A declaration of an ‘energy emergency’ has been touted as a necessary step to “cut through the red tape” and address the electricity crisis. But what exactly does this mean? Which regulations or processes will be bypassed?
When it comes to the Koeberg nuclear plant, one upcoming regulatory requirement and a concern for those advocating for a life extension is getting approval from the National Nuclear Regulator (NNR). The current operating licence expires in July 2024, and without the NNR granting a life extension, this is when the plant will have to be permanently shut down.
Six months after appointing a Board member to the Board of National Nuclear Regulator (NNR) in order to represent affected communities, Minister Mantashe unlawfully suspended Peter Becker on 18 January 2022. He has been a vocal campaigner against nuclear power in South Africa for about 12 years, and when Mantashe appointed him in June 2021 it was widely welcomed as an enlightened step. According to the NNR Act of 1999, the NNR Board also includes a member from the Department of Mineral Resources and Energy (DMRE), well known for a very pro-nuclear stance.
It is generally agreed that nuclear power comes with an inherent risk. What is hotly debated is whether or not there are benefits which outweigh that risk. When it comes to the Koeberg Nuclear Power Plant, Eskom have had the approach that since Koeberg produces electricity at a cost of around R0.45 per kWh, it is a ‘no-brainer’ to spend whatever is needed on a refurbishment to extend the life of the plant beyond the end of its design life in 2024.
A recently released modelling report estimates that doing that refurbishment would result in additional costs of R50bn “from a combination of the actual costs of life extension, additional open cycle gas turbine (OCGT) usage, large key-customer curtailment requests/instructions, and scheduled load-shedding.” It will also increase carbon emissions due to the additional use of OCGTs.
On 15 January Eskom released a statement saying that Koeberg unit 2 “will on Monday 17 January 2022 be taken offline for a regular refuelling and maintenance outage that is scheduled for five months.”
Setting the disingenuous tone Firstly it is disingenuous to call this a “regular refuelling” outage. It is about as accurate as saying your car is going to the mechanic for refuelling, and by the way while busy filling the tank they will also replace the gearbox. The vast majority of the cost and the duration of the outage will be to do the refurbishment, so it is more accurate to call this a refurbishment outage.
An anti-nuclear demonstration held on Bloubergstrand Beach on 16 December highlighted concerns of Capetonians about the implications of Eskom extending Koeberg’s lifespan next year. The nuclear plant reaches the end of its 40-year lifespan in 2024 but Eskom is trying to extend its operating life by another 20 years before any public consultation.
On the show Rossouw said that “Eskom is regulated by an International Nuclear Agency”, which is incorrect. The IAEA can only make recommendations to a member country, and member countries are free to implement, or ignore, those recommendations. For example, in 2013 the IAEA made several recommendations concerning South Africa, and while some of these have been implemented, others have simply been ignored for the past eight years.
Consequently, Eskom does not require a ‘permit’ from the IAEA to operate Koeberg, as Rossouw stated on the show. He said “the real risk is that the Agency will recall their permit, in which case they will have to shutdown”.
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.
It was recently widely reported in the media that a US-based engineering company has been awarded a portion of a R20bn contract to extend the life of the Koeberg nuclear power plant. Activists and civil organisations are concerned that the legal processes required to grant a licence for a life extension have not been followed.
Koeberg’s nuclear licence expires in 2024
In order to operate beyond 2024, Eskom needs the approval of the NNR, and a new licence to be issued. This licencing process is described in new regulations published in March 2021, which requires a notice in the government gazette as well as announcements in local newspapers. This would allow the public to make comments for the NNR to take into account before making a decision. However, it appears that this process has not been followed.
The KAA has noted recent media reports that claim Jacobs Engineering Group has secured a contract to extend the life of the Koeberg nuclear power plant.
Koeberg is operated by Eskom, under a licence from the National Nuclear Regulator (NNR) which expires in July 2024. In order to operate beyond that date, Eskom needs the approval of the NNR for the life extension, and a new licence to be granted. This licencing process requires a public participation process which the NNR is obliged to take into account before making a decision.
The fact that this contract has been announced before the NNR has indicated it has even received the life extension application from Eskom is deeply concerning. The NNR has the mandate to protect the public, but to allow Eskom to ignore due process and make this announcement as if the extension is a ‘done deal’ calls into question the independence of the NNR.
The National Nuclear Regulator (NNR) has announced public hearings relating to an Eskom application to licence the Thyspunt site in the Eastern Cape for a new nuclear plant build. The hearings will take place on 25 and 26 August 2021 in St Francis Bay and Jeffreys Bay respectively.
Brief EIA history
Thyspunt lies 80k west of Gqeberha (formally known as Port Elizabeth), in between St. Francis Bay and Oyster Bay. The site was one of three proposed by Eskom for a new nuclear installation in 2008, the others being Duynefontein (next to Koeberg outside Cape Town) and Bantamsklip (near Hermanus in the southern Cape). The Environmental Impact Assessment (EIA) found that the Thyspunt site was the least risky however in a surprise move the minister for the environment approved the project in 2017, but named Duynefontein for the build. This decision was appealed, and four years later, no decision on that appeal has been made.