Appendix B - Plan of Study Checklist May 08 - PBMR

APPENDIX B:
CHECKLIST OF COMPLIANCE WITH REQUIREMENTS FOR THE PLAN OF STUDY FOR EIA FOR THE PROPOSED PEBBLE BED MODULAR REACTOR
ENVIRONMENTAL IMPACT ASSESSMENT
This checklist has been compiled to assist in ensuring that all requirements for the Plan of Study for EIA have been addressed. The categorisation and source of the requirements is provided in
the table below.
Category No. Category Source of Requirement
1 Legal requirements – Environment Conservation Act 1 • Regulation 7 of Government Notice R.1183 (as amended), promulgated in terms of sections 26 and 28 of the
Environment Conservation Act, 1989 (Act 73 of 1989)
2 DEAT specific requirements • Department of Environmental Affairs and Tourism (DEAT) response (April 2006) to the Final Scoping Report and
Plan of Study for EIA
3 Legal requirements – National Environmental Management Act 2 • Regulation 29 of Government Notice R.385, promulgated in terms of section 24 of the National Environmental
Management Act, 1998 (Act 107 of 1998)
4 DEAT specific requirements • Department of Environmental Affairs and Tourism (DEAT) response (March 2008) to the Draft Plan of Study for EIA
(dated 18 July 2007)
5 Guideline requirements 3 • DEAT ECA guideline
• DEADP Guidelines on Specialist Studies
• NEMA EIA Regulations Guideline Series
1
The EIA regulations promulgated under the Environment Conservation Act are applicable to the application.
2
The EIA regulations promulgated under the National Environmental Management Act are not applicable to this application. Reference to compliance with these regulations is provided in order to demonstrate that
these requirements have been considered in the compilation of the Plan of Study for EIA.
3
These requirements are not detailed within the checklist. The Plan of Study for EIA however makes reference to the various guidelines and indicates compliance therewith in the relevant sections of the document.

Requirement
Number
Requirement
Section/s of this Report Where Requirement has Been
Addressed
1. Legal Requirements – Environment Conservation Act
1.1 A description of the environmental issues identified during scoping that may require further investigation and Section 4
assessment
1.2 A description of the feasible alternatives identified during scoping that may be further investigated Section 3.5 and Section 5.5.1
1.3 An indication of additional information required to determine the potential impacts of the proposed activity on the Section 6
environment
1.4 A description of the proposed method of identifying these impacts Section 5.2
1.5 A description of the proposed method of assessing the significance of these impacts Section 5.2
2. DEAT Specific Requirements – April 2006
2.1 Comments received from IAPs after the submission of the FSR to the authorities, as well as the comments from the Section 3.4
various authorities on the FSR, should be included in the revised FSR and carried into the POS for EIA
2.2 The views of those national departments with an interest in, affected by, or responsible for, the proposed project should Section 4
be obtained and reflected in the revised FSR and carried into the POS for EIA
2.3 Issues need to be clearly and consistently described to allow tracking through the Scoping report and the plan of study Section 4
for EIA to the EIR. The DEAT recommends that the issues are grouped into logical themes with ‘signature words’ (eg
‘health’, ‘economics’) that are used consistently throughout the EIA documentation. The use of simple coding could
assist in the tracking of issues
2.4 Issues that were raised in the 302MW(t) EIA and are relevant to the current EIA process should be included in the Section 4

evised FSR, noting them as such. Any issues not covered in the Final FSR must be carried through into the POS for
EIA
2.5 Issues raised by IAPs must be used to provide focused questions to which answers are required as the basis for Section 4.2 and Section 6
drawing up sound Terms of Reference for specialist studies in the EIA phase, to be included in the POS for EIA.
Issues that are to be addressed in the EIA phase should be clearly assigned to specific specialist studies
2.6 Clear Terms of Reference for the various studies needed in the EIA phase should be provided for comment by the Section 5.2 and Section 6
authorities prior to proceeding with this phase, as part of the revised POS for EIA. The TOR should set the time and
spatial boundaries for the study, provide a clear protocol and criteria for assessing potential impacts and evaluating
their significance, and should specify the format and timing of deliverables. (The Integrated Environmental
Management Information Series and the Western Cape Department of Environmental Affairs and Development
Planning Guidelines for Determining the Scope of Specialist Guidelines provide useful references in this respect.) The
TOR for each specialist should capture explicit questions that require focused answers from that specialist, to ensure
that the scope of work is clearly defined and that information gathering, assessment and evaluation is of direct
relevance
3. Legal requirements – National Environmental Management Act
3.1 A description of the tasks that will be undertaken as part of the environmental impact assessment process, including Section 5 and Section 6
any specialist reports or specialised processes, and the manner in which such tasks will be undertaken
3.2 An indication of the stages at which the competent authority will be consulted Section 5.5
3.3 A description of the proposed method of assessing the environmental issues and alternatives, including the option of Section 5.2 and Section 5.3
not proceeding with the activity
3.4 Particulars of the public participation process that will be conducted during the environmental impact assessment
process
Section 5.4

3.5 Any specific information required by the competent authority See sections below in response to requirements 11 to 16
4. DEAT Specific Requirements – March 2008
1 Provision should be made for both the Department of Public Enterprises and the Department of Trade and Industry to Section 5.6.6
have input into the POS, to ensure that their issues or concerns are carried through to the EIA.
2 You are requested to carry out a thorough check of all potentially significant issues raised during scoping to give Section 4
assurance that they are incorporated in the POS. Where issues are not incorporated, an explanation for their exclusion
should be supplied.
3 The EIA should explain the relationship between the various institutions and shareholders that have a stake in the This will be provided within the EIA Report
PBMR company.
4 The EIA should explicitly address the fate of financial investment in the PMBR DPP in terms of future economic Section 6.4.12
pathways (i.e. potential costs and benefits to the country).
5 The EIR should include a ‘scene-setting’ chapter which describes the strategic context and the opportunities, Section 4.3
constraints and risks that this context might pose to the PBMR DPP as a point of departure for the EIA. These strategic
issues should both inform, and provide a benchmark against which, project level impacts are evaluated.
6 The EIA should provide a clear and easily understood rationale for increasing the size and changing the configuration Section 2.3
of the proposed PBMR DPP.
7 The EIA should give an explanation of the components of the proposed technology that have been tested and those Section 2.3 and Section 2.4
that have not been tested so as to differentiate between untried and new aspects of the proposed PBMR DPP project.
8 The POS should paint a clear picture of how specialist studies are to be integrated by the environmental consultant, Section 6.5
and how an overall assessment of the project will be presented.
9 The environmental consultant should appoint specialist peer reviewers to review potentially contentious specialist Section 6.6
studies prior to their inclusion in the EIR.
10 The EIA should include:

• An explicit description of ‘the study area’ and its boundaries;
• A description of the decision-making framework and different authorisations/permits, and of how decisionmaking
will be synchronised to expedite the authorisation process; and
• Consideration of recent draft policy and legislation.
11 The proposed impact assessment methodology should be revised to:
• Relate significance ratings to accepted societal norms, standards, legal requirements, plans and other
yardsticks;
• Minimise reducing multiple variables by ending the conflation with ‘consequence’ ratings;
• Address cumulative effects separately;
• Identify permanent impacts; and
• Include assurance of mitigation in the evaluation of residual significance of impacts.
12 Specific provision should be made for focus group meetings with the Legal Resources Centre/Earthlife Africa and
Ministry of Health (Western Cape).
13 Should the EIA use potentially controversial specialists, peer reviewers with international creditability should be
appointed to ensure balance in professional judgement.
14 Separate studies by recognised and well-respected specialists should be commissioned to address social impacts and
economic impacts.
15 The environmental consultant should re-visit the need for the large number of specialist studies in the light of the
potentially significant issues raised during scoping.
16 The general TOR should be amended to include:
• Any legal requirements, norms, standards or other limits of acceptable change applicable to the particular
field of study as a benchmark against which specialists should evaluate significance;
• Background trends and patterns that may be a concern or issue or pose a threat to the proposal and/or
Section 5.2
Section 5.3
Section 2.8
Section 5.4
Section 5.6.6
Section 6.6
Section 6.4.12
Section 6.4
Section 6.3.1 and Section 6.3.2

influence the evaluation of impact significance (e.g. plans to expand urban areas, informal settlement
patterns, epidemiological information, pollution);
• Probable/likely factors informing cumulative impacts, including those associated with the background level of
nuclear activity at the Koeberg site;
• Identification and explicit statement of any impacts on irreplaceable resources, areas of major uncertainty,
gaps in information, low confidence levels; and
• Evaluation by each specialist of potential impacts in terms of the NEMA principles, as of particular relevance
to the specialist’s field of study.
17 The environmental consultant should ensure that the need for all of the specialist studies is justified, and that the TOR
for each specialist is tailored to address the key case- and context-specific issues.
18 The specialist study on air quality should consider:
• Possible cumulative impacts associated with emissions; and
• Possible synergistic effects of the PBMR and KNPS emissions, both radiological and non-radiological, in
normal and upset or emergency conditions.
19 The TOR for the specialist studies on health impact and radiological health and safety (Section 6.3.19) need to be
rationalised in order to avoid duplication in addressing impacts due to radioactive and non-radioactive emissions.
20 The specialist study on visual impact should give a clear visual impression of the size and dimensions of the PBMR
DPP plant in scale comparison with the Koeberg nuclear power station.
21 The specialist economic study should address the following:
• Risks to the South African economy, and probable consequences of, investing in the PBMR DPP;
• The opportunity costs of investing in this particular technology in relation to other technologies; and
• The distributional impacts in terms of potential costs and benefits, and a clear description of parties who
stand to benefit from, or bear the costs of, the PBMR DPP.
Section 6.4
Section 6.4.1
Section 6.3.19
Section 6.4.3
Section 6.4.12

22 The specialist study on meteorology and oceanography needs to include a risk assessment and implications for design
of the PBMR DPP.
23 The TOR for the specialist study on epidemiology should be re-worded to reflect DEAT’s requirements to provide an
epidemiological profile of the population of Cape Town in general and of the ‘critical group’ within the 16km radius of
the Koeberg site, including a baseline study on epidemiological issues related to childhood leukaemia in Cape Town.
24 The specialist study on land use should address the opportunity cost to the City of siting the PBMR at the KNPS site. In
addition, the cumulative impact of using the existing infrastructure and services to support the PBMR DPP should be
addressed.
25 The specialist study on radiological waste management should address:
• The nature of the waste in terms of both its quantity and type;
• Whether or not the waste from the PBMR would be compatible with waste from other nuclear operations at
Koeberg and could be handled in a similar manner;
• Disposal of low, intermediate and high level waste in both the short and very long term;
• The capacity and capability of existing policies and institutions to manage and dispose of waste in both the
short and very long term; and
• The perception amongst IAPs that KPNS is becoming a high level radioactive waste site, and the question as
to whether or not use of the site for this purpose has been approved by the NNR.
26 The specialist study on emergency response should address the respective responsibilities for funding, co-ordinating
and implementing an emergency response for the duration of the PBMR DPP’s life, as well as ensuring that the
required infrastructure and systems are in place and maintained.
27 The specialist study on radiological safety and health should:
• Clearly define key radiological safety and health terms such as ‘incident’ and ‘area of influence’;
• Include a risk assessment of the range of potential radiological ‘incidents’ and accidents, including interaction
Section 6.4.8
Section 6.4.14
Section 6.4.16
Section 6.4.18
Section 6.4.21
Section 6.4.19

with/effects of any ‘incidents’ at the existing KPNS; and
• Be conducted in close collaboration with the social, economic, land use and emergency response studies, in
addition to the epidemiology, air quality and radioactive waste management studies.
28 The specialist study on traffic and transportation should address the impact of increased traffic flow and transportation
on security and emergency preparedness plans.
29 The environmental consultant, in collaboration with specialists, should clearly demonstrate how the proposed project
would be consistent with the NEMA principles.
30 The specialist study on legal review should address the issue of compliance with national legislation relevant to issues
of public accountability and public finances.
31 The environmental consultant should obtain approval from the NNR for dose assessment modelling and risk
calculation, prior to undertaking such modelling as part of the EIA process.
Section 6.4.22
Section 6.3.2
Section 6.4.24
Noted