Referral:
EPBC 2021/9128 — National Radioactive Waste Management Facility NRWMF, SA Submission by Philip White, Friends of the Earth Adelaide
Introduction
In response to the question raised in the Minister for the Environment’s invitation for comments, the proposed action is a controlled action. It is acknowledged as such by the proponent, the Australian Radioactive Waste Agency (ARWA).
Establishing that fact may be the formal aim of this particular part of the assessment process, but, before the proposal can proceed, it must be subjected to a full public Environmental Impact Assessment under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act).
It should not be approved based solely on documentation provided by ARWA, or anything less than an Environmental Impact Assessment, for reasons including the following:
The wastes that will be stored and/or disposed of need to be isolated from the environment for thousands of years. The long timescale greatly increases the opportunity for foreseen and unforeseen environmental impacts.
The transport of radioactive waste over thousands of kilometres represents a serious environmental hazard. Besides problems related to mishandling, there is the potential for various types of transport accidents. Radioactive waste shipments are also potential targets of theft, terrorism, or even, as we are currently seeing in Ukraine, acts of war.
The fact that the Barngarla traditional owners are opposed to the plan makes it even more important that aboriginal heritage issues are thoroughly addressed.
Recommendations
1. The referral should be rejected because (a) it is clearly opposed by the Barngarla people, the Traditional Custodians, and (b) there are better alternatives that have not been presented for consideration.
2. If, despite the arguments in recommendation 1 for rejecting the referral outright, the Minister decides not to reject the referral, it should not be accepted in its current form, based on s74A of the EPBC Act, which allows the Minister to not accept a referral if it is a component of a larger action. This proposal is clearly a component of a larger action, as is acknowledged by the proponent ARWA.
3. If, despite the arguments in recommendations 1 and 2 above, the Minister decides to consider the referral in its current form, there should be a full public Environmental Impact Statement under the EPBC Act. It is a controlled action with significant potential environmental and cultural impacts.
Prime minister Scott Morrison insisted on Thursday morning that the landmark nuclear submarine deal struck with US president Joe Biden and UK prime minister Boris Johnson won’t translate into a push for nuclear power plants in Australia. “Let me be clear: Australia is not seeking to establish nuclear weapons or establish a civil nuclear capability. And we will continue to meet all of our nuclear non-proliferation obligations,” Morrison said. On the issue of nuclear power plants, don’t believe him. Morrison could hardly have said anything else. It’s one thing to announce a switch to nuclear powered submarines without any broad social discussion, but quite another to commit the country to nuclear power. But the pro-nuclear lobby – both within and without the federal Coalition government – won’t be able to help themselves, even if the reality is that the sub construction won’t likely even start for the best part of a decade, and be complete for at least another 10 years after that, such is the complexity of the technology. The nuclear lobby will say it is bizarre that Australia could be the only country in the world planning to sustain a nuclear powered submarine fleet without a civil nuclear industry. Even the retired Admiral Chris Barry noted that the absence of a civil nuclear industry left a “big gap” for Australia to manage a submerged nuclear fleet.
Following secret deliberations, this week, the Morrison government has announced that Australia will acquire nuclear-powered submarines. Anti-nuclear movement stalwart, and Friends of the Earth National Nuclear campaigner, Dr. Jim Green, had these comments to common questions about the decision.
Nuclear powered submarines typically use highly-enriched uranium (HEU) fuel. This would undermine global efforts to phase out the use of HEU because of WMD proliferation and security concerns.
The Nobel Peace Prize-winning International Campaign to Abolish Nuclear Weapons notes: “Military nuclear reactors in Australia would present a clear nuclear weapons proliferation risk and become potential sites for nuclear accidents and radiological contamination long into the future.”
The government wants to build nuclear submarines in suburban Adelaide. Does that put a target on our back? Is it prudent to build nuclear submarines in a city of 1.3 million people? What alternative locations have been considered, if any?
Does the government secretly want to bring Australia closer to a nuclear weapons capability with a nuclear submarine program? Do such deliberations explain why the Morrison government refuses to sign the UN’s Treaty on the Prohibition of Nuclear Weapons and has actively undermined the Treaty at every step? (In the late 1960s, John Gorton’s government actively pursued a nuclear power program and Gorton later acknowledged a hidden weapons agenda. Gorton actively opposed Australia signing the UN’s Nuclear Non-Proliferation Treaty.)
Will this encourage the broader nuclear industry?
Then Defence Minister Christopher Pyne noted that in 2019 that Australia would be the only country in the world with nuclear submarines but no domestic nuclear industry to back them up.
All countries operating nuclear submarines (the five ‘declared’ weapons states plus India) have both nuclear power and weapons.
Opposition leader Anthony Albanese says that Labor support for nuclear submarines is conditional on there being no requirement for a domestic civil nuclear industry (among other conditions).
What about nuclear waste?
The government has been silent about disposal of the high-level and intermediate-level nuclear waste generated by a nuclear submarine program.
No country in the world has a repository for high-level nuclear waste. The only deep underground nuclear waste repository in the world ? the Waste Isolation Pilot Plant in the US, for disposal of long-lived intermediate-level nuclear waste ? was shut down from 2014 to 2017 following a chemical explosion in a waste barrel, with costs estimated at $2 billion (clean-up, lost income etc).
Waste from a nuclear submarine program would be dumped on Aboriginal land, as is the case with the federal government’s current plan to dump Australia’s nuclear waste at Kimba in SA despite the unanimous opposition of Barngarla Traditional Owners. It speaks volumes about the crude racism of the federal and SA Coalition governments that they are prepared to ignore unanimous Aboriginal opposition to a nuclear dump. The federal government even fought to exclude Traditional Owners from a so-called ‘community survey’. SA Labor’s policy is that Traditional Owners should have a right of veto over any proposed nuclear facility including a nuclear waste dump.
The high-level and long-lived intermediate-level nuclear waste generated by nuclear submarines would cost tens of billions of dollars to dispose of, based on cost estimates overseas. For example, the cost estimate for a high-level repository in France is A$40 billion. The US government estimates that to build a high-level nuclear waste repository and operate it for 150 years would cost A$130 billion. The South Australian Nuclear Fuel Royal Commission estimated a cost of A$145 billion over 120 years for construction, operation and decommissioning of a high-level nuclear waste repository.
It is highly unlikely that the government has considered these massive long-term costs in its secret deliberations.
Do I get a say in all this?
A 2019, a federal government-dominated parliamentary committee released a report on nuclear power titled ‘Not without your approval’. The report emphasised that nuclear power would not be pursued without community support.
But now, the federal government has secretly decided that Australia will acquire nuclear submarines and any consultation will likely be tokenistic. This is the DAD — Decide, Announce, Defend — approach which is the antithesis of good government.
Despite the government’s secrecy and obstinacy, the plan for nuclear submarines could easily collapse for any number of reasons — economics, the availability of superior options, public and political opposition etc.
Reject the federal Liberal’s unlawful, unfair, unsafe and unnecessary nuclear waste dump plan for SA
Premier Stephen Marshall must stand up for South Australia’s interests and push back on federal Liberal government imposition of an unlawful nuclear waste dump in our State.
The Premier has a duty to respect and uphold the law in SA that prohibits the import, transport, storage and disposal of nuclear waste in our State.
The NUCLEAR WASTE STORAGE FACILITY (PROHIBITION) ACT 2000 was passed by the SA Parliament under the leadership of Liberal Premier John Olsen and strengthened by Labor Premier Mike Rann:
The objects of this Act areto protect the health, safety and welfare of the people of South Australia and to protect the environment in which they live by prohibiting the establishment of certain nuclear waste storage facilities in this State.
As Premier you should give all South Australian’s a Say and take action to instigate a required public inquiry into the impacts of a nuclear waste storage facility on the environmental and socio-economic wellbeing of this State.
If a licence, exemption or other authority to construct or operate a nuclear waste storage facility in this State is granted under a law of the Commonwealth, the Environment, Resources and Development Committee of Parliament must inquire into, consider and report on the likely impact of that facility on the environment and socio-economic wellbeing of this State.
The Port of Whyalla is targeted for shipments of ANSTO nuclear fuel waste and communities along proposed nuclear waste transport routes across our State all have a right to have a Say.
Nuclear waste dumping is a Human Rights issue for our fellow Indigenous South Australian’s. As Minister for Aboriginal Affairs, Stephen Marshall should support the Barngarla People’s right to say No to nuclear waste storage on their country:
The “United Nations Declaration on the Rights of Indigenous People” (2007) Article 29 calls on States “to ensure that no storage or disposal of hazardous material shall take place in the lands or territories of indigenous peoples without their free prior and informed consent.”
The federal Liberal government proposes to ship and truck nuclear waste across SA into indefinite above ground storage in a fancy shed at Napandee on Eyre Peninsula – without any capacity or even a plan for its eventual permanent disposal.
SA’s clean green reputation, and our prime agricultural lands and farming communities, deserve better than untenable imposition of toxic nuclear wastes in a shoddy reckless federal plan to park and dump wastes that require isolation from the environment for 10,000 years.
95 per cent of Intermediate Level Waste (ILW) in Australia are owned by Commonwealthgovernment agencies, the vast majority is produced and held at ANSTO’s Lucas Heights reactor facility in Sydney – where it should stay in secure extended storage.
The federal Budget provided $60 million for further decades of extended storage capacity for ILW at ANSTO Lucas Heights, building onto the operation of existing stores to 2026.
In 2015 a separate Interim Waste Store for ANSTO nuclear fuel waste was built at Lucas Heights with a design capacity for 40 years. This store received a shipment of reprocessed nuclear fuel waste from France in 2015 and is intended to now receive a shipment from the UK in 2022, and is safety rated to 2055.
The CEO of the federal nuclear regulator ARPANSA stated in evidence to a Senate Inquiry in 2020: “Waste can be safely stored at Lucas Heights for decades to come.”
The federal Liberal government proposes to bring all these nuclear wastes to SA, along with decades of ANSTO’s further proposed nuclear waste production and future shipments of ANSTO reprocessed nuclear waste from France.
