Thyspunt Proposal Flawed

Hilton Thorpe comments on Thyspunt Work Groups

Following yesterdy’s post on the Thyspunt Work Groups to be established to help prepare the Kouga municipal area for the construction of a nuclear plant at Thyspunt, local anti-Thyspunt activist activist Hilton Thorpe posted the following comment which some may not have seen so it seems worth reprodicng as a post on its own.

Here is Hilton.s comment but one wonders if the Government would pay attention to the National Nuclear Regulator if they were to rule the site iand the proposed technology, unacceptable such is their determination to develop Thyspunt.

“Everything about the Thyspunt proposal is flawed, from the original site selection under apartheid restrictions to disregard of the Review by the CSIR in 1992, which concluded that the site was not suitable for development; to ignoring of the argument from the local community in 1998 that the site is not viable in terms of international emergency planning requirements; to the Scoping Report, which should have been rejected by the DEA in terms of NEMA requirements for failure to contain material information required; to the “co-operation agreement between the DEA & the Department of Energy, leaving the DoE in charge of nuclear issues, and effectively putting to sleep the viability issue until Eskom has applied to the NNR for a technology licence, which has still not happened; to the proposal by Eskom to apply for a reduction in emergency planning to 3 kilometres around the site, in terms of European Utility Requirements, which have been described by an English nuclear scientist as a “fiction” and only a wish-list; to the multiplicity of flawed draft environmental impact reports; to the flawed impact rating criteria, which made it impossible to have a “fatal flaw”; to the separate, and equally flawed transmission lines EIA, which based its recommendation on “national interest”, rather than environmental considerations; to the fatally flawed Final Environmental Impact Report. No wonder it is taking the DEA so long to come to a decision!

To-date, Eskom has done everything at risk, on the assumption that the EIA & Regulatory processes will go smoothly.

We can shortly expect the process by the National Nuclear Regulator, to determine whether or not both the site itself, and the proposed technology, are acceptable in terms of the Nuclear Regulator Act & Regulations. An immediate problem with this is that South Africa is a signatory to the International Atomic Energy Agency Convention, which demands that the Regulator must be independent of both political and commercial pressure. This will be difficult to justify in the light of recent political developments in the country,and of the fact that Eskom will be financing the process.

The St Francis community should be aware of the probable social impact of the project going ahead. When the Mosgas project began it is said that 100000 unemployed people converged on the town looking for work. Mossel Bay is now a large town, with a huge unemployment problem. Much the same applies to Lephalale, following the Medupi project. This can only lead to land invasion, and all the social pathologies associated with informal settlements.

Eskom’s behaviour so far has been irresponsible, and there is no reason to assume that it will change. It may be necessary to go to court to stop this.”

Thyspunt a Fait Accompli?

Is Thyspunt a fait accompli?

At Tuesday’s  DA AGM at St Francis Bay Golf Club Kouga Executive Mayor made a statement that will not have gone down well with the anti-Thyspunt or the anti-nuclear lobbyists. Addressing a rather small audience of ardent DA supporters her statement that Thyspunt is a ‘fait accompli’ will have had some choking on their gin and tonics or cold lagers and others maybe rejoicing at the news so split is the community pn the subject of Thyspunt.

The press, including St Francis Today, have recently published several articles that building a nuclear power station on a site that may be at risk of surge storms and tsunamis seems maybe not to be such a good idea. At one of the presentations at St Francis Links by consultants Gibbs when presenting their EIA report last year, one recalls their assertion that one of the primary reasons for selecting Thyspunt as an ideal environment for the nuclear power station was that there is little or no possibility of seismic activity in the area.

The question must then be asked, did Gibbs do their homework with the EIA  or if they did, did they simply and expediently cover it up to suit their paymaster. At the self-same presentation when asked about the dangers of contamination from the plant that the prevailing westerly winds may cause they categorically stated that the prevailing winds were North Westerly. Now anyone who has lived in the area for a year or more knows the westerly is our prevailing wind and St Francis is thus directly in the path of the winds blowing from the proposed site.  Possibly there is little or no chance of the wind spreading the contamination but the question is, how reliable are their findings on other matters of importance if they couldn’t ascertain the simple wind direction and what other pertinent facts have been incorrectly reported or simply painted over?

It certainly does appear that the ANC government and Eskom are hell-bent on building Thyspunt whether SA can afford it or not, but one can only wonder at how many houses and schools and improvements to infrastructure could be built for the poor with the money that will be spent on legal fees by the anti-lobby and government alone for this matter is very likely to be dragged through the courts for years to come.

And when the development starts, who is going to pay for the infrastructure upgrades that will be required? Apparently Eskom will be paying only for the building of the plant, nothing more, so who is going to pay for the roads, the housing for workers and, and ……..

Thyspunt may not be another Fukushima anytime in the near future but who knows 50 or more years in the future? With the recent spate of earthquakes and tsunami warnings on the Pacisic Rim can anyone really ascertain whather this may also possibly cause changes to the fault lines on other continents. Can our grand and great grandchildren be guaranteed or should we not worry about them and their future?

Article on Prof Maarten de Wit at the Nelson Mandela Metropolitan University and director of the Africa Earth Observatory Network, a research institute

Thank goodness for Zuma, Malema and Pravin

Thank goodness for Zuma, Malema and Pravin for without them there would be nothing for the daily press to report on. Certainly there are little snippets of stories of relative insignificance from around the country but since the elections and the Olympics interesting news other than the BIG THREE has been hard to come by. We have a magistrate accusing Zimbabweans of only coming to South Africa to steal which is upsetting a few judges.  De Lille is not popular with the ANC in Cape Town for refusing to explain R7-million golden handshakes for two executives and an exonomist predicting five years of doom for South Africa.

Looking at news from our tiny enclave there seems to be even less happening although Nuclear  and Thyspunt are back in the news with deadlines for objections due to close on Monday 29th. The following post of an e-Mail appeared on Facebook on research done by Ilze Salswedel, a well-known investigative journalist. She says “please read and NOTE point no 4 especially, as it concerns the St Francis area”. It is in Afrikaans and a rough translation appears below it but it has been translated (not very well – hey I come from KZN) so excuse any grammatical errors or Afrikaans words that have not been translated.

“Hallo almal

Ek pla julle nie gereeld met hierdie soort van ding nie, maar klik asb op onderstaande skakel en volg die maklike stappe om jou beswaar teen die oprigting van ʼn kernkragaanleg by Thyspunt naby Jeffreysbaai aan die regering voor te le. Ek het al die navorsing hieroor vir OUTA gedoen die afgelope twee maande en dis SCARY stuff hierdie. In kort:

1) Die kontrak met Rusland gaan ons land op die minste R1,2 miljard kos. Dit kom neer op ʼn betaling van R100 miljoen per jaar terugbetalings vir 30 jaar. Ons ekonomie kan dit eenvoudig nie bekostig nie. (Ons kort skole, hospitale, huise, paaie eerder as kernkrag.)

2) Die Russiese kontrak is NOOIT deur die parlement gedebatteer nie. Zuma het dit deurgedruk op die dag wat hy Nhlanhla Nene gefire het en dit vinnig-vinnig deur Des van Rooyen en die kabinet laat goedkeur. Die deal is 2 jaar gelede in die geheim met Rusland se ROSATOM gesluit.

3) Daar is tans ʼn hofsaak in die Kaapse Hooggeregshof wat die geldigheid van die kontrak betwis juis omdat dit nie die vereiste parlementere goedkeuring of openbare deelname gekry het nie. Dit sloer al ʼn jaar, en die regering vertraag dit met opset.

4) NOU het Eskom skelm-skelm ʼn kennisgewing in die staatskoerant van die Oos-Kaap (let wel, ook nie nasionaal nie) geplaas om goedkeuring te kry vir die terreinontwikkeling by Thyspunt naby Jeffreysbaai, reg langs ʼn fynbosreservaat. Daar gaan ook uitgebrei word by Koeberg. As die publiek nie beswaar maak nie, gaan dit deurgedruk word tsv die feit dat die kontrak se geldigheid tans nog ondersoek word.

5) Kennisgewings oor tenders vir konstruksie is al ʼn maand gelede ook suutjies uitgestuur.

6) Daar is NET 6 dae vir die publiek om kommentaar te lewer (Eskom het sommer ook die verpligte 30 dae kommentaartyd na 21 dae verminder).

7) OUTA het niks teen kernkrag nie, maar dit is te duur vir SA en heeltemal onnodig. Dit gaan te min energie te laat verskaf. Ons het dit nou nodig, en kan dit op goedkoper maniere kry (bv as hulle ophou geld steel by Eskom en as hulle soos die res van die wêreld belê in renewables). Eskom en die regering kanselleer ook kontrakte met internasionale voorsieners rondom “renewables” soos sonkrag en windkrag. Upington sit bv met reuse sonkragplase wat deur die Spanjaarde gebou is, maar Eskom weier om dit aan die grid te koppel.

Dis maklik om kommentaar te lewer. En jou kommentaar GAAN ʼn verskil maak, want dan moet die hele proses van vooraf begin.

Maak oop op die skakel, en copy sommer OUTA se wetlike (gecheck deur ons advokate) se besware in jou eie blokkie in. Dit deal met al die tegniese goete waaraan Eskom nie voldoen met die kennisgewings nie, asook met die feit dat ons as belastingbetalers nie gekonsulteer is nie. Of sit jou eie kommentaar in.

Hier is die skakel:

Kom ons keer hierdie korrupte spul! Deel asb ook hierdie e-pos met jou pelle.


Rought translated

“Hello everyone

I don’t often bother you with this kind of thing, but please click on link below and follow the easy steps to make your objection against the construction of ʼn Nuclear Power facility at Thyspunt near Jeffreys. I did all the research for Outa done iover the past two months and it’s scary stuff this. In Short:

1) The contract with Russia is going to cost at least R1, 2 Million. This means a re- payment of R100 million year for 30 years an amount our economy cannot afford. (We need schools, hospitals, houses, roads rather than nuclear power.)

2) The Russian contract was never debated in Parliament and Zuma pushed it through on the day he fired Nhlanhla Nene and fast tracked Des van Rooyen and the cabinet to approve the deal. The deal with the Russians was done in secret two years ago.

3 There is currently ʼn court case in the Cape in the supreme court disputing the validity of the contract because neither Parliamentary approval or public participation has been done. It has been dragging on for a year with the government deliberately delaying it.

4 Eskom published  (skelm- skelm – or Sly – Afrikaans can be so expressive so we will stick with skelm) notice in the Government gazette of the Eastern Cape (note, not national) placed in order to get approval for the site development  at thyspunt , right next to a fynbos reserve. There is also going to be an expansion to Koeberg.  If the public does not make any objection,  it is going to go ahead in spite of the contracts validity still being investigated.

5 Notifications over tenders for construction were secretly sent out a month ago.

6) THERE are only three days for the public to comment   (Eskom has summer also verpligte kommentaartyd 30 days after 21 days by).

7 Outa has nothing against nuclear power, but it is too expensive for SA and not totally needed. It is going to be out of energy too late. We have it now, and can get on goedkoper ways (eg if they stop stealing money at Eskom and if they like the rest of the world invest in renewables). Eskom and government also cancel kontrakte international voorsieners around renewables Like a solar power and windkrag.  Upington sitting g with giant sonkragplase by spanjaarde built but eskom refuses to do it on the grid link too.

It’s easy to comment and your comment can make difference

Here is the link:…/comment-eskoms-nuclear-license-app…/

Let’s reverse this corrup ion! Also please share this email with friends.


Thyspunt Site viability

Thyspunt nuclear site viability

This is the final extract from the Nuclear 1 Final Environmental Report. The full report can be read on

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

Interesting Articles on Nuclear

Flawed Thyspunt Social Impact Report (SIR)

Thyspunt Environmental Report “fatally flawed” Continued

The Social Impact Report has been the weakest of the specialist reports during all five drafts. The final report has been described by the Kromme Trust as “vacuous philosophical ramblings, more appropriate to a Scoping Report than to an Environmental  Impact Report”. It has changed little throughout the process, apart from adding out-dated and irrelevant demographic information.

The Kromme Trust has dismissed the entire report, on the grounds that the specialist failed to assess highly relevant issues, including

  • Failure to follow the changes in the Impact Rating Criteria. He is still using the original pre 2011 version, and this affects all of his conclusions.
  • Failure even to mention, let alone comment on the recommendations in the Nuclear Siting Investigation Programme (NSIP) Summary Report Revision 1 of December, 1994, which recommended that “the eastern part of the Oyster Bay area is unsuited to development because of the proximity of several holiday centres”; and that “the small holiday resorts along the coast be left unaffected”.
  • Failure to explore adequately potentially fatal flaws, such as impact on Sense of Place.
  • Failure to provided credible mitigation proposals.
  • Failure to consider the social impact on Lephalale of the Medupi project.
  • Failure to submit a valid Environmental Impact Report.

The Kromme Trust’s conclusion is that

  • the entire Social Impact Report is fatally flawed and should be rejected in its entirety;
  • the specialist should be replaced by a more competent person; and
  • a totally new Social Impact Report should be drawn up in terms of Section 33 of the NEMA

Flawed Thyspunt Impact Rating Criteria (IRCs)

Thyspunt Environmental Report “fatally flawed” Continued

Flawed Thyspunt Impact Rating Criteria (IRCs)

These are the process by which the significance of an impact can be determined. They are crucial to decision-making.  They were drafted by environmental consultants Gibb, who were appointed and have been paid by Eskom. They have been a point of contention for the past eight years.

The first set of criteria was criticised strongly by the Thyspunt Alliance on the grounds that the requirements were such that it was impossible to identify a fatal flaw. The peer group monitor found them incomprehensible, leading to the conclusion that none of the sites were suitable. A revised set was published in the 2011 Revised Draft, which contained some improvements, but, in the view of the Alliance was still unacceptable. The key issue was “Intensity”. Unless a high rating was awarded for intensity, it remained impossible to have a fatal flaw. The problem with this was that to justify a high rating, both the biophysical (natural) environment had to be destroyed and social, cultural and other factors had to be substantially affected. The complaint was that it was quite possible that one of these was true, whereas the other might be less so; and that in any case, no specialist, being a specialist, was competent to express a view on both groups.

A response to this was only received in September, 2015 (four years later!), in which  the Environmental Impact Assessor (EAP) , the person running the EIA on behalf of consultants Gibb, conceded that it was not necessary for both sets of criteria to have a high rating, and that intensity could be rated high if either set was high.

This was a fundamental change, but the problem was that none of the specialists’ reports had been done on that basis. They all needed to be reviewed to determine whether the final significance rating would have been different in terms of the EAP’s interpretation. To have such a major correction at this stage in the EIA process is not acceptable.

The Alliance regards this deficiency in the Impact Rating Criteria as a fatal flaw. It could affect all 250 odd identified impacts.

Article by Hilton Thorpe, on behalf of the St Francis Kromme Trust, the St Francis Bay  Residents’ Association and the Thyspunt Alliance