You are on page 1of 49

EIA Ref. No.

Gaut 002/09-10/N0095
June 2009

COMMENT AND RESPONSE


ENVIRONMENTAL IMPACT ASSESSMENT
WESTERN UTILITIES CORPORATION MINE
WATER RECLAMATION PROJECT

For public comment from


Tuesday, 9 June 2009 to Tuesday, 14 July 2009
REPORT

Golder Report Number: 12064-8755-1


Comments, Suggestions and Questions Raised Commentator Representing Date Source Response

AIR QUALITY
What sort of emissions (volume and type) will the kiln produce, and Mr Garth Barnes WESSA 01 May 2009 Letter Technical detail on the proposed plant infrastructure will be provided in the
will it be in keeping with air emission standards? 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 Mr Garth Barnes WESSA 20 May 2009 Key Stakeholder This aspect will be addressed in the Air Quality Impact Assessment which
the tailings facility. Workshop, Alberton will form part of the EIA.

A coal-fired furnace will generate CO2, which will offset the benign Dr Richard Doyle Environmental and 13 May 2009 Comment Sheet The benefit of the project includes providing a self-sustaining solution to
effects of cleaning the water – more information is required. Remedial Technology handling of excess water with in the mining compartments. It will have the
Holdings (Pty) Ltd 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 Ms Mariette Liefferink Federation for a 05 May 2009 Letter Technical detail on the proposed plant infrastructure will be provided in the
taken into account in assessing the risk to affected communities. Sustainable EIA report. An air quality specialist study forms part of the impact
Environment 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 Prof Frans Waanders Northwest University 21 May 2009 Key Stakeholder Technical detail on the proposed plant infrastructure will be provided in the
an air pollution problem. Workshop, Randfontein 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 It is not common; however, there are cases of carbon monoxide being
Johannesburg released underground.

ALTERNATIVES
Why can the mine water not be treated and distributed locally, at the Mr Jurgen Theiss Scaw Metals Group 15 April 2009 Pre-consultation There is a certain economy of scale necessary for the project to be
starting point of the proposed pipeline in the Eastern Basin? meeting 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 Mr Andrew Barker Andrew Barker 19 May 2009 Key Stakeholder The preferred end user is Rand Water. The use of an existing Rand Water
decision taken to pump to that area, and what alternatives have been Development Workshop, Brakpan reservoir is the preferred option.The alternative Rand Water reservoirs
considered? Consultant 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 Mr Garth Barnes WESSA 20 May 2009 Key Stakeholder The Klipriviersberg reservoir is the favoured reservoir. It is significantly
alternative reservoirs for the bulk storage of treated water have been Workshop, Alberton further from the proposed treatment plant site than the Germiston
considered. What will be the drive to use another reservoir and not Reservoir, but has 10 times the capacity of the Germiston Reservoir.
the Klipriviersberg 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 Report


Draft Scoping Repot 1 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
ALTERNATIVES (END USER)
Have technical and financial feasible alternatives been considered in Ms Mariette Liefferink Federation for a 21 May 2009 Key Stakeholder Alternative end users have been considered, including Johannesburg
terms of end users? Sustainable Workshop, Randfontein Water and Ekurhuleni Metropolitan Municipality. See the Consideration of
Environment Alternatives Report.

ALTERATIVES (NO-GO)
What type of ‘disaster’ is envisaged in terms of human health and Ms Samantha Boshoff Water Quality 21 May 2009 Key Stakeholder Should the water levels in the Central Basin be allowed to continue to rise
ecological risk if the proposed project is not put in place? Planning, Department Workshop, Randfontein (i.e. no pumping takes place), the ECL will be reached by October 2012
of Water Affairs (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 Dr Henk Coetzee Council for 23 April 2009 Comment Sheet Assessment of alternatives has, and will continue to be undertaken, as
and evaluated. Two important options are the no-go option and the Geoscience part of the EIA. Comment noted with thanks.
option where the process if technically viable but not financially
sustainable.
If the WUC project does not go ahead, the mines will need to Mr Mike Sullivan Central Rand Gold 26 March 2009 Authority Steering CRG currently wishes to install a pump station in the SWV Shaft at ERPM
dewater to prevent the flooding of mine reserves. Committee Meeting (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 Mr Eugene Viljoen Resident, 22 May 2009 E-mail This alternative has been investigated by WUC. A centralised Plant is the
number of small strategically placed plants - that in the event of Noordheuwel preferred option, mainly from a scale, practical implementation, financial
failure of the Central Plant, can continue. 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 Mr Andrew Barker Andrew Barker 19 May 2009 Key Stakeholder Thank you. We reiterate however that only issues addressed directly to
account for this project. Development Workshop, Brakpan the EIA team will be taken up in the process. No consideration will be
Consultant 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, Mr Niels Von Ekesparre Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder Western Utilities Corporation has the right to evaluate technology and
have not been investigated to treat AMD, and have not been taken Workshop, Brakpan select technology at their discretion. This does not preclude any other
into consideration for this project. By using the electrolytic parties from pursuing similar ventures.
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.

With the electrolytic technology we propose to reduce AMD by Mr Niels Von Ekesparre Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder Thank you for this general comment
removing the iron, manganese, etc. from the water. Workshop, Brakpan

Comments Response Report


Draft Scoping Repot 2 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
A Bentonite treatment process would be better than a Barium Prof Frans Waanders Clear Water Effluent 20 May 2009 E-mail Various treatment technologies have been considered by WUC for the
treatment process, for the following reasons: "It is tried and tested and Pollution Control proposed project. The CSIR's ABC process and the SAVMIN process were
and it works on a very large scale, able to treat much more than the chosen to be thoroughly investigated during Pilot Plant studies.
volume of water that presently issues from the Tweelopiesspruit Subsequently, the ABC process proved to be the most self-sustainable
decant. Its only limitation is the one of gypsum. Gypsum occurs treatment technology, specifically in terms of by-product recovery. Refer to
globally and is not a toxic hazard and it is no real limitation. Sufficient the Consideration of Alternatives Report.
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)

Our technology has not been given any consideration – and we can Mr Zwi Wagner Water Engineering 21 May 2009 E-mail Western Utilities Corporation has the right to evaluate technology and
do a lot to alleviate the problem of AMD, whether as an alternative or Systems Unlimited select technology at their discretion. This does not preclude any other
complementary to the WUC solution. (The one technology that WUC parties from pursuing similar ventures. Should you wish to discuss your
said they tested is “Electro Dialysis” which is far from our technology technology with WUC, please contact their team directly.
and may be very costly.)

BY-PRODUCTS
How much sulphuric acid production will take place and how will it Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet Elemental sulphur is a by-product of the water treatment process and will
be transported (Rio Rita Tankers)? What will happen to waste Noordheuwel be sold. The sulphur will be transported by road or railway.
sulphur?

What will happen to the valuable minerals present in the water - who Prof Frans Waanders North West 23 April 2009 E-mail Barium carbonate, calcium carbonate, calcium oxide (lime) and elemental
will benefit if they can be extracted? University 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.

ECOLOGY
What are the consequences of decanting AMD for the Ramsar site Mr Mike Oberholzer Department of 26 March 2009 Authority Steering Currently no AMD decants into the Blesbokspruit at Grootvlei Gold Mine.
(Marievale)? Minerals and Energy Committee Meeting 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 USER
The financial sustainability of the proposed project relies on the off- Ms Mariette Liefferink Federation for a 21 May 2009 Key Stakeholder The off-take agreement is still being negotiated with Rand Water. The
take agreement being assured with Rand Water. Is this agreement Sustainable Workshop, Randfontein Department of Water Affairs is fully aware of the progress of the proposed
assured, and does the Department of Water Affairs approve? Environment project, as the directive for the project came from this Department.

Rand Water has received an RoD and WUL that covers Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of Noted. Thank you.
Klipriviersberg Reservoir. Johannesburg

Are the 117 000 people quoted in the presentation that do not have Mr Michael Oberholzer Chief Director: 19 May 2009 Key Stakeholder These are people with in the municipal framework in general.
access to drinking water the number of people in Ekurhuleni Mineral Regulation, Workshop, Brakpan
specifically, or are these people a niche market WUC identified that Department of
they can cover? Minerals and Energy

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 A draft memorandum of understanding is being negotiated.
Workshop, Randfontein

Comments Response Report


Draft Scoping Repot 3 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
Treated water can be added to the local grids on the West Rand, the Mr Eugene Viljoen Resident, 22 May 2009 E-mail WUC is in the process of compiling a feasibility study that includes
price of which should be subsidised by the Municipalities or the Noordheuwel refinement of the project financial model. This information is,
Gauteng Government directly. After all, they are allowing understandably, of a confidential nature. Should stakeholders require site
unprecedented and unplanned development and the influx of people. of components of this study arrangements for this can be made subject to
Rand Water and the Department of Water and Environmental Affairs signing of the necessary confidentiality agreements
must come to table. Their negligence in this matter also stands out
like a sore thumb.
About 18% of the Rand Water supply is grey water. Has WUC Mr Eugene Viljoen Resident, 21 May 2009 Key Stakeholder WUC proposes to treat mine affected water. The composition of Rand
allowed for that in the proposed scheme? Noordheuwel Workshop, Randfontein water supply is not a matter for the attention of WUC

Why can treated AMD not be used only for industrial purposes, and Mr Niels Von Ekesparre Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder Mine affected water is commonly reused within the mining industry. There
eliminate potable water from being used for mining purposes? Workshop, Brakpan is a limited number of water intensive industries in proximity to the
proposed project.

ENERGY
Has gas been considered as source of energy for the thermal Mr Smuts Marais Water Quality 20 May 2009 Key Stakeholder Yes, but was not favoured.
process? Manager, Ekurhuleni Workshop, Alberton
Metro
What are the power requirements for the project, i.e. at the Water Mr Basie Maree Mintails 26 March 2009 Authority Steering The power requirement for the operation of the Water Treatment Plant is 6
Treatment Plant? Committee Meeting 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.

GEOHYDROLOGY
At the workshop, the point was raised that there will be an inflow and Adv Riaan Jonker Newmarket Property 21 May 2009 E-mail The proposed project does not seek to dewater the compartments, only to
outflow of water. Will there be a general report on the potential Development JV provide a self-sustaining solution to sustained management of water level
impact that this may have on foundations of buildings on properties within the mining compartments below the environmental critical level
or will a specialist report be prepared? The answer at the workshop (ECL). Thus, the proposed project will not change the stability risk in
was that there will be a general report, as I understand, because undermined areas. Concerns regarding such stability issues should also
WUC is under pressure to finalise this EIA to start with construction be addressed directly to the holders of the relevant mining rights. WUC is
end of this year. What is the potential impact on the foundations of not a mining company and has no responsibility for undermined areas.
landowners? How can one do this and finalise this EIA, without a In the contextof the distribution pipeline, shallow geotechnical studies will
specialist report? I am representing a property owner, and it must be inform final design of the pipeline. These studies are typically done after
recorded that we are of the view that a specialist report is required. completion of the EIA as part of the final engineering programme.
We record that we reserve all our rights.

Will there be a specialist geotechnical report generated as part of the Adv Riaan Jonker Newmarket Property 20 May 2009 Key Stakeholder These aspects (primary and secondary impacts) will be addressed as part
EIA? Will potential impacts on the properties associated with the Development JV Workshop, Alberton of the EIA.
proposed project be addressed?

In the Central Basin, how would the mine affected water be Mr Peter Kelly Department of 26 March 2009 Authority Steering From a number of shafts accessing the Central Basin. Murray and Roberts
transported to the Water Treatment Plant site if the sub- Minerals and Energy Committee Meeting Cementation is in the process of evaluating reinstalling pumping capacity
compartments are no longer connected? within the basin.

Seismic activity may occur if the project doesn’t proceed. Mr Peter Kelly Department of 21 May 2009 Key Stakeholder Thank you for this comment
Minerals and Energy Workshop, Randfontein

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 Ms Lebo Molefe City of Johannesburg 07 May 2009 Comment Sheet The proposed project provides a mechanism to manage water level within
out the water on surface water is required. 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 Response Report


Draft Scoping Repot 4 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
Dolomites are a major problem in the Mogale City Local Mr Daniel Motaung Gauteng Department 14 May 2009 Meeting with the The removal of water is aimed at preventing water from decanting.
Municipality’s area. Will the removal of water from underground not of Agriculture, GDACE Western Utilities Corporation will not remove water to a level that will lead
leave cavities underground and therefore lead to the formation of Conservation and to dolomites collapsing and thereby developing sinkholes.
sinkholes in the area? Environment

The GDACE requests geotechnical reports of all the areas where Mr Daniel Motaung Gauteng Department 14 May 2009 Meeting with the At this stage no new pumping is proposed. The proposed project will take
water will be pumped. of Agriculture, GDACE water that has already been lifted to surface by the mines under current
Conservation and permit.
Environment

Why are no geotechnical or geohydrological specialist studies Mr Koogan Naidoo Mogale City Local 21 May 2009 Key Stakeholder Geohydrological and other studies have been done and are continuously
included in the impact assessment? Municipality Workshop, Randfontein 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 Mr Sidney Osborne Resident, Springs 21 April 2009 Facsimile Noted, thank you
government mining engineers office in Johannesburg.

As far as I can remember the water from the mining operations Mr Sidney Osborne Resident, Springs 21 April 2009 Facsimile Thank you for this information
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.
Why are there no geotechnical and geological studies included in the Mr Sidney Osborne Greater Independent 19 May 2009 Key Stakeholder A geo-hydrological study has been done.
specialist studies? Residents Workshop, Brakpan
Association

What will happen if sinkholes develop? Mr Sidney Osborne Greater Independent 19 May 2009 Key Stakeholder The project does not seek to draw down water levels, only to provide a
Residents Workshop, Brakpan solution to sustained management of water at a level that is below the
Association 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 Mr Sidney Osborne Greater Independent 19 May 2009 Key Stakeholder Should the proposed project not go ahead, the basins will continue to fill
floods? Residents Workshop, Brakpan with water as has happened in the Western Basin where decant takes
Association 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 Mrs Barbara Rush Landowner, 06 May 2009 Comment Sheet The project does not seek to draw down water levels, only to provide a
removal will cause more subsidence. Krugersdorp 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 Mr Shan Rush Rush Enterprises, 06 May 2009 Comment Sheet The proposed project does not seek to dewater the compartments, only to
resulted in damage to property - cracks in walls and foundations. Krugersdorp 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 Mr John Smit Mine Managers 24 April 2009 E-mail These issues are inherent to the gold mining industry. They are not
forming in these dolomites than was the case when they were Association of SA specific to the project. The proposed project provides a solution to manage
drained due to mining activities in earlier years. 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 Response Report


Draft Scoping Repot 5 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
We do not have complete and sufficient profiles of Geo- science Mr Eugene Viljoen Resident, 14 May 2009 E-mail This comment appears to relate to the broader body of knowledge
detail in respect of the interrelationship between the various Karst Noordheuwel surrounding mining and mine water interactions within the dolomitic areas.
compartments, permeability’s, stresses, both natural and the various The implications of the proposed project on mine water and mine water
fault rock reaction to both chemical exposure such as AMD, and geochemistry, as it relates to prediction of water quality for treatment, will
unnatural caused by mining itself. What is needed is a complete reflect in the groundwater and water chemistry specialist reports
database, incorporating all the sciences to at least form a reasonably respectively.
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. )

If the mines, as I believe they have, done Sophisticated Geological Mr Eugene Viljoen Resident, 22 May 2009 E-mail Thank you for this comment. It does not appear to have relevance to the
3D Seismic Surveys to create coherent models of the un-mined Noordheuwel proposed water treatment project.
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?

Is only the ingress of water from the Karst aquifers caused by various Mr Eugene Viljoen Resident, 22 May 2009 E-mail The proposed project does not seek to research water movement /
factors, e.g. blasting cracks, seismic movements, Dyke /Fault Noordheuwel ingress within the mining basins. The project is based on feasibility study
penetration? From which aquifers does the present ingress come, as centred around treatment. Water volumes available for treatment will be
the rate of decant does not appear to be entirely related to rain and confirmed through consolidation of mine water management records
storm water penetration? We seem to disregard the normal plate supported by information from available studies within the region. These
tectonic movement of approx. 2 cm per annum and input from a lot of outputs will reflect in the groundwater, water chemistry and hydrology
other disciplines. I suggest your researchers have a look at specialist studies.
“problems” of water ingress through the roofs on tunnels and stopes.

A photo evidence of underground rainstorms, that is besides the dust Mr Eugene Viljoen Resident, 22 May 2009 E-mail The proposed project does not seek to research water movement /
repression programmes, is certainly different from the technical Noordheuwel ingress within the mining basins. The project is based on feasibility study
information disseminated to the Public. 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 Mr Eugene Viljoen Resident, 22 May 2009 E-mail The proposed project does not seek to dewater the compartments, only to
Helderblom area, shown by surface fractures also spells trouble. Are Noordheuwel provide a self-sustaining solution to sustained management of water level
all these included in your plans? with in the mining compartments below the environmental critical level
(ECL)

Comments Response Report


Draft Scoping Repot 6 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
A lot of work has been in the study area regarding geotechnical Mr Peter Withinshaw City of Johannesburg 08 May 2009 Meeting with City of Western Utility Corporation is proposing the project on behalf of the
aspects. This is not only a multi-disciplined project, but is also Johannesburg WBEC, CBEC and EBEC. These Environmental Corporations have been
geographically complex, and involves many stakeholders. WUC set up by affected mines with in the Western, Central and Eastern basins.
would need to ensure that all stakeholders, i.e. the mines, are on The proposed project does not seek to dewatering any of the mining
board and that the potential hazards / risks associated with the basins. It does, however provide a solution regarding how water brought to
project are quantified and mitigatory measures put in place. surface can be used for beneficial purpose rather than being discharged in
Contingency and back-up measures need to be in place for worse- pretreated or even untreated state back into the surface environment.
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.

The City of Johannesburg’s geotechnical department has conducted Mr Peter Withinshaw City of Johannesburg 08 May 2009 Meeting with City of WUC and Golder would appreciate a copy of the relevant report.
a complete assessment on the Witwatersrand. Johannesburg

Does the same geological and chemical characteristics apply Mr Peter Withinshaw City of Johannesburg 08 May 2009 Meeting with City of This issue will be addressed in the groundwater quality and geochemistry
throughout the study area? Johannesburg specialist studies

GEOTECHNICAL
Will the project increase the risk of sinkhole formation in these Mr Garth Barnes WESSA 01 May 2009 Letter The proposed project does not seek to dewater the compartments, only to
areas? Will you be carrying out a risk assessment for this provide a self-sustaining solution to sustained management of water level
possibility? with in the mining compartments below the environmental critical level
(ECL).
Has the seismic activity been studied? If the studies were done – Prof Frans Waanders Northwest University 21 May 2009 Key Stakeholder The project does not seek to draw down water levels, only to provide a
how accurate was the modelling? Workshop, Randfontein 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 HYDROGEOLOGY


There are various options to address future decant. The water can be Mr Mike Oberholzer Department of 26 March 2009 Authority Steering Comment noted with thanks. The proposed project does not seek to
consumed to prevent discharge. There is a risk of de-watering the old Minerals and Energy Committee Meeting dewater the old workings, only to reduce the water level in the Western
underground mine workings, since structures could cave in. This will Basin to below ECL and then provide a self-sustaining mechanism to
depend on the pumping infrastructure. manage water at these levels.

GROUNDWATER
While I recognise the critical importance of being concerned about Mr Andrew Barker Andre Barker 20 May 2009 E-mail These are valuable points. The proposed project will not influence
the decant of water at surface, I also noted concern regarding the Development operational mines with in any of the basins. Water within the Central Basin
need to consider and protect strategic pumping positions and also Consultant will continue to be pumped by Central Rand Gold to allow their operations
provide for possible future access to mineral resources which could to continue. This water will be taken to surface at the Western Utility
still exist in the areas which are to be allowed to flood in the future. Corporation treatment plant.

In the estimated projections in terms of the surfacing of decant, have Mr Andrew Barker Andrew Barker 19 May 2009 Key Stakeholder Yes, the projections are based on measured rate of water level rise in the
both the surface and underground sources been considered? Development Workshop, Brakpan compartments supplemented with pumping data from the mining
Consultant companies.

Should one not attempt to protect existing valuable infrastructure that Mr Andrew Barker Andrew Barker 19 May 2009 Key Stakeholder The proposed plug and pump system will allow Central Rand Gold to
can still be used? Development Workshop, Brakpan continue to operate without compromising mineable reserves or
Consultant 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 Mr Andrew Barker Andrew Barker 19 May 2009 Key Stakeholder The proposed plug and pump system will allow Central Rand Gold to
for Central Rand Gold if a plug system is inserted in the central Development Workshop, Brakpan continue to operate without compromising mineable reserves.
basin? Consultant

Comments Response Report


Draft Scoping Repot 7 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
What risk to groundwater does pumping of this water to surface Mr Garth Barnes WESSA 01 May 2009 Letter The proposed project provides a mechanism to manage water level within
have, if any? 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 Mr Garth Barnes WESSA 20 May 2009 Key Stakeholder This question will be addressed in the groundwater and water quality
Central Basin, will the high uranium levels in the water in the Workshop, Alberton specialist studies
Western Basin have an impact on the water quality in the Central
Basin?
Will water levels rise before the plug and pump station is Mr Garth Barnes WESSA 20 May 2009 Key Stakeholder Timing is critical. The rate of water rise is measured regularly. Indications
implemented? Workshop, Alberton are that the plug and pump station can be installed in time.

Dewatering at Pamodzi won’t increase because of the proposed mine Mr Kimbton Chiota Pamodzi Gold East 19 May 2009 Key Stakeholder Thank you for this information.
water reclamation project. Rand Workshop, Brakpan

At a technical level, I am concerned that the transfer of water from Dr Henk Coetzee Council for 23 April 2009 Comment Sheet The groundwater specialist investigation will evaluate the consequence of
the Western to the Central Basin could have unforeseen Geoscience placing Western Basin water with in the Central Basin and management of
consequences which will need to be properly addressed in the EIA water within the underground compartments
study before this can be permitted.

This project is overdue, there is serious contamination. Mr Willy Fuzani Umlambo Pride Bee 30 April 2009 Comment Sheet Thank you for this comment
Construction Projects

Will water levels fall below ECL and the dolomite level if it is pumped Mr David Hall Dura Soletanche 20 May 2009 Key Stakeholder In the Western Basin, pumping will take place by the mines to drop water
from the Western to the Central Basin? Banchy Workshop, Alberton levels to below ECL, in order to prevent further decanting to surface.

Groundwater levels in the Central Basin are rising at a faster rate Mr Kevin Kruger DRD Gold 26 March 2009 Authority Steering Comment noted with thanks.
than normal. This is due to some of the underground sub- Committee Meeting
compartments becoming disconnected. If groundwater levels
continue to rise at this rate, ECL will be reached by February 2011.

Central Rand Gold (CRG) will soon obtain an RoD for a new mine in Mr Freddie Letsoko City of Johannesburg 08 May 2009 Meeting with City of CRG forms part of CBEC, the Central Basin Environmental Corporation,
the Central Basin. How will this project impact on the proposed Johannesburg on whose behalf Western Utility Corporation proposes the current solution.
mine? 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 Ms Mariette Liefferink Federation for a 05 May 2009 Letter Thank you for this comment. The proposed project will provide a solution to
Western Basin the greatest focus is the Cradle of Humankind World Sustainable enable management of water level within the mining compartments at a
Heritage Site. Of no lesser concern, however, are the downstream Environment level below environmental critical level (ECL). The discharges to the
landowners and agricultural activities that are largely or wholly surface decants points will then cease.
dependent on groundwater for potable and economic use.

The decant or uncontrolled discharge of contaminated water or acid Ms Mariette Liefferink Federation for a 05 May 2009 Letter Thank you for this comment. The proposed project will provide a solution to
mine drainage (AMD) from the Western Basin mine void is a major Sustainable enable management of water level within the mining compartments at a
environmental problem and intervention, namely a medium and long Environment level below environmental critical level (ECL).
term technically viable and financially feasible treatment option, is
urgently called for.

Radioactivity has become an area which required special attention Ms Mariette Liefferink Federation for a 05 May 2009 Letter A radiological specialist study forms part of the EIA
because of a history of extreme secrecy and confidentiality on all Sustainable
nuclear issues. Environment

Comments Response Report


Draft Scoping Repot 8 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
What are the potential impacts of the transfer of water from the Ms Nozipho Maduse City of Johannesburg 08 May 2009 Meeting with City of This issue will be addressed in the groundwater specialist studies
Western Basin to the Central Basin? Johannesburg

The level at which pumping will occur must show that the Mr Tshireletso Mataboge Department of Water 28 May 2009 Letter The proposed project does not seek to dewater the compartments, only to
Environmental Critical Level (ECL) has been carefully considered to and Environmental provide a self-sustaining solution to sustained management of water level
ensure sustainability as well as prevent excessive pumping that may Affairs with in the mining compartments below the environmental critical level
have detrimental impacts. (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 20 May 2009 Key Stakeholder Excess mine affected water will be removed from the Central Basin in order
Manager, Ekurhuleni Workshop, Alberton to prevent water levels from reaching ECL and thus potentially
Metro contaminating surface and groundwater water resources.

Model the pollution plume and proposed mitigation measures and Ms Lebo Molefe City of Johannesburg 07 May 2009 Comment Sheet Impacted mine water in the mining compartment is a mining legacy issue.
make the results known. 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 Ms Lebo Molefe City of Johannesburg 07 May 2009 Comment Sheet Impacted mine water in the mining compartment is a mining legacy issue.
studied. 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 Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of The proposed project will enable groundwater levels with in the Western,
assessment. Will the project influence this assessment? Johannesburg 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 Mr Daniel Motaung Gauteng Department 14 May 2009 Meeting with the For the phase 1 project there will be no change from the current condition
be? of Agriculture GDACE in terms of water management within the Eastern Basin. At surface, there
Conservation and will be a reduced discharge of pretreated water into the Blesbokspruit with
Environment 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 19 May 2009 Key Stakeholder The Western basin is decanting. Water level across the Central Basin
Residents Workshop, Brakpan varies but is below 600 m in depth in the eastern portion of the Central
Association 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 26 March 2009 Authority Steering Water levels and ingress are measured on a regular basis.
and Environmental Committee Meeting
Affairs

There is a risk factor involved in terms of the uranium content in the Ms Vicky Shaw WESSA 19 May 2009 Key Stakeholder This issue will be addressed in the groundwater and water quality
water if water is to be pumped from the Western to the Central Workshop, Brakpan specialist studies.
Basin. This needs to be considered and incorporated into the buffer
zone area. Cooke shaft, for instance, has high uranium levels.

If the water level in the Central Basin rises, there won’t be ‘space’ to Ms Elize Tempelhoff Beeld, Media 24 21 May 2009 Key Stakeholder The consequence of introducing Western Basin water into the Central
pump water from the Western Basin. Is that correct? Workshop, Randfontein 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 26 March 2009 Authority Steering The Eastern Basin and Central Basins are separated by geological
Municipality Committee Meeting structures and mine water does not move between these basins
underground.

Comments Response Report


Draft Scoping Repot 9 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
Details of the entire West Rand mines in terms of their historical and Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet Historical water monitoring data (where available), mine plans (historical
operational activities must be considered during the investigation. All Noordheuwel and current), results of previous geohydrological investigations
water monitoring results, past and present, should form part of the undertaken, etc have all been used to inform the consolidated groundwater
investigation. Compare their Financial Prospectus with scientific reports that inform the project feasibility study. Similarly, the operational
details. Refer to the Manual on Mine Water Treatment and water requirements of these mines has also been considered.
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.

Some of the mines have been operational for 130 years. This has Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet Wherever possible, historical information has been used to inform project
created a lot of dirt and tunnels, i.e. intricate underground conditions. Noordheuwel planning.

Have the boreholes for water (potable supply) into the Karst been Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet Thank you for these comments which relate to the current situation. The
tested and where are the results? Do these boreholes penetrate or Noordheuwel proposed project provides a self-sustaining solution to utilise excess water
bottom near the stopes? And at what levels? A grid system of allowing improvement and management control within the dolomitic basins.
boreholes with above test results of entire surrounding areas are
required, notably in terms of interconnecting stopes to other mines,
including Doornkop operation.

What will happen to the water from such flooded stopes and how Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet Questions pertaining to mine water volumes available for treatment and the
much is involved? If the radioactivity was neutralised by lime, why Noordheuwel quality of available mine water will be addressed in the groundwater
are the slimes still active? specialist studies.

Note the water volumes, ph, conductivity, pollution in 1994. How Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet Questions pertaining to mine water volumes available treatment and the
does this information compare with the latest tests? Noordheuwel quality of available mine water will be addressed in the groundwater
specialist studies.

Bekkersdal and surrounding areas have vegetable farms under Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet Thank you for this comment. It does not relate to the proposed project and
overhead irrigation with waters obtained from boreholes in and Noordheuwel current EIA process.
around Donaldson dam. Where are these vegetables marketed and
were they tested for contamination?

The present ingress cannot necessarily be from surface water. The Mr Eugene Viljoen Resident, 15 May 2009 E-mail Thank you for this general comment.
extensive housing and road development has caused flood Noordheuwel
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.)

May I also suggest that you visit the farmers in the Leeuspruit area Mr Eugene Viljoen Resident, 15 May 2009 E-mail Thank you. This comment is not relevant to the proposed project which
and view the skin lesions caused by bathing in their borehole water . Noordheuwel deals with treatment of mine affected water.

The project appears to be a Robin Hood reverse osmosis process, Mr Eugene Viljoen Resident, 22 May 2009 E-mail The proposed project is a chemical treatment process. Treated water will
robbing the West and East of Water, albeit contaminated, to save Noordheuwel be delivered to the Rand water system, from which potable water is
the Rich in Johannesburg. Resulting in thousands of people who live supplied throughout the proposed project area.
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.

Comments Response Report


Draft Scoping Repot 10 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
Is it Archaean aquifer water found at lower levels than the present Mr Eugene Viljoen Resident, 22 May 2009 E-mail Yes, it is reasonable to expect that active management of water within old
depth of the mines? If so, two things “spring” to mind: these waters Noordheuwel mine workings will be necessary until such time as water quality improves.
cannot be replaced (the same problem as the Yanks have with This can not be expected to occur in the short-term (decades). Until such
Ogalala aquifer) and; secondly, the refilling of the old mines shafts time, the water level in old mine workings will need to be controlled and the
will continue unabated with contaminated water until the source dries water that is pumped surface treated in order to prevent contamination of
up. So will the contamination influence huge agricultural tracts of the surface aquifers.
land?
What amazes me that this filthy water's influence on foodstuff has Mr Eugene Viljoen Resident, 22 May 2009 E-mail Thank you for this comment. It does not appear to have relevance to the
not yet created the outcry as in overseas countries, althoug it has Noordheuwel proposed water treatment project.
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 Mr Eugene Viljoen Resident, 22 May 2009 E-mail Thank you for this comment. It appears to be a statement about the mining
Basin problem, but your approach to solve this problem, the Noordheuwel industry in general, without direct relevance to the proposed water
presentation thereof to us after a visit overseas to obtain Capital treatment project.
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.

How will the sediments that remain in all the tunnels and shafts and Mr Eugene Viljoen Resident, 22 May 2009 E-mail The proposed project does not seek to dewater the compartments, only to
those Karst Acquifers ever be cleared if this project manages to Noordheuwel provide a self-sustaining solution to sustained management of water level
remove the waters? with in the mining compartments below the environmental critical level
(ECL).
I strongly oppose this - this will create an even bigger problem in the Prof Frans Waanders North West 23 April 2009 E-mail The groundwater specialist investigation will evaluate the consequence of
future. The geology is not correct in some instances, which might University placing Western Basin water with in the Central Basin and management of
create unexpected surprises if pumping commences to one central water within the underground compartments.
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.

Why pump more polluted water to a possible area with less polluted Prof Frans Waanders North West 23 April 2009 E-mail The groundwater specialist investigation will evaluate the consequence of
water? University 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 Mr Zwi Wagner Water Engineering 17 May 2009 Comment Sheet No water will be introduced into the Rand water system that does not meet
from a toxic origin. Systems Unlimited South African drinking water standards and Rand water requirements.

Would you be so kind and send us the following water analysis of the Mr Zwi Wagner Water Engineering 21 May 2009 E-mail This information will reflect in the specialist studies and EIA report.
AMD in the Eastern Areas: Raw AMD as pumped from the mine Systems Unlimited
underground; Treated AMD from the mine – before the WUC
treatment.
If water is carried from the Western to the Central Basin, is extra Mr Peter Wood WESSA 19 May 2009 Key Stakeholder Uranium content in water in the Western Basin is indeed high. During the
radio-activity carried into the water? Workshop, Brakpan 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 Response Report


Draft Scoping Repot 11 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
HERITAGE
In terms of Section 38 of the National Heritage Resource Act, No 25 Mr Tebogo Molokomme SAHRA 08 April 2009 Letter A Herritage Impact Assessment will be undertaken as part of the EIA
of 1999 (NHRA), the SAHRA requires to be furnished with sufficient process.
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.

HYDROGEOLOGY
I have been involved with this issue right form the beginning, i.e. Mr Garfield Krige African Environmental 20 May 2009 E-mail Thank you for this information
since long before 1996. Remember that a significant percentage of Development
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.

Similar seepage occurs in the East Rand. For instance, a geological Mr Garfield Krige African Environmental 20 May 2009 E-mail Thank you for this information.
fault crosses right under the Cowles Dam immediately upstream from Development
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.

At present we have only one solution on the table, and that is the Mr Garfield Krige African Environmental 20 May 2009 E-mail WUC proposes to develop a treatment plant. That is the scope of the
solution of treating the mine decant water. For some reason, we are Development current EIA. WUC is not a land holder or mining rights holder. Initiatives at
ignoring the more obvious solution, i.e preventing the water from source are best pursued by such parties, or the State.
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.

How long will it take the water to surface if there is no pumping in the Mr Steve Walker Sappi Fine Paper, 19 May 2009 Key Stakeholder In the absence of pumping, approximately 3 years.
Eastern Basin? Springs Workshop, Brakpan

INTEGRATED REGULATORY PROCESS


While I recognise and accept that this current process is limited to Mr Andrew Barker Andre Barker 20 May 2009 E-mail This is a valuable point. Context will be provided to the "Big picture" in the
specific activities and components of the bigger project it was Development EIA
suggested that the strategic importance of the project as a whole be Consultant
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.

Comments Response Report


Draft Scoping Repot 12 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
It was noted that this project may not be considered as "mining" and Mr Andrew Barker Andre Barker 20 May 2009 E-mail Thank you for these suggestions
that verification needs to be sought regarding the status of the main Development
activities and land uses and whether appropriate land use Consultant
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.

A Strategic Environmental Assessment (SEA) study should be a Mr Andrew Barker Andrew Barker 19 May 2009 Key Stakeholder At a project level, an SEA will unfortunately not be done.
higher priority, as it will also add as motivation for the project. Development Workshop, Brakpan
Consultant

WUC is not a mine, and that will influence the land use authorisation Mr Andrew Barker Andrew Barker 19 May 2009 Key Stakeholder These issues form part of the ongoing feasibility process
that will be required for this project. This is especially important from Development Workshop, Brakpan
a liability and costing point of view, including rate issues – mine Consultant
houses pay much higher rates than industrial areas.

Will change of land use apply? Mr Andrew Barker Andrew Barker 19 May 2009 Key Stakeholder These issues form part of the ongoing feasibility process
Development Workshop, Brakpan
Consultant

The regulatory processes are challenging, considering the fact that Mr Marius Keet Department of Water 26 March 2009 Authority Steering The regulatory process will be pursued with each affected department
not all decision making authorities attended this meeting. and Environmental Committee Meeting individually. The purpose of the Authority Steering Committee meeting is to
Affairs coordinate discussion and understanding related to the project and
associated permitting processes.

It is our respectful opinion that the Western Utilities Corporation's Ms Mariette Liefferink Federation for a 05 May 2009 Letter The EIA will be submitted for authorisation under NEMA, and ascosiated
proposed project will have to be dispensed with under the new legal Sustainable amenDepartment of Minerals and Energynts. The affected mine EMP's will
regime, which include, but are not limited to: The Mineral and Environment also need to be amended through separate process.
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.

Central Rand Gold has commenced mining, albeit alleged trail Ms Mariette Liefferink Federation for a 05 May 2009 Letter Please address this comment directly to the mining house concerned. The
mining, without a water use licence. The matter is currently under Sustainable comment does not relate to the project proposed by Western Utilities
investigation by a task team appointed by the Regional Director of Environment Corporation (WUC).
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.

The Air Pollution Prevention Act (APPA) does not address the Ms Mariette Liefferink Federation for a 21 May 2009 Key Stakeholder Thank you for this general comment.
cumulative impacts of air pollution. The Air Quality Act is now Sustainable Workshop, Randfontein
applicable and will be put into effect by the West Rand District Environment
Municipality.

Comments Response Report


Draft Scoping Repot 13 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
Will EIA documents be submitted to the new departments Ms Mariette Liefferink Federation for a 21 May 2009 Key Stakeholder EIA documents will be submitted under NEMA for authorisation. The
separately, as a result of the new dispensation? Sustainable Workshop, Randfontein department to receive these documents will be agreed with regulators.
Environment

Guidelines are not legally binding. However, I request that the former Ms Mariette Liefferink Federation for a 21 May 2009 Key Stakeholder Thank you for this comment
Department of Water Affairs and Forestry’s water guidelines be Sustainable Workshop, Randfontein
taken into consideration. Environment

Kloof Mine is the only mine in the area that has issues with a water Ms Mariette Liefferink Federation for a 21 May 2009 Key Stakeholder The proponent will apply for an overarching integrated water use licence.
use licence. Will all mines now need to apply for water use licences? Sustainable Workshop, Randfontein Individual mine water use licences may need to be amended.
That will take a very long time. Environment

According to Section 21 of the National Water Act, 1998 (Act 36 of Mr Tshireletso Mataboge Department of Water 28 May 2009 Letter Noted. Thank you.
1998) and Interated Water Use Licence should be lodged with this and Environmental
Department to authorise any water related activities that Western Affairs
Utilities Corporation (Pty) Ltd (WUC) will undertake during the
proposed project.
This Department requires the proof of contract agreements between Mr Tshireletso Mataboge Department of Water 28 May 2009 Letter Noted. Thank you
WUC and the relevant mining houses to collect and treat mine water and Environmental
on their behalf. Affairs

Formal correspondence should be sent to this Department, including Mr Tshireletso Mataboge Department of Water 28 May 2009 Letter This will be provided. Thank you
inter alia: WUC's role and responsibility; the mining houses' and Environmental
responsibility and ownerships of liability. Affairs

The applicant must ensure that the Integrated Waste Water Mr Tshireletso Mataboge Department of Water 28 May 2009 Letter Thank you for this advice.
Management Plans comply with the Department's Best Practice and Environmental
Guideline H3: Water Reuse and Reclamation of 2006 and must be Affairs
submitted to this Department for approval.

Proof of approval / support by the responsible local authority should Mr Tshireletso Mataboge Department of Water 28 May 2009 Letter Noted. Thank you.
be provided to ensure alignment of the proposed project with the and Environmental
municipality's Integrated Development Plan. Affairs

All other relevant environmental legislation should, however, not be Mr Tshireletso Mataboge Department of Water 28 May 2009 Letter Thank you. A comprehensive integrated regulatory process is being
overlooked and should be adhered to. and Environmental followed.
Affairs

In terms of the Integrated Water Use Licence Application, the Ms Deborah Mochlotodi Department of Water 20 May 2009 Key Stakeholder Comment noted with thanks.
Department of Water and Environmental Affairs will only provide and Environmental Workshop, Alberton
comments on the documents subsequent to the submission thereof Affairs
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).

The role of the City of Johannesburg in the proposed project is that Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of Noted. Thank you.
of a commenting authority and not a decision-making authority. The Johannesburg
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.

All EIA documents should be submitted directly to Ms Lebo Molefe Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of Noted. Thank you.
and not to the MMC. Johannesburg

Comments Response Report


Draft Scoping Repot 14 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
What is the Department of Minerals and Energy's involvement in the Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of The Department of Minerals and Energy has had a number of discussions
process, since a number of mines are involved in the project. Johannesburg 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 Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of Noted. Thank you.
City of Johannesburg for comments, including the EMP Johannesburg
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.

Draft documents for comment by the City of Johannesburg should be Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of Thank you for this suggestion.
sent to Ms Molefe early in each comment period, since it needs Johannesburg
internal circulation to many departments. Commenting on draft
documents could speed up the process.

The same Public Participation Process can be adopted for both the Mr Molefe Morokane Department of Water 24 April 2009 Comment Sheet Noted. Thank you.
EIA and the Water Use Authorisation Process. and Environmental
Affairs

All water uses must be identified. More importantly, to separate the Mr Molefe Morokane Department of Water 24 April 2009 Comment Sheet Noted. Thank you.
EIA process from the Water Use Authorisation Process. These two and Environmental
process should be run parallel. Affairs

If WUC has properly applied for the different activities which will Mr Daniel Motaung Gauteng Department 14 May 2009 Meeting with the Noted. Thank you for this comment.
impact on water, GDACE will consider the application. However, the of Agriculture, GDACE
Department does not have jurisdiction over activities that are Conservation and
administered by other Departments. Environment

The Scoping Report that will be submitted to the Department must Mr Daniel Motaung Gauteng Department 14 May 2009 Meeting with the Thank you for this input. This will be done.
clearly indicate that it is a draft. Any changes in subsequent reports of Agriculture, GDACE
must be clearly indicated so that officials can find these when Conservation and
assessing reports. Environment

It is possible to treat the project as urgent based on the need and its Mr Daniel Motaung Gauteng Department 14 May 2009 Meeting with the Thank you for this input. Western Utility Corporation would like to expedite
benefits. of Agriculture, GDACE the project in order to start operation before rising water levels in the
Conservation and different areas become a problem. In order to avoid mine water decanting,
Environment the project has to start operating before mid-2011.

It still has to be determined whether waste generated during the Mr Daniel Motaung Gauteng Department 14 May 2009 Meeting with the Thank you for this contribution. In addressing the issue of waste
project will be regulated under the National Environment of Agriculture, GDACE management through the feasibility study further interaction with the
Management Act or the Environment Conservation Act. Conservation and department will take place.
Environment
You are requested to closely liaise with this Department. In order for Mr E Moyikwa Department of 20 May 2009 Letter Noted. Thank you.
this department to provide an informed input, relevant documentation Integrated
regarding the proposed development must be forwarded to this office Environmental
for review and comment. Management, Mogale
Local Municipality

Who will authorise the proposed project: national or provincial Mr Koogan Naidoo Mogale City Local 21 May 2009 Key Stakeholder The proposed EIA report will be submitted for authorisation under NEMA at
authorities? Municipality Workshop, Randfontein a provincial level

Comments Response Report


Draft Scoping Repot 15 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
How credible will the specialist studies be in such a streamlined Mr Koogan Naidoo Mogale City Local 21 May 2009 Key Stakeholder Considerable work has been done around the regional groundwater
timeframe? Municipality Workshop, Randfontein 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 Ms Nosipho Ngcaba DEAT 24 April 2009 Letter We will do so. Thank you.
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).

Project specific comments will be made on receipt of the Draft Mr M Nkosi Ekurhuleni 29 April 2009 Letter Noted. Thank you
Scoping Report and Plan of Study. Please submit one electronic Metropolitan
copy of the report. Municipality

Mining rights in South Africa is not clear-cut. Mr Sidney Osborne Greater Independent 19 May 2009 Key Stakeholder Thank you for this comment
Residents Workshop, Brakpan
Association

All documents submitted to GDACE, must also be submitted to this Mr A Ramokolo Metsi-A-Lekoa, 19 May 2009 Letter Thank you for this comment.
municipality. Further comments will be forwarded as soon as we Emfuleni Local
received the Scoping Report. Municipality

In terms of environmental authorisation it should be noted that there Ms Elize Tempelhoff Beeld, Media 24 21 May 2009 Key Stakeholder Thank you. This is not the only department that has restructured post the
is no Gauteng Department of Agriculture, Conservation and Workshop, Randfontein 2009 elections.
Environment anymore. The department is now called the Department
of Land Affairs and Rural Development.

If the Study Reports on the radiological tests during the Pilot Plant Mr Thabo Tselane National Nuclear 20 April 2009 Meeting with National Noted. Thank you
study were not forwarded to the NNR previously, they must be Regulator Nuclear Regulator
submitted to the NNR.

Should the NNR process need to be followed, the NNR would require Mr Thabo Tselane National Nuclear 20 April 2009 Meeting with National Noted. Thank you.
the following: 1) A clear indication of who (the mines or WUC) will be Regulator Nuclear Regulator
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.

A guideline is available, outlining the NNR application process. It Mr Thabo Tselane National Nuclear 20 April 2009 Meeting with National Noted. Thank you
should be noted that the NNR needs three months to consider an Regulator Nuclear Regulator
application and that this must be taken into consideration during the
planning of the proposed project.

Comments Response Report


Draft Scoping Repot 16 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
It should be noted that Ekurhuleni Metro is a Water Services Mr Danie van der Merwe Ekurhuleni Metro 28 April 2009 Comment Sheet Thank you. There are ongoing discussions between WUC and Rand water
Authority (WSA) and is not in the business of treating potable water regarding this project. Rand water is also a stakeholder in the EIA
and it currently has a long term agreement with the Service Provider process.
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.

When does WUC expect to get authorisation for the proposed Mr Steve Walker Sappi Fine Paper, 19 May 2009 Key Stakeholder A full EIA process will be followed, but the GDACE has agreed to make
project? Springs Workshop, Brakpan 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 Mr Peter Withinshaw City of Johannesburg 08 May 2009 Meeting with City of WUC is still investigating whether it should register as an alternative
directly with Rand Water or with the Municipalities? Johannesburg 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 Byproducts generated in a water treatment plant will be recovered. The
Johannesburg 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-ECONOMY
There is little or no information available on the economics of the Dr Richard Doyle Environmental and 13 May 2009 Comment Sheet WUC is busy with a feasibility study that includes refinement of the
solution, which could also impact on the timing for implementation. Remedial Technology financial model. This information is, understandably, of a confidential
Holdings (Pty) Ltd 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 Mr Seef Rademeyer Department of Water 26 March 2009 Authority Steering Comment noted with thanks.
problem; there are many potential uses for the treated mine water. and Environmental Committee Meeting
Affairs

The re-use of polluted water is a priority in the Department of Water Mr Seef Rademeyer Department of Water 26 March 2009 Authority Steering Comment noted with thanks.
and Environmental Affairs’s resource protection and waste and Environmental Committee Meeting
management hierarchy; this project is important to Department of Affairs
Water and Environmental Affairs’s national water resource planning.

MINE CLOSURE
The mines' environmental responsibilities after closure should receive Mr Kimbton Chiota Pamodzi Gold East 29 April 2009 Comment Sheet The proposed project provides a KEY component of the regional mine
attention. Rand 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 Mr Willy Fuzani Umlambo Pride Bee 30 April 2009 Comment Sheet Thank you. The project will not influence the life of mine with in the area.
residents in the area. Construction Projects This is an independent issue.

Who would be responsible / liable for the relevant infrastructure Mr Mogwera Khaothane Zimkile Consulting 20 April 2009 Meeting with National WUC will take on the environmental responsibilities / liabilities subsequent
components upon mine Closure of the various mines? Nuclear Regulator 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 Response Report


Draft Scoping Repot 17 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
If Grootvlei (Pamodzi) stops pumping, there will be a huge additional Ms Annemarie Maurizi Water Quality 20 May 2009 Key Stakeholder Pumping and pre-treatment activities at Grootvlei (Pamodzi) will be
amount of water that will need to be treated. Who will be responsible Manager, Ekurhuleni Workshop, Alberton continued either by government or another mining house. The agreement
for the treatment? Metro 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 Mr Sidney Osborne Resident, Springs 21 April 2009 Facsimile Thank you. These are the fundamental issues which motivate this project.
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.

Will all mines eventually stop pumping? If the mines close down, will Ms Vicky Shaw WESSA 19 May 2009 Key Stakeholder Correct. WUC will take over responsibility for the collective pumping of
Western Utilities Corporation have the capacity to continue with the Workshop, Brakpan AMD associated with the 9 mines that agreed to be part of the proposed
pumping of the AMD on their own? 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 Prof Frans Waanders North West 23 April 2009 E-mail The proposed project will not change the levels at which water is managed
stand in for these job losses? University 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 The proposed project is driven by the need for a regional closure strategy
Workshop, Brakpan 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 COLLECTION


Will the pumped water be stored underground in part of a void that Dr Martin Brink Northwest University 21 May 2009 Key Stakeholder Water from the Western Basin will be pumped across and dropped into the
isn’t filled, and then pumped out again? Workshop, Randfontein 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 Mr Marius Keet Department of Water 26 March 2009 Authority Steering Agreed. Water will be taken directly from the pumps at the point where it is
during pumping to prevent iron precipitation. and Environmental Committee Meeting raised out of the Western Basin and pumped in a closed pipe until re-
Affairs depositioninto the Central Basin.

Is there logic in the preferred flow of water from the Western Basin to Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of The proposed water treatment plant will treat between 75 (average) and
the Central Basin, i.e. a pipeline connecting the two basins? Johannesburg 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 Response Report


Draft Scoping Repot 18 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
Will the infrastructure associated with Phase I of the project be Mr Seef Rademeyer Department of Water 26 March 2009 Authority Steering The proposed scheme is being designed in a way that it can be extended
upgraded/designed to accommodate the additional water available at and Environmental Committee Meeting to accommodate additional pumping capacity. At this stage, only the first
mine Closure? Affairs 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 Mr Zwi Wagner Water Engineering 17 May 2009 Comment Sheet Water from the Western Basin will be transported in a sealed HDPE pipe.
and cyanide, to the WTP, for many kilometers on a virgin land is a Systems Unlimited The risk associated with transport of this mine affected water will be
serious concern - any accidental leak may result in a disaster. evaluated as part of the impact assessment.

PIPELINE ROUTES
Are there any existing pipelines that can be utilised for this project, Mr Andrew Barker Andrew Barker 19 May 2009 Key Stakeholder Yes, wherever possible existing pipelines will be used. Similarly, pipeline
such as consolidating the corridors by using road reserves? Development Workshop, Brakpan servitudes will be used, as will servitudes of other linear infrastructure in
Consolidated services will save land. Consultant order to minimise fragmentation of the environment.

The Klipriviersberg area requires specific specialist studies to be Mr Andrew Barker Andrew Barker 19 May 2009 Key Stakeholder Thank you for this information. Realignment of the distribution pipeline
conducted, as it is an environmentally sensitive area. Various studies Development Workshop, Brakpan approaching this reservoir has already been affected to minimise impact on
have been conducted by GDACE already. These, including for Consultant the rocky outcrop.
instance the biodiversity and historical studies, can be used.

My particular concern relates to the requirement to lay a very large Mr Andrew Barker Andrew Barker 20 May 2009 E-mail Thank you for this information. Realignment of the distribution pipeline
pipeline to deliver the potable water to the bulk storage facility and its Development approaching this reservoir has already been affected to minimise impact on
impact on the particularly sensitive and pristine areas of the Consultant the rocky outcrop.
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.

It was suggested that the EMM EMF be carefully reviewed and Mr Andrew Barker Andrew Barker 20 May 2009 E-mail Thank you for this information. Realignment of the distribution pipeline
examined. Your contact in this regard at EMM Environmental Development approaching this reservoir has already been affected to minimise impact on
Planning & Co-ord Dept: Envir & Tourism would be Elsabeth van der Consultant the rocky outcrop.
Merwe (082 494 4167 and vDepartment of Minerals and
Energyrwee@ekurhuleni.com). 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.
The routing of the pipelines should follow existing servitudes but Mr Garth Barnes WESSA 01 May 2009 Letter All pipelines are being positioned in mine servitudes or other servitudes
where it doesn’t, please ensure that it does not affect areas of highly wherever possible. Delineation and evaluation of impact to wetland and
sensitive biodiversity like wetlands. riparian systems will form part of the ecology specialist study.

Comments Response Report


Draft Scoping Repot 19 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
It is planned to build sports fields to the far north of the pipeline Mr Shane Brown Mnandi Property 19 May 2009 Key Stakeholder Thank you for bringing this development to our attention
where it is situated adjacent to Witpoortjie 117, Ptn 62. This will be Development Workshop, Brakpan
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.

Mast projects is located on Vulcania number 10 in Vulcania South, Mr Louis Calitz Mast Projects, 19 May 2009 Key Stakeholder Thank you for this comment.
not Vulcania Erf 10. Judging from the aerial maps, it is not affected Dalview Workshop, Brakpan
by any of the proposed pipeline routes.

The property on which WYDO Engineering is situated will not be Mr Wynand Hutchons WYDO Engineering 19 May 2009 Key Stakeholder Thank you for this comment
affected by the proposed pipeline. The adjacent property (A49), Workshop, Brakpan
which is vacant land, will be affected by the proposed collection line.

What is the basis for this project “traversing” private land. The Adv Riaan Jonker Newmarket Property 21 May 2009 E-mail The issue surrounding use of servitudes appears to have been
answer at the Workshop was in essence that as far as private land is Development JV misunderstood.
concerned that there are servitudes that may be used, for example, Firstly, existing pipeline servitudes held by participating mining companies
South African Railway servitudes, etc. As I understand, if a servitude will be used preferentially. In all other areas alignment of the proposed
is granted, for example, for Transnet, then it can be used by Transnet pipelines will, wherever possible, follow other linear infrastructure (railway
for its purposes, but not for other purposes. In other words, that one lines, roads etc). The proponent (WUC) must still acquire the right to use
cannot use a Transnet servitude for what WUC wants to do. Then, it such servitudes. This right must be obtained from both the primary
was indicated at the workshop that discussions will take place with property owner and, in the case of shared services, the existing servitude
owners of land. That answer is concerning. For a member of the holder as well. From an EIA perspective,the suggestion is merely that the
public, sitting at such a meeting, or in similar meetings and to be impact on the environment, including on private land owners, is minimised
advised that for example Transnet servitudes can be used, raises a if the linear infrastructure associated with the proposed WUC project can
serious concern. What is the basis for saying this to the public? be aligned in areas where other types of linear infrastructure already exist
Most probably such members of the public will simply just accept so as to minimise fragmentation of properties. In contrast, if this was not
same to be correct, but is it? The public must be informed correctly done the proposed pipelines would result in further fragmentation of the
what the position is – is this done? It was indicated that some R65 environment in areas not already impacted by linear infrastructure. Thus,
million has already been spent on this project but then there is no there is no suggestion that a pipeline can be placed inside a rail servitude,
clear answer to such a very fundamental issue forming part of such a for example, without the need to acquire servitude rights for placement of
project. Proper legal opinion will have to be obtained as part of this the pipeline.
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.
Railway servitudes are registered for use for by the railway. Can a Adv Riaan Jonker Newmarket Property 20 May 2009 Key Stakeholder The intent is to make use of existing linear servitudes were ever possible in
servitude be used for another function as for which it has been Development JV Workshop, Alberton order to minimise impact on private land owners. This does not mean that
registered? A legal opinion should be obtained about this matter. 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 Mr Dave Kahts BP, Newmarket 20 May 2009 Key Stakeholder This aspect will be addressed in the EIA.
the BP filling station between the Eskom line and the stormwater Workshop, Alberton
trench.
There doesn’t seem to be any impact on the properties for which I Mr Peter Lin Pam Golding, 19 May 2009 Key Stakeholder Thank you for this information.
am acting as representative. These are vacant properties that were Brakpan Workshop, Brakpan
bought as investment.

Page 5 of the BID states that in some areas the pipelines may Mr Tshireletso Mataboge Department of Water 28 May 2009 Letter Noted. Thank you.
traverse private land. Therefore, proof of agreement between the and Environmental
landowners and the applicant should be provided in the Scoping Affairs
Report.

Comments Response Report


Draft Scoping Repot 20 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
Have the pipeline/railway crossings been identified yet? Mr Patrick Mtzenga Transnet 15 April 2009 Pre-consultation yes, the engineering team has identified these crossings. Individual
meeting 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 Mr Patrick Mtzenga Transnet 15 April 2009 Pre-consultation Comment noted with thanks.
should be issued after detailed discussions with the relevant meeting
Transnet engineers. This is quite a lengthy process; discussions
therefore need to commence as soon as possible.

Two Transnet Depots will be impacted: Isando Depot in the Eastern Mr Patrick Mtzenga Transnet 15 April 2009 Pre-consultation Comment noted with thanks.
Basin and Krugersdorp Depot at Millsite in the Western Basin. The meeting
Transnet contact people for these depots are Linda Skarupke and
Trevor Oosthuizen respectively.

There is a new Transnet directive regarding access to Transnet land. Mr Patrick Mtzenga Transnet 15 April 2009 Pre-consultation Comment noted with thanks.
Transnet is no longer giving servitudes but rather wayleave. meeting

Please note that there are two entrances to the Methodist church just Mr Peter Nancarrow Methodist Churh, 15 May 2009 Telephonic comment Noted with thanks. This will be discussed in detail before construction
off Heidelberg Road. If construction were to impact on the main gates Alberton begins.
and access to the church, we can use the additional gate in Ascot
Road.
Please provide Scaw Metals with the land surveyor general Ms Nicoletta Pera Scaw Metals 20 May 2009 Key Stakeholder This information will be provided.
information. Workshop, Alberton

The proposed line from Rand Uranium Harmony Shaft 8 to West Mrs Barbara Rush Landowner, 06 May 2009 Comment Sheet Thank you. We will look into this with the engineering team.
Wits Shaft 4 seems to be extremely close to my home. Krugersdorp

A servitude cannot be used for another purpose than for which it was Ms Elizabeth Smit Ekurhuleni Metro 20 May 2009 Key Stakeholder Comment noted with thanks. This aspect will be verified as part of the EIA.
registered. However, a new servitude can be registered. Workshop, Alberton

Excavations in the Scaw parking area to lay the pipeline will be Mr Jurgen Theiss Scaw Metals Group 15 April 2009 Pre-consultation Thank you for bringing this to our attention.
problematic. WUC will have to come up with a strategy to address meeting
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.

Scaw Metals uses the railway line and services crossing. Mr Jurgen Theiss Scaw Metals Group 15 April 2009 Pre-consultation This will be taken into account during the design and construction of the
meeting pipeline.

The borders and boundaries of Scaw Metals' properties and Mr Jurgen Theiss Scaw Metals Group 15 April 2009 Pre-consultation Comment noted with thanks.
servitudes are unclear to me at this stage. As soon as I have meeting
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 Mr Jurgen Theiss Scaw Metals Group 15 April 2009 Pre-consultation Comment noted with thanks.
Road) also belongs to Scaw Metals. meeting

I understand the complexities surrounding mine water in the Mr Jurgen Theiss Scaw Metals Group 15 April 2009 Pre-consultation Comment noted with thanks.
Witwatersrand area and support the concept of the proposed meeting
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 Response Report


Draft Scoping Repot 21 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
Would the proposed buffer zone limit Cosira to add infrastructure? Mr Eduardo Trombetta Cosira Group 21 May 2009 Key Stakeholder No. The proposed pipelines will be constructed in the servitude at the back
Workshop, Randfontein of the Cosira Witpoortjie properties.

There is an existing pipeline at the back of the property (Witpoortjie Mr Eduardo Trombetta Cosira Group 21 May 2009 Key Stakeholder Thank you for this information.
117, Ptn 184, PP nr A 64). Workshop, Randfontein

Cosira has added further infrastructure to the factory and it now fills Mr Eduardo Trombetta Cosira Group 21 May 2009 Key Stakeholder Thank you for this information.
the entire property (below the servitude indicated as A130). Workshop, Randfontein

The proposed pipelines will run within mine land for much of the Mr Danie Van der Merwe Water Services, 20 May 2009 Key Stakeholder We appreciate your comments and advice.
routes. Mines have servitudes and also the right of access on these Ekurhuleni Metro Workshop, Alberton
servitudes. Will new servitudes need to be registered? If so, it may
be a good idea to register these under WUC.

PROJECT INFRASTRUCTURE
While it is noted that the Klipriviersberg Reservoir has the capacity to Mr Andrew Barker Andre Barker 20 May 2009 E-mail Alternatives are written up in an alternatives report that will be an appendix
accommodate the potable water output, I questioned what other Development to the Draft Scoping Report. The Germiston Reservoir was also considered
storage facilities and opportunities had been considered and carefully Consultant as an alternative but, this reservoir has capacity roughly equal to the
examined as alternative bulk water storage facilities/solutions. 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 Mr Garth Barnes WESSA 20 May 2009 Key Stakeholder The plug and pump station is a key components of the proposed project,
the plug and pump station in the Central Basin be a temporary Workshop, Alberton and will remain in place to maintain water levels below CRG’s mineral
solution until the project is up and running? 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 21 May 2009 Key Stakeholder Risk of environmental contamination through pipe failure or leaks will be
Environmental Action Workshop, Randfontein evaluated as part of the impact assessment process.
Group

Will the pipelines be on the surface or buried? Mr David Hall Dura Soletanche 20 May 2009 Key Stakeholder Various sections of the pipeline will be on surface and will be buried.
Banchy Workshop, Alberton 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 20 May 2009 Key Stakeholder The Eastern Basin collection pipeline to ERPM will maintain a pressure of
Banchy Workshop, Alberton 2 500 kPa.

For what period of time will private properties be traversed to Adv Riaan Jonker Newmarket Property 20 May 2009 Key Stakeholder It is estimated that the pipeline construction period will be 6 to 8 months.
construct the pipelines? Development JV Workshop, Alberton The potential impact on an individual property owner will typically be much
shorter.

The presentation stated that four potential sites have been identified Mr Peter Kelly Department of 21 May 2009 Key Stakeholder Yes. It is proposed that a plug and pumping system be constructed at the
for the Plant; however, has a decision been made where the Minerals and Energy Workshop, Randfontein South West Vertical shaft.
proposed pump station will be located?

When do you envisage to commence with the construction of the Mr Peter Kelly Department of 21 May 2009 Key Stakeholder Construction is envisaged to start by the end of June 2009. That will
plug system? Minerals and Energy Workshop, Randfontein enable the plug system to be operational by the end of 2009.

More details are needed on the construction of a new WTP Ms Nozipho Maduse City of Johannesburg 08 May 2009 Meeting with City of An existing pre-treatment plant at ERPM will be upgraded and a new By-
mentioned in the BID. Johannesburg product Recovery Plant will be constructed at the same site. Further
details will be provided on the Draft Scoping Report and EIA reports.

Comments Response Report


Draft Scoping Repot 22 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
It must be noted that in terms of Government Notice 704, Regulation Mr Tshireletso Mataboge Department of Water 28 May 2009 Letter Thank you for this advice.
6 Capacity requirements of clean and dirty water systems, sub- and Environmental
section (d) stipulates that every person in control of a mine or an Affairs
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.

Will the infrastructure between the connection shaft in the Central Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of In any built-up area pipelines will be buried.
Basin and ERPM be located underground? Johannesburg

Which existing Water Treatment Plants will form part of this project? Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of The existing WTPs at Grootvlei in the east and at ERPM (Central) will be
Johannesburg 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 Mr Michael Oberholzer Chief Director: 19 May 2009 Key Stakeholder The plug system is proposed for the South West vertical shaft. The plug
decision to opt for a plug system? Mineral Regulation, Workshop, Brakpan and pump system is proposed as a technica solution which can be
Department of implemented within the tight time lines associated with protecting the mine
Minerals and Energy reserves of Central Rand Gold.

The purpose of this message is to introduce our company and in Mr Tommie Smith Clampon (Pty) Ltd 11 May 2009 E-mail Thank you. Please contact WUC directly.
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.

There are many uncertainties in this project that has not been Prof Frans Waanders Northwest University 21 May 2009 Key Stakeholder Reports are currently being collated, incorporating information on the
cleared yet, such as pump station failures that can’t be planned by Workshop, Randfontein various geochemical and other studies that have been conducted over
models. 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 Prof Frans Waanders Northwest University 21 May 2009 Key Stakeholder In all areas were high settlement densities occur the pipeline will be buried.
into the pipe, despite it carrying AMD, should be considered. Workshop, Randfontein

Where will the pump stations will be located? Mr Peter Withinshaw City of Johannesburg 08 May 2009 Meeting with City of Pump stations will be located at each of the mine water collection shafts ,
Johannesburg 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 The reservoir is located on the hilltop immediately to the west of Alberton,
Johannesburg and East of Glenvista.

PUBLIC PARTICIPATION
Please advise me of any public meetings that may take place with Mr Andrew Barker Andrew Barker 21 April 2009 E-mail We will do so.
respect to this application. Development
Consultant

Comments Response Report


Draft Scoping Repot 23 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
I confirm that your professional team agreed to provide me with a CD Mr Andrew Barker Andre Barker 20 May 2009 E-mail Thank you. This information will be provided.
containing the available maps and plans and documentation for Development
closer examination. In this regard, we may require the opportunity to Consultant
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.

Please forward maps of all the basins, an electronic copy of the BID Mr Andrew Barker Andrew Barker 19 May 2009 Key Stakeholder Certainly, this information will be provided.
as well as the presentation done by WUC. Development Workshop, Brakpan
Consultant

From our discussions at the workshop I was under the impression Mr Andrew Barker Andrew Barker 01 June 2009 E-mail Copies of the relevant documents will be forwarded to you as soon as they
that the maps would be put onto a CD and delivered to me shortly Development are available.
after the workshop so that I could examine the routes and make Consultant
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.

If a concurrent public participation process is to be followed, Mr Garth Barnes WESSA 20 May 2009 Key Stakeholder Subsequent to the completion of the comment period on documents (i.e.
comments from authorities as well as public comments should be Workshop, Alberton 4weeks), all comments received from authorities and the public will be
reflected in the final documents. 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 Mr Michiel Bothma Randfontein 21 May 2009 Key Stakeholder Issues related to the water problems in the Witwatersrand gold mining
shared before and on a bigger public scale? Environmental Action Workshop, Randfontein basins have been widely discussed in various forums since the mid-1990s
Group

The technical information shared during today’s workshop is not very Mr Michiel Bothma Randfontein 21 May 2009 Key Stakeholder A comprehensive public consultation process is taking place as part of the
accessible to the broader public. Environmental Action Workshop, Randfontein EIA process. Stakeholders have access to all project information through
Group this process.

People at grassroots level feel that everything has been planned and Mr Michiel Bothma Randfontein 21 May 2009 Key Stakeholder Public consultation is taking place at a variety of levels, including in small
decided. Only now that the scheme has been decided on, are they Environmental Action Workshop, Randfontein groups at a grass roots level. Trained facilitators are available to assist
being consulted. Group people to interpret and contribute to the project through these meetings.

Property owners should be involved in the project process to ensure Mr Michiel Bothma Randfontein 21 May 2009 Key Stakeholder The EIA process is a public process to which all members of the public can
they are aware of the potential impacts on their properties. Environmental Action Workshop, Randfontein register stakeholders to participate in the process.
Group

It is not clear how Focus Group Meetings can be held before Dr Henk Coetzee Council for 23 April 2009 Comment Sheet I&APs were initially provided with the opportunity to register during the
registration of I&APs. Geoscience 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 Mr Klem Courie Klipriviersberg Nature 02 May 2009 E-mail Thank you for this comment.
the project but seeks to ensure that natural areas are protected from Reserve Association
untoward developments.
The BID is a useful summary, however, more detail is required, for Dr Richard Doyle Environmental and 13 May 2009 Comment Sheet WUC is busy with a feasibility study that includes refinement of the
example on the economics, to make a full judgement. It would be Remedial Technology financial model. This information is, understandably, of a confidential
useful if the business case was made available. Holdings (Pty) Ltd 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 Mr Bruce Ebell DRD Gold 17 April 2009 Comment Sheet Comment noted with thanks.
project.

Comments Response Report


Draft Scoping Repot 24 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
We would like to attend a meeting on the project. Mr Willy Fuzani Umlambo Pride Bee 30 April 2009 Comment Sheet We welcome your attendance at the open house meetings that will run
Construction Projects during the scoping process

It is very important to consider the people who live next to the area. Mr Willy Fuzani Umlambo Pride Bee 30 April 2009 Comment Sheet A broad-based public consultation process is running as part of the impact
Awareness creation and meetings are advised. Construction Projects assessment process

Please send me a big aerial map of the proposed route for exhibition Mr Henning Germishuys Laerskool 21 May 2009 Key Stakeholder The public participation team appreciates the assistance offered. Maps will
at the school, where people from the Witpoortjie community can also Culembeeck, Workshop, Randfontein be forwarded to the school at the same time when the Draft Scoping
have access to it. I will also be able to provide information on Witpoortjie Report is made available for public comment.
community representatives in the Witpoortjie area.

The BID was helpful and shows the location and scope of work Mr David Hall Dura Soletanche 24 April 2009 Comment Sheet Thank you
required. Bachy

Please add the following Central Rand Gold officials to the list of Mrs Jenny Johnson Central Rand Gold 17 April 2009 Comment Sheet Comment noted with thanks.
stakeholders: Mr Mike Sullivan and Mr Paul Housler.

Our property is Erf 248 Newmarket Park Ext 15. I am the Mr Riaan Jonker Newmarket Property 13 May 2009 E-mail Noted. Thank you.
representative of the owners thereof, namely Rejem Property Development
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.

The BID was not useful, since it contained too little detail. Mr Garfield Krige African Environmental 29 April 2009 Comment Sheet Thank you for this comment
Development

Please notify stakeholders well in advance of events such as Mr Frans Le Grange Exotic Properties 22 May 2009 Comment Sheet Thank you. Stakeholders are notified well in advance of meetings
meetings.
We strongly advise that "…the participation of all interested and Ms Mariette Liefferink Federation for a 05 May 2009 Letter Thanks for this comment. A broad public participation process forms part
affected parties … must be promoted, and all people must have the Sustainable of the EIA.
opportunity to develop the understanding, skills and capacity Environment
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.

Comments Response Report


Draft Scoping Repot 25 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
The ability of individuals to participate in the process is likely to vary Ms Mariette Liefferink Federation for a 05 May 2009 Letter Thank you for this comment. A broad public participation process forms
considerably depending on a number of factors: Socio-economic Sustainable part of the EIA. This process includes small meetings with various groups
status; education; ability to write and speak English; access to Environment of stakeholders, including disadvantaged communities. These meetings
information on environmental legislation and scientific reports; ability are held in the language of choice with trained facilitators available to
to purchase expert advice. The ability of groups to participate interact with people in a variety of languages
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.
The majority of the affected communities are indigent. It is hoped Ms Mariette Liefferink Federation for a 05 May 2009 Letter Thank you for this comment. A full public participation process is being
that the Applicant will consider providing financial assistance or a Sustainable run. Small group meetings are being held with stakeholders throughout the
specific fund for those parties who cannot afford to pay transportation Environment project area. Trained facilitators are available to assist stakeholders to
fees to attend and participate in public participation meetings. understand and contribute to the EIA process.
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.

Environmental remediation programmes are often presented to local Ms Mariette Liefferink Federation for a 05 May 2009 Letter Thank you for this comment.
communities as fait accompli and any opportunity for real input of Sustainable
local ecological knowledge is lost or deliberately ignored in an Environment
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.

In South Africa, a successful commercial farmer is likely to have Ms Mariette Liefferink Federation for a 05 May 2009 Letter Thank you for this comment. The full public participation process is being
greater capacity to negotiate and influence decision making Sustainable run. This process is structured to engage stakeholders at different levels
pertaining to environmental issues than his impoverished rural Environment and with different technical backgrounds and language competencies.
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.

The challenge to the appointed EAP and the Applicant is to take Ms Mariette Liefferink Federation for a 05 May 2009 Letter Thank you for this comment. The full public participation process is being
proper cognisance of local views of the environment and dispense Sustainable run. This process is structured to engage stakeholders at different levels
with insular and short-term views of public participation. Outsiders Environment and with different technical backgrounds and language competencies.
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 Response Report


Draft Scoping Repot 26 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
Unfortunately as a result of the country's apartheid past, the broad Ms Mariette Liefferink Federation for a 05 May 2009 Letter Thank you for this comment. The full public participation process is being
South African public has not been able to develop a strong culture of Sustainable run. This process is structured to engage stakeholders at different levels
participation in environmental processes, nor has it learned to Environment and with different technical backgrounds and language competencies.
successfully articulate its interests.

Appropriate communication tools are needed to inform local Ms Mariette Liefferink Federation for a 05 May 2009 Letter Thank you for the comment. The full public participation process is being
communities of environmental hazards or risks and how local Sustainable run. This process is structured to engage stakeholders at different levels
communities can get involved when it comes to making decisions Environment and with different technical backgrounds and language competencies.
about remediation programmes. Poor rural communities have their Specific attention is given within this process to engage with community
own existing community organizations and decision-making representatives and existing community bodies.
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.

Largely because of the power of e-mail and the internet, commercial Ms Mariette Liefferink Federation for a 05 May 2009 Letter A full public participation process is being run. This process includes
consultants conduct public participation processes using electronic Sustainable various stakeholder meetings at different levels, including small group
tools. The majority of the inhabitants of the West Rand, however do Environment meetings with directly affected communities. At these meetings trained
not have access to e-mail hence is prevented from participation. 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 Ms Mariette Liefferink Federation for a 05 May 2009 Letter This comment. The full public participation process is being run. This
often not flexible enough to take into account the unique Sustainable process is structured to engage stakeholders at different levels and with
circumstances of local and indigent mining communities. Environment different technical backgrounds and language competencies.

Negative perceptions of real or perceived environmental impacts Ms Mariette Liefferink Federation for a 05 May 2009 Letter Thank you for this comment
within West and Far West Rand Gold Fields have been fuelled by an Sustainable
apparent unwillingness of regulators and industry to discuss these Environment
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.
We recommend: Sufficient time to consult. The sharing and Ms Mariette Liefferink Federation for a 05 May 2009 Letter Thank you for this comment
increasing understanding of information and the likelihood of a Sustainable
change in the proposal. It involves dialogue and feedback. Listening Environment
is just as important as talking.

In the legal precedents established inter alia the State v Smith and Ms Mariette Liefferink Federation for a 05 May 2009 Letter A full public participation process is being run. This process includes
Earthlife Africa v DG of DEAT and Eskom Holdings Ltd it was found Sustainable various stakeholder meetings at different levels, including small group
that consultation is not: Merely telling or presenting: consultation is Environment meetings with directly affected communities. At these meetings trained
a two-way process, Intended to be a charade. The same as facilitators are available to assist stakeholders to engage with the process
negotiation. Consultation needs to be conducted in mutual good faith and stakeholders are able to interact in their language of choice, including
and to a degree sufficient for the authorizing authority to familiarize all local African languages.
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 Response Report


Draft Scoping Repot 27 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
We refer to Shelley Arnstein's (1969) essay on public participation Ms Mariette Liefferink Federation for a 05 May 2009 Letter A full public participation process is being run. This process includes
whereby it was stated: Inviting citizen's opinions, like informing them Sustainable various stakeholder meetings at different levels, including small group
can be a legitimate step towards their full participation. But if Environment meetings with directly affected communities. At these meetings trained
consulting them is not combined with other modes of participation, facilitators are available to assist stakeholders to engage with the process
this run is still a sham since it offers no assurance that citizen and stakeholders are able to interact in their language of choice, including
concerns and ideas will be taken into account. The most frequent all local African languages.
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 Ms Mariette Liefferink Federation for a 05 May 2009 Letter A full public participation process is being run. This process includes
enables the have not citizens, presently excluded from the political Sustainable various stakeholder meetings at different levels, including small group
and economic processes, to be deliberately included in the future. It Environment meetings with directly affected communities. At these meetings trained
is the strategy by which the have-nots join in determining how facilitators are available to assist stakeholders to engage with the process
information is shared…" We recommend the following communicative and stakeholders are able to interact in their language of choice, including
strategies: Cultivate community networks; Listen Carefully; Notify all local African languages.
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 Ms Mariette Liefferink Federation for a 20 May 2009 E-mail Thank you. We reiterate however that only issues addressed directly to
me in my capacity as CEO of the Federation for a Sustainable Sustainable the EIA team will be taken up in the process. No consideration will be
Environment (FSE). I respectfully request inclusion of these Environment given to issues not addressed to the EIA team by a register stakeholder.
documents, which are subjoined and appended hereto, in the Prof Leslie Stoch has been contacted by the public participation office and
Comments and Response Report. My office is to disclose or portray he has confirmed that he does not want to participate in the current
the concerns or issues raised by members of the public not to project.
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)
The public participation process should be extended to include the Ms Mariette Liefferink Federation for a 21 May 2009 Key Stakeholder Thank you for the comment. The full public participation process is being
marginalised, disadvantaged and disempowered communities, not Sustainable Workshop, Randfontein run. This process is structured to engage stakeholders at different levels
only ward councillors as their representatives. Environment and with different technical backgrounds and language competencies.

Will local people participate in the project? Mr Victor Manavhela Gauteng Department 14 May 2009 Meeting with the The proposed project will contribute a number of permanent employment
of Agriculture GDACE opportunities. During construction a larger number of employment
Conservation and opportunities will be created. During the feasibility process, the potential
Environment 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 Mr Tshireletso Mataboge Department of Water 28 May 2009 Letter A full record of the public participation process followed will be included in
Processes. and Environmental submission of final reports for decision-making.
Affairs

Comments Response Report


Draft Scoping Repot 28 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
All ministers of the following national government departments should Mr Chris Mentz Grasslands/Ten 30 April 2009 Comment Sheet Noted. Thank you
be consulted: DEAT, Department of Water and Environmental Acres Forum
Affairs, Department of Minerals and Energy, Health and Agriculture.
All MECs of the Gauteng Province should also be involved.

Involve the relevant departments of the following universities: Mr Chris Mentz Grasslands/Ten 30 April 2009 Comment Sheet Noted. Thank you
Johannesburg, Wits and Tuks Acres Forum

The map on the second last page of the BID does not include the Mr Chris Mentz Grasslands/Ten 30 April 2009 Comment Sheet This is a concept level map. Detailed maps will be included in the draft
Western Basin up to Klerksdorp, which it should. Acres Forum scoping report.

The stakeholder groups represented at this workshop do not seem to Mr Chris Mentz Grassland, Ten Acres 21 May 2009 Key Stakeholder An extensive public consultation process is being run as part of the EIA.
be very representative of the broader affected area. Randfontein, Forum and Workshop, Randfontein This includes a range of focus group meetings with different sectors of the
Westonarea and the Randfontein Western District Municipalities Randfontein stakeholder group, based on common interest
should also have been invited to this workshop. Environmental Action
Group

Please ensure that advertisements for participation in this project Mr Chris Mentz Grassland, Ten Acres 21 May 2009 Key Stakeholder Advertisement of the EIA process has taken place through a variety of
take place on a bigger scale, in order to reach a broader range of Forum and Workshop, Randfontein printed media including local newspapers in circulation across the full width
stakeholders who also have a stake in this project. “Local’ Randfontein of the project area. In addition, site-specific notices have been placed
announcement of the project, EIA and public participation processes Environmental Action along the preferred and alternative routes and plant site locations.
would mean publicising advertisements, including an advertisement Group
of the open houses, in the Herald and TK News in the Randfontein
area.
With regard to the Authority Steering Committee for the proposed Ms Deborah Mochlotodi Department of Water 20 May 2009 Key Stakeholder An invitation to the Authority Steering Committee meeting held on 26
project, provide clarity on the following:· Whether I was invited to and Environmental Workshop, Alberton March 2009, was sent to the following delegates from Department of
the Authority Steering Committee meeting or not, Which delegates Affairs Water and Environmental Affairs: Mrs Thandiwe Buthelezi, Mr Marius
from the Department of Water Affairs and Forestry (Department of Keet, Ms Debra Mochotlhi, Mr Molefe Morokane, Ms Pamela Mqulwana,
Water and Environmental Affairs) attended the meeting, and · In Mr Nndanganeni Musekene, Mr Seef Rademeyer, Mr Matthew Senne, Mr
what capacity did the Department of Water and Environmental Affairs Hennie Smit and Mr Jurgo van Wyk. The following Department of Water
delegates attend the meeting. 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 Ms Lebo Molefe City of Johannesburg 07 May 2009 Comment Sheet Thank you for this comment.
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.
Community engagement will be difficult for this EIA. Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of A full public consultation process is taking place as part of the EIA. This
Johannesburg 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 Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of Ward councillors will indeed be consulted with and will be given support to
process. Johannesburg be able to convey the information to the communities.

Other directorates within the Department of Water and Mr Molefe Morokane Department of Water 24 April 2009 Comment Sheet Noted. Thank you
Environmental Affairs have to be consulted, i.e. Water Resource and Environmental
Planning. Affairs

Please add the following Department of Water and Environmental Mr Molefe Morokane Department of Water 24 April 2009 Comment Sheet Done. Thank you
Affairs officials to the database: Messrs Matthew Senne and Pieter and Environmental
Viljoen Affairs

Comments Response Report


Draft Scoping Repot 29 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
The BID was useful, although not very clear on water uses to be Mr Molefe Morokane Department of Water 24 April 2009 Comment Sheet Thank you for this comment
exercised. and Environmental
Affairs

The department will appoint an official who will liaise with the project Mr Daniel Motaung Gauteng Department 14 May 2009 Meeting with the The EIA team looks forward to receiving the name of the dedicated official.
team in the future. Until this official is appointed, the project team of Agriculture, GDACE We will keep the Department informed of progress.
must liaise with Mr Manavhela and Mr Motaung. Conservation and
Environment

Has pre-consultation taken place with authorities and municipalities? Mr Koogan Naidoo Mogale City Local 21 May 2009 Key Stakeholder Yes, various meetings have taken place with authority groups including
Municipality Workshop, Randfontein 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 Mr Peter Nancarrow Methodist Churh, 15 May 2009 Telephonic comment Noted with thanks.
providing us with good information and replying to our queries. Alberton

Ground level communication regarding this project is necessary, Cllr Dudu Ngubane Kagiso 21 May 2009 Key Stakeholder Comment noted with thanks.
which includes community involvement and explaining technical Workshop, Randfontein
information in lay man’s language.

Due to the sensitivity of the area all interested and affected parties Mr A Ramokolo Metsi-A-Lekoa, 19 May 2009 Letter A full public consultation process is taking place as part of the impact
must be informed to be able to make an informed decision about the Emfuleni Local assessment process
proposed mine water reclamation project. Municipality

Meetings should be held with affected landowners in the affected Mrs Barbara Rush Landowner, 06 May 2009 Comment Sheet A full public consultation process is being run, which includes meetings
areas. Krugersdorp with directly affected land owners.

There should be more awareness creation among the public. The Mr Shan Rush Rush Enterprises, 06 May 2009 Comment Sheet A full public consultation process is being run, which includes open
person in charge of the proposed project should be identified and Krugersdorp houses.
meetings should be held.

We run a successful business in the area of the proposed pipeline Mr Shan Rush Rush Enterprises, 06 May 2009 Comment Sheet Maps are being refined and finalised and will be available with the Draft
and would like to be told in detail where the pipeline will run. Krugersdorp Scoping Report. The route will also be discussed personally with all
landowners possibly being affected.

The Background Information Document reached us after the Mr Shan Rush Rush Enterprises, 06 May 2009 Comment Sheet Comments are welcome and considered right through the EIA process.
comment period was over. Krugersdorp

Future communication with the NNR should be done directly through Mr Thabo Tselane National Nuclear 20 April 2009 Meeting with National Noted. Thank you
the NNR specialist, Mr Mogwera Khaothane, and preferably only Regulator Nuclear Regulator
after the submission of the relevant application.

The NNR prefer not to be part of the Authorities Steering Committee. Mr Thabo Tselane National Nuclear 20 April 2009 Meeting with National noted. Thank you.A document outlining the purpose and objectives of the
The NNR would only be involved in the project once an application Regulator Nuclear Regulator Authority Steering Committee was forwarded to the NNR, so that, should
has been submitted. Subsequent to the submission of the an application be submitted to the NNR, the relevant official can make an
application, an official would be assigned to the project and would informed decision about becoming part of the ASC or not.
work directly with the NNR specialist.

Comments Response Report


Draft Scoping Repot 30 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
Community engagement is vital for this project. How will communities Mr Aaron Tsoku Mogale City Local 21 May 2009 Key Stakeholder A full public participation process is being run. This process includes
and ward councillors be involved in the public participation process? Municipality Workshop, Randfontein 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 Dr Anthony Turton TouchStone 15 May 2009 E-mail Noted. Thank you.
prejudices our position. We might therefore ask a third party to Resources (Pty) Ltd
formally enter into the record a document from us stating what our
position in this matter is.

Please record the fact that this is a very short period of time to deal Dr Anthony Turton Lit Creations 29 May 2009 E-mail The legacy issues of mining pose a significant environmental risk, which
with an issue of this magnitude and implication. I reserve the right has been known for many years. WUC, on behalf of the affected mines,
to enter my concerns into the official record of decision. 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 Mr Eugene Viljoen Resident, 15 May 2009 E-mail When the EIA report is submitted for authorisation, it is accompanied by a
process when submitted to the Various Departments for approval Noordheuwel 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 Mr Eugene Viljoen Resident, 22 May 2009 E-mail A broad public participation process is being run as part of the EIA. A
makers in the area, and the provision of seating arrangements too, Noordheuwel number of meetings with different stakeholder groups are being held.
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.

Present all details to either confirm our suspicions or prove us, the Mr Eugene Viljoen Resident, 22 May 2009 E-mail Various treatment technologies have been considered by WUC for the
objectors, wrong. Not to present all information, and to go ahead Noordheuwel proposed project. The CSIR's ABC process and the SAVMIN process were
without the public having prior insight, constitute a gross miscarriage chosen to be thoroughly investigated during Pilot Plant studies.
of the purpose of the Public Participation process. 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 Mr Eugene Viljoen Resident, 02 June 2009 Telephonic comment NEMA does not prescribe Public Meetings, neither does the Regulations
the Draft Scoping Report. That is what is stipulated by the NEMA. Noordheuwel (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 Mr Zwi Wagner Water Engineering 17 May 2009 Comment Sheet Stakeholders can register with the EIA process at any stage during the
brought to our attention on May 15, 2009 when the registration Systems Unlimited impact assessment. The initial date mentioned reflects a mandatory
process claims that 30 April 2009 is the last day. stakeholder registration period following date of publication of the EIA
announcement advertisements in printed media.

Comments Response Report


Draft Scoping Repot 31 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
The BID was useful because the introduction is short and complete, Mr Zwi Wagner Water Engineering 17 May 2009 Comment Sheet Thank you for this comment
allowing first time reader to understand in a glance the objectives of Systems Unlimited
the proposed solution. The capacity and process are clearly
described in the BID.

Has the project been announced yet? Mr Peter Withinshaw City of Johannesburg 08 May 2009 Meeting with City of Yes. The project was announced in April 2009.
Johannesburg

The City of Johannesburg’s geotechnical department should be Mr Peter Withinshaw City of Johannesburg 08 May 2009 Meeting with City of Thank you for the suggestion.
registered as an I&AP. Johannesburg

Please send me hard copies of all EIA documentation, when Mrs H Zwanziger WESSA 19 May 2009 Key Stakeholder Noted. Thank you.
available for public review. Workshop, Brakpan

The public, communities and NGOs need to be kept informed and Ms Hendrika Zwanziger WESSA 30 April 2009 Comment Sheet Thank you. The broad-based public consultation programme is running as
given the opportunity to submit comments at various stages during part of the impact assessment
the EIA/EMP process.

The BID was useful and confirms the need that stakeholders must Ms Hendrika Zwanziger WESSA 30 April 2009 Comment Sheet Thank you.
participate and submit more detailed comments.

SOCIO-ECONOMY
Will the value of properties deteriorate because it is traversed by Mr Michiel Bothma Randfontein 21 May 2009 Key Stakeholder Wherever possible, pipelines will be confined to existing servitudes. This
pipelines? Environmental Action Workshop, Randfontein will minimise the impact to private land ownership. Should it be necessary
Group 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 Mr Peter Lin Pam Golding, 19 May 2009 Key Stakeholder Wherever possible the proposed pipelines will be aligned wit in existing
proposed pipelines? Brakpan Workshop, Brakpan 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 14 May 2009 Meeting with the The project will create about 15-20 jobs during operational phase of the
of Agriculture GDACE project. About 200 people will be employed during construction phase of
Conservation and the project. Participation by local people in the project will be ensured as
Environment local people will be employed during construction.

Will communities be involved when infrastructure is constructed? Cllr Dean Stone Ekurhuleni 19 May 2009 Key Stakeholder The employment opportunities that will be created through the project are
Metropolitan Workshop, Brakpan described in the Draft Scoping Report.
Municipality

Will people working at the current operations, such as the pump Cllr Dean Stone Ekurhuleni 19 May 2009 Key Stakeholder The feasibility study needs to run its course. Through this process
stations at ERPM, be considered for employment by WUC? Metropolitan Workshop, Brakpan employment opportunities at the treatment plant and during construction
Municipality will be identified.

What is this project’s potential for job creation? Ms Elize Tempelhoff Beeld, Media 24 21 May 2009 Key Stakeholder The feasibility study needs to run its course. Through this process
Workshop, Randfontein 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 Mr Aaron Tsoku Mogale City Local 21 May 2009 Key Stakeholder A full public participation process is being run. In addition, the study
participation process? Municipality Workshop, Randfontein includes social impact assessment and macroeconomic impact
assessment.

Comments Response Report


Draft Scoping Repot 32 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
At the workshop you mentioned that old pipe lines (right of way) may Mr Eugene Viljoen Resident, 22 May 2009 E-mail The proposed project is motivated to address an environmental need. Job
be used. Alternatively the laying of new ones will only create Noordheuwel creation is not the primary objective. Potential employment creation
temporary work and a maintenance crew can serve the entire setup. through the project will be elaborated on in the Draft Scoping Report.
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?

SURFACE WATER
Impacts on the Blesbokspruit should be carefully considered. Mr Kimbton Chiota Pamodzi Gold East 29 April 2009 Comment Sheet Changes in the volume of water being discharged to the Blesbokspruit will
Discharge to the Spruit should be reduced. Rand receive consideration in the hydrology and ecology specialist reports.

If reduced discharge is studied, please also look at other upgrades in Mr Kimbton Chiota Pamodzi Gold East 19 May 2009 Key Stakeholder We understand this to referred to upgrade of existing water treatment
the area, such as Welgedacht. Rand Workshop, Brakpan 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 Ms Mariette Liefferink Federation for a 05 May 2009 Letter The proposed project is motivated by the need to restore the water level in
day. (Reference: www.geoscience.org.za.) Sustainable the Western Basin to a level below ECL, and provide a solution through
Environment 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 Mr Daniel Motaung Gauteng Department 14 May 2009 Meeting with the Noted. The hydrology and ecology specialist studies will address impacts
dam and its water is clearly contaminated as a yellowish colour can of Agriculture GDACE associated with change in the volume of water discharged from Grootvlei
be seen in the water. Conservation and Gold Mine (Pamodzi)to the Blesbokspruit.
Environment

Do we stand a chance to loose Germiston lake as a result of the Mr Cliff Patterson Ward Councillor, 20 May 2009 Key Stakeholder As part of the proposed project, current underground water levels will be
proposed project? Ekurhuleni Metro Workshop, Alberton 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 Mr Mike Sullivan Central Rand Gold 26 March 2009 Authority Steering The aim of the project is to sell as much water as possible to generate an
need to discharge partially treated water? Committee Meeting 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 Mr Mike Sullivan Central Rand Gold 26 March 2009 Authority Steering It is likely that during phase 1 some pretreated water will continue to be
site located at Grootvlei? Committee Meeting 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 Ms Elize Tempelhoff Beeld, Media 24 21 May 2009 Key Stakeholder Where relevant to the project studies will be done. The impact of change in
and rivers in the study area are done in the specialist studies. This Workshop, Randfontein discharge of pretreated water to the Blesbokspruit and Tweelopiespruit will
includes the Blesbokspuit and the Tweelopiespruit. be assessed in the EIA.

Comments Response Report


Draft Scoping Repot 33 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
It seems that upon commencement of the proposed project, the pre- Mr Danie Van der Merwe Water Services, 20 May 2009 Key Stakeholder Pretreated water is currently released down the Blesbokspruit from
treated water that is currently being discharged into rivers will now be Ekurhuleni Metro Workshop, Alberton Grootvlei Gold Mine (Eastern Basin)and down the Tweelopiespruit
taken out of the system and reclaimed as part of the proposed (Western Basin). In Western Basin, where water level within a
project. What impact will this have on streams and rivers in the compartment will be dropped to below the ECL. In the Eastern Basin some
already environmentally sensitive area? 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 Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet Those watercourses which could potentially be impacted on as a result of
Spruit, Tweelopiespruit, Klip River, Hugenotespruit, Mooi River, Noordheuwel the proposed project include those where partially treated mine affected
Leeuspruit, Loopspruit, Vaal River, Cradle of Humankind, Crocodile water is currently being discharged into (e.g. Blesbokspruit,
and Jukskei Rivers. 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 Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet The proposed project provides a self-sustaining solution to treat to potable
operation and once again it is separated from this project - the old Noordheuwel levels excess water within the circuit. The proposed project is motivated by
divide and rule principle. Tweelopiespruit is pouring out between 20 the need to manage excess water emanating from mines with in the
and 70 Mℓ per day into the Cradle caves system, the entire area Witwatersrand. The urgency of the situation in the Western Basin is noted
north of Krugersdorp game reserve. Let us, if necessary, implement
a bit of Gunboat Diplomacy.

You have not allowed for future shenanigans of the mines on both Mr Eugene Viljoen Resident, 22 May 2009 E-mail The proposed project is motivated to address these specific needs through
West and East Rand. Furthermore, the Steenkoppies aquifer (next to Noordheuwel a partial reduction in the water level in the Western mining compartment to
the Krugersdorp Game Reserve) is being flooded by the a level that lies below the environmental critical level.
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.
Refer to the environmental study conducted for the Tweelopiespruit Mr Eugene Viljoen Resident, 21 May 2009 Key Stakeholder Thank you for this valuable information.
catchment area by Stefan du Toit some time ago. It could be very Noordheuwel Workshop, Randfontein
useful for this EIA study.

How will the potential contamination in the entire Cradle of Mr Eugene Viljoen Resident, 21 May 2009 Key Stakeholder The answer to this question lies outside of the scope of the current EIA.
Humankind area be cleared up? Noordheuwel Workshop, Randfontein The proposed project will stop decant to the Tweelopiespruit.

Every region must have its water quota to wash the treated mine Ms Hendrika Zwanziger WESSA 30 April 2009 Comment Sheet The proposed project will reduce the salt load currently reporting into the
water through streams, lakes, dams and wetlands during the dry surface environment as part of the pre treated water stream. This will be an
season. 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 WATER
If there is a chance that the water quality may deteriorate, who will Mr Michiel Bothma Randfontein 21 May 2009 Key Stakeholder The issue of water quality in the Central Rand Basin will be addressed in
be held responsible and accountable? Environmental Action Workshop, Randfontein the water quality specialist
Group

What are the implications of the use of Barium which is highly toxic? Dr Richard Doyle Environmental and 13 May 2009 Comment Sheet Barium carbonate will be used as the primary input chemical. In the form
Remedial Technology as barium carbonate, it is not toxic. Risk associated with the use of Barium
Holdings (Pty) Ltd will be addressed through the impact assessment process

Comments Response Report


Draft Scoping Repot 34 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
Who will be the regulator of the water quality process and who will Mr Chris Mentz Grassland, Ten Acres 21 May 2009 Key Stakeholder The proponent will apply to Department of Water and Environmental Affairs
monitor the process to ensure polluted water is not distributed? Forum and Workshop, Randfontein an integrated water use licence. The potable water that is generated from
Randfontein the treatment plant will be tested by Rand Water prior to receipt of this
Environmental Action water into the system. Thus constitute independent quality control.
Group

What will the quality of the treated water be? Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of The treated water will under all operating conditions meet South African
Johannesburg drinking water standards and Rand Water requirements.

The project must ensure that the standard of potable water quality to Dr Bethuel Sehlapelo Rand Water 04 May 2009 Comment Sheet Agreed. A potable water holding facility is proposed to ensure adequate
be produced must be in line with that of Rand Water. 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, 20 May 2009 Key Stakeholder No agreement has been reached in this regard. WUC financial model is
Ekurhuleni Metro Workshop, Alberton 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 Mr Zwi Wagner Water Engineering 17 May 2009 Comment Sheet Water will be treated to published South African drinking water standards.
contained toxic materials such as uranium and cyanide and in the Systems Unlimited There will need to be various checks and balances within the treatment
case of the central areas may even contain Cr6. We recently heard plant system to ensure that these requirements are met. Treated water
that 22 municipalities could not keep to the legal water quality when holding facility is proposed to enable testing, handling and dispatch of
using fresh rivier water - here we want to treat water infected with potable water under controlled conditions. The testing of the treated
Uranium and possibly Cyanide. The Gauteng population will be potable water will be carried out by the receiving bulk water utility to
drinking an paying for this potentially toxic water. 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 Mr Zwi Wagner Water Engineering 17 May 2009 Comment Sheet No water will be introduced into the Rand water system that does not meet
may be affected. Systems Unlimited 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, Mr Zwi Wagner Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder Acidic saline water from the coal mining industry in South Africa is
contaminated with, amongst others, cyanide and uranium? Workshop, Brakpan 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 No agreement has been reached in this regard. WUC financial model is
Workshop, Brakpan 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 Mr Zwi Wagner Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder Water will be treated to acceptable South African drinking water standards.
water at 98 South African municipalities. Of the 98 municipalities, Workshop, Brakpan There will need to be various checks and balances within the system to
only 22 municipalities’ water complied with the required standards for ensure that these requirements are met. A treated water holding facility is
potable water. This included municipalities that used fresh, stream proposed to enable testing, handling and dispatch of potable water under
and rain water as source water. If the quality of potable water is controlled conditions. The testing of the treated potable water will be
already so poor, is it not advisable rather to treat AMD for industrial carried out by the receiving bulk water utility to ensure that the potable
use, rather than for potable use? There are heavy metals in AMD, water generated from the treatment plant meets the required potable water
such as chromium 6, cyanide and uranium, and these are potentially standard prior to transfer of this water into a the Rand Water Klipriversberg
very dangerous. bulk water reservoir.

Municipalities are not supposed to distribute water that isn’t up to the Mr Zwi Wagner Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder The potable water that will be generated will be subject to independent
required standards, but it happens. Workshop, Brakpan 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 Chlorination will occur at the centralised WTP site before pumping to the
Johannesburg Rand Water Klipriviersberg Reservoir.

Comments Response Report


Draft Scoping Repot 35 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
TREATMENT TECHNOLOGY
Will the CSIR technology be piloted here or has it been tested Mr Garth Barnes WESSA 01 May 2009 Letter The proposed technology has already been piloted and demostrated to be
before? If the former, how certain is the CSIR of the technology’s effective. The Specialist Studies will contain more information on the
efficacy and low impact on the environment? treatment technology.

The project proposes an environmental risk to the region if the Dr Richard Doyle Environmental and 13 May 2009 Comment Sheet The legacy issues of mining pose a significant environmental risk, which
technology does not work at scale. Remedial Technology has been known for many years. WUC, on behalf of the affected mines,
Holdings (Pty) Ltd 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 Mr Smuts Marais Water Quality 20 May 2009 Key Stakeholder WUC is currently investigating the use of an existing railway siding located
transportation. Manager, Ekurhuleni Workshop, Alberton in the vicinity of the proposed Water Treatment Plant site.
Metro

I have just been approached by a company that has technology to Dr Anthony Turton Lit Creations 21 May 2009 E-mail As indicated in the response about (issue 243) the proposed solution is a
remove radioactivity if this is an issue. They are now considering private sector initiative. Technology providers are welcome to contact
whether they wish to join a consortium of technology providers who Western Utilities Corporation to discuss technology matters, should they
were excluded from the first round. 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 Mr Danie Van der Merwe Water Services, 20 May 2009 Key Stakeholder It is proposed that coal fines, a waste product, be transported from nearby
the source of energy. Have other methods of thermal heating been Ekurhuleni Metro Workshop, Alberton coal mines to the proposed Water Treatment Plant site. There is a source
considered? 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 Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet An Air Quality Impact Assessment will be conducted as part of the EIA.
into the air daily? Refer to Air Pollution and Its impacts on the South Noordheuwel
African Highveld; Editors G Held, BJ Gore, AD Surridge, GR Tosen,
CR Turner, and RD Walmsley.

The two plants that the proposed technologies were tested at – are Mr Niels Von Ekesparre Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder This will be confirmed.
they still operational? Workshop, Brakpan

Is it viable and safe to move the project from a very small scale pilot Mr Niels Von Ekesparre Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder This is a key decision that the proponent company will evaluate in their
plant to a very big scale mega plant? Workshop, Brakpan 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 This process has been subject to pilot scale. It is common practice for
Workshop, Randfontein 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 Response Report


Draft Scoping Repot 36 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
The price of barium sulphates, for instance, is very high. WUC won’t Prof Frans Waanders Northwest University 21 May 2009 Key Stakeholder The proposed process involves recovery and reuse of Barium Carbonate.
be able to sell water for the price they indicate if they have to buy Workshop, Randfontein
barium sulphate.

The issue of the Acid Mine Drainage (AMD) solution by the Western Mr Zwi Wagner Water Engineering 17 May 2009 E-mail The legacy issues of mining pose a significant environmental risk, which
Utilities Corporation was brought to our knowledge only on May 15, Systems Unlimited has been known for many years. WUC, on behalf of the affected mines,
2009. This surprises us completely as we are discussing the propose a solution to this problem. This does not preclude any other
problem of eliminating toxic water accumulating in mines and already parties from pursuing ventures of their own subject to receipt of the
supplied equipment that will do exactly that, to miners in South necessary buy in from the mining industry and government.
Africa. Our environmentally friendly technology can be used as an Should the proposed treatment technology not work, it would not pose risk
alternative/complementary to the proposed WUC solution. I include a to the environment beyond that which currently exists.
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)

We reserve the right to register, because of the fact that our Mr Zwi Wagner Water Engineering 17 May 2009 Comment Sheet Western UtilityCorporation has the right to evaluate technology and select
company has been prejudiced because of the short time available to Systems Unlimited technology at their discretion. This does not preclude any other parties
respond. Our company believes the choice of the WUC technology from pursuing similar ventures.
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.

Open the [technology] selection process, make it public domain and Mr Zwi Wagner Water Engineering 17 May 2009 Comment Sheet Western Utilities Corporation has the right to evaluate technology and
let the public decide. Test and compare the alternative solutions and Systems Unlimited select technology at their discretion. This does not preclude any other
technologies with the emphasis on public safety and environmental parties from pursuing similar ventures.
sustainable solution.

We have been in discussion with mining companies regarding Mr Zwi Wagner Water Engineering 19 May 2009 Comment Sheet & E- Thank you for this information. Your technical suggestions and your
treatment of AMD for five years. We have an alternative technology Systems Unlimited mail contact details have been provided to Western Utility Corporation.
which will reduce scale in the water and limit the need to pump AMD. This EIA process however specifically addresses the proposed WUC
The technology will allow mines to directly re-use excess water, scheme. A solution that would be implemented at the level of an individual
reducing the purchase of treated water, and saving on the capital mining company would need to be taken by yourselves directly to that
and operating cost of the WUC scheme. Our UET water treatment company. The WUC proposal in no way precludes you from pursuing such
technology is an alternative/complementary environmentally friendly ventures.
and viable solution. (Comment summarised - full text available)

At what rate was the Pilot Plant at the CSIR run? Mr Zwi Wagner Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder At one cubic metre an hour (24 cubic meter per day).
Workshop, Brakpan
Is it possible to construct a Pilot Plant as a potential solution to Mr Zwi Wagner Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder Licences need to be obtained before water can be sold, and that approval
people without water? Workshop, Brakpan process is now being followed by WUC.

Does the pilot plant need authorisation to be constructed as a mega Mr Zwi Wagner Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder Yes, this is the subject of the current EIA.
plant? Workshop, Brakpan

The technology to treat the AMD seems very specific; can it be used Mr Steve Walker Sappi Fine Paper, 19 May 2009 Key Stakeholder This would need to evaluated based on the chemistry of the water that you
for other water treatment processes as well? Springs Workshop, Brakpan had in mind. We suggest you contact the proponent directly to have this
technical exchange.

WASTE
What measures will be put in place to ensure that the waste metal Mr Garth Barnes WESSA 01 May 2009 Letter These wastes are currently disposed of on to existing tailings dams. This
sludge and waste gypsum do not become an environmental hazard practice will continue in the interim, within the operating parameters of the
due to an over burden on the existent waste facility? tailings dams. Western Utility Corporation seeks to turn these wastes into
byproducts.

Comments Response Report


Draft Scoping Repot 37 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
How 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 In terms of managing the sludge and ash on the existing tailings facility, an
Workshop, Alberton agreement between the mines and WUC will be compiled.

There is a lack of clarity on the disposal of effluent (not an effluent Dr Richard Doyle Environmental and 13 May 2009 Comment Sheet There are ongoing waste studies that form part of the feasibility
free solution). Remedial Technology assessment. As indicated the sludge and coal ash residue will in the
Holdings (Pty) Ltd interim be disposed on mine tailings dam.

WUC needs to take cognisance of the NNR restrictions on the re- Mr Mogwera Khaothane Zimkile Consulting 20 April 2009 Meeting with National Radiological testing of the sludge had been done as part of the pilot plant
use of materials which could have potential radiological risks during Nuclear Regulator studies. Thank you for this comment.
their feasibility studies on the possible conversion of the sludges
emanating from the proposed Water Treatment Plant into cement
clinker, bricks, etc.

Impacts of disposal of waste at an existing mine waste disposal Ms Lebo Molefe City of Johannesburg 07 May 2009 Comment Sheet Noted. Thank you.
facility including information on the name of the facility, ownership
and rehabilitation plans should be made available.

Will a new slimes dam be constructed? Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of Sludge will be disposed of at an existing Tailings Storage Facility (TSF).
Johannesburg

If there is a zero waste factor for this project, how will the sludge be Mr Cliff Patterson Ward Councillor, 20 May 2009 Key Stakeholder WUC is in the process of investigating the feasibility of the converting the
treated? Ekurhuleni Metro Workshop, Alberton 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 Mr Cliff Patterson Ward Councillor, 20 May 2009 Key Stakeholder WUC is busy with ongoing investigation into creating byproducts from
houses. Ekurhuleni Metro Workshop, Alberton waste streams.

What happens to the ash that is produced as part of the process? Ms Vicky Shaw WESSA 19 May 2009 Key Stakeholder WUC is busy with ongoing investigation into turning waste streams into
Workshop, Brakpan 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 Mr Jurgo van Wyk Department of Water 26 March 2009 Authority Steering Mine water treatment plant sludge is currently disposed of together with
the sludge which will be generated during the water treatment and Environmental Committee Meeting mine tailings onto tailings dams. Discussions are underway investigating
process, but it requires disposal in the interim. The sludge will have Affairs continuation of this interim disposal, or new disposal options.
to be disposed of at a lined facility.

It is not ideal to dispose of the sludge at a mine tailings facility. Will Mr Jurgo van Wyk Department of Water 26 March 2009 Authority Steering Sludge from existing pre-treatment plants is currently disposed of onto
the tailings facility become WUC’s responsibility? and Environmental Committee Meeting existing tailings dams. WUCproposes to enter into an agreement with the
Affairs 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 Mr Jurgo van Wyk Department of Water 26 March 2009 Authority Steering During the interim deposition period of 5-8 years, the dam will remain
mine closure authorisation from the Department of Minerals and and Environmental Committee Meeting active and closure would not be possible. Thereafter, the normal mine
Energy? Affairs closure process could run its course.

Please investigate whether it is safe to use sludge for brick making. Mr Eugene Viljoen Resident, 21 May 2009 Key Stakeholder Yes, this forms part of the investigation into bringing the water treatment
Noordheuwel Workshop, Randfontein sludge to beneficial use. This study will be ongoing beyond the extent of
the EIA process

Comments Response Report


Draft Scoping Repot 38 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
WATER SOURCES
If there is a chance that the water quantity may deteriorate, who will Mr Michiel Bothma Randfontein 21 May 2009 Key Stakeholder The issue of water quality in the Central Rand Basin will be addressed in
be held responsible and accountable? Environmental Action Workshop, Randfontein the water quality specialist.
Group

Who will be responsible for the shafts and pump stations at depth, Mr Peter Kelly Department of 26 March 2009 Authority Steering WUC will be responsible at mine closure; pumping from depth will no
subsequent to mine Closure. Minerals and Energy Committee Meeting 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 Mr Justice Maluleke Department of Water 26 March 2009 Authority Steering Western Basin water will not be taken directly to the centralised water
be pre-treated before being pumped to the Central Basin, especially and Environmental Committee Meeting treatment plant. It will be reintroduced into the western portion of the
since there is an existing treatment facility in the Western Basin? Affairs 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 26 March 2009 Authority Steering The mine in the Eastern Basin, i.e. Pamdozi Gold's Grootvlei Mine, will
and Environmental Committee Meeting continue with pre-treatment during Phase I.
Affairs

The quantity and quality of the water to be treated should be clearly Mr Tshireletso Mataboge Department of Water 28 May 2009 Letter Noted. Thank you.
stipulated in the application. and Environmental
Affairs

Mine affected water from the Western Basin was used for the pilot Ms Annemarie Maurizi Water Quality 20 May 2009 Key Stakeholder Only water from the Western Basin was used for the pilot study as the
plant. Was water from the Eastern Basin also used in the study, as Manager, Ekurhuleni Workshop, Alberton water in the Western Basin has the poorest quality. It is anticipated that
this water is high in sodium and chloride? Metro 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 Mr Cliff Patterson Ward Councillor, 20 May 2009 Key Stakeholder Water will accumulate in old mine workings from a variety of sources
reservoir of unlimited water supply? Ekurhuleni Metro Workshop, Alberton 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, Mr Cliff Patterson Ward Councillor, 20 May 2009 Key Stakeholder Yes, WUC is not proposing to dewater the underground voids, but to
only be limited to the fill-up/ingress area? Ekurhuleni Metro Workshop, Alberton 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 Ms Vicky Shaw WESSA 19 May 2009 Key Stakeholder Because of the tight timelines associated with the proposed project, and
Basin? Workshop, Brakpan 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 A considerable volume of water within these three mining basins is
Committee Meeting 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 Response Report


Draft Scoping Repot 39 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
There is no study of the total RW used by the mines. Such a study Mr Zwi Wagner Water Engineering 21 May 2009 E-mail Thank you for this general comment. Such a study will not be done as part
may confirm our concern that this is the cause for AMD rise. Systems Unlimited of the scope for the water treatment project EIA.

Is the 75Mℓ that is mentioned to be the amount of water that will be Mr Zwi Wagner Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder The proposed water treatment plant will treat an average of 75 Mℓ of water
treated the balance of water after the mines have taken water for Workshop, Brakpan per day with peak throughput capacity for 100 Mℓ of water. This water is
their own use? Why can’t the mines use this water themselves? 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 Mr Steve Walker Sappi Fine Paper, 19 May 2009 Key Stakeholder Of this this indicates the Far Western Basin. At this stage, this basin does
represent? Springs Workshop, Brakpan not form part of the current scheme that may be included during proposed
phase 2 ramp up of the scheme.

WATER TREATMENT PLANT SITE


Where will the centralised Water Treatment Plant be constructed? Ms Lebo Molefe City of Johannesburg 07 May 2009 Comment Sheet This information will be provided in the draft scoping report
Details of impacts on the receiving environment should be provided.

Where is the nearest community in relation to the WTP? Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of There is an informal settlement adjacent to the proposed WTP site.
Johannesburg

OTHER COMMENTS AND ISSUES


In view of the need to look at the long-term issues and problems of Mr Andrew Barker Andre Barker 20 May 2009 E-mail Thank you for this information. The underground water quality is however
the mining areas and recognising the contribution of pollution from Development to a large extent determined by geochemical processes that take place on
the surface of the mining areas to the problems of AMD, I request Consultant exposed rock surfaces with in the underground workings
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.

I support the proposed project, and the work done on it so far is Mr Andrew Barker Andrew Barker 19 May 2009 Key Stakeholder Thank you for these comments.
commendable. However, a long-term solution needs to be put in Development Workshop, Brakpan
place that will also address future environmental issues. Surface Consultant
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.

Add-on modules to the proposed project, such as surface clean-up, Mr Andrew Barker Andrew Barker 19 May 2009 Key Stakeholder WUC is a water treatment company. It is not involved with clean-up of
need to be recognised and put in place before the project Development Workshop, Brakpan mine land.
commences. Consultant

Will the coal required for the kiln be procured from a reputable Mr Garth Barnes WESSA 01 May 2009 Letter Thank you for this comment. The project is currently at feasibility stage.
company? Specific market suppliers of coal have not yet been considered.

How will financial and environmental liabilities be transferred to WUC Mr Garth Barnes WESSA 20 May 2009 Key Stakeholder Liabilities will remain with the mines until WUC can prove that the project
once the water reclamation process is operational, particularly since Workshop, Alberton is self-sustainable. Once the project is proven to be self-sustainable, the
some of the mines are still operational? Will WUC assume full mines can apply for Closure and the financial and environmental liabilities
responsibility for the financial and environmental costs of the project? will be transferred to WUC.

Comments Response Report


Draft Scoping Repot 40 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
The commitment by government to one service provider only may Dr Richard Doyle Environmental and 13 May 2009 Comment Sheet Government has tasked the mining industry with finding a regional solution
lead to the premature adoption of a sub-optimal solution to the Remedial Technology to closure of mines and management of shared liability around water.
problem at hand. Holdings (Pty) Ltd 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 Dr Richard Doyle Environmental and 13 May 2009 Comment Sheet If funds for the project are not raised, the project would not go ahead. This
does not raise funds (because of economics or other). Remedial Technology would not introduce any additional risk over that which exists at present.
Holdings (Pty) Ltd 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 30 April 2009 Comment Sheet Please would you contact the public participation office to clarify this
Construction Projects request.

I have seen a few articles on gold mine AMD and the plant WUC is Mr Hugo Grobler Umcebo Mining 23 May 2009 E-mail The cost and financial aspects of a mine water reclamation project are
proposing.We are in coal mining and also have similar problems. In very project specific. It is not prudent to extrapolate from this project to any
terms of sustainability of such a project (to treat the water), what are other project. The project is financially viable if the potable water is sold at
ball park figures for treating the water and at what price is it a price comparable to the current retail price of municipal water in
envisaged to sell to Rand Water ? Gauteng.

There is urgency with regard to the implementation of the proposed Mr Peter Kelly Department of 21 May 2009 Key Stakeholder Thank you for this comment.
project since pumping of mine water ceased at ERPM. Minerals and Energy Workshop, Randfontein

Relating to the many e-mails that have been doing the rounds Mr Garfield Krige African Environmental 20 May 2009 E-mail Thank you for highlighting the urgency of the problem. These are the
condemning the use of mine voids to transport water, etc, whether Development fundamental issues that drive the need to implement solutions such as
we like it or not, this is already occurring to a certain extent in certain those proposed by Western Utilities Corporation.
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.

Current and future rehabilitation of contaminated soil should be taken Mr Frans Le Grange Exotic Properties 22 May 2009 Comment Sheet Please address concerns regarding soil contamination directly to the
into account. relevant mining companies.

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

Why are studies duplicated between WUC and the Department of Ms Irene Lea Pamodzi Gold 26 March 2009 Authority Steering Where ever possible existing and available information will be drawn upon
Water and Environmental Affairs? Committee Meeting to inform the project feasibility and the EIA process

Comments Response Report


Draft Scoping Repot 41 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
In substantiation, I append hereto the instructions and directive Ms Mariette Liefferink Federation for a 05 May 2009 Letter The need to manage excess mine water is the primary motivation behind
which were brought against West Wits Mining by the Department of Sustainable this project.
Minerals and Energy. At the time of writing, West Wits Mining Environment
(affiliated to DRD GOLD) continues to be in flagrant non-compliance
with the instruction and the directive of Department of Minerals and
Energy.

AMD is responsible for costly environmental and socio-economic Ms Mariette Liefferink Federation for a 05 May 2009 Letter Thank you for this comment
impacts. Sustainable
Environment

AMD is characterised by low pH (high acidity), high salinity levels, Ms Mariette Liefferink Federation for a 05 May 2009 Letter Thank you for this comment
elevated concentrations of sulphate, iron, aluminium and Sustainable
manganese, raised levels of toxic heavy metals such as cadmium, Environment
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, Ms Mariette Liefferink Federation for a 05 May 2009 Letter Thank you for this comment
but is also responsible for the degradation of soil quality, aquatic Sustainable
habitats and for allowing heavy metals to seep into the environment. Environment

We refer to page 2 of the BID. We here express great concern Ms Mariette Liefferink Federation for a 05 May 2009 Letter The proposed project will be implemented by the Western Utilities
regarding the poor environmental performance and bad corporate Sustainable Corporation, on behalf of the mining industry. The project will not be
reputation of two of the Applicant's proposed partners, namely Environment implemented by the mining companies themselves.
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."

CRG-SA refused members of affected communities and registered Ms Mariette Liefferink Federation for a 05 May 2009 Letter Please address this comment directly to the mining house concerned. The
I&APs access to its approved EMP notwithstanding the fact that Sustainable comment does not relate to the project proposed by Western Utilities
requests were made in the prescribed format in terms of the Environment Corporation (WUC)
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.

It is alleged that CRG-SA has rescinded upon its agreement with its Ms Mariette Liefferink Federation for a 05 May 2009 Letter Please address this comment directly to the mining house concerned. The
BEE partner, PUNO and upon the Memorandum of Understanding Sustainable comment does not relate to the project proposed by Western Utilities
between CRG-SA and the Affected Communities Elected Environment Corporation (WUC).
Representatives (ACER) in terms of its Social and Labour Plan.

Certain expert assessments by the Environmental Protection Agency Ms Mariette Liefferink Federation for a 05 May 2009 Letter No mining waste will be generated through the proposed project. Water
in 1987 concluded that problems related to mining waste may be Sustainable treatment plant sludge will continue to be produced as the waste stream
rated as second only to global warming and stratospheric ozone Environment from the water treatment plant.
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.

Comments Response Report


Draft Scoping Repot 42 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
During heavy rainfall periods there is AMD seepage into the Ms Mariette Liefferink Federation for a 05 May 2009 Letter The proposed project is motivated by the need to restore the mine water
Wonderfonteinspruit. Radio nuclides are concentrated in sediments Sustainable level in the Western Basin to a level below ECL, and provide a solution
of the Wonderfonteinspruit, downstream of their sources. Sequential Environment through which water in the Eastern and Central Basins can be managed
extractions showed that these radio nuclides are distributed in below ECL in a self sustaining manner into the future.
multiple phases within the sediments of the Wonderfonteinspruit and
that they may be remobilised by environmentally plausible chemical
processes such as AMD.
Is this project sustainable? How many years will the project last? Mr Victor Manavhela Gauteng Department 14 May 2009 Meeting with the The project will be self-sustaining. Overseas investors will provide funding
of Agriculture, GDACE for the project. Western Utility Corporation is transparent about how they
Conservation and will recover costs by selling potable water to end users during the
Environment 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 Mr Basie Maree Mintails 26 March 2009 Authority Steering A detailed financial model has been developed that could be discussed
difficult to understand how a project of this nature can be viable or Committee Meeting with Mintails at a separate meeting.
sustainable.

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 Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of You will be kept informed through this process.
on their jurisdiction. Johannesburg

WUC/Golder should explain in simple terms the potential impacts of Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of Thank you. This will be described in the Draft Scoping Report. In
not implementing a solution to the Acid Mine Drainage (AMD) Johannesburg summary, Western Basin is already decanting. The Central Basin will
problem. 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 Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of The project is aimed at addressing water issues, and not other mining
the mine water problems in its jurisdiction. Will this project only Johannesburg rehabilitation such as rehabilitation of mine dumps.
address water, or will it include overall rehabilitation of the mines.

The City of Johannesburg needs to understand the problem and the Ms Lebo Molefe City of Johannesburg 08 May 2009 Meeting with City of Thank you. The EIA project team and proponent team remain available to
extent thereof. Johannesburg meet with representatives of the City to discuss these matters at any time.

How were the footprints of the different facilities and infrastructure of Mr Daniel Motaung Gauteng Department 14 May 2009 Meeting with the The project will use existing servitudes as far as possible. Infrastructure
the project decided? of Agriculture, GDACE such as pilpelines will be laid along existing pipelines on existing
Conservation and servitudes. A number of potential water treatment plant sites were
Environment 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 Mr Daniel Motaung Gauteng Department 14 May 2009 Meeting with the The project addresses excess water with in the Western, Central and
underground water form Gauteng crosses into the Free State. Does of Agriculture, GDACE Eastern mining basins within the Witwatersrand gold mining area only.
this project include a strategy to address similar underground water Conservation and
problems in the Free State? Environment

There has never been any comments on this matter from the Mr Sidney Osborne Resident, Springs 21 April 2009 Facsimile Certain mines receive subsidy to ensure continuation of pumping and
Department of Water and Environmental Affairs; as far as I know the management of water levels with in the mining basins. This subsidy is
mining company receives a subsidy from government for pumping the motivated by the need to continue the mining operations and protect jobs.
shaft water.

Comments Response Report


Draft Scoping Repot 43 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
Who is WUC? It was mentioned that the company is a subsidiary of Mr Sidney Osborne Greater Independent 19 May 2009 Key Stakeholder WUC is a wholly owned subsidiary of Watermark Global Plc, a London
a company listed in London – how does that information tie in with Residents Workshop, Brakpan listed company. WUC is acting on behalf of WBEC, CBEC and EBEC,
WUC being a South African company? Association 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 Mr Cliff Patterson Ward Councillor, 20 May 2009 Key Stakeholder This aspect does not form part of the scope of this EIA.
from Eikenhoff to create another underground lake. Can this be Ekurhuleni Metro Workshop, Alberton
done?
Could you please, as a matter of urgency, e-mail me the background Ms Mari Scott Springs Advertiser 22 April 2009 E-mail Certainly. These documents can also be sourced directly from
information document, regarding Western Utilities Corporation's mine www.Golder.co.za
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.

The Western Utilities Corporation proposed Mine Water Reclamation Ms Vicky Shaw WESSA 19 May 2009 Key Stakeholder Thank you for this comment.
project is a fantastic idea. Workshop, Brakpan

If the proposed project goes ahead, and in 30 years it is no longer Ms Vicky Shaw WESSA 19 May 2009 Key Stakeholder WUC has the surface and underground mining plans for the next 5 years
economically feasible, who will be responsible for continuing with the Workshop, Brakpan of all the mines involved in this proposed project. According to that,
pumping of the AMD. 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 Mr John Smit Mine Managers 24 April 2009 E-mail Noted. Thank you
purification of mine waters. This is particularly important to also Association of SA
prevent the penetration of acid mine water into overlying dolomites
which are chemically basic.

How will WUC ensure that a mining company that takes over one of Mr Mike Sullivan Central Rand Gold 26 March 2009 Authority Steering The proposed project is part of a proposed regional closure strategy for
the participating mines, agrees to be part of the project? Committee Meeting 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 Ms Elize Tempelhoff Beeld, Media 24 21 May 2009 Key Stakeholder The capital estimate of the project is being confirmed through the feasibility
entire project cost? Workshop, Randfontein study that is currently running.

One concern is the fact that WEBC is a creation of the mining Dr Anthony Turton Lit Creations 21 May 2009 E-mail The technology selection is being done by Western Utilities Corporation
industry and is also being positioned as the final selector of and its private sector parent company, on behalf of the mining industry.
technology. This means that they are both player and referee. I This remains a private sector initiative, not a Government initiative.
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).

Comments Response Report


Draft Scoping Repot 44 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
Please note that my partner, Dave Gadd-Claxton, and I have written Dr Anthony Turton Lit Creations 22 May 2009 E-mail Thank you for these comments.
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.
Let us see what the response is before we get too heated about this. Dr Anthony Turton Lit Creations 22 May 2009 E-mail Thank you for these comments.
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.

The sense of urgency of the proposed project is somewhat artificial. Dr Anthony Turton Touchstone 21 May 2009 Key Stakeholder Yes, these problems have been known for many years. Collectively
Also, the problem with AMD in the Witwatersrand has been known Resources (Pty) Ltd Workshop, Randfontein however these issues have not been addressed. The Western Basin is
for a long time. 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 Dr Anthony Turton Touchstone 21 May 2009 Key Stakeholder These comments relate largely to the need for broad communication,
complex and raises a number of emotive issues. Congratulations to Resources (Pty) Ltd Workshop, Randfontein above the level of individual projects. Within the context of the current EIA
WUC on good work done so far. However, it is a concern that the process, specific questions relating to impact of the proposed project will
Department of Water Affairs has been presented as the only be addressed, and directly affected stakeholders engaged with.
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.

At the moment, the project is treated as a mine problem, whereas it Dr Anthony Turton Touchstone 21 May 2009 Key Stakeholder Thank you for these comments
is not purely a mining problem. Consultation should be taken to Resources (Pty) Ltd Workshop, Randfontein
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.

Comments Response Report


Draft Scoping Repot 45 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
Subsidies from government have been provided to the mines to Mr Danie Van der Merwe Water Services, 20 May 2009 Key Stakeholder Once the proposed project is proven to be self-sustainable, the mines can
sustain the pumping of water for the past 25 years. Who will take Ekurhuleni Metro Workshop, Alberton apply for closure and the financial and environmental liabilities (including
over the liability for pumping the water? 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 Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet Thank you. This point is not directly relevant to the current EIA
updated information. Note the difference in tonnages mined and that Noordheuwel
processed. Where did the 196,000 tonnes go? Refer to to the Mine
Inspection Report of the WRC, 1996.

How many tonnes will be used as backfill and at which slopes and Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet The current project is sized to handle excess water make in the
levels. You need to know the type and tonnes to determine possible Noordheuwel compartments, taking into account operational water use by the mines.
surface area of water contact for chemical reactions. 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 Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet Issues pertaining to back fill of underground workings are not deemed
through boreholes. Where will these be located? Noordheuwel relevant to the current impact assessment.

Wits pits is already earmarked for storing slimes and currently used Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet Thank you for the comment.
by Mintails for this purpose. Noordheuwel

Note the water incursion and supply situation of all mines and report Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet The operational water use of gold mines with in the Western, Central and
on that. Noordheuwel 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 Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet The Cooke Mine and its facilities do not form part of this project. Comment
used. Noordheuwel noted with thanks.

Where will the residue be dumped, as Witfontein is not a viable Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet The proposed project is a water treatment solution. Issues related to
option, and Raatskraal is not yet authorised? Noordheuwel 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, Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet Comment pertaining to operational practice at the goldmines need to be
EIA, EMP meetings what tonnages of residue exist and are not Noordheuwel addressed to the mining companies directly.
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.

Will slimes previously used as backfill, but not under water, be Mr Eugene Viljoen Resident, 18 April 2009 Comment Sheet Comment pertaining to operational practice at the goldmines need to be
processed? We know mines dumped vast tonnages of slimes Noordheuwel addressed to the mining companies directly.
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?

Comments Response Report


Draft Scoping Repot 46 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
Poisoning of our environment by the mines takes place all in the Mr Eugene Viljoen Resident, 15 May 2009 E-mail Thank you for this general comment
name of progress, jobs and foreign exchange. Quite frankly, our Noordheuwel
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)

Lets us first apply common sense; this is a National Disaster and we Mr Eugene Viljoen Resident, 15 May 2009 E-mail Thank you for this general comment.
are at the source. The mines will not pay for it in full, but by proper Noordheuwel
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 Mr Eugene Viljoen Resident, 22 May 2009 E-mail Thank you for this comment.
problem is laudable. However; by your Public admission, for once we Noordheuwel
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!

It is not strange that once again the same historical pervasive Mr Eugene Viljoen Resident, 22 May 2009 E-mail Thank you for this general comment.
attitude of Reinecke and cohorts of the 1930`s in and around Noordheuwel
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 Mr Eugene Viljoen Resident, 22 May 2009 E-mail Thank you for this general comment.
residues from the drugs used such as antibiotics and HIV/Aids and Noordheuwel
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 Mr Eugene Viljoen Resident, 22 May 2009 E-mail The proposed project is a private sector initiative that is not seeking
apply. NEMA, WATER, MINING, etc, are subservient to it. That Noordheuwel government funding
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.

Comments Response Report


Draft Scoping Repot 47 of 48 17/06/2009
Comments, Suggestions and Questions Raised Commentator Representing Date Source Response
It might be an idea to install a similar plant at Gerhardt Minnebronne Mr Eugene Viljoen Resident, 22 May 2009 E-mail Thank you for this comment. It does not appear to have relevance to the
to rehabilitate that volume of natural decant (now contaminated) and Noordheuwel proposed water treatment project.
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 Mr Eugene Viljoen Resident, 22 May 2009 E-mail Thank you for this comment. It does not appear to have relevance to the
approach to the entire problem take place urgently? Otherwise, hope Noordheuwel proposed water treatment project.
that the 2002, 150 + year floods don’t cross the Witwatersrand soon.

There is no need to use potable water in the mining process, Mr Niels Von Ekesparre Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder Thank you for this general comment
especially if it impacts heavily on the water table. Workshop, Brakpan

We could not find the name of Goldfields among the mining Mr Zwi Wagner Water Engineering 17 May 2009 Comment Sheet The project is currently confined to the West and Central and Eastern
companies playing a role in the project. Are they not participating? Systems Unlimited 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 21 May 2009 E-mail Western Utilities Corporation has the right to evaluate technology and
Systems Unlimited 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 Mr Zwi Wagner Water Engineering 21 May 2009 E-mail Thank you for this general comment
Water from Vereeniging/Vaal and disposing it in the Witwatersrand Systems Unlimited
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.

Will WUC address the pumping at Pamodzi and take it over from Mr Zwi Wagner Wiz Holding (Pty) Ltd 19 May 2009 Key Stakeholder Correct. That will happen when the WUC system is in place. That means
them. Workshop, Brakpan that the mine dewatering will have to be addressed by Pamodzi until after
the WUC project has been successfully implemented and commissioned.

Comments Response Report


Draft Scoping Repot 48 of 48 17/06/2009