~...h. .~J­ ~~~1!:"" SENATOR SCOTT LUDLAM AUSTRALIAN GR.l:ENS SENATOR FOR

To the Nuclear Fuel Cycle Royal Commission Level 5, SO Grenfell Street, Adelaide SA 5000

July 29th 2015

Please find enclosed a submission to the South Australia Nuclear Fuel Cycle Royal Commission on behalf of Senator Scott Ludlam.

The Australian Greens have cautiously welcomed the idea of a Royal Commission to settle the issue of the nuclear industry in Australia once and for all. For decades there have been the protagonists for and against the industry. There have been reports and case studies, public debates, political debates but nuclear power always comes up as unfeasible and hugely unpopular.

It is disappointing that this opportunity to examine the industry has been designed to exclude so many important issues and many voices on those issues. The process, independence and good fa ith of the Royal Commission has been damaged by narrow terms of reference, an unbalanced expert panel and consultation failures in remote and regional communities.

The terms of reference have been designed to exclude any review of the existing problems with and waste management, the ongoing costs and liabilities from closed mines and processing facilities- costs that are left to the tax-payer. The panel is in no way independent or balanced; it has been dominated by the nuclear industry and their advocates.

We note complaints from Aboriginal communities in South Australia about the first round of · engagement. Many people did not know about hearings or had limited warning about hearings. Others have not been given access to documents and or do not have access to the Internet, or do not speak English. We have had reports that hearings have been held in pubs at 11am - completely inappropriate for working people, and those who wouldn't set foot in a pub.

There have been significant barriers put up for people in remote and regional communities. Inaccessible meetings and information, language barriers and the added constraint of getting submissions approved by a justice of the Peace all serve to exclude participation in the process. People in remote areas of SA have been most affected by South Australia's involvement in the nuclear industry, and they are also the ones who are most likely to be affected by any future industrial nuclear activities.

We are at a point whe~re is a crisis of confidence in the process.

Signed ... Senator Scot~Ludlam

8 Cantonment Street. 51.36, Parliament House CANBERRA ACT 2600 Fremantle, Western Australia 6160 Ph. (+61) 02 6277 3467 Ph. 08 9335 7477 1 tolrrree. 1300 733 450 Fax. (+61) 02 6277 5821 Fax: 08 9335 7499 [email protected] I scottludlam org.au

Uranium Mining and Milling

The production of uranium in Australia has declined, not increased over the last 5 years - largely due to the downward trajectory of nuclear power globally. The global demand for uranium has declined as reactors have closed, new ones have been slow to come on line or cancelled and uranium stockpiles have been built up.

Figure 1: Quantity and Value of Australian UOC Exports

12,000 . $1,200

1.0.000 $1,000 ~ ~ ~ 8,000 $800 ~ t ~

0,000 $0 06-07 07-08 08-09 0910 1.()-.11 1112 12- 13 13- 14 VOC Exi)OI'1s 7,555 • (tonnes) 9.518 10,1.40 10,114 6.950 6.918 8.391 6.701 \l'atuc $622 (A$ m•tllon) $658 $882 $1.033 $758 $610 $607 $823

(Department of Foreign Affairs and Trade- Australia's uranium production and exports 2013-2014 Annual Report)

In 2014 - 2015 Australia produced just 5,89 7 tonnes ofU30 8.

IB IS World released the Uranium Mining in Australia: Market Research Report in May 2015 showing that there are just 987 people employed in the uranium mining industry and an annual growth rate of -2.4% between 2010 -2015.

Safeguards: Countries where there has been growth in nuclear construction, including Russia, India and China are all countries that Australia previously would not sell uranium to because of concerns about nuclear weapons proliferation. As many other Countries look to phase out or slow down their nuclear programs Australia has increasingly looked to Russia, India and China to sell uranium to. To date the sales deal with India is still under review, Australia has an embargo on uranium sales to Russia, and has only made one shipment of uranium to China. Though we have made a retreat from our position on nuclear non-proliferation by allowing uranium sales to these countries there has been no pay off for the uranium sector. The cost of the uranium industry is vast; from over consumption of water, permanently leaving behind radioactive mine waste in the environment to causing division in communities, cutting off access to country. It is an industry that has time and time again broken promises of protecting the environment and workers.

In this process I would like to pose some questions for the SA Royal Commission to consider in regards to the economic case for uranium mining, and recommend the Commission reflect on the existing uranium industry in Australia: • what is the cost of regulating the uranium industry at a federal and state level -considering the time and wages and legal fees in assessments, regulations, licensing, modernising legislation, training etc • how much does the industry receive in subsidies and grants from state and federal governments • what are the costs of rehabilitation of closed uranium mines, those operational, in care and maintenance and those that have been abandoned • are there sufficient bonds held to remediate those sites - if not how much will they cost to rehabilitate

I note that a similar inquiry through the Australian Nuclear Safety and Technology Organisation in 2006- the Switkowski report suggested that; "Greater certainty in the l ong-~erm planning at Olympic Dam is desirable, coupled with guaranteed financial arrangements to cover site rehabilitation."

In fact there has never been a uranium mine in Australia that has been successfully rehabilitated. They all represent an ongoing risk to the environment and cost the taxpayer. It is these questions around corporate accountability, non­ compliance and inadequacies in the regulatory regime as well as the failures around environmental protection and workers safety that should be addressed in this commission.

While South Australians are hurting from job losses and closure of the automotive industry, the nuclear industry is one that has promised South Australians a lot, taken much more from them and has delivered very little in return. Becoming further entrenched in the nuclear complex is not the solution to creating new jobs and industry.

Enrichment

There are five really clear issues with enrichment: • It produces more waste at a higher grade to manage, we do not have a radioactive waste storage or disposal facility and there are major barriers to developing such a facility • Enrichment of uranium produces fissile materials that can be diverted to produce nuclear weapons, making enrichment a diplomatic issue and a non proliferation issue • There are technological, infrastructure and legislative barriers • Th ere is no market case for Australia to begin enrichment • As with any nuclear installation there i.s a significant legacy/decomm issioning risk

The points above are demonstrated by a number of pro-nuclear sources. The 2006 Switkowski report concluded" ... high commercial and technology barriers could make market entry difficult. Current legal and regulatory impediments would need to be removed, but there may be little real opportunity for Australian companies to extend profitably into these areas."

Former World Nuclear Association executive Steve Kidd said in 2014 "the world enrichment market is heavily over-supplied".

And BHP Billiton said "BHP Billiton believes that there is neither a commercial nor a non-proliferation case for it to become involved in front-end processing or for mandating the development of fuel leasing services in Australia."

Nuclear Power

We have to decarbonise our economy and our environment there is no question on this. How we achieve that and how we do it in a meaningful timeframe is key. This inquiry into the nuclear fuel cycle is likely to prove an expensive distraction from the renewable energy industry that is flourishing in South Australia.

Nuclear is inherently unsafe, it is increasingly expensive, notoriously slow to develop and poli tically unpopular.

Safety: The meltdowns at Fukushima have sharpened the debate over the future of nuclear energy in Australia and elsewhere. If a disaster that has created 150,000 radiation refugees was not enough to end the debate, what kind of disaster will it take?

There are three disasters often cited- Chernobyl, Three Mile Island and now Fukushima, but in fact there have been hundreds and hundreds of accidents at nuclear facilities globally since the beginning of the indus try. These have been documented by Australian Senators since 1983 most recently updated in 2011 in a publication called "Let the Facts Speak". The safety of nuclear power has not been resolved over time because human error and corporate short cuts are timeless. Regulations and safeguards are never fail safe and the ability and capacity to monitor and enforce will never be enough.

The Massachusetts Institute of Technology Interdisciplinary Study of Nuclear Power states: "We do not believe there is a nuclear plant design that is totally risk free. In part, this is due to technical possibilities; in part due to workforce issues. Safe operation requires effective regulation, a management committed to safety, and a skilled work force." Serious, unresolved problems remain on all fronts.

Technology:

The World Nuclear Industry Status report concludes that "The 'Nuclear Renaissance' appears, in retrospect, to have been a last chance for light water reactor technology. Given the failure to reduce costs- and there are few who would forecast costs are going to go down at all, much less decline to the levels originally claimed -and the apparent failure to reduce the incidence of construction overruns, the future looks bleak for light water technology ... If the nuclear industry is to have a future, it can only be through new technologies such as Generation IV designs or Small Modular Reactors. Both of these options are many years from being commercially available."

The promise of Generation IV, Fusion and Thorium are all decades away from becoming commercially viable and unlikely to ever be affordable. If the aim of this exercise is to address the very serious issue of climate change and decarbonising our economy we simply do not have time to spare to wait for technology that may or may not ever be available, safe enough to use or cheap enough to make sense.

If and when technologies become available it is likely then to take decades more to finance, construct, set up regulations other infrastructure and a skilled workforce. Given the risks and safety concerns around nuclear and the widespread public concern and opposition- nuclear is just not something you rush into.

There has been much talk of Small Modular Reactors as the fit for Australia. Steve Kidd- independent nuclear consultant and economist with East Cliff Consulting describes the realities of why SMR have never taken off as a preferred reactor type "Reactor units became progressively larger in an attempt to capture economies of scale in construction costs, but also (and very importantly) to minimise operating and maintenance (O&M) expenses." Again it is the economics of nuclear that proves the biggest barrier.

Of those older light water reactors under construction there are still major problems. The World Nuclear Industry Status report provides a great overview of the reality of new reactors under construction stating that "The most commonly cited causes of delay are: design issues; shortage of skilled labor; quality control issues; supply chain issues; poor planning either by the utility or equipment suppliers; shortage of finance; and public opposition."

If we want decentralised power scattered across the country, renewable energy options are proving to be much cheaper, much quicker to roll out and publicly acceptable. Manufacturing, installing and maintaining renewable energy technology in South Australia would be much quicker to establish and be much more accessible to the existing workforce in South Australia. Economics:

A report published by the Conservation Council of South Australia shows the trajectory of cost of nuclear vs renewables. It shows that the cost of nuclear power has grown almost exponentially as the costs of renewables continues downward.

"This is the real problem: nuclear projects have largely become too expensive and risky to offer lenders the degree of assurance they require." Steve Kidd June 2015.

The Economist published a Nuclear Energy special in 2012 with some useful detail on the cost of nuclear. "The 2010 edition of the IEA/NEA Costs of Generating Electricity study puts overnight costs for Chinese generation II plants at $1,700 for every kilowatt of capacity, giving a gigawatt plant a price tag of less than $2 billion. For the AP1000s the estimated costs are higher ($2,300 fkW) ... Still, almost anywhere else in the world, these figures would today be a source of envy or incredulity... Estimates from the Massachusetts Institute of Technology (MIT) rose from $2,208/kW to $4,000 over roughly the same time. The NEA quotes costs for an EPR in Belgium (now cancelled) at $5,400 per kW. Capacity by gas turbines, for comparison, can cost less than a fifth of that."

The US Energy Information Administration has also pointed out the competition to nuclear "Rising long-term natural gas prices, the high capital costs of new coal and nuclear generation capacity, state-level policies, and cost reductions for renewable generation in a market characterized by relatively slow electricity demand growth favour increased use of renewables." US Energy Information Administration- April 2015.

Renewable Energy:

In 2014 there was US $270 billion invested in renewable energy (excluding big hydro) a 17% increase from 2013 (World Nuclear Industry Status Report). In 2014-2015 there was a 12% growth rate in renewable energy which now provides 6% of the worlds energy (BP Statistical Review). US$ billion Global Investment Decisions In New Renowables and Nuclear Power 350 2004-201C (In US$ billion)

300

250

200

150

100

50

0 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014. [-S;.;;--Wind Other renewables - Nuclear I

Sour·c~..s. FS UNF::P 2015 and WNISR ori9mal res arch (Wcrld Nuclear Industry Statt1s Report 2015) Figure 19: Global Investment Decisions in Renewables and Nuclear Power 2004- 14

Conservation Council South Australia has done some great work in looking at the scope and scale ofthe renewable energy industry in South Australia. They have provided a positive outlook on what the growth of the energy industry could look like in South Australia. A vision the Australian Greens very much support

It is commendable that the renewable energy industry has fl ourished in South Australia providing 36% of the states energy. With or without government support it seems the renewable energy industry is there to stay and looking to expand. With government support the industry could easily beco.me world leaders not just in providing energy but also in technology, research and development and manufacturi ng. International Waste storage

There are no long-term storage solutions for nuclear waste, which is why the Australian Greens believe that nuclear industry activities should be entirely phased out and is one of the many reasons why we oppose nuclear power and enrichment.

Australia's existing nuclear waste must be stored, transported and managed in a transparent, consensual and scientific manner.

Each nation must responsibly deal with their nuclear mistakes, not transport their toxic waste 'out of sight out of mind.' Australia has in the past provided a role in supplying the fuel for the nuclear industry and to many people this equates to a responsibility to take back the waste. Since it became apparent the risk and damage caused by uranium mining and the nuclear fuel cycle Australians have lobbied and protested against the industry. Against their will many Aboriginal communities have had uranium dug up and exported from their country. It would be a cruel and twisted fate for that uranium to come back as high level long lived radioactive waste and imposed on Aboriginal communities.

We should not be mining and exporting uranium, we should not be contributing to an industry that has no way of storing its waste.

The old parties have legislated to impose nuclear waste upon unwilling communities across Australia. The senior women in South Australia and now the Traditional Owners from the Muckaty region in the Northern Territory have, through the courts, defeated plans to impose radioactive waste on their communities. This resistance will no doubt continue and be amplified at the suggestion of international waste storage.

The failed process of trying to impose radioactive waste on remote communities needs to stop. The SA Royal Commission is out of step with existing Australian and State and Territory Legislation, but is running alongside a National process for the nomination of a national site for radioactive waste. This national process has many of its own shortcomings but there is serious concern that the SA Royal Commission may influence the National process, which for the last 20 years has been fraught with issues. ·

Conclusion

Everywhere this industry touches down it leaves an imprint of misery and injury, and everywhere it goes it is challenged and fought. If each of us is called on to choose a side in the contest over nuclear energy on a warming planet, then at the very least, let the facts speak. References

BP Statistical Review http://www.bp.com/en/global/corporate/about-bp/energy­ economics/statistical-review-of-world-energy.html

Department of Foreign Affairs and Trade- Australia's uranium production and exports 2013-2014 Annual Report http:l/dfat.gov.au/about­ us/publications/international-relations/asno-annual-report-2013- 14/html/section-2/-uranium-production-and-exports.html

IBISworld http: //www.ibisworld.com.au /industry/default.aspx?indid= 185 2

Let the Facts Speak http: //scott-ludlam.greensmps .org.au /sites I default/files /l tfs-full. pdf

World Nuclear Industry Status Report http://www.worldnuclearreport.org/IMG/pdf/20150715wnisr2015-v1-lr.pdf

Steve Kidd http://www.neimagazine.com/opinion/opinionnuclear-myths-is-the-industry­ also-guilty-4598343/

Switkowski Report http://www.ansto.gov.au/ data/assets/pdf file/0005/38975/Umpner report 2006.pdf

The Economist- Nuclear Energy the dream that failed http: //www.economist.com /sites /default/files /20120310 nuclear power.pdf