THYSPUNT, 2016 – 2017
REPORT BY H. THORPE 14 JANUARY, 2017
Major developments during the year were repeated evidence of the ANC’s determination to press ahead with nuclear power at Thyspunt; increased opposition by the financial community and others on the grounds that South Africa cannot afford it, and by technical energy experts on the grounds that we do not need it yet; the release of the Final Environmental Impact Report (FEIR) by Gibb, on behalf of Eskom, and our response to that; an increasingly strident propaganda campaign by the business community and NECSA, telling everyone how rich they will become if Thyspunt goes ahead; and an International Information Conference set up by the NNR in October. I attended this, thanks to support from the SFBPO & Kromme Trust. It was a very valuable experience, and led to some important contacts with whom I am in communication.
Reaction by the TA has been to seek to ensure due process. This included response to the National Department of Environmental Affairs (DEA) to the Final Environment Impact Report (FEIR), and preparations for the National Nuclear Regulator’s (NNR) process, which is expected to begin shortly.
We have also engaged Environmental Lawyer Cormac Cullinan to maintain a watching brief in preparation for litigation, should that be required.
The Final Environmental Impact Assessment (FEIR), published in February, 2016, was full of the usual flaws, errors & omissions. We identified a number of what to us were fatal flaws, not least in the Impact Rating Criteria, which determine the seriousness of an impact. Only if a fatal flaw is found will the authorities consider giving a “No go” ruling. Problem: the Impact Rating Criteria were so worded that it was impossible to identify a fatal flaw! Eskom made full capital of this to state that the specialists had found no fatal flaws.
This was raised with Gibb in 2011, and modified by them in 2015, but only just before the release of the FEIR. It was clear that some of the specialist reports, notably the Social Impact Assessment, had been done in terms of original IRCs prior to two revisions. Once Gibb had submitted the FEIR they could only comment on I&AP reactions in terms of the FEIR, and could add nothing new. Their responses, were therefore of little value.
The social impact would be catastrophic to the St Francis area. The specialist report was one of the worst in the entire process, described by us as “vacuous philosophical ramblings, more appropriate to a Scoping Report than an FEIR”. This has led to our requesting that the report be rejected in its entirety, and a new Social Impact Assessor be appointed.
In October I met Milicent Solomon, the Director of Strategic Infrastructure Development in the National Department of Environmental Affairs in Pretoria. She is responsible for the evaluation of the EIA. We had a good discussion. She was fully aware of the issues raised by the Thyspunt Alliance. It was clear to me that the only correct course for her would be to reject the FEIR and to refer it back to Gibb to address the issues which remain unresolved. She admitted that she was under tremendous pressure both from government & Eskom to give a favourable ROD. Release of this is expected in February or March. It seems likely that it will go for review, whatever the outcome. This will be costly, and could lead to yet another appeal for funds.
The position of the TA, and of its predecessors, the Kouga Nuclear Concern Group (KNCG) and the Kouga Anti-Nuclear Group (KANG), has always been, and remains, that, in terms of internationally accepted conventions for emergency planning, the Thyspunt site is not viable for a nuclear plant, on the grounds of population figures, downwind from the site, with only one escape route. This is a fundamental issue which, in our view, should have been resolved before the EIA was even undertaken . As it is, Eskom has done, and paid for, everything at risk.
Eskom’s response has been to sweep this under the carpet by referring it to the NNR, who could do nothing about it until Eskom applied for site & plant licences. They have now applied for a site licence, but not the plant licence, since this has still not been determined. Meanwhile Eskom has decided to use so-called “Generation 111” technology, with its claimed improved passive safety features, in terms of “EURs”, (European Utility Requirements – not European Union Regulations!), and believe that this justifies applying for a reduction of Emergency Planning Zones to 3 kilometres around the site. If approved, this would dispose of the viability issue.
Problems with this are that EURs are little more than a wish list. They are an attempt made by European nuclear vendors to improve credibility, following the Chernobyl accident. 25 years after it was first mooted by European vendors, there is not a single “Gen.111” PWR reactor functioning anywhere, although there are some under construction in BRICS countries. France’s nuclear vendor, Areva, has gone bankrupt trying to develop it. Gen 111 is still in the R & D stage. It has no commercial or safety record. These “improvements” are extremely costly, and the temptation is to water them down to save costs. To base Eskom’s entire case for reducing EPZs to 3 kilometres on evidence Gen111 is kite-flying of note.
In terms of the NNR Act of 1999, the NNR is responsible for ensuring the safety of the environment, people & property from nuclear radiation. One of their tasks is to license nuclear sites and plants. This is the first time that this has come up since Koeberg was selected in the nineteen eighties. They have no expertise, no experience, no independence and inadequate funding. Once again, they will be dependent on Eskom for funding, and will doubtless be under pressure from their Minister, Tina Joemat-Petterson, who is determined to force the project through, so far by Executive decision and not through parliament. This is currently subject to a court case which is expected to resume in February.
To our surprise, the NNR set up the “International Information” three-day conference, mentioned earlier. This was held at the CSIR in Pretoria in October, to draw on expertise from all over the world. It was world-class. The Thyspunt Alliance was invited to participate as observers. The real value to me was the networking opportunities offered. It was an excellent start by the NNR, accompanied by protestations of all the right intentions. Many speakers stressed the importance of a credible public participation process.
One worrying aspect was that there is no international standard for emergency planning, or even Gen 111, leaving governments free to use their own criteria.
Among those I met were some of the leading nuclear regulators throughout the world. One told me that he might consider reduced EPZ for a small 250Mw reactor built mainly underground, but never for a 3600Mw plant as proposed for Thyspunt! He stressed the importance of a credible public participation process, with early engagement; of having the right people with the right skills at the right time; and of transparency, with the primary focus on safety & security. Another told me that he would never consider an application that did not have multiple escape routes!
We could be in for a lively year!