Andrew Allison 23 May 16 Here is my assessment of “NUCLEAR FUEL CYCLE ROYAL COMMISSION – FINAL RECOMMENDATIONS Copied from Pg. 169 of the Commission’s final report, and republished here for the purpose of discussion.
Based on the findings set out in this report, the Commission recommends that the South Australian Government:
1. pursue the simplification of state and federal mining approval requirements for radioactive ores, to deliver a single assessment and approvals process
AA: The devil is in the detail for this one. The word “simplification” could be code for reducing environmental standards, or allowing corporations to avoid the consequences of their actions. I am suspicious.
2. further enhance the integration and public availability of pre-competitive geophysical data in South Australia
AA: It depends who owns the data. If a corporation has collected the data then it is part of the intellectual property of that corporation. It is difficult to see how they could be forced to share it, by a state government. If the data were collected by the state government then one would have to ask why she state government is investing in prospecting for nuclear materials. This is in an era where state governments supposedly cannot operate water utilities, banks, gas companies, public transport etc etc…. Why are they breaking their own laws to prospect for nuclear materials?
3. undertake further geophysical surveys in priority areas, where mineral prospectivity is high and available data is limited
AA: This is a matter for the corporations, subject to regulatory approval.
AA: Readers may remember that Marathon resources breached environmental guidelines in The Flinders Ranges in 2012. We cannot allow this. I don’t see why the resources of the state should be spent prospecting on behalf of mining companies.
4. commit to increased, long-term and counter-cyclical investment in programs such as the Plan for Accelerating Exploration (PACE) to encourage and support industry investment in the exploration of greenfield locations
AA: Once again, this is a purely commercial matter. I don’t see why the state government should be investing money in this. There are much more efficient ways of carrying out counter-cyclical Keynesian investment, than exploring for nuclear materials. We could invest in schools, and hospitals and public transport infrastructure, for example.
5. ensure the full costs of decommissioning and remediation with respect to radioactive ore mining projects are secured in advance from miners through associated guarantees
AA: This seems to be very sensible to me. I ask the question: aren’t we already doing this? See the reference to marathon resources, above.
6. remove at the state level, and pursue removal of at the federal level, existing prohibitions on the licensing of further processing activities, to enable commercial development of multilateral facilities as part of nuclear fuel leasing arrangements
AA: In my view, the existing laws are in place to protect public safety and no good case has been made to overturn them. There is currently a glut of Uranium on the world market. The prices are low. To increase the supply of Uranium at this time would only depress the price further and affect the viability of existing producers.
7. promote and actively support commercialisation strategies for the increased and more efficient use of the cyclotron at the South Australian Health and Medical Research Institute (SAHMRI)
AA: The limited and controlled use of nuclear technology in medicine has been shown to be beneficial. I don’t see any logic in expanding the program, unless there is a demonstrated need that is currently not being met in South Australia.
AA: The use of cyclotrons should be carefully regulated, since they can be used to enrich fuel, leading to weapons proliferation:
8. pursue removal at the federal level of existing prohibitions on nuclear power generation to allow it to contribute to a low-carbon electricity system, if required
AA: It is very doubtful that nuclear energy is “low carbon”, if one considers the entire fuel cycle.
9. promote and collaborate on the development of a comprehensive national energy policy that enables all technologies, including nuclear, to contribute to a reliable, low-carbon electricity network at the lowest possible system cost
AA: Of course, a centralized government energy policy that was oriented towards the needs of the people would be sensible. Unfortunately state governments were in a rush to privatize their energy assets (or to lease out monopolies on a long-term basis) so the control of the system has been relinquished to corporations, for the time being. The Royal Commission has admitted that there is no commercial basis for nuclear power, in Australia, for the foreseeable future.
10. collaborate with the Australian Government to commission expert monitoring and reporting on the commercialisation of new nuclear reactor designs that may offer economic value for nuclear power generation
AA: I will believe in “Generation IV” nuclear power stations when I see one actually operating. In the mean time, we do have to consider the opportunity cost associated with investing Australia’s limited research dollars on a technology that Australia does not even use, and will not use for the foreseeable future.
11. pursue the opportunity to establish used nuclear fuel and intermediate level waste storage and disposal facilities in South Australia consistent with the process and principles outlined in Chapter 10 of this report
AA: I am very curious to know why the Royal Commission is in such a hurry for South Australia to commit to a facility that may not even work, and will not actually hold any nuclear waste for over eighty years. I think that it would be much more prudent for South Australia to watch technological developments elsewhere in the world before committing to such a great an irreversible development as a nuclear waste dump. We should note that no country has yet completely solved the nuclear waste storage problem, not even the former nuclear superpowers, the USA and Russia.
12. remove the legislative constraint in section 13 of the Nuclear Waste Storage Facility (Prohibition) Act 2000 that would preclude an orderly, detailed and thorough analysis and discussion of the opportunity to establish such facilities in South Australia.”
AA: I argue that this legislation serves an important public safety purpose. A convincing case has not yet been made to remove this important piece of safety legislation. The “economic” analysis of the Royal commission is mostly based on the opinion of one consultant, in the Jacobs report. The assumptions that were made in this report are very generous to the pro-dump case.