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Submissions on the Nuclear Determination – groundWork

Nuclear Determination comments – groundWorks Feb 2021

Nuclear determination

gW comment on the minister’s determination on the procurement of 2 500 MW generation capacity from nuclear

 

Introduction

The Minister has issued a determination to commence the process to procure the new nuclear energy generation capacity of 2 500 MW as per decision 8 of the Integrated Resource Plan (IRP) 2019.

 

The IRP 2019 is a deeply flawed document for four main reasons:

  • The build limits imposed on renewables;
  • The inclusion of fossil fuels despite the evident intensification of the climate crisis;
  • The fantasy of clean coal as per decision 6;
  • The nuclear folly in decision 8.

 

A folly is not only a piece of foolishness, it is also an extravagance built for appearance or status. We oppose it for the following main reasons:

 

  1. Environmental damage done in the mining and processing of uranium. At present, radioactive dust blows from the mine dumps on the Rand and particularly the West Rand. The nuclear regulator has no plan, and apparently no will, to deal with it. It may be that South Africa will procure fuel from France or somewhere else. This merely displaces the problem – the uranium mining areas of Mali are heavily contaminated.

 

  1. Following mining, fuel fabrication is energy intensive and polluting.

 

  1. The lack of any feasible plan to deal with high level nuclear waste. At present, high level waste from Koeberg is stored under water on site while low level waste is dumped at Vaalputs. Given the very long half life of uranium, a high level nuclear dump site must be safe, and monitored and managed for several hundred thousand years. The assumption that the present civilisation will last that long is presumptuous. In the short term, the potential for waste spills increases with the quantity of waste.

 

  1. The DMRE regularly repeats the phrase ‘at a pace and scale that the country can afford’, as if repetition will make it affordable. And it periodically pretends to have information on costs which it cannot divulge for reasons of security or confidentiality. Outside of the nuclear lobby, nobody believes it. Eskom CEO Andre de Ruyter recently gave a ball park figure of R1.80 / kWh for nuclear against 60c or 70c/kWh for renewables.[1]

 

  1. That is before cost and time overruns. In 2009, we predicted that the construction of Medupi and Kusile would end in tears with cost and time overruns. Various politicians then implied that we lacked patriotism. Their ‘patriotism’, however, now constitutes the most significant threat to national stability. New nuclear builds are notoriously prone to cost and time overruns and corruption.

 

  1. They are also prone to corruption at the top level of the states involved in any nuclear deal – as it was with the aborted Russian deal. The corruption then, is not merely about money, but also about geo-political leverage over the ‘recipient’ country. This is profoundly anti-democratic.

 

  1. Nuclear power also promotes anti-democratic tendencies within the structures of state and industry. By its nature the fuel requires high levels of security, both because it is radioactive and because of its potential for use in weapons. Hence, nuclear technologies tend to promote state security agencies which thrive on secrecy. Moreover, when those security agencies are corruptly involved in manipulating politics and or taking money, as South Africa’s SSA has, they can be expected to act in ways that are hostile to democracy. Security agencies are also linked to the relevant divisions of energy, minerals and trade departments as well as to private transnational or national corporations, as well as transnational state owned corporations such as EDF or Rosatom. The result is a tightly networked group with a common interest in evading scrutiny and accountability.

 

  1. Nuclear power stations cost as much to decommission as to build – and are similarly subject to time and budget overruns and likely also to corruption. And there is no future income to pay for it. It is of concern that Eskom does not appear to have put aside the money to decommission Koeberg (or any other of its power stations) and we surmise that the extension to its design life has to do with this as well as with Eskom’s capacity shortfall.

 

In the context of nuclear power, it is of particular concern that the Minister’s determination allows that the generator, the buyer and the procurer of nuclear power may be just about anyone and, moreover, that the procurer then decides the procurement process. The contrast with the earlier determinations, where generator, buyer and procurer are predefined, is marked.

 

[1] Terence Creamer, De Ruyter calls for upscaling of power procurement plans as he questions whether coal IPP will proceed, Engineering News, 24 November 2020.

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