From human resources to waste management, South Africa has fallen short of international standards for nuclear expansion, writes Lynley Donnelly.
South Africa's ambitious plans have far to go before six new nuclear power stations can be rolled out. This has emerged from the government's own assessment of the country's readiness to embark on nuclear fleet procurement.
Draft documents, dated late last year and seen by the Mail & Guardian, appear to be part of the government's preliminary preparations for an integrated nuclear infrastructure review, an assessment guide developed by the International Atomic Energy Agency to aid countries embarking on a nuclear power programme.
The review covers 19 infrastructure issues over three phases that a country should address. They include the government's position on its commitment to develop nuclear energy, safety, management, legislation, funding and financing, safeguards, regulatory framework, radiation protection, human resource development, environmental protection, emergency planning, security and physical protection, radioactive waste and procurement.
The draft documents identify many gaps relating to these issues and questions over funding and skills feature prominently.
Regarding nuclear safety, one of the gaps identified was sufficient numbers of qualified staff "with appropriate education, training and retaining [sic]" for safety-related activities at each nuclear installation throughout its life.
Although the Cabinet recently named Eskom as the owner and operator of any future nuclear power stations, an appropriate funding solution for the power utility was identified as a problem in the draft documents.
An appropriate model to ensure that the mandate of the national nuclear regulator was adequately funded and resourced was another gap identified. The regulator's capacity will have to be upgraded significantly to incorporate the oversight of six new nuclear power stations into its operations.
Significant weaknesses were also highlighted under human resources. The skills for "structuring and negotiating the financing and procurement for [a] nuclear programme [were] not in place", it was noted, and a government skills audit for a nuclear build programme had yet to be completed. Qualified staff were "low on technical and industrial experience" and there was a "lack of experienced training instructors in all fields", namely technical, scientific and operator simulator trainers.
In terms of environmental protection, the current regulatory framework did not cover the protection of non-human species in the event of nuclear damage.
Gaps identified regarding radio-active waste included the resources of the regulator and the department of energy, which were deemed insufficient to cope with the workload arising from the proposed nuclear programme and ensure that appropriate processes and procedures were developed.
In terms of procurement, according to the documents, the specialised skills required for a project of this nature were absent.
The documents include an action plan listing the gaps, the actions required to address them and the parties responsible.
It is not clear how much progress the state has made in addressing these and other challenges identified.
According to a media statement released by the department of energy last month, it said the International Atomic Energy Agency would be leading an infrastructure review mission to South Africa in February next year. In preparation for this, nuclear stakeholders such as the South African Nuclear Energy Corporation, Eskom, the regulator and key government departments, including energy and public enterprises, did a self-evaluation.
These entities are all part of the national nuclear energy executive co-ordination committee, led by Deputy President Kgalema Motlanthe, South Africa's decision-making body for the nuclear programme.
The international agency held a workshop in late October to prepare these stakeholders for its February mission and to give stakeholders an opportunity to comment on the self-evaluation report.
The integrated nuclear infrastructure review was not intended to be an "external audit of the national infrastructure. Rather, it describes the sequential development through the three phases for each of 19 milestones", according to the statement.
Naming Eskom as the owner and operator of future nuclear stations is the strongest indication yet that the government will go ahead with its plans.
But there will be a great deal of public debate regarding the affordability of the programme.
Brian Dames, Eskom chief executive, said this week that the utility was pleased by the announcement, which had provided the company with a modicum of clarity over its future role. But the next step was "firming up" the decision, which required a determination by the minister of energy under the new-generation regulations that would set out allocations for nuclear energy.
The first thing Eskom would be doing was looking at how to fund nuclear expansion, Dames said.
Eskom would only have a clearer understanding of the impact nuclear expansion would have on electricity tariffs after the funding solutions had been examined, he said.
But several civil society organisations are opposed to the expansion of South Africa's nuclear fleet. Greenpeace Africa and the South African History Archives announced at the weekend that they had laid a complaint with the public protector and the South African Human Rights Commission over Energy Minister Dipuo Peters's refusal to make the nuclear infrastructure review public.
Their request for its release under the Promotion of Access to Information Act was refused in October and Greenpeace Africa is considering taking the department to court, according to Ferrial Adam, the organisation's energy campaigner.
The minister refused the appeal on the grounds that the review was still in progress and the release of a draft report would be premature.
But Adam said it was clear the country did not have the skills or capacity to tender for, or to build, a fleet of new nuclear power stations. The lack of transparency "over such a large decision where we could be spending trillions of rands" could not go unchallenged, she said.
The department of energy did not respond to questions about the review, but in a previous response to the M&G about South Africa's nuclear status the department said it believed nuclear power was the "least-cost, non-CO2 [carbon dioxide] emitting electricity generation option". Any expansion of the country's electricity capacity would result in an increase in electricity prices "irrespective of the type of primary energy".