Archive for the ‘National’ Category

Busting Australian govt media spin about Napandee nuclear waste plan, – by AustralianGovtWatcher

July 5, 2020

Cut through this spin from the Department of Industry, Science, Energy and Resources – glossing over the licensing problem about waste classification. It is duplicitous about “medical” wastes. It ignores the plan’s failure to comply with all regulatory requirements, failure to properly inform local community. It makes dubious claims on economics and employment, and dubious claims about the selective community ballot, and duplicitous claims about Aboriginal involvement

Department of Industry, Science, Energy and Resources National Radioactive Waste Management Facility: Hearings last Tuesday of the Senate Standing Committee on Economics

Media release
2 July 2020

The following can be attributed to a spokesperson from the Department of Industry, Science, Energy and Resources:
“The department was pleased to attend the committee hearings on Tuesday to discuss the proposed legislation to support the National Radioactive Waste Management Facility,” the spokesperson said.

“Specifically it was also an opportunity to address some questions about the process and proposed facility, including some those which have since been raised in the media, as outlined below.

Is there are need for a facility?
“The legislation delivers on the Australian Government’s commitment to site the facility at Napandee in Kimba, South Australia.

“The facility will be for the disposal of low-level waste and temporary storage of intermediate level waste, which will be stored at the facility only if it meets strict Waste Acceptance Criteria.”

The facility will fail to meet the safety codes and prescriptions of IAEA as adopted in Australia by ARPANSA

What is proposed to overcome this problem as otherwise ANSTO or whoever else will be the operator of the facility will not get the necessary licences

“About 80 per cent of Australia’s radioactive waste stream is associated with the production of nuclear medicine which, on average, two in three Australians will need during their lifetime.”

This is a dubious claim and depends entirely on the level of classification and the source of the waste – it should be specifically broken down into those categories.

“This medical waste, along with Australia’s historical radioactive waste holdings, is currently spread over more than 100 locations across the country, like science facilities, universities and hospitals.”

True but only a portion of that waste is held or controlled by the federal government.

“It is international best practice to consolidate this waste at a purpose-built facility.”

Agreed but the facility at Napandee will not achieve this.

Can’t the waste be permanently stored at ANSTO?
“Australia cannot indefinitely produce the vital nuclear medicine
that it needs, without responsibly and safely managing the radioactive waste by product.
“The national facility will not fit at ANSTO – it requires at least 40 hectares plus a buffer zone and enabling infrastructure.
“On the other hand, the whole ANSTO Lucas Heights campus, designed for nuclear medicine and research, is only 70 hectares in size, and already has more than 80 buildings on it.”

Although unavoidable due to simply adding new buildings when needed it still shows a dismissal lack of planning over many years which is acknowledged by former senior personnel at ANSTO

Do we need more scrutiny around the process to identify a site?
“The process to site the facility was developed with the assistance of an Independent Advisory Panel which included members with a range of academic, industry and environmental backgrounds, and people who are both generally supportive and against the proposal to establish the facility.”

Absolute nonsense since the choice of the site and subsequent development proposals fail to comply with all regulatory requirements.

Moreover the community members against the proposals were never given full and proper information despite their specific requests.

A good example of this was the issue of fire risks which is of prime importance with the proposed above ground structure in the heart of prime agricultural land.

The so-called Independent Advisory Panel proved to be ineffective and was not constituted as initially planned – it certainly did nothing of consequence to identify the location and provide any real scrutiny.

“And the process has already been independently scrutinised
on two occasions.
“In 2018, the Senate Economics References Committee ran an inquiry into the process for the selection of a site for the facility, and this found that that the process was sound.
“Four years of community engagement and three years of technical studies support the identification of Napandee as a site, which is suitable technically to safely and securely manage Australia’s waste, and broadly supported by the community.”

The Senate Committee inquiring into the selection process in 2018 could not possibly be regarded as being an independent scrutiny as seen from its conclusions and recommendations.

What was the second occasion of scrutiny?

Most importantly the community at Kimba has requested funding and governmental assistance in getting their own proper and independent expert scrutiny and assessment but the government has refused the requests.

The District Council of Kimba also refused a similar request despite claiming to represent the whole community.

What economic benefits would the facility deliver for regional Australia?
“Independent economic analysis conservatively estimated the facility would bring over $8 million in economic benefits to Kimba each year.”

How?

“The facility will also be the area’s largest employer, bringing 45 local jobs.”

Much larger facilities overseas employ a fraction of that number – it is more likely to be less than 10 employees in total and will no doubt depend on the infrequent deliveries of waste to the facility.

Hard to see where the yearly economic benefits of $8 million will come – it will do nothing to replace an agricultural industry at Kimba worth between $55 million to $85 million a year which based on recent overseas situations will suffer dramatically due to the presence of the facility.

“And some 62% of the local Kimba community supported the facility in a Council-run ballot undertaken last year.”

This is based on a very selective ballot the results of which have not been correctly interpreted.

Most importantly the ballot failed on the principle of informed consent as there was a lack of proper information given to the voters prior to the ballot.

What are the ways of protecting cultural heritage?
“While there is no native title or registered heritage at Napandee, which is cleared farming land, the department recognises the Traditional Custodians in the region, who have strong views about a radioactive waste facility being situated in the area.
“If the Barngarla People are willing to consider the opportunity, the department is seeking to engage with the objective of a funded agreement between BDAC and the Government, which could include:

• a Barngarla economic plan – including $3 million allocated
by the Australian Government,
• training, employment and business opportunities,
• a cultural heritage assessment and management program,
• the opportunity to ensure Barngarla heritage and cultural values are enhanced by the Facility and its design,

That is not what the Barngarla people say particularly as the proposed funding outlined by the government will in any case come from other existing financial assistance already available to them.

In any case the government should have been consulting the Barngarla for that type of agreement several years ago and certainly well before their legal actions were taken and which were strongly opposed by the government.
It seems that it will be hard to mend the bridges!

CONCLUSION
These comments are based on various expert advice from overseas which is far more credible in the areas of nuclear science and engineering then exists in Australia mainly due to there being no local nuclear generation industry .

This expert advice can be made available to the Senate committee if necessary

However the whole process of selection of a previously nominated site and the subsequent development proposals lack any community consideration of such inherent issues as the radionuclides inventories of the waste and the risk of fires

Australian Senate Inquiry: growing uncertainty about viability of Kimba nuclear waste dump plan

July 2, 2020

The day saw uncertainty grow over the need for the proposed Kimba site while there was a corresponding growth in clarity that there is no urgency re this decision. The govts plan might suit ANSTO but it is not Australia’s only option – and it faces growing scrutiny.

from Jim Green, 1 July 2020 ,   Yesterday, Tuesday June 30 , the Senate Inquiry into Minister Pitt’s planned amendments to the national radioactive waste laws to cement and secure Kimba as a Facility site took evidence in Canberra.

The Committee heard from Govt agencies and contractors and key themes included both the need for the planned new laws and, importantly, for the Facility itself – esp. around the double handling of Intermediate Level Waste from ANSTO’s Lucas Heights.

ANSTO – as ever, there was too much bluff and bluster and too many Dorothy Dixers –  as invariably happens with them in Estimates – but there were some very interesting arisings:

  • Confirmed there are ‘no safety concerns’ with current waste – although ‘we cannot say that in 40 or 50 years they (ANSTO’s waste stores) will be fit for purpose’ – clear acknowledgement that they could retain waste on site and four decades is more than enough for a credible review and a more integrated approach.
  • Further, ANSTO has ‘proposals under development with government for pre-2027 construction of new storage’ for ILW waste
  • Hardly credible that they did not know the general proportions of ANSTO origin waste at the proposed Facility (around 80% of total wastes, and more importantly, 95% of ILW)
  • They see extended on-site storage as a ‘significant management challenge and significant financial cost’ and so want to both cost shift and physically waste shift. Again, this is ANSTO’s agency agenda – not a national imperative or Australia’s sole or best option.
  • Odd claim that a delay in advancing Kimba would be ‘detrimental to our sense of ourselves’ however it would not be inconsistent with any international treaty obligations. No treaty or convention obligations require Kimba to be advanced in its current form – or at all.  (also I would suggest that ignoring Traditional Owner opposition to the siting of a national radioactive waste facility poses a bigger threat to our national sense of self)
  • No credible threat to secure access to nuclear medicine supply should Kimba be delayed – although there would be ‘some scenario’s’ where supply could potentially be impacted. This is a very significant reduction in ANSTO’s threat messaging and a long way from a pressing problem. As I understand the scenario referred to is that Kimba is not advanced and ANSTO has taken no steps to develop a contingency.

In summary Kimba is not essential for nuclear medicine nor is it essential for Australia’s compliance with international frameworks. ANSTO could extend interim storage at Lucas Heights but understandably would prefer to transfer both the waste and its continuing management cost to a non ANSTO purse and place. Not a good enough rationale for a deficient national plan.

ARPANSA

  • ANSTO waste ‘can be safely stored at Lucas Heights for decades to come’ – absolutely critical point: there is no need to rush – we have time to develop a more credible approach.
  • ‘International best practice is to store radioactive waste safely – current storage at the Lucas Heights site is fully aligned with international best practice’
  • There will be distinct licensing applications required for the two waste streams – LLW and ILW (with no certainty that they will have a shared approval outcome)

Dept of Industry:

  • Repeated reference to the ‘contentious’ nature of the siting decision
  • Extremely deficient responses re the rational and process for the change in legislative decision making from Ministerial decision to legislative instrument. Some Senators not happy at Depts inability to answer basic process questions –it is very clear the rationale is to isolate against future legal challenge.
  • Statement that decision to change the legislative basis of the siting was made sometime in 2019 – then a later statement that it was made by Minister Pitt (note: Pitt was sworn in 6/2/20)
  • The Departments Sam Chard rear guard action was to state that the intent of the change was to enable Parliament ‘to test the merits of the action’  – that is long overdue – could we please do this as it simply doesn’t stack up
  • Increasingly clear that the Dept is utterly adrift re Barngarla liaison – understandably as they simply do not want the Facility on their country – the Facility plan is heading for some pretty sharp rocks if it doesn’t change course.

Dept of Defence:

  • strongly arguing against any siting on the Woomera Prohibited Area as this could reduce its functionality. Not at all keen.
  • Hard pressed by Rex Patrick though about how credible is it to say ‘not possible’ for a 100 hectare Facility inside a site twice the size of Tasmania.

AECOM:

  • Predictable defence of process, their expertise and kept referring to the restricted extent of their brief as the way to avoid any tricky questions (like Barngarla liaison)
  • No tech or site reason why the Facility couldn’t be at Kimba

There were good efforts from Sarah Hanson Young, Rex Patrick and Labor’s Jenny McAllister to highlight and tease out issues.

In a nutshell I would say the day saw uncertainty grow over the need for the proposed Kimba site while there was a corresponding growth in clarity that there is no urgency re this decision. The govts plan might suit ANSTO but it is not Australia’s only option – and it faces growing scrutiny.

We now need to keep up the issue profile and the expectation on Labor and the cross-benches to oppose this legislation when it comes to the Senate and instead support a strategy that advances both human and environmental rights and responsible radioactive waste management.

South Australian MP Rowan Ramsey, and Minister for Resources, Keith Pitt, talk nonsense about the planned nuclear waste dump at Napandee. 

June 27, 2020

By Noel Wauchope, 27 June 20Examining the Joint media release by the Member for Grey Rowan Ramsey MP and Keith Pitt, Minister for Resources, 11 June 2020   – “Important step for national radioactive waste facility in South Australia.” – here it is –

Legislation has been introduced to federal parliament that will pave the way for a critical piece of national infrastructure to support the increasing use of nuclear medicine in Australia and provide an economic boost to a regional South Australian
community. The National Radioactive Waste Management Amendment (Site Specification, Community Fund and Other Measures) Bill today passed through the House of Representatives.

Minister for Resources, Water and Northern Australia Keith Pitt said it’s an important milestone for the establishment of the facility.

“Governments have been attempting to find a solution to this issue for decades and today our Government has taken a
significant step in bringing the process to a conclusion,” Minister Pitt said.

My Response That just shows how hopeless and incompetent the government has been on this issue and still cannot do everything correctly and in an acceptable manner under internationally prescribed standards.

Moreover the government lacks the capacity or simply does not want to follow and adopt the most recent developments and advances in the field of nuclear waste disposal and storage.

The legislation will confirm the site near Kimba in South Australia as the home for the facility that will allow the continued growth of nuclear medicine in Australia.

My Response This has nothing to do with nuclear medicine and is a most dishonest representation. It again shows bad planning on the part of the government, particularly as the new nuclear medicine facility at Lucas Heights for the production of molybdenum is having persistent problems which could have led to a total shutdown last year. 

Interestingly there was little public reporting of these problems by either ANSTO or ARPANSA as the regulatory authority which as a result had to issue only an interim operating licence.

“The site was one of 28 across the country that was voluntarily nominated, followed by extensive engagement and consultation with the surrounding community that has shown broad support for the project,” Minister Pitt said.

My ResponseThere have not been 28 voluntary nominations or the extensive  engagement and consultations particularly as there has been no contact by the government with the Azark Project at Leonora in Western Australia since early 2018.

“There has also been extensive engagement with other stakeholders during this process, including with Traditional Owners.”

My Response Again, there has been no extensive engagement with Traditional Owners, particularly as the Azark Project has far more internationally based scientific and technical knowledge available to it in the areas of nuclear chemistry and engineering as to waste then possessed by the government through ANSTO and CSIRO There has not been any contact even with the traditional owners\ of the Azark site at Leonora.

Member for Grey, Rowan Ramsey, said the local community has heard enough and just wants work on the facility to begin. “I thank the landholders who nominated their properties and have been the centre of attention ever since and I also thank the whole community for engaging in the consultation process,” Mr Ramsey said.

My ResponseRamsey is being disingenuous as in all probability the proposal for Napandee will have difficulty getting the necessary licences for its establishment and operations.

No work can begin until those licences are issued.

The land owners concerned did not voluntarily nominate their properties but only did so at the suggestion of Ramsey and the government through the then Department of Industry Innovation and Science, since other properties in the Kimba region were found unsuitable.

The government has refused to produce the nomination forms for the properties at Napandee and Lyndhurst, as they were apparently filled out for them by the Department’s staff.

“Of course there are differing views, but the whole community has made a decision and most are looking forward to the commencement of work.”

My ResponseThis is absolute rubbish as Ramsey knows that there are many people who are against the proposed facility and if a proper and fully informed plebiscite were held then the government would struggle to get approval for its ill-conceived proposals.

Whichever way it is examined the government has failed to provide sufficient information for an informed decision or consent by the selected voters for the Kimba ballots and excluded many other persons who should have had a vote on this important issue.

Minister Pitt said the legislation will now head to the Senate and called on Labor and the cross-benchers to support the project.

My ResponseWishful thinking as discussions with both the opposition and cross-benchers in the Senate are already suggestive of lack of support for the legislation.

“Suggestions that a site in the Woomera area could be used for the facility are simply not practical due to the increase in Defence Force training activities that will limit access to the area,” Minister Pitt said.

My Response  Is not the real reason that the Defence Force does not trust or rely on ANSTO and will not work with it in containing or disposing of any nuclear waste as Defence wants to retain complete control of its nuclear material?

“The passage of this Bill, and the construction of the facility, is crucially important to the future of nuclear medicine in Australia, which will benefit two in three Australians”.

My Response This, as already mentioned, has nothing to do with the future of nuclear medicine in Australia and this is confirmed by overseas experts who regard the proposals for Kimba as unrealistic and uncommercial with an obvious lack of research.

“Currently the waste is stored in around 100 locations across the country, including hospital basements, research facilities and universities”.

My Response Yes but only a relatively small portion of this waste is under the control of the federal government and again, from discussions with state government and private institutions having waste, is that they will not use the facility as they regard ANSTO as completely unreliable.

“The project at Kimba will support the future growth of nuclear medicine in Australia, and provide new job and economic opportunities for a South Australian regional community.”

My Response How will this support the future growth of nuclear medicine in Australia as its production has nothing to do with the storage issue?

Equally the numbers of 45 new jobs or others stated by the government are completely unrealistic, as much larger similar facilities overseas have only a fraction of that staff complement.

To be quite clear about the situation:

1. Even though it claims that it has not raised any concerns regarding the storage of waste at what is known as the interim waste storage facility at Lucas Heights, ARPANSA still requires ANSTO under existing licensing arrangements to report by 30 June 2020 on the plans for the storage and disposal of that waste.

2. This came about because when this waste was returned by the end of 2015 from overseas reprocessing, the intended storage facility for it which is described as the national radioactive waste management facility was not available.

3. As a result ARPANSA permitted by licence for ANSTO to temporarily store the reprocessed waste at the interim waste storage facility at Lucas Heights but on the condition that ANSTO provides plans for the final management of that waste by its removal.

4. It follows that the urgency is for the government through ANSTO to have firm plans for the removal by being able to specify the proposed facility at Napandee for that purpose.

5. This is obviously the reason for the rushed legislative process which will probably involve debating the bill in the Senate before the existing committee inquiry is completed.

6. A similar condition has been imposed by ARPANSA under the licence for ANSTO to operate the new nuclear medicine facility at Lucas Heights.

7. The waste in question is classified by the government as being of intermediate level but it is at the higher end of that class as to volatility and was classified as high level waste by France when being returned to ANSTO after reprocessing.

8. It is this level of waste about which the government has been rather backward in providing any information of a public nature as by the international safety prescriptions it should even for temporary storage be by appropriate geological burial which is simply not possible at Kimba.

9. It is a major reason for the obvious difficulties that ANSTO will encounter in trying to get the necessary licences for the storage facility at Napandee.

10. The other important aspect of the government’s proposals will be the disclosure by ANSTO of the inventory of radionuclides applicable to that waste which becomes the determining factor of the manner of storage and ultimate disposal to be used for that waste. That is why the level or quantum of radionuclides should be the first issue examined by the Senate inquiry as it will form the basis of the safety case and even indicate whether the Napandee facility plans should be pursued.

11. The ridiculous part of all of this is that the government has persistently refused to consider the Azark Project facility at Leonora , which would readily overcome the problems of storage and ultimate disposal of the intermediate level waste in a completely acceptable manner in accordance with all international standards and at a fraction of the cost of the government’s proposals.

Ben Heard –Australia’s corporate-funded nuclear greenwasher   

June 26, 2020

Ben Heard and the fake environment group ‘Bright New World’ that accepts secret corporate donations, Jim Green, Nuclear Free Campaign, Friends of the Earth 

For factual rebuttals of the misinformation promulgated by other nuclear advocates, please visit: https://nuclear.foe.org.au/propaganda/

Ben Heard – corporate-funded greenwasher   Ben Heard is arguably the most aggressive and abusive of Australia’s nuclear advocates − see for example this temper tantrum and compare it with the matter-of-fact tone of the paper he is attacking. He has repeatedly indulged in personal, defamatory attacks.Like so many other nuclear advocates, Heard very rarely or never says or does anything about the problems of the nuclear industry such as its systemic racism (abundantly evident in his home state, South Australia) or the inadequate nuclear safeguards system.

A mining industry magazine article says that Heard was “once a fervent anti-nuclear campaigner”. However Heard never had any involvement whatsoever in anti-nuclear campaigning. Heard made no effort to correct the error in the magazine article – indeed he put the article, uncorrected, on his own website. His website was later corrected, but only after his dishonesty was publicly exposed. Likewise, Heard made no effort to correct an ABC article which describes him as a “former anti-nuclear advocate”.

A November 2015 ABC article falsely describes Heard as a scientist. It isn’t clear whether this was an error by the ABC or the latest fabrication and misrepresentation by Heard. Either way, it’s a safe bet that Heard won’t be correcting the error. And again in March 2016, Heard was described as a scientist in the media (inDaily); and again it’s a safe bet that Heard won’t correct the error.

Heard has a recurring disclosure problem. He rarely disclosed his consulting work for uranium company Heathgate when spruiking for the nuclear industry. More recently, he rarely discloses corporate funding – indeed his fake environment group has a policy of accepting secret corporate donations. He said the reason he rarely disclosed his consulting work with Heathgate was that it was mentioned on his website. So any time you hear anyone speaking about anything in the media, it’s your responsibility to do a web-search to see if they have a financial interest!

Heard’s university supervisor was none other than Barry Brook, best known for insisting there was no risk of a serious accident at Fukushima even as multiple meltdowns were in full swing, and for promoting a bogus ‘outstanding scientist’ award on his university website and leaving it there long after he knew it was bogus.

Ben Heard’s “outright lie”, massive hypocrisy and extreme censorship

June 2020 ‒ Long story short … RenewEconomy published a FoE article about small modular reactor economics. Ben Heard demanded a right of reply. RenewEconomy told him that anyone is welcome to submit a contribution and it would be reviewed. Heard said he had been denied a reply. That was an “outright lie” according to the RenewEconomy editor. Anyhoo … Heard’s response to the FoE article was published on his Bright New World website. He denied me a right of reply (!) so I replied in the comments section and my comments were deleted by Heard! And my comment alerting readers to a substantive response on this FoE webpage was not published!

An “outright lie”, massive hypocrisy and extreme censorship … all in a day’s work for Australia’s foremost ‘ecomodernist’ and his lobby group (which accepts secret corporate donations from the nuclear industry).

Here are the comments censored by Heard.

Ben Heard: “Then find the cost estimates, add them up and divide it by three, and float that as the cost of SMR nuclear that will inform decision-making in Australia.”

Response: Yes, real-world SMR construction cost data is limited but it is a better guide than self-serving industry claims. Also relevant are real-world data about cost overruns including the huge overruns with SMR projects and the A$10+ billion-dollar overruns with large reactors in western Europe and the US.

Ben Heard: “If Friends of the Earth thinks +50% is too low, they could have stated their reasoning, made their case (succinctly, if at all possible) and proposed their loading.”

Response: The general recent pattern is that EARLY vendor estimates underestimate true costs by an order of magnitude (see my article – citing AP1000s, EPRs, and Argentina’s SMR as examples), while estimates around the time of initial construction underestimate true costs by a factor of 2-4 (numerous examples cited in my article).

So a 100% loading above NuScale’s estimate would be the minimum starting point.

Note that the WSP / Parsons Brinckerhoff LCOE estimate for a NuScale SMR (A$225 or ~US$150 per MWh) is 2.5 times greater than NuScale’s estimate, and it is roughly twice the BNW estimate.

Ben Heard: “We went with vendor first-of-a-kind estimate +50%, consistent with this being a Class 4 cost estimate, independently verified, based on well-known and understood technology …”

Response: None of that changes the fact that real-world projects have been subject to vastly greater cost overruns.

Ben Heard: “We look forward to the author securing employment with a major accounting firm and explaining this [that NuScale’s cost estimate is bollocks] the next time the estimates are verified.”

Response: Heard himself adds a 50% loading. WSP / Parsons Brinckerhoff’s LCOE estimate is 2.5 times greater than NuScale’s estimate. No-one believes NuScale’s estimate.

Ben Heard: “Friends of the Earth didn’t understand ‘Class 4 estimate’. It is a defined term, established for estimates of engineer/procure/construct in civil projects. This is clearly described in our submission. We doubt they read it.”

Response: Yes, I do understand the term and have read your various articles and submissions – and referenced three of them at the top of my article. The real-world evidence, for both small and large reactors, demonstrates that Class 4 estimates need a rethink, especially the demonstrably false assertion that a 50% loading will cover any conceivable overruns.

Ben Heard: “‘NuScale’s estimate (per kW) is just one-third of the cost of the Vogtle plant’. Drawing comparison with large nuclear units, the very paradigm SMR is devised to disrupt, while not entirely irrelevant, is pretty dubious.”

Response: The relevance is that there is a solid body of expert opinion that construction costs per kW and LCOE will be greater for SMRs compared to large reactors. For example a 2015 report by the IEA and the OECD Nuclear Energy Agency predicts that costs per MWh for SMRs will typically be 50−100% higher than for current large reactors, and a UK report estimated a 30% cost increase per MWh.

Ben Heard: “‘BNW objected to the previous CSIRO/AEMO estimate of five years for construction of an SMR and proposed a “more probable” three-year estimate’. We neither objected, nor proposed a ‘more probable’ 3 years, nor even used the words ‘more probable’!”

Response: From the cited BNW paper: “No SMR developer is working on the basis of 5-year construction. This would also raise the LCOE considerably compared with a more probable 3 three years on the basis of what those bringing SMR to market are actually devising.”

As noted in my article, SMR projects typically take about a decade from start of construction to completion or near-completion (8 to 12.5 years).

Ben Heard: “‘100% agreed with Friends of the Earth [that there’s no empirical basis, nor any logical basis, for the learning rate assumed in the GenCost report]. There remains lack of transparency and replicability as regards the SMR learning rates applied in GenCost.”

Response: So do the maths … what is a reasonable learning rate based on the 12.5 year Russian floating plant?

What is a reasonable learning rate based on the Argentinian SMR, conceived in the 1980s, with construction of the first prototype currently stalled due to the project’s ‘serious financial breakdown’?

What is a reasonable learning rate based on mPower, abandoned after the expenditure of US$500 million and before construction of a first prototype began?

What is the learning rate for fast neutron reactors? That question could be answered based on 70 years of mostly-failed projects and would usefully inform current SMR / Gen 4 debates. My guess is that the FNR learning rate is negative.

What are the learning rates for large light water reactors? Well, we can answer that question, and I did so in my article: a very slow learning rate with modest cost decreases, or a negative learning rate.

Heard / Bright New World claims about SMR learning rates are 100% speculative.

Ben Heard: “‘Even with heroic assumptions resulting in CSIRO/AEMO’s low-cost estimate of A$129 per MWh…’. Friends of the Earth has studiously avoided all of the other necessary corrections identified by Bright New World, in particular operating costs and capacity factor, which bring this right down to more like $100/MWh.”

We have considered all the real-world data and plenty more besides. That research is synthesised in the RenewEconomy article and there’s loads more info in submissions such as this:

Our conclusions are shared by informed expert opinion (cited in the submission), e.g. the pro-nuclear US academic researchers who concluded that for SMRs to make a significant contribution to US energy supply, “several hundred billion dollars of direct and indirect subsidies would be needed to support their development and deployment over the next several decades”.

Ben Heard: “‘NuScale Power…hasn’t yet begun construction of a single prototype’. The reference case technology uses the most commercially established fuel cycle in the world, with standard fuel.”

Response: mPower was based on conventional light water technology, but still went bust after the expenditure of US$500 million. Rolls-Royce is proposing light water technology for SMRs in the UK but won’t proceed unless and until a long list of demands are met and hefty subsidies granted…….. https://nuclear.foe.org.au/ben-heard-secret-corporate-donations/?fbclid=IwAR3GNEcscxXXrxshahmX6K76lufOPFnr6QXcgXnQrSnG_LAVjK8uw1poX24

 

Small Nuclear Reactors economic? Sorry, that’s a mirage

June 24, 2020

Small modular reactor rhetoric hits a hurdle  https://reneweconomy.com.au/small-modular-reactor-rhetoric-hits-a-hurdle-62196/    Jim Green, 23 June 2020, The promotion of ‘small modular reactors’ (SMRs) in Australia has been disrupted by the Commonwealth Scientific and Industrial Research Organisation (CSIRO) and the Australian Energy Market Operator (AEMO).

The latest GenCost report produced by the two agencies estimates a hopelessly uneconomic construction cost of A$16,304 per kilowatt (kW) for SMRs. But it throws the nuclear lobby a bone by hypothesising a drastic reduction in costs over the next decade.

The A$16,304 estimate has been furiously attacked by, amongst others, conservative politicians involved in a federal nuclear inquiry last year, and the Bright New World (BNW) nuclear lobby group.

The estimate has its origins in a commissioned report written by engineering company GHD. GHD provides the estimate without clearly explaining its origins or basis. And the latest CSIRO/AEMO report does no better than to state that the origins of the estimate are “unclear”.

Thus nuclear lobbyists have leapt on that muddle-headedness and filled the void with their own lowball estimates of SMR costs.

Real-world data

Obviously, the starting point for any serious discussion about SMR costs would be the cost of operational SMRs – ignored by CSIRO/AEMO and by lobbyists such as BNW.

There is just one operational SMR, Russia’s floating plant. Its estimated cost is US$740 million for a 70 MW plant.

That equates to A$15,200 per kW – similar to the CSIRO/AEMO estimate of A$16,304 per kW.

Over the course of construction, the cost quadrupled and a 2016 OECD Nuclear Energy Agency report said that electricity produced by the Russian floating plant is expected to cost about US$200 (A$288) per megawatt-hour (MWh) with the high cost due to large staffing requirements, high fuel costs, and resources required to maintain the barge and coastal infrastructure.

Figures on costs of SMRs under construction should also be considered – they are far more useful than the estimates of vendors and lobbyists, which invariably prove to be highly optimistic.

The World Nuclear Association states that the cost of China’s high-temperature gas-cooled SMR (HTGR) is US$6,000 (A$8,600) per kW.

Costs are reported to have nearly doubled, with increases arising from higher material and component costs, increases in labour costs, and increased costs associated with project delays.

The CAREM SMR under construction in Argentina illustrates the gap between SMR rhetoric and reality. In 2004, when the reactor was in the planning stage, Argentina’s Bariloche Atomic Center estimated an overnight cost of USS$1,000 per kW for an integrated 300-MW plant (while acknowledging that to achieve such a cost would be a “very difficult task”).

When construction began in 2014, the cost estimate was US$15,400 per kW (US$446 million / 29 MW). By April 2017, the cost estimate had increased US$21,900 (A$31,500) per kW (US$700 million / 32 MW).

To the best of my knowledge, no other figures on SMR construction costs are publicly available. So the figures are:

A$15,200 per kW for Russia’s light-water floating SMR

A$8,600 per kW for China’s HTGR

A$31,500 per kW for Argentina’s light-water SMR

The average of those figures is A$18,400 per kW, which is higher than the CSIRO/AEMO figure of A$16,304 per kW and double BNW’s estimate of A$9,132 per kW.

The CSIRO/AEMO report says that while there are SMRs under construction or nearing completion, “public cost data has not emerged from these early stage developments.” That simply isn’t true.

BNW’s imaginary reactor

BNW objects to CSIRO/AEMO basing their SMR cost estimate on a “hypothetical reactor”. But BNW does exactly the same, ignoring real-world cost estimates for SMRs under construction or in operation.

BNW starts with the estimate of US company NuScale Power, which hopes to build SMRs but hasn’t yet begun construction of a single prototype. BNW adds a 50% ‘loading’ in recognition of past examples of nuclear reactor cost overruns.

Thus BNW’s estimate for SMR construction costs is A$9,132 per kW.

Two big problems: NuScale’s cost estimate is bollocks, and BNW’s proposed 50% loading doesn’t fit the recent pattern of nuclear costs increasing by far greater amounts.

NuScale’s construction cost estimate of US$4,200 per kW is implausible. It is far lower than Lazard’s latest estimate of US$6,900-12,200 per kW for large reactors and far lower than the lowest estimate (US$12,300 per kW) of the cost of the two Vogtle AP1000 reactors under construction in Georgia (the only reactors under construction in the US).

NuScale’s estimate (per kW) is just one-third of the cost of the Vogtle plant – despite the unavoidable diseconomies of scale with SMRs and despite the fact that independent assessmentsconclude that SMRs will be more expensive to build (per kW) than large reactors.

Further, modular factory-line production techniques were trialled with the twin AP1000 Westinghouse reactor project in South Carolina – a project that was abandoned in 2017 after the expenditure of at least US$9 billion, bankrupting Westinghouse.

Lazard estimates a levelised cost of US$118-192 per MWh for electricity from large nuclear plants. NuScale estimates a cost of US$65 per MWh for power from its first plant. Thus NuScale claims that its electricity will be 2-3 times cheaper than that from large nuclear plants, which is implausible.

And even if NuScale achieved its cost estimate, it would still be higher than Lazard’s figures for wind power (US$28-54) and utility-scale solar (US$32-44). BNW claims that the CSIRO/AEMO levelised cost estimate of A$258-338 per MWh for SMRs is an “extreme overestimate”.

But an analysis by WSP / Parsons Brinckerhoff, prepared for the SA Nuclear Fuel Cycle Royal Commission, estimated a cost of A$225 per MWh for a reactor based on the NuScale design, which is far closer to the CSIRO/AEMO estimate than it is to BNW’s estimate of A$123-128 per MWh with the potential to fall as low as A$60.

Cost overruns

BNW proposes adding a 50% ‘loading’ to NuScale’s cost estimate in recognition of past examples of reactor cost overruns, and claims that it is basing its calculations on “a first-of-a-kind vendor estimate [NuScale’s] with the maximum uncertainly associated with the Class of the estimate.” Huh?

The general pattern is that early vendor estimates underestimate true costs by an order of magnitude, while estimates around the time of initial construction underestimate true costs by a factor of 2-4.

Here are some recent examples of vastly greater cost increases than BNW allows for:

* The estimated cost of the HTGR under construction in China has nearly doubled.

 The cost of Russia’s floating SMR quadrupled.

* The estimated cost of Argentina’s SMR has increased 22-fold above early, speculative estimates and the cost increased by 66% from 2014, when construction began, to 2017.

* The cost estimate for the Vogtle project in US state of Georgia (two AP1000 reactors) has doubled to more than US$13.5 billion per reactor and will increase further. In 2006, Westinghouse said it could build an AP1000 reactor for as little as US1.4 billion – 10 times lower than the current estimate for Vogtle.

* The estimated combined cost of the two EPR reactors under construction in the UK, including finance costs, is £26.7 billion (the EU’s 2014 estimate of £24.5 billion plus a £2.2 billion increase announced in July 2017). In the mid-2000s, the estimated construction cost for one EPR reactor in the UK was £2 billion, almost seven times lower than the current estimate.

* The estimated cost of about €12.4 billion for the only reactor under construction in France is 3.8 times greater than the original €3.3 billion estimate.

* The estimated cost of about €11 billion for the only reactor under construction in Finland is 3.7 times greater than the original €3 billion estimate.

Timelines

BNW notes that timelines for deployment and construction are “extremely material” in terms of the application of learning rates to capital expenditure.

BNW objected to the previous CSIRO/AEMO estimate of five years for construction of an SMR and proposed a “more probable” three-year estimate as well as an assumption that NuScale’s first reactor will begin generating power in 2026 even though construction has not yet begun.

For reasons unexplained, CSIRO/AEMO also assume a three-year construction period in their latest report, and for reasons unexplained the operating life of an SMR is halved from 60 years to 30 years.

None of the real-world evidence supports the arguments about construction timelines:

* The construction period for the only operational SMR, Russia’s floating plant, was 12.5 years.

* Argentina’s CAREM SMR was conceived in the 1980s, construction began in 2014, the 2017 start-up date was missed and subsequent start-up dates were missed.

If the current schedule for a 2023 start-up is met it will be a nine-year construction project rather than the three years proposed by CSIRO/AEMO and BNW for construction of an SMR.

Last year, work on the CAREM SMR was suspended, with Techint Engineering & Construction asking Argentina’s National Atomic Energy Commission to take urgent measures to mitigate the project’s serious financial breakdown. In April 2020, Argentina’s energy minister announced that work on CAREM would resume.

* Construction of China’s HTGR SMR began in 2012, the 2017 start-up date was missed, and if the targeted late-2020 start-up is met it will be an eight-year construction project.

* NuScale Power has been trying to progress its SMR ambitions for over a decade and hasn’t yet begun construction of a single prototype reactor.

* The two large reactors under construction in the US are 5.5 years behind schedule and those under construction in France and Finland are 10 years behind schedule.

* In 2007, EDF boasted that Britons would be using electricity from an EPR reactor at Hinkley Point to cook their Christmas turkeys in December 2017 – but construction didn’t even begin until December 2018.

Learning rates

In response to relentless attacks from far-right politicians and lobby groups such as BNW, the latest CSIRO/AEMO GenCost report makes the heroic assumption that SMR costs will fall from A$16,304 per kW to as little as A$7,140 per kW in 2030, with the levelised cost anywhere between A$129 and A$336 per MWh.

The report states that SMRs were assigned a “higher learning rate (more consistent with an emerging technology) rather than being included in a broad nuclear category, with a low learning rate consistent with more mature large scale nuclear.”

But there’s no empirical basis, nor any logical basis, for the learning rate assumed in the report. The cost reduction assumes that large numbers of SMRs will be built, and that costs will come down as efficiencies are found, production capacity is scaled up, etc.

Large numbers of SMRs being built? Not according to expert opinion. A 2017 Lloyd’s Register report was based on the insights of almost 600 professionals and experts from utilities, distributors, operators and equipment manufacturers, who predicted that SMRs have a “low likelihood of eventual take-up, and will have a minimal impact when they do arrive”.

A 2014 report produced by Nuclear Energy Insider, drawing on interviews with more than 50 “leading specialists and decision makers”, noted a “pervasive sense of pessimism” about the future of SMRs.

Last year, the North American Project Director for Nuclear Energy Insider said that there “is unprecedented growth in companies proposing design alternatives for the future of nuclear, but precious little progress in terms of market-ready solutions.”

Will costs come down in the unlikely event that SMRs are built in significant numbers? For large nuclear reactors, the experience has been either a very slow learning rate with modest cost decreases, or a negative learning rate.

If everything went astonishingly well for SMRs, it would take several rounds of learning to drastically cut costs to A$7,140 per kW. Several rounds of SMR construction by 2030, as assumed in the most optimistic scenario in the CSIRO/AEMO report?

Obviously not. The report notes that it would take many years to achieve economies, but then ignores its own advice:

“Constructing first-of-a-kind plant includes additional unforeseen costs associated with lack of experience in completing such projects on budget. SMR will not only be subject to first-of-a-kind costs in Australia but also the general engineering principle that building plant smaller leads to higher costs. SMRs may be able to overcome the scale problem by keeping the design of reactors constant and producing them in a series. This potential to modularise the technology is likely another source of lower cost estimates. However, even in the scenario where the industry reaches a scale where small modular reactors can be produced in series, this will take many years to achieve and therefore is not relevant to estimates of current costs (using our definition).”

Even with heroic assumptions resulting in CSIRO/AEMO’s low-cost estimate of A$129 per MWh for SMRs in 2030, the cost is still far higher than the low-cost estimates for wind with two hours of battery storage (A$64), wind with six hours of pumped hydro storage (A$86), solar PV with two hours of battery storage (A$52) or solar PV with six hours of pumped hydro storage (A$84).

And the CSIRO/AEMO high-cost estimate for SMRs in 2030 ($336 per MWh) is more than double the high estimates for solar PV or wind with 2-6 hours of storage (A$90-151).

Reality bats last

 The economic claims of SMR enthusiasts are sharply contradicted by real-world data.

And their propaganda campaign simply isn’t working – government funding and private-sector funding is pitiful when measured against the investments required to build SMR prototypes let alone fleets of SMRs and the infrastructure that would allow for mass production of SMR components.

Wherever you look, there’s nothing to justify the hype of SMR enthusiasts.

Argentina’s stalled SMR program is a joke. Plans for 18 additional HTGRs at the same site as the demonstration plant in China have been “dropped” according to the World Nuclear Association.

Russia planned to have seven floating nuclear power plants by 2015, but only recently began operation of its first plant. South Korea won’t build any of its domestically-designed SMART SMRs in South Korea – “this is not practical or economic” according to the World Nuclear Association – and plans to establish an export market for SMART SMRs depend on a wing and a prayer … and on Saudi oil money which is currently in short supply.

‘Reality bats last’, nuclear advocate Barry Brook used to say a decade ago when a nuclear ‘renaissance’ was in full-swing.

The reality is that the renaissance was short-lived, and global nuclear capacity fell by 0.6 gigawatts last year while renewable capacity increased by a record 201 gigawatts.

Dr. Jim Green is the national nuclear campaigner with Friends of the Earth Australia and editor of the Nuclear Monitor newsletter.

Mysterious, manipulative and corrupt process whereby Napandee was selected for nuclear dump site, Australia

June 20, 2020

 

Kimba was taken completely off the list as a possible site announced April 29th 2016. And that should have been the end of it…… And then the goalposts for nomination were changed

Why would you allow an OBVIOUS INVESTED PERSONAL INTEREST be on the Kimba Consultative Committee – where the members WERE SELECTED BY THE GOVERNMENT! And it gets worse than that

Name Withheld, National Radioactive Waste Management Amendment (Site Specification, Community Fund and Other Measures) Bill 2020 [Provisions] Submission 39   [excerpt] “…..So we examine briefly the nomination process in Kimba. When the 28 nominations were received in 2015, the number were then by a mysterious and yet to be released process whereby 6 sites were ultimately deemed suitable by the Federal Government. This announcement occurred in early 2016 and after another round of processes which were just as mysterious, the two sites in Kimba and one site in Hawker were selected to go to the the next round.

But just as quickly as they were announced – Cortlinye (Current MP at that time and now Rowan Ramsey’s land) and Pinkawillinie (Jeff Baldock’s  land) in Kimba, and Barndioota (former senator Grant Chapman and Philip Speakman pastoral lease), suddenly it was noted that Rowan Ramsey’s nomination of Cortlinye was in direct conflict with Section 44 of the Constitution, so his land nomination was withdrawn. Pinkawillinie, which was Jeff Baldock’s nomination was not accepted as suitable because of lack of community support.

So that left Barndioota as the only candidate. That meant Kimba was taken completely off the list as a possible site announced April 29th 2016. And that should have been the end of it.
https://www.eyretribune.com.au/story/3878053/kimba-not-going-nuclear/

Then following the Federal Election in July 2016, just a few months later, the portfolio of Minster of Resources was shifted from Josh Frydenberg and given to Matt Canavan. And then the goalposts for nomination were changed…. and suddenly Kimba was on the list again, with three different nominations – Napandee (Jeff Baldock’s land), Tola Park (Jeff Baldock’s land) and Lyndhurst (Brett and Michelle Rayner).

So effectively Jeff Baldock seemingly pursued this dump and the nomination process if you look at how many sites he submitted! And he became proactive by being an active member of the newly formed Working for Kimba’s Future (in 2016) AND one of the members of the Kimba Consultative Committee!

There was no apparent submissions required for these nominations in this “second intake” or at least it was not advertised! Many people in Kimba assumed that the previous ones submitted when Cortlinye and Pinkawillinie were nominated would be used for these two new sites of Napandee and Lyndhurst. Tola Park was not taken any further after the nominations were announced possibly because it had too many neighbours to deal with.

To bring the point absolutely to point – Jeff Baldock was intent on making this happen, by submitting his land, not once, not twice but three times! And inserting himself into the Working for Kimba’s Future Committee AND an active member of the Kimba Consultative Committee! Rowan Ramsey did not do this when nominating his land. Brett and Michelle Rayner did not do this when nominating their land. (And go to Hawker – Grant Chapman and peter Speakman did not do this when nominating their land – although granted they do not actually live in the area either!)

Why would you allow an OBVIOUS INVESTED PERSONAL INTEREST be on the Kimba Consultative Committee – where the members WERE SELECTED BY THE GOVERNMENT! And it gets worse than that – the required NUMBERS OF PEOPLE REQUIRED – 6 FOR, 6 AGAINST and 6 NEITHER – were not achieved for the committee when the selected names came back, and when questioned why this is so, were told that it didn’t matter because they were a non voting body. However that is not true as the Committee was used to decide the boundaries for the voting.

“5.20 Mrs Toni Scott outlined her concerns with the allocation of places to the Kimba Consultative Committee: Bruce McCleary…informed people at the meeting that the committee would consist of six people opposed, six people supportive and six people who are neutral. That was also again given to members of our group by the Minister—that that’s how the makeup of the committee would be. On the day that the committee was announced, we were extremely concerned that there were only four people who had expressed opposition who were actually on that committee…

Bruce Wilson took my concerns on board and told me that the makeup of the committee didn’t really matter because it’s a non-voting body.15 5.21 However, it does appear that the Kimba Consultative Committee (KCC) has
been asked to make at least on significant decision: We were told by Bruce McCleary that the KCC would be a non-decision making body. However, our concerns probably came to light a bit in the May meeting, when the KCC was asked to vote on whether we should request that the Minister consider  altering the boundaries for the ballot.”
https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Economics/Wastemanageme
ntfacility/~/media/Committees/economics_ctte/Wastemanagementfacility/report.pdf

Which leads to the use of the Local Government Act in the ballot process. It was not an accident of fortune that it was used to conduct the community ballot – as this meant that it could be used also to exclude Traditional Owners as well – particularly the Barngarla people in the case of Kimba.

“5.21 However, it does appear that the Kimba Consultative Committee (KCC) has been asked to make at least on significant decision: We were told by Bruce McCleary that the KCC would be a non decision making body. However, our concerns probably came to light a bit in the May meeting, when the KCC was asked to vote on whether we should request that the Minister consider altering the boundaries for the ballot.16 5.22 By contrast, Dr Susan Andersson explained how the Barndioota Consultative Committee had effectively been sidelined by DIIS and the Minister in relation to defining the boundaries of the community vote: …we spent hours deciding what community is and who will get the vote and whether that includes Quorn, whether outback areas get in and how broad this should be. We had an expert there to help us define community for two sessions. Plus it was on the agenda two or three times: you will get a vote; BCC will be inputting into what area gets a vote.

Then Minister Canavan arrived on his surprise visit and said, ‘The area will be this.’ At a BCC meeting we said, ‘Hang on, we haven’t had our vote yet.’ ‘Oh, haven’t you? You can still have your vote; we’ll listen to it.’ But he’d already made media and public announcements as to what the area was. The  BCC had been working towards contributing to what defined the community.17”
https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Economics/Wastemanageme
ntfacility/~/media/Committees/economics_ctte/Wastemanagementfacility/report.pdf

 

Although the Act as it stands requires consultation with Traditional Owners, freezing them deliberately out of the community ballot should not the intention of what is considered a right and Australian way of doing things in this day and age – given the scope and timeline of the nuclear waste being considered! Especially when the Local Government Act is only primarily used for Roads, Rates and Rubbish…and electing new council members!

Although the Barngarla people’s Native Title claim was determined on January 22nd 2015, their formal ownership occurred in June 2018, after first being lodged in 1996! Now when was the community ballot originally meant to be conducted for this dump? August 2018. This again is a reason why the Barngarla people are angry. When they conducted their very own ballot in 2019, through an independent ballot agent Australian Election
Company, after being denied one through the Council ballot with boundaries determined by the Minister, their results showed NO VOTES IN FAVOUR OF THE DUMP ON THEIR LAND – 209 eligible to vote, 83 voted NO 0 voted yes! So under Matt Canavan’s loose usage of figures, 100% NO and
0%YES.

But the real kicker are two other points. One that the Baldocks are now actively selling land with three neighbouring famers in Kimba in a large lot  called the “Cunyarie Collection”, 9000ha as
advertised February 14, 2020 https://www.adelaidenow.com.au/business/sa-businessjournal/
large-parcel-of-eyre-peninsula-cropping-land-on-the-market/newsstory/
74188105d449d5920685cdd74637780c

So much for all the media gab about it being good for the community! Actions speak louder than words!

And that the historical information about the announced site, as under the AECOM site study used some historical information from Jeff Baldock himself, who had had the land only for less than 10 years! “The soils at the site are a sandy loam on a relatively impermeable calcrete/silcrete layer at a depth of approximately 0.3m with no known localised flooding or water logging issues (source Jeff Baldock 22 Feb 2018). This is based on approximately 6 years on the property.” Page 72
https://www.industry.gov.au/sites/default/files/2019-
04/nrwmf_site_characterisation_technical_report_napandee.pdf

This is a flawed proposal from start to end. Having ONE person nominate their land is not the best way of dealing with nuclear waste. This is not considering the very best geological site for this waste.Nor the very safest site for this waste. Just a lottery for the landowner who would “win” the
nomination!
And the goal posts were forever changing. The neighbouring areas were farcical as the diameter of the inclusion zone became smaller and smaller…until it was only the immediate fence lines and have a road in-between and you’re not a neighbour! That is how the 100% neighbour figure was achieved. There were four immediate or direct neighbours to Napandee, but that became 3 after this ruling was used. And those 3 neighbours agreed with the site. The neighbour with the road in-between did not! https://www.aph.gov.au/DocumentStore.ashx?id=4211af77-bacf-4cb7-b03c-
98ba573b179b&subId=565156

The Conservation Parks nearby Napandee (Pinkawillinie Conservation Park and also the Gawler Ranges National Park) were not allowed a say as “neighbours” as they are State owned…. as determined by the guidelines set up Department of Industry, Innovation and Science, with advice from Geoscience Australia, independent market research company ORIMA Research the Kimba Consultative Committee… “A neighbour cannot be the Crown in any capacity, a district council or any
other State or Commonwealth government body”
https://www.industry.gov.au/sites/default/files/2019-11/nrwmf-neighbour-sentiment-surveyguidelines.
pdf

Kimba community unaware that Australia’s medicine does not need nuclear reactor

June 18, 2020

even ANSTO is using cyclotrons for generating imaging isotopes! And we actually have imaging/cyclotron partnerships set up in almost every major city in Australia….do not produce nuclear wastes.……..(expanding nuclear production) so that ANSTO can become one of the major players in the global export market. Where was this information in the glossy handouts given to Hawker and Kimba?

Name withheld. to Senate Committee on  National Radioactive WasteManagement Amendment (Site Specification, Community Fund and Other Measures) Bill 2020 [Provisions] Submission 39  Excerpt

“States and territories are responsible for managing a range of radioactive waste holdings, accounting for about one per cent of total radioactive waste holdings in Australia.”…according to the DIIS – “Australian Radioactive Waste Management Framework April 2018”page 7
https://www.industry.gov.au/sites/default/files/2019-
04/australian_radioactive_waste_management_framework.pdf

And what about the requirement of the diagnostic isotope for Australians? It is afterall in our best interests to maintain this? This is an interesting question. In Senate Estimates Adi Paterson in 2017 stated…. ”As we submitted to the question on notice, currently approximately 28 per cent of molybdenum-99 produced by ANSTO is used domestically. Approximately 72 per cent of Mo-99 produced by ANSTO is exported, meeting a global need for access to life-saving nuclear medicines.” https://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;db=COMMITTEES;id=committees%
2Festimate%2F0493150c-8738-423c-a856- 9cb37d9e9073%2F0009;query=Id%3A%22committees%2Festimate%2F0493150c-8738-423c-a856- 9cb37d9e9073%2F0000%22

He then goes on to say later at the Senate Estimates, “The research use of isotopes predominantly takes place in our Camperdown facility, where we produce flourine-18, carbon-15 and oxygen-11.
These are cyclotron-based isotopes which are used for different types of clinical development of new imaging techniques, for developing new drugs and understanding the biological function of human living systems. That is a research cost for the production of those isotopes. There are small
amounts of isotopes whose inclusion into clinical trials we support. We do that under a very careful set of rules that ensures that should those clinical trials be successful we will be able to sell into the market the isotopes we produce that have supported the clinical trials. We have very good protocols on that which are very clear. We also sometimes undertake trials with stable isotopes, which are sourced from different jurisdictions. These are not radioactive isotopes, but with our careful tracing capabilities we can make use of those isotopes as well.”

So, even ANSTO is using cyclotrons for generating imaging isotopes! And we actually have imaging/cyclotron partnerships set up in almost every major city in Australia. For example Adelaide has one set up in the SAHMRI building. The thing about cyclotrons is that the isotopes are generatedon site, and do not have a distance factor involved and do not produce nuclear reactor quantities of nuclear waste!

And just for those interested, there are now advancements being made in immunotherapy and nanotechnology which means that patients can now receive treatment in a way which does not disrupt normal cells as a consequence. Immunotherapy is genetically modifying your own cells and
then reinjecting them into you to fight the cancer cells specifically. And nanotechnology is a way of specifically directing chemotherapy drugs specifically to cancer cells. Scott Morrison has injected almost half a billion dollars into Victoria to aid in this cutting edge technology. And neither involve nuclear reactors. https://www.abc.net.au/news/2016-01-11/nanocrystals-could-change-the-waycancer-
is-treated/7079958
https://www.heraldsun.com.au/news/victoria/peter-maccallum-cancer-centre-to-become-globallifesaving-
cancer-treatment-hub-under-budget-boost/newsstory/
7e6e0880ddac37973d1588c56c13a064

But getting back to the quantities of Molybenum-99 produced by ANSTO. Only 28% is used by Australians. This is for 550,000 doses produced per annum. And 72% is exported. Now, ANSTO has a brand new ANM building which they are intending to use to generate 10 MILLION DOSES PER
ANNUM, so that ANSTO can become one of the major players in the global export market. Where was this information in the glossy handouts given to Hawker and Kimba?
With higher production of course comes higher levels of nuclear waste. It is one of the reasons why Canada exited the global
market scene because it was too expensive for their own taxpayers to continue to subsidize.

“Scheduled to be turned on just next year, once the ANM Project is fully operational, Australia will go from producing 550,000 doses of medicine a year to more than 10 million doses a year.“Our medicine production will increase exponentially. We’ll be producing enough medicine to meet more than a quarter of world demand,” said ANSTO CEO Dr Adi Paterson.” https://anstoprod.
cd.pnx.com.au/news/four-million-nuclear-medicine-doses-produced-and-going-strong

The ANM Project received operational licence by ARPANSA in late 2018.So for people like our MP’s to say that we all as Australians use the medical isotopes and therefore are responsible for the nuclear waste generated runs a bit hollow when we are actually propping up a major player in an export market!…..”

Australia’s history – how South Australia is targeted for an international nuclear waste dump

June 17, 2020

Name withheld. to Senate Committee on  National Radioactive Waste Management Amendment (Site Specification, Community Fund and Other Measures) Bill 2020 [Provisions] Submission 39  Excerpt

The amendment to the Bill put forward by the now Minister of Resources Keith Bill should be rescinded and here are the reasons why.
First and foremost there was NO Broad Community Support achieved.

[The writer now gives an account of the requirement for community support for the nuclear waste facility:  Support “would need to be in the vicinity of 65%, and that submissions and ‘neighbouring views’ would also be taken into consideration.” – and that this support was not achieved]

So why was Kimba announced as the dump site if this stipulation was not fulfilled? To understand it, first you must understand the history behind the dump proposal.

HISTORY
This whole dump proposal has been flawed from the very start. It is the exact same proposal put forward in Parliament in the 1980’s and hasn’t changed. The recurrent statement of “we only have a small amount of Intermediate Level Waste so that can “tag-a-long” or “co-locate” with the Low Level Waste” was used back then and continues to be used right now 40 years later!
If you consider that, back in the 1980’s the proposed dump concept was to be only operating for 50 years, as they also stated that by that time the Intermediate Level Waste would be dealt with before its closure. Think about it – that means the preparation should ALREADY be in place RIGHT NOW according to their statements – ready for 2030!
And yet NOTHING has been done in that regard!! We still have the Woomera Waste still sitting in Woomera, when it was stated by the Federal Government at that time (1994), that it would only be “temporary” for 2 – 3 years maximum! Moving on 25 years plus – and it still remains in Woomera. Past behaviour is a good predictor of future behaviour.
It should be noted that the waste in Woomera – the CSIRO waste from Melbourne Fishermans Bend and the St. Mary’s waste from St. Mary’s Defence Base NSW – were placed in Woomera AS A RESULT of a NSW Environmental Court Case brought onto ANSTO Lucas Heights by the Sutherland Shire Council.
The CSIRO waste was from the cleanup of Fishermans Bend in Victoria – where in fact only 200 of these drums contained radioactive waste according to the then Transport code of a minimum exceeding 70,000 Becquerels per kilogram to be considered a radioactive substance! But due to the media coverage and the concern by the public, all 9726 x 205L of the drums were classified as radioactive and then taken by consignment to ANSTO Lucas Heights NSW for storage. They were
stored on site for 4 years at ANSTO Lucas Heights (1990 -1994). It was only when Lucas Heights agreed to take the waste from St Mary’s Defence Base NSW (1991) that Sutherland Shire Council brought a court case up against ANSTO Lucas Heights from taking waste from other entities.
The Case was won by Sutherland Council, and although ANSTO was swift to change the Federal Act thereafter so that such jurisdictional action would never happen again. The Federal Government sought a suitable Commonwealth site to place the Fishermans Bend and St Marys Bend waste at short notice – which was Woomera in SA. At the time, the Feds were in negotiation with Northern Territory with regards to a dump site in NT, which fell through. The waste remains separately stored in Woomera – although ANSTO was commissioned to condition the St Mary’s Defence waste before it was transported to Woomera.
https://www.aph.gov.au/About_Parliament/Parliamentary_Departments/Parliamentary_Library/Pu blications_Archive/online/RadioactiveWaste
Almost every state in Australia has been the target of this dump in the past. This is the second time SA has been targeted.
And each and every time the establishment of the dump has failed.
Why is this? Because it is a flawed proposal. Trotting out the exact same proposal since 1980’s shows that. The only change this time round is for nomination by land owners to nominate their land for the dump this time! 28 sites all around Australia were nominated in the nomination period 2nd March 2015 to 5th May 2015. It was the 13th November 2015 when the then resources minister Josh Frydenberg announce 6 sites around Australia which the Federal Government had deemed suitable.
https://www.aph.gov.au/DocumentStore.ashx?id=a80c7b35-3fdc-4502-8febd8381b03dae3& subId=565152 “Submission
“Submission to the Senate Inquiry into the Site Selection Process for a National Radioactive Waste Management Facility Radioactive Waste Management Taskforce April 2018” Annexure 6 – Chronology of site selection process.
Coincidentally, the South Australian Royal Commission into the Nuclear Fuel Cycle was established on 19th March 2015. The final report of this Royal Commission was presented to the SA premier Jay Weatherill on 9th May 2016. From October 2016 to November 2016, with final result obtained and given to the Premier of SA on 6th November 2016 a citizen’s jury decided a NO MEANS NO to SA becoming an International Dump site. https://www.abc.net.au/news/2016-11-06/sa-citizens-juryvote- against-storing-nuclear-waste/7999262
  The then opposition leader Stephen Marshall reaffirmed this stance 5 days later 11th November 2016
https://www.abc.net.au/news/2016-11-11/opposition-says-it-will-vote-against-sa-nuclear-wastedump/    8016818?fbclid=IwAR1CiCk6Y1je4l1ZUtpvlJqYT4rHeKcqreHAXtVJ1xZxpKNfHZ6xfToZxVA

Why is this important? Because of the timeline! There is NO WAY ON EARTH that South Australia was NOT BEING TARGETED!

And even today, there are South Australians who believe that the International AND National Nuclear Dump targeting in South Australia had been put to bed back in November 2016! That this was ONE FIGHT instead of TWO!
However, it has to be noted, that when Mike Rann fought to stop the Federal Government putting a dump into South Australia in the early 2000’s, there was a push by an international group called PANGEA with a leaked media video, which is intent on establishing an International Nuclear Dump in Australia. The group is now called itself ARIUS, since 2012, and is alive and kicking as witnessed in the Royal Commission into the Nuclear Fuel Cycle 2016.
TECHNICAL SUITABILITY
So why is the Federal Government so hell bent on putting this nuclear waste onto South Australia? Surely World’s Best Practise would dictate that the best site would be closer to the main site of generation and not over 1700kms across the country and into another state! Less transport and less handling required meaning less human error and mistakes. Which is a perfect time to reiterate ARPANSA’s definition of nuclear waste – “Radioactive waste is material that has no foreseeable use and contains radioactive materials with activities or activity concentrations at levels high enough that regulatory oversight is needed to ensure safety.” https://www.arpansa.gov.au/understandingradiation/ radiation-sources/more-radiation-sources/radioactive-waste-safety/frequently-askedquestions
Why was Sallys Flat NSW which was ONE of the SIX sites deemed suitable by the Federal Government not hounded like the South Australian sites were? Sallys Flat is only 260 kms from Lucas Heights. Even Oman Ama QLD which is another of the SIX sites deemed suitable by the Federal Government is closer at 780kms! The site at Kimba is over 1700kms away!
Over 90% of all Australia’s nuclear waste (non-mining) is generated on site at Lucas Heights NSW for the production of nuclear medical isotopes predominately. And these isotopes are predominately used for diagnostic imaging, and to a much, much smaller extent for treatment.

How much nuclear waste does South Australia actually have itself? Back in 2003 Mike Rann was reported as stating that

South Australia itself had only enough nuclear waste to fill one 44 gallon drum! And today it isn’t much more than that! https://www.abc.net.au/news/2003-06-03/rannrejects-waste-dump-threats/1864470
“States and territories are responsible for managing a range of radioactive waste holdings, accounting for about one per cent of total radioactive waste holdings in Australia.”…according to the DIIS – “Australian Radioactive Waste Management Framework April 2018” page 7 https://www.industry.gov.au/sites/default/files/2019- 04/australian_radioactive_waste_management_framework.pdf……

Lucas Heights was built with ample space so that they could take care of all of the waste they generated on site. It was only with the build of the OPAL reactor which replaced the aging HIFAR reactor that it was thought that the waste could go elsewhere, to pacify the nearby population as a compromise of the build of the new reactor. But the premise still remains, and Lucas Heights has enough space to deal with their own was for up to 100 years.

Since Lucas Heights was built in 1958 there is still plenty of space and time for this research reactor to find a proper solution to this nuclear waste once and for all. Not to bury it somewhere out of sight and out of mind , so it is essentially abandoned. If push comes to shove with Government funding, do you think the proposed nuclear dump will be a priority? This dump simply gives Lucas Heights licence to continue and indeed even increase nuclear waste production.

And then consider the criteria for acceptance of nuclear waste at the proposed dump. These can easily be changed with a stroke of a pen. No liquid now, but that can be changed. No mining waste now, but that can be changed. No High Level Nuclear Waste now, but that can be changed. Just as the management and ownership of the dump can change, should the financing prove too much for the Federal Government. They have off loaded other Government owned entities before, no different with nuclear waste. And there in comes International Nuclear Waste through the backdoor.

Revolving door – Weapons industry to South Australia’s top Government Advisor

June 13, 2020

This could shed some light on the South Australian government’s silence on the Federal plan for a nuclear waste dump in South Australia.  We can expect the South Australian government to now support the nuclear waste dump at Napandee, and to promote schemes to make south Australia a nuclear hub, especially with nuclear submarines production.

 

The Maritime Union of Australia (SA branch) rejects Nuclear Waste Bill, discusses transport dangers

June 11, 2020

The proposal to move long-lived intermediate-level waste (ILW) from interim above-ground storage at Lucas Heights to interim above-ground storage at the Kimba site….exposes communities to unnecessary risks, and it exposes workers (including MUA members) to unnecessary risks. .. and raises “implications for security”… the considerable distances involved create a whole additional level of risk.

MUA policy is that our members will not be involved in moving nuclear waste. The toxicity
of the waste is severe.

The Maritime Union of Australia (SA branch) to Senate Committee on  National Radioactive Waste Management Amendment (Site Specification, Community Fund and Other Measures) Bill 2020 [Provisions] Submission 19   The Maritime Union of Australia (SA branch) recommends that the Senate Committee rejects the National Radioactive Waste Management Amendment (Site Specification, Community Fund and Other Measures) Bill 2020 (hereafter the NRWM Amendment Bill).

The Bill is designed to advance a fundamentally flawed radioactive waste management process which should be put on hold until such time as a comprehensive independent inquiry is held to investigate all options for managing radioactive waste

The Committee should recommend repeal of the unacceptable and draconian overrides of Commonwealth and state laws in the existing National Radioactive Waste Management Act 2012. Further, the Committee should recommend rejection of the NRWM Amendment Bill which would worsen the situation by giving the Federal Government additional sweeping
powers to override Commonwealth and state laws.
The Federal Government’s own 65% benchmark for ‘broad community support’ has not been met; only 43.8% of eligible voters in the combined Kimba and Barngarla ballots supported the proposed nuclear waste facility. The Federal Government has not demonstrated ‘broad community support’ along potential transport corridors or statewide
in SA. The proposed nuclear waste facility is illegal under South Australia’s Nuclear Waste Facility (Prohibition) Act. Instead of respecting that state legislation, the Federal Government intends to override it and the NRWM Amendment Bill outlines a regulatory mechanism to override SA law and thus to undermine democratic rights.
The proposal to proceed with the nuclear waste facility despite the clear opposition of Barngarla Traditional Owners ‒ and their representative body, the Barngarla Determination Aboriginal Corporate ‒ is unacceptable and must not be allowed to stand. The Committee must reject the Bill and recommend that the proposed waste facility near Kimba should be
scrapped in light of the opposition of Traditional Owners. The Committee should also draw
attention to, and strongly reject, proposed amendments in the NRWM Amendment Bill
which would further disempower Traditional Owners, including by stripping them of appeal
rights.
Legal advice in a Feb. 2020 report by the Parliamentary Joint Committee on Human Rights
notes that the Bill “would enable native title to be extinguished, without the consent of the
traditional owners”, and it raises further concerns about the Bill’s intention to permit the
acquisition of land for an access route without any Parliamentary oversight or right of
appeal.
The Federal Government’s actions ‒ including its NRWM Amendment Bill ‒ are inconsistent
with the UN Declaration on the Rights of Indigenous Peoples. The United Nations
Committee on the Elimination of Racial Discrimination (CERD Committee) in 2017 expressed
concern “about information that extractive and development projects are carried out on
lands owned or traditionally owned by Indigenous Peoples without seeking their prior, free
and informed consent” and recommended that Australia “ensure that the principle of free,
prior and informed consent is incorporated into the Native Title Act 1993 and in other
legislation as appropriate, and fully implemented in practice”.
Instead of accepting the principle of free, prior and informed consent, the Federal
Government intends to proceed without the consent of Traditional Owners and to amend
legislation to override their rights and interests.
The Maritime Union of Australia (SA branch) endorses the resolution carried at the SA ALP
State Conference on 13 October 2018 (noting that the targeted site in the Flinders Ranges is
no longer under consideration):
“State Convention acknowledges that radioactive waste management is a complex policy
challenge that requires the highest level of transparency and evidence and that the current
federal approach to site a national waste facility in regional South Australia is strongly
contested.
Supports Traditional Owners and community members in the Flinders Ranges and Kimba
regions of South Australia in their current struggle to prevent a nuclear waste facility
being constructed in their region.
• Calls for full transparency, broad public input and best practice technical and
consultative standards during the current site nomination and selection process.
• Expresses concern at the federal government’s continuing fo
focus on finding a single
remote site for radioactive waste to be disposed (low level) and stored (intermediate
level) to the exclusion of all other waste management options.
• Reaffirms its support for the civil society call for the extended interim storage of federal
wastes at federal sites pending a broad independent inquiry that examines all options for
future responsible radioactive waste, transport and storage and management.
• Commits to support communities opposing the nomination of their lands or region for a
dump site, and any workers who refuse to facilitate the construction and operation or
transport and handling of radioactive waste material destined for any contested facility or sites including South Australian Port communities.”
TRANSPORT ISSUES
The Department’s July 2018 “Site Characterisation Technical Report: Napandee” (p.150)
names Whyalla Port to take shipments of nuclear fuel reprocessing waste.1 Two shipments
of reprocessed nuclear fuel wastes, in 130 tonne TN-81 casks, are intended within the first
two years of operations of an ILW store, with many more over subsequent years and
decades. The Department’s report also proposes 100 x B-double 50 tonne loads of ILW in
the first four years alone (in addition to hundreds of loads of low-level radioactive waste)
and it flags the option of shipping ILW from Port Kembla to an SA port such as Whyalla
(p.157-158): “It may be possible to have these containers shipped from Port Kembla to ports

such as Whyalla.”
There is no logic behind the proposal to move long-lived intermediate-level waste (ILW)
from interim above-ground storage at Lucas Heights to interim above-ground storage at the
Kimba site. The proposed double-handling (once to the Kimba site, then at some unspecified
time to a disposal site) makes no sense whatsoever, it exposes communities to unnecessary
risks, and it exposes workers (including MUA members) to unnecessary risks. Further,
ARPANSA’s Nuclear Safety Committee has stated that dual handling in transport associated
with interim storage “does not represent international best practice” and raises
“implications for security”
Additionally, the considerable distances involved create a whole additional level of risk. The
more time a truck is on the road the greater the chance of an accident. International best
practice is the shortest distance possible for waste transportation to a permanent storage
site.
Clearly ILW waste stored at ANSTO’s Lucas Heights should remain there until a disposal
facility is available. ANSTO has better safety and security arrangements than could possibly
apply at the Kimba site; there are no legal or regulatory impediments to ongoing storage at
Lucas Heights; and storage at Lucas Heights avoids the unnecessary risks associated with the
proposed double handling.
MUA policy is that our members will not be involved in moving nuclear waste. The toxicity
of the waste is severe. Even if the chances of an accident were small, there would
potentially be very significant, negative consequences for members in the vicinity. On this
basis our refusal to handle nuclear waste is easily defensible-and arguably required- under
the nationally harmonised Workplace Health and Safety laws.
The Federal Government has made no effort to consult along potential road corridors or
targeted port towns such as Port Kembla or Whyalla. This is a long-standing breach of advice
from ARPANSA’s Nuclear Safety Committee which stresses the “essential” requirement to
“clearly and effectively engage all stakeholders, including those along transport routes” in its
Nov. 2016 report.3
ARPANSA’s draft Code for Disposal of Radioactive Waste (Dec. 2017) states that an applicant
for an ILW disposal facility would need to satisfy the regulator that safe containment can be
demonstrated over a period of “not be less than 10,000 years.4 Yet the Federal Government has made no progress towards disposal of ILW and instead proposes unnecessary and

unacceptable movement from above-ground storage at Lucas Heights to less secure aboveground
storage at Kimba.

The UK Nuclear Free Local Authorities’ May 2016 “Briefing: Nuclear security concerns – how
secure is the UK civil nuclear sector?” highlights security threats including the risks from
potential attack on a nuclear waste transport or on a nuclear waste storage site.5 The
briefing paper cites nuclear engineer Dr. John Large, who stated:
“Movement of nuclear materials is inherently risky both in terms of severe accident and
terrorist attack. Not all accident scenarios and accident severities can be foreseen; it is only
possible to maintain a limited security cordon around the flask and its consignment; …
terrorists are able to seek out and exploit vulnerabilities in the transport arrangements and
localities on the route; and emergency planning is difficult to maintain over the entire route.”
The SA Nuclear Fuel Cycle Royal Commission concluded that terrorist attack scenarios are
conceivable during the transport of nuclear fuel wastes, with the potential scenario for
rocket attack on the transport of nuclear fuel waste reported as having the greatest
potential to cause a release of radiation.6
Appendix 1 provides detail on nuclear materials transport incidents and accidents. Glib
assurances of transport safety are not supported by real-world experience. Incidents and
accidents are commonplace, and in some cases the consequences are severe.
Appendix 2, an article by maritime worker and MUA member Natalie Wasley, exposes the
poor track record of the shipping company used by the Federal Government to ship spent
nuclear fuel from Australia to France for reprocessing and to ship reprocessing waste to
Australia. Problems have included losing cargo overboard, failing to follow basic navigation
rules, failing safety inspections, and exploiting workers.
TRANSPORT RISKS
APPENDIX 1: NUCLEAR WASTE TRANSPORT SAFETY AND SECURITY RISKS…….. [copious examples and references ]
APPENDIX 2: RESPONSIBILITY OVERBOARD: THE SHOCKING RECORD OF

THE COMPANY SHIPPING NUCLEAR WASTE TO AUSTRALIA….. [copious examples and references]
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