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31.3 Tools and Inputs

This section provides information on the various mechanisms employed during the public participation process. Details will also be provided on the advertising and notification procedures. The following tools and mechanisms were utilised:

Ü        Continued registration of I&APs;

Ü        Providing I&APs with information in the form of an Information Document (Volume I and II);

Ü        Structured interviews in a focus group/individual format;

Ü        Written submissions received from I&APs;

Ü        Public Meetings; and

Ü        Public Review of the Draft EIRs.

31.3.1 Identification of Interested and Affected Parties

Through networking and advertisement, 2738 I&APs are currently registered on a database. Afrosearch endeavoured to ensure that individuals/organisations from a 'vertical' (institutional) as well as a 'horizontal' (geographical) point of view are identified.

Geographically, Afrosearch focused on nearby landowners and residents and the organisations that represent them. A 'vertical' approach was used to identify those institutions or individuals that might be affected by, or could make a contribution to the project, but who are not necessarily in its direct sphere of impact.

Periodically, registered I&APs' details are verified.

31.3.2 Information document (Volume 2)

Note: Refer to Annexure 14 for the Information Document (Volume II).

In April 2002, an Information Document (Volume 2) was compiled. This document is in a questions and answers format (as was the Information Document Volume 1). The objective was to supply information on frequently asked questions, under a number of main headings.

31.3.3 Structured Focus Group and Individual Interviews and Meetings

Focus group meetings are used as a valuable tool to obtain detailed information ranging from statistics and facts to emotive feedback from a sectoral perspective. For this process, a focus group meeting was defined as a meeting where I&APs, who share a common sectoral focus, were brought together to discuss the project and identify questions, concerns and issues. An individual meeting was a meeting where only one representative of a specific organisation was met with or if the individual had a particular function such as a mayor.

The focus group meetings were conducted as a formal meeting, which was chaired by a member of the EIA Consortium. Issues identified by I&APs were formally recorded. Records of issues raised were provided to participants for comment and correction. Issues identified were entered into the issues register.

Table 31‑51: List of Focus Group Meetings held for the EIA phase

Table 31‑52: List of Focus Group Meetings held for the EIA Phase

The main objective of a public meeting during the EIA Phase is to give the public the opportunity to receive feedback on the findings of the specialist studies. Furthermore, public meetings are an important platform by which information assimilated during the consultation process can be verified. Presentations are made regarding the technical studies, the conclusions and the recommendations of the Consultants.

For the two projects, a series of public meetings will be held in the Western Cape, Durban and the Pelindaba area. As indicated in (Figure Error! No text of specified style in document. -13 : Public participation timeframes for the EIA phase) the initial notification (newspaper and communication with registered I&APs) for the Public Meetings took place between 23 April and 03 May 2002. The dates of the Meetings were as follows:

Ü        Thursday 16 May 2002 at 18:30 (Hartbeeshof Service Centre, 125 Kuyper Street, Schoemansville);

Ü        Saturday 18 May 2002 at 10:00 (Mobolekwa Hall, C/o Sehloho & Sethole Street, Atteridgeville);

Ü        Tuesday 21 May 2002 at 18:30 (Ferndale Community Centre, C/o Harley Street & Surrey Avenue, Randburg);

Ü        Thursday 23 May 2002 at 18:30 (Durban Exhibition Centre (Hall 6) 11 Walnut Road, Durban);

Ü        Tuesday 28 May 2002 at 18:30 (Jan van Riebeeck High School, 129 Kloof Street, Cape Town);

Ü        Wednesday 29 May 2002 at 18:30 (Atlantis Secondary School, Palmer Avenue, Atlantis); and

Ü        Thursday 30 May 2002 at 18:30 (Jansen Hall, Jansen Street, Milnerton).

The following steps were taken to inform and remind I&APs and the public of the meetigs   and  )

Table 31‑53: Notification of Public Meetings for the EIA Phase

v         Public Meetings were specifically arranged for Atteridgeville and Atlantis.

v         Formal and informal leaders in Atteridgeville, Diepsloot, Atlantis, Mamre, Khayelitsha and Langa were contacted and informed;

v         Street Posters were put up in Atteridgeville, Mamre and Atlantis and flyers were distributed.

v         Permission was obtained from the respective Departments of Education to distribute information to the schools. All schools in Atteridgeville (33) were informed of the Public Meetings on 24 April 2002 and those in Mamre, Atlantis (and Milnerton) (23) were informed of the Public Meetings on 13 May 2002.

v         The public libraries in Avon, Mamre, Khayelitsha (and Milnerton) were asked to display posters advertising the Public Meetings in an obvious place.

v         A Xhosa advertisement advertising the Public Meetings were placed in the City Vision in the Western Cape.

v         The table below indicates the different media where press releases regarding the Public Meetings were sent. Especially radio is regarded as a prime method of communicating to persons who live in disadvantaged communities.

Table 31‑54: Notification of Public Meetings for the EIA Phase

31.3.5 Public Review of the Draft EIRs

Sixty days is allowed to comment on the reports to provide the PBMR EIA Consortium with comments. During the review period for the draft EIRs, hard copies will be distributed for public review and comment in a number of publically accessible venues (36 countrywide) (see Table X below). A copy will also be available on the website (www.pebble-bed.co.za) and CD-Roms containing the draft EIRs and Supporting Documentation will be made available on request.

Table 31‑55: Venues where Draft Environmental Impact Reports were available for comment.

A table of the comments received will be made available as part of the Final EIR.

31.3.6 Written Submissions Received from I&APs

Letters/e-mails/faxes will be received from I&APs informing the Consortium of their comment on the Draft EIR. Copies of each communication, along with the response sent to the person/organisation will be kept on file for record purposes.

31.3.7 Issues Registers

32.   conclusions

The conclusions of the EIR are dealt with in 4 parts, namely:

Policy/Strategic Issues and Impacts

Ü        Project Related Issues and Impacts

Ü        Projected Related Issues and Impacts

Ü        Cumulative Issues and Impacts

Ü        Linked Impacts

32.1 POLICY/STRATEGIC ISSUES AND IMPACTS THAT IS REPORTED ON

32.1.1 National Energy Policy White Paper

Government has persued its obligations and objectives on the proposed Plant from a technical, economic and environmental point of view. To this end an Expert Review Panel was appointed by the Department of Minerals and Energy to assess the adequacy of information of the Detailed Feasibility and Design Studies; an EIA is being conducted to fulfill the requirements of the Environmental Conservation Act (Act 73 of 1989) and the National Environmental Management Act (Act 107 of 1998); co-investors were secured to assist with the financing of the detailed feasibility and design studies and to gauge international acceptance and markets; the safety assessment of the design for licensing through the NNR, and ultimately the joint decision process of the Cabinet on the desirability to progress to follow-on phases.

The PBMR Plant will:

Ü        Inform the Integrated Resource Planning Process (IRPP) as stipulated in the Energy White Paper to provide guidance on the future use of the technology. This is especially so since demonstration plants for other technologies (e.g. wind, solar thermal and biomass) will be implemented by Eskom and Independent Power Producers (IPPs) in close succession with the Plant.

Ü        Broaden the energy mix for electricity supply.

v         Western Cape Policy on Energy and Spatial Development

These policies form part of the Western Cape Province’s broad vision and policy on “Sustainable Development.” There is an apparent conflict between the Energy Policy, which declares and intends to establish the Western Cape Province as a nuclear free region and the existing nuclear facility in the Province namely Koeberg NPS. While only a broad time horizon is stipulated the Provincial Authority for Economic Affairs and Tourism emphasised that the establishment of the Plant on the Koeberg Site “provides a definitive conflict with the Provincial Policy’s intent. This position is compounded by the development restrictions which Koeberg NPS places on the Spatial Development Framework for Blaauwberg sub-structure. These issues will require resolution at a national policy and governance level.

v         Alternatives in terms of Energy and Technology

Both the EIA regulations and the Energy Policy White Paper stipulate the consideration of alternatives (e.g. energy, technology, etc). This application is, however, not a commercial one for nuclear based power generation, but for the establishment of a demonstration Plant¹⁴⁴ to inform on the techno-economics of the specific plant which, in turn, will inform the IRPP of government, Eskom’s ISEP and the consideration of alternatives. Once this stage has been reached (probable in the years 2006 – 2008) more informed decisions can be made on commercial energy mixes for electricity supply and management.

32.2 Radiological Waste Management and Final Disposal

A draft National Radioactive Waste Management Policy (NRWMP) was issued by the DM& E in 2001 for public comment.

This draft Policy is strategic in nature and sets out the principles and scope for the management of radiological waste(s) generated by the various sectors of the economy e.g. the mining sector, medical sector, food sector and electricity supply sector.

The draft Policy is currently under review by the DM&E and it is understood that it will be re-issued in late 2002 for comment.

Once this Policy is in place, more directive policies for the various economic sectors and types (classes) of radiological waste (i.e. low, intermediate and high level) may be formulated and issued.

While low level and intermediate level radiological waste are well guided by policy and final deposition facilities exist there is a real need to accelerate the establishment of a Policy and facility(ies) (repository) for the long term management and disposal of long lived radioactive waste i.e. high level radioactive wastes (HLW).

32.1.3 Treaty on the Non-Proliferation of Nuclear Weapons and Materials for Mass Destruction

In brief this Treaty makes provision for the international regulation of nuclear and other materials or precursory materials that may be employed for the manufacture, harbouring and use of devices or weapons of mass destruction.

The Treaty therefore addresses the non-proliferation of nuclear weapons.

This has specific and implied meaning for the use of such materials for commercial application since they must be declared and fully accounted for at national and international level.

The Minister of Minerals and Energy functions as the national governor for the implementation of this Treaty, and Safeguards Agreement.

The implementation of the Safeguards Agreement require that Subsidiary Agreements be established for the various nuclear facilities that are under safeguards. For example, a Subsidiary Agreement exists (and has always existed) for Koeberg Units 1 and 2. A Subsidiary Agreement existed for the previous BEVA plant where accounting to gram quantities of uranium was required. Similar Subsidiary Agreements would have to be developed and signed for the PBMR Fuel Manufacturing Plant as well as for the proposed PBMR Demonstration plant. The design and mode of operation of the respective proposed facilities will form part of the negotiations with the International Atomic Energy Agency (IAEA) in developing the Subsidiary Agreements.

In addition, South Africa was instrumental in the formulation of the Pelindaba Treaty or the African Nuclear Weapon-Free Zone Treaty. It should be noted that this Treaty is about keeping Africa free of Nuclear Weapons. It promotes co-operation in the peaceful uses of nuclear energy and recognises the right for countries to develop research on, the production of and use of nuclear energy.

The Treaty states that parties to the Treaty are determined to promote regional co-operation for the development and practical application of nuclear energy for peaceful purposes, in the interests of sustainable social and economic development of the African continent.

32.1.4 Epidemiological Studies

Established national and international standards require very strict radiological surveillance of staff and the environmental media (air, water, soil and wildlife). The undertaking of prior epidemiological studies on the public is not stipulated in South African legislation, nor is it part of any international standard set for nuclear power station facilities.

The National Nuclear Regulator Act (Act 47 of 1999) provides for the regulation of nuclear activities and to exercises the regulatory control and assurance on the health/safety of workers, property and the environment.

It should be noted that no credible correlation has been established between health effects and the routine operation of commercial nuclear facilities anywhere in the world. Widely accepted investigations, such as the comprehensive 1990 National Institutes of Health (NIH) study of some one million cancer deaths in people living near nuclear power plants in the USA, demonstrates no correlation between cancer deaths and plant operations. Investigations carried out in Canada, France, Japan and the United Kingdom support the NIH results¹⁴⁶

Copy of such epidemiological work is provided as an Annexure 3 to the EIR.

Epidemiological study and health monitoring of the public for the proposed Plan is not recommended or required. Assurance that the practices carried out conform to requirement must be demonstrated through operational and environmental monitoring programmes, health monitoring of employees and conformance to the legal requirements as administered by the NNR and in terms of the Occupational Health and Safety Act (Act No. 85 of 1993).

32.1.5 Radiological Safety

This EIR reports on the safety features related to the design and operation of the Plant as well as that of radiological waste management whether gaseous, liquid or solid and confirms conformance to the fundamental safety criteria laid down by the National Nuclear Regulator (NNR).

32.2 PROJECT RELATED ISSUES AND IMPACTS THAT WERE ASSESSED

32.2.1 Construction represents the phase which potentially holds the biggest adverse impacts, namely:

Ü        Temporary concentration, with limited influx, of construction workers with resultant traffic, services and resource requirement. This is largely off-set with better income and local spending, though of a limited duration. On a regional and national scale, component manufactures will further off-set adverse impact as well as the upgrading of some utilities i.e. water supply and electricity.

Ü        Changes to the aesthetic (visual) character that will manifest and become acceptable over time.

Ü        Generation of construction waste(s) and spoil that needs to be disposed off at existing disposal facilities or re-used and rehabilitated.

All the adverse construction impacts can be successfully managed within acceptable levels, provided that a Construction EMP is implemented and monitored.

32.2.2 For the operations/maintenance phase no significant adverse radiological and non-radiological impacts were identified. However, the implementation and monitoring of an operational EMP remains a prerequisite.

32.2.3 The design of the proposed Plant makes provision for simplified and streamlined decommissioning and dismantling from a radiological point of view.

32.2.4 From a Social Impact Assessment point of view a number of important conclusions/recommendations are made which reinforce those already stated above.

Of particular note is the need for the provision of objective and, reliable, information dissemination and risk communication. For this reason it is seen necessary that an organisation such as the African Commission on Nuclear Energy (AFCONE), formed to oversee compliance in respect of the Organisation of African Unity’s Treaty of Pelindaba, be formally requested to extend its activities under Article 12 of the Treaty to educate and inform the public on the real risks and issues related to “the peaceful use of nuclear energy for the betterment of society”.

32.2.5 From an Economic point of view the demonstration Plant will:

Ü        Provide some 1 400 local jobs over the construction period

Ü        Provide some 40 permanent jobs

Ü        Place capital expenditure preference on local content, where possible.

32.3 FROM A CUMULATIVE AND LINKED IMPACT POINT OF VIEW THE FOLLOWING:

Ü        The cumulative effects of the proposed PBMR Plant are largely in association with the Koeberg NPS. These effects and impacts will largely fit into the footprint of Koeberg.

Ü        During construction traffic volumes and patterns will be affected by commuters, material/equipment supplies and abnormal loads. Import of abnormal items will be routed via Saldanha harbour.

Ü        Radiological discharges (gaseous, liquid and solid) will fit into the Annual Authorised Discharge quantities (AADQ) for Koeberg. The NNR will decide on the emergency planning exclusion and evacuation zones. It is however the opinion of the consultants that the current requirements for Koeberg NPS will not be affected.

Ü        The only linked impact of the proposed demonstration module PBMR, and, the fuel Plant proposed to be established at Pelindaba, is the cumulative low and intermediate level radioactive waste to be transported to and disposed of at, Vaalputs. The relatively low quantities of material to be generated render this linked impact insignificant.

32.4 RECOMMENDATOIN

The EIA Consortium identified no significant environmental risk(s) or adverse impact(s) in part or on the whole that can not be adequately managed and mitigated over the life of the Plant.

Ü        It is therefore recommended that the Department of Environmental Affairs and Tourism authorize the proposed activity provided that:

v         The Environmental Management Plans are implemented

v         Financial provisions are made for decommissioning and the long-term management and storage of radioactive waste in particular HLW.

Ü        Furthermore, it is recommended that:

v         the DM&E accelerate the establishment of National Radioactive Waste Management Policy.

v         An information process (centre) is established by government to objectively inform the public on nuclear matters.

33.   ENVIRONMENTAL MANAGEMENT PLAN

33.1. PURPOSE

The purpose of the Environmental Management Plan (EMP) is to provide the Applicant with a plan to meet both current and future environmental requirements and challenges.

This document is a dynamic document that would require updating as the project progresses through its life cycle. It should therefore be seen as the foundation of an Environmental Management Plan for the Demonstration Pebble Bed Modular Reactor at Koeberg and the associated transport of nuclear materials, and not the end result or complete plan.

33.2. INTRODUCTION

Modern society and legislation demand that environmental consequences of developments are understood and adequately considered in the planning process. The Applicant is committed to the above approach and therefore has commissioned a comprehensive Environmental Impact Assessment (EIA) for the proposed Demonstration Pebble Bed Modular Reactor at Koeberg. The findings and conclusions of the EIA are contained in the Environmental Impact Report. Authorities will consider the above findings and conclusions during the evaluation of Application to Proceed.

In the event that the proposed development is deemed to be feasible, and the authorities approve it, it is essential that negative impacts are resolved or mitigated and positive impacts enhanced during the full life cycle of the project. Mentioned mitigation and enhancement of environmental impacts can best be achieved through a formal Environmental Management Plan and Environmental Management System.

33.3. ENVIRONMENTAL OBJECTIVES AND TARGETS

Objectives and targets were developed for those impacts assessed during the Environmental Impact Assessment to be of sufficient significance.

33.4. ENVIRONMENTAL MANAGEMENT PROGRAM

A comprehensive Environmental Management Program has to be compiled during the detailed planning phase of the proposed project. The above program has to reflect the person responsible for each of the objectives and targets, as well as the performance indicators and proposed activity.

33.5. IMPLEMENTATION AND OPERATION

The Environmental Management System could be based on an international accepted model, such as that described in the ISO 14000 documentation.

Table 33.1‑1: ENVIRONMENTAL IMPACTS, OBJECTIVES AND TARGETS FOR THE DEMONSTRATION PEBBLE BED

34.   abbreviations/actonyms

ACRONYMS AND ABBREVIATIONS

AVR : Arbeitsgemeinshaft Versuchsreaktor

BISO : Buffer isotropic pyrolytic carbon

CRWMS : Civilian Radioactive Waste Management System

DOE : U.S. Department of Energy

FY : Fiscal Year

HTGR : High-temperature gas-cooled reactor

LWR : Light Water Reactor

MHTGR : Modular High-Temperature Gas Reactor

PBMR : Pebble Bed Modular Reactor

Pu : Plutonium

PWR : Pressurized Water Reactor

QA : Quality Assurance

SNF : Spent Nuclear Fuel

TRISO : Oxide fuel particle coated with coated with layers of a low-density

buffer, inner pyrocarbon, silicon carbide, and outer pyrocarbon.

TSLCC : Total System Life Cycle Cost

TSPA : Total System Performance Assessment

U.S. : United States

WP : Waste Package

 

SYMBOLS AND UNITS

cm : Centimeter [one-hundredth of a meter (10^-2 m)]

GWe : Gigawatt electric (one billion watts of electric generated)

GWd : Gigawatt-days

kg : Kilograms (1000 grams)

kW : Kilowatt (1000 watts)

kWhe : Kilowatt Hours Electric

M : One million (dollars)

2

m : meter

micron : One-millionth of a meter (10^-6 m)

MTHM : Metric Tons Heavy Metal

MTIHM : Metric Tons Initial Heavy Metal

MTU : Metric Tons of Uranium

MWd : Megawatt day

MWe : Megawatt electric (generated)

MWt : Megawatt thermal (energy)

UO₂ : Uranium Oxide