Behind Eskom’s nuclear environmental impact assessment

Cape Town - Deidre Herbst, Eskom’s environmental manager, gives the background behind Eskom’s environmental impact assessment (EIA) for the first nuclear build plan:

Eskom initiated the EIA for nuclear 1 in September 2006. The EIA process has been protracted due to additional studies requested by the NGOs and the Department of Environmental Affairs (DEA), extended public participation processes and stoppages to the project due to budget constraints. The EIA was in its final public review period from 23 September to 25 November 2015. The final report will be submitted to the DEA for approval in February 2016.  

Background

Gibb (Pty) Ltd was appointed by Eskom Holdings Limited (Eskom), in August 2006, to undertake an Environmental Impact Assessment (EIA) and Environmental Management Plan (EMP) for the proposed construction of a nuclear power station (Nuclear-1) and associated infrastructure on one of five pre-identified alternative siting areas, which had been identified more than 30 years before, through the nationally significant infrastructure project (NSIP). 

The five alternative siting areas that were investigated at the scoping phase, were (1) Brazil and (2) Schulpfontein in the Northern Cape on the west coast between Kleinzee and Hondeklip Bay, (3) Bantamsklip in the Western Cape on the coast next to Pearly Beach, east of Hermanus, (4) Duynefontein, in the Western Cape next to the existing Koeberg power station and (5) Thyspunt in the Eastern Cape on the coast between Oyster Bay and St Francis Bay.

MAP: The five sites identified

The scoping phase commenced in September 2006 and ended in November 2008, under the Environment Conservation Act (Act 73 of 1989). The Final Scoping Report, which recommended exclusion of Brazil and Schulpfontein from further specialist environmental studies for the Nuclear-1 EIA, was accepted by the DEA on 19 November 2008.

This acceptance gave permission for the project to continue to the EIA phase, but the permission to proceed with the EIA phase was subjected to amendment of the Plan of Study for EIA (PoS EIA), which was finally approved by the DEA in January 2010.   

Following the EIA phase, the Draft Environmental Impact Report (Draft EIR) was prepared and provided for public comment on 6 March 2010. The period for comment on the Draft EIR was extended twice, and the end of the extended comment period was 30 June 2010. Due to comments received during this period, the EIA team had to revise selected specialist reports and produced a Revised Draft EIR (Version 1) for public review from 6 April 2011 to 7 August 2011. This report recommended Thyspunt. 

The DEA appointed a review panel to review the Draft EIR, the panel recommended additional specialist studies including a radiological impact assessment, beyond design accident studies and detailed studies for Thyspunt access routes. Subsequent to various stoppages to the project, due to budget and contractual constraints, the latest Revised Draft EIR (Version 2) has been completed and was released for public comment on 23 September 2015.  

Challenges and delays to date

November 2008: Permission to proceed with the EIA was subjected to amendment of the Plan of Study for EIA. The amendment of the PoS EIA included amending the scope of the EIA to make allowances for additional site access routes, amendments to the Emergency Planning Zones and various engineering method statements. Consequently, several specialist studies had to be re-initiated, resulting in an initial delay of approximately eight months.

All amendments to the PoS for EIA were completed and the document was re-submitted for public comment, for a 30-day comment period. The document was submitted to the DEA for approval, which took 6 months; from July 2009 to January 2010.

March 2010:  The Draft EIR was made available to the public for review and comment.  At the request of the public, the duration of the official comment period was extended twice.  The eventual comment period was from 6 March to 30 June 2010, a total of 116 days.   

During this period, key stakeholder meetings were held with local communities, the Khoisan Council and the South African Heritage Resource Association. The result of these meetings was a need for revision of the original Draft EIR.

April 2011: The Revised Draft EIR (Version 1) was made available for a 45-day public review and comment; from 6 April to 7 August 2011. As a result of comments received from the review of the Revised Draft EIR (Version 1), some of the specialist studies, in particular dune geomorphology, cultural heritage, marine and transport impacts had their scopes extended and the respective reports updated.

August 2011: The Revised Draft EIR (Version 1) was submitted to the DEA for comment. It took the DEA 15 months to comment on the Revised Draft EIR (Version 1); from August 2011 to January 2013.

January 2013: comments were received from the DEA and, from these comments, new studies had to be commissioned and conducted, and some existing studies had to be revised and updated.

Primary recommendations by the DEA

-    The DEA comments recommended the following, to name a few:

-    Independent peer review of all specialist studies, including the Eskom Transmission integration report. (This is not a legal requirement, but due to public opposition has been requested to assure integrity of specialist studies.)

-    All associated infrastructure such as roads and ports’ outside site boundaries, which do not form part of the EIA must be briefly described and assessed to determine cumulative impacts.

-    The methodology to determine the preferred site was not adequate and must be revised.  

-    An independent nuclear expert should have input to the revised draft EIR (version 2).

-    The EMP was only for Thyspunt, the preferred site.  EMP’s for the other two sites need to be submitted.

-    Additional studies, including town planning and radiological assessments, are required.

TABLE: This table indicates new specialist studies commissioned and those updated:

Source: Eskom

Nuclear-1 EIA facts and figures

-    One of the largest EIAs in South African history; at a cost in excess of R 25m.

-    In excess of 4500 Interested and Affected Parties on the Stakeholder database.

-    Each report consists of 12 lever arch files.

-    Reports were made available at 33 public venues.

-    Executive summaries of the main report and specialist studies translated into Afrikaans and Xhosa.

-    32 specialist studies were conducted.

Way forward

The EIA process for the nuclear 1 project is almost completed. It is anticipated that, after the current public participation period, which commenced on 23 September 2015, comments will be incorporated into the Final Environmental Impact Report (Final EIR) and submitted to the DEA for decision. The submission of the Final EIR is anticipated to take place in February 2016.

In terms of legislation, the DEA has a total of 115 calendar days, from the date of submission, to issue a decision.  There are several activities which take place in this period, including 14 days to acknowledge receipt of Final EIR, 60 days to acknowledge acceptance of FEIR, 45 days to make a decision, and a further 10 days to notify the applicant of the decision.

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