PROPOSED AMENDMENTS TO THE S21 LISTED ACTIVITIES OF THE AIR QUALITY ACT (ACT 39 OF 2004) Submission to the Portfolio Committee on Water and Environmental Affairs, on behalf of the Federation for a Sustainable Environment7-8 May 2013 A Andrews

NEM: AQA FRAMEWORK -ctd – 4 Setting standards –Best practicable environmental option (BPEO): most benefit/least harm at a cost acceptable to society –Informed by best available technology (BAT) –BAT informed by international documentation –Practicable : cost benefit analysis in peer reviewed and international literature

Subcategory 5.1: Storage and handling of ore and coal Description: Storage and handling of ore and coal not situated on the premises of a mine or works as defined in the Mines Health and Safety Act 29/1996. Application:Locations designed to hold more than tons. Substance or mixture of substances Plant status mg/Nm 3 under normal conditions of 273 Kelvin and kPa. Common name Chemical symbol DustfallN/A New a Existing a a : three month running average not to exceed limit value for adjacent land use according to dust fallout standards promulgated in terms of section 32 of the NEM: AQA, 2004 (Act No. 39 of 2004), in eight principal wind directions

NEM:AQA Framework Section “where the control of diffuse emissions is considered significant enough to warrant inclusion in national standards (eg fugitive dust at bulk ore/coal handling and processing plants and certain metallurgical industries…) emission limits expressed in the form of specific best practice control measures which are applicable across individual industries must be stipulated or alternatively a comprehensive fugitive emission management plan must be put in place”

Concerns Applies only to two mining ores: all ores should be included Requirement of fugitive emission management plan removed Averaging period is monthly: does not address incidents of high levels of dusts Proposed standard under NEMA s 32 is insufficiently protective of health Mine dumps which are to be re-mined should be included as ores

NEMA draft dust regulations 2012 Standard based on a 3 month average dust fallout figure Dust management plan only required after standard is transgressed Discretion as to whether to require dust monitoring Reactive rather than proactive approach

Recommendations category 5.1 Category extended to all mining ores Mining waste that is intended for re-mining classified as ores in terms of category 5.1 Fugitive emission management plan to be required based on best practice internationally

WITWATERSRAND MINING BASIN The Witwatersrand has been mined for more than a century. It is the world’s largest gold and uranium mining basin The basin covers an area of 1600 km 2, and led to a legacy of some 400 km 2 of mine tailings dams and 6 billion tons of pyrite tailings containing tons of uranium and metals such as Mg, Cu, Zn, Mn, As, Ni, Cr, Co and Pb. In addition, long-lived cyanide-metal complexes persist in tailings dams and sand dumps and Hg is still used for gold amalgamation by artisanal miners. A Remote-Sensing and GIS-Based Integrated Approach for Risk Based Prioritization of Gold Tailings Facilities – Witwatersrand, South Africa – S. Chevrel et al

Many active and decommissioned slimes dams are affected by wind erosion blowing off significant amounts of fine tailings dust especially during dry winter months. This not only affects nearby residents but also contributes indirectly to pollution of urban water courses as much of the blown-off dust settles on impervious surface from where it is flushed into stormwater drainage systems. Concentrating dust from relative large urban catchments the resulting tailings volumes finally being discharged into receiving streams are significant. Due to the small particle size of the slimes, particulate matter can be transported over relatively long distances to agriculturally used land in his surroundings. Furthermore, since the dawn of the new uranium renaissance in 2003 many uraniferous slimes dams are reworked by local mining companies as well as foreign investors, which is resulting in the liberation of radioactive and toxic dust particles.

Tailings Dams

Radioactive and Toxic Dustfallout from historical tailings dams.

Remining of Historical Tailings Dams and Sand Dumps

Pollution related to Witwatersrand mines poses a number of hazards to surrounding communities. The major primary pathways by which contamination can enter the environment from a mine site are: – the airborne pathway, where radon gas and windblown dust disperse outwards from mine sites, –The inhalation and ingestion of contaminated dust generated by wind erosion from these objects, and –The contamination of agricultural crop (pasture, vegetables) by the deposition of radioactive dust particles, which can cause considerable dose contributions via ingestion. (Reference: Land-Use after Mine Closure – Risk Assessment of Gold and Uranium Mine Residue Deposits on the Eastern Witwatersrand, South Africa. M. W. Sutton. Mine Closure. 2008)

1.6 Million Persons live in Informal Settlements next to Mine Residue Deposits Source: Tang and Watkins. 2011

Dust exposure in mines is linked to silicosis and Uranium - once it enters the body - has been recently found to exhibit many more toxic effects than were known at the time most of the current guidelines were established. Particularly targeted are the kidney, the brain and the reproductive system. It will be apparent that Uranium and Heavy Metal exposure will have a profound effect on the health of any population, and that the range of effects covers the entire spectrum of disease.