In March 2022 a team from the International Atomic Energy Agency (IAEA) visited Koeberg to report on how ready the plant was to implement Eskom’s plan to extend its life beyond 2024. Eskom wanted to keep this report secret, but due to a request under the Promotion of Access to Information Act, it is now public.

The report lists fourteen safety issues with the planned life extension, or LTO (Long Term Operation), which mostly highlight that given the current conditions at Koeberg, the refurbishment cannot be done on time, nor safely. The full report is included below.

The IAEA has the mandate to promote the use of nuclear power, and can only make suggestions and recommendations to member countries. The authority to issue licences rests solely with the South African National Nuclear Regulator (NNR). Unfortunately, the recommendations from the IAEA can simply be ignored, and this report meekly points out that “eight post Fukushima requirements are still in progress and not completed”. These recommendations were made nearly a decade ago in 2013 and include a concern about lack of independence of the NNR. The IAEA team was “of the view that there is no adequate separation between the regulatory functions and the promotional activities”.

Fourteen safety concerns…
The full title of the document is “IAEA REPORT OF THE SAFETY ASPECTS OF THE LONG TERM OPERATION MISSION (SALTO) TO THE KOEBERG NUCLEAR POWER PLANT UNITS 1 AND 2 South Africa 22-31 March 2022” and in addition to previous issues which have not been resolved it contains the following new concerns. (The meanings of the acronyms used are given below.)

1. Without effective management of the LTO programme the plant will not be able to timely implement all activities to demonstrate preparedness for safe LTO
2. Without an adequately updated SAR for LTO and ageing management, the plant cannot ensure a complete safety documentation for LTO.
3. With incomplete or inconsistent scope setting of SSCs, ageing management and safety function of some SSCs important to safety could be compromised.
4. Without comprehensive revision and implementation of the plant programmes, safety function of SCCs in scope of plant programmes cannot be ensured.
5. Without consistent management and documentation of information, the ageing management review of mechanical SSCs cannot identify in a consistent manner ageing effects that can challenge safety functions for LTO.
6. Without complete AMPs for mechanical SSCs, the plant cannot ensure preserving the safety function of SSCs for LTO.
7. Without implementing a comprehensive ageing management programme, safety function of safety related cables cannot be demonstrated.
8. Without a complete revalidation of environmental qualification of the relevant components, their ability to perform safety functions cannot be demonstrated for LTO.
9. Without a complete assessment of electromagnetic compatibility, the safety function of electrical components with regard to EMC cannot be demonstrated.
10. Without a complete revalidation of environmental qualification of cables, the ability to perform their safety functions cannot be demonstrated.
11. Without a proactive technological obsolescence management, the plant risks unavailability of SSCs important to safety.
12. Without comprehensive revalidation of the TLAAs, the plant cannot demonstrate maintenance of the safety function of concrete structures.
13. Without a fully functional containment monitoring system, not all necessary data for the containment structure will be available to demonstrate the intended safety function during LTO.
14. Without complete implementation of ageing management programmes for civil SSCs, preservation of safety functions cannot be ensured.

Where LTO is Long Term Operation, SAR is Safety Analysis Report, SSC is Structures Systems and Components, AMP is Ageing Management Programmes, AMR is Ageing Management Review, EMC is Electro-Magnetic Compatibility, and TLAA is Time Limited Ageing Analysis.

“That is fourteen safety concerns too many”, says Koeberg Alert Alliance spokesperson Lydia Peterson. “It is worrying to see phrases like “not effective, not adequate, cannot be ensured, not consistently managed, incomplete, and not fully functional” used to describe the plant systems.

“The current operating licence for Eskom, issued by the NNR, expires in July 2024. For Eskom to comply with IAEA safety standards within the time frame seems impossible,” Peterson adds.

Can it be contained?
Items 12-14 refer to the concrete containment domes. Severe rusting of the reinforcing bar, cracking and spalling of the domes was found in 2018, as reported here. These domes enclose the nuclear reactor and steam generator, and are the last line of defence preventing radioactive material being released into the environment if there is ever is a leak from the reactor, steam generators or high pressure tubing.

The IAEA found that the safety of these structures “cannot be demonstrated”. This is a major concern and Eskom have not announced how they intend to address this problem. There are unsubstantiated rumours that the intention is to pour a large amount of epoxy over the domes to attempt to glue them together to prevent further deterioration.

Highly radioactive substances are leaking…
Item 14 also relates to leaks that have been observed in unit 2. The report reads “Leakage through leakage collection system of spent fuel pool of unit 2 was observed irregularly during the plant life, it has even stopped for a few years. An investigation was performed, but the root cause of the leak and disappearance of leak could not be found.”

It continues: “White residue and deposits are observed along cracks in the concrete on structural elements around or below these sumps. In both cases the sumps are unlined, and their contents are highly radioactive.”

This was of particular concern to Peterson. “If not even an investigation by the IAEA could determine the origin of the problem, can we be sure that the leak will not reoccur?” she asks.

Is the Nuclear Regulator adequately independent?
The concern expressed by the IAEA in 2013 about a lack of independence of the NNR is one of the issues that has not been addressed, and in fact appears to have become significantly worse over just the past year as can be seen from the following three incidents. The IAEA was concerned that the Minister who promotes nuclear energy is also in charge of hiring and firing NNR Board members.

In March 2022, civil society representative Peter Becker was dismissed from the Board of the NNR for being anti-nuclear and is challenging that in the High Court in Cape Town, which is set down to be heard on 7 November 2022. In his affidavit, the Minister states that he expects NNR Board members to “Loyally execute the policies of the government of the day”, which includes the life extension of Koeberg. It is difficult to reconcile this expectation of loyalty with independence.

Secondly in May 2022, Minister Mantashe made a speech in which he reportedly said he will fire any Board member who does not support nuclear programmes. In his affidavit, the Minister writes “I admit these statements are unfortunate” but he has not issued a retraction.

Thirdly, the Chair of the NNR Board Dr Thapelo Motshudi wrote in the NNR’s annual performance plan for 2022-2023 that he plans to arrange “further external stakeholder engagements to make the public more aware of the vital role of nuclear power in the country’s clean energy technology and in the energy mix”. This is a clear example of the regulatory function of the NNR not having “adequate separation” from “promotional activities”, to use the words of the IAEA.

“For the NNR, independence can only be guaranteed if legislation is amended taking power away from Ministers, or at the very least curtailing it.” according to Brendan Slade of the Organisation Undoing Tax Abuse (OUTA).

“Can the NNR be impartial and execute its mandate?” asks Peterson. “With so many safety concerns and a clear indication by the IAEA that Koeberg is not ready for a life extension, how could this regulatory body consider granting a LTO licence when our safety cannot be guaranteed?”

Slade adds: “Since 2013, government has done little to address the IAEA’s recommendations, showing a total disregard for the independence of the NNR. If the issue of political interference is not addressed as a priority across the energy landscape, South Africa’s energy future remains bleak.”

Worth going ahead?
It appears that the IAEA is of the opinion that Koeberg is not ready for a life extension refurbishment, that it cannot be completed in the time frame Eskom is planning, that there are multiple severe safety concerns, and that the NNR is still not adequately independent.

“While Eskom continues to fail to release figures about the forecasted cost of the Koeberg refurbishment, it is difficult for the public to get independent analysts to determine if it appears worthwhile”, says Hilton Trollip, an independent energy expert. “The government and its agencies, such as NERSA, who are meant to supply the public with sufficient information are failing to do that.”

But don’t we need Koeberg to avoid more load shedding?
Koeberg will have to be taken offline at some stage. It is not a question of when. Either it will be taken offline towards the end of 2024 as originally planned, or each unit will have to be taken offline for long term outages before the end of 2024 in order to do the refurbishment work. The question is, when will there be a greater need for the 2GW from Koeberg: during 2022 to 2024, or after 2025? It will do the economy huge damage to have a long term outage at the height of the load shedding crisis.

Clyde Mallinson, an independent energy analyst, has used Eskom supplied data and forecasts to calculate that a 6 month outage of one unit at Koeberg will cost the South African economy around R85bn in 2023 as a result of additional load shedding. Mallinson works with a conservative R20 cost per kWh of unserved energy, whereas using the figure of R87 per kWh from the official Integrated Resource Plan of 2019, that rises to R370bn. If Mallinson is correct, whatever Eskom has already spent on the refurbishment, for the country as a whole it will be significantly cheaper to abandon that amount, and it would be extremely irresponsible for Eskom to go ahead with the long term outages now.

If not Koeberg, what then?
Already there are several renewable energy projects in progress, including the leasing of land by Eskom to independent power producers to build 2GW of new capacity. The Department of Mineral Resources and Energy (DMRE) is also slowly beginning to move forward with the renewable energy bid window 5 process by signing on the first three of 25 bidders and issuing a determination for 2.6GW of more renewable energy.

If the foot dragging by the DMRE and Minister Mantashe comes to an end, it is possible to build new renewable plants within two years which will easily cover for the lack of Koeberg after 2025. This report from the IAEA provides insight into just how risky a rushed refurbishment of Koeberg will be. It makes it clear that instead of spending an unknown number of billions of rand on a risky project at Koeberg which might not even succeed, South Africa should be focusing our limited time and funding on developing new generation capacity as rapidly as possible.