Below is the formal submission made to the GIBB Consultants who are running the Environmental Impact Assessment on behalf of Eskom.
Its a long read, so those with limited time can use the contents to find areas of specific interest.
While its hard to choose, there are three items of particular concern.
The first is the practically non-existent assessment of the risk of earthquake damage (see point 1), and the potential impact this could have. The study used outdated methodology when it was done, which was before the 2011 Fukushima disaster. Given the proximity of the Milnerton fault line to Koeberg, this should have been a priority.
The second is the misleading representation of electricity demand (point 3), which paints a picture of phenomenal growth in both the economy and electricity demand using a study done in 2009. It is common knowledge that actual growth, demand and current predictions are way below these figures, which are pertinent facts GIBB conveniently omits.
The third is the scathing peer reviews (point 13) of some of the studies. In these reviews, independent academics review the scientific quality of the specialist studies. Despite these academic writing comments such as “The report as is, is outdated and it would be a risk to the project to put it as is in the public domain.”, the lead consultant, Ms Nortje, described all the specialist studies as ‘adequate’.
Comments on the Second Draft EIR for Nuclear-1
Submitted 10 December 2015 without prejudice
Table of contents
1 Seismic Hazard Study
2 Agricultural specialist report not available
3 Biased representation of predicted peak electricity demand
4 Scoring and weighting system
5 Emergency planning zones
6 Use of the term “practically eliminate”
7 Beyond Design Basis Accident specialist report
8 Public participation period and process
9 Tritium releases and borehole water
10 Deferred issues
11 Alternative sites
12 Alternative power generation technologies
13 Peer reviews in general
14 Economic impact of emergency preparedness
15 Intergenerational ethics
This document has been prepared by the Koeberg Action Alliance (KAA) in response to the invitation for public participation and comment on the Environmental Impact Assessment for Eskom’s proposed Nuclear-1 project.
KAA is a civil society grouping of South African citizens with reservations about the use of Nuclear Energy in South Africa. We are particularly concerned with the actual and potential risks;
to the health of citizens,
to the environment,
related to nuclear waste,
to the economy, and
to future generations
Since a nuclear build will have very large economic implications for the country, and many future generations would be irrevocably committed as custodians of the radioactive spent fuel, we feel that this EIA for the Nuclear-1 project must be meticulous, and as accurate and complete as possible. We have therefore brought together a team of experts in various fields over the course of this EIA to volunteer their time to analyse some aspects of the draft reports.
KAA submitted detailed comments on the previous draft versions of this report, and many of the issues raised remain unresolved. This submission should therefore be read in addition to our previous two submissions.
Below is a list of some flaws in the current draft, as well as remedies which are required before the EIR is submitted to the DEA. Should GIBB decide any of these remedies are not necessary to implement, we request detailed explanation(s).
1 Seismic hazard study
For the first draft of the Nuclear-1 EIR, GIBB produced a seismic hazard study that was of a very poor standard, as described in detail in our previous submissions. In response to criticisms of this specialist study, GIBB representatives agreed that it used outdated methodology, and needed to be re-done.
GIBB wrote “a new PSHA will be undertaken for all three sites, following a SSHAC Level 3 process. Such a PSHA was to start in 2009 and preparations for this work were already made in 2008, but unfortunately it had to be postponed due to financial constraints.”
We note these dates pre-date the Fukushima accident, which has highlighted the risks posed to nuclear power plants by seismic events. We also note the poor track record GIBB has in terms of fulfilling assurances given during this EIA to the public re future work that would be done.
A peer review draws attention to the fact that the report was completed in 2010 and states “Since then, significant developments have occurred which
would have impacted on the report. For example, the Fukushima earthquake and resulting
tsunami would have drawn the authors’ attention to a local risk associated with the proposed
Nuclear Power Station sites.” and further that “…we draw
attention to areas where further investigations are suggested in the light of more recent
developments.” [Combined Peer Review Report].
At the Kenilworth public meeting, Peter Becker asked for information on the progress this new PSHA study group had made, and the lead EAP, Ms Nortje, undertook to supply it. No such information has been received to date.
Ms Nortje stated, according to the GIBB minutes of the same meeting, that all specialist studies “have been peer reviewed and found to be adequate.” This appears to contradict previous statements from GIBB that said this study used outdated methodology and needed to be redone. It would seem that if a report was ‘adequate’, GIBB (or the scientists they contract) would not state that it needs to be re-done. This casts doubt on the judgement of Ms Nortje, which is exacerbated by the point re peer reviews below, and hence we ask that this apparent discrepancy be explained, as requested in the remedies below.
We question the procedural correctness of passing the responsibility onto Eskom, as GIBB did in a previous response: “The requirement Eskom puts upon itself to undertake a new PSHA, following an approach corresponding to the latest international best practice, should therefore be seen as a proactive step in ensuring conformance with this best practice.”
No details were provided as to whether or not Eskom has committed to this in writing or not.
Please supply a written guarantee that a new PSHA will be subject to the same requirements for a public participation process as this EIR, i.e. with independent consultants and facilitator., with a reasonable period for the public to make submissions.
Should GIBB fail to do this, this transferring of responsibility to Eskom (their client) could be interpreted as an attempt to bypass the rigorous public participation process required for EIAs, raising a suspicion of bias on the part of GIBB.
We also note articles in the mainstream press which quote the Department of Energy as saying that Eskom will NOT be the owner/operator of the new plant(s).
Please explain how reassurances from Eskom would have any weight if they are not the eventual owner/operator? Please note that we understand that a positive RoD is transferable, but we are asking here about the details of how or if commitments made by Eskom would be transferred with the RoD in a binding manner.
Remedy 1.1: Ms Nortje must explain why she described as ‘adequate’ a specialist study which others have stated is outdated and should be redone.
Remedy 1.2: A seismic study report must be completed, using up to date methodology and taking into account the Milnerton fault line, and submitted with this EIR to the DEA.
Remedy 1.3: Clarification must be given re Eskom giving a commitment to take on the responsibility of re-doing the work of this specialist study, and documents showing this agreement must be provided. This must include what would occur if Eskom is not the owner/operator of the plant. Clarification must also be given as to why this study is not considered pertinent information which must be placed before the decision maker (DEA) as part of the EIR.
Remedy 1.4: The information re the progress of the seismic study group must be supplied as promised by the EAP (Ms Nortje), and a reasonable time allowed for a response to this information.
Remedy 1.5: Clarity must be provided with the main report as to what value Eskom’s self imposed requirements would hold if Eskom is not the owner/operator, and whether this would invalidate this EIR,
2 Agricultural specialist report not available
This report was unreadable on the CD that was distributed, and at the time of writing was also corrupt on the GIBB website.
During our study of this draft, we noticed for example the following from the the Emergency Response report (app E26): “protective measures such
as the following:
An immediate ban on the consumption of locally grown food in an area affected
by the accident; [ a 40km radius]”
We would have liked to check on whether or not the agricultural report satisfactorily assessed the impact of such a ban on local and export markets, but were not able to do so.
Remedy 2: This report must be distributed to I&APs, and a reasonable comment period allowed.
3 Biased representation of predicted peak electricity demand
On the first page of the executive summary, page 2 of the main report, a prominent graph is provided showing the predicted electricity requirements in South Africa.
The graph is central to the needs and desirability of the project, and hence is a major factor in considering the no-go option.
By the time this EIR is handed to the decision maker, the data on which the graph is based will be seven years old. For a report which has cost over R40 million to compile, this is completely unacceptable. We draw your attention to the principle that it is not acceptable to use outdated data if more recent data is available.
In addition, this graph provides a highly skewed picture for the decision maker, in terms of need and desirability. It gives the impression that GIBB is either incompetent, or is knowingly attempting to conceal information which may not support their clients goal.
The Department of Energy itself has written on releasing the updated IRP draft (our emphasis added): “Since the promulgation of the Integrated Resource Plan (IRP) 2010-30 there have been a number of developments in the energy sector in South and Southern Africa. In addition the electricity demand outlook has changed markedly from that expected in 2010.”
The same report states “Actual national electricity demand has been lower over the past three years than expected in the
IRP 2010, especially when compared to the System Operator Moderate forecast which was
used as the base forecast for the final policy-adjusted IRP.” and “…the
underlying trend indicates a lower growth in electricity demand relative to the previous
Within the updated IRP, the conclusions strongly recommend: “The revised demand projections suggest that
no new nuclear base-load capacity is required until after 2025 and that there are alternative
options, such as regional hydro, that can fulfil the requirement and allow further exploration
of the shale gas potential before prematurely committing to a technology that may be
redundant if the electricity demand expectations do not materialise.”
Whether or not this updated IRP has been promulgated at the time the EIR is submitted, it is clear that the DOE has modified the predictions it made in the IRP2010.
It is obvious that more recent data than that which was referred to above is pertinent to the decision maker. We remind you of your obligations to put all pertinent information before the decision maker, and the legal consequences, including possible prosecution for contravening regulation 81 of the 2006 EIA Regulations under NEMA, a criminal offence which can result in jail sentences for the EAPs as well as the directors of the company they work for.
Remedy 3.1: This outdated and misleading graph must be removed from the report.
Remedy 3.2: The known data w.r.t. winter peak electricity demand for the years 2010 to 2015 must be shown.
Remedy 3.3: The recent economic growth forecasts from the finance minister and/or the DoE must be used to produce a fact based realistic forecast of electricity demand.
4 Scoring and weighting system
In summarising the findings of the various specialist reports, GIBB composed a scoring system.
In a previous submission we criticised the long-term and medium-term classifications
We also support the previous submission by Dr Anthony Reed of UCT, in which he criticised the scientific validity of the scoring system in terms of objectivity and calibration.
We also note that the scoring system was created concurrently with producing the report, which is scientifically questionable and allows the perception that the weighting may have been tweaked by GIBB in order to arrive at a conclusion favourable to their client (the applicant).
Here is a hypothetical scenario to highlight the bias inherent in this scoring system:
GIBB finds that there is a 55% chance of a catastrophic nuclear explosion within the first year of operation, which would render large areas of Cape Town uninhabitable for hundreds of years.
Scoring result: According to the first table on page 26 of the Main Report, this would be classified as ‘likely’. In terms of a residual risk, such an event would obviously be classified as ‘High’. According to the second and third tables, this combination of high residual risk, and ‘likely’ would result in a final recommendation to the decision maker that “Project can go ahead but with strict conditions…”.
This borders on the insane. The outcome and recommendations of this entire report cannot be reasonable if the above scenario does not constitute a fatal flaw.
We understand the motivation to simplify the scoring system to a point where it is digestible. However, this has been taken too far, and the resulting system is not only simplified, it is dumbed-down to a point of being over simplistic and of insufficient granularity.
Remedy 4: A scientifically valid scoring system should be constructed using international best practices, and all the scoring redone, specifically in the Main Report.
5 Emergency planning zones
We note that all the specialists used by GIBB were briefed with respect to the emergency planning zones, and that these would follow the EUR suggested zone sizes. We also note that the EUR is an association of nuclear industry companies, and that the document containing these suggestions was “developed by a group of the major European Gencos (electricity generation companies)” according to the EUR website. [http://www.europeanutilityrequirements.org/Welcome.aspx] This makes it likely that their suggestions favour an optimistic aspirational view of future regulations,
We note further that the EUR started the process of defining these suggestions in 1992, and these zone sizes were first put forward prior to Fukushima. Since Fukushima, the safety issues around nuclear plants have been revisited by all players. We submit that only documents relating to safety which were produced after 2011 are relevant.
We note that some of the EUR documents are not accessible to the public. To allow meaningful participation, all referenced documents must be made available in full to I&APs.
Currently, the evacuation zone for Koeberg is a 16km radius. The EUR suggested that 800m would be sufficient for any new nuclear plants. We note that in Fukushima it was found that a mandatory evacuation zone of 20km was required, and enforced by the authorities.
We question the validity of the assumption that the NNR will accept this industry suggestion of an 800m evacuation zone, and ask that GIBB promptly supply us with a list of countries in which the nuclear regulator has accepted this EUR suggestion.
In the document “Public Meetings Combined”, in response to a question it is stated: “Finally, it is the NNR
who decides if 800 m would be acceptable to comply with
international standards or would they want a larger area.”
It also quotes Ms Ball (lead EAP at the time) as saying “in terms of the
exclusion zones, the NNR would have to make a decision on the exclusion zone for
the new nuclear power station.”
On page 3-48 of the Combined Main Report, it states “It is likely that the corresponding EPZs for the new nuclear power station will be reduced to
800m and 3 km respectively.” and “Eskom
has chosen the EUR as this specification is sound and robust,” Please provide a scientific justification for labelling the EUR suggestions as ‘sound and robust’. Please also explain why you have presented this as if it is Eskom’s decisions to select what the zones will be.
On page 36 of appendix D5 the lead EAP (at the time) is quoted as saying “The current international
requirement specifies that this is the only zone where
development is not allowed and an area out to 3 km where
evacuation may be necessary will also have restrictions.” This gives the false impression that these zones are accepted internationally by regulators.
In a post meeting note by GIBB on page 37 it states “the EIA studies
have been based on the European Utility (EU)
requirements, which are assumed will be the relevant
These new zones are sometimes referred to as ‘likely’, sometimes as ‘assumed’ and sometimes falsely presented as an existing fact. In addition, the specialists were given the explicit brief to make the assumption when doing their studies that the zones would be 800m and 3km. A study of the potential impact on agriculture, as one example, would obviously be hugely affected if the evacuation zone is 800m (2 square km), or for example 4km (50 square kilometres) or the current 16km (804 square kilometres). The latter case would involve over 400 times more area that what has been assumed.
Elsewhere in this submission we note were were not provided with access to the agricultural specialist report for this round. We note however that in the previous draft, the agricultural study (appendix 21 page 12) states “There is no agricultural production within the 800m ”Protective Action Zone” (PAZ).” This makes it clear that this report was created based on the assumption of an 800m zone.
In the Radiological Impact Assessment, it says “The radiological consequences of severe accidents that involve core melt are assessed against
the specific objectives for emergency planning of GEN III NPPs. These are as follows: minimal emergency protection action beyond 800 m…”
It seems that GIBB may have pre-empted the NNR in this matter. It is the NNR who is the competent authority to make this determination, and they can only do so once the design of the plant is finalised and presented to them.
We ask that GIBB confirm that the specialists were instructed to assume 800m and 3km zones, and provide a written copy of that instruction.
Remedy 5.1: The full EUR document used as a basis for the 800m and 3km zones must be made available to I&APs.
Remedy 5.2: All references to any EUR document not in the public domain must be removed from the report and all specialist studies.
Remedy 5.3: A list of the countries which have adopted the emergency zone sizes suggested by the EUR must be provided, and included in the EIR.
Remedy 5.4: A scientific justification for describing the EUR suggestions as ‘sound and robust’ must be provided, or this phrase must be removed from the main report before it is submitted to the DEA.
Remedy 5.5: A written commitment must be obtained from the NNR that the emergency zones for the envisaged nuclear plants will follow the EUR suggestions, based on the ‘envelope’ approach used by GIBB.
Remedy 5.6: It must be stated explicitly in the Executive Summary that this EIR is based on the assumption that the NNR will adopt the EUR suggestions, and will be invalid, and have to be redone, should this not be the case.
Remedy 5.7: The specialists must be re-briefed, and instructed to ignore the EUR suggestions, and to modify their impact assessment studies accordingly before the EIR is submitted to the DEA.
6 Use of the term “practically eliminate”
In the draft as published, many times when the potential impact of a nuclear accident is raised, it is followed by a statement that the design of the nuclear reactor will ‘practically eliminate’ the chance of an accident occurring.
We have found the phrase 23 times across the various specialist studies and summary document, and have been informed by GIBB that this phrase originated in the IAEA document titled “Specific Safety Requirements
We note that in the BDBA study, this phrase is used eight times, yet the above document is not mentioned in the references. Providing references for source material is a basic requirement of a scientific document.
The BDBA study also contains on page 43 the following phrase, without any attributation: “… the possibility of certain NNP accident conditions occurring is
considered to have been practically eliminated if it is physically impossible for the conditions to
occur or if the conditions can be considered with a high degree of confidence to be extremely
unlikely to arise.” SSR-2/1 contains in a footnote on page 6 the sentence “The possibility of certain conditions occurring is considered to have been practically
eliminated if it is physically impossible for the conditions to occur or if the conditions can be
considered with a high level of confidence to be extremely unlikely to arise.” This appears to be plagiarism on the part of the author, J Slabbert. We note that when a scientist is found to have committed plagiarism, they no longer have standing in the scientific community, and can result in expulsion from an academic institution.
We also note that neither the CV of J Slabbert nor a peer review of his report was included in the draft EIR, as was required. This means we have not been able to evaluate and comment on his suitability as a specialist.
We note further that the IAEA document is a suggested standard, and neither South African or Rosatom (the current apparent frontrunner vendor) are legally bound by it.
Remedy 6.1: All documents of the EIR which use this phrase must provide a reference.
Remedy 6.2: Clarity must be provided as to what extent the NNR, Eskom, and a foreign vendor are bound by SSR‑2/1.
7 Beyond Design Basis Accident specialist report
We note the single author of this report does not have a relevant (or any) PhD, has a masters level qualification in the only tangentially related field of management of radioactive waste, and an undergraduate degree in theoretical physics. This seems woefully inadequate for being the sole author of this crucial report, which involves complex engineering issues, and in particular systems engineering, in which fields the author appears to be entirely unqualified.
We also note that no peer review was provided for this report, and we suspect that a peer review would have highlighted these and other shortcomings in this report.
Despite not being qualified in this field ourselves, we have noticed what appears to be indications of poor scientific quality. Had we been given access to a peer review, we would have been able to confirm this, and comment more meaningfully.
As noted elsewhere in this submission, there is what appears to be plagiarism within this report.
A table of frequencies is provided on page 4 (table E-1) without a reference
No site specific analysis of alternatives appears to have been done, e.g. the word Thyspunt appears only twice – once in the introduction, and once in the glossary.
Remedy 7.1: This report must be discarded entirely, and a suitably qualified and reputable team of scientists and/or engineers must be found to produce a report of good scientific quality with references and without unattributed quotations (plagiarism).
Remedy 7.2: A peer review by suitably qualified scientists must be produced, and distributed to the public with a reasonable period for submissions and comment.
8 Public participation period and process
During previous drafts of this report and the public participation period, there has been a consistent pattern of initially allowing a public participation period which is unreasonably short given the complexity and length of the document. Subsequently GIBB announced a longer period would be allowed. We note that for a previous draft, 116 days were allowed for public comment, whereas a 60 day comment period was initially announced for this draft.
This draft contains a few million words, and in order to read it after its release and before the public meetings in Cape Town (19 days) a person would have been required to read over 100 000 words a day. This is not reasonable.
In addition there were other factors that hampered the reading process:
– Some documents were missing (e.g. the Agricultural report, the peer review of the seismic hazard report, the CV of J Slabbert); Inconsistent file naming conventions made it difficult to see which documents had been reviewed and which reviews had elicited responses from the specialists; Some documents were not in the combined PDFs (such as the combined peer reviews).
An email requesting clarity on documents which appeared to be missing was sent to Elisabeth Nortje <firstname.lastname@example.org>, Sean O’Beirne <email@example.com>, and Tashriq Naicker <firstname.lastname@example.org> on 8 December 2015. No reply has been received as at the time of writing.
Immediately on being notified of the planned participation period for the latest draft, we wrote to GIBB (email@example.com) as follows:
I wish to object in the strongest possible terms to the comment period being limited to 60 days.
In the past, the period has been extended to 90 days, as it is obviously unreasonable to expect the public to be able to go through this voluminous report in 60 days.
By announcing 60 days, and then allowing appeals to eventually change your mind to 90 days, you could be seen as playing a game, and abusing the process.
This wastes our time as we first schedule for 60 days, and then have to replan when more time is made available.
Please don’t do that this time around! We appeal to you to announce the period as 90 days immediately.
No response was received.
This request was repeated in person to Ms Nortje on 12 October 2015 (also on record from the Kenilworth meeting of 13 November), and the verbal response was that an extension would not be granted.
Further, in response to a request for a longer participation period from another organisation, Ms Nortje of GIBB wrote: “Thank you for your correspondence – I hereby confirm receipt. Your request has been noted and considered. The review period will however not be extended and will run until 25 November 2015 as has previously been communicated.“
We note that this was a categorical statement that no extension would be allowed.
Later, GIBB wrote on 20 November:
“Dear Interested and Affected Party
Please note that the comment period for the Revised Draft EIR (Version 2) has been extended until Thursday, 10 December 2015.
The Nuclear-1 Public Participation Office”
These contradictory responses have the effect of upsetting the planning of analysing of the draft report by members of the public and organisations, and hence providing meaningful submissions.
This is due to the fact that it takes time to assemble a team of suitably qualified volunteers, and then draw up a schedule to analyse the various specialist reports, taking into account the limited time available to the volunteers, due to their jobs etc. The short period allowed necessitates omitting the analysis of some aspects of the EIR from the plan.
It would not have been difficult for GIBB to give advance notice of the upcoming release of this draft. This would have allowed the planning and team assembly process to start in advance.
In practical terms the outcome was that we planned for a certain period and put that process in motion. A few days before expiration date we were offered another 10 days. This was in effect almost meaningless, since at that late stage it was not practical to revisit the planning to do a more in-depth analysis.
This has the effect of enabling GIBB to claim that a period of 77 days was allowed, whereas in truth this is not the case.
In addition, no public meeting was scheduled for Port Elizabeth until several complaints were sent to GIBB. A last minute public meeting was then arranged for 8 December -two days before the closing of the submission period. Once again, it is patently unreasonable to allow such a short time for members of the public to make meaningful submissions.
Further, the extensions that were granted were not published in the print media to the same extent as the initial announcement. Those who saw the initial printed announcement continued to believe that the comment period deadline was 23 November 2015, once again rendering the extensions meaningless for those who did not receive the emails. This has been further exacerbated by GIBB failing to update their website, and as at 6 December 2015, the web page http://projects.gibb.co.za/en-us/projects/eskomnuclear1reviseddrafteirversion2 states prominently in bold print “The report has thus been updated and the Revised Draft EIR (Version 2) will be available from Monday, 21 September 2015 to Monday, 23 November 2015 for a period of 60 days for public review and comment.” This is misinforming the public, and with the considerable fee charged by GIBB to date (over R40 million), this shoddy attention to accurate communication with the public is unacceptable.
We also note that in the minutes of the Melkbosstrand meeting (and perhaps elsewhere), it is noted that “I&APs will have 21 days to verify the minutes and provide their comments to the GIBB Public Participation Office.” GIBB took about 7 weeks to prepare and release the minutes from the Cape Town meeting, which were made available on or around 1 December 2015. This makes the deadline close to Christmas day! This is a ludicrous requirement. Regarding the 8th December 2015 in Port Elizabeth and assuming an immediate release of the minutes, the 21 day period for this would run until New years Eve! This is equally ludicrous. It is not reasonable to include the Christmas period and new year holidays in the time allowed for public input.
The above is unclear and confusing communication from GIBB, as this seems to specify yet another set of dates for the closing period for input from the public.
We also note that 8 meetings were arranged in the vicinity of Thyspunt including Port Elizabeth, but only two near the Duynefontein site. Given that the population of Cape Town is over 4 times the size of Port Elizabeth, this does not make sense. While GIBB has expressed a preference for Thyspunt, Duynefontein has several advantages, including the existence of transmission lines and emergency planning zones already in place. The DEA has also questioned the preference for Thyspunt (the DEA has written “With regards to transmission integration, the Department believes that the Duynefontein [Koeberg] site would be easier to integrate into the grid than Thyspunt”), which means Duynefontein is still a very real possibility. The ratio of populations suggest that it would have been appropriate to arrange up to 32 meetings in the Cape Town area. Just 2 meetings was inadequate.
Another issue is that during previous rounds, Key Stakeholder meetings were held, as well as Focus Group meetings, as detailed in Appendix D4 and D5. These meetings provided opportunity for well informed groups to interact in-depth with the consultants, as opposed to the public meetings, which tend to get emotional and go over time, and eventually have to be terminated with unanswered questions remaining. No such meetings were held this time.
We note that every public meeting went over time, with some people therefore leaving while the meeting was ongoing, and with remaining unanswered questions from the public.
Remedy 8.1: A reasonable period must be allowed for public submissions, and this period must be restarted with a fixed closing date which is not shifted. Notice of this period should be given in advance of the actual commencement of the period, in order to allow planning on the part of the public and organisations.
Remedy 8.2: The minutes of the public meetings of 2015 must be made available, together with the responses from GIBB to each issue, before the announcement of the new period, to allow these issues and responses to be meaningfully included in the submissions.
Remedy 8.3: Copies of print media notices of the various extensions must be provided.
Remedy 8.4: Key stakeholders meetings must be held.
9 Tritium releases and borehole water
The Radiological Impact Assessment specialist report refers. This report includes data from seawater, surface water, and municipal tap water. However, it fails to present any data on tritium levels found in groundwater collected from boreholes. This is despite the fact that such data is readily accessible, as in the report by SRK Consulting of 2010, titled ‘The Provision of Groundwater Monitoring Boreholes’, document reference 378412/26F. (This report is already in the possession of GIBB, as they provided us with a copy during the participation process of a previous draft.)
Should the nuclear capacity at Koeberg be increased from 1 800MW to a total of 11 400MW, as a potential outcome envisaged by this report. it is likely that the tritium releases would correspondingly increase significantly.
We would like to emphasise that the release of tritiated condensate is part of the normal operation of Koeberg, and therefore most likely also part of the normal operation of a new nuclear plant. Therefore the specialist studies which this could impact, in particular the agricultural and geohydrology studies, should have looked at this in detail.
Modelling must be done taking into account the subsurface water pathways combined with the current and expected releases of tritium from a new plant of the maximum size envisaged at Koeberg, and combined with the half life of any expected radioactive discharge, to assess the potential impact of this.
Given that, according to our minister of Water Affairs, South Africa is a water scarce country, it is possible that we will rely more heavily in the future on groundwater for drinking water. This means that the possible contamination of groundwater and the spread of such radioactive water is highly relevant, and should be explored further, with particular attention to the possible pathways and bioaccumulation effects in farm animals, wildlife and humans.
The agricultural sector depends heavily on borehole water. The effect of this likely increase in tritium on livestock could have serious impacts, including on the export market.
Remedy 9.1: The Radiological Impact Assessment study must be reviewed, and data from groundwater samples form boreholes around Koeberg must be included in the various tables presented.
Remedy 9.2: A study of the groundwater pathways at each potential site must be done, and conclusions should be presented on the possible impact of routine releases of tritium on groundwater.
Remedy 9.3: The Agricultural Impact specialist study (which we note elsewhere was not made available) must incorporate a study of the possible impact of tritium in groundwater, in particular on the dairy industry in the vicinity of the proposed sites.
10 Deferred issues
At the public meetings, GIBB repeatedly assured the public that the NNR process will follow the same public participation process as the EIA. We are concerned that this amounts to misleading of the public by GIBB.
In the Main Report, it states “In this context, it must be mentioned that the approaches of the EIA process and the NNR licensing
process differ substantially.”
We note with concern an article which extensively quotes Tony Stott, at the time employed by Eskom.
It states that the NNR process “will be long after the contracting is complete”. This seems to indicate that the NNR process will be different from the EIA process.
Please urgently supply clarity re these apparent contradictions, i.e. how the NNR process will be the same as the EIA process, given that it would take place after contracting.
Please also supply clarity as to what authority, if any, GIBB has to commit the NNR to a certain process.
During the public participation process for all three drafts, deep dissatisfaction was expressed by many parties as to how certain issues are deferred to a process to be run by the NNR.
The reassurance is given, for example, that since the NNR sets regulations as to the maximum permitted emissions, the EIA consultants have a reduced obligation to assess the impact should these regulated limits be exceeded.
The recent Volkswagen scandal refers. Designers introduced software and hardware into vehicles that manipulated test results, in effect making engine performance differ in test facilities. This allowed them to knowingly exceed emission regulations andis a clear example of why such an approach in invalid.
It seems to us that the NNR is neither competent nor required to perform an environmental impact assessment of their regulated limits being exceeded. The NNR merely dictates the limits that are legal for a plant.
Remedy 10: The repeated verbal assurance given to the public that the NNR process will be ‘the same’ as this EIA needs to be clarified and verified in writing.
11 Alternative sites
As a basis for the possible sites for a nuclear power station, GIBB has relied on a 33 year old NSIP study from 1982. Although GIBB have claimed to have reviewed this study, a specialist report on this subject has not been made available to us.
We submit that it is senseless to base such an important decision on 33 year old data which was analysed under very different political and socio-economic conditions to those that exist today.
We note that the DEA agreed with this and wrote in 6 May 2008 that “Furthermore, this Directorate does not support the exclusion of the Brazil and Schulpfontein sites deom the EIA phase of the project ….”. They wrote further on June 2009 “… it may not be reasonable to exclude these two sites from the current EIA process. Furthermore, much needed specialist studies at these two sites may provide information to suggest that these sites are more appropriate…”
Both both Chernobyl and Fukushima have occurred since the NSIP was done, and the above was written by the DEA before Fukushima. It is therefore obvious that the NSIP did not take into account the lessons which could be learnt from these two nuclear disasters. In particular, the dense population of Cape Town,and the future development plans of the City of Cape Town, as well as private developments such as Wescape, make Koeberg an unsuitable site for a new nuclear power station.
The Koeberg emergency plan, which requires the (so far uninformed) MyCiti bus drivers to drive towards Koeberg in the case of a radiation leak to evacuate residents (in contravention of labour law regarding hazardous work environments), highlights the impracticability of a workable evacuation plan in such a densely populated area.
We have also not seen any analysis of how new developments within the emergency zones at Koeberg, such as Wescape with hundreds of thousands of new residents in the area, would impact on the evacuation plans. This might have played a role in the weighting, which is appropriate to more remote sites in less populated areas.
We have also learnt from Japan that areas 20km from a damaged plant can be uninhabitable for hundreds of years. Neither Eskom nor the state have the resources to create new housing for the number of Cape Town residents who would be displaced should such an event happen at Koeberg.Also, no insurance company will insure residents or business owners for losses that would result.
The reasons given by GIBB circa 2010 for not revisiting the NSIP were that it would introduce a delay of up to five years before the EIR could be released, which was unacceptable given the urgency of the project. It is ironic that since then, 5 years have passed, and the EIR has still not been finalised.
Three things are clear: the project was not as urgent as GIBB porttrayed, that the NSIP should have been revisited, and that a five year delay would not in fact have been a delay.
We also note that both the NDP and IRP 2010 update recommend that the nuclear decision is delayed. It would therefore seem to be unproblematic to introduce such a delay, as it would be in line with the NDP and the latest statements from the DoE.
GIBB have repeatedly put great store in the NSIP, yet in the Combined Main Report, section 5.2.4, GIBB states that the NSIP criteria included the following: “A 50 km radius from metropolitan areas was excluded from
consideration”. Since Duynefontein is significantly closer to the centre of Cape Town than 50km, it appears to be inconsistent that this criteria is not applied now, to exclude Duynefontein as a feasible site. This is especially so since disasters such as Fukushima should have underscored the importance of this precautionary approach. Furthermore, a 50 km radius from metropolitan areas is cited as one reason that Coega was excluded as an option. This contradiction further adds to our belief that Gibb is either incompetent or biased.
Should GIBB only consider as alternative sites areas where the applicant has already purchased land, this could be seen as lack of objectivity, and bias in favour of the commercial interests of their client, the applicant.
Remedy 11: The NSIP must be revisited, and other sites must be considered, particularly those further from densely populated areas, and a detailed report on this process must be made available for public comment before submitting to the DoE.
12 Alternative power generation technologies
The DEA wrote in 2008 in response to the Draft Scoping Report “Power generation alternatives … should form part of the EIA.”
Grid technologies which allow the integration of variable sources of power have developed rapidly in recent years. GIBB have simply stated in the Main Report that there is no viable alternative to nuclear, without providing scientifically credible references.
Remedy 12: GIBB must produce a specialist study dealing with alternative power generation technologies and taking into account actual peak demand and current growth projections, authored by a competent international expert in the field of recent grid technologies and integrating renewable energy and older technologies such as coal within the South African context.
13 Peer reviews in general
We came across several issues when looking at the peer reviews.
Given the tight time frame and the inconsistent file naming, we may have missed some reviews, but according to what we have seen the following specialist reports were not peer reviewed, as required by the DEA: Air Quality Assessment, Faunal Assessment, Marine Ecology Assessment, Economic Assessment, Agricultural Impact Assessment, Noise Assessment, Human Health Risk Assessment, Transportation Assessment, Emergency Response Report, Site Control Report, Eskom Grid Planning Report, Seismic Hazard Report [this was supplied via email by GIBB on 8 December 2015] and the BDBA report.
The reviews form an integral part of our reading of the EIR, as a peer review gives an indication of an independent expert scientific opinion re the validly of the corresponding specialist study. This gives us an indication where to focus our attention in the time allowed. With so many missing reviews, this EIR draft is incomplete, which has negatively impacted our ability to make meaningful submissions.
At least one reviewer (of the Oceanographic Assessment) was not supplied with the full document submitted for review, which is noted in the opening paragraph of the review.
Here we quote some statements from the peer reviews which were supplied by GIBB:
“More recent data from the WR2005 database (these were the most recent hydrological data available in 2011) instead of
the far older WR1990 data should have been used.”
“Certainly more than one and at least three peak flow calculation methods should have been employed.”
“The use of one peak flows calculation method (SCS Method) is not scientifically prudent …”
“A comparison between SAWS, WR90 and local rain gauge (despite only 4 years’ data) should have been undertaken.”
“HEC-RAS flow velocities which were tabulated have not been used or commented on.”
“Storm Water Management measures have been recommended, however, no alternatives have been presented from which the best options could be selected.”
“The areas that need attention include the Methodology, Flood Reduction Measures and the Recommendation sections …”
“This is problematic. The report is outdated and should be updated with the 2011 census data…”
“… the statistical data and a number of the documents used are outdated, some by more than a decade”
“The report as is. is outdated and it would be a risk to the project to put it as is in the public domain.”
On page 11 of the social impact assessment review, points 1.2, 3.2 and 4.5 find the study to be inadequate “Additional information is necessary before the decision making process can proceed”
“After requesting Appendix B… I received a further three files … but not Appendix B.”
“It is recommended that the above, together with the recommendations made by the CGS (2011) should be pursued to substantiate the suitability of the proposed sites…”
“The Terms of Reference supplied for the Geological Assessment provided by Arcus GIBB are in our view inconsistent with the “General Terms of Reference” for the EIA.”
“Finally, the report does not adequately cover the possibility of a serious disaster in the form of flooding of the Nuclear Power Station by tsunamis…”
“The TOR requirement related to ‘…and resistance of soil-cement foundations to
chemical attack.’ Is not addressed in the report.”
“We agree that monitoring is important, but cannot verify that
it is adequate.”
“It is recommended that better model calibration criteria is used…”
“… a review of the status of the species of conservation concern identified during the assessments should be undertaken and the
necessary amendments to the reports made.”
“Areas that require improvement have been indicated above in the relevant sections.”
“The areas that need attention include the following: [a list of 11 points] …”
“In conclusion it is evident that the recommendations for the study areas are in some cases unclear and arbitrary”
“vi. Depth and stratification of the site (where shovel test permits have been given or natural exposures available), both in the text and through photographs of sections; The report does not comply.”
“The report has a distinct lack of visual media such as photographs of stone tools etc.“
“The possible impact of natural disasters causing damage to such a facility should not be underestimated and swept under the carpet based on the sole premise that South Africa will for-ever be spared form such phenomena.”
“New evidence of fault sources should be incorporated into the PSHA.”
“More detailed surveys need to be carried out in these areas, because this new information could alter the conclusions reached in the report regarding the choice of site.”
This makes it clear that several of the reviewers found the studies to be inadequate and/or in need of attention and further work. It also makes the absence of other peer reviews, as noted above, of even greater concern.
Next we note the statement by Ms Nortje, the lead EAP, as recorded in the Kenilworth meeting minutes: “the Department of Environmental
Affairs requested that all specialist studies be peer reviewed by
other experts, which has happened. All studies were found to
We conclude that, at best, Ms Nortje has read the peer reviews with rose-tinted glasses, and at worst, is misleading the public by implying the peer reviews have been positive, and ignoring the slew of corrective actions that the peer reviewers recommended.
In some cases, responses from the original authors to the peer review are included, e.g. the Peer Review Geohyrdology report. It is unclear which version of the specialist study has been reviewed, and whether the version distributed by GIBB incorporated the improvements recommended by the peer reviewers or not. In some cases these are in separate files, such as SRK Reply to GCS Nuclear 1 Fresh Water Supply_EIR Peer Review.pdf and the file naming is done poorly, such that these responses are not listed next to the reviews they are in response to. This means that to engage with a specialist study, the study itself must be read, then its peer review (if present, unlike the BDSA and Seismic risk reviews) which sometimes follow a different naming convention and is in another directory, and finally possibly the response to the review from the original authors, using yet another naming convention.
This confusion is exacerbated by the omission of the full date in some cases, e.g. the Geohyrology report (App E7) is dated ‘September 2015’ without a day of the month. In other cases, the dates are confusing, such as the proposal from GCS to perform the peer review of the Geological,
Geotechnical and Seismic Risk Reports is dated 30 September 2015, yet the actual peer reviews all pre-date this, and are dated 1, September, 3 September, and 23 September respectively. The latter is two days after this draft EIR was released, which is puzzling. It is also unclear if the ‘version 2’ proposal is meant to indicate that further review work has been requested by GIBB, since this proposal is labelled ‘version 2’ and is dated after the actual published peer reviews themselves.
Remedy 13.1: Ms Nortje must clarify what was meant by the statement that the peer reviews found all the specialist studies to be ‘adequate’.
Remedy 13.2: The corrective actions indicated by the peer reviewers must be implemented, and the updated specialist studies, together with all peer reviews, must be released for public comment, prior to submission to the DEA.
Remedy 13.3: For clarity, only the latest version of the specialist reports should be included in the files, and the peer review of that latest version.
Remedy 13.4: File names and directory names should be consistent: all document should have full dates including the day of the month; and peer reviews, and responses to them if any should clearly grouped and/or linked.
14 Economic impact of emergency preparedness
When a nuclear plant is built, it is a legal requirement for an emergency plan to be put in place. For Koeberg, this plan involves the emergency services of the City of Cape Town.
Wherever the plant is located, the local emergency services such as fire services would need to have specialised equipment on hand to deal with a leak of radioactive material within an acceptable period. It would obviously be impractical to plan for vehicles to drive from Cape Town to Thyspunt in the event of an emergency, for example.
This equipment may include Geiger counters, dosimeters, decontamination equipment, isolation tanks for water used in personal decontaminations, specialised vehicles, monitoring equipment etc. Local staff, including fire, ambulance and hospital staff would need initial training in using this new equipment, as well as ongoing training.
The cost of this will likely have to be borne by the local municipality.
Even in a well resourced country like Japan, after Fukushima it was realised that local emergency services were not sufficiently equipped. From the official report from the government appointed body called The Fukushima
Nuclear Accident Independent
Investigation Commission: “At the same time, the emergency radiation medical systems had been established in a
stopgap way…” and “There was one vehicle equipped with monitoring
equipment, but this was also out of action due to a lack of fuel.”
In South Africa, many municipalities are in financial difficulties and are struggling to deal with basic services such as water and sewerage. The cost of nuclear related equipment, personnel and training which they would be required to pay for may well be significant. Bearing these extra costs may impact on the ability of the municipality to deliver other services.
The Economic Report fails to even mention these costs, let alone how they could be funded.
Remedy 14: The cost of nuclear emergency prepared must be assessed, either in a new report or within appropriate
existing reports, and distributed to the public for comment.
15 Intergenerational ethics
This import body of academic work is not referenced anywhere within the EIR.
Remedy 15: An intergenerational impact assessment should be done, including for the no-go option.
The current draft of the EIR is incomplete, biased, and in the case of several specialist studies, inadequate. It is our view that the many corrective actions suggested by the peer reviews and input from I&APs should be implemented, and another draft released for public participation.
Contributors to this submission include:
Robert Isted M.Sc. Eng (Cape Town)
Peter Becker B.Sc (Cape Town), B.Sc. Hons (UNISA)
Andreas Spath M.Sc. (Cape Town), PhD Geology (Cape Town)