GeoSynthesis Pty Ltd

GeoSynthesis Pty Ltd

,

A.B.N. 73 094 463 546

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30 Aug 2015 Att Rear Admiral the Honourable Kevin Scarce AC CSC RAN (Rtd) Royal Commissioner South Australia Nuclear Fuel Cycle Royal Commission GPO Box 11043 ADELAIDE SA 5001 Dear Sir My submission to the Royal Commission on all four Issues Papers is attached. My reason for making a submission stems from my long involvement in uranium exploration, mining, and development in Australia and globally since 1969. With respect to your Commission, I have completed responses to each question separately, as requested. My general conclusions include:

Nuclear power must become a long-term source of adequate baseload electricity for the world, and for Australia. This will ensure minimal potential environmental effects of all waste products from burning fossil fuels (coal, petroleum, natural gas, wood and biofuel).

Given adequate high-level safeguards, there are no logical reasons against Australia investing in nuclear power rapidly, and there are many reasons in favour.

Given adequate high-level safeguards, there are no reasons against Australia becoming a significant global part of the entire nuclear fuel cycle.

Australia has a one-off chance to start from a clean slate and write its own modern standards for regulation and oversight of a nuclear industry

A single Commonwealth entity should be charged with oversight and regulation of all nuclear fuel cycle activities other than mining throughout the Commonwealth, superseding all relevant legislation and departments of all States and Territories (eg an ‘Australian Nuclear Fuel Authority’). This is necessary to avoid duplication of bureaucracy, and to ensure a single Australian entity for compliance with all global legal requirements.

The ‘Australian Nuclear Fuel Authority’ entity should consider adoption of the hard-line safety features and rigorous discipline inherent in the US and UK Naval approach rather than a model based on existing civilian authorities.

Nuclear fuel cycle activities must include utilisation of all radioactive substances after mining, especially uranium and thorium, ranging from secondary and tertiary processing to produce suitable nuclear fuel, transport, and storage, including nuclear power facilities, and waste material and storage resulting from those facilities.

A focus should be on generating training, education, and skills development opportunities as well as advanced engineering businesses for Australian entities to become world leaders in the nuclear fuel cycle,

The imperative for cleaner electricity generation has resulted in imbalances in power supply throughout the Australian electricity network (subsidised non-coal versus traditional coal). Additional forces include government-owned versus private suppliers. Short-term arguments on these bases should not preclude the introduction of nuclear power.

Nuclear power generation should not be subsidised nor penalised by governments.


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Australia should investigate joint venture activities with Sweden and Finland for construction and operation of waste storage facilities.

The potential positive economic benefits to Australia from actively taking part in the nuclear fuel cycle include: cleaner environment; less expensive baseload electricity; increased employment; improved skills; improved business opportunities in support roles; vastly improved engineering opportunities for all business levels; better education and training for workers.

For South Australia, development of a direct involvement in the nuclear fuel cycle offers a way forward for the skilled worker base from the car industries and naval construction.

I have been impelled to make a submission by my personal experience of the uranium industry globally. My experience and expertise includes: Academic:

Bachelor of Science, University of New England, 1971; double degree in geology and zoology.

Bachelor of Science with Honours (class 2), University of New England, 1972. NATA Certificate, Environmental Auditor Training Course, 2001. Negotiation Certificate, ENS International, 2001.

Technical career (uranium): Commenced uranium field exploration in NT, 1969. Team leader for greenfields discovery of Ranger 68 uranium deposit, Alligator

Rivers Uranium Province, 1976. Consultant to Energy Resources of Australia Ltd for underground evaluation

of Jabiluka uranium deposit, Alligator Rivers Uranium Province, 1997-2000. Competent Person for Jabiluka uranium project ore reserves and resources,

2000-2006. Consultant to Energy Resources of Australia Ltd leading to the discovery of

Ranger 1 No 3 Deeps uranium deposit, Alligator Rivers Uranium Province, 2004-10.

Independent Geologist’s Report for Aura Energy Ltd prospectus, 2006. Independent Canadian NI43-101 report on Swedish uranium projects for

Mawson Resources Inc, 2006-08. Vice President Exploration & Development, NexGen Energy Ltd, Canada

2011-14. Team leader for greenfields discovery of NexGen’s giant Arrow uranium

deposit, Athabasca Basin Rivers Uranium Province, Canada, 2014. Field assessment of numerous uranium resource projects in Australia,

Madagascar, Botswana, Sweden, Mongolia, Canada, Spain, and the United States (1988-present).

Other career: Identification/discovery of gold projects (Qld 1980s; USA 1994); heavy mineral

projects (Qld 1980s). Project evaluation of gold, base metal, tin, tungsten, heavy mineral projects

(throughout Australia). Acting Senior Aboriginal Liaison Officer, Ranger and Jabiluka Projects (1998-

99). Negotiation consultant to numerous mining companies, Australia & Canada. Photogeological interpretation specialist.


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Professional affiliations: Fellow Australasian Institute of Mining Metallurgy (elected Fellow Jan 1982,

member since 1973); Chartered Professional Geologist (29 Nov 2000). Member Geological Society of Australia (since 1973). Member Canadian Institute of Mining & Metallurgy (since 1982). Member Geological Society of America (since 1992). Member Society of Economic Geologists (since 2005).

Yours sincerely

Andrew Browne BSc (Hons), FAusIMM (CP), MCIM, MGSAust, MGSAm, MSEG

***

South Australia Nuclear Fuel Cycle Royal Commission – submission by A Browne

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Issues Paper One: Exploration, Extraction, and Milling Issues Paper 1 Questions SUBMISSION 1.1 Are there opportunities for new or further exploration activities directed at locating new mineral deposits, or to better understand existing deposits containing economic concentrations of uranium or thorium in South Australia? What specifically are those opportunities? What might understanding those opportunities be reasonably expected to reveal? What needs to be done to understand their potential more clearly?

Q 1.1 South Australia needs to ensure simplified exploration access throughout the State, including on Commonwealth and private land, for explorers to be able to undertake work for discovery of new deposits of U and Th and for expansion of known deposits. Further exploration must NOT be constrained by rules or regulations restricting activities to those associated with conventionally-accepted geological models; all known models continue to evolve. The Olympic Dam “IOCGU” model did not even exist until 40 years ago, and if administrative restrictions were to have been placed on (for example) the ability to drill through agricultural aquifers, then Olympic Dam would not have been discovered.

1.2 What are the economic conditions including those in resource markets that would be necessary for the financial viability of new exploration activities directed at locating uranium or thorium? Aside from economic conditions, how do factors such as access to investment, skills training, taxation, research and development, innovation and regulation, bear on decisions to invest in new activities? What is most important?

Q 1.2 The long duration lead times for discovery and development of potentially viable U and Th deposits means that forecasting accurate economic conditions is impossible. All are based on forecast supply for current generation uranium-powered nuclear power stations. Neither U nor Th fusion power stations exist yet. Any restrictions on exploration based on theoretical long-range economic forecasting (eg “the uranium market will collapse from over-supply in 20 years’ time, and therefore we should not permit exploration for uranium”) are nonsensical. Investment decisions are based on factors relevant to the potential investors alone, who generally have differing internal views on market conditions. Investors need: (1) security of asset; (2) security of physical access to the asset; (3) no over-onerous regulation; (4) a sense of continuity of government investment climate – eg known taxation regimes. Skills and training for actual exploration will be found at the time required from a variety of sources. Government assistance in ensuring availability of training regimens (University and trades courses) will help but is not paramount, except at the time when a shortage MAY develop.

1.3 What might be necessary to encourage further exploration for uranium and thorium? What might be done to promote viability? Are existing government plans sufficient? Could support be provided in other ways and, if so, how could that be done

Q 1.3 Encouragement of further U and Th exploration involves greater physical land access, taxation assistance, and information availability. Promoting market viability is beyond the assistance of government, except in a negative sense (over-taxation or onerous regulation will actually discourage exploration; actual legal restrictions on whether uranium exploration or exploitation may even occur is the worst manifestation).



most effectively? Is there a sufficient availability of information from exploration activities previously undertaken?

All historical exploration data and information must continue to be freely available. The South Australian government geoscientific information availability is a world leader, and should be encouraged to remain so.

1.4 Are there either existing proven uranium or thorium resources which might feasibly be developed? Where are they? What specifically needs to be done to develop these? How long would the development process take?

Q 1.4 Existing resources of U and Th are known, but remain undeveloped for the good reason of financial non-viability under market conditions. Development of existing resources depends on current and forecast market economic viability, which is beyond the scope of government. Further, reserves of U or Th are totally useless without a mill; development of existing resources requires facilitated development of the requisite processing plant. Government assistance may enhance such processing development by minimising over-onerous regulation and oversight. Metallurgical studies are needed for improved extraction of U from refractory minerals (such as brannerite), and similar concepts apply to extraction of Th from a variety of heavy minerals. Government assistance (eg direct part-funding; establishment of appropriate research facilities) could be useful, but government must beware of “picking winners” (companies cannot do this!). It would be preferable for government to avoid all direct assistance rather than to channel scarce funding into unprofitable areas. Known undeveloped U resources include a large number of sandstone palaeochannel deposits in Mesozoic sedimentary basins – note that their characteristics have already determined non-viability (eg Honeymoon is actually a number of discontinuous mineralised zones, with discontinuous aquicludes, rendering an ISR operation financially non-viable). Small IOCGU projects in the Gawler Craton may invariably be at too great a depth for a financially viable recovery project to proceed. Similarly palaeo-beach sand/heavy mineral deposits may be viable for titanium content but not for Th. Successful development of any of these already known deposits will depend on improving recovery operations within a financially successful mining and processing project. Government can do little, if anything, for such projects, except to ensure that future access is never blocked.

1.5 What would be necessary to develop new mine sites or expand existing sites? To what extent are those factors affected by the ability to extract commercial resources other than uranium? What are the necessary factors that might stimulate an expansion in activity? What is the evidence that those factors have been

Q 1.5 Critical features required are those of infrastructure – power, water, road access. Government initiatives can assist, even if minimal by removing or reducing bureaucratic blockages. Power: South Australia’s indigenous power supply depends primarily on Cooper Basin gas and Leigh Creek coal, plus input from the eastern Australia network. New mining and associated developments must have reliable power supplies, and a new large-scale station is required to replace Leigh Creek. It is recommended that a suitable latest-generation PWR nuclear station should be built along Spencer Gulf. A necessary adjunct should be a desalination plant. Thus



relevant to an expansion in activities elsewhere?

power and water can be supplied to future (and existing) developments in central and western SA. Side benefits include construction and operating employment, and a reduction in burning fossil fuels, while third party benefits from a large-scale housing and employment zone include education, training, and small business opportunities, plus further support for local agricultural activities.

1.6 Does more need to be done now and in the future with factor inputs (including skills and training, research, education and infrastructure) which are relevant to decisions made to invest in new projects or to expand those that already exist? What capabilities and capacities would be required for the development of new projects? What is the evidence that any specific deficiency influences new investment? What needs to be done to address any deficiency and how would it be done?

Q 1.6 The predominant factor causing the popular alienation within Australia of nuclear power and its attendant industries is a lack of public education in facts regarding the industry. The anti-nuclear lobby in the 1960s-70s has been so stridently successful in peddling propaganda that the majority of the Australian population does not know what to believe. The later acolytes have never heard factual material from school onwards, and have only generally been told “nuclear bad, solar good” without any backing of either case. This Royal Commission itself is evidence of a prolonged educational deficiency, as it is the culmination of frustrated political decision-making with regard to the nuclear fuel cycle. Fortunately, it represents an opportunity to educate citizens in the current state of realism of the wider nuclear industry. New projects of mining, processing, or major industry connected to nuclear will only thrive in the sunshine of knowledge. Proponents must be able to disseminate full and frank factual information regarding their projects, regardless of negative data – if the proponents truly believe in the overall objective and positive outcomes, then they must present all sides. Equally, objectors must be forced to admit both positive and negative aspects of their submissions. One thing to be done is to remove non-factual material from government schools and educational institutions, or at least to insist on a genuine even-handedness. The major problem is that teachers themselves have not been taught the difference regarding the nuclear industry. Therefore all sides of the industry must be taught to student teachers. A second thing to be done is to ensure that government documents must also reflect facts (both positive and negative) in all public discussions of potential and proposed nuclear-related projects. Aside from basic education, a number of potential work positions and careers in the nuclear industry should be offered to students and workers (eg radiological technician; decontamination technician), as well as more traditional earth science and engineering disciplines (eg expand the School of Nuclear Engineering at the University of NSW to have a campus in Adelaide or move there). Environmental management education should be expanded to utilise information available from mine sites in all ecological and climatic zones.



A third thing to be done would be to ensure a genuine government scientific ability to accurately assess projects - persons and organisations purporting to be able to rationally assess proposed nuclear-related business MUST have at least a basic education in those associated sciences. Conversely, assessments must NOT be carried out by persons without such basic knowledge.

1.7 Is there a sound basis for concluding that there will be increased demand for uranium in the medium and long term? Would that increased demand translate to investment in expanded uranium production capacity in South Australia (bearing in mind other sources of supply and the nature of South Australia’s resources?).

Q 1.7 Unfortunately, nobody knows whether there will actually be an increased demand for uranium. Official IEA and IAEA data suggests that there will be a supply imbalance (resulting in increased demand) IF the number of proposed new nuclear reactors are actually built (in China, India, Middle East). The current political imperative for increased reactor build is primarily due to the “climate change” argument (meaning only one thing, being that decreased burning of fossil fuels is required – there is NO such thing as “clean coal”; burning gas instead of coal only decreases the volume of waste material, not the amount of CO2). Regretfully the anti-nuclear lobby are still chanting “nuclear bad, solar good” without being able to alter the quantum of solar flux to improve baseload electricity generation. In any form of just world, people require electricity to improve their lives. Constant baseload power is required. There are only two substantive choices to generate baseload power – burning fossil fuels, or nuclear power. It is extremely likely that the latter must eventually take over from the former, and hence nuclear power requirements will increase. Nuclear engineering is improving, and yet there is still no real alternative to the power feedstock being uranium oxide into fission reactors. Until fusion reactors (U and/or Th) come into being, if they ever do, it is likely that the demand will increase for uranium oxide, perhaps for 50-100 years. Market forces will determine whether South Australian uranium will be a part of that increased supply.

1.8 Would an expansion in extraction activities give rise to new or different risks for the health and safety of workers and the community? If so, what are those risks and what needs to be done to ensure they do not exceed safe levels?

Q 1.8 A better knowledge and understanding of definitions of “safe levels” is required initially. The basic physical properties of uranium mining, milling, processing, and use have been well studied, and there are few surprises left if any. The risks are known and have been quantified in intense detail. Alterations to acceptable limits or “safe levels” continue to be proposed and be accepted as new evidence comes to light. Occupational health and safety issues primarily relate to exposure to ionising radiation and to radioactive particles in air, water, and dust. Safeguards already exist and have been proved to be effective WHEN FOLLOWED.



Unfortunately, poor education and workplace practice may form an additional risk to industry workers, if inadequate information is given, and inadequate oversight and audit occurs. Improving this is the responsibility of top down management in private industry and in government oversight.

1.9 Are the existing arrangements for addressing the interaction between the interests of exploration and extraction activities and other groups with interests such as landowners and native title holders suitable to manage an expansion in exploration or extraction activities? Why? If they are not suitable, what needs to be done?

Q 1.9 Government should insist that indigenous and other landowner groups are given the direct opportunity to hear arguments from the pro-uranium side as well as the anti, and to obtain genuine scientific evidence for both arguments.

1.10 Would a future expansion of exploration, extraction and milling activities create new environmental risks or increase existing risks? If so, are current strategies for managing those new risks sufficient? If not, in what specific respects? How would any current approach need to changed or adapted?

Q 1.10 As for Q 1.8: risks are known and easily quantifiable. New research will provide data needed for any required alteration of definitions of “safe levels” or other environmental risks. The main risk to humanity is to not offer the nuclear industry as a viable alternative for production of clean electricity, with appropriate checks and balances.

1.11 Given current techniques of extraction and milling and their regulation, what are the relevant lessons for the contemporary management of environmental impacts that should be learned from past extraction and milling practices?

Q 1.11 Regulation needs to keep up with new technology. An example is use of water jet mining technology in softer mine formations, where uraniferous sludge forms during the mining operation, and then becomes the actual mill feedstock. Another is dewatering tailings to form a much lower volume of tailings, suitable for either subatmospheric storage or subterranean storage, with adequate groundwater exclusion. A third might be retreatment of uranium, radium, or thorium tailings which could become financially viable with new technology.

1.12 If an expansion of exploration or extraction activities were viable, what would the estimated benefit be expected to be directly in those sectors, in terms of economic activity? Can growth in employment relating to

Q 1.12 Market forces determine the availability of exploration funding, and also that of demand for product, and therefore processing. There is always a measureable increase in overall employment from any productive activity (apologies, I’m not an economist, just an observer). Banning a potentially productive activity merely weakens the ability of locally affected communities to improve their lives.



the extraction or milling of uranium (alone or in conjunction with other commodities being extracted) be estimated? Is there evidence increased extraction and milling would create additional capabilities and capacities in related sectors? What are those sectors? What would their value be?

Education and training for nuclear-related activities widens the possible sphere of all concerned, and should be encouraged.

1.13 Would an increase in extraction activities give rise to negative impacts on other sectors of the economy? Have such impacts been demonstrated elsewhere in Australia or in other economies similar to Australia?

Q 1.13 Expansion of Australia’s nuclear businesses must improve the overall economy. It should stimulate local engineering, environmental monitoring, education, upskilling, processing, and export-related industries. It is difficult to conceive a scenario where addition of such opportunities to a wider community (Australia) will lead to negative impacts, unless such impacts are imposed by over-zealous and under-educated regulation.



Issues Paper Two: Further processing of minerals and manufacture of materials containing radioactive and nuclear substances

Issues Paper 2 Questions SUBMISSION 2.1 Could the activities of conversion, enrichment, fabrication or reprocessing (or an aspect of those activities) feasibly be undertaken in South Australia? What technologies, capabilities or infrastructure would be necessary for their feasible establishment? How could any shortcomings be addressed?

Q 2.1 It seems doubtful that a new private company or companies would want to commence secondary and tertiary processing of nuclear materials, due to the high costs, and to the almost total lack of trade/educational skills or engineering expertise in Australia. Regretfully this is a legacy of historical poor political judgment on the part of Australian citizens and parties. However, South Australia (in conjunction with the Commonwealth) could realistically offer a secure and remote environment for such activities, with a number of localities being available for the required transport and siting of the range of facilities required. This might attract an existing European processing entity to set up either subsidiary or new facilities in South Australia. It is unlikely that existing US, Canadian, Russian, or Chinese entities would take up such an offer. South Australia has proved its efficacy in hosting such remote but critical facilities (eg Woomera). If South Australia decided to host a new nuclear power facility, then there would be added attractions in having adequate power and water available; further, a power station would always provide the impetus for having skilled personnel and engineering available, and thus might provide an added attraction. Security could be seen as a major issue, but again remoteness provides a good start, and Commonwealth security would be another area of local employment for the nation.

2.2 Would it be feasible for South Australia to assume a greater role in manufacturing materials containing radioactive and nuclear substances? What factors need to be taken into account in making that determination? Which factors are most important and why?

Q 2.2 Manufacture requires feedstock, and Australia (and particularly South Australia) hosts an enormous quantity of uranium and thorium. The main requirements to commence manufacture are capital and political will. If Australia demonstrated political will, then capital might be found, as suggested in Q 2.1 above. A skilled engineering workforce exists in South Australia (cars; naval; mineral processing). Hence an adequate skills base almost certainly exists suitable for any requisite upgrading.

2.3 What legislative and regulatory arrangements would need to be in

Q 2.3



place to facilitate further processing and further manufacturing activities, including the transport of the products which they generate? How could these arrangements be developed so that they are most effective?

It is critical to avoid bureaucratic duplication of effort, and to have access to the most responsive levels of security. It is proposed that a new single Commonwealth body be set up charged with oversight and regulation of all nuclear fuel cycle activities including transport throughout the Commonwealth, superseding all relevant legislation and departments of all States and Territories (eg an ‘Australian Nuclear Fuel Authority’). South Australian regulatory and legislative arrangements and entities would need to become included within an ANFA. However, if such a Federal body is not forthcoming, then there is no reason why South Australia should not set up its own structure, which could perhaps form the model for a later Federal one. Political will is needed at both the State and Commonwealth levels. A further responsibility of an ANFA would be compliance with all global legal requirements and treaties.

2.4 What are the projections for future supply and demand for conversion, enrichment, fuel fabrication or reprocessing activities? What is the evidence to support those projections? Might it be viable for one or more of those activities, or an aspect of them, to be established in South Australia in the medium or long term? What is the reason for thinking that would be so? What conditions would be necessary for that to be viable?

Q 2.4 As previously noted in Q 1.2 and Q 1.7, future projections are based on current potential nuclear reactor builds and requirements. All international agencies (viz IEA, IAEA) continue to project an increased demand, although the rate of increase is unknown or is variable. The increasing scale of introduction of nuclear power globally should realistically indicate that future supply of all aspects of the nuclear fuel cycle will increase. Establishment in South Australia will depend on its attractiveness to international corporations already involved in secondary and tertiary processing, as noted in Q 2.1 above. One main problem is the almost total lack of the requisite regulatory and oversight framework, either in South Australia or Federally. Economic viability of a secondary/tertiary processing industry will depend greatly on having an adequate and transparent framework.

2.5 Could South Australia viably increase its participation in manufacturing materials containing radioactive and nuclear substances? Why or why not? What evidence is there about this issue? What new or emerging technologies are being developed which might impact this decision?

Q 2.5 Participation in the nuclear fuel cycle is all about political will, adequate capital, and a robust regulatory and oversight framework. South Australia offers an excellent location for such industries (see Q 2.1 above), as well as an adequate skills base suitable for upgrading. Further, specialised nuclear industry tool-making and parts manufacture offers excellent niches for entry-level businesses. Waste repository technology is improving (see WIPP facility in New Mexico), requiring both skills and engineering.

2.6 What are the specific models and case studies that demonstrate the best

Q 2.6 No submission.



practice for the establishment, operation and regulation of facilities for the conversion, enrichment, fuel fabrication or reprocessing of, or the manufacture of materials containing, radioactive and nuclear substances? What are the less successful examples? Where have they been implemented? What lessons can be drawn from them? 2.7 What are the processes that would need to be undertaken to build confidence in the community generally, or specific communities, in the design, establishment and operation of such facilities?

Q 2.7 An enormous amount of factual education is required in Australia to undo the decades of anti-nuclear propaganda. However, the best way is to demonstrate the jobs resulting from building specific skill sets needed for the nuclear fuel cycle, and the opportunities for local communities to embrace such new industries to ensure their communities grow stronger instead of slowly receding. This is a generational attitude which is needed, and generational time for such change to become accepted. Political will is badly needed for successful introduction of such new business.

2.8 What additional risks for health and safety would be created by the establishment and operation of such facilities in South Australia? What needs to be done to ensure that risks would not exceed safe levels? Can anything be done to better understand those risks?

Q 2.8 A better knowledge and understanding of definitions of “safe levels” is required initially. Additional risks which nuclear fuel cycle facilities might incorporate are all to do with understanding ionising radiation and its actual (not putative) effects. Effective containment of all industrial radioactive sources would be improved measurably by establishment of Australia-wide standards. The South Australia and Federal governments must establish a modern upgraded regulatory and oversight framework, and provide skilled workers for monitoring and factual education.

2.9 What additional environmental risks would be created by the establishment and operation of such facilities in South Australia? Are there strategies for managing those risks? If not, what strategies would need to be developed? How would any current approach to management need to be changed or adapted?

Q 2.9 Additional environmental risks could be to air, water supplies, and transport infrastructure. The South Australia and Federal governments must establish a modern upgraded regulatory and oversight framework, and provide skilled workers for monitoring and factual education.

2.10 Q 2.10


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Given current techniques for further processing of radioactive and nuclear substances, what are the relevant lessons for the contemporary management of environmental impacts which should be learned from past South Australian processing practices?

Allocation of actual responsibility is required. Abandonment of radioactive mine sites should never have occurred in the past, and is nominally impossible today. However the Commonwealth must provide for an over-arching entity legally responsible for all ongoing environmental management including reclamation and rehabilitation costs in case of default by private owners. The latter should deposit an annual cash amount to such a funding body from which any surplus can be returned once the Commonwealth body has approved final rehabilitation. This concept can be extended to all upstream processing facilities.

2.11 What security implications are created by the activities of conversion, enrichment, fabrication or reprocessing of nuclear fuel, or by further manufacturing activities, in South Australia? What is the evidence which suggests that such risks might materialise? Can they be addressed and by what means?

Q 2.11 Security of all nuclear facilities must be a state responsibility (preferably a Commonwealth one). Usually environmental containment is constructed for accidental escape, not a directed one. The design and building of all facilities should incorporate anti-terrorist physical security concepts as well as environmental. Armed response should be the preserve of the Commonwealth.

2.12 What safeguards issues are created by the further participation in South Australia in activities (such as the production of uranium oxide, conversion, enrichment, fuel fabrication or reprocessing) necessary for uranium to be used as a fuel in electricity generation? Can those implications be addressed? If so, by what means? Further, would the possession of those technical capabilities give rise to strategic and policy issues for Australia? If so, what are those issues and how could they be addressed?

Q 2.12 Australia is already part of the global nuclear cycle, and cannot diminish its global responsibilities. It is already subject to numerous international treaties dealing with nuclear issues. It is proposed that a single Commonwealth entity should be responsible for all facets of the nuclear fuel cycle throughout Australia, including national and transport safeguards.

2.13 What financial or economic model or method ought be used to estimate the economic benefits from South Australia’s establishment and operation of facilities for the conversion, enrichment, fuel



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fabrication or reprocessing of, or the manufacture of materials containing, radioactive and nuclear substances? What information or data (including that drawn from actual experience elsewhere) 2.14 Would South Australia’s establishment and operation of such facilities give rise to impacts on other sectors of the economy? What would those impacts be? How should they be estimated and what information should be used? Have such impacts been demonstrated in other economies similar to South Australia?

Q 2.14 The establishment and operation of facilities for the nuclear fuel cycle should be viewed as merely another business opportunity, albeit one with peculiar environmental and security requirements. As such, the positive economic spinoff from such businesses can only improve the South Australian economy, and provide work opportunities and security for its citizens.


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Issues Paper Three: Electricity generation from nuclear fuels

Issues Paper 3 Questions SUBMISSION 3.1 Are there suitable areas in South Australia for the establishment of a nuclear reactor for generating electricity? What is the basis for that assessment?

Q 3.1 A nuclear power reactor needs to be sited for: accessibility to its market (ie it must be an integral part of the national

electricity grid to feed into it) availability of cooling water (an upside of a maritime location is the opportunity

for an ancillary water desalination plant) workforce access security access and isolation natural disaster minimisation

It is proposed that a location adjacent to the sea would be ideal, probably along Spencer Gulf. Inland locations are definitely not recommended, primarily due to the unavailability of adequate water supply, because subterranean groundwater resources do not offer sufficient recharge potential to be viable in the long term.

3.2 Are there commercial reactor technologies (or emerging technologies which may be commercially available in the next two decades) that can be installed and connected to the NEM? If so, what are those technologies, and what are the characteristics that make them technically suitable? What are the characteristics of the NEM that determine the suitability of a reactor for connection?

Q 3.2 In the interests of continuity of power availability, it is recommended that two options be investigated: (1) one large power station (viz > 1000 MWe); and (2) that Australia also investigates the proposed smaller modular reactor designs (~< 300 MWe). Modular reactor technology exists (eg US and UK Navy reactors) and a variety of technologies have been proposed (for example see the US Department of Energy Nuclear Regulatory Commission http://energy.gov/ne/nuclear-reactor-technologies/small-modular-nuclear-reactors). It is recommended that an Australian authority (State or Commonwealth) should interact closely with USDOE and other interested global entities to establish whether the concept is reasonable.

3.3 Are there commercial reactor technologies (or emerging technologies which may be commercially available in the next two decades) that can be installed and connected in an off‐grid setting? If so, what are those technologies, and what are the characteristics that make them technically suitable?

Q 3.3 As for Q 3.2, the Small Modular Reactor (SMR) concept is eminently suitable for off-grid purposes, if the concept proves economically viable. The widespread nature of Australian power demand, especially for regional resource developments, could prove suitable customers for SMR off-grid power supply.


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What are the characteristics of any particular off‐grid setting that determine the suitability of a reactor for connection?

All decision-making must recognise that a long time frame is necessary. However, putting off decision-making ostensibly for further research and enquiry is not an option.

3.4 What factors affect the assessment of viability for installing any facility to generate electricity in the NEM? How might those factors be quantified and assessed? What are the factors in an off‐grid setting exclusively? How might they be quantified and assessed?

Q 3.4 The over-riding factor must be that new power sources, NEM or off-grid, must be viewed in the context of national need, and not be subject to short-term financial arguments from private r government-owned power suppliers. If as seems likely that coal- and gas-fired power stations become politically unacceptable due to environmental contamination, then more immediate financial pain must be subsumed to the greater national requirement. This becomes a decision of political will.

3.5 What are the conditions that would be necessary for new nuclear generation capacity to be viable in the NEM? Would there be a need, for example, for new infrastructure such as transmission lines to be constructed, or changes to how the generator is scheduled or paid? How do those conditions differ between the NEM and an off‐grid setting, and why?

Q 3.5 The conditions necessary to establish viable nuclear power in Australia are political, not immediately financial. The source of electricity is immaterial to transmission, unless the new sources are located distant from the existing network.

3.6 What are the specific models and case studies that demonstrate the best practice for the establishment and operation of new facilities for the generation of electricity from nuclear fuels? What are the less successful examples? Where have they been implemented in practice? What relevant lessons can be drawn from them if such facilities were established in South Australia?


3.7 What place is there in the generation market, if any, for electricity generated from nuclear fuels to play in the medium or long term? Why? What is the basis for that prediction including the relevant demand scenarios?

Q 3.7 This submission notes that political decisions are required for successful gradual abandonment of fossil fuel burning power stations, and consequent replacement by nuclear stations for baseload power. Alternative sources such as solar, wind, and tidal power are inconstant, and future development will depend on adequate storage, for home and occasional peak demand; none will ever become sufficient for baseload demand.

3.8 What issues should be considered in a comparative analysis of the advantages and disadvantages of the

Q 3.8 The major issues include: continuity and availability of supply


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generation of electricity from nuclear fuels as opposed to other sources? What are the most important issues? Why? How should they be analysed?

price to consumers safety and security of power sources waste products training, education, and upskilling of workers ancillary industries opportunities for export of products and expertise

The first two here are of critical importance to citizens and consumers; if nuclear power is not introduced in Australia, then a genuine viable replacement for long-term source of baseload electricity must be proposed. Hence the first national decision is an indication of the quantum of electricity required for Australia over the next perhaps 50+ years; the second is the relative cost of introduction of nuclear power and phasing out of fossil fuels over the time frame. These will indicate how many nuclear stations are required and their relative outputs and locations. Analysis of these issues is a huge undertaking beyond the scope of this submission in the time frame available (apologies but I am a private citizen without adequate time).

3.9 What are the lessons to be learned from accidents, such as that at Fukushima, in relation to the possible establishment of any proposed nuclear facility to generate electricity in South Australia? Have those demonstrated risks and other known safety risks associated with the operation of nuclear plants been addressed? How and by what means? What are the processes that would need to be undertaken to build confidence in the community generally, or specific communities, in the design, establishment and operation of such facilities?

Q 3.9 The main lesson from Fukushima and other civilian incidents is that civilian processes are manifestly inadequate to devise, maintain, and oversee nuclear power generation standards and methods, being too dependent on “eye off the ball” factors rather than facing up to the critical training and oversight required to effectively and efficiently design, construct, operate, maintain, and rehabilitate the complexities of a nuclear power generator. In contrast, the rigid discipline and methodology instilled in the US Navy from the 1950s by Admiral Rickover resulted in effectively zero incidents in the last 65 years. It has been said that the US Navy can afford this record because it does not have the financial constraints of a civilian entity; however, the US Navy has always been subject to severe budget constraints imposed by political decisions of the day; the emphasis has been different but the safety standards have not slipped. Similar comments might apply to the UK Royal Navy, and its Nuclear Department. It is recommended that Australia would benefit immeasurably from introduction of a nuclear Navy (necessarily a small establishment, and almost certainly in a form of joint venture with either the Royal Navy or US Navy if possible), and the exact same methods of safety and security of operation should be inculcated in all civilian employees of Australian nuclear power stations.


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Again, all Australian nuclear facilities should be overseen by one Commonwealth entity. There should be no restriction on this entity having joint civilian and Defence staff.

3.10 If a facility to generate electricity from nuclear fuels was established in South Australia, what regulatory regime to address safety would need to be established? What are the best examples of those regimes? What can be drawn from them?

Q 3.10 As previously noted, there should NOT be separate State and Commonwealth nuclear regulatory regimes. However, South Australia has the opportunity to commence the framework to act as a model for the Commonwealth. Australia has a one-off chance to start from a clean slate and write its own modern standards for regulation and oversight of a nuclear industry, using global examples including (as also noted) from Royal and US Navy methodology.

3.11 How might a comparison of the emission of greenhouse gases from generating electricity in South Australia from nuclear fuels as opposed to other sources be quantified, assessed or modelled? What information, including that drawn from relevant operational experience should be used in that comparative assessment? What general considerations are relevant in conducting those assessments or developing these models?

Q 3.11 Much improved definitions of what exactly constitute “greenhouse gas” emitters are required; there is immense confusion as to when accounting for such emissions should start in construction of a project, and how much input should be ascribed at every stage, exacerbated by both proponents and opponents. In particular, such emissions from non-conventional technologies seem to be routinely under-assessed, while conventional fossil fuel and nuclear sources are routinely over-assessed. Life cycles are modified according to the outcome desired (eg new nuclear stations seem to be assessed on a 30-year life, whereas the first- and second-generation stations have actual lives of 60-80+ years). It is proposed that a rigid methodology be adopted by the Commission, with highly transparent definitions.

3.12 What are the wastes (other than greenhouse gases) produced in generating electricity from nuclear and other fuels and technologies? What is the evidence of the impacts of those wastes on the community and the environment? Is there any accepted means by which those impacts can be compared? Have such assessments making those comparisons been undertaken, and if so, what are the results? Can those results be adapted so as to be relevant to an analysis of the generation of electricity in South Australia?

Q 3.12 Note that the uranium content of thermal coal used for power generation globally has never come under scrutiny, which is unfortunate considering the generally high background levels of uranium and other elements in coal. These elements are not shielded as they are in nuclear stations, and there are virtually no studies on the effects of dissemination of harmful elements from coal power. The actual harmful effect is likely to be hardly measurable, but there is zero possibility of such environmental contamination from a nuclear station. Rather than reproduce information from WNA, the link to its information on waste products from a nuclear power station is given here (http://www.world-nuclear.org/info/Nuclear-Fuel-Cycle/Nuclear-Wastes/Radioactive-Waste-Management/).


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As previously proposed, a nuclear power station offers huge opportunities for the introduction of a range of associated small and large businesses, ancillary engineering, and education and training facilities.

3.13 What risks for health and safety would be created by establishing facilities for the generation of electricity from nuclear fuels? What needs to be done to ensure that risks do not exceed safe levels?

Q 3.13 This question effectively constitutes the main one being asked by Australian citizens, suffering from 50 years of negative anti-nuclear propaganda. First, “safe levels” need to be carefully defined for the spectrum of radiation and radioactive substances. The ALARA principle (As Low As Reasonably Achievable) is not only a sound safety principle, but is a regulatory requirement for all radiation safety programs. This question forms the basis for all considerations of nuclear power, and its enormous scope means that no simple submission can be made (I apologise for the brevity of this response).

3.14 What safeguards issues are created by the establishment of a facility for the generation of electricity from nuclear fuels? Can those implications be addressed adequately? If so, by what means?

Q 3.14 Safeguards are required for facility security, materials transport, disaster management, operation and maintenance, education and training. Australia has a one-off chance to start from a clean slate and write its own modern standards for regulation and oversight of a nuclear industry.

3.15 What impact might the establishment of a facility to generate electricity from nuclear fuels have on the electricity market and existing generation sources? What is the evidence from other existing markets internationally in which nuclear energy is generated? Would it complement other sources and in what circumstances? What sources might it be a substitute for, and in what circumstances?

Q 3.15 This is a political question based on whether or not fossil fuel power stations are phased out, at what rate, by when, and what is to supplant them. Design and construction of a large station (>1000 MWe) would occupy 10-15 years or more, which should be sufficient time for the electricity market to face reality. Alternative power sources are not suitable for continuous baseload power, and must be discounted in such an argument.

3.16 How might a comparison of the unit costs in generating electricity in South Australia from nuclear fuels as opposed to other sources be quantified, assessed or modelled? What information, including that drawn from relevant operational experience, should be used in that comparative assessment? What general considerations should be borne in mind in conducting those assessments or models?


3.17 Q 3.17


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Would the establishment of such facilities give rise to impacts on other sectors of the economy? How should they be estimated and using what information? Have such impacts been demonstrated in other economies similar to Australia?

Establishment of nuclear cycle facilities would impact very positively on the entire economy, offering a myriad opportunities for ancillary engineering, transport, security, education and training, upskilling, and export of technology and skills.


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Issues Paper Four: Management, storage and disposal of nuclear and radioactive waste

Issues Paper 4 Questions SUBMISSION 4.1 Are the physical conditions in South Australia, including its geology, suitable for the establishment and operation of facilities to store or dispose of intermediate or high level waste either temporarily or permanently? What are the relevant conditions? What is the evidence that suggests those conditions are suitable or not? What requires further investigation now and in the future?

Q 4.1 Storage and disposal of intermediate and high-level nuclear waste requires assessment of the risk of facility breach over a period of >10,000 years. Waste products must be isolated primarily from contact with groundwaters, and also from air. Either case would permit an unacceptable risk to life. The geological requirements are low/nil groundwater content, low/nil porosity and permeability (including fractures), and tectonic stability, over a minimum of the time frame envisaged. Note that the entire Earth is subject to relatively constant minor tectonic activity (low order earthquakes and temblors). Almost all sedimentary basins contain circulating groundwater, and should not be regarded as possible locales. This stricture effectively precludes some favourable locations which have some sedimentary basin cover. The more likely suitable zones will be in zones of volcanic and intrusive granitic material, effectively restricted to Proterozoic and Archaean terranes where major tectonic events are unlikely, and without a measurable connection to sedimentary basins. South Australian geology has been intensively studied, and the SA Geological Survey is an extremely professional and knowledgeable body. Given a set of geological constraints such as above, the two likely locations are the area associated with the Gawler Craton north of Port Augusta, and the Musgrave Ranges in the NW of the State. Detailed geotechnical drilling will be required to collect the data required for informed opinion and decisions. The requirements for the existing waste repositories in Sweden (actual) and Finland (construction) should be studied to ensure that Australia becomes a world leader in this technology.

4.2 Are there nuclear or radioactive wastes produced in Australia which could be stored at a facility in South Australia? In what circumstances would the holders of those wastes seek to store or dispose of that waste at facilities in South Australia?

Q 4.2 All levels of activity of waste could be suitable for a South Australian repository. The Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) is responsible for identifying and classifying radioactive waste, and has developed criteria and methodologies for disposal. It should continue to be responsible for all


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radioactive waste in Australia, as a subsidiary of a proposed “Australian Nuclear Fuel Authority”.

4.3 Would the holders of nuclear or radioactive waste outside Australia seek to store or dispose of that waste in South Australia? Who holds that waste? What evidence is there that they are seeking options to store or dispose of wastes elsewhere including in locations like South Australia? If so, what kinds of waste and what volumes might be expected? What would the holders be willing to pay and under what arrangements?

Q 4.3 The large volumes of low- and intermediate-level wastes, and the lesser volumes of high-level waste globally all need to be stabilised and stored. There is an opportunity for Australia to take a lead on waste storage as an ongoing commercial activity. Factors to be considered include the ability to reclaim the waste for future reprocessing with new technologies (this not a “bury and forget” issue). Business opportunities include education and training, new technologies, monitoring and remediation, as well as actual preparation for storage of the waste and its proposed cladding.

4.4 What sorts of mechanisms would need to be established to fund the costs associated with the future storage or disposal of either Australian or international nuclear or radioactive wastes? Are there relevant models in operation which should be considered? What mechanisms need to be put in place to increase the likelihood that the South Australian community, and relevant parts of it, derive a benefit from that activity?

Q 4.4 One over-riding feature of the economics of a waste storage facility will need to be an ongoing and increasing cash fund deposit for dealing with any issues arising during the life of the project. The deposit should be funded by all material owners as well as by the storage entity (Australia). Any proposed storage facility in South Australia must ensure that the associated range of business and education opportunities are offered widely to benefit the State and citizens in the long term.

4.5 What are the specific models and case studies that demonstrate the best practice for the establishment, operation and regulation of facilities for the storage or disposal of nuclear or radioactive waste? What are the less successful examples? Where have they been implemented in practice? What new methods have been proposed? What lessons can be drawn from them?

Q 4.5 Sweden has implemented a storage facility, and Finland is constructing one. Both are beset by political issues rather than technical issues. Both have involved latest technology and technical considerations, and both should be consulted in detail for advice and (potentially) a partnership.

4.6 What are the security implications created by the storage or disposal of intermediate or high level waste at a purpose‐built facility? Could those risks be addressed? If so, by what means?

Q 4.6 The location of a purpose-built waste facility will be a major factor in terms of safety and security considerations. The remoteness of possible sites in South Australia should enhance both safety and security. This submission does not address details of security.

4.7 Q 4.7


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What are the processes that would need to be undertaken to build confidence in the community generally, or specific communities, in the design, establishment and operation of such facilities?

Political will is needed to propose, convince, and maintain community confidence against what will inevitably be strident and blatantly emotional non-factual anti-nuclear propaganda. There is no substitute for education and facts, including examples from around the world of the positive and negative sides of the proposal. Being in Australia, community acceptance will almost certainly necessitate a facility being owned and operated by a Commonwealth entity, perhaps with subsidiary contractual work by private entities. Therefore a major factor should be the responsibility for the nuclear fuel cycle in Australia being a proposed “Australian Nuclear Fuel Authority”.

4.8 Bearing in mind the measures that would need to be taken in design and siting, what risks for health and safety would be created by establishing facilities to manage, store and dispose of nuclear or radioactive waste? What needs to be done to ensure that risks do not exceed safe levels? Can anything be done to better understand those risks?

Q 4.8 As before, “safe levels” need to be carefully defined for the spectrum of radiation and radioactive substances. Again, this is part of the question forms the basis for all considerations of the nuclear power cycle, and its enormous scope means that no simple submission can be made.

4.9 Bearing in mind the measures that would need to be taken in design and siting, what environmental risks would the establishment of such facilities present? Are there strategies for managing those risks? If not, what strategies would need to be developed? How would any current approach to management need to be changed or adapted?

Q 4.9 If the waste storage facility is designed to correctly mitigate and negate any effects on groundwater or air, then by definition there will be no extra environmental risks.

4.10 What are the risks associated with transportation of nuclear or radioactive wastes for storage or disposal in South Australia? Could existing arrangements for the transportation of such wastes be applied for this purpose? What additional measures might be necessary?

Q 4.10 Low- and intermediate-level wastes are already transported routinely across Australia. High-level waste will need upgraded security and containment above that normal in Australia, and Commonwealth involvement is proposed for all regulatory and oversight roles.

4.11 What financial or economic model or method ought be used to estimate the economic benefits from the establishment or operation of facilities for the storage or disposal of nuclear and radioactive waste? What information or data (including that drawn from actual experience in



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Australia or overseas) should be used in that model or method? 4.12 Would the establishment and operation of such facilities give rise to impacts on other sectors of the economy? How should they be estimated and what information should be used? Have such impacts been demonstrated in other economies similar to Australia?

Q 4.12 Establishment of nuclear cycle facilities would impact very positively on the entire economy, offering a myriad opportunities for ancillary engineering, transport, security, education and training, upskilling, and export of technology and skills.

Submitted by ANDREW BROWNE BSc (Hons); FAusIMM (CP), MCIM, MGSAust, MGSAm, MSEG Principal, GeoSynthesis Pty Ltd

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