Eskom lawyers insist IRP 2019 must be ignored

After 17h00 on Thursday the 1st of April, the eve of the Easter weekend, Eskom’s response to the Nuclear-1 Environmental Authorisation (EA) appeal was released. This response marks the last step before Environment Minister Barbara Creecy makes a final decision on granting Eskom permission to build a new nuclear plant at the Koeberg site, 27kms north of the city of Cape Town.

According to civil organisations, the response document contains misinformation and worryingly shows Eskom pushing for a new nuclear build, overriding the country’s energy plan, the Integrated Resource Plan of 2019 (IRP 2019).

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Eskom responds to Koeberg cracks

In response to our press release Cracks in Koeberg Safety Claims Eskom released a statement (full text given below) on 12 February 2021. This statement ignores several of the issues we raised, obfuscates others, and provides some further alarming information.

Maintenance and testing is being done …
The Eskom statement says “repairs have been implemented” which sounds initially reassuring. However, the report itself describes the repairs in progress at the time as follows:Extract from report: neither ideal nor sustainable

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Cracks in Koeberg safety claims

A recently released Eskom document revealed that 40 years of exposure to sea air at Koeberg Nuclear Power Station has damaged the concrete of the containment buildings. At one stage the concrete containment dome was found to have cracked around the entire 110 meter circumference.

“The containment buildings are the outer shells of the reactor buildings, built as pressure vessels to withstand the pressure if the reactors inside them ever malfunction and therefore prevent harmful radiation being leaked into the environment,” says DR, a member of Koeberg Alert Alliance (KAA) and a retired analytical chemist.

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Nuclear-1 Appeal Supplementary Submission

After a long process described described here Eskom was granted permission by the minister for the environment to build a new 4000 MW nuclear plant at Koeberg. After three years of silence, the process was revived as described here. We appealed for an extension,  and finally completed the submission below. Continue reading

Eskom releases Koeberg Decommissioning Strategy

Koeberg is the only nuclear power plant in Africa, and is operated by Eskom under a licence issued by the National Nuclear Regulator. Section 17.2 of this licence specifies that “The licensee must submit for approval a decommissioning plan, as early as possible in the life cycle of the activity or facility. The plan should be revisited and updated as necessary.”

Using the Promotion of Access to Information Act in August 2020 we submitted a request to Eskom for a copy of this plan. In October 2020 they responded with a letter and the document below. Continue reading

Nuclear-1 EIA submission period re-opened

Letter from DEFF EIA supplemental submission extension grantedAfter three years of silence, the Nuclear-1 Environmental Impact Assessment process was revived by an invitation for “supplemental submissions”, as described in  Nuclear-1 EIA revived with ‘Supplemental Submissions’. The invitation specified a condition that supplemental submissions may only be made by those who had submitted a formal appeal in 2017. We wrote to the department and objected to this condition as follows:

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New Long Term Nuclear Regulations?

On 19 June 2020 new Draft Regulations on the Long Term Operation of Nuclear Installations were published by the Department of Mineral Resources and Energy for comment, due by 19 August 2020. This is the fourth major nuclear power related activity in government circles since the start of the Covid-19 lockdown (the others were the RFI, the EIA Supplemental submission invitation, and the discussion paper on decommissioning policy).

The exact aim of these new regulations is not clear, giving rise to concerns that they may be aimed at attempting to weaken or bypass the regulations relating to Environmental Impact Assessments.

If they were to be adopted, they would likely be applied to attempting to extend the life of the Koeberg Nuclear Plant, which is due to be shut down in 2024. Continue reading

A National Nuclear Decommissioning Policy?

On 20 July 2020, the Department of Mineral Resources and Energy (DMRE) released a Discussion Paper on National Decommissioning Policy for Nuclear Facilities.

This was a well balanced document which went into some detail, and proposed various decommissioning strategies. It posed 10 questions which covered liability and security for decommissioning costs, strategies, and research needed.

The actual costs of decommissioning the Koeberg Nuclear Power Station, including final disposal of the spent fuel (so far over 1.5 million kilograms),  are unknown. If South Africa had followed the Swedish model with a levy on nuclear power Eskom should have accumulated a fund of about R170bn by now. Instead, Eskom is R450bn in debt. Continue reading

Nuclear-1 EIA revived with ‘Supplemental Submission’ period

The Nuclear-1 Environmental Impact Assessment (EIA) for a large new nuclear plant at the Koeberg site was given the go ahead in 2017, resulting in many appeals against this decision.  After three years of silence, the Department sent out a notice to appellants in July 2020, inviting a supplemental submission.

The EIA was based heavily on the Integrated Resource Plan (IRP) 2010, which included projections of strong economic growth and vastly increased electricity demand by 2020, and hence the need for nuclear power stations. Recently the IRP 2019 was released, which took into account the actual electricity demand, and so delayed any possible need for new nuclear power to beyond 2030.

Despite the length of time that has passed with the EIA process in limbo, the Department have told us that interested parties may not make submissions now, unless they also submitted a formal appeal in 2017. The deadline for submissions is 3 September 2020, although this may be extended. Continue reading

Koeberg Emergency Plan conflicts with COVID-19 regulations

Koeberg Population Density Map

Nuclear-1 EIA App E18

A nuclear incident requiring an evacuation around Koeberg would have a significant effect on the spread of COVID-19. During an evacuation, social distancing will not be followed as people pack into any available transport. Travel restrictions will either be suspended by the government, or overridden by the public possibly with bloodshed. No roadblock can stop 80 000 panicking people! Continue reading