The article originally appeared in New Frame on 12 March 2021. It can be viewed here.
When the government failed to put the National Radioactive Waste Disposal Institute (NRWDI) into action, Eskom applied last July to the National Nuclear Regulator (NNR) for a licence to build and operate a transient interim storage facility (TISF) at Koeberg to store high-level waste, the most dangerous form of radioactive material.
This application was made despite the minister for energy promising in his budget speech in the same month that he had asked the NRWDI “to embark on the establishment and operationalisation of an off-site above-ground centralised interim storage facility (CISF) for spent nuclear fuel”.
It is quite clear that this instruction is yet another example of pie-in-the-sky thinking. Eskom would clearly not be applying to the NNR to build its own facility at Koeberg if it thought the NRWDI had any hope of complying with the minister’s instruction within any meaningful timeframe.
The plan to build a TISF at Koeberg dates to at least 2011, when Eskom was granted permission to do so by the then minister for energy, Dipuo Peters, in terms of the Nuclear Energy Act. The process accelerated from that point with SRK Consulting completing an Environmental Impact Assessment (EIA) on the TISF for Eskom in 2016.
The EIA confirms that Eskom had no expectation that the NRWDI would meet its mandate, stating that Eskom was building the TISF “because of uncertainty regarding the development of the CISF”. It continues by noting that because of this uncertainty “it has become imperative for Eskom to investigate interim options for the storage of used fuel”.
The process was urgent because Eskom was running out of space to store spent fuel. The EIA notes that Eskom expected to run out of space in September 2018. The situation was so desperate that a senior manager at Eskom told a meeting with the Department of Environmental Affairs in late 2015 that if new space was not found, Koeberg faced being shut down. To avoid this, between 2015 and the end of 2019, Eskom purchased 14 additional spent-fuel casks to enable it to operate until 2025.
In another obvious sign that Eskom does not expect the NRWDI to complete the CISF by 2025, the EIA states “that used-fuel assemblies generated beyond 2025” will be stored at the TISF (clearly also noting Eskom’s intention to extend the life of Koeberg after 2025).
It notes that Eskom intends purchasing between 30 and 40 new casks to accommodate the waste generated during the additional 20 years of operation. The proposed TISF can store up to 160 fuel assemblies. The EIA notes it is being built in “modular fashion”, which seems to indicate that Eskom has at least considered the likelihood of having to store more than 160 casks on the site. As Eskom frankly states in its Radioactive Waste Management Plan for Koeberg, “until NRWDI accepts the used fuel, Koeberg is responsible for storing the used fuel”.
Environmental authorisation for the TISF was granted by the Department of Environmental Affairs in May 2017. And it was expected that the TISF would be completed by the end of 2019. The authorisation was amended, however, in October 2018 to accommodate the interim storage of six steam generators, which are being replaced at Koeberg as part of the plan to extend its life to 2045.
These steam generators, which will be dangerously radioactive, will be stored in a “concrete mausoleum building” on the TSIF site for up to three years before being transported to Vaalputs for disposal. It is not clear what Eskom had planned to do with these steam generators before this approved change in authorisation.
To date, the NNR has not yet issued Eskom with a licence to operate a TISF for high-level waste at Koeberg, nor has it issued a licence to store the steam generators at any TISF that gets licenced by the NNR at Koeberg. Given the urgent requirement that such a facility exists, it is certain that Eskom will receive the required licences from the NNR. If it does not receive approval from the NNR, then Koeberg would have to shut down, something the government is clearly not willing to allow.
Keeping waste at nuclear facilities
While we should be deeply concerned about the early dysfunction within the NRWDI and what appears to be its deliberate underfunding to forestall the principle of the polluter paying, there are other very serious ramifications that must be highlighted.
First, there are critical questions of safety. The most significant lesson learned from the Fukushima nuclear disaster of 2011 was that spent nuclear fuel should not, where possible, be kept in the same place as nuclear reactors. This is because the fuel is at risk of being exposed to the atmosphere if a serious accident occurs at a reactor.
As Vanessa Maree from the NNR and Alan Carolissen from the NRWDI noted in an academic article in 2017, the amount of spent nuclear fuel kept on site at nuclear power stations should be kept to an absolute minimum, and any on-site storage that takes place “should only be for cooling purposes”. Basically, the NNR is saying that high-level waste in the form of spent fuel in casks should not be kept on site because it is a potential safety hazard, which is exactly what Eskom is applying to the NNR to do at Koeberg because there is nowhere else to put it in the absence of the CISF. On its current website, the NRWDI notes that Eskom “urgently needs” an CISF to mitigate against “potential storage risks related to spent fuel accumulation and inadvertencies that could occur in future on the Koeberg site”.
In 2006, South Africa became a signatory to the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management of the International Atomic Energy Agency (IAEA). This joint convention was established “to achieve and maintain a high level of safety worldwide in spent fuel and radioactive waste”.
Every three years the South African government is obliged to report on progress it is making towards meeting the joint convention’s goals. In its three reports so far, the South African government has recognised that storing spent fuel at Koeberg is “not sustainable”.
Another safety problem relates to corrosion. The casks will be placed on an unenclosed concrete pad at the Koeberg site, meaning they will be exposed to the elements, including salt coming from the Atlantic Ocean. Corrosion has already been a problem at Koeberg. In 2001, cracks caused by corrosion were found in the fuel pools, which were blamed on “exposure to the marine atmosphere”. The plant was shut down in 2010 due to corrosion in its cooling system. It is no wonder then that in 2016, Dave Nicholls, then the chief nuclear manager at Eskom, stated that offsite storage at a CISF was a “far better option” than storing waste on site because of the “high levels of corrosion” experienced at Koeberg.
The obvious solution to the problem of corrosion is to place the spent-fuel casks in a building at Koeberg as would most likely happen at a CISF. Eskom has made it clear, however, that it will not be building such a structure “because it cannot afford [it] at present” and does not have permission from the NNR to do so.
Separating the generation and disposal of waste
This issue speaks to another serious problem with the storage of high-level waste in South Africa. It is best practice to separate the institution that generates waste from the institution responsible for its management and ultimate disposal. This is one of the core principles pursued by the IAEA and its joint convention. Article 20 of the joint convention states that signatories must take “appropriate steps to ensure the effective independence of the regulatory functions from other functions where organisations are involved in both spent fuel or radioactive waste management and in their regulation”.
This provision exists to ensure that no conflicts of interest arise within an entity that both creates and manages waste. As the Department of Energy informed Parliament in 2008, international best practice is to separate responsibility as “generators of radioactive waste should not be entrusted with the duty of also managing waste disposal”.
The need to separate responsibilities largely explains the NRDWI being set up in 2008. The institute is supposed to take responsibility away from Eskom and the Nuclear Energy Corporation of South Africa (NECSA) within the context of the polluter-pays principle. As the NRWDI is not operational, the NECSA continues to run the Vaalputs facility, despite it not being in its mandate to do so, and despite generating its own waste, while Eskom manages waste at Koeberg. The kind of problems this situation creates has already been revealed with Eskom’s assertion that it will not build a structure over the casks to be stored at the TISF, despite the issue of corrosion. It should not be up to Eskom to make this decision. Rather, it should be an independent, fully-funded and properly capacitated institution such as the NRWDI that decides how waste should be stored.
The government’s failure to start the NRWDI also raises serious questions about its commitment to the IAEA and the joint convention. In its reporting to the IAEA, the government has consistently asserted that the NRDWI is responsible for waste management in South Africa and that it is fully funded on a polluter-pays principle. In its 2014 and 2017 reports, the government stated that the NRWDI “is responsible for the management and disposal of radioactive waste on a national basis”. In the same reports it asserted that the NRWDI is funded on a cost-recovery basis via the polluter-pays principle.
As we have seen, neither of these assertions are true. The NRWDI is not managing waste in South Africa, the NECSA or Eskom do, and a radioactive waste management fund does not yet exist. In addition, the 2017 report to the IAEA boldly states that a CISF will be operational by 2025 even though by 2017 it was abundantly clear that a CISF would not be built by that date.
Another problem with the decision to construct a TISF at Koeberg relates to whether doing so will become the de facto storage solution for spent fuel from both Koeberg and any additional nuclear reactor that may be built in coming years. There is a danger that a CISF will never be built because of the existence of the TISF at Koeberg. That the proposed TISF can accommodate at least 160 casks is worrying – it suggests that used fuel produced from any new nuclear build may end up at Koeberg.
Temporary solutions becoming permanent
This particular issue has emerged in the United States. In the early 1970s, the US Atomic Energy Commission (AEC) proposed constructing several TISFs on existing nuclear power station sites. The AEC was forced to abandon this idea, however, in the face of fierce criticism from the Federal Environmental Protection Agency, which argued that such sites ran the serious risk of becoming permanent disposal facilities.
The failure to set up a CISF also has serious consequences at Pelindaba, South Africa’s nuclear research centre run by the NECSA. Originally the site that developed apartheid-era nuclear bombs, it is now mostly used to produce medical radioisotopes. In the process, its Safari-1 reactor produces high-level waste. This waste is housed in an “interim pipe storage facility” at Pelindaba. At this facility, the waste is stored in pipes placed in boreholes underground. The NECSA is currently applying to extend this facility as it is full and has warned that if the facility is not extended, the reactor will need to be shut down.
The EIA report for this extension notes that the “store is an interim facility, and the intention is to retrieve and remove the waste in the future”. This brief account of the situation at Pelindaba exactly mirrors the problems at Koeberg. In both instances high-level waste is stored on site against best practice because a CISF does not exist, and in both cases the producer of the high-level waste is tasked with managing it, in contravention of the joint convention.