In the high-stakes nuclear game, will a radioactive waste-management policy be foisted on an unsuspecting public or will ”transparency, consultation and stakeholder participation” be a reality?
A draft policy containing those words remains ungazetted while the government commits itself to developing prototype pebble-bed nuclear reactors for commercial use.
”The draft policy appears to be following a ‘design, announce, defend’ approach with respect to all radioactive waste,” said Nik Wullschleger, an independent scientist and geologist.
Wullschleger said given the complex scientific nature of radioactive waste management, there has been ”insufficient time” for capacity building, effective public participation and proper comment.
He said the public participation process is ”seriously flawed” and makes a mockery of a ministerial foreword to the draft legislation that states that among the policy’s ”great achievements is its participatory process”.
By Wednesday afternoon, the government had not commented, despite a list of questions e-mailed to the nuclear chief director, Tseliso Maqubela, and ministerial spokesperson Yvonne Msolo last week.
The radioactive waste-management policy, released for public comment in 2003, is the government’s attempt at addressing shortcomings in managing nuclear waste.
The comment period was initially only a month and the policy was only available in English.
Lack of framework
Despite operating the Koeberg nuclear reactor on the Cape West coast, and another nuclear facility at Pelindaba near Pretoria, the country does not have a regulatory framework for radioactive waste management.
High-level waste at both facilities is stored on site because it is too dangerous to move, while medium- to low-level waste is buried at the Vaalputs site in the Northern Cape.
South Africa might build 20 pebble-bed modular reactors (PBMRs) to meet future electricity demand, with each plant producing up to 32 tonnes of high-level waste a year, including 1,5 tonnes of uranium.
If only five reactors are built, each operating for its entire 40-year lifespan, space would have to be found to store a massive 6 400 tonnes of radioactive waste.
Earthlife Africa’s Sibusiso Mimi said a ”policy is simply an idea of a plan”.
He used the United States — a nuclear giant — to illustrate that proposals to store high-level waste remain unresolved after years of controversial debate.
In the US, the proposed Yucca Mountain high-level waste-storage facility remains unbuilt, with investigations into suitable sites costing hundreds of millions of dollars.
”It is totally foolhardy to continue to produce highly toxic waste with no real plan of what to do with it,” said Mimi.
Critiquing the draft legislation, Wullschleger recommended that polluters carry the full cost for the entire hazardous lifespan of the waste, ”including ‘grave-side’ maintenance and monitoring”.
Wullschleger said the principle of best available technology not entailing excessive cost (BATNEEC) could be abused by profit-motivated generators and operators, such as Eskom.
He said in accordance with the precautionary principle, BATNEEC should be replaced with the best practicable environmental option, as described by the National Environmental Management Act of 1998.
Wullschleger also raised concern over the proposed national radioactive waste-management agency, saying a potential conflict of interest exists because the agency will be a ”wholly-owned subsidiary” of the South African Nuclear Energy Corporation (Necsa).
Necsa is the promoter of nuclear technology and will now be charged with the management of radioactive waste.
While the government appeared to favour deep geological disposal of radioactive waste, Wullschleger said ”retrievability” of containers, when considering public safety or a possible containment breach, should be ensured at all costs — especially because the hazardous lifespan of radioactive waste, such as spent fuel, plutonium or uranium, could be millions of years.
‘True costs’
In its submission, the City of Cape Town suggested that the draft radioactive waste strategy be revised to include a framework timetable, budget and deadline for the establishment of a final repository for high-level nuclear waste.
This timetable would consider the ”true costs” of nuclear power, the city said.
Cape Town wants the costs of providing financial guarantees and security against potential nuclear accidents to be assessed relative to the population potentially affected in a worst-case scenario.
”Although unlikely, a severe accident could have far-reaching and long-term impacts on the entire city population and economy of the Western Cape. To put some perspective on the magnitude, the R3,5-billion guarantee [for Koeberg] would provide just over R1 000 per person [for compensation] for the 3,2-million population of Cape Town.”
The city warned that if the full lifecycle financial and environmental risks and costs are not taken into consideration, current electricity consumers may not have paid the full costs of electricity.
”And the outstanding costs may be held over for future generations to bear.”
The city has already submitted an appeal to Minister of Environmental Affairs and Tourism Marthinus van Schalkwyk, against the record of decision authorising the pilot PBMR at Koeberg.
The PBMR authorisation included the condition that the national policy on radioactive waste must be in place before commencement of construction of the prototype nuclear reactor. — Sapa