A not particularly anti-nuclear Submission still objects to #NuclearCommissionSAust ‘s bias
Response to Tentative Findings of Royal Commission into the nuclear fuel cycle Submission by Gary Rowbottom,
“…….there is very little information on ILW [Intermediate Level Waste] presented in the Royal Commission Issue Paper (No.4) on the hazard level and required safe containment/storage method or duration required for ILW.
During the tentative fmding delivery by Mr. Kevin Scarce in Port Augusta in February, the day following the release of the tentative fmdings, I asked Mr. Scarce of the SA Government Royal Commission, “how long ILW was dangerous for, and needed to be stored safely for” – he replied “hundreds of years”, but one of his advisors piped up at that point & said, “No, there is no specific figure, it depends on the specific radionuclides involved etc., but is generally in the thousands of years”. The FederalGoverment National Radioactive Waste Management Project information indicates hundreds of thousands of years.
I am very concerned at this disparity of information. I think that whole ILW question needs better thinking and collaboration between the SA Government and Federal Government investigating agencies on this issue, to establish the truth and to then represent this true story to the public…….
I am further a little concerned too that Mr. Scarce, in his delivery of the tentative findings, a mere day after the release of these findings, seemed to be critical of any comments made in opposition to deepening Australia’s involvement in the nuclear fuel cycle, often citing lack of evidence for viewpoints expressed. ……
I would have to say that it seems there is a fair bit of evidence that the commission members themselves are in the majority, clearly quite pro nuclear. I am not happy at the lack of subjectivity that may have brought to the findings, particularly on the waste issue. Whilst Mr. Scarce did say that they did look at the negative sides of all the Issue papers, there is not much evidence of that in the Tentative Findings Report…….http://nuclearrc.sa.gov.au/app/uploads/2016/05/Rowbottom-Gary.pdf
Mothers for a Sustainable South Australia outline 8 risks of #NuclearCommissionSAust
Mothers for a Sustainable South Australia: Our Response to the Tentative Findings of the Nuclear Fuel Cycle Royal Commission • Maureen Graney • Mary Houlahan • Tracey Kermond • Michelle Parsons • Barbara Pocock 18 March 2016
“……..Language We understand from public hearings and the text of the Tentative Report that the Commission does not like the word ‘dump’ and would prefer the language of ‘waste disposal’. We believe that language is important: it needs to reflect reality, not cloak it in a preferred – or deceptive – ambiguity. The Oxford dictionary defines a dump as ‘a site for depositing rubbish’ and, more specifically ‘A place where particular kind of waste, especially dangerous waste is left: a nuclear waste dump’. (http://www.oxforddictionaries.com/definition/english/dump…). In this light, in the interests of clarity, we deliberately use the word ‘dump’ in responding to the recommendation that South Australia should build one for high-level nuclear waste.
Abandon all thoughts of this nuclear waste import scheme – Ngoppon Together
The Commission states that there ‘is no existing market to ascertain the price a customer may be willing to pay for the permanent disposal of used fuel’ so such estimates are simply conjectures with no genuine basis in reality
Our members plead with Commissioner Scarce and the members of the Royal Commission, with Premier Weatherill and all Members of Parliament and Members of the Legislative Assembly: for the sake of our common humanity abandon all thoughts of this scheme. As fellow South Australians, Australians and as fellow human beings together, the implications and consequences of importing the world’s radioactive waste in its highly toxic form is indeed terrifying; and, it must be said, a totally irresponsible legacy, for our generation to leave to the grandchildren, great grand children and every generation to come in our state of South AustraliaNgoppon Together Inc. (Walking Together Reconciliation Group Murray Bridge SA) RESPONSE to the NUCLEAR FUEL CYCLE ROYAL COMMISSION TENTATIVE FINDINGS – due March 18th, 2016
South Australia’s wine industry is worried about #NuclearCommissionSAust’s plan
SUBMISSION OF: SOUTH AUSTRALIAN WINE INDUSTRY ASSOCIATION INCORPORATED This submission is specifically focussed on the key issues of brand value, reputation and recognition, with further consideration of the impacts on tourism, regional infrastructure, natural resources, and legacy issues.
No confidence in economic projections of #NuclearCommissionSAust
Economic risks: ‘Trust me I’m an economist’A farming perspective on the Nuclear Royal Commission waste import plan
Nuclear Fuel Cycle Royal Commission Submission. Patricia and Maxwell Jones
After having many years of dealing with Uranium Exploration on our Property, we feel we know more about Uranium than miners know about farming.
1* Uranium storage (dumping) LOW waste or HIGH waste, will have an effect on neighbouring properties. Just the name Uranium puts fear in people, had great effect on sheep sales from our property, people did not want to buy glow in the dark sheep. Did lower the value of our Merino wool, dust, (not Uranium dust) have had trouble getting through to miners that we are talking good old
fashion dust that is stirred up every time a vehicle passes by, caused lower yields in our wool, therefore devalued it. Lowered our returns.
2* The uranium waste will come via ship we assume, if ship is lost at sea, what happens to our seas. Once on land it travels by road or rail. There is only one highway across Australia, if an accident, will Highway be closed, Kimba, Low level waste is half way across Australia. Small towns have been totally closed
by paint spills before.
3* If it is as we are told very safe, why then is it not possible to store it in Adelaide? Lots of land there close to the sea not being used. Plenty of workers going to be needing jobs soon in Adelaide.
This is the only State not allowed to grow GM crops, because it could contaminate other crops (see court cases in WA etc;) and the stigma attached to GM, which upsets our Politicians. So what would South Australians and the rest of the world think is worse? The answer is obvious.
If in the polls or Royal Commission were to ask the South Australian people in their individual areas eg; (5th East, Riverland, Adelaide etc/) did they want a Uranium waste dump, we are sure the answer would be NO, not in our back yard.
If it’s so safe why, does it have to be sent to our Farming Land? The only safe
place for URANIUM, is LEAVE IT IN THE GROUND.
Nuclear Commission’s recommendations – a poisoned chalice for South Australia?
As a South Australian citizen, I am very concerned by what appears to be a disregard for the rule of law. This is particularly concerning as the nuclear industry across the world has a somewhat tarnished reputation when it comes to transparency and compliance with legal requirements. Any lack of confidence in the rule of law (whether perceived or real) will be extremely detrimental to this project and to South Australia as a democratic state.
A high level nuclear waste dump is a permanent solution to a temporary problem. Voluntary importation of one of the deadliest substances known to humanity, with all of its intransigent problems (which no country in the world has yet managed to resolve) may indeed prove to be a poisoned chalice. Indeed, the x billions anticipated as revenue are minor in global economic terms, and definitely insignificant given the 240,000 year time frame of the proposal.
Response to Nuclear Fuel Cycle Royal Commission’s Tentative Findings, Trisha Drioli http://nuclearrc.sa.gov.au/app/uploads/2016/04/Drioli-Trisha.pdf I have a large number of concerns arising from a proposal that seeks to store highly toxic waste in my home State for a period longer than the entire existence of the human species. Never-the-less, I restrict my submission to my some key points: Continue reading
No true transparency in the machinations of the Nuclear Fuel Chain Royal Commission
“Transparency” is a term when used in such context, makes a mockery of public consultation and decision-making. In an industry that is hidden within Legislative Agreements that prohibit “freedom of information” and with information locked up in inter-departmental exchanges that circumvent any public disclosure, there is no transparency. Local get-togethers do not equal public engagement. These are serious matters which are of National concern
Response to “Tentative Findings” – Anne McGovern
Meg Backhouse’s fine Submission to Nuclear Fuel Cycle Royal Commission
RE: HIGH LEVEL and INTERMEDIATE WASTE STORAGE http://nuclearrc.sa.gov.au/app/uploads/2016/05/Backhouse-Meg.pdf Meg Backhouse Catholic Religious South Australia express duty to oppose Nuclear Commission’s import waste plan (extracts from Submission)
Catholic Religious South Australia – response the the nuclear fuel chain Royal Commission’s ‘Tentative Findings’
Major financial risks for South Australia are ignored by Nuclear Fuel Cycle Royal Commission
The proposal has major financial risks to taxpayers that have been ignored or played down in the Tentative Findings. These are sufficient grounds to reject the scheme. However, if the Royal Commission is determined to ignore or downplay the risks and recommend the proposed project, it should also recommend that 5 the substantial financial risks be taken by a private corporation or consortium, not Australian taxpayers
Comments on the Cost Analysis, Business Case and Risks of Management for Storage and Disposal of Nuclear Waste in South Australia Dr Andrew Allison challenges The Nuclear Fuel Cycle Royal Commission’s reckless Tentative Findings
The proposal is that we should accept waste before the repository has been completely built and tested. This proposal is so reckless, as to be negligent. We would face the very real risk of being left with high-level nuclear waste, and no technology to properly handle it.Response to the Nuclear Fuel Cycle Royal Commission’s Tentative Findings By Dr Andrew Allison, B.Sc. B.Eng. PhD. (Elec. Eng.) 17 March 2016
Secrecy on health information about uranium workers – Submission to #NuclearCommissionSAust
NUCLEAR FUEL CYCLE ROYAL COMMISSION TENTATIVE FINDINGS RESPONSE March 2016 Dan Monceaux – Documentary filmmaker & South Australian citizen
EXPLORATION, EXTRACTION & MILLING “………I have previously expressed my criticism that this, and indeed all Royal Commissions conducted in South Australia are exempt from the Freedom of Information Act 1991. This is fundamentally undemocratic, and contradicts claims made by the Commissioner on many occasions of his commitment to openness and transparency.
Returning to the subject of exploration drilling, I would suggest that there is another factor confounding the efficacy of exploration drilling regulation in South Australia- namely regulatory capture. This is accompanied by a tendency to withhold information regarding non-compliance and regulatory failure. The resulting impression can be one of false assurance. For example, by citing Marathon Resources Rectification Plan 2008 in its Tentative Findings, while neglecting to list the Eyre Iron compliance audit report which it also received, the Commission is misleading the reader. A reader would be forgiven for assuming that Marathon’s non-compliance was an isolated example, when clearly, this is not the case. The compliance audit report is found as Appendix A attached to my submission below. http://nuclearrc.sa.gov.au/app/uploads/2016/03/Dan-Monceaux-10-08-2015.pdf
The Government of South Australia has on its own record admissions of its institutional knowledge of lung cancer risk to uranium workers in underground mines. The evidence base dates back to the early experiences of miners at Joachimstahl in Czechoslovakia, from whose high incidence of lung cancer the first precautionary safety standards were subsequently set in other jurisdictions. The risk was understood in the 1920s as evidenced by publications of the South Australian Department of Mines from the mid 1950s, namely: Possible health hazards in uranium mining – Armstrong, A.T., Department of Mines (1955) https://sarigbasis.pir.sa.gov.au/WebtopEw/ws/samref/sarig1/image/DDD/RB00429.pdf The health consequences of workers in the uranium industry – Dr. B. S. Hanson (1956) https://sarigbasis.pir.sa.gov.au/WebtopEw/ws/samref/sarig1/image/DDD/RB4200080.pdf
They are found in the results of Radium Hill worker cohort studies published in peer-reviewed medical journals. The epidemiological studies of the 1980s, published circa 1990 proved, with epidemiological evidence of elevated cancer incidence, that confidence expressed in the safety of working conditions at the Radium Hill mine in the 1950s and 1960s was ill-founded.
Radon daughter exposures at the Radium Hill uranium mine and lung cancer rates among former workers, 1952-1987 – Alistair Woodward, David Roder, Anthony J. McMichael, Philip Crouch and Arul Mylvaganam (1991) http://www.jstor.org/stable/3553403………
the Olympic Dam mine’s radiological safety measures and records remain protected by special secrecy provisions established under the Roxby Downs (Indenture Ratification) Act 1982. Secrecy during the time of the Radium Hill mine was a matter of protecting Commonwealth secrets during the Cold War. The secrecy provisions of the Roxby Downs Indenture (Ratification) Act 1982, were according to Ian Gilfillan of the Australian Democrats, at least in part to protect the project from attack by environmental groups. The Indenture Act was revised in 2011, and forfeited the ideal opportunity to repeal Cold War-style exemptions as a sign of good faith to the people of South Australia and movement towards open government………… https://www.academia.edu/23544163/Nuclear_Fuel_Cycle_Royal_Commission_Tentative_Findings_Submission_-_March_2016
The health of uranium and nuclear workers. Response to #NuclearCommissionSAust’s ‘Tentative Findings’
It is extraordinary that the South Australian Nuclear Fuel Chain Royal Commission is not publishing Responses to its “Tentative Findings” before it makes its final announcement on May 6th.
Meanwhile, here is part of at least one very clear and informative response.
NUCLEAR FUEL CYCLE ROYAL COMMISSION TENTATIVE FINDINGS RESPONSE March 2016 Dan Monceaux – Documentary filmmaker & South Australian citizen.
“…… I sincerely hope that the health and wellbeing of South Australia’s workforce, its citizenry and its environment are considered sufficiently important topics for this Commission to elaborate on the matters raised here ahead of its final report to Parliament in May.
………The Commission’s opening tentative finding states that “South Australia can safely increase its participation in nuclear activities, and by doing so, significantly improve the economic welfare of the South Australian community.”
The evidence base for adopting such a confident and conclusive statement is questionable. In the case of nuclear industrial activities which have established links with health conditions including cancer and associated heart, lung and liver conditions and potential genetic harm, the safety or otherwise of an activity or regulatory regime can only be proven by epidemiological studies spanning a timeframe of decades. For example, little is known about the fates of worker cohorts from existing and past uranium mining and milling activity in South Australia………. The Commission has had time to consider this matter, but appears to have not deemed it sufficiently important. ……
I wish to make a case for the prioritisation of epidemiological studies of past and present South Australian uranium worker cohorts as a matter of the utmost importance. The results of such studies could provide an empirical basis for future commentary regarding the safety or otherwise of the industry as it has existed until now…….
The Commission states that “policies must be based on evidence, not opinion or emotion.” The same rule should apply to statements made by the Commission. To be considered credible, they must be supported by material evidence. The absence of evidence is not evidence of absence. Harm can neither be proven, nor safety assured without relevant epidemiological studies. This was known to South Australia’s Department of Mines in 1956, when Dr. B. S. Hanson wrote in The Health of Workers in the Uranium Industry (pg. 16): “It is only by long-term health examinations that the validity of our present speculative exposure limits may be tested.” This document is currently available on SARIG, the South Australian government’s resources industry geoserver: https://sarigbasis.pir.sa.gov.au/WebtopEw/ws/samref/sarig1/image/DDD/RB4200080.pdf…….
The available evidence suggests that contemporary publications of South Australian Government departments fail to adequately communicate occupational exposure risk to their readers. The perfect example of this is the Uranium fact sheet published by the Department of State Development in 2015, during the proceedings of this Commission. The “Fact Sheet” poses the question “Is uranium safe?” then neglects to answer the question. Instead, it provides the graphic reproduced from http://www.statedevelopment.sa.gov.au/upload/uranium/uranium%C2%ADthe-facts-final.pdf? t=1458534521755
Compare this to Hanson and Armstrongs statement from 1956, in documents held by the same South Australian government, written 60 years earlier:
“Hazards associated with uranium ore are of two kinds, those due to radioactivity, including 6 external radiation as well as internal radiation; and those due to uranium metal poisoning. Radon gas and its solid daughter products would appear to offer the greatest potential danger. They can be inhaled and the solid products so lodged in the body.” (Armstrong, pg. 18)
“The individual employed in a mine or mill risks damage by external or internal radiation, and as to the latter the radioactive particles which form a danger are either ingested or inhaled.” (Hanson pg. 7)
“The daughter products are insoluble, but together with the dust to which they adhere some are engulfed by the reticulo-endothelial cells of the lung surface and there theoretically give a high intensity of alpha radiation to those very surface cells which form the type seen in the usual cancer of the lung.” (Hanson pg. 9)
“The inhalation of active deposit on dust particles, is so much the most important one that most of our [Department of Mines’] effort should be directed towards overcoming it.” (Hanson pg.10)
“In my opinion, dusty clothes inevitably mean an inhalation risk as well as an ingestion risk.” (Hanson pg.14)
“Almost without exception this report deals with the real or probable dangers of radioactivity.” (Hanson pg. 19)
The disparity between the messages of 1955 and 1956 (Department of Mines) and 2015 (Department of State Development) is alarming and deeply concerning…… https://www.academia.edu/23544163/Nuclear_Fuel_Cycle_Royal_Commission_Tentative_Findings_Submission_-_March_2016
South Australia’s Nuclear Fuel Chain Royal Commission virtually ignored dangers of transporting radioactive trash
As the days get a bit closer to #NuclearCommissionSAust’s announcement of its (predetermined) findings, we need to remember that the Commission’s “Issues Papers” almost completely ignored the question of the dangers of transporting highly radioactive trash across land and sea.
Paul Langley, in his fine response to the Commission’s “Tentative Findings” raised this very important matter – in the extract below
Response to the Tentative Findings of the SA Nuclear Fuel Cycle Royal Commission A Submission by Paul Langley Nuclear Exhaust 16 Mar 16 “……Transport of HLNW from around the world to a SA HLNW geologic repository
The Royal Commission apparently assumes that the movements of many hundreds of thousands of tonnes of spent nuclear fuel from many countries around the world to the Gawler Craton will be low risk, no problems and perfectly safe. As contradictory as those stances are. I do not accept that position of default safety. Further I do not accept that the unloading of the HLNW will be perfectly safe. I do not accept that road transport from port to repository site will be perfectly safe, even on a dedicated purpose built road.
I would recommend that Super Freighters laden with the contents of countless reactor cores not sail down the Somali coast nor in the waters to the south of Thailand for fear of pirates. They should avoid man made Islands in the South China Sea. I suppose the ships will be guarded by 6 English policemen each with two revolvers between them. Rather than half the Pacific Fleet they would actually warrant. If they ever get to leave their home ports. What is the Somali coast going to be like in 40 years? Peaceful or short of rad weapons?…….” https://nuclearexhaust.wordpress.com/2016/03/15/response-to-the-tentative-findings-of-the-sa-nuclear-fuel-cycle-royal-commission/
Antinuclear 