PELINDABA WORKING GROUPAGAINST RADIATION

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

2. 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.

3. “Industrial and technological leadership” refers: There is a skills shortage in SA and internationally. Where

will this leadership come from? How can a country without the necessary backup on skills

forge ahead BEFORE sufficient skills pool is created? 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.

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.

4. 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.

5. 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.

6. 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 energyIrregularities 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 and led to low-level radiation, reviving fears 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 certainly did 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 safetyExperts 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 fared worse, 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 problemsNuclear 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 yearsPaulitz 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 hurdleIAEA'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."

 

7. “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.

8. 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.

9. “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.

10. 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:

1. Introduction: The South African government is answerable to the voting public which put it into office. It is therefore, in terms of Constitutional Rights, and in the spirit of democracy, incumbent upon the government to invoke far greater public debate and involvement from civil society before embarking on such a commitment. The recent Energy Summit which aims to rewrite the 1998 White Paper on Energy and the issuance of this document for public comment cannot, under any circumstances be said to represent a thorough investigation of public sentiment or knowledge or information base which, by rights, should contribute to decisions that the government wishes to commit itself to. Furthermore, there is no indication of a “coordinated manner” in which energy development is being framed, other than that determined by the nuclear industry itself.

2. “Upstream and downstream activities” are far from comprehensively understood, researched, legislated, considered or discussed in terms of a broad public awareness and information debate. This nuclear policy considers superficial benefits over a 100 year period when, for example, nuclear reactors have on average a 40-year lifespan, uranium resources are expected to be depleted within a few decades but radioactive waste is expected to be a financial, health and management burden for hundreds of thousands, if not billions of years.

3. “Becoming globally competitive” is certainly a term representing the dreams of those in the nuclear industry rather than concrete facts. To date there have been no indications that South Africa would be able to export its nuclear reactors, and with uranium producing countries globally gearing up to cash in on the current boom in the market, an overall look at where this will leave countries which decide to exploit hazardous substances for short-term gain at extremely long-term risks is foolish. With its know-how and history, South Africa has every resource at hand to shift its innovative technology to clean and clean-up technologies which are in great demand globally, Africa and in this country and, therefore, also exportable.

4. South Africa does NOT have a “track record of safe nuclear power plant operation and maintenance”. Information in the public domain would indicate the assertions of safety by our nuclear industry are devoid of full disclosure. It is therefore recommended that a Commission of Inquiry be established to fully examine the real track record before this policy is, if ever, enforced.

5. Global Warming refers: A growing number of scientific and academic reports in the global arena indicate that the full fuel cycle of nuclear energy is NOT a solution to global warming and climate change and could even be worse than coal. It is recommended that this claim be

fully investigated at a nuclear summit in order for this government to determine for itself the real facts based on in-depth studies and research before accepting this assertion from the nuclear industry.

6. Government policy on prospecting, mining and beneficiation of uranium ore & the Minerals and Petroleum Resource Development Act (MPRDA) is currently highly contentious and hotly disputed. One of the main reasons for this is that these issues have not been put up for public debate. Indeed, democratic principles are being by-passed in order for the “uranium rush” and a fast-tracked nuclear plan to be implemented. An entire re-evaluation of how government should proceed on these issues would be best served by a nuclear summit in which all stakeholders can debate a strategy which is acceptable to the people of South Africa and not merely a handful of officials.

7. The National Nuclear Regulator is rejected as an authoritative or unbiased regulator. It has failed in its legislated mandate to protect people and the environment and has served only the nuclear sector itself. A thorough inquiry into the NNR is necessary in order to determine how best to restructure or strengthen the NNR in order that it heeds it’s mandate and provides civil society with mechanisms that will engender trust in the NNR. Moreover, information in the public domain indicates that the level of competency in the NNR is severely compromised. A number of its expert personnel have resigned, and for sometime the Regulator has been hopelessly understaffed, lacking in sufficient expertise, thoroughly lacking in transparency and accountability, and thoroughly co-opted by the nuclear sector.

Moreover, the inability of the NNR and its predecessor the Council on Nuclear Safety (CNS) to have acted timeously and appropriately to address the fatal contamination of radioactive and chemical substances from over 120 years of mining into the Wonderfonteinspruit Water Catchment on the West Rand, should be enough evidence that the NNR is unwilling and incapable of exercising its mandate. Already evidence of the forever-DNA-altered or genetically deformed children from the area is emerging. This is a national scandal and should be addressed at the highest level before any further nuclear development is considered in this country. Additionally, the NNR is also aware of the 2002 State of the Environment Report for the North West Province which indicates there are at least 5 other mining areas where the drinking water of communities has been contaminated by radioactivity yet, to date, the NNR has failed to force any rehabilitative action.

Additionally, information in the public domain that has been covered up by the nuclear sector and the Regulator of the mass radioactive contamination of the Crocodile River should form the basis of a Commission of Inquiry under public scrutiny. This resulted in the mass deaths of fish and birds which have been recorded by Fauna and Flora. Furthermore, it is understood that genetically deformed reptiles, mammals and fish have been discovered in this area but the nuclear sector has

covered-up the existence of these. Water from this river is the livelihood of hundreds of thousands of people and has entered the food-chain.

While the NNR and the CNS, has in various annual reports, indicated the extent to which nuclear workers and miners have been over-exposed to radiation, the Nuclear Energy Corporation of SA has denied this to Parliament, and the NNR has done nothing to ensure the “protection of people” as per its mandate.

Below is an excerpt from a submission made to the Portfolio Committee of Environment and Tourism public hearings on nuclear energy in June 2007:

Uranium is extremely dangerous to all forms of life. It is often called “The Silent Slow Genocide”. We are about to witness much of this country potentially being mined for it.

In the North West Province alone, the Province’s 2002 “State of the Environment” report states that “There is a growing body of evidence pointing that both the long- and short-term effects of radioactive substances present in the environment may be impacting on the health of the population of the North West Province, particularly in the gold mining areas. Communities that are not currently supplied with safe, treated water and which rely on radionuclide-contaminated surface or ground water resources for their potable water are the most vulnerable to such health risks.

Elevated levels of uranium have been found in the following areas of North West Province:

Koekemoerspruit, which drains parts of the Klerksdorp area (near Stilfontein);

Kroomdraaispruit, near the abandoned New Machavie Goldmine, before its confluence with the Koekemoerspruit;

Wonderfonteinspruit below Carltonville (draining the Far West Rand goldfields);

Mooi River after its confluence with the Wonderfonteinspruit/Mooiriverloop;

Vaal River, where it flows past the Klerksdorp mining area (between the Mooi River mouth and Orkney); and Pilanesberg.

Around 1999 the Council for Nuclear Safety (CNS) estimated that at least 10,000 mineworkers, or roughly one in 20 mineworkers, had, at that time, been exposed to radiation levels that exceeded safety limits. In 1998, according to CNS estimates, 1 000 employees at Harmony Gold mine alone were exposed to radiation levels that in some instances were three times higher than the annual dose limit of 20 mSv a year. At Nigel, workers were exposed to dose levels of up to 130 mSv a year, or seven times higher than the allowable limit. (Business Report Oct. 7, 1999).

In February this year during the NNR submission of its annual budget, its CEO Mr. Magumela stated that in 2002, 7,931 people had been exposed to unacceptably high doses, but this number had declined year by year to 1133, 424, and 8. He said there had been an improvement over the last five

years but failed to mention this was as a result of a largely stagnant uranium mining industry at the time.

Health and Safety Regulations are still being formulated and appear not to have involved significant public participation. It is assumed that such regulations, which are of paramount importance to any Regulator dedicated to protect people and the environment, would in the first instance ensure that all views are discussed before these regulations are drafted, and secondly, that such regulations are promulgated as a matter of urgency. Yet our Regulator appears not to have done this.

That the NNR falls under and is answerable to the DME is in the first instance a conflict of interests which must be resolved.

8. The NNR’s “set radiation standards” refers:The basis and guidelines for these safety standards are highly questionable, and indeed the subject of much international debate. While the NNR subscribes to the ALARA (As Low as Reasonably Achievable) principles worldwide research is favouring the “precautionary principle” based on the studied view that “no dose is a safe dose”. It is for this, among other reasons that at least seven European nations have in the recent past voted to phase out nuclear energy in their countries. To chose to remain ignorant or unwilling to enforce the precautionary principle to its fullest potential, is an unwillingness to uphold basic human rights. In addition, while the NNR enforces the ALARA principle, environmental laws such as NEMA apply the precautionary principle. Our laws are therefore at variance with once another. It is highly regrettable, that because of the fast-tracking of the nuclear policy – even before it is finalised – that the NEMA laws are being eroded through various amendments and rendered toothless in the protection of people and the environment so that the nuclear plan can be foisted on this country.

9. The statement that “the use of nuclear energy is increasingly being recognised worldwide as one of the strategies to mitigate greenhouse gas emissions and global warming, since it is an important carbon-free source of power” is ABSOLUTELY DEVOID OF THE TRUTH. Quite the reverse is true. More countries are now phasing out nuclear power, evidence is that nuclear fuel cycles emit a significant amount of CO2 and CFC gases associated with global warming. We urge the South African government to assess learned studies on this issue at a nuclear summit before assuming such statements to be true. The DME would be best served and informed by a nuclear summit in which the truth of these statements can be adequately challenged.

10. South Africa’s uranium reserves are not as “sizeable” as the

nuclear industry would have us believe. Indeed, the ore-grade in South Africa is of a poor quality which will necessitate the re-processing and various processes which are, in the first place, exceptionally energy intensive themselves, secondly, extremely expensive, and thirdly, are

likely to produce material much sought after by world terrorists for the manufacture of nuclear weapons. Research furthermore indicates that uranium is a finite resource which can supply the nuclear industry only for a few more decades.

We urge this government to assess the reasons why numerous other countries in the world have placed a ban on the mining of uranium in their territories before it considers uranium as a “primary energy source”. Solar, surely, must be a primary energy source – and is freely available throughout this country.

11. Nuclear energy is far from being economically viable or “the only” economically viable alternative to coal as base load generation on a large scale. Please refer to the recent reports by the IEER.

12. South Africa’s mining industry refers: While the South African economy has always been based on its mining industry, this industry’s transgressions over human rights, the environment is only now becoming evident. The “vibrancy” of the industry has ignored the “polluter-pays-principle” and made huge profits at the expense of people and the places where they live. If the mining industry is to carefully consider practises that adequately protect people, its workers and the environment, a true meaning will be given to the work vibrancy!

13. “The extraction of uranium ore does not present any major challenges” refers:This traditional viewpoint ignores the research on Wonderfonteinspruit and the 2002 NW State of the Environment Report plus how many other still not examined or investigated. Cover-ups on the radioactive contamination of Crocodile River and communities living near nuclear installations, etc

14. Uranium beneficiation is the new buzz word for uranium

enrichment – an industry closed with great pride for all the right reasons with the establishment of our new democracy. This industry is traditionally shrouded in secrecy, places a severe burden on environmental safety and therefore human rights, and represents step 1 to the proliferation of nuclear weapons or terrorism. Moreover, uranium enrichment is extremely energy intensive which defeats the stated purpose of this nuclear policy.

15. “Solid regulatory framework” refers: this is what the nuclear industry would have the government believe but the reverse is true. There is no framework in this country which is transparent, accountable or fulfils its mandate to protect people and their environments.

16. “Non-proliferation policy” refers: Already reports indicate the Intelligence Minister has invited briefings on South Africa’s nuclear weapons capability. SA recently refused to sign the Global Nuclear Energy Partnership’s (GNEP) which would provide the South African public with further assurances of this country’s commitment to non-proliferation.

However, there is no guarantee that this policy will continue in the short or long term.

17. International Situation / human development. Sustainability is a poverty issue. Alleviation of poverty is not fostered where safety and health standards fail people and are regulated by an exclusive few, where jobs go to international experts, where energy costs rise to justify expensive technology, where carcinogens and DNA-altering waste products result. The importance of the recent statements by the honourable Minister Tasneem Essop on the relationship between poverty issues and renewable energy initiatives cannot be underestimated. Nuclear energy WILL NOT adequately address any poverty issues.

Renewable Energy & Climate Change Summit

Minister Tasneem Essop of the Department of Environmental Affairs and Development Planning hosted a Renewable Energy and Climate Change Summit on 7 and 8 June in Cape Town. The Summit was during World Environment Week.

The Department would like to share with you the renewable energy and climate change initiatives being pursued in the Western Cape. Studies suggest that this province is highly vulnerable to the impacts of climate change with significant implications for major sectors of the economy, highlighting poverty as a key issue.

Energy security plays a vital role in ensuring that the province can meet its sustainable development objectives, and that it remains an attractive destination for investment. Recent electricity outages have created a window of opportunity to explore alternative energy sources.

The provincial government of the Western Cape has set a target of 15% of energy production from renewable sources by 2014.

18. The “resurgence” of nuclear is a misnomer. Only a few countries, representing a few companies globally have created this myth. The Earthlife Africa press release below explains:

Earthlife Africa Cape TownTel/Fax: 27 21 447 4912

Email: coordinator@earthlife-ct.org.zaadmin@earthlife-ct.org.za

 

14 August 2007

PRESS RELEASE: DEPARTMENT OF MINERALS AND ENERGY NUCLEAR POLICY IGNORES PARLIAMENTARY DIRECTIVE  

The release of a draft Nuclear Energy Policy appears to confirm that The Department of Minerals and Energy operates in ignorance of its own parliamentary directive. The 1998 White Paper on Energy states "Government will ensure that decisions to construct new nuclear power stations are taken within the context of an integrated energy policy planning process with due consideration given to all relevant legislation, and the process subject to structured participation and consultation with all stakeholders." As far as Earthlife Africa Cape Town is aware, such processes have not taken place and yet Cabinet sees fit to leapfrog such requirements, pushing ahead relentlessly with its misguided nuclear energy agenda. In stating that it hopes to finalise the policy by the end of the year the Department hammers the final nail in the coffin of its commitment to public participation and accountability.

Director of nuclear energy Tseliso Maqubela and colleagues of his from various departments speak frequently and with great conviction about the global resurgence in nuclear energy and yet fail to ever site a single example. A recent report, prepared for Greenpeace International, The Economics of Nuclear Energy, highlights some interesting facts in this regard. Currently, there are only 22 reactors under construction in the world. Construction on five of these began over 20 years ago. Of the remaining 20, construction of 14 is currently suspended. In India, the country with the most recent and current construction experience, completion costs of the last 10 reactors have averaged at least 300% over budget. The average construction time for nuclear plants has increased from 66 months in the mid 1970's to 116 months (nearly 10 years) for completions between 1995 and 2000.

The costs of South Africa's own nuclear white elephant, the Pebble Bed Modular Reactor, have escalated from R2 billion in 1999 to R16 billion at last count, without construction even having begun. In 1999, it was expected that the project would be commercialised by 2007 but in 2006 the most hopeful scenario predicted commercialisation in 2015.

Earthlife Africa Cape Town attended two separate meetings with stakeholders in the nuclear energy sector on 13 August 2007. These community representatives and government officials were clear about the very extensive range and depth of concerns they have about the rolling out of nuclear energy in South Africa. It is perhaps time for energy policy in South Africa to be decided upon, not by the Cabinet, but by its citizens.

Maya AbermanCampaign Co-ordinatorEarthlife Africa021 447 4912076 754 6327

19. Climate change: Numerous reports have addressed this false claim by the nuclear industry. Various South African NGOs have written reports, conducted research and issued statements. It is therefore of paramount importance that the government hold a nuclear summit where

this issue can be discussed at length before propagating this misleading assertion. This submission is accompanied by the recent study released internationally by the Institute for Energy and Environmental Research (IEER) which fully considers this myth and provides solution for a “Carbon Free and Nuclear Free” future for the U.S. which should be considered for application in South Africa.

20. If Necsa is to “store” all uranium supplies as well as locally enriched uranium, a full assessment of what the implications of this are must be assessed. The overall plan MUST be publicly disclosed and open for public and environmental scrutiny.

21. Government’s aim to “monitor” the nuclear energy sector is welcome but MUST involve transparent mechanisms which involve civil society.

22. Government’s aim to “promote” and “support” the nuclear energy sector MUST involve informed public debate, not one-sided propaganda from the nuclear industry. A nuclear summit is a good starting place. It is feared this support will, in essence, only render government a bottomless pit for funding.

23. An intrinsic flaw in the policy relates to the Minister of Minerals and Energy being responsible for governance of the nuclear industry and related matters. Both the Environment Minister and the Health Minister should be equally responsible for monitoring and setting standards. NEMA – as it was originally intended – should override all legislation in terms of governance. Additionally, sound financial practises must be employed and it would be expected that the Department of Finance, together with Public Enterprises and Trade and Industry, consider a wide forum for scrutinising the economic implications of the nuclear strategy which involves civil society and experts commissioned by civil society.

24. Is the implication in this document that Foreign Affairs has been stripped of the responsibility to “regulate matters regarding nuclear non-proliferation”?

25. The White Paper did not recommend nuclear. The comments attributed to the White Paper in this document are misleading. Other sections of this document address issues concerning the 1998 White Paper on Energy.

COMMENTS ON POLICY PRINCIPLES FOR NUCLEAR ENERGY USE IN SA (SECTION 7)

P1 This policy must be rejected in favour of renewable alternatives such as solar, wind, hydro, etc.

P2 Technology development in South Africa must contribute to economic growth through investment, job creation and worker skills development in the fields of renewable alternative energy, clean technologies and clean up technologies.

P3 Nuclear energy must NOT form part of SA’s strategy because it DOES NOT mitigate climate change and global warming.

P4 No environmental impact from the nuclear sector must be permitted at all and a precautionary principle must be applied to its fullest with the involvement of mechanisms that enable civil society to monitor such.

P5 International “best practice” must be determined after the nuclear sector and civil society have established what these are at a nuclear summit.

P6 Nuclear energy is open to abuse and ultimately can be used to produce nuclear weapons therefore should NEVER be considered as an option in South Africa.

P7 Statements such as these are meaningless. Refer P4.

P8 Uranium mining should be suspended forthwith and banned forevermore in this country. Additionally areas where uranium has been mined must immediately be rehabilitated and decontaminated.

P9 Transparent accountable proof of all nuclear infrastructures must be ensured.

P10 All technology know-how and skills for South Africa must be geared towards clean technologies and clean-up technologies.

P11 “Appropriate safeguards and security measures” are only applicable if these involve a thoroughly transparent and accountable approach and involve mechanisms for public monitoring of such.

P12 Government must distance itself from global nuclear energy clubs and foster relationships with those global programmes which promote clean technologies.

P14 Any program to stimulate public awareness must be balanced, informative and provide equal amounts of information from both sides of the nuclear debate so that the SA public can determine for itself which option is preferable. Any such program must include a consensus arrangement with opponents of nuclear industry to provide equal amounts of information to the public debate and ensure that the national media cooperate in fairness with this arrangement.

P15 All government funding aimed at energy creation sectors must be determined and agreed upon democratically by all stakeholders, including civil

society at appropriate forums to ensure transparency, accountability and that the SA taxpayer and consumer is consulted and not left carrying the bill.

8.1 Government’s Responsibilities as in Section 8:All stakeholders including civil society must be consulted in terms of overall policies, legal frameworks, regulatory bodies, governance etc. Therefore a nuclear summit involving all stakeholders including civil society is necessary for these to be determined.

8.2 Regulatory BodiesCivil society must be afforded a role in terms of monitoring the transparency and accountability of all regulatory bodies.

8.3 Operators/InvestorsThere are numerous international players in the nuclear sector who are also involved in South Africa. Some of these companies have a less than desirable record in terms of safety, and abuses of various kinds. Some of this information is already known to civil society. A thorough investigation needs to be completed before decision-makers seek business arrangements with many of these international operators.

9. 10. 11. International & Bilateral Multilateral Cooperation Civil society must be consulted at each level of international frameworks in order to alert decision-makers and the government on factors and influences in the global realm which have a bearing on the nuclear sector. For example, the IAEA’s persistence to ignore human rights issues should be taken into account. All other global bodies which relate to the nuclear sector must be assessed for relevance and what these can bring in terms of safeguards, safety, human rights and insurance/ liabilities issues. These issues all need to be thoroughly investigated in terms of “best” international practice acceptable to civil society. A nuclear summit is the best forum for this.

Section BInstitutional Arrangements in 12First institutional arrangement must be a nuclear summit.

“a single national nuclear safety regulator” must be assessed in light of information above. The structure and form of the national safety regulator should be thoroughly assessed taking into account all information in the public domain in order to best structure the regulation of the nuclear sector with a primary aim of protecting people and the environment. There is no way that a regulator, which falls is answerable to a government department with a vested interest in fostering nuclear energy can be trusted to fulfil its mandate.

“a national security agency” needs to be assessed in terms of public fears and therefore in terms of protection mechanisms and international scrutiny which will go some of the way to allaying public fears. Therefore, significantly more research on the international mechanisms which would provide this needs to be taken into account. This cannot be unilaterally determined by stakeholders with a vested interest.

A special note on the NNR. There cannot be a single national nuclear safety regulator if it falls under DME and is involved in the issuance of licenses. If, in terms of the Act, the regulator is mandated to protect people and the environment, this aspect of its role has and cannot be fulfilled as a license issuer under the DME. It is therefore proposed that the NNR as we know it today, continues to function under the DME but solely as license issuers within the current legislative framework and perimeters, but that it is subjected in every respect, and therefore subordinate to, a regulator under the DEAT which shall be the overriding authority with respect to public and environmental assessments which may, or may not result in the issuance of licenses by the NNR. In other words, the current NNR should possibly be called the National Nuclear Licensing Office to consolidate environmental, design, construction, operations, decommissioning and decontamination process but be under the authority of a people and environmental rights-driven National Nuclear Regulator which reports directly to the Minister of Environment & Tourism, who shall be answerable for any abuses in the structure.

Furthermore, the NEMA should be strengthened to become the single guide on all issues environmental which impact therefore on human rights. Without the strengthening of the Department of Environment, along with other departments which are mandated to act as custodians over the environment, there can be no protection of human rights.

No-where in this document is there any mention of civil society monitoring, involvement. This must be considered an imperative.

12.1 refers: The National Nuclear Energy Executive Coordination Committee must provide for civil society input and membership.

Section 12.3 – the National Nuclear Power Generation Organisation must allow for a far greater degree of de-centralised, locally owned power generation partnerships with local authorities, towns and/or regions, and based on clean technologies such as solar. These decentralised power generators can sell excess power to Eskom’s national grid if need be.

12.5 - National Nuclear Security Agency Such an agency provides speculation for sinister intentions and should possibly be scrapped.

12.7 - The Radioactive Waste Management Agency must be directly answerable to the Environment Minister and involve civil society monitoring of all its activities and policies.

13 Strategic Actions on the Nuclear Fuel Cycle - Full Fuel Cycle – before any further development takes place, existing research by various experts, scientists and institutes globally on the full fuel cycle must be taken into account at a nuclear summit in order to determine whether there is any need to continue with either a nuclear future or local development of full fuel cycles.

13.1 Uranium Mining and Milling 13.2 Uranium Conversion 13.3 Uranium Enrichment - Uranium “conversion”/enrichment should under no circumstances be allowed to re-develop in this country. The limited extent to which uranium enrichment is undertaken currently for use in the medical arena should be the full extent to which the nuclear sector ever revisits this notion.

13.4 Fuel Fabrication & the Pelindaba facilityThe entire Pelindaba complex must be dismantled, decontaminated. Any further nuclear sector activity should be relocated to a destination that is well beyond any urban creep, if it must exist at all.There should be no fuel fabrication plant, but if such is to exist close to the source of the fuel or at the end point.The experimentation and development of the Fuel Manufacturing plant at Pelindaba must be immediately suspended. The final NNR license to permit this work has not even been issued, and the license for the PBMR has been suspended. The prognosis for the PBMR, despite optimism from the nuclear sector, is bleak. It therefore indicates that vast sums of taxpayer funds are being pumped into a potential white elephant.

13.5 Spend nuclear fuel and Radioactive waste managementUnder no circumstances should this government encourage any further creation of spent nuclear fuel through any nuclear programme. What currently exists, and is believed to be over limits at certain sites (Koeberg especially) must be carefully assessed and dealt with in a transparent manner involving civil society input.A thorough commission of inquiry should be established to consider the best means for managing current radioactive waste that’s piled up in this country over the past number of decades.Plans for the nuclear Smelter Plants at Pelindaba must immediately be suspended. The nuclear sector is well aware of alternative methods of dealing with its existing radioactive scrap & waste. This issue is of national importance and should immediately be openly debated and researched. Furthermore, draft legislation on Waste Management has been described as a “problem statement” by the chair of the portfolio committee on Minerals and Energy rather than a workable policy. The seriousness of this statement should be considered to its fullest extent. Solutions to radioactive waste exist nowhere in the world. The only solution is not to create radioactive waste.

13.6 Reprocessing of used (spent) fuel and recycling of fissile materials.There are currently more risks, including energy usage, for reprocessing spent fuel. This should not be considered at all until such time as acceptable processes are found, if ever. It is recommended that the DME first consider all available research and information on Depleted Uranium before any rash decisions are made. A nuclear summit could investigate such information at length.

14. Nuclear Reactor Construction and OperationThese should be suspended immediately. All existing nuclear stations should phased out in favour of renewable alternatives.

15.1 Security of Uranium SupplyAs mentioned, there is doubt that the nuclear sector’s assessment of world or national uranium supply is accurate. All views on this issue require open public discussion for an accurate assessment to be made.

15.2 Security of Energy Supply There is no dispute over the government’s concerns regarding security of energy supply. There are, however, other approaches which exclude a nuclear option for solving both energy supply and carbon emissions problems. The DME is strongly urged to afford civil society and experts in sustainable alternative “clean” technologies a forum in which to provide information on the best way forward.

15.3 Employment

NUM says renewable energy sector offers 'huge' employment potential By: Mariaan OlivierPublished: 27 Sep 07 - 16:58

The National Union of Mineworkers (NUM) has called upon the government to step up efforts to examine the number of employment opportunities that could be generated by a viable renewable energy industry in South Africa.

Speaking after a three-day energy summit in Johannesburg, the NUM’s Fred Gona said that the amount of money being spent on research on nuclear energy far surpassed the funds allocated to the development of renewable energies, such as wind, solar and hydropower.

Gona said that, while the NUM was supporting job creation in the mining industry, it believed that the renewable energy sector had “huge” job creation opportunities.

He added that employment in a renewable energy industry would also bring about fewer occupational hazards, when compared with uranium mining, for example.

The South African government has recently committed itself to building a “new industry” around nuclear power, and proposed that some 10 000 additional jobs could be created by uranium mining and beneficiation.

Job creation would firstly come from uranium mining, but the rest of the nuclear energy value chain was expected to contribute to job creation.

A recent independent study on the employment potential of renewable energy

in South Africa stated that, if 15% of South Africa’s electricity came from renewable resources, 36 400 new direct jobs would be created.

It also showed that about 506 000 direct jobs could be created if a portion of the country’s energy needs were sourced from renewable energy technologies by 2020.

South African Climate Action Network coordinator Richard Worthington added that the country had to liberate its energy sector from minerals if it wanted to commit to tackling climate change.

In the 1998 Energy White paper, which was currently being reviewed, government said that it would provide focused support for the development, demonstration and implementation of renewable energy sources for both small- and large-scale applications. Immediate priorities were biomass applications, passive building design, photovoltaic applications, micro-hydro and wind-based electricity systems, and solar water heating.

15.4 Economic DevelopmentThe figures mentioned in the strategy are highly dubious. An assessment and comparison of all research is necessary before such statements can be made. This is best achieved at a nuclear summit where both sides of the story can be assessed.

15.5 Awareness CreationCivil society NGOs and CBOs, academics, activists and various individuals who are concerned over nuclear power have, for several years, conducted research into the nuclear sector and nuclear related research. This research shows that by and large the nuclear sector itself is misinforming decision-makers. A vast amount of taxpayer-funded propaganda (industry advertising in newspapers, juntas and luncheons for media at Necsa, “consultative meetings” etc) has resulted in diminishing amount of balanced information in the public domain. Indeed, there has yet to be adequate public awareness or public debate over nuclear energy. Any endeavour for public awareness must be conducted in fairness to both sides of the debate so that the public can assess the information before it. Furthermore, where this has occurred in numerous European countries, informed debates have led to referendums where, based on educated opinions, governments have conceded to phase out nuclear energy.

15.6 Human Resource DevelopmentWord on the street is there is already such a lack of competent personnel at Necsa, for example, that pensioners are being recalled at extremely lucrative wages. Many of these pensioners are taking the jobs precisely because they are so disturbed by the lack of maintenance at the nuclear installation. Moreover, the full extent of occupational illnesses, including radiation, have occurred over decades, and are only now coming to the fore. Necsa has deceived Parliament on this issue.A full Commission of Inquiry, which is not tainted by nuclear sector bias, is necessary to establish the full extent of this problem both in the nuclear sector and the uranium mining sector.

15.7 Environmental ProtectionThe most important issue in any nuclear plan, in this document has only received ONE LINE!!

Please see Sections 24, 32 and 33 of the Constitution of the Republic of South Africa, Act 108 of 1996:

Section 24 of the Bill of Rights whereby it is stated :

Everyone has the right

a. to an environment that is not harmful to their health or well-being; and b. to have the environment protected, for the benefit of present and future

generations, through reasonable legislative and other measures that i. prevent pollution and ecological degradation;

ii. promote conservation; and

secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development.

Section 32 of the Bill of Rights whereby it is stated:

1. Everyone has the right of access to a. any information held by the state; and b. any information that is held by another person and that is required

for the exercise or protection of any rights.

Section 33 of the Bill of Rights whereby it is stated:

Everyone has the right to administrative action that is lawful, reasonable and procedurally fair.

Everyone whose rights have been adversely affected by administrative action has the right to be given written reasons.

I shall now refer to the environmental management principles of the National Environmental Management Act of 1998 (Section 2, subsection 4 (f); (g); (h); (k) and (q)) in substantiation of my premise:

“The participation of all interested and affected parties in environmental governance must be promoted, and all people must have the opportunity to develop the understanding, skills and capacity necessary for achieving equitable and effective participation, and participation by vulnerable and disadvantaged persons must be ensured.

“Decisions must take into account the interests, needs and values of all interested and affected parties, and this includes recognizing all forms of knowledge, including traditional and ordinary knowledge.

“Community wellbeing and empowerment must be promoted through environmental education, the raising of environmental awareness, the sharing of knowledge and experience and other appropriate means.

“Decisions must be taken in an open and transparent manner, and access to information must be provided in accordance with the law.

“The vital role of women and youth in environmental management and development must be recognized and their full participation therein must be promoted.”

Similar fact evidence is to be found in terms of the Nuclear Energy Act, No 46 of 1999, Chapter IV, Section 47 relating to the reporting of information on occurrence of source material:

”9(1) Any person who, by virtue of information obtained in the course of any prospecting or mining operations or carrying out any scientific investigation or chemical or metallurgical process, or otherwise, has reason to believe that any source material is present at any place, must within 30 days after having developed the belief, submit to the Minister or any person designated by the Minister for that purpose, a written report on the matter, containing full particulars of the grounds on which the belief is based and of the place where the material may be present.”

Furthermore, in terms of Section 40 of the National Nuclear Regulator Act, No 47 of 1999, the Regulator must on the request of any person, make the record of nuclear accidents and incidents available to that person; and no person is civilly or criminally liable or may be prejudiced or harassed on account of having disclosed, in the interests of the public, any information of a health or safety risk or failure to comply with a duty imposed by the said Act to organs of state or to the news media in order to avert an imminent and serious threat to the health or safety of an individual or the public, to ensure that the health or safety risk or the failure to comply with a duty imposed by the said Act was properly and timeously investigated, and to give due weight to the importance of open, accountable and participatory administration.

(Emphasis added.)

By the above phrases I intend to intimate that people ought to be afforded the right:

- to have access to information that is held by the NNR and that is required for the exercise and protection of the right to an environment that is not harmful to health and well-being and to have the environment protected for the benefit of present and future generations through reasonable legislative and other measures;

- to administrative action that is lawful, reasonable and procedurally fair; and

- to be given written reasons if the afore-mentioned rights have been adversely affected by administrative action, which includes a failure to act.

Moral and legal duties have been imposed by the laws, in terms of the National Nuclear Regulator Act, No 47 of 19991 and the Nuclear Energy Act,

1 1 In terms of the said Act, the NNR must provide for safety standards and regulatory practices for protection of persons, property and the environment against nuclear damage, which by definition includes any injury to or death or any sickness or disease of a person or any damage or loss of use of property or damage to the environment; to provide assurance of compliance with the conditions of nuclear authorizations through the implementation of a system of compliance inspections and to enforce punitive measures against polluters who discharge or release in any form, radioactive material or material contaminated with radioactivity.

The Regulator must furthermore, where the possibility exists that a nuclear accident affecting the public may occur, direct the relevant holder of a nuclear authorization to establish an emergency plan; require any person who causes any site or other place to be contaminated with radioactive material to rehabilitate the site or place to a condition that complies with the safety standards contemplated in section 36 of the said Act.

No 46 of 1999 upon the National Nuclear Regulator to protect persons, property and the environment from nuclear damage through the establishment of safety standards and regulatory practices.

Secondly, these duties, it is believed, are annexed to legal measures; the principles of Common Law, including the Law of Delict, promulgated Acts of Parliament inter alia the National Water Act, No 36 of 1998, the National Environmental Management Act, No 107 of 1998, the Mineral and Petroleum Development Act, No of 2002 and Section 24 of the Constitution of the Republic of South Africa.

15.8 FundingThere already exists various reports on economical viability of South Africa’s nuclear programme. These are not favourable. Internationally, the economic viability of nuclear energy has also not been established.Moreover, thusfar no financial plan has offered an analysis of costs for decommissioning, clean-up and the full extent of waste management over the decades, generations and possibly hundreds of thousands, if not billions of years.

ANNEXURE ATHE KEY ROLE PLAYERS IN THE SOUTH AFRICAN NUCLEAR ENERGY SECTOR

Nowhere in this section does it mention the role of the Department of Environment and Tourism. In light of the global and national climate change and environmental crisis, the functions of this department should be considered a national priority. A sustainable environment is synonymous with poverty issues and a decent future for all South Africans.

Over and above all the role players mentioned in Annexure A, there must be an oversight body which involves civil society to monitor all the activities of all the role players. Make them answerable and keep them in check.

Nuclear Energy Costs The Earth CampaignEarthlife Africa Johannesburg

Tel/Fax: Email: mashile@earthlife.org.za  

Embargo: 26 September 2007 (TIME?)

PRESS RELEASE: MINERALS AND ENERGY MINISTER CALLED TO SACK GOVERNMENT’S NUCLEAR POLICY ADVISORS & HOLD CIVIL SOCIETY-INSPIRED SUMMIT

The Minister of Minerals and Energy is hereby called upon to immediately suspend and sack the sinister cabal who are the South African government’s nuclear policy advisors for being deliberately unconstitutional and misleading.

I also call on the Environment and Tourism Minister strengthen his mandate in terms of the law or resign and make way for someone who can take his or her rightful place as an empowered custodian  to lead his departments in sustainable solutions for this country, and therefore human rights.

It has become increasingly clear that a handful of so-called experts are advising the Cabinet and various Parliamentary committees with nothing but a pack of lies and inaccuracies. One wonders how far goes their personal rewards for doing so?

Instead of subsidising yet another expensive and “greenwashed” summit with pre-determined outcomes, we call upon the Energy Minister to urge Cabinet to fund a civil society-inspired summit. We want to work with our decision-makers to properly inform them so they can be empowered with real facts and real information. Information -- well-known to scientists, academics and professionals throughout the world – is being denied not only the South Africa public but the government. Instead, massive propaganda is being dished out that climate change will justify nuclear energy. Nuclear energy is not the answer to climate change and, infact, will achieve just the opposite, and worse.

Several industrialised nations of the world have opted to phase out nuclear energy, but energy advisors in this country are lying to our government about a global “nuclear renaissance”. The truth is that after almost 70 years of splitting atoms, the slow painful genocide this has caused hundreds of thousands of nameless people is ignored by an international nuclear gang with whom nuclear advisors in this country are in cahoots.

The truth is that in this country nuclear workers and miners (by the thousands) and nearby communities, are being nuked. The authorities are lying about this and have for decades been turning a blind eye to the problem. There have been “leaks” at the Vaalputs nuclear dump site in the Namakwaland that adversely affects communities there, there have been “leaks”, “accidents and incidents” at Pelindaba of which communities remain uninformed, Earthlife Africa Cape Town has serious concerns about the safety of high level radioactive waste stored in cooling ponds at Koeberg nuclear power station. Information obtained indicates that an excessive amount of waste is stored onsite, far beyond what the system was originally designed to manage. Of further concern, information supplied suggests that Boron levels in the water around the spent fuel are abnormally high, at approximately 2000 parts per million. Radioactive and chemical pollution from decades of mining activities on the West Rand has resulted in the deadly contamination of water to the Witwatersrand and now through the Cradle of Humankind. Already there is an emergence of genetically deformed children in some areas.

Yet environmental departments and the National Nuclear Regulator chose to do nothing. The National Energy Corporation of SA (NECSA) has chosen to

conceal the truth and focus on smearing its opponents. NECSA and a small cabal of its affiliates have effectively managed mislead decision-makers going to extraordinary lengths to do so – even disrupting residents’ meetings.

It is also time that Intelligence Minister Ronnie Kasrils provides the South African public with answers over media reports that he invited a prominent university professor to give a presentation to the South African intelligence community, which included the suggestion of restarting the country's nuclear weapons programme. It reportedly elicited loud applause. And why is this government refusing to sign the global partnership to prevent the making of nuclear weapons? (see appended articles below)

Procedural and democratic laws are being broken or amended to suit nuclear energy protagonists as they fast track their plan. How far will this go? Will South Africa soon be in the nuclear bomb-making arena again?

We implore the Energy Minister and Cabinet to take stock of what is playing out to very sinister tunes in this country.

I wish to conclude with a call by my colleague Mike Kantey for all democrats to familiarise themselves with the national debate on energy policy before it is too late and to take an active part in the collective determination of a sustainable future.

I thank you.

Issued by: Mashile PhalaneCoordinatorEarthlife Africa Johannesburg NECTEC

Below I have appended several articles of relevancy

THE DRAFT NUCLEAR ENERGY STRATEGY:

LAST CHANCE FOR DISSENT

Mike Kantey of the Coalition Against Nuclear Energy

On 22 August 2007, the Portfolio Committee on Minerals and Energy in the South African Parliament received an “Update” by the Department of Minerals and Energy (DME) and the Nuclear Energy Corporation of South Africa (NECSA). During this session, the Draft Nuclear Energy Policy and Strategy for

the Republic of South Africa was presented, a strategy which had been already “approved by Cabinet” on 8 August 2007.The minutes of this Portfolio Committee briefing (provided by the Parliamentary Monitoring Group), the Draft Strategy Document itself, and from attending  various “Key Stakeholder” meetings, demonstrate clearly that the present South African Government is determined to pursue a full-scale nuclear industry expansion programme in South Africa, with or without popular understanding or popular consent.It therefore raises -- not for the first time – serious issues with regard to the practice of open democracy and public participation in national policy formation.First, however, the public needs to know what has happened on the nuclear energy front.1. DME Chief Director, Tseliso Maqubela, says that we must commit to “one hundred years” of a nuclear industry, according to the Minutes of the above Briefing.

2. The Pebble-Bed Modular Reactor (PBMR) failed its first Environmental Impact Assessment (EIA) process, but has started again with a larger output of 165MWe, because the earlier design was found to be uneconomic, anyway. The revised design therefore remains completely untested and unlikely to proceed beyond a R20-billion demonstration unit at Koeberg -- despite Eskom’s “order” of 24 units -- because there are no buyers anywhere in the world.

3. A more likely scenario will be Eskom’s purchase of five packs of Westinghouse AP1000 Pressurised Water Reactors (PWRs), similar to those at Koeberg. The recent, separate EIA meetings were supposed to determine the suitability of five coastal sites for PWRs, the same as those “chosen” under the Apartheid regime in 1986: are: Brazil and Schulpfontein in Namaqualand; Koeberg; Bantamsklip; and Thyspunt.

4. A Record of Decision has already been granted for fuel fabrication for the PBMR in Pelindaba, while the latest National Radioactive Waste Policy Document of 2005 includes a commitment to reprocessing spent fuel.

The biggest drive right now, however, is to gain support for the one missing piece of the nuclear fuel production chain:

uranium enrichment, the very thing that has everyone hopping up and down about Iran.

In Parliament it was claimed that, because South Africa has “an abundance” of uranium, we needed to “beneficiate” the mineral, instead of selling it abroad as a raw product and that “Investing in the beneficiation of uranium would yield huge rewards for the country.” No justification, no business case, and no bankable feasibility study were presented in support of this assertion. What we see, therefore, is a full house of nuclear options, all amounting to a massive injection of cash into the bank accounts of three beneficiaries: the PBMR (Pty) Ltd, in which Eskom is the major shareholder; Eskom itself, through its ambitious nuclear power-station programme (a projected 20 000 MW); and NECSA, for nuclear enrichment, PBMR fuel fabrication, reprocessing and radioactive waste managementMassive sums of money have been bandied about. Previously, in an Environmental and Tourism Portfolio Committee Meeting (19 October 2004), a Mr Matjila from the Department of Environmental Affairs and Tourism (DEAT) had stated that “the cost of replacing Koeberg would be approximately R30 billion and the cost of decommissioning, including waste disposal, was around R16 billion.”

Assuming that the DEAT official was correct (and we will never know because Government does not like to give out accurate costs without a fight or a lawsuit), then – on available evidence -- we can expect another five Koebergs at R30 billion each; an odd R20 billion each for uranium enrichment and fuel fabrication; and another R16 billion for decommissioning and waste disposal. Add another unsubstantiated R14 billion for a white-elephant PBMR demonstration unit, and we can round off the package to R220 billion.

Now we know why Eskom has suddenly asked for electricity prices to be increased by 18% in 2008, and 17% in 2009. According to a report by Mariaan Olivier, “the increase in prices stemmed from the gap … between Eskom’s current tariff at 18c/kWh and the cost of new production of 36c/kWh.” (Engineering News, 20 Aug 2007) Olivier goes on to report that electricity prices increases had already been set by a NERSA Multi-Year Price Determination, allowing only for a 5,1% increase for 2005/6, 5,9% for 2006/7, and 6,2% for 2008/9.

It follows, therefore, that – not only are we expected to pay for this R220-billion nuclear programme from our normal tax contributions – we are also going to pay for the nuclear industry through a three-fold increase in electricity bills.

Having understood the range and scope of the nuclear ambitions in South Africa, therefore, we need to examine very thoroughly how we got to this extraordinary moment in South African history and what part we are expected to play in determining energy policy.Mr Maqubela in his appearance before the Portfolio Committee is quite comfortable with the assertion that “The [1998 Energy] White Paper made provision for nuclear energy but it was tentative and informed by conditions prevalent at that time, which included anti-nuclear sentiment.”The Chief Director is alluding, of course, to the 1994 ANC Policy Conference on Nuclear Power, which was not wildly in favour of the nuclear industry. Indeed, one of the partners of the Tripartite Alliance, the Congress of South African Trade Unions (COSATU) went on to condemn the expansion of the nuclear industry outright in a Resolution passed at their 2003 Congress. Since their 2006 Congress came and went without any Amendment being proposed, one assumes that such a Resolution still stands.Thus we have a situation where – as far as can be determined – only the current President and his Cabinet (notably Alec Irwin and the Minister of Minerals & Energy) are in favour of nuclear energy, supported by a small gang of bureaucrats. As far as “public participation” is concerned, we are reduced to spectators, where the agendas, the speakers, and the topics are all determined by the proponents. Eskom’s idea of participatory democracy is a two-hour presentation in a highly centralized (but inaccessible) location with about twenty minutes of Q&A, where we are asked to “choose” between dirty, expensive coal and clean, affordable uranium. During the Portfolio Committee briefing of 22 August 2007, Adv Hendrik Schmidt of the Democratic Alliance (DA) noted that “there was a difference between an awareness campaign and public consultation. One should bear in mind that there were communities who were not in favour of the nuclear programme. He said that if Cabinet’s decision would override the views of the public, it would be a dangerous road to follow.”Mr Maqubela’s response is so truly alarming that it ought to be published in full:

“ … the [Draft Nuclear Energy Strategy] document had been approved for public comment. The Department would make copies available to the public. It would also be published in the Government Gazette for sixty days. This process could however not be dragged out due to commercial imperatives. Investments in regeneration need to be made, as there was a need for a new power plant on the coast by 2016. The Department would also be available for public meetings with the affected communities. This would have to be co-coordinated as there was no purpose in extending the period of public meetings which might not even add value to the process.” [Emphasis mine]Earlier in the briefing, Mr Maqubela was quoted as having said:

“The era of investment in nuclear energy had arrived. Those who had invested in this in the past had benefited the economy. The time had arrived to invest in order to benefit this and future generations.”At what point, then, was the capture of State Power taken away from its own citizens and handed over to an invisible elite?How can we as citizens regain control over our own destinies?As we have seen in recent years, through the social movements -- such as the Treatment Action Campaign, the Women and Children’s Rights, and the Environmental Justice Movement, to name only a few – through the just and noble decisions of the Constitutional Court, and through the small struggles of discrete communities against arbitrary behaviour on the part of statutory authorities, our freedoms cannot be won at the ballot box, but by active participation in the day-to-day exercise of participatory democracy.To quote that great champion of democracy, Paolo Freire, “To remain neutral is not to side with the powerless, but with the powerful.”We call upon all democrats to familiarise themselves with the national debate in energy policy and to take an active part in the collective determination of a sustainable future.

Is South Africa considering nuclear weapons? Date: Mon 18 September 2006 Source: http://www.greenclippings.co.za/gc_main/article.php?story=2006091820163932A government spokesperson has stated that South Africa is investigating the possibility of enriching uranium locally, but has denied rumours that the recent decision was linked to the future development of nuclear weapons. But a prominent university professor was recently invited to give a presentation to the South African intelligence community, which included the suggestion of restarting the country's nuclear weapons programme.The controversial presentation comes as South Africa’s Special Representative on Disarmament, Abdul Minty, chairs the 50th session of the International Atomic Energy Agency (IAEA) in Vienna, Austria.Speaking at the conference today, South African Minister of Minerals and Energy Sonjica said that South Africa strongly supported the Convention on Nuclear Safety, and called on the nuclear-weapon states to reaffirm their commitments and undertakings to systematically and progressively eliminate their nuclear weapon arsenals.According to a Weekend Argus report, dean of research at the University of the Western Cape, Professor Renfrew Christie, was invited to give the controversial talk by Intelligence Minister Ronnie Kasrils.During the presentation, Christie warned of possible future wars in Africa, and suggested that that South Africa needed to quickly be able to revert to a nuclear weapons state if it became vital to the country's interests.The professor noted that South Africa still retained a stockpile of weapons grade highly enriched uranium derived from the country's former nuclear weapons programme. He also reminded everyone that technical knowledge of South Africa's former atomic bombs was still contained on CD's held by the current government.The Weekend Argus reported that the presentation was greeted with loud applause from the intelligence community. Critics are concerned that such thinking is likely to spread to policy makers, and warned of the possible consequences for Africa.Sources in government are concerned that the South African government has been ploughing billions of rands into the controversial Pebble Bed Modular Reactor (PBMR) despite a report by Price Waterhouse Coopers suggesting that the project was financially risky, and warned that there may be other motives behind the project.According to Mashile Phalane from the environmental watchdog Earthlife Africa, South Africa is falling into the same trap as the apartheid government by wanting to enrich uranium.

DOES THE FOLLOWING REPORT INDICATE THAT SOUTH AFRICA IS INTENT ON GOING AHEAD WITH A NUCLEAR WEAPONS PROGRAMME?

Daily Despatch 19 September 2007SOUTH Africa is holding off joining a US-led initiative to spread atomic power since it does not want to give up its right to enrich uranium.

Minerals and Energy Minister Buyelwa Sonjica told reporters, at a meeting of the UN atomic agency, about Global Nuclear Energy Partnership’s (GNEP) invitation accompanied by a declaration.

But “we got a bit concerned that there was some conflict of ... our national policy”.

South Africa was not among the 11 countries which joined the US-led GNEP in Vienna on Sunday – an effort to spread atomic power but not technology which can be used to make nuclear weapons. Uranium enrichment makes nuclear power reactor fuel but also atom bomb material.

New members Australia, Bulgaria, Ghana, Hungary, Jordan, Kazakhstan, Lithuania, Poland, Romania, Slovenia and Ukraine joined the United States, China, France, Japan and Russia in signing a statement of principles for GNEP.Sonjica said that under the GNEP “fuel would be distributed” to countries but South Africa “has taken a decision to beneficiate its minerals ... in other words to end-value the minerals in South Africa, and that would include uranium”.

Exporting uranium only to get it back refined, instead of enriching it in SA, would be “in conflict with our national policy”, she said.

Sonjica added that SA, which abandoned its nuclear weapons programme in the 1990s, including uranium enrichment, is now set to expand its civilian atomic power programme in order “to reduce the amount of CO2 our power plants emit”.

It is looking for international partners to develop uranium enrichment.Nuclear power is seen by many as crucial in a world where energy demand is booming since it makes electricity without adding to the greenhouse gases which cause global warming. — Sapa-AFP

Nuclear Safety Reports Called Into QuestionGaps in Global DatabaseBlamed on Regulators;A Scare in BulgariaBy STEVE STECKLOWAugust 3, 2007; Page A1 Front Page Wall Street Journal

To inform the public about nuclear-plant mishaps, a United Nations agency in 1989 helped create a Richter-like scale rating them from zero to seven. Chernobyl was pegged as a seven. Three Mile Island rated five.

How many mishaps have occurred over the years -- and is the rate getting better or worse? It's hard to know. That's because every day, the U.N.'s International Atomic Energy Agency deletes from its Web site any rated incident that's more than six months old. The agency says it doesn't want to penalize more-forthcoming countries by making it look like they have poor safety records.

SAFETY GAP 

• The Issue: As countries around the world are pushing nuclear power, questions are being raised about gaps in the reporting of safety incidents.• What's at Stake: Nuclear power's safety record in recent years may not be as stellar as some claim.• The Scofflaws: Japan nuclear plants have been among the worst in failing to report accidents.

As countries across the globe push nuclear power to feed a growing appetite for electricity, transparency -- or lack of it -- is a big issue. Separately from the accident scale, the IAEA and another agency oversee a global database of nuclear incidents, but regulators often neglect to pass accident reports to it. That database and a second one run by the nuclear industry are off-limits to the public.

"There are countless events that are insufficiently documented or not documented at all," says a May report by nuclear-safety specialists that was commissioned by a Green Party member of the European Parliament.

In Japan last month, Tokyo Electric Power Co. initially said an earthquake near one of its nuclear plants caused no release of radiation, only to admit later that it had. Reactor operators in Japan have admitted falsifying safety records for years, including the coverup of a 1999 incident in which operators lost control of a reactor for about a quarter-hour.

QUESTION OF THE DAY 

• Would you support broader use of nuclear energy in the U.S.?

Proponents of nuclear power say the disclosure lapses shouldn't detract from the bottom-line results: no major nuclear accidents since the Chernobyl disaster in Ukraine in 1986, which killed dozens of workers and spread radiation for hundreds

of miles. "Nuclear power is safe," President Bush declared during a visit in June to a nuclear plant in Alabama.

"The operations of the world's nuclear fleet has demonstrably improved," says Jeffrey S. Merrifield, who served as a commissioner of the U.S. Nuclear Regulatory Commission from 1998 until June. The result, he says, is "improvement in the comfort level of the public in nuclear reactors being built both here in the United States and abroad."

The world has 438 operating commercial reactors in 30 countries, of which 104 are in the U.S. Regulatory records show at least four serious incidents have occurred since 2001 at overseas plants -- in Bulgaria, Hungary, Sweden and Taiwan -- including a radiation release and a fire. A fifth incident, involving severe corrosion in a reactor part that could have led to a major radioactive leak, took place in Ohio. Regulators emphasize that none of the incidents endangered the general public, and that either backup safety systems ultimately kicked in, or the problems were discovered in time.

Amid concerns about climate change and the high price of oil, the Bush administration is trying to restart new plant construction in the U.S. for the first time in three decades. The last new American plant, Watts Bar 1 in eastern Tennessee, opened in 1996, 23 years after construction began.

Noting that reactors produce no greenhouse gases because they don't burn fossil fuel, Mr. Bush signed an energy bill two years ago that offers subsidies and loan guarantees to new plants. Eighteen companies have told the NRC they hope to build up to 30 new nuclear plants in coming years, primarily in the South, with the first to open around 2015.

Outside the U.S., nuclear plant construction never stopped. Thirty-one plants are being built, and China, India and Russia have announced plans for dozens more. Egypt, Indonesia and Vietnam are exploring building their first commercial reactors. Nuclear power currently accounts for about 16% of the world's electricity production. In the U.S., the figure is 20%.

The American nuclear industry and U.S. officials have touted the performance of nuclear plants, including those overseas, as justification for building more plants. Among its "Top 10 Reasons" why the technology is vital, the Washington-based Nuclear Energy Institute includes, "Nuclear power is a trusted technology abroad." The industry's policy association states, "More than 30 countries rely upon nuclear power as a safe and affordable source of electricity."

Two confidential, voluntary databases contain extensive reports of safety-related incidents. One is jointly run by the IAEA in Vienna and the Paris-based Nuclear Energy Agency, part of the Organization for Economic Cooperation and

Development. The other is kept by a London-based industry group called the World Association of Nuclear Operators.

The IAEA, which opens its database to regulators so they can learn from others' mistakes, has seen fewer reports in recent years -- 89 last year, down from 231 in 1985. It says this doesn't reflect improved safety, but regulators' failure to contribute reports to the voluntary system. "We know about many more events that we think should be reported," says Christer Viktorsson, an official in the IAEA's department of nuclear installation safety.

The European report commissioned by the Green Party parliamentarian found that the French nuclear operator, Electricité de France SA, has reported since 2003 around 700 "significant" safety-related events each year at its 59 reactors to the Institute of Radiological Protection and Nuclear Safety, a government-funded body. But the institute passes on only about 10 incident reports each year to the IAEA.

Jacques Repussard, the institute's director general, says the purpose of the system is "not to report every incident, it is to report incidents in which others may learn." He says France's level of reporting is no different from that of the U.S. or Japan.

Mr. Repussard says even the small number of incidents that do make it to the IAEA tend to get ignored: "A lot of countries don't make sufficient use of the reports...for future prevention purposes."

The managing director of the association of nuclear operators, Luc Mampaey, expressed the same concern last year. He told Inside NRC, an independent newsletter, that plants in different countries were suffering the same kinds of incidents, suggesting that some operators weren't checking the association's information. A report last year by the OECD and IAEA cited a number of recurring events at nuclear plants over the years, including corrosion and valve failures in emergency core cooling systems.

Mr. Mampaey also said that while many utilities were doing a better job of reporting events, "the battle remains" because some weren't reporting any. Officials at the

association didn't respond to requests for comment.

In the U.S., even nuclear critics acknowledge that the Nuclear Regulatory Commission is more forthcoming with safety-related information than most other countries. "The NRC provides the public with its inspection reports and incident reports," says James Riccio, a nuclear-policy analyst at Greenpeace USA in Washington. "Even though the amount of information has decreased since 9/11, it still seems to be more than what's provided by other nuclear nations."

In the Japanese earthquake last month, information emerged in dribs and drabs. Tokyo Electric Power apologized after admitting the

quake released radiation and radioactive water into the environment and knocked over hundreds of barrels of low-level nuclear waste. Hiro Hasegawa, a company spokesman, attributed the information delays to the plant being short-staffed on a weekend. The Japanese government said the radiation releases posed no danger to the public. The plant has been shut down indefinitely.

Tokyo Electric and other Japanese utilities have previously admitted to coverups of nuclear plant incidents, including accidents and unplanned shutdowns, repeatedly over the past several decades. In April, the Japanese government said Hokuriku Electric Power Co. had admitted to hiding a 1999 incident at its Shika nuclear plant when several control rods, which are used to slow down or speed up the nuclear reaction in the fuel core, became dislodged during a test while the reactor wasn't operating. The dislodged rods caused the reactor to start inadvertently.

An emergency safety system had been turned off by workers, and the reactor grew hotter for 15 minutes before plant operators could shut it down. The company said it didn't initially report the incident because the plant manager feared that construction on a second reactor would be delayed.

One of the few recent public sources that aims to give an in-depth review of global nuclear incidents is the European report released in May. Rebecca Harms, a German member of the parliament who opposes nuclear power, commissioned the study by seven experts led by French energy and nuclear-policy consultant Mycle Schneider.

After interviewing regulators and studying incident reports, the authors described in detail 16 "significant events" in the last 20 years, including a dozen outside the U.S. They included nuclear-fuel degradation, a fire, a hydrogen explosion and plant blackouts.

One little-publicized incident it describes is a control-rod failure near the town of Kozloduy in northwestern Bulgaria. On March 1, 2006, an electrical failure caused

one of the main coolant pumps at the Russian-designed Unit 5 to stop. The pump circulates water to keep reactor temperatures from reaching dangerous levels. The system automatically began to reduce the plant's power output by dropping control-rod assemblies into the reactor core to decrease the nuclear chain reaction.

But some of the assemblies were stuck, Bulgarian records show. More than six hours later, a backup safety system was used to shut down the reactor. Later tests showed that more than a third of the assemblies were inoperable, and apparently had been that way since their driving mechanisms had been replaced eight months earlier.

Bulgaria's nuclear regulator didn't acknowledge the control-rod problem for 13 days and initially said it had no safety significance. Five months later, the regulator said the plant's operator, state-owned Kozloduy NPP PLC, had fixed the sticking problem. The study done for Ms. Harms called the prior operation of the plant with inoperable control rods "an unprecedented example in the history of nuclear power." In the event of an emergency requiring an immediate shutdown of the plant, it added, the Kozloduy system wouldn't have been able to prevent "severe damage of the reactor core."

Kozloduy NPP disputes that assessment. In its annual report, it stated, "In 2006, we did not have any events with a negative impact on safety due to the high safety culture of our personnel." The report devoted one sentence to the control-rod incident, noting it received a 2 rating on the IAEA scale, one level below a "serious incident."

Mr. Repussard of the French nuclear-safety institute says many utilities fear that if they release information on incidents they consider minor, "it might not be interpreted well by the public." If all incident reports were made public, he says, plant operators would be reluctant to share them with each other.

No radiation was released in the Bulgarian incident. But that wasn't the case with a mishap in Hungary.

On April 10, 2003, workers at the Paks 2 nuclear plant, south of Budapest, were cleaning 30 used, but still radioactive, fuel-rod assemblies by placing them into a cleaning tank containing water and chemicals that remove mineral deposits. At 9:53 p.m., Hungarian records show, a "warning signal" appeared on a radiation detector in the reactor building where the cleaning was taking place. The radiation levels kept climbing; within an hour, the reactor hall was evacuated.

Workers unlocked the lid of the cleaning tank to inspect the assemblies. Radiation levels in the area immediately soared. Two hours later, a cable used to open the lid snapped, leaving the lid stuck and the tank partially open. Radiation levels spiked again. It turned out that the fuel rods had overheated as the nuclear reactions had speeded up, because the cooling system for the tanks wasn't sufficient.

According to the report for the European Parliament, emissions of radioactive gases like xenon and krypton during the accident were nearly four times the total average

annual releases of all of France's 58 reactors. The plant operator wasn't able to remove the radioactive fuel -- more than five tons of it -- until January 2007, nearly four years later.

A report by the Hungarian Atomic Energy Authority concluded that the radioactive exposure to the population was "negligible." It cited an inadequate "safety culture" at the plant. However, the Hungarian utility that operates the plant, MVM Group, publicly blamed a contractor, Framatome ANP GmbH, which designed the decontamination equipment. The contractor later paid damages.

The most serious nuclear plant incident in the U.S. in recent years occurred at the Davis-Besse plant in Oak Harbor, Ohio, in 2002. There, a pineapple-size cavity, caused by extensive corrosion, was found in the lid of the reactor pressure vessel, which houses the fuel core.

The corrosion -- the worst ever found at a U.S. plant -- could have led to a loss of reactor coolant water. Workers discovered the problem before a serious accident resulted. "It's probably the most significant incident we've had" since Three Mile Island, says Mr. Merrifield, the recently departed Nuclear Regulatory Commission member. In that 1979 incident near Harrisburg, Pa., a reactor core was damaged but didn't release widespread radiation.

Davis-Besse subsequently shut down for two years. Its owner, FirstEnergy Nuclear Operating Co., a unit of FirstEnergy Corp. of Akron, last year paid $28 million in fines and admitted to the Justice Department that its employees had lied to the NRC that the plant was safe to operate.

Write to Steve Stecklow at steve.stecklow@wsj.com

NUCLEAR POWER | 01.10.2007

Some EU Officials Want to Resist Nuclear Power Renaissance

  Politicians questioned the actual benefits nuclear energy would bring the environment  High-ranking European government officials, representing seven anti-nuclear states called Monday for alternatives to nuclear energy, which is experiencing a renaissance as attention turns to lowering greenhouse gases. Representatives from Germany, Austria, Ireland, Norway, Italy, Luxembourg, and Latvia started a two-day meeting in Vienna on Sunday, Sept. 30, to forge a joint declaration against nuclear energy. Participating politicians called for more investments in energy-efficiency measures and renewable energies rather than nuclear power. 

"We are no anti-nuclear coalition, but we want to show alternatives," said Austrian Environment Minister Josef Pröll. The declaration, focusing on the safety and security risks surrounding nuclear energy, said this form of energy was not the best way to fight climate change. Matthias Machnig, German deputy minister for environment, criticized the alleged positive role of nuclear energy in reducing global greenhouse gases as a "myth," adding that the world's combined power plants would only contribute with 8 percent to carbon dioxide reduction.  The discussion on nuclear energy only slowed down investment into energy efficiency and alternative energy forms, he said. Nuclear renaissance? 

  The Chernobyl disaster led some countries to rethink their nuclear

power strategy

Support for nuclear energy dropped after the 1986 Chernobyl disaster but the energy source has come back into fashion as governments and officials look at strategies toward lowering greenhouse gas emissions. Recent increases in gas and oil prices as well as questions about the reliability of Russian energy supplies have also raised European energy concerns. European Union Energy Commissioner Andris Piebalgs said in an interview published in Spanish daily El Pais on Monday that the EU should aim to generate 30 percent of its electricity from nuclear sources in order to ensure member states' energy security.  Industry officials are promoting third-generation pressurized water reactors which provide greater energy, improved security and reduced waste compared to earlier versions of nuclear reactors. These new reactors are still rejected by environmentalists. Long-term ecological effects   Nuclear power opponents question what will become of radioactive waste

But Italy's Environment Minister Alfonso Pecoraro Scanio warned of the long-term ecological effects -- his country is still dealing with nuclear waste, 20 years after quitting nuclear energy. 

Latvia was the only country in the group that is actively moving ahead with expanding its nuclear energy capabilities, while all other seven members either have no nuclear energy or are planning a phase-out, like Germany. The cooperation was no contradiction, Latvia's deputy environment secretary Martins Jirgens said, as he hoped the planned Latvian involvement in the construction of the Lithuanian nuclear reactor Ignalina would not go ahead. An issue for national governments European Commission chief Jose Manuel Barroso urged EU nations on Monday to hold a "total and frank debate" about the use of nuclear energy. "Member states can not avoid the question of nuclear energy," he said Monday during an energy conference in Madrid. "It is not the EU's role to decide if they should or should not use nuclear power."  DW staff (sms) DW-WORLD

DW-WORLD: Germany's Nuclear Phase-Out Ignites Fresh Political RowAlthough Germany decided years ago to phase-out nuclear power, politicians from the country's governing parties continue to argue about how and when it will happen. (02.09.2007)

DW-WORLD: Concerns Mount Over Nuclear Energy After Series of Scares 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. (27.07.2007)

ADDITIONAL SUBMISSION FROM THE PELINDABA WORKING GROUP ABOUT CIVIL SOCIETY VIEWS

FOR A NUCLEAR POLICYA. DEMOCRACY & RIGHTS

Participatory governance and democratic principles, human and environmental rights as enshrined in the Constitution and other laws, particularly NEMA, are a major concern particularly as the EIA processes of nuclear and uranium developments appear thusfar to have by-passed any semblance of these principles and concerns, and left vast communities most likely to be affected completely uninformed. Just because large numbers of our population are illiterate or uneducated does not mean they should not be adequately informed over these issues. Moreover, it is ordinary people whose health and land becomes affected by these developments, and more often than not it is ordinary folk who are left grappling in the dark in a defensive manner trying to understand the almost mythical nature of these developments, their impacts, the positioning of various laws over various aspects of these developments and also, ultimately, the various chain of command, accountability and recourse. Democracy implies that governments work for those who elected them into power and those office bearers and the laws they purport to uphold and protect, are answerable to the electorate. These issues cannot be dealt with lightly, flippantly or dismissively.

As such, it is incumbent upon the government to ensure that any Nuclear Policy must consider the above issues thoroughly and objectively and in ways that are understandable to ordinary folk. If nuclear consultants, along with ESKOM and the nuclear industry, approaches this policy and ensuing EIAs from the premise that nuclear energy is unavoidable and inevitable, then such declaration should be made immediately so that public funds are not wasted on a futile “greenwashed” process and citizens can consider their options via the Constitutional Court.

I therefore submit that the Nuclear Policy must address the following:

1. The Constitutionality of nuclear energy developments within the context of possible recourse which may or may not exist for civil society.

2. A thorough overview of laws that have a bearing on each and every aspect of Eskom’s Nuclear Power Stations and Associated Infrastructures;

3. A thorough overview of environmental and human rights legislation of relevance to these developments with consideration to cradle to grave full fuel cycle ;

4. A thorough overview of the chains of command/responsibility, governance and accountability, regulatory control, environmental control, health and safety control, fiscal control and what mechanisms for transparency will be adopted for these controls;

5. In addition a full explanation of the licensing processes involved in terms of authorisations, approvals, avenues for public participation in these processes;

6. The provision for a national referendum over nuclear energy only ONCE its proponents have provided funding for adequate and unbiased debate and public education (based on best international practise where this has occurred).

7. An explanation of how, as stated in the BIDs of the various coastal nuclear reactors, I&APs will assist the EIA Teams to identify issues and suggest mitigation of associated impacts. What objective criteria will this be based on? What rights does this EIA guarantee civil society?

8. In line with the above-mentioned rights of civil society, what will this EIA process do to ensure that civil society is informed beforehand of all the steps, deadlines, procedures and role players of this EIA, and ensure that I&APs remain informed and alerted throughout the entire process?

B. NUCLEAR POLICY & AUTHORISATION REQUIREMENTS

1. The Nuclear Policy needs to assess whether it can continue with a process that is based merely on assumptions for nuclear designs which have not yet been completed.

2. There are vast amounts of non-industry reports and articles on Pressurised Water Reactors and Pebble Bed Modular Reactors and their technologies which raise alarming issues and do not instil confidence. These should be thoroughly investigated. If the EIA consultants are not sure where to obtain these studies and reports, I&APs and the public should be alerted and requested to provide such.

3. The Nuclear Policy should address the recourse I&APs have for checks and balances on the “specialist studies” that will be commissioned for the EIA, and be prepared to accept international studies that have been done.

4. The Nuclear Policy must address the funding for local or international experts whose commissioning for reports or submissions related to various EIAs and issues related to the authorisation requirements as may be deemed necessary by I&APs. Preferably these should first be assessed in a Nuclear Summit before excessive amounts of money are spent on the various nuclear developments.

C. ALTERNATIVES

EIA regulations state a prescriptive imperative that alternatives to the intended project be evaluated. It is not good enough, as has been the practise, to dismiss alternatives to nuclear energy without a holistic and thorough investigation of alternative energy sources and/or alternative approaches to energy provision. In this regard, a great deal of research globally and in this country has produced far-reaching possibilities for energy generation that exclude nuclear energy. Indeed there are many examples of these alternatives already operating efficiently.

I therefore submit that the Nuclear Policy must address the following:

1. A thorough investigation into alternative energy sources and alternative approaches to energy provision and supply.

2. The scenarios for “cleaning up” or mitigating against the massive CO² and other pollution from coal power stations as an immediate measure in the battle against pollution and the causes of climate change and, together with other energy saving mechanisms that can be implemented, what bearing this would have for sustainable energy supply until alternative sources are integrated.

D. CRADLE TO GRAVE FULL FUEL CYCLE & WASTE

A growing number of researchers have concluded from extensive studies that not only does nuclear energy make no economic sense, but that it is also not a mitigating factor insofar as CO² and CFC emissions among others are concerned when the cradle to grave full fuel cycle is concerned. In addition, the cradle to grave perimeters are also being re-evaluated and beginning to indicate that the management of radioactive waste from nuclear installations could be necessary for a lot longer than previously anticipated.

Similarly, increasing international reports indicate that nowhere in the world has a workable solution been found for radioactive waste. With the advent of climate change, tectonic plate shifts, seismic faults and climatic upheaval, have delivered more unanswered questions than sustainable solutions.

In addition, the full cost of decommissioning and waste management, environmental mitigation as well as medical costs to human health and safety throughout the cycle beginning with uranium mining and its processing, through the ensuing emissions and radioactive waste generation, to dealing with the spent fuel, contamination and defunct power stations

I therefore submit that the Nuclear Policy must address the following:

1. A thorough investigation into all existing cradle-to-grave full fuel cycle studies from not only the nuclear industry but including those done by opponents to nuclear energy among them the Massachusetts Institute for Resource and Security Studies, Storm van Leeuwen and Phillip Smith to reach an unbiased view.

2. Thorough geological investigations for the proposed sites of both the power stations and radioactive waste disposal sites, taking into account authoritative views on climate change patterns and geological patterns, seismic activities, global tectonic plate activities, and earthquake patterns both historic and projected.

3. A thorough investigation into ALL views of radioactive waste, its management, its duration, its content, its handling and the associated costs – not just the views of pro-nuclear industry.

4. A thorough analysis of all the different types and volumes of emissions and waste products to be produced by the nuclear power stations AND all associated infrastructures and the long-term assessment of these fate, volume, handling, and danger of these.

5. A thorough investigation into all the auxiliary and ancillary industries such as Uranium Hexaflouride, Hydrogen Flouride or any other chemicals and substances for which there will be beneficiation plants – their potential danger and the environmental impact they could have.

6. And thus, a full outline of what is referred to as “associated infrastructure”. This should therefore take into account the question of what impact will arise from these “associated infrastructures” .

7. A thorough investigation into the costs and effectively of “decommissioning” the nuclear power stations.

8. A thorough investigation into the amounts of radioactive material that will be subject to transportation in, around, and to South Africa. Volumes, types of materials, transportation methods, transportation vehicles and routes. Additionally, the environmental impact along these routes, including a breakdown analysis of towns, ports, communities, airports, informal settlements, traffic volumes, accident rates, hijacking statistics, remedial actions, evacuation plans, markings and warnings on vehicles, trucks, aeroplanes, trains etc; training and occupational health protection and recourses for drivers, pilots, ship captains and there respective staff members and all handlers.

E. ECONOMICS & VESTED INTERESTES/FOREIGN PARTNERS

The nuclear industry is notorious for underestimating costs involved for the development of nuclear power stations. Budget over-runs, lack of private investment, the massive spending of taxpayers’ funds are all major concerns to civil society.

From time to time an unwitting public is being informed of trade and industrial partnerships the government is forging with foreign countries and governments. Where these concern uranium mining and nuclear developments, there is grave concern over the track records of intended and already existing business partners that are chosen.

I therefore submit that the Nuclear Policy must address the following:

1. A thorough and transparent business plan involving all players – current and intended - and to include an analysis of all costs involved in the proposed developments taking into consideration the full cradle-to-grave full fuel cycle scenario with a view to determining who will pay what and who stands to gain.

2. An honest look at the national and international track record of all businesses involved in these developments.

3. Equally important is to address what guarantees/ recourse is available to civil society if there is a massive abuse of taxpayers’ funds and non-adherence to proposed budgets.

4. A thorough unbiased investigation into the financial scenarios of existing nuclear stations – Koeberg and internationally and the implications on the public expenditure and for consumers. Civil society input must determine the neutrality of this study.

5. A thorough investigation into the implications this hold for electricity consumers.

6. Both government and the nuclear industry must openly declare agendas with foreign partners and stakeholders as far as all nuclear and uranium mining activities are concerned.

F. HEALTH SAFETY & LIABILITIES AND THIRD PARTY INSURANCES

I submit that the Scoping Process addresses the following:

1. A thorough investigation into the liabilities and third party insurances policies that exist and what is expected by civil society, human and environmental rights and democracy watchdogs. These policies must take into consideration not only the nuclear power station, but once again, cradle-to-grave issues including uranium mining, transportation of nuclear substances, and waste. What exists in South Africa should be measured against international best practise – possibly Austria – and result in meaningful recommendations to the government.

2. A thorough investigation into well documented reports on ionizing radiation, dose standards and the health effects of all substances involved in the full fuel cycle of the nuclear power station. The criteria applied to this investigation must be acceptable to civil society groups and not merely take into account the views of pro-nuclear groups.

3. Transparent and independently monitored epidemiological studies and medical surveillance programmes for all affected areas within a 100km radius of installations, along all the transportation routes and radioactive waste repositories to begin prior to developments. Mechanisms for ongoing transparent and independently studies and programs must be considered as well as recourse for those nuclear workers and members of the public who become afflicted from any illness or genetic deformities that are identified as having potentially been caused by ionizing radiation or any other activities conducted at nuclear installations or sites.

4. The establishment of hospitals or clinics near affected communities – either underground or to be placed in the area for least possible fallout from wind direction.

5. Evacuation plans must be drafted that take into account scientific knowledge of wind speed, other nuclear disasters to include as wide as possible area and not the bare minimum. The costs of the exercise, who will be paying, where people will be taken to, how they will get there, how they will be informed, what will happen to them once they are removed from their homes are also among the issues that need to be addressed.

6. The recourse available to nuclear workers as well as members of the public where disputes arise that involve the infringement of human and environmental rights, health and safety issues.

7. Mechanisms for the ongoing independent monitoring of health, safety, environment and maintenance issues at the nuclear power station and all auxiliary and ancillary industries and associated infrastructures.

8. Mechanisms whereby whistle-blowers are protected from intimidation and threats in order to alert the public of abuses at the nuclear power stations and associated infrastructures.

9. A clear outline of which government organisations are responsible for and accountable on issues relating to the health, safety, maintenance, environmental and human

monitoring. These are to consider ways of providing maximum transparency and avenues for recourse; and to provide the public with a thorough understanding of who is criminally or legally responsible for substances and materials each step of their existence.

G. SPECIFIC ENVIRONMENTAL ISSUES

1. The implications of these developments on the region’s water supply2. The implications of returning heated sea water used for cooling purposes back into the

ocean on global warming and marine life.3. The exact nature of the sea water that is returned to the ocean – its radioactive content,

and other additives gained during the cooling process – and what the implications are taking into account not only what our nuclear industry asserts is their experience at Koeberg, but what has been discovered by environmental justice groups globally.

4. It would be wise to inform and involve Namibia, as the strong Benguela current would carry any radioactive contamination from SA shore North to Namibia and eventually Angola. This was the case even in the Irish Sea, where radioactive from the British side found it sway to the Irish coast and provoked a strong reaction from the Irish Government. In other words, the transnational nature of radioactivity must be factored in.

5. The effect of radioactivity on dolphins sensory and migratory patterns in particular, as well as the effect that radioactivity and other waste effluent generated by these nuclear power stations or auxiliary industries which may end up in the ocean should be studied.

6. Because specific concerns about nuclear power stations are not necessarily known to ordinary people, it is highly recommended that international experts who have studied the issue for many years internationally be consulted. A starting point is to contact those listed below in the list of suggested stakeholders.

THE REGULATOR, PSIFs, PAIA AND RULE OF POWER vs RULE OF LAW

1. The stated role of the National Nuclear Regulator has never been meaningfully fulfilled and historically there is a mountain of evidence that shows the NNR is neither transparent nor necessarily objective and that it merely serves the interests of the DME and the nuclear industry. It is therefore submitted that this Scoping Process address the issue and consider civil society concerns so as to either provide a mechanism for independent monitoring or civil society involvement in the NNR or recommend the establishment of an auxiliary regulator, under the transparent control of Environmental Affairs which has veto rights over the existing NNR.

Oversight and independent monitoring of the processing of licenses and applications should be provided if there is to be any real concern for “the protection of persons, property and the environment against nuclear damage… etc”. The NNR’s current approach reflects its direct conflict of interests between civil society and industry. The Scoping Process should therefore also consider the possibility that a regulator which is truly accountable for persons, private property and the environment report directly to a non-aligned, autonomous and democratically established “Environmental Watchdog”.

2. The Scoping Report must address the full extent of what is envisaged in terms of the NNR’s public participation process, dates, deadlines and requirements from the public, possible results from participation in such a process.

3. In addition, mechanisms need to be created whereby the so-called Public Safety Information Forums constituted by the NNR are truly representative of civil society so that these bodies do not become extensions of the nuclear industry itself.

4. Mechanisms for efficient and accurate Access to Information insofar as all the health, safety, environmental, surveillance, emissions, waste, and economic issues of the nuclear power station are concerned need to be addressed.

5. For all the above reasons, the Scoping Process should also address mechanisms whereby civil society is able to obtain unhindered access to the Constitutional court or human rights commission.

GLOBAL FEARS OF TERRORISM, PROLIFERATION OF NUCLEAR WEAPONS

Despite assurances by governments and nuclear industry in general, fears concerning the terrorism, the proliferation of nuclear weapons and the production of weapons-grade nuclear material during the process of operating nuclear power stations is an undeniable reality. Although the South African government has signed the Non-Proliferation Treaty, it has not gone beyond bare minimum efforts to instil a sense of security in the South African public that at any time in the future, or with a change of government at any time in the future, these threats may have a real impact on the South African public.

It is therefore suggested that the Draft Nuclear Policy clearly outlines exactly to which international treaties, protocols, agreements, organisations, groups and bodies etc South Africa has become a signatory or member, and how many others exist that are available to the global nuclear industry which provide checks and balances to which South Africa has not yet become a signatory or not yet ratified it’s memberships.

Additionally, the Nuclear Policy should consider “worst case scenarios” of sabotage and acts of terrorism that could be inflicted on these nuclear power stations or any of the auxiliary industries and study the likely effects of these on both the environment, surrounding populations and country as a whole.

”INTERNATIONALLY ACCEPTABLE” STANDARDSThe nuclear sector in this country, and elsewhere in the world, consistently hide behind the claim that it practises so-called “internationally acceptable standards”. Internationally these standards have been questioned and consistently more stringent standards have been applied. These still fall short of expert warnings. Until such time as the precautionary or “no dose is a safe dose” applies, the term “internationally acceptable” can only be viewed as a smokescreen by the industry to get away with murder.Below is a press release from international groups on the issue of the World Health Organisation being subordinated by the International Atomic Energy Agency (IAEA) in research on radiation and health.

20/09/2007 : WHO Action Group Press release 20 September 2007WHO (World Health Organisation) accused of non assistance to population in danger (To insist on WHO independence in the face of severe obstruction of truth from the IAEA over the effects of the Chernobyl disaster)

WHO (World Health Organisation)accused of non assistanceto populations in danger

Press release 20 September 2007

The objective, summarized in a letter to Margaret Chan, Director-General, WHO, and displayed on the website of the group http://independentwho.info, is ambitious: amend the agreement between WHO and the International Atomic Energy Agency, which was signed in 1959 and which, among other things,

stipulates (Art. 1,3) that “Whenever either organization proposes to initiate a programme or activity on a subject in which the other organization has or may have a substantial interest, the first party shall consult with the other with a view to adjusting the matter by mutual agreement”.

According to the protesters, the agreement, in practice, operates in favour of the IAEA, promoter of commercial nuclear power, and this, they assert, is the reason why WHO neglects the health of populations affected by radioactivity. It is taboo to discuss low dose, ionising radiation, explains Michel Fernex, President of the Association Les Enfants de Tchernobyl Belarus and Professor Emeritus of the Faculty of Medicine of Basel.

“Negationism”In regular contact with colleagues in Ukraine, the Russian Federation, and Belarus – including the Rector of the Gomel Institute, Iouri Bandachevsky, who was imprisoned for a time for having undertaken studies on children, he has struggled for years against “negationism”. In April, he was one of the first, with Wladimir Tchertkoff, writer and film maker, to be one of the sandwichmen in front of WHO.

Both point out that in 2005,the IAEA claimed that the Chernobyl catastrophe had resulted in 32 victims and 4000 thyroid cancers, in a document co-signed by WHO. According to Fernex and Tchertkoff, many studies and independent research undertaken in the zone around Chernobyl, among the population, victims of chronic low dose contamination with Cesium 137, have been censored or ignored -studies for example on the increase in diabetes in children or congenital malformations.

They also observe that to this day, WHO has not published the proceedings of two international conferences, Geneva (1995) and Kiev (2001) at which hundreds of specialists, whose views on the health consequences of Chernobyl differ, participated.

The campaign « For an Independent WHO » has maintained a permanent presence at the entrance of the WHO headquarters in Geneva, Switzerland, for nearly six months now.

Since 26 April 2007, one or two people stand in front of WHO from 8 till 6, Monday to Friday. On a large panel next to them is written “One million children in the area around Chernobyl, contaminated, ill, ignored by WHO”.

Many WHO employees and staff of other international organisations, curious about the action and the nature of the « crime » visit the people of the “permanent presence”. They have been astounded to discover the reasons behind WHO’s neglect of the health conditions of affected populations.

Insiders report that the campaign is a source of considerable interest and some anxiety for WHO’s senior staff. The truth about the cover up is likely to be revealed soon thanks partly to the false claim by a WHO spokesperson that the proceedings of the international consultation held in Geneva in 1995 and Kiev in 2001, on the health consequences of the accident, were duly published.

The aim of this unprecedented action is to ensure that WHO recovers complete freedom of action, in line with its constitutional mandate, in relation to care and protection of affected populations. The campaign condemns the subordination of WHO to the International Atomic Energy Agency (IAEA) in research on radiation and health. According to the little known Agreement signed in 1959, WHO recognises that the objective of the IAEA is “to

accelerate and enlarge the contribution of atomic energy to peace, health and prosperity throughout the world”. The IAEA is thus judge and jury in relation to the health risks of nuclear activities.

As a result of this agreement, WHO still claims today, 21 years after the Chernobyl catastrophe, that there have been only 56 victims. Between 600 000 and one million « liquidators » saved Europe by extinguishing the fire and constructing the sarcophagus. Many of these men suffer and die in atrocious circumstances. The same cover up operates in relation to the health effects of depleted uranium 238 in weapons used in Kosovo, Kuwait, Afghanistan and Irak.

Since the existence of this agreement and its effects on WHO’s work were discovered, the director general’s office has received many petitions and letters. In 2001, the Swiss Minister of Health, Ruth Dreifuss, supported by the Ministers of Health of Norway and Canada, requested that the matter be placed on the agenda of the World Health Assembly. No opposition was expressed. Despite this, the agreement has still not been put in question.

Next steps of the Campaign

Around forty people attended the General Assembly of the group «Independent WHO» held in Geneva, 15/16 September. Four decisions were taken:

1. The permanent presence will continue until WHO recovers complete independence in line with its constitution: “to act as the directing and coordinating authority on international health work, to promote and conduct research in the field of health, to provide information, counsel and assistance in the field of health, and to assist in developing an informed public opinion among all people on matters of health (Article 2a, n, q and r) in relation to protection of populations subjected to nuclear risks, in particular in the territories around Chernobyl.

2. The group will organize a series of activities to commemorate the 22nd anniversary of the Chernobyl catastrophe on 26 April 2008 and at the World Health Assembly in May 2008.

3. A resolution will be proposed in January at the Executive Board for inclusion on the agenda of the World Health Assembly in May 2008. The resolution will demand revisions to the 1959 WHO/IAEA Agreement, care and protection of populations contaminated by the Chernobyl catastrophe, and the establishment of a Commission of independent experts on ionising radiation and the effects of chronic, internal, low dose radiation on the genome and on health. This Commission must include all studies undertaken by independent researchers who will report their results at the 2009 World Health Assembly.

4. An International Appeal by Health Professionals to the WHO will be launched by the group. This Appeal will request that the WHO undertake independent research in the national territories concerned, in particular the three countries most affected by the Chernobyl catastrophe – Ukraine, the Russian Federation and Belarus – to study radiocontamination and its effects on population health and to communicate the results to the newly established Commission of independent experts on radiation and health.

Organized by :

• CRIIRAD,• The network Sortir du Nucléaire,• Contratom, Geneva,• SDN Loire et Vilaine,• Compagnie Brut de Béton, • Enfants de Tchernobyl Belarus

• With the support of 40 international NGOs

Contact : Yann Forget (Coordinator)+33 (0) 450 92 64 69 ; +41 (0)79 489 66 01 (mobile)

Philippe de Rougemont• 41 (0)22 344 38 31 + 41 (0)76 517 00 20 (mobile)

Photographs and more detailed information are available on :http://independentwho.info/info@independentwho.info

Link : http://independentwho.info/

I SUGGEST THE FOLLOWING STAKEHOLDERS BE INVOLVED IN THE PROCESS OF FORMULATING A NATIONAL POLICY ON ENERGY:

1. All citizens of this country – notification by means of repeated national advertising using all television stations, all radio stations, national and all community newspapers and information packages handed personally to all inhabitants (landowners, labourers etc) within a 100km radius of each proposed nuclear power station. Such advertising should not be biased in favour of nuclear energy and should be run for a period of 6 months to ensure.

2. Transnational interests – where countries like Namibia, for example, may be affected by the strong Benguela current carrying radioactive contamination from the SA shore north to Namibia and eventually Angola, environmentalists and possibly the governments of these countries should register as I&APs.

3. Environmental groups like Earthlife Africa, groundWork, Green Connections, Biophile, Energy Caucus, and others suggested by these groups.

4. COSATU and NUM – Derek Elbrecht delbrecht@num.org.za5. Dr David Fig - davidfig@iafrica.com6. Sustainable Energy Africa Leila Mohomed - leila@sustainable.org.za7. In light of the perplexing lack of independence of expert knowledge that has not already

been co-opted by the nuclear industry in SA, below is a list of organisations who should be contacted to provide suggestions for experts to be involved in the process. (Where email addresses are not provided, the listed websites below contain active links):1. “An Inconvenient Truth” campaign leader, former vice-president of the US, Al Gore

(particularly on the prognosis for fading coastlines in the face of climate change effects globally). Al Gore’s spokesperson, Kalee Kreider at Kalee@carthagegroup.com or via2100 West End Avenue Suite 620Nashville, TN 37203USA

2. Massachusetts Institute for Resource and Security Studies – Gordon Thompson info@irss-usa.org

3. WISE Uranium Project via wiseamster@antenna.nl4. WISE (World Information Service on Energy)

wiseamster@antenna.nl5. Low-level Radiation Campaign www.llrc.org 6. Institute for Energy and Environmental Research http://www.ieer.org/

Arjun Makhijani, Ph.D. ieer@ieer.org 7. Nuclear Information and Resource Service (NIRS) Michael Mariotte

nirsnet@nirs.org8. Nuclear Policy Research Institute (NPRI) info@nuclearpolicy.org

Led by Dr. Helen Caldicott, educates the American public through the mass media about the medical, environmental, political and moral consequences of nuclear weapons, power and waste.

9. Physicians for Social Responsibility (PSR) National organization working for nuclear disarmament, environmental protection and violence prevention. Also see PSR-Madison.

10. Union of Concerned Scientists National organization with educational and advocacy programs on energy, agriculture, arms control and more.

11. Center for Health, Environment and Justice (CHEJ) Helps people and organizations organize and unify to hold industry and government accountable and work toward a healthy, environmentally sustainable future.

12. ECODEFENSE! Anti-nuclear campaign of the Socio-Ecological Union, Russia.

13. Radiation Effects Research Foundation 14. The Oxford Research Group www.oxfordresearchgroup.org.uk

15. Jan Willem Storm van Leeuwen storm@ceedata.nl 16. European Committee on Radiation Risk (ECRR) – Chris Busby or Rosalie Bertell

www.euradcom.org17. ILEX Energy Consulting.18. Stephan Thomas stephen.thomas@gre.ac.uk

19. Jim GreenJim Green is the director of the Beyond Nuclear Initiative in Australia. Email:

jim.green@foe.org.au.

Beyond Nuclear Initiative, a project supported and led by Friends of the Earth, Australia,

supports and strengthens existing campaigns for a nuclear-free Australia. The Beyond

Nuclear Initiative is campaigning against: the expansion of the uranium mining industry in

Australia; against the imposition of a nuclear waste dump on the Northern Territory; in support

of a clean energy future; and against proposals to use nuclear power as a climate-change

abatement strategy. www.foe.org.au.

20. Mike McCally, MD.Mike McCally is executive director of Physicians for Social Responsibility. Dr. McCally is a

public health physician and most recently was Professor and Vice Chairman of the

Department of Community and Preventive Medicine at the Mount Sinai School of Medicine in

New York, where he was Co-Director of the Center for Children’s Health and the

Environment. He holds a B.A. in English Literature from Princeton University, an M.D. from

Western Reserve University, and a Ph.D. in Physiology from Ohio State University. He has

held positions in academic medicine and hospital administration as well as the foundation

community. Dr. McCally is active in public health advocacy organizations and medical

organizations concerned with militarism and nuclear war. He has served on the board of

directors of Physicians for Social Responsibility (PSR) for many years and as its President in

2004. Dr. McCally was Treasurer of International Physicians for the Prevention of Nuclear

War when it won the 1985 Nobel Peace Prize. Dr. McCally’s most recent book is Life Support:

The Environment and Human Health, published by MIT Press in 2002. Tel: 202.667.4260 /

Email: mmcally@psr.org.

Physicians for Social Responsibility Security Program

21. Karl GrossmanKarl Grossman serves on the board of Beyond Nuclear at NPRI. Karl Grossman is a full

professor of journalism at the State University of New York at Old Westbury and coordinator

of the Media & Communications Major at the college. For 40 years he has pioneered the

combination of investigative reporting and environmental journalism in a variety of media. He

is the host of the nationally syndicated television program "Enviro Close-Up" and writer and

narrator of award-winning TV documentaries including "Three Mile Island Revisited", "Nukes

in Space: The Nuclearization and Weaponization of the Heavens" and "The Push to Revive

Nuclear Power." He is the author of six books including "Cover Up: What you are not

supposed to know about nuclear power," "Power Crazy" and "The Wrong Stuff: The Space

Programs' Nuclear Threat to our Planet." Grossman has received numerous awards for

investigative reporting including the George Polk, James Aronson and John Peter Zenger

Awards. His TV documentaries have received Gold and Silver Awards at the WorldFest-

Houston International Film Festival and other honors. His journalism has been repeatedly

cited by Project Censored, the media initiative at Sonoma State University, as involving the

most "under-reported" issues. Email: kgrossman@hamptons.com.

22. Dr. Joseph GersonDr. Joseph Gerson has served the American Friends Service committee since 1976 and is

currently Director of Programs and Director of the Peace and Economic Security Program for

the AFSC in New England. His program work focuses on challenging and overcoming U.S.

global hegemony: its preparations for and threats to initiate nuclear war, and its military

domination of the Asia-Pacific and the Middle East. He has been involved in the U.S. justice

and peace movements since the mid-1960s. His work with AFSC has included helping to

launch the nuclear freeze movement of the 1980s, preventing New England harbors from

being transformed into nuclear weapons bases, helping to build the U.S. and global anti-

bases and nuclear weapons abolition movements, and helping to create peace and anti-war

coalitions in the Boston area and across New England. His books include The Sun Never

Sets, With Hiroshima Eyes and, most recently, Empire and the Bomb. Tel: 617-661-6130 /

Email:jgerson@afsc.org.

The New England Peace and Economic Security Program is a program of AFSC.

http://afsc.org/newengland/nepeace.htm

23. Bruce GagnonBruce Gagnon is coordinator of the Global Network Against Weapons & Nuclear Power in

Space. He was a co-founder of the Global Network when it was created in 1992. From 1983–

1998 Bruce was the State Coordinator of the Florida Coalition for Peace & Justice and has

worked on space issues for more than 20 years. In 1987 he organized the largest peace

protest in Florida history when over 5,000 people marched on Cape Canaveral in opposition

to the first flight test of the Trident II nuclear missile. He was the organizer of the Cancel

Cassini Campaign (launched 72 pounds of plutonium into space in 1997) that drew enormous

support and media coverage around the world and was featured on the TV program 60

Minutes. In 2006 he was the recipient of the Dr. Benjamin Spock Peacemaker Award. He

frequently travels and offers reflections on organizing and the state of America's declining

empire. Visit Bruce’s blog at: http://space4peace.blogspot.com. Tel: 207.443.9502 / Email:

globalnet@mindspring.com.

Global Network Against Weapons and Nuclear Power in Space opposes U.S. space

domination, the use of nuclear- powered space probes and the deployment of weapons in

space. www.space4peace.org.

24. John BurroughsJohn Burroughs is a specialist on treaty regimes and international law relating to nuclear and

other non-conventional weapons. He represents LCNP in Nuclear Nonproliferation Treaty

(NPT) review proceedings, the United Nations, and other international forums. In 1998, Dr.

Burroughs represented LCNP at the negotiations on the International Criminal Court in Rome,

and in 1995, he was the nongovernmental legal coordinator at the hearings on nuclear

weapons before the International Court of Justice. Dr. Burroughs is co-editor of Rule of Power

or Rule of Law? An Assessment of U.S. Policies and Actions Regarding Security-Related

Treaties, Apex Press, 2003, to which he contributed the chapter on the NPT, and author of

The Legality of Threat or Use of Nuclear Weapons: A Guide to the Historic Opinion of the

International Court of Justice, Transaction Publishers, 1998. He has published articles in the

Bulletin of the Atomic Scientists and the World Policy Journal, most recently co-authoring

"Arms Control Abandoned: The Case of Biological Weapons" (World Policy Journal, summer

2003). He is an adjunct professor of international law at Rutgers Law School, Newark, where

he teaches a seminar on legal controls on weapons of mass and indiscriminate destruction.

He has a J.D. and Ph.D. from the University of California at Berkeley and a B.A. from

Harvard.Tel: 212.818.1861 / Email: johnburroughs@lcnp.org.

The Lawyers’ Committee on Nuclear Policy, Inc. was founded in 1981. It is a national

nonprofit educational association that uses national and international law to promote peace

and disarmament. www.lcnp.org.

25.Jim RiccioJim Riccio is the Nuclear Policy Analyst for Greenpeace, USA, has two decades of

experience on nuclear energy policy and is considered one of the nation's most prominent

anti-nuclear activists. His advocacy experience has put his name in the country’s major

newspapers including the New York Times, Washington Post, Wall Street Journal, Los

Angeles Times, Boston Globe, as well as ABC News, the Discovery Channel and CNN

among others. From the conference rooms of the Nuclear Regulatory Commission to the halls

of Congress, Riccio has long been the voice of safe, renewable energies opposing industry

and government officials’ assertions that nuclear energy poses no safety hazard. He has

worked for Nuclear Information Resource Service as well as the Critical Mass Energy Project

at Public Citizen, one of the leading citizen activist groups founded by Ralph Nader. Riccio

has a Bachelor's degree in International Relations and Political Science from Colgate

University and a J.D. from Syracuse University. Tel: Greenpeace Media Department 202-462-

1177 / Email: jim.riccio@wdc.greenpeace.org.

Greenpeace has grown in 30 years from a small group of dedicated activists to an

international organization with offices in more than 30 countries. The threat of global warming,

destruction of ancient forests, deterioration of our oceans, and the threat of a nuclear disaster

loom large. Greenpeace is actively working to address these and other threats.

www.greenpeaceusa.org.

26. Kay DreyKay Drey serves on the board of directors of Beyond Nuclear at NPRI. She has worked for 30

years as an advocate for the protection of the general public, workers and the environment

from the hazards of nuclear power and radioactive waste. In 1996 she chaired a statewide

campaign in Missouri, her home state, that prevented electric utilities from charging

ratepayers for construction costs of power plants prior to their completion and that led to the

cancellation of a nuclear reactor then under construction. She also led the successful

campaign against the construction of a permanent disposal bunker at the St. Louis Airport for

uranium and thorium wastes generated during the production of atomic weapons in the 1940s

and ‘50s. Through litigation, she helped achieve stricter monitoring controls over releases of

radioactive waste into the Missouri River from the Callaway nuclear plant as part of its routine

operation. Mrs. Drey conducts research and has collected materials on a broad range of

environmental issues, maintaining a library that is used by the media, government officials

and members of the public. Tel: 314.725.7676.

27. Michael MariotteMichael Mariotte, Executive Director, is the chief spokesperson for NIRS. He has led the

organization for 22 years making many television appearances and has been widely quoted in

the press. He has testified before the United States Senate and the U.S. House of

Representatives on radioactive waste transportation; radioactive metals “recycling;” the future

of the nuclear power industry; “one-step” reactor licensing; and other issues.

Nuclear Information and Resource Service is the information and networking center for

citizens and environmental organizations concerned about nuclear power, radioactive waste,

radiation, and sustainable energy issues. www.nirs.org.

28. David LochbaumDavid Lochbaum is the Director of the Nuclear Safety Project for the Union of Concerned

Scientists. Mr. Lochbaum leads UCS’s efforts to ensure the safety of nuclear power in the

United States by monitoring licensed commercial nuclear plants to identify and publicize

safety risks. He has more than seventeen years of experience in commercial nuclear power

plant start-up testing, operations, licensing, software development, training, and design

engineering. Mr. Lochbaum received a Bachelor of Science in Nuclear Engineering from the

University of Tennessee in 1979. He has been a member of the American Nuclear Society

since 1978. Mr. Lochbaum has written numerous articles on various aspects of nuclear safety

and published books entitled Nuclear Waste Disposal Crisis and Fission Stories. Tel: (202)

223-6133 / Email: dlochbaum@uscusa.org.

The Union of Concerned Scientists Security Program works to bring about a safer world

by eliminating the risks posed by nuclear arsenals and nuclear terrorism, improving nuclear

power plant safety, preventing the deployment of anti-satellite and space-based weapons,

and enhancing international dialogue on security issues. www.ucsusa.org/global_security.

29. Dr. Judith JohnsrudJudith Johnsrud, Ph.D., serves on the board of directors of Beyond Nuclear at NPRI. Her

special areas of focus and expertise are: geography of nuclear energy; its entire system of

production, utilization, and waste isolation; radiation impacts on humans and environment;

and problems of sequestration of "high-level," "low-level," and recycled radioactive wastes.

Tel: 814.237.3900 / E-mail:johnsrud@uplink.net.

30. Karl GrossmanKarl Grossman serves on the board of Beyond Nuclear at NPRI. Karl Grossman is a full

professor of journalism at the State University of New York at Old Westbury and coordinator

of the Media & Communications Major at the college. For 40 years he has pioneered the

combination of investigative reporting and environmental journalism in a variety of media. He

is the host of the nationally syndicated television program "Enviro Close-Up" and writer and

narrator of award-winning TV documentaries including "Three Mile Island Revisited", "Nukes

in Space: The Nuclearization and Weaponization of the Heavens" and "The Push to Revive

Nuclear Power." He is the author of six books including "Cover Up: What you are not

supposed to know about nuclear power," "Power Crazy" and "The Wrong Stuff: The Space

Programs' Nuclear Threat to our Planet." Grossman has received numerous awards for

investigative reporting including the George Polk, James Aronson and John Peter Zenger

Awards. His TV documentaries have received Gold and Silver Awards at the WorldFest-

Houston International Film Festival and other honors. His journalism has been repeatedly

cited by Project Censored, the media initiative at Sonoma State University, as involving the

most "under-reported" issues. Email: kgrossman@hamptons.com.

31. Michele BoydMichele Boyd is legislative director of Public Citizen’s Energy Program. She joined Public

Citizen in July 2003 as the Legislative Director. Previously, she was the Global Outreach

Coordinator and Staff Scientist at the Institute for Energy and Environmental Research. She

has two bachelor's degrees in biology and agriculture from Purdue University and a master's

degree in environmental policy from the University of Michigan.Tel: 202.546.4996 / Email:

mboyd@citizen.org.

Public Citizen Critical Mass Energy Program safeguards consumers from the impacts of

electricity deregulation, educates the public on the dangers of nuclear power while

encouraging responsible nuclear waste management, and fights against environmental

degradation by promoting clean energy alternatives. www.citizen.org/cmep.

32. Diane D’ArrigoDiane D'Arrigo is the Radioactive Waste Project Director at Nuclear Information and

Resource Service. Her main area of expertise is radioactive waste and radiation issues. She

has considerable international experience. She has closely followed so-called "low-level"

nuclear waste issues for decades, the national and international moves to deregulate nuclear

waste that would allow it to be made into everyday household items and be dumped as

regular trash. She has been with NIRS since 1986. Tel: 301.270.6477 / Email:

dianed@nirs.org.

Nuclear Information and Resource Service is the information and networking center for

citizens and environmental organizations concerned about nuclear power, radioactive waste,

radiation, and sustainable energy issues. www.nirs.org

33. Helen CaldicottDr Helen Caldicott is the founding president of Nuclear Policy Research Institute. She has

devoted the last 35 years to an international campaign to educate the public about the

medical hazards of the nuclear age and the necessary changes in human behavior to stop

environmental destruction. Born in Melbourne, Australia, Dr Caldicott trained and practiced as

a pediatrician, specializing in cystic fibrosis, before concentrating full time on the prevention of

nuclear war. She co-founded Physicians for Social Responsibility. Its international umbrella

group (International Physicians for the Prevention of Nuclear War) won the Nobel Peace Prize

in 1985. Dr Caldicott has received many prizes and awards for her work and was personally

nominated for the Nobel Peace Prize by Linus Pauling - himself a Nobel Laureate. She has

authored numerous books and articles and is the subject of several documentary films. Dr

Caldicott currently divides her time between Australia and the US where she lectures widely.

Email: info@helencaldicott.com.

The Nuclear Policy Research Institute was established by Dr. Helen Caldicott to educate

the American public through the mass media about the greatest single threat to our country's

– and indeed the world's – public health, namely the profound medical, environmental,

political and moral consequences of perpetuating nuclear weapons, power and waste.

www.nuclearpolicy.org.

34. Donald Aitken, Ph.D.Dr. Donald Aitken, Principal of Donald Aitken Associates, is a LEED™ Accredited

Professional, Affiliate Faculty Member at the Frank Lloyd Wright School of Architecture, and

Senior Consulting Scientist for the Energy Department of the Union of Concerned Scientists.

Previously he has been a staff research physicist and astrophysicist at Stanford University

and founder and Chairman of the Department of Environmental Studies at San Jose State

University. He received his Ph.D. in Experimental Nuclear Physics from Stanford University.

Dr. Aitken has twice served as national Chairman of the American Solar Energy Society. Dr.

Aitken's work has a multiple emphasis on the use of renewable energy in the electric utility

sector, on renewable energy marketing frameworks, and in architecture. Dr. Aitken is a

sought-after architectural and sustainable energy policy consultant, renewable energy policy

and architectural daylighting lecturer, and professional architectural and engineering

workshop leader. Tel: 510.649.9571 / Email: donaldaitken@earthlink.net or

info@donaldaitkenassociates.com.

Donald Aitken Associates is a multi-faced consulting firm experienced in climate-sensitive

sustainable development and building design worldwide. www.donaldaitkenassociates.com.

35. Lori Goodman Lori Goodman, is a member of the Board of Directors of DINE Care. Tel: 970.759.1908 (cell) /

Email: kiyaani@frontier.net.

DINE Citizens Against Ruining our Environment Diné is an organization by and for the

Diné, the People. Its work is mostly sponsored by volunteers and foundation grants and

members are not only those who are leaders in their communities, but all those Diné who

strive to maintain a relationship with Mother Earth based on balance and harmony. For DINE

Care, membership means taking up the cause of honoring our Earth, and honoring the

perspective toward Mother Earth that has been handed down to us from our ancestors. We

are local, community people working together on issues that affect our communities.

www.dinecare.org

36. Kevin KampsKevin Kamps covers all aspects of the nuclear fuel chain with particular expertise on

government and industry efforts to dump nuclear waste at Yucca Mountain, Nevada, as well

as on the risks of radioactive waste generation and storage at reactor sites, and

transportation through communities across the country. Prior to joining Beyond Nuclear he

was for eight years the Radioactive Waste Specialist at Nuclear Information and Resource

Service. He has traveled widely across the U.S. and overseas, speaking at many community

and governmental forums and on television, radio and at press conferences and has testified

before numerous federal, state, and local government agencies. Tel: 301.270.2209 / Email:

kevin@beyondnuclear.org.

37. Arjun MakhijaniDr. Arjun Makhijani is the president of the Institute for Energy and Environmental Research.

He holds a Ph.D. in engineering (specialization: nuclear fusion) from the University of

California at Berkeley. He has produced many studies and articles on nuclear fuel cycle

related issues, including weapons production, testing, and nuclear waste, over the past fifteen

years. He is the principal author of the first study ever done (completed in 1971) on energy

conservation potential in the U.S. economy. He is the principal editor of Nuclear Wastelands

and the principal author of Mending the Ozone Hole, both published by MIT Press. Tel:

301.270.5500 / Email: arjun@ieer.org.

The Institute for Energy and Environmental Research was established to provide people

with literature which has a quality equal to that in scientific journals, but which doesn't require

you to go back to college to get a degree in science to understand it. www.ieer.org.

38. Tom Goldtooth Tom Goldtooth (Dine'/Dakota) is the Executive Director of the Indigenous Environmental

Network. He oversees the work of IEN and assists IEN staff organizers, affiliates, sister

organizations and indigenous communities in organizing, training and policy work around

environmental protection, energy, climate, toxics & environmental health, water, globalization,

and building sustainable communities. Tel: 218.751.4967 / Email: ien@igc.org.Indigenous

Environmental Network is a network of Indigenous Peoples empowering Indigenous Nations

and communities towards sustainable livelihoods, working towards environmental justice and

maintaining the sacred fire of our traditions. www.ienearth.org.

39. Diane CurranDiane Curran is a partner in the law firm of Harmon, Curran, Spielberg and Eisenberg, L.L.P.

A nationally recognized expert in the field of nuclear safety law, Diane has spent over twenty

years representing citizen groups, state and local governments, and individuals in a wide

range of licensing and enforcement cases relating to nuclear facilities. Diane has litigated the

requirements of the Atomic Energy Act, the National Environmental Policy Act, the Safe

Drinking Water Act, the National Historic Preservation Act, and other environmental protection

laws in a broad array of administrative proceedings before the U.S. Nuclear Regulatory

Commission. She has appealed numerous NRC licensing and rulemaking decisions to the

U.S. Courts of Appeals, and she has brought Clean Water Act and Freedom of Information

Act enforcement cases in federal district court. Tel: 202.328.3500 / Email:

dcurran@harmoncurran.com.

Harmon, Curran, Spielberg & Eisenberg, L.L.P specializes in providing legal advice to

nonprofit organizations and individuals in the areas of: Nonprofit Organization Tax law;

Election law; Employment law; Environmental law.

http://www.harmoncurran.com.

40. Julia Huff Professor Julia Huff specializes in environmental law and environmental litigation. She also

has expertise in land use and real estate law. Professor Huff received a B.A. in English and

philosophy from Michigan State University, with high honors, her J.D. from the University of

Iowa College of Law, with distinction, and her LL.M. in Environmental Law, summa cum

laude, from Vermont Law School. In 2003, she joined the Vermont Law School faculty as an

assistant professor of law and the first assistant director of the Environmental and Natural

Resources Law Clinic. Tel: 973.353.5695 / Email: jhuff@kinoy.rutgers.edu.

Rutgers Environmental Law Clinic serves two vital and interdependent functions: providing

an opportunity for law students to practice environmental advocacy and serving New Jersey's

environmental community through trial and appellate litigation, administrative advocacy and

policy development. http://law.newark.rutgers.edu/clinics_environment.html.

41. Linda GunterLinda Gunter is the media and development specialist for Beyond Nuclear. Prior to creating

Beyond Nuclear she worked as a journalist, in public relations and led the media and

development efforts at three national environmental nonprofit organizations. She is the co-

author, with Paul Gunter, of Licensed to Kill, a landmark report on the impact to marine

animals from the routine operation of coastal nuclear reactors.

Tel: 301.270.2209 / Email: linda@beyondnuclear.org.

42. Cindy FolkersCindy Folkers specializes in radiation impacts on health and manages the administrative

operations of Beyond Nuclear. Prior to joining Beyond Nuclear, she specialized in radiation

impacts on health at Nuclear Information and Resource Service where she held a number of

responsibilities during her 12-year tenure. She communicates with members of the public,

U.S. Congress, the press, and national and international agencies on radiation and health

regulation and science, climate change, U.S. energy legislation and activities on Capitol Hill.

She has traveled and spoken at public meetings, conferences and academic symposia.

Tel: 301.270.2209 / Email: cindy@beyondnuclear.org.

43. Kevin KampsKevin Kamps covers all aspects of the nuclear fuel chain with particular expertise on

government and industry efforts to dump nuclear waste at Yucca Mountain, Nevada, as well

as on the risks of radioactive waste generation and storage at reactor sites, and

transportation through communities across the country. Prior to joining Beyond Nuclear he

was for eight years the Radioactive Waste Specialist at Nuclear Information and Resource

Service. He has traveled widely across the U.S. and overseas, speaking at many community

and governmental forums and on television, radio and at press conferences and has testified

before numerous federal, state, and local government agencies. Tel: 301.270.2209 / Email:

kevin@beyondnuclear.org.

44. Paul GunterPaul Gunter covers all aspects of the nuclear fuel chain with a special focus on reactor

operations. He previously served for 16 years as the Director of the Reactor Watchdog

Project for Nuclear Information and Resource Service. He is a lead spokesperson on nuclear

reactor hazards and security issues and acts as the regulatory watchdog over the U.S.

Nuclear Regulatory Commission and the nuclear power industry. He has made national and

regional television and radio appearances and is frequently quoted in the press. He was a

cofounder of the antinuclear Clamshell Alliance in 1976 to oppose the construction of the

Seabrook (NH) nuclear power plant through non-violent direct action. An activist and energy

policy analyst, he has been an ardent critic of atomic power development for more than 30

years. Tel: 301.270.2209 / Email: paul@beyondnuclear.org

Beyond Nuclear aims to educate and activate the public about the connections between

nuclear power and nuclear weapons and the need to abandon both to safeguard our future.

Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic.

The Beyond Nuclear team works with diverse partners and allies to provide the public,

government officials, and the media with the critical information necessary to move humanity

toward a world beyond nuclear. www.beyondnuclear.org.

I thank youRespectfullyDominique Gilbert

CoordinatorPelindaba Working Group

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.