TABLE VIEW RATEPAYERS ASSOCIATION

Transcription

1 RE: Draft Environmental Impact Assessment Pebble Bed Modular Reactor (PBMR) Demonstration Power Plant Koeberg Site We, the Table View Ratepayers Association, duly registered as an Interested and Affected Party to the Environmental Impact Assessment Study for the project mentioned above would like to thank you for having been given the opportunity to submit our comments with regards to this project. The paragraphs below outline our questions and concerns. We would very much appreciate it if these could be addressed in the next version of the EIA. 1. We object to the fact that a document of this importance and having a volume of more than 2000 pages a. was expected to be commented on within a period of only 50 days. Granted, the comment period was extended by another 14 days, but this period is clearly still inadequate. ACER Africa had months to prepare this document, but we as citizens are given 64 days to read it, absorb the contents, do our own research as to the accuracy and possible omissions and then comment thereon within such a short period. This means that I&AP s have to study, research and comment on pages of highly technical information per day, including week ends. We suggest that the comment period be extended by at least another six months so that the ordinary citizen of this country can exercise his constitutional right to comment without being pressurized into either making hasty comments that will be ignored, or by being quietly convinced into making no comment at all by instilling the idea that making comments is futile within the given period anyhow. b. has only been made available at certain Public Libraries, not nationwide as it should, given that the objective of the whole PBMR demonstration program is to build these facilities around the country and ultimately worldwide. The fact that when one of our Exco members asked staff at Milnerton Library (the library closest to the proposed site at Koeberg that was listed as having a copy) whether a copy was available on CD, the member was greeted with absolute astonishment, proof in point that the public hasn t been informed

2 about the issue at hand. How do you expect the general public to be properly informed about the issue if not even Librarians, who supposedly know what is in their Library have no idea what one is talking about? We obtained a copy on CD from them after all, but people without access to a computer have no such advantage, as the printed copies cannot be lent, they can only be read at the Library itself. Reading 2000 odd pages at a Public Library is clearly not something one would expect an average citizen to do. In addition lending periods for the CD copy are limited to 2 working days and there is only one single master copy. c. that the public participation process as enshrined in our long fought for democratic constitution has not only been severely abused in this case as a result of the above, but it should be remembered both by Eskom and Acer that each and every citizen in this country is contributing financially towards the cost of the proposed facilities and thus to the cost of the EIAs, Scoping Reports, etc., and must be treated with more respect and intelligence. 2. The wording inherently safe is being used throughout the document. There is no such thing as inherently safe, no matter whether one is talking about Nuclear Energy or any other technology. Inherently Safe means that the technology itself guarantees that no incident is possible that would require human intervention whatsoever, due to it, the technology, being self regulating. This is clearly impossible, otherwise someone would have invented the Perpetuum Mobile without noticing. We strongly suggest you strike any reference to this term from the document. 3. The PBMR technology is based on the THTR built in Hamm Uentropp in North Rhine Westphalia Germany. This reactor was started up on 13 September 1983 after a construction period of 13 years ( ), went critical on 9 April 1985, was first synchronized with the grid on 16 November 1985, but after at least two known and well documented incidents was decommissioned on 1 September 1989 (see Gutachten 1.html, sorry in German). In total it produced 423 days of its full load capacity in just under 4 years of operation (423 days out of 365 * 4 = 1460 days = 28% of total full load capacity). It cost 2.05bn (approximately R26.3bn as of today s exchange rate) to construct and it is expected to cost about 425m (R5.37bn) to be decommissioned, which does not include the cost of establishment, maintenance and monitoring of a long term repository for

3 spent fuel. Total Electricity produced by this reactor was 2756 GW. This amounts to a cost of approximately R11.50 per kw. Assuming that costs of construction and decommissioning of the PBMR would be in line with the costs incurred at the THTR amounting to R31 billion this would equate to the amount needed to build low cost houses (estimating their cost at Rand each, which is probably a high end estimate). We are of the opinion that in a developing country like South Africa the political and socio economic emphasis should be put on empowering the country s citizens, especially the poor and needy, and not on proving ourselves as being on the fore front of technological innovation. 4. The document gives no indication as to what the real costs of producing electricity via this technology will be in comparison to other sources of electrical energy, whether they are conventional (e.g. Coal Fired Plants, Conventional Nuclear Plants) or Sustainable (e.g. Hydro, Wind, Solar, Wave Energy, Thermal etc.), taking into account the costs of Uranium mining, production of fuel, transportation from mining sites and from fuel producing sites (Pelindaba only?) to the facility, day today running of the facility, decommissioning and eventual storage of the spent fuel. 5. How will fuel be transported from Pelindaba to Koeberg? By road, train, ship, air? What about safety en route from Pelindaba to Koeberg? Will roads have to be closed off to general traffic? Who will bear costs if property is damaged due to an accident during transport and such property is rendered useless for extended periods of time? (see also point 8 below) 6. The NNR has set a rather arbitrary limit of 16 km as the zone around the existing Koeberg PWRs that may need to be evacuated in case of a serious accident. When one considers that after the Chernobyl disaster more than 25 years ago the area in a radius of 30 km around the site is still declared a no go zone (apart from people with special permission with strict limitations on how long they can stay) this 16 km zone is clearly not adequate. According to international standards the zone should be 50 km at least, which would range all the way down to Fishhoek/Noordhoek in the south, Stellenbosch/Paarl/Wellington in the East and beyond Ysterfontein in the north. At the moment the so called 16 km zone where PAS s are installed include Duynefontein itself, Melkbos, Blouberg Sands, Sunningdale, Atlantis and extends to the southern edge of Parklands. However, communities like ours in Table View, Du Noon and Doornbach Farm are situated just outside that area that houses people. Since the PBMR will be built about 500m south of the existing PWRs it is

4 clear that according to the NNR s regulations PASs will have to be installed further south to where the 16km boundary is now. Are there any plans for doing so? Where and how do you envisage land to be acquired to put up masts? Will there be individual EIA s for each of the sites where masts are to be erected? 7. In total we are talking about people living in very close proximity of the envisaged PBMR site. These areas have only a few routes to choose from when being evacuated, or should we rather say trying to escape from affected areas. For Atlantis this would be the N7 or R27 north. The other areas would all need to be evacuated towards the east, with only the already congested Blaauwberg Road leading to the N7/N1 or the minor road leading to Durbanville as an escape route. This is clearly impossible, especially when one considers that people from further outside the 16 km area will attempt to flee the city once news of a major accident breaks. With the number of law enforcement officers the city has at its disposal this will lead to an utter chaos none of us has ever seen before. 8. Given that all home owners insurance policies have an explicit clause in them that properties won t be covered for damage or disusability due to nuclear accidents, every nuclear installation, through its operator, has to contribute into a fund that covers for the loss of property and its use to the residents affected by such accidents. We have been informed that in the case of Pelindaba the total cover for repayment of losses incurred is capped at R120m in total. What is the limit imposed on the PBMR/Eskom as the operator? Given inhabitants close by, assuming 4 people per dwelling unit (already optimistic) and an average of maybe R per unit (an unrealistically low value) one would arrive at R4.625bn. Has any consideration be made for this? If no, why not? If yes, what escalation per annum has been envisaged? After all, since the single shareholder of the operator (ESKOM) is the state, the taxpayer will have to foot this bill? We need to know! 9. Additionally routine emissions of Cesium 137 and Strontium 90 are totally unacceptable given that there are already two PWRs at the site and that an EPR or AP1000 is also likely to be built at the same site. What are the expected combined emissions of these four reactors in Bequerel, and how does this compare to the NNR s Annual Authorised Discharge Quantities (AADQ s)? 10. In terms of Section 24 of the Constitution we as citizens of this country are entitled to a clean environment. Given that there still is no facility catering for the storage

5 and monitoring of long lived, highly radioactive elements such as Cesium 137, Strontium 90 and Plutonium 239, what is the plan for storage of the spent fuel? We cannot accept that it is stored on site, so it will have to be removed. When would this removal occur, and where would it be removed to?