PO Box 1379 Carlton Victoria 3053
54 Victoria St Carlton Victoria 3053
T: (03) 9203 1958
E: mapw@mapw.org.au
F:(03) 9662 2619
W: www.mapw.org.au
The Medical Association for Prevention of War welcomes the opportunity to make a
submission to the Energy White Paper consultation process.
This submission deals specifically with issues regarding nuclear power generation. There are
inherent and increasingly recognised health and safety issues associated with ionising
radiation, which have potential impacts on both the Australian community and the Australian
environment. It is therefore important that the health aspects of nuclear power generation be
considered when determining future energy generation in Australia.
This document is laid out using the categories provided in the submission format. We give
consent for this submission to be made public on the Department of Industry website.
1. The Security of Energy Supplies
Recommendation:
Nuclear power in Australia is recognised as not safe, given:
1) there is demonstrated potential for human factors in the nuclear industry to undermine
critical safety principles.
2) there is no high level nuclear waste facility.
3) no nuclear power company would be prepared to establish a reactor without first
transferring potential liability to the taxpayer.
4) nuclear power facilities represent possible targets for attack, resulting in major long term
irradiation and contamination of surrounding areas.
1) Human factors can derail even the most technologically advanced country in the world. The July
2012 report of the Nuclear Accident Independent Investigation Commission − established by an Act
of Japan's national parliament − states that the Fukushima disaster was "a profoundly man-made
disaster that could and should have been foreseen and prevented" if not for "a multitude of errors and
wilful negligence that left the Fukushima plant unprepared for the events of March 11." The cosy
relationship between the Japanese government and the nuclear power companies contributed
significantly to the lack of appropriate measures to prepare for the tsunami. Australia might not be
immune from a similar man-made disaster. Given the strong push for deregulation at present, there is
no guarantee that regulatory failure may not contribute to future potential catastrophic failure of an
Australian nuclear industry. Corporate negligence and cost cutting were also found to be significant
factors in the Fukushima disaster.
2) Given there are no long term storage facilities for high level nuclear waste anywhere in the world, a
nuclear power industry in Australia will face issues of inadequate and unsafe storage of nuclear waste.
The IAEA ‘Safety Guide on the Classification of Radioactive Waste (GSG-1)’ is unambiguous on this
matter, describing high level waste (from the operation of nuclear power plants) as:
"Waste with activity concentration levels high enough to generate significant quantities of heat by the
radioactive decay process or waste with large amounts of long lived radionuclides that need to be
considered in the design of a disposal facility for such waste. Disposal in deep, stable geological
formations usually several hundred metres or more below the surface is the generally recognised
option for disposal of high level waste."
A storage solution (such as is the case in many countries around the world which have a nuclear
power industry) does not meet international best practice requirements as it is not a disposal solution.
As has occurred also in many countries this failure has become a burden to future generations and
poses unnecessary risks to humans and the environment.
The process of obtaining a deep geological disposal facility location will take many years if not
decades if the history of the National Radioactive Waste Management facility for low and
intermediate level waste is any guide. It would not therefore be appropriate to initiate a nuclear power
program without a credible disposal solution available or at the very least in its advanced stages.
Anything less than this will fail the international best practice standard required, and create large
amounts of stranded high level nuclear waste.
It should be remembered that a typical nuclear power plant creates 25 tonnes of high level nuclear
waste per annum and 5,000m3 of low level waste. By comparison, the total accumulated radioactive
waste in Australia over more than 60 years is 5,000m3 and has taken many decades to reach a
disposal solution (yet to be finalised). Indeed, even the proposed repository at Muckaty will fail to
address disposal of intermediate level radioactive waste (being only a storage facility).
The ARPANS Act requires its CEO “take into account international best practice in relation to
radiation protection and nuclear safety” and places a responsibility on the CEO to inform DRET of
such international best practice issues relevant to national strategy and in particular, those that will
apply in deciding whether to issue any facility licence.
One can only deduce that licensing of any facility that fails to properly dispose of the highest level of
radioactive waste in Australia will create major problem for this and future generations of Australians.
3) Nuclear power companies require the taxpayer to assume liability for adverse events. This, in and
of itself, is clear acknowledgement that despite all the rhetoric surrounding the safety of nuclear
power generation, companies recognise the clear risk of catastrophic harms. There have been multiple
core meltdowns in various reactors including Three Mile Island, Chernobyl and Fukushima Dai-ichi.
The Fukushima meltdowns continue to release radiation into the surrounding environment. In a 2012
review of the nuclear power industry, the Economist concluded that "Nuclear power thus looks
dangerous, unpopular, expensive and risky. It is replaceable with relative ease and could be forgone
with no huge structural shifts in the way the world works". (March 24, 2012)
4) Nuclear power plants are possible targets for attack, given the potential for large and ongoing
damage to surrounding communities and environments. Provision of protections to reduce the
likelihood of attack would add major costs to construction. Such protections would be unlikely to
preclude an attack made from within the plant.
2. Regulatory Reform and the Role of Government
Recommendation:
The Environment Protection and Biodiversity Conservation Act 1999 (the EPBC Act) continue
to apply to the uranium industry. The uranium mining industry produces radioactive
materials that have impacts on both human health and environmental health. It is essential that
appropriate environmental and human safeguards remain, and that uranium mining and
milling remains within the definition of “nuclear actions” for the purposes of the EPBC Act.
There is a clear need for federal oversight to ensure clear and consistent implementation of
these measures.
It is concerning that the uranium industry uses the expression “mild radiation” to describe its
radiological environmental impacts, when there is no regulatory basis or definition to use this term,
potentially giving the impression that the levels of radiation in the uranium mining industry are
without risk to the environment. The evidence is clear and unassailable that this is not correct.
Furthermore, it is appropriate that uranium mining continue to be considered a 'nuclear action' as
specified by the EPBC Act as the radioactivity derives specifically from nuclear decay processes.
Tailings from uranium mining are radioactive for millennia, resulting in unique environmental
considerations for every uranium mine.
The International Commission on Radiological Protection has determined that the dose coefficient for
radon gas, one of the sources of radioactivity from uranium mining, needs to be doubled, indicating
that it is actually thought to be double the previously estimated carcinogenic hazard. ARPANSA is
currently in the process of revising dose estimates to workers. It follows that risks to others is doubled
and makes it even more essential appropriate mitigation strategies are introduced. It also follows that
the environmental risk is also increased.
With regard to human exposure, all radiation regulatory frameworks around the world support the
concept of the 'linear no threshold' (LNT) model of carcinogenesis. As the US National Academy of
Sciences, Biological Effects of Ionising Radiation VII (BEIR-VII) report (2006) summarised:
“..the current scientific evidence is consistent with the hypothesis that, at the low doses of interest in
this report, there is a linear dose-response relationship between exposure to ionizing radiation and the
development of solid cancers in humans. It is unlikely that there is a threshold below which cancers
are not induced...”
This concept is also supported by all radiation regulators, the International Atomic Energy Agency,
the United Nations Scientific Committee for the valuation of the Effects of Atomic Radiation
(UNSCEAR) and many others. It follows that there is strong evidence that even at low doses any
additional radiation over background levels increases the risk of malignancies. It logically follows that
there are thus risks to non-human biota and the broader environment, even at low doses of radiation,
or as the Australian Uranium Association would perhaps describe it, 'mild radiation.'
Indeed, the recently released guidelines from the International Atomic Energy Agency has revised
down the dose limits for occupational exposures to the eye, commenting some of the earlier
epidemiological studies, on which limits were based may not have had sufficient follow-up to detect
either radiation-induced lens changes or visual disability requiring cataract surgery. In addition, better
techniques for detecting, quantifying, and documenting early radiation-associated lens changes, as
well as better dosimetry, may have been factors that contributed to the more recent findings of
radiation-induced cataracts at low exposures. The equivalent dose limit for the lens of the eye for
occupational exposure in planned exposure situations has been reduced from 150 mSv per year to 20
mSv per year, averaged over defined periods of five years, with no annual dose in a single year
exceeding 50 mSv.
This reduction in the dose limit for the lens of the eye follows the recommendation of the
International Commission on Radiological Protection (ICRP) in its statement on tissue reactions on 21
April 2011. In the longer term, the interim guidance provided and experience gained in its application
will be used as input to a number of Safety Guides that are currently being revised - both on
occupational radiation protection, and on radiation safety in the medical uses of ionizing radiation. It
is expected that these Safety Guides will be published in 2015–2016.
With regard to non-human species, the 2010 ARPANSA Technical Report No. 154 entitled
“Environmental protection: Development of an Australian approach for assessing effects of ionising
radiation on non-human species” made the following statements:
“It is now generally accepted that under certain circumstances, there is a need to demonstrate, rather
than assume, that non-human species living in natural habitats are protected against ionising radiation
risks from radionuclides released to the environment by human actions”.
In an Australian context, there is a recognised need for specific national guidance on protection of
non-human species, for which the uranium mining industry provides the major backdrop; it is
Australian Government policy that uranium mining should be based on world best practice standards
for assessing environmental impacts.
It is timely that Australia now considers the development of guidance in order to provide clear and
nationally consistent advice to operators and regulators on protection of non-human species, including
advice on specific assessment methods and models and how these might be applied in an Australian
context.
This report reviews the ICRP and ERICA international frameworks for assessment and protection of
non-human species and the applicability to the Australian context.
The general conclusions to be drawn from this report include:
• At the international level, the International Commission on Radiological Protection has established a
framework for radiological assessment and protection of non-human species based on a reference
animal and plant approach;
• In an Australian context, there is a need for specific national guidance on protection of non-human
species, identified through the National Directory for Radiation Protection, and realised by the need of
the uranium mining industry to integrate world best practice standards for assessing environmental
impacts;”
Without federal oversight and reporting this is highly unlikely to happen in any consistent, coherent or
comparable manner. So inclusion in the EPBC Act is essential.
Given the clear human health and environmental risks of even low dose radiation exposure, it is
entirely appropriate that uranium mining and milling remain within the definition of "nuclear actions”
in the EPBC Act .
Internationally radiation regulation is increasing, as the risks to human health and the environment
become more apparent. The international emphasis (by the IAEA) is increasingly to consider radiation
an environmental (as opposed to just a human) hazard so it is appropriate that uranium mining be
subject to Commonwealth environmental legislation. There is no reason why uranium mining should
be exempt from the remit of the EPBC Act.
In conclusion, the uranium mining industry produces radioactive materials that have impacts on both
human health and environmental health. It is essential that appropriate environmental and human
safeguards remain, and that uranium mining and milling remains within the definition of “nuclear
actions” for the purposes of the EPBC Act. There is a clear need for federal oversight to ensure clear
and consistent implementation of these measures.
3. Growth and Investment
Recommendation:
That the government take note of the massive subsidies and loan guarantees that have been
required to support the establishment of nuclear power plants internationally, and reject the
use of subsidies, loan guarantees and any other government measures to establish an otherwise
financially unviable nuclear power industry in Australia.
Internationally, including in the USA , France and the UK, billions of dollars of loan guarantees and
contracts underwritten by taxpayer funds have been required to make building nuclear power plants
financially feasible. Most recently the UK government has promised $18 billion in loan guarantees to
build European Pressurised Reactors (EPRs) at Hinkley Point. In addition, the UK government is
guaranteeing French utility EDF 16 cents for every kilowatt-hour generated by the Hinkley Point
reactors, fully indexed for inflation, for 35 years. Economic consulting firm Liberum Capital reported
"we are flabbergasted that the UK government has committed future generations of consumers to the
costs that will flow from this deal" and that Hinkley Point will be "both the most expensive power
station in the world and also the plant with the longest construction period." (1)
Two other EPR projects − in Finland and France − have been disastrous. The estimated capital cost
for the EPR in Finland has ballooned from $4.5 billion to $12 billion.(2) The estimated cost for the
EPR in France has ballooned from $5 billion to $12.8 billion. (3)
There are many areas in the Australian health system in desperate need of greater resource provision.
Diverting government revenue to subsidise nuclear power production and the likely major costs blow
outs and delays during construction represents an opportunity cost that our community can ill afford.
(1) http://www.liberumcapital.com/pdf/ULkWtp00.pdf
(2) http://online.wsj.com/article/BT-CO-20121213-703038.html
(3) http://uk.reuters.com/article/2012/12/04/enel-edf-idUKL5E8N4DIJ20121204
4. Trade and International Relations
Recommendation:
The Australian government undertakes an in-depth assessment of the net cost impact of the
nuclear fuel cycle: potential for cost reduction, emissions, proliferation, waste disposal, local
impacts of mining and insurance against disasters.
The United Nations system-wide study on the implications of the accident at the Fukushima Daiichi
nuclear power plant Report of the Secretary-General (UN System-Wide Study) published on 16
August 2013 recommends that internationally all nations address “in-depth assessment of the net cost
impact of the following: potential for cost reduction, emissions, proliferation, waste disposal, local
impacts of mining and insurance against disasters”.
In response to a question asked in the Senate Estimates hearings in November 2013, it was noted that
the Supervising Scientist is not aware of what level of engagement, if any, there has been with
Australian Government agencies in relation to the recommended international level assessment.
8. General Comments
Recommendation:
The Australian government recognises the inherent significant and unresolved health risks
associated with nuclear power generation.
MAPW is primarily concerned with nuclear weapons, and their potential for disastrous effects on
humanity. It is important to recognise that nuclear weapons and nuclear power are inextricably
linked. Use of nuclear weapons represents a massive humanitarian disaster. Many states have used
nuclear power as a cover up for development of nuclear weapons, and the technology is readily
transferable. But numerous melt-downs, including those at Chernobyl and Fukushima, have shown
that even without the risk of proliferation of weapons, nuclear technology is a hugely costly and
potentially catastrophic method of energy production.
Ionising radiation is classified as a Class 1 carcinogen by the International Agency for Research in
Cancer (IARC) of the World Health Organisation (WHO), the highest classification consistent with
certainty of carcinogenicity. The science underpinning the precise effects of ionising radiation on
humans is still evolving, and as methods for evaluating both exposures and outcomes improve,
recommended limits to exposure continue to fall. Throughout the 20th century, the progressively
decreasing radiation dose regulatory limits mirrored the increasing realisation of the hazards to human
health of ionising radiation, even at low doses, to the point where we now recognise there is no safe
lower threshold.
The link between uranium mining and lung cancer has long been established. The Biological Effects
of Ionising Radiation VI report (1999) reviewed eleven cohort studies of 60,000 underground miners
with 2600 deaths from lung cancer, eight of which were uranium miners in Europe, North America,
Asia and Australia. These found a progressively increasing frequency of lung cancer directly
proportional to the cumulative amount of radon exposure in a linear fashion. Smokers had the highest
incidence of lung cancer, as would be expected, but the greatest increase in lung cancer was noted in
non-smokers. The highest percentage increase in lung cancer was noted 5-14 years after exposure and
in the youngest miners.
Uranium miners are also exposed to ionising radiation directly from gamma radiation and the dose
from this is cumulative to that from radon. At the Olympic Dam underground uranium mine, the total
dose per miner is approximately 6 mSv, of which 2-4 mSv (allowing for the new ICRP dose
coefficients) are due to radon and the balance due to gamma radiation.
Most modern uranium mines have air extraction systems and monitored ambient measures of radon
concentrations to ensure levels remain low. Current levels of radon in underground uranium mines are
only a fraction of mines of 100 years ago. Miners are now given personal protective equipment (PPE)
including masks to filter out the radioactive particulate matter. Yet many underground miners find the
masks extremely uncomfortable, especially in the hot underground environment they must contend
with. It is estimated that up to 50 per cent of underground uranium miners in Australia do not use their
masks, and thus drastically increase their risk of lung cancer while underestimating their actual
radiation dose (since this is calculated assuming PPEs are used).
The Olympic Dam doses mentioned above are typical of modern mine practices. The average miner at
Olympic Dam is in his 20s and stays on average five years at the site. A typical calculation using the
linear no threshold model and the latest BEIR-VII figures of radiation carcinogenesis risks indicates
miners at Olympic Dam therefore have a 1:420 chance of contracting cancer, most likely lung cancer.
Note that the research demonstrates that the risk of developing lung cancer is greater for younger
workers. These risks are not insubstantial. Radiation safety and risk principles can be quite complex
and it is debatable whether miners have the training to understand the basis, or are even informed of
the risks in a comprehensive and accurate manner that they can comprehend and make an informed
work decision.
The repercussions of inadequate workplace safety may not be apparent for decades, as asbestosrelated deaths now bring to light the scandalous disregard for employee health and welfare in the
asbestos mining industry, despite the medical evidence at the time which clearly demonstrated a major
health hazard to asbestos workers. The employer obligation to preventing workplace related deaths
has no time limit, particularly as deaths may occur many years after employment has ceased.
The 15-country study of nuclear industry workers (excluding mining) published in 2005, the largest
study of nuclear industry workers ever conducted, was able to arrive at statistically significant
conclusions confirming the increased risk of cancer and leukaemia in nuclear industry workers, even
at low dose. This involved analysing dosimetric records of over 407,000 workers and correlating with
solid cancer and leukaemia mortality with a total follow up of 5.2 million person years. The average
cumulative dose was 19.4 mSv, with 90 per cent receiving less than 50 mSv. Recall that these are
within the current permissible dose limits (50 mSv in any one year, provided that there is no more
than 20 mSv per annum averaged over five years, i.e., 100 mSv total). The results indicated that there
was an excess risk for solid cancers of 9.7 per cent per 100 mSv exposure and an excess risk of 19 per
cent for leukaemia. The more recent study of survivors from Hiroshima and Nagasaki in 2012 confirm
low dose exposures are associated with increased malignancy rates, and that cardiovascular and
gastrointestinal disease is also increased.
In conclusion, it is evident that nuclear power generation is hazardous both to human health and the
health of our environment. Like all human endeavours it is subject to human error. Issues around
safety, liability, occupational exposures, environmental contamination and toxic waste storage for
millennia all remain unresolved. Given Australia has many potential energy options and many other
existing methods of generating electricity, initiating a nuclear power industry in Australia is clearly
inappropriate.
For further information please contact
Dr Margaret Beavis MBBS FRACGP MPH
Vice President
Medical Association for Prevention of War
Mobile +61 401 995 699 Email mjbeavis@outlook.com.au