The Koeberg Alert Alliance (KAA) first requested a copy of the emergency and evacuation plan for for the Koeberg Nuclear Power Station via a Promotion of Access to Information Act (PAIA) request in 2010. This was formally refused on 2 June 2010 by Steve Lennon, the co-ordinating Deputy Information Officer for Eskom Holdings, for convoluted legal reasons.
A second PAIA application was made by the KAA in 2011. This was initially refused on 22 November 2011 by Eddie Laubscher, the National Deputy Information Officer for Eskom Holdings. The CEO of the NNR (National Nuclear Regulator), Adv Boyce Mkhize also formally refused access to the plan on 23 November 2011, claiming it was classified as confidential.
In December 2011, in response to an appeal by the KAA against this refusal, it was reversed and a document has been provided, which is titled “THE INTEGRATED KOEBERG NUCLEAR EMERGENCY PLAN”. The full ‘plan’ is available here: Eskom Koeberg Emergency Plan.
Clearly, the reasons quoted by Steve Lennon, Eddie Laubscher and Adv Boyce Mkhize we all invalid. This does raise the question as to why these people found it necessary to attempt to hide the plan from public view. Either they were ignorant of the regulations, or they were lying to the public.
When asked for comment, spokesperson for the KAA, Peter Becker said “The document itself only 61 pages long, and much of it is definitions and references to other documents, with only about 15 pages dealing with procedure. It is also dated 2008, so it seems questionable if it is complete and up to date in terms of population growth, new housing developments, and lessons learned from the Fukushima disaster of 2010. We will continue to analyse this report and will have further comments in the near future.”
Some more details…
It’s been a year since the Fukushima disaster and yet Eskom still has not found it necessary to add anything to add to their 4 year old Emergency Response Plan. Yet there are many lessons that Eskom should have learnt from the experience of their Japanese counterpart TEPCO (Tokyo Electric Power Company).
The first and perhaps the most important lesson is that TEPCO ignored warnings that its safety case was inadequate. Each nuclear power station is uniquely designed to match its “safety case” which is an assessment of the specific risks associated with its location. Experts had warned TEPCO that their plant could be hit by a bigger Tsunami that what it had been designed to withstand.
Koeberg is surrounded by a wall 8 meters above sea level because their safety case is based on a maximum tsunami size of 7 meters. Yet Eskom’s own environmental impact study for new reactors estimates that the maximum water height at Keoberg could be as high as 10.5 meters above sea level if a Tsunami occurred simultaneously with a big storm. So even their own data shows that Koeberg could be flooded under 2.5 meters of water. This would swamp the backup diesel generators, which is what happened at Fukushima.
Huge storm waves are quite common off the West coast. Every year in mid-winter a big wave surfing contest is held off the Cape Peninsula. If the waves do not reach 10 meters in height then the contest is cancelled (and the contest is seldom cancelled). Sea bottom structures and currents combine in unpredictably complex ways to focus waves so that large waves do not strike at the same height all along the coastline. Any change in the currents or sea level, such as may be created by a Tsunami, can significantly change the focus of big waves so that their highest peaks could make landfall at any place along the coastline, including at Koeberg.
Tsunamis are caused by colliding subducting plates, which cause the vertical movement earthquakes that result in Tsunamis. A tectonic plate boundary of this types exists off Japan and this caused the Fukushima Tsunami. Another plate boundary of this type is found off Indonesia and this caused the Boxing day Tsunami of 2006. This Tsunami travelled clear across the Indian ocean and devastated Sri Lanka. So Tsunamis can travel hundreds of kilometers with only negligible reduction in power. Offshore of Sri Lanka the Tsunami averaged 3 meters in height, but it varied from 2 meters to 10 meters when it hit the coastline.
Unfortunately another tectonic boundary of this type can be found across the ocean from Koeberg at the South Sandwich islands. The alignment of these tectonic plates is such that the biggest waves are likely to head directly towards the West coast of Africa across a clear open stretch of ocean with no land or islands in the way. And the South Atlantic is one of the very few oceans which does not have a Tsunami warning system.
Most of us are familiar with the concept of a 100-year flood line that gets determined for major rivers, and below this line one cannot get planning permission to build a house. In a similar manner ESKOM has calculated a 100-year Tsunami line corresponding to Tsunamis originating from the South Sandwich islands. Only one hundred years is clearly not conservative enough for a nuclear power station. But its even worse that that. They assume that the wave height will be uniform, which experience shows it won’t be. And because the South Sandwich area is remote and largely uninhabited there is very little historical data, so the calculation is based on a data that goes back only 32 years. It is so unreliable that statistically it is no better than a guess. ESKOM commissioned a report by Dr D.L. Roberts titled “Potential sources of Tsunami along the South African coast.” (It is marked as confidential but it is available from the Eskom website.) The report concludes that the magnitude of the threat posed by earthquakes in the South Sandwich area is simply unpredictable.
It is entirely possible that a Tsunami could arrive any time without warning and flood Koeberg. This is a very real threat that Koeberg faces, and yet there is nothing in the Koeberg Nuclear Emergency Plan that says what to do if, for example, the access roads are flooded. A lesson from Japan is that the nuclear emergency may very well occur within a context of a wider emergency, and this does not seem to be taken into account anywhere in the Koeberg emergency planning.
The second lesson that we should learn from Fukushima is about operator complacency. There have been three major nuclear meltdown accidents around the world, out of about 400 reactors globally. The historical experience of actual nuclear disasters proves that the possibility of a nuclear accident is nowhere near as improbable as what the Nuclear industry would like us to believe. Nuclear accidents can and do happen. And it is not only the reactors that are dangerous. At Fukushima some of the massive radiation leaks were from a spent fuel cooling pool. The spent fuel pools at Koeberg are currently filled way beyond their initial design capacity. Yet Eskom repeatedly tells the public Koeberg is safe, and nothing will go wrong here. That same attitude existed in Japan.
The third major lesson from Fukushima is that impractical emergency plans cause more harm than good. TEPCO were criticised for being completely hapless. They were unable to do anything practical to help the affected population as they were too busy holding meetings and press conferences and giving lots of contradicting and often unintelligible information, most of which was aimed at downplaying the reality of the situation. Their formal plans were completely useless in a real emergency.
The same thing would happen here. ESKOM appears to have the attitude that Emergency Response Planning is an exercise in producing long documents for the purpose of meeting bureaucratic legal requirements. Their emergency plan is a document of mind-numbingly tedious legalese. Its full of references to Laws and Acts and Regulations and obscure Job Titles. Important sounding but essentially meaningless tasks are allocated to a number of government and Eskom agencies and sub-committees.
For example activities numbered 8.4 and 8.5 whereby the DISASTER CO-ORDINATION TEAM must “obtain briefings on recommended protective actions as appropriate” from the SHIFT MANAGER AND/OR KOEBERG EMERGENCY CONTROLLER and then “implement protective actions as appropriate”.
This simply means that a manager will tell the team what to do – they must perform “protective actions”. But just what these protective actions might be is not specified. It calls into question whether this document is a plan at all.
Perhaps the best lesson that South Africa can learn from Japan is that the ‘once in a million years’ claim by the nuclear industry is obviously false, and Koeberg should be shut down before it melts down.