Nuclear-1 Appeal Supplementary Submission

After a long process described described here Eskom was granted permission by the minister for the environment to build a new 4000 MW nuclear plant at Koeberg. After three years of silence, the process was revived as described here. We appealed for an extension,  and finally completed the submission below. Continue reading

Eskom releases Koeberg Decommissioning Strategy

Koeberg is the only nuclear power plant in Africa, and is operated by Eskom under a licence issued by the National Nuclear Regulator. Section 17.2 of this licence specifies that “The licensee must submit for approval a decommissioning plan, as early as possible in the life cycle of the activity or facility. The plan should be revisited and updated as necessary.”

Using the Promotion of Access to Information Act in August 2020 we submitted a request to Eskom for a copy of this plan. In October 2020 they responded with a letter and the document below. Continue reading

Nuclear-1 EIA submission period re-opened

Letter from DEFF EIA supplemental submission extension grantedAfter three years of silence, the Nuclear-1 Environmental Impact Assessment process was revived by an invitation for “supplemental submissions”, as described in  Nuclear-1 EIA revived with ‘Supplemental Submissions’. The invitation specified a condition that supplemental submissions may only be made by those who had submitted a formal appeal in 2017. We wrote to the department and objected to this condition as follows:

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New Long Term Nuclear Regulations?

On 19 June 2020 new Draft Regulations on the Long Term Operation of Nuclear Installations were published by the Department of Mineral Resources and Energy for comment, due by 19 August 2020. This is the fourth major nuclear power related activity in government circles since the start of the Covid-19 lockdown (the others were the RFI, the EIA Supplemental submission invitation, and the discussion paper on decommissioning policy).

The exact aim of these new regulations is not clear, giving rise to concerns that they may be aimed at attempting to weaken or bypass the regulations relating to Environmental Impact Assessments.

If they were to be adopted, they would likely be applied to attempting to extend the life of the Koeberg Nuclear Plant, which is due to be shut down in 2024. Continue reading

A National Nuclear Decommissioning Policy?

On 20 July 2020, the Department of Mineral Resources and Energy (DMRE) released a Discussion Paper on National Decommissioning Policy for Nuclear Facilities.

This was a well balanced document which went into some detail, and proposed various decommissioning strategies. It posed 10 questions which covered liability and security for decommissioning costs, strategies, and research needed.

The actual costs of decommissioning the Koeberg Nuclear Power Station, including final disposal of the spent fuel (so far over 1.5 million kilograms),  are unknown. If South Africa had followed the Swedish model with a levy on nuclear power Eskom should have accumulated a fund of about R170bn by now. Instead, Eskom is R450bn in debt. Continue reading

Nuclear-1 EIA revived with ‘Supplemental Submission’ period

The Nuclear-1 Environmental Impact Assessment (EIA) for a large new nuclear plant at the Koeberg site was given the go ahead in 2017, resulting in many appeals against this decision.  After three years of silence, the Department sent out a notice to appellants in July 2020, inviting a supplemental submission.

The EIA was based heavily on the Integrated Resource Plan (IRP) 2010, which included projections of strong economic growth and vastly increased electricity demand by 2020, and hence the need for nuclear power stations. Recently the IRP 2019 was released, which took into account the actual electricity demand, and so delayed any possible need for new nuclear power to beyond 2030.

Despite the length of time that has passed with the EIA process in limbo, the Department have told us that interested parties may not make submissions now, unless they also submitted a formal appeal in 2017. The deadline for submissions is 3 September 2020, although this may be extended. Continue reading

Koeberg Emergency Plan conflicts with COVID-19 regulations

Koeberg Population Density Map

Nuclear-1 EIA App E18

A nuclear incident requiring an evacuation around Koeberg would have a significant effect on the spread of COVID-19. During an evacuation, social distancing will not be followed as people pack into any available transport. Travel restrictions will either be suspended by the government, or overridden by the public possibly with bloodshed. No roadblock can stop 80 000 panicking people! Continue reading

Government Officials Continue to Divert Funds to the Nuclear Industry

It has long been suspected that the only motivation behind pushing for nuclear power in South Africa has been corruption via State Capture, coming from then President Jacob Zuma. Details of this are emerging at the Zondo commission into State Capture where it has been testified that a Minister of Finance was fired specifically because he would not ignore the realities of the cost of nuclear power, and so refused tos sign off on the nuclear deal.

Despite this, and despite Zuma being removed from office, there are disturbing signs that there are still those in positions of power who are pushing for taxpayers’ money to be given to the nuclear industry.

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Response from Eskom to our appeal against the Environmental Authorisation for Koeberg Nuclear site

Title page of response from Eskom to the KAA appeal

Back in 2007, Eskom began an Environmentam fcl Impact Assessment (EIA) for building a large new nuclear power plant on the Koeberg site, about 28km north of Cape Town. Ten years later, after many drafts and submissions, the Department of Environmental Affairs issued an Environmental Authorisation for the project to go ahead. Many organisations appealed this decision, and Eskom was required to respond in detail to the content of each of those appeals, which they have now done (in August 2018).

Many of these responses were combined into one document, which has been widely distributed. However, KAA received the following 115 page specific response. There has not been time to go through it in detail yet, but it is published below to give you all the opportunity to have a look through it and pass it on to others.

Paging through it, a few bits stood out for me.

A tourism plus…
In a show of optimism regarding possible impacts of tourism, Eskom writes “Some nuclear power stations have a positive effect on tourism, as tourists visit specifically to see the stations.”

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Appeal against Environmental Authorisation for Koeberg

After a long Environmental Impact Assessment which began in 2007, an Environmental Authorisation was issued for the Koeberg site, 26km north of Cape Town.  This gave Eskom permission to build a new nuclear plant of unspecified design, plus a nuclear waste reprocessing and/or disposal site.

At first only 30 days were allowed for appeals against this decision, and this was extended on the day of the deadline to about 90 days, until 5th March 2017. There are so many reasons this Authorisation was wrong, and we tried to describe some of them in the 43 page submission we wrote. Continue reading