Proposed pebble bed modular reactor
Western Cape Policy on Energy
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- Alternatives in terms of Energy and Technology
- Radiological Waste Management and Final Disposal
- Treaty on the Non-Proliferation of Nuclear Weapons and Materials of Mass Destruction
- Epidemiological Studies Radiologically Induced Cancers due to Commercial Nuclear Plants
- PROJECT ISSUES AND IMPACTS
- ASSESSMENT OF IMPACTS AND CUMULATIVE EFFECTS
- MITIGATION OF SIGNIFICANT IMPACTS
- PUBLIC PARTICIPATION DURING THE EIA PHASE
- GAUTENG: Hartbeespoort Johannesburg Atteridgeville KWAZULU-NATAL
- AVAILABILITY OF THE (FINAL) EIR
- TIME FRAME FOR THE EIA PHASE
Western Cape Policy on Energy The Western Cape policy titled “Preparing the Western Cape for the Knowledge Economy of the 21st Century” deals with energy on page 50. The energy section reads that the energy objectives is aligned “with the National Governments 1998 White Paper on the Energy Policy of the Republic of South Africa of cost effectives, sustainable and environmentally friendly energy policy for the province ……” The policy further states that it will “support(ing) and take(ing) full advantage, in particular, of the economic and environmental opportunities presented by the distribution of natural gas by the proposed long-distance pipeline from the Namibian Kudu gas field to transform the energy of the Western Cape from Coal-based and nuclear power to thermally efficient and clean gas-fired power”. A foot note is added: “the prospects of a large natural gas field off the West Coast in the Northern Cape could, if realised, further expand the possibilities for cleaner and more efficient gas-fired power stations in South Africa in genera, and the Western Cape in particular”. This does not appear to be in conflict with national policy. This provincial policy is furthermore an “activity” as defined by Section 1 of NEMA and must comply with the principles and provisions of that Act. While the draft EIR reported an “apparent conflict between the Western Cape’s and National policy on energy” the above extracts indicate otherwise. However, interpretation of the Western Cape’s policy by various provincial and local authorities clearly demonstrate a concern with the establishment of further nuclear power generation on the Koeberg Site or the extension of the operational life of the existing Koeberg N.P.S. The EIA Consortium maintains that interpretation of the policy and its implementation requires resolve at an institutional and authority level. Such resolve, however, does not constitute a pre-requisite for a “Record of Decision” (RoD) by the DEAT or a fatal flaw to the proposed activities.
Both the EIA regulations and the Energy Policy White Paper stipulate the consideration of alternatives (e.g. energy, technology, etc). While the proposed demonstration Plant will be linked to the national grid, this application is, not a commercial application for nuclear based power generation, but for the establishment of a demonstration Plant6 to inform on the techno-economics of the specific plant. In turn, this will inform the IRPP of government and Eskom’s ISEP with accurate information and the study 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.
A draft National Radioactive Waste Management Policy (NRWMP) was issued by the DME in 2001 for public comment (Annexure 4). 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 DME 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 (LLW) and intermediate level (ILW) radiological waste(s) are well guided by policy, and, final deposition facilities with sufficient capacity for these wastes 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). The absence of a HLW repository is not seen as a prerequisite for a RoD by the DEAT or a fatal flaw to the proposed activity.
Much confusion exists in the public domain about the scope of the Nuclear Non-Proliferation Treaty. Some members of public interpret/perceive the Treaty to intend the total absence of the use of nuclear materials, processes, technology etc. within national boundaries. 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. It thus has application to the non-proliferation of nuclear weapons as well as 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. In this regard 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 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. It is quite clear that the proposed Plant and associated fuel manufacture facilities have a direct bearing on the Government’s obligations in terms of this Treaty and the Pelindaba Treaty. Government will discharge their duties accordingly. 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.
During the Scoping Phase of this EIA the issue was raised that real time health risk or epidemiological7 studies should/must be conducted as part of the detailed studies to inform this EIR. 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. The accepted approach to this study (PoS as approved by DEAT) was to review and be guided by international literature on the subject. (Annexure 3 provides papers from international research on the subject), to the accepted approach to this study (PoS as approved by the DEAT) was to review and be guided by international literature on the subject of epidemiological studies on cancer included health effects due to low level radiation releases (operational releases) from nuclear plant (Annexure 3 provides papers from international research on the subject), to decide on the desirability of such studies prior to, or during the operation of the proposed Plant. Much international epidemiological research is being (and has been) conducted on the subject, with opposing conclusions on the relationship between cancer incidence and radiation releases from commercial nuclear installations. However one of the primary aims of such research is to determined the safe levels (release standards) for the release of radioactive substances from nuclear installations, to safeguard the health of persons and the environment. The International Commission for Radiological Protection (ICRP) is the international body that advises on such standards and have progressively reduced radiological discharge and exposure levels. Over time very strict international standards have been established to which South Africa subscribes and which is reflected in the Fundamental Safety Criteria of the NNR. By nature these epidemiological studies are complex, needs to extend over at least 15 to 20 years, the population must be stable (i.e. low influx or exit from the population, and preferably start before the commissioning of a commercial nuclear plant to provide meaningful results. Epidemiological study and health monitoring of the public for the proposed Plan is not recommended or required, provided that the recommendations as contained in this EIR and the NNR’s conditions are met. Assurance that the practices carried out conform to requirement, must be demonstrated on an ongoing basis through operational and environmental monitoring programmes (as detailed in the EMP, Chapter 8), 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).
The seriousness of HIV/AIDS is a real concern on international and national level every effort must be made to restrain and curb the epidemic phase of this disease. Eskom has established a comprehensive policy, practices and support programme to address the disease in a positive, informed and non-discriminatory manner, with the co-operation of all employees. The main features of the policy entails the following:
The policy will be applied during the construction phase of the proposed plant and be maintained during the life cycle of the Plant. Of specific concern to the authority(ies) and the public is the issue of radiological safety to man, property and the environment. 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. The EIR confirms conformance to the fundamental safety criteria laid down by the National Nuclear Regulator (NNR) (Chapter 4.20.5).
For the purposes of the EIR, the impacts/issues/concerns which were studied and addressed are divided into four main groups, namely:
The following social studies were undertaken:
The biophysical aspects considered included the following:
The technical aspects considered encompassed the following subjects, namely:
The potential impacts for the proposed Plant were assessed for the full life cycle of the proposed Plant and for significance by employing the Significance Rating Methodology as specified by the DEAT8. A panel was established to rate and rank the various impacts/issues/ concerns. The Panel consisted of the following members; namely:
Mr O Graupner - Poltech (Division of IRCA Technical Services) Mrs A Haasbroek - Poltech (Division of IRCA Technical Services) Mr W Schlechter - Netrisk (Division of IRCA) Mr F Mellet - Netrisk (Division of IRCA) Mr J de Villiers - Netrisk (Division of IRCA) Mr W Lombaard - Poltech (Division of IRCA Technical Services) Mrs K Botes - Interdesign Landscape Architects (Pty) Ltd Dr D de Waal - Afrosearch Mrs H van Graan - Nuclear Consulting International Mr N Andersen - Andersen Geological Consulting Dr M Levin - Africon (Pty) Ltd Mr G Erasmus - Ledwaba Erasmus Associates Mr P van Wyk - J Paul van Wyk Urban Economist and Town Planners
Technical information and explanation was provided by representatives from Eskom, Necsa and PBMR (Pty) Ltd. During the EIA phase possible links between impacts were considered and assessed, i.e. cumulative, linked and induced impacts. Annexure 20 provides the CV’s of consultants that participated in the EIA.
An Environmental Management Plan (EMP), which describes mitigation measures for the management of the proposed Plant’s construction and operational/maintenance impacts is included in the EIR. Through design, provision has been made to minimise the impacts of decommissioning/dismantling (i.e. materials employed, layout, etc). A more detailed EIA will be conducted prior to Plant closure to define and assess the impacts and prescribed mitigation measures.
Issue based consultation was conducted with identified I & APs which included:
These consultations focused on project and site specific issues that informed the Information Document (Vol II) and the Social Impact Assessment. The availability of the draft EIR was notified to I & APs direct and through media releases (advertisements in the daily press and on radio).
Seven public meetings were held between 16 and 30 May 2002, to provide feedback on the draft EIR. I & APs were given the opportunity to provide input on the draft EIR from 4 June to 4 August 2002. Extension of the review period to 4 September 2002, was provided to a number of I & APs on request and in conjunction with the DEAT. The Public Meetings were held in the following areas:
Minutes were taken at all public meetings and circulated for comment before finalisation. In addition a presentation on the findings, conclusions and recommendations of the draft EIR was made to the Western Cape Cabinet at their request. At the request of the Atlantis community, a further meeting was held in Atlantis on 1 August 2002.
Registered I & APs received (either by post, fax or e-mail) notifications on progress with the project, consultation sessions, public events, information availability and the availability of the EIR: During the EIR phase the following information was available to I & APs:
The final EIR is available in hard copy, CD and on the website (http//www.pebble-bed.co.za). Hard copies of the document were distributed to public libraries and venues throughout the study area. The Executive Summary of the project’s scope, main findings and recommendations (EMP) was translated into Afrikaans, Zulu, Xhosa and Sesotho and is available in hard copy and on the web site (http//www.pebble-bed.co.za).
For the purpose of the EIA phase the following milestones were established, namely:
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