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.”

I haven’t ever noticed tourist buses lining up outside Koeberg myself!

Photo of blacg bags containing radiative debris

Over 9 million bags have radioactive debris have been collected around Fukushima

Never mind how much it could cost…
In response to us pointing out the impact of a possible accident on the Economy of the Western Cape and South Africa has not been quantified or assessed, Eskom brushed that off: “Given the unlikeliness of a severe accident occurring, it is submitted that a detailed assessment of the economic impact on each sector was not required.” We believe the decision makers should know what it would cost the taxpayer and the economy if there was a major accident. Only then can a rational decision be made as to whether the risks, however small, are worth it. As a comparison, the Fukushima nuclear plant clean up is estimated as having a direct cost of between $75 billion and $660 billion in this Scientific American article. At the current exchange rate, that corresponds to between R1 trillion to R9 trillion. Loss of property and of export markets for agricultural goods would be additional to that. Note that losses due to a nuclear incident are explicitly excluded in all property insurance policies (if you have one, go check the fine print if you find it hard to believe).

Child in Fukushima being tested for radiation

Word play…
With regard to the effects of the nuclear accident at Fukushima, Eskom does acknowledge a “Theoretical increased risk of thyroid cancer among most exposed children“. This is a clever use of language. Risks are, of course, theoretical by definition! But specifying they are theoretical risks somehow makes it sound less real. Also, these risks are apparently for most exposed children. Really!? Have some exposed children been identified who are immune to radiation? Of course not. This is just a way to further downplay the issue.

And the high level waste?

Photo p a blue open tank with a rack for hold spent nuclear fuel assemblies

Racks in a cooling pond

The waste produced by a plant would seem at first glance to be an important part of its environmental impact, and especially so if that waste remains dangerous for thousands of years. Eskom however, disagrees. They contend that there was no need to “to assess the impact of the final disposal of the high level nuclear waste as the final disposal of high level nuclear waste will be the responsibility of the National Radioactive Waste Disposal Institute“. The waste is a direct and inevitable result of building the plant, and so its impact cannot just be omitted just because someone else will be dealing with it.

Once high level waste is produced, there is no way to back off. After a few years in cooling ponds it must be disposed of so any separate Environmental Impact Assessment done later would be farcical as the “no-go’ option is by then of course impossible.

Fukushima Reactor Pit Crack

A crack in the concrete pit near reactor number 2 after the Fukushima earthquake

The Fukushima disaster demonstrated that a nuclear power station cannot withstand an unexpectedly powerful earthquake. The Koeberg site is within a few kilometres of the Milnerton fault line, which also runs through Ceres. The assessment of the risk of and earthquake damaging a nuclear plant on that site was done so poorly that Eskom’s consultants agreed it needed to be redone: ā€œa new PSHA [Probabilistic Seismic Hazard Analysis] 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.ā€

Photo of a crack in the road and an article about the 1969 Ceres earthquake

Ceres 1969 earthquake

Ten years later, this study has still not been completed, and Eskom are confident in the findings of a 42 year old study. In their response to an appeal, Eskom writes “Dames and Moore (1976) concluded that enough circumstantial evidence exists to postulate the presence of a northwest striking fault offshore of Duynefontein but that it does not come closer than 8 km to the site. It is however possible that such a postulated fault could pass anywhere between 7 and 10 km offshore of Duynefontein (the inferred Melkbos Ridge Fault passes 7.5 km from the Koeberg Nuclear Power Station). No new research has been performed to confirm or refute the presence of the postulated fault or its point of closest approach to the site

Given the advances in computer modelling since 1976, as well as 42 more years of seismic data, it is likely that a new study would asses the risk more accurately. Eskom have known this for ten years, and there is no excuse for not completing this study before the Environmental Impact Assessment was submitted. In their response, Eskom are now attempting to rename this updated study the “NNR study”, so that they can delay it until the NNR licensing process .

The full Monty
Here are all 115 pages of the response from Eskom. Enjoy! Please leave a comment below if something stands out for you.

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