Antinuclear

The EPBC Act ‘Impact Assessment’ Report on Federal imposition of N-Subs fails to provide answers to community’s ‘Right to Know’ on nuclear risks facing Port Adelaide

Initial Brief by David Noonan Independent Environment Campaigner 8 Feb 2025.  Flawed ‘assessment’ of Osborne / Port Adelaide nuclear submarine site ignores accident risk (David Noonan, Feb. 2025)

The Federal Impact Assessment Report “SUBMARINE CONSTRUCTION YARD STRATEGIC ASSESSMENT
OSBORNE, SA” (IAR, 21 Jan 2025) clearly does is not intend to answer lead community concerns over
N-sub nuclear reactor accident risks and radioactive waste storage at Osborne, Port Adelaide.

A deluge of Federal Gov doc’s, a IAR of 200 pages with Appendices of 750 pages, are out for ‘public
consultation’. The proponent Australian Submarine Agency (see ASA web) are to run four Public
Information ‘Drop-In’ Sessions over 19 – 22th Feb. Public input is due in by cob the 17th March.

However, the Federal Gov has ruled a range of lead community concerns as “out of scope” of this
‘Strategic Assessment’, see IAR Section.6 Impact factors 6.16 Radiation (p.6-40 to 6-44).

The management facility for radioactive waste at Osborne, and the disposal pathway for such
radioactive waste, “is considered outside the scope of the Strategic Assessment” (p.6-41).

The IAR says: “Information on potential sources of radiation has been provided to inform, however
does not form part of the Strategic Assessment as these sources will be managed via separate
environmental assessment processes and approvals as necessary.”

The IAR Radioactive waste management section (p.3-19 to 3-21) says: “The facility is to be designed to
have the capacity to manage radioactive material over the 50-year Strategic Assessment timeframe.”
N-sub radioactive wastes may accumulate and stay ‘stored’ at Osborne for decades…

The IAR also mis-represents N-sub radioactive wastes to be stored at Osborne, as: “similar to those
that occur in over 100 locations nationwide, including hospitals, science facilities and universities” (3-
20), and “similar to the waste generated by hospitals and research facilities around Australia” (6-41).

Key health and safety issues are excluded from this EPBC Act public consultation. ASA (p.6-43) is to
conduct a separate ‘Environmental Radiological Assessment’ to license impacts at Osborne. The IAR
(at 6-44) says: “No nuclear actions are included within the Actions or Classes of Actions of the Plan.”

Impacts of commissioning and operation of the ‘power module’ (the nuclear reactor) “is considered
outside the scope of this assessment” (p.3-19 & 6-41) – to be held over for a military nuclear regulator.

The Federal Labor Gov are in denial over N-sub nuclear reactor accident risks. The word ‘accident’
does not even appear in this 200-page IAR. This is a multi-year Federal Gov failure to study and make
public required nuclear accident Emergency response measures and Evacuation plans at Osborne.

See a 2-page Briefer: “Labor imposes AUKUS nuclear submarines while failing to inform the affected
SA community of the health risks they face in a potential reactor accident” (29 July 2024).

Brief sub-heading: ‘SA Emergency workers may face “catastrophic conditions” at a N-Sub accident.’

It is disrespectful of the Federal Gov to continue to push N-sub accident risks onto community across
Lefevre Peninsula and Port Adelaide while only conducting partial impact assessments and limiting
‘public consultation’ to only those aspects that suit Labor’s roil out of the AUKUS N-sub agenda.

The Federal Gov are also now seriously misleading community and misrepresenting nuclear health
and safety risks, see IAR Effects of Radiation p.6-41 and Figure 34 potential health effects p.6-42.

SA State Gov ‘impact’ assessment for the Osborne Submarine Yard concludes ‘No
significant effects’ on community wellbeing, but fails to release nuclear accident studies:

The SA State Gov has released a “Submarine Construction Yard Environmental Impact Statement”
(EIS, Nov 2024, 427 pages, plus 22 x ‘Technical Report’ Appendices) for ‘consultation’ to 17 March. This EIS
process has a ‘YourSAy’ webpage, a Plan SA webpage, and a proponent’s Australian Naval
Infrastructure (ANI) page that promotes the three ASA ‘Drop-In’ Info Sessions over 19 to 22 Feb.

The EIS claims “there is no risk to people or the environment of radiation exposure” (EIS Summary p.9)
from ‘nuclear-powered propulsion systems’ on-site testing of N-sub nuclear reactors at Osborne.

The EIS Ch.23 ‘Social Impact Assessment’ concludes there are “No significant effects” on community
wellbeing (EIS Summary p.36-37), and no danger to people or property across an ‘immediately
impacted community’ who live or work in North Haven, Largs Bay and Semaphore; or in the ‘wider
community’ within Greater Adelaide who it is said ‘may feel some real or perceived broader impacts’.

These claims and concocted conclusions derive from an abject failure to recognise the effects and
impacts of a potential N-sub nuclear reactor accident, with required Evacuation Zone planning. The
word ‘evacuation’ appears 3 times in the 400-page EIS – all to do with flood risks not reactor risks

Why have key public safety accident studies still not been made public for N-subs at Port Adelaide?
Even a visit by a nuclear-powered submarine to a port in Australia requires Emergency response
planning that sets Evacuation Zones for potential nuclear reactor accidents (see a 2-p Briefer).

The SA Premier Hon Peter Malinauskas MP is effectively targeting Osborne Port Adelaide for N-sub
nuclear reactor accident risks, just as Opposition Leader Peter Dutton MP targets Port Augusta for
his nuclear power reactor accident risks and impacts: see David Noonan’s Public Submission No.261
(14 Nov 2024, 10 pages) to an ongoing Federal “Inquiry into nuclear power generation in Australia”

The EIS 4.12 Nuclear-powered propulsion systems and radiation exposure from accident (p.85-88)
says (p.85) that it has assessed: “the process to transport, receive, secure, store, install, test and
commission a nuclear-powered propulsion system”, and: “radiation exposure pathways to workers,
the public and non-human biota during construction and operation (including incident scenarios)”.

The EIS admits (p.87): “A loss of fuel element integrity within the power unit, while highly unlikely,
could result in a radiological release direct from the NSRP into the atmosphere”, and cites: “a number
of scenarios that could lead to a radioactive release from the Power Unit have been extensively
modelled by the NSRP Design Authority”, but fails to make these public safety studies public.

At this late stage, it is unacceptable for the SA Gov to fail to consult the public on N-sub nuclear
reactor accident Emergency response measures including required Evacuation Zone planning.

This EIS also assesses N-sub generation and storage of radioactive wastes at Osborne but concludes
“No significant waste management effects have been identified” (see Executive Summary p.28-29; EIS
Ch.16 Waste Management p.262 to 288; and Appendix 1.11 Waste Management 44 pages). The EIS cites a
‘Low-Level’ radioactive waste category that can require waste isolation for up to a 300 year period.

The EIS further admits (p.87): “Loss of control of any liquid or solid waste could result in the release of
radioactive material and therefore pose a hazard to individuals and the environment. … An aquatic
release into the Port River could result in a wider spread of contamination, and would be dependent
on quantity of the release and the tidal flow at the time of the release.”

For further information, see FoE Australia webpage: https://nuclear.foe.org.au/nuclear-subs/

February 9, 2025 - Posted by Christina Macpherson | safety