Faith and civil society groups warn of regulatory failure and public safety risks ahead of NNR’s 20 October deadline

With less than a week before the public comment period closes on the proposed 20-year licence extension for Koeberg Nuclear Power Station’s Unit 2, the Southern African Faith Communities’ Environment Institute (SAFCEI) warns that both Eskom and the National Nuclear Regulator (NNR) have ignored their own safety codes and international standards. Despite missing containment tests, failed monitoring systems, and unverified data, the NNR appears poised to approve Koeberg’s long-term operation.

At the heart of the concern is the Integrated Leak Rate Test (ILRT) – a mandatory containment safety test required every ten years under nuclear codes worldwide and required before license renewal. Unit 2’s last ILRT was conducted in 2015; Eskom now plans the next one only in 2026 – a full year late and post the license extension approval.

“The ILRT is one of the most important tests proving that Koeberg’s containment can prevent a radioactive accident,” says SAFCEI Executive Director Francesca de Gasparis. “To delay it beyond the licence decision means the NNR is preparing to rule on expired / out of date safety evidence. That’s a breach of procedure – and of public trust.”

Eskom’s own engineering report, approved in 2022, recognised that “successful ILRT results…are required before 40 years to provide confidence of containment integrity.”

Yet three years later, no ILRT has been conducted. Across the world, ILRTs have revealed hidden corrosion and pressure-retention failures requiring repair resulting in nuclear power plants that have safety risks being decommissioned rather than extending operational lives. “Without this test, neither Eskom nor the NNR can claim to know the true condition of Koeberg’s containment,” says de Gasparis. “This is not a bureaucratic delay – it’s a nuclear safety blind spot.”

Eskom and the NNR both assert that Koeberg follows U.S. nuclear safety standards under the American Society of Mechanical Engineers (ASME) codes. Yet those same codes require extra containment pressure tests whenever monitoring equipment fails. “By their own chosen standards, Koeberg is already out of compliance,” says SAFCEI’s energy justice coordinator Ntombizodidi Mapapu. “It’s extraordinary – both operator and regulator are ignoring the very rules they cite.”

According to Eskom’s new Time-Limited Ageing Analysis (TLAA), the containment monitoring system for Unit 2 has effectively collapsed. The TLAA admits that “strain measurements for the domes exhibit variability… the data is sparse with numerous gaps and outliers,” forcing engineers to disregard Unit 2 readings entirely and substitute Unit 1 data instead.

The same report concedes that “the increasing number of non-functioning monitoring devices is a concern” and that restoring the system is still at the pre-feasibility stage – with completion delayed until 2028–2029.

“In plain terms, Eskom no longer has reliable information about how Unit 2’s containment dome is behaving,” says de Gasparis. “The Regulator cannot make a valid safety decision when the data needed to judge containment integrity simply doesn’t exist.”

The use of Unit 1 data to infer the safety of Unit 2 is scientifically indefensible, SAFCEI adds. The two reactors have operated under different conditions and have aged differently. “The licence under consideration is for Unit 2, not Unit 1,” says Mapapu. “Approving an extension based on another reactor’s data is not science — it’s speculation.”

Eskom has also failed to implement the Impressed Current Cathodic Protection (ICCP) system designed to prevent corrosion of critical containment structures. Under international ageing-management guidance (AMP 318), corrosion protection is integral to containment safety validation. SAFCEI argues that by deferring the ICCP installation – originally promised before 2024 – Eskom is again violating its own safety framework.

“Every aspect of containment integrity – from corrosion control to pressure testing – depends on real-world verification,” says de Gasparis. “Paper assurances and extrapolated data are not sufficient for the license extension and puts the risk burden onto the people of Cape Town who would experience the impact of a nuclear radioactive accident.”

SAFCEI says the missed ILRT, failed monitoring system, and absent ICCP form part of a broader pattern of negligence that extends over two decades. Despite repeated warnings, Eskom continues to defer critical safety projects – and the NNR has permitted these breaches.

“When a regulator allows licence conditions to be violated, it ceases to regulate – it becomes complicit,” says de Gasparis. “The NNR must halt any licence decision until all overdue tests are complete and verified. Anything less would be a dereliction of duty. Nuclear safety cannot be assumed – it must be proven,” says Mapapu. “Until Eskom can demonstrate the real condition of Unit 2, the NNR must say no.”

Earlier this month, Hilary Swartz attended the National Nuclear Regulator (NNR) hearing in Atlantis, on the proposed extension of Koeberg Unit 2’s operating licence. “As someone who represents both the business sector and faith-based organisations in Atlantis, I am extremely concerned about the safety and evacuation risks linked to extending Koeberg’s operating life,” says Swartz. “Our community lives right next to the plant – we would be the first affected if anything goes wrong. We have never seen a clear or realistic evacuation plan, and many people have no transport or resources to relocate in an emergency. That is unacceptable.”

“Beyond the safety risks, extending Koeberg’s operation has wider economic implications. Businesses in Atlantis depend on stability and public confidence – but ageing nuclear infrastructure undermines both. If an accident were to occur, the consequences for our local economy, environment and families would be catastrophic. Government should be investing in renewable energy that creates jobs and protects communities, not clinging to outdated technology that puts lives at risk. Nuclear is a false solution – it does not belong in South Africa’s just transition,” adds Swartz.

With more than four million people living in the Cape Town metropolitan area, SAFCEI warns that an approval based on expired tests, missing data, and broken monitoring would set a dangerous precedent for nuclear governance in South Africa. The environmental justice organisation calls on the public to submit comments before 20 October to demand that the NNR enforces its own regulations and to require Eskom to complete all overdue safety tests before any licence extension is granted.