Submission to South Australian Parliamentary Committee. 10 holes in the Royal Commission’s pro nuclear case

It’s no surprise that South Australia’s questionable Nuclear Fuel Cycle Royal Commission (NFCRC) is recommending that Australia become the world’s nuclear waste import hub. That has been the intended outcome from the beginning, when the Commission was set up, over a year ago.

The questionable integrity of the NFCRC was discussed in a submission by Yurij Poetzl over a year ago. Poetzl pointed out Royal Commissioner Kevin Scarse’s conflict of interest, as a shareholder in Rio Tinto, and as a member of CEDA (the Committee for Economic Development In Australia). CEDA’s Policy Perspectives of Nov 2011 clearly supports and promotes the growth of South Australia’s nuclear industry. The Royal Commissioner selected predominantly pro-nuclear experts for the Commission’s Advisory Committee. The Advisory Committee had no involvement of health or medical professionals. Poetzl went on to list 22 significant questions that were not addressed in the RC’s Terms of reference. (1)

Speaking in November 2014 at a Flinders University guest lecture,Scarce acknowledged being an “an advocate for a nuclear industry”.

This doubt is raised again, in the latest batch of Submissions, which were published on the RC’s website on 2nd May. In a Submission that is neutral, not anti- nuclear, Gary Rowbottom notes that

Mr. Scarce, in his delivery of the tentative findings, a mere day after the release of these findings, seemed to be critical of any comments made in opposition to deepening Australia’s involvement in the nuclear fuel cycle, often citing lack of evidence for viewpoints expressed.

there is a fair bit of evidence that the commission members themselves are in the majority, clearly quite pro nuclear. I am not happy at the lack of subjectivity that may have brought to the findings, particularly on the waste issue. Whilst Mr. Scarce did say that they did look at the negative sides of all the Issue papers, there is not much evidence of that in the Tentative Findings.

Kevin Scarse, would, I am sure, once again dismiss such criticisms as just “opinion” or “emotional”, “not fact-based” or “formed upon fear”.

The Royal Commission’s problem is that criticisms of its findings are fact-based.

The latest batch of submissions brings up many unanswered questions.

1. Aboriginal rights
Our involvement with fighting the nuclear industry is nothing new. We were long ago concerned by the government agreeing to uranium mining activities that have now permanently contaminated our land and our groundwater. We want no further expansion of the nuclear industry and we will continue to fight for our rights as traditional owners in respect of the wisdom of our old people that came before us. We care for our country. We only wish governments and industries would do the same. Anggumathanha Camp Law Mob

Our members consider that any attempt of a proposal to place this site on Aboriginal lands in SA will be a blatant disregard for the Custodians of their lands already so long disregarded.

These particular Findings of the Royal Commission (including their many subclauses, not included), which note expressly Aboriginal Communities and specifically those communities deeply affected by the British nuclear tests at Maralinga, ring immediate alarm bells for our members. – Ngoppon Together Inc

2. Economics.

The Royal Commission’s Tentative Finding, that substantial economic benefits could be obtained at low risk from the storage and disposal of used nuclear fuel in South Australia, is not soundly based. Excessive reliance has been placed on Jacobs MCM (2016), which has made over-optimistic assumptions in the financial analysis, such as the willingness of potential customers to pay for their share of the cost of the geological disposal facility before it has been built.

The proposal has major financial risks to taxpayers that have been ignored or played down in the Tentative Findings. These are sufficient grounds to reject the scheme. However, if the Royal Commission is determined to ignore or downplay the risks and recommend the proposed project, it should also recommend that the substantial financial risks be taken by a private corporation or consortium, not Australian taxpayers – Dr Mark Diesendorf

The proposal is that we should accept waste before the repository has been completely built and tested. This proposal is so reckless, as to be negligent. We would face the very real risk of being left with high-level nuclear waste, and no technology to properly handle it- Dr Andrew Allison

If Russia, with vast territory, a mature nuclear power industry, and experience with their own stockpiles of waste, could not establish a waste dump for profit, what chance does Australia have of succeeding in such an enterprise?- Meg Backhouse’s submission.

If this is such a great deal, how come no other country has grabbed it before now? – South Australian Greens

Item 88 How can financial assessments based on operating over about 100 years be relevant when the storage is required over many hundreds of thousands of years? Item 150 The Federal and State Government will have to underwrite the risks if the project goes ahead, which will require taxpayer funds. In the event of a disaster the Government (and therefore, the taxpayer) will be required to sort out the mess. – Graham Glover.

3. Safety.
Accepting waste that – in the Report’s own words ‘requires isolation from the environment for many hundreds of thousands of years’ (p 16) requires a very high-level of confidence that the risks associated with the location of such waste in our state are very low. The Tentative Report does not provide a level of evidence that can give confidence about these risks. Unfortunately the nuclear industry and its proponents have a long record of over stating the benefits of the nuclear industry and understating its risks – to the cost of citizens’ in terms of health, community stability, and economic outcomes. We are asked in the Tentative Report to take these recommendations ‘on faith’ given that the proposed high-level waste dump is not operational anywhere on earth – and, further, that the dump proposed for our state is twenty times larger than that planned (not actual) for Finland. – Mothers for a Sustainable South Australia

4. Transport dangers.
The Royal Commission apparently assumes that the movements of many hundreds of thousands of tonnes of spent nuclear fuel from many countries around the world to the Gawler Craton will be low risk, no problems and perfectly safe. As contradictory as those stances are, I do not accept that position of default safety. Further I do not accept that the unloading of the HLNW will be perfectly safe. I do not accept that road transport from port to repository site will be perfectly safe, even on a dedicated purpose built road. -submission from Paul Langley

We are concerned at the obvious dangers of transporting overseas high level radioactive wastes into our state and country. – Catholic Religious South Australia

5. Climate change

Has the NFCRC incorporated the potential impacts of climate change on the ecology and geology the State? It is essential that some scenario planning for climate change impacts be included in the assessment as conditions in the next one hundred years are likely to be very different to those experienced in the last 100 years. Trisha Drioli

There is no analysis of the potential impacts on the environment into the future. In fact, it is not possible to even comprehend what the environment could be like 100,000 years into the future. For example, climate change models predict significant changes in weather patterns including precipitation and temperature. Models of potential sea level rise indicate significant inundation of coastal areas, but if worst case scenarios eventuate, such as significant melting of the polar ice caps, most of South Australia would be underwater. That might take thousands of years, but there is nothing to indicate the possible impacts of the environment if a currently arid environment became wetter or if groundwater levels rose or if a site became completely inundated. Mark Parnell

6. Health
The Commission’s opening tentative finding states that “South Australia can safely increase its participation in nuclear activities, and by doing so, significantly improve the economic welfare of the South Australian community.”

The evidence base for adopting such a confident and conclusive statement is questionable. – factual evidence is given in this submission by Dan Monceaux
7. The legality of the Commission under question

THE WASTE REPOSITORY PROPOSAL VIOLATES EXISTING AGREEMENTS AND AUSTRALIAN LAWS – Dr Andrew Allison

It is currently South Australian law that “no public money may be appropriated, expended or advanced to any person for the purpose of encouraging or financing any activity associated with the construction or operation of a nuclear waste storage facility in this state.”

As a South Australian citizen, I am very concerned by what appears to be a disregard for the rule of law. This is particularly concerning as the nuclear industry across the world has a somewhat tarnished reputation when it comes to transparency and compliance with legal requirements. Any lack of confidence in the rule of law (whether perceived or real) will be extremely detrimental to this project and to South Australia as a democratic state. -from submission by Trish Drioli

8. Lack of transparency?
Transparency” is a term when used in such context, makes a mockery of public consultation and decision-making. In an industry that is hidden within Legislative Agreements that prohibit “freedom of information” and with information locked up in inter-departmental exchanges that circumvent any public disclosure, there is no transparency. Local get-togethers do not equal public engagement. These are serious matters which are of National concern from submission by Anne McGovern

Many who are attending the meetings in surrounding affected communities are stating they are being told it will be low level waste only, when the report clearly states that the profits expressed so strongly are actually determined on expected high level nuclear radioactive waste from international power stations and other uses, as stated on page 16, tentative finding number 73 through to 95, in addition to intermediate and low level waste. (NFCRC, 2016)

9. Impact on other industries.
The Nuclear Fuel Cycle Royal Commission Tentative Findings Report contains many generously overstated ambitions, almost no analysis of the environmental, tourism or agricultural consequences with its focus on narrowly supported economic benefits.

Concerns about environmental and safety effects of the waste depot are not the result of over-emotional, irrational fears. Holly-Kate Whittenbury

Item 155 Any chance of South Australia being regarded as the “Clean & Green” or the “Carbon Neutral” State will be overshadowed if this proposal goes ahead. Impacts on agriculture, tourism and the renewable energy sectors could be significant, irrespective of whether a major nuclear accident has occurred or not. South Australia could be known as the “Dumb” or the “Dump” State. – Graham Glover.

It was disappointing to note that “Impacts On Other Sectors” was given relatively little attention. … SAWIA notes that its members have genuine concerns about the potential risks to the reputation of the South Australian wine industry in the event of a nuclear accident occurring on South Australian soil.

Such a risk would also have the potential to harm the State government’s economic priority of ‘Premium Food and Wine produced in our Clean Environment and Exported to the World’ – SOUTH AUSTRALIAN WINE INDUSTRY ASSOCIATION INCORPORATED

10. Deceptive spin about medical wastes.

Even if the waste depot did only receive low level, medical waste, the facility would not be economically viable; medical waste, as described by physician Louise Emmett, only needs to be stored for such a short time that it would hardly make it to the waste facility for dumping, before it breaks down;

“In the vast majority of nuclear medicine practices the storage issue is not particularly current in terms of what we keep. It’s waste products have a short half life, up to eight days half life, so it would be difficult to take that long distances for storage.” (Baillie, R. 2012)

This quote was taken from a 2012 interview with ABC reporter Rebecca Bailie and described the deceptive and secretive attempts to store nuclear waste on Muckaty cattle station in the Northern Territory and describes the government and nuclear proponents’ spin on the storage of dangerous waste using medical uses as an excuse as a method of breaking down strong public resistance. Clearly, the supporters of the waste dump in 2016 are using the same deceptive techniques. Radiologist Doctor Peter Karamoskos has also pointed out the deception this time round in 2016;

It is at best misleading and at worst a lie to claim that a large-scale nuclear waste repository such as what is being proposed would be solely justified to handle the minuscule amounts of nuclear medicine waste generated in Australia.” (Parnell, M.2015)…….. Holly-Kate Whittenbury

1. http://nuclearrc.sa.gov.au/app/uploads/2015/09/Yuri-Poetzl-24-07-2015.pdf

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