Submission to : Royal Commission into the nuclear fuel cycle

Submission by : Repower Port Augusta (Community Group), Port Augusta

Issues Paper Three : Generation from Nuclear Fuels

Q 3.1 Are there suitable areas in South Australia for the establishment of a nuclear reactor for generating electricity? What is the basis for that assessment?

Nuclear power is not a suitable technology for South Australia, which can be reliably 1 powered by 100 percent clean, renewable energy ,​ without the potential risks of .

Port Augusta was cited by the Australia Institute as a potential site for a nuclear power 2 plant .​ While we understand it is not the Royal Commission’s role to select sites, Repower Port Augusta opposes the establishment of a nuclear power station in our community.

After living with the health impacts of burning coal at the Port Augusta power stations that will close by 2018 at the latest, the Port Augusta community has campaigned for investment in a renewable energy transition from coal, specifically for concentrated solar thermal with storage. The risks associated with nuclear power, to be detailed further in this submission, should not be placed upon our community - after living with the associated impacts of coal for decades we deserve the opportunities provided by a clean, renewable future.

Any assessment of the suitability for a nuclear facility in Australia or South Australia would need to consider technical, social and environmental issues including: ● The full economic cost of building and operating a Nuclear Plant including the mining, processing, operation, decommissioning and storage of waste disposal over the full lifetime of the nuclear cycle. ● Built on the coast for adequate supply of seawater for cooling (current technology reactors at least); ● Adequate forethought would need to be given to cater for expected sea level rises over the expected lifetime; ● Proximity to grid connection points; ● Population density; ● Geological and seismological factors; ● Adequate buffers to populated areas; ● Extreme weather risk ● Pollution dispersion risk ● Impact on local environment

1 Dr Mark Diesendorf for Conservation SA, 100% Renewable Electricity for South Australia, June 2015. ​ ​ Ellison, et.al. “Simulation modelling of 100% renewable energy in the Australian Electricity Market” in Energy Policy ​ 45:606-613, 2012. 2 Andrew Macintosh (The Australia Institute), 'Siting Nuclear Power Plants in Australia Where would they go?', 2007 www.tai.org.au/documents/downloads/WP96.pdf

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● Indigenous heritage ● Health risks of a nuclear plant

Q 3.2 / 3.3 Are there commercial reactor technologies (or emerging technologies which may be commercially available in the next two decades) that can be installed and connected to the NEM? If so, what are those technologies, and what are the characteristics that make them technically suitable? What are the characteristics of the NEM that determine the suitability of a reactor for connection?

Are there commercial reactor technologies (or emerging technologies which may be commercially available in the next two decades) that can be installed and connected in an off-grid setting? If so, what are those technologies, and what are the characteristics that make them technically suitable? What are the characteristics of any particular off-grid setting that determine the suitability of a reactor for connection?

Nuclear power is not worth the risk, especially with the existence of clean, renewable technologies such as concentrated solar thermal with storage to provide South Australia with on-demand dispatchable energy.

Globally, the economic case for nuclear energy does not stack up and is not improving. According to the World Nuclear Industry Status Report 2015, since 2000 355 gigawatts of wind and 179 gigawatts of solar was added globally compared to 20 gigawatts of nuclear power. Taking into account the retirement of nuclear facilities the amount of 3 nuclear power being used globally actually fell by 17 gigawatts .​

In recent years the nuclear industry has been plagued with delays, of 62 reactors under 4 construction at least three quarters are delayed .​ The major French nuclear company Areva has been downgraded to junk status by Standard & Poor and has had a value 5 loss of 90% since 2007 .​

The shift South Australia is undergoing with more variable renewable sources such as wind and solar PV make firm inflexible capacity such as nuclear unfit for the flexibility required to effectively compete in the South Australian electricity market. The recently announced early closure of the Port Augusta coal stations is an example of that. Flexible, on demand renewable capacity provided by solar thermal with storage and battery storage is a more suitable and less risky option for South Australia.

Q3.4 What factors affect the assessment of viability for installing any facility to generate electricity in the NEM? How might those factors be quantified and assessed? What are the factors in an off-grid setting exclusively? How might they be quantified and assessed?

3 Mycle Schneider, et al. “World Nuclear Industry Status Report” 2015 p.17. 4 ibid, 12. 5 ibid. 2

Australia can reach a very high proportion of its from existing 6 renewable resources, and South Australia certainly can .​ South Australia should be taking a holistic approach to planning its future generation. This mix should aim to meet our power needs at a fair price, provide jobs and not contribute to global warming. South Australia is already undertaking a shift to intermittent renewables such as wind and PV - the best match for these intermittent technologies is flexible, dispatchable renewable generation from technologies like concentrated solar thermal with storage and solar PV with batteries. Concentrated solar thermal with molten salt storage is a highly viable option to provide a significant proportion of South Australia’s energy needs.

Q3.7 What place is there in the generation market, if any, for electricity generated from nuclear fuels to play in the medium or long term? Why? What is the basis for that prediction including the relevant demand scenarios?

South Australia’s energy needs can be met with a combination of clean, renewable energy. South Australia should continue to focus on expanding the use of its plentiful solar and wind resources rather than considering risky nuclear power.

Q3.8 What issues should be considered in a comparative analysis of the advantages and disadvantages of the generation of electricity from nuclear fuels as opposed to other sources? What are the most important issues? Why? How should they be analysed?

Safety, carbon emissions, cost, job creation, environmental concerns, community support and worker and community health should be considered when comparing the advantages and disadvantages of different forms of power generation. This analysis should be done from a South Australia wide approach, rather than facility by facility to ensure the optimum mix of energy sources is created. As argued previously, Repower Port Augusta believes this is a mix of 100% renewable energy - a mix Port Augusta wants to play a major role in with the development of solar thermal and other renewable facilities in our community.

As a community, we are well aware of the costs of certain forms of power generation. While the Port Augusta power stations provided much employment, our community was also left to deal with the health impacts of coal pollution. On the counterpoint, the early closure of the power station with a lack of a current replacement plan is having the impact of creating an uncertain future for hundreds of workers and their families and our broader community. South Australia must engage in a serious discussion about planning our future energy mix and ensuring the communities who are home to these generation facilities are well involved in the change and supported through the transition. When South Australia has the opportunity to create new, clean renewable energy jobs, we are opposed to the creation of potentially risky nuclear 7 power generation. The recent Lancet review ​ of workers in the nuclear power industry

6 Dr Mark Diesendorf for Conservation SA, 100% Renewable Electricity for South Australia, June 2015. ​ ​ Ellison, et.al. “Simulation modelling of 100% renewable energy in the Australian Electricity Market” in Energy Policy ​ 45:606-613, 2012. Zero Carbon Australia, Beyond Zero Emissions, 2010. 100% Renewables Study - Modelling Outcomes, AEMO, 2013. 7 Klervi Leuraud, et al. “Ionising radiation and risk of death from leukemia and lymphoma in radiation monitored workers: an international cohort study” in The Lancet Haematology 2:pp276-281, 2015. ​ ​ 3

provided strong evidence of “positive association between protracted low-dose 8 radiation exposure and leukemia” .​ When there are clear, clean alternatives South Australia should not pursue nuclear power generation if it creates cancer risk for workers in the power station.

Recent international experience of cost, and time delays in construction should also be 9 a point of comparison .​ The problem of climate change requires a quick transition to zero-carbon energy sources, renewable energy appears able to be built quicker than nuclear.

Q3.9 What are the lessons to be learned from accidents, such as that at Fukushima, in relation to the possible establishment of any proposed nuclear facility to generate electricity in South Australia? Have those demonstrated risks and other known safety risks associated with the operation of nuclear plants been addressed? How and by what means? What are the processes that would need to be undertaken to build confidence in the community generally, or specific communities, in the design, establishment and operation of such facilities?

South Australia does not need to risk the costs of previous accidents seen in the nuclear industry. The existence of a 100% renewable alternative means a serious risk management approach in response to events such as Fukushima would focus on transitioning our energy supply to readily available renewable energy technologies.

Q3.11 How might a comparison of the emission of greenhouse gases from generating electricity in South Australia from nuclear fuels as opposed to other sources be quantified, assessed or modelled? What information, including that drawn from relevant operational experience should be used in that comparative assessment? What general considerations are relevant in conducting those assessments or developing these models?

Greenhouse gas emissions should be quantified throughout the life cycle of any form of power generation, wherever emissions occur. Electricity generation makes up a large amount of Australia’s carbon pollution and tackling climate change requires we shift to clean power sources.

Q3.12 What are the wastes (other than greenhouse gases) produced in generating electricity from nuclear and other fuels and technologies? What is the evidence of the impacts of those wastes on the community and the environment? Is there any accepted means by which those impacts can be compared? Have such assessments making those comparisons been undertaken, and if so, what are the results? Can those results be adapted so as to be relevant to an analysis of the generation of electricity in South Australia?

South Australia should not be pursuing electricity generation that creates hazardous waste - renewable energy does not produce waste like nuclear power and should be

8 ibid, 276. 9 Mycle Schneider, et al. “World Nuclear Industry Status Report” 2015. 4

our focus.

Q3.13 What risks for health and safety would be created by establishing facilities for the generation of electricity from nuclear fuels? What needs to be done to ensure that risks do not exceed safe levels?

As noted above, there is a correlation between low dose radiation and leukemia in workers at nuclear power stations. South Australia does not need to put power station workers at risk of cancer when clean, renewable generation sources are readily available.

Q3.16 How might a comparison of the unit costs in generating electricity in South Australia from nuclear fuels as opposed to other sources be quantified, assessed or modelled? What information, including that drawn from relevant operational experience, should be used in that comparative assessment? What general considerations should be borne in mind in conducting those assessments or models?

Existing prices and international experience should be a primary determinant of modelling costs, however projections with industry experience should also be used. Cost of decommissioning should also be included in the Royal Commission’s assessment.

Repower Port Augusta notes the high priced power purchase agreement signed by the UK government for the Hinkley nuclear power station and the fact that nuclear power 10 does not appear to be reducing in cost .​ This is in contrast to renewable energy sources, including solar thermal which is a higher cost renewable technology, which are reducing in cost as the world builds more.

Appendix to Submission for Issue Paper No. 3 – Repower Port Augusta

South Australia has the opportunity to create a job rich, clean and sustainable future by investing in 100% renewable energy. Repower Port Augusta is tremendously concerned at the impact a focus on nuclear power could have both in terms of delaying this future when investment in renewable energy is required now, especially in our city which is looking for a transition beyond coal.

Repower Port Augusta urges the Commission to engage with the solar thermal and broader renewable to realise that renewable energy can provide South Australia’s electricity demand and the benefits we would receive in doing so.

Repower Port Augusta also strongly urges the Royal Commission to engage thoroughly with South Australia’s Indigenous community, noting the impact the nuclear industry has already had on Indigenous communities throughout the state.

10 ibid. 5