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SUBMISSION BY ICAN, THE INTERNATIONAL CAMPAIGN TO ABOLISH NUCLEAR WEAPONS (AUSTRALIA)

TO THE SOUTH AUSTRALIAN NUCLEAR FUEL CYCLE ROYAL COMMISSION PRINCIPAL AUTHOR Dr Sue Wareham OAM Member of the Board in Australia, ICAN

3 August, 2015

This submission will address aspects of Issues Paper 2: Further processing of minerals and manufacture of materials containing radioactive and nuclear substances. Introduction, summary and ICAN recommendations ICAN (Australia) is pleased to submit to the SA Nuclear Fuel Cycle Royal Commission. We believe that community approval is critical before any plans to develop the major and very controversial facilities that are associated with nuclear power. It will be essential for the concerns submitted to this Royal Commission to be addressed in an atmosphere that is not coloured by pre-conceived expectations, plans or vested interests. This point is emphasised in response to the inclusion of confidence-building measures as a specific question to be addressed by this Royal Commission. ICAN recommends that a culture of openness and honesty be rigorously upheld at all times in discussions of the nuclear fuel chain, to obviate the need for any such measures. The establishment and operation of further nuclear facilities in South Australia will create a number of significant health and safety risks. The two risks of greatest concern to ICAN are:

Further augmentation of the catastrophic risks to health and safety posed by nuclear weapons, the most destructive of all weapons of mass destruction. The links between civilian and military uses of nuclear technology and facilities have been amply demonstrated, and any expansion of such facilities will create further obstacles to achievement of the world’s most urgent security imperative - the elimination of nuclear weapons.

Further augmentation of the grave risks posed by nuclear terrorism, which could be in the form of theft of fissile material by terrorists, by an attack on a nuclear power facility, or by other means. Nuclear terrorism can pose a direct and catastrophic risk to those living in the vicinity of a nuclear facility.

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The problems presented by plutonium reprocessing, especially their role in making weapons-usable material available to proliferators and terrorists, are particularly grave.

ICAN strongly recommends that no further facilities for the conduct of any parts of the nuclear fuel chain be built in South Australia. Australia’s uranium sales should be phased out, with the most urgent attention being paid to our sales to nuclear-armed nations. In relation to uranium enrichment, as a bare minimum step for as long as nuclear power continues, all uranium enrichment should be brought under genuine (ie not determined by any self-appointed grouping) international control. Plutonium reprocessing should be ceased, globally.

The following questions will now be addressed: 2.7 What are the processes that would need to be undertaken to build confidence in the community generally, or specific communities, in the design, establishment and operation of such facilities? 2.8 What additional risks for health and safety would be created by the establishment and operation of such facilities in South Australia? What needs to be done to ensure that risks would not exceed safe levels? Can anything be done to better understand those risks? 2.11 What security implications are created by the activities of conversion, enrichment, fabrication or reprocessing of nuclear fuel, or by further manufacturing activities, in South Australia? What is the evidence which suggests that such risks might materialise? Can they be addressed and by what means? 2.12 What safeguards issues are created by the further participation in South Australia in activities (such as the production of uranium oxide, conversion, enrichment, fuel fabrication or reprocessing) necessary for uranium to be used as a fuel in electricity generation? Can those implications be addressed? If so, by what means? Further, would the possession of those technical capabilities give rise to strategic and policy issues for Australia? If so, what are those issues and how could they be addressed. However ICAN notes that there is much overlap between these questions, and the answers that follow should be read as a whole. For example, the distinction between security implications (question 2.11) and strategic and policy issues (question 2.12) is not clear cut, so each answer may apply to several of these questions. This raises the important point that nuclear technology has impacts on many aspects of our national life and must be viewed it its entirety rather than in a piecemeal fashion. 2.7 What are the processes that would need to be undertaken to build confidence in the community generally, or specific communities, in the design, establishment and operation of such facilities?

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The question of building confidence in the community about the design, establishment and operation of nuclear facilities is premature in an inquiry process that is ostensibly about the arguments for and against building such facilities. Rather than addressing the advantages (if any) and disadvantages of building nuclear facilities, this question appears to leap to a final scenario where such facilities will be built against community opposition. A process of confidence building would be needed only if the community have concerns that haven’t been, or can’t be, addressed. If this is the case, then the building of the facilities should not go ahead. If there are not any concerns, and the community welcome the facilities, then why is confidence building needed? ICAN recommends the development of a culture of openness and honesty to obviate the need for “confidence building”. 2.8 What additional risks for health and safety would be created by the establishment and operation of such facilities in South Australia? What needs to be done to ensure that risks would not exceed safe levels? Can anything be done to better understand those risks? This submission will not examine in full the very significant health and safety risks for local communities associated with the nuclear fuel chain. These include the health risks associated with routine radioactive discharges from nuclear facilities, larger radioactive leaks, human and environmental contamination by the enormous unresolved problem of radioactive waste, and the risk of a major accident.

ICAN does however note that the notion of a risk being “safe” is puzzling. How does one define a “safe risk”? Risks might have a low chance of occurring but catastrophic impacts when they do occur (such as a Fukushima-type accident, a terrorist attack on a nuclear facility, or the use of a nuclear weapon made from diverted fissile material), or high risk of occurring but smaller impacts (such as a less serious accident, of which there have been many examples at nuclear facilitiesi, or the routine radioactive discharges from nuclear facilities).

ICAN’s responses to this question will now focus on two of the greatest health and safety risks:

Nuclear power production’s links with nuclear weapons production and their catastrophic health impacts

Nuclear terrorism

Nuclear power production’s links with nuclear weapons production and their catastrophic health impacts

Although the nuclear facilities under consideration are for various steps in the civilian nuclear fuel chain, the close links between civilian and military nuclear facilities must be highlighted in this discussion. Those links will be considered in more detail in the next question on security implications, but it is important to state here the health impacts of nuclear weapons, to underline what is at stake. They must be considered in the gamut of health risks associated with nuclear power reactors.

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The health impacts of nuclear weapons have been addressed in detail for 70 years since the first uses of the weapons, and documented on countless occasionsii. They include immediate or slow death from blast-related trauma, burns, asphyxiation and radiation sickness for hundreds of thousands or millions of people, suffering and deaths related to destruction of health care services and most other infrastructure, and longer term effects such as the induction of cancers. For the vast majority of the survivors in the early phase following a nuclear weapon explosion, there would be little or no medical or other assistance, as the vast majority of health care, transportation, communications and other services would be destroyed.

These impacts have received renewed attention globally over the past two years at a series of intergovernmental conferences, in Norway, Mexico and Austria, which have examined the humanitarian impacts of nuclear weapons. At the most recent of these, in Vienna in December 2014, the conference concluded that “The scope, scale and interrelationship of the humanitarian consequences caused by a nuclear weapon detonation are catastrophic and more complex than commonly understood….No state or international body could address in an adequate manner the immediate humanitarian emergency or long term consequences…”iii. In other words, a nuclear weapon explosion would cause human suffering on a scale beyond any capacity for meaningful assistance, in either the short term or the long term.

One of the longer term impacts that has been extensively studied is the climate disruption that would be likely to follow even a “small” nuclear war involving a tiny fraction of the world’s nuclear arsenals targeted on cities. It is predicted that the vast quantities of smoke, soot and other particulate matter produced in this scenario would be so great as to reduce sunlight and also rainfall for up to a decade, leading to reduced agricultural production and starvation on a scale never before witnessed, possibly affecting up to 2 billion peopleiv.

It must be noted also, especially in South Australia, that the impacts of nuclear weapons have already been very real for many Australians, as a result of the British nuclear weapons testing from 1952 to 1963. Indigenous communities bore the brunt, and much traditional land used for the blasts remains radioactive and off limits today. ICAN’s publication “Black Mist: The impact of nuclear weapons on Australia” addresses this subjectv.

While not every reactor produces material that will end up in a nuclear bomb of course, the point to note is that every reactor has the potential to do so, even the so-called “proliferation – resistant” reactorsvi. As argued in question 2.11, safeguards cannot exclude this possibility.

Nuclear Terrorism Terrorist opportunities are available at several stages of the production of nuclear power. The nuclear power chain is highly centralised, and nuclear power facilities house vast quantities of radioactive materials which, in the event of accident or sabotage, could be widely dispersed. Even the most “benign” form of nuclear terrorism, shut-down of a nuclear power plant by insider or external sabotage, would have far more devastating consequences, including on health, than shut-down of a small-scale, less centralised form of power.

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The following two forms of nuclear terrorism will be discussed further:

Acquiring fissile material (enriched uranium or plutonium) to make a nuclear weapon; and

Attacking a nuclear power reactor and dispersing radioactive material over a wide area.

Terrorist acquisition of fissile material to make a nuclear weapon A nuclear weapon can be made with either highly enriched uranium or plutonium. Nuclear smuggling or theft of either of these substances has long been recognised as a possible route to a nuclear nightmare. For example, efforts of the al-Qaeda network to obtain nuclear weapons or weapons grade nuclear materials have been documentedvii. Dangerous amounts of radioactive material have gone missing, especially since the end of the Cold Warviii. In the report “Securing The Bomb 2010: Securing all nuclear materials in four years”, by the Nuclear Threat initiative in the US, the section “Nuclear thieves could strike in any country” reminds us that international terrorists have global reachix. David Albright, of the Institute for Science and International Security in Washington, commented in 2004 on the significant risk of theft of plutonium: “The big risk we face with separated plutonium is from theft by terrorists at a factory making reactor fuel - maybe an inside job. You always have to worry about the physical protection of plutonium. Nations always tell you their protection is good. But it may not be enough”x. In March 2005, UN Secretary-General Kofi Annan, in calling for a world treaty to outlaw terrorism in all its forms, said “Perhaps the thing that is most vital we deny to terrorists is access to nuclear materials”xi. In January of that year, Mohamed El-Baradei, Director General of the International Atomic Energy Agency (IAEA) also expressed his concern about this issue, stating to the Washington Post that the acquisition of nuclear materials by a terrorist group was "a real possibility."xii

Attack on a nuclear power reactor Nuclear reactors and associated facilities potentially pose a highly attractive target for direct terrorist attack. Considering feasibility, visibility, large number of potential targets, and potential for severe consequences - with persistent environmental contamination over large areas, the need for costly clean-up, major social disruption, widespread fear and panic, the need for evacuation of populations in the fallout path, economic damage and political effect - it is hard to envisage many more attractive terrorist targets. Professor Frank Barnaby, British nuclear physicist, defence analyst and Emeritus Consultant to the Oxford Research Group, has written extensively on this subject. He states that, in relation to nuclear power plants in the UK:

There is a definite trend in paramilitary targeting from hard targets like security forces to softer targets like energy infrastructure, banking centres and tourist spots. Nuclear power stations are soft targets.

Terrorists are increasingly targeting energy infrastructure, such as oil pipelines and refining plants. As dependence on nuclear power increases, the value of nuclear

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plants and fuel production facilities to terrorists will increase, making nuclear terrorism more likely.

Given the potentially disastrous consequences of nuclear terrorism, even a minimal risk is too highxiii.

There is no reason these observations should not be extrapolated to Australia, whose people have already been the targets of terrorism and may well be so again in the future.

The closest the world has come to a major attack on a functioning nuclear plant (excluding the 1981 Israeli bombing of the near completed Osiraq reactor under construction in Iraq) may have been the fourth hi-jacked airliner on 11 Sept 2001, which crashed into a Pennsylvania field reportedly after passengers and crew fought the hijackers. When it crashed, the plane was headed towards and only about 180 km from the Three Mile Island nuclear power plantxiv. Had it collided with the reactor, breach of the reactor containment and massive release of its radioactive contents is likely to have occurred.

Of even greater concern than the reactors themselves are nuclear fuel storage facilities, particularly storage ponds for highly radioactive spent nuclear fuel. These often contain much larger radioactive inventories than reactors themselves, and generally are housed in simple buildings without robust containment structures, and therefore are more vulnerable to attack. Containment structures surrounding nuclear reactors could generally be breached by attacks such as those which occurred in New York in 2001xv.

Even unarmed environmental groups have been readily able to demonstrate the vulnerability of nuclear plants. For example, in 2003 Greenpeace activists scaled the Sizewell reactor in the UK after storming the plantxvi, and others similarly accessed the reactor complex at Lucas Heights in Sydney in 2001xvii.

In February 2014 an 84-year old nun in the US was sentenced to prison for a break-in into the Oak Ridge nuclear weapons plant. In 2012 she and two other activists had cut through three fences before reaching a storage bunker, hung banners, strung up crime-scene tape and hammered off a small chunk of the fortress-like storage facility for uranium material, inside the most secure part of the complex, before they were arrested. Incidents such as this do not inspire confidence in the security of nuclear materials in one of the most security-conscious nations on earthxviii.

The risk of terrorism at a nuclear facility in South Australia might be small, but the consequences could be catastrophic. On September 10, 2011, the chances of hi-jacked planes flying into the World Trade Centre in New York the next day would have appeared remote, and yet it happened. Much Australian government attention and funding is currently spent on the global problem of terrorism. Regardless of how effective or otherwise our current approaches to terrorism are, to add attractive terrorist targets on Australian soil, appears foolish in the extreme.

Assurances that nuclear facilities in Australia would be made terrorist-proof will be a very hard sell. To the extent that attempts would be made to make them so, Australians will be

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subject to even greater incursions on their freedoms. These matters are a vital part of the discussion for communities before plans for any facilities develop further. 2.11 What security implications are created by the activities of conversion, enrichment, fabrication or reprocessing of nuclear fuel, or by further manufacturing activities, in South Australia? What is the evidence which suggests that such risks might materialise? Can they be addressed and by what means? The security implications of undertaking conversion, enrichment, fabrication or reprocessing of nuclear fuel are profound, and should be at the top of the list of concerns associated with the current proposal to expand the nuclear industry in South Australia. There are two overwhelming security concerns:

Raising the risk of nuclear terrorism, and

The creation of further obstacles to the elimination of nuclear weapons The first of these has been discussed above in the responses to question 2.8 on health and safety risks. The second will now be discussed. The creation of further obstacles to the elimination of nuclear weapons The elimination of nuclear weapons has been repeatedly identified as one of the world’s pre-eminent security challenges; it is almost certainly the most urgent of many such challenges. The enormous barriers to be overcome before we realise this goal are compounded by the raw materials made available by the nuclear power industry. A daunting but critical task is rendered infinitely more daunting. This is because the material and capacity to produce nuclear power intrinsically involve the capacity to produce fissile material usable for nuclear weapons. The world’s so-called ‘peaceful’ uses of nuclear technology have in the past, and continue today, to contribute to the spread of nuclear weapons. Irradiated nuclear fuel can be used in nuclear weapons, and uranium can be enriched for civil or military uses – the process is the same. In 1975, Fred C Ikle, former director of the US Arms Control and Disarmament Agency, said:

“With the benefit of hindsight we can now clearly see that projects for peaceful applications of nuclear technology provided the essential expeditor, and in many case the necessary cover, for gaining capabilities to make the bomb.”xix

Thirty years later the situation had not changed. In 2006 former US Vice-President Al Gore made clear that weapons proliferation is a major unresolved problem with nuclear power:

“There are serious problems that have to be solved, and they are not limited to the long-term waste-storage issue and the vulnerability-to-terrorist-attack issue. Let’s assume for the sake of argument that both of those problems can be solved. We still have other issues. For eight years in the White House, every weapons-proliferation problem we dealt with was connected to a civilian reactor program. And if we ever

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got to the point where we wanted to use nuclear reactors to back out a lot of coal -- which is the real issue: coal -- then we’d have to put them in so many places we’d run that proliferation risk right off the reasonability scale. And we’d run short of uranium, unless they went to a breeder cycle or something like it, which would increase the risk of weapons-grade material being available.”xx

This view is shared by other authorities. The foreword to the 2007 Oxford Research Group publication “Secure Energy? Civil nuclear power, security and global warming” stated:

“Most of the times, when we discuss the hazards of nuclear power, we think of the dangers of a meltdown at nuclear plants and the problem of the disposal of radioactive nuclear waste. We might also think of further disadvantages like the dependency on massive subsidies or the limited availability of uranium in the long run. All these are bad enough but an even worse aspect of nuclear technology is the creation of massive security risks such as nuclear weapons proliferation and nuclear terrorism. In the broad public debate, a naive optimism over nuclear power’s peaceful application is still fairly widespread.”xxi

The US International Security Advisory Board reported in 2008 that “….the rise in nuclear power worldwide, and particularly within Third World nations, inevitably increases the risks of proliferation.”xxii The report also commented on existing “protections” against proliferation: “It is also apparent that the Additional Protocol [to NPT obligations] itself is not comprehensive enough to block all of the paths to proliferation that are possible under the current non-proliferation treaty. Neither are the corresponding IAEA safeguards protections comprehensive enough.” In 2009 Victor Gilinsky, physicist, former member of the US Nuclear Regulatory Commission and assistant director for policy and program review at the Atomic Energy Commission, wrote:

“When formulating its nuclear energy policy, the new Obama administration will have to face the reality that advances in technology, combined with politics and ideology, have made it much harder to prevent nuclear energy use from contributing to the spread of the Bomb.”xxiii

A number of countries have developed nuclear weapons via essentially clandestine programs largely utilising “research” and “civilian” reactors. Examples include Israel, South Africa, North Korea, India and Pakistan. South Korea’s “civilian” nuclear scientists were involved in clandestine weapons research from 1979 to 2000xxiv. See below regarding Iran and nuclear enrichment also.

In the five nuclear armed states that are party to the NPT, civilian and military nuclear facilities are not necessarily separated. For example, In the US, the Savannah River facility is used to produce both fuel for commercial reactors and tritium for thermonuclear weaponsxxv.

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Even in Australia, where we have traditionally prided ourselves on being a good international citizen, the use of nuclear power to produce plutonium for a possible weapons program was considered by Prime Minister John Gorton in 1968.

Then as now, any decision to develop nuclear technology must take into account the fact that acquisition of the technology with the implicit weapons capability has the potential to sow doubt in neighbours’ minds. For example, If Indonesia were to develop nuclear power, it would be surprising if this did not, at the very least, raise questions in Australia about our neighbour’s new capacity. Japan’s huge stockpiles of plutonium (see below) also demonstrate this problem.

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

Safeguards, which are an attempt to keep civilian and military nuclear programs separated, have relied heavily on the International Atomic Energy Agency (IAEA). However they have not always detected in a timely fashion, let alone prevented, nuclear weapons proliferation. This is hardly surprising given that article 2 of the IAEA statute states that “The agency shall seek to accelerate and enlarge the contribution of atomic energy to peace, health and prosperity throughout the world.” The organisation is both promoter and regulator of the nuclear industry – a clear case of conflicts of interest that are impossible to reconcile within the one organisation. Weapons programs in both North Korea and Iraq occurred while each country was subject to IAEA safeguards.

Several stages of the nuclear fuel chain, such as the mining, milling and conversion of uranium, and the fuel fabrication, are not subject to safeguards. Nor do safeguards apply to transportation of fissile material, which is a particularly vulnerable phase during which the risk of terrorist access to the material is raised. Safeguards also have minimal application in the countries that are at the very heart of the nuclear weapons problem – the nuclear armed states. Inspection visits, for example, are virtually non-existent in the P5 (Russia, the US, China, France and the UK), which means that horizontal proliferation issues will generally not be detected. Uranium oxide mining, processing and sales Countries purchasing Australian uranium must enter into bilateral safeguards agreements. Australian Governments assert that such agreements provide reliable assurance that our uranium cannot end up in weapons. However the evidence is that safeguards cannot provide this guarantee. Accounting procedures for nuclear materials involve uncertainties and margins of error which, on the industrial scale involved, leave open the possibility of undetected diversion of fissile material. And at any stage of uranium enrichment, processing or fuel rod fabrication, it is impossible to distinguish between uranium from one source and uranium from any other source. Accounting is ‘virtual’.

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Australian governments state that our uranium is not sold to countries that are not compliant with their Nuclear Non-Proliferation Treaty (NPT) obligations. However ICAN rejects that claim. Article 6 of the NPT says:

“Each of the Parties to the Treaty undertakes to pursue negotiations in good faith on effective measures relating to cessation of the nuclear arms race at an early date and to nuclear disarmament, and on a treaty on general and complete disarmament under strict and effective international control.”

In other words the NPT members states that possess nuclear weapons (the USA, Russia, France, the UK and China) must get rid of their weapons. None of them are doing so. On the contrary, they have emphasised the central role that these weapons play in their defence planning (despite reductions in the numbers of US and Russian weapons) and are all modernising their nuclear weapons programsxxvi. Australia’s uranium sales to countries that undermine Article 6 of the NPT represents a serious breach of our Treaty obligations and should cease. The fact that this would almost certainly sound a death knell to our uranium export industry is irrelevant to our non-proliferation obligations. Australia also prides itself on supporting the Comprehensive Test Ban Treaty (which has not yet come into effect). However successive federal governments appear determined to sell uranium to India, which has not ratified the CTBT. India’s first nuclear test in 1974 used a reactor supplied by Canada and heavy water supplied by the US, and was in breach of assurances made to these suppliers that the materials would be used only for peaceful purposes. Its development of nuclear weapons sparked a nuclear arms race with Pakistan. Senior officials have acknowledged that, by exporting uranium to India, Australia would free up India’s domestic reserves of uranium for weapons productionxxvii. Unfortunately the situation has changed little since the 1970s Fox Report into Australia’s uranium sales, which referred to safeguards as providing an “illusion of protection”. Enrichment Uranium enrichment is one of the two processes by which fissile material for nuclear weapons can be produced (the other being reprocessing). Its significance is borne out by the grave concerns that were held in relation to Iran’s enrichment program, which illustrates how difficult it can be to distinguish peaceful from military programs. Because of this difficulty (and regardless of the facts on the ground in Iran) the process is vulnerable to political manipulation and the raising of tensions, especially if the latter also serves other agendas.

The serious proliferation problems associated with enrichment (and reprocessing, see below) have received de facto acknowledgement by virtue of efforts on the part of the US to limit the process to select countries. This was one element of President Bush’s 2006 Global Nuclear Energy Partnership (GNEP), now called the International Framework for Nuclear Energy Cooperation. (GNEP also sought “internationalization” of nuclear waste

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management, whereby countries could accept nuclear waste from elsewhere for interim storage, presumably in the belief that future generations would know what to do with it.)

GNEP’s attempt to define which countries can be trusted with domestic uranium enrichment and reprocessing raised the critical issue: who decides and by what authority? Rules made by self-appointed global policemen are not acceptable by any fair assessment and certainly not by countries excluded under the rules.

There is the additional problem that governments change, but nuclear technology and materials remain for a very long time. Iran’s first nuclear research reactor came from the US in the 1960s. Today’s friend may be tomorrow’s foe.

For these reasons, ICAN believes that, as a bare minimum step for as long as nuclear power continues, all uranium enrichment should be brought under genuine (ie not determined by any self-appointed grouping) international control. Plutonium and Reprocessing Reprocessing, the process whereby plutonium and unused uranium are extracted from spent fuel, poses particular proliferation and terrorism risks. Of the two materials that can fuel a nuclear weapon, enriched uranium and plutonium, enriched uranium is generally harder to acquire. Therefore any process that increases the availability of plutonium will increase the risk of diversion by proliferators and terrorists. Contrary to statements made by the nuclear industry, power reactors can be used to produce weapons grade plutoniumxxviii. The Global Fissile Material Report 2009, of the International Panel on Fissile Material (IPFM), stated:

“Reprocessing plants, by producing nuclear weapon material directly or nearly directly……provide the most plausible route to get weapon-usable material, and they shorten the time for a breakout to days or weeks. …….Given this situation, serious consideration should be given to the possibility of phasing out reprocessing plants altogether. In principle, this should not be a difficult decision, since reprocessing will not be necessary or economic for the foreseeable future. In practice, however, the powerful reprocessing and breeder reactor establishments in a number of countries would put up strong political resistance. ……..Even with stringent and equitable new rules to govern nuclear power, its continued operation and certainly any global expansion will impose serious proliferation risks in the transition to nuclear disarmament. A phase-out of civilian nuclear energy would provide the most effective and enduring constraint on proliferation risks in a nuclear weapon- free world.”xxix

In the summary of its 2015 report, “Plutonium separation in nuclear power programs”, the IPFM stated:

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“Reprocessing …..leaves two costly and dangerous legacies: reprocessing complexes that are contaminated with radioactive materials, and a steady build-up of a global stockpile of separated civilian plutonium that is currently estimated as being sufficient for more than 30,000 nuclear bombs.

As all these problems with reprocessing have become more widely appreciated, there has been a steady decline in the number of countries that reprocess — currently six —and this trend is likely to continue. The decline has not been as rapid as warranted by the magnitude of the problems confronting reprocessing because of resistance from entrenched bureaucracies that have sought to sustain national commitments to separating plutonium and, often, breeder reactors. Nevertheless, as this global overview of reprocessing shows, the world is closer to the end of separating plutonium and the associated security, economic and environmental dangers.”xxx

The Panel also recognises the concerns of neighbouring countries that are raised by plutonium stockpiles, using the example of Japan’s enormous quantities of plutonium:

“By the 1990s, Japan’s stockpile of separated plutonium had grown considerably because of continued reprocessing of the spent fuel from its light water reactors despite the postponement of its breeder reactor program. This raised questions in the United States and among Japan’s neighbours.”xxxi

In the light of the grave security and other concerns in relation to reprocessing, there can be no legitimate reason for continuing the technology. The commencement of reprocessing technology in South Australia would be a foolish and regressive step beyond all comprehension.

i Nuclear power plant accidents: Listed and ranked since 1952. The Guardian 18 March 2011. http://www.theguardian.com/news/datablog/2011/mar/14/nuclear-power-plant-accidents-list-rank. Nuclear power accidents. Union of Concerned Scientists. http://www.ucsusa.org/our-work/nuclear-power/nuclear-power-accidents#.Vb3EGnk4Gbg ii See for example: Paul R Ehrlich et al. Long term biological consequences of nuclear war. Science, vol 222, 23 Dec 1983, pages 1293 - 1299. War and Public Health. Eds Barry S Levy, Victor W Sidel. Oxfor University Press 1997. Pages 65 -83. Lachlan Forrow et al. Accidental nuclear war: A post Cold War assessment. New Engl J of Medicine.April 30, 1998. 1326 -1331 Unspeakable suffering – the humanitarian impact of nuclear weapons, 2013 Reaching Critical Will, a programme of the Women’s International League for Peace and Freedom, 2013, at http://www.icanw.org/wp-content/uploads/2012/08/Unspeakable.pdf

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iii Vienna Conference on the Humanitarian Impact of Nuclear Weapons. 8 to 9 December 2014. Report and summary of findings. http://www.bmeia.gv.at/fileadmin/user upload/Zentrale/Aussenpolitik/Abruestung/HINW14/HINW14 Chair s Summary.pdf iv http://www.ippnw.org/nuclear-famine.html

Michael J. Mills, Owen B. Toon, Julia Lee-Taylor, and Alan Robock, 'Multidecadal global

cooling and unprecedented ozone loss following a regional nuclear conflict', Earth's Future,

Volume 2, Issue 4, pages 161–176, April 2014, DOI: 10.1002/2013EF000205,

at http://onlinelibrary.wiley.com/doi/10.1002/2013EF000205/full; and David Pimentel,

Michael Burgess, 'Nuclear War Investigation Related to a Limited Nuclear Battle with

Emphasis on Agricultural Impacts in the United States', AMBIO 2012, 41:894–899, DOI

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See also.

v http://www.icanw.org/wp-content/uploads/2014/02/BlackMist-FINAL-Web.pdf

vi R Alvarez. Thorium: The wonder fuel that wasn’t. Bulletin of the Atomic Scientists 11 May, 2014. http://thebulletin.org/thorium-wonder-fuel-wasnt7156 Jim Green. Civil nuclear programs and weapons proliferation. EnergyScience. http://thebulletin.org/thorium-wonder-fuel-wasnt7156 vii I Helfand et al. Nuclear terrorism. British Medical Journal Vol 324, 9 Feb 2002. viii KJ Borger. The nuclear time bomb. Guardian Weekly 12 Sept 2008, page 23-25 ix http://www.nti.org/media/pdfs/Securing The Bomb 2010.pdf? =1317159794 . Page 22. x Plutonium: Rising terrorist threat. The Christian Science Monitor. October 7, 2004 xi UN calls for world terror treaty. The Canberra Times, March 12,2005. xii IAEA Director General concerned that terrorists could steal nuclear materials. http://www.nti.org/analysis/articles/iaea-director-general-concerned-terrorists-could-steal-nuclear-materials/ xiiihttp://www.oxfordresearchgroup.org.uk/publications/briefing papers/effective safeguards secure energy factsheet 2 xiv Lloyd J Dumas. Waking up to the real threats to security in the post-Cold War world. Swedish Section of International Physicians for the Prevention of Nuclear War. Human factor - and the risk of nuclear war. Stockholm, SLMK, 2004:16.

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xxviii Frank Barnaby. The management of radioactive wastes and the disposal of plutonium. https://www.mapw.org.au/files/downloads/Barnaby%20- Page 10 xxix International Panel on Fissile Materials. 2009. Global Fissile Material Report 2009. Page 113. http://fissilematerials.org/library/gfmr09.pdf xxx Plutonium Separation in Nuclear Power Programs. International Panel on Fissile Materials 2015. http://fissilematerials.org/library/rr14.pdf. Page 4. xxxi Plutonium Separation in Nuclear Power Programs. International Panel on Fissile Materials 2015. http://fissilematerials.org/library/rr14.pdf. Page 63