Proposed pebble bed modular reactor


Cumulative and Linked ImpactS



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Cumulative and Linked ImpactS


  • 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.

  • HLW, as is the case with Koeberg NPS, will be managed on site for the life of the Proposed Plant to allow sufficient thermal cooling and radiological decay of the mother products. This has specific implications in terms of safety measures, security measures and non-proliferation protocols.

  • 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 conclusion of the consultants that the current requirements for Koeberg NPS will not be affected.

  • 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.

  • 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.

Recommendations


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.

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

  • The proposed activity is licensed by the NNR.

  • The Environmental Management Plans for Construction and Operation/Maintenance are implemented

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

  • Furthermore, it is recommended that:

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

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

6.ENVIRONMENTAL MANAGEMENT PLAN

Introduction


This environmental management plan (EMP) for the construction and operation/maintenance is developed to ensure that those activities of the PBMR demonstration module that have, or could have, a significant impact on the environment are appropriately controlled.

The EMP for Decommissioning will be developed at an appropriate stage during the operational phase of the project.

This EMP forms part of the final Environmental Impact Report (EIR) to be issued to the DEAT for a ROD and must be regarded as a dynamic document and a minimum requirements to be updated and detailed as the need arise. It is also available to I&APs for information purposes.

Scope

Purpose


The purpose of this document is to ensure that the final EMP requirements, as based on the findings and recommendations of the EIA, are included into all contracts and site specifications for the construction activities and operational/maintenance practices to take place for the PBMR demonstration module. The purpose of which shall be to ensure adequate management of activities that have or could have an impact on the environment.

Applicability


This specification is applicable to all construction and operational/maintenance activities associated with the PBMR demonstration module at the Eskom Koeberg Nuclear Power Station Site.

Accountability and Responsibility


The implementation, review and updating of these EMPs, for the construction and operation/maintenance of the proposed Plant, remain the accountability of Eskom, even where parts thereof have been contracted out to a 3rd party.

Responsibility for the various EMP measures must be clearly stated in all contracts, work orders and job descriptions together with reporting lines, format and frequency.

The appointment of an Environmental Control Officer (ECO) to advise, co-ordinate and monitor the implementation of the EMP’s must be considered as integral to the successful implementation of the EMPs. Such person shall enjoy direct reporting to the Project Manager for the Construction Phase, and the Power Station Manager for the operations/maintenance phase.

Authority Reporting


The various recommendations provided in the EMPs must be monitored and audited for progress and compliance and reflected in an Annual Report to be submitted to the DEAT and other relevant authorities e.g. the NNR, Water Affairs and Forestry, Provincial Government and Local Authorities.

Normative references


The following documents contain provisions that, through reference in the text, constitute requirements of this procedure. All standards are subject to revision and parties to agreements are encouraged to apply the most recent revision of the documents listed below. Information on currently valid national and international documents will be available from various Eskom centres, namely the Information Centre at Megawatt Park, the Technology Standardisation Department and the Generation Client Office document control section.

PSE, PBMR Environmental Surveillance Programme.

ESKPBAAD6, Environmental Management Policy.

ESKADAAP8, Nuclear Sites Management Policy.



KSA-085: Koeberg Standard: Requirements for the Environmental Management System.

Definitions


  • Environment. The surroundings within which humans exist and that are made up of:

  • the land, water and atmosphere of the earth;

  • micro-organisms, plant and animal life;

  • any part or combination of a) and b) and the interrelationships among and between them; and the physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health and well-being. (National Environmental Management Act. No. 107 of 1998)

  •   environmental issue:  Elements of an organization’s activities, products or services which can interact with the environment. (SABS ISO 14001)

  •   environmental impact: Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization’s activities, products or services. (SABS ISO 14001)

  •   environmental impact assessment (EIA):  A systematic process which involves collecting, analysing, interpreting and communicating data that will reduce negative impacts while enhancing positive impacts associated with new site-specific or area-specific activities, in advance of their implementation. (Department of Environmental Affairs and Tourism, 1998a; 1998c)

  •   environmental management plan (EMP):  A plan that seeks to achieve a required end state of the environment and describes how activities, that could have a negative impact, will be managed and monitored and how impacted areas will be rehabilitated.

  •   mitigate:  The implementation of practical measures to reduce adverse impacts or enhance beneficial impacts of an action.

  •   monitoring:  An activity that ensures that the requirements of the Environmental Management Programme are met.

  •   site:  the Koeberg Nuclear Power Station owner controlled area.

Abbreviations


  • DEAT: Department of Environmental Affairs and Tourism

  • EIA: Environmental impact assessment

  • EMP: Environmental Management Plan

  • EMS: Environmental Management System

  • GOR: General Operating Rules

  • KNPS: Koeberg Nuclear Power Station

  • NNR: National Nuclear Regulator

  • PBMR: Pebble bed modular reactor

  • PRA: Probabilistic Risk Assessment

  • QA: Quality Assurance

  • QC: Quality Control

  • ROD: Record of decision (as issued by DEAT)

  • SAR: Safety Analysis Report


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