to drain. It should be remediated as soon as is practical,

remove the sediment to a slimes dam, and divert water around the dam and into existing

canal. This remediation could be done over the next 1-3 years.



6.3 CATEGORY 3

6.3.1 MP12

Donaldson Bridge on Road 559

Observations

Just upstream of this area irrigation water

is being used from the

Wonderfonteinspruit. Water quality and

quantity usage should be monitored at

this site during upstream remedial

activities (when higher levels of

contaminants may exist in the water) to

ensure that irrigation is only for small

scale farming, and not subsistence use

where all of the food is being used for

consumption by the residents, until such

time as levels of uranium and other

radionuclides that are present in the water drop to acceptable levels. Soils from this area

should be sampled as part of the catchment research and evaluated for retention of

radionuclides and trace contaminants to help justify catchment specific irrigation water

quality criteria for the catchment.

Recommendation

The available data suggests this wetland site would appear to pose no immediate

hazard and would be classified as a category 3 site where natural attenuation processes

should be allowed to occur.

The wetland area should also be surveyed using gamma (or scintillation) and

confirmatory chemistry technique to determine if there are any areas that are justified in

remediating in the wetlands above Donaldson dam.



6.3.2 MP13

Donaldson Dam Northern Part Fishing Station

Observations

This site is located in an older portion of

the Donaldson Dam property which had

been extensively used for recreational

purposes in the past. Evidence of an old

swimming pool and other recreational

water features was visible. However,

these features have been removed and

the site is not longer a recreational area.

The site is accessed by residents from

Bekkersdal to a limited extent and needs

to be addressed in terms of management

and impact.

Recommendation

Contaminants in sediments in Donaldson dam need to be surveyed and magnitude of

contaminated sediments quantified to determine if remediation is justified. If significant

contamination justifies remediation this area should be remediated only once

remediation of upstream areas has been addressed to prevent potential

recontamination.

6.3.3 MP14

Donaldson Dam Southern Part, Caravan Station (at the wall)

Observations

The point is just downstream of

Donaldson Dam where a 750mm pipe

that carries the controlled release for the

Donaldson Dam, discharges into the

beginning of the 1 meter pipeline.

Recommendation

The area of the old stream channel below

the Donaldson Dam should be surveyed

with a gamma (or scintillation) survey

meter and if found to contain any

significant areas of slimes justifying cleanup (the area below Lebanon Road would

appear to be such an area) these areas should be classified as category 2 sites and

remediated within the next 3 years as there is a possibilty of these materials being



spread throughout the catchment during periods of high flow. A major problem is that

solid waste and sewage from informal settlement is clogging the gratings causing

overflow. A trap to remove solid waste should be installed to avoid clogging and be

emptied periodically.

6.3.4 MP36

Padda Dam (Western Bank)

Observations

This dam is located between the

communities of Carltonville and

Khutsong.

Recommendation

This dam based upon available data

(there is a concern that the assessed

potential dose is probably over-

conservative and needs reassessment)

would appear to pose no immediate

radiological health hazard and is

classified as a category 3 site.

As part of the remedial survey of the catchment several core samples should be taken in

the pond and this conclusion validated or rejected as results dictate.



6.4 CATEGORY 4

6.4.1 MP5

Private Garden Kagiso-SW near MP4

Observations

This site was classified as an area of

potential concern because it was believed

that the water in the stream at this point

was used for irrigation. There was

evidence of a small garden (about 15m

by 15m) adjacent to housing in the area.

It is a site that is part of the MP4 wetland.

The soil is fill that was deposited upon the

slimes that make up the sediment of the

wetland. MP4 and MP5 are in close

proximity and part of the same wetland

system. There is minimal contamination in the fill soil, but it is likely that levels similar to

MP4 would be found below the fill. A soil sample from the garden was analysed but the

activity was at background level.

Recommendation

The amount of produce that could be produced from the garden and the activity

concentrations of radionuclides in the water that could potentially be use for irrigation

would not result in radiation doses that would justify a significant public health concern.

The section of the stream upstream and downstream of this site as far as where it enters

the attenuation dam should be surveyed for the presence of contamination and the

criteria for cleanup applied. Although the sediments of the attenuation dam were not

identified as an area or potential concern, additional core sample sediments should be

taken in the centre (deepest sedimentary basin of the reservoir) and analysed.

MP5 should be remediated as part of MP4. Gardening should be terminated as the crop

vegetation may concentrate uranium and daughter products in the plant tissues. This

would be a particular problem if the gardens were irrigated with the 2000 mBq/L water

from the stream.



6.4.2 MP11

Mine Water from Randfontein Estate GM at van Greunings Farm

Observations

Randfontein Estates Gold Mine had been

supplying water to van Greunings farm

for farming activities. The source of the

water supplied to the farm was

ascertained to be fissure water. However,

based on several studies and reports it

was clear that there was a water quality

impact related to the use of the water.

The mine has stopped supplying fissure

water to the farmer who is currently using

borehole water for farming purposes.

Recommendation

The main factor which contributed to this site being identified as a potential area of

concern was related to the use of fissure water for farming activities. However, based on

impact assessments, the mine has stopped supplying the farmer with fissure water.

Currently dolomitic water is being used on the farm. The specific remedial action for this

area must be verified before it can be considered complete.

6.4.3 MP37

Furrow at Khutsong Bridge

Observations

This site is located at the bridge to

Khutsong on the Wonderfonteinspruit

downstream of Padda Dam. Based on the

available information this site was not

deemed to pose a significant radiation

health hazard.

Recommendation

This area is not deemed to pose any

significant radiation health hazard and as

such remedial work may not be required.

The off-line pond upstream of the road crossing should be sampled and the stream bed

between the Padda Dam and the road and the stream downstream of the road should be

surveyed as part of the remedial survey to validate this classification.



6.5 CATEGORY 5

6.5.1 MP3

Upstream Wetland Kagiso near Kagiso Ext. 8 Turnoff

Observations

This site is located downstream of mining operations and is relatively extensive in area.

The area exhibited extensive impact related to domestic waste, illegal dumping and

sewage pollution. The extract extent of the pollution as well as well impact linked to

mining activities were not easily apparent and will require additional investigation prior to

any action being taken.

Recommendation

A survey should be completed and a remediation plan should be put together within the

next year and implementation within two years, following the approval of the plan and

obtaining the necessary authorizations.



6.5.2 MP4

Downstream Wetland Kagiso (at Bridge of Road Azaadville-Kagiso)

Observations

The site was formed from eroding slimes

dam and is bisected by a dirt road. The

most obvious visible feature of the site is

the extensive deposit of trash in the

wetland, by the road. Bags filled with

excrement presented an objectionable

odour and likely contribute to water and

sediment contamination. Uranium

contamination in the water was higher

than at most sites, at 2,200 mBq/L. The

slimes are in the process of being re-

mined. The local authority needs to be

instructed to clear the site of general waste material and ensure ongoing maintenance.

Recommendation

It is difficult to devise a specific remediation plan, but some action plans are in order.

The party remining the slimes should develop and submit an action plan now, as they

are remining. Remediation can take place while the responsible party is earning income

from the remining. The company should be required to make certain that there will be

money available should the responsible parties not remediate the site to mandated

levels. It may take several years for the site to be rehabilitated as remining takes place.

The company should remove the slimes and some upper top soil. The site should re-

seed naturally from the surrounding plants, but re-seeding could be enhanced if

necessary. Turn the wetland into part stream and part wetland. Bring the radiation down

to the clearance level of 0.5 Bq/g or a higher level justified by an ALARA analysis and

found acceptable to the regulatory authorities.



6.5.3 MP10

Small Dam of van Greuning’s Farm Near Road 559

Observations

This site is essentially a small farm/duck pond

on the van Greuning’s farm. The farm

previously used fissure water for irrigation,

resulting in moderate levels of uranium

contamination in the water and sediments.

Currently dolomitic water is being used, so

original samples taken for uranium are no

longer representative. The pH is 8.5 and there

is a flow from an upstream wastewater

treatment plant entering the pond at 17 Ml per day.

Recommendation

The dam itself is classified as a category 5 site, however, if significant slimes are found

upstream of the pond eroding into the water course they would be classified as a

category 2 area and immediate actions will need to be taken to remove them.

This section of the stream upstream of the pond and below the attenuation dam should

be surveyed to ensure that there is no slimes contamination (exceeding the cleanup

criteria) along the banks or in the sediment of the marsh area released from any pipeline

breaks or other sources near the gold or old uranium processing plant. If there is any

significant contamination exceeding the justifiable cleanup criteria discussed above

these areas should be remediated.

6.5.4 MP21

Dam NW from Elandsrand GM

Observations

The site is located to the Northwest of

Elandsrand Gold Mine and was not easily

accessible. This area would appear to pose no

significant radiological hazard and is classified

as a category 5 site.

Recommendation

The sedimentary areas in the pond upstream

and downstream of this site should be

sampled as part of the remediation justification



program. The access of the cattle grazing near the site could be restricted from the area

simply by adding and improving fences.

6.5.5 MP22

Canal from Blyvooruitzicht GM, Bridge on Road to Welverdiend

Observations

This site was in a canal and does not

appear to pose any immediate significant

radiological health hazard.

Recommendation

Mine personnel suggested that the mine

was going to zero discharge within a year

and water should stop flowing in this

canal. The mine should be encouraged to

do this. This as with all other canals

should be considered as a potential line

source of groundwater contamination to

be evaluated as a part of the overall catchment remedial model.

6.5.6 MP41

Wetland Upstream of Coetzee Dam

Observations

This site is characterised by the

Doornnfotein Canal discharge into the

spruit. The point of discharge occurs

upstream of the Coetzee Dam. No

significant radiological health issues would

appear to be posed at this site based upon

available data and further work will be

required in order to re-categorise the site.

Recommendation

The stream sediments need to be surveyed

above and below this area to validate that there are not significant slimes present that

would justify remediation applying the agreed upon criteria. It is suspected that

downstream areas may have significant slimes.



6.5.7 MP42

Weir DWAF Flow Gauging Station C2H069

Observations

This is the DWAF continuos monitoring

station in the Wonderfonteinspruit. No

significant radiological health hazards

would appear to be posed at this site.

Recommendation

For the site to be classified as a category

5 there must be a proviso that upstream

and downstream sections be included in

the catchment wide remedial survey.

6.5.8 MP43

Coetzee Dam (Upstream Part, Stagnant Area)

Observations

This site is located in the upstream inlet

to Coetzee’s Dam. The sediment sample

collected here appeared abnormally high

at 7700 mBq/kg U-238 and needs to be

validated as a part of a further catchment

remediation investigation.

Recommendation

Based upon the assessment this would

be classed as a site potentially requiring

remediation but not until the potential for

recontamination from upstream sources

has been reduced to insignificant levels.

The sediment at this site should be validated as part of a further catchment remediation

investigation. If the extent of contamination exceeds the criteria for this section of the

catchment then this remedial actions should be investigated. This would be classified as

a category 5 site with survey verification work to be carried out within the next 3 years as

part of the remedial cleanup justification program.



6.5.9 MP44

Wall of Coetzee Dam (Near Overflow to Visser Dam)

Observations

This site would not appear to pose any

significant radiation public health hazard.

The sediments should be spatially

sampled and cored as part of the

remedial justification cleanup survey and

if significant contamination present

dredged at the time of mine

decommissioning when the potential for

recontamination is not significant.

Recommendation

The sediments should be spatially

sampled and cored as part of the remedial justification cleanup survey and if significant

contamination present dredged at the time of mine decommissioning when the potential

for recontamination is not significant.

6.5.10 MP45

Visser Dam (Southern Bank)

Observations

Blyvooruitzicht process water flows to

Coetzee and Visser Dams. The sediment

samples taken here were scooped off the

sediment surface. There were no cores

taken of the sediment, and the scoop

sample is not adequate for interpretation

of data. The Visser Dam is the oldest

dam on the stream. Water is low in the

dam and some sediment is exposed on

the shoreline.

Recommendation

This site would not appear to pose any significant radiological hazard and is also

classified as a category 5 site because of what would appear to be high levels of

contamination in the sediment, but there is a significant level of uncertainty due to

methods of sampling. The sediments should be spatially sampled and cored as part of

the remedial justification cleanup survey and if significant contamination is present,



dredged at the time of mine decommissioning when the potential for recontamination is

not significant.

The sediment at this site should be validated as a part of the catchment remediation

investigation. If the extent of contamination exceeds the criteria for this section of the

catchment then this remedial actions should be investigated. This would be classified as

a site with survey verification work to be carried out within the next 3 years as part of the

remedial cleanup justification program.



7. RELEVANT ENVIRONMENTAL LEGISLATION

Development of cleanup goals is based primarily on the regulatory authority applied and

the risk assessment used. Legislation governing radioactively contaminated sites are

rather complex and somewhat confusing due to overlapping mandates of the different

authorities.

In undertaking remediation action, it is necessary to understand the regulatory

framework that controls or authorises and limits the radiological remedial action. In

essence no remedial action will take place without having obtained the required

regulatory authorisations. This section summarizes the various regulatory standards

and requirements that dictate cleanup at radioactively contaminated sites.

The main reasons that environmental legislation has to be taken into consideration are:

1. In the remediation of the AoI there will be Environmental Legislative requirements

that must be met, such as Environmental Authorisations. Legislation will have to be

complied with and taken into consideration in the remediation strategy. Legislation

may impact on the priority, time period of remediation and or even the type of

mitigating actions to be implemented, and,

2. That there are Legal requirements in terms of Environmental Legislation that is

applicable to pollution prevention and remediation, rectification of contraventions,

offences, etc. Legislation defines responsible parties and empowers the relevant

authorities to act against or enforce remediation or the prevention of pollution.

To address this action a specialist was appointed to address the environmental

legislative framework in which the remediation of AoIs needed to be done. A full copy of

the report can be found in Appendix E. Additional comments were made by the

Radiation Protection specialist which is included in the discussion below. A full copy of

that report can be found in Appendix G.

A summary of the main legislative issues are as follows:

• Pollution, as defined in the National Water Act (NWA), 1998 (Act 36 of 1998),

includes the indirect or direct alteration of the physical, chemical or biological

properties of a water resource so that it is less fit beneficial purpose, or harmful

or potentially harmful. This can be linked to Section 24 of the Constitution of the

Republic of South Africa (RSA);

• Definition of a water resource and a water course, which includes wetlands and

dams are important in the extent of the mitigating actions. NWA’s definitions of a

water resource and water course are very broad but also very clear what is a

water resource or water course. The only ambiguity is the flood lines, which is



clearly defined in Government Notice No. 704, 4 June 1999, NWA, which applies

in the development of the strategy.

• Polluter pays principle (Section 2 of NEMA) which requires that the persons

responsible for the pollution must cover the costs of prevention, remediation and

impacts of the pollution or impact from the activity. Section 5 and 8 of the NWA

discusses the establishment of National Water Resource Strategy (NWRS) and

Catchment Management Strategy (CMS). The WCA remediation plan must be

included in the strategies as they will be an integral part of the strategy to be

developed in the catchment;

• Section 19 of the NWA is an important regulatory tool specifically for DWAF to

give the responsible parties options to implement the remediation in the WCA

and to take legal and constructive intervention if so required. This is closely

coupled with Section 28 and 30 of the Nation Environmental Act (NEMA), 1998

(Act 107 of 1998);

• Section 20 of the NWA can be implemented in a more structured way to

implement a strategy of dealing with pollution incidents as they occur in the

future.

• Government Notice No. 704, 4 June 1999, NWA can also be used as a legal tool

and one of the fundamental pillars of the establishment of clean up and

prevention strategy in the WCA.

• Section 53 of the NWA is used where there is contravention of licence conditions

and in this exercise Section 19 can be used more effectively in a remediation

strategy.

• Section 151 of the NWA, taking a party to court for non-compliance, should seen

as a last resort. Legal action in court is a long and arduous process and does not

leave scope for remediation in a short period of time. If this action is followed it

should be done in conjunction with an action where the authorities take

responsibility of the remediation and in parallel seeks criminal and legal

compensation.

• Section 2 of the NEMA sets the principles for sustainability, and the need to

avoid any activities that degrade or pollute the environment. The remediation

plan must view this section from two angles; (1) the actions taken must take the

impact of the action on the environment into consideration and (2) whether the

remediation action taken will benefit the environment. This view or consideration

is in light that one of the objectives of the remediation plan only considers the

impact of the AoI on human health and not the environment.

• Section 24 of the NEMA requires that the EIA process must be followed.

However, there are processes which can be followed that will allow for

exemption. There are stricter EIA requirement for Wetlands that could influence

the priority of remediation or even the mitigating actions to be implemented to

effect the remediation.



• Section 28 of the NEMA is similar to Section 19 of the NWA, however, Section 28

of NEMA may not be allowed to be enforced in retrospect. In other words Section

28 only deals with current companies currently polluting.

• Legal action can be taken in terms of Section 32 of NEMA. However, this as

discussed above should be seen as a last resort or in parallel with other forms of

mitigating actions.

• Government Notice R388, promulgated in terms of Section 36 of the NNR Act of

1999 (Act 47 of 1999). In terms of the provisions of section 2 (2) (b) of the NNR

Act, the Act does not apply to solid materials where the level of radioactivity

concentration of each radionuclide in materials is below 0.5 Bq per gram for

naturally occurring radioactive nuclides of uranium and thorium and their progeny

except for radon.

• NNR guideline: a guideline document for the release of contaminated sites from

regulatory control. Section 6 of the above mentioned guidelines refers to Release

Criteria. Contaminated sites may either be released conditionally (restricted use)

or unconditionally (unrestricted use):

o Unrestricted Release of Land and Water

It is required that sites used in the conduct of authorised activities may be

released for unrestricted use provided that it is demonstrated that

radioactive contamination, which can reasonably be attributed to the

regulated activity, have been removed from the site. Compliance with this

requirement can be achieved by demonstrating that the activity

concentration levels are below those on the Background Reference Site.

o Restricted Release of Contaminated Land and Water

In the event that removal of radioactive contamination and radioactive

materials, which can reasonably be attributed to the regulated activity, is not

feasible, then release for use is allowed subject to any restrictions specified

by the Regulator provided that the following can be demonstrated:

(i) Compliance with an annual effective dose limit, applicable to the average

member of the critical group from residual contamination for all feasible

future situations. The limit must be approved by the Regulator on a case-by-

case basis and must provide sufficient assurance that the site-specific limit

that was applicable during operations will not be exceeded.

(ii) Remedial measures have been taken to achieve an optimal level of

safety, which is, cleaning to levels equivalent to that of exclusion. Under

these circumstances the regulator may choose not to put any restrictions.”



8. DISCUSSION

As part of the detailed catchment strategy justifiable criteria for instream remediation will

need to be developed. The remediation criteria will likely involve a combination of the

mass of contaminants present in the area to be remediated (volume of material x its

specific activity), its potential for rapid remobilisation into the water column, the

environmental damage or social disruption that may be caused by the remedial action

and the cost of carrying out the remediation. The criteria would likely be applicable per

meter of stream length as this would be an approximate proxy for the rate of release of

contaminants into the water volume (Bq/s/L) within the stream. These determinations

would need to be made in conjunction with the integrated catchment model where all

inputs (including contributions for remaining in-stream contaminants) are taken into

account. The surveys to determine the extent of the in-stream contamination should

extend as far onto the flood plain of the stream as the contamination extends.

As sections of the Wonderfonteinspruit are remediated it is essential that upstream

sections are made secure against further slimes and effluent release to the stream. This

will require that the paddocks and downstream retaining dams be designed in

compliance with regulatory requirements.

In principle five levels of action have been identified. They are:

Category 1:

This category would apply to sites which may or may not pose an immediate public

health hazard but which have been contaminated to some degree. The clean up of such

sites would be uncomplicated, requiring minimal capital and technical work. Such sites

would be considered as priority sites where remedial action could take place

immediately.

Category 2:

This category is applicable to sites that pose an immediate and significant public health

or environmental concern from the standpoint of radiological and environmental

protection. In the interest protecting the public and or the environment from significant

radiation or toxic material exposure it should be immediately remedied or cleaned up to

a standard acceptable to the regulatory authorities.

Category 3:

Sites which fall into this category will be characterised by some degree of contamination

and would in the longer term require strategic management. However, based on the

nature, location and characteristics of the sites, the remediation of such sites would

entail extensive costs (environmental costs) which would not in essence be justified by

the limited benefits which would be reaped from such action.



Category 4:

In many instances sites which had previously been identified as areas of high priority

requiring intervention have already been dealt with by the responsible party or regulatory

authority. Required action for the remediation of such sites would be considered as

complete without requiring any additional mitigation measures in the immediate future.

Category 5:

Certain sites once again based on the nature, location and characteristics of the sites

would not lend themselves to a quick determination and may require further

investigations to be carried out. Once these investigations have been carried out in order

to address the uncertainty, the site can be re-assessed in terms of the above categories.

This category would apply to long term management options.

8.1 IMMEDIATE INTERVENTION

In all, fifteen sites fall into Category 1 requiring immediate action, of which the wetland

downstream of Lancaster Dam (MP46) is the most urgent. The DWAF has already

issued a directive following the site visit, and this area is therefore being addressed.

Other sites such as MP 47, MP18, MP20, MP29 and MP30 are mostly related to

accidental spills from mining infrastructure and represent relatively small quantities of

easily accessible slimes. These sites were identified as priority areas requiring

immediate clean up.

Sites MP23, MP24, MP25, MP26 and MP40 have been prioritised as Category 1 based

on the fact that stricter regulatory enforcement will address the problem to a large extent.

MP34, MP35, MP38 and MP39 occur within the “greenbelt” canal in Carletonville and

are characterised by pollution due to slime spillage. Although cleanup action has taken

place at these sites, it was clear that some additional work will be required to complete

the cleanup action. The work required to achieve this is envisaged to be uncomplicated

and cost effective.

8.2 CLEANUP

Two sites, particularly for Harry’s Dam fall into Category 2 requiring immediate action for

clean up. It has been ascertained that these sites are a source of pollution from a dam

which does not serve any functional purpose. A plan for the remediation of these sites

must be developed in the short to medium term.



8.3 NO ACTION

Remedial action at Donaldson Dam and Padda Dam, where the level of contamination is

so low, that the damage that these systems would incur during a clean-up operation

does not appear to be justified at this time based upon the information available. In these

cases natural clean-up could occur if mines comply fully with their licensed discharges.

These sites include MP12, MP13, MP14 and MP36.

8.4 REMEDIAL ACTION COMPLETE

Only two sites, namely MP11 and MP37 fall into the category where no remedial action

will be required due to work already been done or no radiological impact.

8.5 FURTHER INVESTIGATIONS

A total of 11 sites fall into Category 5 and will require some form of further investigation

in order to determine the action which needs to be taken to address the contamination at

these sites. It is envisaged that the remedial action for these sites will form part of a long

term action plan which must be developed. Most of the sites in this category are

wetlands or dams that need more care in the way the clean-up action is conducted.

8.5.1 Wetlands

For wetlands the following course of action is recommended:

� A survey to determine the nature of the wetland with the eye on rehabilitation

after the clean-up,

� A survey (sediment core samples collected on a grid) to determine the extent and

local and catchment significance of the sediment contamination,

� An assessment of the incremental effect on the catchment water quality of the do

nothing option and a series of graded remedial options up to complete cleanup.

� The selection of the best option’s engineering implementation strategy so as to

minimize costs, local social disruption and effects on downstream water quality.

� Clean-up of the contaminated portion of the wetland (mucking out during the dry

period), and

� Rehabilitation of the wetland.

Wetlands are protected by law, and authorisation for the clean-up action will have to be

obtained from the environmental authorities.

8.5.2 Dams

For dams much the same course of action is required as for wetlands:

� Collect sediment samples on a grid pattern to establish the extent of

contamination,



� Drain the dam and allow the sediment to dry to a spade-able consistency,

� Muck out the contaminated sediment, and

� Close the dam and allow refilling.

There must be caution in mucking out any dams. The existing sediment may seal the

bottom of the dams. If removed, the dams may become more permeable, resulting in

dissolution of the underlying dolomites and formation of sink holes. The necessary

licences and authorisation for this action must be obtained before the actual cleaning up

starts. Issues such as permeability or sink holes will be taken into consideration during

this evaluation process.



9. REMEDIATION ACTION PLAN

Table 5 below provides an overview and brief summary of the actions to be taken pertaining to each site and its associated

category. The sites have been listed in order to priority in terms of the action to be taken.

For the purposes of this plan the timeframes recommended are structured as follows:

• Short Term: 0 – 1 year

• Medium Term: 1-3 years

• Long Term: 3-5 years

Table 5: Remediation Action Plan

AoI Responsible

Party Short Term Medium Term Long Term

C

A

T

E

G

O

R

Y

1

MP46 Mine

• Breach in dam wall to be repaired

• Install Engineered sump to collect water

• Assess impact of municipal landfill

seepage adding to contamination

• Develop and implement detailed

sampling analysis plan

• Develop a mining and rehabilitation plan

for Lancaster Dam

• Remediate and stabilise Lancaster Dam

area upstream of the wetland

• Assess extent of contamination between

Lancaster Dam and the highway

• Conduct sediment sampling to determine

extent of slimes contamination in this area

• Comprehensive remediation of the

wetland area downstream of Lancaster

Dam

MP47 Mine

• Ensure that the current land preparation

activities are conducted efficiently

• Downstream area must be cleaned up to

<0.5 Bq/g per nuclide of soil or to

background levels

• Develop a gamma survey correlation with

radionuclides found in slimes to allow

“real time” monitoring

• Initiate cleanup of paddocks and

downstream secondary dam

• Extend the downstream survey to the

confluence of the tributary with the

Wonderfonteinspruit

• Ensure that paddocks are suitably

constructed to handle a slimes release if

re-mining is to take place

MP1 Mine

• Recover material containing in excess of

0.5 Bq/g of any radionuclide or in excess

of background levels



AoI Responsible


• Submit complete rehabilitation plan with

timelines and rehabilitation objectives to

regulatory authorities

• Implement concurrent mining and

remediation

MP2 Mine • Responsible mine must clean up the

contaminated sediments in this area

• Following the remediation of Tudor Dam,

this site must be cleaned up to closure

standards

MP18

Mine

DWAF

NNR

• Ensure stricter regulatory controls are

implemented

• Repair breach in wall of containment

paddock

• Clean up the slimes spill resulting from

breached wall

MP20

Mine

DWAF

• Poor housekeeping must be addressed

• Regulators must inspect site to ensure

cleanup of slime pockets

• Equipment must be maintained and

monitored to prevent overflows

MP23

Mine

DWAF

• Finalise Water Use License

• Enforce compliance with discharge

requirements

• Upgrade monitoring system

• Assess suitability of dams to reduce

contaminants by settling

• Identify alternatives for treatment

• Implement Best Practicable

Environmental Option for treatment

MP24

MP25

MP26

Mine

Local

Authority

• Supply water to local residents

• Implement measures to limit access to

water in the canal

• Ensure compliance to license conditions

• Regularly monitor local access to and use

of water from the canal

• Quantify sources of potential groundwater

contamination

MP34

Mine

DWAF

• Survey whole area with gamma (or

scintillation meter)

• Cleanup areas of contamination where

the radiation is above 0.5Bq/g or to

background

• Physically remove contaminated material

and dispose at nearest mine

• Implement ongoing monitoring for residual

impacts

MP35

MP38

MP39

MP40 Mine

DWAF • Enforce stricter regulatory controls

• Assess the canals contribution to

groundwater contamination



AoI Responsible


C

A

T

E

G

O

R

Y

2

MP29

Mine

DWAF

• Assess the value of the dam to the local

system

• Conduct impact assessment of removing

dam

• Identify possible options or alternatives

for remediation of the area

• Develop a remediation plan for the

removal of the dam

• Initiate the actions required for the

remediation

• Complete remediation of the area

MP30

C

A

T

E

G

O

R

Y

3

MP12

Mine

DWAF

Local

Authority

• Survey area with gamma (or scintillation

meter) to confirm categorisation

• Assess the area below Lebanon Road

• Ensure cleanup of solid waste and

sewage from informal settlement clogging

the gratings causing overflow

• Install trap to remove solid waste and

ensure regular maintenance

• If significant areas of slime are found

below Lebanon Road remediation must

be conducted within the next 3 years

• Allow natural attenuation to occur

• Re-assess sites pending cleanup action

at upstream sites

MP13

MP14

MP36 Mine

DWAF

• Validate categorisation by taking core

samples

• Allow natural attenuation to occur

• Re-assess sites pending cleanup action

at upstream sites

C

A

T

E

G

O

R

Y

4

MP5 Mine

DWAF

• Survey upstream and downstream sites

for presence of contamination

• Core samples must be taken in the

centre of the reservoir to ascertain extent

• Crop vegetation should not be allowed in

this area

MP11 Mine

DWAF

• Action has already been taken

• DWAF and Mine to monitor situation

• Specific remedial action for this area

must be verified before it can be

considered complete

MP37 DWAF

Mines

• DWAF to monitor situation

• Remove slimes and some upper soil

based on assessment of extent of

contamination



C

A

T

E

G

O

R

Y

5

MP3

DWAF

Mines

Local

Authority

• Local Authority to ensure cleanup of

illegal dumping

• Conduct Survey of wetland area

• Develop long term remediation plan

• Implement remedial actions according to

plan

MP4

DWAF

Local

Authority

Mines

• Mine must develop and submit an action

plan to address the remining aspects

• Local Authority to ensure cleanup of

solid waste material at culvert



• Reduce radiation levels to 0.5Bq/g or to

background levels

MP10 Mine

• Allow natural attenuation to take place

• Mine must survey for slime pockets

• If found, slime pockets must be removed

• If there is any significant contamination

exceeding the justifiable cleanup criteria

these areas should be remediated.

MP21 Mine • Sample sediments in pond area as part

of long term remedial program •

• Long term remedial action to be identified

and plan developed

MP22 Mine

DWAF

• Monitor zero discharge commitment by

mine

• Assess potential for groundwater

contamination


and plan developed

MP41 Mine

DWAF • Survey stream above and below area




and plan developed

MP42 Mine

DWAF

• Include upstream and downstream

sections in catchment wide remedial

survey

MP43 Mine

DWAF

• Conduct sediment survey to validate

category

• Carry out survey verification work

• Identify possible remedial actions linked

to upstream remediation

• Initiate remedial actions after upstream

actions have taken place


and plan developed

MP44 Mine

DWAF

• Conduct sediment survey to validate

category







and plan developed

MP45 Mine

DWAF

• Uncertainty due to sampling methods

needs to be addressed

• sediments should be spatially sampled,

cored and analysed







and plan developed



9.1 NEXT STEPS

Based on the findings and recommendations of the STT a Remediation Action Plan has

been compiled. This plan together with the map of the AoI needs to be presented to the

stakeholders in the WCA. The major actions which need to be undertaken are as follows:

• Finalisation of the Remediation Action Plan after presentations to the SCRMRRC,

and the WCAPTWG.

• Establish and cooperate with the Public Involvement and Participation (PIP) Team in

order to facilitate the implementation of the remediation plan.

• Presentation of the Remediation Action Plan to the stakeholders and interested and

affected parties in the WCA through the PIP.

• Address comments received from the various stakeholders,

• Establishment of the Implementation Task Team (ITT),

• Development of an action and time based plan by the ITT for the implementation of

the recommended remediation.

• Confirm the roles and responsibilities of the various parties in the remediation

process.

9.2 ACTIONS PERTAINING TO THE PIP

The PIP will play a vital role in ensuring that the implementation plan progresses in an

efficient manner. The following actions are critical in the establishment and functioning of

the PIP:

• Appointment of a reliable and suitable convenor for the PIP Team.

• Develop and formalise the Terms of Reference of the PIP and the mandate of the

convenor.

• The convenor must

o ensure co-ordination between the PIP and the existing forums and CEC in the

WCA;

o Convene an initial meeting of the stakeholders and interested and affected

parties in the WCA;

o Facilitate dissemination of information to interested and affected parties;

o Maintain registers of interested parties, correspondences, issues and responses.

9.3 ACTIONS PERTAINING TO THE ITT

Based on the critical nature of the work being conducted and the urgency in terms of the

remedial actions which will need to be undertaken, the WCAPTWG established the ITT

which will be responsible for the development of an action and time based plan for the



implementation of the recommendations which arose from the RAP. The following were

recommendations made by the WCAPTWG:

• It was agreed that it is critical to begin with the remedial actions as soon as

practically feasible in order to capitalise on the advent of the dry season. Based on

this it was therefore decided that the ITT needs to be constituted as a matter of

priority.

• Since the PIP process is critical to the successful execution of the RAP, it was

considered critical that a public meeting be convened prior to the development of an

implementation plan by ITT in order to include public comments and

recommendations.

• The ITT will thereafter convene and develop the implementation plan based on the

recommendations of the RAP and the comments received from the public. A clear

indication of the timeframes for each action as well as details in terms of roles and

responsibilities and funding will also have to be specified.

Based on the urgency of the actions required to be taken, the establishment of the ITT

was approved and the following membership of the ITT was proposed and accepted:



Sector Number of

Members Recommended Members

PIP 4

PIP Convenor - M. Liefferink

1 additional member from the PIP

1 member from Wonderfonteinspruit Forum

1 member from Mooi/Loopspruit Forum

Local Government 3

West Rand District Municipality - S. Stoffberg

Merafong Local Municipality - J. Evans

Tlokwe Local Municipality - B. Nell

Provincial

Government 2

GDACE – I. Kebalepile

NWDACE – T. Ramoroa

National

Government 7

DoA – D. Kleyn

DME – S. Modau

DWAF – M. Keet

DWAF – P. Mqulwana

DWAF: HO – J. van Wyk

NNR – O Phillips. T. Tselane

Mining Interest

Group 2 MIG – P. Jacobs. (plus one)

Chamber of Mines 1 COM – N. Lesufi

STT 1 STT – M. van Veelen

Total Members 20

Administrative

Support K. Pema

Once the initial PIP meeting has been convened, the ITT will commence with the development

of an implementation action plan. This plan as well as the ongoing progress made in terms of

the implementation of the actions will be communicated to the public on a regular basis.



10. CONCLUSION

The process embarked upon by the DWAF and the NNR in co-operation with other

government departments and stakeholders is based on the need to deal with

perceptions as well as address specific issues related to radiological impacts due to

mining in the WCA. It must be stressed that the STT was specifically tasked to examine

the radiological contamination issues in the WCA. Water pollution aspects related to the

chemical concentrations of Uranium in the water are also considered important but were

not included in the scope of this exercise. Recent reports have opened the debate on

the sediments and have identified them as a potential future problem.

The regulatory authorities accept that a wide range of studies, often with varied findings

and conclusions have been conducted in the WCA. It is also accepted that the focus of

the studies were varied with a wide range of methodologies and criteria of assessment.

The intent of this exercise was not to conduct any additional studies, but was rather

focused on the identification of areas where actual action can begin to take place.

Although there are differences in approaches to address the pollution situation in the

WCA amongst various stakeholders, the regulators are of the view that it is imperative

that action to remedy the situation is initiated. In essence the findings of the Specialist

Task Team emphasises the fact that there is no reason to delay the implementation of

remediation measures for Category 1 and Category 2 sites. The sites which do not fall

into these categories will have to be dealt with as part of a longer term remedial strategy.



REFERENCES

Brenk Report (2007) NNR – Radiological impacts of the mining activities to the

public in the Wonderfonteinspruit Catchment Area

Coetzee et al. (2002) Council for Geoscience – Uranium and heavy metals in

sediments in a dam on the farm Blaauwbank

Coetzee et al. (2006) An assessment of sources pathways, mechanisms and risks

of current and future potential pollution of water and sediments in gold mining areas

of the Wonderfonteinspruit catchment

IAEA, Generic Models for Use in Assessing the Impact of Discharges of Radioactive

Substances to the Environment, Safety Report Series No. 19, IAEA, Vienna, 2001.

IAEA, Handbook of Parameter Values for the Prediction of Radionuclide Transfer in

Temperate Environments, International Atomic Energy Agency Technical Reports

Series, No. 364, IAEA, Vienna, 1994.

IWQS (1999) – Radioactivity in water

NNR, Guideline on the Assessment of Radiation Hazards to Members of the Public

from mining and Minerals Processing Facilities. Licensing Guide LG-1032 (1997)

Wade et al. (2002) WRC – Radioactivity in sediments



Appendix A: Studies Used in Assessing Areas of Intervention



Study Relevant Findings

IWQS (1999) – Radioactivity in

water

Mining activities are a major contribution to

Uranium and Uranium series radionuclides within

the catchment. Concentrations decrease

downstream of the sources, indicating removal

from the dissolve fraction by interaction with

sediments.

Wade et al. (2002) WRC –

Radioactivity in sediments

Radionuclides are concentrated in sediments

downstream of their sources. Sequential

extractions showed that these radionuclides are

distributed in multiple phases within the sediments

and that they may be remobilized by

environmentally plausible chemical processes.

Coetzee et al. (2002) Council

for Geoscience – Uranium and

heavy metals in sediments in a

dam on the farm Blaauwbank

This study confirmed the finding of Wade et al.

and used further sequential extractions to

characterise the sediments in a dam downstream

of mining activities in the Carletonville area.

Coetzee et al. (2006) An

assessment of sources

pathways, mechanisms and

risks of current and future

potential pollution of water and

sediments in gold mining

areas of the

Wonderfonteinspruit

catchment

This study provides a background to

contamination issues in the Wonderfonteinspruit

Catchment identifies uranium as the key

contaminant of interest and quantifies risks, with

the primary risk due to chemical toxicity. The latent

risk due to uranium and other metals sequestered

in the sediments is also highlighted. Continuous

monitoring data is presented looking at temporal

variations in water flow and quality and the

applicability of the use of stable lead isotopes as

tracers is identified.

Brenk Report (2007) NNR –

Radiological impacts of the

mining activities to the public

in the Wonderfonteinspruit

Catchment Area

This study looked at additional contamination

pathways e.g. sediment in stock watering water

and transfer to milk and meat. The key conclusion

of this study was that radioactivity has

accumulated to levels in the sediment that exceed

regulatory requirements in 50% of the sites. This

implies that there is a radiological risk to the use of

water for irrigation of crops or for watering of

animals if the sediment is disturbed. The study

also indicates that there is no radioactivity risk with

regards to drinking water since the high levels of

radioactivity are in the sediment and not in the

water phase.



Appendix B: Project Time Table



1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4

1 Project Management

2 Project Initiation

2.1 WCATPWG Meeting

2.2 Draw up Terms of Reference for STT

2.3 Distribute ToR for comment

2.4 Finalise and Distribute ToR

3 Establishment of STT

3.1 Proposal for STT Members

3.2 Address Recommendations

3.3 Final STT approval

3.4 First Meeting of STT

4 STT Tasks

4.1 Specialist Task Clarification

4.2 Development of "Hotspots" Map

4.3 Presentation of Map to WCATPWG

4.4 Presentation of Map to SCRMRRC

4.5 Distribute Map for Comments

4.6 Inputs on Map by full STT

4.7 Public Meeting

4.8 Field Investigation

4.9 Strategic Workshop

5 Remediation Action Plan

5.1 Obtain Strategic Input from Specialists

5.2 Develop Remediation Action Plan

5.3 Presentation of Plan to WCATPWG

5.4 Distribute document for comments

5.5 Address comments and input

5.6 Final Draft Remediation Plan

5.7 Public Meeting

6 Project Closure

6.1 Fianlise Comments

6.2 Final Report Prepared

6.4 Project Closure

Feb-08 Mar-08 Apr-08

Proposed Time Frame for Project ExecutionOct-08May-08 Jun-08 Jul-08 Aug-08 Sep-08Jan-08



Appendix C: Identification and Classification of Areas of Intervention



Development of a map ranking sites

with known radioactive pollution

in the Wonderfonteinspruit catchment

according to the urgency of required intervention

('Intervention site map')

Underlying methodology and results

Compiled for:

Joint Coordinating Committee of the

Department of Water Affairs and Forestry and the

National Nuclear Regulator

Attn. Mr. M. Keet

Pretoria

Submitted to:

Wonderfonteinspruit Catchment Area Technical Working Group

Project Manager

Dr. M. van Veelen

Iliso Consulting, Centurion, PO Box 68735

Email: martin@iliso,co.za

Tel.: 012/ 665 3602

Fax: 012/ 665 1886

Cell: 082 575 3690

Date of submission: 11. August 2008

Mode of submission: MS word document attached to email

Compiled by:

Prof. Dr. rer. nat. habil. Frank Winde

Email: [email protected]

Tel.: 018/2991582

Fax: 018/299 1580

Cell: 072 40 59 561



1. Background and administrative context

In response to mounting evidence of mining-borne uranium pollution in the Wonderfonteinspruit

catchment area (WCA) and possibly associated health risks accompanied by increasing media

attention, the Department for Water Affairs and Forestry (DWAF) and the National Nuclear

Regulator (NNR), on 7 October 2007, formed the Joint Coordinating Committee (JCC) as well

as a Working Group (WG) tasked to remediate contaminated sites.

In order to facilitate regulatory co-operation on this matter subsequently the national Steering

Committee for the Remediation of Mining related Radioactive Contamination (SCRMRC) was

established (20.12.2007) comprising representatives from the DWAF and the NNR as well as

from the Departments for Minerals and Energy (DME), Agriculture (DoA), and Environmental

Affairs and Tourism (DEAT). Later representatives from local municipalities such as Mogale

City, Tlokwe City and Merafong as well as the West Rand District municipality were included.

Chaired by the NNR, the SCRMRC appointed the WCA Technical Project Working Group

(WCATPWG) which consists of two representatives from the DWAF and one from the NNR as

well as two members from the DME and the Chamber of Mines (CoM) respectively still to be

identified. As part of their Radiological Contamination Mitigation Plan the DWAF and NNR

agreed on the following four principles (WCA: Mitigation TOR, Feb. 2008: 2):

1. ‘Immediate remediation of hotspots is required.’

2. ‘The exact hotspots where the remediation takes place will have to be identified.’

3. ‘A team of experts should be appointed to determine the priority hotspots.’

4. ‘The team of experts must also provide the preferred methodology option to be used for the remedial action to take place.’

Subsequently eight specialists were appointed as members of the team of experts (later termed

‘Specialist Task Team’, STT), including two non-South African members from Canada and the

USA respectively, covering the following areas of expertise:

• Member 1: Radiation Protection

• Member 2: Geohydrology, radionuclide migration

• Member 3: Environmental Management

• Member 4: Local knowledge, technical expertise

• Member 5: Technical expertise, hydrology, geohydrology

• Member 6: Sedimentation

• Member 7: Remediation

• Member 8: Radiation protection (WCA: Mitigation TOR, Feb. 2008: 3).

The work of the STT is coordinated by a DWAF-appointed consultant (Project Manager, llisio

Consulting) who reports to the WCATPWG (WCA Radioactivity Management, Feb. 2008: 3).



On the inaugural meeting of the STT on 29 Feb. 2008 at Iliso offices in Centurion it was agreed

that a map depicting the hotspots of radioactive contamination in the WCA needs to be

compiled. The author who was officially appointed on 7 April 2008 to compile such map (Van

Veelen, 7. April 2008, Letter of Appointment, fax, pp. 2).

It is to be noted that the STT, since its inception, did not yet have an opportunity to meet with

more than 50% of its members being present. Therefore, the map introduced here represents

an individual effort that has not yet been discussed with all members of the STT. This is despite

the fact that the author, succeeded in soliciting some feedback from overseas members of the

STT via email correspondence (July 2008).

2. Purpose of the map

The general purpose is defined by the above mentioned Radiological Contamination Mitigation

Plan stating: ‘The exact hotspots where the remediation takes place will have to be identified.’

(WCA: Mitigation TOR, Feb. 2008: 2).

In the context of the project the map aims to identify all sites in the WCA which in previous

studies were found to be radioactively polluted and rank them according to the urgency of

required intervention.

As such the map mainly serves as a tool for screening an existing data and interpret them in

terms of the associated health risk. The pool of data to be used for the map was specified by the

client (see scope of map). Recommendations as to the nature of interventions are excluded

from the brief.

3. Scope of the map

Following a presentation of the author at the second meeting of the STT (24.2.2008) questions

regarding the scope of the map and methodological challenges were addressed. In the

subsequent discussion it was stipulated by the project manager that the scope of the map is

defined by the following limitations:

1. 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.);

2. 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 (e.g. due to insufficient sewage purification) etc.

It also excludes forms of possible radioactive pollution which is not mining-related such as

possible contamination through application of uraniferous fertilizers, activities of the Nuclear

Fuels Corporation of South Africa, NUFCOR, or any other source of radioactive pollution.



3. Only sites are to be considered which may pose a risk to members of the general public

specifically excluding possible occupational health risks to staff of mining companies such as

workers underground and on surface handling uraniferous ore, tailings etc. or experts

professionally dealing with radioactive pollution issues.

4. Only sites within the boundaries of the Wonderfonteinspruit (WFS) catchment are to be

included into the map.

Furthermore, the programme manager further specified what is expected of the map (email to

the author dated 4 April 2008) and what data are to be used:

“ What the Client requires is a map of the so-called hot spots in the Wonderfonteinspruit

catchment with respect to radioactivity and public health. This map should be based on the

following three reports:

• Assessment of the radiological impact of the mine water discharges to members of the public living around Wonderfonteinspruit catchment area.( IWQS 1999 – reference added

by author)

• BSA project no 0607-03. BSA Asssociates Pty Ltd, April 2007.Report on the radioactivity monitoring programme in the Mooi River (Wonderfonteinspruit) catchment. Institute for Water Quality Studies, DWAF, July 1999 (BSA 2007 – reference

added by author).

• 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. WRC report no 1214/1/06, March 2006 (WRC 1214 –

reference added by author).

The map should distinguish between categories of hot spots (i.e. water, sediment, tailings,

etc) and give some indication of risk based on parameters such as accessibility to the

public, and/or use of the land or resource. There should also be a cross-reference to the

source of the data used to define a hot spot as such.

In accordance with the three selected reports the scope of the map is confined to two principle

environmental media of concern:

a) Water (incl. surface water, groundwater, mine effluents) and

b) Sediment (mainly fluvial sediments from streams and dams but partly also including soils and

eroded tailings material)

I.e. 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.

Definition of ‘hotspot’ / ‘intervention site’

While the term ‘hotspot’ was still used at the time the work at the map commenced it was later

suggested to replace it by an alternative concept invoking less emotionally charged perceptions

by members of the public. In this report term ‘intervention site’ is used in place of ‘hotspot’.



In order to create the requested map a definition of the term ‘intervention site’ is required. Based

on the outlined scope of the map the following definition is suggested:

An ‘intervention site’ in the context of this report is any location in the WFS

catchment where waterborne pollution with mining-related radionuclids resulted

in levels of radioactive contamination that may pose a significant health risk to

members of the general public and thus needs some form of intervention to

address such risk.

4. General approach

The objective of the map is to identify intervention sites in the WFS catchment. As

specified by the client these sites are to be chosen from an existing pool of

samplings sites as determined by the three specified studies listed above i.e. IWQS

(1999), WRC 1214 (2004) and BSA (2007).

A possible way of creating the requested ‘hot spot map’ could therefore be to select

all sites identified as areas of high concern in each of the three studies and combine

them into a single map. Apart from the fact that such rather mechanistic compilation

would add little (if any) value to the maps already provided by the available reports, it

also would have a number of disadvantages such as:

a) The map would compare site-specific risks for which different methodologies were used to

determine possible health risks (e.g. radiological dose modelling vs. chemical toxicity approach,

different exposure pathways, different parameters such as transfer coefficients, …). As a

consequence the conclusions of the three studies which sites indeed constitute health risks are

inconsistent and partly contradictory. This is illustrated by the following facts:

� WRC 1214 has been questioned for the application of the Tier 1 risk approach adopted from

the US-EPA superfund procedure (NNR disclaimer in WRC 1214);

� BSA (2007) dedicates a whole chapter to discussing methodological shortcomings of IWQS

(1999)

� Scientist participating in IWQS could not resolve differences in opinion resulting in the

rejection of the final report by some of them;

� Assumptions underlying the dose calculations for certain exposure scenarios in BSA (2007)

such as habitual parameters for critical groups, animal behaviour, selected and ignored

pathways etc. are currently also questioned (Stoch, L. pers. communication, 2008).

b) Furthermore it needs to be noted that the temporal and spatial representativity of data on

which the conclusions in three reports are based differ vastly. The controversial IWQS study

generated by far the most extensive and comprehensive data base on water pollution for this

catchment. Unfortunately the original data have not been provided along with the report the

author was supplied with by the client and had to be retrieved from a third party.



In order to overcome abovementioned problems a simplified way of identifying hotspots /

intervention sites is adopted. This will be largely based on original (raw) data on radionuclide

concentrations (mainly U238) as found in water and sediments by previous studies. Focussing

on measured concentrations (‘hard data’) aims to avoid the introduction of large ranges of

uncertainty commonly associated with modelling that is based on a variety of (partly vastly)

differing assumptions. Furthermore, IWQS (1999) found a linear relation between measured U-

concentrations and calculated dose levels rendering U-concentration the single most important

parameter for all subsequent (water-related) risk modelling.

While regarding measurements in this report as ‘hard data’ i.e. undisputable facts, it needs to be

stressed that this is somewhat of a simplification since the quality of measurements may (and in

fact does) differ significantly between the three studies. This includes aspects such as the

followed sampling strategy (e.g. site selection and description, sampling frequency, sampling

depth, time etc.) and the analytical methodology employed (i.e. radio-chemical, XRF, mass

spectroscopy: semi-quantitative vs. quantitative etc. and the associated accuracy, reproducibility

as well as samples description and provision of accompanying parameters governing pollution

levels such as concentration of suspended solids in water samples or organic content and grain

size distribution in solid samples etc.). However, the assessment of the quality of data

generated by the three different reports falls outside the scope of this project.

It was frequently stated that water does not pose a health risk while sediment does, implying

that there is no need to include any water data into the map. This assertion is most likely based

on the findings of IWQS (1999) and BSA (2007) which both agree that the drinking water

pathway does not pose a risk from a radiological point of view.

However, WRC 1214 (2004) points out that in several instances limits based on the chemical

toxicity of U in SA guidelines are exceeded. BSA (2007), on the other hand, also identifies a

number of sites where the primary risks relates to the use of polluted water and not to sediment.

Furthermore, a study from the N-Cape based on epidemiological evidence suggests a link

between elevated U-levels in groundwater (comparable to those found in the WFS) and

leukaemia in residents consuming this water (Toens et al. 1998). The latter could suggest that

radiological dose models may underestimate health risks associated with consumption of U-

polluted drinking water.

As a first step s the geographical location of all sampled sites was captured including the

measured levels of radionuclids (mainly U238) distinguishing between water (surface and

underground) and sediments. In order to facility easier comparability between the data sets

generated by the three reports U-concentration values will be converted to a common unit

which, in some instances may differ from the way it was originally reported.

However, a map displaying all sampling sites with their respective U-concentrations would not

be sufficient to indicate the risk these sites may pose to the health of people living in the

catchment. In order to assist with that a simple method is proposed which aims to (semi-)



quantify the possible exposure of members of the general public to each contaminated site. To

this end additional information is introduced based. The challenge in this regard is to find a

method which does not result in an exceedingly complex model but still allows for an acceptable

and easy to understand assessment of risk.

It needs to be noted that all maps provided by the three studies lack a number of geographical

features essential for a comprehensive interpretation and assessment of the measured U-levels.

This includes, inter alia, the indication of potential U-sources as well as features crucial for

understanding surface and underground pathways of water borne U-transport and last but not

least the distribution of people (as potential receptors) within the catchment (e.g. updated maps

of rapidly growing informal settlements).

5. Development of the map

The development of the map comprises three major parts:

• 1. Compilation of an appropriate, sufficiently detailed and updated base map

• 2. Extraction of relevant data from selected studies and their import into the base map

• 3. Development of method to categorize the mapped data in terms of associated health risk

These steps are explained in the following sections.

5.1 Compilation of comprehensive base map

In order to comprehensively assess contamination-related risks as well as possible means for

remediation and risk mitigation a sound base map is needed that allows to link contaminated

sites to possible sources and pathways of pollution as well as to potential receptors such as

formal and informal residents.

Relevant topographical features include, inter alia, the following features pertaining to ...:

a) ...the fluvial system as most affected part of the environment including: all streams (perennial,

non-perennial, springs, seeps, drainage lines, wetlands, dams, lakes and canals etc.). The

currently available topographic maps of the 1:50.000 series for the catchment area are all

outdated and frequently incorrect regarding the detailed hydrography.

b) ... mining as major source of contamination including: mine lease areas, mining residues (i.e.

slimes dams, sand dumps, waste rock dumps, ore piles...), discharge points of mine effluents

associated with canals, pipelines and other potential source of pollution such as metallurgical

plants, return water dams, settling ponds etc. Most of these features are not contained in

conventional topographic maps.

c) ... settlements as indicators for the distribution of potentially affected people in relation to

contaminated sites including formal and informal settlements. Owing to the rapid growth of the

latter and the pivotal role for risk assessment all maps needed to be updated.



d) ... the geology of the area which impacts greatly on waterborne transport on surface and

underground. Relevant features, mostly not contained in conventional maps, include e.g.

outcropping dolomite, dykes, boundaries of full and dewatered compartments, sinkholes,

dolines and caves.

In order to obtained a base map in which these aspects are covered different sources were

combined using a Geographical Information System (GIS: Arc Map). Imported data originated,

inter alia, from geological maps of different scales and from recent satellite imagery of the area

(with the oldest imagery dating back 4 years) retrieved from Google Earth Pro. The latter was of

particular assistance in mapping recent changes in size and distribution of informal settlements

as well as of wetlands and dams. It also helped to map the course of drainage lines and mine

canals.

5.2 Extract and map relevant results of previous studies

Forming the core of the map it is most unfortunate that all original (raw) data could either not be

provided at all (as it was the case with IWQS 1999) or was provided in format not or only

indirectly usable for subsequent electronic evaluation (WRC 1214 – MS Word format, BSA 2007

– pdf format). This necessitated a time-consuming extraction of data either by cumbersome

format conversions or by typing them over from the original documents into EXCEL

spreadsheets. This includes geographical coordinates as well as details pertaining to sampling

(original name/ number of the site, date, time, sampled medium) and analytical results

(concentration values, methods used).

Ultimately all relevant data were incorporated into a single data base. In order to ease the

comparison of data from the different reports all U238-concentrations were converted from

Bq/kg or (or mBq/g) to µg/l for water samples and mg/kg (dry substance) for solid samples such

as sediments and soils. Activity concentrations of Ra226 given in Bq/l (water) or Bq/kg

(sediment) are expressed as percentage of the activity concentration of U238. They are only

included were the specific activity of R226 exceeds that of U238 (i.e. resulting in values above

100%).

When the extracted data are displayed in the map a distinction between water and sediment is

made.

Furthermore, for all displayed data the original source and the associated sampling details can

be referenced in the GIS through interrogating associated attribute tables linked to each site.

In total, data pertaining to 99 sampling sites have been extracted from the three reports

characterised by a total of 896 U-concentration data of which 808 data relate to water samples

(~90% of all U-data) and 88 data to solid samples (mainly fluvial sediments, soils and eroded

tailings, in the following collectively referred to as ‘sediment’).



For sediments typically one analysis per site exists even though a number of near identical

locations have been sampled. This has resulted in several clusters with high sampling density

contrasting with areas of significant sampling gaps. At the very few sites where sediment

samples from different depths were analysed only the U-concentration at the surface was used.

At the two sites where more than one surface sediment sample was taken the average of the

two U-concentration is calculated retaining the higher value (maximum) in the data base as well.

The same principle was applied to the water samples to which the overwhelming majority of the

U-measurements relates. In contrast to sediments which display a rather static U-concentration

samples especially from flowing surface water bodies (such as stream and mine canals) were

found to have highly fluctuating U-levels even when taken at identical sites. The bulk of the U-

data on water (755 out 808: 93%) was generated by IWQS (1999) through weekly and later

monthly sampling in the period January to December 1997. In order to condense these data the

average concentration for each site has been calculated and imported into the database

together with the number of samples analysed for each site. Owing to the significance for

conservative risk assessments the highest U-concentration measured at each site was also

imported into the data base (maximum). This duality of U-concentration values for each site

where water samples were taken allows the potential user of the map to either use average or

maximal U-concentrations to assess associated health risks.

All 99 sites have received an internal number in addition to the original name given in the

respective studies. Seven of the sites identified fall outside the catchment boundary of the WFS

and were only included for providing either indication on natural background levels in the area (3

sites) or uranium levels downstream the confluence of the WFS with the Mooi River in order

assess potential pollution of the drinking water supply to the Potchefstroom (Tlokwe)

municipality (4 sites) which is a major concern with respect to the WCA.

In addition to U238 levels also concentration data for R226 as well as risk-related data such as

calculated annual radiation dosages [mSv/a] and the associated risk categories as used in the

original source have been extracted from the two of the three studies which reported them. This

mainly serves to provide an opportunity for comparing the different risk assessment results of

the respective studies with those generated this project. It also allows to generate a synoptic

overview on sites and their associated risks as originally determined in the three studies.

The data base underlying the map contains currently a total of 157 average and maximum U-

data of which 102 relate to water samples (65%) and 55 to sediment (35%). For Ra226 levels a

total 67 values has been extracted of which 57% (38 values) relate to water and 43% (29

values) to sediment. For the 99 sites this results in a total of 224 data on U238 and Ra226

concentrations of which 63% relate to water and 38% to sediments.

5.3 Categorization of mapped sites and determination of associated health risks

5.3.1 General approach to assessing health risk adopted in this study



In view of the large number of sites and associated data a screening tool is needed which

allows to condense all sites into a convenient number of classes that can then be assessed in

terms of the associated health risk they pose to members of the general public.

Since determining health risks through rather complex radiological dose modelling proved to

yield inconsistent and partly contested results of little transparency this study tried to develop a

simpler and more transparent way of assessing risks associated with radioactively polluted

sites.

Instead of estimating effective radiological dosages for individuals or critical groups based on

numerous assumptions with large ranges of uncertainty, this study attempts to quantify how

likely members of the general public are to be exposed to polluted media at a given polluted site

in the first place. Such ‘exposure probability’, i.e. the likelihood for people to come in contact

with radioactively polluted sites at all, was so far completely ignored by previous risks

assessments. While exact dose values have been calculated for a number of hypothetical

pathways no attempt has been made to assess how likely such exposure was to occur, i.e. how

many people may indeed by affected by the proposed exposure scenarios.

This study assumes that the probability of exposure increases proportionally with increasing

numbers of people that potentially are able to gain access to a polluted site. For prioritizing

remediation of contaminated sites this aspect, i.e. the number of potentially affected people, is

thought to be of crucial importance especially in terms of cost-benefit considerations.

Using only ‘exposure probability’ as an indirect measure for quantifying health risks does,

however, not allow to determine the potential severity of health effects as provided by

radiological dose modelling for example. This again, can be indirectly assessed through

incorporating the degree of U-contamination into the risk assessment for a given site. The use

of U-concentrations as a proxy for the severity of potential health effects is possible since IWQS

(1999) established a statistically highly significant direct, linear relationship between U-levels in

the study area and calculated annual radiological dosages.

5.3.2 Identification of risk factors

Since high levels of U per se may not pose any risk to humans if no realistic possibility of

exposure exists, some form of additional information is required for translate pollution levels into

some form indicative of associated levels of health risks. Risks in this context is understood as

the probability of polluted media to actually cause adverse health effects in humans.

In contrast to the dose-calculation-approach of previous studies we will not attempt to quantify

the actual exposure to radioactive pollution for different age groups and a range of assumed

pathways not taking into account the actual number of people potentially affected. Omitting such

sophisticated, but often non-transparent and disputable models, this study simply attempts to

characterise the general probability of members of the general public being exposed to polluted

media at the identified sites. For this three factors are taken into account:



1. The ease at which a contaminated site can be accessed by members of the public (legally

and illegally);

2. The number of people likely to make use of this access, i.e. visiting the site)

3. The probability of using the type of polluted media (i.e. surface / groundwater, sediments) in

ways which could adversely affect the human health.

Details on what parameters could be used to semi-quantify above factor are discussed later in

the document. Based on a matrix which combines the data generated by the two steps all

sampled sites will be categorized into one of the following three risk categories: low, medium,

high indicating a successively increasing need and urgency for intervention. A stated earlier,

recommendations as to the nature of such intervention are excluded from the brief. Intervention

measures may range from sites of low risk class requiring additional investigation to restricting

access to or the use of contaminated media for medium class sites, to active remediation of

sites in the highest class of pollution.

For the risk assessment approach adopted in this study health risk associated with a

contaminated site is determined by two major components:

(I) The degree of radioactive pollution in a certain medium (‘contaminant level’) and

(II) The probability of members of the general public being exposed to such media (‘exposure probability’).

Exposure in this context is confined to and specifically excludes workers and specialist dealing

professionally with radioactive pollution)

Details on how these components are characterised are given below.

(I) Contaminant level (CL)

This factors indicates the level of radioactive pollution of a specific site. Normally this is

determined by the concentration of U238 in water [µg/l = ppb] and sediment [mg/kg = ppm]. In

exceptional cases Ra226 [Bq/kg], as only daughter product of the radioactive decay chains of

the three U-isotopes, was found to display a higher activity concentration than U238. Since

Ra226 is particularly hazardous those sites will be indicated separately in the map.

(II) Exposure probability

This term refers to an approximate measure of the likelihood to which members of general

public might be exposed to radioactively contaminated media in the study area. In order to

characterise this exposure probability three parameters are suggested:

(1) ‘Accessibility’ (A)

This refers to the ease at which polluted sites can be accessed by members of the public

(legally and illegally): e.g. sediments in the middle of a large dams or wetlands are thought to be

more difficult to access than surface water in a mine canals and streams intersected by publicly

used pathways, fenced private properties are less accessible than sites in the public space)



(2) ‘Access Probability’ (AP)

This stands for the probability of such access to occur and mainly refers to the number of

people potentially making use of the access identified above. E.g. polluted sites on remote

farms are less likely to be visited by large numbers of people than those in the close vicinity of

large settlements.

(3) ‘Usage Probability’ (UP)

This refers to the degree to which a certain use of polluted media adversely affecting human

health is likely to occur: e.g. using surface water for cooking is thought to be more common (and

therefore more likely to occur) than eating contaminated sediment (pica syndrome/ geophagy.

(III) Computing the Health risk (HR)

(a) Owing to their very different nature of above parameters varying from qualitative to

numerical it is necessary to transform them into a common (numerical) system that can be used

for computation. This is effected by assigning three classes (low, medium, high) to each

parameter into which all data of the respective parameter are grouped. With each class carrying

a (numerical) factor (‘class weight factor’) this allows for using these very different parameters in

numerical computation. The three classes have the following class weight factors:

� low: 1

� medium: 2

� high: 4

(b) In acknowledgement of the fact that the significance of each of the four risk parameters for

the determination of a possible health risk may differ, weight factors for each parameter have

been introduced to allow to fine tune the degree to which a certain parameter determines the

resulting risk. In this report and the associated map the following weight factors have been

allocated to the four risk parameters:

� Contamination Level (CL): 0,4

� Accessibility (A): 0,2

� Access Probability (AP): 0,2

� Usage Probability (UP): 0,2

Through incorporating the possibility of modifying weight factors the proposed risk assessment

method remains flexible and is able to accommodate possible changes in risk perceptions. With

60% of the total weight exposure is currently somewhat higher weighted than the actual degree

of radioactive pollution (40%). Regarding the allocation of weights a reasonable balance should

be found between the two possible extremes of allocating 100% to the CL (thus ignoring

exposure probability altogether) on the one side and only looking at exposure probability on the

other. Modifications in weight distribution will lead to changes in the number of sites falling into

the three different classes of intervention urgency.



Ignoring exposure probability completely (i.e. 100% CL) will possibly yield an overall higher

number of sites falling into the highest risk category for scenarios where many rather

inaccessible sites are highly contaminated – thus overestimating the risk. Including exposure

probability counterbalances this overestimation and reduces the number of high urgency

intervention sites by excluding those which are remote and inaccessible.

On the other hand, ignoring exposure probability in a scenario where many only moderately

polluted sites exist which are highly accessible would result in a general underestimation of

potential health risks. There might , however, be also be instances where low or unpolluted sites

fall into a higher risk category because they are highly frequented by the public.

With almost 100 different sites in the WFS catchment it is difficult to predict what the exact

outcome of weight changes on the distribution of sites across the risk class spectrum would be.

It should, however, be kept in mind that the main purpose of the map is to not to determine an

absolute level of health risk but to assist with the prioritization of sites according to the need for

intervention. As long as the weight distribution is applied consistently to all sites the relative

error remains constant and will thus not affect the screening function of the method.

(c) Based on the above the Health Risk (HR) for a specific site equals the sum of the products

of class weight and risk factor weight:

HR = 0,4CL + 0,2A + 0,2AP + 0,2UP (HR: 1…4 )

(d) With heath risk values ranging from a minimum of one to a maximum of four the following

breaking values for three different classes of intervention urgency are suggested:

Low urgency: HR = 1…<2: site requires further studies before establishing possible need for

interventions

Medium urgency: HR = 2…3: site requires further studies but may necessitate medium-term

intervention (within one to three years after establishment of HR value)

High urgency: HR = >3…4: site requires immediate intervention (within one year after

establishment of HR value)

While the class breaking values are used to categorize the sites in the WFS the associated

class characterisations (and recommendations) technically fall already outside the scope of the

project and were only included to illustrate what is meant by the term ‘degree of urgency for

intervention’.

While the weight of each risk parameter is now defined details as to how each parameter is to

group into the three suggested classes are still to be determined. This is done in the following

section.

5.3.3 Quantification of risk factors

(I) Contamination Level



Generally concentration of U-238 given in µg/l (for water samples) and mg/kg dry substances

(for sold samples such as sediment and soil) is used as sole indicator for the contamination

level. Where other radionuclides are of greater concern this will be indicated (e.g. Ra 226 …) In

order to reduce the complexity associated with 99 different sites and over 220 data on

radionuclide concentrations all data will be categorized into three classes indicating low,

medium and high levels of pollution separately for each type of affected media (i.e. surface

water, groundwater, sediment). In order to categorise the data a common benchmark is needed

against which they can be compared (i.e. normalised). Two different types of benchmarks are

suggested:

a) natural background concentrations for the radionuclids of concern (e.g. their regional or

global average levels) and

b) regulatory limits/ guideline values from applicable legislation (internationally or South African). 1

In order to categorize the U-concentration in low, medium, high levels of pollution the factor by

which the U-concentration exceeds the chosen benchmark (i.e. natural background value or

legislative limit) is used (‘exceedance factor’):

Exceedance factor = measured U-concentration at site: Benchmark U-concentration

Depending on the type of benchmark used different class breaking values based on the

exceedance factors are suggested:

Tab. 1: Class breaking values for normalised U238-concentrations in water and/or sediment samples based

on the factor by which the measured U-concentration at a contaminated site exceeds the chosen benchmark

(legislative limit or natural background concentration)

Benchmark

Class Natural

background

(global or

regional)

Legislative limit

(international or

SA)

low < 10x <1x

medium 10 … 100x 1…2x

high >100x >2x

1 Through employing a spreadsheet used to calculate classes based on selected benchmark parameters possible

(e.g. politically motivated) changes in preference can easily be accommodated s (e.g. using regional instead of global

background values or limits derived from international rather than national legislation).



Example for interpretation: If the measured U-concentration in water or sediment at a certain

sites is 11 times higher that the natural background concentration of U, than the Contaminant

Level of this sites falls into the medium class (with a class factor of 2).

The fact that the permitted exceedance factors for natural background benchmarks are much

higher than for legislative limits is based on the fact that the former represent pristine conditions

which in many anthropogenic environments are exceeded without necessarily posing a health

risk. This, however, is not the case with legislative limits which are generally much higher than

mean background concentrations and aimed to protect human health. Exceeding such limits is,

therefore, much more serious in terms of potential health risks.

Again, it is stressed that these factors are only first approximations which can and should be

adapted to the outcome of discussions of stakeholders and affected parties about perceptions

and acceptable levels of risks. Changing the corresponding values in the EXCEL database

allows to accommodate required modifications in a flexible and transparent manner.

Tab. 2 list U-concentrations for the different classes if exceedance factors from Tab. 1 are

applied to selected benchmark values for water and sediment regarding global natural

background concentrations and South African legislative limits.

Tab. 2: U-concentrations class breaking values for selected benchmark values for water and sediment based

on global natural background concentrations and different limits stipulated in applicable South African

legislation

Class

Natural background

(global)

Legislative limits (South Africa)

Water (DWAF, 1996:

0,4 µg/l Unat)

Sediment (Turekian &

Wedepohl, 1996:

2,7ppm Unat)

Water (DWAF, 1996)

Sediment (NNR, 2006)

Irrigation (clay rich soil:

10 µg/l Unat)

Domestic

use (drinking

water: TWQR:

70 µg/l Unat)

Specific activity of

single

radionuclide Old: 0,2 mBq/kg (=

16ppm U238)

New: 0,5 mBq/kg (=

40ppm U238)

low <4µg/l <27ppm <10µg/l <70µg/l <40ppm

medium 4…40µg/l 27…270ppm 10…20µg/l 70…140µg/l 40…80ppm

high >40µg/l >270ppm >20µg/l >140µg/l >80ppm

(II) Accessibility (A)

Meaning: This refers to the ease at which a polluted site can be accessed by members of the

general public. Public areas are assumed to be generally more accessible than e.g. (fenced)

private properties such as farms, mine areas etc.. However, contaminated sites on private land



are commonly also easily accessible to the owners and on-site residents. Private properties

which are not fenced or otherwise access-controlled are regarded as public space, even in

cases where such access would be illegal. Features such as roads (tarred or dirt), informal

pathways and other commuting routes intersecting canals, streams, dams are regarded as

increasing accessibility. On the other hand natural barriers such as streams, large wetlands

covered in dense and high vegetation are thought to decrease accessibility.

Suggested scale:

Low (1x): Areas in large wetlands, remote fenced farms, other access-controlled private

properties etc.

Medium (2x): Public areas river banks, wetlands, stream channels, canals, dams etc. accessed

by nearby roads, informal pathways etc.

High (4x): Areas designated to public use e.g. functioning as established recreational sites

(Donaldson Dam, A. Bailey Nature Reserve, Kdp Game Reserves etc.)

(III) Access Probability (AP)

Meaning: This parameter is an indication of how likely a contaminated site is to be visited by

members of the general public. It is assumed that the frequency of visits increases with an

increasing population density of the surrounding area.

A generally higher AP is assumed for sites which fulfil certain functions for adjacent

communities such as:

� dams and open water wetland attracting people for fishing,

� mine canals attracting people as source of (visibly) clean water,

� decommissioned slimes dams used for driving 4x4s, quad bikes, motor bikes,

mountain bikes etc.)

Suggested scale:

Low (1x): Remote areas well away from larger settlements (>5km walking distance, >15km

driving distance), and featuring no special attractions (such as fishing, swimming etc.), and

where the number of local residents is below ten.

Medium (2x): Areas in the vicinity of larger settlements (2-5km walking distance), or displaying

some features of special attraction (such as fishing, swimming etc.), or where 10-30 local

residents are present

High (4x): Areas next to larger settlements (<2km walking distance), or sites with special

attraction (such as fishing, swimming etc.), or sites with >30 local residents



(IV) Usage probability (UP)

Meaning: This parameter addresses takes into account that some uses of polluted media are

more common than others: e.g. using polluted water for irrigation is more common than using

dam sediments as food supplement (geophagy). However, the possibility of sediments and soils

being ingested needs to be considered especially for children suffering from the ‘pica syndrom’

(deliberate ingestion of comparably large amounts of soil) as well as unintended ingestion of

soil/ sediments/ tailings by playing children through normal hand to mouth contact. A particular

risk may be associated with highly uraniferous salt crusts which may enter the food chain

through animals licking them off and hand to mouth activities of children. In view of a possibly

increased bioavailability of U in such soluble crusts associated sites receive a higher class

weight.

Furthermore, it is assumed that visiting contaminated sites in many cases is more likely for

people from informal settlements and other poverty-dominated environments who do not have

access to alternative resources. This includes, for example, the use of water from polluted

streams, canals or dams for domestic purposes which is less likely to occur in areas with proper

water supply systems in place. Children from informal settlements are also assumed to visit

polluted sites more frequently than children who have access to supervised and/ or designated

playgrounds. A possible exception with regard to the latter is the reported use of slimes dams

for skate boarding, quad-biking, mountain biking etc. which is assumed to be a more dominant

activity amongst rather affluent white teenagers.

A higher class weight also applies if the land use of the area relates to the use of contaminated

media e.g. farms using polluted water for irrigation, live stock watering and contaminated soil for

grazing, crop production, communal gardens in floodplain, etc.

Suggested scale:

Low (1x): Remote groundwater boreholes not used for domestic or agricultural purpose,

sediments in inaccessible areas such as large wetlands with dense vegetation covers,

sediments sampled in sufficiently deep dams where no remobilisation occurs through normal

activities (swimming, fishing….)

Medium (2x): Boreholes used for domestic/ agricultural purposes, surface water (streams,

dams, mine canals, water used for fishing, swimming, sediments in shallow dams, floodplain soil

at commercial farms with no nearby informal settlements

High (4x): Surface water in streams, dams, mine canals or sediments in shallow dams,

wetlands, floodplain soil in vicinity to townships/ informal settlements, or areas with salt crusts,

communal gardens in floodplain, or farming activities contaminated sites

Site characterisation in terms of exposure parameters



All data regarding the exposure parameters were determined based on visual assessment only.

For increasing confidence levels detailed reevaluation consulting local experts on specific

condition is advised. In order to support the allocation of AP values population data from a

DWAF database on water supply and sanitation were used. Furthermore, the IWQS survey on

water users in the catchment was incorporated into the risk calculation database to support the

allocation of UP values to selected sites.

Summary of risk calculation procedure

Fig. 1 displays a graphic summary on the components of the risk assessment procedure

underlying the ranking of sites with known radioactive concentrations in terms of the assocaited

need for minimizing health risks through intervention.

Fig.1: Overview on the method used to quantify risks associated with radioactively polluted sites in the WCA

Risk (HR)

at individual sampling site

Contamination level(40%)

Contamination level(40%)

U238-conc. water

U238-Ra226 ratio

U238-conc.sediment

U238-conc. water

U238-Ra226 ratio

U238-conc.sediment

Av. Max. Max.Av. Av. Max. Max.Av.

Accessibility (20%)

Access

probability(20%)

Usage

probability(20%)

Accessibility (20%)

Access

probability(20%)

Usage

probability(20%)

Legislative

limits

medium: 1…2xexceedence factor

Legislative

limits


HR = 0,4CL + 0,2A + 0,2AP + 0,2UP

Class factor: 1, 2 or 4Class factor: 1, 2 or 4

Exposure probability(60%)

Exposure probability(60%)

Class factor: 1, 2 or 4Class factor: 1, 2 or 4

Natural

background


Natural

background




6. Limitations of map

In order to use the generated map correctly and avoid possible misinterpretations in the

following some limitations of the map are discussed.

(a) Database used to identify polluted sites in the WCA is not exhaustive

Confined to three out of a minimum of 35 studies, reports and documents containing relevant

data that were identified by the author the database underlying the identification of polluted sites

in the WCA is by no means exhaustive. Furthermore, all data used are secondary data with the

principally associated uncertainty regarding their quality and comparability.

It also needs to be stressed that only ‘hard’ i.e. measured data have been used while other

types of relevant information such as anecdotal and circumstantial evidence as provided in a

large number of recent newspaper articles and TV-documentations as well as documents of

environmental pressure groups have been ignored. This might of concern in a situation where

remedial actions may miss main concerns of environmental pressure groups which are not

supported (yet) by measurements and are, therefore, be regarded by the latter as unsuccessful.

(b) Limited spatial representativity of used data

Since most studies conducted on radioactive pollution in the study area concentrated on sites

which preceding studies found polluted (e.g. Andries Coetzee’s dam, Tudor dam etc.) clusters

of very densely sampled areas contrast with long stretches of the WFS were no samples were

taken (neither water nor sediments). Site which have been largely ignored so far include the

wFS downstream of AC Dam, the head waters of the WFS around the decant area of the

Western Basin. Areas affected by tailings spills from adjacent slimes dams and others. Thus,

the spatial representativity of the used database is to be regarded as generally insufficient.

Moreover, in many instances the choice of sampling sites was determined by accessibility rather

than actual understanding of the contamination process.

A principle problem in delineating areas for possible intervention is the fact that so far only point

data are available which need to be extrapolated. Owing to certain peculiarities of fluvial

uranium transport such extrapolation requires a sound understanding of transport mechanisms

resulting in established extrapolation procedures such as Kriging frequently not yielding reliable

results.

(c) Limited temporal representativity of used data

In view of the fact that the majority of pollution data relates to water samples the question

temporal representativity of analytical results is a major concern. With water samples displaying

pollution levels only for the exact moment they were taken, a sufficiently small sampling interval

is needed for reliably characterising such dynamic systems such as streams. This, however, is a

major shortcoming of the data used, since two of the three evaluated reports only analysed grab

samples while the remaining one (IWQS 1999) at least sampled at weekly intervals (for the first

half of 1997) and later once a month.



In view of frequently drastic short-term fluctuations of pollution levels caused by day-night

rhythms of discharging mine effluents, natural diurnal fluctuations of water chemistry as well as

events such as rainstorms and spillages weekly sampling intervals are inadequate. This is

illustrated by the fact that U-levels in samples used in IWQS (1999) from identical sites

(normally sampled at the same day of the week and the more or less the same time of the day)

at some locations fluctuate by up to an factor of 1000 (i.e. 100000%) (see appendix). In view of

such fluctuations and the fact that the IWQS data as data set with the highest temporal

representativity is more than 11 years old, the temporal representativity of the data used is

insufficient.

However, ranges of U-concentration reported for the WFS over the past 10 years seem to fall

into a certain, rather stabile range. This changed recently when decanting mine water from the

Western Basins was diverted into the WFS causing rising U-levels especially in the upper part

of the stream (Dorling 2008).

Temporal representativity is less problematic for sediments which, unless affected by extreme

flood events, are rather constant in their pollution levels.

(d) No biological and epidemiological data included

Subsequently to the release of BSA (2007) into the public domain a number of elements of the

food chain were analysed for U and other radionuclids. This includes vegetables, milk, fish,

beef, poultry and others. These date could be used verify risk assessment results based on

modeling and assumed transfer factors. Also some epidemiological data on possible effects of

U-pollution on residents exist no systematic compilation and evaluations is so far available. The

latest incident in this regard relates to the claim of a member of the South African Cancer

Association that even driving through the study area for only a couple of hours on open vehicle

might cause cancer (Tempelhoff 2008).

(e) Other health risks associated with mining-related pollution ignored

Owing to mandate-related limitations all non-waterborne pollution has been ignored in the map

including wind erosion of slimes dams transporting uraniferous tailings dust into nearby

settlements, the exhalation of the radioactive gas radon from tailings material and the

accumulation in houses built on old slimes dams or which used tailings as construction material.

Exposure of underground mine workers as well as farmers to u-contaminated service water etc.

Furthermore, effects of other chemically toxic heavy metals possibly associated with U in mining

effluents are also not included in the map.

(f) Risk determination influenced by settings in risk calculation matrix

Lastly it is stressed that the risk values calculated for the identified sites are largely controlled by

settings in the underlying computation system. This includes the use of maxima or average U-

concentrations, the choice of benchmark against which these values are compared (global/



regional natural backgrounds or national/international legislative limits), the chosen exceedance

factors which define the risk classes and the weight factors allocated to the four risk parameters.

However, the presented methodology underlying the map is specifically designed to

accommodate changed preference and risk perceptions in a flexible, traceable and transparent

manner.

7. References

BSA – BS Associates (Pty.) Ltd.(2007): Assessment of the radiological impact of the mine water

discharges to members of the public living around Wonderfonteinspruit catchment area.

BSA-project-no: 0607-03. Prepared on behalf of the National Nuclear Regulator (NNR) of

South Africa. Unpublished report, Centurion

IWQS – Institute for Water Quality Studies of the DWAF (1999): Report on the radioactivity

monitoring programme in the Mooi River (Wonderfontein) catchment. April 1999,

unpublished, Pretoria

DWAF (1996): Water Quality Guidelines, Domestic use and Agricultural use. Pretoria

Tempelhoff E (2008): Kankertoetse vir mense by myne. Beel, 09.06.2008

Toens PD, Stadler W, Wullschleger NJ (1998): The association of groundwater chemistry and

geology with atypical lymphocytes (as a biological indicator) in the Poffadder area, North

Western Cape, South Africa. WRC report No 839/1/98. Pretoria

WRC 1214 – Water Research Commission report no 1214 (2006): 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. Coetzee H, Winde

F, Wade P. WRC report no 1214/1/06. Pretoria



Appendix D: List of Areas of Intervention



No. Code Description of Measurement/Monitoring Point Location

1 MP1 Tudor Dam south side, about 50m distance to wall and bank each Mine

2 MP2 Stream bottom 150m downstream of Tudor Dam Mine

3 MP3 Upstream wetland Kagiso near Kagiso ext 8 turnoff Public

4 MP4 Downstream wetland Kagiso (at bridge of road Azaadville-Kagiso) Public

5 MP5 Private garden Kagiso-SW near MP4 Public

6 MP10 Small dam of van Greuning's farm near road 599 Public

7 MP11 Mine water pipe from Randfontein Estate GM at van Greuning's farm Public

8 MP12 Donaldson Bridge on road R559 Public

9 MP13 Donaldson Dam Northern part fishing station Public

10 MP14 Donaldson Dam southern part, caravan station (at the wall) Public

11 MP16 Wetland Muiskraal at culvert that crosses the sand road Public

12 MP17 Klerkskraal Dam, east side Public

13 MP18 Runoff seepage collection pond at slime dam north of Doornfontein Public

14 MP20 mine water from Doornfontein shaft and runoff water from slime dams Mine

15 MP21 dam NW from Elandsand GM Public

16 MP22 Canal from Blyvooruitzicht GM, bridge on road to Welverdiend between Public

17 MP23 Canal from West-Driefontein GM (from SE of Carletonville) Public

18 MP24 Canal from West-Driefontein GM (from E of Carletonville) Public

19 MP25 Storage/sedimentation ponds E of Carletonville (overflow water ) Public

20 MP26 Canal from West-Driefontein GM Public

21 MP29 Harry's Dam, upstream part Public

22 MP30 Harry's Dam, downstream (after crossing the sand road) Public

23 MP34 Water edge Bridge Plot 68 (Paul Matthee) Public

24 MP35 Water edge bridge near Agricultural Holdings Public

25 MP36 Padda Dam (western bank) Public

26 MP37 Furrow at Khutsong bridge Public

27 MP38 Bridge of R501 at Blyvooruitzicht GM (SW of Carletonville) Public

28 MP39 Canal crossing R501 at Blyvoorruitzicht GM (SW of Carletonville) Public

29 MP40 Doornfontein canal from Blyvooruitzicht GM (sand road to Coetzee's farm) Public

30 MP41 Wetland upstream of Coetzee Dam Public

31 MP42 Weir DWAF flow gauging station C2H069 Public

32 MP43 Coetzee Dam (upstream part, stagnant area) Public

33 MP44 Wall of Coetzee Dam (near overflow to Visser Dam) Public

34 MP45 Visser Dam (Southern bank) Public

35 MP46 Former wetland downstream of Lancaster Dam Public

36 MP47 Abandoned dam in Rietvalei (SE of Randfontein) Public



Appendix E: Overview of Environmental Legislation



1. Introduction

The Department of Water Affairs and Forestry (DWAF) started monitoring and measuring

radioactivity in water in 1995 after numerous concerns were raised in the Wonderfonteinspruit

Catchment Area (WCA).

The Radiological contamination issues in the WCA have received great media attention in

recent months which has escalated the perception of contamination to a greater degree of

awareness and concern. The Department of Water Affairs and Forestry (DWAF) and the

National Nuclear Regulator (NNR), the regulatory authorities responsible for the management of

radiological contamination in the water resources, have jointly embarked on a co-operative

programme to address the radiological aspects in the WCA.

With the above background in mind, DWAF and NNR realised that a team of experts or

specialists will be required to advice the two regulators on the methodology to be adopted for

the implementation of mitigation measures identified. Subsequently, eight (8) specialists were

appointed as members of the Specialists Task Team (STT), with expertise covering the

following areas:

Radiation Protection;

Geohydrology / Radionuclide Migration;

Environmental Management;

Local Knowledge / Technical Expertise;

Technical Expertise / Hydrology / Geohydrology;

Sedimentation;

Remediation; and

Radiation Protection.

It was agreed that the Radiological Contamination Mitigation Plan initiated by DWAF and the NNR will be

based on the following principles:

Immediate remediation of the hotspots;

Identification of the exact hotspots where the remediation will take place;

Determination of the priority areas;

Provide the preferred methodology option to be used for the remedial action.

Objectives of the Project

Several investigations to assess the nature of the contamination level and the risks associated

with the radioactivity in the Wonderfonteinspruit have been undertaken over the past few years.

Due to the uncertain nature of the contamination levels and the risks associated with

radioactivity in the Wonderfonteinspruit Catchment Area, several investigations have since

taken place over the past few years to try and establish the status quo within the Catchment. In

light of the various sources of information, it was decided that an objective appraisal of the

situation was required.

Therefore, the objective of the project is to establish the status quo within the WCA, identify

hotspots, determine priority areas, and to provide the Regulators with an indication of the most

feasible remedial measures to be undertaken so as to render the Catchment safe.



Project Scope

The scope of the project as outlined in the project’s terms of reference was as follows:

Assessment of all existing work done in the WCA in terms of radiological contamination;

Identification of all the possible hotspots in the WCA in terms of radiological contamination;

Ranking of the identified hotspots in order of degree of contamination and overall benefit

implementation of mitigation measures;

Provision of an indication of the best possible mitigation measures which could be implemented

to address the contamination of the sediments in the identified hotspots;

Recommendations on the most feasible mitigation measures for addressing the contamination

issues at the hotspots identified;

Provision of a method for the implementation of the mitigation measures recommended for the

identified hotspots;

Development of a monitoring programme for the ongoing assessment of the mitigation

measures from initiation to completion and long term assessment.

OVERVIEW OF THE RELEVANT ENVIRONMENTAL LEGISLATION

The environmental legislative framework (i.e. this document) provides an overview of the

relevant environmental legislation that could be considered in the remediation plan(s) of the

Wonderfonteinspruit Catchment Area. It does however not provide a descriptive approach or

process that should be followed in remedying the various hotspots identified within the WCA.

The precise environmental process(es) or regulatory requirements for the remediation of the

WCA will depend on the feasible remedial measures or recommendations proposed by the

various members of the Specialist Task Team (STT), and therefore, does not form part of this

report.

This report therefore, outlines the environmental legal requirements that are applicable to

pollution prevention and remediation, rectification of contraventions, offences, environmental

authorisation, etc., as provided in the various Acts. Table 1 below, provides an overview of the

relevant environmental legislation.



SECTION / REGULATION

THE PROVISION: REQUIREMENTS RELEVANT PROCESS / PROCEDURE

COMMENTS

THE CONSTITUTION OF THE REPUBLIC OF SOUTH AFRICA, ACT 108 OF 1996

Section 24 Environment

This section clearly states that everyone has the right to an environment that

is not harmful to their health or well-being (section 24 (a)), and to have the

environment protected, for the benefit of present and future generations,

through reasonable legislative and other measures that prevent pollution and

ecological degradation, promote conservation, and secure ecologically

sustainable development and use of natural resources while promoting

justifiable economic and social development (section 24 (b)).

Relevant legislative and other measures.

Everyone has a right to take to court anyone who fails to protect the environment.

Schedule 4

Environment, nature conservation, pollution control and soil conservation are

“functional areas of concurrent national and provincial legislative

competence”. Therefore, national and provincial government may

promulgate legislation concerning these matters.





COMMENTS

NATIONAL WATER ACT (NWA), ACT 36 OF 1998

Section 1

Definition:

“Pollution” – is “the direct or indirect alteration of the physical, chemical or biological properties of a water resource so as to make it:

o less fit for any beneficial purpose for which it may reasonably be expected to be used; or

o harmful or potentially harmful –

� to the welfare, health or safety of human beings;

� to any aquatic or non-aquatic organisms;

� to the resource quality; or

� to property.”

Section 3 Public trusteeship of nation’s water resources

(1) As the public trustee of the nation's water resources the National

Government, acting through the Minister, must ensure that water is

protected, used, developed, conserved, managed and controlled in a

sustainable and

equitable manner, for the benefit of all persons and in accordance with

its constitutional mandate.

(2) Without limiting subsection (1), the Minister is ultimately responsible to

ensure that water is allocated equitably and used beneficially in the

public interest, while promoting environmental values.

(3) The National Government, acting through the Minister, has the power to

regulate the use, flow and control of all water in the Republic.

Take note.





COMMENTS

Section 5 Establishment of National Water Resource Strategy

The progressive development, by the Minister, after consultation with society

at large, of a national water resource strategy is required. The national water

resource strategy provides the framework for the protection, use,

development, conservation, management and control of water resources for

the country as a whole. It also provides the framework within which water will

be managed at regional or catchment level, in defined water management

areas. The national water resource strategy, which must be formally

reviewed from time to time, is binding on all authorities and institutions

exercising powers or performing duties under this Act (NWA).

A National Water Resource Strategy is required as it provides a framework for the protection, use, development, conservation, management and control of water resources for the country as a whole.

Section 8 Establishment of Catchment Management Strategies

Every catchment management agency is required to progressively develop a

catchment management

strategy for the water resources within its water management area.

Catchment management strategies must be in harmony with the national

water resource strategy. In the process of developing this strategy, a

catchment management agency must seek co-operation and agreement on

water-related matters from the various stakeholders and interested persons.

The catchment management strategy, which must be reviewed from time to

time, will include a water allocation plan. A catchment management strategy

must set principles for allocating water to existing and prospective users,

taking into account all matters relevant to the protection, use, development,

conservation, management and control of water resources.

A Catchment Management Strategy for the water resources which is in harmony with the national water resource strategy is required within a water management area.





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Section 19

Prevention and remedying effects of Pollution

This section deals with pollution prevention, and in particular the situation where pollution of a water resource occurs or might occur as a result of activities on land. The Act states that the person who owns, controls, occupies or uses the land in question is responsible for taking measures to prevent pollution of water resources, and is also responsible to remedy the effects of the pollution. If these measures are not taken by the responsible person, the catchment management agency concerned (or the Minister if there is no catchment management agency in place) may itself do whatever is necessary to prevent the pollution or to remedy its effects, and to recover all reasonable costs from the persons responsible for the pollution.

The Generic Process for the Remediation of Contaminated Land Areas & Deteriorated Water Resources (Generic Remediation Process Guidelines) – developed by the Department of Water Affairs & Forestry (DWAF)

The involvement of DWAF in remediation of contaminated land or deteriorated water resources originated from its mandate as the custodian of South Africa’s “water resources”, as defined in the NWA, and the definition of “pollution” in the context of the provisions of ss19 & 20 of the NWA.

In accordance with this mandate, as well as in relation to the provisions of ss19 & 20 of the NWA, and ss28 & 30 of National Environmental Management Act (NEMA), Act 107 of 1998, DWAF has established a process to be followed by those embarking on an exercise aimed at the remediation of contaminated land areas and/or deteriorated water resources.

Section 20 Control of emergency incidents

Emergency incidents, remedial measures and clean-up directives.





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Section 21

Water Use

Water licences are required for all water uses listed in s21 unless the water

use is permissible (i.e. s22) in terms of schedule 1 to the Act, falls within the

general authorisations in terms of s39 of the Act, or is an “existing lawful

water use.”

The definition of “water use” includes:

(a) taking water from a water resource;

(b) storing water;

(c) impeding or diverting the flow of water in a watercourse;

(d) engaging in a stream flow reduction activity contemplated in section 36;

(e) engaging in a controlled activity identified as such in section 37(1) or

declared under section 38(1);

(f) discharging waste or water containing waste into a water resource

through a pipe, canal, sewer, sea outfall or other conduit;

(g) disposing of waste in a manner which may detrimentally impact on a

water resource;

(h) disposing in any manner of water which contains waste from, or which

has been heated in, any industrial or power generation process;

(i) altering the bed, banks, course or characteristics of a watercourse;

(j) removing, discharging or disposing of water found underground if it is

necessary for the efficient continuation of an activity or for the safety of

people; and

(k) using water for recreational purposes.

All the above water uses must be licensed with the Department of Water

Affairs.

Water Use Licence Application Process Guideline – DWAF: Chief Directorate Water Use.

The NWA provides the broad legal framework for water resources management. The requirements of the Act have to be implemented. The following Regulations outlines the implementation of the Act, as published in the Government Gazette:

o Government Notice No. 704, 4 June 1999, NWA, Act 36 0f 1998: Regulations on the use of water for mining and related activities aimed at the protection of water resources;

o Government Notice No. 1352, 12 November 1999, NWA, Act 36 of 1998: Regulations requiring that a water use be registered.

The DWAF should ensure that all mines within the WCA have water use licences and ensure that their operating within the ambit of their licence conditions. Therefore, DWAF should enforce compliance.





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Section 53 Rectifications of Contraventions

This section deals with the consequences of contraventions of licence conditions. These range from:

o the responsible authority requiring the licensee to take remedial action, failing which it may take the necessary action and recover reasonable costs from the licensee;

o suspension or withdrawal of a licence, where the licensee offers to surrender the licence, whereby the responsible authority is obliged to accept surrender & cancel the licence.

Section 151 Offences & Remedies

Non-compliance is a criminal offence therefore, any person who contravenes (i.e. does not comply with) the Act is guilty of an offence and can be prosecuted in a court of law. The NWA also gives the water management institutions and courts certain powers to remedy problems when a person has been prosecuted for an offence.

THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NEMA), ACT 107 0F 1998

Section 1 The “Environment” means the surroundings within which humans exist and

that are made up of:

(a) the land, water and atmosphere of the earth;

(b) micro-organisms, plant and animal life;

(c) any part or combination of (i) and (ii) and the interrelationships among and between them; and

(d) the physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health and well-being.”





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Section 2 Principles of Sustainability

The principles for sustainable development in the Act include the need to

avoid activities, which may degrade and pollute the environment, disturb

ecosystems or cause the loss of biological diversity. Where such activities

cannot altogether be avoided it is necessary to minimise and mitigate their

impacts on the environment. The principles also include the polluter pays,

preventative and precautionary principles and must serve as general

guidelines by reference to which all mining companies must exercise all of

their functions.

Section 24 Environmental Authorisations

(1) In order to give effect to the general objectives of integrated

environmental management laid down in the NEMA, the potential

impact on the environment of listed activities must be considered,

investigated, assessed and reported on to the competent authority

charged by the NEMA with granting the relevant environmental

authorisation.

(2) The Minister or MEC may identify:

(a) activities which may not commence without environmental

authorisation from the competent authority;

(b) geographical areas based on environmental attributes in which

specified activities may not commence without environmental

authorisation from the competent authority;

(c) geographical areas based on environmental attributes in which

specified activities may be excluded from authorisation by the

competent authority;

(d) individual or generic existing activities which may have a

The EIA process requirements should be conformed to.





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detrimental effect on the environment and in respect of which an

application for an environmental authorisation must be made to the

competent authority:

(3) Procedures for the investigation, assessment and communication of the

potential impact of activities must ensure, as a minimum, the following:

(a) investigation of the environment likely to be significantly affected by

the proposed activity and alternatives;

(b) investigation of the potential impact of the activity and its

alternatives on the environment;

(c) investigation of mitigation measures to keep adverse impacts to a

minimum;

(d) public information and participation which provide all interested and

affected parties with a reasonable opportunity to participate in such

information and participation procedures;

(e) reporting on gaps in knowledge, the adequacy of predictive

methods and underlying assumptions, and uncertainties

encountered in compiling the required information;

(f) investigation and formulation of arrangements for the monitoring

and management of impacts, and the assessment of the

effectiveness of such arrangements after their implementation;

(g) coordination and cooperation between organs of state in the

consideration of assessments where an activity falls under the

jurisdiction of more than one organ of state;

(h) that the findings and recommendations flowing from such investigation, the general objectives of integrated environmental management laid down in this Act and the principles of environmental management set out in section 2 are taken into account in any decision made by an organ of state in relation to the





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proposed policy, programme, plan or project.

GN R385 in GG 28753 of 2006-04-21

Regulations in terms of Chapter 5 of the National Environmental Management Act, 1998

These Regulations deal inter alia with the following:

(a) Competent authorities (identification of competent authorities, where to submit applications, etc.);

(b) Applications for environmental authorisations (determination of assessment process applicable to application, appointment of environmental assessment practitioners to manage applications, etc.);

(c) Amendment and withdrawal of environmental authorisations under certain circumstances;

(d) Exemptions from provisions of the Regulations; and

(e) Public participation process to be followed.

These Regulations

replaced the regulations

published in terms of

section 21 of the

Environment

Conservation Act.

Read these Regulations with GNs R386 and 387 of 2006-04-21, as well as GN 657 of 2006-05-19.

GN R386 in GG 28753 of 2006-04-21

List of activities and competent authorities identified in terms of sections 24 and 24D of the National Environmental Management Act, 1998

List of activities which may not commence without environmental authorisations from the competent authority and in respect of which the investigation, assessment and communication of potential impact of activities must follow the procedure as described in regulations 22-26 of the Environmental Impact Assessment Regulations published under GN R386 in

As described in regulations 22-26 of the Environmental Impact Assessment Regulations published under GN R386 in GG 28753 of 2006-04-21.

Any planned activity (ies), development, process, etc., must be verified prior to being undertaken whether they are listed in terms of these Regulations.





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GG 28753 of 2006-04-21

GN R387 in GG 28753 of 2006-04-21

List of activities and competent authorities identified in terms of sections 24 and 24D of the National Environmental Management Act, 1998

List of activities which may not commence without environmental authorisations from the competent authority and in respect of which the investigation, assessment and communication of potential impact of activities must follow the procedure as described in regulations 27-36 of the Environmental Impact Assessment Regulations published under GN R386 in GG 28753 of 2006-04-21

As described in regulations 27-36 of the Environmental Impact Assessment Regulations published under GN R386 in GG 28753 of 2006-04-21.

Any planned activity (ies), development, process, etc., must be verified prior to being undertaken whether they are listed in terms of these Regulations.

GN 657 in GG 28854 of 2006-05-19

Proposed Guidelines as part of the implementation of Environmental Impact Assessment Regulations in terms of section 24(5)of the National Environmental Management Act, 1998

These proposed guidelines were published for comment before 18 June 2006

EIA Minimum Requirements for Wetlands

o All specialist studies must be undertaken by suitably qualified specialists who (1) are registered in accordance with the Natural Scientific Professions Act (2003) as Professional Natural Scientists within the field of Ecological Science and (2) have specific post-graduate qualifications relating to wetlands. In the absence of the latter, the specialist must have attended an appropriate course on wetland rehabilitation and delineation (copy of certificate must be provided).

o The wetland delineation procedure must identify the outer edge of the temporary zone of the wetland, which marks the boundary between the wetland and adjacent terrestrial areas and is that part of the wetland that remains flooded or saturated close to the soil surface for only a few weeks in the year, but long enough to develop anaerobic conditions and

It should be established whether the proposed wetlands remedial action(s) within the WCA are listed activities in terms of Regulations R386 or R387 of the NEMA EIA Regulations, prior to any remedial work being undertaken. The remedial activities proposed should also consider GDACE’s





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determine the nature of the plants growing in the soil. o Delineation must be undertaken according to “DWAF, 2003: A practical

Guideline Procedure for the Identification and Delineation of Wetlands and Riparian Zones”.

o Locating the outer edge of the temporary zone must make use of four specific indicators including the terrain unit indicator, the soil form indicator, the soil wetness indicator and the vegetative indicator.

o The wetland and a protective buffer zone, beginning from the outer edge of the wetland temporary zone, must be designated as sensitive in a sensitivity map (refer to Sensitivity Mapping rules for Biodiversity Assessments).

The report must include the following information (but not restricted to):

o The present ecological state of the wetland. o The impacts which are likely to occur due to the proposed development,

and recommendations to avoid or minimize such impacts. o If the wetland is degraded, a rehabilitation plan must be included (all

wetlands must be conserved and rehabilitated if necessary; their destruction for development purposes will not be supported).

o The delineation procedure that has been applied. o Conservation worthy/valuable biota identified in the wetland or

surrounding areas. o Sensitivity map showing the outer edge of the temporary wetland and the

buffer in relation to the proposed development. o A plan indicating how the stormwater that will be generated by the

proposed development will be managed.

The edge of the wetland must be clearly demarcated in the field with pegs,

poles, sticks, or any solid structure that will last for the duration of the

construction phase, colour-coded as follows:

o RED – Indicating the edge of the wetland (Note: This includes the permanent, seasonal and temporal wetlands, or parts thereof; and no vehicles or building materials are allowed in this zone) [These should be put along the entire length of the property/site.];

o ORANGE – Indicating the edge of the buffer zone (30m for areas within

Requirements for the Biodiversity Assessments.





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the urban edge and 50m outside the urban edge). However, allowance must be made for sensitive species that require larger areas, e.g. Grass Owl, Giant Bullfrog, etc.

o GREEN – Should indicate where the first structure(s) will be built (e.g. stands/ plots, building, paving, ‘wall fencing’, etc.).

All wetland habitats must be surveyed for the following mammal species:

Chrysospalax villosus,

Mystromys albicaudatus, Lutra maculicollis, Amblysomus septentrionalis,

Dasymys incomtus.

Minimum requirements for mammal studies apply.

Section 28 Duty of Care & remediation of environmental damage

This section establishes a general duty of care to prevent environmental

pollution or degradation and also provides for liability where this duty is

breached. Reasonable remedial measures required are set out in the Act.

Organisation must make

explicit arrangements to

demonstrate compliance

to section 28.

Also see section 19 of the National Water Act 36 of 1998 which contains similar provisions.

Section 32 Legal standing to enforce environmental laws

(a) Should the organisation violate any provision of this Act or any other law concerning the environment, any interested or affected person or group may institute litigation against the company in the interest of protecting the environment (in line with the Constitution).

(b) Even if the litigant does not succeed with its action, the court may award costs to the respondent under certain circumstances.

Take note.





COMMENTS

ENVIRONMENT CONSERVATION ACT (ECA), ACT 73 OF 1989

Section 1 Definitions

Waste means “any matter, whether gaseous, liquid or solid or any combination thereof, which is from time to time designated by the Minister by notice in the Gazette as an undesirable or superfluous by-product, emission, residue or remainder of any process or activity”.

Read with GN 1986 in GG 12703 of 1990-08-24.

Section 2 The following policies promulgated in terms of section 2 have are still

applicable:

o GN 51 in GG 15428 of 1994-01-21; and

o General Notice 749 in GG 18894 of 1998-05-15.

Take note.

GN 51 in GG 15428 of 1994-01-21

General Policy in terms of the Environment Conservation Act 73 of 1989

This policy can be used in court to proof contravention of specific legislation.

This Policy should be complied with.

General Notice 749 in GG 18894 of 1998-05-15

White Paper on Environmental Management Policy for South Africa

This is an overarching framework policy.

Principles: cradle to grave, custodianship, demand management, due process, equity, environmental justice, full cost accounting, global and international co-operation and responsibilities, good governance, open information, participation, precaution, prevention, polluter pays and waste avoidance and minimisation.

Companies, institutions, organizations, etc., should adhere to the policy principles when conducting their business.





COMMENTS

GN 227 in GG 20978 of 2000-03-17

White Paper on Integrated Pollution and Waste Management for South

Africa – A Policy on Pollution Prevention, Waste Minimisation, Impact

Management and Remediation

Integrated pollution and waste management is a holistic and integrated

system and process of management aimed at pollution prevention and

minimisation at source, managing the impact of pollution and waste on the

receiving environment and rehabilitating damaged environments.

This White Paper on Integrated Pollution and Waste Management for South

Africa represents a paradigm shift towards:

o Pollution prevention;

o Waste minimisation;

o Cross-media integration,

o Institutional horizontal and vertical integration of departments and spheres of government; and

o Involvement of all sectors of society in pollution and waste management.

Take note of the National Waste Management Strategies and Action Plans for South Africa.

MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT (MPRDA), ACT 28 OF 2002

Section 37 Environmental Management Principles

(1) The principles set out in section 2 of the National Environmental

Management Act, 1998 (Act No.107 of 1998) -

(a) apply to all prospecting and mining operations, as the case may be,

and any matter relating to such operation; and

(b) serve as guidelines for the interpretation, administration and

implementation of the environmental requirements of this Act.

(2) Any prospecting or mining operation must be conducted in accordance

with generally accepted principles of sustainable development by

The requirements or provisions of the MPRDA should be considered in the remedial measures of the WCA. Compliance should be enforced.





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integrating social, economic and environmental factors into the planning

and implementation of prospecting and mining projects in order to ensure

that exploitation of mineral resources serves present and future

generations.

Section 38 Integrated Environmental Management & Responsibility to remedy

(1) The holder of a reconnaissance permission, prospecting right, mining

right, mining permit or retention permit -

(a) must at all times give effect to the general objectives of integrated

environmental management laid down in Chapter 5 of the National

Environmental Management Act, 1998 (Act No. 107 of 1998);

(b) must consider, investigate, assess and communicate the impact of

his or her prospecting or mining on the environment as contemplated

in section 24(7) of the National Environmental Management Act,

1998 (Act No. 107 of 1998);

(c) must manage all environmental impacts—

(i) in accordance with his or her environmental management plan or

approved environmental management programme, where

appropriate; and

(ii) as an integral part of the reconnaissance, prospecting or mining

operation, unless the Minister directs otherwise;

(d) must as far as it is reasonably practicable, rehabilitate the

environment affected by the prospecting or mining operations to its

natural or predetermined state or to a land use which conforms to the

generally accepted principle of sustainable development; and

(e) is responsible for any environmental damage, pollution or ecological

degradation as a result of his or her reconnaissance prospecting or

mining operations and which may occur inside and outside the

boundaries of the area to which such right, permit or permission

The requirements or provisions of the MPRDA should be considered in the remedial measures of the WCA. Compliance should be enforced.





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relates.

(2) Notwithstanding the Companies Act, 1973 (Act No. 61 of 1973), or the

Close Corporations Act, 1984 (Act No. 69 of 1984), the directors of a

company or members of a close corporation are jointly and severally

liable for any unacceptable negative impact on the environment,

including damage, degradation or pollution advertently or inadvertently

caused by the company or close corporation which they represent or

represented.

Section 41 Financial Provision for remediation of environmental damage

(1) An applicant for a prospecting right, mining right or mining permit must,

before the Minister approves the environmental management plan or

environmental management programme in terms of section 39(4), make

the prescribed financial provision for the rehabilitation or management of

negative environmental impacts.

(2) If the holder of a prospecting right, mining right or mining permit fails to

rehabilitate or manage, or is unable to undertake such rehabilitation or to

manage any negative impact on the environment, the Minister may, upon

written notice to such holder, use all or part of the financial provision

contemplated in subsection (1) to rehabilitate or manage the negative

environmental impact in question.

(3) The holder of a prospecting right, mining right or mining permit must

annually assess his or her environmental liability and increase his or her

financial provision to the satisfaction of the Minister.

(4) If the Minister is not satisfied with the assessment and financial provision

contemplated in this section, the Minister may appoint an independent

assessor to conduct the assessment and determine the financial

provision.

(5) The requirement to maintain and retain the financial provision remains in

Take note.





COMMENTS

force until the Minister issues a certificate in terms of section 43 to such

holder, but the Minister may retain such portion of the financial provision

as may be required to rehabilitate the closed mining or prospecting

operation in respect of latent or residual environmental impacts.

Section 45 Minister’s power to recover costs in event of urgent remedial measures

(1) If any prospecting, mining, reconnaissance or production operations

cause or results in ecological degradation, pollution or environmental

damage which may be harmful to the health or well-being of anyone and

requires urgent remedial measures, the Minister may direct the holder of

the relevant right, permit or permission to -

(a) investigate, evaluate, assess and report on the impact of any

pollution or ecological degradation;

(b) take such measures as may be specified in such directive; and

(c) complete such measures before a date specified in the directive.

(2) (a) If the holder fails to comply with the directive, the Minister may take

such measures as may be necessary to protect the health and well-

being of any affected person or to remedy ecological degradation

and to stop pollution of the environment.

(b) Before the Minister implements any measure, he or she must afford

the holder an opportunity to make representations to him or her.

(c) In order to implement the measures contemplated in paragraph (a),

the Minister

may by way of an ex parte application apply to a High Court for an

order to seize and sell such property of the holder as may be

necessary to cover the expenses of implementing such measures.

(d) In addition to the application in terms of paragraph (c), the Minister

may use funds

appropriated for that purpose by Parliament to fully implement such

Take note.





COMMENTS

measures.

(e) The Minister may recover an amount equal to the funds necessary to

fully implement the measures from the holder concerned.

Section 46 Minister’s power to remedy environmental damage in certain instances

(1) If the Minister directs that measures contemplated in section 45 must be

taken to prevent pollution or ecological degradation of the environment

or to rehabilitate dangerous occurrences but establishes that the holder

of the relevant reconnaissance permission, prospecting right, mining

right, retention permit or mining permit, as the case may be, or his or

her successor in title, is deceased or cannot be traced or, in the case of

a juristic person, has ceased to exist, has been liquidated or cannot be

traced, the Minister may instruct the Regional Manager concerned to

take the necessary measures to prevent further pollution or

degradation, or to make the area safe.

(2) The measures contemplated in subsection (1) must be funded from the

financial provision made by the holder of the relevant reconnaissance

permission, prospecting right, mining right, retention permit or mining

permit in terms of section 41, where appropriate, or if there is no such

provision or if it is inadequate, from money appropriated by Parliament

for that purpose.

(3) (a) Upon completion of the measures contemplated in subsection (1), the

Regional Manager must apply to the registrar concerned that the

title deed of the land in question be endorsed to the effect that such

land had been remedied.

(b) The registrar concerned must, on receipt of an application

contemplated in paragraph (a), make such endorsements as he or

she may deem necessary so as to give effect to provisions of that

Take note.





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paragraph, and no office fee or other charge is payable to the

registrar in respect of such endorsement.

NATIONAL NUCLEAR REGULATOR ACT (NNRA), ACT 47 OF 1999

Section 5 Objects of Regulator

The responsibility of the National Nuclear Regulator is to provide for the

protection of persons, property and the environment against nuclear damage

through the establishment of safety standards and regulatory practices and to

exercise regulatory control related to safety over the siting, design,

construction, operation, manufacture of component parts and

decontamination, decommissioning and closure of nuclear installations and

other actions to which this Act applies. These would include radioactive

waste management facilities associated with nuclear power stations, nuclear

fuel cycle facilities and those facilities that mine and process radioactive ores

and minerals.

Take note.

Section 6 Co-operative governance

The Regulator must conclude co-operative governance agreements with

every relevant organ of state, as defined in section 239 of the Constitution,

on which functions in respect of the monitoring and control of radioactive

material or exposure to ionising radiation are conferred.

Take note.





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Section 7(1)(h)

Functions of the Regulator

For the purposes of Act 47 of 1999, the National Nuclear Regulator acts as

the national competent authority in connection with the International Atomic

Energy Agency's Regulations for the Safe Transport of Radioactive Material.

Take note.

NUCLEAR ENERGY ACT (NEA), ACT 46 OF1999

Section 45 Authority over management of radioactive waste, and storage of

irradiated nuclear fuel

The authority over the management of radioactive waste and the storage of

irradiated nuclear fuel vests in the Minister of Minerals and Energy. The

Minister, in consultation with the Minister of Environmental Affairs and

Tourism and the Minister of Water Affairs and Forestry, may make

regulations prescribing the manner of management, storage and discarding

of radioactive waste and irradiated nuclear fuel. The Minister must perform

this function with due regard to the provisions of the National Nuclear

Regulator Act, 1999.

Take note.





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Section 46 Discarding of radioactive waste and storage of irradiated nuclear

fuel

Discarding of radioactive waste and storage of irradiated nuclear fuel require

the written permission of the Minister and are subject to any conditions that

the Minister, in concurrence with the Minister of Environmental Affairs and

Tourism and the Minister of Water Affairs and Forestry, deems fit to impose.

The conditions so imposed will be additional to any conditions contained in a

nuclear authorization as defined in the National Nuclear Regulator Act, 1999.

Take note.

Section 50 Responsibility for institutional obligations of Republic

The responsibility for the Republic's institutional nuclear obligations vests in

the Minister. The management of nuclear waste disposal on a national basis

is one of these obligations as defined in section 1(xii) of the Act.

Section 34(1)(s) Authorisation required for acquisition or possession of, and certain

activities relating to, nuclear material, restricted material and nuclear-

related equipment and material

In terms of the responsibilities of the Minister of Minerals and Energy

regarding nuclear non-proliferation, authorisation is required to dispose of,

store or reprocess any radioactive waste or irradiated fuel.





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HAZARDOUS SUBSTANCES ACT, ACT NO. 15 OF 1973

The Hazardous Substances Act provides for the control of Group IV

hazardous substances (radioactive material not at nuclear installations or not

part of the nuclear fuel cycle, for example fabricated radioactive sources,

medical isotopes) and Group III hazardous substances (involving exposure to

ionising radiation emitted from equipment). Radioactive waste arising from

activities authorized under this Act falls under the regulation of the

Department of Health’s Directorate of Radiation Control. In practice, the

Department of Health does not regulate naturally occurring radioactive

material.

Take note.

For the purposes of Act 15 of 1973, the Department of Health’s Directorate of

Radiation Control acts as the national competent authority in connection with

the International Atomic Energy Agency's Regulations for the Safe Transport

of Radioactive Material.

Take note.

MINE HEALTH AND SAFETY ACT, 1996 (ACT NO. 29 OF 1996)





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The Act makes provision for the protection of the health and safety of

employees and other persons at mines. Any hazardous materials, including

waste that is radioactive, therefore also fall under the inspection and

enforcement tasks of the Mine Health and Safety Inspectorate.

Take note.

CONSERVATION OF AGRICULTURAL RESOURCES ACT (CARA), ACT 43 OF 1983

This Act is intended to conserve agricultural resources, but contains provisions on water resources and is also used for estate management.

The general objective of the act is to provide for the conservation of the

natural agricultural resources of the country by the maintenance of the

production potential of the land, by combating and preventing erosion and

weakening or destruction of water resources; and by the protection of

vegetation and the combating of weeds and invader species.

Section 29 In order to achieve the objects of the Act, the Minister of Land Affairs may

prescribe certain control measures through the issuing of Regulations, which

must be complied with by the landowners to whom they apply.

Such control measures could relate to:

o the prevention or control of water logging and salination of land;

o the utilisation and protection of vleis, marshes, water sponges, water courses, and water sources;

o the protection of water sources against pollution on account of farming practices;

o the regulation of the flow pattern of run-off water;

o restoration and reclamation of disturbed land, etc.

Take note.





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GN R1048 in GG 9238 of-1984-05-25

Regulations regarding inter alia:

(a) Protection of vleis and veld;

(b) Lists of weeds and invader plants;

(c) Combating of weeds and invader plant;

(d) Restoration and reclamation of disturbed land.

Take note.

Discussion Paper: Wetlands in Agriculture, 2006.

Wetlands are sensitive and vital systems in our environment, and yet they

are decreasing and degrading at an alarming rate. Agriculture is considered

the principal cause of wetland loss worldwide. Not only do wetlands need to

be protected or conserved to secure water resources for our own future and

well-being, but we are also bound by national and international commitments

to do so. A body of international, regional and national policies and treaties

exists that relates to the conservation of water ecosystems. South Africa also

has policies and acts protecting wetlands, but overlaps and gaps regarding

wetland legislation exist, and shared responsibilities between different

government departments lead to ineffective implementation. The need for

clear guidelines regarding the sustainable use of wetlands in agriculture is

vital for their conservation in South Africa.

Take note.



2. CONCLUSION

This document provides a broad environmental legislative framework, i.e. the relevant provisions or requirements of various Acts in terms of environmental authorisations, pollution prevention and remediation, powers held by the state in enforcing environmental legislation, etc., that should be considered in the remedial measures to be adopted as proposed by the other members of the Specialist Task Team (STT). It however, does not provide details on the precise environmental processes to be followed or which regulatory requirements should be enforced in addressing each identified hotspot within the WCA, given that the STT’s recommendations on the remedial measures to be implemented or adopted in addressing the identified hotspots were unknown during the compilation of this report.



3. REFERENCES

DEPARTMENT OF AGRICULTURE (DoA). 2007. Discussion Paper: Wetlands in Agriculture. August 2007.

DEPARTMENT OF AGRICULTURE, CONSERVATION AND ENVIRONMENT: DIRECTORATE OF NATURE CONSERVATION (GDACE). 2008. GDACE Requirements for Biodiversity Assessments - Version 2, March 2008.

DEPARTMENT OF WATER AFFAIRS AND FORESTRY. The Generic Process for the Remediation of Contaminated Land Areas and Deteriorated Water Resources. February 2002.

DEPARTMENT OF WATER AFFAIRS AND FORESTRY: CHIEF DIRECTORATE WATER USE. Water Use Licence Application Process Guideline. 2007.

REPUBLIC OF SOUTH AFRICA: CONSTITUTION, ACT 108 OF 1996.

REPUBLIC OF SOUTH AFRICA. ENVIRONMENT CONSERVATION ACT (ECA, Act 73 of 1998).

REPUBLIC OF SOUTH AFRICA: NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NEMA, Act 107 of 1998).

REPUBLIC OF SOUTH AFRICA: NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NEMA, Act 107 of 1998). Regulations in terms of Chapter 5 of the National Environmental Management Act, 1998.

REPUBLIC OF SOUTH AFRICA: NATIONAL WATER ACT (NWA, ACT 36 OF 1998).

REPUBLIC OF SOUTH AFRICA: MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT (MPRDA, ACT 28 OF 2002.

REPUBLIC OF SOUTH AFRICA :HAZARDOUS SUBSTANCES ACT, ACT NO. 15 OF 1973.

REPUBLIC OF SOUTH AFRICA: CONSERVATION OF AGRICULTURAL RESOURCES ACT (CARA, ACT 43 OF 1983).

REPUBLIC OF SOUTH AFRICA: NUCLEAR ENERGY ACT (NEA, ACT 46 OF1999).

REPUBLIC OF SOUTH AFRICA: NATIONAL NUCLEAR REGULATOR ACT (NNRA, ACT 47 OF 1999).



Appendix F: SPECIALISTS REPORTS



Field Visit Comments and Recommendations on Identified

“Areas of Potential Concern”

Dr. Don Lush

Introduction

Prior to our site visit Dr. Frank Winde had reviewed all of the water and sediment quality data for the

Wonderfonteinspruit watershed and prioritized sites for visit and possible remedial action/cleanup

based upon a number of criteria and weighting factors for the criteria as described in his methodology

report dated 11/08/08.

On September 2nd 2008, the identified sites on the upper watershed were visited from the headwaters

at Tudor Dam down to a distance approximately 1/3 of the way down the pipeline discharging from

Donaldson dam. On September 3rd 2008 the identified areas of concern in the section of the

watershed between the canal discharging water from the West Dreifontain mine (MP-23) and the

Cottzze dam were visited. On September 4th the remaining identified areas of potential concern sites

within the lower section of the watershed down to the Visser dam were visited.

The purpose of the visit was to:

1. Identify any sites that may pose an immediate and significant public health or environmental concern from the standpoint of radiological and environmental protection and that in the interest protecting the public and or the environment from significant radiation or toxic material exposure should be immediately remedied or cleaned up to a standard acceptable to the appropriate competent authority.

2. In recognition of the fact that a long term cleanup strategy is being developed for the watershed; identify those sites where cleanup to a standard acceptable to the appropriate competent authority within the next three years would appear to the team to be both reasonable and practical, fits into the long-term watershed cleanup strategy and would serve to assist in reducing radiological doses to persons living within the catchment in keeping with the ALARA principle.

3. Identify those sites where past slimes and or effluent spills have occurred, further detailed evaluation will be required over the next 3 years and cleanup will likely be required over a longer time frame of approximately 3-10 years (the exact time to be determined by the time needed for the individual site assessment and the role the site cleanup will play in the detailed watershed rehabilitation strategy). Cleanup should be to a standard acceptable to the appropriate competent authority. The remediation strategy to be followed at these sites will be a function of the quantity of material to be cleaned up and the environmental or public constraints that may be placed on the cleanup. These sites will likely require a detailed evaluation of the quality and quantity of the material to be remediated and the net benefit associated with this remediation. The cleanup of these sites is in keeping with the need to rehabilitate the watershed water and sediments and to assist in complying with ALARA.

4. Identify those sites where cleanup will be required over a longer time frame of approximately 10-50 years (the exact time to be determined as part of the detailed watershed rehabilitation strategy) or until such time as the cessation of mining within the watershed occurs and at which time local aquifers will recharge and surface springs will be discharging into the watershed. Cleanup at this time will be to a standard acceptable to the appropriate competent authority. The cleanup of these sites is in keeping with the need to rehabilitate the watershed water and sediments and to assist in complying with ALARA. These sites will likely consist of licensed areas such as slimes dams , extraction plants, other supporting mine infrastructure such as other buildings, shafts, head frames, pipelines, etc. For these sites a conceptual



decommissioning plan costed to +/- 15% if not already developed by the mines as a requirement of licensing should be developed over the next 5 years as part of the watershed strategy. This conceptual decommissioning plan and associated costs should be required to be updated by the mines every 5 years taking into account the long term plans of the mines and changes in knowledge and technology.

5. Identify those sites at which cleanup in the future is deemed not to be required as the radiation risk posed is low and the activity of cleanup is likely to result in a greater environmental or public health detriment than allowing the sites to naturally clean themselves over many decades through the processes of dispersion, dilution and decay. It is recognized that decay will be a minor influence as the half-life of the parent radionuclides are very long.

In this report the sites identified will be, based upon a review of the available data, what was observed

during the field visit and our expert opinion, grouped into one of the 5 categories identified above.

Specific approaches to remediation will need to be developed immediately for categories 1and 2. For

these categories it is recommended that detailed action plans along with specific targets for timing

and cleanup criteria and a plan as to how these targets will be achieved be developed in association

with the appropriate regulatory authority and the parties, that will be responsible for the

implementation of the cleanup actions, within the next 3 months.

Conceptual recommendations should be developed for categories 3-5 as part of the overall watershed

strategy but more specific details will require the full participation of the companies, regulators and

affected general public in the watershed. Specific implementation and action plans are to be

developed by the appropriate regulatory authority and the parties that will be responsible for the

implementation of the cleanup actions within the next two years for full and open public discussion

and participation prior to finalization within a 3 year time frame. Specific remedial actions will be

developed for the sites by the companies involved and approved by the regulators at a time dictated

by the overall basin remediation strategy.

In order to ensure that long term water quality problems are not exacerbated in the watershed, all

waters discharged to the Wonderfontainspruit should meet minimum water quality standards as set by

the competent regulatory authority. In association with this discharge concentration site-specific daily

loading limits may need to be established as part of the watershed strategy.

The broad framework suggested in the framework report, and into which the following comments are

meant to fit, is meant to serve as a basis for a starting point for discussions with the public and

negotiations with the mining companies and regulatory authorities.

The following are my general comments on the sites visited and opinions as to which category the

areas represented by these sites may fall within. These comments are based upon the data that has

been made available for the site visit and observations made during the site visits to the selected

sites. During the course of the public hearings and detailed site surveys which will precede cleanup

activities additional data may become available which may result in some of the recommendations

made below being altered or changed. For some of the sites more detail is presented than for others

simply to provide an example as to a possible process that may be followed.

Recommendations for Specific Sites Visited

MP-1 – Tudor Dam –

The Tudor dam is located in the south eastern portion of the headwaters of the watershed. The area

behind the dam is currently dry and appears to be being mined to recover gold from the sediments



that had accumulated behind the dam during its period of use possibly as a process water reservoir.

At the time of the field visit it appeared that the re-mining had ceased or been suspended.

This is classed as a category 2 site, the remediation of which from a radiation health perspective is

required in order to be released from license and to meet ALARA. (ALARA is the concept to be

followed in radiation protection that states that all practices are to be carried out in a manner in which

radiation exposure/doses are kept As Low As Reasonably Achievable social and economic factors

taken into account.)

Based upon our site visit it would appear that there is no reason remediation of this area be delayed.

It is in a headwater area and if remediated there would appear to be little to no chance of

recontamination. Accordingly it is recommended that recovery of material containing in excess of

0.5Bq/g of any radionuclide be completed within the next year and that a complete rehabilitation plan

be submitted to the appropriate regulatory authority for approval within 3 months. If cleanup to the

0.5Bq/g standard is deemed not to be feasible then the company would be expected to propose an

alternative cleanup target and justify the proposed cleanup target. The proposed remediation plan

along with the proposed cleanup targets and the criteria by which the proposed target(s) is to be

judged should be reviewed by the appropriate authority for acceptability within 2 months following

submission. If it is not found acceptable as submitted, the appropriate authority will within 3 months of

submittal specify what will be required for its acceptability along with specific milestones and

objectives to be met to constitute an acceptable plan and the company will have to meet this

requirement in order to retain its operating license. It is recommended that the goal should be to have

site rehabilitation completed to a state where the area no longer will need to be licensed within a 3-

year period.

As a general licensing principle – It is recommended that if a company is given a license to re-mine an

area it should be a requirement of the license that the project continue uninterrupted until the area is

fully decommissioned and not left in an un-decommissioned state, in which a potential public health

risk may exist and ALARA is clearly not being achieved as soon as the profitable material has been

removed. That is the full decommissioning of the site needs to be costed into the re-mining plan.

MP- - Drainage channel below the Tudor Dam.

The drainage channel below the Tudor dam appears to be contaminated with radioactive material

exceeding clearance levels of 0.5 Bq/g and will need to be remediated prior to the site receiving

clearance and being released from license obligations.

This is identified as a category 2 site and if no more mining will be occurring above this area in the

watershed it is recommended that this area be cleaned to clearance levels or some alternative and

justified level immediately following the rehabilitation and issuance of a clearance certificate for the

Tudor Dam site within the next 3 years.

MP –46 Lancaster Dam



The area behind the Lancaster dam appeared to have been filled with slimes that appear to have

recently been re-mined. During the site visit it appeared that the Dam had been breached by heavy

equipment so as to allow acidic slimes water and fine slimes to drain into the pond and wetland

immediately below the dam. Drainage of water from this area was continuing at the time of the site

visit. These actions would appear to be in clear breach of the law. As the site presently exits it is

suspected that acutely toxic acidic drainage likely containing significant radionuclide levels is currently

draining from the site through the breach in the dam into the pond and wetland immediately below the

dam. Because of the lack of any flow restriction this could become an extremely serious situation

following a heavy rainfall.

Because of the imminent threat that this site poses, the way it currently exists, to the downstream

environment this is categorized as a class 1 site requiring immediate action.

Accordingly it is recommended that:

1. The dam be immediately repaired and that all water that collects above the repaired dam be collected in an engineered sump system and be pumped to a suitable treatment facility and treated prior to release to the environment so as to meet all applicable regulatory discharge standards. The dam and treatment facility shall be maintained in good repair until the site is released from licensing.

2. That a re-mining and rehabilitation plan for the Lancaster dam site be prepared and submitted to the licensing authority for approval within a year.

3. Note the municipal landfill is also likely contributing contaminated seepage to the water above the Lancaster Dam. There may be an advantage to the mining company and the municipality jointly working together to address water quality issues above the Lancaster Dam.

MP-3 – Wetland Below Lancaster Dam

The wetland area below Lancaster dam can logically be broken down into two sections.

1. The upper section is between Lancaster Dam and the highway where the flow crosses the highway in a culvert. In this area sediment sampling should be carried out to determine the extent of slimes contamination as a consequence of the breach of the Lancaster Dam and possibly earlier discharges. This sampling should be comprehensive in both aerial extent and depth. This section is classified as a category 2 area that should be remediated following the rehabilitation of the dam if sampling shows significant contamination in this area. If significant contamination is found remediation will in all likelihood involve excavation of the contaminated sediments and replanting of the wetland vegetation and this may require additional permitting depending upon the classification of the wetland.

2. The lower section lies between the highway and the blocked off fill road crossing the wetland near the high voltage transmission lines. This area should also be surveyed spatially and with depth and if found to contain a significant amount of slimes also be categorized as a category 2 area and be remediated at the same time as the area above the highway.

A detailed remediation strategy and plan for both of these areas should be developed within the next

year.

Note

As part of the detailed watershed strategy a justifiable criteria for in streambed remediation will need

to be developed. The remediation criteria will likely involve a combination of the mass of contaminants

present in the area to be remediated (volume of material x its specific activity or toxic trace elemental



concentration), its potential for rapid remobilization into the water column, the environmental damage

or social disruption that may be caused by the remedial action and the cost of carrying out the

remediation (rand/Bq or Rand /g toxic trace element above the target remediation criteria). The

criteria would likely apply per m of stream length as this would be an approximate proxy for the rate of

release of contaminants into the water volume (Bq/s/L) within the stream. This implies that larger

masses of in-stream contamination can be tolerated (and consequently a higher mass flux Bq/s), for

letting natural attenuation (dilution) clean the stream in downstream sections, where there are higher

flows (L/s) to dilute contaminant fluxes to acceptable concentrations. These determinations would

need to be made in conjunction with the integrated watershed model where all inputs (including

contributions for remaining in-stream contaminants) are taken into account. This would need to

consider for example the issue of simply exporting contaminants downstream to an area where they

could accumulate and cause a significant problem. The surveys to determine the extent of the in-

stream contamination should extend as far onto the flood plain of the stream as the contamination

extends.

From a practical standpoint it may be appropriate to develop a relationship between radiation levels

and other contaminant levels in the sediments and a radiation reading using a high sensitivity

pancake meter. As cores are taken and segmented into 5 cm slices and placed in labeled plastic

sampling bags each bag could be flattened to a standard geometry and read with the pancake meter.

This would allow a field evaluation of the areas requiring sampling and possible remediation to be

made. If a good correlation can be obtained then possibly only one in 10- 50 samples would be

analyzed in the laboratory for uranium (Unat) confirmation of the field samples. Using an approach

such as this possibly only one in 100 samples would need to be analyzed radiometrically for the

presence and levels of other radionuclides. In addition the field crews would carry a standard

reference sample to check the field calibration of the instrument every 20 samples or so. These are

only suggestions so as to make an extensive field survey practical and a proper sampling design

would have to be developed for each site based upon its characteristics.

As sections of the Wonderfonteinspruit are remediated it is essential that upstream sections are made

secure against further slimes and effluent release to the stream. This will require that the paddocks

and downstream retaining dams be designed to withstand a storm. For example the competent

authority may require 10 x the time it will take to re-mine the slimes up to the forecast (not hind cast

taking climate change into account) 1000 yr storm. That is if it will take 10 years to remove a slimes

pile with re-mining the paddocks and retaining dams will need to be designed for a 100 yr forecast

storm. The issue being if a section of stream is cleaned up there has to be a very low probability that it

will need to be rehabilitated again as a consequence of a slimes spill or accidental discharge. Since

the polluter pays policy will likely be enforced it may be that the companies may wish to reduce this

probability even further. The competent authority should however set a minimum standard.

MP-4 – The section of the stream between MP3 and MP4 should be surveyed for sediment

contamination by uranium. If this section is found to contain areas of sediment contamination

exceeding the justified remedial level these areas should be remediated.

This section is likely a category 3 and a survey and remediation plan should be put together within the

next 3 years for implementation, if appropriate, within a year or two following the approval of the plan

and obtaining the necessary environmental authorizations.



MP-5 - The MP-5 site was classified as a site of potential concern because it was believed that the

water in the steam at this point could be used for irrigation. There was evidence of a small garden

adjacent to housing in the area but the amount of produce that could be produced from the garden

and the levels of radionuclides in the water that could potentially be use for irrigation would not result

in radiation doses that would justify a significant public health concern. The section of the stream

upstream and downstream of this site as far as where it enters the Attenuation dam should be

surveyed for the presence of contamination and the criteria for cleanup applied. As discussed above

and for all the sites the default cleanup criteria should be the 0.5 Bq/g clearance standard. In some

cases a site specific standard can be proposed justified under ALARA and if found acceptable by the

regulator applied for that site. Although the sediments of the Attenuation dam were not identified as

an area of potential concern additional core sample sediments should be taken in the center (deepest

sedimentary basin of the reservoir) and analyzed (using the field and laboratory conformation

approaches suggested above).

MP-47 – This is an area below one of the Rand Uranium (Harmony) tailings areas into which a slimes

spill occurred following the breach of a small retaining dam. Presently the slimes are not contained

and pose a risk of moving downstream into the watershed following heavy rains.

This area is classified as a category 1 area. Actions appear to be being taken by the company at the

site and discussions with a company representative suggest that they are preparing for a cleanup.

The company should be required to clean this up as soon as possible so that slimes are not allowed

to migrate further downstream. The area downstream should be cleaned up to < 0.5 Bq/g of soil (or

as mentioned above a justified ALARA criteria found acceptable to the regulator) so as to allow the

area to be removed from licensing and minimize any residual slimes that may wash downstream. As

discussed above a gamma survey correlation with radionuclides and potentially toxic trace elements

found in slimes should be developed such that cleanup efforts at this and other sites can be

monitored in “real time” reducing the potential need for remobilization of cleanup actions when a

confirmation survey is carried out by the regulator.

The downstream survey at this site should extend as far as where the tributary channel enters the

Wonderfonteinspruit.

Following the cleanup the paddocks should be inspected and the secondary downstream dam

inspected to ensure that they are constructed to withstand a slimes release that may be consistent

with up to a 100 year storm if re-mining of the slimes in the upstream section will take place within the

next 10 years or some other appropriate risk criterion.

MP-10 – Van Grunen’s Farm pond. The section of the spruit upstream of the pond and below the

Attenuation dam should be surveyed to ensure that there is no slimes contamination (exceeding the

established cleanup criteria) along the banks or in the sediment of the marsh area released from any

pipeline breaks or other sources near the gold or old uranium processing plant. If there is any

significant contamination exceeding the justifiable cleanup criteria discussed above these areas

should be remediated.

The pond itself based upon the reported readings collected to date is classified as a category 5 site

where natural attenuation should be allowed to take its course.

If significant slimes are found upstream of the pond that could possibly wash downstream into it they

would be classified as a category 2 area and immediate actions should be taken to remove them.



MP -12- Above Donaldson’s Dam – The sampling available suggests this wetland site would appear

to pose no immediate risk and would be classified as a category 5 site where natural attenuation

processes should be allowed to occur. These marshes should also be surveyed using the gamma and

confirmatory chemistry technique to determine if there are any areas that are justified in remediating

in the wetlands above Donaldson dam. Just upstream of this area irrigation water is being used from

the Spruit. Water quality and quantity usage should be monitored at this site during upstream

remedial activities (when higher levels of contaminants may exist in the water) to ensure that irrigation

is for small scale farming, and not subsistence use where all of the food is being used for

consumption by the residents, until such time as levels of uranium and other radionuclides that are

present in the Spruit waters drop to insignificant levels. Soils from this area should as part of the

watershed research and be evaluated for retention of radionuclides and trace contaminants to help

justify watershed specific irrigation water quality criteria for the watershed.

MP –13 –Overflow From Upper Donaldson’s Dam – This area would appear to pose no immediate

concern and be classified as a category 5 site not to be disturbed but to allow natural attenuation to

reduce levels. Contaminants in sediments in Donaldson dam need to be surveyed and magnitude of

contaminated sediments quantified to determine if remediation is justified. If significant contamination

justifies remediation this area should be remediated only following remediation of upstream areas.

MP-14 – Donaldson Dam Overflow Pipe – This area would appear to be of no immediate concern

and would be classed as a category 5.

The area of the old stream channel below the Donaldson dam should be surveyed with a gamma

survey meter and if found to contain any significant areas of slimes justifying cleanup (the area below

Lebanon Road would appear to be such an area) these areas should be classified as category 2 sites

and remediated within the next 3 years as there is a risk of these materials being spread throughout

the watershed during periods of high flow.

MP-23- Mine and Process Water Settling Ponds There are a total of 16 settling ponds that are

currently being used for settling of solids prior to the water being discharged to the canal discharging

to the Wonderfontainespruit. These ponds are all on mine controlled property, are part of a mine

water treatment polishing system and are fenced off from the public. As long as public access is

restricted they only require proper decommissioning once their useful life is finished. It should be

ensured that the decommissioning strategy and associated costs for these ponds is included in the

conceptual decommissioning strategy for the mine

MP-26 – This is at the junction of the two canals and local inhabitants were using water for washing

clothes. Just below this point the canal flows past an illegal settlement. Water should be supplied to

these people so that they do not use canal water for drinking purposes. With this proviso this is

categorized as a category 5 site and proper decommissioning of the canals, as part of the overall

mine decommissioning strategy must be carried out once their useful life is completed.

It is suspected that there has been significant water (and contaminant) loss to the dolomites

underlying this and the other canals over the long term. At the time of decommissioning these line



sources of potential groundwater contamination should be quantified and their contribution factored

into the long-term rehabilitation groundwater portion of the model for the Wonderfonteinspruit.

MP-27 – Point of discharge of Donaldson pipe to Canal – At this site no unacceptable risk would

appear to exist based upon available data and as such it is ranked as a category 5 site only requiring

proper decommissioning at the end of its useful life. The Spruit downstream should be surveyed using

the survey techniques agreed upon for the watershed remediation characterization and cleanup

justification and if areas justifying remediation are found the appropriate remediation carried out.

MP- 29 – 30-31 Harry’s Dam – This site appears to have relatively high sediment concentrations but

poses no immediate health risk. Because the dam serves no useful purpose and is on mine owned

land it should be decommissioned as soon as is practical to do so and mine water diverted around it.

This would be classed as a category 3 site with decommissioning recommended within the next

decade or as soon as reasonably achievable by the mine. The pond is on the saturated side of the

dike and may support a natural seasonal static water level. Without mine water flow into the pond

water quality will likely rapidly deteriorate if cattle are allowed access directly to the pond for watering.

MP- 34 – 35 – This is a dry stream bed that carries storm flow. It contains evidence of slimes having

been washed down into it from an upstream slimes spill. This whole storm water channel bed should

be surveyed with a gamma meter and if significant areas of slimes are found they should be cleaned

up applying ALARA. This would be classed as a category 1 area.

MP-36 – Padda Dam- This dam based upon available data would appear to pose no immediate

radiation health risk and is classified as a category 5 site such that natural processes be allowed to

clean the site through dilution and sediment burial of contaminants. As part of the remedial survey of

the watershed several core samples should be taken in the pond and this conclusion validated.

MP-37 Road Crossing below Padda Dam – This area is not deemed to pose any significant

radiation health hazard and it is classified as a category 5 site although the off line pond upstream of

the road crossing should be sampled and the stream bed between the Padda dam and the road and

the stream downstream of the road should be surveyed as part of the remedial survey to validate this

classification.

MP-40 – Doornfontein canal sample – This location does not appear to pose any significant

radiological public health hazard and is classified as a category 5 site just requiring appropriate

remediation upon decommissioning and as the case with all of the canals its consideration as a

groundwater line source of potential contamination.

MP- 41 – Doornfontain canal Discharge to Spruit - No significant radiation health issues would

appear to be posed at this site based upon available data and it is suggested as a category 5 site.

The steam sediments need to be surveyed above and below this area to validate that there are not

significant slimes present that would justify remediation applying the agreed upon criteria. It is

suspected that downstream areas may have significant slimes.



MP-42 Gauging Station - No significant radiation health issues would appear to be posed at this site

and it is suggested as a category 5 site with the proviso that upstream and downstream sections be

included in the watershed wide remedial survey.

MP-43- Upstream Inlet to Cotezze’s Dam- The sediment sample collected here appeared

abnormally high at 7700 mBq U-238/ Kg and should be validated as a part of the watershed remedial

justification investigation. Based upon this assessment this would be classed as a category 4 site

potentially requiring remediation but not until the potential for recontamination from upstream sources

has been reduced to insignificant levels. If the extent of contamination exceeds the criteria for this

section of the watershed then this remedial actions should be investigated. This would be classified

as a category 4 site with survey verification work to be carried out within the next 3 years as part of

the remedial cleanup justification program.

MP-44 – Outlet of Coetzee’s Dam – This site would not appear to pose any significant radiation

public health hazard and is also classified as a category 4 site because of what would appear to be

high levels of contamination in the sediment. The sediments should be spatially sampled and cored

as part of the remedial justification cleanup survey and if significant contamination present, and if a

site specific ALARA justification warrants, dredged at the time of mine decommissioning when the

potential for recontamination is not significant.

MP-45- Upper Visser Dam approx 500m downstream of Coetzze dam - This site would not appear

to pose any significant radiation public health hazard and is also classified as a category 4 site

because of what would appear to be high levels of contamination in the sediment. The sediments

should be spatially sampled and cored as part of the remedial justification cleanup survey. If

significant contamination is present, as justified by ALARA justified criteria, it should be dredged at the

time of mine decommissioning when the potential for recontamination is not significant.

MP 22 – This site was in a canal and does not appear to pose any immediate significant radiation

health hazard. Mine personnel suggested that the mine was going to zero discharge within a year and

water should stop flowing in this canal. The mine should be encouraged to do this. This as with all

other canals should be considered as a potential line source of groundwater contamination and is

classed as a category 5.

MP-18 – Slimes spill area – Slimes spill appears to have spilled across field and into canal where it

likely carried through to the Wonderfontainspruit and discharged near MP 40 and MP 41 and it is this

spill that may be at least partly responsible for the relatively high levels of uranium seen in the

Coetzze’s and Visser’s dams. The cleanup of the spill is continuing. This site is categorized as a

category 1 area and the mine should be encouraged to have the work complete by the start of the

rainy season so that there is no further potential for slimes discharge to the canal and Spruit.

MP 21- Small stream below dam NW of Elandstran mine. This area would appear to pose no

significant radiological risk and is classified as a category 5 site although the sedimentary areas in the

pond upstream and downstream of this site should be sampled as part of the remediation justification

program.



MP-20 – Mine water Return dam – This area would appear to pose no immediate significant

radiological risk. There is evidence of a slimes spill below the dam associated with a pump failure.

Mine personnel indicated that it would be cleaned up in the very near future. The regulator should

encourage this to prevent the slimes from spreading. This is a category 1 site and cleanup should not

be delayed.

MP-30 – Site of slimes spill down into the Carletonville greenbelt area. This area would not appear

to pose any immediate radiological risk. The greenbelt area and the storm drainage down to the

Wonderfontainspruit should be surveyed with a gamma meter and if any significant areas of

contamination are detected and cleanup justified they should be cleaned up as mentioned for the

downstream portions of this storm water drainage. This would be classified as a category 1 site.



Report to the Specialist Task Team, September 1-5, 2008

By Prof. Ronald R. Cohen, PhD

The following material is a summation of my recommendations and action plans concerning areas of

potential intervention for the mitigation of uranium contamination in the Wonderfonteinspruit

catchment in Gauteng and Northwest Provinces of South Africa. The report consists of:

A description of the site with pertinent characteristics that weigh on the recommendations and action

plans.

A categorization of sites based upon the risk at the sites and the urgency of intervention, and

Recommendations for implementation of remediation strategies for the individual sites and the

catchment as a whole.

It should be noted that some areas of concern may not require remedial actions due to their low levels

of uranium and radiation that would likely not present an unacceptable level of risk, or that the site

presents little to no route for human exposure, either directly or through the food chain. For some

sites, it is obvious, upon inspection, that the involved parties have already addressed and remediated

the area of intervention.

In this report, acceptable risk is based upon objective criteria established by the World Health

Organization, South Africa, the United States (America), and individual states of the USA that have

standards and guidelines even more strict that of the USA as a whole. The acceptable risk that is

subjective and culturally determined is not used in my report as it is difficult, if not impossible to

quantify and set forth as an objective criterion. At some sites, the acceptable risk is based upon the

concept of ALARA, as low as reasonably attainable.

Categorization

The sites, where possible, will be associated with a particular category. There are some instances in

which the sample collection location, the method of taking the sample, of the results of the sampling

are ill-defined and may not be sufficient for establishing a clear cut category.

Initially, the categories were:

1. Easy – why not

2. High Priority

3. Too costly

4. Completed

5. Uncertain

I modified the categories to better resolve the characteristics of the mines and the need for action in a

timely fashion. This resulted in the following categories. If necessary, there categories can be made to

be congruent with the above, simplified classification.

Category



The site presents an unacceptable risk or is in such poor condition that rapid remediation action is

mandatory.

The site is in such a state that it would be unreasonable to tolerate it any longer. The site should be

subject to remedial action as soon as possible.

The site will require a long period of time to remediate, perhaps being remediated as slimes are

reprocessed.

The site does not present a high or even medium risk, either due to radiation or uranium levels that do

not exceed national or international standards or sites that are inaccessible to humans and

contaminated media on the site is not used for any purpose that would place the contaminated

material in a location or a product that is accessible to humans.

The site requires no remedial action because risk is very low

The site requires no remedial action because it already has been dealt with by responsible parties.

The site is being used by the responsible parties for re-mining and can be remediated as re-mining

takes place.

The site should be remediated because it will take very little in human and financial resources to bring

the site to even lower levels of contamination and will result in positive responses from and a greater

comfort level for the community.

The site presents medium-high uranium and/or radium levels, at or exceeding national or international

standards.

Remediation will be inexpensive and easy. Should be done or started soon.

Contamination is not very high, but may be high enough and with ready human access such that

remediation should be undertaken, even if the remediation is spread out over several years.

Remediation may cause more problems than the contamination itself. For example, removal of the

contaminated sediment at the bottom of a farm dam may break the seal that reduces permeability to

the overlaying water. The water permeates through the bottom sediments and dissolves the

carbonates of the underlying dolomite resulting in a sink hole and creates a route for groundwater

contamination.

Remedial Action Plans for the Sites

The remedial action strategies that I recommend for implementation are based upon current

technologies. No remediation technology that I will recommend is innovative or unproven. Some are

based upon techniques as fundamental as earth moving. Others may require commonly used

chemical methods for treating water. Some may require a small level of construction.

Recommendations for Areas of Intervention

MP1: This is the Tudor Dam, formerly a return water dam. The site is now mostly water-free and the

slimes sediment is being re-mined. Thus, the uranium issues at the site are being addressed. There is

evidence of sulphate evaporites on the surface of the sediments. Activity due to uranium is high,

8000-10000 Bq/Kg with radium 226 at 1700-2800..

Category: 2.c) The site is being used by the responsible parties for re-mining and can be remediated

as re-mining takes place.



Recommendation and action plan: Continue to re-mine and remediate as the mining takes place.

The site can be converted from a mining site to a rehabilitation site. Once re-mining is completed, it

should be filled, graded and revegetated. The site rehabilitation should be inexpensive and yet yield

significant returns as a model reclaimed site.

MP2: Dry “wetland” just below Tudor Dam. The channel contained well-sorted fine sediments that I

would consider slimes deposited from overflow from the Tudor Dam. Uranium and radium were high

here, at 2000 Bq/kg for uranium and 1200 for radium, as would be expected if they were sourced from

the Tudor Dam.

Category: 3.a) The site presents medium-high uranium and/or radium levels, exceeding national or

international standards. Remediation will be inexpensive and easy. Should be done soon.

Recommendation and action plan: Remove the small amount of slimes and place in a slimes dam.

Actions should be taken quickly as runoff in the rainy season may move slimes downstream in the

catchment.

There are several concrete foundations and other structures on the site. Remove the concrete blocks

to increase aesthetics of site. It can be done quickly and inexpensively.

MP46: Wetland downstream from breech of Lancaster Dam. The dam breech looks to have been

excavated using heavy earth moving equipment and slimes have passed from the dam, into a

wetland. A small stream of orange water flows through the basin, then through the breech in the dam.

On the downstream side of the dam, there is an orange pool of settled slimes, filled with acid mine

drainage water, where there is few plants and signs of dead wildlife. Dry slimes were observed

blowing throughout the Lancaster dam site. There is a plan to re-mine the site. Conditions at the site

are very poor.

Category: 1.a) The site presents an unacceptable risk or is in such poor condition that remediation

action is mandatory. The site is in such a state that it would be unreasonable to tolerate it any longer.

The site should be subject to remedial action as rapidly as possible.

Recommendation and action plan: First, the dam breech should be repaired immediately. Then, the

slimes that have been deposited in the wetland should be removed to a slimes dam as soon as

possible. Then, the site should be reclaimed as it is re-mined. The site will require a long period of

time to remediate, perhaps being remediated as slimes are reprocessed. A bond should be set aside

by parties mining the slimes to guarantee rehabilitation until final decommissioning. Ultimately, after

remining is completed, the site should be loaded with fill, graded, and revegetated.

MP3: This site is a wetland, just downstream from the Lancaster Dam, which was formed once a

stream was dammed by the road. Before the establishment of the Lancaster Dam, there was no

wetland. There was a stream cutting through Highveld. The road not only trapped water to form a

wetland, but it also trapped slimes eroded from the Lancaster Dam. The fine slimes trapped seepage

and formed the wetlands.



Category: 3.b) Contamination is not very high, but may be high enough and with ready human

access such that remediation should be undertaken, even if the remediation is spread out over

several years.

Recommendation and action plan: Only a single sample of the sediment was taken and the

radiation level was elevated at 80 mBg/g. The water sample radiation was only moderately elevated

at 280 Bq/L for uranium and 250 mBq/L for radium. It is not known where the sediment sample was

taken or at what depth. Therefore, there is uncertainty as to just how high the radiation risk is at the

site. First, cores should be taken to characterize the level of contamination in the wetland sediment. A

core should be sectioned into 1-2 cm layers and 238U radiation levels should be determined for each

layer. The characterization of the site should take place as soon as practicable.

If the wetland is determined to be an unacceptable radiation risk, then responsible parties should

consider restoring the area to the “stream surrounded by high veld” topography that it was before

slimes contamination and road damming. Such a rehabilitation may take several years.

MP4: The site was formed from eroding slimes dam and is bisected by a dirt road. The most obvious

visible feature of the site is the extensive deposit of trash in the wetland, by the road. Bags filled with

excrement presented an objectionable odor and likely contribute to water and sediment

contamination. Uranium radiation in the water was higher than at most sites, at 2,200 mBq/L. The

slimes are in the process of being remined.

Category: 1. b) The site presents an unacceptable risk or is in such poor condition that rapid

remediation action is mandatory. The site will require a long period of time to remediate, perhaps

being remediated as slimes are reprocessed.

Also 3.a) The site presents medium-high uranium and/or radium levels, at or exceeding national or

international standards. Remediation will be inexpensive and easy. Should be started soon.

Recommendation and action plan: It is difficult to devise a specific remediation plan, but some

action plans are in order. The party remining the slimes should develop and submit an action plan

now, as they are remining. Remediation can take place while the responsible party is earning income

from the remining. The company should be bonded to make certain that there will be money available

should the responsible parties not remediate the site to mandated levels. It may take several years for

the site to be rehabilitated as remining takes place. The company should remove the slimes and

some upper top soil. The site should re-seed naturally from the surrounding plants, but re-seeding

could be enhanced if necessary. Turn the wetland into part stream and part wetland. Bring the

radiation down to < 0.5 – 1.0 mBq/g.

MP5: It is a site that is part of the MP4 wetland and has been turned into a garden. The soil is fill that

was deposited upon the slimes that make up the sediment of the wetland. MP4 and MP5 are in close

proximity and part of the same wetland system. There is minimal radiation in the fill soil, but it is likely

that levels similar to MP4 would be found below the fill.

Category: Same as MP4.



Recommendation and action plan: MP5 should be remediated as part of MP4. Gardening should

be terminated as the crop vegetation may concentrate uranium and daughter products in the plant

tissues. This would be a particular problem if the gardens were irrigated with the 2000 mBq/L water.

The mine that is the source of the uranium should be advised to treat their effluent to remove the

uranium, perhaps by using BaSO4 . The mine should start the treatment within a year.

MP47: An abandoned dam in Reitvalei, SE of Randfontein. It used to be a slimes dam. Now they are

open cast mining on it. Uranium is high at 5200 mBq/L with radium at 720 mBq/L. When it rains, water

flows in and fills a stagnant pond. The water evaporates and leaves a deposit of sulphates, uranium

and daughter products. This process is repetitive, with concentrations of contaminants increasing with

each precipitation event. Cattle were grazing in the area and represent a potential route of

contamination to humans. The mining company said that they were remining and cleaning out the

area. They had added paddocks to trap slimes during extreme events. The mining company is doing

reclamation along with the remining. The site is a high priority cleanup as it is at the head of the

catchment.

Category: 1.b) and 2.c). The site presents an unacceptable risk or is in such poor condition that rapid

remediation action is mandatory. The site will require a long period of time to remediate, perhaps

being remediated as slimes are reprocessed.

The site is being used by the responsible parties for re-mining and can be remediated as re-mining

takes place.

Recommendation and action plan: Remediation action are taking place as remining is underway.

NNR must monitor the adherence to plans to remediate. Large rocks from the area could be used as

a fence line to keep the illegal cattle from grazing in the contaminated site.

MP10: Small dam on Greuning farm. The farm previously used fissure water for irrigation, resulting in

moderate levels of uranium contamination in the water and sediments. Now, they are using dolomitic

water, so original samples taken for uranium are no longer representative. The pH is 8.5 and there is

a flow from an upstream wastewater treatment plant entering the pond at 17 megaliters per day.

Category: Contamination, if still present, must be characterized and quantified to identify category

and remediation actions.

Recommendation and action plan: To be determined after quantification of contamination.

MP-11: Mine water pipe from Randfontein Estate GM was present on the Greuning farm in the past.

Category: 2.b) The site does not present a high or even medium risk, either due to radiation or

uranium levels that do not exceed national or international standards. The site requires no remedial

action because it already has been dealt with by responsible parties.

Recommendation and action plan: Mine has already removed pipe.



MP12: Donaldson Bridge on Road 559. There is considerable uncertainty concerning location of

sample collection both over the area and with depth. Contamination requires further quantification.

Slimes likely not present in significant amounts.

Category: 2.a) or 3.b) The site does not present a high or even medium risk, either due to radiation or


action because risk is very low, or: Remediation will be inexpensive and easy. Should be done or

started soon. Contamination is not very high, but may be high enough and with ready human access

such that remediation should be undertaken, even if the remediation is spread out over several years.

Recommendation and action plan: The site may be low risk as is and may need no remediation, but

that cannot be determined until cores are taken to identify deep the contamination goes. Immediate

remediation actions are not urgent.

MP13: Northern part of Donaldson Dam. Fishing site. Privately owned with catch and release rules.

Uncertainty about location of sampling site.

Category: 2.a) The site does not present a high or even medium risk, either due to radiation or

uranium levels that do not exceed national or international. The site requires no remedial action

because risk is very low.

Recommendation and action plan: The site requires no remedial action because risk is very low.

Final decision should be based on better quantified sampling of cores in sediment.

MP14: Overflow from lower Donaldson Dam. Sediment samples should be taken downstream from

discharge.

Category: 2. d) The site should be remediated because it will take very little in human and financial

resources to bring the site to even lower levels of contamination and will result in positive responses

from and a greater comfort level for the community.

Recommendation and action plan: A major problem is that trash and sewage from informal

settlement is clogging the gratings causing overflow. Install trash trap to avoid clogging and empty

trap periodically. The dam is an efficient sediment trap. Sample the sediment to identify whether the

site is a candidate for remediation.

MP18: Runoff seepage collection pond at slime dam north of Doornfontein. There is a large slimes

dam that towers over the site. There has been an escape of slimes from the dam all the way to the

Blyvooruitzicht canal. Toe paddocks have been constructed to contain the slimes, but one of the toe

paddocks has been breeched so that slimes could be transported during a precipitation event.

Category: 2.d) The site does not present a high or even medium risk, either due to radiation or

uranium levels that do not exceed national or international standards. The site should be remediated

because it will take little in human and financial resources to bring the site to even lower levels of

contamination and will result in positive responses from and a greater comfort level for community.



Recommendation and action plan: In terms of radiation, the site does not seem to be particularly

significant or alarming. There is evidence of very poor management of the slimes dam, so any costs

for remediation should be born by the mines. All that is need are several people or a backhoe-

bulldozer to repair the toe paddock to protect against future release of slimes from the dam. The mine

representative said that the slimes that have moved toward the canal have been cleaned up.

MP20: Return water dam made up of mine water from Doornfontein mine as well as runoff water from

slimes dam. The slimes dam water moves through pen stock to the return water dam. There was a

leak at the pump station that was not contained and has not been addressed. There is evidence of

slimes around and down gradient from the pump station. There also is evidence of cattle grazing

around the pump station, with relatively fresh manure directly on top of the escaped slimes. Radiation

from water and the slimes was unacceptable, according to the Wonderfontein Spruit reports,

particularly in the form of radium, at 1750 Bq/kg.

There are two return water dams. One operates while the settles slimed in the other dries out. The dry

slimes are transported to the slimes dam.

Category: 3.a) Site presents medium-high uranium and/or radium levels, at or exceeding national or

international standards. Remediation will be inexpensive and easy. Should be started soon.

Recommendation and action plan: Slimes around the pump station should be cleaned up

immediately. There is a fence to keep cattle out, but it must have been built very recently as the

manure on and about the slimes spill was fresh.

MP21: Dam NW from Elandsrand GM, at end of slimes dam near storm channel. The stream flows

from treated process water and sewage. Rocks in the stream were examined and a large number of

invertebrates were found to be thriving. Many leeches on some rocks.

Category: 2.a) The site does not present a high or even medium risk, either due to radiation or


action because risk is very low

Recommendation and action plan: This site really isn’t an area of concern unless cattle nearby may

be ingesting uranium. The cattle could be restricted from the area simply by adding and improving

fences.

MP22: A canal from the Blyvooruitzicht GM. It is a point of compliance that is sampled every week. It

flows with process and fissure water from the mine. Uranium is elevated at 1980 mBq/L, which

converts approximately (using conversion that 84 µg U238 = 1 Bq) to 200 µg U/L. DWAF limit is 50

µg/L and Canada’s is < 100 µg/L . There is high iron in the samples, and ferric iron can cause

uranium to flock, thus serving to remove U down to standards.

Category: Uncertain.



Recommendation and action plan: Given concentrations of uranium 238 and flows, loads can be

calculated to permit decisions about remediation.

MP23: Canal from West-Driefontein GM (from SE of Carletonville)

MP24: Canal from West-Driefontein GM (from E of Carletonville)

MP25: Storage/sedimentation ponds E of Carletonville

Canals carry water from shafts # 8 and 10 into a group of 16 ponds. The water from shaft 10 primarily

is fissure or intercepted groundwater. From shaft 8, it is process water with radiation levels higher

than shaft 10 water. The impact of the process water can be seen at sampling sites 24 and 25. Flow

typically is 30-35 megaliters per day. Thus, the ponds receive about 2 megaliters of water per day.

There is treated sewage water coming in from a golf course. With a size of 50 x 150 m and 1 m depth,

there is a 3-4 day residence time in each pond. The ponds primarily serve as sedimentation basins. A

farmer has been using process water for irrigation. The mine is attempting to buy out farmer to stop

use of process water for irrigation. The area is completely fenced.

Category: 2.b), The site does not present a high or even medium risk, either due to radiation or


action because it already has been dealt with by responsible parties.

Recommendation and action plan: It would be helpful to know the amount of uranium and daughter

products on the soil and vegetation of the irrigated farm. The farmer should cease using process

water for irrigation. The ponds are not an area of concern. The ponds could be configured to remove

even more uranium from the water, but that is not of immediate concern. Once the process water is

no longer used for irrigation, these sites are not areas of concern.

MP26: Canal from West Driefontein. Fissure water and process water move through canal together.

People were observed washing clothes in the canal. They said that they do not drink the canal water

but get potable water from nearby farm. We saw buckets used to take water from the canal.

Category: 3.c) The site presents medium-high uranium and/or radium levels, at or exceeding national

or international standards. Contamination is not very high, but may be high enough and with ready

human access such that remediation should be undertaken, even if the remediation is spread out over

several years.

Recommendation and action plan: Agencies should manage the site by ascertaining if residents by

the canal are using the canal water for drinking. If they are, then regulatory action should be taken to

force them to stop.

MP29: Harry’s Dam, upstream site

MP30: Harry’s Dam, Downstream

Just above these sites is the discharge point of the 1 m pipeline. Some of the water goes to Harry’s

Dam and the rest is transported to the Mooi River in an open canal. There is considerable uncertainty

about the location of the samples taken and why the sediment uranium and radium radiation levels



are as high as observed, 1500 Bq/kg and 1600 Bq/kg, respectively. The lake is shallow and easy to

drain. There is no known use for Harry’s Dam.



because it will take very little in human and financial resources to bring the site to lower levels of

contamination and will result in a greater comfort level for the community.

Recommendation and action plan: Harry’s Dam seems to serve no useful purpose except to collect

sediment and concentrate uranium and radium. It is shallow and easy to drain. Drain the dam, remove

the sediment to a slimes dam, and divert water around dam and into existing canal. This remediation

could be done over the next 1-3 years.

MP34: Sampling site on Wonderfonteinspruit near Carletonville, water edge Bridge Plot 68. This is

now a dry bed that only flows with stormwater. There may be pockets of sediments with uranium that

have built up over the years when the system received mine-sourced water.



because it will take very little in resources to bring the site to even lower levels of contamination and

will result in positive responses from and a greater comfort level for the community.

Recommendation and action plan: Using a scintillometer, identify whether there are small areas of

elevated radiation or if the whole area is contaminated. If contamination is found only in a few spots,

no remediation is necessary. If radiation is above 1 Bq/g and is widespread in the sediments, then the

site should be cleaned up. The remediation, if necessary as determined using the scintillometer, can

be completed quickly and should completed within a year.

MP35: Same bed as MP34, near agricultural holdings, draining from Carletonville. It is a public open

space. Uranium is in the sediment at 3-4 Bq/g. mostly from a failed slimes dam.

Category: 2.d)

Recommendation and action plan: same as MP34.

MP36: Padda Dam on the Wonderfonteinspruit. It receives dry ditch runoff. Few people visit the site.

Two fishermen were there during our visit and said they only caught 3-4 fish a month.

Category: 2.a) The site requires no remedial action because risk is very low.

The site does not present a high or even medium risk, either due to radiation or uranium levels that do

not exceed national or international standards or sites that are inaccessible to humans and

contaminated media on the site is not used for any purpose that would place the contaminated

material in a location or a product that is accessible to humans.



Recommendation and action plan: No remediation necessary.

MP37: Wetland at Khutsong Bridge, Merafong. Radiation not elevated significantly.

Category: 2.a) The site requires no remedial action because risk is very low.


MP38: Bridge on R501 at Blyvooruitzicht GM. Near slimes dam and mine entrance.

MP39: Storm drain under R501 at Blyvooruitzicht GM, within 200 m of MP38.

There was a slimes spill that occurred at the time of the Brenk report sampling. Slimes were removed

by mine. It is no longer a problem area.

Category: 2.b) The site requires no remedial action because it already has been dealt with by

responsible parties.

MP40: Doornfontein canal carrying mine water and discharge from sewage treatment plant. Flow is

very diffuse. MP40 discharge sampled near road.

Category: not on list


: Regulators (DWAF) should enforce compliance. Water should meet standards as determined by

Water Affairs.

MP41: Wetland upstream of Coetzee Dam.

MP42: Weir at DWAF gauging station C2H069

MP43: Coetzee Dam, upstream area

MP44: Wall of Coetzee Dam nar overflow to Visser Dam.

Category: not on list.


: The site needs to be better characterized before remediation methods can be selected. Uranium

levels should be determined in water and sediment based on sound sampling design. This includes

taking cores in the dam sediment and quantifying uranium in 1-2 cm layers of the sediment to define if

there is a problem and at what depth in the sediment is a problem. Replicate water samples also need

to be taken and the uranium levels quantified.

Once the system has been quantified adequately, then remediation actions can be recommended. If

the water samples exceed regulatory standards, any irrigation using the dam water should cease. The

dam is highly eutrophic. As algae photosynthesize, they remove carbon dioxide from the water and

raise the pH. This could induce precipitation of uranium.

MP45: Visser upstream dam. Blyvooruitzicht process water flows to Coetzee and Visser Dams. The

upper dam has an 80,000 m2 area with approximately a 1 m depth. There had been a tails spill in the



area that may have been transported, in part, to the Coetzee and Visser Dams. The sediment

samples taken here were merely scooped off the sediment surface. There were no cores taken of the

sediment, and the scoop sample is not adequate for interpretation of data. The Visser Dam is the

oldest dam on the stream. Water is low in the dam and some sediment is exposed on the shoreline.

Category: 4. Remediation may cause more problems than the contamination itself.


: Removal of the exposed and underwater sediments could break the seal that reduces permeability

to the overlaying water and make the dam bottom more permeable. The water could percolate into

the dolomites resulting in contamination of the subsurface water and dissolution of the dolomite,

causing sinkholes and wholesale contamination of the subsurface with sediments.

Before any actions are taken, the dam uranium contamination should be characterized as for MP41-

44.



REPORT No.: PR-VLG-08-16

DATE: November 2008

TITLE:

ASSESSMENT COMMENTS AND

PROPOSAL FOR THE WCA

REHABILITATION PROJECT

NAME SIGNED DATE

PREPARED G P de Beer

CHECKED G R Liebenberg

ACCEPTED

APPROVED

DISTRIBUTION

NO. NAME NO. NAME NO. NAME

1 NLM QA RECORDS 8 15

2 PELRAD RECORDS 9 16

3 PS&CM-GEA-

05/001RECORDS

10 17

4 NNR 11 18

5 ILISO 12 19

6 13 20

7 14 21



CONTENTS

1.0 BACKGROUND .................................................................................................... 170

2.0 REVIEW COMMENTS ON NNR REPORT ........................................................... 170

2.1 Habits, Pathways and Scenarios ....................................................................... 170

2.2 Analysis Results ................................................................................................. 170

2.3 Parameter Values ................................................................................................ 171

2.4 Background Conditions ..................................................................................... 171

2.5 Chemical Toxicity ............................................................................................... 171

3.0 FUTURE ASSESSMENT METHODOLOGY ........................................................ 172

4.0 ADDITIONAL CONSIDERATIONS ...................................................................... 172

5.0 REFERENCES ..................................................................................................... 173



BACKGROUND

A draft report by the NNR [1], describing a public radiological impact assessment for a set of

sampling sites along the Wonderfonteinspruit has been submitted to NECSA for review by a

Radiation Protection Specialist (RPS), also to present a proposal for a future assessment

strategy. The same NECSA RPS also serves on a Specialist Technical Team (STT) who, during

the week 1 to 5 September 2008, visited the various sampling sites addressed in the NNR

report. STT members were asked to provide a report on their specialist inputs to a rehabilitation

plan for the Wonderfontein Catchment Area (WCA). This report combines the two tasks above,

providing review comments on the assessment methodology in [1], while also proposing a way

for further assessments related to planned remediation options. The report will hence focus on

the impact assessment requirements rather than the remediation options, as this is foreseen as

the major input from the NECSA RPS.

REVIEW COMMENTS ON NNR REPORT

The NNR regards the assessment reported on [1] as a screening assessment. A screening

assessment is normally performed as the first assessment in an iterative assessment process to

identify the lower risks that can be screened out by using a conservative approach. The review

comments below will hence focus on possible improvements in the assessment methodology for

more comprehensive and more realistic future assessments.

10.1 HABITS, PATHWAYS AND SCENARIOS

The assessment approach is defined in the NNR report [1] as a “per sample approach” using

the analysis results of a number of water and sediment samples to assess public doses for

which standardized habit parameters are assumed. As indicated in the report, these

standardized habits could deviate from the real parameters applicable to specific communities.

It is recommended that more accurate habit information be collected and used to specify a

number of representative groups within the affected communities along the WCA as well as

other groups affected by food distributed from the area. From these groups, reference

individuals could be selected and a detailed source-pathway-receptor analysis could be

performed for each of these to derive more realistic scenarios and assessment detail and to

define parameters.

10.2 ANALYSIS RESULTS

While reference is made to samples collected for other studies, the assessment reported in [1]

is mainly based on a single set of samples collected for the study. Experience indicated that



nuclide concentrations in environmental water and sediment samples can vary over two orders

of magnitude due to seasonal and diurnal variations. An effort should hence be made to obtain

samples representative of a longer period like a year. This may partly be realized by enquiring

after analytical data from routine samples collected by the Department of Water Affairs and

Forestry (DWAF) and the licensed mines.

10.3 PARAMETER VALUES

The NNR report [1] indicates that it followed the methodology presented in their licensing guide

LG-1032 [2]. Parameters provided in this guide are sometimes very conservative and exceed

values provided in international literature by substantial margins. Soil-to-plant and plant-to-

animal transfer factors are generally almost an order of magnitude higher than those in 0 and at

the maximum value of the range presented in 0. While interception, translocation, transfer and

bio-accumulation factors are associated with rather large uncertainties, internationally published

best-estimate values are normally used in assessments, while uncertainties in such values are

normally only considered in uncertainty evaluations.

There should also be a distinction between soil contaminated through adsorption of

radionuclides from water and soil containing slimes. The soil-to-plant transfer factors of the latter

are likely to be significantly lower than those of the former.

The long-term accumulation of activity in the soil through irrigation may also be better calculated

by using Kd values, also considering leaching from the top soil layer due to non-transpired rain.

Finally the addition of a fraction of the sediment activity to the water activity due to sediments

considered to become suspended during cattle watering may need better motivation through

experimentation closer to the in-situ conditions.

10.4 BACKGROUND CONDITIONS

Radiological background conditions were based on measurements and analytical results from a

single site. Based on geological information on the WCA region, it should be established

whether this is sufficient or whether more background sites should be considered.

10.5 CHEMICAL TOXICITY

The assessment considered only the radiological impact. The chemical toxicity impact of soluble

uranium outweighs its radiological impact and should also be assessed and evaluated.



FUTURE ASSESSMENT METHODOLOGY

While the mathematical formulation is presented in the report and seems to be in order, the

specific Software Product used is not presented. For more advanced calculations, the use of

well-established software is recommended, satisfying generally-accepted V&V requirements.

Various software products for radiological public impact assessments are available

internationally. Locally a group of personnel from NECSA, PBMR, NNR and Koeberg has

recently been trained on the GENII software developed at the Pacific Northwest National

Laboratory (PNNL) in the USA. This group will form a users group to facilitate and expand the

further use of the software locally. The developer also undertook to qualify the software to the

ASME NQA-1 and 10CFR50 standards in the USA, which will satisfy local V&V requirements in

the nuclear industry.

The software also deals with NORM as per the uranium and thorium decay series. It contains

models to handle atmospheric and surface water transport as well transfer to soil, plants and

animals. It also contains data libraries and default parameters for the models above and also

internationally accepted coefficients for dose and risk assessments through external radiation,

inhalation and ingestion.

It is recommended that this software be used for further assessments on the WCA. Such

assessments may not only include a more comprehensive assessment to confirm or replace

results of the screening assessment, but also to evaluate remediation activities and more

comprehensive survey and analysis results.

ADDITIONAL CONSIDERATIONS

Considering the review comments above and remarks in the NNR report itself, the doses in [1]

are regarded as conservative values. For monitoring location MP20 the annual real and

potential doses presented in [1] are above 100 mSv, while for location MP38 an annual potential

dose above 100 mSv is reported. For location MP1, an annual dose close to 100 mSv is also

reported. At these levels determinable stochastic health risks may be relevant after relative

short chronic exposure periods. Doses for these three samples relate, however, more to the

uranium decay products in the sediment samples than the uranium isotopes themselves. It also

appears that slimes rather than sediments are the more likely cause of the contamination. As

indicated in Section 10.3, slimes material needs special consideration, especially with regards to

transfer of activity to food and the calculated doses in [1] may hence be very conservative and

should rather be re-assessed considering site-specific conditions. Monitoring point M20 relates

to a spill on a mine site and should be cleaned before entering the public domain. Rehabilitation



on the other two sites (MP1 and MP38) seems to be completed or is in progress. Other

sampling points with similar problems seem to be MP35 and to a lesser extent MP34, with

reported potential annual doses in the range 30 to 70 mSv. The contamination at MP34 and

MP35 again seems to be due to a slimes spill and the doses are regarded as conservative

needing a more detailed re-assessment. The monitoring points above should receive special

attention in a more detailed assessment.

For monitoring points MP10, MP11, MP30, MP32 and MP43, annual doses in the range 10 to

20 mSv are reported. At these and lower doses determinable stochastic health risks are more

related to prolonged chronic exposure periods of several years. At least those monitoring point

for which annual doses above 1 mSv were reported should also be re-assessed.

A rehabilitation plan is discussed in [5] as per a prioritisation scheme presented in [6]. This plan

should start as early as possible to reduce the risks, and should not wait for a detailed

assessment, which may require additional surveys or sampling over a more extended period.

REFERENCES

[1] NNR, Radiological Impacts of the Mining Activities to the Public in the

Wonderfonteinspruit Catchment Area, Report No. TR-RRD-07-0006, July 2007.

[2] NNR, Guideline on the Assessment of Radiation Hazards to Members of the Public

from mining and Minerals Processing Facilities. Licensing Guide LG-1032 (1997).

[3] IAEA, Generic Models for Use in Assessing the Impact of Discharges of Radioactive

Substances to the Environment, Safety Report Series No. 19, IAEA, Vienna, 2001.

[4] IAEA, Handbook of Parameter Values for the Prediction of Radionuclide Transfer in

Temperate Environments, International Atomic Energy Agency Technical Reports

Series, No. 364, IAEA, Vienna, 1994.

[5] M. van Veelen, K. Pema, D. Maree, Report on Site Visit and Recommended Actions,

ILISO Consulting (Pty) Ltd, First Draft, October 2008.

[6] Joint Coordinating Committee of the Department of Water Affairs and forestry and the

National Nuclear Regulator, Development of a map ranking sites with known

radioactive pollution in the Wonderfonteinspruit catchment according to the urgency

of required intervention.



WONDERFONTEIN CATCHMENT AREA –

FIELD INVESTIGATION ON AREAS OF

INTERVENTION

Compiled by:

Mogwera Khoathane (Pr.Sci.Nat)

Radiation Protection Specialist

Zimkile Consulting T/A

Level 5 Radiation Protection Specialists

PO Box 90775

Garsfontein, 0042

Tel: +27 12 811 2986 Fax: +27 86 672 2245

Mob: +27 72 239 3082

[email protected]

www.level5rps.co.za



1. INTRODUCTION

Water is one of the principal pathways by which contamination may be dispersed into the

environment from mining and milling operations. Mining, be it open-pit or underground

mining, almost always requires, owing to the presence of groundwater, the dewatering of

the zone to be mined. A variety of processes may render these waters contaminated.

Contaminated water may also occur as a consequence of surface water runoff from, and

seepage through, waste rock piles and ore stockpiles, and is expelled from tailings during

their settling process. The radioactivity of this water is generally derived from uranium,

thorium, radium and lead, either dissolved or attached to suspended particles.

Where pyrite and other sulfidic minerals are present, acid may be generated during their

oxidation. Acid generation, also known as acid mine drainage (AMD) or acid rock

drainage (ARD), is a concern in all types of mining. The acid dissolves and increases the

mobility of heavy metals and metalloids such as manganese, iron, nickel, zinc, cadmium,

arsenic, or selenium. It could also mobilises the radionuclides present in uranium ores.

2. OBJECTIVES OF REMEDIAL ACTIVITIES

• Remedial measures shall do more good than harm & shall provide optimised arrangements for protection.

• The goal of remediation activities is the timely and progressive reduction of hazard to � Reduce the doses to individuals or groups of individuals being exposed, � Avert doses to individuals or groups of individuals that are likely to arise in

future, and to � Prevent or reduce environmental impacts from radionuclides present in

contaminated area.

3. SCOPE

This report provides the description of each area of intervention visited during the period 2-5

September 2008. The background of each site and nature of contamination is discussed, while

proposing remedial action per area of intervention.

4. RADIATION PROTECTION LEGISLATIVE FRAMEWORK

Development of cleanup goals is based primarily on the regulatory authority applied and

the risk assessment used. Regulations governing radioactively contaminated sites are

rather complex and somewhat confusing due to involvement of overlapping authorities.

In undertaking remediation action, it is necessary to understand the regulatory framework

that drives the radiological remedial action. This section summarizes the various



regulatory standards and requirements that dictate cleanup at radioactively contaminated

sites.

4.1 GOVERNMENT NOTICE R.388, PROMULGATED IN TERMS OF SECTION 36 OF THE NNR ACT, ACT

47 OF 1999

In terms of the provisions of section 2 (2) (b) of the NNR Act, the Act does not apply where

the level of radioactivity concentration of each radionuclide in materials is below 0.5 Bq per

gram for naturally occurring radioactive nuclides of uranium and thorium and their progeny

except for radon.

4.2 NNR GUIDELINE: A GUIDELINE DOCUMENT FOR THE RELEASE OF CONTAMINATED SITES FROM

REGULATORY CONTROL

Section 6 of the above mentioned guidelines refers:

“6. RELEASE CRITERIA

Contaminated sites may either be released conditionally (restricted use) or unconditionally (unrestricted use): 6.1 Unrestricted Release of Land and Water

It is required that sites used in the conduct of authorised activities may be released for unrestricted use provided that it is demonstrated that radioactive contamination, which can reasonably be attributed to the regulated activity, have been removed from the site. Compliance with this requirement can be achieved by demonstrating that the activity concentration levels are below those on the Background Reference Site.

6.2 Restricted Release of Contaminated Land and Water

In the event that removal of radioactive contamination and radioactive materials, which can reasonably be attributed to the regulated activity, is not feasible, then release for use is allowed subject to any restrictions specified by the Regulator provided that the following can be demonstrated:

(i) Compliance with an annual effective dose limit, applicable to the average member of the critical group from residual contamination for all feasible future situations. The limit must be approved by the Regulator on a case-by-case basis and must provide sufficient assurance that the site-specific limit that was applicable during operations, will not be exceeded.

(ii) Remedial measures have been taken to achieve an optimal level

of safety, that is, cleaning to levels equivalent to that of exclusion. Under these circumstances the regulator may choose not to put any restrictions.”



5. SITE VISIT – OBSERVATIONS

The following recommendations comprise suggestions regarding immediate measures (0-12

months), Short-term (2-5 years), medium-term (6-10 years), long-term (>10 years) aiming at

reduction of radiological impacts of mining activities.

Tudor dam (DRD Mine)

Location

South side, about 50 m distance to wall and bank.

Status

• Tudor Dam includes soils and sediments at the site potentially contaminated with radionuclides. The site had been excavated as part of the process of being mined by a company called Mintails.

• The dam is a previous return water dam, and during the inspection there was no inflow or outflow of water. The officials from Harmony Mine confirmed that there was flow of water during rainy seasons.

Proposed recommendations on remedial actions

• The site is currently being cleaned up by the Mintails. There must be follow-up inspection by the NNR & the DWAF to confirm if cleanup is carried out as per the licence requirements.

• Independent sampling should also be conducted by the regulators since post-remedial sampling must ensure that the dose from all residual radionuclides will not exceed 1 mSv/a taking into account institutional control for the specified land use.

Action category

• Cleanup must be completed immediately.

MP2 – sediments

Location

Stream bottom 150m downstream of Tudor Dam.

Status

• This is downstream to Tudor dam. The material observed on this site has a squishy appearance and seem to be fines of mineral deposits

Proposed recommendations on remedial actions

• This site must be cleaned up as part of the current Tudor dam cleanup operation.

• It would be advisable to carry out the clean up before the rainy season starts.



• The Regulators must ensure that this requirement is incorporated in the current clean up plan of Tudor Dam.

Action category

• Clean immediately.

MP46 – Lancaster Dam

Location

Former wetland downstream of Lancaster Dam

Status

• Slimes footprint is left on the site, the pictures taken on site illustrates the effects of acid mine drainage at the Lancaster Dam. The main culprits for this action are metal sulfides such as iron disulfide, also known as pyrite or fools gold. Acid mine drainage does not require a special process to become toxic to the waterways. The lethal effect results from the reaction of pyrite to oxygen and water cause a lowering of pH due to the formation of acid. Also, there is a precipitant that blocks out the sunlight, restricting plant growth and virtually upsetting the balance of many waterways. The effects are sometimes devastating to the plants and animals in the environment surrounding the mine.

• The river passes nearby the Lancaster Dam, with visible seepage of loose slimes from the Lancaster Dam into the river connected to the upper Wonderfonteinspruit Catchment Area (WCA).

• Many natural erosion processes can lead to the release of radioactive and non-radioactive contaminants to the environment. Principal among these are water and wind erosion, which typically most seriously affect above ground waste piles. Surface water erosion is the most likely mechanism for the degradation of unstabilised waste piles over the long term. Surface water bodies adjacent to impoundments can cause erosion by overflowing or meandering into the impoundments. Runoff water that contacts waste may become contaminated.

Proposed recommendations on remedial actions:

• The site must be cleaned as part of the NNR and DWAF enforcement regime.

• A programme for the cleanup must be submitted to the regulators (NNR & DWAF) by the responsible mine as a matter or urgency.

• The cleanup of the area must involve the removal of the slime material and surveillance programme that will ensure that slimes material are removed and

the specific activity of the soil is below 0.5 Bq/g and the dose to the member of the

public does not exceed 1 mSv/a.

Action category




MP3

Location

Upstream wetland Kagiso near Kagiso ext 8 turnoff

Status

• Wetland area.

Proposed recommendations on remedial action

• Wetland rehabilitation must be considered as part of the long term plan.

• The rehabilitation programme must consider the implications of re-engineering the entire wetland in the area. This should determine if the rehabilitation will cause more degradation or not.

Action category

• High priority – long term.

MP4

Location

Downstream wetland near Kagiso (at bridge of road Azaadville – Kagiso)

Status

• Wetland passing next to Kagiso


• Same as MP3.

Action category


MP5

Location

Private garden next to Kagiso near MP4.

Status

• Part of MP4

• Low levels of radioactivity reported in the Brenk report




No action required, the soil specific activity levels are below the NNR exclusion level of 0.5

Bq/g.

Action category

• Do nothing.

MP47 (HGM)

Location

Abandoned dam in Rietvalei (SE of Randfontein)

Status

• No inflow or outflow of water.

• Some slimes footprint left on site and at the time of the inspection stagnant water was observed and there was a TLB moving the soil preparing the site for mining.

• From the information given by mine personnel, it was noted that paddocks had been built to prevent inflow of water into the area.


• The site must be cleaned by the responsible mine as part of the NNR and DWAF licence requirements.

• A programme for the cleanup must be submitted to the regulators (NNR & DWAF) by the responsible mine as a matter or urgency.

Action category


MP10

Location

Small dam of van Greuning’s farm near R599.

Status

• Seepage from slimes dam – 10%

• Sewerage water – 90%

• 17Ml/day discharged from sewerage plant.


• Detailed characterisation must be done to quantify the extend of the problem and plan of action.

MP11

Location

Mine water pipe from Randfontein Estate GM at van Greuning’s farm.



Status

• Stopped, pipe has been removed by the mine.

• Was previously used as water supply for farmers.


• The responsible mine must present plan of action.

Action category

• Uncertain.

MP12

Location

Donaldson Bridge on road R599

Status

• Used for irrigation purposes by the nearby Village.

• Flows into a wetland.


• Alternate water supply must be made available to the nearby village for irrigation purposes.

• Wetland rehabilitation must be considered as part of the long term plan.

• The rehabilitation programme must consider the implications of re-engineering the entire wetland in the area. This should determine if the rehabilitation will cause more degradation or not.

Action category


MP13 & 14 – Donaldson dam

Donaldson Dam northern part, fishing station and southern part, caravan station (at the wall)

Status

• Litter blocks the pipeline inlet, and this causes overflow of water into the natural stream instead of the water going via the 1 meter pipeline.

• Water seeps into sink holes (in the natural stream) and the mines then pump the water out.

• Active controls in place.


• The responsible mine must ensure that current restrictions on the use of the water are maintained.



• The responsible mine must be required to ensure unobstructed flow of water into the inlet of the 1 m pipeline.

MP23

Location

Canal from West-Driefontein Gold Mine

Status

• Canal from number 10 and 8 shafts of Goldfields (West-Driefontein).

• The water goes into the settling ponds – 16 ponds

• The ponds are cleaned every 3-4 years.

• Physical security is in place at the settling ponds, thus access restricted.


• The settling ponds are currently managed as part of Goldfields operation.

• As part of ongoing compliance to DWAF and NNR requirements, the mine must submit results of ongoing monitoring done at these ponds.

Action category

• Do nothing – site managed as part of the operation.

MP26

Location

Canal from West-Driefontein GM.

Status

• Canal from the mine, downstream of settling ponds.

• During the inspection people from nearby village were found using water for laundry purposes.


• The nearby community must be informed immediately about the associated radiological risks of the canal water.

Action category

• Do nothing – site managed as part of the operation.

• Public awareness on the potential risks of using the water must be done by the mine.

MP29 & 30 – Harris dam

Location

• Harris Dam, upstream

Status



• Inlet from the 1m pipeline.

• There were signs suggesting that cattle could have been drinking the water at this site.


• The dam should be cleaned.

Action category

• Short term

MP 34 & 35

Location

Water edge Bridge Plot 68 (Paul Matthee).

Status

• At the time of the inspection, the channel was dry.

• The channel is used for storm water that drains from Carletonville.

• The levels of radioactivity in water and sediments were found to be low as reported by BS Associates.


• The site must be monitored at the frequencies agreed by the regulators to confirm the low levels.

Action category

• Do nothing.

MP36 – Padda Dam

Location

Padda Dam (western bank)

Status

• Discharge of water from 1m pipe.

• Area was a previous recreational area, buildings now demolished.

• Wetland forms part of the water course.

• Fishing done on the other side of the dam (2-3 times a month).


• The radioactivity results obtained from BSA report are low for this site, however, the people fishing on the dam should be informed about the potential radiological risks.

Action category

• Immediately inform the people fishing on the potential radiological risks of the water.



MP37

Location

Furrow at Khutsong Bridge.

Status

• Specific activity results of the sediment sampled was below 0.5 Bq/g.


• Notification of the local community is in place, thus increasing public awareness to avoid involuntary dose uptake.

Action category

• Do nothing.

MP40

Location

• Blyvooruitzicht GM discharge point

Status

• Water discharging from Blyvooruitzicht GM into the Coetzee’s Dam


• Compliance must be enforced by DWAF and NNR as part of Blyvooruitzicht licence requirements.

MP44

Location

Wall Coetzee’s Dam.

Status

• Pipes used for irrigation have been taken out.

• Farmer stopped irrigation – only cattle farming.


• Short term monitoring plan to confirm the results, thereafter a plan of action should be put in place commensurate to the results obtained.

MP45

Location

Visser Dam (Southern bank)



Status

• Sediments exposed due to broken dam wall

• Water used for irrigation and drinking water for livestock


• Further sampling must be done to confirm the results, if limits are exceeded then current water use must be discontinued.

MP22

Location

Canal from Blyvooruitzicht GM

Status

• Observation suggested possibility of critical group in the area.


• Water use must be investigated in detail.

MP 18

Location

Runoff seepage collection pond at slimes dam north of Doornfontein.

Status

• At the time of the inspection, the paddock wall was found to be broken.

• The area could be encountering overflow problems during storm conditions


• As part of the operation, the mine must improve on toe paddocks management. MP21

Location

Dam NW from Elandsrand GM

Status

• Access not easy, physical security in place


• No immediate action.

MP 20

Location



Mine water from Doornfontein shaft and runoff water from slimes dam

Status

• Return water dam receiving water from the shafts and run off water from slimes


• Must be managed as part of the mine operation on return water dams. (Note: it is not clear as to why a sample was taken at this point since the return water

dam will by definition have high levels of radiation)

MP38 & 39

Location

Canal and bridge crossing R501 at Blyvooruitzicht GM

Status

• Slimes from the mine flowing across the road during the slime dam spillage operational incident.


• The slime spillage cleanup has since been addressed as part of the operations.

• A survey to assess the specific activity of the soil must be carried out immediately to determine if the levels were the spillage occurred are below 0.5 Bq/g.

6. WFCA – SUMMARY OF REMEDIATION OPTIONS

6.1 Active controls

Active controls involve some form of either, continuous or intermittent, human activity to

maintain the condition of the site, detecting any radiation exposure of the public or to the

environment, and cleaning up radiation leakage from the site caused either by intrusion or

natural processes. The controls include restriction of access to the site by physical

barriers, e.g fences, or by warning signs, restriction of land use.

6.2 Passive controls

Passive controls rely on engineering and management solutions that do not require human

intervention and that have the amount of redundancy of controls built into them. The

design has to take into account natural phenomena that can lead to failure, such as

erosion, and provide adequate margins of safety against their occurring.

6.3 Site inspections



The purposes of inspections are to confirm the integrity of visible natural and man made

feautures at the site, to identify changes or new conditions that may affect site integrity,

and to determine the need, if any, for maintenance or follow-up inspections and monitoring.

The inspector would have to evaluate the effectiveness of site-specific institutional controls

and ensure that the site remains in full compliance with regulations, guidance, or other

requirements.

7. SHORT, MEDIUM & LONG TERM MONITORING

The long half lives of uranium, radium and their daughter products may be a cause of long

term concern for communities, where the facilities are located. A inherent problem,

however, with long half lives of uranium is with the institutional controls, the major problem

being institutional memory, or the willingness and ability of the chosen institution to

continue managing a site over prolonged timespan measuring in, perhaps, centuries.

Assurance of continued funding can pose another serious problem. Consequently, the

ultimate objective should be to design closure and remediation solutions that would require

a minimum of active controls, both with respect to the duration and extent.

8. OTHER OBSTACLES TO BE CONSIDERED

One of the most important aspects to be considered in connection with wetland filters for

water treatment is rainfall. Remobilisation of radionuclides could happen after rainfall

events.

Care must be also be taken to manage the wetland filter during dry season. The system

needs to be kept moist to ensure that essential plants to not perish due to desiccation.

Also, if the sediments dry out, the resulting oxidation leads to extensive remobilisation of

previously adsorbed solutes, particularly the heavy metals that the system is designed for

to capture.

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