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This document is a formal objection letter from the Centre for Environmental Rights (CER), on behalf of the Mining and Environmental Justice Community Network of South Africa (MEJCON-SA) and Mining Affected Communities United in Action (MACUA), regarding Tetra4's application to amend its Water Use Licence (WUL) for the Cluster 2 expansion of gas and helium production near Virginia, Free State. The document includes the original objections and the corresponding responses from Tetra4, focusing on risks to groundwater, radioactive contamination, waste management, and the impacts of climate change on water security.

This document contains the Appellants' Heads of Argument filed by the Centre for Environmental Rights on behalf of the Endangered Wildlife Trust and the Federation for a Sustainable Environment. The appeal, brought under section 149 of the National Water Act (NWA), challenges a Water Tribunal decision that dismissed an appeal against the granting of a water use licence (WUL) to Atha-Africa Ventures (Pty) Ltd for the proposed Yzermyn Underground Coal Mine. The appellants argue that the Water Tribunal erred on several questions of law, including the failure to consider the strategic importance of the mine area, the absence of landowner consent, the misapplication of the precautionary principle, the lack of post-closure water treatment provisions, and the misapprehension of the burden of proof regarding socio-economic impacts.

This April 2018 Site Assessment Report and Remediation Action Plan, prepared by WSP Environmental (Pty) Ltd for ArcelorMittal South Africa (AMSA), evaluates land and groundwater contamination at the Vanderbijlpark steel mill. The report concludes that while soil impacts are generally low risk, substantial groundwater contamination exists on the western boundary due to historical coal tar sludge deposition in Dam 10, which created a Dense Non-Aqueous Phase Liquid (DNAPL) plume extending approximately 2.5km west. The report recommends a shift from informal DNAPL abstraction to enhanced natural attenuation via chemical dosing, alongside consolidated groundwater monitoring and further investigation of specific soil contamination in the southeast.