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Clean Bight Alliance Australia Clean Bight Alliance Australia Submission to: Nuclear Fuel Cycle Royal Commission SA 14th August 2015 Introduction Clean Bight Alliance Australia is a local community group based in Ceduna on the far west coast of SA. Members have a strong interest in the ongoing health of the marine and coastal areas of the Great Australian Bight and the Eyre Peninsular. CBAA advocate for appropriate use of the region’s natural marine resources and educate the community on the risks associated with industrialization of the marine environment and prominent local industries such as aquaculture, fishing and tourism. Issues Paper Three: Electricity 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? CBAA take the position that there are no suitable areas in South Australia for a nuclear reactor. Currently our position is supported by legislation as Nuclear Power generation in South Australia is prohibited by the Environment Protection and Biodiversity Conservation Act 1999 Act and the Australian Radiation Protection and Nuclear Safety Act 1998. CBAA strongly encourages the Royal Commission to appreciate the background to these important pieces of legislation and implications if these were to be further altered or weakened. 1 | P a g e Furthermore Nuclear power generation requires large quantities of water for cooling – typically 36.3 to 65.4 million liters per reactor per day. 1 South Australia is known as one of the driest states on one of the driest continents. No inland areas are suitable for the establishment of a nuclear reactor for generating electricity. The amount of water needed can definitely not be sourced with current reservoirs and transportation of the large amounts of sea water required would be unfeasible and costly. Locating a Nuclear Reactor in South Australia is restricted to coastal areas. However this is also highly unsuitable as siting a nuclear reactor would conflict with other key industries (see below Q 3.17) and add unnecessary environmental impacts to South Australia’s coastal areas and marine ecologies, which are already under pressure from a range of factors2. Even if a Nuclear Reactor located on SA’s coast utilized the less damaging cooling tower system to minimize sea water usage and heated water discharge the impacts on marine life would still be at a questionable scale. CBAA’s diverse membership includes members of the local Aboriginal community who have strong affiliation and understanding of the coastal environment. CBAA’s members may have unique local knowledge but they are not unique in their outlook. South Australia is home to multiple Aboriginal communities, many who have long standing connections with coastal areas. Many groups express their cultural connection to coastal areas and coastal waters, emphasising their strong importance in physical cultural heritage, traditional economies, a place of bushfoods and medicine. This rich cultural understanding which has continued for thousands of generations must be considered in any suitability for nuclear reactor site selection. In addition to current mechanisms such as Native Title agreements, consultation and informed consent would have to ensure that communities were aware of the time frame of a nuclear reactor and possible implications for cultural heritage and continuation of cultural practices and passing on of knowledge. Restricted access to a nuclear reactor site means that cultural groups and the general public would be locked out from an area during the reactor’s lifespan - which could range from 30-60 years. This restricted access could extend well beyond this time period if there was to be any problems during decommissioning. In this way a nuclear reactor located in South Australia could irreversibly impact on physical cultural heritage, cultural knowledge and any native title rights gained which are protected by the Aboriginal Heritage Act and Native Title Act. South Australia has been put up as suitable location for nuclear reactors because of its relatively stable geology. However any stability in regards to earthquakes is countered by the unknown impacts of climate change and a likely increase in extreme conditions in South Australia3. Adequate predictions on sea level rises and how reactor technologies would cope with high temperatures would need careful technological consideration. There are already examples of Nuclear Reactor’s malfunctioning in other parts of the world because of storms, drought, high temperatures, fire and restricted water supplies – 1 Andrew Macintosh (The Australia Institute), 'Siting Nuclear Power Plants in Australia Where would they go?', 2007 www.tai.org.au/documents/downloads/WP96.pdf pg 6. and 'How much water does a nuclear power plant consume?', Nuclear Monitor #770, 24 Oct 2013, www.wiseinternational.org/nuclear-monitor/770/how-much-water-does-nuclear-power-plant-consume 2 Department for Environment and Heritage.2004. Living Coast Strategy for South Australia.http://www.environment.sa.gov.au/our-places/coasts. 3 “Climate Change Impacts in South Australia” http://www.environment.gov.au/climate-change/climate-science/impacts/sa 2 | P a g e all of which are likely to increase in severity and frequency.4 The perceived benefits are outweighed by these risks, again making a nuclear reactor for energy production in South Australia unfeasible. Other issues which rule out South Australia’s suitability are: Risks to human populations and inability to both have adequate buffers to populated areas and access to grid connectivity; Inadequate emergency services and evacuation zones Environmental impacts and risks of pollution dispersion and; Terrorism and weapons proliferation risks Finally, South Australia’s suitability for renewable energy production as demonstrated by a recent report by Mark Diesendorf clearly shows that any development of a nuclear reactor is unnecessary5. This makes a focus on nuclear risk mitigation unnecessary and a distraction from furthering South Australia’s renewable energy sector capabilities. This will be further discussed in other sections of our submission. 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? There are obviously a multitude of issues to be considered and a variety of ways they could be analysed in any comparative analysis of electricity sources. Because current and emerging sources of renewable energy, fossil fuels and nuclear may require variations to economic and political contexts such a comparison is further complicated. However CBAA believe that the long lead time in establishment of a nuclear reactor, the potential risks and high consequences of any accidents, combined with generation of high level radioactive waste outweigh any perceived advantages of nuclear over other forms of electricity generation. According to CBAA the most important issue to consider in any comparative analysis of electricity generation should be long term sustainability. This is sustainability for environment, for job creation and resource use. Decisions made now will have ramifications for generations to come. With this pragmatic approach renewable sources are far more advantageous for South Australia than nuclear or fossil fuels. Important issues to consider in any comparison should include: Efficiency and Scale Department of Energy, July 2013, 'U.S. Energy Sector Vulnerabilities to Climate Change and Extreme Weather', http://energy.gov/downloads/us-energy-sector-vulnerabilities-climate-change-and-extreme-weather and Robert Krier, 15 Aug 2012, 'Extreme Heat, Drought Show Vulnerability of Nuclear Power Plants', InsideClimate News, http://insideclimatenews.org/news/20120815/nuclear-power-plants-energy-nrc-drought-weather-heat-water 5 Diesendorf, Mark for Conservation SA, 100% Renewable Electricity for South Australia, June 2015. 3 | P a g e Does the energy source require high levels of consumption? Can production be scaled up and down in a flexible way to meet demand? Life-cycle CO2 emissions Any comparison must include emissions from mining eg. uranium and increases in emissions as resources become less concentrated and more energy intensive to recover. Finite supply Limited time scale as opposed to supply of renewable power sources such as wind, sun, wave, geothermal. Capital investment and total economic cost, including subsidies Nuclear is capital intensive and will require legislative change to implement in Australia. Evidence to suggest global nuclear industry heavily dependent on subsidies. Local expertise Unlike nuclear expertise Australia has a foundation of experience and workforce associated with renewable energy sector Job Creation Time period from planning, building, infrastructure, construction, to generation Including history of delays and complications for various energy projects Ability to be integrated into the grid Determinate of site location and scale Land/Coast/Water degradation Total area required including buffer zones Risk of major accident And the scale of impact Water Use A focus on nuclear energy will curb the exciting growth and possibilities for renewable energy sources in South Australia. During 2013-2014 37% of electricity generated in South Australia was from wind and rooftop solar. There is also a risk that nuclear
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