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Medical Association for Prevention of War recommends that Australia keep its nuclear prohibitions.

Environment and Other Legislation Amendment (Removing Nuclear Energy Prohibitions) Bill 2022
Submission 28

The Medical Association for Prevention of War (Australia) is an association of medical and
other health professionals who work for the elimination of all weapons of mass destruction
and the prevention of armed conflict. Nuclear weapons abolition is our primary focus. We
promote peace through research, advocacy and education. MAPW is affiliated with IPPNW,
the International Physicians for the Prevention of Nuclear War (Nobel Peace Prize 1985),
and was the founder of ICAN, the International Campaign to Abolish Nuclear Weapons
(Nobel Peace Prize 2017).
Principal author: Dr Sue Wareham OAM
President, MAPW Australia

The existing legal prohibitions against nuclear power for Australia should remain.
 Australia should not acquire naval nuclear reactors, and legislated prohibitions on nuclear energy should not be compromised to allow for the acquisition of naval nuclear reactors. Their proposed acquisition should be separately and publicly scrutinised with regard to the Nuclear Energy Prohibitions Bill, and to longstandingpublic opposition to nuclear energy.
 Australia must sign and ratify the Treaty on the Prohibition of Nuclear Weapons.

Climate change is already having devastating ecological and health consequences, with worse to come. It demands urgent responses to transform global energy production to zerocarbon emissions. Nuclear power proponents, including those associated with uranium mining interests, have again called for the consideration of nuclear power for Australia as part of this response. Their calls paint an idealised and simplistic picture of an industry
which has a long list of mostly insurmountable problems.

 is inextricably linked with producing the world’s worst weapons,
 is carbon-intensive in nearly all stages of its operation,
 produces intractable highly toxic waste which remains a global problem,
 is far too slow to implement, even as part of a response to climate change,
 is vulnerable to disastrous accidents and sabotage,
 requires huge amounts of our most precious resource – water,
 has major health implications for populations living near its facilities,
 Is prohibitively expensive,
 Is unnecessary, given the rapid expansion of renewable energy sources.

Nuclear power is a time-wasting distraction from the real work of tackling climate change, when we don’t have such time to waste.
This submission will examine most of the above problems, but will first address the current context of this inquiry, specifically the government’s deliberations on naval nuclear power for Australia. This is highly relevant for two reasons.

Firstly, the nuclear reactors on board nuclear submarines share nearly all of the problems of reactors on land, as listed above.
Naval nuclear power should in no way provide a foothold for the nuclear industry in Australia.
Secondly, it is unclear how the current prohibitions on nuclear power in Australia – prohibitions which would extend to naval reactors – will be managed if the naval nuclear power proposal proceeds. There is grave risk that they will be weakened in order to pave the way for technology which has been consistently rejected by a majority of Australians.


MAPW opposes naval nuclear power. One of our concerns is that the increased nuclear technology the submarines would require here would be a very significant foot in the door for the adoption of civilian nuclear power with all its attendant problems.

Long before the naval nuclear power decision was announced in September 2021, the question had arisen as to how much nuclear technology would be required in Australia to sustain it. In addition to unofficial commentary, then Defence Minister Marise Payne
commented in June 2017, in rejecting former Prime Minister Abbott’s suggestion of naval nuclear power, that developing the domestic capacity to service naval nuclear power would take “far longer than a decade” and that in the short term there were significant disadvantages.

In more recent times, official statements on this have at best created confusion, and at
worst, indicated an opaque process that has marginalised the Australian people. For
example, the Australian Strategic Policy Institute (ASPI) reported in September 2021, after
the AUKUS announcement, that in a White House briefing two unnamed senior US officials
said ‘Australia does not have a nuclear domestic infrastructure. They’ve made a major
commitment to go in this direction’. What commitment has been made, by whom, when,
and on behalf of whom? Certainly not on behalf of the Australian people.

However, in November 2021 then Foreign Minister Marise Payne assured south-east Asian
neighbours that Australia will not adopt nuclear weapons or a civil nuclear industry. As at
least the latter of those promises appears to be of little value, it would be surprising if the
other were not also regarded with caution by neighbouring and other countries.

In June 2022, in a meeting in Australia with US Senate Foreign Relations Committee staff
members, to discuss topics including “workforce development and training requirements to
support Australia’s acquisition of nuclear-powered submarines”, Vice-Admiral Jonathan
Mead, who is the head of Australia’s nuclear-powered submarine taskforce, said he believes
that Australia must give ‘an unwavering commitment to safely and securely stewarding
nuclear propulsion technology “from cradle to grave” ’ (emphasis added). How much
nuclear workforce development and training is envisaged for Australia? At what point does
nuclear stewardship for submarines become an easy slide to nuclear power for civilian
purposes? At the very least, given the responsibility to indeed take care of the “grave” end
of the nuclear fuel chain, where is the discussion of what will happen to the waste from the
nuclear submarine reactors? There appears to be none.

Concerns regarding a possible drift from nuclear power for submarines to nuclear power for
civilian purposes were further justified in August 2022 when UK Secretary for International
Trade Anne-Marie Trevelyan said, in relation to the submarines, “As the development of
nuclear skills across Australia grows, things like SMRs [Small Modular Reactors] could
become part of Australia’s mix. There is a really big agenda there around clean energy”. As
referenced in the Introduction above, the Minerals Council of Australia has also claimed
‘Now that Australia is acquiring nuclear submarines which use small reactors, there is no
reason why Australia should not be considering SMRs for civilian use’, citing oft-claimed but
mythical attributes of nuclear power.

When in opposition Labor gave conditional support to the naval nuclear power proposal.
The first pre-condition was that there be no requirement for a domestic civil nuclear
industry, and Labor vowed to hold the then government to its promises not to set one up.
Then shadow Foreign Minister Wong also referred to the need for Australian sovereignty in
decisions relating to the submarines. Given that Australian sovereignty would demand
significantly expanded domestic nuclear technology, how does the Labor government intend to remain true to its commitment to no domestic nuclear power (if naval nuclear powereventuates)?

An obvious way is through upholding legislation, the very legislation to which the Removing
Nuclear Energy Prohibitions Bill refers and which already prohibits nuclear power in
Australia. The prohibitions should not be weakened in any way.

Secrecy in nuclear matters
The AUKUS and nuclear submarine issues have unfortunately strengthened the secrecy that
has long characterised the nuclear industry, beginning with the appallingly secretive manner
in which the decisions were made in 2021.

Before the May 2022 election, Labor asked for details as to how then PM Morrison chose
the locations of Brisbane, Newcastle and Wollongong’s Port Kembla as contenders to host a
nuclear submarine base. Guardian Australia applied to the Department of Defence under
freedom of information laws seeking the site analysis, and for any advice etc prepared for
then Defence Minister Dutton regarding the preferred locations. All this was denied. In
other words, residents of at least three Australian cities have been simply told that they
might have a nuclear reactor in their port and they have no access to the reasons their cities
were chosen. This cannot simply be attributed to pre-election politics. The nuclear industry
has operated with false promises (beginning with ‘too cheap to meter’ in the 1950s), totally
inadequate regulation (see for example here), and lack of consultation. In the UK, no
information regarding naval nuclear accidents has been made publicly available since 2017,
even though such accidents are a public health matter. There is no reason to believe that
things would be transparent, even in the civilian sphere, if Australia were to develop civilian
nuclear power.

There are clear historical links between the nuclear industry and nuclear weapons
proliferation. Civil nuclear power generation goes a long way to providing a nuclear
weapons capability. Proposals for Australia to acquire nuclear power – when we have other
cheaper and less risky energy options – have the serious potential to raise questions
elsewhere as to our motives, which may in turn fuel nuclear weapons proliferation. Then
Prime Minister John Gorton had plans for nuclear power in the late 1960s, and later
admitted ‘We were interested in this thing because it could provide electricity to everybody
and it could, if you decided later on, it could make an atomic bomb’1.

Nuclear power generally uses enriched uranium as the fuel. Any uranium enrichment plant
can be used to produce not only reactor-grade uranium but also weapons-grade uranium
(highly enriched uranium, HEU). Plutonium, also used as nuclear weapons fuel, is produced
in reactors and can be chemically extracted from the spent fuel (via reprocessing). Thus the production of nuclear power provides two possible routes to nuclear weapons. All nuclear
armed states have used facilities and/or fuel that were ostensibly for peaceful purposes for
their weapons programs.

In the US, a 2019 report from the Atlantic Council titled ‘The value of the US nuclear power
complex to US national security’ stated that ‘civilian nuclear power and the associated
supply chain are interwoven with key US national security priorities, specifically US
leadership in global nuclear non-proliferation norms, the support of the nuclear navy, and
the nation’s nuclear deterrent’.

Also in 2019, a report by the German Institute for Economic Research (DIW) concluded that
all nuclear energy production ‘harbors the high risk of proliferation’. Its survey of the 674
nuclear power plants built between 1951 and 2017 showed that military interests rather
than economic interests have been the driving force within the industry. It also notably
concluded that ‘nuclear energy is not a relevant option for supplying economical, climatefriendly,
and sustainable energy in the future’.

Drawing on the DIW findings, IPPNW authors wrote a report, ‘How Nuclear Power Powers
the Bomb’, which stated that:

Without a “robust” civil nuclear industry and the associated nuclear infrastructure,
nuclear weapons programmes would not be sustainable due to the high costs, risks
and need for trained personnel.
 In all nuclear weapon states, the military utilizes the civilian nuclear industry through
hidden subsidies regarding human resources, research funds and investments in
dual-use nuclear infrastructure.

None of this means that nuclear power for Australia would necessarily lead to us having
nuclear weapons. But it does mean that we would far more readily have the capacity to
develop them if we chose to. This capacity would raise concerns within our region and
almost certainly pressure in some instances for our neighbours to develop the same

Nuclear weapons abolition, which is on a par with climate action as the world’s most urgent
security imperatives, is rendered much harder in a nuclear powered world.

Naval nuclear power for Australia and nuclear weapons proliferation
Given the evidence cited above of the strong links between nuclear power and nuclear
weapons establishments, it is important to note the impacts that even the use of nuclear
technology for the navy in Australia could have on nuclear weapons proliferation globally.

The nuclear submarine announcement in September 2021 elicited rapid and strong
condemnation from around the world (see for example here, here and here). If Australia
proceeds with the submarines we would set a precedent by becoming the first state to take
advantage of a “loophole” in comprehensive safeguards agreements that permits nuclear
material for a non-explosive military purpose to be removed from safeguards.

Tariq Rauf, who was head of verification and security policy coordination at the IAEA, and
others, state that this could well open a Pandora’s box of proliferation, with states such as
Argentina, Brazil, Canada, Iran, Japan, Saudi Arabia and South Korea also pursuing nuclearpowered
submarines and keeping nuclear fuel outside the scope of IAEA safeguards.

Countries in our region have expressed concern about the nuclear submarine proposal. The
Malaysian Prime Minister Ismail Sabri Yaakob has expressed alarm about the possibility of a
nuclear arms race in the region and nations acting more aggressively, stating that if, for
example, China wanted to help North Korea to buy nuclear-propelled submarines ‘we can’t
say no because AUKUS has set a precedent’. At the Nuclear Non-Proliferation Treaty Review
Conference that was held in August 2022 (postponed from 2020), Indonesia submitted a
Working paper titled ‘Nuclear naval propulsion’, which expressed significant concerns
relating to nuclear weapons proliferation, safety, environmental and humanitarian risks.
The document stated that the sharing of nuclear technologies and materials for military
purposes ‘could run counter to the spirit and objectives of the NPT’, set a precedent and
‘complicate safeguards mechanisms’.

Any policy that ignores how nations outside our own sphere of friendships might react is
irresponsible and dangerous. MAPW believes that naval nuclear power, like civilian nuclear
power, carries an unacceptable nuclear weapons proliferation risk.

Treaty on the Prohibition of Nuclear Weapons
Regardless of what Australia decides in relation to nuclear power, civilian or naval, the single
best way that we could promote not only nuclear weapons non-proliferation but their
abolition, would be to sign and ratify the 2017 Treaty on the Prohibition of Nuclear
Weapons. This would leave no doubt about our short, medium and long term commitment
to a nuclear weapons free world, and would be a powerful example to set for other nations
that – like us – hypocritically claim that we need a ‘nuclear umbrella’ to ‘protect’ us.

While much has been made by nuclear power advocates of the newer Small Modular
Reactors (SMRs), these reactors have not yet been commercialised; they are yet another
promise from a failing industry. The IPPNW report cited above concluded that it is the
modernisation of nuclear arsenals in nuclear armed states that is driving the development
of SMRs, stating that ‘Although allegedly intended for civilian use, SMRs are used primarily
for military purposes, in particular for the propulsion of nuclear submarines, which have become the most important component of the nuclear weapons doctrines of the major
nuclear powers’.

In common with other reactors, SMRs share the problems of being far too costly, too slow,
and creating high level waste that lasts thousands of years. They also produce more
expensive energy than larger scale reactors (which are already not cost competitive with

Contrary to claims often made, the nuclear fuel chain generates very significant carbon
emissions. A 2019 report from the Climate Council stated: “Unlike coal and gas, no
greenhouse gas pollution is created in the operation of the nuclear reactor. However, all
other steps involved in producing nuclear power (from mining, to construction,
decommissioning and waste management) result in greenhouse gas pollution. Greenhouse
gas pollution associated with nuclear power could be similar to a gas power station…’

Despite 70 years of research and many optimistic promises, the question of what to do with
nuclear waste remains an unsolved problem. Globally there are no functioning long term
disposal facilities for high level waste (HLW).

It is worth noting the difficulties the Federal government has faced for over two decades
(and continues to face) in finding a location for our relatively small amount of long lived
intermediate level waste (ILW). Current proposals are deeply flawed, contested and well
below international best practice. The process has divided communities and created
enormous distress. The misinformation provided by the government has been highly
problematic. Opposition to any nuclear reactor is likely to be much greater.

On the first anniversary of the AUKUS announcement, Defence Minister Marles said that the
government will be providing answers to five questions in relation to the nuclear
submarines: the final design, when they can be acquired, what capability gap the timeline
will create and solutions to plug it, the cost, and how Australia’s plans comply with nuclear
non-proliferation obligations. He did not mention the nuclear waste from the submarines –
another problem for future generations perhaps.

Nuclear power is far too slow as even part of the response to the accelerating climate crisis.
The International Atomic Energy Agency (IAEA), whose primary purpose is the promotion of
the peaceful uses of nuclear energy, publishes guidelines titled ‘Establishing the Safety

Infrastructure for a Nuclear Power Program’. They include the following regarding

‘1.2. A considerable period of time is needed to acquire the necessary competences
and to foster a strong safety culture before constructing and operating a nuclear
power plant….Establishing a sustainable safety infrastructure is a long process, and it
has been internationally acknowledged that a period of 10–15 years under optimum
conditions is generally necessary between the consideration of nuclear power as part
of the national energy strategy and the commencement of operation of the first
nuclear power plant.’

The key words are ‘10-15 years under optimum conditions’. Those conditions would include
very strong political and community support, which is lacking in Australia. At present there
is no political consensus around nuclear power and opinion polls repeatedly suggest the
electorate is likely to be resistant in the short to medium term at the very least. Therefore a
timeframe of two decades is probably more likely if Australia were to proceed with nuclear

Even in countries where there is already an established nuclear industry, there are cost and
timing blow-outs. For example in the UK, the Hinkley Point C station which is the country’s
first new nuclear plant in decades, is running 10 years behind schedule and is expected to
cost at least A$45 billion, nearly 50% more than initially expected. It will require huge
government subsidies.

Nuclear power for Australia, including from SMRs, would result in major delays in emissions
reduction, resulting in greater climate disruption.

Much has been written on the problem of nuclear accidents, and this submission will make
only a very few comments. Although the best known and worst such accidents were
Windscale, Chernobyl, Three Mile Island and Fukushima, there have been at least fifteen
accidents involving fuel or reactor core damage, with substantial risk of uncontrolled
radioactive release, in a variety of reactor types in Canada, Germany, Japan, Slovakia, the
United Kingdom, Ukraine and the United States. In addition there have been many nearmisses.
The public health impacts of radioactive contamination released in accidents are
outlined in the section ‘Radiation and Health’ (below).

Associate Professor Tilman Ruff has written extensively on the public health and other
impacts of the 2011 Fukushima disaster in Japan. He writes:
‘What happened in Fukushima because of poor design, governance failure and a
large earthquake and tsunami could equally happen because of commandos or
terrorists, especially with insider help, disrupting the power or cooling water supply
for reactors and/or spent fuel pools for long enough—only a matter of minutes—to
cause meltdown and/or explosions. Such an event could also occur because of
cyberattack, or as a result of electricity-supply and electronic-equipment failure….’

Such attacks or disruption ‘could cause severe and extensive radioactive contamination
requiring the long-term evacuation of large areas.’

At Fukushima, vast quantities of seawater were pumped onto the damaged reactors as
coolant. Over a decade later, there are still over a million tonnes of cooling wastewater,
most of it radioactive, which the Japanese government plans to dump into the Pacific

Nuclear submarine accidents
Like other naval vessels and crew, nuclear submarines and submariners are not immune
from human and technical error and therefore accidents. With a nuclear reactor on board
however, the risks are expanded to include radioactive contamination, affecting human
health and the environment. Like all nuclear accidents, such harm is extremely difficult to
quantify as it is greatly dispersed in space and time. Naval nuclear reactors in Australian
ports have the potential to cause the release of radioactivity in population centres. MAPW’s
Safety Brief on nuclear powered submarines summarises some of the issues that are
relevant for communities that host these vessels in their ports.

In total, nine nuclear powered submarines have sunk (from causes including fires, weapons
explosions, flooding and storm). In 2010 HMS Astute, ‘the world’s most advanced nuclear
submarine’, ran aground off the Isle of Skye. In October 2021, the US attack submarine USS
Connecticut was grounded while in the South China Sea.

Nuclear reactors are also vulnerable to deliberate attack. The most recent and potentially
most catastrophic are the attacks on the Zaporizhzhia plant in Ukraine, Europe’s largest
nuclear power facility, as part of Russia’s war on that country. The complex contains six
reactors and six spent fuel ponds, all of which contain vast quantities of radioactivity that, if
released, could spread over a huge area, far beyond Ukraine. At the time of writing, the
ultimate fate of the plant is still unknown.

Other attacks on nuclear facilities include:
 1979: Israeli agents’ bombing of research reactor components in France while they
were awaiting shipment to Iraq;
 1981: Israel’s airstrikes on a research reactor in Iraq;
 1980-88: attempted military strikes by Iraq and Iran on each other’s nuclear facilities
during the Iran-Iraq war;
 1991: Iraq’s attempted strikes on Israel’s nuclear facilities;
 1991: the US destruction of a research reactor in Iraq;
 2007: Israel’s bombing of a suspected nuclear reactor site in Syria.

Most of those attacks were directed at ‘research’ reactors capable of producing plutonium
for weapons. Most or all of them were driven by weapons proliferation fears, often
legitimate fears.


Ionising radiation2, such as that created by the nuclear power industry, has long been known
to cause damage to living cells. This includes damage to DNA molecules, which are our
genetic material.

The known cancer and other health effects of exposure to low dose ionising radiation are
authoritatively estimated by the Biological Effects of Ionising Radiation (BEIR) report from
the US National Academy of Sciences. BEIR VII in 2005 stated that ‘the risk of cancer
proceeds in a linear fashion at lower doses without a threshold and…the smallest dose has
the potential to cause a small increase in risk to humans’. In other words, there is no
exposure to ionising radiation that is risk-free.

Ionising radiation also increases the risk of occurrence and death from some non-cancer
diseases, including circulatory diseases such as heart attack and stroke. This has been clearly
demonstrated at moderate and high doses, and recent evidence has confirmed that
circulatory disease mortality also increase at low doses, such as those that occur in nuclear
industry workers.

There has been a consistent trend over time that the more we know about radiation effects,
the greater those effects appear to be. Maximum permitted radiation dose limits have
never been raised; they have only ever been lowered. From 1950 to 1991, the maximum
recommended whole-body radiation annual dose limits for radiation industry workers
declined from approximately 250 to the current limit of 20 mSv per annum. Even this limit
is not regarded as ‘safe’, but merely a compromise between, on the one hand, safety, and
on the other hand commercial and economic interests.

Childhood leukaemia near nuclear power plants
Apparent excesses of leukaemia occurring in children living near nuclear power plants have
caused concern and controversy over decades. The most prominent initial example was a
perceived excess of leukaemia and lymphoma cases around the Sellafield nuclear plant in
England in the 1980s. An investigation recommended by a government commissioned
committee found that the risks for leukaemia and lymphoma were higher in children born
within 5 km of Sellafield. In 2007, a meta-analysis supported by the US Department ofEnergy examined all of the reliable data available worldwide, confirming a statistically
significant increase in leukaemia for children living near nuclear power plants.

Further confirmation of this link came from a large national German study, which examined
leukaemia among children living near any of Germany’s 16 operating nuclear plants over a
25-year period. It showed that the risk of leukaemia more than doubled for children living
within 5 km of a nuclear plant, with elevated risk extending beyond 50 km from a plant.

Recent advances in low-dose radiation epidemiology are providing valuable new
information on disease risks from radiation sources such as medical imaging technologies
(CT and others), and nuclear power plant accidents.

By no means least (although often overlooked) in the list of reasons why nuclear power is
inappropriate, especially for Australia, is the fact that nuclear power plants require very
large amounts of water. This is needed both for conversion to steam to drive the turbine,
and for cooling of the reactor core and the spent fuel ponds. Water outflows from the plant
are relatively warm, and this can affect fish and other aquatic life when it is discharged back
to the body of water from which it came.

In France, where river water rather than the sea is often used to cool local reactors, the
nuclear industry is obliged by law to reduce electricity output during hot weather when
water temperatures rise, or when river levels and the flow rate are low. In the spring of
2022, warm temperatures, including in the rivers, threatened the output of some nuclear
power plants. However in the hot summer that followed, the country’s nuclear power
regulator issued temporary waivers allowing five power stations to continue discharging hot
water into rivers. Environmental concerns were sacrificed.

Australia is a hot, dry continent, prone to heatwaves and droughts (notwithstanding recent
and ongoing climate-exacerbated floods). Water is our most precious resource; it must not
be jeopardised further by technology that has additional risks for our particular geography and climate.


February 6, 2023 - Posted by | AUSTRALIA - NATIONAL, politics

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