Briefing provided by Ecologistas en Accion
During this year’s London Mines and Money conference (29 November – 1 December) the Australian-listed Rafaella Resources (RFR) will be rebranding itself as Pivotal Metals, in an attempt to greenwash its destructive environmental record in the Santa Comba and San Finx mines it owns in Galicia (NW Spain).
THE SANTA COMBA MINE
The mine has a long history of heavy metals pollution, affecting nearby streams and wetlands. It reopened in 2011 lacking environmental impact assessment and leaving abandoned tailings dams and surface works without restoration. Criminal and administrative proceedings are ongoing on charges of pollution and corruption.
Heavy metal pollution from mine drainage significantly affects the contiguous streams (Rego da Braña Ancha and Rego dos Lagos), both tributaries of the Xallas river, which is 6 km downstream from the mine. Cadmium, copper and zinc concentrations are above maximum allowable limits. Since 2020, flooded mine levels have been dewatered through a previously blocked cross drift and polluted water discharged directly in absence of treatment or permits at a rate of 250,000 litres/day. Other previous mine workings including pits and shafts remain unrestored and pose significant risk.
In 2011 a new mine development project and a restoration plan were approved without running them through an environmental impact assessment. These projects failed to address pollution associated with acid mine drainage and had no provision for its adequate treatment prior to discharge into a nearby wetland. They also excluded environmental liabilities from the restoration plan, such as abandoned mine tailings dams and old workings. A financial guarantee of just 104,410 euros was imposed, which is insufficient to cover such liabilities.
Dozens of NGOs have demanded that the mining tenements be declared expired, and an administrative procedure is underway that could force Pivotal Metals to lose its mining rights but still have to pay restoration costs, which will likely be several millions of euros more that the current guarantee.
Pivotal Metals has kept its investors in the dark regarding its liabilities, and also about the activities of EuroBattery Minerals within its tenements.
THE SAN FINX MINE
In an Open letter sent by over 230 European NGOs to the European Commission in 2020, the San Finx mine is mentioned as an example of “systemic non-compliance in relation to mining operators across EU Member States”. Heavy metal pollution from mine drainage and waste dumps significantly affects the contiguous stream and the Muros – Noia estuary (a Natura 2000 area), which is just 7 km downstream. The estuary is an important shellfish gathering area that provides livelihoods to over 1,500 families. Cadmium, copper and zinc concentrations are above maximum allowable limits. Since the mine reopened in 2009, mine drainage is discharged directly into the river in the absence of a discharge permit or any effective treatment. Two tailings dams remain abandoned and at risk of critical failure.
In 2009 a new mine development project and a restoration plan were approved without running them through an environmental impact assessment. These projects failed to address pollution associated with acid mine drainage and had no provision for its treatment prior to discharge into a nearby river.
They also excluded environmental liabilities from the restoration plan, such as abandoned mine tailings dams, waste dumps and old workings. A financial guarantee of just 178,000 Euros was imposed, which is insufficient to cover such liabilities.
Since 2009, public authorities ignored continuous mine drainage discharges which led to illegal concentration of heavy metals in affected rivers and never imposed sanctions or forced the mine to adopt mitigation measures. Only in 2016 was the mine forced to request a discharge permit. The discharge authorisation procedure was kept open for years (and still is in 2022) in an attempt to avoid imposing fines, which would now add up to over 30 million euros.
Public authorities attempted to cover-up pollution and the exclusion of mine tailings dams by issuing reports in which the existence of a “natural background level” was claimed and the tailings dams were said to be part of an inexistent hydroelectric power plant, and later on that they served a water mill. Criminal proceedings followed. Administrative neglect allowed the mine to operate within flooded levels in absence of a discharge permit and beyond what the 2009 project allowed.
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