Before any major development, South African law requires a detailed Environmental Impact Assessment to be submitted to the Department of Environmental Affairs before the project may begin.  In 2009, Gibb consulting submitted a scoping report for such a study on behalf of Eskom, with a view to building a large nuclear power plant.

During the public participation process Koeberg Alert, as well as many other organisations, scientists and members of the public submitted extensive and detailed comments on the report, and in particular the poor quality of the specialist reports.  In response to this deluge of criticism, GIBB produced four versions of the report, and finally submitted its final version to the Department in February 2016.  Based on a wide range of factors, the report recommended that Thyspunt in the Eastern Cape was the best site for the plant.  Nearly two years later, Sabelo Malaza, the Chief Director, issued an authorisation which overrode the consultants recommendation, and specified Duynefontein (Koeberg), near Cape Town, was were the plant could be built.

The full text on the authorisation is here: Duynefontein authorisation full text

If you made any submission during any of the four public participation processes, it is crucial that you indicate that you wish to appeal against this finding. [Note: we have received a legal opinion which is clear that anyone who may be affected by this decision may appeal, even if you have not participated to date]

To do this, simply send an email to appeals@environment.gov.za and to Herbstdl@eskom.co.za in which you say you intend to appeal the authorisation for a nuclear power station at Duynefontein, reference number 12/12/20/994. The price of a participative democracy is participation – please find a few minutes to do this before the deadline of 21 October 2017. [Correction: 31st October 2017]

There are many flaws in the report, some clearly intended to bias the finding for Eskom, and others perhaps just due to sloppiness or scientific incompetence.  And example of the former is the ludicrously inflated projected demand for electricity, which is used to justify the need for a nuclear plant.  Despite being given far more up to date data, Gibb refused to incorporate this into their report.  This is dealt with in more detail, including graphs, in Eskom and GIBB living in la-la land.

An example of sloppy science is the thorny issue of seismic risk.  Since the earthquake near Japan caused the 2011 Fukushima nuclear disaster, there has been more concern worldwide about the risk of a seismic event causing a leak or reactor explosion.

In the first version of the seismic study, a specialist found that the Peak Ground Acceleration (PGA)_ for the Koeberg site was 0.30g.  Any scientific measure is accompanied by a confidence interval, for example 0.30g ±0.01g. The scientists who write this report, Erna Hattingh and Johann Neveling, were apparently unaware of this, and did not give any interval, despite the inherent uncertainty in their methodology.

It also noted that 0.30g was the threshold over which a site is considered unsuitable for a nuclear plant.  Finally, it added that the 0.30g for Koeberg was arrived at using an outdated methodology, and that this will “necessitate additional geological investigations and implementation of an advanced PSHA that will follow internationally accepted practice“, and that “may increase or decrease these values“.   So if a post-Fukushima study is done using up to date methodology, it may increase the risk value, and if it increases by just 0.01g, that would make Koeberg and unsuitable site, based on seismic risk alone.

After consultations with Gibb, this wording was omitted from the second draft report

Since the Koeberg site was chosen in the late 1970’s population patterns have changed significantly.  If for any reason it was necessary to evacuate the zones as per other nuclear disasters, the number of people needing to be evacuated would make the job simply impossible.

Radiation from Caesium makes a contaminated area uninhabitable for hundreds of years.  Where will the millions of displaced people live?  However small the risk of an earthquake damaging this nuclear plant, the consequences in term of economic damage and human suffering are too awful to contemplate.

While it will be difficult to draw up a comprehensive appeal in the 30 day period allowed, Koeberg Alert will be doing what it can.  If you can assist with this process, particularly if you have legal or scientific expertise, or if you would like assistance in formulating your own appeal, please contact us on info@koebergalert.org