No New Nuclear: OUTA opposes Thyspunt nuclear site licence

OUTA has made a formal submission to the National Nuclear Regulator (NNR), opposing Eskom’s revived application for a nuclear site installation licence at Thyspunt in the Eastern Cape.

OUTA calls on the NNR to refuse the application.

Eskom applied to the NNR for the site licence five years ago, for an unspecified new nuclear plant, but no decision was made. The application now appears to have been revived, presumably because there is a renewed determination in government to pursue a new nuclear power build.

The NNR recently called for public comment on the application and plans public hearings on 25 and 26 August in the Eastern Cape and virtually.

OUTA opposes proposals for a new nuclear power station, on the grounds that South Africa cannot afford this, it is not needed, it is not appropriate technology and is thus not in the public interest.

In this case, OUTA also opposes the site licence application due to the lack of information.

“OUTA recommends that the NISL application be rejected until such time that Eskom can demonstrate a need and desirability for the nuclear power plant project and that sufficient information is provided, possibly through a new environmental impact assessment to enable the public to make meaningful inputs at all stages of the application process,” says Liz McDaid, OUTA’s Parliamentary Advisor and Energy Advisor, in OUTA’s submission.

OUTA’s objections

OUTA’s objections to the Thyspunt application include:

• Neither Eskom nor the NNR has provided sufficient information for the public to make any meaningful contribution. The information provided is general, not specific to the site in many cases, and also seems outdated. This undermines the public participation process.

• The Thyspunt site has been refused an environmental authorisation. Although this is being appealed, this is still pending, plus this Environmental Impact Assessment (EIA) is now 10 years out of date, although this should inform the site application process.

• Neither the EIA nor the site safety report are provided to the public.

• The National Energy Regulator (NERSA) has not issued a section 34 determination in terms of the Electricity Regulation Act that any nuclear energy plant is needed (NERSA is still considering the Minister’s application last year for 2 500 MW of new nuclear build). The Integrated Resource Plan 2019 (IRP 2019) does not include nuclear energy before 2030. 

• Government has not produced a feasibility study for new nuclear power.

• Eskom is R401 billion in debt, can’t afford new nuclear build and has indicated that nuclear procurement is not certain.

• In December 2018, the NNR said it had received 25 000 public comments on the Thyspunt and Duynefontein site applications and provided a summary of these, but has not provided details. OUTA was unable to establish whether any of the points made had been considered or changed the situation. Comments were on health, safety and environmental aspects. There is no NNR public document on any assessment of these comments.

• The Eskom application and the Eskom 2019 public information document do not address in any meaningful way the issues raised by the public in 2016.

• There is no independent safety analysis.

• The description of the reactor types reads like an advertisement but provides no comparison of the implications that such different designs would have for the site. The usefulness of the information is therefore not clear.

• The site has insufficient space for permanent storage of all the spent nuclear fuel.

• The safety measures regarding radiation risk do not appear to be aimed at ensuring complete health and safety, but only to reducing harm “to the extent reasonably achievable”. It is not clear how the surrounding public are involved in determining “reasonable”.

• The demographic analysis is based on the population in 2000.

• Countermeasures in case of an accident include sheltering, but this depends on the type of building, and it is not clear how this would apply to informal settlements.

• Transport of nuclear materials is by road but there is no safety assessment.

• Given that nuclear energy is expensive and is not considered an adequate response to climate change and its role in ensuring energy security has been surpassed by technological advances through storage, hydrogen and renewables, it is likely that the next IRP would also not contain new nuclear.

• Nuclear plants are not value for money.

OUTA’s submission to the NNR is here and the additional annexure is here.

New nuclear build: the Eskom site application

Eskom’s application is for a nuclear installation site licence (NISL) at Thyspunt, near St Francis Bay in the Kouga municipality in the Eastern Cape.

Eskom refers to this as an early site permit, independent of a specific nuclear power plant design. The application is to evaluate the suitability of Thyspunt for a new nuclear installation, not an application to build. The application does not include the specifics of any plant design.

When Eskom applied in March 2016, it submitted two applications: one for Thyspunt (see here) and another for Dynefontein, near Koeberg in the Western Cape (see here).

This is the second public participation process. In August 2016, OUTA opposed both the applications (see here). In December 2018, the NNR said it had received 25 000 comments on the two applications. The NNR statement is here.

In August/September 2019, Eskom published a public information document on the Thyspunt application. This document is here.

In May 2021, the NNR’s published list of fees for regulator services for nuclear installations included R9.6 million in 201/22 for the Thyspunt nuclear installation site licence application (the 2020/21 fee was R18.5 million). The fees schedule is here (page 26).

New nuclear build: the story so far

In April 2017, the Western Cape High Court ruled that the nuclear build agreements by then President Jacob Zuma’s executive were unlawful and overturned them.

In June 2020, the Minister of Mineral Resources and Energy issued a non-binding Request for Information on building 2 500 MW of new nuclear power.

In November 2020, NERSA announced it had received a request from the Minister to concur with a determination (authorisation) that South Africa needs another 2 500 MW of new nuclear power. In February 2021, OUTA opposed this request. More on this, and OUTA’s reasons for opposing new nuclear build, are here.

WATCH: OUTA’s video of February 2021, explaining our opposing the new nuclear build proposal, is here.

NERSA’s decision on whether to concur with the Minister’s determination is still awaited.

In May 2021, the Minister told Parliament in a written reply that if NERSA concurs with the determination, the department intends to complete the procurement of 2 500 MW of nuclear new build by 2024. This reply is here.

Voicenote

A voicenote with comment from OUTA’s Liz McDaid is here.

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