NUCLEAR REPORT 2009 - Archives - St Francis Bay Residents Association

The Department of Environment and Tourism (DEAT) has accepted the Final Scoping Report for the Environmental Impact Assessment being conducted on the three proposed nuclear sites of Koeberg, Bantamsklip and Thyspunt.

This was the first of four phases required, namely the Scoping Phase, which identifies potential issues and nominates preferred alternatives to focus on in the EIA phase. The second phase, beginning now, and known as the “EIA Phase” , involves detailed specialist studies of potential positive and negative impacts associated with the nominated preferred alternative. This feeds into the third phase, namely the Environmental Impact Report (EIR) and Environmental Management Plan (EMP). Here, findings of impact assessment studies and comments and concerns raised by Interested and Affected Parties throughout the EIA are addressed and consolidated into a report, including a draft Environmental Management Plan. Finally the process moves on to the Decision-Making Phase in which the authorities use EIA findings to decide whether the project should be authorised. This will lead to a Record of Decision (ROD), with certain conditions. At every level of this process there is the opportunity for public participation.

The acceptance of the Final Scoping Report is subject to a long list of exacting conditions. It goes some way to indicating that the EIA is a genuine process; that the DEAT is no push over; and that Eskom will have to produce very precise evidence on a wide range of key issues before any approval is given to their application. Furthermore, it indicates that issues raised by the public are being taken seriously, and not simply papered over. The full letter from the DEAT to Arcus Gibb, and via them to Eskom, is published on the St Francis Bay Residents Association website www.sfbresidents.org.

Among some sixty conditions of approval, the letter identifies areas requiring clarification in the revised Plan of Study, to include: issues not to be included in the EIA phase (such as viability and waste disposal) and justification of these; robust screening of all issues raised by I & A Ps; refinement of baseline studies, which are regarded as unfocused and inadequate; identification of key impacts and how they will be addressed; the need to identify a specific ‘model’ (i.e PWR technology) before the Nuclear Regulator can consider any application for licensing of the plant; potential radio-nuclide emissions during accidents and significance of risk, to include details of criteria, documents and methodology used to reach conclusions; and clarification on criteria and documents to be used throughout the assessments.

It is clear that Eskom is now being challenged by the leading environmental watchdog in the country, which has the power to approve or reject the application. Affected communities need to monitor very carefully every step of this process, to ensure that the DEAT requirements are fully met.

Alternative sites
In a more recent development, DEAT has approved combining the EIA processes on the three selected sites into one EIA. This has been challenged by the St Francis Bay Residents Association and St Francis Kromme Trust as irregular, and clarification has been requested on the specific implications of this in terms of the stringency of the EIA process with regard to each site. One implication is that the EIA is no longer looking at alternative sites, since the three sites were the alternative sites. This is a requirement of the EIA process.

In this context, a further letter was recently sent by the St Francis Bay Residents’ Association and St Francis Kromme Trust to the Chairman, CEO and Nuclear generation spokesman of Eskom, and copied to DEAT, proposing that Eskom re-visit the possibility of siting the power station at Coega. The pros of Coega, and the cons of Thyspunt were clearly spelt out, with an emphasis on the vast infrastructural cost of using Thyspunt, and the possibility of using this money to mitigate any shortcomings in the Coega area. This letter also appears in full on the Residents’ Association website under “Nuclear”.

Public participation
The public in general may not be aware of the importance of public participation in the EIA process. This is a cornerstone of any EIA, and is enshrined in legislation. This is a two-way process, involving transparency and a proper flow of information from the developer to the public, as well as input by the public in the process at all stages. Much of the content of the terms of reference for the present specialist reports, as well as many of the conditions imposed by DEAT, are a direct consequence of public participation. There are opportunities at every phase of the process for public comment, and it is up to affected communities to be extremely vigilant, and to make their voices heard where there are valid concerns.

Whatever the merits of having a power station in the Eastern Cape, and these are acknowledged, this should not be at the cost of huge environmental, social, safety and economic damage to established communities, especially when there may be a preferable and viable alternative.

A period of sixty days will be allowed for public comment following release of the specialist reports. It is essential that these be read in detail to ensure that the terms of reference given to the specialists have been meticulously observed, that problem areas are clearly articulated, and that any proposed mitigation measures are credible. This will be the opportunity for the Kouga community to rally its forces to ensure that this piece of environmental and social vandalism is not permitted in this area.

Call for assistance
The issues raised by a nuclear site are wide-ranging and complex. The documentation put out by the consultants and specialists is unavoidably lengthy and not always reader-friendly. It would be wise of this community to pool its expertise in preparing for the various documents which will follow the EIA phase and will require responsible public comment. Anyone who has an interest, and especially any expert knowledge in this sphere, who would like to assist in developing a responsible and well-informed joint community response, is asked to contact the Chairman of the St Francis Bay Residents Association, Hilton Thorpe. P.O.Box 445, St Francis Bay, 6312; Tel 042 2940282/0836608909; or waterwaysbb@webmail.co.za.

To the Board and Senior Management – 16 June, 2009

Dear Mr Godsell, Mr Maroga and Tony Stott,

This letter comes from the above Residents’ Association and the St Francis Kromme Trust, an environmental body based in St Francis Bay. It concerns the siting of the proposed nuclear power station in the Eastern Cape.

It is very clear to this community that Eskom is set on its course to build a NPS at Thyspunt at the first available opportunity. This, despite the numerous environmental, safety, visual and social issues raised by the public and by expert consultants, regarding the suitability of the site. It is as if Eskom is like some super tanker, whose course was set in about 1982, and no matter what is done or said, nothing will deviate it from it.

Unfortunately, the EIA process does not require the positive motivations which led to the initial selection of Thyspunt. So far as we can understand, there are very few factors which really favour Thyspunt. It is close to the sea, but so are thousands of potential sites around the country. The only really strong point in Thyspunt’s favour would appear to be its geological and seismic foundation. Almost everything else points against it. The negative environmental impact will be massive. It is clear that the potential safety of the surrounding community, situated downwind with a strong prevailing wind, and with only one escape route for five communities, is now regarded as an acceptable risk. The visual impact of huge transmission lines, crossing areas of outstanding natural beauty and major tourism attractions, is shrugged off. The social problems for the St Francis area of the inevitable huge influx of unskilled and unemployed job-seekers, who will simply remain, living in total squalor, as is already the case here, are brushed aside. And finally the infra-structural cost of up-grading the road and bridge system, and the transmission lines themselves, amounting to billions of rands, seem to be of little concern. Surely, common-sense dictates that in such a situation, serious attention should be paid to other possibilities. We are not aware that this is happening.

Common sense dictates that, other things being equal, the obvious site for a power station in the Western half of the Eastern Cape is the Coega area.

Accepting that the Coega area may not be ideal from a geological perspective, the question raised, and which we request be fully considered, is whether there is not a site close to Coega, whose geological and other limitations could be mitigated adequately, at a lower expenditure than the several billion rands which will be required to render Thyspunt usable. If this were to be the case, there would seem to be no justification for pursuing the Thyspunt site. Commonsense dictates that, only if the Coega region is ruled out, following, an in-depth viability study, and despite the huge funds available to mitigate limitations, should Thyspunt even be considered as a site.

The delay in proceeding with the project, which is likely to be a lengthy one in view of the world economic situation, gives us a window period of opportunity to consider fully the Coega area as an alternative site, as is required by the EIA process. We therefore request that this be undertaken as a matter of urgency.

If serious attention has already been given to this possibility, in the light of the huge costs involved in developing Thyspunt, and it can be demonstrated that the Coega area could not under any circumstances be suitable, we request that we be given full details of the investigations undertaken.

Chairman, St Francis Bay Residents’ Association

Click here to read DEAT’s Response letter to FSR

2009/06/01
Guy Rogers ENVIRONMENT & TOURISM EDITOR rogersg@avusa.co.za
TONY STOTT

THE biggest nuclear plant in the world – four times the size of the one at Koeberg – could be developed at Oyster Bay. This was confirmed by Eskom at the weekend and came after the power utility had had a change of heart on the future roll-out of nuclear power stations.

Eskom‘s latest proposals for Oyster Bay have been slammed as a “farce” by environmentalists. The world‘s largest existing nuclear power station is the 8212MW Kashiwazaki plant in Japan. Asked to comment on reports that the size of the proposed Thyspunt, Oyster Bay, plant west of St Francis had been increased from 4000MW to 10000MW, Eskom nuclear spokesman Tony Stott said this was related to “long-term options”.

“Eskom has projected that 40000MW of new-generation capacity will be needed by the country by 2025 and it wants half of that to come from nuclear power. The first phase of investigations included an environmental impact assessment for a proposed nuclear power station with a generating capacity of up to 4000MW.

“However, to enable Eskom to consider the longer- term options for the supply of electricity in SA, knowledge of the maximum potential generating capacity in different parts of the country is important.”
The assessment that Eskom has applied to do, is for this reason evaluating the maximum capacity for each site and, to allow its specialist consultants to do this, Eskom has proposed that the specialists “assume a capacity range of a minimum of 4000MW (already twice the size of Koeberg) to a maximum of 10000MW”.

This does not necessarily imply that any of the sites will be approved for 10000MW, as environmental perspectives brought to bear in the assessment will be taken into account, he said. However: “If at some stage a requirement exists to increase the generating capacity on any of the sites, the information provided by the current EIA would be used … to obtain the required approvals for any generating capacity beyond the 4000MW for which the application has been made.”

Having initially short-listed five possible sites, two in the Western Cape and two in the Northern Cape, for the construction of a single pressurised water nuclear reactor, Eskom has now changed its focus, Stott confirmed.

“Eskom proposes to develop a nuclear power station at each of the three sites. The timing of Nuclear-1, Nuclear-2 and Nuclear-3 will be determined through energy planning processes and subject to National Energy Regulator of SA approval.

“Since the environmental impact assessment has not been completed, there is at this stage no decision from the Environment Department on authorisations for any of the three sites, and hence there is no finalisation on which site will be developed first.”

Asked about concerns raised, including that a nuclear accident could result in catastrophe because St Francis Bay and Cape St Francis are directly downwind from the plant, Stott said all concerns would be considered by the regulator, which would undertake “safety studies”.

But these studies can only be only take place “once the actual nuclear power station design has been chosen”, he said. St Francis resident Trudy Malan, operations chief for marine conservation organisation Ajubatus, said the jettisoning of the two Northern Cape sites was unacceptable.

“They admitted to us this was done for economic operational reasons rather than environmental ones – but in fact they are the two best sites from an environmental impact point of view. It makes the whole so- called environmental impact assessment a farce.” If a 10000MW station is built, Eskom will be operating in unknown territory, she said.

Ajubatus and other concerned parties are not yet fighting the Thyspunt plant from a nuclear angle, she said. “We are already having terrible problems with eroding beaches and if the plant is built on a moving dunefield, as planned, this could exacerbate that situation.”

The utility, which halted its nuclear bidding programme for Nuclear-1 in December last year, has now revised its application to the environmental authorities, asking to be allowed to combine authorisations to develop Nuclear-1, Nuclear-2 and Nuclear-3 power stations at all three coastal sites earmarked for the nuclear programme.

The three sites are Bantamsklip near Pearly Beach in the Overstrand, Thyspunt near Oyster Bay in the Eastern Cape and the Koeberg site of Dynefontein 30km north of Cape Town. At the start of the environmental impact assessment (EIA) the three places were to be assessed as alternative sites for the proposed Nuclear-1.

Now, because of amendments to the environmental legislation which are in the pipeline, Eskom has applied to Water and Environment Affairs to “sequentially construct” nuclear power plants at all three sites in a combined application, starting with Dynefontein, followed by Bantamsklip and Thyspunt.

“Thus specialists will no longer be required to compare, rank and provide recommendations with respect to a single preferred site”, but will only compare different layouts and positioning of the nukes on each site.

The application includes the “roll-out dates” for the first three nuclear power stations: site preparation for Nuclear-1 will start in January next year and the nuke will come online in July 2018; site preparation for Nuclear-2 will begin in January 2013 and come online in July 2020 and Nuclear-3 site preparation start in January 2015 and come online in July 2022.