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:

Continue reading

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

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

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

World Bank to fund nuclear power in South Africa?

The South African government has been driving its nuclear power plans forward over the last few months.  There have long been concerns, as recently expressed by President Zuma’s Minister of Finance, Malusi Gigaba, that South Africa cannot afford nuclear power.  There has been speculation that the World Bank might be a source of funds to allow the project to go ahead.  However, there are several reasons that make this is extremely unlikely, to say the least. Continue reading

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. Continue reading

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