CANE - Coalition Against Nuclear Energy South Africa

Submission to the Department of Minerals and Energy
on the draft for public comment of the document
Nuclear Energy Policy and Strategy for the Republic of South Africa
from
NECTEC
Nuclear Energy Costs the Earth Campaign,
Earthlife Africa, Johannesburg

0. Participation of civil society is minimal and problematic.

We welcome the opportunity to make submissions to the policy process. However, in our view that the policy process is misplaced, having had no input from civil society in its very formulation. Gone are the days in our democracy when different sectors of society were drawn into the policy making process. Now we are back to the apartheid-era style of governance, whereby the policy documents are formulated behind closed doors by bureaucrats and then opened to public comment for a brief period.

Inclusion of civil society within the most recent 2007 Energy Summit was derisory. Many parts of civil society felt it was an illegitimate process, because they had been excluded from participation, unlike the previous Summit in 1996.

We are pessimistic that public comment on this document will be taken seriously by government, rendering the entire process a cosmetic and therefore an illegitimate form of consultation and participation. Our sense is that we are dealing with a fait accomplit (a done deed) in which government is only going through the motions of consultation.

Nevertheless once again we need to place our concerns on record.

1. The nuclear path is an unsuitable way forward for sustainable development in South Africa.

South Africa has enshrined the principle of sustainable development in its constitution (see article 24) and in its legislation (see the National Environmental Management Act no. 107 of 1998). Furthermore South Africa’s commitment to sustainable development was witnessed in its agreement to host in Johannesburg the 2002 UN World Summit on Sustainable Development. The summit produced the Johannesburg South Africa has also, since 1994, acceded to the Rio treaties on Climate Change, Desertification and Biological Diversity. Under the latter, the government is meant to produce a strategy on sustainable development to be tabled with the secretariat of the Convention on Biological Diversity.

Despite these commitments, government is making choices to introduce unsustainable technologies like nuclear. Nuclear energy is an unsustainable energy source because:
– It is based on fuel that is finite in nature
– It creates a perpetual problem of radioactive waste
– It creates unnecessary risks for workers, consumers, communities
– It removes control over energy to centralised secretive elites
– It poses unnecessary economic burdens on municipalities who need to be prepared for the special disaster management possibilities posed by the industry
– It creates a few high-end jobs for highly trained technicians compared with renewable sources which open up huge job possibilities at local level, therefore it is not the best route for poverty alleviation
– It increases the risks of environmental contamination including our precious freshwater supplies and marine resources
– Unlike the industry’s claims, the nuclear fuel chain is not carbon-neutral
(see the argument for this below)

Furthermore, it requires such large investments that it absorbs resources that could be better devoted to more equitable forms of development. It makes little contribution to poverty alleviation, thus making the realisation of the Millennium Development goals even more remote.

As uranium becomes scarcer, there are a number of important consequences:
– Using this form of energy will become costlier with time
– The quality of the uranium ore mined will deteriorate and become more expensive to mine and process
– There will be longer supply chains as more remote areas will have to be mined
– Electricity tariffs will become less affordable, unless highly subsidised
– Some analysts believe that uranium supply is likely to peak quite soon, making the mineral scarcer and more expensive as a source of fuel, and unavailable in the long run

Nowhere in the policy document is there any serious scientific study of the economics of uranium, and its global availability in the long-run.

We believe that the expense of choosing the nuclear option will take us further down the road of unsustainable energy solutions, raise the price of energy to most consumers, and demand resources from the state that should better be devoted to the meeting of the Millennium Development Goals.

2. The nuclear energy policy and strategy document is an example of special pleading, the embodiment of vested interests, and hence unscientific.

The 1998 Energy White Paper noted that no nuclear developments would take place without first undertaking integrated energy planning. There is no evidence that this planning has been undertaken and that independent scientific evidence shows that nuclear is the most efficient, cost effective and environmentally acceptable option. The nuclear policy and strategy document is therefore a case of special pleading on behalf of one section of the energy industry.

We can only surmise, then, that this scientific work remains undone, and that therefore, the unproven case for nuclear is being motivated by people or organisations with a self-interest in promoting it. Organisations include Eskom, NECSA, at least two ministers, and a small group of scientists, politicians and bureaucrats, former apartheid bomb makers, industrial suppliers, based in and around the industry, all of whom would be beneficiaries if this policy becomes accepted. These people have access to power and therefore can impose their views on the rest of society.

Independent studies around the costs (e.g., of the PBMR) have been suppressed and not placed in the public domain.

Without a scientific or a financial case for this technology, and in the absence of public scrutiny, we now see the DME — which should be defending the interests of the public at large — defending the interests of NECSA and Eskom, bodies which should also be serving the nation, and not serving such narrow sectarian interests.

3. The document relies on half-truths for its arguments that the nuclear energy industry is carbon neutral

Whilst there are few emissions in the fissile reaction itself, there is a considerable carbon footprint resulting from:
– Mining and milling: South Africa’s gold mines, of which uranium is a by-product, has ores located at very deep levels, resulting in a huge need for refrigeration technology, haulage, and drills powered by electricity
– The conversion to gas, enrichment, fuel fabrication and reprocessing stages: these are extremely energy intensive; while the bulk of the power they use up will be coal-fired, these processes will emit a huge amount of carbon
– Transport of nuclear materials, including fuel and waste: this will escalate under the proposed programme and will emit a huge amount of carbon; this will be intensified if long-distance imports and exports are included
– Construction materials for the reactors: cement is especially energy intensive, and together with the manufacture of turbines and other large machinery, is likely to leave a large carbon footprint
– The decommissioning and decontamination of nuclear facilities after use: these activities are likely to be highly energy intensive and raise levels of carbon in the atmosphere, they need to be factored into the overall carbon used in generating nuclear energy
Let us have the arithmetic of the cradle-to-grave stages in the nuclear fuel chain, before glib announcements of how carbon-friendly the industry is. Let us also have the comparative arithmetic on alternative renewable energy resources before we proclaim that nuclear energy has environmental advantages.

4. The nuclear industry is of necessity shrouded in secrecy, not helpful for establishing democratic values in our young democracy

Since it is the citizens and taxpayers who foot the bill for the industry, and who consume its products, every South African should have the right to know about decisions made in their names on energy futures.

However the nuclear industry operates in relative secrecy, which often masks mismanagement:
– There has been no independent audit of the industry for the past ten years and little public scrutiny of the industry is permitted
– Where things have gone wrong, for example at Koeberg in the summer of 2005/6, independent regulators (NERSA) have blamed Eskom mismanagement and failure to report incidents or conform to licence conditions, while politicians insisted that sabotage was the cause, then later denied this was ever suggested
– The finances of the PBMR Company should be openly available, as should the amounts of state investment and subsidy in the company
– All documentation related to the apartheid-era programme of making weapons of mass destruction should be released to the public domain; those responsible for the programme should be named and shamed
– Trials of nuclear traffickers should never be behind closed doors

The policy document advocates the setting up of a dedicated security service, a nuclear police force. This is a typical example of how we are expected to support proposals which see South Africa falling back into the hands of a ’security state’ as we were under apartheid, where we rely on industries that are so risky that they need special types of police forces. We don’t want the country remilitarised for the sake of this industry, especially when there are cleaner alternatives that pose relatively little risk to the public. We therefore reject all technologies that require us to remilitarise or return our state to how it was under apartheid, driven by security-obsessed minority interests. If the very nature of the nuclear energy industry requires such policing, we should reject it out of hand. We believe such a nuclear police will be repressive in relation to civil society organisations which oppose the industry. In addition, the cost implications of setting up such a security police need to be factored into the costs of nuclear energy.

5. The policy and strategy maintain that the nuclear energy industry exists for peaceful purposes, but cannot offer assurances that this will be respected by all future governments

The enthusiasm expressed in the document for South Africa to re-acquire enrichment technology, as well as reprocessing technology, open up the way to proliferation of weapons of mass destruction.

The current government may profess to want to do enrichment or reprocessing for peaceful purposes, but once the genie is out of the bottle, is in no position to underwrite that this position will be honoured by all future governments.

The DME sees enrichment and reprocessing as being the same as ‘beneficiation’ of all other minerals. However, uranium is not like other minerals, for obvious reasons: it can be utilised to make nuclear weapons if enriched in the appropriate way.

We reject the idea that enrichment and reprocessing of uranium are necessary for the South African economy. Clearly the sums have not been done, and we suspect that the extra cost burden would raise the price of our energy, when enriched uranium would be imported more cheaply. We reject the technological nationalism which requires us to ape the nuclear industries in the developed economies, to give some spurious status to a handful of scientists, and further devote scarce resources to the local nuclear industry when these could more beneficially be devoted to renewable forms of energy generation and other forms of poverty alleviation.

At the very least, should South Africa go the route of enrichment of uranium, we insist that the Constitution be amended to guarantee that this will be used solely for energy purposes, and that proliferation of nuclear weapons will be deemed illegal and unconstitutional.

6. If expansion of the industry is to be envisaged, we insist on the strengthening of the nuclear regulatory apparatus, its independence, and its obedience to principles of good governance

The National Nuclear Regulator is ill-resourced in relation to its tasks. It needs to be fully capable of managing licence applications for nuclear facilities, as well as securing the nuclear safety of the entire population, and dealing with the backlog of contamination due to over fifty years of uranium mining.

The National Nuclear Regulator should not be fused with other regulatory bodies.

The National Nuclear Regulator should not fall under the control of the Department of Minerals and Energy. The DME is a clear promoter of the industry, and therefore it is a conflict of interest to have any control over the regulator. The regulator should be made independent of the DME, and fall under another authority such as Parliament.

Good governance of the regulator demands that the revolving door syndrome between the industry and the regulator should be made illegal. For example, the current CEO of the NNR should immediately recuse himself from office, having been a formerly an incumbent in the management of the Pebble Bed company. There is clearly a conflict of interest here, something which flies in the face of good corporate governance and the principles of the King Committee. While the revolving door syndrome is allowed to function, the public can have no confidence in the legitimacy and independence of the NNR.

Board members of the NNR should be selected from appropriate constituencies and given budgets to report back to these constituencies. Board minutes should be placed in the public domain as a matter of course.

7. The policy document lists some key role players but reveals its bias in ignoring others

There is no mention of the following being included as key role players
– The Department of Environmental Affairs and Tourism
– The Department of Water Affairs and Forestry
– Provincial and local authorities
– The general public - who need to be included in all policy formulation on
national energy questions, given their role as citizens, consumers and taxpayers who fund the industry
– Affected communities - based in the vicinity of nuclear facilities, transport routes or ports where nuclear materials are imported and exported
– Workers in the nuclear industry and their trade unions
– Civil society organisations concerned with safe energy provision and environmental justice
– The news and information media, as potential hosts of open debates on our energy future

It is sad that the DME cannot acknowledge that these constituencies also have important roles to play in the deliberation of nuclear policy.

8. Expansion of the industry will pose enormous extra risk to human and ecological health

Unlike sources of renewable energy, the expansion of the nuclear industry will place an extra burden of risk on the entire population and the eco-systems that sustain its livelihoods.
– Chances for radioactive contamination of land, water and people will expand rapidly
– Workers in the industry will be particularly vulnerable, as will communities adjacent to nuclear facilities
– Chances of transport accidents involving nuclear materials will increase dramatically on our overcrowded road system; our road safety record in South Africa is such that an increase accidents involving radioactive materials is an inevitability
– Preparedness by local government authorities for nuclear-related accidents will place an extra burden on their budgets and skills and redeploy resources away from basic service delivery for the poor
– Victims of nuclear incidents and accidents will be burdened by the costs of contamination, since the insurance industry is unwilling to risk underwriting claims for nuclear damage

Given this situation, we propose:

– That epidemiological studies are undertaken, under the aegis of the NNR, of communities adjacent to nuclear facilities; the NNR needs to adjust its methodology to account not just for the radioactivity leaving the nuclear facilities, but also its impacts on receiving communities
– Nuclear liability act must be established for the protection of the public, environment and person for any nuclear /radiation exposure amounting to R4 billion per injury.
– Substantial buffer zones between nuclear facilities and populations need to be promulgated and upheld under the law; members of communities adjacent to nuclear facilities be issued with Geiger counters and the appropriate training to monitor levels of radioactivity
– Insurance companies and homeowners are not insured for nuclear accident, therefore the nuclear industry must put forward an insurance fund managed by Parliament for any nuclear incident.
– That given the mismanagement, secrecy and chicanery of NECSA and Eskom, that medical records of nuclear workers be maintained by an independent public health agency
– That, given the especially risky nature of the industry, nuclear industry employers be directly responsible for the health of their employees, that compensation should be offered directly by the industry, and that this be acknowledged as a special case; it has been shown that expecting former nuclear workers to deal with the Compensation Commission is untenable
– That mine owners be held responsible for the cleaning up of any radioactive contamination resulting from mining and milling of uranium, particularly when it results in contamination of watercourses and land; a system of large fines should also be instituted as a deterrent
– The impacts on marine eco-systems adjacent to pressurised water reactors should be analysed annually and the reports placed in the public domain; similarly there should be regular, transparent monitoring of the impacts on land, water and people in a predetermined radius around PBMRs
– Nuclear industry must be refrained from using compensation fund for their workers. They must put a fund separate to manage any nuclear workers espoused to radiation illness.
– An independent public health institution must be appointed to monitor nuclear workers ,communities near nuclear installation. It must have power to access medical records, examine and propose exposure damage to the government for the compensation of the identified workers.

9. Energy alternatives should be more carefully considered

The DME has a responsibility to do the comparative mathematics involved in assessing both the nuclear industry and its alternatives. This should be done independently and the results placed in the public domain. In doing so, all financial subsidies and state investments should be made explicit. All externalities should be included in the comparative pricing of the different options. We insist that this should occur prior to any expansion of the nuclear industry.

10. Export to other African and developing countries

We object to the notion that South Africa should try to profit from exporting its nuclear expertise and materials to other African and developing countries.

We feel that this reopens South Africa to accusations of a ‘big brother’ or sub-imperialist position with respect to its trading partners in the continent. There will be a temptation to foist its technology onto these partners in order to justify economies of scale at home. The danger this poses to other countries extends grave risk, and will impose upon each partner the need to establish highly capital-intensive energy systems, as well as creating the expensive regulatory apparatus needed to manage the industry. It also creates the possibility of South Africa offering to dispose of the nuclear waste of these countries, or placing the burden on each country of disposing of its own waste.

All these plans will create unnecessary energy dependency on South Africa, offer a highly expensive and risky technology, and cause other countries to divert their economies away from poverty alleviation. The possibilities of proliferation of nuclear weapons will multiply accordingly. We need to re-examine our role and responsibility in relation to these possibilities.

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