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Transcript

JOINT COMMITTEE ON FINDINGS OF THE NUCLEAR FUEL CYCLE ROYAL COMMISSION

Submission prepared by Dan Monceaux.

The author is an unaffiliated independent researcher and documentary filmmakerresiding in South Australia, with no conflicts of interest to declare.

13 July, 2016

INTRODUCTION

During 2015 and 2016, the Nuclear Fuel Cycle Royal Commission was tasked to examine both op-portunities and risks associated with the potential expansion of nuclear industrial activity in South Australia. The Commission delivered its Final Report in May 2016- a document some 318 pages in length. Despite the overall size of this document, I believe that the Commission has not satisfied its Terms of Reference by adequately investigating risks associated with prospective nuclear industrial expansion in South Australia. It appears that economic opportunities were far more comprehensively examined. This result occurred despite of the public’s best efforts to inform and support the Commission’s work, myself among them.

In this submission, I will refer to, reiterate and expand upon statements made and evidence providedin my four personal submissions made both during the setting of the Commission’s Terms of Refer-ence and during the Nuclear Fuel Cycle Royal Commission itself. These examples serve to illustratethe problem of selectivity of inquiry. I will also elaborate on this problem, with further reference to the first Citizens’ Jury, which commenced in June and delivered its report on 12 July 2016.

As I understand it, the first Citizens’ Jury’s task was to consider the Commission’s Final Report and its recommendations, then assist the State Government in the production of a simplified summary ofit. This summary was to contain what the jury determines to be the most critical information. This will then be deliberated on by a second Citizens’ Jury, which will provide some indication to gov-ernment as to whether the citizens of South Australia are comfortable allowing the Government of South Australia to advance or implement the recommendations of the Commission.

MISSING THE BIG PICTURE?

The Commission’s recommendations include the establishment of a deep geological storage facility for spent nuclear fuel to be imported to from nuclear power generating countries.[1] While this singlerecommendation has dominated civic discussion and media reports to date, I am concerned that the public is missing what I perceive to be the big picture: that the Commission has recommended that all relevant prohibitions be repealed, so that any aspect of nuclear industrial development may be enabled in the future. The Commission’s report presents spent fuel storage as the first step in a po-tential staged expansion of nuclear industrial activity in South Australia for which it notes that bi-partisan support will be required. Waste storage facilities would enable the prospect of a nuclear

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fuel leasing scheme, which the Commission has determined could lead to further processing activities.

This is summarised on page XIV of the Final Report’s preface summary:[2]

“The Commission recommends that the South Australian Government remove at the state level, and pursue removal of at the federal level, existing pro-hibitions on the licensing of further processing activities, to enable com-mercial development of multilateral facilities as part of nuclear fuel leasing arrangements.”

In 2008 a US congress research paper named Australia as a nation which has expressed interest in developing uranium enrichment capacity for export.[3] Enrichment is but one part of a suite of pro-spective “multilateral facilities” Australia could develop in the future to service international cus-tomers and the south-east Asian region generally. This has been a topic of interest to the USA since the Gerald Ford administration, as indicated in a series of diplomatic cables from Australia’s US Embassy transmitted in 1975 and 1976.[4][5] Similarly, Japan has had an interest in establishing facil-ities for the storage and reprocessing of spent nuclear fuel in Australia since at least 1976.[6] A 2015 publication from the South Australian defence sector suggests that the reprocessing of spent nuclear fuel could also be a future consideration, and notes South Australia’s alleged suitability for co-loc-ated reprocessing and waste storage facilities.[7]

In the 1970s, reprocessing was considered controversial due to potential implications for the prolif-eration of nuclear weapons, following the separation of plutonium from spent nuclear fuel. The im-portation of spent nuclear fuel was also considered by US diplomats to be a difficult political pro-spect to sell to environmentally aware Australian people.[4]

In South Australia today, the reprocessing of spent nuclear fuel has vocal champions in former South Australian Senator Sean Edwards[8] and nuclear energy advocate, Ben Heard of ThinkClimateConsulting,[9] though both favour a novel technique not yet commercially available known as pyro-processing with alleged non-proliferation and waste reduction benefits. Should South Australia commit to receiving international stockpiles of spent nuclear fuel, future discussions regarding the establishment of reprocessing research or commercial facilities are likely to follow.

Irrespective of this, reprocessing is not mentioned as part of the fuel cycle in the report of the first Citizens’ Jury. It does not appear in the Jury’s definition- which renders it inaccurate, and incom-plete.[9b]

I believe that the South Australian people have a right to know about the implications of all relevantnuclear materials handling processes and their consequences for human health and the environment in advance of making or influencing any government decision to accept or reject spent nuclear fuel. The brevity of the Final Report’s discussion of these topics presently betrays the public interest. In fact, matters of the environmental and occupational hazards presented by reprocessing activities (using existing or future processes) were not explored in the Royal Commission’s Final Report at all. The rationale for this was so expressed:[2]

“a new reprocessing facility based on current technology would not beeconomically viable under current and likely future market condi-tions. For these reasons, and without the development of domestic nuclear power generation, there would be no need to develop a repro-cessing facility in South Australia. Given this finding, the environ-mental risks associated with the activity do not require further con-sideration.”

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I am concerned that the Citizens’ Jury currently tasked with simplifying the Nuclear Fuel Cycle Royal Commission may not comprehend the full extent of the Commission’s recommendations- thatis, that they are seeking to enable currently prohibited industrial activities across the whole nuclear fuel cycle.[1]

There are sound environmental bases for a precautionary approach to such activities (sufficient to justify the existence of current prohibitions) and I do not believe that the Commission’s final report accurately reflects these. Some significant omissions from the Commission’s final report include ANY consideration of:

• the environmental impacts of spent nuclear fuel reprocessing• incidents at nuclear industrial facilities in Tokaimura, Japan • nuclear worker health studies and compensation schemes internationally• leukaemia clusters near nuclear industrial facilities internationally• studies of effluent from nuclear processing or energy generation facilities during

standard operation

Furthermore, the implications of Chernobyl and Fukushima disasters are oversimplified, with both known and estimated harm understated. The resultant overall impression given is a biased and in-complete picture of existing and past nuclear industrial activities and their consequences.

It is important, I would argue essential, that the jurors and the wider public have access to the best available information regarding nuclear industrial activities and their implications across the entire fuel cycle. I believe that they are presently being denied this. Meanwhile, the nuclear futures of South Australia and potentially the nation lie in their hands, to a great extent.

I am concerned that the Royal Commission’s final report, and now the Citizen’s Jury’s deliberationsmay have been intended to maintain or build social license in support of prospective activities, rather than forensically analysing both opportunities and risks in an objective and even-handed manner. If so, such a design would be consistent with the defence sector’s apparent attitude toward nuclear industrial development, as expressed in 2014 by students of the South Australian Defense Industry Leadership Program. Their publication ‘A Nuclear Future for South Australia’ describes the sector’s synergies with nuclear industry. It expresses the need for a three part plan, involving a public education campaign, government policy reforms and the encouragement of private invest-ment in the sector.[6] I will return to this topic later in this submission, in the section MILITARY INTERESTS.

CITIZENS’ JURY & THE MISSING INFORMATION

On Saturday 26 June 2016, while addressing the first sitting of the Citizens’ Jury in Adelaide, Chad Jacobi (formerly Counsel Assisting the Royal Commission) said of the Commission:

“We read all of the submissions and indeed, we read all of the references that were contained in the submissions as well… I can indicate that I read all of the submissions. I can say I read all the submissions. Yes, I was verytired, but we genuinely read what was there, we genuinely looked behind what was there.”[11]

Given Jacobi’s confirmation that all submissions and their supporting references were read and considered by the Commission, the question arises: how selective or otherwise was the process of

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assembling its Final Report and recommendations? Why was certain information received not in-cluded in the Commission’s final report?

If jurors are denied access to relevant information related to nuclear hazards (by their omission fromthe Nuclear Fuel Cycle Royal Commission’s Final Report) this could be considered a dereliction of duty by the Commission. The report, since passing into the hands of the Department of the Premier & Cabinet in May 2016 has become the South Australian government’s central reference as it pre-pares a lengthy series of outreach activities around the state. Aside from brief oral presentations provided by called witnesses, this as I understand it, will be the only document considered in any detail by the Jurors.

According to Madeline Richardson, CEO of the recently formed Nuclear Fuel Cycle Royal Com-mission Consultation and Response Agency (CARA), the Government will respond to the Citizens’ Jury’s report in November 2016.[12] Whether the South Australian Government will do as the Com-mission has, and choose to disregard or withhold accurate and pertinent information from its cit-izens at this critical decision-making time is yet to be seen.

Could staff and representatives of DPC and CARA also be considered derelict in their duty, should they choose to ignore the shortcomings and omissions of the Royal Commission’s Final Report? Will they continue to repeat and refine the Final Report’s messages, which appear to be based on deliberately selective analyses?

“SAFETY... IT’S VERY MUCH TOP OF MIND”

Safety is a major theme in current civic discussions surrounding the prospect of nuclear industrial expansion in South Australia. This was reflected explicitly on Day 1 of the first Citizens’ Jury’s de-liberations, held on 25 June 2016. Facilitator Emily Jenke of democracyCo said of the jurors:

“Safety is one thing that we know is really on your minds from the survey. There was one question I think we asked, "What's on your mind?" and I think every single one of you had the word "safety" in there. I was actually look-ing at a time to see if could find one that didn't have safety, and I don't think I did, so it's very much top of mind. If that's what's on your minds, highly likely it's on the minds of everyone out there.”[13]

In spite of this shared priority, the first Citizens’ Jury did not hear from a presenter who was appro-priately knowledgeable on matters of radio-biology and the pathways and effects of exposure to nuclear materials in environmental or occupational contexts (with respect to uranium and nuclear fuel). The only medical professional to address the jurors for any significant length of time was As-sociate Professor Michael Penniment.

Penniment’s ten-minute presentation to jurors offered almost no information on nuclear hazards, biological effects, uranium or nuclear fuel. He spoke instead of the need to manage medical wastes better,[14] and neglected to inform people of the actual risks posed by exposure to ionizing radiation. Perhaps he was unaware that no-one else had spoken on this important topic.

Penniment spoke of ionizing radiation being used to “cure” cancer, without acknowledging that ex-posure, should it be uncontrolled, or poorly controlled can cause cancer to develop. He discussed sources of natural background radiation, and went so far as to trivialise the topic by showing a slide of a dog on skis while speaking of increasing background exposure at high altitudes. I would de-

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scribe the overall effect of his presentation as placatory, and he inferred his personal position was one of ‘trust the experts’.

Penniment referred explicitly to radiation’s usefulness in lung cancer detection, without discussing radon gas and its known causal link to lung cancer. He spoke of radiotherapy’s ability to cure “closeto 100%” of thyroid cancer patients,[14] without mentioning that epidemics of thyroid cancer in chil-dren have been linked to uncontrolled emissions of Iodine-131 from fallout from nuclear weapons tests[15] and nuclear power plant meltdowns at Chernobyl and Fukushima.[16]

It is my opinion that by not providing fundamental information about the connection between radi-ation exposure and the development of cancers and leukaemia, the Department of the Premier and Cabinet is preventing the jurors from being able to adequately consider risks, which being bom-barded by the opportunity of waste storage, and the numerous mechanical processes which would need to occur to enable it.

DISASTERS & ACCIDENTS

• CHERNOBYL

In his presentation to the jurors, Penniment went on to describe the consequences of Chernobyl in-correctly, stating that only 28 people died as a result of the incident, and that those were the first re-sponder clean-up workers. This misinformation conflicts with all recent accounts of the disaster, in-cluding those published in the Nuclear Fuel Cycle Royal Commission’s own Final Report. No-one present in the room was able to correct him, which likely reflected those present’s lack of familiar-ity with the contents of the NFCRC’s report. There are many complexities involved in assessing the human health impact of the Chernobyl disaster, and the topic’s article on Wikipedia helps explain these, with many inline citations.[17]

Penniment referred to the “fallacy of radiation” claiming that 1500 people took their own lives as a result of fear of radiation. I have been unable to corroborate this figure, but I must say that widely contrasting accounts of the suffering of the liquidators exist. For example, the Chernobyl Founda-tion says of the liquidators:

“The initial Chernobyl cleanup operation took many lives and contributed to an enormous number of people living with disabilities. The total number of liquidators is estimated at 830,000 – most of them were young military sol-diers aged 18 to 22 years old. Approximately 20% of all the liquidators diedby 2005, most of them passing away in their 30s and 40s.

Out of those who are still alive, 90% became inundated with disabling healthproblems such as: thyroid cancer, leukemia, heart & cardiovascular diseases,mini-satellite mutations, different solid cancers, and respiratory diseases.

Today, Chernobyl liquidators represent the highest risk group; both in termsof their health and the future health of their children.”[18]

Honest appraisals of the Chernobyl disaster admit that the full human health consequences of the fallout from Chernobyl disaster will never be known, and estimates of deaths vary from thousands of excess cancer and leukaemia cases to tens of thousands and even greater. Proving a causal link between exposure to Chernobyl fallout and the development of cancers and leukaemia is highly problematic but the members of the Citizens’ Jury need to hear of these uncertainties to aid their own evaluations of opportunities and risks.

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I supplied evidence to the Commission for its consideration demonstrating the different approaches taken to measuring and estimating the human health consequences of Chernobyl in my submission to the Tentative Findings. I had hoped that the Commission would compare these with its own refer-ences to UNSCEAR and the WHO. No such comparisons were reflected in the Final Report.

The documents provided to the Commission were:

1. Pflugbeil, S. et al. ‘Health Effects of Chernobyl - 25 years after the reactor catastrophe’.German Affiliate of International Physicians for the Preventions of Nuclear War (IPPNW). Berlin, Germany, 2011. http://www.chernobylcongress.org/fileadmin/user_upload/pdfs/chernob_report_2011_en_web.pdf .[19]

2. Fairlie, I. et al. ‘The Other Report on Chernobyl (TORCH) - AN INDEPENDENT SCIENTIFIC EVALU-ATION OF HEALTH AND ENVIRONMENTAL EFFECTS 20 YEARS AFTER THE NUCLEAR DISASTER PROVIDING CRITICAL ANALYSIS OF A RECENT REPORT BY THE INTERNATIONAL ATOMIC ENERGY AGENCY (IAEA) AND THE WORLD HEALTH ORGANISATION (WHO)’. Berlin, Brussels & Kiev, 2006. http://chernobylreport.org/torch.pdf . [20]

• FUKUSHIMA

In the case of the 2011 Fukushima disaster, the Commission’s final report fails to reflect the gravity,extent of harm and technical complexities related to the incident and the response thus far. In my Tentative Findings submission in March 2016 I wrote:[21]

“[The Commission] should detail the known extent of the consequences of the Fukushima disaster to date… [it] neglects to mention the number of people evacuated, the area of land evacuated, the inability for existing technology to resist the heat and radiation emitting from the molten reactor cores, the ongoing discharges of contaminated water to the sea, the deaths of citizens including suicides resulting from displacement from their homes, and the in-crease of childhood thyroid abnormalities, including cancers. These are graveomissions, and I interpret them as an attempt to paint an artificially favor-able picture of the event and its consequences.

The Commission's conclusions reached… regarding the Fukushima disaster are based exclusively on UNSCEAR's conclusions, which no longer represent the best available data. In October 2015, 137 children from the Fukushima Prefec-ture were described as either being diagnosed with or showing signs of devel-oping thyroid cancer. The study's lead author Toshihide Tsuda from Okayama University has stated that the increased detection could not be accounted forby attributing it to the screening effect. He described the screening resultsto be "20 times to 50 times what would be normally expected."

https://en.wikipedia.org/wiki/Fukushima_Daiichi_nuclear_disaster#Thyroid_screening_program

Another statistic worth the Commission including in its final report is the number of cases of suicide linked to the Fukushima disaster. As of November 2015, these totaled 154 according to the Japanese Cabinet Office. At that time, 24,000 people in Iwate and about 55,000 in Miyagi were still living in temporary housing away from their homes while in Fukushima, the number was approximately 103,000. The humanitarian impact caused by the evacuation zone and resulting in approximately 182,000 disaster refugees is a substantial risk deserving of detailing in the Commission's findings.

http://ajw.asahi.com/article/0311disaster/fukushima/AJ201512280026

It is also worth noting that the Commission has neglected to mention the un-certain fate of the molten reactor cores, and the inability for existing technology to be deployed to assess their status, due to the heat and radi-ation they continue to emit.

http://phys.org/news/2015-03-fuel-fukushima-reactor-tepco.html

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Japan is relying on future technological developments in order to recover thecorium from the crippled reactors, and is yet to observe the location and condition of it. Periodic news updates from the Japanese Atomic Energy Agencyprovide the most recent status of developments, though they do not describe the fate of robots used previously, which have not survived the conditions within the reactor building.

http://fukushima.jaea.go.jp/english/topics/pdf/topics-fukushima070e.pdf

http://fukushima.jaea.go.jp/english/topics/pdf/topics-fukushima071e.pdf

The most important information for the Commission to responsibly convey is that the full extent of the Fukushima disaster's consequences are unlikely toever be known. Radioactive cooling water continues to be discharged to the sea, bags of contaminated soil and vessels of cooling water continue to accu-mulate within the exclusion zone. The human health impacts of initial air-borne emissions will take decades to manifest, and will be difficult to link definitively to exposure.

Information regarding the Fukushima nuclear disaster, synthesized from an ex-tensive number of references can be found on Wikipedia, in the following art-icles:

https://en.wikipedia.org/wiki/Fukushima_disaster_cleanup

https://en.wikipedia.org/wiki/Fukushima_Daiichi_nuclear_disaster

The economic cost estimates associated with the Fukushima nuclear disasterare significant, and the Commission should acknowledge these. In July 2015, the Japanese government confirmed that compensation exceeding US$57 billion was expected to be paid out. These costs are expected to rise as further lawsuits are mounted.

http://phys.org/news/2015-07-tepco-fukushima-compensation-bn.html

Estimates of the wider economic costs of the disaster range from US$105 billion to US$500 billion. Sources for such estimates are listed below.

https://www.rt.com/news/183052-japan-fukushima-costs-study/

http://www.psr.org/environment-and-health/environmental-health-policy-institute/responses/costs-and-consequences-of-fukushima.html

Very little (quite possibly none) of the above information is reflected in the Final Report of the Nuc-lear Fuel Cycle Royal Commission. Furthermore, since providing this submission, I have learned that childhood thyroid and suspected thyroid cancers had continued to increase to 166 cases in Fukushima prefecture prior to the end of 2015. While the cause remains a topic of some contro-versy, additional scientists have expressed agreement that the excess cannot be attributed to the aforementioned screening effect.[22]

Additionally, the first case of a Fukushima clean-up worker developing leukaemia linked to his oc-cupational exposure to ionizing radiation was announced in October of 2015.[23]

• TOKAIMURA

I provided the example of Tokaimura as a case study on the hazards of further processing for con-sideration during the call for submissions related to the Royal Commission’s Issues Papers. I wrote in my submission: [24]

Tokaimura's history reads as a warning of the many hazards associated with uranium enrichment and spent fuel reprocessing. In the 1970s, the Carter gov-ernment in the USA was concerned that enrichment technology being developed in Japan could potentially leak to states or organisations seeking to developnuclear weapons capabilities.

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http://www.newspapers.com/clip/2977222/japans_tokaimura_gaseous_diffusion/

Another concern was the potential for diversion of plutonium for nuclear weapons production.

http://www.newspapers.com/clip/2977299/slate_meet_on_japans_nuclear_plant/

Concerns regarding the separation of uranium and plutionium via spent fuel reprocessing were realised, when 70 kilograms of plutonium was reported 'lost' in 1994.

http://www.newspapers.com/clip/2977398/plutonium_missing_from_nuclear_plant/

A lackadaisical approach to safety was later attributed to major accidents atTokaimura in 1997 and 1999. The first event saw two fires start within 10 hours at the facility, damaging plant and exposing 37 workers to elevated levels of radiation.

http://www.newspapers.com/clip/2977412/japanese_nuclear_plant_has_two_fires/

While the environmental impact of the event was downplayed, video footage re-vealed the intensity of the blast, and its proximity to nuclear waste.

http://www.newspapers.com/clip/1956750/video_shows_evidence_of_powerful_blast/

Despite officials assuring people that there was no public safety risk, elev-ated levels of Cesium, a product of the fission process, were detected 35 miles distant from the site.

http://www.newspapers.com/clip/2977436/greater_radiation_leak_hinted/

Another accident in 1999 accident resulted in two fatalities following a criticality incident which occurred during an improvised liquid uranium mix-ing process. Two workers received fatal doses of radiation and died several months later, a third exposed worker was severely injured, but survived. The IAEA described the cause of the accident as “human error and serious breachesof safety principles.“

https://en.wikipedia.org/wiki/Tokaimura_nuclear_accident

The Nuclear Fuel Cycle Royal Commission’s Final Report made no mention of the nuclear facilitiesat Tokaimura, Japan or any of the events or incidents listed and referenced above.

NUCLEAR OCCUPATIONAL HAZARDS

The occupational hazards of employment in nuclear industrial activities was a recurring theme in each of my four written submissions provided to the Department of the Premier & Cabinet and Royal Commission during 2015 and 2016.[24][21]

Safety-related recommendations made during consultation for setting the Terms of Reference for the Royal Commission included:[25]

“MINING • Review of Radium Hill epidemiology study (1990s) and update with new data on subsequent health developments, including lung cancer mortality • Epidemiology study of fate of Wild Dog Hill underground miners

PROCESSING & ENRICHMENT

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• Cancer epidemiolgy study of Port Pirie uranium processing plant workers (1954-1961) • Review of existing worker safety protocols at Olympic Dam, Beverley and Honeymoon processing plants, with respect to ionising radiation and inhala-tion/ingestion of alpha emitters (ie. Radon gas and its progeny) • Comparison of current safety practise in SA with 'world's best practise' inother jurisdictions • Review of safety record of enrichment and fuel reprocessing industries and facilities worldwide including fuel recycling plants”

SUBMISSION TAMPERING!

I proceeded to explore these themes and others relevant to the Commission in my next Terms of Reference submission, submitted in March 2015. When revisiting this submission on the YourSAy website, I was shocked to discover that all seven of the web links that I provided as sources support-ing my assertions had been tampered with prior to their republication, rendering them broken and useless. This occurred without my knowledge or consent, and I consider this to be a malfeasant act, likely intended to block readers’ access to relevant sources of information. The seven doctored linksand their subjects are tabled below (doctored letters are highlighted in red):[26]

Submitted (original) link

Published (tampered) link

Subject of reference

http://www.gao.gov/assets/100/9516 0.pdf

http://www.gao.gov/assets/100/9516Q.pdf

Report from the US Government’s General Accounting Office (2007) re-garding the status of compensation paid under the USA’s Radiation ExposureCompensation Act which showed that $US 1.2 billion dollars had been paid out to successful claimants.

htt p ://www.ianfairlie.or g /news/childhood-leukemias-near-nuclear-p ower-stations-new-article/

httD://www.ianfairlie.ore/news/childhood-leukemias-near-nuclear-Dower-stations-new-article/

Evidence that “world-wide, over 60 epidemiological studies have examined cancer incidences in children near nuclear power plants (NPPs): most (>70%) indicate leukemia increases.”

htt p ://www.case-fl.or g /content/short-latency-between-radiation-ex p osure-nuclear-p lants-and - cancer-y oung-children

httD://www.case-fl.ors/content/short-latencv-between-radiation-exDosure-nuclear-Dlants-and*cancer*voung-children

*denotes deleted character

American study of leukemia and cancer risks to children under 10 years old in the USA, from fallout and proximity to nuclear power reactors.

Original link is now also broken. An archived copy is available at: http://web.archive.org/web/20160308151444/http://case-fl.org/content/short-latency-between-radiation-exposure-nuclear-plants-and-cancer-young-children

htt p ://www-p ub.iaea.org/books/IAEABooks/10756/Nuclear-Power-Reactors-in-the-World-2014-Edition

httD://www-Dub.iaea.ore/books/IAEABooks/10756/Nuclear-Power-Reactors-in-the-World-2014-*******

*denotes deleted character

Book recommended to assist the Commission with considering “the ra-tionales behind different countries’ wide-ranging positions and variable com-mitment to or withdrawal from nuclear power generation.”

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htt ps ://en.wiki p edia.or g /wiki/Breeder_ reactor#Fast _ breeder _ reactor

httDS://en.wikiDedia.ore/wiki/Breeder reactor#Fastbreeder reactor

Article about fast breeder reactors on Wikipedia.

htt ps ://en.wiki p edia.org/wiki/Mon j u _Nuclear_Po wer _ Plant

httDS://en.wikiDedia.org/wiki/Moniu Nuclear Power Plant

Article about Monju fast breeder reactor, Japan, on Wikipedia. Contains in-formation regarding US$9.8 billion total cost for 1 hour of electricity gener-ated, weapons proliferation risks, accidents and a whistleblower suicide.

htt ps ://en.wiki p edia.or g /wiki/Clinch _River _ Breeder _ Reactor _ Project

httDS://en.wikiDedia.ors/wiki/Clinch River Breeder Reactor Project

Information on unrealised Clinch River Breeder Reactor project, including scope creep and cost blow-out from $400 million to $8 billion, including tax-payer funds. Alleges that bribery and fraud contributed to cost.

UNDERGROUND MINERS

It is a simple fact that the South Australian Department of Mines had knowledge of the human health implications Radium Hill miners were likely to face, prior to the establishment of the under-ground mine. This is reflected in two documents that I presented to the Commission in my TentativeFindings submission. I provide a condensed summary below, but would encourage the Committee to consider pages 4-7 of my original submission.[21]

Underground uranium mine workers are exposed to elevated levels of radon gas, and can inhale andingest its decay products, which attach themselves to dust in the environment. Internal exposure to ionizing radiation via inhalation, and the deposition of particles in the lung resulted in elevated in-cidence of lung cancer in Radium Hill workers at the mine,[27] despite the mine’s relatively short lifeof seven years. The precautionary measures described in South Australian Department of Mines documentation from 1954 and 1956 (which related to mine ventilation and dust control measures) proved insufficient to prevent loss of health and subsequent to employment, loss of life.

Such losses could have been reduced if advice given prior to the mine’s establishment had been ad-equately implemented. These losses remain uncompensated, despite the USA, which guided South Australia in the establishment of Radium Hill and its associated processing plant at Port Pirie, even-tually establishing a compensation scheme for contaminated workers or their surviving relatives.

In my submission in response to the Royal Commission’s Tentative Findings, I pointed out that the United States Government has compensated uranium miners, mill workers and ore transportation workers under Radiation Exposure Compensation Act since 1990. Claims continue to be honoured, and awarded claimants (or their surviving relatives) number 6,244 uranium miners, 1,687 uranium millers and 332 ore transporters at 11 July 2016.[27]

Despite its clear relevance to the occupational health and safety of uranium miners in Australia, no reference was made to the Radiation Exposure Compensation Act in the Royal Commission’s Final Report.

The Commission’s Final Report makes the claim that conditions for workers in underground uranium mines in Australia have improved since the closure of Radium Hill in the 1960s. While thismay be so in theory (due to the provision of protective equipment and improved mine ventilation)

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the only way to prove that modern uranium miners are not suffering from internal contamination from ionising radiation originating from radon gas and radon daughter is by conducting long-term health monitoring and epidemiological studies. No such epidemiological studies have been conduc-ted on the Olympic Dam worker cohort, nor for any of Australia’s other past or present uranium mines. I made this point in multiple submissions prior to and during the Commission, yet it was not reflected in the report, and no indication has been given that such studies should be undertaken.

I recommended that the Commission consider undertaking epidemiology studies to assess worker cohorts from the Port Pirie Uranium Treatment Plant, the Wild Dog Hill uranium mine and OlympicDam, but the recommendation was not acted upon. It appears that we are expected to place faith in regulation alone, and not seek the reassurance of long-term health studies with statistical power.

Equally troubling is the way that the Department of State Development today continues to wilfully deceive the general public with respect to the hazards of ionising radiation among uranium workers.In December of 2015, during the undertakings of the Nuclear Fuel Cycle Royal Commission, Min-ister Tom Koutsantonis proudly endorsed a new brochure and website entitled “Uranium: The Facts”. Both pose the question “Is uranium safe?” then provides the graphic below in response.[29]

Given the paucity of information provided, readers could be forgiven for assuming that uranium is no cause for concern, when this is not the case. The document is ambiguously deceptive and yet re-mains online. In my submission in response to the Commission’s Tentative Findings, I pointed out that the Department of Mines has had much more accurate and detailed information in its posses-sion since at least the mid-1950s. I quoted directly from these, providing the Commission with de-tailed information which was not referred to in the Final Report.

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I would encourage Committee members to read pages 4-7 of my Tentative Findings submission for more detail on this topic. [21]

OTHER NUCLEAR WORKERS

Since preparing my past submissions, I have looked further into international health studies of nuc-lear industry employees. Medical literature on the subject of uranium miners’ health date back to at least as early as 1939. Cohorts from Germany[30], Spain[31],Czechoslovakia,[32] France,[33] Canada,[34] the USA[35] and Australia (Radium Hill)[27] are consistent in describing risks and detailing con-sequences of occupational exposure to radon gas and radon progeny, primarily increased incidence of lung cancer in smoking and non-smoking uranium miners. The French cohort study succinctly states that its results “confirm the existence of a risk of death from lung cancer in a population chronically exposed to relatively low levels of radon.”[33] A Czech cohort study revealed that “incid-ence of all leukaemia combined and chronic lymphocytic leukaemia (CLL) alone was positively as-sociated with cumulative radon exposure.”[36]

Other epidemiological studies have been made of worker cohorts in other categories of nuclear in-dustrial employment. A study of French nuclear workers found that “The risk of leukaemia in-creases with increasing exposure to external radiation; this is consistent with published results on other nuclear workers cohorts.”[37] Uranium mill workers in the USA have been shown to experiencevarious kidney problems,[38] which eventually led to their eligibility for compensation under the Ra-diation Exposure Compensation Act. They also experienced increased incidence of Hodgkin’s dis-ease, respiratory disease and pneumoconioses.[39] A study of uranium processing workers at Fernald Feed Materials Production Center (FFMPC) in Ohio revealed elevated incidence of lung and radio-sensitive solid cancers.[40] A study of French nuclear workers revealed that “exposure to slowly sol-uble uranium compounds, notably reprocessed uranium compounds, may increase the risk of circu-latory system disease mortality.”[41] A study of mortality of workers exposed to uranium compounds at a uranium processing facility, the Linde Air Products Company Ceramics Plant, showed elevated incidence of laryngeal cancer and pneumonia.[42] Excess laryngeal cancer incidence has also been detected in Czech uranium miners.[43] A study in Namibia showed that “miners exposed to uranium are at an increased risk to acquire various degrees of genetic damage, and that the damage may be associated with an increased risk for malignant transformation.”[44] Workers at plutonium and repro-cessing facilities in Mayak in the former USSR developed elevated incidence of lung cancer.[45] Maintenance workers at the Oak Ridge National laboratory were found to have elevated incidence of leukaemia (though not statistically significant).[46]

At a press conference held by the Nuclear Fuel Cycle Royal Commission on the day of the release of its Final Report, I asked Commissioner Scarce about occupational hazards faced by employees atvarious stages of the nuclear fuel cycle. A video recording of the press conference was published on 9 May 2016. My exchange with the Commissioner is transcribed below:[47]

DAN MONCEAUX

Commissioner, to what extent did your team consider the elevated incidence of leukaemias and cancers among nuclear employees within the fuel cycle in other regions, and what are their implications for your work?

KEVIN SCARCE

Well, there's a.. you'd have to say the evidence is mixed on that. There were reports earlier that the incidence of rates amongst nuclear workers wasmuch higher than average. And a later report I saw, that that evidence was not accepted.

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DAN MONCEAUX

There are actually many decades of medical literature which show this as a recurring theme. There are elevated...

KEVIN SCARCE

No, I understand Dan, that you think there's this connection. What I'm say-ing to you is, in the reports that I've seen from UNSCEAR also the World Health Organisation, organisations that have been established following Chernobyl and those accidents, that that linkage is not there or is yet to be proven. So the answer to your question is, we've had a group of four ra-diologists and radiological experts review this, review the data that we've used, review the report. They're from all over Australia. And they're com-fortable that this is an accurate reflection of what we know at the moment.”

The Commissioner’s response to my question and correction demonstrate that the Commissioner was at that time unaware of the problematic nature of the elevated risk of cancers and leukemias ex-perienced by nuclear industry workers, despite my submissions. This also confirmed that the evid-ence I provided to the Commission was ignored, either wilfully or negligently. I reach this conclu-sion with confidence, given Chad Jacobi’s recent admission that all submissions were read by the Commission, and by him personally.[11] I have received further confirmation from the Royal Com-mission’s Chief of Staff, Greg Ward that Chad Jacobi was the chief author of the final report. If Jac-obi read all of my submissions, what cause did he have to ignore the evidence that I provided?

How many other people or organisations provided information from reputable sources which was similarly omitted from the final report? Is this outcome acceptable? To what extent was the Com-mission working for or against the public interest in the conduct of their inquiry?

NUCLEAR FACILITY EFFLUENT & EMISSIONS

In my submissions to the Commission, I drew attention to several studies which identified or ana-lyses clusters of leukemias in close proximity to nuclear facilities. In response to the Commission’s claim that nuclear facilities operate within regulations, I wrote:[21]

“Finding #119: Data from modern nuclear fuel cycle facilities demonstrates that they operate well within the applicable regulatory limits for worker, the public and the environment.

While this may be so, assurance can only be given with confidence pending theresults of long term health studies. A recent decision to discontinue a long term investigation into the health of Americans living near nuclear facilit-ies in the USA is deserving of question. Why was the study terminated prema-turely? Surely if people had nothing to worry about, having evidence to sup-port this position would have been welcome news to the nuclear industry. Whatcan be said of the probability that the news was, in step with past claims and predictions, that assurances of safety were prematurely confident and overstated?

http://www.southernstudies.org/2015/09/feds-cancel-nuclear-health-study-leaving-questions.html

We will never know, unless the study is resumed. However, other studies of the health of people living in proximity to nuclear power plants have been conducted in other jurisdictions and by other organisations. Some of these have encouraged further research after detecting elevated incidence of child-hood leukemia. Examples below:”

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France: http://www.sortirdunucleaire.org/IMG/pdf/Childhood-leukemia.pdfGermany: https://www.nirs.org/radiation/radhealth/kikkcommentary0709ijoeh.pdf

The Commission chose not to include this controversial subject in its final report, despite a prelim-inary search revealing a substantial number of peer-reviewed medical research papers exploring thistopic.

On the related topic of effluent generated by nuclear facilities, I am not satisfied that the commis-sion adequately explored the risks associated with power generation or further processing emissionsunder standard operating conditions. While the Commission considered the extraordinary events of Chernobyl, Fukushima and Three Mile Island, no effort was invested in understanding the emis-sions to air, water and land associated with facilities’ regular operation.

In my 2015 submission to the Royal Commission, I provided a reference to a detailed characterisa-tion of effluent in the Irish Sea resulting from the operation of various nuclear facilities in the United Kingdom.[24] The Commission’s final report gives no indication that this evidence was con-sidered.

The document I provided is cited and linked below:[48]

• Kershaw, P.J., Pentreath, R. J., Woodhead, D.S., Hunt, G.J., ‘A review of radioactivity in the Ir-ish Sea – A report prepared for the Marine Pollution Monitoring Management Group’ Aquat. Environ. Monit. Rep., MAFF Direct. Fish. Res., Lowestoft, (32): 65pp. https://www.cefas.co.uk/publications/aquatic/aemr32.pdf . Accessed 2016-07-13.

I also raised the topic of airborne emissions, giving the example of Krypton-85, which is released from spent fuel during reprocessing. I wrote in my Tentative Findings submission:

Reprocessing spent fuel has a unique pollution profile. One pollutant of noteis the noble gas Krypton-85, which is released to the atmosphere. Naturally occurring Krypton-85 in the atmosphere retains equilibrium at 0.09 Pbq and isproduced by the interaction of cosmic rays with stable Krypton-84.

Year Atmospheric Kr-85 inventory

Pre-WWII 0.09 Pbq(estimate based on naturally occurring Kr-85 production by cosmic rays)

1973 1961 PBq

2000 4800 PBq

2009 5500 PBq

In 2009, the global inventory represented 61,111 times the naturally occur-ring background concentration.

Clearly there is a case for investigating the consequences of such an in-crease, resulting almost exclusively from nuclear fuel reprocessing. The onlyother anthropogenic sources of Krypton-85 in the atmosphere are the testing of nuclear weapons, or nuclear accidents such as Three Mile Island, Chernobyland Fukushima. Contributions from such events are small and occasional when compared to the emissions resulting from the ongoing reprocessing of spent nuclear fuel. Krypton-85 is radioactive, and has a half-life of 10.8 years. It has the potential to alter the electrical conductivity of the atmosphere, and while not a greenhouse gas in the conventional sense, has a poorly under-stood potential to alter weather. Research into the implications of increas-ing presence of Krypton-85 in the Earth's atmosphere is lacking and in my opinion, deserving of investigation.

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Krypton-85 inventory data sources and references are available at: https://en.wikipedia.org/wiki/Krypton-85

Ultimately, the Commission chose not to investigate the characteristics of nuclear facility effluents, their environmental impacts or human health implications. Spent fuel reprocessing was the most neglected further processing activity, despite this being potentially enabled in a future multi-lateral nuclear industrial development scenario for South Australia.

NUCLEAR FUEL LEASINGThe Final Report refers to the prospect of establishing a nuclear fuel leasing scheme in South Aus-tralia, contingent on the establishment of a permanent storage facility for spent nuclear fuel. The re-port then goes on to say that such a program could provide a competitive advantage capable of im-proving prospects for the development of additional uranium processing activities in South Aus-tralia.

The report states:[2]

“There could be a potential competitive advantage if further processing ser-vices were linked with a guarantee to take back used fuel for permanent dis-posal. This concept of fuel leasing could in turn provide additional employ-ment and technology-transfer opportunities. The Commission recommends that the South Australian Government remove at the state level, and pursue removalof at the federal level, existing prohibitions on the licensing of further processing activities, to enable commercial development of multilateral fa-cilities as part of nuclear fuel leasing arrangements.”

This process of gradual expansion into enrichment and fuel processing is summarised as follows:[49]

Step 1: the operator of the South Australian geological disposal facility seeks to partner in a fuel leasing arrangement with either a major LWR vendorcompeting in the market for new-build large nuclear power plants… [or] a ma-jor SMR vendor competing in the market for new-build small nuclear power plants... [and] a nuclear fuel vendor, and/or large nuclear utilities, whichare experienced in obtaining uranium and other front end services as re-quired.

Step 2: If successful over time, sufficient business volume may accumulate tojustify investment in multilateral conversion and enrichment facilities in South Australia, the products of which can be integrated into the fuel leas-ing arrangement. This would include considering partnerships with existing commercial entities engaged in delivering those services, or seeking to com-mercialise new technologies for the delivery of such services, through new facilities in South Australia.

By my assessment, these statements reveal the broader intent of the Commission’s recommenda-tions, yet this information is buried deep inside the body of the Final Report. The Commission sug-gests that South Australia work with established nuclear industrial players to add value to the cur-rently exported product: uranium oxide concentrate.

Regrettably, the first Citizens’ Jury’s report doesn’t reflect the apparent ‘big picture’ plan, which leaves me concerned that South Australians more broadly will continue to debate the merits or oth-erwise of high-level nuclear waste transportation, receipt, storage and disposal, without understand-ing further reaching implications of expanding into further processing activities.

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The only comparable service to the proposed nuclear fuel leasing scheme that the Final Report ad-vocates for, exists in Russia. The report states:[49]

“Despite significant international analysis and discussion, Russia is the only country to date to undertake a type of fuel leasing service, via the state-owned Rosatom Overseas Inc. (Rosatom). Rosatom offers international customers a variety of integrated services associated with the construction and operation of its nuclear power plants, including guaranteed fuel supply, and take-back of used fuel for storage and eventual reprocessing. Russia, however, does not have a permanent repository for the long-term disposal of nuclear waste. A number of countries, such as Iran, Turkey and Vietnam, have entered agreements with Rosatom for nuclear power plant construction combinedwith fuel supply and take-back services, indicating that such services are potentially viable as part of a bundled offering. Other nations have also ex-pressed positive interest in the fuel leasing concept.”

Is Australia, along with its allies seeking to establish a multi-lateral nuclear fuel centre in South Australia, to serve as a Western block competitor to Russia’s offering?

MILITARY INTERESTS?The Nuclear Fuel Cycle Royal Commission’s Terms of References specifically excluded explora-tion of the military uses of nuclear materials.[50] This decision prompted me to question the appro-priateness of the appointment of two senior defense industry professionals to positions of Commis-sioner and Chief of Staff. Additionally, the Commissioner lacked any legal or relevant scientific background, placing him at a gross disadvantage. The overwhelming majority of past South Aus-tralian Royal Commissions since World War II have appointed either a serving or retired Supreme Court Justice to the position of Commissioner.[51]

Such a qualification is appropriate, and arguably necessary, given that any Commissioner’s task is to evaluate evidence from which conclusions relevant to its Terms of Reference are based. By com-parison, the relevance of the Commissioner’s professional experience as a former Rear Admiral RAN remains unclear. With respect to his former role as Governor of South Australia, Scarce told Defense SA magazine in 2010:[52]

“My major role as Governor is helping to sell the opportunities of investing in South Australia. I welcome visiting delegations and travel overseas help-ing to promote the state’s capabilities and aspirations.”

Such a statement supports the skeptical view held by parts of the South Australian community that the Commission was in part a trade delegation designed to support an economic objective. So why was the Commissioner selected for this task?

If the Australian defense sector has an interest in developing nuclear materials handling and pro-cessing capacity, or building upon the existing social license to mine uranium in South Australia, I believe that South Australians have a right to know about it.

The fact is that it does, and this has been expressed publicly in discussions regarding the prospect ofa hybrid (mixed or combined) fleet of diesel-powered and nuclear powered submarines for the Fu-ture Submarine Project. The Barracuda-class submarine is natively nuclear powered, where compet-ing designs did not offer a potential nuclear option. The Department of the Premier and Cabinet act-

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ively pursued this design as part of its France Engagement Strategy, which continues in financial year 2016-17.

It was also expressed in a paper produced by students of the South Australian Defense Industry Leadership Program in 2014 that the defence sector could benefit in numerous ways should South Australia extend its role in the nuclear fuel cycle. It states:[10]

“We believe it is time that Australian political parties, industry, and aca-demia steer Australia towards a much larger and more significant nuclear fu-ture.”

Specific opportunities are explored in the 2014 paper, and in another produced in 2015. Key quotes are provided below:

“South Australia is renowned as being the driest State on the driest Contin-ent. These dry conditions and the geologically stable landform present idealphysical conditions for the co-location of a nuclear reprocessing plant and storage capability.”[7]

“Primary opportunities are in contributions to facilities construction, op-eration and maintenance. Some facilities are heavily automated and have a clear dependency monitoring the plants behaviour. Skills of companies such as Schneider Electrical and Sage Automation who supply electrical and logic controller equipment are applicable. These two companies support Defence In-dustry in variety of areas such as air (F/A-18 Hornet fighter), land (Land Vehicles) and sea (AWD, Collins class).”[7]

“Short‐term, the Defence Industry involvement in a nuclear industry could beaimed at design and manufacture of technological components, with the longer‐term trend to support an expanding nuclear industry perhaps in en-richment or power generation.”[10]

“Design localisation, logistics, and local content requirements present the initial opportunity for established Defence Industry companies to enter the nuclear industry at Tier 3 or 4. From here, capability can be built and roles expanded; with support from an overseas prime this is achievable.”[7]

“Perhaps the greatest challenge to the cradle‐to‐grave supply and managementnuclear cycle is security and transportation of the processed radioactive product. The local Defence Industry security and transport industries, well‐versed in dealing with sensitive, dangerous, and often highly classified ma-teriel would be able to tackle such roles.”[10]

“There is also a requirement for the [transport] vessels to have naval guns for defence against threats and to prevent nuclear proliferation. With the Common User Facility (CUF) at Techport there is the potential that new or retrofitted ships could be designed, built or modified to transport these transport casks, there is also the potential to service and maintain these vessels in the facility.”[7]

“The establishment of a nuclear industry will provide a clear and ongoing benefit for local SA defence industry in particular, as the characteristics of the two industries have some interesting parallels. The similarities in-clude their highly regulated environments; the high quality and precision requirements in manufacturing; the safety and security constraints of the work environments; the leading edge manufacturing techniques employed; work-ing with ‘unusual materials’; and a commonality in cultures of workers and managers operating in a tightly constrained and monitored industry. The op-portunities for software and hardware engineers with defence experience in safety‐critical system design and development would translate well into par-allel activities associated with a nuclear industry.”[10]

“Beyond serving as a demand leveller for the Defence Industry, participationin the Nuclear Fuel Cycle would offer companies many spill-over benefits,

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and could usher in the next era of Australian advanced manufacturing and technology. There are clear parallels between the Defence and nuclear in-dustry, such as high tech, high precision, safety critical and regulatory requirements. These synergies can be easily transitioned between the indus-tries with some minor upskilling required.”[7]

The 2015 paper proceeds to list companies established as defence sector contractors, and how they could benefit. Included are: Schneider Electrical, SAGE Automation, Palamir (which provides “Big Data” analysis services), companies producing advanced sensor technology, Dedicated Systems (which currently resells for suppliers who serve the nuclear industry), the Defense Science & Tech-nology Group (which currently collaborates with the Australian Nuclear Science and Technology Organisation), RGM Maintenance (which maintains specialised transport vehicles) and Tactical Training, which trains security personnel.[7]

CONCLUSIONI am deeply concerned that public discussion during the course of the Royal Commission and since its conclusion has been dominated by the economic opportunity presented by waste storage alone. While I accept that an opportunity to profit from receiving international shipments of used nuclear fuel for storage and disposal may exist, what concerns me is the apparent reluctance for the Com-mission to look as deeply into other matters.

I am concerned about the consequences of a variety of nuclear fuel cycle activities and incidents (Fukushima, Chernobyl, Tokaimura), about effluent and emissions from nuclear facilities and about occupational health and safety (contamination, worker compensation schemes and epidemiological studies). I don’t believe that the Royal Commission has done these matters justice.

I also believe that the Commission has failed to adequately explain the risk of excess exposure to ionising radiation, and its biological effects, most notably the topics of internal contamination and chronic low dose exposure (as one might expect in future nuclear industrial employment).

I hold the firm belief that an informed public can and should make informed decisions about its ownfuture. By comparison, the selective provision of information to the citizenry by Government or a public inquiry can lead to biased, politically and/or financially motivated outcomes. The apparent selectivity of the Royal Commission’s inquiry and final report, by my assessment, has established a hierarchy where opportunities are placed before risks, and hopes for the future are placed before ad-missions of past harm and thorough explorations of the historical record.

I am concerned that the South Australian people are being denied access to credible evidence which was supplied to the Nuclear Fuel Cycle Royal Commission in good faith on the understanding that it would be duly considered. Rejected or overlooked evidence, contained in submissions like my own examples here, has the potential to improve South Australian understanding of the complexity of nuclear industrial opportunities and risks. I had faith that a Royal Commission would accept the inconvenient truths of past experiences in South Australia and beyond and not sweep them under the carpet.

The previously mentioned 2015 SADILP paper provides some further insight into the defence sec-tor’s attitude towards nuclear industrial development. This is relevant in light of the common back-ground of the Commission’s leadership (Kevin Scarce and Greg Ward) and its apparent prioritisa-tion. After making clear its position in support of nuclear industrial development, the SADILP papersuggests that the industry essentially has a public relations problem. This neglects the legitimate

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concerns held by members of the public who are aware of the industry’s historic record of contam-ination and harm to human health and the environment. It states:[7]

“Managing civilian perception is a significant challenge of the Nuclear Fuelindustry, where a long history of negative media has led to the current cli-mate of anxiety and negativity… careful management of the media will be critical in the industry’s success.”

This Parliamentary Committee should be aware that not all South Australians share the bullish sup-port for nuclear industrial development expressed by the defence sector, and select industry repres-entative bodies such as the South Australian Chamber of Mines and Energy, Business SA and the Committee for Adelaide. The assumption often made by promoters that advocates for a precaution-ary approach to the nuclear fuel cycle are ignorant is an insult to many and a very crude generalisa-tion. It would be fair to assume that every South Australian has knowledge gaps in this complex area, and the Government of South Australia should do all it can to provide the best available in-formation, including discussion of areas where even the scientific results are controversial.

As such, I wish to recommend that a portion of the $3.6 million allocated to the Department of the Premier & Cabinet for Nuclear Fuel Cycle Royal Commission follow-up activity be invested in filling these knowledge gaps by revisiting previously omitted evidence (such as my own, as presen-ted here) and addressing the deficiencies of the Commission’s Final Report in a second edition of the Final Report.

With respect to the path ahead for South Australia, Lucinda Byers, former Council Assisting the Nuclear Fuel Cycle Royal Commission, spoke on the topic of choice to the first Citizens Jury on 26 June 2016. She said:

“Obviously you're already aware that this is not something South Australia has to do. We have the choice. It's not a problem we have to solve; we have the choice. So we all have to think about: are we going to be better off? Are these benefits actually going to improve our lives going forward such that we would be interested in even looking at this further?”

I strongly believe that unless the deficiencies of the Nuclear Fuel Cycle Royal Commission’s select-ive inquiry are addressed in full, and the wider interests and beneficiaries of nuclear industrial de-velopment in South Australia are disclosed and enter the public discourse openly, the questions put by Byers cannot be adequately or accurately answered- either by the second Citizens’ Jury, or the wider South Australian public.

RECOMMENDATIONSIn conclusion, I wish to recommend that...

1. The deficiencies of the Nuclear Fuel Cycle Royal Commission’s Final Report be acknowledged and corrected

2. Previously omitted, reliably-sourced evidence provided to the RC via submissions be revis-ited and synthesised into a 2nd edition of the Final Report (or addendum)

3. All prospective industry partners and beneficiaries of nuclear industrial development (publicand private sector) be disclosed in the public interest

4. The commencement of the second Citizens’ Jury be postponed until the 2nd edition of the Nuclear Fuel Cycle Royal Commission’s Final Report has been published

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REFERENCES[1] Nuclear Fuel Cycle Royal Commission, Government of South Australia, ‘Nuclear Fuel Cycle Royal Commission Re-port’, 2016: pg. XV. http://yoursay.sa.gov.au/system/NFCRC_Final_Report_Web.pdf . Accessed 2016-07-01

[2] Nuclear Fuel Cycle Royal Commission, Government of South Australia, ‘Nuclear Fuel Cycle Royal Commission Re-port’, 2016: pg. XIV-XVI. http://yoursay.sa.gov.au/system/NFCRC_Final_Report_Web.pdf . Accessed 2016-07-01

[3] Nikitin, M., Andrews, A., Holt, M. ‘Congressional Research Service Report RL34234 - Managing the Nuclear Fuel Cycle: Policy Implications of Expanding Global Access to Nuclear Power’. United States Government, 2008. http://wikileaks.org/wiki/CRS-RL34234 . Accessed 2016-07-06

[4] ‘Multinational nuclear centres - Assessment of Australian attitudes towards plutonium reprocessing’ US Em-bassy, Canberra, 1975. http://wikileaks.org/plusd/cables/1975CANBER04456_b.html . Accessed 2016-07-06.

[5] ‘Re-assessment on siting of multilateral nuclear center’ US Embassy, Canberra, 1976. http://wikileaks.org/plusd/cables/1976CANBER00900_b.html . Accessed 2016-07-06.

[6] ‘Proposed Australian-Japanese joint venture to develop nuclear recycling program’. US Embassy, Canberra, 1976.http://wikileaks.org/plusd/cables/1976CANBER03183_b.html . Accessed 2016-07-06.

[7] Dennis, C., Fechner, M., Kaesehagen, C., Morris, M., Papaioannou, P. ‘South Australian Defence Industry Lead-ership Program 2015 : Industry Diversity Nuclear Fuel Cycle opportunities for Defence Industry’. Defence Teaming Centre, 2015: pg. 6 http://www.dtc.org.au/Portals/0/SADILP%202013%20Nuclear%20Industry%20Concept%20Paper.pdf . Ac-cessed 2016-07-04

[8] Edwards, Sean. ‘Nuclear South Australia’ http://www.senatoredwards.com.au/nuclear-south-australia . Accessed 2016-07-05

[9] Heard, B., Brook, B. ‘Royal Commission into nuclear will open a world of possibilities’. The Conversation, 2015. https://theconversation.com/royal-commission-into-nuclear-will-open-a-world-of-possibilities-37363 . Ac-cessed 2016-07-05

[9b] Citizens’ Jury. ‘Citzens’ Jury Draft Report’ New Democracy. Adelaide, South Australia, 2016. http://assets.yoursay.sa.gov.au/production/2016/07/10/07/36/03/43d9a951-541c-4276-a795-d17c931fd452/Citizens'%20Jury%20draft%20report.pdf . Accessed 2016-07-11

[10] Dametto, F., Galeano M., Krause, D., Ross, H., Paior, J. ‘South Australian Defence Industry Leadership Pro-gram 2013 Concept Paper : A Nuclear Future for South Australia’. Defence Teaming Centre, 2014. http://www.dtc.org.au/Portals/0/SADILP%202013%20Nuclear%20Industry%20Concept%20Paper.pdf . Accessed 2016-07-04

[11] Spark & Cannon. ‘NUCLEAR FUEL CYCLE ROYAL COMMISSION CONSULTATION and RESPONSE AGENCY – CITIZENS' JURY - TRANSCRIPT OF PROCEEDINGS ADELAIDE 9.28 AM, SATURDAY, 25 JUNE 2016 DAY ONE’. 2016: pp 21, 25. http://assets.yoursay.sa.gov.au/production/2016/06/28/01/39/46/697d6024-944e-4d93-825e-509303813a67/201606125%20NFCRC%20CaRA%20Citizens'%20Jury%20transcript%201.pdf Accessed 2016-07-05.

[12] Monceaux, Dan. Photograph of Madeline Richardson’s CARA presentation at Minter Ellison, Adelaide. https://www.facebook.com/photo.php?fbid=10153652338261179&set=g.1021186047913052&type=1&theater . 2016. Accessed 2016-07-06

[13] Spark & Cannon. ‘NUCLEAR FUEL CYCLE ROYAL COMMISSION CONSULTATION and RESPONSE AGENCY – CITIZENS' JURY - TRANSCRIPT OF PROCEEDINGS ADELAIDE 9.28 AM, SATURDAY, 25 JUNE 2016 DAY ONE’. 2016: pg. 16. http://assets.yoursay.sa.gov.au/production/2016/06/28/01/39/46/697d6024-944e-4d93-825e-509303813a67/201606125%20NFCRC%20CaRA%20Citizens'%20Jury%20transcript%201.pdf Accessed 2016-07-05.

[14] Spark & Cannon. ‘NUCLEAR FUEL CYCLE ROYAL COMMISSION CONSULTATION and RESPONSE AGENCY – CITIZENS' JURY - TRANSCRIPT OF PROCEEDINGS ADELAIDE 10.01 AM, SUNDAY, 26 JUNE 2016 DAY TWO’. http://assets.yoursay.sa.gov.au/production/2016/06/28/01/40/08/d268ee6a-6097-4ace-8de1-3745a3d4b965/201606126%20NFCRC%20CaRA%20Citizens'%20Jury%20transcript%202.pdf . 2016: pp. 122-133.

[15] LaForge, John ‘Cancer pandemic: reaping the seeds of nuke tests’ Centre for Research on Globalization, 2013. http://www.globalresearch.ca/cancer-pandemic-reaping-the-seeds-of-nuke-tests/5328893 . Accessed 2016-07-06.

[16] Skerrett, Patrick J. ‘Thyroid cancer a hazard from radioactive iodine emitted by Japan’s failing nuclear power plants’. Harvard Medical School, 2011. http://www.health.harvard.edu/blog/thyroid-cancer-a-hazard-from-radioactive-iodine-emitted-by-japans-failing-nuclear-power-plants-201103141867 . Accessed 2016-07-05

[17] 'Chernobyl disaster'. Wikipedia, 2016. https://en.wikipedia.org/wiki/Chernobyl_disaster . Accessed 2016-07-05

[18] Chernobyl Foundation. ‘Chernobyl’. http://chernobylfoundation.org/chernobyl/ . Accessed 2016-07-06.

[19] Pflugbeil, S. et al. ‘Health Effects of Chernobyl - 25 years after the reactor catastrophe’. German Affili-ate of International Physicians for the Preventions of Nuclear War (IPPNW). Berlin, Germany, 2011. http://www.chernobylcongress.org/fileadmin/user_upload/pdfs/chernob_report_2011_en_web.pdf . Accessed 2016-07-07.

[20] Fairlie, Ian et al. ‘The Other Report on Chernobyl (TORCH) - AN INDEPENDENT SCIENTIFIC EVALUATION OF HEALTH AND ENVIRONMENTAL EFFECTS 20 YEARS AFTER THE NUCLEAR DISASTER PROVIDING CRITICAL ANALYSIS OF A RECENT REPORT BY THE INTERNATIONAL ATOMIC ENERGY AGENCY (IAEA) AND THE WORLD HEALTH ORGANISATION (WHO)’. Berlin, Brussels & Kiev, 2006. http://chernobylreport.org/torch.pdf . Accessed 2016-07-07.

[21] Monceaux, D. ‘NUCLEAR FUEL CYCLE ROYAL COMMISSION TENTATIVE FINDINGS RESPONSE March 2016 ’. Adelaide, South Australia. 2016. http://nuclearrc.sa.gov.au/app/uploads/2016/04/Monceaux-Dan.pdf Accessed 2016-07-07.

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[22] ‘Experts divided on causes of high thyroid cancer rates among Fukushima children’. Mainichi Japan. March 7, 2016. http://mainichi.jp/english/articles/20160307/p2a/00m/0na/022000c . Accessed 2016-07-07.

[23] ‘Fukushima No. 1 worker’s leukemia officially deemed a work accident’ The Japan Times. October 20, 2015. http://www.japantimes.co.jp/news/2015/10/20/national/science-health/nhk-says-health-ministry-confirms-link-workers-leukemia-fukushima-blast/#.V42qJfl96Uk . Accessed 2016-07-07.

[24] Monceaux, Dan. ‘Nuclear Fuel Cycle Royal Commission Submission – Dan Monceaux – 8 August 2015’ Adelaide, South Australia, 2015. http://nuclearrc.sa.gov.au/app/uploads/2016/03/Dan-Monceaux-10-08-2015.pdf . Accessed 2016-07-07.

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