Ivan Quail says -No logic in double handling of nuclear waste, and makes 14 strong recommendations
There is no logic behind the proposal to move intermediate-level waste from interim above-ground storage at Lucas Heights to interim above-ground storage at the Kimba site. The proposed double-handling is illogical, it exposes communities to unnecessary risk, and ARPANSA’s Nuclear Safety Committee says it
breaches international best practice
It should further be borne in mind that we in Australia currently enjoy an international
reputation for clean green agricultural products and food. Are we prepared to put that at risk?
Ivan Quail to Senate Committee on National Radioactive Waste Management Amendment (Site Specification, Community Fund and Other Measures) Bill 2020 [Provisions] Submission 12
Intermediate level radioactive waste should not be stored above ground. Low- and intermediate-level radioactive wastes are buried in geological repositories. These repositories must isolate the nuclear waste from the biosphere for as long as 100,000 years. Only solid wastes are stored; liquid wastes are solidified by cementation or bitumen. The strategy adopted by many countries for the disposal of low and intermediate level radioactive wastes requires an engineered repository placed at considerable depth underground.
https://www.sciencedirect.com/topics/chemistry/intermediate-level-radioactive-waste
The National Radioactive Waste Management Amendment Bill amends the National Radioactive Waste Management Act to specify a site near Kimba in South Australia for a nuclear waste ‘facility’ ‒ a repository for low-level waste and an above-ground ‘interim’ store for long-lived intermediate-level waste.
Moving Intermediate level waste from above ground temporary storage at Lucas heights to another above ground storage does not solve the problem. It only moves it around. Furthermore, if the waste contains Uranium, Thorium or Radium (which it almost certainly does) it will inevitably decay into Radon gas…………
Radioactive Waste Repository & Store for Australia
Long-lived intermediate-level (category S) wastes will be stored above ground in an engineered facility designed to hold them secure for an extended period and to shield their radiation until a geological repository is eventually justified and established, or alternative arrangements made.
Long-lived intermediate-level (category S) wastes will be stored above ground in an engineered facility designed to hold them secure for an extended period and to shield their radiation until a geological repository is eventually justified and established, or alternative arrangements made.
Hydro power dams have a design life of 125 years. Does “secure for an extended period” mean 100,000 years? If so let them prove it. Does “eventually justified” mean on a $ and cents basis? This material is highly carcinogenic and could cause 100’s of thousands of cancers for a very long time. Once it escapes into the biosphere the genie is out of the bottle and it cannot be recovered.
Burden of disease
Between 1982 and 2010, the number of new cancer cases in Australia more than
doubled (from 47,388 to 116,580 cases).1
In 2012, cancer was estimated to be the leading cause of burden of disease in Australia,
accounting for approximately 19 per cent of the total disease burden.3
Cancer and other neoplasms $3,000 million (In 2013–14,)
Source: AIHW disease expenditure
Australian Institute of Health and Welfare 2016. Australia’s health 2016. Australia’s health series
no. 15. Cat. no. AUS 199. Canberra: AIHW
https://www.aihw.gov.au/getmedia/3be568f2-d938-4575-bf1f-8742bad4d2ce/ah16-2-2-howmuch-
does-australia-spend-on-health-care.pdf.aspx
doubled (from 47,388 to 116,580 cases).1
In 2012, cancer was estimated to be the leading cause of burden of disease in Australia,
accounting for approximately 19 per cent of the total disease burden.3
Cancer and other neoplasms $3,000 million (In 2013–14,)
Source: AIHW disease expenditure
Australian Institute of Health and Welfare 2016. Australia’s health 2016. Australia’s health series
no. 15. Cat. no. AUS 199. Canberra: AIHW
https://www.aihw.gov.au/getmedia/3be568f2-d938-4575-bf1f-8742bad4d2ce/ah16-2-2-howmuch-
does-australia-spend-on-health-care.pdf.aspx
The proposed nuclear waste facility is illegal under South Australia’s Nuclear Waste Facility
(Prohibition) Act, introduced by the SA Liberal Government in the year 2000 and
strengthened by the SA Labor Government in 2002. The federal government is expected to
take the draconian and unacceptable step of using regulations to specifically override the SA
Nuclear Waste Facility (Prohibition) Act. South Australians are opposed to the proposed
nuclear waste facility: a 2015 survey found just 15.7% support for a nuclear waste dump, and
a 2018 survey found that those who strongly agreed with stopping the dump outnumbered
those who strongly disagreed by a factor of three (41:14).
(Prohibition) Act, introduced by the SA Liberal Government in the year 2000 and
strengthened by the SA Labor Government in 2002. The federal government is expected to
take the draconian and unacceptable step of using regulations to specifically override the SA
Nuclear Waste Facility (Prohibition) Act. South Australians are opposed to the proposed
nuclear waste facility: a 2015 survey found just 15.7% support for a nuclear waste dump, and
a 2018 survey found that those who strongly agreed with stopping the dump outnumbered
those who strongly disagreed by a factor of three (41:14).
Only 4.5% of South Australia is arable land. It is of deep concern that a radioactive waste
could be allowed to jeopardise the Eyre Peninsula’s agricultural industries. Indeed the
government’s proposal is a clear breach of the National Health and Medical Research
Council’s ‘Code of Practice for Near-Surface Disposal of Radioactive Waste in Australia’
which states that “the site for the facility should be located in a region which has no known
significant natural resources, including potentially valuable mineral deposits, and which has
little or no potential for agriculture or outdoor recreational use”
could be allowed to jeopardise the Eyre Peninsula’s agricultural industries. Indeed the
government’s proposal is a clear breach of the National Health and Medical Research
Council’s ‘Code of Practice for Near-Surface Disposal of Radioactive Waste in Australia’
which states that “the site for the facility should be located in a region which has no known
significant natural resources, including potentially valuable mineral deposits, and which has
little or no potential for agriculture or outdoor recreational use”
Measured by radioactivity, long-lived intermediate-level waste currently stored at ANSTO’s
Lucas Heights site in NSW accounts for an overwhelming majority (>90%) of the waste
destined for the nuclear waste facility in SA. There is no logic behind the proposal to move intermediate-level waste from interim above-ground storage at Lucas Heights to interim above-ground storage at the Kimba site. The proposed double-handling is illogical, it exposes communities to unnecessary risk, and ARPANSA’s Nuclear Safety Committee says it
breaches international best practice
Lucas Heights site in NSW accounts for an overwhelming majority (>90%) of the waste
destined for the nuclear waste facility in SA. There is no logic behind the proposal to move intermediate-level waste from interim above-ground storage at Lucas Heights to interim above-ground storage at the Kimba site. The proposed double-handling is illogical, it exposes communities to unnecessary risk, and ARPANSA’s Nuclear Safety Committee says it
breaches international best practice
There is no consent whatsoever from Barngarla Traditional Owners let alone free, prior and
informed consent. The National Radioactive Waste Management Amendment Act
systematically disempowers and dispossesses Traditional Owners, and the Amendment Bill
worsens the situation. 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.
informed consent. The National Radioactive Waste Management Amendment Act
systematically disempowers and dispossesses Traditional Owners, and the Amendment Bill
worsens the situation. 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.
Recommendations:
1. The Senate Economics Legislation Committee should recommend the withdrawal or
rejection of the National Radioactive Waste Management Amendment Bill 2020 (in which
case a number of following recommendations are redundant) and repeal of the National
Radioactive Waste Management Amendment Act.
1. The Senate Economics Legislation Committee should recommend the withdrawal or
rejection of the National Radioactive Waste Management Amendment Bill 2020 (in which
case a number of following recommendations are redundant) and repeal of the National
Radioactive Waste Management Amendment Act.
2. The Committee should recommend repeal of the NRWM Act 2012 Section 12(1)(c) &
13(1), and of the Bill’s sections 34GA(1)(c) and 34GB(1), as unacceptable draconian
overrides of existing State and Commonwealth legal protections for Indigenous people’s
heritage and traditions.
13(1), and of the Bill’s sections 34GA(1)(c) and 34GB(1), as unacceptable draconian
overrides of existing State and Commonwealth legal protections for Indigenous people’s
heritage and traditions.
3. The Committee should undertake a review of the potential impacts of the existing Act, the
proposed amendments, and the proposed nuclear waste facility, on Aboriginal rights, interests
and traditions. This should include consideration of the impacts of the government potentially
issuing a Regulation to override the SA Aboriginal Heritage Act 1988, so as to legally impose
the nuclear waste facility over State law.
proposed amendments, and the proposed nuclear waste facility, on Aboriginal rights, interests
and traditions. This should include consideration of the impacts of the government potentially
issuing a Regulation to override the SA Aboriginal Heritage Act 1988, so as to legally impose
the nuclear waste facility over State law.
4. The Committee should assess the compatibility of the Act, the Bill and the proposed
nuclear waste facility with the UN Declaration on the Rights of Indigenous Peoples, in
particular the principle of free, prior and informed consent.
particular the principle of free, prior and informed consent.
5. The Committee should recommend that the federal government adopt the proposal from
then SA Premier Jay Weatherill in 2017 that traditional owners should have a right of veto
over any proposed nuclear waste facility on their lands. Mr. Weatherill’s letter noted that
“Aboriginal people’s history with the nuclear industry demonstrates a need for significant
healing” and it noted the SA Labor Government’s policy that a right of veto would apply to
any comparable state initiative.
then SA Premier Jay Weatherill in 2017 that traditional owners should have a right of veto
over any proposed nuclear waste facility on their lands. Mr. Weatherill’s letter noted that
“Aboriginal people’s history with the nuclear industry demonstrates a need for significant
healing” and it noted the SA Labor Government’s policy that a right of veto would apply to
any comparable state initiative.
6. The Committee should investigate the government’s plan to move intermediate-level waste
from above-ground interim storage at ANSTO’s Lucas Heights site to above-ground interim
storage near Kimba, for no logical reason and despite the obvious inefficiencies and risks
associated with this double-handling of nuclear waste.
from above-ground interim storage at ANSTO’s Lucas Heights site to above-ground interim
storage near Kimba, for no logical reason and despite the obvious inefficiencies and risks
associated with this double-handling of nuclear waste.
7. The Committee should seek advice from the regulator ARPANSA as to whether the
proposed double-handling of intermediate-level waste is consistent with national and
international standards and what ARPANSA’s approach will be to a licence application that
proposes double-handling.
proposed double-handling of intermediate-level waste is consistent with national and
international standards and what ARPANSA’s approach will be to a licence application that
proposes double-handling.
8. Given that the government has consistently failed to provide any logical justification for
double-handling of intermediate-level waste, the Committee should recommend that
intermediate-level waste stored at ANSTO’s Lucas Heights site should remain there until a
long-term solution is realised.
double-handling of intermediate-level waste, the Committee should recommend that
intermediate-level waste stored at ANSTO’s Lucas Heights site should remain there until a
long-term solution is realised.
9. The Committee should recommend withdrawal or rejection of the Bill on the grounds that
the government’s own benchmark for broad community support has not been met (43.8%
support among eligible voters in the combined ballots).
the government’s own benchmark for broad community support has not been met (43.8%
support among eligible voters in the combined ballots).
10. The Committee should recommend that the Bill is withdrawn, and the federal
government’s nuclear waste agenda put on hold, until such time as public opinion among
other relevant stakeholders is determined (including state-wide opinion in SA; and opinion
along potential transport corridors).
government’s nuclear waste agenda put on hold, until such time as public opinion among
other relevant stakeholders is determined (including state-wide opinion in SA; and opinion
along potential transport corridors).
11. The Committee should recommend repeal of section 13(1)(b) of the Act, and withdrawal
or rejection of section 34GB (1)(b) of the Bill, both of which seek to compromise and
undermine operation of the Environment Protection and Biodiversity Conservation Act 1999.
or rejection of section 34GB (1)(b) of the Bill, both of which seek to compromise and
undermine operation of the Environment Protection and Biodiversity Conservation Act 1999.
12. The Committee should seek independent expert advice regarding the Federal
Government’s claim that 45 jobs will be created at the facility. That job figure is deeply
inconsistent with comparable facilities overseas and it assumes that Australian workers are at
least 10 times less productive than workers at comparable facilities overseas. Successive
federal governments have claimed there would be zero, six or 15 jobs, and the current figure
of 45 jobs is implausible.
Government’s claim that 45 jobs will be created at the facility. That job figure is deeply
inconsistent with comparable facilities overseas and it assumes that Australian workers are at
least 10 times less productive than workers at comparable facilities overseas. Successive
federal governments have claimed there would be zero, six or 15 jobs, and the current figure
of 45 jobs is implausible.
13. My proposal above will require no extra personnel to monitor and mange the storage of
low or intermediate level waste thus reducing the operating cost and minimizing the creation
of potential jobs and costs in the health care system. Not to mention the pain and suffering
caused to cancer patients and their families.
low or intermediate level waste thus reducing the operating cost and minimizing the creation
of potential jobs and costs in the health care system. Not to mention the pain and suffering
caused to cancer patients and their families.
14. It should further be borne in mind that we in Australia currently enjoy an international
reputation for clean green agricultural products and food. Are we prepared to put that at risk?
reputation for clean green agricultural products and food. Are we prepared to put that at risk?
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