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"title": "Civil society and Eskom at odds over proposal to extend Koeberg’s life by 20 years",
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"contents": "<span style=\"font-weight: 400;\">The Koeberg nuclear power plant faces a crucial juncture when its 40-year operational licence comes to an end in July, with Eskom pushing for a 20-year extension from the National Nuclear Regulator (NNR).</span>\r\n\r\n<span style=\"font-weight: 400;\">With just over a month to go before the licence expires, the NNR has concluded public hearings to consult on Eskom’s proposed licence application for the long-term operation (LTO) of Koeberg. But civil society has criticised the process, raising concerns about the safety of the plant.</span>\r\n\r\n<span style=\"font-weight: 400;\">The concerns raised in these public hearings related to the lack of transparency, alleged incomplete studies and lack of impartiality, climate change risks, and concerns about emergency and evacuation drills that community members felt were not addressed properly at the hearings.</span>\r\n\r\n<span style=\"font-weight: 400;\">The NNR hosted three public hearings from 7 to 9 June in Table View, Athlone and Atlantis on the Western Cape, where community members and civil society representatives presented their comments for and against the 20-year extension. This followed concerns that the previous public consultation was insufficient.</span>\r\n<h4><b>Eskom’s case for Koeberg</b></h4>\r\n<span style=\"font-weight: 400;\">Eskom’s nuclear support manager, Keith Featherstone, said that international experience had demonstrated that nuclear plants like Koeberg could safely, economically and reliably operate beyond the design life assumed in their original analyses. </span>\r\n\r\n<span style=\"font-weight: 400;\">“Koeberg Power Station is no different. It reaches the 40-year life assumed in the original analysis in 2024/2025 and because of the conservative design, the good condition of the plant and the positive results of all the required regulatory studies that have been performed, Eskom has demonstrated that the plant can safely be operated for another 20 years,” Featherstone said.</span>\r\n\r\n<span style=\"font-weight: 400;\">He added that the five-year-old Integrated Resource Plan (2019) reflected this position and that shutting down the Koeberg power station in July at the end of its design life was not recommended as it was one of the “best-performing power plants” with a low operational cost.</span>\r\n\r\n<span style=\"font-weight: 400;\">He said its lifespan must be extended by another 20 years by undertaking the necessary technical and regulatory work, which could only be done once the necessary regulatory approvals had been received.</span>\r\n\r\n<p><img loading=\"lazy\" class=\"size-full wp-image-2226682\" src=\"https://www.dailymaverick.co.za/wp-content/uploads/2024/06/Koeberg-1.jpeg\" alt=\"Koeberg\" width=\"720\" height=\"446\" /> <em>Civil society groups have criticised the process for Koeberg's LTO extension as inadequate and lacking in transparency, raising concerns about the safety of the nuclear plant. (Photo: Peter Becker)</em></p>\r\n\r\n<span style=\"font-weight: 400;\">On 10 May 2021, the NNR received an application from Eskom to operate Koeberg beyond its current licence term of 21 July 2024, for an additional 20 years, to 21 July 2044 for Unit 1 and to 9 November 2045 for Unit 2.</span>\r\n\r\n<span style=\"font-weight: 400;\">In Eskom’s presentation, Featherstone said the advantages of granting the LTO application included:</span>\r\n<ul>\r\n \t<li>Koeberg’s strategic location, which supported the Western Cape grid;</li>\r\n \t<li>Its reliable operations and high energy availability;</li>\r\n \t<li>It had the lowest primary energy costs of Eskom thermal plants;</li>\r\n \t<li>Koeberg’s low water consumption due to its design and use of seawater for cooling;</li>\r\n \t<li>Globally, nuclear is recognised as essential to meet emission reduction targets; and</li>\r\n \t<li>Koeberg is a national asset that can safely be operated for longer.</li>\r\n</ul>\r\n<span style=\"font-weight: 400;\">Featherstone said the plant safety, ageing, operating and maintenance practices and environmental impacts of LTO had been assessed and posed “no undue risk” to public health and safety and the environment.</span>\r\n\r\n<span style=\"font-weight: 400;\">Responding to questions at the public hearing in Athlone about the safety of the plant should the application be granted, Featherstone said:</span>\r\n\r\n<span style=\"font-weight: 400;\">“How do we guarantee the safety of the plant? The nuclear environment is extremely regulated, which is why we are sitting here in front of the NNR. The very reason it’s regulated is because the core of nuclear power is very energy-intensive and has the potential – as we know through Chernobyl and Fukushima – to be very unforgiving. The regulations are there to ensure safety and that’s the job of the regulator, to ensure we comply with the regulations.</span>\r\n\r\n<span style=\"font-weight: 400;\">“There are very strict rules that we have to follow in meeting those regulations and ensure that if we follow them, the safety of the plant is assured,” he said. </span>\r\n\r\n<span style=\"font-weight: 400;\">“Everyone gets emotional around Chernobyl and Fukushima, and quite rightly so, but we have to put it into context. There’s another nuclear accident, that happened in America, that not many people talk about – that is Three Mile Island (1979) and that is the plant that is closest to Koeberg’s plant design, compared to Chernobyl and Fukushima. No one talks about that accident because they did the same as what happened in Fukushima and Chernobyl, but it was a non-event,” Featherstone said.</span>\r\n\r\n<span style=\"font-weight: 400;\">He said the plant design allowed the situation to be managed in a way that had no impact on the environment. </span>\r\n\r\n<span style=\"font-weight: 400;\">“Now Koeberg is virtually the same design as the plant in Three Mile Island. It [Koeberg] is a safe plant and when managed correctly can be used very safely and effectively… That is the way the world is going now in terms of meeting the climate emission targets that have been set in the different countries.” </span>\r\n\r\n<p><img loading=\"lazy\" class=\"size-full wp-image-2226678\" src=\"https://www.dailymaverick.co.za/wp-content/uploads/2024/06/Koeberg-5.jpeg\" alt=\"Koeberg\" width=\"720\" height=\"441\" /> <em>Civil society groups say the process for Koeberg's LTO extension is inadequate and lacks transparency. (Photo: Extinction Rebellion (XR) Cape Town)</em></p>\r\n<h4><b>Public concerns and criticisms </b></h4>\r\n<span style=\"font-weight: 400;\">Despite Eskom’s assurances, the public hearings revealed substantial opposition.</span>\r\n\r\n<span style=\"font-weight: 400;\">In Athlone, the session began with demonstrations by community members and civil society groups outside the venue, calling for no more nuclear power and criticising the process for being inadequate and lacking transparency about the safety of Koeberg.</span>\r\n\r\n<span style=\"font-weight: 400;\">On behalf of the social and environmental justice organisation Project 90 by 2030, Gabriel Klaasen delivered their main points on why they were against Koeberg getting an LTO. They were supported by Extinction Rebellion Cape Town, the Koeberg Alert Alliance (KAA) and others.</span>\r\n\r\n<span style=\"font-weight: 400;\">KAA said that for the public to be meaningfully consulted, all of the safety information relating to Koeberg should have been released in early 2022 when Eskom first submitted the life extension application to the NNR. Instead, they had to resort to repeated Paia (Promotion of Access to Information Act) applications for the release of vital documents. </span>\r\n\r\n<span style=\"font-weight: 400;\">“The NNR and Eskom have fought a Stalingrad defence, releasing additional information in dribs and drabs only in response to pressure via lawyers’ letters.”</span>\r\n\r\n<span style=\"font-weight: 400;\">KAA said the NNR had ignored requests for copies of documents showing that the 14 non-compliances from a November 2022 emergency drill had been addressed.</span>\r\n\r\n<p><img loading=\"lazy\" class=\"size-full wp-image-2226675\" src=\"https://www.dailymaverick.co.za/wp-content/uploads/2024/06/Koeberg-4.jpeg\" alt=\"\" width=\"720\" height=\"354\" /> <em>Eskom presents the case for Koeberg's LTO extension at a public hearing in Athlone on 7 June 2024. (Photo: Peter Becker)</em></p>\r\n\r\n<p><img loading=\"lazy\" class=\"size-full wp-image-2226674\" src=\"https://www.dailymaverick.co.za/wp-content/uploads/2024/06/Koeberg-3.jpeg\" alt=\"\" width=\"720\" height=\"349\" /> <em>Gabriel Klaasen from Project 90 by 2030 presents comments at the public hearing for Koeberg's LTO extension in Athlone on 7 June 2024. (Photo: Peter Becker)</em></p>\r\n\r\n<span style=\"font-weight: 400;\">The seismic study (more than 1,000 pages) and the Duynefontein Site Safety Report were only made available in April 2024, leaving an unreasonable time for that information to be reviewed.</span>\r\n\r\n<span style=\"font-weight: 400;\">“We believe that the evidence makes it clear that there is more than sufficient reason for the NNR to refuse the life extension of Koeberg. If the NNR is not ready to arrive at that conclusion, then the missing and redacted information which is being withheld from the public must be made available with a reasonable comment period. The issues with the non-compliant emergency plan must also be remedied as a matter of urgency,” KAA said in its submission.</span>\r\n\r\n<span style=\"font-weight: 400;\">In the presentation for Project 90 by 2030, Klaasen said: “The International Atomic Energy Agency </span><a href=\"https://www.iaea.org/newscenter/pressreleases/iaea-concludes-long-term-operational-safety-review-of-south-africas-koeberg-nuclear-power-plant\"><span style=\"font-weight: 400;\">(IAEA) </span></a><span style=\"font-weight: 400;\">identified 15 safety concerns in its report from 2022. Eskom’s safety case report has yet to set out practical and long-term solutions to fix all these concerns. The IAEA is set to come back to South Africa to assess Koeberg in September 2024.</span>\r\n\r\n<span style=\"font-weight: 400;\">“Would it not be advisable to wait for the outcome of this mission before any decision on the lifetime extension is taken?” </span>\r\n\r\n<b>Read more in Daily Maverick: </b><a href=\"https://www.dailymaverick.co.za/article/2022-04-04-koeberg-gets-a-safety-thumbs-up-from-iaea-while-eskoms-veil-of-secrecy-lingers/\"><span style=\"font-weight: 400;\">Koeberg gets a safety thumbs up from IAEA while Eskom’s veil of secrecy lingers</span></a>\r\n\r\n<span style=\"font-weight: 400;\">Klaasen said many other countries were looking at extending the lifetime of their nuclear power stations. </span>\r\n\r\n<span style=\"font-weight: 400;\">“A comparison with LTO processes in France, where they are dealing with identical nuclear power plants, shows that France is taking many more precautions and upgrades than South Africa. France is investing significantly to ensure its plants are as close to Generation III safety standards as possible. Eskom maintains that Koeberg’s Generation II design is safe, and the NNR does not question this claim.</span>\r\n\r\n<span style=\"font-weight: 400;\">“Why is it that France is taking these precautions while second-best safety measures are good enough in South Africa?” Klaasen said.</span>\r\n\r\n<span style=\"font-weight: 400;\">Another difference in approach between France and South Africa, Klaasen said, was the length of the operating licence. While Eskom wants to extend Koeberg’s lifespan by 20 years, France is looking to extend its plants’ lifespans for 10 years to prove the safety of the plant is intact before extending the lifetime for a second time.</span>\r\n\r\n<span style=\"font-weight: 400;\">“In addition, France has decreased the intervals between integrated leak tests to five years, yet South Africa will keep the 10-year intervals. The last leak test happened nine years ago but the next one is only scheduled for later this year and therefore will be after the NNR has made its decision on the life extension,” Klaasen said.</span>\r\n\r\n<span style=\"font-weight: 400;\">Elaine Mills from KAA – a civil society alliance of citizens with reservations about the use of nuclear energy in South Africa – said that Eskom should have submitted its life extension application, safety case and supporting documentation at least two years before the NNR decision deadline of 21 July 2024.</span>\r\n\r\n<span style=\"font-weight: 400;\">However, she said that when Eskom failed to meet this deadline, the NNR adjusted the regulations to allow Eskom to submit later and instead of having two years to study the application, the public was given an unreasonably short time to comment, while some reports were incomplete or still in draft format.</span>\r\n\r\n<p><img loading=\"lazy\" class=\"size-full wp-image-1467305\" src=\"https://www.dailymaverick.co.za/wp-content/uploads/2022/11/GettyImages-1229796241.jpeg\" alt=\"\" width=\"720\" height=\"360\" /> <em>The Koeberg nuclear power station as seen from Melkbosstrand beach in Cape Town on 25 November 2020. (Photo: Dwayne Senior / Bloomberg via Getty Images)</em></p>\r\n\r\n<span style=\"font-weight: 400;\">“Eskom being late in completing required studies is no justification for NNR setting unrealistic deadlines and rushing the public through the process. The over 1,000-page seismic study was only made available in April 2024, leaving hardly any time for information to be read and understood.</span>\r\n\r\n<span style=\"font-weight: 400;\">“In addition, Vaalputs communities were only included in April 2024, even though low and intermediate Koeberg waste is shipped to the area where they live… The NNR extended public consultation deadlines numerous times but did not communicate this clearly,” she said.</span>\r\n\r\n<span style=\"font-weight: 400;\">The KAA said one inevitable consequence of granting the life extension would be 20 more years of low and intermediate waste being shipped to Vaalputs. </span>\r\n\r\n<span style=\"font-weight: 400;\">“Despite this, the NNR did not appear to take into consideration the communities living in that area. Instead of including those communities from the start in January 2023, the NNR waited until April 2024 before allowing them to participate,” the KAA said.</span>\r\n\r\n<span style=\"font-weight: 400;\">Klaasen said: “We would like to highlight the health issues of those who have worked at Koeberg Power Station and surrounding areas. The lack of medical records and review is not proof of a clean bill of health.”</span>\r\n\r\n<span style=\"font-weight: 400;\">Klaasen also raised concerns about safe and clean water supplies as Cape Town is a water-scarce city that came close to Day Zero. “The long-term operation extension will require massive amounts of water. In a changing climate we cannot risk the misuse of this scarce resource.” </span>\r\n\r\n<span style=\"font-weight: 400;\">Klaasen, Mills and others expressed concern about the lack of a transparent and accessible evacuation plan, leaving communities unsure of what to do in the case of an emergency.</span>\r\n\r\n<span style=\"font-weight: 400;\">These issues have been raised before, but Mills said there had been no improvement in communication.</span>\r\n\r\n<span style=\"font-weight: 400;\">“It is vital that this life extension application is subject to the most rigorous public scrutiny within a reasonable time frame to allow experts to offer their views and expertise to assist the NNR in making its decision,” Mills said.</span>\r\n\r\n<span style=\"font-weight: 400;\">Mills added that there were more than enough reasons for the NNR to refuse the life extension of Koeberg and if the regulator was not ready to arrive at that conclusion, then missing and redacted information being withheld from the public must be made available with a reasonable comment period. </span>\r\n\r\n<p><img loading=\"lazy\" class=\"size-full wp-image-2226683\" src=\"https://www.dailymaverick.co.za/wp-content/uploads/2024/06/Koeberg-2.jpeg\" alt=\"\" width=\"720\" height=\"483\" /> <em>Civil society members protest outside the public hearing for Koeberg's LTO extension in Athlone on 7 June 2024. (Photo: Peter Becker)</em></p>\r\n<h4><b>Health, safety and socioeconomic consequences</b></h4>\r\n<span style=\"font-weight: 400;\">Joyce Malebo, a member of Project 90 by 2030 and a concerned senior resident, said that they were there as women talking on behalf of women who cannot express themselves. She said Eskom must not be granted the 20-year extension because nuclear waste was putting their lives at risk.</span>\r\n\r\n<span style=\"font-weight: 400;\">“Eskom is concerned about profit and not human safety. Why can’t we build renewable solar and wind instead?” she said.</span>\r\n\r\n<span style=\"font-weight: 400;\">The Southern African Faith Communities’ Environment Institute’s (Safcei) executive director, Francesca de Gasparis, said they had made several submissions since Eskom’s application was announced and raised serious concerns including that the documents made available for comment included a heavily redacted LTO Safety Case, and many important source documents relied upon by Eskom in the LTO Safety Case had not been made available.</span>\r\n\r\n<span style=\"font-weight: 400;\">De Gasparis said that while some required safety improvements had been implemented, others remained planned for implementation either before the LTO or during the period of the LTO. </span>\r\n\r\n<span style=\"font-weight: 400;\">It was submitted that the LTO documents made available to Safcei did not address the health, safety and socioeconomic consequences of a beyond-design catastrophic incident, such as a reactor core meltdown, or provide up-to-date information justifying the claim that the LTO was economically justifiable. </span>\r\n\r\n<span style=\"font-weight: 400;\">De Gasparis said there had been unacceptable delays in maintenance and safety upgrades at Koeberg, and a significant amount of information highly relevant to the safety of the reactor was still not available to the public. </span>\r\n\r\n<span style=\"font-weight: 400;\">“There are 41 references in the… Koeberg Safety Analysis Report which looks at severe nuclear accidents such as a meltdown. The public is advised that, ‘This document contains multiple instances of third-party confidential information and cannot be made available to the public’ – which, it is submitted, is insufficient information or justification for withholding disclosure, given the inherently hazardous nature of nuclear power generation,” she said.</span>\r\n\r\n<span style=\"font-weight: 400;\">Based largely on the observations of the IAEA’s Safety Aspects of Long Term Operation mission of 2022 and work done in the interim, De Gasparis said the conclusion was “inescapable” that the plant was not ready from a safety point of view for the authorisation to continue beyond its current licence.</span>\r\n\r\n<span style=\"font-weight: 400;\">“The long-term extension of the licence application process thus far has been marred by significant procedural unfairness, mainly as a result of the failure to disclose information critical to meaningful participation timeously. As a result, those most likely to be affected by a nuclear accident have been deprived of the right to properly participate in decisions about the future of the reactor,” she said. </span><b>DM</b>",
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"name": "Civil society demonstrating outside the public hearing for Koeberg's LTO Extension in Athlone on Friday, 7 June 2024. (Photo: Peter Becker)",
"description": "<span style=\"font-weight: 400;\">The Koeberg nuclear power plant faces a crucial juncture when its 40-year operational licence comes to an end in July, with Eskom pushing for a 20-year extension from the National Nuclear Regulator (NNR).</span>\r\n\r\n<span style=\"font-weight: 400;\">With just over a month to go before the licence expires, the NNR has concluded public hearings to consult on Eskom’s proposed licence application for the long-term operation (LTO) of Koeberg. But civil society has criticised the process, raising concerns about the safety of the plant.</span>\r\n\r\n<span style=\"font-weight: 400;\">The concerns raised in these public hearings related to the lack of transparency, alleged incomplete studies and lack of impartiality, climate change risks, and concerns about emergency and evacuation drills that community members felt were not addressed properly at the hearings.</span>\r\n\r\n<span style=\"font-weight: 400;\">The NNR hosted three public hearings from 7 to 9 June in Table View, Athlone and Atlantis on the Western Cape, where community members and civil society representatives presented their comments for and against the 20-year extension. This followed concerns that the previous public consultation was insufficient.</span>\r\n<h4><b>Eskom’s case for Koeberg</b></h4>\r\n<span style=\"font-weight: 400;\">Eskom’s nuclear support manager, Keith Featherstone, said that international experience had demonstrated that nuclear plants like Koeberg could safely, economically and reliably operate beyond the design life assumed in their original analyses. </span>\r\n\r\n<span style=\"font-weight: 400;\">“Koeberg Power Station is no different. It reaches the 40-year life assumed in the original analysis in 2024/2025 and because of the conservative design, the good condition of the plant and the positive results of all the required regulatory studies that have been performed, Eskom has demonstrated that the plant can safely be operated for another 20 years,” Featherstone said.</span>\r\n\r\n<span style=\"font-weight: 400;\">He added that the five-year-old Integrated Resource Plan (2019) reflected this position and that shutting down the Koeberg power station in July at the end of its design life was not recommended as it was one of the “best-performing power plants” with a low operational cost.</span>\r\n\r\n<span style=\"font-weight: 400;\">He said its lifespan must be extended by another 20 years by undertaking the necessary technical and regulatory work, which could only be done once the necessary regulatory approvals had been received.</span>\r\n\r\n[caption id=\"attachment_2226682\" align=\"alignnone\" width=\"720\"]<img class=\"size-full wp-image-2226682\" src=\"https://www.dailymaverick.co.za/wp-content/uploads/2024/06/Koeberg-1.jpeg\" alt=\"Koeberg\" width=\"720\" height=\"446\" /> <em>Civil society groups have criticised the process for Koeberg's LTO extension as inadequate and lacking in transparency, raising concerns about the safety of the nuclear plant. (Photo: Peter Becker)</em>[/caption]\r\n\r\n<span style=\"font-weight: 400;\">On 10 May 2021, the NNR received an application from Eskom to operate Koeberg beyond its current licence term of 21 July 2024, for an additional 20 years, to 21 July 2044 for Unit 1 and to 9 November 2045 for Unit 2.</span>\r\n\r\n<span style=\"font-weight: 400;\">In Eskom’s presentation, Featherstone said the advantages of granting the LTO application included:</span>\r\n<ul>\r\n \t<li>Koeberg’s strategic location, which supported the Western Cape grid;</li>\r\n \t<li>Its reliable operations and high energy availability;</li>\r\n \t<li>It had the lowest primary energy costs of Eskom thermal plants;</li>\r\n \t<li>Koeberg’s low water consumption due to its design and use of seawater for cooling;</li>\r\n \t<li>Globally, nuclear is recognised as essential to meet emission reduction targets; and</li>\r\n \t<li>Koeberg is a national asset that can safely be operated for longer.</li>\r\n</ul>\r\n<span style=\"font-weight: 400;\">Featherstone said the plant safety, ageing, operating and maintenance practices and environmental impacts of LTO had been assessed and posed “no undue risk” to public health and safety and the environment.</span>\r\n\r\n<span style=\"font-weight: 400;\">Responding to questions at the public hearing in Athlone about the safety of the plant should the application be granted, Featherstone said:</span>\r\n\r\n<span style=\"font-weight: 400;\">“How do we guarantee the safety of the plant? The nuclear environment is extremely regulated, which is why we are sitting here in front of the NNR. The very reason it’s regulated is because the core of nuclear power is very energy-intensive and has the potential – as we know through Chernobyl and Fukushima – to be very unforgiving. The regulations are there to ensure safety and that’s the job of the regulator, to ensure we comply with the regulations.</span>\r\n\r\n<span style=\"font-weight: 400;\">“There are very strict rules that we have to follow in meeting those regulations and ensure that if we follow them, the safety of the plant is assured,” he said. </span>\r\n\r\n<span style=\"font-weight: 400;\">“Everyone gets emotional around Chernobyl and Fukushima, and quite rightly so, but we have to put it into context. There’s another nuclear accident, that happened in America, that not many people talk about – that is Three Mile Island (1979) and that is the plant that is closest to Koeberg’s plant design, compared to Chernobyl and Fukushima. No one talks about that accident because they did the same as what happened in Fukushima and Chernobyl, but it was a non-event,” Featherstone said.</span>\r\n\r\n<span style=\"font-weight: 400;\">He said the plant design allowed the situation to be managed in a way that had no impact on the environment. </span>\r\n\r\n<span style=\"font-weight: 400;\">“Now Koeberg is virtually the same design as the plant in Three Mile Island. It [Koeberg] is a safe plant and when managed correctly can be used very safely and effectively… That is the way the world is going now in terms of meeting the climate emission targets that have been set in the different countries.” </span>\r\n\r\n[caption id=\"attachment_2226678\" align=\"alignnone\" width=\"720\"]<img class=\"size-full wp-image-2226678\" src=\"https://www.dailymaverick.co.za/wp-content/uploads/2024/06/Koeberg-5.jpeg\" alt=\"Koeberg\" width=\"720\" height=\"441\" /> <em>Civil society groups say the process for Koeberg's LTO extension is inadequate and lacks transparency. (Photo: Extinction Rebellion (XR) Cape Town)</em>[/caption]\r\n<h4><b>Public concerns and criticisms </b></h4>\r\n<span style=\"font-weight: 400;\">Despite Eskom’s assurances, the public hearings revealed substantial opposition.</span>\r\n\r\n<span style=\"font-weight: 400;\">In Athlone, the session began with demonstrations by community members and civil society groups outside the venue, calling for no more nuclear power and criticising the process for being inadequate and lacking transparency about the safety of Koeberg.</span>\r\n\r\n<span style=\"font-weight: 400;\">On behalf of the social and environmental justice organisation Project 90 by 2030, Gabriel Klaasen delivered their main points on why they were against Koeberg getting an LTO. They were supported by Extinction Rebellion Cape Town, the Koeberg Alert Alliance (KAA) and others.</span>\r\n\r\n<span style=\"font-weight: 400;\">KAA said that for the public to be meaningfully consulted, all of the safety information relating to Koeberg should have been released in early 2022 when Eskom first submitted the life extension application to the NNR. Instead, they had to resort to repeated Paia (Promotion of Access to Information Act) applications for the release of vital documents. </span>\r\n\r\n<span style=\"font-weight: 400;\">“The NNR and Eskom have fought a Stalingrad defence, releasing additional information in dribs and drabs only in response to pressure via lawyers’ letters.”</span>\r\n\r\n<span style=\"font-weight: 400;\">KAA said the NNR had ignored requests for copies of documents showing that the 14 non-compliances from a November 2022 emergency drill had been addressed.</span>\r\n\r\n[caption id=\"attachment_2226675\" align=\"alignnone\" width=\"720\"]<img class=\"size-full wp-image-2226675\" src=\"https://www.dailymaverick.co.za/wp-content/uploads/2024/06/Koeberg-4.jpeg\" alt=\"\" width=\"720\" height=\"354\" /> <em>Eskom presents the case for Koeberg's LTO extension at a public hearing in Athlone on 7 June 2024. (Photo: Peter Becker)</em>[/caption]\r\n\r\n[caption id=\"attachment_2226674\" align=\"alignnone\" width=\"720\"]<img class=\"size-full wp-image-2226674\" src=\"https://www.dailymaverick.co.za/wp-content/uploads/2024/06/Koeberg-3.jpeg\" alt=\"\" width=\"720\" height=\"349\" /> <em>Gabriel Klaasen from Project 90 by 2030 presents comments at the public hearing for Koeberg's LTO extension in Athlone on 7 June 2024. (Photo: Peter Becker)</em>[/caption]\r\n\r\n<span style=\"font-weight: 400;\">The seismic study (more than 1,000 pages) and the Duynefontein Site Safety Report were only made available in April 2024, leaving an unreasonable time for that information to be reviewed.</span>\r\n\r\n<span style=\"font-weight: 400;\">“We believe that the evidence makes it clear that there is more than sufficient reason for the NNR to refuse the life extension of Koeberg. If the NNR is not ready to arrive at that conclusion, then the missing and redacted information which is being withheld from the public must be made available with a reasonable comment period. The issues with the non-compliant emergency plan must also be remedied as a matter of urgency,” KAA said in its submission.</span>\r\n\r\n<span style=\"font-weight: 400;\">In the presentation for Project 90 by 2030, Klaasen said: “The International Atomic Energy Agency </span><a href=\"https://www.iaea.org/newscenter/pressreleases/iaea-concludes-long-term-operational-safety-review-of-south-africas-koeberg-nuclear-power-plant\"><span style=\"font-weight: 400;\">(IAEA) </span></a><span style=\"font-weight: 400;\">identified 15 safety concerns in its report from 2022. Eskom’s safety case report has yet to set out practical and long-term solutions to fix all these concerns. The IAEA is set to come back to South Africa to assess Koeberg in September 2024.</span>\r\n\r\n<span style=\"font-weight: 400;\">“Would it not be advisable to wait for the outcome of this mission before any decision on the lifetime extension is taken?” </span>\r\n\r\n<b>Read more in Daily Maverick: </b><a href=\"https://www.dailymaverick.co.za/article/2022-04-04-koeberg-gets-a-safety-thumbs-up-from-iaea-while-eskoms-veil-of-secrecy-lingers/\"><span style=\"font-weight: 400;\">Koeberg gets a safety thumbs up from IAEA while Eskom’s veil of secrecy lingers</span></a>\r\n\r\n<span style=\"font-weight: 400;\">Klaasen said many other countries were looking at extending the lifetime of their nuclear power stations. </span>\r\n\r\n<span style=\"font-weight: 400;\">“A comparison with LTO processes in France, where they are dealing with identical nuclear power plants, shows that France is taking many more precautions and upgrades than South Africa. France is investing significantly to ensure its plants are as close to Generation III safety standards as possible. Eskom maintains that Koeberg’s Generation II design is safe, and the NNR does not question this claim.</span>\r\n\r\n<span style=\"font-weight: 400;\">“Why is it that France is taking these precautions while second-best safety measures are good enough in South Africa?” Klaasen said.</span>\r\n\r\n<span style=\"font-weight: 400;\">Another difference in approach between France and South Africa, Klaasen said, was the length of the operating licence. While Eskom wants to extend Koeberg’s lifespan by 20 years, France is looking to extend its plants’ lifespans for 10 years to prove the safety of the plant is intact before extending the lifetime for a second time.</span>\r\n\r\n<span style=\"font-weight: 400;\">“In addition, France has decreased the intervals between integrated leak tests to five years, yet South Africa will keep the 10-year intervals. The last leak test happened nine years ago but the next one is only scheduled for later this year and therefore will be after the NNR has made its decision on the life extension,” Klaasen said.</span>\r\n\r\n<span style=\"font-weight: 400;\">Elaine Mills from KAA – a civil society alliance of citizens with reservations about the use of nuclear energy in South Africa – said that Eskom should have submitted its life extension application, safety case and supporting documentation at least two years before the NNR decision deadline of 21 July 2024.</span>\r\n\r\n<span style=\"font-weight: 400;\">However, she said that when Eskom failed to meet this deadline, the NNR adjusted the regulations to allow Eskom to submit later and instead of having two years to study the application, the public was given an unreasonably short time to comment, while some reports were incomplete or still in draft format.</span>\r\n\r\n[caption id=\"attachment_1467305\" align=\"alignnone\" width=\"720\"]<img class=\"size-full wp-image-1467305\" src=\"https://www.dailymaverick.co.za/wp-content/uploads/2022/11/GettyImages-1229796241.jpeg\" alt=\"\" width=\"720\" height=\"360\" /> <em>The Koeberg nuclear power station as seen from Melkbosstrand beach in Cape Town on 25 November 2020. (Photo: Dwayne Senior / Bloomberg via Getty Images)</em>[/caption]\r\n\r\n<span style=\"font-weight: 400;\">“Eskom being late in completing required studies is no justification for NNR setting unrealistic deadlines and rushing the public through the process. The over 1,000-page seismic study was only made available in April 2024, leaving hardly any time for information to be read and understood.</span>\r\n\r\n<span style=\"font-weight: 400;\">“In addition, Vaalputs communities were only included in April 2024, even though low and intermediate Koeberg waste is shipped to the area where they live… The NNR extended public consultation deadlines numerous times but did not communicate this clearly,” she said.</span>\r\n\r\n<span style=\"font-weight: 400;\">The KAA said one inevitable consequence of granting the life extension would be 20 more years of low and intermediate waste being shipped to Vaalputs. </span>\r\n\r\n<span style=\"font-weight: 400;\">“Despite this, the NNR did not appear to take into consideration the communities living in that area. Instead of including those communities from the start in January 2023, the NNR waited until April 2024 before allowing them to participate,” the KAA said.</span>\r\n\r\n<span style=\"font-weight: 400;\">Klaasen said: “We would like to highlight the health issues of those who have worked at Koeberg Power Station and surrounding areas. The lack of medical records and review is not proof of a clean bill of health.”</span>\r\n\r\n<span style=\"font-weight: 400;\">Klaasen also raised concerns about safe and clean water supplies as Cape Town is a water-scarce city that came close to Day Zero. “The long-term operation extension will require massive amounts of water. In a changing climate we cannot risk the misuse of this scarce resource.” </span>\r\n\r\n<span style=\"font-weight: 400;\">Klaasen, Mills and others expressed concern about the lack of a transparent and accessible evacuation plan, leaving communities unsure of what to do in the case of an emergency.</span>\r\n\r\n<span style=\"font-weight: 400;\">These issues have been raised before, but Mills said there had been no improvement in communication.</span>\r\n\r\n<span style=\"font-weight: 400;\">“It is vital that this life extension application is subject to the most rigorous public scrutiny within a reasonable time frame to allow experts to offer their views and expertise to assist the NNR in making its decision,” Mills said.</span>\r\n\r\n<span style=\"font-weight: 400;\">Mills added that there were more than enough reasons for the NNR to refuse the life extension of Koeberg and if the regulator was not ready to arrive at that conclusion, then missing and redacted information being withheld from the public must be made available with a reasonable comment period. </span>\r\n\r\n[caption id=\"attachment_2226683\" align=\"alignnone\" width=\"720\"]<img class=\"size-full wp-image-2226683\" src=\"https://www.dailymaverick.co.za/wp-content/uploads/2024/06/Koeberg-2.jpeg\" alt=\"\" width=\"720\" height=\"483\" /> <em>Civil society members protest outside the public hearing for Koeberg's LTO extension in Athlone on 7 June 2024. (Photo: Peter Becker)</em>[/caption]\r\n<h4><b>Health, safety and socioeconomic consequences</b></h4>\r\n<span style=\"font-weight: 400;\">Joyce Malebo, a member of Project 90 by 2030 and a concerned senior resident, said that they were there as women talking on behalf of women who cannot express themselves. She said Eskom must not be granted the 20-year extension because nuclear waste was putting their lives at risk.</span>\r\n\r\n<span style=\"font-weight: 400;\">“Eskom is concerned about profit and not human safety. Why can’t we build renewable solar and wind instead?” she said.</span>\r\n\r\n<span style=\"font-weight: 400;\">The Southern African Faith Communities’ Environment Institute’s (Safcei) executive director, Francesca de Gasparis, said they had made several submissions since Eskom’s application was announced and raised serious concerns including that the documents made available for comment included a heavily redacted LTO Safety Case, and many important source documents relied upon by Eskom in the LTO Safety Case had not been made available.</span>\r\n\r\n<span style=\"font-weight: 400;\">De Gasparis said that while some required safety improvements had been implemented, others remained planned for implementation either before the LTO or during the period of the LTO. </span>\r\n\r\n<span style=\"font-weight: 400;\">It was submitted that the LTO documents made available to Safcei did not address the health, safety and socioeconomic consequences of a beyond-design catastrophic incident, such as a reactor core meltdown, or provide up-to-date information justifying the claim that the LTO was economically justifiable. </span>\r\n\r\n<span style=\"font-weight: 400;\">De Gasparis said there had been unacceptable delays in maintenance and safety upgrades at Koeberg, and a significant amount of information highly relevant to the safety of the reactor was still not available to the public. </span>\r\n\r\n<span style=\"font-weight: 400;\">“There are 41 references in the… Koeberg Safety Analysis Report which looks at severe nuclear accidents such as a meltdown. The public is advised that, ‘This document contains multiple instances of third-party confidential information and cannot be made available to the public’ – which, it is submitted, is insufficient information or justification for withholding disclosure, given the inherently hazardous nature of nuclear power generation,” she said.</span>\r\n\r\n<span style=\"font-weight: 400;\">Based largely on the observations of the IAEA’s Safety Aspects of Long Term Operation mission of 2022 and work done in the interim, De Gasparis said the conclusion was “inescapable” that the plant was not ready from a safety point of view for the authorisation to continue beyond its current licence.</span>\r\n\r\n<span style=\"font-weight: 400;\">“The long-term extension of the licence application process thus far has been marred by significant procedural unfairness, mainly as a result of the failure to disclose information critical to meaningful participation timeously. As a result, those most likely to be affected by a nuclear accident have been deprived of the right to properly participate in decisions about the future of the reactor,” she said. </span><b>DM</b>",
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