My submission on the South Australian Nuclear Draft Terms of Reference

sign-thisTo the Attorney-Generals Department,
Please consider the below points for the draft Terms of Reference into the nuclear industry in South Australia.
On February 9, Premier Weatherill promised “a full and thorough examination of the opportunities and the risks that this industry presents for our State.”
I am deeply disappointed that the draft Terms of Reference don’t match the Premier’s original promise. When releasing the draft ToR, he said that the government has “ruled out retracting from our involvement in the mining of uranium” and the terms of reference appear to limit consideration of whether there “is any potential for the expansion of the current level” of uranium mining.
The uranium mining industry needs thorough assessment and all aspects of current and past uranium mining operational impacts must be included:
·   The Royal Commission should investigate all aspects of the uranium mining industry in South Australia, including issues such as the Olympic Dam mine’s exemptions from environmental, Aboriginal heritage protection, and Freedom of Information laws.
·   The Royal Commission should investigate the merits and risks associated with government’s current practice of entrusting SA uranium to repressive, authoritarian states; nuclear weapons states; states refusing to sign the Nuclear Non-Proliferation Treaty; and states blocking the Comprehensive Test Ban Treaty.
·   Following the March 2011 Fukushima accident – a continuing nuclear crisis directly fuelled by Australian uranium – the UN Secretary General urged uranium producing nations to conduct ‘an in-depth assessment of the net cost impact of the impacts of mining fissionable material on local communities and ecosystems’. To date this has not occurred and the SA Royal Commission provides an important mechanism to address this omission.
·   The nuclear industry starts with uranium and so should any genuine assessment of the nuclear sector in South Australia.  Uranium mining is SA’s point of connection with the international nuclear industry and to seek to quarantine this from full consideration is inconsistent with the Premiers call for an ‘informed and mature’ debate.
Other issues that should be included in the Terms of Reference are as follows:
·   The reputational risks of a nuclear industry for South Australia and its potential impacts on key industries such as tourism.
·   Contaminated sites such as the Port Pirie Uranium Treatment Complex, Maralinga and Radium Hill. Consideration of Maralinga is all the more important since SA Nuclear Energy Systems Pty Ltd is reportedly proposing to use the site for an international high-level nuclear waste storage or disposal facility. Thus the Royal Commission should be tasked with investigating current radioactive contamination of the Maralinga site, the feasibility of pursuing an industrial venture on contaminated land and other such matters.
.Foodstuffs from Australia are known to be clean and radiation free. This status would be threatened by nuclear operations, and lose Australia’s reputation for clean food exports. Nuclear environmental damage also threatens our tourism industry.
· Nuclear waste; the Royal Commission must look widely at nuclear waste management in South Australia, including uranium tailings. The Commission should examine proposals to host international nuclear waste and status of the waste industry globally.
. Safety. Though nuclear accidents are rare, their consequences are catastrophic. Terrorism is a risk – nuclear facilities and transport of radioactive materials are becoming an attractive target for terrorist attacks.
. Climate change. Climate change is bringing sea level rise which in turn would threaten nuclear facilities near the coast, such as at Port Adelaide. Risks of storm surges and even tsunamis cannot be discounted. Climate change will increase droughts, adding to the water shortage problems that already beset the nuclear industry. Climate change brings extreme weather, with greater risk to transport. The recent Malaysian airliner disappearance in the Indian ocean was almost certainly due to an unprecedented extreme weather event. As we must expect more of these extreme events, this brings into question the danger of transporting radioactive wastes over long distances.  Australia is contracted to take back  a relatively small amount of radioactive waste that originated from Lucas Heights. That is hazard enough, without contemplating an international waste repository as an import business.
· Legacy sites; South Australia’s contaminated nuclear sites including Maralinga, the Port Pirie Uranium Treatment Complex, and Radium Hill. There are unresolved concerns over the status of these sites (in relation to public health and environmental impacts) and the Royal Commission provides an opportunity to finally resolve these issues.
· Insurance, financial risk, public liabilities and subsidies; a comprehensive examination of the potential liability of the SA Government in the case of an incident or accident.
· Exploration of alternative energy sources to address the challenge of climate change, including the potential for growth in renewables and other low carbon technologies
If the Royal Commission is to be a genuine inquiry, the draft terms of reference need significant revision. Otherwise it will lack credibility.

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