Why the Thyspunt Impact Assessment is flawed

By Trudi Malan

THE decision to use nuclear or not is a national decision and should be engaged with on a national level.

I am more concerned with the environmental impact assessment (EIA) process for Nuclear 1.

This process in itself has been fraught with mismanagement and misrepresentations. The environmental consultant for the project is Arcus Gibb – apparently now known as Gibb.

I can entertain you for hours with the mistakes and missing pages, figures and tables that we were presented with in the first draft, but that is water under the bridge.

A better edited draft with fewer inaccuracies was presented to us as the second draft of the EIA. We had to submit our comments in August 2011.

Due to a variety of reasons provided by the environmental practitioner and Eskom, the process went into a holding pattern.

We received very little information or updates from the consultants. Release dates for the next draft were promised, but passed by like the “Days of our Lives”. The last formal communication from the Arcus Gibb about the release of the next draft stated that it would be released in February 2015.

Nothing was released in February and then suddenly in September 2015 the third draft was released. (Arcus Gibb refers to the document as the second version of the draft environmental impact assessment).

The release of the document at the end of the year created countless problems for us as a large number of the specialists willing to assist with the review of the various studies are understandably fairly busy at this time of the year.

In spite of several requests via our lawyers (Cullinan & Associates), we have not been granted a fair extension. But be that as it may – we submitted what we could on December 10.

It very quickly becomes clear that there is bias from the consultant in favouring the development at Thyspunt.

Thyspunt is a green field site and was deemed not viable for the development of the Pebble Bed Modular Reactor (by the same consultants, strangely enough) because of the lack of access roads, infrastructure, power lines, etc.

The infrastructure of Kouga cannot keep up with existing demand - a Humansdorp sewage spill
The infrastructure of Kouga cannot keep up with existing demand – a Humansdorp sewage spill

Will development in Kougas be sustainable?

Dr Kelvin Kemm’s contention that it will lead to development in the area does have some element of truth. Of course development will happen. But will this development be sustainable?

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The Kouga Municipality is not a poster child for good governance and service delivery. At present we have a backlog of 10 000 people on the housing list.

The provincial Department of Environmental Affairs (DEA) has issued negative records of decision for several housing applications due to the lack of services in the area.

Sewerage, water, electricity, hospitals, schools and clinics are all in very short supply and completely over-subscribed.

If we consider the massive social impacts that occurred at Lephalale during the Medupi construction, even Eskom admits that it is better to develop close to areas where structures are already in place.


One of the flaws in the Impact Assessment:

On page 9-49 of the Main Report under 9.7.1 – Air Quality & Climate:

a) Land Use and Topography

“The absence of any industrial activities in the vicinity of Thyspunt results in very low current air pollution levels. Cape St Francis is located 13 km east of the site, and Humansdorp, which is relatively more industrialised, is located approximately 18 km north of the site.

However, the prevailing winds, i.e. easterly and westerly, offer little opportunity to carry air pollution from Humansdorp to the site.”

On the same page 9-49

b) Meteorology

“Wind Field: From the historical dataset produced by Eskom (1987), it is clear that the most dominant wind direction in this region is from the west northwest to northwest.”

To read more, visit Fin 24

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