Proposed pebble bed modular reactor

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(REV 03)

Prepared by: The PBMR EIA Consortium

C/o Poltech (Pty) Ltd

P O Box 7211




In terms of the Environment Conservation Act (Act 73 of 1989), Eskom, South Africa’s national utility for electricity supply, submitted an application to establish and operate a 110MegaWatt (MWe) electricity class demonstration module Pebble Bed Modular Reactor (PBMR2) on the site of the Eskom Koeberg Nuclear Power Station in the Western Cape.

The purpose of the proposed Plant is to assess the techno-economic viability3 of the technology for South African and international application for electricity generation and other commercial applications.

The Plant forms part of a suite of feasible technologies to optimise electricity supply and demand4 for future sustainable and affordable electricity management and to support economic growth. Since many of these technologies are new to the South African market demonstration plants will first be established to thoroughly understand the techno-economic characteristics of such technology(ies).

The introduction of these technologies forms part of Eskom’s Integrated Strategic Electricity Programme- (ISEP) which will ultimately inform the National Integrated Resource Planning Process (IRPP) as described in the National Energy Policy White Paper.


The Plant consists of a combination of two well established and tested technologies which have been combined and adapted through a modular South African design. These two technologies are the so-called “pebble bed modular reactor” which is based on a nuclear design with helium cooling and a Brayton cycle gas turbine which is helium driven.

Its modular design, size and output 5 position the technology package for commercial manufacturing and flexible integration into the energy mix.

The designers of the Plant state the following advantages:

  • It has a high thermal efficiency (42%).

  • The construction time frame is about 24 months.

  • The building dimensions are 60m long and 37m wide and 60m high with about 24m above ground.

  • It has a high availability (limited maintenance) and reliability

  • The design of the reactor and material features of the nuclear fuel coatings make the technology radiologically safe.

  • The capital investment to provide for electricity growth or replacement of old generation plants is more affordable than for large coal fired stations.

  • It can be utilised for base load, mid merit or peak demand electricity supply.

  • It can rapidly change load rating from low levels (e.g. 50MWe) to peaking level (110MWe plus). This is referred to as the ramping capability of the Plant.

The global history of PBMR Technology, safety aspects and management of radiological waste(s) especially High Level Waste is dealt with in the Environmental Impact Report (EIR) and supplemented with international experience as summarised by Kugeler et. al. (Annexure 16 a and b).

The manufacture of nuclear fuel for the Plant as well as the associated transport of nuclear materials forms part of a separate Environmental Impact Assessment (EIA) application by the South African Nuclear Energy Corporation (NECSA). It is proposed that Fuel manufacture will be done on the Pelindaba campus that is located to the west of Pretoria in North West Province. The Transport of imported Uranium oxide is proposed to be by road via the N3 highway from Durban Harbour (preferred harbour of import) to Pelindaba. The manufactured fuel will follow the N1 highway down to the PBMR demonstration module at the Koeberg Nuclear Power Station Site.

The Uranium oxide will be sourced from Russia and transported to South Africa by sea. This part of the transport falls outside the scope of this EIR.


The overall project (the Plant, fuel manufacture and transport) is governed by various Acts, Regulations, Treaties and Policies under the jurisdiction of various government departments, listed hereunder, namely:


No of Act

No and Date:


The Constitution of South Africa

Act 108 of 1996

Office of the State President

Environment Conservation Act

Act 73 of 1989

Environmental Affairs and Tourism

National Environmental Management Act

Act 107 of 1998

Environmental Affairs and Tourism

Atmospheric Pollution Prevention Act

Act 45 of 1965

Environmental Affairs and Tourism

Electricity Act

Act 41 of 1987

Public Enterprises

Hazardous Substances Act

Ac 15 of 1973

Labour and Industry

National Heritage Resources Act

Act 25 of 1999

S A Heritage Resources Agency

National Nuclear Regulator Act

Act 47 of 1999

Minerals and Energy

National Roads Traffic Act

Act 94 of 1996


National Water Act

Act 36 of 1998

Water Affairs and Forestry

National Nuclear Energy Act

Act 46 of 1999

Mineral and Energy

National Monuments Act

Act 28 of 1969

National Monuments Council

Occupational Health and Safety Act

Act 85 of 1993

Health and Welfare

Physical Planning Act

Act 135 of 1991

Land Affairs

Promotion of Access to Information Act

Act 2 of 2000


Seashore Act

Act 21 of 1935

Environmental Affairs and Tourism


  • The EIA Regulations contained in government notice 1183 of 5 September 1997 as amended.

  • National Road Traffic Regulations as published in the Government Gazette of 17 March 2000

  • Regulations for the safe transport of radioactive material (IAEA No. TS-R-1 (ST-1 revised)


    South Africa, as a responsible member of the world community, has become a signatory to a variety of international agreements, dealing with issues such as marine conservation and pollution, the atmosphere, fauna and flora, Antartica, whaling and the conservation of wetlands. These conventions place specific environmental impact management requirements and obligations on the South African Government in complying to the aims and objections of these conventions. In cases where the proposed undertaking of an identified activity may influence or affect compliance with these conventions or is likely to have a significant detrimental effect across South Africa’s international boundaries, special procedures and EIA requirements may be required.

  • Bonn Convention (Convention of Migratory Species of Wild Animals) (extracted from the DEAT EIA Guideline of April 1989)

South Africa acceded to the Bonn Convention in December 1991. The convention was a response to the need for nations to co-operate in the conservation of animals that migrate across their borders. These include terrestrial animals, reptiles, marine species and birds. Special attention is paid to endangered species. No direct application to the proposed PBMR project.

  • CITES (Convention on Trade in Endangered Species of Wild Fauna and Flora) (extracted from the DEAT EIA Guideline of April 1989)

The main objectives of this convention are the protection of endangered species, the economic utilisation of species, monitoring the status of species and control of illegal trade. No direct application to the proposed PBMR project.

  • Convention on Biological Diversity (CBD) (extracted from the DEAT EIA Guideline of April 1989)

The aim is to effect international co-operation in the conservation of biological diversity and to promote the sustainable use of living natural resources world-wide. No direct application to the proposed PBMR project, however the protection of biological diversity within the affected areas of the PBMR demonstration module and fuel plant will be undertaken through the construction EMP and operational environmental surveillance programmes and general operating practices.

  • The International Whaling Convention (International Convention for the Regulation of Whaling (IWC) (extracted from the DEAT EIA Guideline of April 1989)

South Africa is a founder member of the IWC and has a proud record regarding conservation and research for whale management. No direct application to the proposed PBMR project.

  • Montreal Protocol (Protocol for the Protection of the Ozone Layer) (extracted from the DEAT EIA Guideline of April 1989)

South Africa became a signatory in January 1990. The protocol is aimed at ensuring measures to protect the ozone layer. No direct application to the proposed PBMR project.

  • Basel Convention (Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposals) (extracted from the DEAT EIA Guideline of April 1989)

South Africa became party to the convention in May 1994. The main objectives of the convention are the reduction of the production of hazardous waste and the restriction of transboundary movement and disposal of such waste. This has application to the proposed PBMR project and are factored into the requirements of the National Nuclear Regulator with regard to the waste generated by the proposed Plant.

  • Framework Convention on Climate Change (FCCC) (extracted from the DEAT EIA Guideline of April 1989)

The convention addresses the threat of global climate change by urging governments to reduce the sources of greenhouse gases. Although no obligations to the reduction of greenhouse gases rests on South Africa as a developing nation, it is of relevance to the proposed PBMR project in that it was noted at the 18th World Energy Congress (October 2001) that for electricity generation “the most effective means currently in use to reduce CO2 emissions are nuclear power and hydroelectric power” and that “they should continue to play an important role in electricity generation.”

  • World Heritage Convention (extracted from the DEAT EIA Guideline of April 1989)

Convention concerning the protection of the world cultural and natural heritage. This has application to the proposed PBMR project. It needs to be noted that the Koeberg Nuclear Power Station is in proximity to Robin Island a recognised world heritage site and that Eskom has established a nature reserve on its surrounding land. The Koeberg nature Reserve has been declared a private nature reserve and a natural heritage site. The siting of the PBMR demonstration module and the EMP requirements take this into account in terms of the Emergency Planning Procedures.

  • Convention on Desertification (extracted from the DEAT EIA Guideline of April 1989)

Convention to combat desertification in those countries experiencing serious drought and/ or desertification, particularly in Africa. No direct application to the proposed PBMR project. However, the siting of the PBMR demonstration module allows the use of sea water for the indirect cooling requirements, therefore conserving fresh water resources.

  • National Nuclear Non-proliferation Treaty enacted by the Nuclear Energy Act.

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 PBMR thus have application to the non-proliferation of nuclear weapons.

This has specific and implied meaning for the use of such materials (including nuclear material) 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 proposed PBMR has definitive application in terms of the Treaty and is dealt with in more detail in the Executive Summary and EIR (Chapter 4.2.3).


  • The White Paper on the Energy Policy of the Republic of South Africa issued on 17 December 1998.

  • The Western Cape’s White Paper on “Preparing the Western Cape for the Knowledge Economy of the 21st Century” which sets out the Western Cape’s vision and policy on inter alia sustainable development.

The different authorities that administer these Acts/Regulation/Treaties/Policies each have their own unique processes for approval and governance, which presents the applicants (Eskom/Necsa) and the participating public (Interested and Affected Parties) with a very diverse compliance framework.

The environmental authorisation process (i.e. the EIA) is only one of these process(es) and not an all embracing or final approval process. Approval by one authority does not automatically entail approval by another authority.

To ensure diligent governance, the government has decided that the National Cabinet in addition to other compliance requirement will jointly decide on the progressive development of the project, to provide the public with additional assurance.

The more important government approval processes that must be met before the proposed activity can be undertaken are mentioned below.


The Department of Environmental Affairs and Tourism (DEAT) is the competent environmental authority for the Environmental Impact Assessment for the proposed Plant, fuel manufacture and associated transport of nuclear materials.

The DEAT discharges this function in close co-operation with other affected national authorities and provincial environmental authorities of the Western Cape, North West and in liaison with the Free State, Gauteng, Kwa-Zulu Natal and Northern Cape. The key national stakeholders were consulted by the DEAT via the Interdepartmental Co-ordination Committee (IDCC) under the auspices of the Department of Minerals and Energy.

These coordinating activities are discharged in terms of the National Environmental Management Act (Act No. 107 of 1998).

The Consultant engaged the other relevant state bodies (e.g. provincial/local authorities) as well as Interested and Affected Parties (I & APs) through the public participation process(es) for the EIA.

The EIA process was formally initiated in April 2000 and during 2001 the draft and final Scoping Reports were prepared and submitted for public comment and authority review and acceptance. On the 14 December 2001 the DEAT accepted the Scoping Report and instructed the consultants to proceed with the EIA phase.

The DEAT appointed a Review Panel to assist them with the evaluation of the Scoping Reports (draft and final) as well as Environmental Impact Reports (draft and final) and report their conclusions and recommendations to the Director General of the DEAT. The appointment and finalisation of the Review Panel falls outside of the competence of the EIA Consortium.


The radiological design (Safety Case) and safety features (Safety Analysis Report) of the Plant are prepared by Eskom and the PBMR (Pty) Ltd and submitted for evaluation to the National Nuclear Regulator (NNR), which, if satisfied, will grant the necessary nuclear licences for the phased implementation of the Plant. This means that the applicant (Eskom) needs to obtain various progressive nuclear licences i.e. a site preparation, a construction licence and an operational licence. The decommissioning and dismantling phase of the Plant is integrated into the various earlier licence requirements, but will also be specifically dealt with by this authority at that stage.

The NNR is an autonomous statutory body and which governs the radiological safety/health of the public and the environment according to national radiological safety legislation (the NNR Act, Act 47 of 1999). The South African radiological safety/health and environmental standards are also based on the standards and norms of the International Atomic Energy Agency (IAEA).

The environmental assessment procedure is a separate governance process, with different time scales to that for the nuclear licensing and the statutory jurisdiction of the NNR for the assessment of radiological impacts is acknowledged in the EIR.

In addition to the above legislation the Minister of Minerals and Energy must also provide written approval for the transport and disposal of nuclear materials/waste in terms of the Nuclear Energy Act (Act 46 of 1999). This provides a multiple system of checks and balances, to safeguard the public and the environment against particularly radiological damage.


Further to the governance on national level, various acts, regulations and ordinances on provincial and local authority level will have bearing on the proposed Plant. These relate mainly to land use planning, service provision and economic development.


During the Scoping Phase some 2 600 Interested and Affected Parties (I & APs) were registered and engaged in the process through information dissemination (Notifications in the media, Information Document (Vol I) and Background Information Documents), public meetings, focus group meetings, interviews, capacity building workshops, open days and the publishing of the Scoping Report for comment.

The subjects/issues and impacts of key significance were highlighted in the Scoping Report and served as the Terms of Reference (ToR) for the formulation of the Plan of Study (PoS) for the EIA which is attached as Annexure 1.

For the EIA Phase extensive Issue Based Consultations were conducted with a broad range of stakeholders. Public meetings were furthermore held in seven centres in and around Cape Town, Durban, Johannesburg and Pelindaba to discuss the conclusions and recommendations of the draft EIR report

The public meetings, and the availability and review period of the draft EIR were widely published in the media and communicated to I & APs.

A review period of 60 days, (4 June 2002 to 4 August 2002) was provided to I & APs, to provide comment on the draft EIR. Requests for further extension of the review time were received and in consultation with the DEAT, extension was granted until the 4th September 2002.

Availability of the final EIR was again communicated individually to registered I & APs and published in the national and regional printed media.

The final EIR contains a comprehensive issues/comments register that was compiled from comments provided by I & APs, with responses from the EIA Consortium.

Chapter 6 and Annexure 10 of the final EIR provides detail of the public participation process and the Issues Register.


The key issues and impacts that served as the basis of the EIR studies are subdivided into the following main categories, namely:

  • Issues of a policy (strategic) and/or legal nature.

  • Impacts which relate to the technical, biophysical, social and economic environment.


  • White Paper on a National Energy Policy (Annexure 2 provides the executive summary)

The White Paper is quite clear on its intent that the option of nuclear energy for commercial application, while open, will only be pursued with caution.

The government has exercised this intent by introducing various checks and balances on the whole development process for the PBMR, from a procedural 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 fulfil the requirements of the Environment 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 operation of the PBMR Plant, if approved, will inform the Integrated Resource Planning Process (IRPP) as prescribed in the Energy White Paper. Informing the IRPP will be further facilitated through demonstration plants for other technologies (e.g. wind, solar thermal and biomass) which is in the process of being implemented by Eskom and Independent Power Producers (IPPs) in close succession with the Plant. Ultimately the real time techno-economic information obtained from these demonstration plants will facilitate decisions on future energy options and mixes.

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