Ngoppon Together Inc. (Walking Together Reconciliation Group)

We acknowledge the Land, Waters and Environment of the Ngarrindjeri People,

the traditional custodians of this area

Royal Commission into the Nuclear Fuel Cycle SUBMISSION TO ISSUES PAPERS 1 - 4 Ngoppon Together Inc is an organisation based in Murray Bridge SA of community members from diverse backgrounds with Aboriginal and non-Aboriginal members. We recognise that Aboriginal peoples have a long history of dispossession and disadvantage which still impacts today. Our common purpose is to contribute to a fair and cooperative community locally and generally, where all people, particularly Aboriginal people, are accepted and valued for who they are, their beliefs, customs, history and cultural practices. In writing our submission to the Royal Commision into the nuclear fuel cycle we are conscious of our responsibility as South Australians to work to ensure our state of South Australia continues to provide a healthy and safe environment for its peoples (present and future generations), lands and water. As a Reconciliation group we strongly recognise the need for our state with our particular historical past, to refrain from compounding mistakes made in the past in this nuclear area, including in regard to Aboriginal communities.

1.7 Is there a sound basis for concluding that there will be increased demand for uranium in the medium and long term? Would that increased demand translate to investment in expanded uranium production capacity in South Australia (bearing in mind other sources of supply and the nature of South Australia’s resources?).

Our members appreciate the Royal Commission’s desire for submissions to be based on fact and extracts carefully noted. Below we present evidence from both a mining analyst and from a conservation group as a very ‘sound basis ‘ that there is not now, and there seems no evidence that there will be, ‘increased demand for uranium.’ Uranium equities are currently trending below the uranium spot price and have been under-performing long term (since Fukushima in 2011). The average loss since January 2011 is 85% and equity went down 25% in the financial year 2015. Matthew Keane, Metals and Mining Research Analyst, Argonaut Ltd Uranium Conference Perth July 2015 From mid-2000’s until Fukushima in 2011, production was in a period of stagnation Uranium price was lower than average cost of production, produces <0.2% of national export revenue and accounts for less than 0.02 per cent of jobs in Australia. Conservation Council of SA (CCSA) report 2015 p14 We submit an Australian example: ERA Energy Resources of Australia (ERA) has posted losses for each of the past five years, totalling $500 million. ERA has struggled with the political and economic impacts of many mine leaks and high impact accidents ( identified in 1.8 below) CCSA 2015.

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Ngoppon Together adds our warning to easy acceptance of those pro-uranium enthusiasts– no doubt many of whom who will contribute to the Royal Commission. We fear that enthusiasts’ reports, backed up as they have and can be, by easy access to the media in SA are dangerously ill -informing the South Australian community with fallacious claims. We present an example: our members well remember the claims which appeared in the local media of South Australia becoming the ‘Saudi of the South. ‘We present the reality: Politicians, academics and uranium industry representatives have drawn comparisons between the potential of Australia's uranium industry and Saudi oil revenue. The comparisons do not stand up to scrutiny. Australia would need to supply entire global uranium demand 31 times over to match Saudi oil revenue. Australian Conservation Foundation (ACF), 2013, 'Yellowcake Fever: exposing the uranium industry’s economic myths', www.acfonline.org.au/resources/yellowcake-fever-exposing-uranium-industrys-economic-myths

In this regard, we call upon the Royal Commission to act with the utmost integrity to ensure this reality is presented at all times – not only in these quite over -the -top headlines but in the truth of the actual basic facts and genuine risks of this, the world’s most dangerous industry.

1.8 Would an expansion in extraction activities give rise to new or different risks for the health and safety of workers and the community? If so, what are those risks and what needs to be done to ensure they do not exceed safe levels?

Ngoppon Together emphasises that an expansion would give rise to both new AND different risks for the health and safety of workers and communities as well as continue the quite substantial risks of the present. The planned expansion (now delayed) of BHPBilliton’s Olympic Dam in our state, was intending

to use an incredible 250 million litres of water A DAY! of the desert State’s water. leave a 44 sq. kilometre mountain range of 76 million tonnes of radio-active waste

uncovered (to be blown about the state by the fierce spring winds of the SA desert.) while using one quarter of the State’s electricity (various reports)

Over the years since the opening of the SA Roxby Downs/Olympic Dam mine -regardless it would seem of the identity of the various operators-there have been multiple leaks and even shutdowns.

Photos taken by an Olympic Dam mine worker in December 2008 showed multiple leaks of radioactive tailings liquid from the so-called rock armoury of the so-called tailings retention system. BHP Billiton's response was to threaten "disciplinary action" against any worker caught taking photos of the mine site. BHP Billiton claimed that the "allegations" related to a single incident when a small damp patch appeared on the wall of the tailings retention system. In fact, the photos clearly showed multiple leaks, and the leaks were ongoing for months.

The Monitor, 1 April 2009, 'BHP Billiton opens up on tailings'

Olympic Dam generates 10 million tonnes low-level tailings waste each year . We wonder at the safety of this material. Our members also remember well the multiple severe risks, dangers and actual disasters that the Traditional Owners, the Mirrar, have faced in the life of uranium mining at the Ranger mine NT. Our following quotation names just the latest disasters in the long history of these mines …a December 2013 leach tank collapse at Ranger resulting in the spillage of 1.4 million tonnes of radioactive slurry; the collapse of a ventilation shaft in 2014; and the revelations of a whistleblower published in the Mining Australia magazine in May 2014. CCSA Report 2015

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The Ranger mine has generated over 30 million tonnes of liquid tailings waste. Rio Tinto subsidiary Energy Resources of Australia (ERA) runs Ranger. In 2005, ERA was found guilty and fined for a contamination incident in March 2004 where 150 people were exposed to drinking water containing uranium levels 400 times greater than the maximum Australian safety standard. Twenty-eight mine workers suffered adverse health effects including vomiting and skin irritation as a result australianmap.net The present dangers of this industry’s contamination directly to workers and community members, to the land and waters are only too clear to need our further elaboration. Surely they provide ample reason why there should be no further expansion of this industry and indeed sufficient evidence for the closing down of presently active mines. 1.9 Are the existing arrangements for addressing the interaction between the interests of exploration and extraction activities and other groups with interests such as landowners and native title holders suitable to manage an expansion in exploration or extraction activities? Why? If they are not suitable, what needs to be done?

As a Reconciliation group, Ngoppon Together is particularly concerned with this question. Ngoppon Together works towards achieving greater recognition of the rich laws and cultures of our First People. By breaking with their laws and culture, we diminish the whole Australian nation, both by damaging our beautiful land, Mother Earth, and by ignoring her cultural beliefs. Mining uranium has caused immense suffering and displacement of Aboriginal communities. in SA as well as elsewhere in Australia. Some of our members recall the Kokatha in the sandhills of Roxby Downs in the 1980s in the desperate hope of stopping the Roxby uranium mine before such a mine wreaked havoc on Kokatha country and on the ancient waters of the Arabunna. Regarding the proposed expansion of Olympic Dam we know that the Traditional Owners were not even consulted. BHP Billiton held all the cards and merely had to say that they wanted to continue the (exremely favourable to them) previous conditions.

Of old, the tactics of the mining companies in Australia and no doubt world wide are to divide and conquer. Peoples who have been dispossessed and so in consequential poverty have been prime candidates for such tactics causing deep divisions both within and between various language groups. An added problem is the guilt and shame of the Traditional Owners who have lost the fight to protect their country and their awareness that they have not been able to carry out this reponsibility in the face of the huge influence, massive resources and often underhand tactics of the mining companies. The problems of felt responsibility have multiplied together with the fulfilment of the concerns and warnings of the Traditional Owners regarding the destruction of country and waters and the consequential dangers and serious effects on their own, their children’s and future generations’ health and well-being -and as well on the health of the workers. Ngoppon Together members live and work on the lands of the Ngarrindjeri peoples. As such, our members are acutely aware that while the Ngarrindjeri are a group of Aboriginal people who may not have yet been subjected to the dangers and threats to health on their lands that the nuclear cycle delivers, however they have, as a group, in their struggles to protect their lands, waters and culture, their own mental health and well being for themselves and for future generations, been subject to every one of the following tactics summarised by the environmental group Friends of the Earth. Tactics used by the nuclear industry with Aboriginal Traditional Owners up to the present day

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‘have included ignoring the concerns of the Traditional Owners insofar as the legal and political circumstancess permit; divide and conquer tactics; bribery; ‘humbugging’ Traditional Owners’ (exerting persistent and unwanted pressure; providing Traditional Owners with false and misleading information; threats, most commonly legal threats.’ Friends of the Earth paper January 2013 To this list we could add the well known tactics of mining magnates with a reputation for refusing to pay royalties to the Traditional Owners. The Ranger uranium mine operates on the lands of the Mirarr Traditional Owners. The mine lease sits within the bounds of the Kakadu National Park and has been in place for over 30 years. In that time there have been over 200 leaks, spills and breaches of licence conditions. In 2009, it was revealed that around 100,000 litres of contaminated water is leaking daily from the tailings dam. australianmap.net In partial answer to question 1.9 it’s clear that these practices need to cease and that there be strict controls to ensure that right relations become a reality. However we also stress the bottom line as follows: Ngoppon Together submits that the only way to ethically operate on the lands of Traditional Owners is to cease giving mining permissions to those companies who intend to mine uranium with its unavoidable risks to these lands and waters and public health and safety for Aboriginal people and indeed of all South Australians. Apparently it is possible even in a mine with the huge reserves of Olympic Dam to mine only the accompanying copper, gold and silver. Aboriginal people have said “leave it in the ground … these are dangerous places” when considering and referring to Uranium ore deposits.

In the likely event this course of action is not taken, then our members advise in the

strongest possible terms that the absolute minimum protection is to ensure the legislation for Aboriginal Heritage is never overridden as it has been in the case of Olympic Dam to CEASE WEAKENING THE ABORIGINAL HERITAGE LEGISLATION and to restore the Act at least to its original strength ENSURE EXISTING MINING LEASES INCLUDING URANIUM MINING LEASES IF THEY ARE TO CONTINUE cf ROXBY DOWNS /OLYMPIC DAM ARE REQUIRED TO COME UNDER THE SA ABORIGINAL HERITAGE ACT FOR WHICH BHP/BILLITON IS PRESENTLY EXEMPT 1.10 Would a future expansion of exploration, extraction and milling activities create new environmental risks or increase existing risks? If so, are current strategies for managing those new risks sufficient? If not, in what specific respects? How would any current approach need to changed or adapted?

In one word- Obviously As above Olympic Dam has a history of very significant environmental impacts. See above and - The use of WATER is a huge risk to the environment in South Australia – the driest state in the driest continent. The existing undergound mine at Olympic Dam/Roxby Downs uses 35 million water each day, from the GAB Great Artesian Basin making it the largest industrial user of underground water in the southern hemisphere. 1.13 Would an increase in extraction activities give rise to negative impacts on other sectors of the economy Have such impacts been demonstrated elsewhere in Australia or in other economies similar to Australia?

The Hunter Valleyand The various other former agriculture and food areas taken over or attempting to live side by side with fracking.

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ISSUES PAPER TWO FURTHER PROCESSING OF MINERALS AND MANUFACTURE OF MATERIALS CONTAINING RADIOACTIVE AND NUCLEAR SUBSTANCES 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?

Regarding Enrichment The 2006 Switkowski Review points out that (a)there is little opportunity for Aust companies to extend profitability to enrichment (b) the world enrichment market is already heavily over-supplied 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?

Regarding any potential role of thorium, we quote from the experts: ‘Contrary to the claims made or implied by thorium proponents, however, thorium doesn’t solve the proliferation, waste, safety, or cost problems of nuclear power, and it still faces major technical hurdles for commercialization.’ Arjun Makhijani and Michele Boyd -Thorium Fuel: No Panacea for Nuclear Power

2.7 What are the processes that would need to be undertaken to build confidence in the community generally, or specific communities, in the design, establishment and operation of such facilities?

We again call upon the Royal Commission to act with the utmost integrity to ensure this reality is presented at all times –in the truth of the actual basic facts and genuine risks of this, the world’s most dangerous industry.We recognise that the media including the local print media, especially in the last three or four years can and often seems to act as a propaganda vehicle for the implementation on all aspects of the nuclear fuel cycle

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?

As below for Nuclear power generation and radiactive storage facility 2.14 Would South Australia’s establishment and operation of such facilities give rise to impacts on other sectors of the economy? What would those impacts be? How should they be estimated and what information should be used? Have such impacts been demonstrated in other economies similar to South Australia?

The establishment of further processing of minerals and manufacture of materials containing radioactive and nuclear substances in South Australia with all the risks and negative effects outlined above would undermine and even destroy the state’s vital fishing, agricultural, world famous wine and also the tourism sectors. If such a facility is established the State’s largely clean, green image will be impossible to sustain. tourist destinations obviously lose appeal when travel arrangements are considered – a possibility of sharing the road or railtrack with highly toxic radioactive waste, whether marked or not: not every SA tourist place is accessible by plane (ANSTO has acknowledged that there are 1-2 accidents or ‘incidents’ every year involving the transportation of radioactive materials to and from the Lucas Heights reactor plant. The NSW Parliamentary Inquiry into radioactive waste found there “is no doubt that the transportation of radioactive waste increases the risk of

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accident or incident – including some form of terrorist intervention”.) If South Australia has sometimes been in danger of being known as a ‘cinderella ‘ state, any former such thought will be multiplied enormously. Action – withdrawal, loss of industries especially food industries, the loss of populations, especially of the well off classes of South Australian citizens. The Hunter Valley and the various other former agriculture and food areas taken over or attempting to live side by side with fracking. ISSUES PAPER THREE: ELECTRICITY GENERATION FROM NUCLEAR FUELS 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? NO In particular we warn against the proponents of nuclear power being permitted to look towards the Aboriginal lands of Maralinga or the APY Lands when such lands and peoples suffered through the generations even to the present from the British nuclear tests. After many supposed ‘clean ups’ through significant cost, much, if not all, of the Maralinga Lands are still contaminated to some degree, particularly the Taranaki area. When advanced and technologically savvy countries like Germany are withdrawing from the production of nuclear energy, Ngoppon Together questions strongly: why should we in South Australia succumb to the pressures of a frightened and failing nuclear industry looking for ever restricted areas of the global market to establish their products? The main basis for our NO assessment is the number of nuclear accidents: 99 accidents at plants 1952—2009 57 accidents since Chernobyl in 1986 (56 in the USA) and the tie up of the nuclear accidents with an increased incident of cancer. Long-term cancer death toll (Chernobyl estimate 16,000 to 93,000) Fukushima estimate is currently at about 5,000 cancers (UK radiation biologist Dr Ian Fairlie) Ngoppon Together also cites the trauma of relocation to the men, women and children as a result of these nuclear disasters: of 350,000 people after Chernobyl/ 80,000 after Fukushima. Our members remember mainstream media accounts at the time and many months after, the Fukushima disaster when the fear of radiation was so high that families were frightened to even let their children outside. (various sources including CCSA 2015) Indeed we have our own SA example to this trauma of displacement and severe health problems through the nuclear industry in the lives of the Southern Pitjantjantjara, displaced from their country by the British nuclear tests for the next 25 years, left with contaminated country of Maralinga, plagued by widespread difficulties and health problems to this day. Such knowledge from both Australia and overseas cause our members to wonder again and again- Why would any South Australian intending to remain in the state be a proponent of nuclear power ? Why would any SA politican, trusted with the duty of care to his/her electorate and State be a proponent of nuclear power for South Australia?

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3.2 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?

‘Next generation reactors first Generation 1V systems expected to be deployed commercially in 2030-2040’. (The International Atomic Energy Agency) This is 15 to 20 years down the track and yet we understand that proponents of nuclear power alocally have been writing and speaking of such ‘next generation reactors’ as though they were almost a reality. Again our members warn how it is essential to avoid illusions in the conclusions and recommendations and reports to the public of the Royal Commission 3.7 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?

While the nuclear advocates are wont to speak of a ‘Renaissance’ in the establishment world wide of nuclear power reactors, Ngoppon Together addresses the reality of the situation

operable reactors fell 443 to 437 in 10 years to Jan 2015 2014… world capacity increased by 2.4GW 2014… world capacity Solar and wind power increased by 100GW 2013… world capacity Solar and Wind power was 74GW ( CCSA 2015) Cost? Nuclear power stations have very large start up costs. Nuclear becomes more expensive over time (renenewables expenses decrease). The nuclear power industry can survive only because of huge taxpayer subsidies (the money of we taxpayers). EnergyScience Briefing paper#1:energyscience.org.au Our members believe that insurance companies do not insure nuclear power stations so that is another enormous expense for the taxpayer when disaster strikes cf Fukushima. Water Nuclear power reactors typically consume 35-65 million litres of water a day ‘Coal fired power-plants have large water requirements for cooling and steam generation, but these are dwarfed by the water needs of nuclear power.’ Tim Flannery, Australian Climate Change Commissioner Greenhouse Emissions. ‘Nuclear power emits three times more greenhouse gases than windpower.’ Switkowski Report 2006 Our members are united in saying that there is NO place for electricity generated by nuclear fuels to play in the medium or long term electricity market. With immediate safety and long term issues of safety in mind, we point out the obvious: as opposed to nuclear fuels energy, renewable energies have by far the lowest risk of any immediate contaminations, cost less to establish, do not require impossible lenghts of time under close supervision and are unlikely to be a terrorist target. We remind the Commission that the rods from nuclear fuel generation will need an impossible 100,000 years to be safeguarded (Dr Mark Diesendorf UNSW) We go further to remind the Commission that it is their solemn responsibility to ensure that the general population of South Australians are clearly informed of this extraordinary circumstance – that it is indeed highlighted and noted in plain English in their publications in any media releases and interviews.

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3.8 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?

Lack of safety, enormous cost, long term and short term disadvantages and the complete worldwide inability of technology to find a safe way of storage of nuclear spent fuel rods of the nuclear power facilities are the extremely urgent issues to be considered. An urgent salient issue for the legislative decision -makers of the driest state in the driest country to keep squarely in their sights: 1000 megawatt reactors require up to one million gallons per minute to keep them cool. Ngoppon Together submits that there exists already abundant and very accessible reliable analysis and urges that the Royal Commission accepts the advantages of the renewable energies sources, having the courage to deny the powerful advocates of the nuclear industry within the state in their push for an industry which has so much danger and so little to recommend it. We quote at some length Dr Mark Diesendorf’s recent report for CCSA:‘100% renewable electricity for South Australia’(June 2015)which documents the many positives of renewable energy, highlighting those substantial benefits that have already been achieved; ‘SA households have embraced rooftop solar with open arms – over one quarter of us have it. Every renewable energy target and expectation has been beaten time and time again. And while the year on year trend is for the costs of renewable energy to continue to fall, the trend for nuclear power is the opposite – it’s getting more expensive over time, not less. The shift to a reliable electricity system with 100% renewables in SA is not only feasible, but also affordable. As the amount of renewable energy in our energy grid increases, it brings down the wholesale price of electricity. This transition also increases the requirement for flexible, ‘dispatchable’ renewable technologies that complement wind and solar PV. Baseload power stations such as coal and nuclear become redundant. We simply won’t need dirty coal-fired power stations, and we won’t need to build any nuclear power plants. In fact, compared with nuclear power, renewable energy is more reliable, much less dangerous, less expensive, emits less life-cycle CO2, offers a wider range of environmental, health and employment benefits, and can be implemented much more rapidly. Furthermore, a standard- sized nuclear power station would be too big to fit into the SA grid and small reactors are not commercially available. It’s simply not an option for our state based on cost, size and need. 3.9 What are the lessons to be learned from accidents, such as that at Fukushima, inrelation to the possible establishment of any proposed nuclear facility to generate electricity in South Australia? Have those demonstrated risks and other known safety risks associated with the operation of nuclear plants been addressed? How and by what means? What are the processes that would need to be undertaken to build confidence in the community generally, or specific communities, in the design, establishment and operation of such facilities?

The lesson to be learned from Fukushima (or Chernobyl or any of the other many nuclear disasters worldwide including Three Mile and many others in the affluent United States) is that IT IS IMPOSSIBLE TO ELIMINATE RISKS OR EVEN THE NEAR PROBABILITY OF RISKS IN THIS ULTRA DANGEROUS INDUSTRY USING THE MOST DANGEROUS SUBSTANCE EVER KNOWN in the tens of thousands of years of human existence. There are no safeguards as addressed above that can, nor will ever address the dangers

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arising from the generation of nuclear energy.

We stress again that the best lesson learned is the admission of these dangers, the refusal to impose them on the South Australian people, lands and waters and the whole hearted adoption of renewable energy already proudly commenced.

3.13 What risks for health and safety would be created by establishing facilities for the generation of electricity from nuclear fuels?

Regarding risks to children Dr Ian Fairlie states: "The core issue is that, world-wide, over 60 epidemiological studies have examined cancer incidences in children near nuclear power plants (NPPs): most (>70%) indicate leukemia increases. I can think of no other area of toxicology (e.g. asbestos, lead, smoking) with so many studies, and with such clear associations as those between NPPs and child leukemias. Yet many nuclear Governments and the nuclear industry refute these findings and continue to resist their implications. It's similar to the situations with cigarette smoking in the 1960s and with man-made global warming nowadays. Ian Fairlie, 25 July 2014, 'Childhood Leukemias Near Nuclear Power Stations', www.ianfairlie.org/news/childhood- leukemias-near-nuclear-power-stations-new-article/

The weight of scientific opinion holds that there is no threshold below which ionising radiation poses no risk of inducing fatal cancers. Radiation protection agencies around the world including the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA), all base regulations on the linear no-threshold model which assumes there is no threhold below which radiation exposure is safe. Friends of the Earth ‘Ionising Radiation and Cancer.’ Jan 2013 (our emphasis) In 2012, cancer was estimated to be the leading cause of burden of disease in Australia, accounting for approximately 19 per cent of the total disease burden. In 2012, cancer was estimated to be the leading cause of burden of disease in Australia, accounting for approximately 19 per cent of the total disease burden.3 Australian Institute of Health and Welfare & Australasian Association of Cancer Registries2012.Cancer in Australia: an overview, 2012. Cancer series no. 74. Cat. no. CAN 70. AIHW. What needs to be done to ensure that risks do not exceed safe levels?

Unfortunately this is an impossible task see evidence cited above and below. The genuine need is to prevent the building of such a dangerous facility as a nuclear power station which jeopardises the health of children as well as adults, which lays our state open to the derisive title of the Radioactive State with all the negative consequences for health, safety, wealth and wellbeing of its citizens from thereon.

Ngoppon Together members note with astonishment that the possible sites identified for South Australia by the Australia Institute nuclear power plants in a 2007 report were Mt Gambier / Millicent Port Adelaide Port Augusta and Port Pirie Are residents of those sites happy for site construction? Their local media made clear the immediate indignation of Port Adelaide residents with Mayor Johansson suggesting the better suitability of Port Augusta. This in turn led to front page article/photos in the Transcontinental

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with predictable indignation from their Mayor and residents to both the original selection body and to the Port Adelaide residents. The Royal Commission from the outset has made the point that the investigation into the nuclear cycle was confined to ‘peaceful purposes.’ Of course. And no doubt the present proponents have this in mind. However, our members realise we would be remiss if we failed to mention the possible link of a nuclear reactor facility with nuclear weapons. It is our suggestion that no-one in this discussion must so naïve as to ignore the fact that of the ten states (countries) known to have produced nuclear weapons, five did so under cover of their ‘peaceful’ weapons programs.

Neither should we as Australians think that our own Governments will never succumb to the building of a nuclear weapon if a decision were made to build this infrastructure initially for electricity. Doing so leaves the opportunity open in the future to increasingly fearful governments in our own country to making their own nuclear weapon. Lest that be dismissed by the Commission as out of the question we remind the Commission that PM John Gorton announced that the proposed power reactor he envisioned in the late 1960s in Jervis Bay ‘because it could provide electricity to everyone and it could, if you decided later on, it could make an atomic bomb.’(reported SMH Jan 1999)Friends of the Earth 2013

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? The establishment of a nuclear reactor in South Australia with all the risks and negative effects outlined above would undermine and even destroy the state’s vital fishing, agricultural, world famous wine and also the tourism sectors. If such a facility is established the State’s largely clean, green image will be impossible to sustain. tourist destinations obviously lose appeal when travel arrangements are considered – a possibility of sharing the road or railtrack with highly toxic radioactive waste, whether marked or not: not every SA tourist place is accessible by plane (ANSTO has acknowledged that there are 1-2 accidents or ‘incidents’ every year involving the transportation of radioactive materials to and from the Lucas Heights reactor plant. The NSW Parliamentary Inquiry into radioactive waste found there “is no doubt that the transportation of radioactive waste increases the risk of accident or incident – including some form of terrorist intervention”.) If South Australia has sometimes been in danger of being known as a ‘cinderella ‘ state, any former such thought will be multiplied enormously. Action – withdrawal, loss of industries especially food industries, the loss of populations, especially of the well off classes of South Australian citizens. The positive alternative is still possible as SA presntly is the leading state in renewable energy and has the opportunity if taken by governent to go down this positive healthy path to maintain a clean, safe country and waters, safe and healthy employment opportunities and for the safety, health and well being of all of its citizens Have such impacts been demonstrated in other economies similar to Australia? The Hunter Valleyand The various other former agriculture and food areas taken over or attempting to live side by side with fracking 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

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relevant conditions? What is the evidence that suggests those conditions are suitable or not? What requires further investigation now and in the future?

NO "Australia is relatively stable but not tectonically inert, and appears to be less stable than a number of other continental regions. Some places in Australia are surprisingly geologically active. ... To the extent that past earthquake activity provides a guide to future tectonic activity, Australia would not appear to provide the most tectonically stable environments for long-term waste facilities." Dr Mike Sandiford, the School of Earth Sciences, University of Melbourne.

As Dr Sandiford also points out the big ones have tended to occur in somewhat unexpected places Commission members may be surprised to learn that the Aboriginal community of Pukatja/Ernabella in the APY Lands SA has recorded several earthquakes. Of course we know about the earthquakes there as since the opening of the Presbyterian Mission there by Dr Duguid in the late 1930s there have been records. There must be vast areas in the SA outback which may have seen the same activity and of course been unrecorded.

4.2 Are there nuclear or radioactive wastes produced in Australia which could be stored at a facility in South Australia? In what circumstances would the holders of those wastes seek to store or dispose of that waste at facilities in South Australia?

During the six year long campaign against the Federal Government’s attempts to establish a radioactive dump in South Australia 1998-2004, we the people of SA heard every argument possible about what sort of materials are sought to be stored, how inoffensive they were, things like watches that shine in the night, how it would be no trouble to transport them hundreds of kilometres across the country, how terrible it was that hospitals had to be bothered storing their used radioactive clothing, how there were already many drums of radioactive waste stored in a facility in Woomera so SA may as well have a dump nearby or nearly nearby, how the dump ( repository) wouldn’t be larger than a football field…

All the while many of us, surely most of us could only ask the question – if it’s all so harmless why not keep it where it is? Of course the spent fuel rods of the governmenst’s reactor at Luca Heights aren’t so harmless and, as suspected, were the primary reason for the ongoing search to find a place in the nation where people would be forced to have the nuclear waste, if they not willing to have a dump. Never mind the materials wouldn’t have the same expertise to safeguard their supervision as they would if they remained at the Lucas Heights facility; that the drums would eventually decay; that the dump would be unlined, that it is a great distance half way across the nation from Sydney to ‘outback’ SA; that Aboriginal people and their beliefs would be disregarded, their intimate knowledge of country (the ‘outback is not as dry as you think’ ) ignored; their fears for the contamination of ground waters unheard.

Then the poliically disposable SA turned out not to be so politically disposable with the support of the then State Labor Government and that campaign was won with Federal Senator Minchin’s head lined ‘rolled gold’ assurance that a dump would never be built in South Australia .

Now just 11 years later the campaign has got more sophisticated and the repository is now a facility, a Royal Commission has been established and there are many specific questions posed like the ones at the top of this page rather than demands made. At least at this stage.

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But the task is still the same. Ngoppon Together’s answer - leave it where it is, where the expertise is, in Lucas Heights where it won’t be out of sight, out of mind; so that we avoid the hope of the pro-nuclear lobby and the consequent burgeoning of high and intermediate level waste in having finally established a repository, nuclear power will be far more possible (and the pressure to establish a nuclear power reactor thus increase.)

Measured by radioactivity, spent nuclear fuel reprocessing waste from Lucas Heights reactors accounts for over 90% of the waste the Government wants to dump ... Although the volume of this waste is relatively small – some tens of cubic metres – it is by far the most radioactive material “ANSTO is capable of handling and storing wastes for long periods of time. There is no difficulty with that.” Dr Ron Cameron, ANSTO.(Lucas Heights (quoted in ‘Nuclear Freeways ‘)

4.3 Would the holders of nuclear or radioactive waste outside Australia seek to store or dispose of that waste in South Australia? Who holds that waste? What evidence is there that they are seeking options to store or dispose of wastes elsewhere including in locations like South Australia? If so, what kinds of waste and what volumes might be expected? What would the holders be willing to pay and under what arrangements?

Our members can only reply: Of course other countries would be delighted to know that some other country would be both so foolish and foolhardy to be prepared to accept their radioactive waste - dangerous for 100,000 years or more! BUT- What price could the receivers possibly put on the likely and irreversible damage to their country and waters, its people, its children? In such a vast country to discount the potential high level dangers of transport? Do we have no responsibility towards the future generations of South Australian and indeed Australian children? One can envisage future court cases which will be fought in the future for damages incurred by citizens – similar to those fought regarding asbestos – with the difference being that all the evidence for not going ahead with such a clearly dangerous scheme was indeed well known at the time. And with a far more widespread, serious and totally irreversible situation at stake. The Muckaty site NT was defeated in Federal Court in June 2014 It’s likely successful legal fights will continue in future CCSA Report May 2015) In this whole shocking scenario Ngoppon Together are reminded of the words of the Native American Elder – and when the last tree is cut down and the last fish is caught, then they will find out that you can’t eat money! We hear the contemporary cry of the Ngarrindjeri Elder of our region, shocked to hear this scheme posed as a serious question from the Royal Commission: ‘They’re determined to destroy the country!’ We agree- this is a shocking suggestion and one that is still really too hard for our members to believe - that the question could even be allowed to be proposed by a SA government sponsored Royal Commission. We ask what Duty of Care to its citizens is being exercised.

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Our members plead with Commissioner Scarce and the men and women of the Royal commission, with Premier Weatherill and all Members of Parliament and Members of the Legislative Assembly: for the sake of our common humanity abandon all thoughts of this terrifying scheme. As fellow South Australians, Australians and as fellow human beings together, the implications and consequences of importing the world’s radioactive waste in its highly toxic form is indeed a terrifying and, it must be said, postulating as it does, a totally irresponsible legacy, for our generation to leave to the grandchildren, great grand children and every generation to come in our state of South Australia. Ngoppon Together strongly refutes the muddled, quite fallacious so-called ‘ethics’ argument - We export and so are ethically bound to receive waste. This argument fails, as the people do not choose to export uranium but Governments and companies do. Aboriginal people oppose digging up uranium on their land in the first place and then to compound the burden, in the past at least are faced with the waste being imposed on them and their lands, waste that is up to one million times more reactive after enrichment. Our members point out the obvious reality- if any government imports uranium then they import the responsibility for dealing with the implications of the purchase. Fewer than 1 in 6 South Australians are inclined towards reactors or waste dumps in S.A. We remind the Commission of their duties – to inform clearly and fully the SA Community of the facts and implications , rather than to persuade and cajole. Radioactive Waste spent nuclear fuel takes about 200,000 years to reduce to original ore body There are 350,000 tonnes spent fuel in world reactors (now) 1/3 has been reprocessed, 2/3 is stored 4.6 What are the security implications created by the storage or disposal of intermediate or high level waste at a purpose-built facility? Could those risks be addressed? If so, by what means? As for 4.2, 4.3

And following-

The absolute salient fact in this whole issue is that in the entire world there is only one deep geological repository- thi sis the only way that is deemed really the safest for high level and long lived nuclear waste.by world experts. This one depository, in one of the world’s wealthiest countries, in the US state of New Mexico is the Waste Isolation Pilot Plant (WIPP), which stores long-lived intermediate-level military waste. We point out that even this sole deep WIPP is currently closed because of a fire and radiation leaks. (2014) troubling aspect of the WIPP problems is that complacency and cost-­cutting set in just 10-15 years aftr the respository opened. Earl Potter a lawyer who reresented Westinghouse, WIPP’s first operating contractor, said: "At the beginning, there was an almost fanatical attention to safety. I'm afraid the emphasis shifted to looking at how quickly and how inexpensively they could dispose of this waste." Dr Jim Green CCSAA#62

Ngoppon Together draws the obvious conclusion. If this complete inability to cope with the outrageous expense and hyper vigilant monitoring required to deal with their own country’s high level waste happens in super-affluent US, it is completely naïve and irresponsible to pretend the same cost-cutting and complacency will not happen in Australia. Add into the mix that the 4.6 proposal is for SOUTH AUSTRALIA’s to the astronomical heights of volume and toxicity being proposed to actually deal with the WORLD”S high/intermediate waste …

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For we South Australians there is further overwhelming , sadly local evidence of the complete inability of technology to contain risks and even in contemporary times to decontaminate . Our members draw attention to a completely relevant example of such failure to dispose of intermediate level waste in our own country; in fact in our own state. There have been a total of four ‘cleanups’ of the Maralinga British nuclear bomb sites. The last in the mid 1990s is well remembered by our members presented by authorities as the ‘final solution’ to the vexing question of the on going serious contamination of the Maralinga Lands post British nuclear tests. The plan was to vitrify contaminated material, turning it into a solid glass-like monolith. But the government later realised that there was far more contaminated material than they had originally estmated and budgeted for. So, to cut costs, they curtailed and then abandoned vitrification and simply dumped the plutoium-contaminated material in shallow pit. Friends of the Earth paper 2013

Exactly as they had been before this extremely expensive and much vaunted exercise! And then- in a gesture that does nothing to help the belief that any governments know or want the public to know what is the genuine reality of the situation, the operators were actually lauded as proponents of ‘world’s best practice’!

As Professor Mark Diesendorf summarises ‘High level nuclear wastes will have to be safeguarded for 100,00 years or more’, and in a classic understatement, he concludes that this enormous time frame is ‘far exceeding the lifetime of any human institution’

Ngoppon Together members are distressed that an industry with so many negatives — economic, environmental, safety — is even being considered for expansion within our state and nation. Our members submit that the Royal Commission must

accept and make perfectly clear to the citizens of South Australia

that there are simply NO World's Best practice for the storage of nuclear high level or intermediate long lived waste. The material is simply too dangerous, will live on dangerously for an outrageous 100,00 years and despite the fervent hopes of the nuclear industry/lobby– there are no technological solutions to its safe storage – now or likely to be in the forseeable future and quite forseeably never.

4.7 What are the processes that would need to be undertaken to build confidence in the community generally, or specific communities, in the design, establishment and operation of such facilities?

This like many other questions within the Royal Commission document seems to be taking it for granted that any nuclear facility can be established – that seems to be the thrust of this and many other questions - and all that remains will merely be a matter of persuasion - it will only be a matter of marketing – selling the message to the public.

Our members submit that if the confidence of the community is achieved it can only, in the face of such genuine risks and danger if not catastrophe by the refusal to adopt such facilities.

.Refer also to the question asked by the Nuclear Freeways campaign throughout the NSW country towns c 2007

Does your community have an adequate emergency services plan for radioactive spills?

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4.8 Bearing in mind the measures that would need to be taken in design and siting, what risks for health and safety would be created by establishing facilities to manage, store and dispose of nuclear or radioactive waste? What needs to be done to ensure that risks do not exceed safe levels? Can anything be done to better understand those risks?

The weight of scientific opinion holds that there is no threshold below which ionising radiation poses no risk of inducing fatal cancers. Radiation protection agencies around the world including the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA), all base regulations on the linear no-threshold model which assumes there is no threhold below which radiation exposure is safe. (our emphasis) Friends of the Earth ‘Ionising Radiation and Cancer.’ Jan 2013 In 2012, cancer was estimated to be the leading cause of burden of disease in Australia, accounting for approximately 19 per cent of the total disease burden. In 2012, cancer was estimated to be the leading cause of burden of disease in Australia, accounting for approximately 19 per cent of the total disease burden.3 Australian Institute of Health and Welfare & Australasian Association of Cancer Registries2012.Cancer in Australia: an overview, 2012. Cancer series no. 74. Cat. no. CAN 70. AIHW. Every Australian and every South Australian is surely wanting to create a world which is safe for their grandchildren’s health. Eileen Wani Wingfield, Kokatha Elder spent most of her adult life opposing different forms of the nuclear cycle because of her early experiences with fallout the Black Mist bomb from Emu in 1953. ‘I’ve been fighting Roxby since the start. We don’t want the dump because we’ve seen what happened to our children (from the bomb). Everyone was sick. I’ve got a grandchild, he’s got a tumour in his head. Why do they do this to the innocent? EWW, Coober Pedy September 2003 4.9 Bearing in mind the measures that would need to be taken in design and siting, what environmental risks would the establishment of such facilities present? 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?

See above replies and also-

There is no container whether it is steel, concrete, titanium etc that will last for over one hundred years, so the notion of storing radioactive waste isolated from the ecosphere for one million years is pure fantasy. Doctor Helen Caldicott July 2015

4.10 What are the risks associated with transportation of nuclear or radioactive wastes for storage or disposal in South Australia? Could existing arrangements for the transportation of such wastes be applied for this purpose? What additional measures might be necessary?

Prof. John Veevers from Macquarie University states: "Tonnes of enormously dangerous radioactive waste in the northern hemisphere, 20,000 kms from its destined dump in Australia where it must remain intact for at least 10,000 years. These magnitudes of tonnage, lethality, distance of transport, and time − entail great inherent risk."Australian Geologist August 1999.

There have been a number of spills in Australia already in connection with the transport of radioactive waste. Advocates who claim there is no danger are simply flying in the face of the reality of the real world. The NSW Parliamentary Inquiry into radioactive waste found there “is no doubt that the

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transportation of radioactive waste increases the risk of accident or incident – including some form of terrorist intervention”. ANSTO has acknowledged that there are 1-2 accidents or ‘incidents’ every year involving the transportation of radioactive materials to and from the Lucas Heights reactor plant. Ngoppon Together asks: What kind of resources do individual Councils have throughout Australia to deal with the probability of a crash involving particularly intermediate or high level waste.?

Our members present the alternative “ANSTO is capable of handling and storing wastes for long periods of time. There is no difficulty with that.” Dr Ron Cameron, ANSTO.

4.11 What financial or economic model or method ought be used to estimate the economic benefits from the establishment or operation of facilities for the storage or disposal of nuclear and radioactive waste? What information or data (including that drawn from actual experience in Australia or overseas) should be used in that model or method?

DANGERS TO LIFE, LAND, GROUNDWATERS, FEELINGS OF SAFETY. No amount of rationalising and attempts to normalise this as a reasonable industry can eliminate the impact of demoralisation on the sa population as a whole when the inevitable happens and leaks, explosions and even a terrorist attack is threatened occcurs. Parents and care givers responsibility for the safety of their children/ grandchildren is completely undermined Governments have a responsibility to create as far as possible, a safe environment for its citizens. not promulgate one of risk and inevitable danger 4.12 Would the establishment and operation of such facilities give rise to impacts on other sectors of the economy? How should they be estimated and what information should be used? Have such impacts been demonstrated in other economies similar to Australia?

A nuclear industry particularly a radioactive storage facility for high or intermediate level waste in South Australia would undermine and even destroy the state’s vital fishing, agricultural, world famous wine and also the tourism sectors. If such a facility is established the State’s largely clean, green image will be impossible to sustain. Tourist destinations obviously lose appeal when travel arrangements are considered – a possibility of sharing the road or railtrack with highly toxic radioactive waste, whether marked or not: not every SA tourist place is accessible by plane (ANSTO has acknowledged that there are 1-2 accidents or ‘incidents’ every year involving the transportation of radioactive materials to and from the Lucas Heights reactor plant. The NSW Parliamentary Inquiry into radioactive waste found there “is no doubt that the transportation of radioactive waste increases the risk of accident or incident – including some form of terrorist intervention”.) If South Australia has sometimes been in danger of being known as a ‘cinderella ‘ state, any former such thought will be multiplied enormously. Action – withdrawal, loss of population, loss of industries especially food industries. The positive alternative is still possible as SA presently is the leading state in renewable energy and has the opportunity if taken by governent to go down this positive healthy path to maintain a clean, safe country and waters, safe and healthy employment opportunities and for the safety, health and well being of all of its citizens. Michele Madigan for Ngoppon Together Inc August 1st , 2015