Att: Ms Albertina Kakaza
Dear Mr Langa Zita


Thank you for this opportunity to air views on Nuclear Energy in South Africa.

1. We all know Nuclear Power Stations and the storage of the hazardous radio active waist is Not 100% safe . Radio active waist remains hazardous for 240 000 years , no debate on responsibility there. An accident will cause very serious problems to the health and well being of South African citizens. Our country is also not 100% seismically inactive and the Radio active waist issue is a world wide problem that still has no solution.

2. Nuclear Power is Not sustainable development. Too often the word Sustainable Development is used where it does not belong. Further more the jobs that are created by these power stations will be few and will be for highly experienced , trained and sometimes foreign personal.

4. New technologies are coming to life all the time and by the time new nuclear power stations are running they will be out dated by Renewable Energy .

4. Only "Renewable Energy " rightfully deserves to be classed as " TRUE Sustainable Development" technology.

5. The statement used by Eskom that renewable energy's only work when it is sunny or windy is false .
When we produce more than we use with renewable energy we should incorporate the "hydro pump water uphill and let it flow down hill to generate energy later system" which would prove that renewable energy can be used at any time. There is also the air car example as another technology. These and other new and old technologies should be developed and incorporated with renewable energy. Now there is even tidal energy !

6. Government subsidies and tax incentives for renewable energy should be a top priority today.
Creating affordable alternative energy for all will mean healthy competition and a great market for renewable energy .
As a result a new industry will develop in South Africa creating countless jobs and new PROUDLY SOUTH AFRICAN companies and products. : )
This would all dictate accelerated technology in the field of renewable energy letting us all sleep at night.

7. Solar power should be made affordable for the individual to install at home.
Since solar panels are placed on the roof , no EIA process is needed .

8. Many leading countries push alternative energy , and better efficiency. For the sake of serious Global Issues, lets not follow , lets proudly lead the way !
Below is a nice video example of a booming solar industry in California:

http://www.youtube.com/watch?v=jX-zfCDhHrY

9.We have faxed through our F.A.C.T. members list with objections and suggestions and have received conformation of receipt.

Once again , we sincerely appreciate the opportunity to speak.

Kind Regards
Ryan Donnelly
Founder and chairperson of F.A.C.T. ((( for a clean tomorrow )))

For the attention of: Ms Albertina Kakaza

Mr Langa Zita
Chairperson
Portfolio Committee
Department of Environmental Affairs and Tourism
Nuclear Energy Hearings

Dear Sir

RE: NUCLEAR ENERGY IN SOUTH AFRICA

The request from Parliament for written comment by the public on nuclear energy in South Africa has queried the impacts of this development on the following:

1. socio-economic
2. waste management
3. security of supply
4. human resource development
5. science and technology

I would also like to add:

6. environmental costs
7. health

1. SOCIO ECONOMIC
Firstly the socio-economic issue is one of grave concern for all South Africans. The economist, Professor Stephen Thomas was employed by the South African government to investigate nuclear energy and its impact on the economy as part of a panel of researchers. The official reports conducted as a result of this investigation have never been made known to the South African public, although they were presented to Cabinet and research was published in nuclear trade journals with a narrow readership.

Professor Thomas made his concerns about the financial implications of embarking on a nuclear programme very clear(1). He stated that in other countries of the world where nuclear reactors had been built, the huge costs of construction had been supported by private investors. He warned that financial institutions usually did not invest in nuclear development as it was seen to be too risky a venture.

Aside from the huge construction costs, there would also be huge decommissioning or cleaning up costs - and these were apparently not factored in to the South African programme. There would also be vast liability costs in the case of accidents that could result in deaths to labourers, as well as poisoning and deaths to a wide area around the reactor (2).

It is for this reason that the Cape Town courts are currently prohibiting building in an area 5km around Koeberg. This has huge economic implications for South Africa because wherever a nuclear reactor is built, other industries will suffer:

*The tourism industry suffers, since no one wants to visit an area where radioactivity may be a concern for themselves or their children.
*Agriculture suffers, since no one wants to buy food produce from an area where radioactivity could leach into water supplies or be released into the air and
*Real Estate values plummet, so that the housing and other business development markets suffer. (3)

What this means is that the huge start up costs (currently stated to be R150 billion over five years by Eskom, although apparently rising every year) are added to decommissioning and liability costs as well as the losses to other sectors of the economy. (4)

The projected markets for nuclear energy may also not exist. (5) Most developing nations cannot afford to build nuclear reactors themselves and so would not embark on a nuclear programme. Many nations are also now concerned about global warming and the effects on the environment of destructive industries (and this includes nuclear reactors despite advertising to the contrary) and so energy that is sold or marketed as "green" has found instant buyers, whereas other "dirty" industries (including nuclear) cannot be endorsed by businesses as "green" and are not bought. This means that if South Africa embarks on a nuclear programme with the idea of exporting either reactors or energy, a market will be hard to find and this country will be left with yet another industrial "white elephant".

2. WASTE MANAGEMENT
The second issue of waste management is also a major concern for all South Africans. Currently high level radioactive nuclear waste has been produced by overseas nations that has a lifespan of thousands of years - and there is nowhere to put this waste.(6)

According to a recent report a new spent nuclear fuel facility will have to be constructed: "In other countries that make use of nuclear energy, the cost of building such a waste facility has reached around R5-billion, says Necsa nuclear liability management divisional manager Dr Piet Bredell.

"Low- and medium-level radioactive nuclear waste from Koeberg is currently transported to the Vaalputs near-surface repository, in the Northern Cape, where it is buried in seven- to eight-metre- deep trenches. Higher-level waste, such as spent nuclear fuel, is kept in storage pools on site at Koeberg. Necsa’s own waste is stored on site at Pelindaba. Low-level waste typically consists of gloves, clothes, paper and cleaning material, and medium-level waste of resins, filters and smaller components.

"It is planned that high-level waste from Koeberg and Pelindaba, and possibly other nuclear plants, will go to a “future high-level waste repository site”, says Bredell. Such a deep geological repository is typically 500 m to a kilometre deep, and costs around R5-billion to develop. Bredell says South Africa is in the process of preparing legislation to establish a radioactive waste-managemen t agency, as well as a waste fund, all before 2010. It is expected that the Bill regarding the agency will be before Parliament in March next year, while that on the fund will follow later.

"It will be the task of the radioactive wastemanagement agency to initiate the project to establish a deep-level disposal site for South Africa. The establishment of such a site is normally an extremely sensitive social issue, with Bredell noting that several similar initiatives failed abroad, as they were “wrongly initiated”. “It can take up to 20 years to get a site adopted.” One example of where this happened is the proposed Yucca mountain site, in the US. “We need to ensure the timely selection of a site for Eskom’s nuclear power station needs,” emphasises Bredell. Eskom Generation nuclear fuel procurement manager Hans Lensink says the power utility has a reference plan for its spent nuclear fuel, which includes not only disposal, but also reprocessing. Reprocessing nuclear fuel reduces the volume of waste, through the removal of plutonium and uranium. However, even reprocessing nuclear fuel leaves waste products in need of disposal at the end of the cycle". (6)
When issues have arisen regarding waste spills, the Nuclear Energy Corporation of South Africa (Necsa) has refused to make the information known to the public. This lack of accountability on the part - not only of Necsa, but also Eskom and the National Nuclear Regulator (NNR) have led the South African public to doubt whether they could ever trust in future transparent dealings with these bodies. (7)

Necsa requires environmental organizations that are operating on behalf of the public - like Earthlife Africa - to go to court in order to get information regarding public safety issues. This smacks not only of a lack of transparency, but also a deliberate attempt to hide the truth from the public.

Workers who have had complaints against Necsa regarding health compensation have also been forced to go to court and still have received no reddress from the company. And yet research documents from the company and from the Department of Minerals and Energy (DME) clearly show the dangers of radiation to human beings.

This has been highly misleading for the South African public - nuclear energy has been advertised through the press in a public relations campaign as being both "green" and "safe" which it is obviously not. The waste that builds up through the uranium mining and milling process to the nuclear reactor itself and the spent fuel rods all comprises an extreme danger to the immediate community and the nation as a whole.

People have learned from the accident at Chernobyl that there are immediate deaths and a wide area of land, air and water polluted for years to come causing cancers and mutations in children and pregnant women and sterilization of men. Nuclear waste cannot just be "swept under the carpet" or buried out in the desert. It will eventually pile up and pose a disposal crisis. (8)

The United States and Europe have still not been able to find a site to locate a deep repository for high level waste since no one wants it in their backyard. They cannot store it at sea, or launch it into space. There is simply nowhere to put this waste. (9)

In this sense, nuclear energy is not sustainable since it requires 50 000 tonnes of uranium to fuel a reactor every year and the uranium supply will come to an end but the waste will not. (10) Even the waste that the reactor deems "low level" that is pumped back into the air and water systems has proven to be deadly to residents who live around the water sources.

Research has shown "cancer clusters" around dams where the community fish and swim, such as the Trawsfynydd Lake in Wales. Ex-Environment Minister Michael Meacher of the UK said these research findings were "a sensational development" and true health effects of radioactive discharges should be resolved before any commitment to new nuclear power stations was made. (11)

Unfortunately radioactivity cannot be seen or smelled, but as Chernobyl investigator Vladimir Chernousenko said: "It has a voice". This is the ticking of the geiger counter. (8)
The Nuclear Age Peace Foundation states: "The majority of high level radioactive waste produced comes from the fuel in the core of nuclear power reactors. Irradiated fuel is the most radioactive fuel on the planet and accounts for some 95% of radioactivity generated in the last 50 years from all sources, including nuclear weapons production. Once removed from the core, irradiated fuel is stored in cooling pools on the nuclear reactor site. Each 1000 megawatt nuclear power plant produces about 500 pounds of plutonium a year and about 30 metric tons of high-level radioactive waste". (12)
3. SECURITY OF SUPPLY
According to the Nuclear Age Peace Foundation: "There have been repetitive problems with security, safety and environment impact in the nuclear industry. Radioactive contamination does not discriminate between national borders and nuclear power plants threaten the health and well-being of all surrounding environments.
Nuclear power plants produce extremely toxic radioactive wastes that are long-lived and have no safe means of disposal. Disposal is neither scientifically credible nor is there any sustainable options for interim storage. Producing long-lived radioactive wastes with no solution for its disposal will leave serious and irreversible environmental damage and degradation for generations to come, which is contrary to the principles of sustainability". (12)
Nuclear reactors obviously comprise one of the highest risk factors to any nation in terms of terrorist attacks or sabotage. The potential for devastation to an area from either of these factors, or even the purely human factor of error, is huge. Contrary to advertising by the pro-nuclear sector, there have been many accidents and spills in nuclear reactors over the past years, causing radioactive contamination to the community and spreading as far as contaminants have been carried. It is not possible for anyone to guarantee the safety of a nuclear reactor. (13)

Even in Russia - one of the countries that is proposing to trade nuclear science and technology with South Africa - there have been a number of accidents and the hightened security alert required by nuclear reactors has been impossible to maintain in terms of manpower and costs. (14)

Aside from the dangers to reactors themselves, there have been many documented cases of transport spills and accidents involving radioactive material such as uranium hexafluoride. (15) Since traffic accidents, sabotage and thefts from energy facilities are common in South Africa, this becomes a high risk factor.

The court case being enacted in South Africa at the moment - that certain people have wanted totally cut off from the media - is proof of the dangers of a nuclear programme. (16) The smuggling of nuclear weapons or weapons' material has put South Africa in the world spotlight as a nation where companies have been able to trade covertly with other nations. (17)The potential danger of nuclear arms smuggling only increases with the expansion of a nuclear programme - regardless as to whether this programme is intended to be for civil or defence reasons. There are always elements of society who will attempt to bribe and corrupt in order to get hold of nuclear materials. This makes the country extremely vulnerable unless South Africa is willing to spend even more money on high alert security systems.

The environmental group Greenpeace showed how easy it was to break into Koeberg - South Africa's one existing nuclear facility - let alone ten, twenty or more reactors around the nation. (7) South Africa already struggles to protect electrical wiring and cables from sabotage and theft. South Africa could be put in a position of extreme risk either from planned theft and sabotage from foreign or neighbouring nations, or accidental interference by local communities, as has happened in other developing nations where the people are not aware of the dangers of radioactive materials.
The Nuclear Age Peace Foundation states: "The Nuclear Non-Proliferati on Treaty (NPT) was signed on July 1, 1968 and entered into force on March 5, 1970. Its initial duration was 25 years. In 1995 it was extended indefinitely, with a review conference to be held every five years. At the heart of the NPT is a central bargain in which the Non-Nuclear Weapons States (NNWS) agreed to refrain from acquiring nuclear weapons. In exchange the Nuclear Weapons States (NWS) pledged to end the nuclear arms race and to negotiate nuclear disarmament (Article VI). As an incentive, the NNWS were promised assistance with research, production and use of nuclear energy for "peaceful" purposes (Article IV). Each NNWS also agreed to accept "safeguards" under the auspices of the International Atomic Energy Agency. These safeguards do not apply to the NWS. The treaty defined a NWS as one that had manufactured and exploded a nuclear weapon or other nuclear explosive device prior to January 1, 1967. However, any country with a nuclear reactor can in theory produce a nuclear weapon.
"MOX, or mixed oxide plutonium, is an experimental fuel in which plutonium, usually from dismantled nuclear weapons, is mixed with uranium for use in commercial nuclear reactors. The MOX projects require transporting plutonium by rail, ship or truck. The use of plutonium MOX fuel creates serious security threats as the transportation of plutonium increases the possibilities for theft and/or diversion of plutonium.
"In a study conducted in 1999, the Nuclear Control Institute determined that a severe accident at a civilian reactor powered by plutonium or MOX fuel could cause twice as many fatal cancers as an identical accident at a reactor that uses uranium fuel. MOX plutonium fuel produces more radioactivity than does uranium fuel.
"The use of plutonium MOX fuel also greatly exacerbates the problem of storing and disposing high-level radioactive waste. The use of plutonium in a nuclear reactor will not get rid of plutonium, which is an impossible goal. The idea behind using MOX plutonium, rather, is to render it less approachable by terrorists or "states of concern" because it is so lethal". (12)
4. HUMAN RESOURCE DEVELOPMENT
Unfortunately any people working in a nuclear reactor, or even in the uranium mines and mills that supply a reactor, are subject to ill-health unlike most other working environments. In Canada, primary cancers are regarded as an occupational health hazard of working in uranium mines. Research that has been conducted into cancers caused by uranium mines, the "milling" process and nuclear reactors is extensive. (18)

Since there is no cure for cancer, workers should not be subjected to this kind of "occupational health hazard". Necsa still refuses to compensate workers who have been affected by this, let alone an extended nuclear programme that would affect so many millions more. Once again the government will have to pay out health compensation and medical costs for years to come. There is no electricity supply that is worth the sacrifice of so many lives.

To consider sacrificing labour in this way is a form of "environmental racism" that has been widely experienced by the Navajo people in the United States who worked in uranium mines there. (19) It is devaluing and "writing off" a sector of the population as worthless. The human resources or labour that South Africa has to offer would be better off in alternative energy sectors such as solar, wind or tidal energy industries that would not comprise the kind of threat to themselves or their community that is posed by nuclear energy.

It is also sad that despite the fact that Necsa, the PBMR company, the DME and Department of Public Enterprises realises that South Africa does not have the atomic scientists available for this nuclear programme or manufacturing skills - and would have to import these scientists from Russia or elsewhere - they have chosen to forge ahead with a nuclear programme and throw millions of rand at this concept, instead of focusing funds on local skills and capacity. (14)

Statements by Necsa regarding nuclear energy have been contradictory. On the one hand, CEO Rob Adam has been quoted as saying to the media that PhDs do not come cheap and so they require the millions that government has been allocating each year. On the other hand, they persist with advertising the concept that "nuclear energy is cheap".

Adam has also been quoted as saying on the one hand that not just anyone can do rocket science in their backyard, but on the other hand he has stated that the average person can work in a nuclear plant. Perhaps he means that the CEOs and "rocket scientists" need high pay packages but the workers at the bottom do not. This is the usual pyramid of society with company directors bringing home the bacon while the majority of labourers live on the breadline. And perhaps this is the way society functions on many levels.

But in the nuclear industry, labourers are literally putting their lives on the line every day and may not realise the true cost to their lives and futures. For example, DME documents on radiation protection state that pregnant women must make their condition known immediately since radiation would harm the foetus. (2)

5. SCIENCE AND TECHNOLOGY
Necsa has stated that South Africa would have to bring atomic scientists out of retirement in order to work on a nuclear programme. Alternately they would have to employ nuclear scientists from other countries, such as Russia. In either case, the outlook is not good for South Africans. In the first scenario, there is a case where nuclear reactors that are developed with elderly staff in charge would soon be left with under-qualified staff to manage and maintain them. In the second scenario, South Africa would be spending a great deal of money investing in foreign skills, instead of investing in local skills (such as the scientists who are able to develop solar energy programmes).
Eskom also wishes to build Pebble Bed Modular Reactors (PBMRs). (20) According to research from Earthlife Africa: "The proposal is that the fuel for these PBMRs be produced at Pelindaba. There are fourteen thousand tons of radioactive weapons scrap metal at Pelindaba from decommissioned nuclear facilities. Necsa wants to smelt this waste and sell the metal on the open market, followed by commercialisati on of the smelter process - this process is not international best practice, and could turn South Africa into the North's radioactive waste dumping ground. The proposed reactors, radioactive fuel plant, and the proposed radioactive waste smelter, will emit many kilograms of radioactive emissions into the air, water and soil every year. Pelindaba is located within two kilometres of a World Heritage Site, The Cradle of Humankind, and ten kilometres from the townships of Atteridgeville and Diepsloot.
"At full production, for all the planned reactors, there would be nine trucks carrying nuclear material, and 145 trucks carrying chemicals every day between Durban, Pelindaba and Koeberg for forty years. There is no doubt that radiation is harmful. Furthermore, the level of what is considered a "safe" dose has been lowered consistently, and now stands at a few percent of what was originally considered a "safe dose".
"One of the arguments for the PBMR is that South Africa will need massive amounts of new power. This will not be true for at least ten years. In this time, we will be able to install all of South Africa's power requirements using safe and clean Renewable Energy Technologies, which are available off the shelf, and can be installed within weeks. The planned nuclear reactors for South Africa will generate little electricity for so great an expenditure and carry with them hazardous consequences for hundreds of thousands of years".
ENVIRONMENTAL COSTS:
On its website, Eskom claims that nuclear sites will be "revegetated" and environmentally restored after nuclear reactors are decommissioned. In reality in other areas of the world, this has not proved successful.
As an example, scientists have studied the area around Chernobyl to examine the health of the environment after this nuclear disaster. Douglas Birch, wrote for Associated Press: "In the journal Biology Letters in March, a group led by Anders Moller, from Pierre and Marie Curie University in Paris, said that in a study of 7,700 birds examined since 1991 they found 11 rare or unknown abnormalities in a population of Chernobyl's barn swallows. Roughly one-third of 248 Chernobyl nestlings studied were found to have ill-formed beaks, albino feathers, bent tail feathers and other malformations. Mousseau was a co-author of the report. In other studies, Mousseau - whose work is funded by the National Science Foundation and National Geographic Society - and his colleagues have found increased genetic damage, reduced reproductive rates and what he calls "dramatically" higher mortality rates for birds living near Chernobyl. The work suggests, he said, that Chernobyl is a "sink" where animals migrate but rapidly die off. Mousseau suspects that relatively low-level radiation reduces the level of antioxidants in the blood, which can lead to cell damage. "From every rock we turn over, we find consequences," he told the Associated Press in a phone interview. "These reports of wildlife flourishing in the area are completely anecdotal and have no scientific basis." (8)
The Nuclear Age Peace Foundation states that: "While electricity generated from nuclear power does not directly emit carbon dioxide (CO2), the nuclear fuel cycle does release CO2 during mining, fuel enrichment and plant construction. Uranium mining is one of the most CO2 intensive industrial operations and as demand for uranium grows because of new electricity generation and new plant construction, CO2 levels will also rise. (12)
"In a case study in Germany, the Oko-Institute determined that 34 grams of CO2 are emitted per generated kilowatt (kWh). Other international research studies show much higher figures (up to 60 grams of CO2 per kWh). In comparison to renewable energy, energy generated from nuclear power releases 4-5 times more CO2 per unit of energy produced, taking into account the entire nuclear fuel cycle.
"US government regulations allow radioactive water to be released into the environment at "permissible" levels. Accurate accounting of all radioactive wastes released into the air, water and soil from the nuclear fuel cycle is simply not available. The Nuclear Regulatory Commission relies on self-reporting and computer modeling from reactor operators to track radioactive releases and project dispersions".
HEALTH:
The Nuclear Age Peace Foundation states: "It has been scientifically established that low-level radiation damages tissues, cells, DNA and other vital molecules. Effects of low-level radiation doses cause cell death, genetic mutations, cancers, leukemia, birth defects, and reproductive, immune and endocrine system disorders. (12)
Radioactivity is measured in "curies." An average operating nuclear power reactor core has about 16 billion curies at its core, which is equivalent to the long-lived radioactivity of at least 1,000 Hiroshima bombs. In comparison, a large-sized medical center with as many as 1000 laboratories in which radioactive materials are used, has a combined inventory of about 2 curies".
Dr Helen Caldicott, Pediatrician and President of the Nuclear Policy Research Institute states: "The classic dictum in medicine states: If a disease is incurable, prevention is the only recourse. While the specter of global warming looms large with associated epidemics of arthropod-borne diseases and millions of ecological refuges escaping catastrophic meteorological conditions, nuclear power as an alternative energy has an equally dire prognosis. (18)
"Nuclear power is responsible for the emission of substantial quantities of global warming gases from each step of the nuclear fuel chain, and the medical consequences of nuclear power are equally catastrophic.
"Each nuclear reactor contains 1000 times more long-lived radiation than released by the Hiroshima bomb, in the form of 200 new biologically dangerous isotopes - some with minuscule half-lives and others with half-lives of 17 million years. This material - radioactive waste - must be isolated from the environment for geological time spans, a scientific and physical impossibility. Already radioactive isotopes are leaking into soil and water from nuclear waste repositories in many countries, and these isotopes bioconcentrate by orders of magnitude at each step of the food chain. Invisible and cryptogenic to the senses, these mutagenic radioactive materials will migrate to and concentrate in specific bodily organs - iodine 131 in the thyroid, cesium 137 in brain and muscle, strontium 90 in bone, and plutonium 239 (with a half-life of 24,400 years) in lung, liver, bone, fetus, and testicle. Ultimately, these radioisotopes will induce malignancy; however, because of the latent period of carcinogenesis, the cancers will not be diagnosed for many years.
"Over generations, radioisotopes in gonads will increase the incidence of genetic and chromosomal diseases. Animals and plants will be similarly affected. Nuclear power is therefore a fundamentally mutagenic industry that results in cancer with a transient byproduct - electricity generation. As such, nuclear power is medically contraindicated".
CONCLUSION
Since the proposed nuclear programme affects all South Africans, regardless of the siting of nuclear reactors, it is vital that this issue should be addressed by all stakeholders at a summit meeting where the alternative energy resources offered by renewable and sustainable projects could be given the necessary time, research and opportunities afforded to the nuclear sector by large budget allocations. Nuclear energy has been advertised as sustainable, yet uranium is a finite source. A great deal of money will be spent on reactors that need large quantities of water and will run out of fuel, unlike solar, wind and tidal energy options that are truly sustainable and renewable. South Africa cannot afford to go backwards in scientific and social development, but must progress into a new "greener" future, where the health of the people and the environment on which they rely, is made a priority.
Yours faithfully
INGELA RICHARDSON
REFERENCES:
(1)The Economic Impact of the Proposed Demonstration Plant for the Pebble Bed Modular Reactor Design By Steve Thomas, Senior Research Fellow, Public Service International Research Unit, University of Greenwich, UK, August 2005
The economic risk to electricity consumers of the Pebble Bed Modular Reactor by Steve Thomas, Senior Research Fellow, PSIRU, University of Greenwich, London, January 2006
"Taxpayers will have to lie in the pebble bed government makes", Hilary Joffe, 22 May 2007
(2)Understanding Radioactivity & Radiation in Everyday Life, Department of Minerals and Energy, South Africa, April 2005
"Are you ready for meltdown?" From News24, Koeberg's emergency planning
(3)"The True Price of Nuclear Power, The Economic, Environmental and Social Impacts of the Nuclear Fuel Cycle", by Peter Bossew, Peter Bossew, Austria. Physicist, member of the Austrian Ecological Institute for Applied Environmental Research and the Institute for Gamma Ray Measurement, Vienna.
"Koeberg property ban" , May 25, 2007, By Ronnie Morris, Cape Town - A ban by the National Nuclear Regulator (NNR) on property development within a 5km radius of the Koeberg nuclear power station was unreasonable, arbitrary and unlawful and ought to be reversed, the Cape high court was told yesterday.
"High-Level Atomic Waste Dump Targeted at Skull Valley Goshute Indian Reservation in Utah", "There is nothing moral about tempting a starving man with money." – Keith Lewis, of the Serpent River First Nation in Ontario, reflecting on his impoverished community’s 50 years of working in and living near uranium mines & mills, and the health and environmental catastrophe that has resulted.
(4)"Nuclear clean-up 'to cost £70bn' ", BBC News, Business, 30 March 2006
"Level of financial security to be provided", From Gazette 26327 of 7 May 2004, 3. The level of financial security to be provided by holders of nuclear installation licences in respect of each of the categories as determined in section 2 hereof, for the financial year 2004/5, shall be— (a) Category 1: R2.4 billion to be provided in such currency, which is acceptable to the Board of the National Nuclear Regulator. Where the financial security has been provided in a foreign currency and the exchange rate has resulted in the required level of financial security being devalued more than 15%, the holder of the nuclear installation licence must report it to the regulator within 10 days. (b) Category 2: R120 million (c) Category 3: Rl million
(5) "Smell of money is turning investors green" , February 27, 2007, By Gerard Wynn, Reuters
"Households warm up to solar water heating plan ", March 16, 2007, By Samantha Enslin, Business Day
"Enterprising Chinese cash in on green wave ", April 29, 2007, By Joe McDonald, Business Day
"Green with Energy", Dr Garth Cambray, Science In Africa, June 2007
(6)"As SA opts for nuclear, where to with the waste?" Irma Venter, Engineering News, 6 Apr 2007
"Cape Town Rejects Nuclear Waste," Xinhua News Agency, 9 April 2003, The City of Cape Town tells Eskom that it will not accept the toxic, high-level nuclear waste that would be produced by the pebble bed modular reactor (PBMR). Cape Town informed Eskom that it does not support the findings of the final environmental impact report for the modular reactor project and that Eskom must still formally apply for planning permission before any nuclear plant can be built. Cape Town has criticized the PBMR environmental impact assessment several times in the past; however, Eskom did not address the issues it raised
"Nuclear Waste Pumped into S. Africa River Exceeds Legal Limit," Agence France Presse, 30 May 2000, The South African Nuclear Energy Corporation (NECSA) admits that its Pelindaba facility inadvertently discharged higher than allowed amounts of radioactive liquid material into the Crocodile River in the second quarter of 1999

"Seven year old South African dump is already leaking": Metal drums filled with low level waste and concrete drums filled with what the U.S. would consider high level nuclear waste have been leaking radioactivity for years at Vaalputs, the South African Energy Corporation's (AEC) storage site, according to a senior AEC official. (Johannesburg Mail and Guardian, 7/10/97)
"South Africa: A radiation leak from the Vaalputs waste disposal site was probably caused by adverse weather conditions". Extreme cold and heavy rains could have caused hairline cracks in some of the concrete blocks containing the waste. (BBC Monitoring Summary of World Broadcasts, 27 June)
(7) "Death threats, secrets and lies", by Shellee-Kim Gold , Biophile Issue 6, 14 July 2006
"Koeberg is hotbed of disease - activists", by Mzolisi Witbooi, Cape Argus, October 2006

"Dark cloud over SA's nuke plant ex-employees", by Melanie Gosling, Cape Times, October 10, 2006

"A seal of approval", Carte Blanche, 3 December 2000, Victoria Cullinan: Thomas Fronte: 'I am out of a job because I wrote about safety lapses, and the reaction was not to solve the problem. The reaction of the employer was to change nothing and to keep silent about this problem.'

(8) Chernobyl Environment, June 8 2007, Douglas Birch, Associated Press
"Poison Fire, Sacred Earth", testimonies, lectures, conclusions at the World Uranium Hearing, Salzburg 1992: pages 21-24 , Vladimir Chernousenko, CIS. Physicist, scientific co-ordinator of the clean-up in Chernobyl. Matome Patrick Malatji, South Africa. Itereleng Educational Project, Phalaborwa, South Africa, pages 182-184, James Garret, Lakota Nation, Degree in Environmental Law, Director for Environmental Affairs of the Cheyenne River Reservation in 1992, Thomas Banyacya, Sr, Hopi Nation, Arizona, Hopi Elder, interpretor for the Kikmongwis (Hopi spiritual leaders), "Beyond Nukes, The Promise of Renewable Energy", by Dr Bill Keepin, "The True Price of Nuclear Power, The Economic, Environmental and Social Impacts of the Nuclear Fuel Cycle", by Peter Bossew, Prof Ryspek A. Ibraev, Geologist, geochemist, leader of the Inter-faculty Laboratory of the Kasakh State University, head of the Independent Public Expert Council of Radioecology of Kazakhstan, Cleophas Mutjavikua, Secretary-Gener al of the Mineworkers' Union of Namibia, Matome Patrick Malatji, Itereleng Educational Project, Phalaborwa, South Africa, Strongman Mpangana, Health and safety officer of the National Union of Mineworkers of South Africa (NUM) , Gernadij Grushevoi, Co-founder of the Foundation for the Children of Chernobyl, Irina Grushevaya, Medical doctor, co-founder of the Foundation for the Children of Chernobyl, Nikolaj Ostrogskij, Head of an aviary clean-up task-force in Chernobyl, Andres Illan, Member of a clean-up task-force in Chernobyl, Vladimir Nechunaev, Member of the Estonian Chernobyl Committee
"The Declaration of Salzburg", Chronical of The World Uranium Hearing Society

(9) "Yucca Mountain: No Place for Nuclear Waste", Faye Brown, Honor the Earth, 2641, Kevin Kamps, Nuclear Information & Resource Service, kevin@nirs.org, www.nirs.org , Corbin Harney, Shundahai Network, 5007 Elmhurst Lane, Las Vegas, NV 89108-1304; ph. 702.647.3095, shundahai@shundahai.org
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"IAEA Cautions on PBMR Safety", Nuclear Engineering International, 31 July 2000, Members of the IAEA's International Nuclear Safety Advisory Group (INSAG) recommend a full review of the safety features of the Pebble Bed Modular Reactor (PBMR)

Submission by PBMR:

THE SOCIO-ECONOMIC, WASTE MANAGEMENT AND SECURITY OF SUPPLY, HUMAN RESOURCE. DEVELOPMENT AS WELL AS SCIENCE. AND TECHNOLOGIAL IMPLICATIONS OF NUCLEAR ENERGY IN SOUTH AFRICA

Paper submitted by Pebble Bed Modular Reactor (Pty) Ltd to the Portfolio Committee .on Environmental Affairs and Tourism as input for a Public Hearing held on 20 June 2007

1. INTRODUCTION

Global energy demand, which is governed by population growth and increase in standards of living, is presently growing at about 2% per annum. The electricity component of demand is increasing more rapidly than the overall energy growth and is projected to increase by some 70% between 2000 and 2020, almost two-thirds of which will be from developing countries.

Currently, about 2 billion people have no access to electricity. Most electricity in the world is generated in coal-fired power stations (39%) followed by hydro (19%), nuclear (16%), gas (15%) and oil (10%). Apart from hydro-based power generation, renewable sources of electricity such as wind, solar, tidal, geothermal and biomass are intrinsically or economically not yet suitable or feasible for large-scale power generation where continuous, reliable supply is needed. These sources will have most appeal where demand is for small-scale, intermittent supply of electricity.

The World Nuclear Association lists 435 nuclear power plants in operation worldwide. About 30 more are under construction, over 60 power reactors with a total net capacity of nearly 70,000MWe are planned and over 150 more are proposed. Civil nuclear power has accumulated more than 11 000 reactor years of operational experience to date.

There is as much electricity generated by nuclear power today as from all sources worldwide in 1960. Nuclear power is increasingly being regarded as an important component of the energy mix in countries as part of their strategies to combat global warming and meet their Kyoto Protocol commitments for reduction in C02 emissions. The revival of nuclear power expectations is also reflected in the world uranium price, which increased from /lb in 2001 to the present 5/lb.

South Africa presently has approximately about 39 000 MWe local generating capacity, 87% of which is coal based and 5% nuclear. The projected future electricity demand indicates that this capacity will have to double over the next twenty years to keep up with growing demand. According to the South African Energy Policy and various statements by government, nuclear power must be retained as part of the energy mix and the relative contribution should even be increased.

Mention was further made of the planned establishment of a nuclear power export industry based on Pebble Bed Modular Reactor (PBMR) technology. Sustainable implementation of these expectations will require a review of, and coordinated RSA national strategy for, all the components of the nuclear fuel cycle, particularly in view of the major changes and downscaling within certain areas of the nuclear industry over the past 15 years.

The potential contribution of nuclear power to future electricity generation in South Africa should be viewed against the background of the sustainability of present plant as well as the anticipated growth in demand.

Assuming that the replacement of the existing 39 000 MWe does not include any additional nuclear plant, it can be seen that the stated objective of 4 000 MWe PBMR plant within 20 years (24 PBMR modules) would comprise only 5% of the anticipated 80000 MWe demand by then. This growth scenario would further allow all nuclear plants to be located at coastal sites, thus avoiding the high transmission premiums for delivering Highveld coal power to coastal regions.

This document presents information on the status and expected future developments in the various components of the fuel cycle in South Africa. It was generated as an input to the formulation of national strategy and policy making for the future deployment of additional nuclear power in South Africa.

2.PBMR TECHNOLOGY

The PBMR reactor is a helium-cooled, graphite moderated HTR which uses carbon and silicon carbide coated particles of enriched uranium enclosed in graphite to form a pebble or sphere as fuel. Helium is used both as the coolant and energy transfer medium. PBMR technology was initially developed in Germany, where two PBMR-type demonstration reactors operated successfully between 1965 and 1989. The PBMR project in South Africa was launched .in 1993 after Eskom acquired a licence from the German developers of the technology.

2.1. Plant Design

The DPP features a helium-cooled pebble bed reactor with a power output of 400 MWt coupled to a closed cycle gas turbine power conversion unit that consists of a power turbine driving a compressor on one shaft end, and the generator on the other as well as a recuperator, a pre-cooler and an intercooler. The main power system utilizes a recuperative Brayton cycle with helium as the working fluid. This differs from the German approach, which used a steam cycle. The rated power output of the DPP is 165 MWe. Reactor inlet and outlet temperatures are MR is also a partner in a concept design contract with the US Department of Energy, to consider the PBMR technology as future source of hydrogen. The project is still in its pre-conceptual phase, but it could result in the construction of a South African-designe d Pebble Bed Modular Reactor in the US before the end of the next decade.

The PBMR technology furthermore has desalination properties. To this end, the Department of Water Affairs has requested PBMR to work on a proposal for utilising the waste heat of the demonstration reactor at Koeberg for desalination purposes.

3. SUPPORTING INDUSTRIES

Deployment of new PBMR-based nuclear power capacity will be dependent on several supporting industries for the supply of materials and components. Whereas the demonstration plant will contain a fairly high percentage of imported materials and components, it is envisaged that the local content of the commercial PBMR reactors will be significantly higher due to the programme's strategy of promoting the establishment of local suppliers where thought economically feasible.

Supporting industries for the supply of enriched uranium for fuel production as well as material and components for reactors such as graphite and graphite structures, turbo machinery, pressure vessels, heat exchangers and main support systems (fuel handling, reactivity control, gas conditioning and inventory control), are of particular relevance. The programme would also require a nuclear waste disposal service for operational waste and spent fuel.

Local supporting industries for the programme will have many benefits, e.g. strategic (particularly with respect to nuclear material supply), job creation, skills development, upliftment of certain industrial sectors, import reduction and export opportunities. Local supply can, of course only be considered if it makes commercial sense. It may, in this respect, be prudent to revisit the reasons for the failure of South Africa's previous ventures into the field of local uranium enrichment and fuel production.

4. URANIUM-RESOURC ESAND-MINING

4.1. Background

Uranium production in South Africa commenced in 1952 as result of the demand created by international nuclear weapons programmes. Production peaked in 1959 at 5 000 t p.a. U. After a 50% decrease in production, another peak, caused by the energy crisis of the 1970s, at more than 6 000 t p.a. U, followed in 1979. Since then, a sharp drop in demand and prices resulted in less than a 1000 t U currently being produced in South Africa.

More than 95% of the approximately 160 000 t U mined in South Africa thus far was obtained as a by-product of gold from the gold mines of the Witwatersrand-K lerksdorp-Free State area. Uranium production in South Africa is heavily dependent on the future of gold mining, which in turn is governed by prevailing gold prices, exchange rates and production costs. Gold production in South Africa is on the decline, and already fell from 580 t p.a. in 1994 to 342 t in 2004. Some uranium is also recovered from the mine tailings that have been generated over more than 100 years at the gold mines. Although previously associated with the gold mining industry, the Dominion mine near Klerksdorp is now regarded as a primary uranium mine with significant future potential.

There are at least two other uranium deposits of interest which are not associated with gold. One is the Phalaborwa Igneous Complex, from where about 5% of South Africa's total uranium production originated. Uranium production in this case is determined by the copper mining strategy of the mine where it is extracted as a by-product. Another potential area of interest is the Karoo sandstones which have not been mined thus far, but where uranium deposits have been explored in several areas. Results from drilling operations carried out during the 1970s indicated that the resource may contain approximately 100 000 t U in various cost categories.

4.2 Resource estimates

South Africa's uranium resources which can be recovered at a production cost of erformance was the low capacity of the plant. International experience has shown that a commercial plant should have a capacity of at least five times the nameplate capacity of the Pelindaba plant.

The conversion process required facilities for the production of HF (from locally mined CaF2, fluorspar) and F2 gas. The HF plant with a capacity of 4 500 t p.a. HF is still operational, and supplies HF to Necsa's commercial fluorochemical programme for local industry and also for export. F2 is also still being produced at Necsa for its fluorochemical business.

5.2. Future conversion requirements

Local production of fuel for 30 PBMR reactors would require a UF6 production capacity of approximately 750 t p.a. U as UF6. Even if all of Koeberg's fuel were produced from locally converted uranium, a total local conversion capacity of approximately 1 000 t p.a. U as UF6 would be required.

The establishment of an economically viable conversion plant in South Africa could therefore only be considered if the bulk of production were exported as UF6, enriched uranium or reactor fuel, if such plants of economic capacity were available locally. The transport penalty of exporting UF6 instead of .uranium oxides should be further noted. Global demand for commercial conversion services (52 000 t U as UF6 for 2005) is presently met by the five major commercial producers. It seems likely that some existing producers (Areva, for example) will expand their capacities to meet the expected growth in demand in future.

5.3. Future strategies

South Africa's future needs for enriched uranium will largely be determined by the requirements of the Light Water and PBMR power reactors. Enrichment levels of approximately 5% will be required for Light Water Reactors and 9.6% for PBMR reactors. Assuming a scenario where the nuclear power component of Eskom gradually increases to 14.5% in 2030 when 5 000 MWe will be generated by Light Water Reactors and a further 4 950 MWe by PBMR reactors, an enrichment capacity of almost 1 500 000 SWU p.a. would be required to fuel the reactors.

There are three broad approaches which can be considered for meeting the SWU deand:

Firstly, the construction of an independent indigenous enrichment facility in South Africa under fulllAEA safeguards can be considered. This would, in all probability, be based on centrifuge technology, which should provide the best and lowest risk opportunity for establishing commercially competitive enrichment technology in South Africa. Recent statements by South African researchers that an improvement of the old vortex tube technology can be expected to lower the power requirement for uranium enrichment would still require confirmation by an extensive and costly Research and Development (R&D) programme before any view on the competitiveness of the improved technology for uranium can be formulated. Unfortunately most of the other unfavourable characteristics of the process, such as the use of hydrogen as carrier gas, will also still apply. The option of a local plant may possibly be seen as providing maximum assurance of supply, but it suffers from serious disadvantages such as the availability of mature competitive technology, very high capital investment and low economy of scale, particularly matching of the enrichment plant capacity to the growing product requirement over time. The approach of constructing an independent plant in South Africa would certainly result in the highest cost of enrichment services for Eskom.

Secondly, procurement of-enrichment services on international markets is of course an option. Uranium at enrichment levels of up to 5% is readily available from various suppliers as part of an extensive international trade network. Security of future supply should be very high, particularly for countries that forego the building of their own enrichment facilities. There is, however, no diversity of supply for 9.6% enriched uranium for PBMR reactors. The initial limited demand for this level of enrichment will also not stimulate diversity of supply, and the programme may be dependent on a single supplier with the associated risk. When Generation IV nuclear reactors come into commercial production, there may be a growing demand for higher enrichment fuel for future High-temperatur e Gas-cooled Reactors (HTGRs). This may lead to a diversity of suppliers entering this market, resulting in an assurance of supply situation similar to that in the current up to 5% services market. It should, however, be noted that the bulk (91.4%) of the separative work required for the production of 9.6% enriched uranium is required for taking it up to 5%. If, therefore, 5% enriched uranium is procured on the normal market and a single enricher (or more) is contracted to upgrade it from 5% to 9.6% (8.6% of the total-separativ e work), it would not be too serious to even pay a significant premium for this last step. A centrifuge facility required to do the upgrading for 20 PBMR reactors would hardly be more than a laboratory scale facility.

Thirdly, joint ownership in facilities either in the country of the technology holder or in South Africa is an option. The plant will be financed, managed and staffed on a multinational basis and partners of the technology holder will not gain access to sensitive technology. Details of this type of arrangement are still being developed, but it can be accepted that it would result in adequate assurance of non-proliferati on as well as assurance of supply. Economy of scale would be an advantage of such a jointly owned facility. It would also require a more manageable investment for each member state than building an indigenous national facility. In addition, it would be suitable for enrichment levels up to 9.6% or more.

Another possibility for the procurement of 9.6% enriched uranium which may be worth exploring is linked to the down-blending of HEU from Russian and American nuclear warheads. Dow-blended HEU from both sources is presently being used in USA power reactors. The question arises whether 9.6% enriched uranium could be obtained from the USA or Russia for the interim period until such time as this level of enrichment becomes generally available as a result of future demand by High-temperatur e Reactors (HTRs).

In conclusion, the PBMR requirement for fuel enriched to 9.6% may well turn out to be the determining factor in deciding on a procurement strategy. It is important that a feasible and economically acceptable strategy for the procurement of the 9.6% enriched fuel be found and agreed with a reliable producer in good time.

The supply of 20% enriched uranium for SAFARI-1 fuel is not addressed in this document, since it involves very small quantities of material for which international supply lines are well developed and secure.

6. FUEL FABRICATION

6.1. Background

South Africa-is nuclear fuel requirements for the foreseeable future will be determined by the needs of the Koeberg Nuclear Power Station, the SAFARI-1 reactor and the PBMR programme.

Koeberg procured all its fuel requirements from Framatome (now Arera) since commissioning of the two reactors in 1984/1985 until 1988, after which Necsa provided the fuel until the closure of the Beva plant in 1996. The Beva plant had a production capacity of approximately 200 fuel assemblies per annum while the Koeberg requirement was approximately 70. The plant was closed due to cost considerations as result of the low throughput and the negative expectations of future growth in local demand, as well as the inability to find export opportunities. Eskom has since procured its fuel on the open market and recently entered into a long-term contract with Areva for fuel production, and with Russia for the supply of the enriched uranium.

Highly Enriched Uranium (HEU) fuel for the SAFARI-1 reactor was procured from the USA from commissioning of the reactor in 1965 until 1977, when the USA terminated the agreement. Since 1982, SAFARI-1 fuel has been produced by Necsa -in the Materials Test Reactor (MTR) fuel fabrication facility after locally produced HEU became available. The South African inventory of HEU is presently used to fuel the reactor, as well as for target plates for the commercial production of radioisotopes. The fuel consumption of the reactor, on average 40 fuel elements containing 300 g U-235 each, is largely determined by the isotope production programme.

Following the licence agreement between Eskom and the German PBMR technology holder, a laboratory was established at Pelindaba, where PBMR fuel production

technology has been demonstrated on laboratory scale. Fuel spheres for irradiation testing will be available from the laboratory by the end of 2007. The design and licensing of a Pilot Fuel Plant (PFP) is at an advanced stage.

6.2. Future strategies

Koeberg will continue its practice of procuring fuel production and enriched uranium on the open market. Should uranium conversion and enrichment be resumed in South Africa, it can be expected that preference for locally enriched uranium will be considered for the production of Koeberg fuel. It is unlikely that local PWR fuel production will be considered in South Africa again, as a fuel production plant would face the same obstacles as the Beva plant. Koeberg will continue to strive for higher burn-up of fuel and would thus require fuel with higher enrichment levels (up to 4.95%). The introduction of MOX fuel could also be considered in future.

The SAFARI-1 reactor will, as part of the worldwide trend, convert to operation with Low Enriched Uranium (LEU) fuel. LEU fuel implies a technology changeover for the MTR fuel plant, and it is likely that future fuel production will be a mix of imported and locally manufactured components. The optimum mix will have to be determined. LEU will have to be imported in any case. That would result in the existing HEU inventory possibly becoming available for the production of isotope production targets only. SAFARI-1 may consider upgrading to 30 MW in future, which would result in 30% higher fuel consumption.

PBMR fuel spheres from the laboratory facility will be irradiated in foreign facilities as part of the fuel qualification programme. Construction of a PFP will commence by the middle of 2007 and production will start by the end of 2009. Sufficient fuel (450 000 fuel spheres) must be available for loading the Demonstration Power Plant (DPP) by the end of 2010. The PFP will have an initial capacity of 270 000 fuel spheres per annum. It will be upgraded gradually to 540 000 fuel spheres per annum and later on to even higher capacity. The present PBMR strategy would require a fuel production capacity of at least 900 000 fuel spheres per annum to service the equilibrium cores of PBMR reactors by 2015. A commercial fuel plant with a capacity of at least 3.6 million fuel spheres per annum would be required to service the equilibrium cores of six four-pack power plants for Eskom as envisaged in the PBMR strategy. Development of a next generation PBMR fuel will be initiated in future. It would be necessary for a fuel development laboratory to be maintained at Pelindaba, for SAFARI-1 to be equipped for test irradiations, and for a Post-irradiatio n Examination (PIE) capability to be established at Necsa.

7. NUCLEAR WASTE MANAGEMENT AND DECOMMISSIONING

7.1. Background

The following categories of nuclear waste are formed during the generation of nuclear power:

· The production of fuel for nuclear reactors creates radioactive waste containing un-irradiated natural and enriched uranium from conversion, enrichment and fuel production processes;



· During reactor operations, small quantities of fission products from the fuel and neutron activation products from construction materials are recovered during decontamination of liquid and gaseous effluent streams. This type of radioactive waste, together with redundant components, is classified as Short-lived Low and Intermediate Level Waste (LlLW-SL) and consists predominantly of radionuclides with half-lives of PBMR design relative to the norms set for the next generation nuclear reactors, technological development will be required in several areas, including the following:

· Improvement of reactor efficiency by developing tools for plant design optimization and conditioning technology to improve graphite radiation resistance;



· Minimization of radioactive waste generation and personnel exposure to radiation by limiting the transfer of radionuclides to the power conversion system;



· Improvement of the inherent characteristics and applicability of the reactor for New Generation Nuclear Plant (NGNP) applications.



8.6. Radioactive waste and decommissioning technology

R&D needs for the effective long-term management of existing Low and Intermediate Level Waste (LlLW) in South Africa are low. Technology for the processing and disposal of short-lived LlLW (LlLW-SL) is well established and is dealt with on a routine basis. Processing technology for un-irradiated uranium containing waste in the category LlLW-LL is also well established, but no disposal methodology has been licensed as yet. Finalization of this matter would require the design, safety assessment and licensing of a facility at a suitable site, probably Vaalputs. Management of radioactive waste arising from the PBMR programme will, due to its uniqueness and special requirements, however, require the development of special technologies. High-level Waste (HLW), predominantly spent fuel from the Koeberg power station and SAFARI-1, would use internationally developed best practices whether being directly put into final storage, or being reprocessed.

8.6.1. PBMR Radioactive Waste

Waste minimization and reuse of certain materials are the main drivers of technology development for PBMR radioactive waste. This would imply the separation of coated particles from spent fuel spheres and the reclamation of matrix graphite. HLW originating from the PBMR programme will be dealt with similarly from a. policy perspective to other HLW in South Africa.

8.6.2. High-level Waste

There is as yet no HLW disposal methodology or facility for dealing with this category of waste from Koeberg, Necsa or the PBMR. Planning of R&D work on the preparation of HLW for final disposal must await finalization of the national policy and strategy on radioactive waste, particularly with regard to reprocessing. The draft policy and strategy document does, however, indicate that investigations for the establishment of a deep geological facility must go ahead in the interim. This directive would imply that work be initiated on the selection of a suitable site (which could be Vaalputs), the conceptual design of a repository, as well as geological modelling and associated studies to support the safety assessment and licensing of the facility.

International knowledge and experience of radioactive waste technologies, particularly HLW, are generally readily accessible through the IAEA and other international forums. Inputs from such sources are most valuable and should be fully exploited in support of local activities. The key would be to establish and maintain a group of experts who would be able to absorb the international information and apply it locally.

8.6.3 Decommissioning

Decommissioning and the associated decontamination technology of non-irradiated uranium contaminated equipment is well established in South Africa and hardly merits supporting R&D. Present work in this field presents an ongoing learning experience in the optimal synchronization and costing of the full chain of activities, as well as the estimation of the full nuclear liability associated with plants and equipment.

Decommissioning experience of equipment contaminated with actinides and fission products, as found in nuclear reactors, is limited in South Africa. International experience in this field is growing rapidly and technical information is generally shared widely between countries. It can realistically be assumed that with the aid of existing D&D experience in South Africa as well as information from international sources, it should be possible to plan and execute an effective D&D programme if reactor personnel with operational experience and knowledge of plant hazards are involved in the project.

9. CAPACITY BUILDING

9.1. Background

An extensive and high-level human resource capability in nuclear science and technology was established in South Africa in the past as part of a broad range of R&D programmes and nuclear services, as well as fabrication and production facilities. The most notable of these are the following:

· The activities at Necsa, where people gained experience in research reactor operation and applications; isotope production and applications; radiation applications; various scientific and technological R&D programmes; uranium conversion and enrichment as well as nuclear fuel production; decontamination of nuclear facilities; nuclear waste management and disposal; nuclear component design and manufacturing technology; and nuclear regulation and safety. -

· iThemba Labs, which provide experience in accelerator construction, operation, maintenance and application for nuclear particle physics research, isotope production and particle therapy of patients.



· Operation and maintenance experience of PWRs at Koeberg.



· Regulatory experience of nuclear facilities and mines at the National Nuclear Regulator (NNR).



· Various universities, hospitals and clinics which provide experience and training in nuclear sciences as part of academic curricula, accelerator applications, medical applications of isotopes and radiation, and radiation protection training.



· More recently, the launch of the PBMR programme created an exciting and demanding new earning opportunity for the South African nuclear sector. Significant experience has been gained with high-temperatur e power reactor design, as well as laboratory scale fuel fabrication. An extensive international technological support network with the associated skills transfer opportunities has also been established.



Apart from a number of facilities which were closed down at Necsa, all the other activities referred to above are still an ongoing part of the national nuclear Science and Technology (S&T) human resource capability. The rapid growth in the human resource requirements of the PBMR programme as well as the need for transformation in existing institutions have, however, created a high demand for suitably qualified persons which are presently just not available in the nuclear sector. The existing training capability is further insufficient to meet the demand and several actions aimed at rectifying the situation have been initiated in the recent past.

9.2. Future Strategy

The following existing and planned training opportunities will be available for addressing the shortage of skilled workers in the nuclear sector.

9.2.1. Existing Nuclear Focused Postgraduate Qualifications at Universities

- North-West University (Mafikeng)

The Centre for Applied Radiation Science and Technology (CARST) presents a two-year MSc degree in radiation sciences and technology. The first year is full­time study at the university followed by a year at a nuclear institution during which experimental work is done for a dissertation.

- North-West University (Potchefstroom)

Two Masters' programmes in nuclear engineering for candidates holding BEng and BHons degrees are offered on a distance contact basis (including one lecture week per course) which enables full-time workers to participate. Courses are presented by local and international experts. The university is a member of the World Nuclear University. The engineering faculty developed and operates a physical model of the PBMR power conversion unit, which also serves as a useful tool for postgraduate training. (Refer to Appendix I for more information.)

- Masters in Accelerator and Nuclear Sciences

The two-year course is presented jointly by the universities of Zululand and the Western-Cape together with iThemba LABS. The first year is full-time study at the universities for an Honours degree followed by a year at a nuclear institution where experimental work is done for a dissertation. Students can specialize either in accelerator science (MANUS) or material science (MA TSCI). (Refer to Appendix I for more information.)

- Witwatersrand University

The university offers two postgraduate courses. A course on radiation protection and safety follows the syllabus of the IAEA on this subject. It is an 18-week full­time course. The other course on physics, engineering and safety of nuclear power reactors is normally given at Koeberg and requires full-time study of about 22 weeks. Industrial visits to SAFARI-1, the micro-model of the PBMR power conversion unit and the PBMR fuel development laboratory are included. (Refer to Appendix I for more information.)

- PHRIF

The PBMR Human Capital Research and Innovation Frontier (PHRIF) Programme was initiated by the Department of Science and Technology (DST) in conjunction with the nuclear industry in 2004. Although the programme is primarily focused on the human resources needs of the PBMR programme, it is evident from the list of projects that the whole nuclear industry will benefit from it.

The projects include support to grade 10, 11 and 12 pupils from disadvantaged areas to study science and mathematics; bursary support to undergraduate, masters, doctoral and postdoctoral students; the sponsoring of eight research chairs in PBMR-related technologies at South African universities; sponsoring of conferences; and networking for communities of practice in the nuclear sector. Programme funding for the next 10 years will amount to a total of R230 million. Although the research chairs will be focused on topics of particular interest to the PBMR programme, several of these will also be of interest to the broader nuclear industry. (Refer to Appendix I for more information.)

- Other Courses

- IAEA

Local capacity building can further benefit by a broad range of IAEA-sponsored initiatives such as:

· The fellowship scheme, whereby fellows from South Africa can receive on-the-job training at foreign institutions for periods of up to one year.



· AFRA workshops in South Africa or elsewhere in Africa where workshops, normally lasting one to two weeks, on various topics such as nuclear waste, and research reactor, medical and agricultural applications, are presented by recognized international experts.



10. INDUSTRIALIZATI ON AND LOCALIZATION

10.1. Introduction

The decision of the South African Government to support and finance the development of the Pebble Bed Modular Reactor (PBMR) was partially based on the economic and developmental advantages to South Africa - in addition to the provision of electric power. The future local and international sales provide a significant industrial and skills development opportunity for South Africa. PBMR (Pty) Ltd has consequently embarked upon an aggressive industrializati on and localization drive in order to maximize the economic and technological opportunities for South Africa.

10.2. Supply chain

a. Following the successful completion of the demonstration unit, PBMR intends supplying pebble bed reactors to the local and international market.

b. The first 'commercial' units are scheduled for delivery to Eskom in 2018, and can thereafter be supplied at a rate of three per annum;

c. To support this programme and. the export market potential, PBMR must:

i. Establish a secure an internationally competitive supply chain capable of delivering six pebble bed reactors per annum;

ii Maximize South African local content which is economically justifiable and-sustainable,-and-technicall y-achievable

10.3 Localization initiative

10.3.1. Objective of Localization Initiative The objectives of the localization initiative are:

1. Active participation in the establishment of an economically viable and sustainable nuclear industry in South Africa.

2. Skills development, job creation and Black Economic Empowerment (BEE) through the nuclear industry.

3. Export promotion of capital goods and value-added products.

4. Promotion of local industrial capacity and capability and the support of Small, Medium and Micro Enterprises (SMMEs) where possible. The promotion of manufacturing improvements and R&D- in order to remain internationally competitive.

5. Promotion of technology transfer, joint ventures, new trading partners and foreign investment.

10.3.2. National Industrial Participation Programme

The National Industrial Participation Programme (NIPP) of the Department of Trade and Industry (DTI) constitutes an important mechanism whereby international suppliers will be obliged to formulate programmes which would benefit the South African economy.

10.3.3. Steps to establish a South African support industry for PBMR

The following steps have been identified in a localization initiative to establish a South African support industry for PBMR:

a. Industrial development

- Recapitalizatio n of the heavy industry capability in South Africa.

-New industrial development for capabilities that do not currently exist.

- Industrial upgrade of existing industries that could potentially deliver components to PBMR.

- Significant NIPP opportunities.

- Production technology R&D.

- Competitiveness and cost reduction strategies.

- Optimized logistics and consolidation.

- International benchmarking.

b. Skills development

- Must be linked to other skills development programmes to support all the capital projects in the country.

- University and technikoneducat ion

- Artisans - especially in welding and machining.

- Learnership Programmes.

- Mentoring Programmes.

- Project-specifi c Training Programmes.

- International Exchange Programmes.

c. Scientific and technological development

- Technology transfer (important NIPP opportunity).

- Establishment of Centres of Excellence at universities as well as the identification of networks of expertise countrywide.

- Local R&D.

- Contracted R&D.

- Optimum utilization of existing facilities, i.e. Necsa, CSIR.

d. Quality assurance

- Re-establishmen t of quality assurance programmes and disciplines with the required procedures and documentation.

- Reskilling of manufacturers.

- Promotion of safety culture.

- Training f

Submissions by DEAT:

DEPARTMENT OF ENVIRONMENT AND TOURISM: NUCLEAR REGULATION

The role of DEA T Presentation to the Portfolio Committee: June 2007

The Intergovernment al Context

· DME main department responsible for nuclear issues - policy and legislation as well as National Nuclear Regulator. Includes policy on radioactive waste management



· DPE as custodian of state owned enterprises as role in relation to establishment of facilities



· DST role in relation to custodianship of R+D



· Deat has limited regulatory role - no policy role



DEA T's Role

· Establishment of nuclear facilities is a listed activity in terms of EIA Regulations



· DEAT responsible for authorising applications for nuclear related EIAs



· Also role in relation to nuclear waste to the extent that it is not dealt with by other legislation. (NNR Act, Nuclear Act, Health legislation)


Managing Nuclear EIAs



· Deat authorising body



· Currently two applications - PBMR and conventional nuclear



· MOU with the NNR. NNR responsible for licencing safety case and DEAT responsible for EIA authorisation. DEA T represented on NNR Board.



· Agreement that the two bodies will not duplicate or repeat each others' work environment & tourism



In assessing technical issues DEA T establishes panel of national and international nuclear experts



All existing government policies, legislation and prescripts taken into account in decision making



DEAT takes decisions on nuclear issues in relation to the facts of the given application and in the context of established policy and legislation.

THANK YOU

Submission by Ms Mariette Lieferink:

PARLIAMENTARY PORTFOLIO COMMITTEE ORAL SUBMISSION: NUCLEAR ENERGY IN SOUTH AFRICA

HISTORIC PRECEDENT OF INSTITUTIONAL CONTROL, MONITORING AND MANAGEMENT OF HAZARDOUS WASTE, P ARTICULARL Y URANIUM: WONDERFONTEINSP RUIT CATCHMENT

INTRODUCTION

The following is submitted with deference and diffidence, but not with timidity since the matter of U contamination and the handling of hazardous waste are of appreciable magnitude. U is, as you may reflect, radio-active and chemically toxic. The half life of U is 10 8 to 10 10. It therefore implies a long term hazard or risk.

Prefatory or preliminary to my submissions, permit me please to briefly advert to the Law of Evidence.

LAW OF EVIDENCE

In terms of the law of evidence, evidence of reputation or general character is admissible in a Court of Law in order to adduce evidence or to suggest that it is likely or unlikely that a person of historic reputation or record would have committed the offence with which he is charged. Evidence can be adduced of either good character or bad reputation.

For the purpose of our discussion I shall adduce evidence of the historic precedents which were established regarding institutional control, the monitoring and management of hazardous waste, particularly uranium and its radioactive daughter or transformation products, such as thorium, radium; radon and radon gas and the enforcement of environmental legislation pertaining to hazardous waste. From the past or historical performance of organs of state, particularly the DME, the NNR and the DW AF we can then arrive at the conclusion whether there had been poor or good institutional control regarding hazardous waste, particularly U. The historic management and monitoring of U has relevancy because of the proposed pebble bed modular technology.

HISTORICAL PRECEDENT: WONDERFONTEINSP RUIT

A historical precedent of U contamination and the handling of hazardous waste have been established in the Wonderfonteinsp ruit catchment.

In terms of official scientific Reports, inter alia the WRC Report 1095/1/02, the WRC Report 1214/1/06, entitled An Assessment of Sources, Pathways, Mechanisms and Risks of Current and Potential Future Pollution of Water and Sediments in Gold-Mining Areas 'of the Wonderfonteinsp ruit Catchment and the Wetlands Report, 2005 of the Council of GeoScience it was found that the uranium concentration at many of the sites sampled, inside and outside mine property, significantly exceeds the legislated exclusion limit for regulatory control. 16mg/kg uranium is equivalent to an activity concentration of 0,2Bq/g, the limit for regulatory control set by the NNR is 0,5Bq/g. The National Nuclear Regulator was called upon to take a regulatory decision in this regard.

The NNR responded by disclaiming the radiological (carcinogenic) health risk quotient of the U by stating that tl1e assessment was based upon the US Environmental Protection Agency methodology and not upon international methodology. The NNR undertook to conduct its own investigation and to make the findings available to the public. At the time of this submission, the NNR has not made the findings available. In the absence of evidence to the contrary, the findings of the WRC. Report 1214 therefore hold.

The WRC Report No 1214 found that:

· the tailings dams contain 100 000 tons of U;



· the gold mining industry discharges 50 tons of U into the water courses annually;



· 24 tons of U is discharged into the receiving water courses from seepage or percolation from tailings dams. We are credibly informed by the learned authors that the levels of U concentrations in the seepage water are 1 000 to 1 million times higher than the background U concentrations;



· 12 tons of U is discharged from point discharges



· 10 tons of U is discharged from storm water discharges



sinkholes that had historically been filled with uraniferous tailings will become secondary sources of U contamination after mine closure, when pre-mining flow patterns and volumes restore itself.


- Sediments in the Upper Wonderfonteinsp ruit have very high uranium concentrations - I 000 mg/kg in places (the background of U concentration recorded at the Klerkskraal Dam is Img/kg).

- One specific dam, the Andreis Coetzee's farm dam has concentrations of up to 900 mg/kg.

At present the U and other heavy metals, such as cadmium, copper, zinc, arsenic and cobalt are adsorbed in the sediment. Plausible environmental conditions such

- Acid mine drainage

- Acid rain

~ Drying out of the sediment and influx of water

- Dredging operations

- Tailings spillages

- Turbulence caused by cattle drinking the water or children playing in the water can cause the mobilization or transport of uranium in the Wonderfonteinsp ruit.

We here refer our esteemed listeners to what had happened in 2002 in the Krugersorp­Randfontein area where water has started to decant from a number of shafts into the rates of HIV / Aids and chronic and acute malnutrition is particularly vulnerable to additional stress of the immune system by contaminants such as uranium.

Risks associated with the ingestion of riverbank material by young children and pregnant mothers - 'pica' - are widespread in rural African communities and are not quantified. It is worth noticing that uraniferous salt crusts were found to contain extremely high concentrations of uranium 9up to 1 100mg/kg.)

At the time of this submission, there had been no efforts on the part of organs of state to create awareness of the risks or hazards amongst affected communities.

At the time of this submission there has been no epidemiological studies done in order to determine pathways of contamination or health impacts. Abundant anecdotal evidence, however, exists of mental retardation, pancreatic cancers, etc .

Strong institutional control is required to prevent the remobilization of U into the water column. Regrettably institutional control has been poor.

PROMULGATED ACTS OF PARLIAMENT

The duty of care provisions contained in both then National Water Act, No 36 of 1998 and the National Environmental Management Act, No 107 of 1998, and the Mineral and Petroleum Resources Development Act, No 28 of 2002 create a general duty not to pollute and remediate where pollution has been caused. In addition, these provisions create retrospective liability.

Under both the MPRDA And NEMA (and by implication the NWA). Liability is specifically extended to the director of the business concern in his or her personal capacity, i.e personal liability



· MPRDA section 38(2): Notwithstanding the Companies Act, 1973 (Act No. 61 of 1973), or the Close Corporations Act, 1984 (Act No 69 of 1984), the directors of a company or members of a close corporation are jointly and severally liable; for any unacceptable negative impact on the environment, including damage, degradation or pollution; advertently or inadvertently caused by company or close corporation which they represent or represented, inside and outside the mine property.



· Under section 19(4) of the NW A costs to prevent further pollution or degradation or to make the area safe can be recovered from any other person who benefited from the remediation measures to the extent of such benefits.



Apportionment of liability is provided for in NEMA and the NW A, but not under the MPRDA since the holder of the right or permit is deemed to be the responsible person. If more than one person is liable under the NW A, "the responsible authority (D WAF or CMA) agency must apportion the liability, but such apportionment does not relieve any of them of their joint and several liability for the full amount of the

costs" (section 19). Liability may also be apportioned by DEAT in terms of NEMA section 28(11): If more than one person is liable, "...the liability must be apportioned among the persons concerned according to the degree to which each was responsible for the harm to the environment resulting from their respective failures to take the measures required.

Regrettably, in a written response to question raised in Parliament in March 2007, the honourable Minister of Water Affairs and Forestry, stated that "No steps are being taken to lay criminal charges against past polluters.

By the failure of the relevant organs of state to have taken timeous actions against polluters and to enforce the Polluter must Pay principle, ordinary taxpayers, who have no connection whatsoever to the harm and degradation caused by historic and current gold mining activities, and derived no benefit from it, are now compelled to carry the costs that is the health costs, the ecological degradation, the loss of agricultural potential, the pollution of ground and surface water.

CONCLUSION

The only way we can judge future environmental performance is by historic precedents. Poor institutional control and failure to adequately monitor and manage the U contamination of the Wonderfonteinsp ruit, and to enforce the Polluter must Pay principle have resulted in long term ecological degradation and pollution and an inequitable and unfair externalization the costs upon the general public. It is trusted that this historic precedent will stand as testimony in the assessment of the foreseeable environmental impacts of the pebble bed modular technology

Pelindaba Working Group[1]





COPY OF ORAL SUBMISSION PRESENTED TO ENVIRONMENT AND TOURISM PORTFOLIO COMMITTEE PUBLIC HEARINGS ON NUCLEAR ENERGY 20 JUNE 2007





Honourable Chairperson Zitha, honourable members, I sincerely thank you for this opportunity that you have created to open up the debate on nuclear energy so that we can bring to your attention today some of the issues facing the people of this country, and which are being withheld from the public.



There are many issues which cannot adequately be addressed in the short time we have today, and possibly a Nuclear Summit that includes the involvement of all affected communities and representatives acceptable to civil society, could better serve this purpose. Nevertheless, I will focus on some of those issues that have a direct bearing on democratic principles as enshrined in our Constitution that are being side-shafted, and also on the issue of environmental justice that will - for years to come -affect our future generations. Some of these amounts to environmental racism whereby the most disadvantaged communities often have never been consulted and end up the most critically affected – especially by the nuclear industry.



I live next to what I’ve come to consider the heart of the beast, the nuclear installation at Pelindaba. As a school leaver in the 70s my first job for R235 pm was working in the Environmental Studies Unit at Pelindaba where my tasks involved having to collect samples in order to check for radioactivity in the surrounding environment – Crocodile River, Hartbeespoortda m, around Brits, to as far away as Krugersdorp, Rustenburg, Pretoria and towards Johannesburg. Over the years Necsa’s environmental study area appears to have narrowed considerably.



Those years when people in the area whose boreholes, for example, dried up they found it difficult to raise bank funding because, they were told, there was a policy for keeping the area underpopulated because of the potential danger from the nuclear activities at Pelindaba. In recent times, land claimants that included Necsa’s vast property, have been told the ground is too radioactively polluted and that they’d better focus their land claim elsewhere.



During that time I worked at Necsa called the Atomic Energy Corporation at the time, I witnessed rows and rows of 44 gallon drums of so-called “low active waste” – liquid radioactive waste – being lined up on the banks of the Crocodile River not far from the their picnic and sports terrain. These drums, and probably hundreds of thousands of others have since the 60s to this day systematically been released into the Crocodile River which flows into the Hartbeespoortda m (considered one of the most toxic internationally) in much the same way as toxic radioactive waste is released into the Atlantic Ocean from Koeberg. These practices have continued unabated to this day for over 40 years. There are considerable other sources to the pollution in this river and the dam, but Necsa appears to have hidden its radioactive contribution behind these and continue to this day to assert that what they do falls within “internationally acceptable” levels and practises. But people depend on this water for drinking, crop irrigation, fish and thus the poison of radioactivity enters the food chain. More often than not it is formerly disadvantaged communities and the poor of poor who are most affected and have absolutely no knowledge of the dangerous, deadly consequences to them and their families. But no-one remains unaffected. These toxins could be flowing into the underground water aquifers of the entire region, and together with the radioactive and chemical pollution from the gold mines on the West Rand, the entire “Cradle of Humankind” World Heritage Site and Hartbeespoortda m is being contaminated and affected.



During that time, the 70s, I was involved in a study of milk from cows in the area that had become irradiated from the AEC’s radioactive sources planted into the ground. The cow milk had been sent into a major Pretoria milk distributor. Literally hundreds of thousands of people could have been drinking irradiated milk without knowing about it. What action was taken, if any, was never made known to me. Certainly the public were never informed.



Also during this time, the Three Mile Island disaster occurred in the United States and thus there was focus on Pelindaba. Although a teenager, I remember how those at the AEC minimalised the disaster and instead turned their venom on the media – this practise continues to this day. All working there were against transparency – a practise that continues to this day despite assertions to the contrary.



Over the years this area has become highly populated with massive developments and thousands of people daily now living far too close to a nuclear complex where we now know nuclear bombs were developed, and where from time to time there were leaks and spills, accidents and fires, emissions so dangerous that their 30,000 or so employees were forced to remain indoors for hours. In the last number of years more and more information passed through our community, and made known to us from the company’s former workers – all victims of occupational disease you’ll also be told about later today - indicates a worrying lack of maintenance at the Pelindaba complex. The PWG has been informed that many who were retired and too old to return to work, are accepting not only because of the enormous packages they’re being offered, but because they are so shocked about the lack of maintenance there. They’re worried we’re sitting on the time-bomb waiting to happen.



I have begun my own research into the health, safety and environmental issues of nuclear energy and development which forces me today to stand here – although not an expert - but very much more aware that the nuclear industry have effectively killed public debate, largely swayed public opinion through misinformation, secrecy and cover-ups, and going to great trouble to discredit environmentally minded groups in the media, disregarding massive amounts of expert information that is available internationally – all of which tell a different story.



The devastating environmental effects of ionizing radiation, some of the chemicals used in the processes, the resultant nuclear waste, the potential for contamination along transportation routes, and not to forget tailings from uranium mining are overwhelming and well-documented.



There are many reports based on actual first hand accounts, or from experts and academics or scientists, which we could make available to this committee. Most involve international communities, but in SA some of this information is beginning to surface but is not being given publicity and is certainly not being taken seriously by regulators or those entrusted with custodianship of our environment or public health and concerns. We recently managed to find a report written several years ago by a Danie van As from Necsa that states that much of the Witwatersrand’s general population has been exposed for many years to excessive amounts of radioactive Radon – a uranium by-product from decades of mining on the West Rand. This report has never been made public.



A meeting earlier this year of the Pelindaba Working Group was thoroughly disrupted and heckled by a large contingent from the nuclear industry preventing many issues from being raised. And heckling alongside employees of Necsa, the PBMR Company and others in the nuclear industry was the chairman of our Public Safety Information Forum - ostensibly a resident’s forum representing the interests of the community.



The meeting, held earlier this year, was called after the Pelindaba Working Group had given up hope for any meaningful results from involvement in the Environmental Impact Assessment (EIA) processes held for the Nuclear Pebble Fuel Manufacturing Plant and the two Nuclear Smelter Plants earmarked for Pelindaba. Bearing in mind that we are ordinary community members and not nuclear scientists, we’ve had to go to extraordinary lengths to access and understand information in order to exercise our democratic right to participate in these processes. In the process, we’ve accessed an enormous amount of information readily available off the internet and include reports by experts and scientists all of which I could make available to this committee. Most “experts” in this country have been co-opted by the nuclear industry and are unwilling to provide a balanced view. I would like to add, that we’ve consistently raised the issue that the many disadvantaged communities in the area have never been adequately informed of these processes, let alone been able to participate in them.



The nuclear industry’s flippant and often sarcastic responses in official documents to genuine concerns that the public raised, have largely been dismissed, never answered or addressed and leave us with no choice but to consider these as “greenwashing” processes that have little bearing on the intention as prescribed by law or our Constitution. Non-nuclear industry viewpoints or concerns have simply been dismissed. The nuclear industry and the various authorities involved appear to be more concerned with “the process” than the content. For example, in the most far-fetched of the responses given by Necsa on the question of safety, the company stated in an official document that an aircraft crash into its facility would be of “no environmental impact” whatsoever. Nobody in their right minds could believe that to be true.



The Pelindaba Working Group meeting was held for all community members to discuss the implications of what seems to be an unstoppable nuclear programme in this country, and in particular the lack of evacuation plans for anyone beyond 5km from Pelindaba, non-existence of community health surveillance or monitoring programs (Necsa and the NNR hide behind a smokescreen methodology to produce official results they say are internationally acceptable although these follow an ALARA – As Low As Reasonably Achievable - principle and not the Precautionary Principle which states that if you don’t know what the effects are going to be don’t allow it), and also to discuss the dismal third party liabilities and insurance policies which fall way short of those international countries which have considered these issues with knowledge and insight. Our meeting was thoroughly disrupted and many of these issues could not even be discussed adequately by the community because of the way in which the nuclear industry hijacked it. The nuclear industry has wide-spread access to the media and holds many of its own meetings. This sort of behaviour is, to say the least, very sinister, smacks of a fascist approach to transparency and accountability, and is far removed from the hard-won democratic principles of public participation.







Against this backdrop, current reports on the lack of decommissioning or clean-up costs in this country (when the UK’s nuclear industry recently found its nuclear waste clean-up program could cost more than #8356;70bn) are further cause for concern.



Of equal concern is that there are a number of international treaties, protocols and agreements to which countries with a nuclear industry become signatories. While South Africa has signed some of these, there are a significant number of others, particularly concerning health, safety and liabilities to which SA has not become a signatory. These would also force a measure of international transparency.



The public has tried as best it can to back up EIA submissions with reports by experts: these say “no dose of ioninzing radiation is a safe dose”. (Radiologist R M Sievert, after whom the radiation measure was named, said ‘There is no known tolerance level for radiation’). We also have research documents stating that even routine emissions from nuclear installations cause cancer and whole array of other deadly illnesses. We have reports of how these routine emissions affect the health of people for miles around these installations, waste sites or uranium mines – possibly as far away as Johannesburg or Pretoria depending on windspeeds – and the deadly causes of longterm low doses of ionizing radiation on civilian populations. Low dose, ionizing radiation is the major cause of the public health catastrophe at Chernobyl and its surrounds today, as well as other parts of the world where nuclear installations exist.



There are extensive lists of nuclear accidents and disasters reported on the internet, all of which wreck communities and often kill nuclear workers, but the industry passes these off as “incidents” and makes light of even the most devastating known nuclear disaster Chernobyl – still passing it off as media propaganda.



Over and above, nowhere in the world has any scientist figured out what to do with radioactive waste which has already starting piling up in the backyard of several communities including ours and is only set to get worse if this country’s nuclear program is favoured over renewable alternative energies for which immense research globally and even in our own country is producing remarkable results.



Worst still, there is growing irrefutable documentation that suggests the main reasons being put forward for a uranium and nuclear renaissance have all been disproved. These include:

· The suggestion that it is safe

· The suggestion that it provides mitigation for climate change – it does not and reports suggest that its full fuel cycle may even produce more CO² than even our conventional dirty coal stations;

· There have only been 2 nuclear disasters and they weren’t so bad anyway – this is simply not true. The impacts of these disasters were devastating.



The World Health Organisation (WHO) has estimated that the total radioactivity from Chernobyl was 200 times that of the combined releases from the atomic bombs dropped on Hiroshima and Nagasaki; about 2.3% of Europe’s surface area has been contaminated. In many countries, restriction orders remain in place on the production, transportation and consumption of food still contaminated by Chernobyl fallout.



The Pelindaba Working Group has received information from a Fauna and Flora official about fish and bird deaths that occurred the extreme numbers of in the 90s along the Crocodile River. Of course, we have no backup documents of this because of an information clamp for many years. This was apparently investigated and linked to radioactivity by the Pretoria University’s science faculty and then quietly taken off everyone’s agenda because their funding was threatened. We’ve been told about the occurrence of abnormalities in animals – a five-legged dog, two headed fish, baboons born with stumps for arms – but proof is hard to find. And about spontaneous abortions in women in our area. No-one is prepared to go on record, and one of the reasons for this amongst those in the know, is that they are either afraid to talk publicly or, in some cases, more concerned over the property values than exposing the truth.



Time does not permit to go into any great depth of the overwhelming magnitude of issues, save to mention but a few more of relevancy. I briefly wish to talk about uranium – the resource that feeds the nuclear industry. Large portions of this country are being earmarked for new uranium mines, one of them being Magaliesburg near to where I live.



Shortly before Christmas one of the residents of Magaliesburg perchance found an obscure notice in the area notifying residents of an EIA process for uranium prospecting in the area, including his own farm. Like many Magaliesburg residents, I also applied to register as an “interested and affected party” because, as this committee heard earlier, uranium mine tailings get windborn and its deadly radioactive carcinogens are carried many miles downwind. These get inhaled or ingested via the food chain and can cause cancers and genetic abnormalities. I live close enough to Magaliesburg and am concerned.



To this day, no-one that has applied for involvement in the EIA process has been registered, let alone received acknowledgement of their applications.



· Uranium is extremely dangerous to all forms of life. It is often called “The Silent Slow Genocide”. We are about to witness much of this country potentially being mined for it.



· In the NW Province alone, the Province’s 2002 “State of the Environment” report states that: “There is a growing body of evidence pointing that both the long- and short-term effects of radioactive substances present in the environment may be impacting on the health of the population of the North West Province, particularly in the gold mining areas. Communities that are not currently supplied with safe, treated water and which rely on radionuclide-co ntaminated surface or ground water resources for their potable water are the most vulnerable to such health risks.”



It goes on to say that “elevated levels of uranium have been found in the following areas of North West Province:

Ø Koekemoerspruit, which drains parts of the Klerksdorp area (near Stilfontein);

Ø Kroomdraaisprui t, near the abandoned New Machavie Goldmine, before its confluence with the Koekemoerspruit;

Ø Wonderfonteinsp ruit below Carltonville (draining the Far West Rand goldfields); (The radioactive pollution from this area is now known to have seeped into the water aquifer throughout the World Heritage Site to as far as Hartbeespoortda m. We can provide this honourable committee with extensive reports that back this).

Ø Mooi River after its confluence with the Wonderfonteinsp ruit/Mooiriverloop;

Ø Vaal River, where it flows past the Klerksdorp mining area (between the Mooi River mouth and Orkney); and Pilanesberg.”

Apart from Wonderfonteinsp ruit, little more is known about research, if any, into any of the other areas.



· Around 1999 the Council for Nuclear Safety (CNS) estimated that at least 10,000 mineworkers, or roughly one in 20 mineworkers, have been exposed to radiation levels that exceeded safety limits. In 1998, according to CNS estimates, 1 000 employees at Harmony Gold mine alone were exposed to radiation levels that in some instances were three times higher than the annual dose limit of 20 mSv a year. At Nigel, workers were exposed to dose levels of up to 130 mSv a year, or seven times higher than the allowable limit. (Business Report external linkOct. 7, 1999).



· In February this year during the NNR submission of its annual budget, its CEO Mr. Magumela stated that in 2002, 7 931 people had been exposed to unacceptably high doses, but this number had declined year by year to 1133, 424, and 8. He said there had been an improvement over the last five years but failed to mention this was as a result of a largely stagnant uranium mining industry at the time.

In conclusion,

1. I ask for intervention from this portfolio committee because you are the custodians of NEMA and therefore the Constitution and therefore the communities who look to these laws for their protection;



2. I ask that this committee consider scrapping in its entirety the second amendment on EIAs in NEMA and rather call for a full inquiry into nuclear energy involving all stakeholders including those acceptable to civil society, possibly in the form of a Nuclear Summit before any further nuclear and uranium developments are approved;



3. I ask that this committee also consider a full investigation into all EIA processes that have been conducted on behalf of the nuclear industry or uranium mining. These have been termed “fatally flawed” by participants and should in all probability be scrapped and re-launched so as to ensure transparency and public participation as originally intended by our law and Constitution;



4. I ask this committee to consider a parliamentary office of non-aligned independent environmental groups (much like the unions have here) because in the face of climate change, the environment globally has become one of the biggest issues facing this planet. Developments in this country are being fast-tracked without sufficient public participation;



5. I ask you to consider recommendations that do not allow the DME to hand our mining licences before environmental laws are in place to protect the health of the people;



6. I ask that this committee considers the severity of the submissions it will hear today, and try to use its influence to persuade other organs of the state, namely Minerals and Energy, and Public Enterprises to also reconsider this country’s nuclear future; and for Science and Technology not to waste what may have been spent on training new skills but to use them to find environmental and energy solutions that are sustainable.

I am here today because I am a mother of a young child, because I took the trouble to find out more, because I have learned of the pain and suffering of ordinary people that accompanies nuclear energy.

I wish to end with a QUOTE with which I concur and read somewhere: “Human rights in the context of environment and sustainable development recognize that for human communities to survive, they must have an adequate and secure standard of living; they must be protected from harmful substances and unsafe products; they must learn to conserve and equitably share natural resources. Without these environmental and public health policies in place, human rights for respect, dignity, equality, non-discriminat ion and the ability for the public to participate in decisions that affect their lives cannot be achieved". I thank you.



Presenter: Dominique Gilbert

From Andy W Pienaar

To

Date: 14 June 2007

We representing the Namaqualand Action group for Environmental Justice has learnt about the public hearings of the portfolio committee on Environmental Affairs and Tourism.

We herewith give notice that we wish to make an oral submission at the public hearings on Nuclear Energy on Wednesday 20 June 2007 and could please arrange a spot for us during the hearings.

Regards

Andy W Pienaar

INSAKE : KERNKRAG IN SUID AFRIKA

Ons in die Namakwalandse Aksiegroep vir Omgewingsgeregt igheid wens graag in reaksie tot u uitnodiging die volgende voorlegging aan u te maak oor ons vertolking van die kemkrag industrie in Suid Afrika en spesifiek in NamakwaIand.

"We have noted the intense haste in the debate on this subject by informed people. For us the most crucial; aspect and the crux of the matter is that we are stewards of our land, lives and of the future of our community. We are in no position to bargain our future away for a new crumbs namely jobs, infrastructure or a fleeting moment in the limelight. Let us remember that the whole reason for this new dispensation in South Africa was to gain dignity and a better quality of life, jobs, housing and energy, not as a privilege, but as fundamental rights for all our people. We urge the representatives of the very people not to entice our communities with short term advances at the expense of sustainability;

In our community our heritage is our land, already encroached on by sanctimonious monopoly-mines and estranged by a cynical government. When the mines close, as they will, and the nuclear facilities break down, as they will, we do not want to live in the shadow of the gallows."

Vir ons behoort kernkrag nie 'n opsie vir Namakwaland, Suid Afrika, Afrika en die hele wereld te wees nie.

"The representatives of bureaucracy and all kinds of elites often argue that we must sacrifice for the common good. We see no economic sustainability in nuclear power as opposed to alternatives like hydro or solar electricity. Our people as a whole are in tremendous need of basic facilities. The billions of rands to be spent on nuclear power could very well open the door to a creative future if spent on our real needs.

The technocrats of all stripes urge us to trust them and not stifle the advancement of science. Eskom go as far as to argue that the containment of nuclear waste is a problem solved. Leave it to the experts, they argue. One Eskom representative even complemented the Namaqua Community and said they have reason to be proud of the "Mercedes-Benz of a facility in waste disposal at Vaalputs". Our community decline that sort of compliment. As a community of faith, rooted in the absolute presence of God, we know it is impossible to put our trust in science and the assurances of men. We urge all the stakeholders not to belittle the moral imperatives and set themselves up as God.

Lastly, we regret that some heavy voices are calling for an energy industry that in essence will be a betrayal of the nature of our struggle. To invest billions of rands in a nuclear facility, clearly is no technical decision. It is an investment in everything that is undemocratic, even anti-democratic, where a few secretive groups control vast resource, where power is concentrated to an extraordinary extent. We cannot argue that "this government will not be prone to the temptation of misusing power.

Will history perhaps be witness to the fact that energy policies of a new government in SA laid the cornerstone for an authoritarian future or a future of participation, ecological health and dignity."

For the Komaggas and Namaqua people

Andy W Pienaar

recognizing the contributions of V Clarke; C Clarke JB Ruiter and T Mathews-Grove

2007 SUBMISSION OF HABITAT COUNCIL WITH RESPECT TO THE PUBLIC HEARINGS ON NUCLEAR ENERGY

20 June 2007

Prepared by Marie- Lou Roux Executive Officer

Honourable chairman and members of the Portfolio Committee, we appreciate the opportunity to address the committee on this issue.

I speak here particularly on behalf of those of our members who are especially concerned for the way in which we as a country are dealing with waste and pollution which includes nuclear waste, and the plight of our poorer communities.

1. General disillusionment with the inadequate implementation of our legislation and the gradual erosion of some of our environmental legislation

We are deeply saddened and concerned about what we perceive to be a gradual weakening of the fine principles embedded in our Constitution,. (with its section 24, guaranteeing an environment not harmful to the health and well-being of present and future generations), and in NEMA, the National Environmental Management Act (15 of 1007). This weakening takes place through the failure to implement and monitor implementation of our laws and through progressive changes to these laws.

At the time NEMA was being finalised we suffered the disappointment, which those of you who were members of this committee then will recall contained a section providing for an Environmental Appeal Tribunal. Such a Tribunal (which exists in some other countries), would hand down decisions in cases affecting the environment based on the actual merits of the case, not merely review whether the correct procedures had been followed in the origina1 trial. This provision ,vas thrown out by the Council of Provinces after considerable lobbying by developers and industrialists.

During the past decade we have seen a gradual weakening of our environmental safeguards. The first Amendment of NEMA scuppered the provision that any action which would cause "significant environmental harm" would trigger an Environmental Impact assessment. After this was to follow the NEMA have ill this regards, is that inappropriate waste resources can be authorised as fuel. A case in point is the burning of tyres in cement kilns, test burns of which are taking place at the moment, and the lobbying to incinerate Municipal Solid Waste to produce energy, (so-called waste to energy plants). Such processes indisputably produce dioxins and furans and other heavy metal emissions and contaminated bottom ash. These are serious threat to the health of communities and the environment.

2. Concerns with respect to nuclear waste management

2a Lack of independence of National Nuclear Regulator

This possibly lies at the heart of many of the incursions on human health that have been taking place in the industry.

We wish to refer you to the Draft National Radioactive Waste Policy Framework of 2003 (although to our knowledge this has not yet been finalised).

Section 2 gives International Policy Principles, developed by the international community through the International Atomic Energy Agency (IAEA) and applicable to all countries, including South Africa.

I quote:” As a member state of the IAEA. and in accordance with National and International objectives, it is government's policy to deal with radio active waste in a manner that protects human health and the environment, now and in the future, in accordance with the following principles”

It is important to note the principle of having an appropriate national Legal Framework, with the requirement that provision shall be made for “ clear allocation of responsibilitie s and independent regulatory functions”

This requirement is not honoured.
The Draft Framework referred to is exemplary in its provisions.

The internationally recognised Precautionary Principle, which stems from the Rio World Summit, in NEMA reads: "that a risk-averse and cautious approach is applied, which takes into account the limits of current knowledge about the consequences of decisions and actions".

Among the other principles listed are: Protection of Human Health, of the EnvirolID1ent and of Future Generations, and that radioactive waste management will not «impose undue burdens on future generations".

2b Absence of transparency and public participation on the part of the nuclear industry

Other parties present cite examples of this lack of transparency today. We just wish to refer you to the Draft National Radioactive Waste Policy Framework of 2003 (although to our knowledge this has not yet been finalised).

The Draft National Radioactive Waste Policy Framework, under section 3, has as its second bullet point: Transparency regarding an aspects of radioactive waste management, and requires "that the public shall have access to infom1ation regarding waste management where this does not infringe on the security of radioactive material. "

It cannot be clain1ed that information requested on the number of spills and accidents, or the numbers of workers falling ill can be seen to compromise the "security of nuclear material".

This draft Policy framework includes the necessary principles, such as the Precautionary Principle (bullet point 4). "Where there is uncertainty about the safety of an activity, a conservative approach should be adopted."

and on Public Participation (bullet point 8): "Radioactive waste management should take into account the interests and concerns of all interested and affected, \"hen decisions are being made"

If the concerns of citizens were truly taken into accow1t, we believe that there would be a change of heart by the authorities with respect to its nuclear program. We are fearful of mishaps in the nuclear plants. Human frailty has proven that human error can never be discounted. We here in the vicinity of Koeberg feel especially vulnerabJe.

Without transparency and dependable reporting, and public participation there can be no honourable planning.

3. In conclusion

On a perhaps flippant note, I should like to admit that every time an Orange Alert or Red Alert message flits across our television screens, I feel that it is Eskom conditioning the people of South Africa to panic about our so –called shortage of electricity and condition them to feel that we must get nuclear power as soon as possible to fend off this disaster of cut-offs.

However , seriously, if Eskom were sincere when it states that it does support alternative sources of energy , such as wind or sun energy, the moneys spent on research of those technologies would show that. To me the integrity of Eskom is compromised by the fact the more than 6 billion rands have bben spent on the Modular Nuclear Pebble Bed and not yet even 50 million on wind turbine research in this country.

Considering the potential for job creation in a country desperate for work opportunities such as the development of these alternate technologies offers, we hold this push for nuclear power generation to be morally indefensible

Can the Radioactive Waste Management Policy and Strategy be finalised, with the retention of its laudable clauses for the protection and safety of our people and environment?

We look to your committee to help is achieving these objectives.

I thank you

SOUTH AFRICAN COUNCIL OF CHURCHES

SUBMISSION ON NUCLEAR ENERGY SUBMISSION TO THE PORTFOLIO COMMITTEE ON ENVIRONMENT AND TOURISM

20th June 2007

Introduction

1. The South African Council of Churches (SACC) is the facilitating body for a fellowship of 26 Christian denominations and associated Para-church organisations. Extrapolated information from Statistics SA's National Census in 2001 religious communities analysis indicates that the SACC represents some 15-16 million Christians in the country. Founded in 1968, the SACC includes among its members Protestant, Catholic, African Independent, and Pentecostal churches, representing the majority of Christians in South Africa. SACC members are committed to expressing jointly, through proclamation and programmes, the united witness of the church in South Africa, especially in matters of national debate.

2. The South African Council of Churches (SACC) thanks the Portfolio Committee on Safety and Security for the opportunity of making this submission. In the spirit of ensuring justice through its traditional prophetic witness for the poorest, marginalised and most vulnerable of the nation, a Parliamentary Office has been established and hereby we make this submission.

3. We welcome this opportunity to make a submission to government on Nuclear Energy and affirm government in its practice of promoting participatory and deliberative democracy through parliamentary hearings and other methods such as Imbizos. Furthermore, we believe that Christian churches, and the religious sector as a whole, have significant roles to play in shaping the path of moral transformation, the promotion of values such as justice, peace for humanity together with respect and care of all forms of life - known and unknown - and therefore for all creation.

4. While science and technology have the ability to further social and economic progress, they must never be allowed to exceed the pace and development of society's ability to reason and judge their moral and ethical implications for the human and earth communities. To this end an ad hoc group has utilized an exercise in deliberative democracy to reflect on the use of nuclear energy as part of a complex system of thought. We engaged in the broadest expression of thought, interest - allowing difference of opinion while working toward consensus on issues related to the use of nuclear energy.

Sustainable development

5. What is sustainable development? In short, taking the lead from various ecumenical sources, sustainable development concerns the provision for human basic need and reliance on water, energy and food as a priority over the neo-liberal and multi-national priority of gain and profit over the production and provision of these needs. In brief, sustainable development is about the "re-imaging" of global and local economic systems, their capacity for production as well as the reasons for such production. Such decision making needs to be participatory and creative because, as claimed in the example of the Indian State of Kerala, "non-creative participation will not be just, and unjust things are not sustainable."

6. So then, an approach to sustainable development warn us against the danger of economic policies that promote the principles of "bigger is better" or of economic systems based on exponential growth resulting from capital intensive business. Globally - and to large extent in South Africa as well - similar capital intensive economy has resulted in disciplined fiscal growth but has been accompanied equally by a hemorrhaging of jobs and joblessness on the other. This is a dangerous symbiosis if - as we believe is the case in the Pebble Bed Modular Reactor - science is funded by government as business. As an exercise in the promotion of sustainable development, we therefore urge government to invest in research that explores alternative energy sources and usages more extensively. This would mean exploring more fully a "zone of complexity" that relates to " traditional energy sources and their alternatives - fossil fuels and nuclear as well as renewable sources - in order to come to broader consensus in complexity.

7. While war and conflict may open up certain areas of marketability for energy resources - witness the wars in Iraq, Afghanistan and ongoing conflict in the Middle East - such options never sustain development but rather fuel a spiral of conflict demanding an ever spiraling increase in demand for human, financial and natural capital. We caution that future joblessness is a greater challenge to human security than the protection of economic and state systems of security. What, however, if such joblessness continues and safety and security becomes plotted through jobs that rely on a path to weapons production? And what if such weapon production becomes reliance on access to enriched Uranium and Plutonium stocks whose availability and access become defined by an energy industry that makes proliferation to such material easier? War and terrorism, we argue, become political and economic ends that begin a downswing to a cycle of sustainable dest5uction rather than development.

8. The SACC has never been alarmist - and neither are we here - but argue that the level of possible nuclear harm can in no way be compared to an overdose of permissible and regulated harms caused by, say, smoking cigarettes and/or consuming alcohol. While we understand that there exist elements of harm in every source of energy we question whether - in comparative situations such as Long Mile Island and Chernobyl disasters - regulation would provide sufficient and adequate protection for such disasters should the occur South Africa. We have then now not even begun to question dealing with such problems as Uranium depletion, Plutonium storage and destruction or even of radiation.

9.We note that South Africa has a number of international duties to protect the environment such as, amongst others'



· The African Peer Review Mechanism.



· The United Nations Millennium Development Goals.



· The World Summit on Sustainable Development Plan of Action.



· The Rio Declaration.



· The African Charter on Human and People's Rights.



10. At the same time, we note that there is consensus by the United Nations and scientific communities worldwide that global warning is a threat to environmental and human security.


11. Without deeper analysis of these implications at this stage, suffice it to say that these times constitute for the Churches in South Africa - if not on a global level -a Kairos - or crisis or turning point - at which we need to take stock and make decisions on global, continental, regional, national, provincial, city, local and-personal levels to live in a sustainable way. The original Kairos document in the mid eighties challenged then churches' way of reasoning' on social and political issues. This was referred to as "Church theology". It challenged what way in which the churches supported the status quo of economic and political trends of the day and called it "State theology". But it proposed a way forward with and for those who bore the brunt of apartheid - the poor, marginalized, vulnerable, especially women and children.

So, in these times of energy crisis, a Kairos would provide for a way forward through the melee of status quo energy provisions and their complementary sources as well as for alternatives. In order to do this, we recommend that extended public space be provided for questioning, deliberations, decision making on policy processes and prescriptions on our use of non­renewable resources and fossil fuels, the production of waste, population development, economic growth - especially as they relate to jobs and inequality -amongst other environmental, human security and energy related issues. We commend government for this process of deliberations and suggest that it is necessary to plot a path toward a common understanding and progression for sustainable development and livelihoods. Such a Kairos or turning point must include extended democratic decision making so as to ensure that the quality of life envisaged by our Constitution - as a base line - becomes consensus driven as well as an agreed path for present and future generations.

12. We therefore call on the government - in all transparency and through the provision of access to all relevant information - to partner civil society and the churches in the promotion of awareness and education on issues of sustainable development and livelihoods in order to deal with the threat of global warming. Furthermore, we urge government to facilitate deliberations towards reaching consensus on the way forward through parliamentary and extra-parliamen tary hearings.

Nuclear energy

13. There are others who are more qualified to make contributions on the "science and technological" implications of Nuclear energy in South Africa. We make the following submissions of principle and process in the hope that we will assist the Portfolio Committee to search for consensus on charting a progressive course ­not necessarily or essentially toward nuclear energy as a logical progression - but rather toward a sustainable future for a range and mix of energy sources. We encourage government to deal with this matter as one of considerable complexity. We therefore make reference, in no particular order, to a diversity of socio-economic, waste management, human resource development as well as human-security related principles as they may apply to the supply and use of nuclear energy in South Africa.

13.1 Energy policy decisions should contribute to sustainable development

A legal prescription for "sustainable development" may be found in the National Environmental Management Act 107 of 1998 (NEMA) which lies at the heart ofNEMA2. Our points 5-10 above on sustainable development provide a forum, we believe, for an additional interrogation on the sustainability of energy sources. Essentially, government is required to evaluate the social, economic and environmental impacts of activity - in this case the use of nuclear energy - as it may affect the environment. The public needs to be actively involved in any decision government may take to proceed with energy development that affects the social, economic or environment of its communities.

13.2 Energy policy decisions should be based on a full accounting of current economic costs as well contributions to global warming

The People's Budget Campaign has estimated earlier this year that government has already spent R 3,85 billion likely to balloon to over R 14,84 billion for the reference module and – if the full decommissioning of the PBMR is included - on may be as high as R 25 billion by 2012. The problem of finance allocation and of priority choices is two fold. In the first instance, the PBC has no reference point as to measure the allocation for the PBMR and therefore believes it (PBMR) to be one of government's "follies"

Secondly, the PBC has no reference to a rigorous public interrogation that underlies nuclear energy as a feasible choice. The PBC therefore suggest that the policy principle of cost-reflective pricing should be applied to the full costs of energy use be phased in while interim measures are also used. While not being prescriptive on this matter, we would refer the Portfolio Committee to the work of Herman Daly, a former economist on the Environment at the World Bank and John Cobb Jr., a professor of theology to their work "For the Common Good: Redirecting the economy towards community, the environment and a sustainable future" in which they develop a useful "Index of Sustainable Economic Welfare".

This work points further to a procedure proposed by economist Salah El Serafy (1988) in which he calculates the amount of money that would need to be set aside from the proceeds of the liquidation of a natural asset to "generate a permanent income stream that would be as great in the future as the portion of receipts from nonrenewable assets that are consumed at present.

13.3 Energy policy decisions should be transparent and take into account environmental and social impact assessments that consider threats to (a) the environment and (b) human security including threats to nuclear energy plants by war and terrorism.

13.4 Energy policy decisions should recognize and consider more equitably - when compared with considerations for nuclear energy - sustainable energy sources such as sun, wind, wave power and the use of bio-fuels as advantageous in developing a sustainable future.

In addition to 13.2 above, we note that South Africa is blessed with an abundance of renewable sources of energy, in particular solar and wind. We believe that renewable energy is a neglected aspect of our energy mix. Of particular concern is the significant amount of nuclear waste produced by nuclear energy sources, especially the PBMR. In the case of Uranium 235, which has a half life of 7l3 million years, there exists no licensed high-level storage cite in the world. Since the time frame of decay is incalculable, we dare not take a hasty decision in sanctioning its implementation and further use. In terms 'of climate change, it is true that nuclear sources produce lese CO2 emissions than either coal or gas. However, not much is considered by factoring that nuclear energy produces much more CO2 emissions than either wind, solar thermal and/or tidal energy sources.

13.4 Energy policy decisions for the above sustainable energy sources should allocate at least an equivalent support for research and development as is currently expended on nuclear energy.

We have learnt that, in comparison with the billions spent and planned on nuclear energy, a mere R140 million has been set aside on research and development of the complete mix of renewable sources of energy. An equal investment in renewable energy part for part as for nuclear energy, we believe, will deliver an achievable goal of 15% of all electricity generation from renewable sources by 2020. This is not only achievable, but will significantly impact on the lives of all people and particularly of the poor and working class people who fork out significant increases on current energy sources.

13.5 Energy policy decisions should give practical consideration to local and consumer generation of energy and savings in order to maximize energy security and minimize cost of energy generation.

Local use of solar generation through solar thermal panels for example and other popular alternatives such as wind and tidal energy generators may easily be regulated to feed into the energy grid and compensate the consumer" or community of consumers for the production of energy. Since such generation occurs closer to the consumer and/or community of consumers, management, control and repair would be easier and cheaper to deal with than from a source/s tens or hundreds of kilometers away from supplementing the grid with energy, such alternatives also provide for greater energy security, energy savings and minimize the cost of energy generation.

13.6 Energy policy decisions should factor in and support the opportunities for local and consumer energy generation as possibilities for sustainable job creation.

In line with the above, the factorization of local energy production could provide for opportunities of local job creation through and alongside the provision of energy. An example of recycling waste into landfills for compost which in turn provides a source of food and/energy such as at the Sustainability Institute outside Stellenbosch is an excellent example of a mix of job creation from biogas and other alternatives that should be more creatively explored.

13.7 Energy policy should facilitate a choice of alternatives to consumers and regulate against the monopoly of ESKOM.

The current options toward nuclear energy occur because of a lack of alternatives or alternatives such as wind turbines proven to be uneconomical through monopolized research. During the energy crisis in the Western cape in November 2005 and through to 2006, it was generally known that the electricity grid had not been sufficiently upgraded over the past 13 years or more. ESKOM, however, is known to be accumulating significant profits, sufficient to pay extremely large salaries to its executive operating officers. Upgrading of the grid, an allowance of alternatives as well as a closer monitoring of measures ESKOM is able to promote toward alternative energy usage, could provide for both cheaper and more affordable energy sources. An example of one of ESKOM's questionable alternatives was the provision of "energy-saving lamps" for incandescent lamps. These lamps do not use significantly less energy than an incandescent lamp but still ensure that ESKOM makes a profit from energy supply. There are also environmental problems with these lamps in that they contain mercury vapour. A suggestion might be for ESKOM to consider the subsidy and/or free provision of solar panels to households and to count real cost savings in, say, five years.

13.8 Energy policy should amend building regulations to include the compulsory installation of solar/thermal water heaters for reduction of energy consumption costs which in turn could subsidize poorer households.

In line with 13.7 above and with creative alternative energy exploration, policies that amend building regulations to enable the use and provision of alternative energy sources for households such as water heaters and the inclusion of energy conservation measures, measurable savings would be made. Municipal and local government systems could then provide for wider reaching subsidies for poorer households.

13.9 Base policy on comprehensive and symbolic nuclear non proliferation as a signal of intent and purpose to the world. Apply the "do no harm principle" to health and environment first.

The energy crisis has implications for personal, community, national, regional and global levels. Much of the above principles have dealt with the first four levels. South Africa, as we stated earlier international obligations just as international socio obligations rights relate to South Africa being a part of the international and global family of humanity and ecosystems. The application of policy that led South Africa to dismantle its nuclear facilities - for whatever socio-economic and/or political cause - must under gird its intentions toward ongoing nuclear non-proliferati on. In a world that faces this Kairos -and which is caught up in a spiral of nuclear program intentions as well as an end to dependence on oil - South Africa has the opportunity to lead the world in seeking the "do no harm first" principle and to promote energy alternatives that deliberately seek to compound human and environmental health rather than promote energy alternatives with unknown future and present risks such as nuclear energy.

13.10 Energy policy should explore application of nuclear energy as a final, desperate measure on indication that balance of all probabilities of current energy systems and alternatives have been sufficiently explored and applications indicate absolute non-viable, non-sustainable future use.

"Finally, it would appear logical that, seeking to promote the use of nuclear energy in any way as an alternative to fossil fuels and renewable energies would need far proof and study other than popular media strategies. As we have indicated before, proof that energy sources comply with the sustainable development criteria as well as with the most rigorous social, economic and environment impact assessments would require the most extensive democratic and participatory decision making mechanisms if it is to justify its inclusion in a mix of alternative energy sources. And then, it should not receive and/or be given priority funding over other sources that it IS currently receiving.

Conclusion

We thank the Department of Environment and Tourism for this opportunity to have made submission on nuclear energy. We are grateful for the democratic initiative extended to public participation for this submission. We would urge and recommend far more extensive and deliberative democratic decision making processes in order to reach the nation's common mind on nuclear usage. Due to the serious nature of climate change before the world, all face energy usage as a crisis - or theological Kairos - that needs to be weighed against the most stringent criteria for sustainable development possible. Against this backdrop the Churches have proposed a selection of criteria and/or principles for energy use. Chief amongst these must be the need to evaluate current energy sources together with nuclear and renewable in the most objective fashion possible in order to find a combination that cares for the environment while also generating sustainable livelihoods for our present generation and for generations to come.

Submitted:

Mr. Eddie Makue. General Secretary, SA Council of Churches

PEARLY BEACH CONSERVATION SOCIETY

14 June 2007

Dear Sir

WRITTEN SUBMISSION ON NUCLEAR ENERGY IN SOUTH AFRICA

As Bantamsklip, which is situated 10 km South-East of Pearly Beach, is one of the 5 identified sites for the potential construction of a nuclear power station, we as the Pearly Beach Conservation Society would like to comment as follows:

Bantamsklip is situated within a rather unspoilt piece of coastal fynbos veld and the possible construction of a nuclear power station and associated infrastructure will definitely have a very negative effect on the conservation of this piece of land. We as an organization are not against the use of nuclear power as such. as we understand that this is one of the best options to meet the growing demand for electricity in South Africa. We would however like to request that a full environmental impact study be undertaken to identify the best site where the potential damage to the environment will be restricted to the minimum.

We also want to request should the nuclear power station be constructed near Bantamsklip. that the exterior of the building should be painted (using special and very expensive paint) a blue which blends in with the colour of the sky in order to camouflage the station. We further request that there should be NO overhead pylons. It is perfectly possible to bury the access in underground cables and is an absolute must for the Bantamsklip site.

There will be considerable damage when the building is being build, normally mud, building detritus, and silt, so we should ensure the damage to the local environment is put right on completion of the building operations. This would include in our area a need to replace vegetation with the opportunity to use indigenous plants and trees. Our experience has been that the use of the reactor does not cause the same environmental problems.

We are aware that the process takes cold water out of the sea and at the end of the process warm water is put back into the sea. This is safe water so the effect is dependent on whether it is acceptable to have sea water a bit warmer in tht3 vicinity. Our biggest concern however is whether the whale population would be affected and we demand that a special report be submitted on the environmental effect the warmer water will have on the whale population.

On a more general point the power station will create jobs in an area of high unemployment and we would like to say at this stage that we expect work to be made available for the local population.

Another point of extreme concern is where the construction people and-eventually the operational staff will be housed, as' Pearly Beach is the nearest town to Bantamsklip, but as this town was developed as a holiday destination, we are very concerned that the internal services of the town will not be adequate to cater for a huge influx of permanent residents.

Another point of extreme concern is where the huge amounts of high levels of radioactive waste will be disposed of.

It is trusted that these concerns will be thoroughly considered and discussed before a final resolution is taken as to which site will be used for the construction of a nuclear power station.

Yours faithfully

ELRINA VERSFELD: CHAIRPERSON
PEARLY BEACH CONSERVATION SOCIETY