To Australia’s Federal Nuclear Inquiry – a Submission for the Public Good

Recommendation. There is no need to change Australia’s laws prohibiting nuclear activities. They were devised to protect Australians from the health, and safety risks of nuclear facilities, – far-sighted in that they have saved Australia from the unnecessary expense of a now collapsing industry. Meanwhile Australia is very well placed to put energy and funds into truly modern developments, and could become a world leader in energy efficiency and renewable energy.

To start with, the title of this Inquiry , featuring the word  “prerequisite” really makes clear the major issue.

What is the major prerequisite?

Obviously the one important  prerequisite is to repeal Australia’s laws banning nuclear activities. 

First the Federal Law would have to be repealed. (a1)

Then – State Laws –  Victoria’s  NUCLEAR ACTIVITIES (PROHIBITIONS) ACT (a2) -and South Australia’s Nuclear Waste Storage Facility (Prohibition) Act 2000 (a3)




Once these laws are repealed, then nuclear industry proponents will be free to spend much money on publicising the benefits of the industry. With helpful politicians and press, particularly from the predominant Murdoch media, this will give the industry huge boost. As Australia moves further into drought and water shortages, they will claim that nuclear power is essential to solve climate change.  (Even if nuclear power could combat climate change, it would take decades to establish, and by then it would be too late.)

So – that is what the global nuclear industry needs, especially for South Australia, which has specific legislation against spending public money on promoting the nuclear industry .

While Australians have concerns about cost, safety, environment , health, wastes, Aboriginal rights, weapons proliferation etc, I am sure that the nuclear lobby will be able to overcome those hesitations, with an effective programme.

So, I have my doubts that the Terms of Reference matter all that much, but – here goes.  I understand that the emphasis in this Inquiry is on Small Modular Nuclear Reactors (SMRs)

a . waste management, transport and storage.   

SMRs are designed to produce less radioactive trash than current reactors. But they still produce long-lasting nuclear wastes, and in fact, for SMRs this is an even more complex problem. Australia already has the problem of spent nuclear fuel waste, accumulating in one place – from the nuclear reactor at Lucas Heights.  With SMRs adopted, the waste would be located in many sites, with each location having  the problem of transport to a disposal facility.  Final decommissioning of all these reactors would compound this problem.   In the case of underground reactors, there’d be further difficulties with waste retrieval, and site rehabilitation.

  1. health and safety.  Small modular reactors .

Health. All nuclear activities do carry health risks. There is ample evidence from the 1945 atomic bombing, from the accidents at Chernobyl and Fukushima , and some less well known ones, that “high level” radiation causes severe illness, and death.  It is unlikely , though not impossible, that  such accidents would occur with SMRs. Yet there remain the less sensational risks of prolonged exposure to “low level” radiation. (1)   Nuclear proponents will talk about the “safety” of low level radiation, and even propound the quack science of “radiation hormesis”. That theory – that low level radiation is “good for you” is not accepted by the World Health Organisation (WHO)  or by any national science or health organisation.  Meanwhile – there is a wealth of epidemiological evidence of cancer and other health effects from exposure to “low level” radiation, and this is accepted as true by the WHO. (2)    The routine operations of nuclear facilities also release some ionising radiation, and  increased incidence of leukaemia has been reported in surrounding  communities. (3) Nuclear workers are at increased risk of cancer. (4)

Safety problems. Small nuclear reactors still have the same kinds of safety needs as large ones have.(5)  The heat generated by the reactor core must be removed both under normal and accident conditions, to keep the fuel from overheating, becoming damaged, and releasing radioactivity.   The passive natural circulation cooling could be effective under many conditions, but not under all accident conditions. For instance, for the NuScale design a large earthquake could send concrete debris into the pool, obstructing circulation of water or air. (6)  Where there are a number of units, accidents affecting more than one small unit may cause complications that could overwhelm the capacity to cope with multiple failures.


Because SMRs have weaker containment systems than current reactors, there would be greater damage if a hydrogen explosion occurred.  A secondary containment structure would prevent large-scale releases of radioactivity in case of a severe accident.  But that would make individual SMR units unaffordable. (7) The result?  Companies like NuScale now move to projects called “Medium” nuclear reactors – with 12 units under a single containment structure.(8)   Not really small anymore.

Underground siting is touted as a safety solution, to avoid aircraft attacks and earthquakes. But that increases the risks from flooding.  In the event of an accident emergency crews could have greater difficulty accessing underground reactors.


  1. environmental impacts

Well, for a start, as SMRs would have to be purchased and deployed in large numbers (this is for reasons of economic viability, as I’ll explain later), this would mean increased mining of uranium or thorium, with all the envirionmental hazards of radioactive tailings. It would also mean radioactive waste facilities.  For dry Australia, there is the potential impact on water, as the Souyth Australia Nuclear Fuel Cycle Royal Commission  noted:

“In addition to the management of radioative exposure, a significant issue is the potential for the contamination of groundwater sources.  …. Also significant is the potential risk of land contamination at handling, storage and disposal sites……..Aside from its ecological impact upon animals and plants, contamination of the environment has implications for the health and safety of humans who use those resources.”  (9)

  1. energy affordability and reliability and e. economic feasibility,

Researchers from Carnegie Mellon University’s Department of Engineering and Public Policy concluded that the SMR industry would not be viable unless the industry received “several hundred billion dollars of direct and indirect subsidies” over the next several decades. (10)  For a company to invest in a factory to manufacture reactors, they’d need to be sure of a real market for them (11) – Australia would have to commit to a strong investment up front.

The diseconomics of scale make SMRs more expensive than large reactors.(12)   A 250 MW SMR will generate 25 percent as much power as a 1,000 MW reactor, but it will require more than 25 percent of the material inputs and staffing, and a number of other costs including waste management and decommissioning will be proportionally higher.

study by WSP / Parsons Brinckerhoff, commissioned by the 2015/16 South Australian Nuclear Fuel Cycle Royal Commission, estimated costs of A$180‒184/MWh (US$127‒130) for large pressurised water reactors and boiling water reactors, compared to A$198‒225 (US$140‒159) for SMRs.


To have any hope of being economically viable, SMRs would have to be mass produced and deployed, and here is a “Catch-22″  problem The economics of mass production of SMRs cannot be proven until hundreds of units are in operation. But that can’t happen unless there are hundreds of orders, and there will be few takers unless the price can be brought down. Huge government subsidy is therefore required

  1. community engagement

Well, the community has not been involved so far,  since Dr Adi Paterson quietly signed Australia up to the  Framework Agreement for International Collaboration on Research and Development of Generation IV Nuclear Energy Systems.   (13)  Nor did we know that Australia is helping to develop the very high temperature reactor and the molten salt reactor being constructed in China at the moment. as stated by . ANSTO’s Professor Edwards :

As part of the generation forum, I will be visiting those in October. They’ve actually started co-commissioning those plans. …. Those two reactors are particularly suitable for Australia  (14)

This is all news to the Australian public. There seems to have been very little information on these developments, and no community consultation. There doesn’t seem to have been  discussion on this in the general parliament – and apparently no media coverage.

So – if these very important decisions can be made so quietly, it doesn’t augur well for future processes of decision-making, in regard to setting up nuclear facilities, or for example, importing the plutonium or enriched uranium that would be needed to start fission in thorium nuclear reactors.

  1. workforce capability, While Australia does have the nuclear expertise of people at Lucas Heights, to move to commercial nuclear energy will require many more skilled workers.  That is going to be a huge challenge, as the global nuclear industry is already struggling with the problem of worker shortage. This is further complicated by the rapid developments in renewable energy, and the perception that nuclear is an antiquated industry.  Nearly a third of nuclear professionals are over 55, and there’s a “vast wave of imminent retirements.”  (15) The uncertainty about the industry’s future means that there’s a cloud over this industry as far as a career path is comcerned.   To develop a nuclear industry in Australia would require huge expenditure in training and tertiary education, – large public investment would be needed.


  1. security implications.  

Proponents of SMRs argue that they can be deployed safely both as a fleet of units close to cities, or as individual units in remote locations. In all cases, they’d have to operate under a global regulatory framework, which is going to mean expensive security arrangements and a level of security staffing.  ‘Economies of scale’ don’t necessarily work, when it comes to staffing small reactors.   SMRs will, anyway, need a larger number of workers to generate a kilowatt of electricity than large reactors need.  In the case of security staffing, this becomes important both in a densely populated area, and in an isolated one.

 Weapons Proliferation.

The latest news on the Russian explosion is a dramatic illustration of the connection between SMRs and weapons development.

But not such a surprise. SMRs have always had this connection, beginning in the nuclear weapons industry, in powering U.S. nuclear submarines. They were used in UK to produce plutonium for nuclear weapons. Today, the U.S. Department of Energy plans to use SMRs  as part of “dual use” facilities, civilian and military. (16) SMRs contain radioactive materials, produce radioactive wastes – could be taken, used part of the production of a “dirty bomb” The Pentagon’s Project Dilithium’s small reactors may run on Highly Enriched Uranium (HEU) , nuclear weapons fuel – increasing these risks. (1&)


It is now openly recognised that the nuclear weapons industry needs the technology development and the skilled staff that are provided by the “peaceful” nuclear industry. The connection is real, but it’s blurred.  The nuclear industry needs the “respectability” that is conferred by new nuclear, with its claims of “safe, clean, climate-solving” energy.

  1. national consensus.   The Labor Party , the Greens, and some Independents oppose nuclear power, so there’s certainly no consensus at the political level. National polls over the past decade have consistently found  less than 50%b support for nuclear power, and people’s overwhelming opposition to having a nuclear facility set up in their own local area.   Meanwhile there is strong support across the nation for renewable energy.   There is no social license to introduce nuclear power. There’s no general movement for overturning the laws that have been passed, to protect Australians from this industry – its health and environmental hazards, its costs that are passed on to future generations.  The push for nuclear comes from small sectors of Australian society,  the industry itself, and from those in politics and in the defence sector, who see nuclear power as the pathway to nuclear weapons.

To get a national consensus in favour of introducing nuclear power will require a major propaganda effort.  No wonder that the industry wants those laws repealed. That would allow them to launch a campaign for the hearts and minds of Australians.

  1. any other relevant matter.


For Australia, this has to be the most salient point of all. Economist John Quiggin has pointed out that Australia’s nuclear fans are enthusing about small modular nuclear reactors, but with no clarity on which, of the many types now designed, would be right for Australia. (18)   NuScale’s model, funded by the U.S. government, is the only one at present with commercial prospects, so Quiggin has examined its history of delays.   But Quiggin found that NuScale is not actually going to build the factory: it is going to assemble the reactor parts, these having been made by another firm, – and which firm is not clear.  Quiggin concludes:


Australia’s proposed nuclear strategy rests on a non-existent plant to be manufactured by a company that apparently knows nothing about it.


As  there’s no market for small nuclear reactors, companies have not invested much money to commercialise them. Westinghouse Electric Company tried for years to get government funding for its SMR plan, then gave up, and switched to other projects. Danny Roderick, then president and CEO of Westinghouse, announced:


The problem I have with SMRs is not the technology, it’s not the deployment ‒ it’s that there’s no customers. … The worst thing to do is get ahead of the market. (19)


Russia’s  programme  has been delayed by more than a decade and the estimated costs have ballooned.  (20)

South Korea decided on SMRs, but then pulled out, presumably for economic reasons. (21)

China is building one demonstration SMR, but has dropped plans to build 18 more, due to diseconomics of the scheme. (22)


There’s a lot of chatter in the international media, about all the countries that are interested, or even have signed memoranda of understanding about buying SMRs, but still with no plans for actual purchase or construction.


Is Australia going to be the guinea pig for NuScale’s Small and Medium Reactor scheme?  If so,when?  The hurdles to overcome would be mind-boggling. The start would have to be the repeal of Australia’s laws – the Environment Protection and Biodiversity Conservation (EPBC) Act 1999 Section 140A and Australian Radiation Protection and Nuclear Safety Act 1998. Then comes the overcoming of States’ laws, much political argy-bargy, working out regulatory frameworks, import and transport of nuclear materials, – finding locations for siting reactors, – Aboriginal issues-community consent,  waste locations.  And what would it all cost?


And, in the meantime, energy efficiency developments, renewable energy progress, storage systems – will keep happening, getting cheaper, and making nuclear power obsolete.


There is no need to change Australia’s laws prohibiting nuclear activities. They were devised to protect Australians from the health, and safety risks of nuclear facilities, – far-sighted in that they have saved Australia from the unnecessary expense of a now collapsing industry. Meanwhile Australia is very well placed to put energy and funds into truly modern developments, and could become a world leader in energy efficiency and renewable energy.


(1) Large retrospective study shows the connection between low level radiation and leukemia

(2) Multiple studies confirm exposure to low levels of radiation can cause cancer

(3)      Elevated Childhood Cancer Incidence Proximate to U.S. Nuclear Power Plants

(4)  Even low doses of radiation increase risk of dying from leukaemia in nuclear workers, says IARC

(5) Small Modular Reactors: Safety, Security and Cost Concerns

(6)  Small Isn’t Always Beautiful Safety, Security, and Cost Concerns about Small Modular Reactors

(7)  The problems with small nuclear reactors

(8) NuScale won’t solve energy problems

(9) Management, Storage and Disposal of Nuclear and Radioactive Waste.

(10)  US nuclear power: The vanishing low-carbon wedge

(11)  Small modular reactors for nuclear power: hope or mirage?

(12)   An obituary for small modular reactors











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