NERSA conditional nuclear concurrence distracts from Koeberg problems

NERSA conditional concurrence with new nuclear

The National Energy Regulator of South Africa (NERSA) has given a conditional concurrence with the section 34 ministerial determination to proceed with procuring a new nuclear plant. This concurrence has some crucial suspensive conditions, in particular 1.3. This makes it clear that given the information put before NERSA, the decision to go ahead with a nuclear build cannot be considered rational.

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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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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

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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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

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.”

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Appeal against Environmental Authorisation for Koeberg

After a long Environmental Impact Assessment which began in 2007, an Environmental Authorisation was issued for the Koeberg site, 26km north of Cape Town.  This gave Eskom permission to build a new nuclear plant of unspecified design, plus a nuclear waste reprocessing and/or disposal site.

At first only 30 days were allowed for appeals against this decision, and this was extended on the day of the deadline to about 90 days, until 5th March 2017. There are so many reasons this Authorisation was wrong, and we tried to describe some of them in the 43 page submission we wrote. Continue reading

Extension Granted for Appeal Against Nuclear-1 Authorisation

On 11 October 2017 the Department of Environmental Affairs (DEA) issued an authorisation to Eskom for a second nuclear power plant at Koeberg, 28km north of Cape Town City centre.  This was in response to a final Environmental Impact Report submitted to the Department by Gibb (Pty) Ltd on behalf of Eskom, the applicant.

Please sir, may we have some more time?
We wrote to the Department on 30 October, requesting an extension of the 30 day appeal period, which was set to expire on 1 December 2017. Continue reading

Koeberg authorised to be Cape Town’s permanent radioactive waste dump

On 11 October 2017 the Department of Environmental Affairs (DEA) issued an authorisation to Eskom for a second nuclear power plant at Koeberg, 28km north of Cape Town City centre.  It came with a surprise.  The Department also authorised the “construction of facilities or infrastructure, including associated structures or infrastructure for … disposal of nuclear fuels, radioactive products and waste.

Waste disposal not part of project…
You would have been surprised if you had studied the final Environmental Impact Report (EIR) because it gave the impression this was not about waste disposal. Continue reading

Nuclear-1 Submission to Dept of Environmental Affairs

Before approval for a nuclear plant can be granted, by law an Environmental Impact Assessment (EIA) has to be done and submitted to the Department of Environmental Affairs (DEA).

The EIA for the so called ‘Nuclear-1’ project has been in progress for over six years, and the fourth and final draft of the resulting report was eventually submitted to the DEA in early 2016.

This report is of a low scientific standard, and should be rejected by the DEA.

We have made submissions on each draft to the EIA consultants, GIBB, which have been largely ignored, and have not resulted in the changes to the EIA report we hoped for.

We have therefore written to the DEA giving reasons why we believe they should reject this report.

To see our submission, including a short summary, click here: KAA Submission to DEA