KHULUMANI SUBMISSION TO THE EIA CONSULTANTS REGARDING THE TASMAN RSA MINES APPLICATION TO MINE URANIUM IN THE CENTRAL KAROO
Five years ago on 11 March 2011, a massive earthquake off the east coast of Japan triggered a 10 metre high tsunami that crashed into the Fukushima Daiichi nuclear power station, causing multiple meltdowns, the deaths of some 19,000 local residents and the loss of homes and livelihoods of another 160,000 local residents. Five years later the radiation at the Fukushima plant is still so powerful that even unmanned robots are unable to get into the bowels of the Fukushima plant to try to remove the dangerous blobs of molten radioactive fuel rods. Five days after this catastrophe, South Africa sent 45 members of a rescue team to give assistance to the post-earthquake devastation in the area known as Tokohu. The Fukushima catastrophe highlighted the problems and risks associated with nuclear energy generation.
These risks throw into stark relief the proposals to invest in nuclear energy in South Africa and the potential major public health risks that would result from uranium mining in the Central Karoo area of the country.
Khulumani has written to express its concerns and to table its rejection of the inadequate and incomplete Environmental Impact Assessment provided to the applicant mining company, Tasman RSA Mines.
To Tim van Stormbroek, Ferret Mining and Environmental Services,
I am writing to you as an interested party in the matter of the Uranium Mining Rights Application of Tasman RSA Mines.
I am National Director of Khulumani Support Group, a national membership-based organisation which includes members in the Beaufort West District. I am also a member of the South African Faith Communities Environmental Institute and a medical practitioner concerned about the impact of social and environmental determinants of health on the peoples of the Central Karoo.
The decisions to be made in this application for rights to mine uranium in such a sensitive and fragile environment as the Central Karoo with their potential to cause health problems for generations to come, cannot be made in the context of the problems that have been identified in the apparently deeply flawed EIA conducted for Tasman RSA Mines by Ferret Mining and Environmental Services.
With respect to the process carried out by Ferret Mining and Environmental Services, and as an organisation that empowers its members to use the Promotion of Access to Information Act legislation, we regard the conduct of the EIA for this project to be completely inadequate.
We are concerned at evidence of failure of the company tasked with conducting the Environmental Impact Assessment report, to ensure adequate and effective notice to the public to enable their effective and informed participation in the required public participation process. We note that no cut-off date for submissions was announced to the public. We are aware that the public presentations made were of very poor quality on issues that are of deep importance to the health of a unique environment and its people and animals. We are aware that the EIA does not cover the entire area of the proposed uranium mining, but only a portion of the application area. We suggest that these failures imply that the process should be found to be severely wanting and unreliable in assisting in the making of any decisions regarding the application by Tasman RSA Mines for uranium mining in the Central Karoo.
There are further evident problems with respect to the EIA. Amongst these are issues related to the EIA's defective calculations regarding water consumption by the project should it be approved and the terrible risk that would be posed to populations by the pumping of contaminated waste water into tailings dams that would evaporate rapidly in the climate of the Karoo, leading to the wide dispersal by wind erosion of low-level radioactive substances into the environment including into its drainage systems with consequent serious public health consequences.
As an organisation committed to facilitating social and economic justice for those most left out of the country's economy, we confirm that a sustainable development strategy for the Central Karoo Municipality does not, and would not, include uranium mining which is understood as incompatible with long-term sustainable development.
Our country with almost 50% of its population surviving below the poverty line, can ill afford the implementation of mining activities with their potential to cause the severity of problems described in this communication as opposed to alternative people-centred development models that enable the acquisition of skills by those for whom there have been few opportunities for building working local economies that are not based on models of extraction and repatriation of profits outside of our country.