sp2-ec2864561748b6bb.pdf
Summary
This report, prepared by GCS (Pty) Ltd for the Centre for Environmental Rights, reviews the water use license application (IWULA) and specialist studies for the proposed Yzermyn Underground Coal Mine in Mpumalanga. The review identifies significant gaps in hydrogeological and wetland assessments, arguing that the mine poses a substantial risk to sensitive water resources and that the current groundwater models are of low confidence and insufficient for decision-making.
Key insights
- The proposed mine poses a substantial risk to sensitive water resources, specifically the NFEPA wetland CVB5, which falls within PES category B and EIS category A. This wetland is located within 500m of the underground mining boundary and corresponds with the cone of dewatering in both the deep fractured and shallow weathered aquifers.
- The groundwater model used for the project is classified as 'low confidence' (Class 1), making it unsuitable for design, engineering, or decision-making purposes. GCS argues that a Class 3 model with high confidence is required given that the mine is situated in a 'sensitive and conservation important area' with high ecological sensitivity.
- There is a critical lack of information regarding the financial viability of the mine concerning post-closure water treatment. The report notes there is no data on the likely cost of a water treatment plant to manage post-closure decant, which is expected to occur approximately 45 years after closure.
- The report identifies a fundamental flaw in the water use license (WUL) authorization: the WUL only authorizes water discharge for the operational phase (estimated at 8,900m³/a) but does not authorize the discharge of treated water resulting from post-closure mine decant.
- The claim that a dolerite sill would prevent the dewatering of wetlands is described as flawed and lacking a scientific basis. GCS asserts that the sill is unlikely to be uninterrupted and that the drawdown of 2m to 5m in the shallow aquifer would lead to the drying up of springs and wetlands above the underground mining area.
- The project's environmental assessments failed to simulate a groundwater contaminant plume post-closure. Given that 67% of coal samples were classified as potentially acid generating, the lack of a simulated plume means the report cannot identify which water users and wetlands will be affected by acid mine drainage (AMD).
Cite the original document
- APA
- Centre for Environmental Rights (n.d.). sp2-ec2864561748b6bb.pdf. https://cer.org.za/wp-content/uploads/2018/03/SP2.pdf?x21779
- Chicago
- Centre for Environmental Rights. sp2-ec2864561748b6bb.pdf. n.d. https://cer.org.za/wp-content/uploads/2018/03/SP2.pdf?x21779.
- Wikipedia
- {{cite report |author=Centre for Environmental Rights |title=sp2-ec2864561748b6bb.pdf |url=https://cer.org.za/wp-content/uploads/2018/03/SP2.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}
- BibTeX
- @techreport{centreforenvironmentalrightsndsp2ec2864561748b6bbpdf, author = {{Centre for Environmental Rights}}, title = {{sp2-ec2864561748b6bb.pdf}}, institution = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2018/03/SP2.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }
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