Submission to the Nuclear Fuel Cycle Royal Commission
A Response to Issues Paper 2: Further Processing of Minerals and Manufacture of Material Containing Radioactive and Nuclear Substances
I can confirm that all evidence highlighted in this submission which is not that of the authors, has been properly cited, in accordance with academic conventions.
James Abbott BA (Hons), Master, MSc
1 Introduction
The responses herein are based on a Dissertation [1] completed as partial fulfilment of the requirements for an MSc Energy & Resources Management at University College London (School of Energy and Resources, Adelaide). The legal analysis in the dissertation was supervised by the Crown Solicitor’s Office of South Australia via an academic placement.
The work completed was a multidisciplinary study of the economic, legal and environmental viability of uranium conversion and enrichment. Although the results were generic to Australia; it contained explicit discussion of the economic issues facing South Australia, the potential role further nuclear development could play in alleviating said concerns, and the prominent position of South Australia in previous nuclear industry deliberations.
The economic analysis can be divided into three key subsets:
1) Determining what transport cost advantage (if any) would Australia hypothetically posses if it exported enriched uranium to (high nuclear growth) Asian neighbours, in comparison to current market incumbents?
2) Estimating the operational costs of varying sized Australian uranium conversion facilities, in comparison to current producers and historical market prices?
3) Given 1&2, ascertaining the operational cost of Australian enrichment facilities at varying maximum capacities and comparing this to estimates for current producers, historical market trends and predicted prices.
As a consequence of this modelling, it was possible to answer the question of whether development of the front-end of the nuclear fuel cycle would be a profitable venture, something explicitly lacking in the last governmental nuclear review [2]. A number of potential strategies to ensure further development of the nuclear fuel cycle were also discussed.
The legal discussion concerning uranium conversion and enrichment focussed on the current status-quo regarding development of uranium processing in Australia, followed by an analysis of one outstanding issue within current legal arrangements that represent significant uncertainty and could hinder further industry growth. This is by no means a comprehensive discussion of the legal issues surrounding development of the nuclear industry in Australia. For a more in-depth legal discussion, readers should consult an analysis by [3].
The final area of analysis contained a review of the academic literature regarding both the environmental and medical effects of ‘front-end’ facilities. Studies ranged from hypothetical modelling, analyses of uranium levels in the environment surrounding installations, discussion of accidents involving uranium hexafluoride, and medical studies of long-term health consequences.
2 This submission will begin with the Abstract from the Dissertation in order to give the Commission a concise overview of my work
Executive Summary
Australia is one of the world’s largest producers of uranium. Current production only transforms uranium ore into yellowcake, which is then exported to other jurisdictions for manufacturing into nuclear fuel. Australia’s lack of vertical integration and the failure to capture significant value-added in an environment of growing uranium demand warrants further evaluation.
A brief review of the history of Australian nuclear policy indicates that an undeveloped front-end nuclear fuel cycle can be attributed as much to geopolitical machinations as with a lack of economic incentives.
In light of the lack of detailed discussion on developing the nuclear fuel cycle, a microeconomic cost-engineering model was used to determine whether Australia could profitably operate a conversion and enrichment plant. An estimation of the transport advantage for Australia in supplying South/East Asia (in comparison to incumbent producers) was also completed.
As there may be additional factors for policy-makers to consider, a review of legal impediments to domestic development of the nuclear fuel cycle was presented. A literature survey of the environmental and health effects of the front-end of the nuclear fuel cycle operations was conducted, to demonstrate the possible externalities for Australia.
The economic analysis indicates the uranium conversion could not independently operate in Australia. In light of current enrichment market predictions, a conversion and enrichment plant with joint operations could be marginally profitable in Australia. However, this would be subject to the facility being one of the largest in the world and operations starting after 2020. The most outstanding legal impediment would be in the area of international law; relating to the regulation and liabilities surrounding transport nuclear materials. There is evidence to indicate that uranium has entered the environment as a result of nuclear-fuel cycle activities but the effects on worker/public health have been relatively small and the impact may be comparatively lower than other Australian resource industries.
Whilst the results indicate the possibility that domestic enrichment could be economically viable in the near future, the strategy would entail a high-degree of risk, especially since new enrichment capacity is entering the market from competitors. A more suitable solution would be for the government to invest in the enrichment firm Urenco, which is being privatised. This would give Australia access to profits without the risk of developing a new technology, whilst simultaneously leaving open the option for Australia to construct a facility in the future. Whether these suggestions can be implemented in the required time-frame is unknown and as such, other aspects of the nuclear fuel cycle should be investigated e.g. waste storage or nuclear fuel leasing.
3 2.1) Could the activities of conversion, enrichment, fabrication or reprocessing (or an aspect of those activities) feasibly be undertaken in South Australia? What technologies, capabilities or infrastructure would be necessary for their feasible establishment? How could any shortcomings be addressed?
Discussions concerning potential enrichment facilities in South Australia can be traced back to the early 1970’s [4], with the Spencer Gulf area [5] and later Port Pirie [6] highlighted as suitable locations. A 1980 South Australian study [7] evaluated two potential sites in Whyalla concerning their suitability for an enrichment plant. One area under investigation was located approximately 5km south of the town, the other 10km north. The northern site was deemed superior due to more suitable geology (including lower earthquake risk), better access to infrastructure and a less disruptive impact on Whyalla. More contemporary discussions have highlighted Redcliff Point (approximately 30km South of Port Augusta) [8] as a potential plant site, although given the area’s status as a marine reserve [9], approval for the site may be extremely challenging.
Historical discussion assumed sufficient manufacturing capacity and expertise within Australia [7]. Since the winding down of Australia’s nuclear program under Bob Hawke [10], Australia’s domestic ability to facilitate nuclear operations has been reduced (manufacturing and academic). Nuclear Engineering has only been recently reintroduced as an academic discipline in Australia [11] and there have been concerns expressed that an “infant” Australian nuclear industry would have problems associated with manufacturing and training [12]. Whilst some expertise has been preserved via ANSTO, it is still debatable on the extent to which Australia could construct and operate enrichment facilities without significant external manufacturing, or the extensive importation of foreign technology and expertise.
4 2.3) What legislative and regulatory arrangements would need to be in place to facilitate further processing and further manufacturing activities, including the transport of the products which they generate? How could these arrangements be developed so that they are most effective?
There is legislation covering uranium conversion and enrichment at both a Commonwealth [13, 14, 15, 16, 17] and State level [18, 19], in addition to legal numerous legal rulings [135, 136, 137] regarding the legality current fuel cycle developments (back-end). For a convenient legal analysis and implications for Australia, interested individuals should review [3]. In terms of an international legislation and regulation, the OECD-NEA [20] has produced a number of easy to understand reports summaries covering the legislation of countries with nuclear power, and those engaged in activities across the spectrum of the nuclear fuel cycle.
The author lacks the legal background to provide a robust commentary of Australian nuclear legislation, but under the Supervision of the Crown Solicitor’s Office, some key legal issues were highlighted that may need to be addressed if Australia is to develop either the front-end or the back-end of the Nuclear Fuel Cycle.
A key problem that needs addressing is the current legal uncertainty regarding the status of maritime nuclear product and waste transport. This is important given the geographical nature of Australia and its neighbours, international trade routes, and Asian growing nuclear demands.
A number of coastal States in proximity to Australia may be quite hesitant to allow the transport of radioactive materials, due to the high population densities of coastal districts, the environmental fragility of coastal areas and the economic dependency on the coastal environment/sea. Other jurisdictions have had incidents of ‘denial of shipment’ or ‘denial of entry’ despite such shipments being ostensibly legal. Refusals have also occurred for additional reasons such as: concerns regarding a lack of information on radiation risks, costs issues related to regulation and monitoring, and disputes brought about by the diversity of regulations governing nuclear material transport [21].
One would intuitively consider that if shippers of nuclear materials complied with the necessary legal obligations and precautions, said shipments would be subject to ‘freedom of navigation’ in international waters. In reality, there is a high degree of disagreement between States and within academia over the right to regulate and control the transport of nuclear materials (within Exclusive Economics Zones).
This dispute arises from the potential conflicting requirements in the international conventions regarding maritime transport and the conventions relating to the rights to mitigate pollution. Regulations governing the transport of radioactive materials are generally associated with one of two objectives; security (of the material) and safety (reducing risk of accident and its effects) [22], however these principles can easily come into conflict. The original drafters of conventions such as United Nations Convention on the Law of the Sea [23] may not have foreseen the current or likely
5 future scale of nuclear shipments [24]. Considering the importance of international Straits in maritime transport, it is perhaps surprising that the elements of legislation focussing on nuclear transportation are only found for territorial seas [25]. There are no provisions in the convention of nuclear transportation in Straits used for international navigation. This could represent a problem for Australian exports of enriched uranium, especially as key sea-lanes pass through international straits.
Legal experts are divided on the matter. One interpretation is that under International Law: coastal states primary right to regulate maritime transport [26, 27, 28, 29, 30, 31]. Dissenting opinions can be found in [24, 32, 33], who advocate the position that International Law dictates that primacy resides with the shipments.
For the sake of brevity, this submission won’t go into the finer details of international maritime law, although this can be perused in [1]. It was concluded in [1] that given the current state of international law, vessels carrying nuclear materials should enjoy the same freedoms as other comparable vessels. This opinion derives from the lack of legislation regulating nuclear material transport, the tendency to conflate risk with an actual environmental threat, and the rather non-specific nature of provisions regarding prevention of harm and damage. Supporters of increased regulation of nuclear shipments have failed to demonstrate the distinction between nuclear material transport as a ‘risk’, and nuclear material transport as a ‘threat’. To the authors’ knowledge, none of the supporters of restricting ‘Innocent Passage’ of nuclear shippers have deemed current technical/safety standards of vessels insufficient. It would therefore seem that unless there are specific guidelines (and under the reasoning of increased regulation proponents), any ship would be considered a threat due to the risk of fuel leaks from an accident or spillage of cargo. Similarly, if a small container vessel holding normal/enriched uranium hexafluoride in specially designed (to prevent leaks from accidents) cylinders are a threat, and then by that reasoning, an oil-tanker would be even more of a threat (due to ship size and the lack of special protections for the cargo).
In terms of terms of future legal arrangements for Australia to consider; the opinion defending the right of nuclear material transport to sail unhindered should not be construed as advocating the status-quo. Even legal experts who maintain nuclear- material transport is covered by concepts such as ‘Innocent Passage’ and ‘Freedom of Navigation’ [24, 33] concede that the regime needs amending. Potential disruptions by coastal states may reflect the perception of a lack of risk assessment or management, rather than the belief that nuclear transport is an imminent threat. The ‘perception of harm’ could therefore be considered the instigating factor in disputes, not ‘actual harm’ [33]. As a consequence, there should be solutions to enable risk mitigation to reduce the perception of risk. Given the growing pressures on maritime resources it would seem that a pragmatic response is necessary. Any remedy must try and increase regulation whilst maintaining ‘Innocent Passage’ and shipper sovereignty. A new regime proposed by [25] provides a tentative solution to some of the possible concerns Australia would face it were to engage in the export of nuclear materials.
As in [25], it would seem prudent for Australia to attempt negotiations with south/east Asian Sates, with the aim of formulating a regional agreement to provide greater clarification and coordination on nuclear transport issues. The example in [25] would
6 appease anxious coastal States by codifying provisions regarding ‘Prior Notification’ and contingency planning. From the perspective of coastal States, any omission of these measures would leave them at a huge disadvantage if there was an accident, both in terms of designating authorities responsible for remediation/containment, and for circulating information to limit public exposure [25].
A Maritime Agreement codifying ‘Prior Notification’ and cooperation in contingency planning would not unduly affect ‘Freedom of Navigation’ [25] but would result in a compromise between the safety concerns of coastal States and the security/sovereignty demand of shipping States. Multilateral and consensus-based solutions are also being piloted by the International Maritime Organisation and the International Atomic Energy Authority with regard to reducing denial of shipment incidents [21].
In order to gain support for such an Agreement, there may need to be deliberations surrounding changes to the legal liability regime. Australia currently has no specific rules regarding third-party liability and is not a member of any of the conventions codifying nuclear damage compensation [34, 35]. Of the States located in South or East Asia; only the Philippines is a signatory to a liability scheme [33]. Although reforms to Conventions increased the scope and depth of nuclear liability for nuclear transport accident (compared to their predecessors) [36], the international liability regime is still characterized by divergent rules and significant legal overlap [37]. Any Regional Maritime Agreement would have to be formulated carefully and methodically, as there is a significant risk that such accord could lead to overlapping regulations that come into conflict with established Conventions. As a result shippers would be subject to international inefficiencies due to the need to conform to multiple legal regimes [24].
If Australia fails to generate a consensus regarding new Regional Agreements, there are potential alternatives. [24] cites a solution proposed by [38], that details how a regionally or multilaterally proposed ‘Universal Sea Lane’ would instigate progress without needing the codification of a new legal agreement. This type of compromise would facilitate shipping of nuclear materials but also give coastal States some option in prohibiting passage in certain areas [24]. Again this type of solution requires multilateral consensus, which may be difficult to foster [24]. Other than procedural negotiations, a pragmatic approach may be lobby for more stringent regulations concerning storage and loading (despite the very low nuclear material accident rate) given that 91% of maritime accidents involving dangerous substances can be attributed to deficiencies in packaging, containment or loading [37].
7 could increase domestic uranium production to required levels, and therefore regard cooperation with Australia as essential to fulfilling Sino-nuclear ambitions [44, 45] Further along the Nuclear Fuel Cycle, Chinese domestic enrichment capacity is currently inadequate given its nuclear expansion goals [46], although there were plans for a quadrupling of potential supply [47]. Conveniently (for Australia), the current plans appear to have been suspended due to public dissatisfaction [47]. Evidence of a lack of domestic capability can be observed by increased imports of uranium hexafluoride and enriched uranium, with increasing international purchases of likely in the future[41].
In terms of more direct estimations of enrichment demand, modelling by [48] and [49] should be of particular interest. [48] utilise a market-clearing model that includes primary and secondary uranium supplies and their interaction with the enrichment market. Using a reference case similar to assumptions made by world nuclear association in 2009 [50], their model suggests that Separative Work Unit (SWU) output would be slightly above the 2009 World Nuclear Association projections (around 80 million SWU/year compared to 75 million SWU/year) with similar upper bounds (between 95 million and 100 million SWU/year). Disparities between the two models can be attributed to greater substitution away from uranium and towards enrichment1 .
The modelling in [48] also generated price projections for enrichment. The onset of new centrifuge enrichment capacity results in the enrichment price collapsing to as low as $84 in 2015. Prices will remain around $90 per SWU until the mid-2020, where a combination of increased demand and rising uranium supply costs cause the price to appreciate towards $115 per SWU by 2030. A similar model by [49] (with greater focus on the effects of individual uranium producers) generates comparable results to Schneider et al. (2014), with enrichment consumption of just under 90 million SWU per year and SWU price of approximately $110/SWU by 2030.
An important consideration is that the enrichment market projections in [48, 49] have overestimated the value of enrichment services since 2013. A perusal of current SWU values [51] indicates a market price of $68 dollars per SWU, whilst existing models predict a price circa $85-90 per SWU. Whilst it is not purpose of this submission to speculate on the reasons for the state of the uranium market, the exhibited low prices could impair the remote likelihood of an enrichment facility in Australia, especially if these trends continue into the medium and long-term, and the market becomes further saturated with supply from new enrichment facilities.
1 greater use of enrichment means reduced tails assay and therefore reduced uranium feedstock
9 2.8) What additional risks for health and safety would be created by the establishment and operation of such facilities in South Australia? What needs to be done to ensure that risks would not exceed safe levels? Can anything be done to better understand those risks?
Accidents
In the aftermath of the Fukishima disaster, the Australian public has become much more pessimistic about the influence of nuclear activities on human health and safety, in addition exhibiting increased concern about nuclear waste [52]. Therefore quantifying the environmental and health impacts of the Nuclear Fuel Cycle is essential in getting public support. The author has no expertise in the field of epidemiology, meaning this section should be treated as literature review of the potential long-term effects of Nuclear Fuel Cycle development, rather than as a conclusive analysis.
There have been two ‘significant incidents’ involving uranium hexafluoride which have led to fatalities. The first of these occurred at the Seqoyah Fuels Facility on January 4th 1986 in Oklahoma, USA. Contrary to regulations, an attempt was made to remove (solidified) uranium hexafluoride from an overfilled cylinder by heating the vessel in a steam chest. This caused the container to rupture, releasing an estimated 13,400 kg of uranium hexafluoride [53]. Inhalation of the subsequently generated hydrofluoric acid led to the death of one worker and the hospitalisation of 37 employees [53]. As should be apparent from this summary, this incident was not a random event, but rather caused by a failure to follow regulations.
Operating contrary to regulations was also the precipitator for the other major incident involving uranium hexafluoride. This second incident occurred in the village of Tokai-mura on the 30th September 1999 at the JCO Uranium Processing Plant in Ibraki Prefecture, Japan. A criticality event occurred for 20 hours due to the pouring of enriched (18.8%) uranium hexafluoride (equivalent to 16.6kg of uranium) into a precipitation tank [54], where specific regulations dictating only an equivalent of 2.4 kg uranium should be handled at any one time. This led to the deaths of 2 workers and hospitalisation of another for serious radiation exposure [55].
The accident led to the evacuation of all individuals within 350 metres of accident [54]. Radiation exposure for 207/234 neighbourhood residents was less than 5 millisieverts. Within a 350m zone the average exposure was for indoor and outdoor residents was 2.2 and 5.6 millisieverts respectively [56]. Further analysis suggests that for those residents who were indoors, 83% would have received exposure of less than 1 millisievert [57]. This is lower than limits usually enforced for Australian public radiation exposure [58]. In the context of potential sites listed for Whyalla [7], those would be much further away from residential areas than was the case of the Tokia- mura accident, with the southern site being approximately 5km from outskirts of
10 Whyalla and the northern site around 10km from the edge of Whyalla. Fission products were also released into the air [59], and radioactive particles (as a result of the accident) were detected in soil, but these were in close proximity to the accident site [60, 61]. It should also be noted that both sites were fuel research facilities rather than enrichment or conversion plants, and were utilising enriched uranium hexafluoride at enrichment levels far higher than would be expected from a standard enrichment plant.
A number of papers have modelled the potential effects of accidents (both at the facility and in the transportation of uranium hexafluoride). A review of risk data from the US Academy of Sciences suggests that the long-term collective does risk from the nuclear fuel cycle is significantly lower than a number of major industries e.g. construction, aviation, agriculture and water supply [62]. Modelling a hypothetical accident at a uranium conversion plant [63] suggests that the expelled uranium hexafluoride surrounding the accident would be at the concentration of 100mg/m³, where 72mg/m³ would be the 30-minute exposure lethal concentration [64]. A vehicular accident involving a uranium hexafluoride container [65] could lead to exposures of 185, 18.5 and 1.85 times recommended annual public exposure (based on exposure limits found in [66, 67]), depending on ones distance from accident2. Modelling of cancer and genetic defect risk of a major accident involving a ship carrying radioactive spent fuel3 [68] suggested that even if there was a maritime collision and fire in close proximity to a major urban centre, the latent cancer deaths and genetic effects would be small, with values lower than accepted limits and congruent with previous risk estimates.
Public Health Risks
Although the impacts of the Nuclear Fuel Cycle on the general population can be reduced by siting it in a remote location [see 53], an important consideration for Australia is whether any installation will have perverse effects on the general population. Although the number of investigations of the public health effects is sparser than that of nuclear workers, studies and discussion on this matter can be found in [69, 70, 71]. These found no elevated cancer/disease risks, nor elevated levels of radiation exposure [71].
Other than the intuitive potential cancer risk from such nuclear facilities, [72] highlights the need to store depleted uranium correctly4 as inhalation has shown to impair kidney functions. From a regulatory perspective, although there is a lack of evidence suggesting a causal link between water-borne uranium levels and health problems, most jurisdictions have very strict provisions regarding uranium levels in water [72]. Any facility in Australia would therefore need strict regulation and regular monitoring. [73] suggests increased radiological protection of the public can be
2 185 times exposure in 1 20m by 200m ellipse form the accident, 18.5 times exposure in 100m by 600m ellipse from the accident, and 1.85 times recommended exposure in a 300m by 1500m ellipse from the accident. 3 Note higher radioactivity then uranium hexafluoride or enriched uranium 4 By-product of enrichment
11 derived from more accurate monitoring and consistent regulation. As an aside, one should also consider that existing resource industries can generate negative effects for both workers and communities in close proximity. The negative health outcomes of coal mining can be found [74, 75] while there are also detrimental effects of living close to thermal (coal) power stations [76]. Again, it should be clarified that there are a relatively few studies on the impacts of coal mining on surrounding populations and the limited scope of assessments in available studies [74].
Worker Heath Risks
The health effects for European enrichment plant workers can be found in [77, 78, 80]. The analysis in [77] suggested an increased mortality risk from pleural cancer and a lagged dose-repose for bladder cancer. However, any definitive conclusion was difficult because cumulative radiation exposure levels were below those likely to decrease health outcomes, and cancer incidence was uncorrelated with radiation exposure. Radiation exposure was found to have a more definitive effect in [80], although only for non-cancer mortality. The results of [78] suggest a link between radiation exposure and both certain forms of leukaemia and non-leukaemia malignant neoplasms. However, this should be qualified by the fact that the results included health outcome data from other nuclear industries, not just conversion and enrichment plants.
For US enrichment facilities, there was a broader array of studies [81, 82, 83, 84, 85, 86, 87], although not all of these published definitive results. For instance, [81] found there was a relationship between hematopoietic cancer and exposure, although this relationship was non-significant. Similarly, [83] could only find a weak correlation between chronic-low level uranium exposure (internal uranium dose) and cancer risk. More definitive results were found in [87]; where there were statistically significant results for chronic renal disease, lymphatic and haematopoietic issues and non- significant increases in neoplasm of lung, larynx and diseases of kidney, bladder and oesophagus. However, like [78], this study included data from installations across the nuclear fuel cycle5 rather than just enrichment and conversion facilities. An analysis of diffusion enrichment plants in [84] found that there was an elevated risk of lung cancer mortality, which was likely related to radiation exposure and employment length; although it was conceded that the results may be driven by the fact that certain individuals are susceptible to the effects of cancer causing radiation.
There have been a number of studies regarding the health outcomes of uranium conversion plant workers [88, 89, 90, 91, 92]. In contrast to the other studies, [91] found multiple negative health outcomes, in particular an association between cumulative dose and Hodgkin’s Lymphoma (morbidity and mortality), non-Hodgkin’s Lymphoma (mortality) and bladder-cancer mortality. Some detrimental health outcomes were ascertained in [89], although only an increase in lymphatic cancer mortality was associated with increase uranium exposure (at a significant level).
5 3/18 were from enrichment or conversion plants.
12 Given the restricted number of sites, the relatively low number of incidents associated with the Nuclear Fuel Cycle and the cumulative nature of environmental and health risks, there is uncertainty concerning whether the evidence truly reflects the risks involved. Results in these health studies should be treated with some degree of caution, as measurements can be imprecise and monitoring data unreliable [93]. Long-term health studies have only recently been able to capture the risks associated with diffusion enrichment facilities; however this type of installation is now obsolete. As a consequence, health and safety outcomes for workers associated with the nuclear fuel cycle are likely to improve, due to the decommissioning of old plants/technology and the utilisation of newer facilities [73]. The true effects of working in a nuclear fuel cycle facility may also be distorted by the presence of the ‘Healthy Worker Effect’6 among uranium workers [77, 78, 79].
6 Workers sampled are healthier than population or more prone to reducing risk/ unhealthy/detrimental behaviours than the surrounding population
13 2.9) What additional environmental risks would be created by the establishment and operation of such facilities in South Australia? Are there strategies for managing those risks? If not, what strategies would need to be developed? How would any current approach to management need to be changed or adapted?
Impact of Uranium
Whilst uranium oxides such as yellowcake are very stable in the environment [94], uranium hexafluoride and enriched uranium are extremely dangerous chemicals. Solid uranium hexafluoride doesn’t react with oxygen, nitrogen, CO2 or dry air [94] but when it comes into contact with water or water vapour it reacts to create Hydrogen Fluoride and Uranyl Fluoride [94] chemicals with serious corrosive effects on tissue. These damaging impacts are independent of the chemical toxicity of uranium compounds [95], which can also affect human and environmental health. Natural uptake of water-soluble uranium hexafluoride is higher than uranium oxides [96].
Environmental Impact
Despite the toxicity and radiation danger of uranium, the current evidence suggests that overall uptake by plants; worms and micro-organisms is low [96], although analysis of bioavailability in humans and animals is limited [96].
There are a number of studies highlight either the direct environmental effects of front-end Nuclear Fuel Cycle facilities on the environment or discharges of uranium in the environment [97, 98, 99, 100, 101,102]. The effects of the latter studies can be inferred by contrasting with their results with the uranium concentrations necessary to produce a variety of negative effects in plants (terrestrial and freshwater) and wildlife (birds, mammals, freshwater fish, freshwater invertebrates) [104]. An investigation of modern Japanese enrichment facility [97] shows no detectable uranium releases in a lake next to the facility. In terms of the direct effects on wildlife [98], the genetic characteristics (nucleotide diversity) and breeding numbers of bird populations close to Nuclear Fuel Cycle facilities was found to be superior to that of comparable populations near copper smelters.
The investigation in [99] found uranium isotopes originating from a UK enrichment facility in tidal sediment extracts in a nearby harbour. In [100], freshwater sediment close to a UK enrichment plant was analysed, indicating the prepense of uranium isotopes above natural levels. It should be noted that UK regulations allow the release of some uranium alpha activity and that typically this enrichment plant discharges uranium at levels far below permitted levels [100]. Two readings from the freshwater sediment [100] would have been high enough to affect freshwater plants and invertebrates if the surrounding water had similar concentrations. In [101] uranium isotopes associated with enrichment were found in elevated concentration in tree bark and sites close to a UK enrichment plant, although at levels that wouldn’t affect the environment. At one site in close proximity to UK conversion facility, there were
14 uncharacteristically high levels of uranium but only at concentrations high enough to affect freshwater invertebrates (water concentration).
An analysis of a French conversion plant [102] in light of [104] suggests uranium levels high enough to affect terrestrial wildlife and plant life (when converting measurements to the scales used in [104], see [105]). The authors of [104] do highlight the difficulty in determining whether the increased uranium levels were caused by the conversion plant or the spent-fuel facility on the same site. Although atmospheric uranium releases have limited applicability to [104], it is worth noting that the divergence in results between facilities may be driven by the age of a facility, plant reliability and plant production processes [103]. This may indicate that a modern enrichment or conversion plant built in Australia would be responsible for reduced uranium pollution, a hypothesis also evidenced by the results in [97].
Water withdrawal7 and consumption8 by the front-end of the nuclear fuel cycle (including mining and milling) are lower than comparative processes for coal mining and gas extraction [106, 107] .
7 Water extracted or diverted for processes 8 Water evaporated, transpired or incorporated into products via the production process
15 2.13) What financial or economic model or method ought be used to estimate the economic benefits from South Australia’s establishment and operation of facilities for the conversion, enrichment, fuel fabrication or reprocessing of, or the manufacture of materials containing, radioactive and nuclear substances? What information or data (including that drawn from actual experience elsewhere) should be used in that model or method?
This is a degree of contention concerning whether it would be beneficial for Australia to supply part or all of the elements of the front-end of the nuclear fuel cycle. Commentators have indicated that there is limited commercial appetite for bundle- supplied of uranium-based products9 and that Australian Nuclear Fuel Cycle development is constrained by market overcapacity, technical and regulatory barriers to entry, and a lack of a domestic nuclear sector [108]. However, the European Commission [109] highlights a counter-veiling trend in the market i.e. demand for ‘bundled’ uranium supplies is likely to grow and that many jurisdictions with of high uranium demand may suffer from various supply issues.
Although [2] failed to provide substantive modelling (other than the potential value- added from further front-end development), there are a number of sources outlining both the estimated capital costs new facility in Australia, and for existing and enrichment plants globally. The author found estimates for the construction of an enrichment plant of between $2-3 billion [110, 111, 112], depending on size and configuration. An estimate for a 10,000 ton Australian conversion plant suggests a cost range of $200-400 million [112], which can be compared to a projected cost of $ 902 million for a potential French 21,000 ton conversion plant [113]10. Estimated costs of new enrichment plants were highlighted in [2], although more recent estimates of both ‘western’ and Russian enrichment facilities can be found in [114] and [115] These indicate total capital investment costs (non-Russian) circa $1.95-4.80 billion, again dependent on facility size and configuration.
Although the above literature review indicates the potential costs of Australian investment, the sources fail to answer the salient question of whether significant investment uranium enrichment is a viable financial proposition. The lack of a ‘concrete’ answer is perhaps understandable given the constrained nature of information relating to the front-end of the nuclear fuel cycle [116, 117], although average costs estimates have been formulated for existing facilities and those under construction [114, 115, 118]. As far as the Author is aware, analogous estimates for the conversion sector do not exist. Estimates for transport costs of enriched uranium suggest they would have a higher bound of only around 1% of the product value [119] although volatile and rising costs are increasingly important issues for the industry [120].
9 Buying enriched uranium directly from a supplier rather than the customer independently purchasing yellowcake, sending it to a conversion facility and then to an enrichment plant. 10 Includes taking into account inflation.
16 The modelling of transport costs by the Author (savings generated Australia exporting enriched uranium to Asia compared to the current industry structure) generated results broadly in-line with current industry estimates [119, 121] and at current enrichment prices would represent a cost advantage to Australia of approximately 1% ($0.7/SWU)11 at current enrichment market prices.
In terms of the total costs for a conversion plant, these range from $320 million for a 6000t installation (perceived to be smallest sized facility that is commercially viable [122]) to $1.34 billion for a 25,000t ton plant (a size larger than any current or proposed conversion plant).
Relationship between Operating Costs and Capacity for Uranium Conversion Operating Cost ($/Kg) 50.00 Australian Conversion Costs 45.00
40.00 Current Conversion Price
35.00 Port Hope (CAN) 30.00 Metropolis (USA) 25.00
20.00 Commurhex 2 (FR)
15.00 Springfields (UK) 10.00
5.00
0.00 Conversion Capacity (T/UF6) 0 5000 10000 15000 20000 25000 30000 35000 Figure (2): Relationship of potential Australian Conversion Costs to plant capacity in comparison to other conversion plants, Source: [1]12
Utilising the construction costs, one can build a cost-engineering model of enrichment operational costs. As the above figure indicates, even with the economies of scale of a large facility, a conversion plant would be unprofitable at current market values. Contrasting with historical prices [123] indicates that even the most efficient Australian plant would only have been operating profitably in 3 of the last 20 years. The drivers of this poor performance are capital repayment costs and uncompetitive Australian electricity charges. Even if one assumes an Australian facility uses the gas- intensive ‘dry’ conversion process rather than the more common and electrically- demanding ‘wet’ processes, the model suggests Australian enrichment would still lack profitability.
11 Original results in [1] calculated costs savings as $0.15/SWU. This have been revised upwards 12 Results have been updated since original 13/14 publication
17 Utilising and slightly amending the enrichment model found in [114] it is possible to determine the average operating costs for an Australian Centrifugal enrichment plant. The results also incorporate the transport costs savings for supplies to Asia, the capital costs of a ‘feeder’ conversion plant and the internalising the losses of Australian Conversion (compared to buying uranium hexafluoride at market prices).
Relationship Between Enrichment Operating Costs and Capacity
Operating Cost ($/SWU) Aus Enrich 600 Aus Enrich (High Cost of Capital)
Aus Enrich (No Legacy Costs) 500 National Enrichment Facility (USA)
400 Areva Idaho (USA)
American Centrifuge Project (USA) 300 Georges Besse 2 (FR)
200 Resende (BRZ)
Projected 2030 SWU Price 100 Current SWU Price
0 0 2 4 6 8 10 12 14 Capacity (Million SWU)
Figure (3): The relationship between potential Australian enrichment costs and plant size at different cost of capital levels, Source: [1]13
Figure (3) highlights the results of the enrichment modelling. The green and pink lines show enrichment operating costs taking into account the lower and upper-bound costs of capital (5% and 10%) associated with the nuclear industry, similar to [114]. Given increasing public animosity to the nuclear industry [52] and the environmental concerns of waste products from enrichment process [2], estimates for waste disposal and decommissioning costs found in [124] were also incorporated into the Australian and foreign enrichment estimates. These variables that weren’t included in the original estimates by [114]. To highlight the impact of this measure, enrichment operating costs without internalizing externalities has been indicated in Figure (3) by the blue line.
These estimates can be contrasted with the current enrichment price [51] and a 2030 enrichment price projection derived from a dynamic model of the uranium market [48]. Evident from Fig (3) is that under contemporary price-levels, uranium
13 Results have been updated since original 13/14 publication
18 enrichment in Australia would be operating at a loss, even if one ignores disposal and decommissioning costs. It should be noted that an enrichment plant would meet its fixed costs (assuming 100% of production is sold) at capacities over 6 million SWU..
Assuming projected 2030 prices ($115/SWU), Figure (3) indicates that uranium enrichment in the normal scenario would generate profits if the facility had a capacity of over 8.5 million SWU. Failure to incorporate externalities into the operating costs would reduce the necessary size of a facility to around 6 million SWU. The total investment cost of a viable sized plant under normal conditions (including a conversion feeder plant) would be at least $8.7 billion.
It should be noted that the analysis was conducted on the assumption that materials produced from the NFC would be sold on the international market. It is possible that Australia could enter into a bilateral agreements with other States, where the main objective being that of energy security. As a consequence agreed-price could potentially be negotiated that is higher than the market levels, in return for export guarantees [125]. Other countries (noticeably Brazil) have internationally uncompetitive enrichment facilities [118] which imply an energy security impetus may be driver of investment in the Nuclear Fuel Cycle.
19 2.5) Could South Australia viably increase its participation in manufacturing materials containing radioactive and nuclear substances? Why or why not? What evidence is there about this issue? What new or emerging technologies are being developed which might impact this decision?
Given the results of the presented modelling (see 2.13), I suggest there are three potential strategies Australia could implement if it wishes to derive further value- added from its uranium resources.
Strategy 1
The first strategy would be to invest in enrichment corporation Urenco, rather than building a facility directly in Australia. The direct economic drawback of this proposition would be approximately 600 direct construction jobs and between 200 to 550 operational jobs for over the lifetime of the plant [1, 124], with similar number of decommissioning positions [124]. Whilst there would be a reduction in benefits from construction and employment opportunities, it would give Australia financial access to a highly profitable enrichment corporation [114, 115] in a market with good long- term growth prospects [48], without the risks associated with development. Australia already has a history of consulting with Urenco regarding enrichment opportunities [7] and with the assumption by some commentators that any future Australian developments will utilise Urenco technology [110, 111]. If Australia was to possess a stake in Urenco, there would be nothing to preclude the future construction of an enrichment facility in Australia. The potential vertical-integration benefits, concerns over uranium transport [119] and Australia’s notable record on non-proliferation [126] would make Australia an ideal candidate
It should be conceded that there would be numerous legal uncertainties regarding Australian (government or corporate) ownership of Urenco. These would manifest as issues regarding regulatory oversight and the temporal aspect of treaty negotiations governing the Australian ownership of enrichment technology. At this embryonic stage of Australian Nuclear Fuel Cycle development, it is difficult to do anything more the vaguely postulate on the difficulties of such an agreement, although the ability of the USA to agree a treaty with four European countries over American development of centrifugal technology [127] may alleviate some concerns.
The main impediment to this strategy is whether the fiscal climate or the private- sector in Australia could support the acquisition of Urenco and could (even if the previous caveat was irrelevant) policymakers / business leaders agree and initiate a bid before the company is sold to other interests.
20 Strategy 2
Similar to first strategy, investment in another foreign enrichment company could be a profitable venture for Australia, albeit with a reduced economic impact given the lack of initial domestic development. The Laser Enrichment technology developed by the Australian company SILEX could herald the next generation of enrichment facilities around the world, in part because the its use could dramatically lower enrichment costs [128]. GE has commercial rights to the technology [2] (should current trials prove to be successful), and that the Treaty regulating the technology mandates that it can only be used for research and development purposes in Australia [129]. Where Australia does posses an advantage is from the fact that sales are restricted (without mutual agreement) to a pre-defined group of countries [129]. The list of proscribed countries includes many European nations, which being governed by EURATOM, which has the ability to restrict uranium imports [130]. The power to limit laser- derived uranium imports could severely constrict the market for the new technology. If sales were to be conducted to ‘unlisted’ countries with high-nuclear capacity growth, then this would require the permission of Australia, giving significant room for negotiation over expanded use of the technology. Australia could use this leverage to secure a laser-based facility for Australia.
As there has yet to be a full commercial demonstration of laser enrichment [131] and the lack of disclosure regarding current operations in the USA [131], both the technology and this strategic pathway are far more speculative than the Centrifuge (Urenco) option. Similarly to investment in Urenco, it would also be subject to the same dilemma regarding whether the Australian government or companies have the appetitive or ability to investment the large amounts if capital necessary for such a facility (given the current and predicted economic climate). This issue if further augmented the fact that as the as time progresses, the cost is likely to rise significantly as full-scale commercialisation becomes more probable (assuming that current investors are willing to sell). The US operations of laser enrichment have also seen financial investment from Cameco [132] (yellowcake and uranium hexafluoride producer) and Toshiba (nuclear technology and uranium hexafluoride producer) [132]. As a uranium producer, Cameco especially, may not be willing to sell a stake or work with an Australian consortium because any benefits to Australia may come at the expense of Canadian yellowcake and uranium hexafluoride. A further impediment would be US concerns over proliferation of the laser enrichment technology. A plausible situation could arise, whereby some of the investors are willing to sell their stake, but US Authorities refuse to grant any new developments outside the USA.
21 Strategy 3
Given the precarious nature of domestic front-end development and investment in foreign enrichment companies, I would urge the Royal Commission to thoroughly investigate the potential for nuclear waste storage and / or nuclear fuel leasing. Whilst it is the opinion of the Author that extensive research would need to be conducted regarding the technical feasibility, economics, regulation and proliferation concerns, there are a variety of indictors to suggest that this would be a worthwhile endeavour for Australia. Factors to consider include the postponement of the Yucca Mountain Nuclear Waste Storage Project (USA) [133], economic modelling suggesting significant revenue generation for Australia if it was to engage in waste disposal [134], the geological stability of Australia, and an ethical argument the Australia should be responsible for the uranium it produces.
Nuclear Waste Storage in Australia is not a new idea, with discussions of the development of back-end infrastructure dating as far back as the 1980’s [10]. Australia has already started the process for developing such a facility for the waste generated by ANSTO [17]. If Nuclear Waste Storage is a viable proposition, cross- subsidisation could allow the simultaneous development of conversion and enrichment facilities and for Australia to engage in nuclear fuel leasing. In addition to capturing value-added, nuclear fuel leasing would allow Australia to exert significant control over Australian Uranium throughout the nuclear cycle, ensuring congruence with Australia’s historical non-proliferation stance.
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