GENERAL EMP Specifications During Construction

Social issues

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  While the contingent of international workers during construction and operation of the proposed PBMR will not be large, it does serve as an opportunity for local service providers to extend their current client base. Allowing for maximum equal offset opportunities for service providers, must be promoted. ¹⁵⁹
  
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  The availability of international specialists provides an opportunity to promote knowledge/skills transfer to the local in-house competence and expertise of South African workers. It is recommended that it be a requirement that international specialists provide mentoring where appropriate for South African specialists. ¹⁶⁰
  
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  It is recommended that staff bind themselves to a code of conduct aimed at ensuring that pro-social behaviour is maintained. ¹⁶¹
  
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  The conduct of contract workers would have to be specified in worker related management plans and employment contracts. It is suggested that a peer-group based incentive/fine scheme, which has been successfully used in other projects to achieve compliance, be introduced.¹⁶²
  
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  Eskom should (as far as is practicable) make the appointment of local labour for construction activities a priority issue. ¹⁶³
  
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  An employment/skills registration agency or ‘labour desk’ should be put in place to identify prospective candidates who would meet the job specifications. Such an agency/desk would have to take responsibility for accurate information dissemination at community level. Experience has shown that formalising this process through such an agency avoids duplication, misrepresentation, confusion and unrealistic expectations. The number of persons required, as well as the specific skills required in respect of each worker should be specified as soon as possible. It is also important to clarify project time frames and when candidates from local communities are anticipated to be required. ¹⁶⁴. Informing local businesses and structures like the tourist and business forum regarding direct business opportunities associated with the project, is also strongly recommended. ¹⁶⁵
  
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  It is common practice for local informal vendors (notably women providing cooked food) to enter construction areas, given the new business opportunity provided by the construction workers. Due to requirements for security, it is believed that the PBMR construction site will not readily lend itself to this practice. Nonetheless the possibility to allow this practice through the allocation of a designated area where vendors could ply their trade, must be considered by Eskom. ¹⁶⁶
  
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  The contract and tender documentation in respect of the work to be undertaken during the construction phase will need to ensure that affirmable procurement practices as well as mechanisms for the active promotion of employment equity are put in place. Ensuring that local workers will gain access to employment opportunities through optimisation measures such as the establishment of a labour desk, etc. are recommended. ¹⁶⁷
  
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  Standardised communication and dispute resolution procedures in respect of employment creation and training are advised. The needs to be standardised in the form of contract provisions, specifying input (skills development; job-creation plans) and output key performance indicators (actual evidence that local contractors & labour is being used). ¹⁶⁸
  
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  Construction staff for the PBMR demonstration module will impact on the transient population numbers especially in the 0 – 5km and 0 – 20km concentric sector around the Station. This aspect needs to be incorporated into the Emergency Response Plan for the Koeberg NPS and the proposed Plant and communicated with the relevant players (e.g. emergency teams and liaison committees) and become part of the Communication actions pursued by the Koeberg NPS. ¹⁶⁹
  
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  The development of an integrated on- and off-site Emergency Response Plan for Koeberg and the proposed PBMR demonstration module should include mechanisms for communicating potential risk, health and safety information to affected communities as part of a pro-active risk communication strategy.¹⁷⁰
  
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  In terms of mitigation (if the PBMR is implemented), it would be necessary to (1) clarify whether existing emergency plans for Koeberg require any overview and adaptation and would apply to the PBMR; (2) clarify issues regarding evacuation specifically for Koeberg; and (3) rehearse emergency plans – specifically for Koeberg - in association with the local emergency services and community organisations. ¹⁷¹
  
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  The SAP as well as local appropriate policing forums should be urged to ensure that baseline statistics are available regarding existing crime rates and should, proactively engage with Eskom in developing mechanisms for monitoring and the distribution of information to counter potential community perceptions that there are perceived changes in the crime rate directly as a result of construction workers being in the immediate area. ¹⁷²
  
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  Care should be taken that persons with possible criminal intent are not in a position to use the increased activity during the construction phase as a ‘cover’ or platform to launch opportunistic criminal activities.¹⁷³
  
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  Meetings should be arranged with residents’ associations, community policing forums, as well as the local police personnel to discuss contractors’ plans, procedures, schedules and possible difficulties and safety and security concerns. Proactive discussions between the contractor(s) and project proponents have been found to be effective in addressing concerns and putting possible preventative measures in place.
  
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  As far as possible, the movement of construction workers should be confined to the work site to avoid any potential for impact or interference with proximate residential areas. ¹⁷⁴
  
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  Health and Safety Management Plans should be developed in respect of construction worker safety. ¹⁷⁵
  
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  The promotion of an understanding of radiation, radiation exposure and nuclear power-related activities is seen as a central requirement in initiatives to reduce the levels of fear and anxiety emanating from perceptions about nuclear-related risks. The development of an honest, transparent and comprehensive awareness creation campaign for the dissemination of information about energy generation and nuclear and other technologies (as currently being promoted by Eskom) is seen as an important requirement for Eskom.¹⁷⁶
  
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  The development of an integrated on- and off-site Emergency Response Plan for Koeberg Nuclear Power Station and the proposed PBMR demonstration module should include mechanisms for communicating potential risk, health and safety information to affected communities as part of a pro-active risk communication strategy.¹⁷⁷
  
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  Traffic congestion. The off-site movement of construction vehicles should, as far as is possible, be limited to off-peak periods in order to avoid exacerbating the existing congestion of roads.¹⁷⁸
  
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  An effective risk communication strategy must be established. The following serve as guidelines that may be formulated and introduced prior to a crisis and implemented during a crisis¹⁷⁹:¹⁸⁰
  

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  Involve the most senior person at Eskom to communicate with the public.
  
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  Offer information on a pro-active and voluntary basis and involve the public from the outset.
  
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  Work first and foremost to earn trust and credibility.
  
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  Do not give mixed messages and ensure that all information has been checked and double-checked for accuracy.
  
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  Tell the truth at the outset, instead of attempting to salvage the situation later.
  
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  Provide substantive information that meets people’s needs and pays attention to community fears and concerns rather than only communicating “scientific data” thus acknowledging that response to risk is more complex than linear response to the facts.
  
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  Wherever practicable, enlist the help of organizations that have credibility in communicating with communities.
  
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  Be sensitive about the fact that people believe that nuclear related activities have been cloaked in secrecy for decades and that visible proof should be offered that international and national rules, agreements and regulations are being adhered to at all times.
  
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  While not essential, it is believed that it would be advantageous to ensure that a monitoring function will be implemented. The Environmental Officer could fulfil this role, although community involvement in monitoring is desirable. It is further suggested that a toll-free complaint service be initiated and that the access number for this service is sign-posted at key impacts sites, for use by the public. Co-operation with local traffic law enforcement agencies would be important to ensure compliance with traffic legislation.¹⁸¹
  

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  It is recommended that an information programme on power generation and nuclear technology within the broader sciences and mathematics framework be developed. The development of a bursary fund to allow promising scholars from previously disadvantaged communities to complete higher education (secondary and tertiary) and gain access to mentoring programmes would serve to directly contribute to the promotion of equity. ¹⁸²
  
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  Overnight accommodation inside the Koeberg owner controlled area shall not be allowed.
  
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  A plan of action shall be established with the neighbouring property owners and the relevant authorities in the case of an emergency (veld fire, oil spillage, water contamination, etc.).
  
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  All complaints received by Eskom or its contractors must be recorded and investigated in compliance with a procedure.
  
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  An HIV/AIDS programme shall be implemented based on Eskom’s policy and practices. Eskom has established a comprehensive wellness programme, intended to address the well being of individuals and groups. The programme consists of employee assistance, sports and recreation; managing the impact of HIV/AIDS, biokinetics, spiritual wellness, occupational health and medicine, travel medicine and health promotion. Health and wellness teams have been created to implement the total integration of services, information sharing and allocation of resources. The key focus areas for HIV/AIDS remain education, communication, care and support, self-awareness and the management of associated risks.
  
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  Continuation of the Koeberg Liaison Forum and extension of the forum to include the PBMR demonstration module. This Forum should be made up of representatives of local groups from Atlantis, Melkbosstrand and Table View (surrounding communities to the Koeberg and site for the PBMR demonstration site). Meetings to continue to take place every quarter and cover events and issues relating to Nuclear, PBMR and Koeberg. In this regard it is proposed that Eskom extends its efforts regarding communication with the surrounding and potentially affected communities and involve them in transparent and open monitoring and evaluation processes. In this regard, the formation of a monitoring and evaluation committee for the proposed PBMR demonstration module is strongly recommended to be established under this forum. ¹⁸³
  

Visual

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  Although the site for the proposed PBMR is recessed and surrounded by dunes in the direction of Melkbosstrand, illumination and reflective glow from the KNPS and PBMR would be visible from the R27 and Robben Island. The positioning of permanent mast lights should be done taking due cognisance of the potential impact on the surrounding residential areas. ¹⁸⁴
  
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  The form of the proposed PBMR building, as well as the material finish, relates well to the existing structures and the landscape. This architecture should be adhered to for the detail design and construction of the proposed PBMR.¹⁸⁵
  

Radiation Environmental Surveillance¹⁸⁶

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  A radiological environmental surveillance programme shall be implemented prior to operation of the PBMR demonstration module.
  

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  The programme shall be done in terms of the Eskom Generation PBMR Client Office standard (PSE0001). This programme shall be for the monitoring of ionising radiation exposure, PBMR employees and the environment in the vicinity of the PBMR demonstration module. The results of this programme will serve as a measure of exposure and safety of the public.
  
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  The purpose of this radiological environmental surveillance programme shall be to ensure that the operation of the PBMR demonstration module does not result in unacceptable contamination of the environment and complies with regulatory discharge limits.
  
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  The results on the monitoring results shall be reported to the National Nuclear regulator (NNR) and be made available to relevant authorities and communities through the established liaison/communication forums, on request.
  
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  I&APs shall, on request, be afforded the opportunity to witness sampling.
  
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  A pre-operational environmental surveillance programme shall be fully operational two years prior to the operation of the PBMR demonstration module.
  
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  The duration of the pre-operational programme for specific environmental media, presented in Table 57 below, shall be followed.
  

Table 57: Duration of pre-operational sampling programme

Six months	One year	Two years
airborne iodine iodine in milk products [while animals are in pasture]	airborne particulates milk [remaining analysis] surface water ground water drinking water	direct radiation fish and food invertebrates sediment from shore-line

Note : Table 57 tabulates the environmental sampling and monitoring programmes to be initiated at time intervals prior to the operation of the PBMR Demonstration Module. However, existing data may be used, if available, should the PBMR Demonstration Module be built at a nuclear site where an environmental sampling programme has been operational.

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