Cape Town - Thyspunt Alliance's Trudi Malan responds to Dr Kelvin Kemm's opinion piece regarding the proposed nuclear site being on the verge of getting a green light.
EDITOR'S NOTE: Fin24 interviewed Deidre Herbst, Eskom’s environmental manager, who said the environmental impact assessment was not being fast-tracked. Read the interview as well as her full statement below, and see Dr Kelvin Kemm's opinion piece that this opinion story refers to.
ADD YOUR VOICE: Do you have an opinion or a story regarding nuclear you want to share? Tell us now.
By Trudi Malan
THE decision to use nuclear or not is a national decision and should be engaged with on a national level. I am more concerned with the environmental impact assessment (EIA) process for Nuclear 1.
This process in itself has been fraught with mismanagement and misrepresentations. The environmental consultant for the project is Arcus Gibb – apparently now known as Gibb.
I can entertain you for hours with the mistakes and missing pages, figures and tables that we were presented with in the first draft, but that is water under the bridge.
The better edited draft with fewer inaccuracies was presented to us as the second draft of the EIA. We had to submit our comments in August 2011. Due to a variety of reasons provided by the environmental practitioner and Eskom, the process went into a holding pattern.
We received very little information or updates from the consultants. Release dates for the next draft were promised, but passed by like the “Days of our Lives”. The last formal communication from the EAP about the release of the next draft stated that it would be released in February 2015.
Nothing was released in February and then suddenly in September 2015 the third draft was released. (The EAP refers to the document as the second version of the draft environmental impact assessment).
The release of the document at the end of the year created countless problems for us as a large number of the specialists willing to assist with the review of the various studies are understandably fairly busy at this time of the year. In spite of several requests via our lawyers (Cullinan & Associates), we have not been granted a fair extension. But be that as it may – we submitted what we could on December 10.
We have obviously been referred to as NIMBYs (Not in my back yard), but that is the nature of the beast for all EIAs. We tried as far as possible to constructively engage with the information provided to us in the impact report.
It very quickly becomes clear that there is bias from the consultant in favouring the development at Thyspunt.
Thyspunt is a green field site and was deemed not viable for the development of the Pebble Bed Modular Reactor (by the same consultants, strangely enough) because of the lack of access roads, infrastructure, power lines, etc.
Will development be sustainable?
Dr Kelvin Kemm’s contention that it will lead to development in the area does have some element of truth. Of course development will happen. But will this development be sustainable?
The Kouga Municipality is not a poster child for good governance and service delivery. At present we have a backlog of 10 000 people on the housing list. The provincial Department of Environmental Affairs (DEA) has issued negative records of decision for several housing applications due to the lack of services in the area.
Sewerage, water, electricity, hospitals, schools and clinics are all in very short supply and completely over-subscribed. If we consider the massive social impacts that occurred at Lephalale during the Medupi construction, even Eskom admits that it is better to develop close to areas where structures are already in place.
A critique of Dr Kemm's story
While I could write volumes about the issues contained in the EIA, I prefer to address the inaccuracies in the opinion piece by Dr Kemm.
Dr Kemm is welcome to state his opinion about nuclear, but he should refrain from expressing opinions on factual issues, therefore turning an opinion piece into nothing more than propaganda.
Dr Kemm writes: “The process has just been completed, with the last legally required public meeting being held in Port Elizabeth in December. The final recommendation was published a few weeks ago and the environmental investigation team has recommended that the Thyspunt site, near Jeffreys Bay be used. (Actually the site is nearer Oyster Bay, a few kilometres south of Jeffreys Bay.)”
The only thing that has been completed is the public participation process for the second version of the draft EIA for Nuclear 1.
To date not all the minutes of the various meetings have been published, and attendees will have 21 days to submit comments about the accuracy of the minutes. The comment period for submissions closed on December 10 2015.
The EAP will now have to compile all the comments and issues into a “comments and response report”.
They have to provide answers to all the issues and questions raised at the various meetings and in the various submissions.
Once they have completed this, they can submit the final environmental impact assessment to the DEA. They have to advise all interested and affected parties about the submission, who will then have another period to provide input directly to the department.
Only after this process has been concluded can the DEA start engaging with the document. Previously, it took them nearly two years to provide the EAP with their inputs, but let us presume that political pressure fires them up into overdrive – they can maybe issue a record of decision within three months after the final document has been submitted.
The public will then have the opportunity to appeal the decision. Once the appeals process has been finalised and if the public is still not happy with the outcome, we can ask for a review.
That is when we will be going to court. In short – the DEA has a great deal of information to consider and they are legally bound to make a best practice environmental choice, not a “this site suits the proponent best” choice.
Dr Kemm writes: “It is now up to cabinet to make the formal government decision, based on the recommendations of the scientists.”
Cabinet will not be making the decision – that will be unlawful. The decision will be made by the DEA. The minister will only get involved once the appeal process starts. Cabinet is definitely not equipped to make an environmental decision.
Dr Kemm writes: “The geology under the ground has been examined. So have the weather patterns, going back historically for many years. The fauna and flora have been documented and studied. The sea currents, sea life, bird populations, and everything conceivable has been studied.”
Yes, everything conceivable has been studied and the studies clearly indicate that Thyspunt is a far more sensitive site from a biodiversity perspective than the other sites.
The mere fact that everything has been studied does not mean that because it was studied it is now OK to proceed. It is about more than just the birds and the bees and the flowers and the trees.
It is about ecosystem services and their effects on the development and effects of the development on other downstream infrastructure. It is clear from the EIA that there are massive inconsistencies in the data.
Allow me an example:
On page 9-49 of the Main Report under 9.7.1 – Air Quality & Climate:
a) Land Use and Topography
“The absence of any industrial activities in the vicinity of Thyspunt results in very low current air pollution levels. Cape St Francis is located 13 km east of the site, and Humansdorp, which is relatively more industrialised, is located approximately 18 km north of the site. However, the prevailing winds, i.e. easterly and westerly, offer little opportunity to carry air pollution from Humansdorp to the site.”
On the same page 9-49
“Wind Field: From the historical dataset produced by Eskom (1987), it is clear that the most dominant wind direction in this region is from the west northwest to northwest.”
Dr Kemm writes: “The site itself is just under 4 000ha in size, of which about 50ha will be used for the nuclear plant. If the whole site is equated to a chess board, the nuclear plant will use one square. The other 63 squares will stand vacant forever, in line with international standards.”
As per the EIA the footprint of the station, without the stockpiles, roads and HV yard is 250ha.
Dr Kemm writes: “Stories that the plant construction will devastate the entire 4 000ha plus the seabed are just untrue. Every procedure, for activities such as moving beach sand, is prescribed in detail. Not only is this in line with international protocol, it is also just good business practice. The more one knows in advance which procedures will be used, the more efficiently the work can be done when building starts.”
No beach sand is to be moved; 6.3 million cubic metres of sand has to be excavated to get to bedrock. The granule size of the sand is actually different to that of beach sand and this must be considered.
The current study indicates that three million cubic metres would be stockpiled and three million cubic metres would be pumped into the ocean as slurry. This slurry will drift above the sea bed as a plume and suffocate a large amount of organisms, including the squid spawning grounds.
The biggest problem is actually that none of these processes is described “in detail” as we still do not know what kind of technology will be used, because no vendor has been selected. The application was therefore for an “envelope of information”, but no plans can be provided for exactly what the intake and outfall tunnels will look like.
Some of the mitigation measures described in the document have never before been deployed, so no detailed information is available.
Dr Kemm writes: “That means building the access roads, levelling the ground, preparing for the concrete foundations and a host of other activities, independent of choosing the one or more international partners who are offering their nuclear plant designs.”
The EIAs for the proposed access roads have not yet commenced and they did not form part of this EIA. There are therefore at least three outstanding EIAs that will have to be completed before any work can start on access roads.
This information is contained in the report (Eskom Nuclear-1 Project at Thyspunt Site Road Investigations for EIA Process Addendum). Without access roads, it will be very difficult to get the earthworks going on the site; this would be contradictory to the environmental management plan.
Dr Kemm writes: “What was the result? Well, the total amount of people killed by nuclear radiation was zero. The total harmed by radiation was zero. The total private property harmed by radiation was zero. Nuclear radiation hurt nobody.”
Will we ever know the real costs?
I am not a nuclear expert, but I will not disrespect the 50 000 people who had to leave their homes, businesses and lives behind with a trivial comment like the above by Dr Kemm – that smacks of propaganda.
Koeberg was not on time, in actual fact. It was 18 months behind time. It was a project of a government that needed to hide a bomb-building project.
Dr Kemm also fails to mention the heritage of our First Nation. Thyspunt is a site that can be called the Cradle of Modern Human Man, but the most important part of that heritage is the heritage of the First Nation.
They were removed off their roaming grounds; they were hunted and called vermin. It would seem that nothing has changed.
* Trudi Malan is the coordinator of the Thyspunt Alliance.