Uranium Exploitation and Environmental racism: why environmental despoliation and the ignorance of radiological risks of uranium mining cannot be justified by nuclear fuel production Response to consultation on: Stations ‘Justification Application New nuclear power stations Submitted by the Nuclear Industry Association’ (June 2008) By *Dr David Lowry Environmental policy and research consultant Context In May 2008 the then environment minister, Phil Woolas, stated in a written Parliamentary reply that: ―The UK currently sources uranium for commercial reactors from Australia and Russia.‖ (source: Hansard, 21 May 2008 : Column 344W) It is not known where uranium would be procured for any future nuclear fuel required by any new build nuclear energy programme. The Strategic Siting Assessment documentation, including the study on the potential environmental and sustainability effects, failed to look at any environmental implications of new nuclear plants beyond the United Kingdom shores. I made a submission of over 150 pages, some of which is repeated in this submission, but predictably, if disappointingly, not one word on uranium environmental hazards appeared in the Government response to that consultation. I would not expect the issue to be ignored in such a cavalier way a second time, for the nuclear industry is global and the nuclear fuel chain involves many countries in a complex interlocking set of managerial and processing arrangements. Extraction and processing beyond British shores are part of the radiological burden of nuclear fuel: these impacts must not be ignored. Government has a moral responsibility to ensure these important concerns are addressed. The draft Nuclear Industry Association ‗Justification Application‘ – dated June 2008 – which complements the SSA documentation, devotes only seven paragraphs (2.18-2.34) to general discussion of uranium supplies, and eight further paragraphs in the Annex 1 on the nuclear fuel cycle (three on uranium mining and milling, and five on enrichment). None address the environmental consequences of uranium mining and milling. The annexes have sections on radiological risk to reactor operators and to members of the public from reactor operation, but nothing on radiological risk to uranium miners and polulations living in the vicinity of uranium mines and the radioactive waste arisings.(http://www.berr.gov.uk/files/file49231.pdf). The annex section on radioactive waste states the following: 1 ―The applicant judges the detriment from radioactive waste and spent fuel to have the potential to be significant in terms of justification were there to be no defining attribute identified to constrain it. The issues here centre around confidence that the quantities and characteristics of these materials are such that they could be managed responsibly and without significant detriment, including potentially placing a significant financial burden on the UK taxpayer. This is captured by the defining attribute set out in Table 1.1 that these arisings should be ―compatible with UK disposal or interim storage plans‖. From this is is clearly apparent that only radioactive waste arings from irradiating the fuel, ie reactor operations and back-end management, are considered by the applicants as worthy of consideration. This is sadly predictable, but is also unconscionable. The perspective is purely national and managerial, with no international or ethical assessment. By limiting the consideration of the prospective ‗detriment‘ to UK citizens and residents alone, the comparative costs and benefits are far too narrowly drawn. As a consequence, the questions posed by the Justification consultation fail to capture this extraterritorial and ethical dimension Therefore in the context of the Justification questions on the scope of the matters canvassed in the documentation, on grounds of intra generational and indeed inter- generational equity, it is clear that the affected stakeholders and communities stretch well beyond the UK‘s shores, literally across the globe, and any Justification should encompass the ethical and equity consequences of this factual reality. This submission thus rectifies this omission, and includes as illustration primary materials ( and associated references) covering problems encountered in the major uranium production countries (Australia, United States, Canada, Kazakhstan, & Namibia, and some more minor ones such as the Czech Republic, France and eastern Germany). I thus recommend government advisors and regulators carefully read these materials to gain a holistic picture of the externalised environmental costs of the use of uranium in commercial reactors. I have also included at the end in an annex some material on radiological weapons („dirty bombs‟), another possible radiological detriment from the continued operation of the nuclear fuel chain, an essential component of any new nuclear reactor operation, which is not addressed by the NIA Justification document Prolegomena In the same month as this consultation closed (March 2009), an American non governmental organization, Beyond Nuclear, published in its regular information bulletin, Thunderbird, a review and summary of a conference its heled host in Washington DcC in February 2009, addressingthe issue of the impact on indigenous people of uranium mining, milling and its waste streams. I reproduce the summary immediately below. 2 Beyond Nuclear Bulletin March 5, 2009 Standing Room Only as Indigenous Speakers Describe Atomic Genocide It was standing room only at the huge PowerShift 2009 youth conference on climate change in Washington, DC, February 27, when Beyond Nuclear hosted a panel that included three indigenous activists, a scientist and a prominent actor. The panel - Human Rights, Uranium Mining and Unfolding Genocide - featured actor, James Cromwell; French nuclear scientist, Bruno Chareyron, Manuel Pino of the Acoma Pueblo; Sidi-Amar Taoua, a Touareg from Niger; and Mitch, an Australian Aboriginal. The panel held a press conference, briefed legislators on Capitol Hill and spoke at PowerShift to more than 500 students. The activists described how uranium mining has disproportionately targeted indigenous communities across the world and represents a deliberate genocide. Mine workers were poorly protected and informed and suffered from often deadly diseases without proper treatment. Most disused mine sites have never been cleaned up while water supplies remain contaminated. "Poison Wind," a documentary by Jenny Pond, was also shown to a packed room at Busboys and Poets in Washington, DC at an event hosted by Cromwell. The three days of events represent the beginning of a new Beyond Nuclear campaign to draw attention to the consistent violation of fundamental human rights caused by uranium mining. See our Home Page and the Atomic Discrimination page on the Beyond Nuclear Web site for more information. In addition, Beyond Nuclear staff presented at two No Nukes panels that were attended by more than 500 young people each, and conducted a workshop that was filled to capacity. The Beyond Nuclear information table was also well trafficked all weekend and Beyond Nuclear staff briefed the PowerShift lobbyists on nuclear power loan guarantees before they headed to Capitol Hill the following Monday. Beyond Nuclear in the News The Beyond Nuclear tour of indigenous speakers on human rights and uranium mining received a variety of press coverage, including an article by Agence France Presse that appeared in the Melbourne Age, the Melbourne Sun and the Economic Times (of India) among other publications. View the articles here. In addition, James Cromwell was interviewed live on CleanSkies TV. http://ent.groundspring.org/EmailNow/pub.php?module=URLTracker&cmd=track&j=2650 54143&u=2835008 Country–by-country reports AUSTRALIA 3 Olympic Dam, Roxby Downs (South Australia) Olympic Dam expansion project BHP intends to have first stage of Olympic dam expansion in production by 2013 On Oct. 31, 2008, BHP Billiton said it plans to have the first of five planned stages of expansion at its Olympic Dam mine in production by 2013. The first phase of expansion is to optimise the existing underground operation and increase its production capacity to 200,000 tonnes of copper, 4500 tonnes of uranium and 120,000 ounces of gold. The development of the open pit is to take five years with the ore processing expansion to be developed in three stages. The mine has a capacity to produce 180,000 tonnes of copper and 4000 tonnes of uranium per year, with the staged expansion looking to increase copper and uranium output to 730,000 and 19,000 tonnes, respectively. (The Australian, Oct. 31, 2008 ) NT Government invites comment on EIS draft guidelines for increasing uranium transport from Olympic Dam to Darwin As part of the proposed expansion BHP Billiton is proposing to export copper concentrate and uranium oxide through the Port of Darwin via the Adelaide to Darwin rail line. Northern Territory Environment Minister Alison Anderson has determined that the proposal is considered environmentally significant requiring preparation of an Environmental Impact Statement (EIS) for the Australian, South Australian and Northern Territory governments. Comments must be submitted by 31 October 2008. > View NT Gov. media release 17 Oct 2008 > Download draft guidelines for Olympic Dam Expansion (NT Transport Option) project Scientists denounce location of proposed desalination plant for Olympic Dam mine as inappropriate (South Australia) Three hundred residents from