Dan Monceaux’s Submission urges the Senate to keep Australia’s legal protections against the hazards of nuclear industrial facilities
Various nuclear industrial facilities are currently prohibited in Australia. These are prohibited for good reason:
they carry with them unique and problematic risks to people, the environment and the public purse.
The legislation in its current form protects the Australian people from harm from ionising radiation,
and our land, air and waters from radioactive contamination.
If there is a genuine need for any currently prohibited nuclear industrial development to occur in Australia, a case should be made openly to the Australian people prior to, not following, the repeal of these protections.
Environment and Other Legislation Amendment (Removing Nuclear Energy Prohibitions) Bill 2022 Submission 146.
My name is Dan Monceaux, I’m a lifelong resident of South Australia, and emerging documentary
filmmaker. Through my work on the forthcoming film Cuttlefish Country, I sought to understand
the nuclear history of South Australia, from the nuclear weapons tests at Maralinga to Emu Field, to
the scramble to find and develop uranium deposits in the 1940s and 1950s to fuel the nuclear arms
race of the Cold War. It included the establishment and abandonment of uranium processing plants
at Port Pirie and suburban Adelaide (Thebarton) and a handful of other uranium mines in my home
state. My interest in nuclear legacies, including costs borne by exposed people, communities and
the environment was piqued during this work, which led me to participate in the 2015-16 Nuclear
Fuel Cycle Royal Commission as a citizen journalist. I became the chief author for the
commission’s Wikipedia article, and have made significant contributions to many other Wikipedia
articles related to nuclear subjects, from transportation to legacy sites and workers’ compensation
programs, some of which I refer to in this submission.
During the Nuclear Fuel Cycle Royal Commission, I also established a Facebook discussion group
to follow and discuss the Commission’s work, which later evolved into Nuclear Fuel Cycle Watch
Australia. With roughly 500 members from around Australia, the group contains members of all
persuasions, from the curious to those staunchly pro or anti-nuclear. As a pre-text to this
submission, I wish to mention that pro-nuclear voices have typically been the most disruptive in the
group, including waves of apparently choreographed incursions from international origins, some of
whom openly admitted that they were there to disrupt, as members of a group called “Nuke
Warriors”. Once the group’s membership requirements were reset to permit Australian members
only, the discussion became less adversarial. Since changing the membership criteria, and enforcing
stricter rules on conduct, the majority of active members today are of anti-nuclear persuasion. In
response perhaps to realising their minority status, some of the active pro-nuclear members have
blocked other group members (their critics) which has distorted the discussion by allowing much of
their shared content to go unchallenged. I believe this to be a reasonable reflection of the interested
public on this issue: that members of the public engaged with nuclear issues are more likely to
oppose rather than support further nuclear industrial development.
As far as I know, the Nuclear Fuel Cycle Watch Australia group is unique in that it does not
promote a particular attitude of support or opposition to the nuclear industry. It has held true to its
original purpose: to serve as a place for exchange of information, critical analysis, discussion and
debate. Beyond my moderator’s role at NFCWA, I have personal views and I will share them
openly here and whenever asked. The views expressed in this submission are my own, and do not
reflect those of the membership of Nuclear Fuel Cycle Watch Australia.
IT STARTED WITH THE BOMB
The historic record shows that nuclear industry has from its genesis been coupled to military
interests. The development of the atomic bomb came first, with nuclear power generation a
secondary development in the application of nuclear fission. In my opinion, nuclear power was
politically useful in helping nuclear nations build and maintain both 1) a social license for their
nuclear estates and 2) the expertise to build, operate and maintain them. With the passage of time,
some of those estates have trended into decline (USA, UK, France), while perceived military
opponents have established or maintained their nuclear estates more affirmatively (Russia and
China). It is my belief that the push to enable nuclear industrial development in Australia is driven
by a fear that the strengthening nuclear estates of Russia and China could precipitate a shift in the
balance of power away from Anglo-American global domination.
Nuclear weapons remain the most destructive weapons ever created by humans, and I do not believe
that the so-called “nuclear deterrent” (aptly also referred to as M.A.D. or Mutually Assured
Destruction) has effectively prevented war or been a net-positive for humanity. My position
considers the worldwide distribution of fallout from nuclear weapons tests, and the contamination
of people, lands and the environment at every stage in the nuclear fuel chain.
The prospect of facing a nuclear winter, caused by a nuclear war, is an existential threat to life as we
know it on Earth. With the modernisation of nuclear arsenals, developments in hypersonic delivery
systems over the past decade, and advancements of artificial intelligence influencing military
technology, the threat of nuclear conflict is increasing. The Doomsday Clock, which is set by the
Bulletin of Atomic Scientists to indicate how close we are to obliterating ourselves, has the dial set
at a mere 100 seconds to midnight; the closest we have ever been to “the end”. An update is
imminent, and I’m not optimistic about the clock hands’ direction.
https://thebulletin.org/doomsday-clock/current-time/
LEGACY SITES & CONTAMINATION
A quick look at the USA’s list of Superfund contaminated sites shows what nuclear industrial
practise leaves in its wake. Among its listed properties around the USA are hundreds of abandoned
uranium mines, some uranium mining and milling sites, some sites managed by the Department of
Energy as part of the USA’s nuclear weapons research and development program (including some
that date back to the Manhattan Project), a nuclear waste repository called Maxey Flats where
plutonium was stored that leaked, and even legacy sites left by luminous clock dial painters which
used radioactive paint.
https://en.wikipedia.org/wiki/List_of_Superfund_sites
The short history of nuclear industrial development has shown that contamination and waste have
historically been afterthoughts, but with very costly consequences for contaminated people and
environments. This is true the world over. The most obvious local example is the Ranger uranium
mine in Australia, where the remediation cost is likely to fall between 1.4 and 2.2 billion Australian
dollars. The project ran for roughly forty years in the Australian tropics, but not without
environmental problems, including periodic concerns about the contamination of nearby waterways.
https://en.wikipedia.org/wiki/Ranger_Uranium_Mine
LOSSES OF LIFE AT AND NEAR NUCLEAR FACILITIES
A quick survey of incidents involving nuclear industrial facilities or their products that have lead to
losses of life includes nuclear fuel-fabricating or production facilities at Marcoule (France),
Kyshtym (USSR) and Tokaimura (Japan). Lives have been lost at nuclear power plants in Mihama
(Japan), Surry, Virginia (USA), Jaslovské Bohunice (Czechoslavakia) and Idaho Falls (USA).
https://en.wikipedia.org/wiki/Nuclear_and_radiation_accidents_and_incidents
More widely known are major accidents at power plants at Fukushima (Japan), Chernobyl (USSR)
and Three Mile Island (USA), though the extent of harm caused by the resulting plumes of
radioactive contamination from these “meltdowns” include conflicting projections of the number of
cancer developments and fatalities. In short, it is hard to prove that a particular cancer was
attributable to exposure to fallout, though fatalities did occur from thyroid cancer developments
following the Chernobyl disaster. Published estimates of numbers of fatalities occurring linked to
the Chernobyl disaster range from 4,000 to 60,000.
https://en.wikipedia.org/wiki/Effects_of_the_Chernobyl_disaster
WORKERS COMPENSATION PROGRAMS
Another important measure of the inherent risk when handling or being exposed to radioactive
materials comes via reports of nuclear industrial workers compensation programs. Figures are
available for programs in the USA and UK, while other countries programs either suffer for lack of
data (Japan) or secrecy measures (France). In the USA, the Federal government administers
compensation programs that have paid out approximately $2.6 billion USD (under the Radiation
Exposure Compensation Act) and over 40,000 claims which includes downwinders (people
impacted by nuclear weapons test fallout), onsite participants (people who worked on the weapons
tests who were exposed to fallout), uranium miners, millers and ore transport workers. Another
scheme called the Energy Employees Occupational Illness Compensation Program has paid out
over $22.6 billion USD and represents over 136,000 impacted workers. In the United Kingdom, the
Compensation Scheme for Radiation-linked Diseases has paid out 163 successful claims, to a total
sum of 8.9 million pounds.
https://en.wikipedia.org/wiki/Radiation_Exposure_Compensation_Act
https://en.wikipedia.org/wiki/Energy_Employees_Occupational_Illness_Compensation_Program
https://en.wikipedia.org/wiki/Compensation_scheme_for_radiation-linked_diseases
Given Australia’s abundance of renewable energy ready to be harnessed, surely no sane industrialist
would seriously consider constructing a new nuclear power plant, uranium enrichment, fuel
reprocessing or fuel fabriciation facility on Australian soil, if it were to be a purely commercial
proposition. Nor should Australia engage in establishing facilities for the servicing or production of
nuclear vessels or nuclear weapons programs if we are to encourage nuclear non-proliferation as a
pathway to peace.
If there is indeed, as history and probability suggest, one or more defence interests leading this push
to repeal prohibitions, it is worth considering that the military also has a poor track record when it
comes to environmental contamination. Many airforce, army and navy facilities appear on the
USA’s Superfund contaminated site lists, with a wide range of contaminants present in lands andwaters. In the Australian context, we have recently observed that defence facilities are among the
many nationally identified as having dangerous concentrations of PFAS, impacting soil and water,
and the Department of Defence has been criticised for its poor past practises in environmental
management and its sale of contaminated sites.
https://www.theguardian.com/australia-news/2018/may/24/contaminated-australian-defence-sitesput-spotlight-on-environmental-record
DECOMMISSIONING COSTS
Even where environmental and safety performance has been good, nuclear facilities are very costly
to decommission at the end of their working lives. It has been estimated by the United Kingdom’s
Audit Office that the decommissioning of the UK’s nuclear estate could cost 260 billion pounds.
The decommissioning of just one complex, Sellafield, is estimated to reach 67 billion pounds and is
not expected to to be complete until 2035.
https://www.prosperoevents.com/it-is-estimated-that-the-uks-nuclear-waste-cleanup-operationcould-cost-260-billion/#:~:text=Decommissioning%20a%20nuclear%20site%20can,take%20until
%202035%20to%20complete.
The USA’s Nuclear Regulatory Commission estimates that decommissioning costs for most nuclear
power plants will cost $300-400 million USD each.
https://www.nrc.gov/reading-rm/doc-collections/fact-sheets/decommissioning.html
CONSTRUCTION COSTS
The cost of building new nuclear power plants since the Fukushima disaster have also increased.
Emblematic of this is the Hinckley C project in the United Kingdom, which is now expected to cost
25-26 billion UK pounds to construct. In 2012, it was predicted to cost 16 billion. The project is
expected to take ten years in total to construct. There are also many nuclear power plant
developments that have been suspended or cancelled entirely. There are at least 84 such projects in
the USA alone spannig the history of the industry.
https://en.wikipedia.org/wiki/List_of_cancelled_nuclear_reactors_in_the_United_States
One example of this phenomenon is Clinch River, USA. The project was to be a so-called
“advanced” breeder reactor site, with an initial estimated cost of $400 million USD in 1971. Before
the project was ultimately cancelled in 1983, the cost estimate had increased to $8 billion USD;
twenty times the original projected cost.
https://en.wikipedia.org/wiki/Clinch_River_Nuclear_Site
INDUSTRIAL & MEDICAL FATAL EXPOSURES
Proponents of nuclear industry often point to medical uses of radiation to help bolster their social
license. Yet radiation from engineered sources is inherently dangerous, and some of the worst
radiological disasters have involved radiation sources from medical or other domestic industrial
equipment that have been poorly handled, managed and/or disposed of.
A worker in Brescia received a fatal dose from a Cobalt-60 source at a cereal irradiation facility.
Workers in Israel and Belarus overrode safety systems to clear stuck conveyors and received fatal
radiation doses at commercial irradiation facilities. In San Salvador, three workers at a medical
irradiation plant were exposed to a Cobalt-60 source; one died and another lost a limb.
Fatal overdoses were given to three patients by Canadian-designed Therac-25 radiation-therapy
machines due to poor programming. In Epinal, France, five people were killed and twenty-four
severely injured by receiving overdoses of radiation during therapy due to a software error. In
Zarazoga clinic, Spain, eleven patients received fatal overdoses with a radiotherapy device. In
Panama, 28 cancer patients were killed during a period of gross medical negligence by lethal doses
of radiation. In Indiana, USA, an Iridium-192 source “broke off” inside a patient during
brachytherapy and was in the patient for four days where it administered a fatal dose. In Rio de
Janeiro, a 7-year old girl was given a fatal series of radiation overdoses by negligent doctors and
technicians.
https://en.wikipedia.org/wiki/List_of_civilian_radiation_accidents
LOST RADIATION SOURCES
Radiation sources may be abandoned or disposed of improperly, thus creating a public health risk.
In Xinzhou, China a Cobalt-60 source was removed from a former environmental monitoring
station, contaminating over a hundred people and killing three. In Estonia, a thief stole a Caesium137 source which gave him a fatal radiation dose. In Samut Prakan, Thailand, a stolen Cobalt-60
source injured seven people and killed three. In Lia, Georgia, a lumberjack was killed by radiation
exposure after finding two Strontium-90 cores from radioisotope thermoelectric generators and
choosing to sleep beside them, using them as heaters.
In New Delhi, a man died after handling scrap metal containing Cobalt-60 from an incorrectly
disposed of medical source. Six others were hospitalised. In Goiania, Brazil, a Caesium-137 source
was salvaged from abandoned medical equipment and contaminated 250 people, of whom four
died. In the USA an unemployed radiation worker killed himself by intentional exposure, with the
source believed to have been a temporarily appropriated Iridium-192 source.
In Kramatorsk, Ukraine, a radiation source was found embedded in construction material of an
apartment. Prior to its discovery, six residents of the building had died from leukaemia. It is
believed to have been picked up by accident in a gravel building aggregate. Further incidents
involving lost radiation sources can be seen at the link below.
https://en.wikipedia.org/wiki/List_of_orphan_source_incident
SO WHY REPEAL SAFETY PRECAUTIONS?
So why repeal prohibitions that were clearly instated to protect Australians and the Australian
environment from nuclear weapons, nuclear hazards, radioactive pollution and escalating
militarisation? In my opinion, an argument as to why they should be repealed should precede the
movement of any bill that seeks to remove safeguards. Without providing a complete and honest
rationale, I can only assume that vested interests in allied military and civilian nuclear estates
(notably the UK and USA) are attempting to lead us in this direction. Such interests include those
seeking to arm Australia against an increasingly powerful China, as well as the many private
interests in the nuclear fuel chain who would design, build and maintain any new facilities should
they be constructed in Australia. This is a specialised field with a relatively small number of
companies eager to profit should Australia extend its participation in the nuclear fuel cycle beyond
its current reach: uranium mining in South Australia and Western Australia, and a single research
reactor at Lucas Heights. The objectives of these minority interests are not shared by the wider
Australian community and I caution the Senators who have sponsored this bill to represent the
interests of the many over the few.
The only way to mitigate the risks associated with Australia escalating regional tension by
expanding its own nuclear estate is to turn in the opposite direction. That requires following the lead
of the Nobel Peace Prize winning not-for-profit organisation, ICAN (International Campaign to
Abolish Nuclear Weapons). That organisation, founded here in Australia, actively and consistently
promotes and lobbies for global nuclear disarmament. Australia and other uranium mining nations
should also seek to phase out their production of fissile material. The risks presented by the
production, transformation, transportation, use and storage of radioactive materials are hazards
which humanity has struggled to contain since discovery, and they are unnecessary.
As the Climate Council reminds us: “nuclear power is the slowest, most expensive, most dangerous
and least flexible form of new power generation for Australia”. It is clear from the precedent set in
my own state of South Australia, that hybrid systems which combine various renewable energy and
energy storage technologies can lead states and territories to truly carbon-free electricity generation
and more resilient and reliable electricity supply. Nuclear power is not required to supply
Australia’s current or projected electricity needs. Nuclear weapons aren’t required to establish and
maintain peace.
https://www.climatecouncil.org.au/nuclear-power-stations-are-not-appropriate-for-australia-andprobably-never-will-be/
Containment remains a major problem and cost factor at every step of the nuclear fuel chain, from
radon gas inhalation and radioactive tailings management at mine sites, to long term storage of
spent, reprocessed nuclear fuel and other lower-level radioactive materials, which need to be
isolated and safeguarded for centuries. Australia should strive to support peace over war, health
over sickness and majority over minority interests by disassociating itself from nuclear power and
nuclear weapons and instead advocating for peace, harmony and renewable power generation and
storage technologies.
CONCLUSION
Out of my combined concerns for protecting human health, preventing environmental
contamination, protecting against costly “white elephants” and eliminating nuclear weapons, I wish
to express my disapproval of the proposed amendments to both the ARPANS Act 1998 and EPBC
Act 1999. The changes seek to allow the consideration and potential approval of various nuclear
industrial facilities that are currently prohibited in Australia. These are prohibited for good reason:
they carry with them unique and problematic risks to people, the environment and the public purse.
The legislation in its current form protects the Australian people from harm from ionising radiation,
and our land, air and waters from radioactive contamination.
If there is a genuine need for any currently prohibited nuclear industrial development to occur in
Australia, a case should be made openly to the Australian people prior to, not following, the repeal
of these protections. https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Environment_and_Communications/Nuclearprohibitions/Submissions
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