Clean Bight Alliance

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.

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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 (), '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 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 . 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.

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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 power generation will work against efforts to increase energy efficiency.

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?

South Australia and NEM are far better suited to an increases in renewable capacity. Flexible, on demand sources are required to compete in South Australian electricity market. Wind and Solar PV are

4 | P a g e influencing this change in the market. Concentrated solar thermal with storage could further provide South Australia with on demand dispatchable energy. There are no Commercial reactor technologies suitable for off-grid setting and again an investment in renewable technologies would be a far better use of South-Australian tax-payer funds.

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?

There are various factors (many mentioned in response to Q3.8) that create uncertainty on how fast a nuclear reactor could be built and made operational in South Australia. But given the fact that legislation would need to be changed, site selection is likely to be contentious and contested, any establishment is likely to be long and drawn out. Added to this is the nuclear industries’ poor track record with delays in construction of facilities. The establishment of a nuclear reactor would be a timely and costly way of addressing any medium or long term energy needs. In contrast current and emerging renewable technologies could readily be expanded without the high risks to the environment and community.

3.17 Would the establishment of such facilities give rise to impacts on other sectors of the economy? How should they be estimated and using what information? Have such impacts been demonstrated in other economies similar to Australia?

CBAA believe there are several key areas of the South Australian and broader Australian economy which could be impacted by the establishment of nuclear facilities. These include but are not limited to: 1. Fishing and Aquaculture 2. Tourism 3. Agriculture 4. Renewable Energy Sector

In the case of any accident impacts on 1-3 above would be greatly exacerbated. These could be results of physical disruption but also by association and reputation. Industries distant from the site of accident can be impacted as has been the case in Japan following Fukishima and over long periods as in the case in eastern Europe following Chernobyl. In addition any notable incidents or accidents linked with the facility or transport of radioactive elements could put undue pressure on: a. Emergency Services b. Hospital and Medical services c. Housing and Accommodation

Finally, a major accident, depending on location of facility could impact on large populations. If located near the capital city of Adelaide an economy worth billions and billions of dollars could be devastated.

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What would be worse however would the scale of human tragedy associated with major accidents as clearly demonstrated by Chernobyl and Fukishima.

Issues Paper Four: Management, Storage and Disposal of Nuclear and Radioactive Waste

4.1. Are the physical conditions in South Australia, including its geology, suitable for the establishment and operation of facilities to store or dispose of intermediate or high level waste either temporarily or permanently? What are the relevant conditions? What is the evidence that suggests those conditions are suitable or not? What requires further investigation now and in the future?

To the north west of Ceduna is Emu Field and Maralinga – sites of nuclear testing in the 1950s and 1960s. It is an area which at the time was chosen because of its perceived isolation, desolation and futility for other land uses. This perception has been tirelessly questioned by Aboriginal people who reiterate that the land was intimately known, cared for and a source of culture, identity and pride. From Maralinga, the Anangu Story: The Earth made Anangu proud and strong. It made them happy. They knew who they were. They knew where they belonged. They were free and they travelled their country from north to south, from east to west. They knew the red earth and the rocks, from the soles of their feet right up through their hearts and minds and memories. Memories that went back thousands of years, hundreds of generations through all the Anangu who had lived, and loved that precious land6.

The ongoing impact of mass dispossession of Anangu people because of nuclear testing on their traditional homelands has very real consequences today, for many residing on the Far Coast of SA. These include ongoing trauma and disruption of Anangu identity and resultant substance abuse and social issues. These issues are raised to illustrate that “physical conditions” cannot be separated from social consequence and as such broader costs need to be carefully assessed. Maralinga is also raised because of the interest it attracts as a potential nuclear waste dump location. The logic appears to be that it is already contaminated, so it perfect for more radioactive waste. CBAA dismiss this logic outright. Locating any type of radioactive waste, whether local or international, low- level or high at Maralinga is illogical because:  There still needs to be recognition of the suffering and ongoing impacts already incurred on Aboriginal people by nuclear testing.  Already high levels of anxiety and suspicion around unknown impacts of radiation exposure (because of inadequate monitoring and research) are likely to be heightened by presence of nuclear waste and additional risks of radiation.  Tyranny of distance means that any risks associated with nuclear waste transport are greatly exasperated.  Lack of expert technical knowledge.

6 Yalata and Oak Valley Communities, with Christobel Mattingley.2009. Maralinga. The Anangu Story. Allen and Unwin Press.Pg1.

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 Extreme temperatures mean that issues around cooling high level waste would be highly impractical.  Previous attempts to “clean up” Maralinga have been riddled with problems making the area unsafe for any earth moving works.  Highly increased radiation risk for dump construction workers and security personnel.

CBAA advocate strongly that nuclear waste management should focus on an audit of current Australian waste amounts and their type of radioactivity. Thorough investigations should be made on management options for safe maintenance at the site of nuclear waste production or centralized options that can utilize and update best practice monitoring and nuclear expertise for the long periods of time required. CBAA do not believe that the Royal Commission should repeat the mistakes of past nuclear waste site assessments which had a focus on finding an illusive ideal physical condition. The Royal Commission should instead look at the social issues surrounding any waste management options. The Royal Commission needs to work closely and immediately with the Commonwealth government in regards to its own national nuclear waste management plans so as to minimize confusion for the public.

References

Andrew Macintosh (The Australia Institute), 'Siting Nuclear Power Plants in Australia Where would they go?', 2007 www.tai.org.au/documents/downloads/WP96.pdf

“Climate Change Impacts in South Australia” http://www.environment.gov.au/climate-change/climate-science/impacts/sa

Department for Environment and Heritage.2004. Living Coast Strategy for South Australia.http://www.environment.sa.gov.au/our-places/coasts.

'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

Linda Gunter, Paul Gunter, Scott Cullen, & Nancy Burton, 2001, License to kill: How the nuclear industry destroys endangered marine life and ocean habitat to save money, Nuclear Information and Resource Service: http://www.nirs.org/reactorwatch/licensedtokill/licensed2kill.htm http://www.nirs.org/reactorwatch/licensedtokill/LiscencedtoKill.pdf

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.

Mycle Schneider, et al. “World Nuclear Industry Status Report” 2015 p.17.

Yalata and Oak Valley Communities, with Christobel Mattingley.2009. Maralinga. The Anangu Story. Allen and Unwin Press.Pg1.

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