After a day of telephone tag, I manage to pin Carin Bosman down for a solid good half hour analysis of the DWA’s response to our letter. She’s a trained chemist, and was once one of the DWA’s big guns on matters of water standards, testing and licencing requirements for years.
Now she’s a consultant, and she knows the system backwards.
This kind of insider knowledge is the whetstone against which government policy should get honed - hopefully, but who knows at this stage.
Carin’s analysis of the department’s response to our questions is pretty searing.
a) Toxic sludge: it’s not inside, it’s on top!
Don’t be distracted by the story about all this drilling apparently happening 5km underground. The real threat to the groundwater is much closer to the surface - and the department doesn’t have the human capacity to make sure what happens at the surface doesn’t become a pollution spill that we’re saddled with for a millennia. Here’s why.
‘Fracking wells vary between 5km and 200m… and it’s the top aquifers that will be more under threat from leaking,’ Carin says.
The leaking of returned fracking fluid from above-ground storage ponds is the worry. This is because the regulations, as they stand, fail to specify in enough detail how the ponds should be sealed and lined.
‘A hazardous waste disposal dam like this should be made of various layers of clay, leachate protection layers, and gravelly leachate collection layers that are 2m thick, and then it should be lined with a 2mm thick plastic liner, amongst other things,’ explains Carin. Carin continues,‘There also needs to be continuous monitoring so that as soon as something shows up in the leachate layers, you know the plastic has perished and you can go in and clean up.’
None of this is in the current regulations, according to her.
b) The one-man bottle neck
When a containment dam like this is designed, it has to be approved by the department before it can be built. But the DWA only has one engineer to do this, and the poor bloke’s so over-stretched that there’s a year-long waiting list for his time.
‘We’re waiting for approval on an acid mine drainage control dam for another client in Mpumalanga. If we got the go-ahead, it’d take three months to build. But we can’t get an appointment with the department’s engineer for a year to approve the design. So in the meantime, this acid mine spill just keeps leaking into the environment.’
c) Best what!?
‘These best practices to prevent fracking leaks? Never heard of them. Show me!’
And so I drop the department another email, asking for them.
d) A Potemkin village
The up-beat ‘we’ll follow the best practices’ email from the department is starting to look like a Potemkin village: a pretty front of street houses to trick the visitor into believing the place is prospering when in fact it’s just a fake veneer for a faux village.
As a consultant, Carin audits a lot of DWA-issued mining licences and the various conditions they impose on the mining company or industry.
‘In about 80 percent of those cases, the licences aren’t auditable. Many aren’t even applicable to the site in question. The conditions in a licence often just look like copy-and-paste jobs, as if a non-technical person has put the licence together.
‘Here’s an example: one gold mining licence talked about the conditions required for the facility’s uranium processing plant. But this particular mine doesn’t have a uranium processing plant, the closest one is 50km away.’
Many of South Africa’s sewerage works don’t comply with their licensing conditions and are failing, which results in untreated sewerage running into our rivers and wetlands. This is not a great reflection of the department’s capacity to handle a relatively well-established technology. If they can’t get that right, how are they going to manage on the fracking side where there are so many unknowns?
e) Condomise: safe sex and the precautionary principle
‘No one in this day and age has unprotected sex with a stranger, right? Well, that’s what we call the precautionary approach, because the consequences of something going wrong - getting pregnant, or getting certain diseases - are irreversible, and are obvious to anyone with two brain cells that are not controlled by hormones. It’s the same with fracking – only the hormone is called ‘greed’.’
If raw sewage spills into a river, you just need to wait for the next rains to come… ‘… and all that sewage water is kwwwwuuuuussshhhh washed down into the ocean and the fish are happy again and people won’t get sick anymore, and you can go and fix the problem at the sewage works.’
Not so with fracking. Archaic underground water of the kind we’re talking about in the Karoo can take millennia to recharge, so the residue of a spill can linger for millions of years.
‘You can take some corrective measures with a surface spill, like put skimmers into the water or do bioremediation or use suctions or build berms. You can channel off the polluted water or add chlorine.
‘But a spill deep underground, where the water will only pop up 200km away? There’s nothing you can do to fix that. It’s irreversible,’ Carin explains.
f) Referee and player
Who do you trust to make sure everyone plays nicely, when the environment is most at risk? Carin reckons she wouldn’t trust any research by proponents and beneficiaries of the technology because there’s too much vested interest.
‘And since government is investing in advertising the positives about fracking, I would include the government as one of the beneficiaries of fracking and I wouldn’t trust them.’
The problem here is that the mining companies pay the bills for environmental impact assessments (EIAs), and the government is responsible for issuing licensing conditions (as we’ve seen, above, they don’t seem to doing a great job of this in other mining sectors) and for monitoring compliance of those conditions, as well as test for well leaks.
The Treasure the Karoo Action Group (TKAG) reported in March that the Cancer Association of South Africa (CANSA) has taken water samples on a farm north of Craddock in the Eastern Cape, to establish ‘base line data’. Once they know what the ‘pristine’ state is of the water flowing through the honeycombs of this aquifer, they’ll be able to see if anything changes in the event of fracking going ahead.
The Nelson Mandela Metropolitan University will follow up with a five year study, according to the TKAG Carin tells me it should be compulsory that research linked to EIAs should be ‘peer reviewed by independent reviewers who are accepted to the community at large’, meaning reviewed by experts that are not linked to the licence applicants or licence holders.
‘At the moment, the EIA regulations only call for peer review if the department asks for it. And that is why they are of such a poor quality, and why we get such poor licence conditions.’