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Submission to the SA Nuclear Fuel Cycle Royal Commission by Friends of the Earth, Australia; the Australian Conservation Foundat

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Submission to the SA Nuclear Fuel Cycle Royal Commission by Friends of the Earth, Australia; the Australian Conservation Foundat Submission to the SA Nuclear Fuel Cycle Royal Commission by Friends of the Earth, Australia; the Australian Conservation Foundation; and the Conservation Council of SA Contacts: Dave Sweeney (Australian Conservation Foundation) Craig Wilkins (Conservation Council of SA) Cat Beaton (Conservation Council of SA) Jim Green (Friends of the Earth) CONTENTS: Page List of Recommendations 5 Issues Paper #1: Exploration, Extraction and Milling Questions 1.1 to 1.6: Uranium industry 8 Question 1.7: Uranium demand 10 The status and trajectory of nuclear power 10 Nuclear power growth forecasts 12 Ageing reactors 19 The global uranium industry 21 Australia's uranium industry 23 Arkaroola − serious failure of SA government oversight 28 Corporate governance at Beverley 28 The 2005−07 uranium bubble 31 Question 1.8: Public and worker health hazards Radiation and health 32 Radon 35 Leukemia 35 Uranium, radiation and health 37 Olympic Dam whistleblower 38 Polonium exposure at Olympic Dam 40 Uranium companies promote radiation junk science 41 Case study: the Chernobyl death toll 43 Question 1.9: Traditional Owners Introduction 46 Maralinga 46 The proposed repository in SA 51 Dumping on Muckaty Traditional Owners 56 The uranium industry and Aboriginal people 57 1 Question 1.10: Uranium mining − environmental risks Introduction 60 Olympic Dam 61 In-situ leach uranium mines 69 Question 1.11: Past uranium industry practices 74 Question 1.12: Uranium economics 77 Export revenue 77 Jobs 78 Royalties 79 Subsidies 80 Tax arrangements 80 Question 1.13: Negative impacts on other sectors 81 Issues Paper #2: Further Processing of Minerals and Manufacture of Materials Containing Radioactive and Nuclear Substances Questions 2.2 and 2.3: Manufacturing materials containing radioactive and nuclear substances 83 Questions 2.5: Manufacturing medical radiopharmaceuticals 85 Questions 2.1, 2.4, 2.13: Nuclear fuel cycle processes (conversion, enrichment, fabrication, reprocessing, fuel leasing) Conversion, enrichment, and fuel fabrication − feasibility 87 Australia's 'natural advantage'? 88 The Switkowski Review 88 BHP Billiton's submission to the Switkowski Review 89 Conversion 90 Enrichment − viability 90 Enrichment and proliferation 94 Enrichment − depleted uranium waste 95 Enrichment − Silex 96 Fuel fabrication 97 Reprocessing 97 Fuel leasing 99 Question 2.12: Safeguards 100 New reactors types − proliferation-resistant? 111 Question 2.11: Security 120 Issues Paper #3: Electricity Generation Question 3.1 Sites for nuclear power reactors 125 Question 3.2 Reactor technologies 127 Generation III reactors 127 Introduction 127 AP1000 127 EPR 130 CANDU EC6 132 South Korea's APR1400 133 Russia's AES-2006 134 Generation IV reactor concepts 135 Introduction 135 Decades away 136 Purported benefits 137 2 French government's IRSN report 139 Integral fast reactors 141 Thorium 146 Question 3.3 Off-grid reactors / Small Modular Reactors 149 Question 3.6 Best practice / less successful examples 152 Question 3.7 Medium or long term options for nuclear power 153 Question 3.8 Comparative analysis 153 Question 3.9 Lessons from accidents such as Fukushima 154 Question 3.10 Regulation 156 Question 3.11 Greenhouse emissions 161 Summary 161 Life-cycle greenhouse emissions 162 Nuclear power is not a silver bullet 164 Nuclear vs. renewables 165 Nuclear power is impractical as a short-term response 165 Nuclear winter 167 Climate change and nuclear hazards 168 Question 3.12 Wastes 170 Question 3.13 Health and safety 170 History of accidents 170 Safety challenges 171 Safety of nuclear vs renewables 172 Probabilistic risk assessments 173 Attacks on nuclear plants 173 Childhood leukemias near nuclear power stations 175 Australia's track record 178 Counterfeit, fraudulent and suspect items 180 Question 3.14 Safeguards 180 Question 3.16 Economics 180 Comparison of unit costs 180 Nuclear cost escalations and nuclear's negative learning curve 185 Generation IV reactors 188 Nuclear newcomers 188 Costing accidents 188 Nuclear liability 189 Finance 190 Question 3.17 Impacts on other sectors 190 Issues Paper #4: Management, Storage and Disposal of Waste Question 4.1: Physical conditions in SA 191 Social dimensions of risk assessment 191 Question 4.2: Wastes produced in Aust. which could be stored in SA? 192 Waste from a nuclear power program in Australia 193 Question 4.2: Storage or disposal of foreign nuclear waste 194 Introduction 194 National policies 194 A moral responsibility? 196 Questions: 4.4 and 4.11: Revenue / costs 197 Possible revenue 197 Costs 198 3 Questions 4.5, 4.8 and 4.9: Best practice and less successful examples of nuclear waste storage / disposal. Risks for health and safety. Environmental risks. 'Best practice' and 'less successful examples' 199 Hazards associated with high level nuclear waste 202 WIPP − explosion in deep geological repository 206 Question 4.6: Security 214 Proliferation issues 215 Question 4.7: Building community confidence 216 Question 4.10: Transportation 218 Serious transport incidents 218 Costs of transport accidents 219 International experience 220 Uranium transport 226 Waste transport 230 Sea transport 230 Transport security 234 Radioactive materials transport in Australia − further comments 241 Question 4.12: Impacts on other sectors 248 4 List of Recommendations Recommendation 1: The Royal Commission should ask the federal government and uranium companies supplying China what they are doing about the serious problems with China's nuclear power industry (safety, security, corruption, inadequate regulation, etc.). Recommendation 2: The Royal Commission should ask the SA government what steps have been taken to prevent a recurrence of problems such as those that arose with Marathon Resources and what regulatory and monitoring changes have been adopted in response to this situation. Recommendation 3: The Royal Commission should determine what action if any the federal and SA governments took in response to allegations of corporate impropriety by General Atomics / Heathgate as detailed in Fortune Magazine. Recommendation 4: The Royal Commission should recommend the enactment of legislation outlawing the infiltration of NGOs by mining companies. Recommendation 5: The Royal Commission should recommend the enactment of legislation outlawing police infiltration of NGOs involved in peaceful protest activities. Recommendation 6: The Royal Commission should determine the extent and adequacy of usage of protective equipment including masks at underground uranium mines (currently limited to Olympic Dam in Australia). Recommendation 7: The Royal Commission should investigate claims made by a BHP Billiton whistleblower in 2010 that the company uses manipulated averages and distorted sampling to ensure its official figures of worker radiation exposure fall under the maximum exposure levels set by government. The Royal Commission should also investigate the claim that radiation dose estimates are based on the assumption that all workers wear a respirator when exposed to polonium dust in the smelter. Recommendation 8: The Royal Commission should investigate why BHP Billiton's radiation plans were seriously outdated and why the SA government did not act to rectify the problem. The Royal Commission should seek further detail into what steps SA agencies have taken to address these deficiencies and enhance transparency. Recommendation 9: The Royal Commission should investigate FoI-based claims by MLC Mark Parnell regarding polonium exposure and reporting requirements at Olympic Dam. Recommendation 10: Uranium company representatives should explain to the Royal Commission why they have promoted self-serving contrarian views regarding radiation and health instead of promoting the accepted scientific understanding that there is no safe level of exposure to ionising radiation. Recommendation 11: The Royal Commission should investigate the use of Doug Boreham by some uranium companies to provide 'employee radiation training'. Are Boreham and uranium companies encouraging practices at odds with established OH&S advice and recommendations? Recommendation 12: The Royal Commission should determine whether the provision of contrarian advice at odds with mainstream scientific opinion meets the legislative and regulatory requirements for the provision of advice on radiological workplace hazards in SA. Recommendation 13: The Royal Commission should determine whether the provision of personal protective equipment is sufficient or if there is (or should there be) a requirement for workers to actually use protective equipment? Recommendation 14: The Royal Commission should recommend against any further uranium/nuclear developments until such time as: Laws exempting the uranium industry from Aboriginal heritage protection laws are repealed. Maralinga is cleaned up adequately. There have been independent inquiries into the mistreatment of Aboriginal people in relation to attempts to establish national nuclear waste facilities in SA (1998−2004) and the NT (2005−2014), and mechanisms put in place to prevent further such adverse processes and impacts. The use of divide and rule tactics by uranium companies against Aboriginal people is investigated and mechanisms put in place to prevent such tactics being deployed in future. Aboriginal land owners are afforded an effective veto provision over proposed mining and wider nuclear industry developments on their lands. 5 Recommendation 15: The Royal Commission should investigate the pattern of Aboriginal heritage protections and land rights
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