Thyspunt nuclear site viability
This is the final extract from the Nuclear 1 Final Environmental Report. The full report can be read on http://stfrancistoday.com/community/thyspunt/
As far back as 1997, Eskom paid for the “Kouga Coast Sub-Regional Structure Plan”, one of whose imperatives was to “protect the viability of the Thyspunt nuclear site.” Eskom’s concern was that the rapid development of St Francis Bay was a threat to the site in terms of internationally recognized Emergency Planning Zones (EPZs). These limited the population within 16 kilometres of the site for evacuation purposes in the event of accidental release of radio-nuclides from the plant. This remains the international norm.
It was at this point that the community began to take a serious interest in Eskom’s plans for Thyspunt. The “Kouga Nuclear Concern Group” (KNCG) was formed, with input from the St Francis & Jeffreys Bay communities. They argued that, quite apart from population issues, the site was not viable in any case in view of the proximity of St Francis Bay & Sea Vista to the site, directly downwind from the prevailing westerly to south westerly winds, (evidenced by the Headland By-pass Dune Fields), and the single escape route from the St Francis area along the R330, which would be cut before anyone had time to evacuate. The KNCG challenged Eskom to an open debate in the local media. Eskom took this seriously enough to send a high-level team to discuss this, but they left without any resolution, either on the viability issue or to the debate.
It was only about nine years later that Eskom began the EIA process, and announced that they would be using “Generation 111” technology. Because of its “passive” safety. Eskom would apply to the National Nuclear Regulator (NNR) to change the rules, with reduced emergency planning zones to 3 kilometres around the site. This is a pure strategic manoeuvre to get round the viability issue, and should be regarded as propaganda, rather than a serious proposal.
Generation 111 is a product of the “EURs” ( European Utility Requirements) – an initiative by five nuclear vendors in Europe shortly after the Chernobyl disaster. Obviously improved safetywould be welcome. Whether this would justify radical reduction in EPZs remains unproven.
Twenty-five years after publication of the EURs, apart from a claimed small plant in Japan, there is not a single commercial Gen111 plant operating in the world, and Areva, the world’s leading nuclear vendor, has gone bankrupt trying to develop Gen 111 plants in France and Finland, which are now years behind schedule, and up to three times over budget. Nor have we been able to identify any western country whose nuclear regulator has approved reducing emergency planning zones to 3 kilometres. Since Fukushima, some are considering increasing them. This being the case, Gen 111 has no commercial or safety record. Eskom has based its entire nuclear programme on the assumption that Gen 111, with its reduced emergency planning, would be accepted by the NNR, and has gone ahead at risk, not only with the EIA, but with buying up vast tracts of land at inflated prices. This, of course, puts huge pressure on the decision-maker to approve the site, so as to avoid the embarrassment of further waste of public funds.
Emergency planning is the concern of the National Nuclear Regulator (NNR). In another strategic manoeuvre, the Departments of Energy & Environment drew up a ”Co-operative Agreement”, in terms of which DEA would handle environmental issues, and the NNR radiological ones. Decisions on EURs, Generation 111, reduced EPZs and viability of the site would come within the competence of the NNR. This sounds plausible enough until it is discovered that the NNR can do nothing until an application is received from Eskom for site & operation licences for a nuclear plant – something which did not happen during the EIA process. As a result, the NNR has played no part in the EIA process, and the viability issue has been left unresolved.
In the view of the Thyspunt Alliance, this should have been the very first issue to be resolved, before the EIA began. This is contrary to the requirements of NEMA, which demands that all material information must be available to the DEA in considering whether or not to issue a favourable ROD. Why DEA should have permitted the EIA to go ahead under such circumstances is not clear.
The Kromme Trust regards failure to resolve the viability issue prior to the EIA, in non-compliance with NEMA requirements, and based on unproven technology, as another fatal flaw.
In view of the numerous flaws contained in the Final Environmental Impact Report, as outlined above, DEA is requested to reject the Report in terms of section 35 2 d) of the NEMA Regulations 3114 dated 13 June, 2008.
Hilton Thorpe, on behalf of the St Francis Kromme Trust, the St Francis Bay Residents’ Association and the Thyspunt Alliance
Article by Hilton Thorpe, on behalf of the St Francis Kromme Trust, the St Francis Bay Residents’ Association and the Thyspunt Alliance
Disclaimer: The views and opinions expressed in this article are those of the authors and do not necessarily reflect the official position of St Francis Today