Friends of the Earth Australia’s Submission to Environment Minister calls out the dishonesty in the proposal for a national nuclear waste dump at Kimba, South Australia
Provide reasons for why you believe this is/is not a controlled action.
As a significant “nuclear action” under the EPBC Act this Nuclear Radioactive Waste Management Facility (NRWMF) Referral is a “Controlled Action”.
IT REQUIRES A FULL ENVIRONMENTAL IMPACT ASSESSMENT / STATEMENT (EIA/EIS) AT THE HIGHEST LEVEL OF PUBLIC ASSESSMENT.
In a nuclear action “the whole environment” is the “Matter of National Environmental Significance” protected under the EPBC Act. An EIA/EIS is warranted to cover the scope of this protected matter.
The behaviour of the Morrison government and the Australian Radioactive Waste Agency (ARWA) in relation to the imposition of a national nuclear waste dump in SA has been disgraceful. If Minister Sussan Ley is minded to require anything less than a full EIA/EIS at the highest level of assessment, she should consider the following:
1. The new South Australian government is clearly opposed to the dump, primarily because of the crude racism of the Morrison’ government’s willingness to impose a dump on Barngarla country despite the unanimous opposition of Barngarla Traditional Owners. Expect a hardening of that opposition if anything less than a full EIA/EIS is required.
2. Media silence is far from guaranteed as evidenced by the extraordinary recent coverage in The Australian and The Advertiser ‒ both Murdoch publications ‒ regarding BHP’s mismanagement of the Olympic Dam mine and in particular its mistreatment of Traditional Owners:
https://www.theaustralian.com.au/business/mining-energy/dam-busters-aborigines-battle-bhp-over-water-rights/news-story/5771234ab2fca122009e83720ecbaf01
https://todayspaper.adelaidenow.com.au/infinity/article_popover_share.aspx?guid=23a5b7bd-e6d5-4a82-972e-347f65874b3a
And also widespread national and international media coverage of Rio Tinto’s crimes at Juukan Gorge.
3. Community opposition to the dump in South Australia is building. Expect it to build further if anything less than a full EIA/EIS is required.
Australian Radioactive Waste Agency (ARWA) is the ‘proponent’ in this NRWMF Referral, as a non-independent office of the Industry Department. The Environment Minister must not make a decision to approve and allow the nuclear dump to proceed on the inadequate limited basis of non-independent input by the proponent, or on the basis of anything less than a full EIA/EIS at the highest level of assessment.
A public impact assessment must be carried out under the Environmental Protection and Biodiversity Conservation Act ( EPBC Act). ARWA wants something less than a full EIA/EIS due to a separate ARPANSA licensing process, but the ARPANSA process covers different issues, under different legislation, and in no way could substitute for a full EIA/EIS under the EPBC Act. The ARPANS Act does not protect nor assess ‘the whole of environment’ protected matter involved here under the EPBC Act.
ARWA’s claim there is no alternative to the proposed dump is dishonest and Minister Ley is obliged to call out that dishonesty. Many alternatives are available. See for example the proposals in the paper online at:
https://nuclear.foe.org.au/wp-content/uploads/Responsible-Radioactive-Waste-Management-The-need-for-an-Inquiry-Final.pdf
In particular, the implicit claim that there is no alternative to ongoing storage of intermediate-level waste (ILW) at ANSTO is absurd and dishonest. Clearly ILW should remain at ANSTO because: a large majority of ILW is already stored there (well over 90 percent measured by radioactivity); Australia’s nuclear expertise is concentrated at ANSTO; security at ANSTO is vastly superior to that proposed at the Kimba dump site; it avoids unnecessary transportation; it avoids unnecessary double-handling given that the final disposal site for ILW will not be at Kimba (and could easily be in NSW or any state/territory).
The proposal to store ILW at Kimba is absurd and must be clearly rejected by Minister Ley.
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