Western Utilities Corporation Proposed Mine Water Reclamation Project Comment and Response Report

June 2009

ENVIRONMENTAL IMPACT ASSESSMENT WESTERN UTILITIES CORPORATION MINE WATER RECLAMATION PROJECT

For public comment from

Tuesday, 9 June 2009 to Tuesday, 14 July 2009

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Golder Report Number: 12064-8755-1

EIA Ref. No. Gaut 002/09-10/N0095

Comments, Suggestions and Questions Raised Commentator Representing Date Source Response

AIR QUALITYWhat sort of emissions (volume and type) will the kiln produce, and will it be in keeping with air emission standards?

Mr Garth Barnes WESSA 01 May 2009 Letter Technical detail on the proposed plant infrastructure will be provided in the EIA report. An air quality specialist study forms part of the impact assessment.

Assess potential air pollution due to the treatment of the sludge on the tailings facility.

Mr Garth Barnes WESSA 20 May 2009 Key Stakeholder Workshop, Alberton

This aspect will be addressed in the Air Quality Impact Assessment which will form part of the EIA.

A coal-fired furnace will generate CO2, which will offset the benign effects of cleaning the water – more information is required.

Dr Richard Doyle Environmental and Remedial Technology Holdings (Pty) Ltd

13 May 2009 Comment Sheet The benefit of the project includes providing a self-sustaining solution to handling of excess water with in the mining compartments. It will have the water level in the Western mining compartment reduced to a level that is below the environmental critical level, and management of all three mining compartments at a level below ECL. Similarly, the secondary benefit of the project is that it removes significance salt load associated with the pretreated mine water, that is currently discharged down both the Blesbokspruit and Tweelopiespruit. The impact of coal burning associated with byproduct recovery will be evaluated through air quality specialist study.

Will mine dump dust be addressed through this project? Mr Frans Le Grange Exotic Properties 22 May 2009 Comment Sheet No. The proposed project looks at treatment of mine affected water only. Concerns regarding dust from mine dam should be addressed directly to the relevant mining companies.

The potential for cumulative air pollutant concentrations must be taken into account in assessing the risk to affected communities.

Ms Mariette Liefferink Federation for a Sustainable Environment

05 May 2009 Letter Technical detail on the proposed plant infrastructure will be provided in the EIA report. An air quality specialist study forms part of the impact assessment.

Dust pollution should be considered. Ms Lebo Molefe City of Johannesburg 07 May 2009 Comment Sheet An Air Quality Impact Assessment will be conducted as part of the EIA.

This project may potentially change the water pollution problem into an air pollution problem.

Prof Frans Waanders Northwest University 21 May 2009 Key Stakeholder Workshop, Randfontein

Technical detail on the proposed plant infrastructure will be provided in the EIA report. An air quality specialist study forms part of the impact assessment.

Can methane be released in gold mines, as in coal mines? Mr Peter Withinshaw City of Johannesburg 08 May 2009 Meeting with City of Johannesburg

It is not common; however, there are cases of carbon monoxide being released underground.

ALTERNATIVESWhy can the mine water not be treated and distributed locally, at the starting point of the proposed pipeline in the Eastern Basin?

Mr Jurgen Theiss Scaw Metals Group 15 April 2009 Pre-consultation meeting

There is a certain economy of scale necessary for the project to be financially viable. Establishing multiple smaller plants within each basin significantly increases the project cost. In addition, the treated water needs to be distributed to an existing bulk water supplier and their infrastructure.

ALTERNATIVES (BULK WATER STORAGE FACILITY)The Klipriviersberg area is a very sensitive area. Why was the decision taken to pump to that area, and what alternatives have been considered?

Mr Andrew Barker Andrew Barker Development Consultant

19 May 2009 Key Stakeholder Workshop, Brakpan

The preferred end user is Rand Water. The use of an existing Rand Water reservoir is the preferred option.The alternative Rand Water reservoirs considered include the Germiston Reservoir and the Klipriviersberg Reservoir. The Klipriviersberg Reservoir is the preferred option as it has sufficient capacity for storing the treated water. Refer to the Consideration of Alternatives Report for details.

From the Background Information Document, it is clear that alternative reservoirs for the bulk storage of treated water have been considered. What will be the drive to use another reservoir and not the Klipriviersberg Reservoir?


The Klipriviersberg reservoir is the favoured reservoir. It is significantly further from the proposed treatment plant site than the Germiston Reservoir, but has 10 times the capacity of the Germiston Reservoir. Consideration has been given to change the alignment of the pipeline approaching the Klipriviersberg Reservoir. The proposed revised alignment sees the pipeline running with in the road reserve to the north of the rocky ridge and approaching the reservoir immediately adjacent to the existing Rand Water board pipeline.

Comments Response ReportDraft Scoping Repot 1 of 48 17/06/2009

Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseALTERNATIVES (END USER)

Have technical and financial feasible alternatives been considered in terms of end users?


21 May 2009 Key Stakeholder Workshop, Randfontein

Alternative end users have been considered, including Johannesburg Water and Ekurhuleni Metropolitan Municipality. See the Consideration of Alternatives Report.

ALTERATIVES (NO-GO)What type of ‘disaster’ is envisaged in terms of human health and ecological risk if the proposed project is not put in place?

Ms Samantha Boshoff Water Quality Planning, Department of Water Affairs


Should the water levels in the Central Basin be allowed to continue to rise (i.e. no pumping takes place), the ECL will be reached by October 2012 (resulting in contamination of groundwater/borehole water). Mine affected water will decant (surface) by January 2013.

As required in terms of legislation, alternatives need to be proposed and evaluated. Two important options are the no-go option and the option where the process if technically viable but not financially sustainable.

Dr Henk Coetzee Council for Geoscience

23 April 2009 Comment Sheet Assessment of alternatives has, and will continue to be undertaken, as part of the EIA. Comment noted with thanks.

If the WUC project does not go ahead, the mines will need to dewater to prevent the flooding of mine reserves.

Mr Mike Sullivan Central Rand Gold 26 March 2009 Authority Steering Committee Meeting

CRG currently wishes to install a pump station in the SWV Shaft at ERPM (in the Central Basin) in order to dewater to prevent the flooding of mine reserves. As part of the proposed project, no dewatering activities are proposed. Underground water levels in the Western Basin will be lowered to below ECL and maintained. In the Eastern Basin, current underground water levels will be maintained, and water levels in the Central Basin will be maintained below the mineral reserves CRG wishes to mine. Responsibility for managing the water level with in the dolomitic compartments will remain with the mining industry. WUC proposes a self-sustaining solution to utilise this water brought to surface.

ALTERNATIVES (PROJECT)Similar projects should be established for each and every basin - a number of small strategically placed plants - that in the event of failure of the Central Plant, can continue.

Mr Eugene Viljoen Resident, Noordheuwel

22 May 2009 E-mail This alternative has been investigated by WUC. A centralised Plant is the preferred option, mainly from a scale, practical implementation, financial and distribution of potable water perspective - See the Consideration of Alternatives Report for details.

ALTERNATIVES (TREATMENT TECHNOLOGY)Maybe all alternatives to treat AMD have not been taken into account for this project.



Thank you. We reiterate however that only issues addressed directly to the EIA team will be taken up in the process. No consideration will be given to issues not addressed to the EIA team by a register stakeholder. Prof Leslie Stoch has been contacted by the public participation office and he has confirmed that he does not want to participate in the current project.

All alternative technologies, including WESU electrolytic technology, have not been investigated to treat AMD, and have not been taken into consideration for this project. By using the electrolytic technology we propose, gland, cooling and AMD water can be used in the mines, instead of potable water. It is a renowned and proven technology, and we have sold more than 2000 systems worldwide. We are the only company worldwide offering this technology.

Mr Niels Von Ekesparre Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder Workshop, Brakpan

Western Utilities Corporation has the right to evaluate technology and select technology at their discretion. This does not preclude any other parties from pursuing similar ventures.

With the electrolytic technology we propose to reduce AMD by removing the iron, manganese, etc. from the water.


Thank you for this general comment


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseA Bentonite treatment process would be better than a Barium treatment process, for the following reasons: "It is tried and tested and it works on a very large scale, able to treat much more than the volume of water that presently issues from the Tweelopiesspruit decant. Its only limitation is the one of gypsum. Gypsum occurs globally and is not a toxic hazard and it is no real limitation. Sufficient quantities of top adsorbtion quality bentonite clay are now available from Bentonite at well below the market price." (From: A COMPARISON BETWEEN SOME METHODS, CURRENTLY PROPOSED FOR USEIN THE REHABILITATION OF ACIDIC MINE DRAINAGE (AMD)- Prof Frans Waanders) (Full report available)

Prof Frans Waanders Clear Water Effluent and Pollution Control

20 May 2009 E-mail Various treatment technologies have been considered by WUC for the proposed project. The CSIR's ABC process and the SAVMIN process were chosen to be thoroughly investigated during Pilot Plant studies. Subsequently, the ABC process proved to be the most self-sustainable treatment technology, specifically in terms of by-product recovery. Refer to the Consideration of Alternatives Report.

Our technology has not been given any consideration – and we can do a lot to alleviate the problem of AMD, whether as an alternative or complementary to the WUC solution. (The one technology that WUC said they tested is “Electro Dialysis” which is far from our technology and may be very costly.)

Mr Zwi Wagner Water Engineering Systems Unlimited

21 May 2009 E-mail Western Utilities Corporation has the right to evaluate technology and select technology at their discretion. This does not preclude any other parties from pursuing similar ventures. Should you wish to discuss your technology with WUC, please contact their team directly.

BY-PRODUCTSHow much sulphuric acid production will take place and how will it be transported (Rio Rita Tankers)? What will happen to waste sulphur?


18 April 2009 Comment Sheet Elemental sulphur is a by-product of the water treatment process and will be sold. The sulphur will be transported by road or railway.

What will happen to the valuable minerals present in the water - who will benefit if they can be extracted?

Prof Frans Waanders North West University

23 April 2009 E-mail Barium carbonate, calcium carbonate, calcium oxide (lime) and elemental sulphur will be recovered for re-use or for sale as commercial by-products of the process. These represent a combination of minerals with in the water and recovery of chemicals used in the water treatment process.

ECOLOGYWhat are the consequences of decanting AMD for the Ramsar site (Marievale)?

Mr Mike Oberholzer Department of Minerals and Energy

26 March 2009 Authority Steering Committee Meeting

Currently no AMD decants into the Blesbokspruit at Grootvlei Gold Mine. Water is neutralised prior to discharge at the Grootvlei Gold Mine. authorisation. If untreated AMD entered the Blesbokspruit system in significant volumes it would have a negative effect on the Blesbokspruit. This is a regional issue that will not be addressed in any detail in the current EIA. The proposed project seeks to avert this possibility.

END USERThe financial sustainability of the proposed project relies on the off-take agreement being assured with Rand Water. Is this agreement assured, and does the Department of Water Affairs approve?



The off-take agreement is still being negotiated with Rand Water. The Department of Water Affairs is fully aware of the progress of the proposed project, as the directive for the project came from this Department.

Rand Water has received an RoD and WUL that covers Klipriviersberg Reservoir.

Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of Johannesburg

Noted. Thank you.

Are the 117 000 people quoted in the presentation that do not have access to drinking water the number of people in Ekurhuleni specifically, or are these people a niche market WUC identified that they can cover?

Mr Michael Oberholzer Chief Director: Mineral Regulation, Department of Minerals and Energy


These are people with in the municipal framework in general.

All issues of concern to Rand Water Services have been factored in. Dr Bethuel Sehlapelo Rand Water 04 May 2009 Comment Sheet Comment noted, thank you.

Has an agreement with Rand Water been signed? Ms Elize Tempelhoff Beeld, Media 24 21 May 2009 Key Stakeholder Workshop, Randfontein

A draft memorandum of understanding is being negotiated.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseTreated water can be added to the local grids on the West Rand, the price of which should be subsidised by the Municipalities or the Gauteng Government directly. After all, they are allowing unprecedented and unplanned development and the influx of people. Rand Water and the Department of Water and Environmental Affairs must come to table. Their negligence in this matter also stands out like a sore thumb.


22 May 2009 E-mail WUC is in the process of compiling a feasibility study that includes refinement of the project financial model. This information is, understandably, of a confidential nature. Should stakeholders require site of components of this study arrangements for this can be made subject to signing of the necessary confidentiality agreements

About 18% of the Rand Water supply is grey water. Has WUC allowed for that in the proposed scheme?



WUC proposes to treat mine affected water. The composition of Rand water supply is not a matter for the attention of WUC

Why can treated AMD not be used only for industrial purposes, and eliminate potable water from being used for mining purposes?


Mine affected water is commonly reused within the mining industry. There is a limited number of water intensive industries in proximity to the proposed project.

ENERGYHas gas been considered as source of energy for the thermal process?

Mr Smuts Marais Water Quality Manager, Ekurhuleni Metro

20 May 2009 Key Stakeholder Workshop, Alberton

Yes, but was not favoured.

What are the power requirements for the project, i.e. at the Water Treatment Plant?

Mr Basie Maree Mintails 26 March 2009 Authority Steering Committee Meeting

The power requirement for the operation of the Water Treatment Plant is 6 MW. 40 MW is currently available via existing mining infrastructure at, or close to, the proposed Water Treatment Plant Site. The water treatment process itself will also generate a small amount of energy.

GEOHYDROLOGYAt the workshop, the point was raised that there will be an inflow and outflow of water. Will there be a general report on the potential impact that this may have on foundations of buildings on properties or will a specialist report be prepared? The answer at the workshop was that there will be a general report, as I understand, because WUC is under pressure to finalise this EIA to start with construction end of this year. What is the potential impact on the foundations of landowners? How can one do this and finalise this EIA, without a specialist report? I am representing a property owner, and it must be recorded that we are of the view that a specialist report is required. We record that we reserve all our rights.

Adv Riaan Jonker Newmarket Property Development JV

21 May 2009 E-mail The proposed project does not seek to dewater the compartments, only to provide a self-sustaining solution to sustained management of water level within the mining compartments below the environmental critical level (ECL). Thus, the proposed project will not change the stability risk in undermined areas. Concerns regarding such stability issues should also be addressed directly to the holders of the relevant mining rights. WUC is not a mining company and has no responsibility for undermined areas. In the contextof the distribution pipeline, shallow geotechnical studies will inform final design of the pipeline. These studies are typically done after completion of the EIA as part of the final engineering programme.

Will there be a specialist geotechnical report generated as part of the EIA? Will potential impacts on the properties associated with the proposed project be addressed?



These aspects (primary and secondary impacts) will be addressed as part of the EIA.

In the Central Basin, how would the mine affected water be transported to the Water Treatment Plant site if the sub-compartments are no longer connected?

Mr Peter Kelly Department of Minerals and Energy


From a number of shafts accessing the Central Basin. Murray and Roberts Cementation is in the process of evaluating reinstalling pumping capacity within the basin.

Seismic activity may occur if the project doesn’t proceed. Mr Peter Kelly Department of Minerals and Energy


Thank you for this comment

Geotechnical studies should include the implications of the project. Ms Lebo Molefe City of Johannesburg 07 May 2009 Comment Sheet The proposed project does not seek to dewater the compartments, only to provide a self-sustaining solution to sustained management of water level with in the mining compartments below the environmental critical level (ECL).

Detailed information on the relationship and implications of pumping out the water on surface water is required.

Ms Lebo Molefe City of Johannesburg 07 May 2009 Comment Sheet The proposed project provides a mechanism to manage water level within the mining compartments at a level that is below ECL. This will prevent contamination of shallow groundwater resources through contact with mine water from the underlying mining compartments. Risk to the environment through accidental release from pipelines will be addressed as part of the impact assessment


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseDolomites are a major problem in the Mogale City Local Municipality’s area. Will the removal of water from underground not leave cavities underground and therefore lead to the formation of sinkholes in the area?

Mr Daniel Motaung Gauteng Department of Agriculture, Conservation and Environment

14 May 2009 Meeting with the GDACE

The removal of water is aimed at preventing water from decanting. Western Utilities Corporation will not remove water to a level that will lead to dolomites collapsing and thereby developing sinkholes.

The GDACE requests geotechnical reports of all the areas where water will be pumped.



At this stage no new pumping is proposed. The proposed project will take water that has already been lifted to surface by the mines under current permit.

Why are no geotechnical or geohydrological specialist studies included in the impact assessment?

Mr Koogan Naidoo Mogale City Local Municipality


Geohydrological and other studies have been done and are continuously being done. Information will be consolidated from the many studies already done and specialists will determine what the impacts of the proposed project will be on the baseline information already collated.

Any information on the old mining areas should be obtained from the government mining engineers office in Johannesburg.

Mr Sidney Osborne Resident, Springs 21 April 2009 Facsimile Noted, thank you

As far as I can remember the water from the mining operations adjacent to the Paul Kruger Highway in Springs flowed towards the old Sallies Mine (SA Lands). This area has long been closed and the shaft flooded.

Mr Sidney Osborne Resident, Springs 21 April 2009 Facsimile Thank you for this information

Why are there no geotechnical and geological studies included in the specialist studies?

Mr Sidney Osborne Greater Independent Residents Association


A geo-hydrological study has been done.

What will happen if sinkholes develop? Mr Sidney Osborne Greater Independent Residents Association


The project does not seek to draw down water levels, only to provide a solution to sustained management of water at a level that is below the environmental critical level (ECL) with in the three mining compartments. Consequent the, the project should not change sinkhole risk within any of the basins.

What will happen if the proposed system collapses and the area floods?



Should the proposed project not go ahead, the basins will continue to fill with water as has happened in the Western Basin where decant takes place. In the absence of intervention, decant from the Central Basin is projected for 2011 at the current rate of water level rise.

The West Rand Basin already has ground subsidence. Water removal will cause more subsidence.

Mrs Barbara Rush Landowner, Krugersdorp

06 May 2009 Comment Sheet The project does not seek to draw down water levels, only to provide a solution to sustained management of water at a level that is below the environmental critical level (ECL) with in the three mining compartments. Consequent the, the project should not change sinkhole risk within any of the basins.

We warned about earth movements, due to pumping of water. This resulted in damage to property - cracks in walls and foundations.

Mr Shan Rush Rush Enterprises, Krugersdorp

06 May 2009 Comment Sheet The proposed project does not seek to dewater the compartments, only to provide a self-sustaining solution to sustained management of water level with in the mining compartments below the environmental critical level (ECL)

Erosion due to acidic water will lead to considerably more sinkholes forming in these dolomites than was the case when they were drained due to mining activities in earlier years.

Mr John Smit Mine Managers Association of SA

24 April 2009 E-mail These issues are inherent to the gold mining industry. They are not specific to the project. The proposed project provides a solution to manage excess water within the circuit and enable the water level with in the dolomitic compartments to be managed at a controlled level so that it does not make contact with, and contaminate, shallow groundwater resources that overlie these compartments.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseWe do not have complete and sufficient profiles of Geo- science detail in respect of the interrelationship between the various Karst compartments, permeability’s, stresses, both natural and the various fault rock reaction to both chemical exposure such as AMD, and unnatural caused by mining itself. What is needed is a complete database, incorporating all the sciences to at least form a reasonably accurate survey of the interactions within all the Karst areas in the vicinity of our out of control developments in these watersheds. Massive amounts of backfill, both rock and slimes, was dumped in the workings under the Karst system; some compartments still carrying water reserves which first fill and then decant later. Going through many papers (titles provided), I have not come across an entire underground profile of Wonderfontein or Tweelopiesspruit flow with the Karst areas, or for that matter below the Karst. The opinions expressed (by specialists) are mostly academic educated guesswork, based on limited information in their fields, defining in set protocols. Apparently, Mandelbrots Fractional Chaos findings (ask the Weather bureau for detail) is still new to them; as with Lovelocks Gaia Principal and Konrad Lorenz` works. South Africa, with all the hype and damage in respect of sustainable development, is only listed 93rd out of 146 countries. Even Ghana (49), Congo (39) and the Ivory Coast (88) is lower (thus higher) on the totem pole than we are (2005 figures). (Built Mag. June 2005) (Comments shortened. Full text available. )


14 May 2009 E-mail This comment appears to relate to the broader body of knowledge surrounding mining and mine water interactions within the dolomitic areas. The implications of the proposed project on mine water and mine water geochemistry, as it relates to prediction of water quality for treatment, will reflect in the groundwater and water chemistry specialist reports respectively.

If the mines, as I believe they have, done Sophisticated Geological 3D Seismic Surveys to create coherent models of the un-mined ground at depths below present operations, to attract investors to the West Rand Gold Mining operations, where is this information to substantiate your suggested programme?


22 May 2009 E-mail Thank you for this comment. It does not appear to have relevance to the proposed water treatment project.

Is only the ingress of water from the Karst aquifers caused by various factors, e.g. blasting cracks, seismic movements, Dyke /Fault penetration? From which aquifers does the present ingress come, as the rate of decant does not appear to be entirely related to rain and storm water penetration? We seem to disregard the normal plate tectonic movement of approx. 2 cm per annum and input from a lot of other disciplines. I suggest your researchers have a look at “problems” of water ingress through the roofs on tunnels and stopes.


22 May 2009 E-mail The proposed project does not seek to research water movement / ingress within the mining basins. The project is based on feasibility study centred around treatment. Water volumes available for treatment will be confirmed through consolidation of mine water management records supported by information from available studies within the region. These outputs will reflect in the groundwater, water chemistry and hydrology specialist studies.

A photo evidence of underground rainstorms, that is besides the dust repression programmes, is certainly different from the technical information disseminated to the Public.


22 May 2009 E-mail The proposed project does not seek to research water movement / ingress within the mining basins. The project is based on feasibility study centred around treatment. Water volumes available for treatment will be confirmed through consolidation of mine water management records supported by information from available studies within the region. These outputs will reflect in the groundwater, water chemistry and hydrology specialist studies.

The seismic disturbance or sinkhole formation in progress in the Helderblom area, shown by surface fractures also spells trouble. Are all these included in your plans?


22 May 2009 E-mail The proposed project does not seek to dewater the compartments, only to provide a self-sustaining solution to sustained management of water level with in the mining compartments below the environmental critical level (ECL)


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseA lot of work has been in the study area regarding geotechnical aspects. This is not only a multi-disciplined project, but is also geographically complex, and involves many stakeholders. WUC would need to ensure that all stakeholders, i.e. the mines, are on board and that the potential hazards / risks associated with the project are quantified and mitigatory measures put in place. Contingency and back-up measures need to be in place for worse-case scenarios, e.g. sinkhole formation. Since the proposed project will be infinite, the City of Johannesburg needs to work hand in hand with WUC to develop a Disaster Management Plan. A Disaster Management Plan and risk profile is important and urgent.

Mr Peter Withinshaw City of Johannesburg 08 May 2009 Meeting with City of Johannesburg

Western Utility Corporation is proposing the project on behalf of the WBEC, CBEC and EBEC. These Environmental Corporations have been set up by affected mines with in the Western, Central and Eastern basins. The proposed project does not seek to dewatering any of the mining basins. It does, however provide a solution regarding how water brought to surface can be used for beneficial purpose rather than being discharged in pretreated or even untreated state back into the surface environment.

The City of Johannesburg’s geotechnical department has conducted a complete assessment on the Witwatersrand.


WUC and Golder would appreciate a copy of the relevant report.

Does the same geological and chemical characteristics apply throughout the study area?


This issue will be addressed in the groundwater quality and geochemistry specialist studies

GEOTECHNICALWill the project increase the risk of sinkhole formation in these areas? Will you be carrying out a risk assessment for this possibility?

Mr Garth Barnes WESSA 01 May 2009 Letter The proposed project does not seek to dewater the compartments, only to provide a self-sustaining solution to sustained management of water level with in the mining compartments below the environmental critical level (ECL).

Has the seismic activity been studied? If the studies were done – how accurate was the modelling?


The project does not seek to draw down water levels, only to provide a solution to sustained management of water at a level that is below the environmental critical level (ECL) with in the three mining compartments. Consequently, the project should not change sinkhole risk within any of the basins.

GEOTECHNICAL AND HYDROGEOLOGYThere are various options to address future decant. The water can be consumed to prevent discharge. There is a risk of de-watering the old underground mine workings, since structures could cave in. This will depend on the pumping infrastructure.

Mr Mike Oberholzer Department of Minerals and Energy


Comment noted with thanks. The proposed project does not seek to dewater the old workings, only to reduce the water level in the Western Basin to below ECL and then provide a self-sustaining mechanism to manage water at these levels.

GROUNDWATERWhile I recognise the critical importance of being concerned about the decant of water at surface, I also noted concern regarding the need to consider and protect strategic pumping positions and also provide for possible future access to mineral resources which could still exist in the areas which are to be allowed to flood in the future.

Mr Andrew Barker Andre Barker Development Consultant

20 May 2009 E-mail These are valuable points. The proposed project will not influence operational mines with in any of the basins. Water within the Central Basin will continue to be pumped by Central Rand Gold to allow their operations to continue. This water will be taken to surface at the Western Utility Corporation treatment plant.

In the estimated projections in terms of the surfacing of decant, have both the surface and underground sources been considered?



Yes, the projections are based on measured rate of water level rise in the compartments supplemented with pumping data from the mining companies.

Should one not attempt to protect existing valuable infrastructure that can still be used?



The proposed plug and pump system will allow Central Rand Gold to continue to operate without compromising mineable reserves or operational infrastructure. The existing mine water treatment infrastructure at ERPM South West Vertical Shaft will be used as an integral part of the proposed treatment plant.

What is the wealth still underground? Won’t it be an opportunity lost for Central Rand Gold if a plug system is inserted in the central basin?



The proposed plug and pump system will allow Central Rand Gold to continue to operate without compromising mineable reserves.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseWhat risk to groundwater does pumping of this water to surface have, if any?

Mr Garth Barnes WESSA 01 May 2009 Letter The proposed project provides a mechanism to manage water level within the mining compartments at a level that is below ECL. This will prevent contamination of shallow groundwater resources through contact with mine water from the underlying mining compartments. Risk to the environment through accidental release from pipelines will be addressed as part of the impact assessment.

With regards to the transfer of water from the Western Basin to the Central Basin, will the high uranium levels in the water in the Western Basin have an impact on the water quality in the Central Basin?


This question will be addressed in the groundwater and water quality specialist studies

Will water levels rise before the plug and pump station is implemented?


Timing is critical. The rate of water rise is measured regularly. Indications are that the plug and pump station can be installed in time.

Dewatering at Pamodzi won’t increase because of the proposed mine water reclamation project.

Mr Kimbton Chiota Pamodzi Gold East Rand


Thank you for this information.

At a technical level, I am concerned that the transfer of water from the Western to the Central Basin could have unforeseen consequences which will need to be properly addressed in the EIA study before this can be permitted.


23 April 2009 Comment Sheet The groundwater specialist investigation will evaluate the consequence of placing Western Basin water with in the Central Basin and management of water within the underground compartments

This project is overdue, there is serious contamination. Mr Willy Fuzani Umlambo Pride Bee Construction Projects

30 April 2009 Comment Sheet Thank you for this comment

Will water levels fall below ECL and the dolomite level if it is pumped from the Western to the Central Basin?

Mr David Hall Dura Soletanche Banchy


In the Western Basin, pumping will take place by the mines to drop water levels to below ECL, in order to prevent further decanting to surface.

Groundwater levels in the Central Basin are rising at a faster rate than normal. This is due to some of the underground sub-compartments becoming disconnected. If groundwater levels continue to rise at this rate, ECL will be reached by February 2011.

Mr Kevin Kruger DRD Gold 26 March 2009 Authority Steering Committee Meeting

Comment noted with thanks.

Central Rand Gold (CRG) will soon obtain an RoD for a new mine in the Central Basin. How will this project impact on the proposed mine?

Mr Freddie Letsoko City of Johannesburg 08 May 2009 Meeting with City of Johannesburg

CRG forms part of CBEC, the Central Basin Environmental Corporation, on whose behalf Western Utility Corporation proposes the current solution. CRG is currently investigating the re-establishment of a pump station in the Central Basin, in collaboration with Murray & Roberts Cementation, in order to prevent the flooding of the reserves proposed to be mined (600m below ground). A pump station will be established below 600m to keep the mine dry.

The ramifications of AMD for the sub-regions are enormous. In the Western Basin the greatest focus is the Cradle of Humankind World Heritage Site. Of no lesser concern, however, are the downstream landowners and agricultural activities that are largely or wholly dependent on groundwater for potable and economic use.


05 May 2009 Letter Thank you for this comment. The proposed project will provide a solution to enable management of water level within the mining compartments at a level below environmental critical level (ECL). The discharges to the surface decants points will then cease.

The decant or uncontrolled discharge of contaminated water or acid mine drainage (AMD) from the Western Basin mine void is a major environmental problem and intervention, namely a medium and long term technically viable and financially feasible treatment option, is urgently called for.


05 May 2009 Letter Thank you for this comment. The proposed project will provide a solution to enable management of water level within the mining compartments at a level below environmental critical level (ECL).

Radioactivity has become an area which required special attention because of a history of extreme secrecy and confidentiality on all nuclear issues.


05 May 2009 Letter A radiological specialist study forms part of the EIA


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseWhat are the potential impacts of the transfer of water from the Western Basin to the Central Basin?

Ms Nozipho Maduse City of Johannesburg 08 May 2009 Meeting with City of Johannesburg

This issue will be addressed in the groundwater specialist studies

The level at which pumping will occur must show that the Environmental Critical Level (ECL) has been carefully considered to ensure sustainability as well as prevent excessive pumping that may have detrimental impacts.

Mr Tshireletso Mataboge Department of Water and Environmental Affairs

28 May 2009 Letter The proposed project does not seek to dewater the compartments, only to provide a self-sustaining solution to sustained management of water level with in the mining compartments below the environmental critical level (ECL).The recommended ECL will reflect in the groundwater specialist reports

Why will water be taken out of the Central Basin to be treated? Ms Annemarie Maurizi Water Quality Manager, Ekurhuleni Metro


Excess mine affected water will be removed from the Central Basin in order to prevent water levels from reaching ECL and thus potentially contaminating surface and groundwater water resources.

Model the pollution plume and proposed mitigation measures and make the results known.

Ms Lebo Molefe City of Johannesburg 07 May 2009 Comment Sheet Impacted mine water in the mining compartment is a mining legacy issue. The current impact assessment addresses the surface infrastructure proposed to enable treatment and distribution of water for beneficial use.

The impact of the accumulation of water in mine shafts should be studied.

Ms Lebo Molefe City of Johannesburg 07 May 2009 Comment Sheet Impacted mine water in the mining compartment is a mining legacy issue. The current impact assessment addresses the surface infrastructure proposed to enable treatment and distribution of water for beneficial use.

The City of Johannesburg is considering to conduct groundwater assessment. Will the project influence this assessment?


The proposed project will enable groundwater levels with in the Western, Central and Eastern compartments to be managed below the environmental critical level.

What will the impact of the project on farmers in the Eastern Basin be?

Mr Daniel Motaung Gauteng Department of Agriculture Conservation and Environment


For the phase 1 project there will be no change from the current condition in terms of water management within the Eastern Basin. At surface, there will be a reduced discharge of pretreated water into the Blesbokspruit with the remainder of the water being brought to the central treatment plant for reclamation and reuse. Current understanding is that there is an excess of water in the Blesbokspruit. The proposed change will result in a reduction in salt load discharged to the Blesbokspruit.

How deep is the sub-surface water level? Mr Sidney Osborne Greater Independent Residents Association


The Western basin is decanting. Water level across the Central Basin varies but is below 600 m in depth in the eastern portion of the Central Basin. Central Rand Gold mine above this level. Similarly, water level in the Eastern Basin is managed to allow continuation of operational mining.

Are underground water levels currently being measured? Mr Seef Rademeyer Department of Water and Environmental Affairs


Water levels and ingress are measured on a regular basis.

There is a risk factor involved in terms of the uranium content in the water if water is to be pumped from the Western to the Central Basin. This needs to be considered and incorporated into the buffer zone area. Cooke shaft, for instance, has high uranium levels.

Ms Vicky Shaw WESSA 19 May 2009 Key Stakeholder Workshop, Brakpan

This issue will be addressed in the groundwater and water quality specialist studies.

If the water level in the Central Basin rises, there won’t be ‘space’ to pump water from the Western Basin. Is that correct?

Ms Elize Tempelhoff Beeld, Media 24 21 May 2009 Key Stakeholder Workshop, Randfontein

The consequence of introducing Western Basin water into the Central Basin, in terms of time to fill, will be addressed in the EIA and associated specialist studies.

Does water from the Eastern Basin drain into the Central Basin? Mr Aaron Tsoku Mogale City Local Municipality


The Eastern Basin and Central Basins are separated by geological structures and mine water does not move between these basins underground.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseDetails of the entire West Rand mines in terms of their historical and operational activities must be considered during the investigation. All water monitoring results, past and present, should form part of the investigation. Compare their Financial Prospectus with scientific details. Refer to the Manual on Mine Water Treatment and Management Practices in South Africa- 5 Volumes by W.Pulles, D.Howie, D. Otto, J. Easton, et al, WRC Report 527/5/96 done for the Chamber of Mines.


18 April 2009 Comment Sheet Historical water monitoring data (where available), mine plans (historical and current), results of previous geohydrological investigations undertaken, etc have all been used to inform the consolidated groundwater reports that inform the project feasibility study. Similarly, the operational water requirements of these mines has also been considered.

Some of the mines have been operational for 130 years. This has created a lot of dirt and tunnels, i.e. intricate underground conditions.


18 April 2009 Comment Sheet Wherever possible, historical information has been used to inform project planning.

Have the boreholes for water (potable supply) into the Karst been tested and where are the results? Do these boreholes penetrate or bottom near the stopes? And at what levels? A grid system of boreholes with above test results of entire surrounding areas are required, notably in terms of interconnecting stopes to other mines, including Doornkop operation.


18 April 2009 Comment Sheet Thank you for these comments which relate to the current situation. The proposed project provides a self-sustaining solution to utilise excess water allowing improvement and management control within the dolomitic basins.

What will happen to the water from such flooded stopes and how much is involved? If the radioactivity was neutralised by lime, why are the slimes still active?


18 April 2009 Comment Sheet Questions pertaining to mine water volumes available for treatment and the quality of available mine water will be addressed in the groundwater specialist studies.

Note the water volumes, ph, conductivity, pollution in 1994. How does this information compare with the latest tests?


18 April 2009 Comment Sheet Questions pertaining to mine water volumes available treatment and the quality of available mine water will be addressed in the groundwater specialist studies.

Bekkersdal and surrounding areas have vegetable farms under overhead irrigation with waters obtained from boreholes in and around Donaldson dam. Where are these vegetables marketed and were they tested for contamination?


18 April 2009 Comment Sheet Thank you for this comment. It does not relate to the proposed project and current EIA process.

The present ingress cannot necessarily be from surface water. The extensive housing and road development has caused flood conditions. Even if the Mega liter discharges from mine pumps is considered, the spread flow over the surface areas. Thus, unless direct openings exist, the speed of water alone would negate such a possibility Tweelopiesspruit is a prime example of direct opening. Also see the Klip River rehabilitation programmes. (It is not mentioned at the Scoping, EIA, EMP meetings that these tonnages of sludge exist underground and are not included in the figures fed to the Public. A document about AQUA TRACK is attached as means to establish the movement of underground water) (Comment shortened. Full text available.)


15 May 2009 E-mail Thank you for this general comment.

May I also suggest that you visit the farmers in the Leeuspruit area and view the skin lesions caused by bathing in their borehole water .


15 May 2009 E-mail Thank you. This comment is not relevant to the proposed project which deals with treatment of mine affected water.

The project appears to be a Robin Hood reverse osmosis process, robbing the West and East of Water, albeit contaminated, to save the Rich in Johannesburg. Resulting in thousands of people who live on the land being deprived of water, as we do not even know where all this water comes from and which of the reserves will be depleted.


22 May 2009 E-mail The proposed project is a chemical treatment process. Treated water will be delivered to the Rand water system, from which potable water is supplied throughout the proposed project area.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseIs it Archaean aquifer water found at lower levels than the present depth of the mines? If so, two things “spring” to mind: these waters cannot be replaced (the same problem as the Yanks have with Ogalala aquifer) and; secondly, the refilling of the old mines shafts will continue unabated with contaminated water until the source dries up. So will the contamination influence huge agricultural tracts of land?


22 May 2009 E-mail Yes, it is reasonable to expect that active management of water within old mine workings will be necessary until such time as water quality improves. This can not be expected to occur in the short-term (decades). Until such time, the water level in old mine workings will need to be controlled and the water that is pumped surface treated in order to prevent contamination of the surface aquifers.

What amazes me that this filthy water's influence on foodstuff has not yet created the outcry as in overseas countries, althoug it has manifested itself in various forms, conveniently ascribed to suit certain fractions of the establishment.



We are aware of the circumstances that arose, causing the Central Basin problem, but your approach to solve this problem, the presentation thereof to us after a visit overseas to obtain Capital Injection, for this crazy idea, smacks of historical association with the mining fraternity, who, to this day, rides rough shot over any opposition to their investors' interest. The cloak and dagger retention of information in respect of scientific research by mining groups, in all facets pertaining to the making and solving of this problem, must be placed on the table. You state that is has been done — prove it by supplying the draft information.


22 May 2009 E-mail Thank you for this comment. It appears to be a statement about the mining industry in general, without direct relevance to the proposed water treatment project.

How will the sediments that remain in all the tunnels and shafts and those Karst Acquifers ever be cleared if this project manages to remove the waters?


22 May 2009 E-mail The proposed project does not seek to dewater the compartments, only to provide a self-sustaining solution to sustained management of water level with in the mining compartments below the environmental critical level (ECL).

I strongly oppose this - this will create an even bigger problem in the future. The geology is not correct in some instances, which might create unexpected surprises if pumping commences to one central point. I have worked on the mines for a couple of years and know that many tunnels were dug that lead to nowhere just to get bonuses or "make the grade" as it was called. These tunnels can lead to ways of water escape from the "perfect" storage place.


23 April 2009 E-mail The groundwater specialist investigation will evaluate the consequence of placing Western Basin water with in the Central Basin and management of water within the underground compartments.

Why pump more polluted water to a possible area with less polluted water?


23 April 2009 E-mail The groundwater specialist investigation will evaluate the consequence of placing Western Basin water with in the Central Basin and management of water within the underground compartments

The current intention is to take clean pure water and mix it with water from a toxic origin.


17 May 2009 Comment Sheet No water will be introduced into the Rand water system that does not meet South African drinking water standards and Rand water requirements.

Would you be so kind and send us the following water analysis of the AMD in the Eastern Areas: Raw AMD as pumped from the mine underground; Treated AMD from the mine – before the WUC treatment.


21 May 2009 E-mail This information will reflect in the specialist studies and EIA report.

If water is carried from the Western to the Central Basin, is extra radio-activity carried into the water?

Mr Peter Wood WESSA 19 May 2009 Key Stakeholder Workshop, Brakpan

Uranium content in water in the Western Basin is indeed high. During the pretretament liming process, water will be treated to be below the required limits of uranium.

The risk of depleting the water table should be taken into account. Ms Hendrika Zwanziger WESSA 30 April 2009 Comment Sheet The project does not seek to draw down water levels, only to provide a solution to sustained management of water at a level that is below the environmental critical level (ECL) with in the three mining compartments


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseHERITAGE

In terms of Section 38 of the National Heritage Resource Act, No 25 of 1999 (NHRA), the SAHRA requires to be furnished with sufficient information to determine the possible impact on heritage resources in the area affected by the proposed development. We therefore request that a Heritage Impact study be undertaken as part of the EIA process. Your report should, among other things, indicate the presence of any improvements/structures on the property and also identify and map all heritage resources that might be impacted in the area affected by the proposed development.

Mr Tebogo Molokomme SAHRA 08 April 2009 Letter A Herritage Impact Assessment will be undertaken as part of the EIA process.

HYDROGEOLOGYI have been involved with this issue right form the beginning, i.e. since long before 1996. Remember that a significant percentage of the decanting water actually originates from the Vaal River, i.e. via Rand Water's system. In a study I carried out some years ago I concluded that a significant amount of water originating from Rand Water being discharged into all the small tributaries draining the Johannesburg area and forming part of the Klip River, enters the mine void through streambed leakage where these streams cross the Main, Bird and Kimberley Reefs. These reefs were mined using simple opencast mining techniques and they were simply backfilled using the waste removed from the pit. This backfilled material acts something like a French Drain in transporting water. If I remember correctly, we can prevent 32 Mℓ/day from entering the Central Rand mine void alone by constructing concrete channels across the areas where these streams cross the mined-out reefs. Remember, 120 years ago these tributaries of the Klip River were non-perennial and insignificant little streams. Today they are prennial, flowing around the year as a result of Rand Water being discharged (legally or otherwise) from the City on a continuous basis.

Mr Garfield Krige African Environmental Development

20 May 2009 E-mail Thank you for this information

Similar seepage occurs in the East Rand. For instance, a geological fault crosses right under the Cowles Dam immediately upstream from Grootvlei Mine. Then the wetland, formed by the discharged water, also passes over a section of dolomite and it is believed that a significant amount of water pumped from underground leaks right back into the mine void.


20 May 2009 E-mail Thank you for this information.

At present we have only one solution on the table, and that is the solution of treating the mine decant water. For some reason, we are ignoring the more obvious solution, i.e preventing the water from entering the mine void in the first place.The more water we prevent from entering the void, the less we will have to treat. Preventing water from entering the mine void will not increase the salt concentration of the water decanting, as it reaches an equilibrium at some stage in the mine void.


20 May 2009 E-mail WUC proposes to develop a treatment plant. That is the scope of the current EIA. WUC is not a land holder or mining rights holder. Initiatives at source are best pursued by such parties, or the State.

How long will it take the water to surface if there is no pumping in the Eastern Basin?

Mr Steve Walker Sappi Fine Paper, Springs


In the absence of pumping, approximately 3 years.

INTEGRATED REGULATORY PROCESSWhile I recognise and accept that this current process is limited to specific activities and components of the bigger project it was suggested that the strategic importance of the project as a whole be examined, addressed and included as a key component of the EIA. Not only would this provide additional strength to the motivation for the project, but it would also set the platform for future modules and phases, such as Project Hloekisa mentioned above.


20 May 2009 E-mail This is a valuable point. Context will be provided to the "Big picture" in the EIA


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseIt was noted that this project may not be considered as "mining" and that verification needs to be sought regarding the status of the main activities and land uses and whether appropriate land use authorisations need to be sought. Not only could this have implications in terms of the legality of the uses, but it could also have implications for the cost issues for the project in terms of the land values and municipal rating. Although I did not mention it at the workshop, due to the nature of the project and its importance and the need to work closely with the provincial and municipal authorities, you may wish to consider making submissions to the affected and appropriate municipalities and provincial authorities regarding the project which could be incorporated into their Integrated Development Plan (IDP) and relevant components such as the Spatial Development Framework.


20 May 2009 E-mail Thank you for these suggestions

A Strategic Environmental Assessment (SEA) study should be a higher priority, as it will also add as motivation for the project.



At a project level, an SEA will unfortunately not be done.

WUC is not a mine, and that will influence the land use authorisation that will be required for this project. This is especially important from a liability and costing point of view, including rate issues – mine houses pay much higher rates than industrial areas.



These issues form part of the ongoing feasibility process

Will change of land use apply? Mr Andrew Barker Andrew Barker Development Consultant


These issues form part of the ongoing feasibility process

The regulatory processes are challenging, considering the fact that not all decision making authorities attended this meeting.

Mr Marius Keet Department of Water and Environmental Affairs


The regulatory process will be pursued with each affected department individually. The purpose of the Authority Steering Committee meeting is to coordinate discussion and understanding related to the project and associated permitting processes.

It is our respectful opinion that the Western Utilities Corporation's proposed project will have to be dispensed with under the new legal regime, which include, but are not limited to: The Mineral and Petroleum Resources Development AmenDepartment of Minerals and Energynt Act, National Environmental Management (NEMA) AmenDepartment of Minerals and Energynt Bill and the Draft NEMA EIA regulations 2009. Difficulties can, however, be foreseen regarding the Western Utilities Corporation bringing its compliance to the Mineral and Petroleum Resources Development AmenDepartment of Minerals and Energynt Act in alignment with its compliance with the Draft NEMA EIA Regulations which have not been passed by Parliament. The Air Quality Act 39 of 2004.


05 May 2009 Letter The EIA will be submitted for authorisation under NEMA, and ascosiated amenDepartment of Minerals and Energynts. The affected mine EMP's will also need to be amended through separate process.

Central Rand Gold has commenced mining, albeit alleged trail mining, without a water use licence. The matter is currently under investigation by a task team appointed by the Regional Director of Water Affairs (Gauteng), Mr. Marius Keet. The fact that the applicant has been operating without the necessary NWA authorisation is in itself a disqualification from being granted the amenDepartment of Minerals and Energynt since no authorization must be granted to an applicant that is in non compliance with any part of the MPRDA.


05 May 2009 Letter Please address this comment directly to the mining house concerned. The comment does not relate to the project proposed by Western Utilities Corporation (WUC).

The Air Pollution Prevention Act (APPA) does not address the cumulative impacts of air pollution. The Air Quality Act is now applicable and will be put into effect by the West Rand District Municipality.



Thank you for this general comment.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseWill EIA documents be submitted to the new departments separately, as a result of the new dispensation?



EIA documents will be submitted under NEMA for authorisation. The department to receive these documents will be agreed with regulators.

Guidelines are not legally binding. However, I request that the former Department of Water Affairs and Forestry’s water guidelines be taken into consideration.




Kloof Mine is the only mine in the area that has issues with a water use licence. Will all mines now need to apply for water use licences? That will take a very long time.



The proponent will apply for an overarching integrated water use licence. Individual mine water use licences may need to be amended.

According to Section 21 of the National Water Act, 1998 (Act 36 of 1998) and Interated Water Use Licence should be lodged with this Department to authorise any water related activities that Western Utilities Corporation (Pty) Ltd (WUC) will undertake during the proposed project.


28 May 2009 Letter Noted. Thank you.

This Department requires the proof of contract agreements between WUC and the relevant mining houses to collect and treat mine water on their behalf.


28 May 2009 Letter Noted. Thank you

Formal correspondence should be sent to this Department, including inter alia: WUC's role and responsibility; the mining houses' responsibility and ownerships of liability.


28 May 2009 Letter This will be provided. Thank you

The applicant must ensure that the Integrated Waste Water Management Plans comply with the Department's Best Practice Guideline H3: Water Reuse and Reclamation of 2006 and must be submitted to this Department for approval.


28 May 2009 Letter Thank you for this advice.

Proof of approval / support by the responsible local authority should be provided to ensure alignment of the proposed project with the municipality's Integrated Development Plan.



All other relevant environmental legislation should, however, not be overlooked and should be adhered to.


28 May 2009 Letter Thank you. A comprehensive integrated regulatory process is being followed.

In terms of the Integrated Water Use Licence Application, the Department of Water and Environmental Affairs will only provide comments on the documents subsequent to the submission thereof to the Department. Only then will the Department indicate whether the specialist studies conducted for this multi-faceted process meet the requirements of the Department (or not).

Ms Deborah Mochlotodi Department of Water and Environmental Affairs



The role of the City of Johannesburg in the proposed project is that of a commenting authority and not a decision-making authority. The City of Johannesburg will submit formal written comments on the EIA documents, but cannot provide concession on the proposed fast-tracking of the EIA process. The NEMA does make provision to do so, and such concession needs to be sought from the GDACE.


Noted. Thank you.

All EIA documents should be submitted directly to Ms Lebo Molefe and not to the MMC.


Noted. Thank you.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseWhat is the Department of Minerals and Energy's involvement in the process, since a number of mines are involved in the project.


The Department of Minerals and Energy has had a number of discussions with the mining industry regarding finding a regional closure solution that enables shared liability around water to be addressed. A liability cost apportionment had been conducted, which clearly indicated which mines in the relevant basins are accountable. The State is accountable for the liabilities associated with abandoned mines in the basins.

All applications (e.g. IWULA, APPA, etc) need to be submitted to the City of Johannesburg for comments, including the EMP amenDepartment of Minerals and Energynts to be conducted by the mines. The proposed project will probably pick up the existing issues that people have with the mines. The urgency of the Integrated Regulatory Process would need to be stressed to all Authorities.


Noted. Thank you.

Draft documents for comment by the City of Johannesburg should be sent to Ms Molefe early in each comment period, since it needs internal circulation to many departments. Commenting on draft documents could speed up the process.


Thank you for this suggestion.

The same Public Participation Process can be adopted for both the EIA and the Water Use Authorisation Process.

Mr Molefe Morokane Department of Water and Environmental Affairs

24 April 2009 Comment Sheet Noted. Thank you.

All water uses must be identified. More importantly, to separate the EIA process from the Water Use Authorisation Process. These two process should be run parallel.


24 April 2009 Comment Sheet Noted. Thank you.

If WUC has properly applied for the different activities which will impact on water, GDACE will consider the application. However, the Department does not have jurisdiction over activities that are administered by other Departments.



Noted. Thank you for this comment.

The Scoping Report that will be submitted to the Department must clearly indicate that it is a draft. Any changes in subsequent reports must be clearly indicated so that officials can find these when assessing reports.



Thank you for this input. This will be done.

It is possible to treat the project as urgent based on the need and its benefits.



Thank you for this input. Western Utility Corporation would like to expedite the project in order to start operation before rising water levels in the different areas become a problem. In order to avoid mine water decanting, the project has to start operating before mid-2011.

It still has to be determined whether waste generated during the project will be regulated under the National Environment Management Act or the Environment Conservation Act.



Thank you for this contribution. In addressing the issue of waste management through the feasibility study further interaction with the department will take place.

You are requested to closely liaise with this Department. In order for this department to provide an informed input, relevant documentation regarding the proposed development must be forwarded to this office for review and comment.

Mr E Moyikwa Department of Integrated Environmental Management, Mogale Local Municipality


Who will authorise the proposed project: national or provincial authorities?



The proposed EIA report will be submitted for authorisation under NEMA at a provincial level


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseHow credible will the specialist studies be in such a streamlined timeframe?



Considerable work has been done around the regional groundwater issues. This work is being consolidated, and supplemented, as part of the EIA groundwater, geochemistry and hydrology specialist studies. Similarly, where existing information exists relating to other specialist disciplines such information will be utilised. An independent set of specialist studies will become available for public scrutiny as part of the EIA process.

The Gauteng Department of Agriculture, Conservation and Environment is the competent authority in terms of the environmental impact assessment regulations for consideration of this EIA, but the national Department of Environmental Affairs and Tourism (DEAT) would like to be kept fully informed about progress with the EIA process. Therefore, it is requested that DEAT (Ms Lize McCourt) be copied on all minutes of meetings and draft/final documents (contact details provided).

Ms Nosipho Ngcaba DEAT 24 April 2009 Letter We will do so. Thank you.

Project specific comments will be made on receipt of the Draft Scoping Report and Plan of Study. Please submit one electronic copy of the report.

Mr M Nkosi Ekurhuleni Metropolitan Municipality

29 April 2009 Letter Noted. Thank you

Mining rights in South Africa is not clear-cut. Mr Sidney Osborne Greater Independent Residents Association



All documents submitted to GDACE, must also be submitted to this municipality. Further comments will be forwarded as soon as we received the Scoping Report.

Mr A Ramokolo Metsi-A-Lekoa, Emfuleni Local Municipality

19 May 2009 Letter Thank you for this comment.

In terms of environmental authorisation it should be noted that there is no Gauteng Department of Agriculture, Conservation and Environment anymore. The department is now called the Department of Land Affairs and Rural Development.


Thank you. This is not the only department that has restructured post the 2009 elections.

If the Study Reports on the radiological tests during the Pilot Plant study were not forwarded to the NNR previously, they must be submitted to the NNR.

Mr Thabo Tselane National Nuclear Regulator

20 April 2009 Meeting with National Nuclear Regulator

Noted. Thank you

Should the NNR process need to be followed, the NNR would require the following: 1) A clear indication of who (the mines or WUC) will be accountable for which environmental responsibilities / liabilities. 2) A clear description of the project, including quantities and qualities of water and wastes. 3) The results of a safety assessment, which covers all project components, including the source of water and wastes. 4) An indication of existing authorisations and background information with regards to the participating mines.



Noted. Thank you.

A guideline is available, outlining the NNR application process. It should be noted that the NNR needs three months to consider an application and that this must be taken into consideration during the planning of the proposed project.



Noted. Thank you


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseIt should be noted that Ekurhuleni Metro is a Water Services Authority (WSA) and is not in the business of treating potable water and it currently has a long term agreement with the Service Provider Rand Water who fulfils this obligation for the WSA. It is therefore crucial that Rand Water be an integral part of all discussions in order for us and them to jointly considering this initiative/s.

Mr Danie van der Merwe Ekurhuleni Metro 28 April 2009 Comment Sheet Thank you. There are ongoing discussions between WUC and Rand water regarding this project. Rand water is also a stakeholder in the EIA process.

When does WUC expect to get authorisation for the proposed project?



A full EIA process will be followed, but the GDACE has agreed to make certain concessions by allowing some activities to take place in parallel, such as that draft documents may be submitted to them for comment. These documents will be updated after the public comment period, with changes and additions highlighted. Authorities will then comment on the final documents, on which they have already started reviewing. The authorisation date will depend on the authorities and their available resources.

Will WUC register as a Water Services Provider? Will WUC work directly with Rand Water or with the Municipalities?


WUC is still investigating whether it should register as an alternative Water Services Provider or whether an agreement will be drawn up between WUC and Rand Water. Financially, it would make more sense to reach agreement with Rand Water, since they are the establised bulk water services provider in the region.

Will the mines apply for waste disposal? Mr Peter Withinshaw City of Johannesburg 08 May 2009 Meeting with City of Johannesburg

Byproducts generated in a water treatment plant will be recovered. The primary pretreatment plant sludge will be disposed of on two existing slimes dams, as currently happens. Authorisation of this activity will be influenced by the contractual arrangements between Western Utility Corporation and the affected mines.

MACRO-ECONOMYThere is little or no information available on the economics of the solution, which could also impact on the timing for implementation.


13 May 2009 Comment Sheet WUC is busy with a feasibility study that includes refinement of the financial model. This information is, understandably, of a confidential nature. Should stakeholders require site of components of this study, arrangements for this can be made subject to signing of the necessary confidentiality agreements.

The proposed project is a first step in addressing the regional problem; there are many potential uses for the treated mine water.

Mr Seef Rademeyer Department of Water and Environmental Affairs



The re-use of polluted water is a priority in the Department of Water and Environmental Affairs’s resource protection and waste management hierarchy; this project is important to Department of Water and Environmental Affairs’s national water resource planning.




MINE CLOSUREThe mines' environmental responsibilities after closure should receive attention.


29 April 2009 Comment Sheet The proposed project provides a KEY component of the regional mine closure solution related to management of water within interconnected workings. Individual closure issues need to be taken up directly by the mines themselves.

We are really concerned about the future of these mines and the residents in the area.

Mr Willy Fuzani Umlambo Pride Bee Construction Projects

30 April 2009 Comment Sheet Thank you. The project will not influence the life of mine with in the area. This is an independent issue.

Who would be responsible / liable for the relevant infrastructure components upon mine Closure of the various mines?

Mr Mogwera Khaothane Zimkile Consulting 20 April 2009 Meeting with National Nuclear Regulator

WUC will take on the environmental responsibilities / liabilities subsequent to mine closure, provided that the project proves to be sustainable. In the interim, environmental responsibilities / liabilities will remain with the mines. WUC is in the process of finalising commercial and contractual arrangements with the relevant mining houses.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseIf Grootvlei (Pamodzi) stops pumping, there will be a huge additional amount of water that will need to be treated. Who will be responsible for the treatment?

Ms Annemarie Maurizi Water Quality Manager, Ekurhuleni Metro


Pumping and pre-treatment activities at Grootvlei (Pamodzi) will be continued either by government or another mining house. The agreement between Grootvlei (Pamodzi) and WUC will be transferred to the successor. WUC will only be responsible for pumping and pre-treatment once the proposed project has proven to be self-sustainable and the mine has obtained Closure.

I enclose reports on the financial position of Pamodzi mining company. The concern in the Springs area is that with the closure of the shafts, particularly the one in the Strubenvale area, the brack mining water will flood the shaft and possibly pollute the Blesbokspruit, which is a World Heritage Site.

Mr Sidney Osborne Resident, Springs 21 April 2009 Facsimile Thank you. These are the fundamental issues which motivate this project.

Will all mines eventually stop pumping? If the mines close down, will Western Utilities Corporation have the capacity to continue with the pumping of the AMD on their own?


Correct. WUC will take over responsibility for the collective pumping of AMD associated with the 9 mines that agreed to be part of the proposed project. WUC will therefore also be liable for sustaining the pumping of AMD past mine closure.

What will happen if current working places get flooded - who will stand in for these job losses?


23 April 2009 E-mail The proposed project will not change the levels at which water is managed within the Eastern Basin. Mining companies are considering a project to stabilise the mine water level in the Central Basin. Project infrastructure is sized to accommodate the available excess water within the capacity of the proposed Water Treatment Plant.

What will happen when mining houses close down? Mr Zwi Wagner Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder Workshop, Brakpan

The proposed project is driven by the need for a regional closure strategy to handle co-liability associated with water in interconnected underground workings. When mines close with in the affected basins, assuming that they stop pumping water, the rate of water rise in the basins will increase and, if not managed, the basins will decant.

MINE WATER COLLECTIONWill the pumped water be stored underground in part of a void that isn’t filled, and then pumped out again?

Dr Martin Brink Northwest University 21 May 2009 Key Stakeholder Workshop, Randfontein

Water from the Western Basin will be pumped across and dropped into the western portion of the Central Basin. Water will be lifted from the Central Basin in proximity to the central water treatment plant. The rate at which water is pumped from the Central Basin will accommodate the addition of water from the Western Basin.

It must be ensured that water from the Western Basin is not aerated during pumping to prevent iron precipitation.

Mr Marius Keet Department of Water and Environmental Affairs


Agreed. Water will be taken directly from the pumps at the point where it is raised out of the Western Basin and pumped in a closed pipe until re-depositioninto the Central Basin.

Is there logic in the preferred flow of water from the Western Basin to the Central Basin, i.e. a pipeline connecting the two basins?


The proposed water treatment plant will treat between 75 (average) and 100 (peak) Mℓ of water per day. The Western Basin contributes between 12 and 20 Mℓ of water per day. The distance between the Western Basin and location of the central treatment plant is approximately 60 km. The capital cost of building a surface pipeline over this distance is prohibitively expensive. The Central Basin is interconnected through the underground workings. Consequently, moving water from the Western Basin and dropping it into the western part of the Central Basin, while allowing adequate pumping capacity in the Central Basin in proximity to the treatment plant to lift this volume of water in addition to water from the Central Basin, allows the Western Basin to be included in the scheme thereby stopping the decant in the Western Basin.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseWill the infrastructure associated with Phase I of the project be upgraded/designed to accommodate the additional water available at mine Closure?



The proposed scheme is being designed in a way that it can be extended to accommodate additional pumping capacity. At this stage, only the first phase is being permitted to accommodate excess water currently available. Minimum treatment capacity will be 75 Mℓ per day, average treatment capacity will be 88 Mℓ per day with the peaking capacity of 100 Mℓ per day

The transportation of untreated water which may contain uranium and cyanide, to the WTP, for many kilometers on a virgin land is a serious concern - any accidental leak may result in a disaster.


17 May 2009 Comment Sheet Water from the Western Basin will be transported in a sealed HDPE pipe. The risk associated with transport of this mine affected water will be evaluated as part of the impact assessment.

PIPELINE ROUTESAre there any existing pipelines that can be utilised for this project, such as consolidating the corridors by using road reserves? Consolidated services will save land.



Yes, wherever possible existing pipelines will be used. Similarly, pipeline servitudes will be used, as will servitudes of other linear infrastructure in order to minimise fragmentation of the environment.

The Klipriviersberg area requires specific specialist studies to be conducted, as it is an environmentally sensitive area. Various studies have been conducted by GDACE already. These, including for instance the biodiversity and historical studies, can be used.



Thank you for this information. Realignment of the distribution pipeline approaching this reservoir has already been affected to minimise impact on the rocky outcrop.

My particular concern relates to the requirement to lay a very large pipeline to deliver the potable water to the bulk storage facility and its impact on the particularly sensitive and pristine areas of the Klipriviersberg. I noted that the recent Environmental Management Framework (EMF) of the Ekurhuleni Metropolitan Municipality (EMM) had identified this area to be of particular importance. During our discussions various ideas and suggestions regarding pipelines and storage facilities were mentioned. In particular, the need to consider consolidated services corridors which would improve accessibility, reduce costs and minimise environmental and land use impacts. This would require sharing existing servitudes and reserves whenever possible. In this particular area that could require collaborating with Rand Water and using their pipeline servitude routes to avoid establishing new pipeline routes through the area. Due to the nature of the area I requested that a specialist report be undertaken for the Klipriviersberg ridges and immediately surrounding area which would address various issues including but not limited to biodiversity, Red Data species, visual impact, heritage settlements.


20 May 2009 E-mail Thank you for this information. Realignment of the distribution pipeline approaching this reservoir has already been affected to minimise impact on the rocky outcrop.

It was suggested that the EMM EMF be carefully reviewed and examined. Your contact in this regard at EMM Environmental Planning & Co-ord Dept: Envir & Tourism would be Elsabeth van der Merwe (082 494 4167 and vDepartment of Minerals and [email protected]). I also mentioned policy documents from the Southern Metropolitan Local Council (Klipriviersberg Development Framework - 2000) and GDACE (Development Guidelines for Ridges - 2001) copies of which I have attached for ease of reference. I indicated that I was aware of a major study regarding the biodiversity of the Klipriviersberg area recently undertaken by GDACE which could also be of value to you. We requested an opportunity to examine this alignment in greater detail and to discuss it with your project team to establish how impact could be minimised if this is selected as the preferred alternative for bulk water storage and thus the preferred pipeline route.


20 May 2009 E-mail Thank you for this information. Realignment of the distribution pipeline approaching this reservoir has already been affected to minimise impact on the rocky outcrop.

The routing of the pipelines should follow existing servitudes but where it doesn’t, please ensure that it does not affect areas of highly sensitive biodiversity like wetlands.

Mr Garth Barnes WESSA 01 May 2009 Letter All pipelines are being positioned in mine servitudes or other servitudes wherever possible. Delineation and evaluation of impact to wetland and riparian systems will form part of the ecology specialist study.


mailto:[email protected])

Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseIt is planned to build sports fields to the far north of the pipeline where it is situated adjacent to Witpoortjie 117, Ptn 62. This will be done as part of a school development. It seems that the pipeline route runs far away from this proposed development and will have no impact on it.

Mr Shane Brown Mnandi Property Development


Thank you for bringing this development to our attention

Mast projects is located on Vulcania number 10 in Vulcania South, not Vulcania Erf 10. Judging from the aerial maps, it is not affected by any of the proposed pipeline routes.

Mr Louis Calitz Mast Projects, Dalview


Thank you for this comment.

The property on which WYDO Engineering is situated will not be affected by the proposed pipeline. The adjacent property (A49), which is vacant land, will be affected by the proposed collection line.

Mr Wynand Hutchons WYDO Engineering 19 May 2009 Key Stakeholder Workshop, Brakpan


What is the basis for this project “traversing” private land. The answer at the Workshop was in essence that as far as private land is concerned that there are servitudes that may be used, for example, South African Railway servitudes, etc. As I understand, if a servitude is granted, for example, for Transnet, then it can be used by Transnet for its purposes, but not for other purposes. In other words, that one cannot use a Transnet servitude for what WUC wants to do. Then, it was indicated at the workshop that discussions will take place with owners of land. That answer is concerning. For a member of the public, sitting at such a meeting, or in similar meetings and to be advised that for example Transnet servitudes can be used, raises a serious concern. What is the basis for saying this to the public? Most probably such members of the public will simply just accept same to be correct, but is it? The public must be informed correctly what the position is – is this done? It was indicated that some R65 million has already been spent on this project but then there is no clear answer to such a very fundamental issue forming part of such a project. Proper legal opinion will have to be obtained as part of this EIA process. Can one really expect the owner of a small piece of land, let’s say 500 sqm or 1000 sqm to engage independent legal advice where, it seems to me, one must be able to rely on what is stated by the consultants at such an EIA meeting. Ms Smit (who is the Chief Property Officer – Alberton CCC: Ekurhuleni) said that, in her view, what I said is correct, namely that one cannot for example use a Transnet servitude for this.


21 May 2009 E-mail The issue surrounding use of servitudes appears to have been misunderstood. Firstly, existing pipeline servitudes held by participating mining companies will be used preferentially. In all other areas alignment of the proposed pipelines will, wherever possible, follow other linear infrastructure (railway lines, roads etc). The proponent (WUC) must still acquire the right to use such servitudes. This right must be obtained from both the primary property owner and, in the case of shared services, the existing servitude holder as well. From an EIA perspective,the suggestion is merely that the impact on the environment, including on private land owners, is minimised if the linear infrastructure associated with the proposed WUC project can be aligned in areas where other types of linear infrastructure already exist so as to minimise fragmentation of properties. In contrast, if this was not done the proposed pipelines would result in further fragmentation of the environment in areas not already impacted by linear infrastructure. Thus, there is no suggestion that a pipeline can be placed inside a rail servitude, for example, without the need to acquire servitude rights for placement of the pipeline.

Railway servitudes are registered for use for by the railway. Can a servitude be used for another function as for which it has been registered? A legal opinion should be obtained about this matter.



The intent is to make use of existing linear servitudes were ever possible in order to minimise impact on private land owners. This does not mean that the proponent does not need to obtain permission to make use of the servitude. A way leave agreement with Transnet for the placement of a pipeline within their servitude is currently being negotiated.

It should be considered that the pipeline is to be constructed behind the BP filling station between the Eskom line and the stormwater trench.

Mr Dave Kahts BP, Newmarket 20 May 2009 Key Stakeholder Workshop, Alberton

This aspect will be addressed in the EIA.

There doesn’t seem to be any impact on the properties for which I am acting as representative. These are vacant properties that were bought as investment.

Mr Peter Lin Pam Golding, Brakpan



Page 5 of the BID states that in some areas the pipelines may traverse private land. Therefore, proof of agreement between the landowners and the applicant should be provided in the Scoping Report.




Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseHave the pipeline/railway crossings been identified yet? Mr Patrick Mtzenga Transnet 15 April 2009 Pre-consultation

meetingyes, the engineering team has identified these crossings. Individual discussions will be held with existing land owners/servitude holders to agree right of access. This will form part of the servitude negotiation process that will run independently from the EIA.

When will this project commence? For each railway crossing, a letter should be issued after detailed discussions with the relevant Transnet engineers. This is quite a lengthy process; discussions therefore need to commence as soon as possible.

Mr Patrick Mtzenga Transnet 15 April 2009 Pre-consultation meeting


Two Transnet Depots will be impacted: Isando Depot in the Eastern Basin and Krugersdorp Depot at Millsite in the Western Basin. The Transnet contact people for these depots are Linda Skarupke and Trevor Oosthuizen respectively.



There is a new Transnet directive regarding access to Transnet land. Transnet is no longer giving servitudes but rather wayleave.



Please note that there are two entrances to the Methodist church just off Heidelberg Road. If construction were to impact on the main gates and access to the church, we can use the additional gate in Ascot Road.

Mr Peter Nancarrow Methodist Churh, Alberton

15 May 2009 Telephonic comment Noted with thanks. This will be discussed in detail before construction begins.

Please provide Scaw Metals with the land surveyor general information.

Ms Nicoletta Pera Scaw Metals 20 May 2009 Key Stakeholder Workshop, Alberton

This information will be provided.

The proposed line from Rand Uranium Harmony Shaft 8 to West Wits Shaft 4 seems to be extremely close to my home.


06 May 2009 Comment Sheet Thank you. We will look into this with the engineering team.

A servitude cannot be used for another purpose than for which it was registered. However, a new servitude can be registered.

Ms Elizabeth Smit Ekurhuleni Metro 20 May 2009 Key Stakeholder Workshop, Alberton

Comment noted with thanks. This aspect will be verified as part of the EIA.

Excavations in the Scaw parking area to lay the pipeline will be problematic. WUC will have to come up with a strategy to address the parking problem that will arise as a result of excavation during construction. The parking area belongs to Transnet, but Scaw has an agreement with them to make use of it. WUC will have to get authorisation from Transnet to construct the pipeline through the parking area, which belongs to Transnet.


Thank you for bringing this to our attention.

Scaw Metals uses the railway line and services crossing. Mr Jurgen Theiss Scaw Metals Group 15 April 2009 Pre-consultation meeting

This will be taken into account during the design and construction of the pipeline.

The borders and boundaries of Scaw Metals' properties and servitudes are unclear to me at this stage. As soon as I have obtained all relevant information, it would be good to meet again to discuss the proposed pipeline route.



The land on the other side of the highway (other side of Black Reef Road) also belongs to Scaw Metals.



I understand the complexities surrounding mine water in the Witwatersrand area and support the concept of the proposed Western Utilities Corporation Mine Water Reclamation Project. Authorisation for the proposed pipeline route to cross Scaw Metals land, however, will have to be obtained from the Executive Committee.




Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseWould the proposed buffer zone limit Cosira to add infrastructure? Mr Eduardo Trombetta Cosira Group 21 May 2009 Key Stakeholder

Workshop, RandfonteinNo. The proposed pipelines will be constructed in the servitude at the back of the Cosira Witpoortjie properties.

There is an existing pipeline at the back of the property (Witpoortjie 117, Ptn 184, PP nr A 64).

Mr Eduardo Trombetta Cosira Group 21 May 2009 Key Stakeholder Workshop, Randfontein


Cosira has added further infrastructure to the factory and it now fills the entire property (below the servitude indicated as A130).

Mr Eduardo Trombetta Cosira Group 21 May 2009 Key Stakeholder Workshop, Randfontein


The proposed pipelines will run within mine land for much of the routes. Mines have servitudes and also the right of access on these servitudes. Will new servitudes need to be registered? If so, it may be a good idea to register these under WUC.

Mr Danie Van der Merwe Water Services, Ekurhuleni Metro


We appreciate your comments and advice.

PROJECT INFRASTRUCTUREWhile it is noted that the Klipriviersberg Reservoir has the capacity to accommodate the potable water output, I questioned what other storage facilities and opportunities had been considered and carefully examined as alternative bulk water storage facilities/solutions.


20 May 2009 E-mail Alternatives are written up in an alternatives report that will be an appendix to the Draft Scoping Report. The Germiston Reservoir was also considered as an alternative but, this reservoir has capacity roughly equal to the phase 1 peak treatment capacity (100 Mℓ per day). This would constrain the project and limit expansion of the scheme to its second phase.

In terms of the timelines associated with the proposed project, will the plug and pump station in the Central Basin be a temporary solution until the project is up and running?


The plug and pump station is a key components of the proposed project, and will remain in place to maintain water levels below CRG’s mineral reserves and below ECL. Water levels in the Central Basin are currently rising in excess of 1m per day.

What is the chance of leakages in the pipe? Mr Michiel Bothma Randfontein Environmental Action Group


Risk of environmental contamination through pipe failure or leaks will be evaluated as part of the impact assessment process.

Will the pipelines be on the surface or buried? Mr David Hall Dura Soletanche Banchy


Various sections of the pipeline will be on surface and will be buried. Where geotechnical possible, the pipeline will be buried in populated or ecologically sensitive areas.

What pressure will be maintained in the pipelines? Mr David Hall Dura Soletanche Banchy


The Eastern Basin collection pipeline to ERPM will maintain a pressure of 2 500 kPa.

For what period of time will private properties be traversed to construct the pipelines?



It is estimated that the pipeline construction period will be 6 to 8 months. The potential impact on an individual property owner will typically be much shorter.

The presentation stated that four potential sites have been identified for the Plant; however, has a decision been made where the proposed pump station will be located?



Yes. It is proposed that a plug and pumping system be constructed at the South West Vertical shaft.

When do you envisage to commence with the construction of the plug system?



Construction is envisaged to start by the end of June 2009. That will enable the plug system to be operational by the end of 2009.

More details are needed on the construction of a new WTP mentioned in the BID.

Ms Nozipho Maduse City of Johannesburg 08 May 2009 Meeting with City of Johannesburg

An existing pre-treatment plant at ERPM will be upgraded and a new By-product Recovery Plant will be constructed at the same site. Further details will be provided on the Draft Scoping Report and EIA reports.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseIt must be noted that in terms of Government Notice 704, Regulation 6 Capacity requirements of clean and dirty water systems, sub-section (d) stipulates that every person in control of a mine or an activity must (d) design, construct, maintain and operate , operation any dirty water system at the mine or activity so that it is not likely to spill into any clean water system more than once in 50 years. Thus all relevant activities should adhere to the above regulation as well as any other relevant sections of the Regulations.


28 May 2009 Letter Thank you for this advice.

Will the infrastructure between the connection shaft in the Central Basin and ERPM be located underground?


In any built-up area pipelines will be buried.

Which existing Water Treatment Plants will form part of this project? Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of Johannesburg

The existing WTPs at Grootvlei in the east and at ERPM (Central) will be utilised as part of the project. Grootvlei will continue pumping mine water to surface and pre-treat the water; WUC will transport the pretreated water to the centralised WTP. No pre-treatment will be conducted in the west. Mine water in its raw state will be transferred to the Central Basin.

Where will the plug system be constructed and what motivated the decision to opt for a plug system?

Mr Michael Oberholzer Chief Director: Mineral Regulation, Department of Minerals and Energy


The plug system is proposed for the South West vertical shaft. The plug and pump system is proposed as a technica solution which can be implemented within the tight time lines associated with protecting the mine reserves of Central Rand Gold.

The purpose of this message is to introduce our company and in particular new technology we developed to join or repair plastic piping. In the event of WUC be laying plastic pipes (HDPE or PVC) we have no doubt that substantial cost savings can be achieved by utilising our technology. I would therefore appreciate it very much if you would be so kind as to relay this message to the appropriate person/s at WUC who are involved in the project.

Mr Tommie Smith Clampon (Pty) Ltd 11 May 2009 E-mail Thank you. Please contact WUC directly.

There are many uncertainties in this project that has not been cleared yet, such as pump station failures that can’t be planned by models.


Reports are currently being collated, incorporating information on the various geochemical and other studies that have been conducted over many years in the area. There may well be additional questions, but if every potential flow, etc, is investigated, studies will continue and the actual point of addressing the problem will keep on being delayed.

The pipelines will go through sensitive areas, and potential tapping into the pipe, despite it carrying AMD, should be considered.


In all areas were high settlement densities occur the pipeline will be buried.

Where will the pump stations will be located? Mr Peter Withinshaw City of Johannesburg 08 May 2009 Meeting with City of Johannesburg

Pump stations will be located at each of the mine water collection shafts , a booster pumpstation at ERGO as well as the potable water pumpstation at the WTP.

Where exactly is the Klipriviersberg Reservoir located? Mr Peter Withinshaw City of Johannesburg 08 May 2009 Meeting with City of Johannesburg

The reservoir is located on the hilltop immediately to the west of Alberton, and East of Glenvista.

PUBLIC PARTICIPATIONPlease advise me of any public meetings that may take place with respect to this application.


21 April 2009 E-mail We will do so.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseI confirm that your professional team agreed to provide me with a CD containing the available maps and plans and documentation for closer examination. In this regard, we may require the opportunity to discuss the proposals with you and make further submissions. Please contact me should you require any clarification regarding the issues noted above. Please note, we reserve our rights to make additional comments and submissions due course.


20 May 2009 E-mail Thank you. This information will be provided.

Please forward maps of all the basins, an electronic copy of the BID as well as the presentation done by WUC.



Certainly, this information will be provided.

From our discussions at the workshop I was under the impression that the maps would be put onto a CD and delivered to me shortly after the workshop so that I could examine the routes and make appropriate comments or have meetings with your professional team before you finalised your Draft Scoping Report. However, in the light of your e-mail I request that the final maps and the Draft Scoping Report and accompanying reports all be put onto a CD for me.


01 June 2009 E-mail Copies of the relevant documents will be forwarded to you as soon as they are available.

If a concurrent public participation process is to be followed, comments from authorities as well as public comments should be reflected in the final documents.


Subsequent to the completion of the comment period on documents (i.e. 4weeks), all comments received from authorities and the public will be captured in an updated Comment and Response Report and the Scoping Report will be updated based on comments received. These final reports will then be submitted to the authorities.

Why have information regarding the proposed project not been shared before and on a bigger public scale?

Mr Michiel Bothma Randfontein Environmental Action Group


Issues related to the water problems in the Witwatersrand gold mining basins have been widely discussed in various forums since the mid-1990s

The technical information shared during today’s workshop is not very accessible to the broader public.



A comprehensive public consultation process is taking place as part of the EIA process. Stakeholders have access to all project information through this process.

People at grassroots level feel that everything has been planned and decided. Only now that the scheme has been decided on, are they being consulted.



Public consultation is taking place at a variety of levels, including in small groups at a grass roots level. Trained facilitators are available to assist people to interpret and contribute to the project through these meetings.

Property owners should be involved in the project process to ensure they are aware of the potential impacts on their properties.



The EIA process is a public process to which all members of the public can register stakeholders to participate in the process.

It is not clear how Focus Group Meetings can be held before registration of I&APs.


23 April 2009 Comment Sheet I&APs were initially provided with the opportunity to register during the period 14 - 30 April 2009. The Focus Group Meetings were held subsequent to this period, i.e. 19-21 May 2009. I&APs can register at any point during the EIA process.

Our Association does not have any business or financial interest in the project but seeks to ensure that natural areas are protected from untoward developments.

Mr Klem Courie Klipriviersberg Nature Reserve Association

02 May 2009 E-mail Thank you for this comment.

The BID is a useful summary, however, more detail is required, for example on the economics, to make a full judgement. It would be useful if the business case was made available.


13 May 2009 Comment Sheet WUC is busy with a feasibility study that includes refinement of the financial model. This information is, understandably, of a confidential nature. Should stakeholders require site of components of this study, arrangements for this can be made subject to signing of the necessary confidentiality agreements.

The BID was useful, since it contained a good summary of the project.

Mr Bruce Ebell DRD Gold 17 April 2009 Comment Sheet Comment noted with thanks.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseWe would like to attend a meeting on the project. Mr Willy Fuzani Umlambo Pride Bee

Construction Projects30 April 2009 Comment Sheet We welcome your attendance at the open house meetings that will run

during the scoping process

It is very important to consider the people who live next to the area. Awareness creation and meetings are advised.

Mr Willy Fuzani Umlambo Pride Bee Construction Projects

30 April 2009 Comment Sheet A broad-based public consultation process is running as part of the impact assessment process

Please send me a big aerial map of the proposed route for exhibition at the school, where people from the Witpoortjie community can also have access to it. I will also be able to provide information on community representatives in the Witpoortjie area.

Mr Henning Germishuys Laerskool Culembeeck, Witpoortjie


The public participation team appreciates the assistance offered. Maps will be forwarded to the school at the same time when the Draft Scoping Report is made available for public comment.

The BID was helpful and shows the location and scope of work required.

Mr David Hall Dura Soletanche Bachy

24 April 2009 Comment Sheet Thank you

Please add the following Central Rand Gold officials to the list of stakeholders: Mr Mike Sullivan and Mr Paul Housler.

Mrs Jenny Johnson Central Rand Gold 17 April 2009 Comment Sheet Comment noted with thanks.

Our property is Erf 248 Newmarket Park Ext 15. I am the representative of the owners thereof, namely Rejem Property Development (Pty) Ltd and Linton Projects (Pty) Ltd (the latter a wholly-owned subsidiary of Nedbank). From the beginning I want to make the following abundantly clear – our registration as an interested and affected party, and any involvement in the EIA, must under no circumstance whatsoever be conceived or perceived as a concession or acknowledgement of any alleged rights or entitlement on behalf of your client or anyone else. We will of course once more clarity is available obtain the necessary advices from those who we may consider appropriate to advise us. In other words, all our rights are strictly reserved without any limitation or restriction whatsoever and what is embodied in this e-mail will along embody our position. Please specifically acknowledge receipt of this e-mail and confirm that the contents of this e-mail have specifically been brought to the attention of your client.

Mr Riaan Jonker Newmarket Property Development

13 May 2009 E-mail Noted. Thank you.

The BID was not useful, since it contained too little detail. Mr Garfield Krige African Environmental Development


Please notify stakeholders well in advance of events such as meetings.

Mr Frans Le Grange Exotic Properties 22 May 2009 Comment Sheet Thank you. Stakeholders are notified well in advance of meetings

We strongly advise that "…the participation of all interested and affected parties … must be promoted, and all people must have the opportunity to develop the understanding, skills and capacity necessary for achieving equitable and effective participation, and participation by vulnerable and disadvantaged persons must be ensured…" regarding the proposed project. (Reference: NEMA Chapter 4(f)). We here refer to page 8 of the BID whereby it is stated that "in obtaining initial comment focus group meetings will be held with private landowners and other stakeholders". The complexity of the legal measures furthermore makes it difficult for the ordinary person unqualified in the law to understand or conceive accurately the legal requirements and the environmental rights of communities. Members of the public can assist during broad based and wide ranging public participation meetings to make sense of the environmental legislation.


05 May 2009 Letter Thanks for this comment. A broad public participation process forms part of the EIA.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseThe ability of individuals to participate in the process is likely to vary considerably depending on a number of factors: Socio-economic status; education; ability to write and speak English; access to information on environmental legislation and scientific reports; ability to purchase expert advice. The ability of groups to participate effectively also varies according to the mix of individuals involved. In view of the aforesaid, we foresee that focus meetings will exclude marginalized communities, the underprivileged and indigent local communities. Because the proposed project involves detailed scientific and technical issues, which may not be readily understood by many members of the public, it requires that experts or informed members of the communities meet together with the uninformed in order for the ill-informed to draw on the expertise and knowledge of the informed.


05 May 2009 Letter Thank you for this comment. A broad public participation process forms part of the EIA. This process includes small meetings with various groups of stakeholders, including disadvantaged communities. These meetings are held in the language of choice with trained facilitators available to interact with people in a variety of languages

The majority of the affected communities are indigent. It is hoped that the Applicant will consider providing financial assistance or a specific fund for those parties who cannot afford to pay transportation fees to attend and participate in public participation meetings. Indigent and historically disadvantaged communities have the following capacity constraints: 1. Inadequacy of resources to engage (e.g. financial resources to travel to and attend meetings, and human resources with respect to time; meetings can only be attended by those who are near to major centres where these are being held). 2. Insufficient access to technical knowledge to enable stakeholders to understand the decisions being made and the underlying issues surrounding the decisions 3. Members of indigent and historically disadvantaged communities exhibit only sporadic interest in environmental affairs and few participate actively. 4. Insufficient access to information to be able to engage. 5. Inaccessibility of documentation. Documents are often available on the internet only.


05 May 2009 Letter Thank you for this comment. A full public participation process is being run. Small group meetings are being held with stakeholders throughout the project area. Trained facilitators are available to assist stakeholders to understand and contribute to the EIA process.

Environmental remediation programmes are often presented to local communities as fait accompli and any opportunity for real input of local ecological knowledge is lost or deliberately ignored in an apparent haste to reach a desired outcome. In contrast, some local communities require time to reach consensus and to develop formulated responses. Adequate time is needed to ensure that all affected people are appraised and provided an opportunity for input. Historically disadvantaged mining communities in West Rand lack basic information about the mining industry and its impacts and the capacity to offset the impacts.


05 May 2009 Letter Thank you for this comment.

In South Africa, a successful commercial farmer is likely to have greater capacity to negotiate and influence decision making pertaining to environmental issues than his impoverished rural subsistence farmer counterpart. Great care thus needs to be taken to ensure environmental justice through stakeholder engagement processes. In addition, it is problematic to assume that all stakeholders can be engaged and informed in a uniform way.


05 May 2009 Letter Thank you for this comment. The full public participation process is being run. This process is structured to engage stakeholders at different levels and with different technical backgrounds and language competencies.

The challenge to the appointed EAP and the Applicant is to take proper cognisance of local views of the environment and dispense with insular and short-term views of public participation. Outsiders who bring external assessment and public participation instruments, must be careful not to undermine local ways of seeing. The need is to develop ongoing consultation processes that meet the needs of local communities both now and in the future.




Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseUnfortunately as a result of the country's apartheid past, the broad South African public has not been able to develop a strong culture of participation in environmental processes, nor has it learned to successfully articulate its interests.



Appropriate communication tools are needed to inform local communities of environmental hazards or risks and how local communities can get involved when it comes to making decisions about remediation programmes. Poor rural communities have their own existing community organizations and decision-making mechanisms in place. In the process of public participation, this should be taken into account and existing practices should be strengthened where appropriate. A pro-poor approach must be used in the process of participation to ensure that the interests of the disadvantaged are taken into account in all decision-making processes.


05 May 2009 Letter Thank you for the comment. The full public participation process is being run. This process is structured to engage stakeholders at different levels and with different technical backgrounds and language competencies. Specific attention is given within this process to engage with community representatives and existing community bodies.

Largely because of the power of e-mail and the internet, commercial consultants conduct public participation processes using electronic tools. The majority of the inhabitants of the West Rand, however do not have access to e-mail hence is prevented from participation.


05 May 2009 Letter A full public participation process is being run. This process includes various stakeholder meetings at different levels, including small group meetings with directly affected communities. At these meetings trained facilitators are available to assist stakeholders to engage with the process and stakeholders are able to interact in their language of choice, including all local African languages.

Formalised public participation and information gathering tools are often not flexible enough to take into account the unique circumstances of local and indigent mining communities.


05 May 2009 Letter This comment. The full public participation process is being run. This process is structured to engage stakeholders at different levels and with different technical backgrounds and language competencies.

Negative perceptions of real or perceived environmental impacts within West and Far West Rand Gold Fields have been fuelled by an apparent unwillingness of regulators and industry to discuss these impacts in public. It is recommended that public communication regarding mining related environmental impacts within the West Rand Basin be approached transparently, and that the appointed EAP provides reliable information with sufficient detail to allow affected communities to make informed decisions regarding their environment.


05 May 2009 Letter Thank you for this comment

We recommend: Sufficient time to consult. The sharing and increasing understanding of information and the likelihood of a change in the proposal. It involves dialogue and feedback. Listening is just as important as talking.



In the legal precedents established inter alia the State v Smith and Earthlife Africa v DG of DEAT and Eskom Holdings Ltd it was found that consultation is not: Merely telling or presenting: consultation is a two-way process, Intended to be a charade. The same as negotiation. Consultation needs to be conducted in mutual good faith and to a degree sufficient for the authorizing authority to familiarize itself as to the nature and substance of the interests and concerns of I&APs. Consultation should be ongoing. The parties must consult at the initial stages in the process.




Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseWe refer to Shelley Arnstein's (1969) essay on public participation whereby it was stated: Inviting citizen's opinions, like informing them can be a legitimate step towards their full participation. But if consulting them is not combined with other modes of participation, this run is still a sham since it offers no assurance that citizen concerns and ideas will be taken into account. The most frequent methods used for consulting people are attitude surveys, neighbourhood meetings, and public meetings. When power holders restrict the input of citizens ideas solely to this level, participation remains just a window dressing ritual. People are primarily perceived as statistical abstractions, and participation is measured by how many come to meetings, take brochures home or answer a questionnaire. What citizens achieve in all this activity is that they have participated in participation." And what power holders achieve is the evidence that they have gone through the required motion of involving "those people."



Public participation is concerned with the redistribution of power that enables the have not citizens, presently excluded from the political and economic processes, to be deliberately included in the future. It is the strategy by which the have-nots join in determining how information is shared…" We recommend the following communicative strategies: Cultivate community networks; Listen Carefully; Notify people early; Educate affected communities about the process and the 'rules of the game'; Supply information - get technical and scientific information to communities to enable them to be informed and participate effectively; Use informal channels; Use NGOs and civil society groups involved in the AMD issue.



I am in receipt of a number of documents, which were submitted to me in my capacity as CEO of the Federation for a Sustainable Environment (FSE). I respectfully request inclusion of these documents, which are subjoined and appended hereto, in the Comments and Response Report. My office is to disclose or portray the concerns or issues raised by members of the public not to dissect or to promote commercial products or processes. Analysis of the technical and scientific theories or postulations is furthermore not the business of an NPO but of impartial experts. No attempt is therefore made to interpret, augment or endorse the appended and subjoined submissions. (Comments from Mr Garfield Krige fully quoted elsewhere in this report. The document compiled by Prof Frans Waanders is summarised in this report, while the full text is available)


20 May 2009 E-mail Thank you. We reiterate however that only issues addressed directly to the EIA team will be taken up in the process. No consideration will be given to issues not addressed to the EIA team by a register stakeholder. Prof Leslie Stoch has been contacted by the public participation office and he has confirmed that he does not want to participate in the current project.

The public participation process should be extended to include the marginalised, disadvantaged and disempowered communities, not only ward councillors as their representatives.



Thank you for the comment. The full public participation process is being run. This process is structured to engage stakeholders at different levels and with different technical backgrounds and language competencies.

Will local people participate in the project? Mr Victor Manavhela Gauteng Department of Agriculture Conservation and Environment


The proposed project will contribute a number of permanent employment opportunities. During construction a larger number of employment opportunities will be created. During the feasibility process, the potential employment numbers will become known. This will be reported in the draft scoping report, EIA report and associated specialist studies

This Department must be informed of all Public Participation Processes.


28 May 2009 Letter A full record of the public participation process followed will be included in submission of final reports for decision-making.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseAll ministers of the following national government departments should be consulted: DEAT, Department of Water and Environmental Affairs, Department of Minerals and Energy, Health and Agriculture. All MECs of the Gauteng Province should also be involved.

Mr Chris Mentz Grasslands/Ten Acres Forum

30 April 2009 Comment Sheet Noted. Thank you

Involve the relevant departments of the following universities: Johannesburg, Wits and Tuks



The map on the second last page of the BID does not include the Western Basin up to Klerksdorp, which it should.


30 April 2009 Comment Sheet This is a concept level map. Detailed maps will be included in the draft scoping report.

The stakeholder groups represented at this workshop do not seem to be very representative of the broader affected area. Randfontein, Westonarea and the Randfontein Western District Municipalities should also have been invited to this workshop.

Mr Chris Mentz Grassland, Ten Acres Forum and Randfontein Environmental Action Group


An extensive public consultation process is being run as part of the EIA. This includes a range of focus group meetings with different sectors of the stakeholder group, based on common interest

Please ensure that advertisements for participation in this project take place on a bigger scale, in order to reach a broader range of stakeholders who also have a stake in this project. “Local’ announcement of the project, EIA and public participation processes would mean publicising advertisements, including an advertisement of the open houses, in the Herald and TK News in the Randfontein area.



Advertisement of the EIA process has taken place through a variety of printed media including local newspapers in circulation across the full width of the project area. In addition, site-specific notices have been placed along the preferred and alternative routes and plant site locations.

With regard to the Authority Steering Committee for the proposed project, provide clarity on the following:· Whether I was invited to the Authority Steering Committee meeting or not, Which delegates from the Department of Water Affairs and Forestry (Department of Water and Environmental Affairs) attended the meeting, and · In what capacity did the Department of Water and Environmental Affairs delegates attend the meeting.

Ms Deborah Mochlotodi Department of Water and Environmental Affairs


An invitation to the Authority Steering Committee meeting held on 26 March 2009, was sent to the following delegates from Department of Water and Environmental Affairs: Mrs Thandiwe Buthelezi, Mr Marius Keet, Ms Debra Mochotlhi, Mr Molefe Morokane, Ms Pamela Mqulwana, Mr Nndanganeni Musekene, Mr Seef Rademeyer, Mr Matthew Senne, Mr Hennie Smit and Mr Jurgo van Wyk. The following Department of Water and Environmental Affairs delegates attended the meeting: Ms Samantha Boshoff, Mr Marius Keet, Mr Seef Rademeyer, Mr Jurgo van Wyk, Mr Justice Maluleke, Mr Matthew Senne, and Miss Pamela Mqulwana.

Issues with regard to approval and input on requirements for standards of water pumped into pipelines and Water Treatment Plants, establishment of a Water Treatment Plant within the City of Johannesburg's jurisdiction or establishment of a Plant that impact on the City's infrastructure should be discussed with Johannesburg Water.

Ms Lebo Molefe City of Johannesburg 07 May 2009 Comment Sheet Thank you for this comment.

Community engagement will be difficult for this EIA. Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of Johannesburg

A full public consultation process is taking place as part of the EIA. This includes a number of meetings with community based groups across the breadth of the project area.

Ward councillors need to be included in the public participation process.


Ward councillors will indeed be consulted with and will be given support to be able to convey the information to the communities.

Other directorates within the Department of Water and Environmental Affairs have to be consulted, i.e. Water Resource Planning.



Please add the following Department of Water and Environmental Affairs officials to the database: Messrs Matthew Senne and Pieter Viljoen


24 April 2009 Comment Sheet Done. Thank you


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseThe BID was useful, although not very clear on water uses to be exercised.



The department will appoint an official who will liaise with the project team in the future. Until this official is appointed, the project team must liaise with Mr Manavhela and Mr Motaung.



The EIA team looks forward to receiving the name of the dedicated official. We will keep the Department informed of progress.

Has pre-consultation taken place with authorities and municipalities? Mr Koogan Naidoo Mogale City Local Municipality


Yes, various meetings have taken place with authority groups including regulators and local councils. A description of these meetings is contained in the appendix to the draft scoping report

The consultation process has been excellent so far. Thank you for providing us with good information and replying to our queries.

Mr Peter Nancarrow Methodist Churh, Alberton

15 May 2009 Telephonic comment Noted with thanks.

Ground level communication regarding this project is necessary, which includes community involvement and explaining technical information in lay man’s language.

Cllr Dudu Ngubane Kagiso 21 May 2009 Key Stakeholder Workshop, Randfontein


Due to the sensitivity of the area all interested and affected parties must be informed to be able to make an informed decision about the proposed mine water reclamation project.

Mr A Ramokolo Metsi-A-Lekoa, Emfuleni Local Municipality

19 May 2009 Letter A full public consultation process is taking place as part of the impact assessment process

Meetings should be held with affected landowners in the affected areas.


06 May 2009 Comment Sheet A full public consultation process is being run, which includes meetings with directly affected land owners.

There should be more awareness creation among the public. The person in charge of the proposed project should be identified and meetings should be held.


06 May 2009 Comment Sheet A full public consultation process is being run, which includes open houses.

We run a successful business in the area of the proposed pipeline and would like to be told in detail where the pipeline will run.


06 May 2009 Comment Sheet Maps are being refined and finalised and will be available with the Draft Scoping Report. The route will also be discussed personally with all landowners possibly being affected.

The Background Information Document reached us after the comment period was over.


06 May 2009 Comment Sheet Comments are welcome and considered right through the EIA process.

Future communication with the NNR should be done directly through the NNR specialist, Mr Mogwera Khaothane, and preferably only after the submission of the relevant application.



Noted. Thank you

The NNR prefer not to be part of the Authorities Steering Committee. The NNR would only be involved in the project once an application has been submitted. Subsequent to the submission of the application, an official would be assigned to the project and would work directly with the NNR specialist.



noted. Thank you.A document outlining the purpose and objectives of the Authority Steering Committee was forwarded to the NNR, so that, should an application be submitted to the NNR, the relevant official can make an informed decision about becoming part of the ASC or not.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseCommunity engagement is vital for this project. How will communities and ward councillors be involved in the public participation process?

Mr Aaron Tsoku Mogale City Local Municipality


A full public participation process is being run. This process includes various stakeholder meetings at different levels, including small group meetings with directly affected communities. At these meetings trained facilitators are available to assist stakeholders to engage with the process and stakeholders are able to interact in their language of choice, including all local African languages.

I wish to place on record that the notice given is very short and this prejudices our position. We might therefore ask a third party to formally enter into the record a document from us stating what our position in this matter is.

Dr Anthony Turton TouchStone Resources (Pty) Ltd

15 May 2009 E-mail Noted. Thank you.

Please record the fact that this is a very short period of time to deal with an issue of this magnitude and implication. I reserve the right to enter my concerns into the official record of decision.

Dr Anthony Turton Lit Creations 29 May 2009 E-mail The legacy issues of mining pose a significant environmental risk, which has been known for many years. WUC, on behalf of the affected mines, propose a solution to this problem. Should the proposed treatment technology not work, it would not pose risk to the environment beyond that which currently exists.

Please ensure that the attachments is included in the EIA now in process when submitted to the Various Departments for approval


15 May 2009 E-mail When the EIA report is submitted for authorisation, it is accompanied by a public participation process document to which is attached a complete record of all comments received from stakeholders

The attendance at the workshop fell short. The absence of decision makers in the area, and the provision of seating arrangements too, was noticeable. Why were they not invited and if so please advise how? A spattering of Mogale City Environmental Officers and a few apparently selected Mogale City Councillors, attended but none from West Rand Municipality or opposition members environmental officers, who have over time been deeply involved with the all-round situation. Neither were groups lower down the Wonderfontein valley represented, other than the selected professors from Potchefstroom.


22 May 2009 E-mail A broad public participation process is being run as part of the EIA. A number of meetings with different stakeholder groups are being held.

Present all details to either confirm our suspicions or prove us, the objectors, wrong. Not to present all information, and to go ahead without the public having prior insight, constitute a gross miscarriage of the purpose of the Public Participation process.


22 May 2009 E-mail Various treatment technologies have been considered by WUC for the proposed project. The CSIR's ABC process and the SAVMIN process were chosen to be thoroughly investigated during Pilot Plant studies. Subsequently, the ABC process proved to be the most self-sustainable treatment technology, specifically in terms of by-product recovery. Refer to the Consideration of Alternatives Report.

A Public Meeting should be held instead of an Open House to review the Draft Scoping Report. That is what is stipulated by the NEMA.


02 June 2009 Telephonic comment NEMA does not prescribe Public Meetings, neither does the Regulations (GN R385 of 2006). However, the Guidelines from the DEAT recommends that Public Meetings or Open Days may be held. In regard to a large (geographical) or complex technical project such as this, an Open House is rather recommended. This gives I&APs with technical knowledge an opportunity to have detailed discussions with the EIA-team, while other I&APs, such as people with more interest in the socio-economic aspects of the project, also have an opportunity for detailed discussions, without one group dominating discussions at the meeting.

The fact that an action was taken to solve the AMD issue was brought to our attention on May 15, 2009 when the registration process claims that 30 April 2009 is the last day.


17 May 2009 Comment Sheet Stakeholders can register with the EIA process at any stage during the impact assessment. The initial date mentioned reflects a mandatory stakeholder registration period following date of publication of the EIA announcement advertisements in printed media.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseThe BID was useful because the introduction is short and complete, allowing first time reader to understand in a glance the objectives of the proposed solution. The capacity and process are clearly described in the BID.


17 May 2009 Comment Sheet Thank you for this comment

Has the project been announced yet? Mr Peter Withinshaw City of Johannesburg 08 May 2009 Meeting with City of Johannesburg

Yes. The project was announced in April 2009.

The City of Johannesburg’s geotechnical department should be registered as an I&AP.


Thank you for the suggestion.

Please send me hard copies of all EIA documentation, when available for public review.

Mrs H Zwanziger WESSA 19 May 2009 Key Stakeholder Workshop, Brakpan

Noted. Thank you.

The public, communities and NGOs need to be kept informed and given the opportunity to submit comments at various stages during the EIA/EMP process.

Ms Hendrika Zwanziger WESSA 30 April 2009 Comment Sheet Thank you. The broad-based public consultation programme is running as part of the impact assessment

The BID was useful and confirms the need that stakeholders must participate and submit more detailed comments.

Ms Hendrika Zwanziger WESSA 30 April 2009 Comment Sheet Thank you.

SOCIO-ECONOMYWill the value of properties deteriorate because it is traversed by pipelines?



Wherever possible, pipelines will be confined to existing servitudes. This will minimise the impact to private land ownership. Should it be necessary to cross private land detailed negotiation around acquisition of servitudes will be necessary that will involve evaluation of the impact to properly value. This takes place outside of the EIA process.

Will there be any compensation for the properties impacted by the proposed pipelines?

Mr Peter Lin Pam Golding, Brakpan


Wherever possible the proposed pipelines will be aligned wit in existing servitudes to minimise impact on private land ownership. Should private land be crossed, an independent estimator will be engaged in the negotiation process.

Will local people participate in and benefit from the project? Mr Victor Manavhela Gauteng Department of Agriculture Conservation and Environment


The project will create about 15-20 jobs during operational phase of the project. About 200 people will be employed during construction phase of the project. Participation by local people in the project will be ensured as local people will be employed during construction.

Will communities be involved when infrastructure is constructed? Cllr Dean Stone Ekurhuleni Metropolitan Municipality


The employment opportunities that will be created through the project are described in the Draft Scoping Report.

Will people working at the current operations, such as the pump stations at ERPM, be considered for employment by WUC?

Cllr Dean Stone Ekurhuleni Metropolitan Municipality


The feasibility study needs to run its course. Through this process employment opportunities at the treatment plant and during construction will be identified.

What is this project’s potential for job creation? Ms Elize Tempelhoff Beeld, Media 24 21 May 2009 Key Stakeholder Workshop, Randfontein

The feasibility study needs to run its course. Through this process employment opportunities at the treatment plant and during construction will be identified. Initial estimates of employment opportunities described in the Draft Scoping Report.

How are socio-economic issues incorporated into the public participation process?

Mr Aaron Tsoku Mogale City Local Municipality


A full public participation process is being run. In addition, the study includes social impact assessment and macroeconomic impact assessment.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseAt the workshop you mentioned that old pipe lines (right of way) may be used. Alternatively the laying of new ones will only create temporary work and a maintenance crew can serve the entire setup. There is no advantage for the locals whatsoever as far as job creation is concerned. How many people does it require to run a properly maintained pump station?


22 May 2009 E-mail The proposed project is motivated to address an environmental need. Job creation is not the primary objective. Potential employment creation through the project will be elaborated on in the Draft Scoping Report.

SURFACE WATERImpacts on the Blesbokspruit should be carefully considered. Discharge to the Spruit should be reduced.


29 April 2009 Comment Sheet Changes in the volume of water being discharged to the Blesbokspruit will receive consideration in the hydrology and ecology specialist reports.

If reduced discharge is studied, please also look at other upgrades in the area, such as Welgedacht.



We understand this to referred to upgrade of existing water treatment plants in the region. The impact of changing the volume of pretreated water discharged Blesbokspruit will receive consideration in the hydrology and ecological specialist studies.

Currently 100 tons of salt are discharged into the Tweelopiespruit per day. (Reference: www.geoscience.org.za.)


05 May 2009 Letter The proposed project is motivated by the need to restore the water level in the Western Basin to a level below ECL, and provide a solution through which water in the Eastern and Central Basins can be managed below ECL in a self sustaining manner into the future.

Water pollution should be studied. Ms Lebo Molefe City of Johannesburg 07 May 2009 Comment Sheet The proposed project provides a mechanism to manage water level within the mining compartments at a level that is below ECL. This will prevent contamination of shallow groundwater resources through contact with mine water in the underlying mining compartments. Risk to the environment through accidental release from pipelines will be addressed as part of the impact assessment.

The impacts on the RAMSAR site will be minimal. The site has a dam and its water is clearly contaminated as a yellowish colour can be seen in the water.

Mr Daniel Motaung Gauteng Department of Agriculture Conservation and Environment


Noted. The hydrology and ecology specialist studies will address impacts associated with change in the volume of water discharged from Grootvlei Gold Mine (Pamodzi)to the Blesbokspruit.

Do we stand a chance to loose Germiston lake as a result of the proposed project?

Mr Cliff Patterson Ward Councillor, Ekurhuleni Metro


As part of the proposed project, current underground water levels will be maintained. The proposed project will prevent decanting of contaminated water on surface and thus will prevent the contamination of surface water resources, such as Germiston Lake.

The proposed project is a long term solution. Will there still be a need to discharge partially treated water?


The aim of the project is to sell as much water as possible to generate an income to ensure that the project is self-sustainable, so there should not be need to discharge partially treatred water.

Will pre-treated water continue to be discharged into the RAMSAR site located at Grootvlei?


It is likely that during phase 1 some pretreated water will continue to be discharged down the Blesbokspruit. An ecological reserve determination on this river system is under way (Department of Water and Environmental Affairs). This will determine the minimum water requirements to sustain ecosystems with in this system. Our current understanding is that there is a surplus of water in the system.

Please make sure that assessments of impacts on all catchments and rivers in the study area are done in the specialist studies. This includes the Blesbokspuit and the Tweelopiespruit.


Where relevant to the project studies will be done. The impact of change in discharge of pretreated water to the Blesbokspruit and Tweelopiespruit will be assessed in the EIA.


http://www.geoscience.org.za.)

Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseIt seems that upon commencement of the proposed project, the pre-treated water that is currently being discharged into rivers will now be taken out of the system and reclaimed as part of the proposed project. What impact will this have on streams and rivers in the already environmentally sensitive area?



Pretreated water is currently released down the Blesbokspruit from Grootvlei Gold Mine (Eastern Basin)and down the Tweelopiespruit (Western Basin). In Western Basin, where water level within a compartment will be dropped to below the ECL. In the Eastern Basin some pretreated water will continue to be discharged to the Blesbokspruit. These questions will be addressed in the hydrology and ecology specialist studies the form part of the EIA.

Rivers and Wetlands that will be involved include Wonderfontein Spruit, Tweelopiespruit, Klip River, Hugenotespruit, Mooi River, Leeuspruit, Loopspruit, Vaal River, Cradle of Humankind, Crocodile and Jukskei Rivers.


18 April 2009 Comment Sheet Those watercourses which could potentially be impacted on as a result of the proposed project include those where partially treated mine affected water is currently being discharged into (e.g. Blesbokspruit, Tweelopiespruit), those where pipeline crossings will be located (new and existing pipeline/watercourse crossings) (e.g. Natalspruit), and the greater catchment specifically in terms of salt load (e.g. Vaal River).

The entire issue with the Millsite/Mintails site forms part of this operation and once again it is separated from this project - the old divide and rule principle. Tweelopiespruit is pouring out between 20 and 70 Mℓ per day into the Cradle caves system, the entire area north of Krugersdorp game reserve. Let us, if necessary, implement a bit of Gunboat Diplomacy.


18 April 2009 Comment Sheet The proposed project provides a self-sustaining solution to treat to potable levels excess water within the circuit. The proposed project is motivated by the need to manage excess water emanating from mines with in the Witwatersrand. The urgency of the situation in the Western Basin is noted

You have not allowed for future shenanigans of the mines on both West and East Rand. Furthermore, the Steenkoppies aquifer (next to the Krugersdorp Game Reserve) is being flooded by the contaminated decant. People are forming a Water Users Forum there. How will your actions influence them? It is an agricultural area and the ingress from Tweelopies' decant next door is in the direction of this aquifer. Thus, Blaaubankspruit, the Cradle, the peat fields in Tarlton, in addition to the present contamination of Rietspruit are all in danger.


22 May 2009 E-mail The proposed project is motivated to address these specific needs through a partial reduction in the water level in the Western mining compartment to a level that lies below the environmental critical level.

Refer to the environmental study conducted for the Tweelopiespruit catchment area by Stefan du Toit some time ago. It could be very useful for this EIA study.



Thank you for this valuable information.

How will the potential contamination in the entire Cradle of Humankind area be cleared up?



The answer to this question lies outside of the scope of the current EIA. The proposed project will stop decant to the Tweelopiespruit.

Every region must have its water quota to wash the treated mine water through streams, lakes, dams and wetlands during the dry season.

Ms Hendrika Zwanziger WESSA 30 April 2009 Comment Sheet The proposed project will reduce the salt load currently reporting into the surface environment as part of the pre treated water stream. This will be an environmental benefit. The consequence of this reduction in discharge of pretreated water will be evaluated in the hydrology and ecology specialist studies. This will include the secondary benefits of being able to reduce the volume of "flushing water" due to reduction in salt load within the system.

TREATED WATERIf there is a chance that the water quality may deteriorate, who will be held responsible and accountable?



The issue of water quality in the Central Rand Basin will be addressed in the water quality specialist

What are the implications of the use of Barium which is highly toxic? Dr Richard Doyle Environmental and Remedial Technology Holdings (Pty) Ltd

13 May 2009 Comment Sheet Barium carbonate will be used as the primary input chemical. In the form as barium carbonate, it is not toxic. Risk associated with the use of Barium will be addressed through the impact assessment process


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseWho will be the regulator of the water quality process and who will monitor the process to ensure polluted water is not distributed?



The proponent will apply to Department of Water and Environmental Affairs an integrated water use licence. The potable water that is generated from the treatment plant will be tested by Rand Water prior to receipt of this water into the system. Thus constitute independent quality control.

What will the quality of the treated water be? Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of Johannesburg

The treated water will under all operating conditions meet South African drinking water standards and Rand Water requirements.

The project must ensure that the standard of potable water quality to be produced must be in line with that of Rand Water.

Dr Bethuel Sehlapelo Rand Water 04 May 2009 Comment Sheet Agreed. A potable water holding facility is proposed to ensure adequate quality controls that allow testing, holding and dispatch of only water meeting the required potable water standards.

What will WUC charge Rand Water for the treated water? Mr Danie Van der Merwe Water Services, Ekurhuleni Metro


No agreement has been reached in this regard. WUC financial model is based on selling the reclaimed water at a price comparable to the current retail cost of municipal water in the Gauteng area.

The BID indicates the human risks in drinking water that may have contained toxic materials such as uranium and cyanide and in the case of the central areas may even contain Cr6. We recently heard that 22 municipalities could not keep to the legal water quality when using fresh rivier water - here we want to treat water infected with Uranium and possibly Cyanide. The Gauteng population will be drinking an paying for this potentially toxic water.


17 May 2009 Comment Sheet Water will be treated to published South African drinking water standards. There will need to be various checks and balances within the treatment plant system to ensure that these requirements are met. Treated water holding facility is proposed to enable testing, handling and dispatch of potable water under controlled conditions. The testing of the treated potable water will be carried out by the receiving bulk water utility to ensure that the potable water generated from the treatment plant meets the required potable water standard, prior to transfer of this water into a the Rand Water Klipriversberg bulk water reservoir.

No risk assessment is provided for, when 11 million South African may be affected.


17 May 2009 Comment Sheet No water will be introduced into the Rand water system that does not meet South African drinking water standards and Rand water requirements. The delivered water quality will be evaluated as part of the impact assessment.

Is there anywhere in the world where people drink AMD water, contaminated with, amongst others, cyanide and uranium?

Mr Zwi Wagner Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder Workshop, Brakpan

Acidic saline water from the coal mining industry in South Africa is successfully desalinated, in that instance through reverse osmosis technology, and used to augment potable water supply (25Mℓ/d) in the Emalahleni Municipality.

What is the projected cost of the water that will be sold? Mr Zwi Wagner Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder Workshop, Brakpan

No agreement has been reached in this regard. WUC financial model is based on selling the reclaimed water at a price comparable to the current retail cost of municipal water in the Gauteng area.

A recent report published, reflected on the current quality of potable water at 98 South African municipalities. Of the 98 municipalities, only 22 municipalities’ water complied with the required standards for potable water. This included municipalities that used fresh, stream and rain water as source water. If the quality of potable water is already so poor, is it not advisable rather to treat AMD for industrial use, rather than for potable use? There are heavy metals in AMD, such as chromium 6, cyanide and uranium, and these are potentially very dangerous.


Water will be treated to acceptable South African drinking water standards. There will need to be various checks and balances within the system to ensure that these requirements are met. A treated water holding facility is proposed to enable testing, handling and dispatch of potable water under controlled conditions. The testing of the treated potable water will be carried out by the receiving bulk water utility to ensure that the potable water generated from the treatment plant meets the required potable water standard prior to transfer of this water into a the Rand Water Klipriversberg bulk water reservoir.

Municipalities are not supposed to distribute water that isn’t up to the required standards, but it happens.


The potable water that will be generated will be subject to independent testing by Rand Water to ensure that it meets their quality requirements before water is introduced into the Rand Water system.

Will the water be chlorinated at the Kliprivierberg Reservoir? Mr Peter Withinshaw City of Johannesburg 08 May 2009 Meeting with City of Johannesburg

Chlorination will occur at the centralised WTP site before pumping to the Rand Water Klipriviersberg Reservoir.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseTREATMENT TECHNOLOGY

Will the CSIR technology be piloted here or has it been tested before? If the former, how certain is the CSIR of the technology’s efficacy and low impact on the environment?

Mr Garth Barnes WESSA 01 May 2009 Letter The proposed technology has already been piloted and demostrated to be effective. The Specialist Studies will contain more information on the treatment technology.

The project proposes an environmental risk to the region if the technology does not work at scale.


13 May 2009 Comment Sheet The legacy issues of mining pose a significant environmental risk, which has been known for many years. WUC, on behalf of the affected mines, propose a solution to this problem. This does not preclude any other parties from pursuing ventures of their own subject to receipt of the necessary buy in from the mining industry and government. should the proposed treatment technology not work, it would not pose risk to the environment beyond that which currently exists.

Could you give me an indication of the operating costs ? Mr Hugo Grobler Umcebo Mining 25 May 2009 E-mail The cost and financial aspects of a mine water reclamation project are very project specific. It is not prudent to extrapolate from this project to any other project. The project is financially viable if the potable water is sold at a price comparable to the current retail price of municipal water in Gauteng.

If coal is used, it may impact on roads and infrastructure during transportation.

Mr Smuts Marais Water Quality Manager, Ekurhuleni Metro


WUC is currently investigating the use of an existing railway siding located in the vicinity of the proposed Water Treatment Plant site.

I have just been approached by a company that has technology to remove radioactivity if this is an issue. They are now considering whether they wish to join a consortium of technology providers who were excluded from the first round.

Dr Anthony Turton Lit Creations 21 May 2009 E-mail As indicated in the response about (issue 243) the proposed solution is a private sector initiative. Technology providers are welcome to contact Western Utilities Corporation to discuss technology matters, should they have products that they wish to market. The Western Utility Corporation initiative in no way precludes other companies from pursuing initiatives of their own

The Water Treatment Plant will require thermal heating with coal as the source of energy. Have other methods of thermal heating been considered?



It is proposed that coal fines, a waste product, be transported from nearby coal mines to the proposed Water Treatment Plant site. There is a source of at least 25 years available. As part of the treatment process, a steam turbine will also generate power for use in the process. Future expansions to the project can address coal consumption and alternatives like gas.

What about air pollution? How much sulphur dioxide will be released into the air daily? Refer to Air Pollution and Its impacts on the South African Highveld; Editors G Held, BJ Gore, AD Surridge, GR Tosen, CR Turner, and RD Walmsley.


18 April 2009 Comment Sheet An Air Quality Impact Assessment will be conducted as part of the EIA.

The two plants that the proposed technologies were tested at – are they still operational?


This will be confirmed.

Is it viable and safe to move the project from a very small scale pilot plant to a very big scale mega plant?


This is a key decision that the proponent company will evaluate in their feasibility study. It is fundamental to the investment decision.. The WUC process is a 5 stage process, of which 2 are already operated at scale. The fourth is the recovery of barium carbonate and the fifth is the production of elemental sulphur.

The ABC process has not yet been tested on full scale. Prof Frans Waanders Northwest University 21 May 2009 Key Stakeholder Workshop, Randfontein

This process has been subject to pilot scale. It is common practice for such testwork to be scaled up. This is fundamental to the proponents investment decision and forms a key component of the ongoing feasibility study..


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseThe price of barium sulphates, for instance, is very high. WUC won’t be able to sell water for the price they indicate if they have to buy barium sulphate.


The proposed process involves recovery and reuse of Barium Carbonate.

The issue of the Acid Mine Drainage (AMD) solution by the Western Utilities Corporation was brought to our knowledge only on May 15, 2009. This surprises us completely as we are discussing the problem of eliminating toxic water accumulating in mines and already supplied equipment that will do exactly that, to miners in South Africa. Our environmentally friendly technology can be used as an alternative/complementary to the proposed WUC solution. I include a one page introduction of our approach to AMD and mine water excess of water balance reduction with the objective of meeting the requirements of Zero Effluent Plant, in an economical and environmentally friendly process/technology. (Pamphlet available)


17 May 2009 E-mail The legacy issues of mining pose a significant environmental risk, which has been known for many years. WUC, on behalf of the affected mines, propose a solution to this problem. This does not preclude any other parties from pursuing ventures of their own subject to receipt of the necessary buy in from the mining industry and government. Should the proposed treatment technology not work, it would not pose risk to the environment beyond that which currently exists.

We reserve the right to register, because of the fact that our company has been prejudiced because of the short time available to respond. Our company believes the choice of the WUC technology was biased by not including alternative water treatment technologies such as ours. In other words, we are concerned that this was not a free and fair selection process.


17 May 2009 Comment Sheet Western UtilityCorporation has the right to evaluate technology and select technology at their discretion. This does not preclude any other parties from pursuing similar ventures.

Open the [technology] selection process, make it public domain and let the public decide. Test and compare the alternative solutions and technologies with the emphasis on public safety and environmental sustainable solution.


17 May 2009 Comment Sheet Western Utilities Corporation has the right to evaluate technology and select technology at their discretion. This does not preclude any other parties from pursuing similar ventures.

We have been in discussion with mining companies regarding treatment of AMD for five years. We have an alternative technology which will reduce scale in the water and limit the need to pump AMD. The technology will allow mines to directly re-use excess water, reducing the purchase of treated water, and saving on the capital and operating cost of the WUC scheme. Our UET water treatment technology is an alternative/complementary environmentally friendly and viable solution. (Comment summarised - full text available)


19 May 2009 Comment Sheet & E-mail

Thank you for this information. Your technical suggestions and your contact details have been provided to Western Utility Corporation. This EIA process however specifically addresses the proposed WUC scheme. A solution that would be implemented at the level of an individual mining company would need to be taken by yourselves directly to that company. The WUC proposal in no way precludes you from pursuing such ventures.

At what rate was the Pilot Plant at the CSIR run? Mr Zwi Wagner Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder Workshop, Brakpan

At one cubic metre an hour (24 cubic meter per day).

Is it possible to construct a Pilot Plant as a potential solution to people without water?


Licences need to be obtained before water can be sold, and that approval process is now being followed by WUC.

Does the pilot plant need authorisation to be constructed as a mega plant?


Yes, this is the subject of the current EIA.

The technology to treat the AMD seems very specific; can it be used for other water treatment processes as well?



This would need to evaluated based on the chemistry of the water that you had in mind. We suggest you contact the proponent directly to have this technical exchange.

WASTEWhat measures will be put in place to ensure that the waste metal sludge and waste gypsum do not become an environmental hazard due to an over burden on the existent waste facility?

Mr Garth Barnes WESSA 01 May 2009 Letter These wastes are currently disposed of on to existing tailings dams. This practice will continue in the interim, within the operating parameters of the tailings dams. Western Utility Corporation seeks to turn these wastes into byproducts.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseHow will the ash be re-used? Mr Garth Barnes WESSA 01 May 2009 Letter Waste handling is being investigated as part of the feasibility study. The

consequences of waste disposal on the existing tailings dams will be addressed in the impact assessment.

How will the sludge and ash on the tailings facility be managed? Mr Garth Barnes WESSA 20 May 2009 Key Stakeholder Workshop, Alberton

In terms of managing the sludge and ash on the existing tailings facility, an agreement between the mines and WUC will be compiled.

There is a lack of clarity on the disposal of effluent (not an effluent free solution).


13 May 2009 Comment Sheet There are ongoing waste studies that form part of the feasibility assessment. As indicated the sludge and coal ash residue will in the interim be disposed on mine tailings dam.

WUC needs to take cognisance of the NNR restrictions on the re-use of materials which could have potential radiological risks during their feasibility studies on the possible conversion of the sludges emanating from the proposed Water Treatment Plant into cement clinker, bricks, etc.

Mr Mogwera Khaothane Zimkile Consulting 20 April 2009 Meeting with National Nuclear Regulator

Radiological testing of the sludge had been done as part of the pilot plant studies. Thank you for this comment.

Impacts of disposal of waste at an existing mine waste disposal facility including information on the name of the facility, ownership and rehabilitation plans should be made available.

Ms Lebo Molefe City of Johannesburg 07 May 2009 Comment Sheet Noted. Thank you.

Will a new slimes dam be constructed? Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of Johannesburg

Sludge will be disposed of at an existing Tailings Storage Facility (TSF).

If there is a zero waste factor for this project, how will the sludge be treated?



WUC is in the process of investigating the feasibility of the converting the sludge generated during the treatment process to cement clinker, bricks, etc. In the interim, it is proposed that the sludge be disposed of at an existing tailings storage facility.

Can the waste be treated or converted to be used to make bricks for houses.



WUC is busy with ongoing investigation into creating byproducts from waste streams.

What happens to the ash that is produced as part of the process? Ms Vicky Shaw WESSA 19 May 2009 Key Stakeholder Workshop, Brakpan

WUC is busy with ongoing investigation into turning waste streams into byproducts. In the interim the pretreatment plant waste and ash will be disposed of on existing tailings dams.

My understanding is that WUC is investigating the future re-use of the sludge which will be generated during the water treatment process, but it requires disposal in the interim. The sludge will have to be disposed of at a lined facility.

Mr Jurgo van Wyk Department of Water and Environmental Affairs


Mine water treatment plant sludge is currently disposed of together with mine tailings onto tailings dams. Discussions are underway investigating continuation of this interim disposal, or new disposal options.

It is not ideal to dispose of the sludge at a mine tailings facility. Will the tailings facility become WUC’s responsibility?



Sludge from existing pre-treatment plants is currently disposed of onto existing tailings dams. WUCproposes to enter into an agreement with the mines to continue with this practice until such time as an alternative has been developed.

How will an agreement about a temporary tailings facility affect a mine closure authorisation from the Department of Minerals and Energy?



During the interim deposition period of 5-8 years, the dam will remain active and closure would not be possible. Thereafter, the normal mine closure process could run its course.

Please investigate whether it is safe to use sludge for brick making. Mr Eugene Viljoen Resident, Noordheuwel


Yes, this forms part of the investigation into bringing the water treatment sludge to beneficial use. This study will be ongoing beyond the extent of the EIA process


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseWATER SOURCES

If there is a chance that the water quantity may deteriorate, who will be held responsible and accountable?



The issue of water quality in the Central Rand Basin will be addressed in the water quality specialist.

Who will be responsible for the shafts and pump stations at depth, subsequent to mine Closure.



WUC will be responsible at mine closure; pumping from depth will no longer be required as the underground workings will be flooded. It is proposed to isolate the shaft barrel, at which time WUC will take responsibility, allowing mines to apply for closure

Why will the mine water pumped to surface at the Western Basin not be pre-treated before being pumped to the Central Basin, especially since there is an existing treatment facility in the Western Basin?

Mr Justice Maluleke Department of Water and Environmental Affairs


Western Basin water will not be taken directly to the centralised water treatment plant. It will be reintroduced into the western portion of the Central Basin workings, from which water will be abstracted 40 km away close to the plant site. It would be a costly exercise to pre-treat the water and then allow it to be acidified again as it flows through underground mine workings in the Central Basin.

Will the mines continue with pre-treatment? Mr Justice Maluleke Department of Water and Environmental Affairs


The mine in the Eastern Basin, i.e. Pamdozi Gold's Grootvlei Mine, will continue with pre-treatment during Phase I.

The quantity and quality of the water to be treated should be clearly stipulated in the application.



Mine affected water from the Western Basin was used for the pilot plant. Was water from the Eastern Basin also used in the study, as this water is high in sodium and chloride?

Ms Annemarie Maurizi Water Quality Manager, Ekurhuleni Metro


Only water from the Western Basin was used for the pilot study as the water in the Western Basin has the poorest quality. It is anticipated that the proposed technology will not be affected by the monovalent ions in the water from the Eastern Basin.

Is it correct that the Central Basin has an underground water reservoir of unlimited water supply?



Water will accumulate in old mine workings from a variety of sources including ground water ingress and infiltration of water from surface. This does not create an unlimited supply but, if roughly the volume of water flowing into the old workings is taken out of the workings for treatment, does become an ongoing source of water.

Will the mine affected water taken out from the underground voids, only be limited to the fill-up/ingress area?



Yes, WUC is not proposing to dewater the underground voids, but to remove what is flowing into the voids, i.e. water ingress. In the Western Basin, however, the rate of water abstraction from the Western mining compartment will purposely be higher than the recharge rate, in order to drop the water level in this compartment to a level that is below ECL in order to stop decant to the Tweelopiespruit from this compartment.

Why will water from the Western Basin be pumped to the Central Basin?


Because of the tight timelines associated with the proposed project, and the eminent urgency that AMD needs to be addressed to avoid it reaching an environmentally critical level, a short-term solution needed to be found that would address the problem within 2 years. A 7 km pipeline connecting the Western Basin to the Central basin seems a doable target. A parallel EIA process is also being conducted because of the tight timelines.

What will the effect of mine closure be on the project? Mr Mike Sullivan Central Rand Gold 26 March 2009 Authority Steering Committee Meeting

A considerable volume of water within these three mining basins is currently used to sustain the operational water requirements of the gold mines. As mines close, additional water will become available for treatment and reuse. Approximately 325 Mℓ/day of water will be available for treatment upon cessation of all mining activity within the four basins.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseThere is no study of the total RW used by the mines. Such a study may confirm our concern that this is the cause for AMD rise.


21 May 2009 E-mail Thank you for this general comment. Such a study will not be done as part of the scope for the water treatment project EIA.

Is the 75Mℓ that is mentioned to be the amount of water that will be treated the balance of water after the mines have taken water for their own use? Why can’t the mines use this water themselves?


The proposed water treatment plant will treat an average of 75 Mℓ of water per day with peak throughput capacity for 100 Mℓ of water. This water is largely surplus to the mines re-use capability. Pretreated water is currently discharged to the environment in both the Western and Eastern basins. This pretreatment is in effect neutralisation only. The water is discharged bearing a salt load.

What does the blue-circled section to the west of the three basins represent?



Of this this indicates the Far Western Basin. At this stage, this basin does not form part of the current scheme that may be included during proposed phase 2 ramp up of the scheme.

WATER TREATMENT PLANT SITEWhere will the centralised Water Treatment Plant be constructed? Details of impacts on the receiving environment should be provided.

Ms Lebo Molefe City of Johannesburg 07 May 2009 Comment Sheet This information will be provided in the draft scoping report

Where is the nearest community in relation to the WTP? Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of Johannesburg

There is an informal settlement adjacent to the proposed WTP site.

OTHER COMMENTS AND ISSUESIn view of the need to look at the long-term issues and problems of the mining areas and recognising the contribution of pollution from the surface of the mining areas to the problems of AMD, I request that the concepts and ideas regarding Project Hloekisa be taken up and recognised at this stage of the project. The focus of this project is the reclamation of the mining land areas and their release for urban development and requires close collaboration and cooperation between all the stakeholders, in particular the mining companies operating through the area, to ensure a collective and sustainable solution. The cleanup of the surface area would also reduce the levels of pollution which would have to be addressed by the Water Treatment Plant and therefore ultimately contribute to reduced costs. have attached a copy of a concept document prepared a few years ago which sets out some of the principles and ideas regarding this project for your consideration.


20 May 2009 E-mail Thank you for this information. The underground water quality is however to a large extent determined by geochemical processes that take place on exposed rock surfaces with in the underground workings

I support the proposed project, and the work done on it so far is commendable. However, a long-term solution needs to be put in place that will also address future environmental issues. Surface water is also a problem in the study area: if surface cleaning is applied concurrent with addressing AMD, about 16000 ha of land could be released for future development.



Thank you for these comments.

Add-on modules to the proposed project, such as surface clean-up, need to be recognised and put in place before the project commences.



WUC is a water treatment company. It is not involved with clean-up of mine land.

Will the coal required for the kiln be procured from a reputable company?

Mr Garth Barnes WESSA 01 May 2009 Letter Thank you for this comment. The project is currently at feasibility stage. Specific market suppliers of coal have not yet been considered.

How will financial and environmental liabilities be transferred to WUC once the water reclamation process is operational, particularly since some of the mines are still operational? Will WUC assume full responsibility for the financial and environmental costs of the project?


Liabilities will remain with the mines until WUC can prove that the project is self-sustainable. Once the project is proven to be self-sustainable, the mines can apply for Closure and the financial and environmental liabilities will be transferred to WUC.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseThe commitment by government to one service provider only may lead to the premature adoption of a sub-optimal solution to the problem at hand.


13 May 2009 Comment Sheet Government has tasked the mining industry with finding a regional solution to closure of mines and management of shared liability around water. Through this initiative, Environmental Corporations have been established in consultation with Government. These Environmental Corporations have contracted with Western Utility Corporation to act on their behalf to implement the proposed solution. This does not indicate a commitment of Government to one service provider, merely that the proposed solution is acceptable, in principle, to Government. It does not preclude other service providers from pursuing ventures of their own.

The project proposes an environmental risk to the region if WUC does not raise funds (because of economics or other).


13 May 2009 Comment Sheet If funds for the project are not raised, the project would not go ahead. This would not introduce any additional risk over that which exists at present. The project proposes a solution to the current problems associated with recharge of mine water with in the underground mining compartments.

Our organisation would like to do a presentation. Mr Willy Fuzani Umlambo Pride Bee Construction Projects

30 April 2009 Comment Sheet Please would you contact the public participation office to clarify this request.

I have seen a few articles on gold mine AMD and the plant WUC is proposing.We are in coal mining and also have similar problems. In terms of sustainability of such a project (to treat the water), what are ball park figures for treating the water and at what price is it envisaged to sell to Rand Water ?

Mr Hugo Grobler Umcebo Mining 23 May 2009 E-mail The cost and financial aspects of a mine water reclamation project are very project specific. It is not prudent to extrapolate from this project to any other project. The project is financially viable if the potable water is sold at a price comparable to the current retail price of municipal water in Gauteng.

There is urgency with regard to the implementation of the proposed project since pumping of mine water ceased at ERPM.




Relating to the many e-mails that have been doing the rounds condemning the use of mine voids to transport water, etc, whether we like it or not, this is already occurring to a certain extent in certain parts of the mine voids and if we continue to argue about it, it is going to happen anyhow. We have known about the looming disaster since 1996 and have opted to do nothing (or very little) about it. We now only have months left to "save" what's left of the Central Rand Basin (i.e. the bit that is not already flooded). In 1996, we still had time to do something about the problem, at present we do not! We have wasted our time talking about the problem or ignoring it, hoping it would go away if we ignore it for long enough; the little time we now have left is to implement solutions, whether the solutions have been tested or not, we simply do not have time to test or argue about the solutions on the table, we can only implement them, as is! That's all we have time for. I hope this will spark a more positive approach towards the problem.


20 May 2009 E-mail Thank you for highlighting the urgency of the problem. These are the fundamental issues that drive the need to implement solutions such as those proposed by Western Utilities Corporation.

Current and future rehabilitation of contaminated soil should be taken into account.

Mr Frans Le Grange Exotic Properties 22 May 2009 Comment Sheet Please address concerns regarding soil contamination directly to the relevant mining companies.

Mine dumps containing AMD contaminants, should be kept separate to prevent contamination of run-off water.

Mr Frans Le Grange Exotic Properties 22 May 2009 Comment Sheet Thank you for this comment. It does not appear to have relevance to the proposed water treatment project.

Why are studies duplicated between WUC and the Department of Water and Environmental Affairs?

Ms Irene Lea Pamodzi Gold 26 March 2009 Authority Steering Committee Meeting

Where ever possible existing and available information will be drawn upon to inform the project feasibility and the EIA process


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseIn substantiation, I append hereto the instructions and directive which were brought against West Wits Mining by the Department of Minerals and Energy. At the time of writing, West Wits Mining (affiliated to DRD GOLD) continues to be in flagrant non-compliance with the instruction and the directive of Department of Minerals and Energy.


05 May 2009 Letter The need to manage excess mine water is the primary motivation behind this project.

AMD is responsible for costly environmental and socio-economic impacts.



AMD is characterised by low pH (high acidity), high salinity levels, elevated concentrations of sulphate, iron, aluminium and manganese, raised levels of toxic heavy metals such as cadmium, cobalt, copper, molybdenum and zinc, and possibly even radio nuclides. The acidic water dissolves salts and mobilises metals from mine workings and residue deposits.



AMD is not only associated with surface and groundwater pollution, but is also responsible for the degradation of soil quality, aquatic habitats and for allowing heavy metals to seep into the environment.



We refer to page 2 of the BID. We here express great concern regarding the poor environmental performance and bad corporate reputation of two of the Applicant's proposed partners, namely Central Rand Gold and West Wits Mining SA. We have little confidence, grounded upon current and historical unlawful conduct, that the said mining companies will lawfully "develop and implement a sustainable solution to the mine water issue."


05 May 2009 Letter The proposed project will be implemented by the Western Utilities Corporation, on behalf of the mining industry. The project will not be implemented by the mining companies themselves.

CRG-SA refused members of affected communities and registered I&APs access to its approved EMP notwithstanding the fact that requests were made in the prescribed format in terms of the requirements and provisions of the Promotion of Access to Information Act, No 2 of 2002 and notwithstanding the fact that CRG-SA is currently conducting an EIA process for the amenDepartment of Minerals and Energynt of its approved EMP. How does interested and affected parties evaluate an amenDepartment of Minerals and Energynt without the document that is being amended? If insufficient information is being supplied it cannot be construed as consultation, but rather as a mere opportunity to make ineffective representations. It is necessary to investigate the original EMP and make comparisons between the predictions and the results of the monitoring as was required in the EMP.


05 May 2009 Letter Please address this comment directly to the mining house concerned. The comment does not relate to the project proposed by Western Utilities Corporation (WUC)

It is alleged that CRG-SA has rescinded upon its agreement with its BEE partner, PUNO and upon the Memorandum of Understanding between CRG-SA and the Affected Communities Elected Representatives (ACER) in terms of its Social and Labour Plan.


05 May 2009 Letter Please address this comment directly to the mining house concerned. The comment does not relate to the project proposed by Western Utilities Corporation (WUC).

Certain expert assessments by the Environmental Protection Agency in 1987 concluded that problems related to mining waste may be rated as second only to global warming and stratospheric ozone depletion in terms of ecological risk. The release to the environment of mining waste can result in profound, generally irreversible destruction of ecosystems". (EEB, 2000). In many cases the polluted sites may never be fully restored, for pollution is so persistent that there is no available remedy.


05 May 2009 Letter No mining waste will be generated through the proposed project. Water treatment plant sludge will continue to be produced as the waste stream from the water treatment plant.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseDuring heavy rainfall periods there is AMD seepage into the Wonderfonteinspruit. Radio nuclides are concentrated in sediments of the Wonderfonteinspruit, downstream of their sources. Sequential extractions showed that these radio nuclides are distributed in multiple phases within the sediments of the Wonderfonteinspruit and that they may be remobilised by environmentally plausible chemical processes such as AMD.


05 May 2009 Letter The proposed project is motivated by the need to restore the mine water level in the Western Basin to a level below ECL, and provide a solution through which water in the Eastern and Central Basins can be managed below ECL in a self sustaining manner into the future.

Is this project sustainable? How many years will the project last? Mr Victor Manavhela Gauteng Department of Agriculture, Conservation and Environment


The project will be self-sustaining. Overseas investors will provide funding for the project. Western Utility Corporation is transparent about how they will recover costs by selling potable water to end users during the operational phase of the project. The phase 1 project configuration has been sized to treat the available water with in the Western, Central and Eastern mining compartment, while certain mines continue to operate. The project phase 2 can be ramped up to treat the required volume of water to maintain these three mining compartments in balance at a level that remains below the environmental critical level, once mines cease to operate.

Since no financial information was presented during the meeting, it is difficult to understand how a project of this nature can be viable or sustainable.

Mr Basie Maree Mintails 26 March 2009 Authority Steering Committee Meeting

A detailed financial model has been developed that could be discussed with Mintails at a separate meeting.

The impacts on existing infrastructure should be considered. Ms Lebo Molefe City of Johannesburg 07 May 2009 Comment Sheet Noted, thank you.

The City of Johannesburg is interested in how the project will impact on their jurisdiction.


You will be kept informed through this process.

WUC/Golder should explain in simple terms the potential impacts of not implementing a solution to the Acid Mine Drainage (AMD) problem.


Thank you. This will be described in the Draft Scoping Report. In summary, Western Basin is already decanting. The Central Basin will decant in 2011 if pumping capacity is not restored within the Central Basin.

The City of Johannesburg has been struggling to find a solution to the mine water problems in its jurisdiction. Will this project only address water, or will it include overall rehabilitation of the mines.


The project is aimed at addressing water issues, and not other mining rehabilitation such as rehabilitation of mine dumps.

The City of Johannesburg needs to understand the problem and the extent thereof.


Thank you. The EIA project team and proponent team remain available to meet with representatives of the City to discuss these matters at any time.

How were the footprints of the different facilities and infrastructure of the project decided?



The project will use existing servitudes as far as possible. Infrastructure such as pilpelines will be laid along existing pipelines on existing servitudes. A number of potential water treatment plant sites were considered. The site selection process will be reported in an alternatives evaluation report which will be an appendix to the Draft Scoping Report.

There are areas between Gauteng and the Free State where underground water form Gauteng crosses into the Free State. Does this project include a strategy to address similar underground water problems in the Free State?



The project addresses excess water with in the Western, Central and Eastern mining basins within the Witwatersrand gold mining area only.

There has never been any comments on this matter from the Department of Water and Environmental Affairs; as far as I know the mining company receives a subsidy from government for pumping the shaft water.

Mr Sidney Osborne Resident, Springs 21 April 2009 Facsimile Certain mines receive subsidy to ensure continuation of pumping and management of water levels with in the mining basins. This subsidy is motivated by the need to continue the mining operations and protect jobs.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseWho is WUC? It was mentioned that the company is a subsidiary of a company listed in London – how does that information tie in with WUC being a South African company?



WUC is a wholly owned subsidiary of Watermark Global Plc, a London listed company. WUC is acting on behalf of WBEC, CBEC and EBEC, which in turn constituted environmental corporations comprising mining companies within the Western, Central and Eastern basin

There were talks some years ago about diverting underground water from Eikenhoff to create another underground lake. Can this be done?



This aspect does not form part of the scope of this EIA.

Could you please, as a matter of urgency, e-mail me the background information document, regarding Western Utilities Corporation's mine water proposal EIA. I am doing a story about the mine water crisis at Pamodzi Gold's East Rand operations and need to see if this proposal is any way related to it.

Ms Mari Scott Springs Advertiser 22 April 2009 E-mail Certainly. These documents can also be sourced directly from www.Golder.co.za

The Western Utilities Corporation proposed Mine Water Reclamation project is a fantastic idea.



If the proposed project goes ahead, and in 30 years it is no longer economically feasible, who will be responsible for continuing with the pumping of the AMD.


WUC has the surface and underground mining plans for the next 5 years of all the mines involved in this proposed project. According to that, calculations were made of the amount of water that needs to be pumped, taking the ingress into consideration, minus the individual water consumption of each mine. Mines will also notify WUC if they plan to close, and that is also included in the calculations. WUC is putting this proposed infrastructure in place to ensure a self-sustainable and economically viable treatment of AMD for the entire Witwatersrand basin even after closure of the mines.

I fully support your proposed action regardng pumping out and purification of mine waters. This is particularly important to also prevent the penetration of acid mine water into overlying dolomites which are chemically basic.

Mr John Smit Mine Managers Association of SA

24 April 2009 E-mail Noted. Thank you

How will WUC ensure that a mining company that takes over one of the participating mines, agrees to be part of the project?


The proposed project is part of a proposed regional closure strategy for affected mines. Department of Minerals and Energy requires the company to sign an agreement to be part of WBEC/CBEC/EBEC.

R65 million has been spent already on the project. How much will the entire project cost?


The capital estimate of the project is being confirmed through the feasibility study that is currently running.

One concern is the fact that WEBC is a creation of the mining industry and is also being positioned as the final selector of technology. This means that they are both player and referee. I proposed the establishment of an independent Adjudication Panel that would adjudicate all technologies and then make a recommendation to the Minister as this would protect her from being accused of doing a private deal (the Arms Deal debacle in the water sector).

Dr Anthony Turton Lit Creations 21 May 2009 E-mail The technology selection is being done by Western Utilities Corporation and its private sector parent company, on behalf of the mining industry. This remains a private sector initiative, not a Government initiative.


http://www.Golder.co.za

Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponsePlease note that my partner, Dave Gadd-Claxton, and I have written a formal letter to the Minister raising some of our conerns about the lack of viable alternatives from which to choose. This was done on advise from her personal advisor with whom we have direct contact. One of the issues we raised was the one mentioned in this attachment, namely the paradigm in which the problem is being formulated - as a mine closure problem versus a national strategic problem based on a transition from an extractive economy to a value-added economy. I did an interview with Sunday Times on the latter so read it and see what we mean. The former paradigm gives us what we have - the WUC proposal. The latter has not even been considered seriously, but could potentially see Mogale City becoming a new industrial hub that generates more jobs in beneficiation-styled industry than are being lost by mine closure. This is a high-level strategic choice that would ideally need to be driven from Mr. Trevor Manual's office, but it would also need high level buy-in at Mogale City level. It would need visionary leadership and robust partnerships between the public sector and private sector to make it happen, but it is doable.

Dr Anthony Turton Lit Creations 22 May 2009 E-mail Thank you for these comments.

Let us see what the response is before we get too heated about this. Let us make future decisions based on solid information rather than perceptions. Our complex history must not become an impediment to our potentially better future. It is to the future we must apply our minds because that is where we will live the rest of our lives.

Dr Anthony Turton Lit Creations 22 May 2009 E-mail Thank you for these comments.

The sense of urgency of the proposed project is somewhat artificial. Also, the problem with AMD in the Witwatersrand has been known for a long time.

Dr Anthony Turton Touchstone Resources (Pty) Ltd


Yes, these problems have been known for many years. Collectively however these issues have not been addressed. The Western Basin is decanting and, the loss of the ERPM pump station in the Central Basin does as a measure of real urgency before similar problems are experienced in the Central Basin.

The entire proposed project and what it attempts to address, is complex and raises a number of emotive issues. Congratulations to WUC on good work done so far. However, it is a concern that the Department of Water Affairs has been presented as the only stakeholder. This is incorrect: there are 11 million stakeholders that need to be involved. If an agreement regarding this proposed project is signed ‘in secret’, it will be like the ‘arms deal’ of the water sector. Have all alternatives been considered? The WUC effort is indeed laudable, but is it giving ‘the people of South Africa’ the best alternative? Consultation methods such as corporate governance and an adjudication panel should be put in place to ensure that public consultation is done on a much bigger scale.



These comments relate largely to the need for broad communication, above the level of individual projects. Within the context of the current EIA process, specific questions relating to impact of the proposed project will be addressed, and directly affected stakeholders engaged with.

At the moment, the project is treated as a mine problem, whereas it is not purely a mining problem. Consultation should be taken to another level and encourage a transition of thought, where the economy in the area is not only seen as a purely extractive economy but rather a move towards a mixed level value-added economy. Instead of addressing the strategic ‘problem’ of AMD, rather look at the situation as a void underneath Mogale City with industrial level water that the municipality can benefit from. However, considering the timelines mentioned, it seems that there is not enough time left to debate the strategic significance of the proposed project.



Thank you for these comments


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseSubsidies from government have been provided to the mines to sustain the pumping of water for the past 25 years. Who will take over the liability for pumping the water?



Once the proposed project is proven to be self-sustainable, the mines can apply for closure and the financial and environmental liabilities (including the pumping of underground mine water to surface) will be transferred to WUC. importantly, once mining ceases within a basin, the water level within the basin can be allowed to rise to below the environmental critical level, at which point at water level needs to be maintained. This will reduce the pumping head with associated reduction in cost.

Note that the tonnages mined in in the West Rand in 1994 require updated information. Note the difference in tonnages mined and that processed. Where did the 196,000 tonnes go? Refer to to the Mine Inspection Report of the WRC, 1996.


18 April 2009 Comment Sheet Thank you. This point is not directly relevant to the current EIA

How many tonnes will be used as backfill and at which slopes and levels. You need to know the type and tonnes to determine possible surface area of water contact for chemical reactions.


18 April 2009 Comment Sheet The current project is sized to handle excess water make in the compartments, taking into account operational water use by the mines. Reduction in void space underground will not influence water make. Thank you for the suggestion regarding consideration of geochemical consequence of backfill. A geochemical assessment forms part of the feasibility study to inform groundwater quality predictions.

What volumes of slimes will be used and the SG at the time of fill or if through boreholes. Where will these be located?


18 April 2009 Comment Sheet Issues pertaining to back fill of underground workings are not deemed relevant to the current impact assessment.

Wits pits is already earmarked for storing slimes and currently used by Mintails for this purpose.


18 April 2009 Comment Sheet Thank you for the comment.

Note the water incursion and supply situation of all mines and report on that.


18 April 2009 Comment Sheet The operational water use of gold mines with in the Western, Central and Eastern basins has been accounted for. Similarly, ingress of water via other pathways informs the water balance.

The Cooke mine is still in operation and now slimes and rock will be used.


18 April 2009 Comment Sheet The Cooke Mine and its facilities do not form part of this project. Comment noted with thanks.

Where will the residue be dumped, as Witfontein is not a viable option, and Raatskraal is not yet authorised?


18 April 2009 Comment Sheet The proposed project is a water treatment solution. Issues related to management of operational mine residues with in the West Rand need to be addressed directly to be affected mining companies.

It is not mentioned at the Rand Uranium (Harmony) Mine Scoping, EIA, EMP meetings what tonnages of residue exist and are not included in the figures fed to the public, or the backfill of whatever nature used over the years. Some of these tunnels/stopes and shafts have already been flooded and contaminated through this. This is the reason for WUC project. We need to know what the mine has been up to underground. Judging by what is happening on surface, the situation must be horrendous.


18 April 2009 Comment Sheet Comment pertaining to operational practice at the goldmines need to be addressed to the mining companies directly.

Will slimes previously used as backfill, but not under water, be processed? We know mines dumped vast tonnages of slimes underground, but water incursion took place, covering or mixing with such slimes. Will these “slimes” albeit of a higher viscosity, be reprocessed and thus open these backfilled areas?


18 April 2009 Comment Sheet Comment pertaining to operational practice at the goldmines need to be addressed to the mining companies directly.


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponsePoisoning of our environment by the mines takes place all in the name of progress, jobs and foreign exchange. Quite frankly, our problems exist because we want to see them in isolation, specialist groups, instead of saying we have problems let us solve it. Clean the present water in situ by filtration plants, sealing off the ingress through re-creating vlei areas,peat areas, evaporation systems, you name it, it’s there. This is still ongoing and observed in 2008. All under old order permits and no policing. (Comment shortened. Full text available)


15 May 2009 E-mail Thank you for this general comment

Lets us first apply common sense; this is a National Disaster and we are at the source. The mines will not pay for it in full, but by proper policing and applications of the present laws, prevent further contamination and deal harshly with those transgressors.



The fact that at least an attempt has been made to address this problem is laudable. However; by your Public admission, for once we recognise that we have a National Disaster on our hands, created by the Mines in general, and the do nothing brigade and I include myself, which has had a field day for years. It has to stop now!


22 May 2009 E-mail Thank you for this comment.

It is not strange that once again the same historical pervasive attitude of Reinecke and cohorts of the 1930`s in and around Carltonville remains as policy for any activities resulting from Mining action. Then, as now, numerous farms were purchased on the quiet, in the Wonderfonteinspruit/ Gatsrand Basin by these groups, with the blessing of the then Government, followed by the legal decant of aquifers in the Oberholtzer and Bank areas. In a similar vain, WUC was formed, now as a saviour, again on the quiet, and the public held to ransom because of the time frames involved, to prevent a disaster on the foundations of City of Gold. Quite frankly, let it remain a Johannesburg problem for the time being, and let them finance the protection of the City out of Johannesburg Funds. Adopt a similar attitude as that of the mines — let's look the source of contention in our own interests first!



Please highlight that the CSIR process proposed will remove the residues from the drugs used such as antibiotics and HIV/Aids and others, to name a few, of these chemical concoctions. I say this as the plans presented appears to be fait accompli.



It is my Constitutional Right, not privilege, that is the only law that will apply. NEMA, WATER, MINING, etc, are subservient to it. That this matter must be solved post haste we all agree, but NOT under the guise of the bone of contention financial restraints. It is a national disaster and must declared as such, to obtain the necessary funding immediately. The very people you need to promote and push for financing from Parliament are absent from the process. The cost to convert your pilot plant on the West Rand to supply potable water should come from both the mining contribution and funds from an emergency slush fund ex the coffers of the Minister of Finances, to get this operational within weeks.


22 May 2009 E-mail The proposed project is a private sector initiative that is not seeking government funding


Comments, Suggestions and Questions Raised Commentator Representing Date Source ResponseIt might be an idea to install a similar plant at Gerhardt Minnebronne to rehabilitate that volume of natural decant (now contaminated) and get the Gold Fields group to supply additional volumes from the south of Gatsrand, Leeuspruit, Kariega, and Loopspruit areas - at a price of course (ppp principal. They have just submitted an application for another super dump - the shards of will once again become evident.



As time is of the essence, may I suggest that a revision of the basic approach to the entire problem take place urgently? Otherwise, hope that the 2002, 150 + year floods don’t cross the Witwatersrand soon.



There is no need to use potable water in the mining process, especially if it impacts heavily on the water table.


Thank you for this general comment

We could not find the name of Goldfields among the mining companies playing a role in the project. Are they not participating?


17 May 2009 Comment Sheet The project is currently confined to the West and Central and Eastern mining basins. Goldfields operations are largely located within the Far Western Basin, which may become part of the scheme at a later date.

Our solution to the AMD issue has never been considered. Mr Zwi Wagner Water Engineering Systems Unlimited

21 May 2009 E-mail Western Utilities Corporation has the right to evaluate technology and select technology at their discretion. This does not preclude any other parties from pursuing similar ventures.

The cause for the AMD rising is a result of the mines pumping Rand Water from Vereeniging/Vaal and disposing it in the Witwatersrand Basin – stopping the mines from using potable water cooling and gland water and replacing it with fissure and AMD will solve the problem and require no special WTP.


21 May 2009 E-mail Thank you for this general comment

Will WUC address the pumping at Pamodzi and take it over from them.


Correct. That will happen when the WUC system is in place. That means that the mine dewatering will have to be addressed by Pamodzi until after the WUC project has been successfully implemented and commissioned.


Western Utilities Corporation Proposed Mine Water Reclamation Project Comment and Response Report

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Transcript of Western Utilities Corporation Proposed Mine Water Reclamation Project Comment and Response Report