Antinuclear

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Submission on Required Protection of Cultural Heritage from impact by Disposal Facility Site selection AND on the Principle of Non-Imposition of Disposal Facilities 

This submission was sent today – not yet published on ARPANSA’s site . To read all 24 submissions already published, go to the site   https://www.arpansa.gov.au/code-disposal-solid-radioactive-waste-rps-c-3

OR to our new page Submissions on Radioactive Waste Code 2018 

David J Noonan B.Sc., M.Env.St. Independent Environment Campaigner, 2 March 2018 

Summary for ARPANSA Website:

David Noonan: To be credible, a finalised ARPANSA Code must mandate the best practice Principal of Non-Imposition of nuclear waste disposal facilities on community.

It is untenable for this Code to countenance Disposal Facility Siting in an area of special cultural heritage significance to Aboriginal people. Proposed NRWMF siting in the iconic Flinders Ranges must stop. A finalised ARPANSA Code must respect Aboriginal people’s rights and interests.

ARPANSA needs to recognise the Storage and Disposal of nuclear wastes affects the rights, interests and safety of all South Australians and is prohibited in our State under the Nuclear Waste Storage (Prohibition) Act 2000.

Any imposition of Disposal Facility Siting in SA will be strongly resisted by community across SA.

Please feel free to contact regarding this submission (contacts provided in e-mail cover note).

To: ARPANSA Public Consultation on the Code for Disposal of Solid Radioactive WasteRadiation Protection Series C-3, RHC Draft – December 2017 StakeholderComment@arpansa.gov.au

Re: D.Noonan public submission on Required Protection of Cultural Heritage from impact by Disposal Facility Site selection AND on the Principal of Non-Imposition of Disposal Facilities 2nd March 2018

Dear Secretary

Please accept and consider this 3 page public submission on Code for Disposal of Solid Radioactive Waste Radiation Protection Series C-3 (RHC Draft Dec 2017), a Summary for Website is provided.

  1. Required Protection of Cultural Heritage from impact by Disposal Facility Siting:

Updating the related 1992 Code is long overdue and advanced societal standards & expectations must now be incorporated if the 2018 version is to have integrity and realise community support.

Therefore, the draft must be amended so that Site Selection 3.1.27-3.1.29 must comply with the protection of special cultural heritage significance and must comply with the 3.1.29 (d) criteria that the vicinity of any proposed disposal facility must have “no special cultural heritage significance”.

It is untenable in this era (as proposed in the RHC Draft) for site selection to only have to consider but not have to comply with this key criteria. And thereby, to expressly threaten and impact special cultural heritage significance held by community through imposition of disposal facility siting.

No amount of proposed 538-540 “well-founded arguments must be provided in association with the safety case to address any criteria that are not fully met” will undue the harm caused by disposal facility siting in the vicinity of special cultural heritage significance held by Aboriginal people.

This is a high level current issue which the SA Premier has addressed in writing to the Prime Minister (Letter dated 24 Oct 2017, as reported in The Australian on 31 Nov 2017):

South Australian Premier Jay Weatherill has asked Malcolm Turnbull to give Aborigines the “final right of veto” over any site chosen by the federal government for the planned national radioactive waste dump. …

In the letter obtained by The Australian, Mr Weatherill said Aboriginal leaders were deeply concerned about the Hawker proposal and urged the commonwealth to commit to “provide a local Aboriginal community with a final right of veto over any future facility proposed on their lands”. 2

 

http://www.theaustralian.com.au/news/nation/bernardi-seeks-to-lift-ban-on-nukes/news-story/06ef1d96c74c833146722aaeb88c3248

ARPANSA has an obligation to see to it that the Commonwealth must not target, divide and harm Aboriginal communities and threaten their Cultural Heritage through disposal facility siting.

That is exactly what the Commonwealth has already done through proposed siting of the NRWMF near Hawker on the cultural country of the Adnyamathanha people in the iconic Flinders Ranges in an acknowledged vicinity of special cultural heritage significance to traditional owners.

Including: that the vicinity and immediately adjoining property is an Indigenous Protected Area as a part of the National Reserve System instigated for protection by the Commonwealth, AND that the broad area is a precedent registered Story Line protected under the SA Aboriginal Heritage Act 1988.

Adnyamathanha people have rejected NRWMF Siting on their country and this must be respected.

Flawed Commonwealth practice in this matter to date must not be allowed to constrain due content in this ARPANSA Code, otherwise this Code will fail to realise community respect and support.

ARPANSA must now have the integrity to deliver a Code that mandates due practice in site selection which fully protects areas of special cultural heritage significance to Aboriginal people.

A finalised ARPANSA Code must explicitly respect Aboriginal people’s rights and interests.

That is preferable to “a final right of veto” which still forces Aboriginal people through a demanding lengthy site selection process threatening their cultural heritage and dividing & harming community.

  1. The Principal of Non-Imposition of Disposal Facility Siting must be an Object of the Code:

This RHC Draft Code unacceptably fails to reflect the Principal of International Best Practise that Nuclear & Radioactive Waste Disposal Facilities must not be imposed on unwilling communities.

A final Code must mandate a Principal to not impose Disposal Facility Siting on community.

Disposal Facility Site selection is a National, a State, a regional and a local community core issue.

Disposal Facility Site selection is not only an issue for local communities or for local ‘consent’.

The Commonwealth NRWMF process to date has been flawed in this respect, in targeting local communities and in addressing only local consent, while ignoring broad State and regional issues.

ARPANSA has to recognise the Storage and Disposal of nuclear wastes affects the rights, interests and safety of all South Australians and is prohibited in our State under the Nuclear Waste Storage (Prohibition) Act 2000.

The import, transport, storage and disposal of ANSTO irradiated nuclear fuel wastes & reprocessed nuclear wastes were prohibited in SA under the leadership of Liberal Premier John Olsen in 2000: 3

 

“The Objects of this Act are to protect the health, safety and welfare of the people of South Australia and to protect the environment in which they live by prohibiting the establishment of certain nuclear waste storage facilities in this State”

Labor Premier Mike Rann then extended this legislation to prohibit other classes of nuclear wastes.

Initially, the Commonwealth claimed to forego co-location of the Store for nuclear fuel waste & for Intermediate level wastes in SA, and then abandoned any nuclear dump siting in SA in mid-2004.

Since April 2016 the Commonwealth has solely targeted proposed NRWMF sites in South Australia.

The NRWMF process to date and this RHC Draft Code fail to recognise the will of the Parliament and the people of SA expressed in clear State legislation that proposed NRWMF siting is illegal in SA.

The illegality of proposed NRWMF Siting in SA is proof of intended Commonwealth imposition of NRWMF Siting onto the people of SA – at State wide, regional and local community level.

Any imposition of Disposal Facility Siting is untenable and will be strongly and effectively resisted by community across South Australia.

ARPANSA has to address this matter or see this Code and proposed NRWMF Siting continue to fail.

 

Yours sincerely

Mr David J Noonan B.Sc., M.Env.St.

Independent Environment Campaigner

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March 2, 2018 - Posted by | AUSTRALIA - NATIONAL, Federal nuclear waste dump

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