SUBMISSION TO THE NUCLEAR FUEL CYCLE ROYAL COMMISSION. The Ranger Uranium Environmental Inquiry Commissioners said p 5-6 1st Report in 1976

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1 SUBMISSION TO THE NUCLEAR FUEL CYCLE ROYAL COMMISSION HEALTH EFFECTS OF IONISING RADIATION If South Australians relied solely on articles in the Advertiser over the last six months, or on statements by politicians, business leaders and others reported by the Advertiser, they would be firmly convinced of the safety of nuclear power at all stages of the nuclear fuel cycle, from mining to waste storage even after major accidents.. The Ranger Uranium Environmental Inquiry Commissioners said p 5-6 1st Report in 1976 In considering the evidence, we have found that many wildly exaggerated statements are made about the risks and dangers of nuclear energy production by those opposed to it. What has surprised us more is a lack of objectivity in not a few of those in favour of it, including distinguished scientists. (my emphasis) So it was a pleasant surprise to see the issues papers include acknowledgment of at least some dangers from nuclear radiation. These dangers have been known for a long time at very least from the mid 1920's with the deaths of the 'radium girls' (who painted watch dials / hands with radium based paint to make them glow in the dark). Denial of the dangers dates from exactly the same time. An article in the Advertiser this year suggested that Chernobyl nuclear accident has only resulted in deaths. This is a massive distortion of the human health effects of the radiation releases from the incident. It only counts immediate deaths (ie the first month or so) from radiation sickness, and ignores all other health effects. There is plenty of scientific evidence that ionising radiation causes damage to living cells and increased cancer risk in humans. For example, in June 2014, the International Physicians for the Prevention of Nuclear War (IPPNW) a global federation of 19 physician organisations, published a Critical Analysis of the UNSCEAR Report on the levels and effects of radiation exposure from the 2011 Fukushima accident. The report is available at It includes at page 8 many examples of studies establishing cancer increases at low levels of radiation such as studies of uranium miners, children living next to reprocessing plants, people downwind of nuclear tests, people living near nuclear power plants, clean up workers at Chernobyl and people exposed indoors to radon. It is well accepted that the foetus is more susceptible to ionising radiation than adults or infants, and most susceptible in the early weeks. A single Xray to the abdomen of a pregnant woman is enough to almost double the risk of childhood cancer, and the risk increases with the number of in utero xray exposures. This has been confirmed in multiple case controlled studies and reviews from the 1950s to the present see the summaries and references at page 9 of the IPPNW Critical Analysis report. Other papers discuss at some length the problems with various study designs for assessing health effects from low level radiation. The US National Academy of Sciences did a scoping study for the US Nuclear Regulatory Commission in 2012 available online at An article in the Advertiser this year suggested that studies of people living in areas of naturally high background radiation, such as Kerala in India, showed they did not have any more cancers than those living in. lower background areas. Therefore low levels are claimed to be safe. Another international

2 study published in 2009 assessed studies on Human Exposure to High Natural Background Radiation explains that most Indian and Chinese studies have provided little information, relying largely on ecological designs and very rough effective dose categories. This report is available on line at Both reports conclude that follow up cohort and case controlled studies with careful individual dose reconstruction and information about possible confounding factors are needed to produce useful results. A paper on Chernobyl liquidators and their doses by Belyakov and others in about 1998 highlights the margins of error in the estimating effective radiation doses in clean up workers at Chernobyl (up to 500%) The United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) stated that no discernible changes in future cancer rates and hereditary diseases are expected due to exposure to radiation from Fukushima. However, IPPNW point out at least 10 main ways in which UNSCEAR underestimated the effective doses for the Japanese population near Fukushima, including use of industry data instead of much higher data from reputable independent institutions. In particular IPPNW pointed to worrying signs of an increase in childhood thyroid cancer already showing up in March An update by IPPNW as at Mar 2015 confirms an increase in child thyroid cancer in Fukushima, and a decline in birthrates since the accident. UNSCEAR is made up of representatives of countries with research reactors and /or commercial civilian nuclear power. The other main UN nuclear body is the International Atomic Energy Agency, with the job of promoting civilian nuclear power, and supervising non proliferation treaties, and reports to the UN Security Council, not the General Assembly. The third body is the World Health Organisation, which should be independent, but in fact has been required since 1959 to consult with IAEA before doing any studies or making statements on nuclear radiation and health. The record of the agreement is available The resolution is on p 49 pdf approving the agreement at annex 11 p545-7 pdf. The agreement in article 1(2) gives IAEA primary responsibility for nuclear research. All of this means obvious conflict of interest for all 3 bodies, and the possibility of a strong bias to underestimating health risks. This conflict of interest and potential bias extends to nuclear power providers and designers and their nuclear associations and even some governments and their regulatory agencies. The Japanese Atomic Energy Agency was singled out for its lax attitude to the dangers of nuclear power, by the Independent Commission into Fukushima in its report to the Japanese Diet, as was TEPCO the Japanese power company responsible for the nuclear reactors at Fukushima. See reference in your issues paper. I believe there is good reason to prefer the views of independent researchers who give priority to public health, over those involved in the nuclear industry. Those views are that the health effects go far beyond deaths and cancer rates cardiovascular, gastro-intestinal diseases, cataracts and congenital defects have all increased following nuclear accidents and the dangers are ongoing. Fukushima continues to release contaminated water into the ocean, and Ukrainians, Russians and Belorussians continue to face dangers from eg radioactive cesium accumulating in mushrooms, berries and wild boar in the Chernobyl exclusion zone, 30 years after the accident. I believe that it is very clear, and is acknowledged in your issues papers, that every stage of the nuclear fuel cycle, from mining, to transport to fuel enrichment, fuel rod fabrication, nuclear power, temporary and permanent storage of nuclear waste including decommissioning of reactors, increases the exposure of the general population to ionising radiation, and increases the risks of adverse effects. This does not

3 include the risk of major accidents or theft/sabotage/terrorism or of nuclear arms proliferation. The nuclear industry claims that new designs have improved safety, but this is theoretical, given that no generation 3 reactor has yet been completed and started commercial operation, and no generation 4 reactor has even been designed at commercial scale. I also have serious doubts about the existence of a safety conscious culture in a nuclear industry that loudly proclaims how safe it is, while ignoring the science saying otherwise, and at the same time pushing for a reduction in 'regulatory red tape'. I realise that the proven increases in cancers etc from low level radiation are quite small numbers, but these are additional risks involved. These risks would be imposed on us all, whether we consented or not, with public assurances it is all quite safe, in the same way that we were all subject to fallout from the Monte Bello and Maralinga/Emu Fields atomic tests that covered almost all of mainland Australia but told there was no conceivable injury (see McClellan Royal Commission). The number of children and grandchildren with cancer in their bones, with leukemia in their blood, or with poison in their lungs might seem statistically small to some, in comparison with natural health hazards. But this is not a natural health hazard and it is not a statistical issue. The loss of even one human life, or the malformation of even one baby who may be born long after we are gone - should be of concern to us all. Our children and grandchildren are not merely statistics toward which we can be indifferent. John F. Kennedy July 26 th, 1963 (as quoted p18 IPPNW ) MINING The issues paper sets out the current state of uranium and thorium exploration and mining in SA. Frankly, with so many known deposits and 2 mines in mothballs and a third operating but with expansion plans on hold, it would be a complete waste of public money to encourage more now. The sector will expand if there is a sustained price rise. I believe the Chinese stockpiled uranium in 2007 and caused the price rise. Although the nuclear industry claims lots of new orders, many nuclear plants are closing and orders have been withdrawn, supplies of uranium have expanded, and there is always the possibility of a further round of nuclear disarmament flooding the market. This doesn't seem likely when Putin considered a nuclear weapons alert during the recent Ukrainian fighting. FUEL ENRICHMENT AND FUEL ROD FABRICATION The Ranger Commissioners said in their First Report at p50 that in the US without subsidy, prices for enriched fuel would double. They also said that these prices have always been publicly subsidised. This remains true today. The Union of Concerned Scientists published a report on subsidies in the US called Nuclear Power: Still Not Viable without Subsidies in Again I see no justification for using public money or any form of assistance in any way to establish an industry that has never been commercially viable in 60 years of civilian nuclear power, and seems likely to never be viable. NUCLEAR POWER The UCS study details the nuclear subsidies from research grants, limitation on liability for damage, loan guarantees, cheap enriched fuel, taxpayer funded write off of construction costs, to waste storage subsidies and more. Some assistance couldn't be quantified, but even without those items, there have been times when subsidies have cost the public more than the electric power produced was worth. I suspect that a nuclear reactor for power production would need public subsidies to be built in SA. The economics of nuclear power were analysed in detail in 2005 by Steve Thomas for the Public

4 Services International Research Unit report available on line at This includes his comment on p12 that forecasts of construction costs of nuclear facilities have generally seriouslly underestimated those costs. He also says that with most technologies, costs have fallen with time, but the experience with nuclear power is that costs have increased with time. He also predicted that if new nuclear power plants were to be built in Britain, extensive government guarantees and subsidies would be required for construction costs, operating performance nuclear fuel cost and decommissioning, and possibly commercial guarantees that the output of the plants would be purchased at a guaranteed price. The deal finally announced in October 2013 for 2 reactors at Hinkley Point C, each reactor costing 8 billion English pounds, with UK government loan guarantees for about 10 billion pounds, plus a guaranteed price of 92.5 English pounds per Mwh for all power produced over 35 years, indexed via CPI, with an expected first power date of These details are set out in the World Nuclear Industry Status Report 2014 in the chapter on Hinkley Point C available at There are substantial construction costs overruns and time delays in the first generation 3 reactors being built. At Olkiluoto in Finland the original price was to be 3 billion euros, with construction complete by The reactor is still not finished, and by December 2012 construction costs had blown out to 8.3 billion euros. Similar delays and cost overruns are occurring with the French reactor currently being built by the same company. The claimed jobs bonanza might not be real.. The issues papers keep making the point that SA doesn't have the skills for most of the jobs in the nuclear fuel cycle beyond mining, so that any nuclear industry in SA would need to import expertise. Site preparation and construction of the concrete shell might be exceptions, but there is no guarantee of this. Olkiluoto 3 in Finland is currently being built by Areva, and according to its website, the workforce of over 4,000 people are from 55 countries. The nuclear power industry also claims that it is a low carbon power source, and your issues paper refers to a exercise in the US attempting to compare carbon emission from nuclear power and various renewable energy sources. On figures so far, emissions from nuclear power per kwh are comparable to other renewables, but none of the studies have included carbon costs of full decommissioning and waste storage. The economic costs of nuclear reactor decommissioning are a negligible component of lifetime nuclear reactor costs when a decision is made to build a nuclear reactor, largely because these costs are so far into the future and have been heavily discounted to net present values. When it comes to actually decommissioning a nuclear plant, the experience of the UK Nuclear Decommissioning Authority at Sellafield is costs are rapidly escalating with actual experience at the site from 25.1 billion pounds in to 47.9 billion pounds in according to the UK Audit Office report at WASTE STORAGE Payments for waste storage might well be in the billions, but nowhere in the world have payments ever come close to meeting the full costs of storage so far, let alone for half a million years. It is definitely not a bonanza when the costs are higher than any income. I think it highly unlikely that any company or country will pay South Australia the money needed to identify a site, design and construct the storage facilities, and presumably operate it for many years

5 and maintain it securely until it is full, and presumably totally closed off for at least 250,000 years. Even if any waste storage facility was restricted to Australia's own nuclear waste, this will include reprocessed fuel rods from Lucas Heights, including small amounts of plutonium. These wastes are from Australian government facilities, and although the federal government might pay some upfront design and construction costs, I can't see them paying SA for the full costs, let alone a bonanza.. The Advertiser published an article on 11 April 2015 about Yucca Mountain, Nevada which was intended to be permanent storage for 70,000 tonnes of hazardous waste in casks in 8 kilometres of tunnels 305 metres underground. Funding was cut off in 2007 because Nevadans oppose the site. The US government has already spent somewhere between $15 billion and $100 billion in drilling and testing this site so far. A federal court ordered the US Nuclear Regulatory Commission to resume the licensing process for the site, and it seems likely Congress will support it again in the next few years. Australia has already been through at least 4 series of processes over the last 30 years for identifying and building a waste storage site for its own wastes, mainly for Lucas Heights fuel. I doubt if anyone has attempted to calculate the public cost to date. Most of the likely sites will be aboriginal land or pastoral lease or Crown land subject to native title claims, and I believe most aboriginal groups will oppose further and effectively permanent loss of control and poisoning of their lands. If we receive the waste, we are not going to be able to get rid of it. For those who still think nuclear waste is safe or harmless, the Ranger Commissioners at page 102 of their first report had this to say about solidified reprocessed spent fuel - in 100 years time, if the material was not shielded in any way, a person standing 10 metres away would receive the annual allowable whole body dose of radiation for members of the public in 18 seconds. OTHER COSTS The cost of regulatory regimes at both state and federal have never been included in any cost analysis of nuclear power. The US Nuclear Regulatory Commission 2015 Congressional Budget Justification gives some idea of the income and budget involved in the oversight of the industry, and many of the additional tasks involved in co-operating with other federal agencies plus state and local government agencies. The income is about $100 million less than expenses. This is only one agency. Emergency services co-ordination and training, work of the Crown Solicitor including contract costs, court costs, consultation costs, costs associated with changes in legislation, security costs and many other hidden costs are never included in the costs for the nuclear industry. As the Ranger Commissioners said, any public assistance not fully paid for by the nuclear industry amounts to a breach of the polluter should pay principle. We made that mistake with coal and gas studies of the hidden costs paid by government and individual public showed that the true costs were several multiples of the carbon tax. ALTERNATIVES Nuclear power advocates are promoting nuclear as the solution to climate change, because of its low carbon emissions while operating and its ability to deliver baseload power. It claims that renewable energy like wind or solar can't do this. I'm not sure how seriously anyone in the electricity business takes this baseload argument. Alinta has just announced it is retiring its coal burning baseload stations at Port Augusta, and claims that a solar thermal installation would not meet its profit requirements. What the industry really seems to want is

6 gas powered stations that can be easily turned on and off to take advantage of (and create) peak power demand at massive prices. There have been many studies suggesting that Australia could get all its stationary power needs from renewable energy sources that are currently available plus energy efficiency measures plus home energy storage including electric vehicle storage, smart meters and smart grids, at a price that is less than electricity consumers currently pay for their power. They all agree that the process would create jobs, including regional jobs, that are sustainable in the long term, without any of the catastrophic and longterm dangers of nuclear power and its wastes. I suspect it is already happening, and will continue, simply because the economics make sense for the individual consumer already for solar PV panels, regardless of the renewable energy target, and small scale energy storage systems are likely to make sense for the individual household soon, possibly by the time this Commission publishes its report. Nuclear power is handicapped at present by its very large up front uncertain capital costs, long lead times before any income is produced, very long term toxic waste issues and need for large supplies of cooling water (the 2 current generation 3 designs approved and being built are both water cooled). In SA the water supply requirement for the next 60 years could be guaranteed only by desalination, which means a coastal location and a significant increase in costs and loss of income. Nuclear power is said by some enthusiasts to be the answer to climate change. However, recent research by Hansen and others suggests that the targets to date for reduction in greenhouse emissions are far too low, and we need to reduce our net emissions to below zero within the next decade or so. Although this is not generally accepted by climate scientists at present, Hansen has a history of leading the pack. The precautionary principle suggests we should take him seriously now, and take any action we can now that will start reducing emissions within that time frame. Even solar PV will do this the time frame for larger installations from go to producing power is about 18 months to 2 years, and the carbon payback period for solar panels is 2 years or less. For many installations, the capital payback period is not much more than this. This 2012 study suggests that the risks of a major nuclear accident have been underestimated in the past, as well as the extent of the global fallout following such accidents. The Ranger First Report in 1976 included a postscript quoting from the UK Royal Commission on Environmental Pollution Nuclear Power and the Environment Report of September 1976 'The dangers of the creation of plutonium in large quantities in conditions of increased world unrest are genuine and serious. We should not rely for energy supply on a process that produces such a hazardous substance as plutonium unless there is no reasonable alternative'. The Australian Commissioners placed more stress on nuclear weapons proliferation risks, but reached much the same conclusion build in safeguards and police them, be ready to halt the industry totally for security reasons, take it slowly and start an immediate and vigorous program of research into energy efficiency and renewable. CHRIS ANDERSON 2015

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