Civil society rejects NNR public consultation process for Koeberg life extension

Koeberg comes to the end of its life in the second half of 2024 when Eskom’s licence issued by the National Nuclear Regulator (NNR) expires. Eskom has applied to the NNR for a twenty year extension to this licence and were required to prepare a Safety Case which described why such an extension would be safe. Initially, at a Public Safety Information Forum meeting on 31 March 2022, Eskom refused to release the Safety Case publicly but later backtracked and released a redacted version of it with many sections blacked out in January 2023. 

As part of the licence application, the NNR started a public consultation process on 8 January 2023 with a deadline for submissions on 16 March 2023. Due to the lack of transparency from Eskom, civil society organisations have rejected this process and demanded the complete suspension of the comment period.

Eskom’s redacted safety case
Many sections of Eskom’s Safety Case have been blacked out as seen in Table 9-4. This table lists Time Limited Ageing Analysis which needed to be done and is a core part of the Safety Case. This analyses the suitability of components to operate beyond their designed lifetime and lists actions that will be undertaken by Eskom to ensure these components are in fact safe to operate for another twenty years. As all the actions are blacked out in this table, the public cannot see how Eskom will address these issues or if any action will be taken at all.  

“I have studied the Safety Case released by Eskom as well as the Public Information Document,” said Koeberg Alert Alliance (KAA) spokesperson, Lydia Petersen. “The Safety Case is heavily redacted and blacking out the actions make it impossible to ascertain how safe it would be to extend the lifetime of Koeberg.

“I wrote to the NNR on 17 February 2023 to demand full access to the Safety Case as without it, it is not possible to engage in this public consultation process meaningfully,” said Petersen.  

According to Petersen, the NNR refused this request in February claiming: “… the following has been redacted from the Safety Case; i. Confidential and /or sensitive information; ii. Commercial information; and iii. Security arrangements as contemplated in section 51 of the NNR Act”. Not satisfied with the response Petersen said: “Claiming that safety related information is withheld because it is ‘sensitive’ is unacceptable.”

Eskom’s lack of transparency around safety issues

Eskom has a history of such behaviour as reflected in a 31-page report released in 2020 after a Promotion of Access to Information Act (PAIA) request. Eskom’s report had eleven pages entirely blacked out and various other sections, photos and tables redacted. That report revealed that 40 years of exposure to sea air at Koeberg Nuclear Power Station had damaged the concrete of the containment buildings and at one stage the concrete containment dome was found to have cracked around the entire 110m circumference.

These cracks in the containment building represent a serious safety risk and a 2022 report by the International Atomic Energy Agency (IAEA), which falls under the United Nations, highlighted problems with monitoring these cracks in the containment building. These are large concrete domes and are intended to contain any radioactive material which might be released from the reactor and cooling system. The IAEA report contains references to problems with the concrete of the containment domes such as “large-scale delamination, progressing concrete carbonation front and chloride front, concrete cracks, exposed and corroded reinforcement bars.”

The IAEA report stated: “The containment monitoring system is not fully functional. Some thermocouples linked to the strain gauges of the containment monitoring system are not functional. Some strain gauges are out of service or provide erratic values.” 

“The monitoring of these containment dome cracks is a serious issue,” said Petersen. ”It is possible that Eskom has described in the Safety Case how these issues will be addressed but it is not possible for the public to know this due to the blacked out sections.”

Hermanus based organisation, Bantamsklip spokesperson, Rodney Anderson, said: “It is ludicrous to expect us to engage with this public consultation process while information is being kept from us. To follow the correct process we have submitted a PAIA request to the NNR for the unredacted Safety Case, apart from personal information and phone numbers etc. We have also sent a PAIA request for the unredacted report into the state of the spalling of the containment buildings.” Spalling is a term used for cracked and flaking concrete.

Organisations usually have 30 days to respond to a PAIA request and asked when he expected a response from the NNR, Anderson said, “Unfortunately the 30 days period expires after the deadline for submissions which is why we are demanding that the NNR cancel this public consultation process until the PAIA requests have run their course.”

The concerning IAEA report
The 2022 IAEA report contains additional concerning information such as: “Leakages have been noted in sumps… N281 and N032… White residue and deposits are observed along cracks in the concrete… In both cases the sumps are unlined, and their contents are highly radioactive. The procedure to address unlined sumps is not completed yet.”

“It is possible that Eskom has a plan to address this very worrying radioactive leak,” said Petersen, “but it is not possible to know given the heavy redaction in the Safety Case report.

“The 2013 IAEA report also pointed to a lack of independence of the NNR. It will be a good test of the actual independence of the NNR to see if they allow the Safety Case to remain redacted or if they will instruct Eskom to be more transparent with the public,” said Petersen.

The IAEA report stated that they were “…of the view that there is no adequate separation between the regulatory functions and the promotional activities, thus calling into question the effective independence of the NNR.”

Affected communities are not informed
Project 90 by 2030 director, Lorna Fuller, believes that the NNR has not made enough effort to engage with affected communities. “At a recent workshop we asked 40 community representatives if any of them had heard about the public participation process – only one had. 

“The NNR is obliged to make more effort to inform involved stakeholders, and also to hold meetings within those communities so that they can be provided with the information they need to participate meaningfully in this important decision,” said Fuller. 

Gabriel Klaasen, an intersectional justice youth activist said, “It is our right to participate in all major decisions taken by government, and especially those that will affect our future. 

“Nuclear waste is a worry, as we are the ones who will be left to deal with it. It is questionable to us whether running Koeberg for another twenty years is worth it, due to the additional nuclear waste that will be produced. Given the incomplete information provided by Eskom and the absence of any plans to engage with affected communities directly, when it comes to this public consultation process by the NNR, we demand #SuspendDontExtend.”

Brendan Slade from the Organisation Undoing Tax Abuse, OUTA, said, “A heavily redacted Safety Case makes public participation meaningless. This trend of withholding information from the public, specifically where the public is asked for input, has become far too common. This creates an impression of a tick boxing exercise from government. Frustration and having no confidence in government becomes warranted.”

“If any members of the public agree that safety related information should not be withheld from the public, we encourage them to write to the NNR and make their voice heard,” concludes Petersen. The NNR have created the email address for comments from the public.

Here is the redacted version of the Safety Case as released by Eskom in January 2023:


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