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The statement below was sent to the Parliamentary chairperson of the portfolio committee on Environment and Tourism as well as the chairperson of the portfolio committee on Minerals and Energy

Why are we against the PBMR?
Position statement June 2004

Eskom has put forward the Pebble Bed Modular Reactor (PBMR) as a nuclear project with economic benefits to South Africa, as a project which will also provide electricity to meet South Africa's future demand. However, during the Environmental impact Assessment process, a number of extremely critical issues have been raised. Eskom has failed to respond.

Amongst these issues is:
- the economic viability of the PBMR,
- the radioactive nuclear waste that remains toxic for millions of years with no place to store it, and
- the health impacts, particularly of low dose radiation
- the technical safety aspects

Economics:
In the energy field, there are many different models of costing the generation of new capacity. In essence, someone whether private or state, must pay for the research and development (if needed), the building of the new plant, the operations and maintenance, the decommissioning and any waste which is left over.

Investors, whether state or private, want their money back with interest. They can do this by charging customers/consumers for the electricity they produce. Therefore, the more the electricity costs to produce, the more expensive it will be for consumers!

Involuntary investment in an experiment with no benefit to us!
According to Eskom the PBMR process to date cost over R1 billion. This is just the cost of the feasibility studies, without building an experimental design and testing it. Eskom admitted in 2003 that the cost of one demonstration plant would be R10 billion and we guess that is an underestimate. That does not include the long term costs of waste storage for millions of years. This is public money which will be squandered on experimental technology and the majority of the costs will be borne by the public whether as consumers or taxpayers.

According to a notice issued on 27th March 2003 by Eskom?’s consultants:
?“Eskom (state owned) on its part, is financed from sales revenue and loans (and not from the Treasury as may be generally believed) for new projects as well as for the operation/maintenance of existing plant or the decommissioning of redundant plant/facilities. ?…?…. Eskom?’s portion of the development, capital, operation/maintenance and decommissioning cost will be converted to a sales tariff?….?”


However, the document then says:
?“The precise amount for the development and construction of the PBMR demo plant is not available to the PBMR EIA Consortium (the information is also considered commercially confidential)?”.


What is going on here? Eskom is taking our money and putting it into some high risk experiment. How can we as taxpayers and consumers be forced to pay for something and yet we are not allowed to know how much it costs?

Foreign Investment:
If the PBMR was such a good investment how come there were only two international investors prepared to invest in the technology ?– Exelon which withdrew, and BNFL which is in grave financial difficulties, facing clean up charges of billions of pounds. (BNFL was also guilty of falsifying data for a nuclear reprocessing shipment). Eskom's last desparate attempts to attract Areva failed and Areva has since stated that " the PBMR is 'not competitive to generate large-scale electricity ?…..".

Will Eskom and IDC as the two local investors make up the shortfall? Eskom admits that it has paid 45% of costs to date despite only having a 30% shareholding. According to Dave Nicols, then CEO of the PBMR company, a condition sine qua non for the PBMR to go ahead is that there must be credible international investors. Where are they?
At what point does someone shout stop!

Waste:
Currently high level radioactive waste from Koeberg is stored in on site, (to be sent to a yet to be decided final storage site) and the low level radioactive waste is taken to Vaalputs in Namaqualand.

To date NO storage facility anywhere in the world has been built to accept high level nuclear waste.

The proposed Yucca Mountain Repository in the USA is still not built after 25 years of investigations costing more than $ 8 billion .

In South Africa, Vaalputs, Northern Cape, is only allowed to store low and intermediate radioactive waste, such as 45 gallon drums containing used protective clothing, resin filtrates etc. It is very likely that Vaalputs will be identified as a high-level nuclear waste site. In motivating Vaalputs as a high level waste storage facility, the consultants will point to the dryness of the climate, and geological stability.

However despite Vaalputs apparent aridity, desolateness and geological stability much can change in 250 000 years or 7 million years for that matter! In the last two million years the global climate change has drastically fluctuated more 46 times between dryer and wetter periods each lasting approximately 40 000 years. Not so long ago, the Sahara desert was a marshland.

In time it will rain in on Vaalputs, and the rain will bring life abundantly, springs and rivers will flow again. If we overlay high level hazardous waste in the area this will be compromising the rights of the future generations to meet their very basic needs.

Health:
Internationally there is increasing evidence that exposure to low dose radiation causes cancer.

An epidemiologic study published in 1997 reported no significant rise in childhood cancer rates around West German nuclear power plants. The conclusions of this study were extensively used by politicians and lobbyists as proof of no increased cancer risk around nuclear power plants. A reanalysis of the data, however, reveals a statistically significant increase of childhood cancers (all malignancies) when the evaluation is restricted to commercial power reactors, the vicinities closest to the plants, and children of the youngest age group (0-4 years). [2]

The European Committee on Radiation Risk (2003) found that the nuclear industry has calculated the risk posed by ionising radiation in a way which underplays its negative health impact. Thousands of people who live near reactors are at risk.

There seems little doubt that communities living near nuclear plants are at risk. Before we even think of more nuclear reactors, we need to see epidemiological studies of communities around Koeberg.

Eskom appears to have presented misleading and biased information during the PBMR EIA process in an attempt to play down possible negative health impacts.

In his submission to the PBMR EIA, Professor Lesley London from UCT: " The fact that the major reference relied upon in making its conclusions is to the International Atomic Energy Agency web site is particularly disturbing. This agency exists to promote nuclear technology. As such, it is hardly a neutral source of information..

In summary, none of the annexures contain any epidemiological evidence of adequate quality. It is therefore astonishing that the EIA report could base its conclusions ?…on only a handful of epidemiological studies of between 5 and 20 years old, out of a huge literature. Indeed, since 1996, there are over 200 such articles in the peer-reviewed literature..! The fact that the EIA makes no effort to tap this very rich source of data is simply unacceptable."

In other words, the document which the public were able to comment on, and which the Minister is to make a decision on provided misleading information and did not inform people of the real health risks. Eskom?’s is prepared to lie in order to prevent the public from finding out the truth.

Technical Safety:
There are serious reservations about the safety of the current PBMR design. The Nuclear Regulatory authority in the USA has raised serious concerns and that the PBMR is significantly flawed. As the PBMR relies upon circulating gaseous helium instead of water to cool the reactors, Dr. Powers of the NRC, questioned the designers?’ confidence that water and air intrusion into the core can be easily ruled out.

Such scientific doubts raise more questions about the risk of an accident involving uncontrolled fissioning and subsequent fire leading to a significant release of radiation. Dr. Powers pointed out that difficulty in obtaining the relatively pure graphite needed to control the reactor?’s fission process is also problematic as lower grade graphite significantly raises the susceptibility of the design to a runaway fire.


Conclusion:
Earthlife Africa believes that if any rational parliamentarian listens to all sides of the story, there is only one conclusion they can come to - nuclear power is not for South Africa - and our country is not to be used as a dumping ground for nuclear waste.

Earthlife Africa calls on the new parliament to hold a national nuclear summit, to provide a platform where organizations like ours can put our views, and should enable technical experts to provide information to counter the nuclear propaganda put out by the nuclear industry.

Earthlife Africa believes that South Africa needs environmentally responsible development that will lead to an improvement in the quality of people's lives and will lead to truly sustainable development - economically, socially and environmentally.

For more info, contact Sibusiso Mimi - 072 494 1395 ??


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