Cape Town nuclear build approved by Dept Environment

Before any major development, South African law requires a detailed Environmental Impact Assessment to be submitted to the Department of Environmental Affairs before the project may begin.  In 2009, Gibb consulting submitted a scoping report for such a study on behalf of Eskom, with a view to building a large nuclear power plant.

During the public participation process Koeberg Alert, as well as many other organisations, scientists and members of the public submitted extensive and detailed comments on the report, and in particular the poor quality of the specialist reports.  In response to this deluge of criticism, GIBB produced four versions of the report, and finally submitted its final version to the Department in February 2016.  Based on a wide range of factors, the report recommended that Thyspunt in the Eastern Cape was the best site for the plant.  Nearly two years later, Sabelo Malaza, the Chief Director, issued an authorisation which overrode the consultants recommendation, and specified Duynefontein (Koeberg), near Cape Town, was were the plant could be built.

The full text on the authorisation is here: Duynefontein authorisation full text

If you made any submission during any of the four public participation processes, it is crucial that you indicate that you wish to appeal against this finding. To do this, simply send an email to appeals@environment.gov.za and to Herbstdl@eskom.co.za in which you say you intend to appeal the authorisation for a nuclear power station at Duynefontein, reference number 12/12/20/994. The price of a participative democracy is participation – please find a few minutes to do this before the deadline of 21 October 2017. [Correction: 31st October 2017]

Graph showing predicted and actual peak electricity demand in South Africa

There are many flaws in the report, some clearly intended to bias the finding for Eskom, and others perhaps just due to sloppiness or scientific incompetence.  And example of the former is the ludicrously inflated projected demand for electricity, which is used to justify the need for a nuclear plant.  Despite being given far more up to date data, Gibb refused to incorporate this into their report.  This is dealt with in more detail, including graphs, in Eskom and GIBB living in la-la land.

fukushima-nuclear-explosion2An example of sloppy science is the thorny issue of seismic risk.  Since the earthquake near Japan caused the 2011 Fukushima nuclear disaster, there has been more concern worldwide about the risk of a seismic event causing a leak or reactor explosion.

Photograph of crack in road in Ceres caused by earthquake

Damage in Ceres from 1969 quake

In the first version of the seismic study, a specialist found that the Peak Ground Acceleration (PGA)_ for the Koeberg site was 0.30g.  Any scientific measure is accompanied by a confidence interval, for example 0.30g ±0.01g. The scientists who write this report, Erna Hattingh and Johann Neveling, were apparently unaware of this, and did not give any interval, despite the inherent uncertainty in their methodology.

It also noted that 0.30g was the threshold over which a site is considered unsuitable for a nuclear plant.  Finally, it added that the 0.30g for Koeberg was arrived at using an outdated methodology, and that this will “necessitate additional geological investigations and implementation of an advanced PSHA that will follow internationally accepted practice“, and that “may increase or decrease these values“.   So if a post-Fukushima study is done using up to date methodology, it may increase the risk value, and if it increases by just 0.01g, that would make Koeberg and unsuitable site, based on seismic risk alone.

After consultations with Gibb, this wording was omitted from the second draft report

Cape Town evacuation zones 20km and 50km

Recommended evacuation zones as per Fukushima and Chernobyl

Since the Koeberg site was chosen in the late 1970’s population patterns have changed significantly.  If for any reason it was necessary to evacuate the zones as per other nuclear disasters, the number of people needing to be evacuated would make the job simply impossible.

Radiation from Caesium makes a contaminated area uninhabitable for hundreds of years.  Where will the millions of displaced people live?  However small the risk of an earthquake damaging this nuclear plant, the consequences in term of economic damage and human suffering are too awful to contemplate.

While it will be difficult to draw up a comprehensive appeal in the 30 day period allowed, Koeberg Alert will be doing what it can.  If you can assist with this process, particularly if you have legal or scientific expertise, or if you would like assistance in formulating your own appeal, please contact us on info@koebergalert.org

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From Russia, with Liability

The minister of Energy signed an agreement with Russia in September 2014. More recently made a ministerial determination to allow Eskom to go ahead with the procurement of nuclear plants for South Africa.  The National Energy Regulator of South Africa (NERSA) had concurred with this determination.  I sat in for the final day of the three day high court hearings questioning the legality of these dealings.

Drawing of advocate Oosthuisen arguing before the high court, with advocate Unterhalter and assistant

Advocate Oosthuisen driving home a point

Continue reading

What’s the deal??

There has been a lot of press recently about the ‘nuclear deal’ with Russia.

It all started when our brand new Minister of Energy, Ms Tina Joemat-Pettersson, came back from a United Nations hosted International Atomic Energy Agency (IAEA) meeting in September.  Among her papers was a press release, which was issued on 22 September 2014, and publicised for example here.

There is a deal…
However, the newspapers provided very little, if any, actual information.  Some bits were quotes from old speeches by the Minister or statements from the Department of Energy, and it spoke of ‘laying a foundation’, which clearly was not a purchase order.  Despite that, it was headlined as a ‘deal’, and mixed in with figures about the total cost of a fleet of nuclear reactors.

There is no deal…
There followed a week of flurry in the press, with a retraction from the Department being released almost immediately, and continued furious backtracking with articles appearing like No nuke reactor deal with Russia and SA signed several nuclear agreements.

Theories…
So what happened?  One theory is that our President has signed a secret deal with Putin and perhaps others in Russia to commit to buying nuclear reactors from them.  This would be tricky to implement, since it would so clearly bypass any bidding process and the Public Finance Management Act.  However, there are worrying factors, such as the Secrecy bill, President Zuma assuming control of the inter-ministerial committee formed to implement the nuclear roll out, Russia being free of EU anti-corruption laws, nuclear being carefully excluded from the 2011 new generation build regulations, and increasing control over the judiciary by the executive.

Another theory is that this was the product of the public relations people hired by the nuclear industry.  They would have been swarming all over the recent IAEA conference in Vienna, and our freshly appointed energy minister would have been easy prey.

These PR professionals would have generously offered to assist with the wording of an agreement, and even with writing the associated press release.  They were perhaps surprised by the lack of resistance or any analysis by Joemat-Pettersson, and no doubt pleased with themselves and the positive press they had manufactured, especially by wedging the word ‘deal’ into things.

Column inches…
Someone more informed than Joemat-Pettersson saw the press release, and understood any such deal would be illegal and invalid.  There followed some intense damage control, and the deal became an agreement.  There were also apparently many such agreements planned with other countries.

The job satisfaction of the PR team must have also been short lived, as the backlash resulted in articles about the ever increasing costs of nuclear power and other negative aspects.

Fusion will be here in 15 years?
There is another IAEA conference coming up in October 2014, this time about fusion, hosted by Rosatom in Russia.  The PR machine will again be out in force, and no doubt there will be press releases appearing around the 18th October.  Hopefully they will come up with something more than ‘fusion will be in use in about 15 years’ – which has been the case since 1956.

Policies and plans…
In South Africa, decisions are made in the context of various govermental documents.  First there is the nuclear policy, adopted by the ANC in 2008, which is pro-nuclear.  Then there are two energy plans, the Integrated Energy Plan (IEP), and the Integrated Resource Plan (IRP) which deals with electricity specifically.  There is also the National Development Plan (NDP), a vision for South Africa from some of the most respected thinkers in SA.  At a lower level, there is the Nuclear-1 Environmental Impact Assesment and also a National Nuclear regulator licensing process, both of which must be passed before any order for nuclear reactors can be finalised.

Wait, don’t do it, wait…
The IEP recommends that a decision on nuclear is delayed for a few years to see what happens to relative energy costs, specifically from renewable sources.

The IRP states that should nuclear power capital costs exceed $6500 per kWh, the nuclear option should be abandoned.  However, the Rand has fallen to around R11.30 to the dollar, so this figure should be adjusted to around $5800. [Subsequently to publishing this, the rand has fallen below R15.50 to the dollar, which means the figure should now be  about $4150.] The most recent nuclear build in the United Kingdom came in at $8000 per kWh, and that is before any future cost overruns. This means the IRP clearly recommends that nuclear power be abandoned.

Finally, the NDP came out strongly against going ahead with nuclear power, calling for a national debate on the issue before any decision is made.

Nay, nay, nay… the yay’s have it!
Despite these three ‘no’ votes, the executive seems to be steaming ahead. Possibly its because they are working off outdated documents – the IRP 2010 and the Nuclear Policy of 2008 are about five years old, included overestimates of electricity demand, and pre-date recent advances in renewable energy, as well as the Fukushima nuclear disaster.

Hopefully, when the updated IRP is released the Department of Energy will align itself to that and formally abandon the nuclear path.

And hopefully, there won’t be a cheap Russian solution which omits some of the more expensive safety features and comes in under $5800/kWh.

Hopefully.