In February, nuclear physics engineer Bruno Chareyron visited Malawi’s Kayelekera Uranium Mine to collect water samples and to provide feedback on radiation monitoring conducted in May 2012. He was invited by the Natural Resources Justice Network. In January, allegations were reported in the press against Paladin Africa, a subsidiary of ASX-listed Paladin Energy, that the company was releasing “waste” into the environment.

Paladin announced at the beginning of January 2015 that a plant run-off water tank at the mine was damaged during a storm event, releasing up to 500 cubic metres of material into the bunded areas of the site and that a small amount may have overtopped one of the containment bunds. The company reported that remediation was undertaken during the following five days.

[…] Paladin undertook sampling at the site of the storm-damaged tank and surface water upstream and downstream of where any possible incursion might have occurred. Malawi’s Water Resources Department also sampled at these sites to get independent verification. Results of chemical analysis by Paladin’s on-site laboratory showed that no contamination had occurred.

The Company also obtained confirmation through analysis of duplicate water samples undertaken by an accredited, global and independent laboratory services group. The independent results confirmed the results obtained by Paladin from its own laboratory and those collected by the Malawi authorities. All results demonstrated that no measurable contamination had occurred as a consequence of the event. These results have been forwarded to Malawi’s Environmental Affairs Department for their files.

Civil society organisations through the Natural Resources Justice Network, government officials (from the Ministry of Natural Resources, Energy and Mining) and company representatives took part in the meetings with Chareyron, who is head of the laboratory at the French non-governmental, non-profit organisation CRIIRAD (Commission for Independent Research and Information about RADiation). CRIIRAD works to improve information and protection of the public against ionising radiation and radioactivity. Its monitoring around Kayelekera has been funded through the Environmental Justice Organisations, Liabilities and Trade (EJOLT) project.

Coinciding with Chareyron’s visit, the EJOLT project published an 80-page report of its finding from the Kayelekera Uranium Mine monitoring visit in 2012. The main recommendations are summarised below. Paladin’s initial response to media reports questions the independence of CRIIRAD as the Commission describes itself as

a “partner” of the Malawian NGO, Citizens For Justice (CFJ), which is aligned with international anti-nuclear NGOs and has been in the forefront of campaigning on uranium mining in Malawi since 2006, including the recent fear-mongering campaign run by the Natural Resources Justice Network (NRJN).

Paladin goes on to question why the report was published over two years after Chareyron’s first visit to Malawi.

Neither CRIIRAD nor CFJ has explained why, if either organisation was greatly concerned about the environmental situation in the vicinity of Kayelekera Mine at the time, they waited for more than 2-1/2 years before publishing their findings. The report has been released to coincide with Mr Chareyron’s brief visit to Malawi for the purpose of participating as the NGO’s nominated representative in the GoM’s monitoring of surplus water treatment and release at Kayelekera Mine.

In addition, the Daily Times article “Workers, residents exposed to radiation” (26 February 2015) and the CRIIRAD report suggest that mine workers face radiation-associated health risks. Paladin’s response clarifies the measurements:

Compared with the radiation dose limit of 50 mSv in any single year, the average independently-measured dose level for a Designated Worker at Kayelekera Mine in 2013 was 3.2 mSv, with the maximum dose for a work group being 4.7 mSv – well within the accepted radiation exposure limit set under Malawi law in compliance with the ICRP [International Commission for Radiological Protection] standard.

To suggest that Kayelekera Mine employees, or the community, should require treatment or compensation for health risks associated with exposure to such low level occupational radiation is simply imprudent and misleading.

The EJOLT project funding for CRIIRAD will come to an end at the middle of March 2015. This means that extensive analysis and reporting of results of sampling from this visit will not be made available, according to Chareyon. CRIIRAD prefers to train community members to collect their own samples and to conduct basic radiation monitoring, however, in Malawi, this training has not been made available due to the limited resources and short periods of time CRIIRAD has had for their missions in the country.

The report from the last monitoring visit makes the following concluding recommendation,

Paladin should not be allowed to discharge radioactive and chemical pollutants in the Sere river as long as it does not publish the full EIA [Environmental Impact Assessment] and the results of its environmental monitoring.

To learn more about Paladin’s water treatment and discharge process, read Mining in Malawi’s account of the Parliamentary Committee for Natural Resources and Climate Change visit to the Kayelekera Uranium Mine last year. Paladin’s responses to literature published by non-governmental and civil society organisations can be found online here.

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The EJOLT report Impact of the Kayelekera uranium mine, Malawi is available for download here. It provides an overview of Kayelekera Uranium Mine and the context of the May 2012 mission. Detailed descriptions of and results from monitored sites for underground water, surface water, soil and sediments and radon in the air are included.

The key observations made by the report include:

• Serious lack of transparency of Paladin company: the results of Paladin’s environmental monitoring programme after the commissioning of the uranium mining are not accessible, which is “not acceptable and in contradiction with Paladin official policy”. All environmental reports should be published on the company website.

• Exposure of the workers to radiation: workers complained in 2012 that the results of individual dosimetry tests (radiation monitoring) were not given to them. “The mean dose of about 2 mSv mentioned by Paladin is not a satisfactory achievement but rather a maximum tolerable level of risk” and “there is no evidence that the Paladin dose assessments are reliable”. The report also states that Paladin should explain
  • how the health status of the workers will be monitored in the longer term taking into consideration the fact that radiation induced pathologies sometimes appear decades after exposure, and
  • what financial resources will be allocated in order to cure and compensate workers that will become sick in the long term.

• Evaluation of people exposure to radiation in the village of Kayelekera: 
  • Gamma radiation – gamma radiation rates were checked inside the vehicle on the road from Karonga to Kayelekera using a scintillometer; no readings higher than typical background were found. Readings were also taken while walking in Kayelekera village; the range of values are due to the amount of naturally occurring radionuclides in the soil. However, higher levels of radiations were discovered in the area of Nkhachira on sand accumulated by drainage on sandstone on a path leading to the village; the village was recommended not to use this sand for building purposes. There is a risk of re-used contaminated material from the mine as people sometimes illegally enter the mine and steal tyres, batteries and other equipment; scrap before clearance is tested by Paladin but the methodology needs to be made public. CRIIRAD also recommended the community to avoid being close to the rucks that transport “yellow cake” (uranium concentrate) that passes through the village.
  • Water used for human consumption – three samples of underground water used by the community were tested for chemicals and radionuclides; one sample met the World Health Organisation standards, “but the regular consumption of the water from the production borehole located near the primary school and of the artesian borehole will induce a dose to the consumer which is exceeding the guideline of 0.1 milliSievert per year taking into consideration the activity of radon 222”. This is “probably of natural origin, as shown by monitoring performed prior to the opening of the mine (2006 EIA report), but it is shocking to realise that the dose […] was strongly underestimated”.
  • Radon – Radon 222 activity was checked in four buildings and showed that radon inhalation is a non negligible contributor to the dose received by the population. However, “additional studies would be necessary to evaluate the amount of radon which is of natural origin and the proportion that may be due to the dispersion of radon into the atmosphere since the commissioning of the mine”.
  • Dust – Analysis of samples of top soil collected in Kayelekera and Nkhachira did not reveal abnormal concentration of radioactive material but “these limited tests are not sufficient to evaluate the impact of the mining activities in terms of radioactive dust in the air (especially during blasting activities), and radioactive dust deposition on the soil and crops.”
  • Food chain and bioindicators – CRIIRAD was unable to monitor radioactivity of the food chain or bioindicators in Kayelekera due to limited financial resources. The uranium mine may have an impact on the crops (deposition of radioactive dust and radon decay products) and fish (impact on the Sere river). The report recommends independent monitoring and ensuring Paladin includes monitoring of the food chain and sediments and aquatic flora in the rivers.

• Detection of hot spots on the eastern slope of the uranium mine: gamma radiation detection while walking on the eastern toe of the Kayelekera uranium mine revealed hot spots. In one case, the elevated radiation “is clearly due to industrial activities” and the local population may have access to this area and thus be exposed to radioactive material. The report indicates that Paladin should provide comments on the origins of the hot spots, rehabilitate the area and conduct a gamma radiation survey of the surroundings and publicise the results.

• Management of the radioactive waste: “Uranium mining in Kayelekera will produce huge amounts of radioactive wastes including, as indicated in Paladin EIA: 13 million tonnes of tailings and 9.1 million cubic metres of waste rocks” which will be radioactive for many years. Paladin’s own EIA report (2006) concludes that “the tailings might be potentially acid generating, with slightly acidic leachate and this may result in the contaminating the [sic] groundwater” and the sulfates and the manganese from the tailing may also be high.
  • Concern over location of tailings (quoted from p.64) – “It is shocking to discover that these radioactive and chemically polluting wastes are disposed of on a plateau with very negative geological and hydrogeological characteristics”:
    • The plateau is surrounded by rivers on all sides including the Sere river which flows into the North Rukuru river and Lake Malawi.
    • The area has a non negligible seismicity. According to 2006 EIA (page 6-22) :“The Kayelekera Uranium Project is located within an area containing Cenozoic Rift faults and reactivated Pre-Cenozoic faults and lies close to an area of high seismic activity in Malawi”. “Earthquakes in the vicinity of Kayelekera generally range between magnitudes of 3,0 to 4,9 on the Richter Scale, however, it is expected that earthquakes up to magnitude 6,5 are possible.”
    • There are “fault lines” within the project area and under the tailings storage facilities.
    • There are high rainfall events and a strong erosion. According to Paladin 2006EIA (page 6-35) : “During the peak of the rainy season, these rains can bevery intense, causing significant erosion of the landscape”.
    • In addition, the radioactive wastes are not properly confined and they put at high long term risk the whole area. This situation is not acceptable.

• The report suggests some questions citizens of Malawi should ask Paladin (quoted from p.64-65) –
  • What are the radiological and chemical characteristics of the tailings? According to CRIIRAD calculation, taking into consideration the activity of the ore, the total activity of the tailings is probably about 100 000 Bq/kg. The 2006 EIA does not give detailed radiological characteristics of the tailings as the dedicated section (2-60) gives only the gross alpha and gross beta activities of the tailings supernatant (8.28 and 4.5 Bq/l) and tailings slurry (112.6 and 27.3 Bq/l).
  • How is the impact of airborne transfer of contaminants from the surface of the Tailings Storage Facility A (TSFA) monitored (radioactive dust and radon gas)?
  • What is the annual amount of water seeping from the base of the dam of TSFA and collected in the seepage detection dam? What are the radiological and chemical characteristics of these waters ?
  • How many boreholes are used to monitor the quality of the underground water in the surroundings of TSFA, at what depth and location? What are the results of the monitoring ?
  • According to Paladin 2006 EIA (ES-14): “Each facility will be designed to withstand the 1:475 year return period seismic event and the 1:100 year return period 24-hour storm event”. What will happen in case of earthquakes or storms exceeding these ones? Could Paladin produce a copy of the emergency response plan in case of dam failure? What studies have been done to evaluate the long term stability of the dam of TSFA? In case of a breaking of the dam (violent storms with heavy rain, earthquakes), the situation will be catastrophic.
  • According to Paladin 2006 EIA (page ES-73): “The closure plan must include the requirements for institutional control of areas that could still potentially pose a radiation risk after closure (i.e. TSFs)”. How will PAL and the government of Malawi guarantee the long term monitoring of the stability of the TSF? Who will pay for this?
  • How long is Paladin intending to maintain the pumping equipment designed to pump back the contaminated seepage water that is leaking through the TSFA basin lining and grout curtain?

• Uncontrolled discharge of liquid effluents: Champhanji stream (below the open pit, flowing into the Sere river) has been contaminated by uranium and sulfates of concentrations much higher than before the commisioning of the uranium mine. Paladin has acknowledged various spills (March 2013, January 2015) but has not published detailed environmental monitoring results. Results from monitoring of water downstream from the tailings storage facility are not easily accessible to the public although should be submitted to the Environmental Affairs Department on a quarterly basis. The report recommends detailed monitoring of surface water to check the impact of leakages and spills from the mine on the Sere and North Rukuru rivers.

• Controlled discharge of liquid effluents: Paladin announced plans to discharge “up to 450,000 cubic metre of effluents per year in the Sere river […] after treatment”. The report argues that Paladin does not provide sufficient information of the radiological and chemical characteristics of the water to be treated and the residual contamination of the water to be discharged into the Sere river, or enough details about the water treatment methodology. The report argues that the discharge limits for both sulfates and uranium are high taking into consideration the environmental impact of these on the aquatic environment. In addition, the contamination of run-off waters is a serious long-term problem, “Who will take care of the facilities designed to collect and treat the contaminated waters [after the closure of the mine in a few years]?”.

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This visit and report has been covered in the print and online media. However, some of these accounts are misleading.

• “French nuclear physicist arrives in Malawi over Kayerekela uranium mine“, 25 February 2015, Nyasa Times
• “Expert warns on uranium long-term effects“, 26 February 2015, James Chavula, The Nation
• “Workers, residents exposed to radiation“, 26 February 2015, Adam Phiri, The Daily Times
• “Expert warns of radioactive related diseases around Kayerekela: Paladin’s uranium mine in Malawi“, 27 February 2015, Tiwonge Kumwenda, Nyasa Times
• “Paladin’s curse in Malawi“, 27 February 2015, Jessie Boylan, Mining Monitor
• “Inside the damning Kayelekera report“, 7 March 2015, Charles Mpaka, The Daily Times
• “Govt failing KA people over Kayerekela“, 8 March 2015, Lowani Mtonga, The Nation
• “Karonga groups fight over Paladin’s Kayerekela Mine report“, 8 March 2015, Nyasa Times
• “No cause for radiation alarm in Malawi, Paladin hits back at French activist“, 9 March 2015, Thom Chiumia, Nyasa Times