On the 20th of August, Earthlife Africa Jhb (acting through the Legal Resources Centre) made a submission on the Social Impact Assessment for the Pebble Bed Modular Reactor.
This submission exposes safety, legal, design and economic flaws within the PBMR. For example:
Our clients submitted in their response to the Draft EIAR1, that because the PBMR DPP design is not yet final, and the enhanced safety claims of the PBMR have not yet been proven, it is not yet possible to propose appropriate mitigation measures.-This is borne out by the fact that neither the Safety Report nor the Probabilistic Risk Assessment have been completed nor are available to the public for its input and possible challenge.2-Statements as to the appropriate mitigation measures for the PBMR DPP are premature.3-Our clients argued that the fact that the EIAR cannot at this stage determine or confirm appropriate mitigation measures proposed by the NNR means that authorization at this stage would comply with the legal requirements for EIAR’s.
Statements made in the SIA regarding mitigation measures for likely impacts are likewise based on insufficient information. Since the socio economic impacts of a catastrophic or significant abnormal release of radiation are not and cannot be evaluated at this stage the report is not able to suggest any specific or concrete mitigation measures for such possible events.-Consistent herewith the SIA report makes only vague recommendations on issues such as the availability of hospital capacity and “regional competency”. It also suggests that-“dread risk perception” be managed.
It is submitted that these recommendations constitute insufficient information for the competent authority to make a decision in regard to a hazardous industry that is capable of significant and widespread socio economic impacts.4-Instead, an in depth analysis of the consequences of a worst case scenario nuclear accident should be undertaken with due regard given to current and future mitigation capacity including emergency response capability and availability of medical care.
It is thus submitted that the SIA report recommendation of limited mitigation measures is premature and based on inadequate information.-As such the recommendation is in violation of the PAJA section 6(e)(iii) requirements that all relevant considerations should be placed before the decision maker.-Should the report fail to rectify these deficiencies the authorization will be unlawful.
The entire SIA is available for download (pdf, 208kb) 2009-final-submission-on-pmbr-sia.