Thyspunt Environmental Report “fatally flawed”
This is the first in a series of articles submitted by Hilton Thorpe of Kromme Trust. St Francis Today invite readers to make comment and / or submit any articles either in favour of or against the Thyspunt nuclear development.
The Response period by the public to the “Nuclear 1 Final Environmental Impact Report” expired on 12 May, 2016. Submissions have been sent in to the Department of Environmental Affairs by the various member bodies of the Thyspunt Alliance, with different bodies focusing on different aspects.
During the EIA process, Eskom has constantly stated, in response to difficult questions, that the specialists had identified “No fatal flaws” in the various impacts investigated. The implication was that there was no valid reason for the DEA to refuse a favourable Record of Decision (ROD).
The St Francis Kromme Trust has followed up on four main issues: Impact Rating Criteria; Social Impact Assessment; Impact on Sense of Place; and emergency planning proposals. This letter reports on these. Details from other Interested and Affected Parties can be expected.
The Kromme Trust believes that all four issues contain fatal flaws.
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 destroyedand 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.
Flawed Social Impact Report (SIR)
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 Sense of Place Assessment
This is part of the social impact that can be expected if the project goes ahead. It should have received major attention in the SIR, but is hardly mentioned.
In terms of the EAP’s interpretation of the “Intensity” rating criteria, a high rating should be given where “valued, important, sensitive or vulnerable systems or communities are substantially affected.”
The Trust argues that the entire environment under consideration is an irreplaceable resource. It is home to an archaeological & paleontological treasure house of some of the earliest known history of mankind, which led SAHRA to reject the project out of hand; access requires major disturbance of wetlands in the by-pass headland dune field system, described by the Dune Morphology specialist as being one of the best examples in the world, and of high conservation value; it has claims to be declared a World Heritage Site; it will involve 150 kilometres of transmission lines, traversing areas described in the Transmission line EIA as being “areas of scenic beauty with wide-ranging vistas and low visual absorption capacity”, including the Baviaanskloof Mega Reserve, which is itself a World Heritage Site. Furthermore, it is the sense of place which has attracted people to this “top end” area, which is now world-renowned.
Substantially affected this irreplaceable resource would be by the invasion of incompatible elements, such as massive industrial structures, roads, heavy traffic and equipment, transmission lines; and by artificially importing thousands of artisans and their families, and unemployed and unskilled job-seekers, with their construction villages, informal settlements, land invasion and accompanying social pathologies, for a decade or more.
The site was selected during the apartheid era, when strict influx controls were in place, and the authorities empowered to prevent mass migration of communities in search of work. The fact that this is no longer the case is a cause for rejoicing in the right context, but it can have strong, unmitigable environmental impacts, which can be damaging to sense of place. This has to be factored into any EIA with regard to massive developments, and the implications for an area responsibly assessed. The Social Impact Report virtually ignores it, dismissing it as a “possibility”.
There is no avoiding the fact that this is an inevitable and unmitigable impact; that it will change for ever the sense of place of this area; that the community will be “substantially affected” ,or that this is an irreplaceable resource.
In terms of the EAP’S interpretation of “Intensity”, this can only lead to a “high” significance rating for loss of sense of place, which is a fatal flaw.
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 & Renewable / Alternative Energy (click here to read)
Conference takes SA a step closer to nuclear reality – With South Africa’s nuclear energy programme edging closer to reality, leading businesses in its supply chain will meet next week to explore ways of benefiting from the R1trn industry.
Why SA should be excited about nuclear – A piece of uranium the size of an egg contains enough nuclear energy to supply the electricity needs for the entire lifetime of one person. This is millions of times more energy than is contained in a similar size lump of coal, or in a cupful of petrol.
Eskom can fund the nuclear build programme – Molefe – Eskom has appetite for the planned nuclear build programme. It believes it can fund it and sees a role for itself in the construction
Another brilliant Elon Musk call – glut drops solar power production costs
Shedding light on the true state of Eskom – An energy sector leader recently observed that the electricity crisis in South Africa is maturing (perhaps like cheese)
Although this has nothing to do with Thyspunt but rather with Fracking, it is worth watching if only to see the passion of those attending a public
The SIA Report is fundamentally flawed – it is clear that this report is fatally flawed and that it is of little value to inform decision-makers
Why South Africa should not build eight new nuclear power stations – It has been an eventful year in South Africa, characterised by power cuts, parliamentary confrontations about wasteful expenditure and student fee protests. There has, however, been a massive elephant in the room that has impacted all these issues but enjoyed surprisingly scarce attention. The idea, vigorously driven by government, is for the country to build nuclear plants with an expected price tag of one trillion rand.
‘SA urgently nees Nuclear in its Energy Mix’ – Eskom CEO Brian Molefe said no load shedding is expected until the end of April but South Africa urgently needs more nuclear power in its energy mix
National Grid uses ‘last resort’ measures to keep UK lights on – Coal plant breakdowns and low wind power output force National Grid to pay dozens of businesses to reduce their energy usage
Power from poop? Yes, it’s possible – Gas produced by decaying human waste is a potentially major source of energy, providing electricity for millions
A different boom for nuclear power stations – A characteristic of bien pensants*, usually found in the leafier suburbs and the halls of academe, is their capacity for holding two opposing views at once
Massive opportunity for Africa – in South Africa, investment in renewable energy has expanded from next to nothing in 2011 to an anticipated
South African Energy – How world sees SA: Govt integrity questioned after “brazen” Hitachi bribe
German Energy Minister Baake tells SA: Build your renewables – dump nuclear – Green energy is cheap in the long run and clean compared to “dirty” coal and costly nuclear power, a senior German energy official said on the sidelines of a Cape Town conference, at a time when South Africa plans to expand atomic power generation.
SA’s nuclear programme is classified – Parliament – While South Africa’s National Treasury has completed most of the preliminary work into the country’s proposed nuclear build programme, all the details, including the cost to the fiscus, remained classified, MPs were told on Tuesday.
The Clock is Ticking
The following was submitted by a reader
What all the objectors to Nuclear fail to appreciate is that the “Clock is Ticking” and it takes more than 10 years to set up and build these Nuclear power stations and from the lessons of Medupi, the same applies to Coal.
We know that the current “Old” Coal Driven Power stations are reaching the end of their life spans and will ultimately have to be shut down. Is that when they intend to start worrying about Load shedding and all that goes with it? In 10 years there may be progress in the storage of power but it certainly doesn’t exist now and forward planning requires some action based on what is available now with the proviso that whatever is planned can be adapted to take on board the latest technology advancement. Of course that proviso also assumes there will be advancement in Nuclear technology.
We are really talking about the lead time it takes to implement whatever is decided or face the future problems in silence when we have no electricity and the economy is in tatters. We can then turnaround again and blame the government rather than all the objectors. Nuclear technology is far advanced over what was built at Chernobyl and few really know what the real impact has been on that “accident”.
Certainly the objectors fail to take into the account the impact of the Tsunami on the Fukishima incident, the disaster that befell people from the tsunami far outweighs the actual damage caused by the Fukishama Power station but of course people couldn’t find anyone to blame for the Tsunami unless you turned on God, so we blame nuclear. It is also interesting that Germany has been a great voice against nuclear but fail to mention that they buy the bulk of the electricity from the European power grid so they don’t have to have all the “dirty power generation” in their backyard. The reality is that the bulk of that power comes from France who have an extensive Nuclear driven power supply.
One should also consider “all the problems” the folk in Cape Town are having with the Koeberg Nuclear power station which is surrounded by millions of Capetonians. It doesn’t seem that the water has warmed up and the surfers, paddle boarders and beachgoers still have to brave the frigid Atlantic waters. Just this morning on the a talk show they were talking about how the perlemoen poachers have turned their attention to Robben Island where the perlemoen and crayfish are apparently thriving notwithstanding the fact that it is but a short but “cold” swim from the Koeberg facility.
Also read Court bid to stop nuclear procurement
Thyspunt will alter residents quality of life forever
Article by Brent Williams – JBay News
Quality of life of residents would change unequivocally and only the passage of time will mitigate that sense of change says the the updated Impact Studies regarding the suitability of Thyspunt for the construction of a nuclear power plant.
“The proposed Nuclear Power Station (NPS) and associated infrastructure will bring about a fundamental change in sense of place at Thyspunt,” says the report.
It continues: “It is only the passage of time that will steadily mitigate the huge sense of change that will be experienced at Thyspunt and for some residents it is a change that they will never get used to.Many of the residents specifically live in that area due to the sense of place that prevails currently and the sense of being in a remote and peaceful environment.
”Kouga will be turned into an industrial zone through Thyspunt and there is nothing to prevent that from happening, should the construction go ahead.
The reports also admit that crime will increase in the area. There will be an influx of job seekers into the Kouga and many will not find work.
This will lead to an increase in crime as well as place more pressure on the infrastructure of Kouga, as more informal settlements will develop and more RDP houses will eventually need to be built.
More clinics, hospitals, police, schools and law enforcement officials will be required to handle the influx.
Article Website http://www.jbaynews.com
Company: Jbay News
Communities invited to help review the IDP
The IDP is a five-year plan that sets out the development needs of a municipal area. It forms the basis of the municipality’s budget and determines which projects are prioritised and funded in a particular year.
The most recent IDP for Kouga covers the planning period 2012 to 2017. Because circumstances change, the IDP is reviewed annually in consultation with communities to ensure that it remains up-to-date and relevant. The current review will be for the 2016/2017 financial year.
Kouga Executive Mayor Daphne Kettledas has called on all residents to attend the meetings and to make known what they consider important for their wards to prosper.
“Your voice is important. You know your community and its need. We need your input to ensure that the IDP captures what needs to happen for your ward to grow strong,” she said.
Public meetings will be held from 15 October to 10 November 2015 at community halls across Kouga to give residents the opportunity to highlight development they would like to see happening in their wards.
All meetings will start at 6pm as per the following programme:
- 15 October at the Newton Hall, Jeffreys Bay, for Wards 3, 8 and 11
- 19 October at the Oyster Bay Community Hall for Ward 1
- 20 October at the Pellsrus Community Hall for Ward 2
- 21 October at the Sea Vista Community Hall for Ward 12
- 22 October at the Kruisfontein Community Hall for Wards 4 and 5
- 27 October at the Katrien Felix Hall, Thornhill, for Ward 7
- 27 October at the Loerie Community Hall for Ward 7
- 28 October at a tent adjacent to Lungiso High, KwaNomzamo, for Ward 6
- 3 November at the Dan Sandi Hall, Patensie, for Ward 10
- 4 November at the Weston Community Hall for Ward 13
- 5 November at the Vusumzi Landu Hall, Hankey, for Ward 9
- 10 November at the Pellsrus Community Hall for Wards 14 and 15.
Enquiries can be directed to the IDP Manager, Colleen Dreyer, at email@example.com or 042 200 2143.
Nuclear can pay its own way
John Hammond sent in an interesting article from the other side of that ugly fence on the Cape St Francis road providing balance to the article we published under Thyspunt in yesterday’s newsletter. A link to the article by Prof Dawid Serfontien, a Nuclear Scientistthat appeared in the Mail & Guardian last month can be found at the bottom of this page.
The article is well worth reading to see the issue from a different perspective and as John Hammond says “I believe that Nuclear can and should be a factor in any energy mix. In a perfect world would I choose to have a Nuclear plant on my doorstep? No! But given the amount of research on this subject and the findings in the latest Nuclear EIA report, then Thyspunt looks like a go if the Nuclear option is taken“.
On a slightly different perspective, John continues, “it is very interesting to see the the UK government has recently stopped or reduced its subsidy of both wind and solar power and has given the go ahead on the first new large scale Nuclear plant at Hinkley Point, Somerset. This plant will be built by the French in part using Chinese money, an interesting combination”.
South Africa used to be the powerhouse of Africa due in part to our capacity to generate surplus amounts of energy. A criminal lack of investment by Eskom and decisions by then Minister of Energy Alec Erwin in the 90’s, resulted in today’s load shedding and by extension, a reduction in GDP and he tough trading conditions we find ourselves in today. South Africa had roughly as much generating capacity when the ANC came into power in 1994 as we have now but with Eskom ignoring the need to maintain and replace ageing power stations with new generating capacity for so long, is directly responsible the high unemployment and a reduction in investment by large international and local companies.
“The country needs an energy plan for the next thirty plus years and hence an infrastructure that will assist in the development of jobs, business and the upliftment of our communities”.
“Kouga needs this project due to our high levels of unemployment and while it will impact on our life styles, we do need to start planning how we can can get involved and best manage the impact on our villages. If its not nuclear, then fine, but if it is, then lets make the best we can of the developing senario”.
Article and foreword supplied by John Hammond – edited
The link to the Mail & Guardian article
Is Nuclear really the answer?
Eskom (government) obviously feels the answer can be found by building more Medupi’s and Thyspunt’s but are they considering the many alternatives being developed by other countries who face similar generating capacity as they grow their economy’s into the future.
The following article puts an interesting spin on whether these multi- billion Rand monstrosities really necessary or are they simply to “reward the empowered few who wish for centralisation of the energy system so their dominance might persist, against the disempowered many who wish to claim back their autonomy”. READ MORE
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