Welsh Affairs Committee
Oral evidence: Metal Mine Pollution in Wales, HC 715
Wednesday 8 May 2024
Ordered by the House of Commons to be published on 8 May 2024.
Members present: Stephen Crabb (Chair); Tonia Antoniazzi; Ruth Jones; Ben Lake; Robin Millar, Beth Winter.
Questions 1 - 86
Witnesses
I: Professor Mark Macklin, Professor of River Systems and Global Change, University of Lincoln, and Dr Andrea Sartorius, Research Fellow, University of Nottingham.
II: Dave Johnston, Senior Specialist Adviser, Abandoned Metal Mines, Natural Resources Wales, Christian Wilcox, Head of Strategic Projects, Natural Resources Wales, Carl Banton, Operations and Sustainability Director, Coal Authority, and Nick Cox, Head of Programme Delivery, Metal Mines, Coal Authority.
Written evidence from witnesses:
Witnesses: Professor Mark Macklin and Dr Andrea Sartorius.
Chair: Good morning, bore da. Welcome to this session of the Welsh Affairs Committee where we are looking today at the extent of metal mine pollution in Wales and what is being done, and what should be done to address the impacts of metal mine pollution.
We have two panels of expert witnesses this morning. For our first panel, we are joined by Professor Mark Macklin, who is Professor of River Systems and Global Change at the University of Lincoln, and we are joined by Dr Andrea Sartorius, who is Research Fellow at the School of Veterinary Medicine and Science at the University of Nottingham. Welcome to both of you. We are looking forward to hearing your evidence. I am going to ask my colleague Ben Lake to open the questions.
Q1 Ben Lake: Bore da, Professor Macklin and Dr Sartorius. It is great to have you here. There has been quite a bit of press reporting and coverage in the media of the problem of disused metal mines in Mid Wales, and Ceredigion features quite heavily in some of the reporting. Can I just ask at the outset, Professor Macklin, how well we understand the extent of metal mine pollution in Wales?
Professor Macklin: Thank you, Ben. In terms of the distribution of mines, we know that pretty well. On the record, there are about 2,300 mines—lead mines at least—in Wales. We know their locations and that is excellent.
The other bit that we perhaps do not know so well—and it is probably one of the main areas that I suggest this Committee should focus on—is the impact of historical metal mining. Bear in mind that the heyday of mining in Wales was the late 19th century, and 1868 was the first river pollution commission in Wales. That is a few years back and unfortunately, as a consequence of poor regulation at that time, many rivers, channels and floodplains were significantly polluted.
The area where we do not know as much—and it is obviously where people live and where they grow food stuff—are the channels and floodplains downstream of the mines. The work that we have been doing over many years has been the mapping and modelling of that. We have been running some of our high resolution models, and we estimate around 1,600 kilometres of Welsh rivers are contaminated by historical metal mining, which is a much larger area than simply from the mines themselves.
It is a two-part problem. We have the mine sites, which are understood, I would say, and in part regulated. Then we have the channels and floodplains affected by historical mining. Again, for the non-experts, there was no regulation, and the waste was directly dumped into the river channels. It was dispersed downstream over many tens of kilometres—hundreds of kilometres in some instances—and it has remained there ever since. It does not biodegrade. It will remain there for as long as we are going to be around.
To answer your question, Ben, we know where the mine sites are. Through the work that we have been doing recently we have a very good idea of where the contaminated channel floodplains are. I think it is combining those two elements of information in a new way that needs to be done.
Q2 Ben Lake: Thank you, Professor Macklin. I know my colleagues will want to get into that in greater detail in a moment.
Dr Sartorius, in terms of the environmental impact of this pollution and the impact and the legacy of these disused metal mines, how well do we understand the environmental impact of this problem?
Dr Sartorius: The short answer is not as well as we should, most certainly, and it has wide spanning effects. These pollutants can get into the water, sediment and soil, and once it is there anything that is living in that can be exposed to the pollutants and it can have a wide range of health effects. Trace metals can cause infertility. They can cause cancer and can affect the development of the nervous system, muscle and skeletal growth. They can have significant effects especially on children and young animals, and we do not sufficiently know—especially in the UK and in Wales—the extent of the effect that that is having.
To add on to what Mark was saying, we know that the mines are contaminated and that we can expect to see some of those health effects at the mines themselves, but what we do not know is how far away from those mines those health effects also accumulate and how big those zones of concern could possibly be.
Ben Lake: Thank you very much both.
Chair: Thank you.
Q3 Beth Winter: Why do we not know that? Why do we not know the impact? Is it because the research has not been done? Could you just expand on that a bit?
Dr Sartorius: Yes, the health effects of these metals is known and that has been studied. Often that is studied in laboratories. The difference is between what you can see in a lab and what you actually see in the environment, especially over hundreds if not thousands of years of exposure. We are talking communities that have been exposed to very high concentrations of metals for a very long time because the impact that that could have is not fully understood.
Q4 Beth Winter: They could be understood if the research was undertaken?
Dr Sartorius: Yes. We could definitely know more about what is happening at these sites.
Q5 Chair: Thanks, Beth. Professor Macklin, I think you were involved in a previous study that estimated that 23 million people worldwide are living on land where the ground is contaminated through metal mine pollution. Do you have an estimate for the number of people in Wales living on contaminated land?
Professor Macklin: We do, and it really chimes with what Andrea was saying. These are known unknowns. Professor Chris Thomas and I have just completed some high resolution modelling in Wales. It is not published, so these are very much provisional figures that need to go out for peer review. In terms of Wales, we estimate that approximately 200,000 people live in a square kilometre of floodplain that is contaminated by historical mining. That is around 7% of Wales. Again, there are a number of livestock that live on contaminated floodplains.
Just to develop what Andrea said, we have known about it for probably 30 years, and we have been able to map where the contaminants are located. We know that climate change is having a big impact, because the other thing I failed to mention was probably one of the reasons in the last 20 or 30 years or so—and this was one of the reasons for doing the paper we published in “Science” that Stephen mentioned—as a consequence of climate change, floods have become certainly more frequent and larger, and you have contaminants that are stored in floodplains as well as the mine sites themselves.
It is the floodplains that very often are the principal source of the contaminants. More frequent floods and higher rates of bank erosion is resulting in an increasing recycling of this material. There were big floods, for example, in 1986 in North Yorkshire, which we worked on. Again, in 2000 there were very big floods in North Yorkshire, which were reported widely on the BBC. Then in 2012 we had the Ceredigion floods where there was lead poisoning of cattle as a consequence of eating contaminated silage. So, yes, this is a regional problem. This is a national problem. It is not just Wales.
Q6 Chair: Sorry, Professor, if I could come back to the figures? There is a crude estimate of 200,000 people currently in Wales that you assess are living on contaminated land.
Professor Macklin: They are living within a square kilometre, which has a contaminated floodplain within it.
Q7 Chair: Am I correct in thinking that those 200,000 people would be the people most at risk of health impacts from the contamination?
Professor Macklin: Yes. The good thing about our modelling is it is georeferenced and spatially based, so we can identify areas where we need to start work—
Q8 Chair: Sorry, forgive me for talking over you but it is just because of the material that we need to get through in the short space of time that we have.
If the spread of the abandoned mines across Wales is well known, if the numbers of people potentially affected is reasonably well known—as you suggest—and given the length of time the problem has been known about, why are we not further ahead in terms of remediation of the problem? What is the block?
Professor Macklin: As an academic, my own view is that there is the need to join things up. I have worked with regulators for many years in this area, and published policy guidance. I think there has been a focus on the mine sites themselves and that has been a good thing. We need to turn off the tap, so to speak, but the area that really has not been joined up—
Q9 Chair: Sorry, Professor, you said there has been a focus on the mine sites themselves. Hearing that I would think the mines have been fixed, but that is not the case, is it?
Professor Macklin: No, they clearly haven’t. In terms of research and some degree of regulation, there has been a focus on the mine sites themselves. As you point out, a few of those have been remediated and regulated to some degree, but not many.
Just to extend that, the other area that has not been addressed—and I think that was the main area of our focus and Andrea’s research—is the channels and floodplains downstream, and that is the key area. I think the tendency, not just in the UK, not just in Wales but in many parts of the world, is to focus on the mine. But unfortunately, we have legacy contamination. It is the channels and floodplains downstream of those mines where people live, where they grow food stuff, where they collect water, those are the areas that need to be looked at as well. Very often, they extend over hundreds of square kilometres, so that is the element that we have not considered.
Q10 Chair: Thank you very much. Dr Satorius, I don’t know whether you want to offer an answer as to why more has not been done to address this problem if it is so well understood.
Dr Sartorius: Yes. To add to what Mark said, another factor that I think is important is the lack of awareness about these pollutants. People think of it as a historical issue. Oftentimes, when I have been in communities that have a mine site nearby, they consider it a kind of historical ruin, an interesting curiosity from the past, but they don’t know that it is a toxic site, and a site that could still be impacting them today. People go there to cycle often. They walk their dogs. They use those sites for recreation, but they are not aware of the potential toxic elements there.
If they are not even aware of the toxicity, people will not know to advocate or ask for cleanup. Even local authority members might not know that is something that is necessary. It is not the fault of anybody, it is just the situation. There are so many other things to look at that I think this has been a bit overlooked.
Q11 Chair: In terms of the seriousness of this issue compared with, say, sewage pollution—there has been an extraordinary amount of publicity about that issue and time devoted in Parliament to debating and thinking about the issue—how would you compare the issue of contamination from abandoned mines with sewage pollution?
Dr Sartorius: It is very hard to compare something like that, because for an individual impacted by sewage pollution that will be the biggest issue for them versus an individual impacted by metal pollution that will be the biggest issue for them. It is very hard to compare, and I do not have figures of how many people get impacted by metal mine contamination.
Q12 Chair: There is a bigger public health risk from abandoned metal mine contamination compared to—
Dr Sartorius: I cannot say because it depends on the situation.
Chair: Robin, you have a supplementary.
Q13 Robin Millar: Welcome this morning. I am very interested in your comments, particularly that reference to the Ceredigion flooding where cattle were poisoned by lead in the silage. That leads me to my question: what do you consider a level of contamination to be? I am presuming that the silage acted as a filter that pulled some of that material out of the flows concentrated in that place, and your reference was even to the focus having been on the mines and not on the downstream. Within the mine, within an ore body, the level will be much higher, but it will not be classed as a contaminant. So, when you use the phrase “contaminant” and talk about floods, is that one particle or is there a threshold level that you are applying that is universally consistent?
Professor Macklin: That is a very good question. One of the areas that we will need to explore—but probably there is not time for that in this Committee—is what sort of guideline values we use and develop. That has probably been one of the major problems we have had over the last 30 years, and we have been trying to help with that.
Q14 Robin Millar: If I could just put a point on it, then. When you talk about 200,000 people living within that square kilometre, which contains a contaminated area of floodplain, what is the level of contaminant you are using to establish that number?
Professor Macklin: To answer your first question in terms of the silage—just for reference so that colleagues have a good idea about this—the maximum concentrations that were recorded in silage, which was inadvertently fed to the cattle, was close to 2,000 part PPM lead, so significantly elevated. To put that into some sort of context, 80 PPM is the guideline in terms of allotments.
Robin Millar: That is parts per million?
Professor Macklin: Parts per million lead. In terms of the modelling work that we are doing—and it is process based, there is an enormous amount of ground truth work that has been done—we have been using the threshold of 300 milligrams per kilogram of lead as mapping the likely extent.
Bear in mind that 90% of heavy metals, metalloids, things like arsenic, are sediment associated, so there is very often a focus on water, which is important near the mine sites, particularly if they are acidic, but actually the vast proportion of contamination is soil and sediment associated. We are using that as a guideline, and what we are doing is mapping and modelling the extent of that downstream and then we can identify parts of the channels and floodplains at risk and, on that basis, come up with hazard mapping technology.
What I should say very quickly is that we had developed this back in the early 2000s but it was not taken up in the way that we had hoped. This was in the River Swale in the Richmond constituency, where there was very significant contamination from the millennium floods. Again, there were animal deaths as a consequence of ingesting this material. We provided policy guidance to the EA in that instance and there should have been greater linkages in a way from regulators but that did not happen.
Q15 Tonia Antoniazzi: I want to be quite blunt. You said abandoned metal mines have been polluting surrounding areas for decades, and my question is, is it too late to focus on the remediation of the actual sites themselves?
Professor Macklin: In terms of the mine sites themselves, as I suggest we need to turn off the tap. There are some great technologies in Wales. I think hydro industries have developed new technologies in terms of cleaning up this material. So, yes, we need to look after the mines themselves.
Remediating the floodplains and channels is a much bigger problem. In many instances that is likely to be unrealistic. It is managing them, mapping them and then, in terms of the way that they are used, it is advising farmers and particularly local authorities where the problems lie.
Q16 Tonia Antoniazzi: We should be more concerned about the historic pollution in surrounding areas?
Professor Macklin: In my view, yes.
Dr Sartorius: Yes, I agree with that. As Mark mentioned earlier, it is important to consider that climate change will cause more frequent weather events, which will cause further pollution in the future, so it definitely should be done.
Another thing that I have noticed—again visiting these communities—is people do move in and out. People bring livestock in from other regions, so you are always having animals that have not been exposed in the past coming in and being exposed and potentially being quite harmed by the levels of contamination.
Tonia Antoniazzi: Those livestock that then move out.
Dr Sartorius: Yes.
Q17 Tonia Antoniazzi: From a public health point of view—and I know you have spoken about this and about the communities, Andrea—what more can the Welsh Government, local authorities and communities be doing to get that message across to raise awareness within these communities that there is a problem?
Dr Sartorius: First of all, sharing the message needs to be done. A lot of the people that I spoke to were not informed. They did not know. They would only figure out that there were issues when their animals started dying. At that point they would reach out to NRW for support but before that they were not informed. They did not know that this could potentially be occurring.
Q18 Tonia Antoniazzi: Obviously, Ceredigion is a tourist area, let’s say. Is that an issue for people visiting the area?
Dr Sartorius: The biggest risk is definitely chronic long-term exposure to these metals. If you go down for a couple of days for a holiday, it is unclear whether that would have an effect on your health. The bigger risk is definitely the long-term exposure.
Chair: Thank you. Ruth Jones, please.
Q19 Ruth Jones: Thank you both for attending this morning. You have highlighted that we have knowledge. We have seen the maps of where the issues are, and obviously the red rating and everything. We have talked about the problem and the issues. What concrete steps can be taken to alleviate the concerns of people living in these areas? Shall I start with Professor Macklin?
Professor Macklin: That is probably one of the most important questions we should address. We have touched on that. In terms of the mine sites, certainly the water and sediment they generate needs to be controlled and there are technologies for that. On the channels and floodplains, I reiterate that these extend over very large areas. We estimate there are 1,600 kilometres of river channels and floodplains. This is large parts of Mid and North Wales. In those areas with a little bit more hard work, a little bit more ground truth, we can actually start to produce hazard maps of those areas that could be used as guidance for the local people that live there.
It could also be used as guidance for working with local authorities, who in many instances—as Andrea was saying—are really not fully aware of these issues. Also, the consequence of climate change is one of the areas we flagged up more than 30 years ago. We were slightly ahead of the curve in this respect.
Looking at river channels and floodplains, where you get high rates of bank erosion, which are contaminated, we can say, in terms of targeting areas where there should be stabilisation, where there should be rewilding, in my view these would be perfect areas for rewilding. They should not be grazed. People should not be growing stuff on them. There should not be allotments.
I live in Ceredigion, seven miles south of Aberystwyth. I have lived there for many years, and I have worked on these rivers for 40 years. Yes, we can map them. We can model them. I would suggest it would probably take two to three years to do that. Wales would be world leading in this respect because one of the things that Stephen touched on was the paper we published in “Science” last September. It got worldwide global coverage, and most importantly the area that was picked up was legacy mining, historical mining.
I worked in Australia on the Victorian gold rush, and they are still dealing with problems. We could take a lead in terms of restoration technologies, in terms of mapping technologies. So it is not all bad news, but we do need to do something about it. We have the technology. We have the ability. We have the expertise, but we do need to act on it. I was saying this nearly 30 years ago and it is probably time for us to move on.
Q20 Ruth Jones: I suppose, Dr Sartorius, the question would be: concrete steps—obviously communicating is clear, but what can we do to mitigate and alleviate the issues for people living in these areas? Is it clear where the responsibility lies for dealing with the metal mine pollution and its impacts? We have talked about local authorities. Is it clear exactly where the responsibility lies?
Dr Sartorius: To answer the first question really quickly, I agree with everything that Mark says. I do think it is important to note—and I know this is part of communication—there are small steps that people living in potentially contaminated areas could take to at least reduce their exposure. Things like gardening. If gardening, they can use raised beds or focus less on vegetables and more on ornamental plants and reducing soil coming into their homes. These are all suggestions that are put out by Governments of other countries to people in potentially affected areas.
These have been vetted and produced for media, for people, so this could be a really fast thing to do to give people some peace of mind, so that if they hear about this they know that, at the very least, they could take off their outdoor shoes and switch to different shoes and that would be something that could legitimately help.
As for your second question, of course I am an academic and I am based in Nottingham, but I have definitely found that for the landowners that I have spoken to, they have been unclear as to who to engage with.
Q21 Chair: On the subject of those small steps that you are suggesting that people could take, like using raised beds for growing, and I think you said ornamental plants rather than vegetables. Forgive me, but those are more than just small steps, because implicit in what you are saying is that people living in those affected areas should avoid eating vegetables grown in those areas. Is that what you are saying?
Dr Sartorius: It really depends. The difficulty with giving this sort of advice is that it really depends on the soil/lead concentrations. I have seen certain information put out for public consumption that literally has lead concentrations and which plants you should or should not grow, which I think the US Government put out for people to see. So those do exist, but that makes it very complicated. The idea is that if you have a garden, where you are gardening with your children for fun, if you could switch away from vegetables that might potentially help.
Q22 Chair: That is interesting. Professor, you said that you are a long-term resident of Ceredigion, which is the part of Wales that you said is the most affected. Do you avoid eating vegetables grown near you?
Professor Macklin: I could give a facetious answer, but that would clearly be inappropriate. We live on a hill. We have a three and a half acre smallholding. I work on flooding, so it would be very inconvenient if our property got flooded. The short answer is, no, we don’t because I know we do not live on a contaminated floodplain.
Just in terms of taking practical steps—and I think it is very important—in the last 20 years there have been huge strides in technologies for measuring contamination. These days we use what are called XRF guns. They look like something out of “Star Trek”, and basically they are a gun. X-ray fluorescence is a particular form of measuring elemental concentrations.
The guns cost about £25,000 to £30,000. I understand that local authorities are responsible for contaminated land, whereas it is probably NRW, EA and the Coal Authority that are responsible for the mines themselves. I know in the States at the beginning of this year the EPA actually reduced lead concentrations from 400 to 200 PPM in soil. Those are pretty low levels. It is recommended that these guns are a way of doing things. Folks could bring their soil samples to a local authority. We could go out and measure these on site and you can do measurements that would be accurate enough within probably a couple of minutes per sample. It is something that is very tractable, but it does need a bit of joined up thinking, which I think so far we have not done.
Q23 Robin Millar: I want to go back to this issue of contamination because I am a bit concerned at the way some of these questions are going. The levels that we are talking about, though, it is right that we raise concerns and alarm about them. However, the point, for example, about eating vegetables it is the way in which the contaminant moves through the system from the mine, through the washings, downstream into the floodplain, into the ground, then into the vegetable and then into the human. There are so many different steps in that process, and the level of contaminant and the exposure over time. I am not going to fall over from eating a carrot that has been planted in a contaminated field, for example. Can you expand on that a little because it is important that we do not send the wrong message from these questions?
Professor Macklin: I will start and then Andrea can add more detail. Robin, you have described very clearly the various steps that we need to understand. In terms of the silage, it was clear that it poisoned the animals. It killed them.
Q24 Robin Millar: To be clear, it wasn’t the silage. I am presuming it was the sediment that had been trapped in the silage. That is the point. It wasn’t that the silage had grown, and had absorbed—
Professor Macklin: Again, that is a very interesting point, which hopefully Andrea will be able to expand. The key thing is that very often for grazing animals, at least, maybe for children, it is eating the stuff directly. What happened is with the floods in June 2012, Bow Street flats were flooded, and there were contaminated floodplain sediments, up to 30,000 PPM lead, 3% by weight. This is large concentrations, not small, and almost commercially viable for mining in some instances. I am being slightly facetious there. This got into the silage, dirty herbage, and then this was inadvertently fed to the animals. In terms of the concentrations in plants and animals, Andrea is a vet so I will pass the—
Dr Sartorius: I am actually not a vet, they just put me in the vet school. With regard to vegetables, I did collect vegetables from patches downstream of mine sites. I took them back to the lab, washed them rigorously, peeled them and then tested their concentrations. It really varied from vegetable to vegetable but in some of them you could not eat one of the vegetables without exceeding your daily lead intake threshold based on the European Food Safety Authority. I will be happy to talk about what thresholds I used later.
In some vegetables and in some situations there can be concentrations of lead that could be quite elevated. The biggest danger, of course, is if you consume soil with it. Therefore one of the small recommendations is carefully washing vegetables, peeling them if possible and removing outer layers. That will help—I saved peels and tested them as well. You can definitely have very elevated concentrations in the vegetables themselves.
Q25 Chair: On this point—and I am mindful of not wanting to unduly raise alarm—there has been a movement in Wales, and presumably elsewhere, to encourage school children to grow in the school, to have an area of ground set aside for growing vegetables. The children learn about growing vegetables and the importance of eating food that is locally sourced and locally grown. In an area like Ceredigion, presumably there needs to be some kind of advice given to schools so they do that in a way that parents can know the children are not being exposed to risk?
Dr Sartorius: Obviously that is not my job but I would imagine there could be ways to do that safely, even if it is bringing in soil from somewhere else to be sure. That exercise has other benefits that are definitely worth exploring.
Q26 Ben Lake: Given everything you have told us this morning, what is your view of the work and the effort being undertaken at present by Welsh Government, NRW and the various bodies? I suppose it goes back to an earlier question, but are we doing enough? How do you assess the efforts to date in identifying the extent of the problem? How effective have these efforts been to explain the risk—or potential risk—to the areas affected?
Dr Sartorius: I think, on explaining the risk, from my interactions with communities, people did not know much about the contamination. What they knew were things they would hear. I deliver a message and about a year later I hear the message that I delivered given back to me in some sort of skewed way. Often people were not well aware. I met people who bought land that had mine spoil on it and were still not aware of the risks. There does need to be more information shared with locals so they know what is there so they can, at the very least, try to deal with it with the knowledge of what they have.
As for the action that has been taken, again, I am an academic so cannot speak too much about that. I think Mark and I have both said some things that could be helpful in the future but I am not involved in the day-to-day workings of this.
Professor Macklin: I have been working on this for close to 40 years. As I mentioned, in 2000 we had the millennium floods. We did a major report for DEFRA that was published in, I think, 2003. Many of the things we are talking about today were identified then but were not acted on by the regulators, although they knew and although we did work for them. The feeling was—it is more than 20 years ago—that these floods were a one-off. John Prescott at the time described them as an environmental wake-up call and I think he was right in that instance. But the thought was that it was a one-off.
What we have seen subsequently in many parts of the world, and particularly in Ceredigion in Wales, is that it is not a one-off. As a consequence of more frequent floods, this material has been remobilised. It is affecting people’s wellbeing and livestock. The regulators have been slow, to say the least, in joining that research up. Presumably this afternoon, after us, they will explain why. The information has been out there. It is mostly done by academics like myself. I do a lot of policy guidance work, particularly outside the UK, and I find it very frustrating that our research has been taken up and used in many other parts of the world. It is time it was used in a routine way.
What Andrea and I have been sketching out is that there are very practical steps. It needs some work to be done. I estimate probably two or three years in terms of developing these maps and they would be world-leading. It will take resource to do it. We will need to overlay health data. It would be a game changer and we could be ahead of the curve compared to many other parts of the world. That is my viewpoint at the moment. Thank you, Ben.
Chair: Thank you. Robin, do you have a supplementary?
Q27 Robin Millar: Thank you, yes, it is a clarification really. How concerned should we be about legacy and the very many ancient and historic mines—we know those are extensive across Wales—and how concerned should we be about current extraction and handling? Is there effective regulation on both? Are you taking them as a whole or can you draw a clear line between the two and say, “This is an issue, this is not an issue”?
Professor Macklin: In terms of mining, certainly in Wales we are talking about non-ferrous mining. We are not talking about coal mining. I think the last goldmine closed in 1998 in Mawddach. It is a legacy issue. It is again, as Andrea was saying, people forget about these things. Mines are in clear sight. You can revegetate them.
In terms of a contaminated floodplain, we do a lot of work worldwide on tailings dams failures; in Canada, in South America and Eastern Europe. I cheer my colleagues up from these countries because I show the levels of contamination from the spills we are working on in these countries and then I show them concentrations we have in the UK, particularly in Ceredigion, and then show the pictures of what these landscapes look like, which are beautiful and green. They do not tie together. It is a hidden problem but we do have the technology now to expose it in a positive way, as both Andrea and I have suggested.
Q28 Beth Winter: Professor Macklin, your expertise is metal mining. I live and work in South Wales where we had vast amounts of coalmining. I wondered if you could say anything about potential risks in terms of contaminated land in other forms of industries and the legacy from that. We have had furnace sites, and it resonates in a lot of ways in terms of what is going on.
Professor Macklin: I am not a coalmining specialist. What I should add is that, obviously, in terms of South Wales, Swansea area, you had long-term copper smelting. We have not touched on the smelting technologies. Historical or even contemporary airborne contamination is something that is of significance.
In terms of coalmines themselves, as I understand from my academic reading there is a legacy issue in terms of things like acid mine drainage. Therefore, again, it is something we do need to be mindful of. In my mind, the clear difference between legacy mining—and it is lead—and coalmining is that lead is a poison. There is no other way of describing it. It has no metabolic function and it is poison, even in relatively small concentrations. In my mind that is one of the prime reasons that we need to address this. When you look at other parts of the world, particularly the United States, children have their blood lead levels tested routinely in areas affected by historical mining.
Yes, coalmining is problematic, certainly in terms of ecosystem health but I would venture that perhaps in terms of ecosystem and public health legacy non-ferrous metal mining is more problematic.
Q29 Beth Winter: Can I—sorry, I am conscious of time—dig a bit deeper in terms of the responsibility of various agencies? What are your views on the level of co-operation between academics and people like the NRW and local authorities, and also between those bodies? You are quoted as saying there is a disconnect in perceived responsibilities of the relevant authorities, Professor Macklin.
Professor Macklin: There is. Everyone is cash strapped, that goes without saying, and I think we do need to put some cash into this area of things.
I have worked with the Welsh Government for many years on flood risk and there is a willingness there. This is an opportunity to join the dots and obviously we will hear after us what can be done.
Q30 Beth Winter: Dr Sartorius, anything to add? You said in terms of co-operation between yourselves.
Dr Sartorius: My PhD project was funded by National Resources Wales so I did work with them and they were very helpful to help the project come forward. I have been working this past year on encouraging more co-operation by running various workshops between the different agencies that either work on metal pollution or could be interested in metal pollution and local authority members and academics, trying to draw us all a little bit closer and encourage that co-operation, which I am hoping will continue now into the future.
Q31 Chair: Professor Macklin, coming back to your comments about lead. When the Financial Times did their investigation into this issue they mentioned a number of different metals that were coming from these abandoned mines. Is lead the very worst of them?
Professor Macklin: Lead and cadmium; yes, those are the most problematic.
Q32 Chair: In terms of the remediation work that needs to be done, NRW has this list of 50 mines that they have identified as priorities. How should they be prioritising the remediation work? Is it going to the places where we know there are the largest areas of contamination with presumably the worst metals?
Professor Macklin: As I have continued to emphasise, it is looking at the mines and then looking at the channels and floodplains downstream of those mines. Again, I think there needs to be better analysis of the major contaminants, the fluxes, the volumes of material that are being released from the legacy mines. That needs to be done—this is the critical point—in combination with assessment of the channels and floodplains downstream.
Q33 Chair: If NRW came to you and said, “Professor, where are the top 10 places we need to be, as a matter of urgency, remediating right now?”, would you know with the information you have?
Professor Macklin: In terms of the mine sites, working with them we could do that. We would be able to then identify the rivers, channels and floodplains downstream from those. As a bit of joined-up working, yes, it could be done.
Q34 Chair: Thank you very much. Dr Sartorius, before we end this first part of the session is there anything you want to add?
Dr Sartorius: I want to add something to what Mark was saying about the toxicity of lead. The World Health Organisation relatively recently, in 2019, issued a statement where they said that absolutely no level of lead is safe in the human body. That is—at least right now in the world we live in—a very difficult target to hit and potentially an unrealistic target. However, it is important to note that lead is that toxic that the suggestion is no exposure. Like Mark mentioned, it does not serve a positive metabolic function. That is the World Health Organisation recommendation.
I know you have a question, but to talk about thresholds for a second, it then makes it extremely difficult to come up with any thresholds because you are warring against this idea that any lead could potentially be bad. With blood lead thresholds, they have been steadily dropping for the last 50 years or so, as we set one, we might then find out there is a toxic consequence even below that concentration.
Q35 Robin Millar: I want to go back to context and make sure we do not misunderstand it. What do you know, as a veterinarian perhaps, about the take-up of ingested lead through a vegetable into the body? Is it 100%, so the high levels you find in the carrots do automatically always come through to the body, or not? The second question is, sitting here today around this room there will be a level of lead in each of our bodies I suspect. Although we say that lead is harmful in any dose, it is something like radiation. There is background radiation all the time but we all know that radiation is harmful. Can you clarify on those two points please?
Dr Sartorius: For your second point, I exactly agree. There is no chance that any of us do not have some lead in us. We definitely all have lead. I probably have quite a bit because I was the one collecting all these samples.
Professor Macklin: I have for 40 years.
Dr Sartorius: You are made of lead now.
Robin Millar: Thank you for doing it on our behalf.
Dr Sartorius: Just because it is there it could potentially have had some minor health effect on us that we might not be able to tell. However, as I mentioned with the World Health Organisation, it is more of a goal target and emphasis about the level of toxicity rather than a realistic threshold that we can reach.
As for your first question, I am not a veterinarian so I cannot speak too clearly around that—
Robin Millar: Forgive me.
Dr Sartorius: —but I have measured not just total lead in samples, mostly in soil samples and sediment, but also measured it running through a simulated digestive system to see the uptake. As I am sure you know, it is relatively low ratio wise, particularly for mine sites because often you cannot absorb as much lead from there as from other sites. However, because these concentrations are so high they do still come out as toxic at the end of that whole process. The FSA threshold that I used for food does take that into account to some extent. It might be a little bit less because of this mine situation because it is less bio-available, but it does take that into account.
Robin Millar: Thank you very much. I really appreciated the clarity of your answers.
Chair: That brings this part of this morning’s session to a close. Professor Mark Macklin, Dr Andrea Sartorius, thank you both very much for giving us your time and your expertise and helping set the scene for us.
Witnesses: Dave Johnston, Christian Wilcox, Carl Banton and Nick Cox.
Q36 Chair: Welcome back to part two of this session of the Welsh Affairs Committee where we are looking at the extent of pollution from abandoned metal mines in Wales.
For this second panel we are joined by Christian Wilcox, who is Head of Strategic Projects at Natural Resources Wales, and his colleague, Dave Johnston, who is Senior Specialist Advisor for Abandoned Metal Mines at Natural Resources Wales. We are also joined from the Coal Authority by Carl Banton, who is Operations and Sustainability Director, and by Nick Cox, who is Head of Programme Delivery for Metal Mines.
You heard the first session where we took evidence from Professor Macklin and Dr Sartorius about the extent of the problems and the risks in Wales. Can I open the session by asking both agencies a question. This problem has been known about for decades now. I think, NRW, your predecessor body, Environment Agency Wales, produced a report on a strategy for metal mines more than 20 years ago. Why is it taking so long for anything substantive to be done about this? I think Professor Macklin used the phrase “slow” in terms of the regulatory response to this. Is that a fair criticism?
Dave Johnston: We published that report in 2002, which was the Wales Metal Mine Strategy. That was our attempt to almost define the problem; we had been working on metal mines for some time leading up to that. There had been big programmes of remediation led by the local authorities and the Welsh Development Agency. They dealt with some of the big sites, generally looking at human health issues. Around Cwmsymlog in particular, in the Clarach, it was specifically designed to deal with human health issues arising in measured blood levels in the children in the local school. In the late 1990s and the early 2000s there was still some of that work going on, most of that funded by what were the derelict land grants and Welsh Development Agency funding through different methods.
We started to take an interest in the offsite impact, the water quality impact. That was our job as the Environment Agency at the time, looking into what we could do better about water quality because it was becoming clearer and clearer that the impacts of that were significant and perhaps not well understood. That Wales Metal Mine Strategy was an attempt to identify from existing information which were the sites we ought to be prioritising. What it did was give us that top 50. However, it was not top 50 based on known impacts on the water environment. It was the top 50 based on effectively the size of the mine and the volume of ore and waste that had been moved around, the size of the underground mine and the expectation that they would be the sites that were the worst polluters.
From that time we have put a great deal of effort into better understanding the whole of the situation. The monitoring programmes that went in to implement the water framework directive—a lot of site specific characterisation work and a lot of investigations on the rivers characterising the catchments—led us to understand far better the scale of the problem, the scale of the impact, and the sites that were then causing the problems.
Throughout that time we were identifying sites where there was obviously a need for remediation, sites like Parys Mountain on Ynys Môn, the world’s largest copper mine in its day. Work was undertaken there in 2003 that drained the mountain because it was flooded. It has a discrete ore body that sits above the landscape. The mine had been dammed at the lowest drainage level, it flooded the mine and it was draining out of a higher drainage level into a different catchment. There was a large consortium including the council, including ourselves and including academic partners, to make sure we made that safe because the water in the mine had a pH of 2 and it was all being held back by a concrete barrier that was rapidly dissolving. That was one of the major interventions. That cleaned up the river behind it but focused all of the mine water in one place.
We have spent time since then better understanding the impact, prioritising and working within the scope of the funding we have always had from Welsh Government, and bringing in other funding as well in places from the European Regional Development Fund and from other sources to effectively work within our capacity to deliver what we could. Major works at Frongoch in the Aberystwyth Valley diverted a stream that was running directly into the mine and causing a pollution source. We cleaned up the stream that it was otherwise discharging to. Major capping works at that site isolated the waste material from the elements, from groundwater running through it.
Q37 Chair: Sorry to cut across you.
Dave Johnston: No problem.
Chair: I am conscious that time is against us. We will get on to some of the detailed remediations you have undertaken in recent years in a few moments. Essentially, in terms of response to my question, the bulk of the last 20 years has been around improving understanding of the problem, with a few cases of actual remediation work?
Dave Johnston: Yes. We have greatly increased our understanding on a Wales scale and also on a site and catchment scale and taken action where it has been possible. Getting from the starting point of knowing nothing about a site to remediation is always going to be in the region of four to seven years, so we have that capacity issue. We start with two years of monitoring just to make sure we understand and apply our resources appropriately.
Q38 Chair: Sorry again, if there are more than 1,300 of these abandoned mines, with the timescales you suggest for understanding each mine none of us are going to be around at all before we have even got halfway through them.
Dave Johnston: We have been refining our numbers downwards. Thirteen hundred is all the mines and there are some you would not even notice. There are two mines on Flat Holm, for example.
We have much smaller numbers. We have refined our numbers. We identified the top 50. We did a report more recently with the Coal Authority in 2020 that identified, I think, 129 sites where we could prove an impact. However, that still does not mean that we have to intervene on every one of those sites.
Q39 Chair: Very helpful, thank you. From Mr Banton, yes, from the Coal Authority’s perspective.
Carl Banton: From the Coal Authority’s perspective, we have been here since 1994 and there has been more work done on the coal programme, which is a UK-funded programme of course. We have been involved in the metal mine side since 2020. We are funded differently through the Welsh Government to deliver that programme, working very closely with National Resources Wales.
From a coal point of view, there are 60 mine water treatment schemes in Wales. I can give more facts on those. I think the coal side is a lot more well understood, and the treatment side from a coal point of view is a lot easier to do. From a metal mine point of view we are looking at sustainable solutions. It is only in the past 15 years where we have been developing those sustainable solutions to be able to treat these metal mine waters. However, we are looking back over many, many hundred years for some of these mine sites where they have been adding poor quality water into the systems.
Q40 Ruth Jones: Thank you, gentlemen, for coming in this morning. There was something you said just now, Mr Johnston, that you have been working on these sites and that you are quite confident of the top 50. There are 129 marked as red on our maps. If I was a person living in Ceredigion, for instance, I would want to know that everything is being done. I am not convinced at the moment that everything is being done to make me feel safe in this place. We heard from the academics in the previous session that communication is key; find out what you know about your own soil in your back garden. My question to NRW is, are you talking to residents? Are you making them aware of the situation? Are you ensuring they understand what is going on?
Christian Wilcox: Our primary focus is around the water quality impact, hence trying to tackle the problem at source, particularly in the mines themselves. I think the wider engagement, from our perspective, is around water quality rather than contaminated land. That would sit with the local authorities to pick up. What I am not sighted on is how much that engagement is taking place through the local authorities into those communities.
Q41 Ruth Jones: I am anxious now because obviously we have heard that soil is one of the biggest issues. If the lead is in the soil and you are not picking it up, and the local authorities maybe do not know to pick it up, there is a massive hole that things are falling through here, is there not?
Christian Wilcox: There are certainly areas where we can work closer. We are plugged into certain areas at local authorities. However, in terms of that broader engagement, I agree, to map out and understand what the academics said earlier, mapping out what those risk areas are and understanding the impacts but making sure we are working within the remit that we are working with. As I said, primarily our focus is around the water quality impacts.
Q42 Ruth Jones: To the Coal Authority then, how do you, as organisations, work together? You are big organisations and you have your own remits. This is an issue that needs close co-operation and partnership working. Mr Banton, how do you see the partnership working here?
Carl Banton: We have always worked very closely with the EA and National Resources Wales in Wales for the past 20 years. We currently have an MOU with National Resources Wales that was signed five years ago. We are currently working, along with Welsh Government, on a different methodology, different governance, within that where they can potentially fund us directly to work with all parties so we can build this long-term programme to help deliver some of the solutions we are looking at, not only the solutions but then the long-term management of those solutions. Once we have built these mine water treatment schemes they need to be managed for the long term. From a counter point of view, we have a 100-year provision from the coal side of what we do. For this, long term, you would need similar sorts of things which have to be accounted for because once you build them they do need to be maintained and operated.
Q43 Ruth Jones: Mr Cox, your title is Head of Metal Mines Programme so I would assume you will be stepping outside your coal remit, if you like. How are you working to ensure there is joined-up working here?
Nick Cox: In terms of the Coal Authority, our role is as the delivery partner. We work very closely with NRW. Obviously their role is in the monitoring, the catchment characterisation and the prioritisation. Then it comes over to us to then develop those solutions, to deliver and construct. That is our role in that process.
In terms of engagement with the local authorities and the public, the local authority is one of our statutory consultees in that process but our involvement in that public consultation piece is when the works actually take place on those sites.
Ruth Jones: Thank you.
Q44 Beth Winter: I took some notes when the Professor was speaking earlier. It came across very loudly and clearly that the focus of remediation work continues to be on the mine sites. That needs to change. Listening to the Professor, there is extensive international research providing all the evidence that is required, as well as recommendations about what action is needed. Listening to you now, I am perplexed as to why we are where we are when the evidence is clearly there.
Dave Johnston: Our focus, again, is water quality, the sources of the water quality impacts on the rivers. Our focus, which is the remit we have been given by Welsh Government, are the mine sites. There is a contribution, undoubtedly, from the floodplains as well. However, when we have modelled it, when we have monitored and when we have worked it out, the significant sources are the mine sites so we are dealing with those. The remediation plans do not just look at the mine water running out of the mine and looking at the treatment methods for those, they are looking to stop sediment movement that would be continuing to add to the problem downstream. We do recognise the Professor’s work. The original work was funded by the Environment Agency and published by our Groundwater and Contaminated Land Centre.
Q45 Beth Winter: Are you challenging the validity and reliability of the research?
Dave Johnston: I am not challenging it at all. Not at all. It is very much respected. We have been working with Professor Macklin for some time.
Q46 Beth Winter: Do you agree that more emphasis needs to be not just on sites but exactly on what the Professor was saying earlier?
Dave Johnston: I agree they are both important. From a water quality perspective, in terms of ongoing water quality, it remains the sites that are the cause.
Q47 Beth Winter: Is your emphasis because of where your remit lies and not based on what the evidence shows is required? Are we being blinkered about our responsibilities in terms of our agencies when we need to look at it differently?
Dave Johnston: Our remit is water quality and that is the focus of the metal mines programme. The remit for understanding contaminated land and the leakages between soil concentrations and human health lies with the local authority.
Christian Wilcox: It is worth adding that even if you were able to decontaminate the land, an dclean up the land, if we did not stop the pollution at source that would then continue, it would be an ever-going cycle. Therefore it is important from our perspective to stop it at the source. I agree there is a complement around what we can do in terms of remediation, but unless you stop the initial source of the problem, that is going to continue to pollute the ground going forward as well.
Dave Johnston: We do have a role in the contaminated land regulations and their implementation. There is a forum between ourselves, the local authorities, the Welsh Local Government Association and the Health Security Agency that meets regularly and discusses issues of contaminated land across Wales. I am well aware that this issue of contaminated floodplain soils is on its radar, it was discussed at its last meeting.
Q48 Chair: Thank you very much. On the issue of continuing pollution from source, I think the figure that was quoted in the FT investigation was 500 tonnes of metals going into Welsh waters from these abandoned mines. Is that a figure that resonates with you? Do you recognise that figure?
Dave Johnston: Yes, that arises from our monitoring, our data. We have published that figure. We have been monitoring our sites for 20 or so years when calculating the loadings discharged both from the mine sites themselves, the water running out of the mines, but also looking at the concentrations in the river. Yes, that sum is quite reasonable.
Back in 2002 we got up to about 350 tonnes but that was only looking at heavy metals. If you go to Parys Mountain, which I mentioned before, that accounts for almost a third, if not more than that, of that total load. What we have to remember is that it is not the load that causes the impact in the rivers, it is the concentration and the water quality. There is also a sediment burden and, of course, the ecosystem relies on the sediment as much as it does the water quality. We have another research collaboration looking into the impacts of that with Queen Mary University London at the moment, looking into better developing our monitoring techniques to be able to pick up those ecosystem effects in the invertebrate populations and in the plant populations as well.
Q49 Robin Millar: Mr Cox, you joined the Coal Authority in 2017 I believe.
Nick Cox: I did, yes.
Q50 Robin Millar: In 2020 the Coal Authority produced the Metal Mine Failing Waterbodies Assessment. How is that going? What has been the impact of it and the subsequent metal mines programme, please?
Nick Cox: As my colleague, Carl Banton, described, in 2020 we signed an MOU and formalised this Welsh metal mine programme. Since then there has been a focus on the priority sites. As Dave Johnston described before, there is a timeline to developing solutions and delivering solutions on these sites. In 2020 we were in COVID, there was lots of scoping and early design works. Moving forward to where we are today, we have 12 projects currently that are in the development stage, within this year of the programme. There is then 18 that are in solution development, where we are working on detailed designs, delivery, getting ready to construct. Of that, there are five projects where we will be conducting works on the ground that, again, are largely erosion control, which is stopping that sediment input or diverting clean water around workings to stop dissolved metals getting into that system.
Q51 Robin Millar: I will come to that in a moment. I represent Aberconwy—that is Dyffryn Conwy, the entire length of the Conwy Valley. I know there are mines at the top end of the valley between Llyn Crafnant and Llyn Bodgynydd, quite extensive historic mine workings. I spotted on the map that was included in the report that there were various asterisks around that point. What does a remediation programme look like effectively in that sort of case, where you have large bodies of water, there are reservoirs that have been built there and it has a huge impact downstream? What does the remediation programme look like in that case?
I should add I was very excited to see in the report as well that there was a full status change possible and high confidence that would be the case for the Conwy River, so I am very eager to hear it.
Nick Cox: As Dave Johnston described before, we have to collect a lot of information both in terms of that monitoring and assessment. It is about understanding what is happening with the water. One of my colleagues described this process of mine water treatment and the length of time, that once you start treating mine water you are treating it into perpetuity. From a hierarchy of control we would much rather divert clean water around mine workings and not have to take on that burden of cost. A lot of work goes into the design is to make sure we have the most appropriate method. If we can divert clean water around, and look to cap some of this fine, metal-rich sediment material so, with erosion control, we can avoid that sediment load getting into the river. It is around prioritising. As Dave Johnston said, that is the role of NRW and we are coming in as a delivery partner to identify and work up those solutions.
Q52 Robin Millar: I was very interested in the last session to hear from the academics that they felt the concentration—that is not a pun, it is certainly not intended as a pun—had been on the mine sites rather than downstream. I spotted a civil engineer among the witnesses that I was very encouraged to see. My dissertation was on this transition between laminar and turbulent flow and that has a key impact on the carrying of sediments. Do you feel there has been too much of a focus on the mine sites and not enough on the downstream impact? Again, I think of the Conwy Valley and the extensive sedimentation that occurs, especially in the lower reaches of the valley.
Nick Cox: As I said upfront, our role is one of delivery partner. We are given these sites to work with and to identify. When you are describing them as a mine site, very often it is an adit, it is a mix of adit and underground workings together with lots of spoil, typically very small particles maybe from historical dressing floors. It is not just one or the other, typically what we are having to do is to look at both dissolved metals—maybe the clean water that is getting into workings, washing out metals and coming back out into the system—but also picking up that in high flow, in flood events, it is around this erosion control and what we call diffuse pollution. It is that sediment loading and trying to avoid that or reduce it either by capping or by revetment structures and so forth.
Q53 Robin Millar: As a simple question, do you feel you have the balance right between the upstream, if you like, interception of water and diversion around a contaminated site to prevent further pollution and the downstream prevention of re-concentration or redistribution of sediments that will cause legacy problems downstream? Do you think you have the balance right?
Carl Banton: Within the Coal Authority’s role, yes.
Q54 Robin Millar: You are caveating that very carefully, both of you are saying, “within our role, within our scope”. Is that a suggestion that if your scope was different you might concentrate resources differently but you are working within the terms you have been given?
Carl Banton: We are funded by and work with National Resources Wales and Welsh Government on a specific element of the programme and that is our role. I think it is more a wider question for National Resources Wales or Welsh Government.
Robin Millar: If I may, Chair, I will direct it to National Resources Wales?
Dave Johnston: I will start, I think Christian will pick up. As I said before, looking at the water quality remit, yes, those are the sources. There is an impact but we can account for the water quality impacts with the runoff, the erosion, the loadings, we are seeing coming off the mines themselves. There could well be a move towards that wider floodplain. As I said, we commissioned that early report and we have been very interested to read the later iterations, particularly the global side of things. We probably would await the report that Professor Macklin was talking about of actually mapping it better, then we will understand it better and we can make decisions about it. Currently we have identified the sources that are causing the water quality impacts that we are recognising and so we are focusing our efforts there.
Q55 Robin Millar: I will ask one follow-up then. Are you suggesting we are flying blind on this?
Dave Johnston: No, not at all. I do not think we are. Floodplain sediments have been picked up in investigations by local authorities. In 2014 Ceredigion Council closed the allotments in Aberystwyth because of the flood that had just happened. They closed the allotments because of the understanding that floodplain sediments contaminated by metals were a problem—they knew that. They closed the allotments until they were able to test the soil and test the vegetables and give them a clean bill of health.
Q56 Robin Millar: Are you confident—this will be my final question, Chair—that the downstream testing regime is sufficient to catch that sort of information because that seems critical?
Dave Johnston: There is not a testing regime. Again, we have a good monitoring programme around the rivers, around water quality, but there is not an overall testing regime for the land. There is no driver for it, no statutory driver for it. The contaminated land regulations require the local authority to identify what they call the significant pollutant linkage, so they expect to find an impact and a source and the connection between it. Therefore they would be looking for the impacts of that land pollution.
Q57 Robin Millar: It is event driven, perhaps, rather than a fixed regime.
Dave Johnston: They have an inspection strategy that they work through and that will be prioritised depending on the different priorities they have and different potential sources and different potential impacts in their areas.
Q58 Chair: Ruth has a quick question but I will throw an extra one in first. How many local authorities are you aware of right now in Wales that are actively testing for contamination of land from metal mines?
Dave Johnston: I cannot answer that.
Q59 Chair: Are you able to name a single local authority in Wales that is doing the work you have just described?
Dave Johnston: All of the local authorities are implementing their inspection strategies but I do not know the answer to that question.
Q60 Ruth Jones: Following up on that, in 2002 the Environment Agency Wales was aware of the situation. Academics have been aware of it for 30 years. You said earlier, Mr Johnston, the Welsh Government remit is for water, not soil. My worry is that we are missing a massive area here. We talked about rewilding earlier on. The soil is the problem, not the water necessarily. I understand where you are coming from with the sediment but I am anxious that the remit is too narrow and you are missing out on things.
Dave Johnston: I understand that. It is not that it is one or the other, they are both a problem. Yes, our metal mines programme is dealing with the water. There is also an issue, as has been shown, with the soil. It is not Welsh Government’s remit only to worry about the water, their remit covers everything, of course. Our remit in the metal mines programme as defined is to deal with the water pollution.
Q61 Ruth Jones: NRW deal with soil across Wales. In my area, Newport West, we have had soil issues and NRW comes in and deals with them.
Dave Johnston: I do not know the detail of that, obviously, but for contaminated land we have the issue I talked about that the local authority has to identify the source, the pathway and the receptor. Then their recourse for remediation is to identify the responsible party for that. Certainly in terms of the mine sites that responsible party has long gone and, in fact, there are exemptions written into the legislation that mean we could not serve a notice on any person, even the landowner at the sites, for issues of water quality, although the local authority could if there was a human health issue. I lost my track there.
Chair: That is fine, thank you very much.
Q62 Ben Lake: Thank you, gentlemen, for your time this morning. Can I go back to this figure of 1,300 mine sites to begin with and ask a very simple question? How did we identify 1,300 mine sites? It seems a laborious task to walk across the mountains of Wales and identify them.
Dave Johnston: It did not involve going out and looking as such, it was literature research. These sites are well documented. Albeit it was an entirely unregulated industry, the sources are out there. People are fascinated by these sites, they have written histories of them. Leading up to the 2002 report—in fact the 1,300 sites came out earlier, in the mid-1990s—it was identification of all the sites simply that were in the literature that we could identify as a site. As I say, 1,300 is an estimate. It is very difficult to define a mine. They have been worked in multiple phases over different years. There are multiple entrances and exits leading into the same mines, and multiple mines are connected together so we have four or five mines that cause one problem. Thirteen hundred is our best estimate but it all came from history, from the historic literature, which is pretty well recorded.
Q63 Ben Lake: That is very interesting. The red sites have been mentioned already and I think 129 red sites have been identified. What constitutes a red site as opposed to an amber, green, yellow, or whatever other colour there might be? What are the factors and thresholds that you look at to consider red?
Dave Johnston: It is a proven link between the site and the impact on the watercourse. Our monitoring or the evidence we have collected over the years, either on the site or in the river, has made that link. It is a red site if we know it is a significant contributor. Again, it does not mean we will necessarily intervene at all of them but we have identified that those red sites are the areas we need to be focusing on.
Q64 Ben Lake: Of the 129 red sites, how many are you planning to remediate or have undertaken work already on them?
Dave Johnston: I can pick that one up again. We plan to work through all of them. If we only have a limited capacity it will take a very long time, as you have already recognised. We proposed a 30-plus year programme to Welsh Government and we are in discussions about how we do that. We will look at all of them. Many of them will drop off the list as needing intervention. It is a tiered investigation. We start with monitoring to determine if there is really an impact. Then we look at how we could remediate it and look at the feasibility of doing that. Then we look at the balance between cost and benefits as to whether we go. It could fall out or be taken on to the next stage at any one of those stages.
Q65 Ben Lake: The 129 red sites are provisional in a sense, they may well change and there may be amber sites that are promoted or elevated to red?
Dave Johnston: Yes, and red sites may drop. Yes, exactly.
Q66 Ben Lake: At which point do you think we will have a firm idea of whether or not the 129 are 129? From what you are saying, it seems to me as though we may well be here in five years’ time talking about a completely different set of mines that are still there right now.
Dave Johnston: We started some of this work that led on to this metal mines programme with a specific fund from Welsh Government and went straight out and did 50 investigations at 50 sites that we picked; not the original top 50, we have moved on from that. We did desk studies to investigate the information we already had. That has already taken a big chunk. Some of those have moved forward. We currently have, I think, 25 live projects but many of those are looking at multiple sites, they are looking at a catchment rather than a single site. We are probably looking at in the region of 35 of those sites at the moment. Some of those have moved right on to being almost on the cusp of delivery. We have undertaken the feasibility studies and gone right through detailed design so we know what we need to do, we know what we need to build and we are hopefully starting some of that work this year because have now had the four years of consolidated funding from Welsh Government. If we can move on some of those sites this year that will be great.
Carl Banton: That is the importance of the long-term funded programme on this because without that programme you would be almost stopping and starting again. Therefore it is about that continuing programme of feasibility and then moving projects through each of the stages.
Q67 Ben Lake: Can I clarify? I appreciate the constraints on your resources and I will not ask you a hypothetical question that if you had a blank cheque how many of the sites you would want to remediate. It would, nevertheless, be the case that all this work will address issues relating to water quality. They would not necessarily impact or address the legacy contamination that we have heard a lot about this morning. That is correct, is it not?
Dave Johnston: That is correct, yes.
Q68 Ben Lake: Very briefly, Chair, if I may? I am unclear as to who precisely is responsible for that risk. My colleague, Ms Jones, said in certain parts of Wales NRW has been able to help remediate issues with soil. I have also heard you mention local authorities. We are all aware of the constraints on their budgets as well. Who is taking the bird’s-eye view of monitoring the potential risk and then identifying or instructing the relevant body to take action? At the moment it seems to me as though this issue of legacy contamination is falling between not just two stools but a number of stools, and falling through the net. Can you give me an assurance that somebody is keeping an eye on this?
Christian Wilcox: I suspect Welsh Government will have a role to play. Obviously the remit sits with the local authority unless it is deemed a special site—forgive my terminology, I am an engineer and not a scientist—at which point NRW could then intervene around that contaminated land. However, Welsh Government would ultimately have the overall view of both of those bodies.
Q69 Chair: Thank you, Ben. I am going to come back to this list. Forgive me, I feel a little bit bamboozled here. There was an original list of 50 sites that were identified. There is a list of 129 red sites. How many of those 50 are deemed red?
Dave Johnston: Almost all of them. Some have already dropped out of the process. We identified the largest sites, the ones we assumed to be the largest polluters, and that has generally carried through. Most of those sites are still on the list.
Q70 Chair: You have said you have been looking at another 50 sites, a different list of 50.
Dave Johnston: That came out of that list of 129.
Q71 Chair: So today, right now, is there any work going on, on any of those mines, be it on the list of 50 or the list of 129? Is there any physical engineering work going on to fix any of the mines on that list?
Dave Johnston: Yes.
Nick Cox: As I described upfront, there are 32 projects that are in various stages of either project development or solution development.
Q72 Chair: I am going to pause you there, Mr Cox. Thirty-two projects, is that the same as the 25 live projects you have just referred to?
Nick Cox: At different stages. We have 12 projects that are in early project development. We have 18 projects that are in solution development, of which five of those have planned works within this financial year—on the ground, physical works. A further two projects are relating to R and D trials.
Q73 Chair: For the five projects scheduled for this financial year for work to start, do you have contractors in place so there are engineering partners that have been brought on board and contracted with to do that work?
Nick Cox: Yes.
Q74 Chair: Are you able to say what those five mines are, please?
Nick Cox: As it stands, Cwm Rheidol is blowout protection; Cwmnewydion has had some work there on millpond overflow, erosion control; Nantycreiau, which is again erosion control so it is sediment; Pandora, work there on lake access; and at Castell Sett, which again is erosion control so it is around stopping the source of the material that is going to be transported.
Q75 Chair: It is encouraging there are works underway. However, how have those five sites been picked? Have they been selected because they are the most troublesome, they demand the most urgent attention or are they convenient to do? What has been the decision making around that?
Nick Cox: Partly in terms of that prioritisation process. The erosion control stuff is obviously a lot easier to do. From our involvement in the programme in 2020 to where we are today the erosion control stuff is easier and shorter to plan and deliver than the delivery of some of the mine water treatment schemes or some of the flow paths. In terms of the prioritisation, yes, some of it might be easy. Some of the sites are quite complex. Areas might be of special scientific interest or SACs, so some require a lot more stakeholder engagement or planning and so forth. There is a range of prioritisation. Within those five we have also already started engaging, for example, at Dylife, which is another one of the sites, where we have started public engagement with the local authority, statutory consultations, for four phases of delivery over the next four years. It is not just around what we are going to do this year but moving forward as well.
Q76 Ben Lake: Very briefly, of the five sites identified, if the work is successful what are your hopes in terms of reducing pollution to the watercourses?
Nick Cox: In Cwm Rheidol that is around blowout protection. That is around trying to protect a one-off influx of material from entering the watercourse. For the other four it is around reducing the amount of erosion and therefore influx of diffuse or sediment loading. It is difficult to quantify what that might look like because, depending on rainfall, the volume that goes into the watercourse will vary.
Q77 Robin Millar: In 15 years’ time is there going to be a headline that says there is a huge public scandal due to contamination from abandoned Welsh mines and that we knew about it 15 years ago? You are the people who are closest to this. There is the apocryphal story of somebody in a power station and there is a flashing red light and with a little tap the light stops flashing. That happens for years until suddenly it goes bang and then, “Oh, yes, there was always that red light flashing”. You are the people closest to that dashboard. You are the people who have written the reports. You have heard the academics. You are doing the works. Is there anything we are missing? Is there a lack of political will? Is there a lack of funding? Is there something we are missing? Is there going to be a big problem two decades down the road?
Christian Wilcox: Those are really good questions. We have some priority sites at the moment. We have a programme of works that takes projects through from inception all the way through to construction on site. That programme can be as scalable as you need it to be and you want it to be. At the moment our forecast is based on the funding we currently receive from Welsh Government, which is the constraining factor.
Q78 Robin Millar: You are doing what you can with what you have right now, but there is nothing—no glaring omission or big worry—at the back of your mind which you are thinking is at the top of it?
Christian Wilcox: There is no silver bullet to this. This needs investment and better regulation. This needs collaboration and integration across all parties and working with our delivery partners to move this forward.
Carl Banton: I will add to that research and development as well. We have two programmes across England and Wales that are cross-collaborating, which is great, and that research is being done, but worldwide as well. We are part of International Mine Water Association. But the work that Mark was talking about earlier—
Q79 Robin Millar: To be clear, are you talking about unknown unknowns or known unknowns; things that we know that we do not know? Or are you saying we just do not know what we do not know?
Carl Banton: I think it is a little bit of both. Mainly on the mine water treatment side, it is the known unknowns of how we do this sustainably. More widely, there is some more work to do, which we have heard from the academics earlier, which I think is very valid.
Q80 Beth Winter: This is a comment because we have had similar questions already. I am concerned there is a risk that we are working in silos as agencies—which is understandable given your remit and the funding and so on—which is hindering the prioritisation and the need to have a whole systems approach, which I think people have acknowledged. Where does change need to happen? You have mentioned Welsh Government in response to my colleague, Mr Lake; the Welsh Government has a responsibility. In terms of the strategic work that needs to be done, do you agree that there is change that needs to be taken so that we have the whole systems approach?
Dave Johnston: I am aware that the Welsh Government are fully sighted and we have a good relationship with Welsh Government—certainly with the water branch who have provided the funding for our work. We know that they are also entirely sighted on the work you heard about in the earlier session, and we are discussing it with them. I have every expectation that we will be having more discussions and reviewing the way it goes.
The way we work is taking that influence from current research, from current interest, because public interest in issues is also a key driver. That is one of the reasons that we have the stakeholder communications around our work. But we have also commissioned, as part of the metal mines project, a project with the Strata Florida Trust, so based around the Ystrad Fflur; the abbey near a mine was run by the monks originally. That is an outreach project to take out information about the mine sites and their history, their heritage, but also the pollution they cause—the full pollution they cause, not just the on-site pollution—with the local community.
Beth Winter: Did you want to come in, Mr Banton, or not?
Carl Banton: No, I think it is very much a Welsh Government point.
Q81 Beth Winter: The professor was saying there are international models that could be adopted or replicated in Wales. Is that something Welsh Government should be looking at, at a strategic level?
Dave Johnston: I will be talking to Professor Macklin in any case. We are going to have a meeting with Dr Sartorius tomorrow looking at how we can communicate.
Beth Winter: That is with Welsh Government as well.
Dave Johnston: Welsh Government are also there. They are involved in it.
Q82 Beth Winter: The final question, sorry, because I know we are probably over time. We mentioned targets; in England, there are targets in terms of addressing pollution. Should we have similar targets in Wales?
Christian Wilcox: I think targets are always good. We work to targets at the moment. We set ourselves targets each year anyway. So I would always welcome the introduction of targets to allow us to work to. It is something that we are adopting at the moment.
If I may just come back on your previous point: I think you are absolutely right, funding drives us to work in silos, and I would love us to all get to a place not just on metal mines and coal tips, but generally to understand what the vision for a particular area is. Let’s forget about who is responsible for what, what is it we are trying to achieve, who is best placed to deliver it, where and when. Ultimately, it is the nature and climate emergency that we are all trying to tackle as the main benefactor rather than an individual’s problem.
Q83 Chair: We are coming to the end of the session. It has been very helpful. There is probably some ground we have not covered, so we may follow up with some written questions, if we may. Can I just ask though: previous evidence that we have received from NRW, mentions, I think, that one of the mines in that original 50 list that was identified back 22 years ago has been remediated, the Frongoch mine. Is that correct?
Dave Johnston: Yes.
Chair: That work has been done?
Dave Johnston: Yes, it is not a complete remediation. What we dealt with was the old ore processing area, which was a major source of metals into one tributary of the Ystwith. Some of the work that Nick alluded to, we diverted a stream that was running directly into the mine. There were open mine workings, the stream was going into that. A major part of the work was taking that clean water and keeping it clean and diverting it around. The outcome of that was a 70% reduction in the metal loads into that river—
Chair: Sorry, I am just conscious of time. I am told that 15 tonnes of metal is still being polluted each year from the Frongoch mine.
Dave Johnston: It is. Because, like I say, there are two parts to it. There is the dressing floor, the oil processing area—that is largely dealt with—but there are still the underground workings, they are discharging. That is one of our priority sites on the Nant Cwmnewydion that Nick mentioned that we are looking to progress fairly rapidly.
Q84 Chair: Thanks for being frank on that, but it is not true therefore to point to Frongoch as an example of success, is it; a mine that is still leaking 15 tonnes?
Dave Johnston: No, for the entirety of the mine, the work is not complete. The work that we did was very successful.
Q85 Chair: Sure. But coming back to that list of 50, 22 years ago, the metal strategy was put in place—22 years on, in 2024, here we are, and not even one of the mines has been fixed.
Dave Johnston: Not in its entirety, that is true.
Q86 Chair: We were speaking a moment ago about silos. We talked about resource constraints. We have talked about the different drivers of policy. You would forgive us if we came to the conclusion that the whole setup just is not fit for purpose for dealing with this problem and the scale of it, right?
Dave Johnston: Yes, I would forgive you for that.
Chair: I do not want to end on such a depressing note, but it is pretty concerning what we have heard this morning, and we do appreciate you taking the time to respond to our questions. We are over time now, and we have Wales questions down in the main Chamber in a few moments, so forgive us, we are going to have to rush away. But thank you for being here. We will bring the meeting to an end.