A flawed process- National Radioactive Waste Management- Submission from David Noonan
The Bill entrenches proposed untenable indefinite above ground storage and unnecessary double /
dual handling of ANSTO nuclear fuel wastes and Intermediate Level Wastes (ILW).
to be imposed onto the community of SA contrary to our Parliament’s express will.
an unacceptable threat to impose nuclear waste
against the express will of the Barngarla People, compromising their Indigenous rights and interests
against the express will of the Barngarla People, compromising their Indigenous rights and interests
To: Senate Standing Economics Legislation Committee of Inquiry
National Radioactive Waste Management Amendment Bill 2020 – public submission
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Re: Flawed Federal process contrary to Nuclear Safety Committee advice and untenable interim
nuclear waste storage compromises Safety & Security and Rights & Interests in SA.
nuclear waste storage compromises Safety & Security and Rights & Interests in SA.
**********
Dear Committee Chairperson
Dear Committee Chairperson
Please consider this submission and my request to give Evidence as a Witness at a Hearing in SA.
The Bill’s amendments to the National Radioactive Waste Management Act 2012 further entrench
failures of best practice and shortcomings of the Federal gov. process on these issues to date.
failures of best practice and shortcomings of the Federal gov. process on these issues to date.
******
After 4 years of solely targeting SA sites (since April 2016) the Bill amends the Act to specify SA as a
nuclear waste state and Napandee near Kimba as an above-ground interim Nuclear Waste Store.
nuclear waste state and Napandee near Kimba as an above-ground interim Nuclear Waste Store.
*****
The Bill entrenches proposed untenable indefinite above ground storage and unnecessary double /
dual handling of ANSTO nuclear fuel wastes and Intermediate Level Wastes (ILW). The nuclear
regulator ARPANSA states these wastes require radiation shielding, safe handling and security, and
require isolation from people and from the environment for over 10,000 years.
dual handling of ANSTO nuclear fuel wastes and Intermediate Level Wastes (ILW). The nuclear
regulator ARPANSA states these wastes require radiation shielding, safe handling and security, and
require isolation from people and from the environment for over 10,000 years.
****
The proposal is contrary to a range of public interest advice from the Nuclear Safety Committee
(NSC) to the regulator ARPANSA and arguably compromises safety and security in South Australia.
(NSC) to the regulator ARPANSA and arguably compromises safety and security in South Australia.
****
The Bill exposes the Federal government’s failure to recognise that ARPANS Act Licensing may not be
granted to the proposed Nuclear Store, leaving an amended Act stranded with a specified failed site.
granted to the proposed Nuclear Store, leaving an amended Act stranded with a specified failed site.
***
The proposed Nuclear Store is illegal under SA Law passed by the State Liberal gov. in 2000 and is
thereby intended to be imposed onto the community of SA contrary to our Parliament’s express will.
thereby intended to be imposed onto the community of SA contrary to our Parliament’s express will.
***
Further, the Federal gov. practice to date has conspicuously failed to consult or engage the SA
****
community on core plans to ship nuclear fuel waste to a Port in SA and to transport ILW across SA.
The Bill’s proposed specification of Napandee as a Nuclear Store effectively targets the Whyalla Port.
***
The “Site Characterisation Technical Report: Napandee” (DIIS, July 2018, Proximity to ports p.150)
named Whyalla Port to take shipments of nuclear fuel wastes, in the event Napandee is specified.
thereby intended to be imposed onto the community of SA contrary to our Parliament’s express will.
named Whyalla Port to take shipments of nuclear fuel wastes, in the event Napandee is specified.
thereby intended to be imposed onto the community of SA contrary to our Parliament’s express will.
***
Two shipments of reprocessed nuclear fuel wastes are intended to an SA Port, in 130 tonne TN-81
casks, within the first two years of operations of a Nuclear Waste Store at Napandee (p.152).
Some 100 x B-double 50 tonne loads of Intermediate Level Wastes (ILW) are also intended in the
first four years of Nuclear Store operations at Napandee (p.152). The Report (p.157-158) states:
“It may be possible to have these containers shipped from Port Kembla to ports such as Whyalla”
casks, within the first two years of operations of a Nuclear Waste Store at Napandee (p.152).
Some 100 x B-double 50 tonne loads of Intermediate Level Wastes (ILW) are also intended in the
first four years of Nuclear Store operations at Napandee (p.152). The Report (p.157-158) states:
“It may be possible to have these containers shipped from Port Kembla to ports such as Whyalla”
***
The affected Eyre Peninsula, Whyalla and transport route communities have been denied a say on
these Federal plans and now face potential serious reputational risks and material impacts.
these Federal plans and now face potential serious reputational risks and material impacts.
***
The Whyalla City Council states there has had no advice from Federal or SA gov’s on use of the Port.
Whyalla is targeted for nuclear waste shipments and should have a right to refuse untenable plans.
Whyalla is targeted for nuclear waste shipments and should have a right to refuse untenable plans.
**
This flawed Federal gov. process is a direct breach of advice from the Nuclear Safety Committee in a
letter to APRANSA CEO Dr Carl-Magnus Larsson (Nov 2016), NSC Chair Dr Tamie Weaver stressed the
“ongoing requirement to clearly and effectively engage all stakeholders, including those along
transport routes”, with the NSC stating such engagement “is essential”.
letter to APRANSA CEO Dr Carl-Magnus Larsson (Nov 2016), NSC Chair Dr Tamie Weaver stressed the
“ongoing requirement to clearly and effectively engage all stakeholders, including those along
transport routes”, with the NSC stating such engagement “is essential”.
***
The NSC has also advised (2013) that dual handling transport for interim storage “does not represent
International Best Practice” and “also has implications for security” and for safety.
International Best Practice” and “also has implications for security” and for safety.
***
Importantly, the proposed NRWM Facility presents an unacceptable threat to impose nuclear waste
against the express will of the Barngarla People, compromising their Indigenous rights and interests.
against the express will of the Barngarla People, compromising their Indigenous rights and interests.
***
This Inquiry must Recommend repeal of overrides of Aboriginal heritage and traditions in the Act &
in Bill. Then Premier of SA Jay Weatherill (Oct 2017) argued for recognition of an Aboriginal People’s
‘right of veto’ over proposed nuclear waste storage and disposal on their traditional lands.
in Bill. Then Premier of SA Jay Weatherill (Oct 2017) argued for recognition of an Aboriginal People’s
‘right of veto’ over proposed nuclear waste storage and disposal on their traditional lands.
****This flawed Federal gov. process has also divided and damaged the Kimba agricultural community
and presents a reputational and material impact risk to their livelihood and community cohesion
and presents a reputational and material impact risk to their livelihood and community cohesion
***
Overall these matters cut to the core of SA public interests at stake in a draconian Federal agenda.
***
Co-location of an above ground Nuclear Store alongside a Low-Level Waste Disposal Facility may fail.
***
The regulator ARPANSA has said it expects separate Licence Applications for the above ground
Nuclear Store and for the Low-Level Waste Disposal Facility. The Federal gov. must not pre-empt nor
take for granted the outcome of this separate ARPANSA Licensing process for a Nuclear Store in SA.
Nuclear Store and for the Low-Level Waste Disposal Facility. The Federal gov. must not pre-empt nor
take for granted the outcome of this separate ARPANSA Licensing process for a Nuclear Store in SA.
****
The Nuclear Store in SA is unnecessary given ANSTO capacity for Extended Storage at Lucas Heights.
My background experience is relevant: as an Australian Conservation Foundation (ACF) campaigner
based in Adelaide over 1996 to 2011, including 5 years on the prior Federal attempt to impose a nuclear waste facility in SA (over 1998 to 2004) – another flawed process that had to be abandoned.
based in Adelaide over 1996 to 2011, including 5 years on the prior Federal attempt to impose a nuclear waste facility in SA (over 1998 to 2004) – another flawed process that had to be abandoned.
***
I was also a Witness as an individual on nuclear waste issues at a Hearing of the SA Parliament Joint
Committee Inquiry on the Findings of the Nuclear Royal Commission, held in 2016.
Committee Inquiry on the Findings of the Nuclear Royal Commission, held in 2016.
***
I have made submissions to the Minister on Nuclear Waste Store issues (May 2017 – Attachment 5, &
Nov 2018), provided a range of Briefing materials (see Attach’s 1 & 2), and given media comments.
Please feel free to contact regarding any aspect of this public submission, by Mobile, Text or E-Mail.
Yours sincerely
Mr David J Noonan B.Sc., M.Env.St.
Independent Environment Campaigner
Nov 2018), provided a range of Briefing materials (see Attach’s 1 & 2), and given media comments.
Please feel free to contact regarding any aspect of this public submission, by Mobile, Text or E-Mail.
Yours sincerely
Mr David J Noonan B.Sc., M.Env.St.
Independent Environment Campaigner
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