PELINDABA WORKING GROUP

AGAINST RADIATION

Tel: 012-205-1125 Cell: 083-740-4676 E-mail: pelindaba @telkomsa.net

P.O. Box 143, Broederstroom 0240 North West Province

On behalf of the residents in the following communities who are being deprived of a free flow of information concerning the nuclear developments: Lanseria, Broederstroom, Diepsloot, Atteridgeville, Hartbeespoortdam, Hennops River Valley, Rhenosterspruit, Muldersdrift, Honeydew, Kalkheuwel, Skeerpoort, Hekpoort, Lethlabile, GaRankuwa, Majaganeng, Brits, Oukasie, Dainfern, Mooi Nooi, Magaliesburg, and others.

October 2007

COMMENT ON DRAFT NUCLEAR ENERGY POLICY AND STRATEGY FOR THE REPUBLIC OF SOUTH AFRICA

Herewith please find the submission on behalf of the Pelindaba Working Group.

It is respectfully submitted that the Honourable Minister of Minerals and Energy seriously consider calling for:

  • A Nuclear Summit where issues can be properly discussed and in order for civil society, NGOs, CBOs and researchers can present information and reports of relevance to the honourable decision-makers in this country;
  • A national referendum in order that the South African public is afforded their democratic right to decide on the future energy mix for this country given all information available in the general international and local domain.

In addition to the submission herein contained, also please find:

  1. The various PDF files I submit as ANNEXURES hereto from the report by the Institute on Energy and Environment Research (IEER) which addresses a well-researched solution that addresses the solution for climate change and energy supply without having to resort to nuclear energy. The report is titled the “Carbon Free Nuclear Free Policy Plan for the US” and has recently been submitted to that government. While this plan is intended for consideration in US energy policy, it provides an invaluable basis for discussion in our own country.
  2. Documentation regarding research into human and environmental dose limits from radiation.
  3. Additional submission from the Pelindaba Working Group about civil society views on a Nuclear Policy subjoined hereunder.

General comments on the document & the Minister’s statement:

  1. This entire document is based on the falsehood of nuclear energy being “safe and sustainable”. This document also refers to nuclear energy and technology as “alternative” which it most certainly is not. It is only an alternative to coal-based energy stations. However, the term “alternative” in the context of energy sources has its roots in sustainable renewable alternatives – or “clean” technologies” - such as solar, wind, hydro etc. These terms have increasingly been commandeered by the nuclear sector to not only confuse the general public, but also to mislead decision makers. If the basic premise of a national policy framework is based on incorrect assumptions, it renders any pre-emptive conclusion null and void.

It is respectfully submitted, that the nuclear sector has performed a coup d’etat over policy frameworks, both in this country and the world over. It is part of an international strategy devised by the so-called Generation IV Forum some time back by Dr. Helen Caldicott in her book “Nuclear Power is Not the Answer” (2005) to ensure that nuclear options are adopted.

It is hoped the South African government will permit the scrutiny of all assertions before it by the nuclear sector by means of a nuclear summit that involves all stakeholders, decision-makers, and civil society (not as a “greenwashing” presence but as integral players with meaningful contributions to make). NGOs, CBOs, academics and various individuals in this country have spent years investigating and researching claims by the nuclear sector. Much of this information is being withheld from the South African public and government.

Contrary to the assertions by the nuclear sector of a global “nuclear renaissance”, there is also an international resurgence of an anti-nuclear movement backed up by ongoing research by experts. Earthlife Africa has, in several press releases recently, attempted to alert the government to this misinformation. It is hoped government will consider the importance of a nuclear summit in order to evaluate all the information available to it. Moreover, in countries like Australia for example, where significant uranium deposits reside, based on educated research most States in that country have opted to ban the mining of uranium.

Civil society is willing and eager to work with this government, and not against it, to provide decision-makers with a balanced view and information which, for some years now, has been in the international public domain. There is, however, a growing realisation that the nuclear sector is managing to exclude every opportunity for such balanced views in favour or its own agenda before decision-makers and, increasingly, is resorting to alarmingly secretive, non-transparent, and dirty tactics traditionally the trade-mark of the industry, to suppress a meaningful public debate. It goes without saying that civil society has nothing to gain by promoting its beliefs except a clean and safe environmental future for all unlike those in the nuclear sector who gain directly by propagating their views.

The recalcitrance of decision-makers to hold a nuclear summit and provide a meaningful platform to civil society on these issues is resulting in a growing groundswell of community-based opposition to South Africa’s nuclear programme. In addition to the already established NPOs and NGOs which oppose nuclear energy, a coalition of CBOs, individuals, academics, professionals, unionists and environmental activists have come together under the national umbrella movement, the Coalition Against Nuclear Energy (CANE). This coalition is growing weekly. It strives to engage with the government to democratically assist government in determining the most acceptable policies for an energy mix for this country which are truly sustainable, renewable, clean and green. This excludes a nuclear option and is backed up with solid research which will benefit decision-makers if given a chance. A nuclear summit will therefore be an appropriate mechanism.

International opposition to the nuclear option of energy creation, in the face of serious global climate change issues, is growing. In South Africa, citizens would prefer to believe we have a democracy that works and that it is our democratic and Constitutional right to be heard before resorting to all international and legal avenues.

  1. Peaceful purposes referred to in “purpose of the document”: There is no guarantee that nuclear development in this country will continue, in perpetuity, to be peaceful and that this development will not lead to the proliferation of weapons, terrorist threats, terrorist threats etc. Already there is a measure of doubt as to the long-term intention of our nuclear sector. The announcements of the intention to once again enrich uranium, places the industry and this country at the cross-roads of “peaceful purposes” and opens this country up for many unwanted problems. Please refer to articles below in this document, which refer to Intelligence Minister Ronnie Kasrils’ reported investigation into South Africa’s nuclear weapons capability for the future.
  1. “Industrial and technological leadership” refers:
  2. There is a skills shortage in SA and internationally. Where will this leadership come from?
  3. How can a country without the necessary backup on skills forge ahead BEFORE sufficient skills pool is created?
  4. Students currently being trained WHILE the nuclear plan is being implemented will not have the expertise, skills or experience to act responsibly over technology which is so dangerous.
  5. True leadership would consider all views and research and not try to suppress it, as is currently the case.

“Alternative”:

  • Uranium and nuclear energy are NOT “alternative” energy resources. We already have two nuclear power stations and several coal power stations. The Minister repeatedly misinterprets uranium as a sustainable renewable which it is not. Real alternatives lie in wind, solar, hydro etc.

“Globally competitive”:

  • Most jobs and economic benefits will be for international accounts. Why are we not focussing on global and local breakthroughs in the arena of alternative renewables such as solar, wind, hydro etc.
  1. This policy states that “it does not cover non-energy related applications of technology”. Nor does it cover viable “clean” sustainable and renewable energy resources and technology. This is a glaring omission which thusfar has accompanied all approaches to solving the energy crisis. Furthermore, it is the constitutional right of citizens that alternatives be seriously considered.
  1. The use of uranium as a primary energy resource: Uranium is NOT the primary energy resource available to South Africa. The abundance of sunshine must be considered the primary energy resource along with other “clean” options.
  1. The assertion, as a point of departure that South Africa has “more than 20 years experience of safe nuclear power plant operation …etc” is based on assumptions for which there has been no pubic disclosure, public scrutiny and from information in the public domain is highly contestable. Information in the public domain does not confer with such a statement. Indeed, it should be incumbent upon our decision-makers to assess the information held by civil society NGOs in this regard before contemplating a continuation down the nuclear route. Moreover, increasingly international governments are questioning the safety of nuclear power plant operations.

In South Africa information exists of:

  • Radioactive leaks at Vaalputs
  • Radioactive leaks at Pelindaba (numerous)
  • Repeated radioactive emissions at Pelindaba that warranted house arrest of all its staff
  • Radioactive leaks at the Safari 1 reactor
  • Repeated unexplained faults at Koeberg
  • Over exposures to radiation of workers at nuclear installations and on the mines
  • Radioactive contamination of drinking water and therefore the food chain in communities on the West Rand.

Internationally there is mounting concern over the claims that nuclear energy is safe, as this following article testifies:

Energy|27.07.2007

Concerns Mount Over Nuclear Energy After Series of Scares

Sceptics say recent errors highlight the drawbacks of nuclear energy

Irregularities at nuclear reactors in Germany and Japan in recent weeks have rekindled safety fears and raised tough questions about nuclear energy amid increasing environmental concerns.

The nuclear plant at Brunsbüttel in the northern German state of Schleswig-Holstein is now the world's safest. It's not surprising considering the reactor was shut down following a technical irregularity earlier this month.

The problem at Brunsbüttel, one of 17 nuclear reactors in Germany, is by no means the only mishap in recent months that has increasingly called the safety of atomic power into question.

Earlier this month, an earthquake caused leaks at a reactor in northwestern Japan andled to low-level radiation, revivingfears about nuclear safety, and the closure of the Brunsbüttel plant in Germany followed a fire at another reactor close to Hamburg.

Around the world, there are 438 nuclear plants currently in operation. The majority are in industrialized nations -- 104 in the US, 59 in France and 31 in Russia.

How dangerous were the incidents?

Despite the recent slew of incidents at nuclear power stations, the International Atomic Energy Agency (IAEA) said the errors in Germany, Sweden and Japan were exceptions and certainlydid not pose a danger.

That's a view echoed by Klaus Kotthoff of the GRS group, an independent nuclear assessment and research organization.

While there is no technology that's free of errors, Kotthoff pointed out that nuclear power plants are subject to a range of registration procedures and measures aimed at managing irregularities -- as was the case at two nuclear plants in Germany earlier this month.

A fire broke out last month at the Krümmel nuclear plant near Hamburg in Germany

"I believe these incidents were not noteworthy from a technical security point of view," Kotthoff said.

Critics of nuclear energy, however, don't buy the argument. Henrik Paulitz of International Physicians for the Prevention of Nuclear War (IPPNW) said the recent German incidents were dangerous.

"The reactor protection system was activated. That only happens in serious cases," Paulitz said, adding that they weren't isolated cases.

There are several nuclear incidents in Germany about which the public is not sufficiently informed, he said. The information that is released is mostly "incomprehensible" and the controversial backgrounds are often concealed.

"Serious security deficits are usually glossed over," Paulitz said.

Experts split over nuclear safety

Experts remain divided about the safety of nuclear reactors.

While Kotthoff said German plants are generally considered the safest, a 1997 study by the Organization for Economic Cooperation and Development ranked the German nuclear power station Biblis B second to last in an international nuclear power plant comparison.Only the Maine Yankee plant in the US faredworse, and it's since been shut down.

But Paulitz said other nuclear power stations too aren't much better.

Germany is again debating whether to stick to a nuclear energy phase out"An unfortunate mixture of technical problems and human error can at any time cause a major nuclear meltdown anywhere," he said.

The recent string of incidents comes at a time when nuclear energy seems to be undergoing somewhat of a revival. Considered one of the most cost-effective forms of generating electricity as prices of oil and gas rise, nuclear energy is largely favored by rapidly expanding economies in eastern Europe and Asia to meet their spiraling energy needs.

"The debates about climate change and reducing emissions also play a role here," said Alan McDonald of the IAEA. "And naturally, it's about securing production."

Nuclear energy plagued by problems

Nuclear energy production, however, remains problematic as most countries using nuclear energy need to import uranium. According to the IAEA, there are only 4.7 tons of economically viable uranium reserves worldwide. Given current levels of usage, experts believe stocks will only last for another 60 years. That would mean that uranium would be depleted faster than oil and gas reserves.

Experts also pointed to the unsolved problem of disposing nuclear waste, which remains radioactive for decades.

Experts estimate that uranium stocks will only last another 60 years

Paulitz said the environmental advantages of using nuclear energy are also limited since it only provides an estimated 1.2 percent of the world's energy needs. For nuclear energy to make a real difference in cutting greenhouse gas emissions, thousands of new reactors would have to be built, he said. That is hardly possible given the nuclear industry's low production capacity.

"It's only about sustaining energy production on this low level and maintaining the technology -- also because of interest in nuclear weapons," Paulitz said, adding that the world could easily do without this marginal energy source.

Security poses biggest hurdle

IAEA's Mcdonald said that security issues increasingly pose the biggest hurdle when it comes to using nuclear energy. The Vienna-based nuclear watchdog has set up an entire department to explore ways of preventing the misuse of nuclear materials and terrorist attacks on reactors.

"Terrorists who plant to blow up a nuclear reactor can do so with relatively easy means," Paulitz said. "Protecting against such attacks is just not possible."

  1. “Safe and sustainable use of an extended nuclear energy program” refers: ALL international research and reports indicate, firstly, that safety claims are highly dubious and secondly, that nuclear energy is NOT sustainable nor are uranium resources infinite. Down the line uranium will need to be re-processed resulting in further CO2 and CFC emissions, intensive use of fossil fuels and energy, the increased production of deadly radioactive waste and nuclear weapons capability.
  1. The “implementation of new structures and mechanisms to ensure successful implementation of this Policy” refers: Government’s stated policy claims transparent, accountable processes in terms of which, based on democratic principles, the public are entitled to participate in a meaningful manner.

Any and all new structures and mechanisms require public participation at every level. Furthermore, the government undertook to hold a Nuclear Summit some years back but this never occurred. It is therefore incumbent on this government to ensure that such a summit is held before any further nuclear policies or developments are implemented. The by-passing of this process in order to rewrite the 1998 White Paper on Energy via the September Energy Summit, involving mainly proponents of nuclear energy and uranium mining, does a massive disservice to democratic decision-making and the spirit of our fledgling democracy as contained in the 1998 White Paper.

Unlike “clean technologies”, nuclear energy has consequences for taxpayers, previously disadvantaged communities, workers, and the environment for generations to come. The nuclear option can therefore not be foisted on the public without the public firstly being educated about nuclear energy and, secondly, based on an educated opinion, being allowed to decide on this option.

  1. “Strategic Actions” refers: These are of importance to citizens and should be clearly outlined in order for comment to be made. It is suggested that “strategic actions” be high on the agenda of a nuclear summit.
  1. A “South African collective vision” is only obtainable through a nuclear summit involving all stakeholders, civil society and interested and affected persons. A “collective vision”can only be achieved by involving all sectors, all stakeholders from civil society in democratic processes. Increasingly processes for decision-making are discriminating against civil society and have come to be viewed as “greenwashing”. This is in defiance of Constitutional rights of the voting public. Therefore, a nuclear summit, as suggested in this letter, is necessary.

ISSUES NOT COVERED IN THE DRAFT FRAMEWORK:

  • A nuclear summit.
  • The history, track record and research on the state and consequences of the nuclear industry on peoples around the world.
  • Acceptable legislative requirements sought by civil society.
  • Nuclear insurance and third party liability policies.
  • International agreements on nuclear insurance and third party liability policies.
  • International agreements that provide for the protection of civilians.
  • Civil society monitoring / surveillance of the nuclear sector.
  • Discussion on dose limits for the public and environment.
  • Evacuation plans and health insurance for affected communities.
  • International implications of the nuclear policy with reference to international alliances and terrorist threats.
  • A thorough evaluation of the economic feasibility of a nuclear option for South Africa versus “clean technology” options.
  • Decommissioning costs.
  • Costs of radioactive waste management and containment over hundreds of thousands of years taking into account massive geological disruption globally.

Comments on Section A. Nuclear energy policy framework: