Koeberg’s 40 year operational licence comes to an end in July 2024 and Eskom is pushing for a twenty year extension from the National Nuclear Regulator (NNR). The NNR is now holding public hearings in Tableview, Athlone and Atlantis from the 6th to the 8th of June to consult on the proposed life extension.

The process of public consultation run by the NNR has been beset by issues. The NNR announced the first comment period in January 2023 which civil society organisations found inadequate due to information that was being withheld from the public by both Eskom and the NNR. Similar complaints have been made about this follow up process of public hearings and submissions.

Lack of transparency
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 civil society organisations have had to resort to repeated PAIA applications for the release of vital documents. Instead of simply releasing all the relevant information, the NNR and Eskom have fought a ‘Stalingrad’ defence, releasing additional information in dribs and drabs only in response to pressure via lawyers’ letters. The NNR for example has simply ignored requests for copies of documents showing that the 14 non-compliances from the November 2022 emergency drill have been addressed.

In addition, some major studies such as the Seismic study (over 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 to make a meaningful submission.

“Our voices as youth and communities are essential when it comes to the decisions our leaders are making when it comes to this long-term operation extension licence,” says youth activist, Gabriel Klaasen. “Approaching the hearings, the topics of transparency, waste, and poor governance of Koeberg are fresh in my head. Having struggled to properly go through the documents that have only recently been released, there is no time for meaningful and fully informed participation.”
Inadequate consultation with Northern Cape communities

One inevitable consequence of granting the life extension would be 20 more years of low and intermediate waste being shipped to Vaalputs. 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.

At the recent hearings in the Northern Cape, a young woman from Concordia said: “Nuclear waste is a technical issue and the authorities hope that we remain uninformed, but we take the initiative to share information in our community to understand nuclear waste and what is already being buried at Vaalputs. We know about low level and high level waste (which will eventually come to Vaalputs). Communities in this area are not recognised and things happen here without our permission. We say a strong NO to extending Koeberg for another 20 years.”

A resident from Leliefontein near Vaalputs said: “I am concerned about our groundwater. We have heard of nuclear waste spills and we would like to know about our groundwater. I have lived here for 56 years in Leliefontein and we can’t allow our area and our future to be contaminated by more nuclear waste.”

A Kamiesberg communal farmer said the following: “People hardly ever speak to us and explain what is happening at Vaalputs. I know that the bigger danger is still to come with more waste coming from Koeberg. Never in my life will I give permission for another 20 years of nuclear waste to be buried here.”

“On our trip in the Northern Cape, what stood out for me was the promises made by NECSA (South African Nuclear Energy Corporation) with regards to a secondary school and a ‘game reserve’,” says Project 90 by 2030’s Director, Lorna Fuller. “What the people really want is the assurance that their groundwater is safe – being regularly monitored – and the results shared with them. They want transparency around Vaalputs and the operations in that area, especially since Namakwaland is so sacred. There was a resounding NO to the additional 20 years of waste potentially coming their way!”

Incomplete studies and lack of impartiality
The NNR’s primary responsibility is the safety of the public and environment. According to civil society organisations, it would therefore be unacceptable to consider granting the life extension licence while the safety case is based on, or makes references to, incomplete or draft studies. To fulfil its mandate responsibly, the NNR must insist that all studies are completed, and then released to the public with a suitable comment period before the NNR makes any decision on the licence.

“There has been a pattern of the NNR modifying regulations, safety requirements and timelines in order to cater to Eskom,” says Koeberg Alert Alliance spokesperson, Lydia Petersen. “Unfortunately from a public perception point of view, Eskom is also a licence holder which is responsible for the majority of the NNR’s revenue. We have seen a stereotypical ‘tick-box’ approach being applied.

“The result is that instead of having the originally planned two years to study the application as originally envisaged, the public are given unreasonably short periods in which to make comments and submissions, and that some reports are incomplete or in draft format,” says Petersen.

Climate change risks
Scientific predictions as well as recent experience both locally and globally have shown that previously unexpected weather is inevitable, including storms, storm surges combined with sea level rise, and unusual torrential rains. This obviously involves risks to the plant, the potential need to supply diesel to the onsite generators, the transport of nuclear waste over untarred roads in the Northern Cape, the disposal pits at Vaalputs, etc.

According to a submission from the KAA: “The Safety Case Report mentions extreme storms and climate change in passing, but does not sufficiently address either. The documents submitted by Eskom do not cover the risks associated with these topics sufficiently, nor do they indicate how Eskom would mitigate them.”

Emergency and evacuation drill
The ability to evacuate if necessary is an inherent part of the safety of a nuclear plant. The response of the NNR to non-compliances is not up to the standard of international best practice. A year after the drill in November 2022, there remain non-compliances which are unresolved. In the USA, any non-compliances result in a 90 day ultimatum to the plant operator to redo the drill with zero non-compliances, or have their operating licence withdrawn.

According to the KAA submission: “This is what we would expect from a strong, independent regulator which takes their mandate of protecting the public seriously. In stark contrast, after a drill the NNR sends a report to Eskom, which is kept secret from the public, and then requests Eskom to indicate within 6 months how they intend to rectify any issues. In the case of the November 2022 drill, there were 14 non-compliances. It was revealed at the Koeberg Public Information Safety Forum that Eskom failed to ensure that all these issues were fully addressed within the 6 months, and yet the NNR has not taken action.”

Conclusion
While the probability may be small, the consequences of a major nuclear accident at Koeberg would be catastrophic, resulting in the displacement of thousands of people, the collapse of the tourism industry in Cape Town and possibly South Africa. There would be massive economic damage and untold human suffering. The primary cause of the Fukushima nuclear disaster was a regulatory failure according to the official report to the parliament of Japan, and hence it is vital that all aspects of this life extension application are subject to the most rigorous public scrutiny with a reasonable time frame, to allow experts from South Africa and all over the world to offer their views and expertise to assist the NNR in making its decision.

“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,” according to the KAA submission.

This is the last chance for the public to have a say about the Koeberg life extension and the potential impact that could have on the communities surrounding the nuclear power plant.

NNR Public Hearings:
Thursday, 06 June 2024, 10:00 – 14:00: Western Cape, Church on the Rise, Tableview.
Friday, 07 June 2024, 10:00 – 14:00: Western Cape, Belthorn Recreation Centre, Athlone.
Saturday, 08 June 2024, 10:00 – 14:00: Western Cape, Atlantis Multipurpose Sports Centre, Atlantis

ENDS