Because the quality of groundwater is influenced by the host rock through which it moves, it differs on a site-specific basis, and is often naturally brackish or even potentially harmful to people. In spite of this, many practitioners incorrectly use the SANS 241 Drinking Water Standard as “compliance requirement” to compare groundwater quality against. This standard only applies to water that has been purified to be suitable for potable purposes at a water treatment works in terms of regulations made under the Water Services Act 108 of 1997. The only circumstance in which it could be used to compare the quality of natural groundwaters against, is where such groundwater is (to be) used, for potable purposes (with or without treatment), and then only to provide guidance on the level of treatment required to facilitate suitability for such domestic use, and not to determine possible ‘unacceptable’ levels of contamination. Therefore, the comparison of groundwater quality results against the SANS 241 Drinking Water Standard is not only a scientifically flawed practice, it has no basis in law. It is furthermore a scientifically flawed practice to refer to groundwater quality as ‘good’, ‘bad’, or ‘poor’, as it reflects a judgemental anthropocentric perspective that has no place in modern discussions on judicious environmental management and monitoring.
This then raises the question, what are, or should the limit values be against which groundwater quality results should be compared to determine if it has been negatively affected by anthropogenic activity to such an extent that a scientifically substantiated claim can be made that the groundwater has been ‘polluted’, an allegation with criminal liability implications?
This paper aims to answer this question in the context of South African Framework law and policy, and propose a methodology to determine appropriate site-specific limit values for groundwater quality.