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Dayne Eckermann August 2015 1 Generating electricity from nuclear fuels A submission to Issues Paper #4 of the Royal Commission into South Australia’s involvement in the nuclear fuel cycle August 2015 Preface Our changing climate and the relationship with energy generation The latest report from the Intergovernmental Panel on Climate Change (IPCC) reinforces the link between concentrations of greenhouse gasses in the earth’s atmosphere and increases in global mean surface temperatures, stating that human interference of the global climate system is “clear”, that “recent anthropogenic emissions of carbon dioxide are the highest in history” and that a warming of the climate system is now “unequivocal” (Intergovernmental Panel on Climate Change, 2014). Global mean surface temperatures have increased by 0.85 degrees Celsius between 1880-2012 and annual average global carbon dioxide (CO2) concentrations reached 395 parts per million in 2013, their highest level for 800,000 years due mainly to the combustion of fossil fuels for energy generation (Intergovernmental Panel on Climate Change, 2014). In a more local context, Australia’s climate has warmed by 0.9 degrees Celsius since 1910 and these temperatures are projected to continue to increase into the future, cognisant to the concentrations of greenhouse gasses such as CO2 emitted into the atmosphere and ‘locked-in’ temperature increases due to current accumulated atmospheric greenhouse gas concentrations (Australian Government Bureau of Meteorology & Commonwealth Scientific and Industrial Research Organisation, 2014). Australia’s goal is to reduce greenhouse gas emissions to 80% below 2000 levels by 2050 (Wood & Edis, 2012). Reaching this target will require the successful reduction of emissions from electricity generation via a combination of increasing energy efficiency, reducing our overall energy production and consumption and in changing the way in which we produce stationary energy (e.g. electricity). Historically, stationary energy policy in Australia has focused on supplying electricity that is both secure and affordable. Australia has now effectively added a third objective: achieving low-carbon electricity generation within the coming four decades (Wood & Edis, 2012). More locally, South Australia has a greenhouse gas reduction target of 40% less than 1990 levels by 2050, legislated for in the Climate Change and Greenhouse Emissions Reduction Act 2007 (South Australia). Much of this reduction will come from changing the way in which South Australia produces its electricity and to date, South Australia has made significant inroads into the decarbonisation of its electricity generation via the successful integration of renewable energy such as wind and solar photovoltaic (PV) into its grid (Heard, Bradshaw, & Brook, 2015). This submission touches on the economic and technical complexities of integrating large amounts of intermittent renewable energy sources such as wind and solar PV and asserts that complementing South Australia’s successful renewable energy scale up and completing the decarbonisation task could be technically feasible using nuclear energy technologies. A number of analyses have been undertaken in recent years exploring pathways for Australia to adopt in order to transition it energy sector toward low or zero carbon sources. For example, Stock (2014) outlines a practical pathway to achieving a greenhouse gas emissions reduction

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Page 1: Generating electricity from nuclear fuels...2015/08/01  · Generating electricity from nuclear fuels A submission to Issues Paper #4 of the Royal Commission into South Australia’s

Dayne Eckermann August 2015 1

Generating electricity from nuclear fuels

A submission to Issues Paper #4 of the Royal Commission into South Australia’s involvement in the nuclear fuel cycle August 2015

Preface

Our changing climate and the relationship with energy generation The latest report from the Intergovernmental Panel on Climate Change (IPCC) reinforces the

link between concentrations of greenhouse gasses in the earth’s atmosphere and increases in

global mean surface temperatures, stating that human interference of the global climate system

is “clear”, that “recent anthropogenic emissions of carbon dioxide are the highest in history” and

that a warming of the climate system is now “unequivocal” (Intergovernmental Panel on Climate

Change, 2014). Global mean surface temperatures have increased by 0.85 degrees Celsius

between 1880-2012 and annual average global carbon dioxide (CO2) concentrations reached

395 parts per million in 2013, their highest level for 800,000 years due mainly to the combustion

of fossil fuels for energy generation (Intergovernmental Panel on Climate Change, 2014). In a

more local context, Australia’s climate has warmed by 0.9 degrees Celsius since 1910 and

these temperatures are projected to continue to increase into the future, cognisant to the

concentrations of greenhouse gasses such as CO2 emitted into the atmosphere and ‘locked-in’

temperature increases due to current accumulated atmospheric greenhouse gas

concentrations (Australian Government Bureau of Meteorology & Commonwealth Scientific

and Industrial Research Organisation, 2014).

Australia’s goal is to reduce greenhouse gas emissions to 80% below 2000 levels by 2050

(Wood & Edis, 2012). Reaching this target will require the successful reduction of emissions

from electricity generation via a combination of increasing energy efficiency, reducing our

overall energy production and consumption and in changing the way in which we produce

stationary energy (e.g. electricity). Historically, stationary energy policy in Australia has focused

on supplying electricity that is both secure and affordable. Australia has now effectively added

a third objective: achieving low-carbon electricity generation within the coming four decades

(Wood & Edis, 2012).

More locally, South Australia has a greenhouse gas reduction target of 40% less than 1990

levels by 2050, legislated for in the Climate Change and Greenhouse Emissions Reduction Act

2007 (South Australia). Much of this reduction will come from changing the way in which South

Australia produces its electricity and to date, South Australia has made significant inroads into

the decarbonisation of its electricity generation via the successful integration of renewable

energy such as wind and solar photovoltaic (PV) into its grid (Heard, Bradshaw, & Brook, 2015).

This submission touches on the economic and technical complexities of integrating large

amounts of intermittent renewable energy sources such as wind and solar PV and asserts that

complementing South Australia’s successful renewable energy scale up and completing the

decarbonisation task could be technically feasible using nuclear energy technologies.

A number of analyses have been undertaken in recent years exploring pathways for Australia

to adopt in order to transition it energy sector toward low or zero carbon sources. For example,

Stock (2014) outlines a practical pathway to achieving a greenhouse gas emissions reduction

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target of 80% by 2050, which recommends the replacement of old fossil fuel power plants with

more efficient technologies, the capture and sequestration of emissions produced from existing

fossil fuel plants and the production of more zero emission renewable energy. Unfortunately,

what is otherwise a sound and informative analysis does itself a disservice by arbitrarily

excluding the use of nuclear power from its discussion of options for Australia’s energy future.

In addition, the analysis discusses large-scale solar photovoltaic (PV) energy installations but

fails to adequately compare this technology to other large-scale sources on criteria such as

capacity factor, which would reveal substantial limitations associated with this technology. In

addition, the analysis fails to account for the intermittency of renewable energy technologies

such as wind and solar PV, which creates unique complexities in managing their contribution

to a standard electricity grid and often leads them to be wedded to natural gas (The Grattan

Institute, 2011). Another study of note, undertaken by Elliston, Diesendorf and MacGill (2012),

also consciously excludes nuclear energy from its work in modeling a decarbonised electricity

system comprised of 100% renewable energy using a combination of energy storage

technologies, intermittent renewable sources and sources such as biomass to provide baseload

electricity typically performed by thermal generators such as coal or natural gas. While the

study in question recognises the crucial function of baseload generation in an electricity market

such as the National Electricity Market (NEM) of which South Australia’s grid is connected to,

the work of Elliston, Diesendorf and MacGill (2012) has been effectively critiqued on

technological and economic grounds in studies such as Heard, Bradshaw and Brook (2015).

The key factors underpinning critical analysis of the works such as those mentioned above will

be touched on throughout this submission.

Energy reliability and economic development The development of the Australian economy, much the same as the rest of the western

developed world, has been underpinned by access to cheap and reliable energy. In the

Australian context, fossil fuels such as coal and natural gas have supplied this cheap and

reliable energy. Countries in the global ‘south’ (i.e. developing nations), with large populations

and significant sections of society lacking access to reliable electricity, are in the midst of

unprecedented development and as such, will require large amounts of installed electricity

generation. Contrary to popular notions of sustainable development that prescribe a form of

energy austerity to address socio-environmental objectives, it is the massive expansion, rather

than contraction of energy systems, carried out primarily in the relentlessly urbanising global

‘south’, that provides the context and opportunity for a robust, coherent, and ethical response

to the global challenges of sustainable human and economic development (Caine, et al., 2014).

The use of solid fuels (coal and biomass) - a common source of energy in developing nations

where populations lack access to large scale, reliable energy - is likely to be the largest source

of air pollution on a global scale and as such, more than 1.6 million deaths of 38.5 million

disability adjusted life years are attributable to indoor smoke from solid fuels in 2000 (World

Health Organisation, 2006). For example, the air in New Delhi, India, is the world’s most toxic

in part due to the high concentrations of PM2.5 1, comprised of burning garbage, coal and diesel.

While ‘developing’ countries such as India are planning to expand their use of coal-fired

electricity out of necessity and accessibility (Harris, 2014), the global energy, air quality and

climate change imperative means that decisions to bring online new electricity generation

infrastructure will need to, where possible, consider lifecycle greenhouse gas emissions if

countries are committed to a global effort to avoid the worst case temperature rise scenario

and worst impacts of climate change by containing atmospheric CO2 concentrations to 450

1 PM2.5 refers to particulate matter less than 2.5 micrograms in diameter. The safe level of PM2.5 is 25 micrograms per

cubic meter. The air in New Delhi has been measured at 225 micrograms per cubic meter (Harris, Delhi wakes up to a problem it cannot ignore, 2015).

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parts per million.

For rural and smaller scale settings in countries such as India, renewable energy technologies

such as solar photovoltaic (PV) will form an important component of the energy access

challenge (Katakey & Chakraborty, 2014). However, the scale of energy required is such that

in order to satisfy its goal of achieving 20 per cent low carbon energy by 2030, China, for

example, will need to build between 800-1000 Gigawatts of clean power over the next fifteen

years, essentially duplicating the entire energy fleet of the United States (Johnson, 2015). Thus,

as the largest, most mature source of low carbon baseload energy globally (World Nuclear

Association, 2015a), nuclear energy will play an important role alongside renewable energy in

addressing the dual climate change and economic development imperatives for many

jurisdictions. In this context, it is inevitable that the scale up of low carbon baseload sources of

energy such a nuclear power will occur at a significant rate in the coming years. This submission

outlines the factors that may determine the potential for nuclear power to play a role in in the

future South Australian energy mix. In addition, it will identify barriers to deploying nuclear

energy in South Australia along with the actions necessary to overcome these barriers and

facilitate the development of a nuclear energy industry in the State.

Nuclear energy and the social licence to operate

In an increasing world of scrutiny and mobilisation of local voices, a lack of broad-based support

for a particular action will deprive a company, individual or government a ‘social licence’ to

operate (Morrison, 2014). The historical social apprehension to nuclear energy in Australia,

arguably cultivated by negative reactions to the nuclear bombings of Hiroshima and Nagasaki

during the second World War, the negative legacy of nuclear tests in places such as Maralinga

and serious civilian nuclear accidents such as Chernobyl, Ukraine in 1986 and Fukushima

Daichi, Japan in 2011 make earning and maintaining a social licence to operate crucial for the

adoption of a nuclear industry in South Australia. While sometimes being overly subjective,

conceptual or ill defined in its criteria, the ‘social licence’ is intended as a metaphor to

encapsulate values, activities and ideas, which companies, individuals or governments must

espouse within society to ensure successful operation (Bice, 2014). The social licence to

operate is a concept at the forefront of the sectors that operate at the front end of the nuclear

fuel cycle (EY Global, 2014). However, broadening the discussion to nuclear energy generation

in South Australia will require a strategic, inclusive and effective engagement process in order

to secure this social licence. The work of the Royal Commission into the nuclear fuel cycle is a

timely and important contribution to developing and securing a social licence for the prospective

development of a nuclear energy industry in South Australia.

The following submission will respond, where possible, to the key questions proposed in Issues

Paper #4.

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

Almost 80% of the nuclear reactors operational worldwide are "Light Water Reactors", which were the fi rst civi lian nuclear reactors to be deployed in the United States (Perry, et al. , 1977). Most Light Water Reactors use a 'once through' fuel cycle, where 99% of the potential energy content of the fuel is unused and required to be managed as high-level nuclear waste (Price & Blaise, 2002). Light Water Reactor technology also relies upon traditional uranium enrichment technologies, which some more modern reactor technologies do not (Rothwell & Van der Zwann, 2002). The following table documents the nuclear reactors currently in operation around the world.

Table 1.0 - nuclear reactors in operation around the world, according to the International

Atomic Energy Agency ~~~~ li!i.mlill•IO IIIIU U:.l-"1 11111•111 l[;.j ~ (;mm [itO'r.1 F.1'il ~

Pressurised Water US, France, Japan, 277 257 enriched U02 light Reactor (PWR) Russia, China water Boiling Water Reactor US, Japan, Sweden 80 75 enriched U02 light (BWRf water Pressurised Heavy Canada 49 25 natural U02 heavy Water Reactor 'CANDU' water (PHWR) Gas-cooled Reactor UK 15 8 natural U (metal), C02 (AGR & Magnox) enriched U02 Light Water Graphite Russia 11 + 4 10.2 enriched U02 light Reactor (RBMK & EGP) water Fast Neut ron Reactor Russia 2 0.6 Pu02 and U02 liquid (FBR) sodium

This submission asserts that on the basis of the factors explained above and others that will be explored throughout this paper, that a gigawatt scale Light Water Reactor is not a suitable reactor technology for the near term involvement in South Australia. Nuclear reactor technology has matured over the last few decades, enhancing the efficiency of reactors, optimising fuel inputs, energy output dynamics and minimising the necessity of managing large amounts of high-level waste material. Two of these two key technologies are explored below:

Enhanced CANDU 6 (EC6) pressurised heavy water reactor (PHWR) The enhanced CANDU 6 (EC6) pressurised heavy water reactor (PHWR) is designed by Candu Energy Inc. , a wholly owned subsidiary of SNC-Lavalin Inc. It is a heavy water moderated reactor that operates at low pressure with online refuelling. The utilisation of a heavy water (deuterium, 020) enables the operator to fuel the reactor with natural uranium, thorium or in special configurations plutonium in mix oxide fuel (MOX). The reactor has a rated gross generation of 740 MWe and net 690 MWe generation capacities. The CANDU series of reactors operate predominately on the grid of Ontario, Canada, South Korea, Romania, India, Pakistan and Argentina where there are 34 CANDU reactors constructed worldwide (Canadian Nuclear Association, 2015).

Dayne Eckermann August 2015 4

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GE Hitachi PRISM Reactor

The General Electric (GE) Hitachi Power Reactor Innovative Small Module (PRISM) is a version

of the Integral Fast Reactor, the successor to the Experimental Breeder Reactor II (Think

Climate Consulting, 2013). It is a high neutron (fast) reactor, using liquid sodium as its coolant,

which allows neutrons in the reactor to remain at a higher energy (or speed). The energy level

(or speed) of the PRISM allows an efficient reaction with substances such as plutonium and

other very heavy elements that contribute to the complexity of managing spent nuclear fuel.

This reaction produces heat energy, which can be converted into electrical energy through a

conventional steam turbine. This process of utilising plutonium as a feedstock for electricity

generation helps to close the current nuclear fuel cycle by reducing the half life of spent fuel to

hundreds, rather than hundreds of thousands of years (GE Hitachi, 2015).

Characteristics that make the CANDU and PRISM technically suitable The most common characteristic of all nuclear reactor technologies which make them

technically suitable for generating electricity for the NEM is their ability to provide dispatchable,

synchronous generation (i.e. baseload) which has the potential to assume the role currently

performed by the gas-fired generation plants at Pelican Point and Torrens Island.

The CANDU reactor utilises passive safety systems (i.e. without the need for human

intervention) and standardised designs and construction (Think Climate Consulting, 2013). In

addition, it uses non-enriched uranium as fuel, making it a viable option for utilising uranium

oxide mined in South Australia without the need to establish enrichment facilities. In addition,

one fuel bundle lasts for over a year and this fuel can be continuously changed while the reactor

is in operation, keeping the capacity factor of the plant high (Bordia, 2012).

Two operating modes are possible with a CANDU reactor: reactor following turbine mode and

turbine following reactor mode. Under the reactor following turbine mode, the turbine generator

load is set by the operator, whereby the steam generator pressure control program ‘requests’

variations be made to reactor power in order to maintain a constant steam generator pressure.

Under the turbine following reactor mode, station loads are made to follow the reactor output.

Plant loads are adjusted to maintain constant steam pressure, usually at low reactor power

levels, during start up and shut down (Kok, 2009). These are reactor regulator systems

designed to accommodate changing turbine steam demands in response to changing grid

conditions. In addition, the new CANDU reactors proposed for build in Ontario, Canada, should

be extremely flexible and able to operate within a grid featuring high penetrations of wind power

generation (Jones, 2013), similar to South Australia’s current grid. This concept is explained in

further detail when the relationship between a nuclear reactor and the National Electricity

Market (NEM) is discussed.

Characteristics of the National Electricity Market (NEM) that determine the suitability of a nuclear reactor for connection

In order to sustain the network within the National Electricity Market, a level of synchronous

thermal generation is required (Australian Energy Market Operator , 2013). In other words,

electricity generation sources that service base load requirements are necessary and

generation and distribution systems need to maintain an instantaneous balance between

supply and demand. If this does not occur, the system voltage or frequency may fall or increase,

which may cause the system to become unstable, tripping out other generation sources.

System imbalances can occur through variances in demand (from factors such as increased

use of heating and cooling devices during temperature extremes) or variances in supply caused

by operational set backs at base load plants or intermittency in renewable energy sources such

as wind (Stock A. , 2014).

Nuclear energy is the world’s largest and most mature low-carbon base load source of energy,

accounting for 11% of global electricity generation over 437 reactors worldwide (World Nuclear

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Association, 2015a). South Australia currently sources its baseload electricity generation from

brown lignite coal at Port Augusta and open cycle gas plants at Torrens Island (Australian

Energy Regulator, 2012). In addition, South Australia relies upon its participation in the NEM –

predominately by importing a level of electricity from Victoria via the Heywood interconnector -

for a reliable supply of electricity (Australian Energy Market Operator , 2013). This is due to the

high penetration of variable wind energy that has come at the expense of existing coal and gas

generators, which are now run less frequently (Australian Energy Market Operator, 2014).

Based on the characteristics of the NEM, nuclear energy is technically suitable to perform the

function as a thermal baseload generator, currently performed in South Australia by coal,

natural gas and integration with the broader NEM, as a replacement for a portion – if not all –

of this existing generation. This conclusion is reinforced by Heard et al. (2015) in a comparative

analysis of technological options for the decarbonisation of South Australia’s electricity

generation infrastructure

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

Typically, for an off grid setting there would need to be sufficient load demand to operate a nuclear reactor at a constant rate for a period of time. These locations would often be uneconomical to connect to the grid due to spatial factors and be unable to source alternative off-grid electricity generation technologies such as diesel co-generation.

Small Modular Reactors The present suite of small modular reactors could be suitable for the small to medium load requirements of remote areas. The small electrical output size ranging from 1 OMWe to 300MWe of these reactors affords the opportunity to provide a steady year round output of 74% to 95%2.SMRs have the capability to have multiple reactor units on one site providing the flexibility to deliver a variable supply to meet the demands of the respective network. The following table (table 1.x) (World Nuclear Association, 2015b) highlights the current SMRs in operation, under construction, near-term deployment, and designs.

2 This range represents the average minimum and maximum of all countries operational nuclear reactors as determined by Platts. As most designs for SMRs are of a light water design the operational capabilities would be similar; (Platts, 2015)

Dayne Eckermann August 2015 7

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LFTR/TMSR 5, 100 MWe SINAP, China

PB-FHR 100 MWe UC Berkeley, USA

Integral MSR 29, 120, 288 MWe Terrestrial Energy, Canada

Fuji MSR 100-200 MWe ITHMSI, Japan-Russia-USA

Leadir-PS100 36 MWe Northern Nuclear, Canada

In addition to the GE Hitachi PRISM reactor, which can be developed as an off-grid, small-

modular style reactor, the Westinghouse SMR is a >225 MWe integral pressurised water

reactor with all primary components located inside the reactor vessel. It features passive safety

systems designed to shut down the plant automatically in the event of a loss of AC power for

up to seven days. The Westinghouse SMR also has the capability of economically handing the

unique challenges of providing baseload power on smaller grids and those with non-steady

power sources, with an easy transition between load following and baseload of 5% power

output change (from 100% to 20%) per minute (Westinghouse, 2015).

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What factors affect the assessment of viability for installing any facility to generate electricity from the National Electricity Market? How might these factors be quantified and assessed? What are the factors in an off-grid setting exclusively? How might they be qualified and assessed? There are three key constraints that will determine the viability for installation of a facility into

the National Electricity Market (NEM):

1) Demand for electricity generation in the respective region (plant need)

2) Market availability (economics)

3) Transmission capabilities (transmission links)

Installation into the National Electricity Market (NEM) will require that the operational aspects

of the nuclear plant to be assessed against the local market. As stated earlier, the large size of

current operational light water reactors are not presently suitable for the South Australian

market. This is due to the operational design of nuclear reactors that is optimal at constant

supply at full or near full power (World Nuclear Association) and the decreasing minimum

demand profiles needed in South Australia (Australian Energy Market Operator, 2014).

However this is not to say that nuclear reactors cannot be flexible as operational experience in

Germany by RWE and E.On (2011) demonstrated that a nuclear reactors can load follow in

peaky or grids with a high penetration of renewable energy (Fuchs, ON, & Timpf, 2011).

The two key factors to assess are the design of the reactor and its operational capabilities and

the need for further electricity supply or to replace retiring generators in a respective market.

Modelling conducted by Australian Energy Market Operator (AEMO) and the design profiles of

respective reactors will need to be quantified to determine a suitable fit for the South Australian

grid.

As mentioned earlier, the CANDU reactor has been designed to smaller module size in India

(300MWe) and the PRISM reactor modules are small enough (311MWe) to fit into the South

Australian grid. There are existing generators such as the Northern coal-fired plant (2x

260MWe) and Torrens Island A combined cycle gas turbine (480MW) that are planned to close

that present opportunities to similar sized and operating plants to supply the South Australian

grid.

Off grid settings will require a large load for giga-watt sized nuclear plants or for medium to

smaller loads a small modular reactor could be appropriate. Presently in South Australia there

is not a significant off-grid load to utilise a nuclear power plant.

In addition to the operational capabilities there will be assessment criteria that will be

established under a regulator to license and approve siting of new nuclear power plant facilities.

These will need to be taken into consideration once the regulator is established to determine

the viability for installing a facility into the NEM.

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

Grid augmentation

As nuclear reactors operate in the same manner as other thermal power plants, theoretically

there is no physical impediment to constructing a plant on the existing network. As the NEM

grows into the future there may be capacity additions that would require further augmentation,

especially if a large-scale plant (Giga watt size) was built in South Australia where the likely

surplus electricity would be exported into Victoria. As explored in a study by Baker McKenzie,

Worley Parsons and MacQuarie (2010) on the potential for integration of wind energy into the

South Australia electricity grid, the integration of new electricity generating infrastructure in

South Australia is likely to be limited by the quality of its grid. There is a current thermal limit of

about 500MW between South Australia and Victoria due to the constraints on the Heywood

interconnector transformers which can result in network congestion and during periods of light

electricity demand, a lack of augmentation in the South Australian electricity network will limit

the potential for the integration of new electricity generating infrastructure into the grid (Baker

McKenzie, Worley Parsons and MacQuarie, 2010).

Removing economic barriers and supporting the development of new technologies The development of a nuclear reactor in South Australia would require more favourable

electricity market mechanisms and investment conditions to de-risk investments and allow

investors to recuperate high up-front capital costs. This could be achieved through long-term

contracts to manage the specifications of high fixed-cost, low carbon technologies and via the

following other environmental and energy policy mechanisms.

Carbon pricing The policy intent of a carbon price or emissions trading scheme (ETS) is to internalise the cost

of an environmental externality – greenhouse gas emissions – to reduce high carbon-emitting

activities while simultaneously supporting the emergence of new forms of technology and

innovation as to facilitate a transition to a low carbon economy (AECOM, 2013). The practical

experience of carbon pricing in Australia has been limited and highly politicised, particularly

from a cost of living and industry competitiveness perspective. However, a carbon price is

generally considered necessary for enabling least cost emissions reductions and should be the

cornerstone of any climate-energy policy package (Hood, 2013).

In the absence of a mechanism that adequately prices greenhouse gasses, baseload electricity

generation sources such as coal and combined cycle natural gas enjoy more favourable

economics over nuclear energy to a degree of approximately 20-50% (Uranium Mining,

Processing and Nuclear Energy Review Taskforce, 2006). Comparatively, the Australian

Government Bureau of Resource Energy Economics (2012) in its Technology Assessment,

cites a levelised cost of electricity (LCOE)3 for supercritical pulverised brown coal at $95/MWh,

supercritical pulverised black coal at $84-94/MWh and a combined-cycle gas turbine at $81-

93/MWh in the absence of a carbon price. As a point of comparison, Generation 3 nuclear was

rated at $94-99/MWh.

3 LCOE represents the per-kilowatt hour (KWh) cost (in real dollars) of building and operating a generating plant over

an assumed financial life and duty cycle. Key inputs to calculating LCOE include capital costs, fuel costs, fixed and variable operations and maintenance (O&M) costs, financing costs, and an assumed utilization rate for each plant type (US Energy Information Administration, 2015).

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An analysis of profits conducted by the Organisation for Economic Co-operation and

Development (2011) showed that during the years 2005-2010, nuclear, when compared against

coal and natural gas (its chief competitiors in an Australian example) made substantial profits

due to carbon pricing. Low and medium-high carbon prices of up to 50€/tonne of CO2-e

increase the competitiveness of nuclear power. However, in contrast to the conclusions of the

LCOE methodology employed in the study, high carbon prices do not unequivocally improve

the competitiveness of nuclear energy in a liberalised electricity market such as the NEM, as it

can actually increase the profitability of natural gas faster than nuclear when coal is made

marginal under the pricing scenario (Organisation for Economic Co-operation and Development

Nuclear Energy Agency, 2011). With this in mind, the development of a nuclear reactor in a

liberalised electricity market such as the NEM is also likely to rely upon a complementary

subsidy scheme such as a Clean Energy Target.

CET instead of a RET One of Australia’s primary energy policy instruments designed to facilitate the decarbonisation

of Australia’s electricity generation is the renewable energy target (RET), which operated in

tandem with a carbon price, legislated under the Clean Energy Act 2011 (Cth) until the repeal

of the carbon price in 2014. It is now the primary climate change policy instrument in the

absence of a carbon price and the target mandates the purchase of renewable energy

generation ‘certificates’ by electricity retailers in an effort to incentivise investment in renewable

energy generation assets. The overall objective of the target is to have renewable energy

comprise 20% of Australia’s entire electricity grid.

The complexities of the RET are highly political, often poorly understood and misreported in the

media. This is illustrated by a 2014 review into the target – albeit political in its own right – which

has been largely dismissed by individuals or organisations in support of renewable energy

expansion such as the Climate Council as a loaded document insensitive or hostile to

Australia’s electricity sector decarbonisation imperative (Stock, 2015). Nevertheless, the key

messages of the 2014 review were that mandated purchase of electricity certificates from

variable sources of generation irrespective of demand had encouraged significant growth in

renewable energy but created an oversupply in the electricity market which had distorted

energy prices, investment decisions and compromised the economics of some baseload

generators (Commonwealth of Australia, 2014). While the initial RET was set at 46TWh (or

20% according to forecasts at the time), declines in energy demand for reasons such as energy

efficiency improvements meant that on current trajectory, achieving the target would see

renewable energy comprise up to 30 per cent of Australia’s electricity sector, further inundating

the market with variable and superfluous electricity, affecting the economics of baseload

generators and thus placing the reliability of electricity grids such as the NEM at risk

(Commonwealth of Australia, 2014). The scale of oversupply, mostly through the eastern

states, is between 7650 and 8950 megawatts, lowering the wholesale electricity price and

causing some baseload generators to go offline in places such as Tasmania, where it has been

reported that nearly 1400 megawatts of coal and gas capacity were withdrawn alone (Potter,

2015). The International Energy Agency cites common challenges associated with increasing

the share of renewable energy in an electricity grid, such as challenges for electricity security,

voltage stability issues, depressed wholesale electricity prices and declining profitability of

existing power plants (International Energy Agency, 2013). The Australian experience of the

RET to date mirrors some of these cited challenges.

Ostensibly, the retirement of large, inefficient and carbon-intensive baseload generators is a

positive thing from an energy efficiency and climate change perspective. However, there are

unintended consequences of this policy in its current form that can compromise energy security

and the reliability of grids such as the NEM. Given the nature of the NEM and the requirement

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to have synchronous generation to provide adequate backup in light of the variability from high

penetrations of intermittent renewable energy generation such as wind, the withdrawal of

current or additional baseload generators could result in widespread power outages within the

NEM as the market operator would be unable to maintain frequency in a power system that

becomes isolated in a scenario of high penetration of variable generation sources (Australian

Energy Market Operator , 2013).

In a liberalised electricity market such as South Australia’s and many other parts of the NEM,

a more equal system, whereby all sources of low carbon electricity generation are subject to

mechanism such as the mandatory purchasing of certificates or feed-in tariffs would create

conditions favourable for the development of a nuclear power plant. This is a sentiment echoed

by the International Energy Agency (2013) and as it currently stands, the mandatory certificate

mechanism in place has a narrow focus on renewable energy technologies and particularly

those that are variable such as wind and solar photovoltaic, degrading the economics of

baseload generators and thus creating a large disincentive to develop new baseload generation

assets, nuclear or otherwise (natural gas, hydroelectric, solar thermal). The adoption of a ‘clean’

or ‘low carbon energy’ target, one of the recommendations proposed in the 2014 review of the

RET (Commonwealth of Australia, 2014), would satisfy this need.

Contract-for-Difference scheme The United Kingdom (UK) currently has a contract-for-difference (CfD) scheme to encourage

the construction and deployment of low carbon technologies. This scheme sets a price at which

the generator is guaranteed for a period set out in a contract. This guaranteed price will ensure

that for generation sold under the set CfD price will be made up to the CfD and that generation

sold over the CfD will be payed back to the statutory authority (Department of Energy and

Climate Change, 2015).

In the UK the statutory authority is the UK Low Carbon Contracts Company (LCCC) that

administers and regulates the CfD scheme. The LCCC recuperates the cost of paying

generators by a levy on electricity consumers. Currently in the UK new nuclear has arranged a

set contract price for electricity of 9.25p/kWh (18c/kWh AUD) and wind projects have secured

8.05p/kWh for onshore and 11.7p/kWh for offshore (Weston, 2015).

This is a scheme that has allowed projects to bid for a price of electricity that ensures the

viability of the project though payments from a statutory authority when the wholesale market

price is below the set CfD with a levy upon all users of electricity on that grid to fund the scheme.

Legislative repeal of anti-nuclear laws

Any consideration of construction of a nuclear power industry in South Australia will need to

overcome three key legislative barriers that presently exist. These barriers are at the Federal

and State level. The following are the Acts and Sections that will need to be amended or

repealed:

Section 10 Australian Radiation Protection and Nuclear Safety Act 1998 (Cth)

Section 140A Environment Protection and Biodiversity Conservation Act 1999 (Cth)

Nuclear Waste Storage Facility (Prohibition) Act 2000 (SA)

ARPANS and EPBC Act Section 10 of the Australian Radiation Protection and Nuclear Safety Act (ARPANS Act) and

Section 140A of the Environment Protection and Biodiversity Conservation Act (EPBC Act)

prohibit the Chief Executive Officer of ARPANSA or the Commonwealth Environment Minister

from licensing or approving the construction of any of the following facilities:

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Nuclear fuel fabrication plant

Nuclear power plant

Enrichment plant

Reprocessing facility

While the ARPANS Act would not necessarily apply to licenced facilities in South Australia, the

EPBC Act would certainly need to be amended to allow the Environment minister to approve a

facility through the Environmental Impact Assessment process that would be triggered as per

section 21 of the EPBC Act (nuclear actions). For further discussion of the origins of the nuclear

prohibitions in the EPBC and ARPANS Acts refer to Appendix A.

Nuclear Waste Storage Facility (Prohibition) Act 2000

The Nuclear Waste Storage Facility (Prohibition) Act 2000 is a South Australian Act in response

to the proposal to store high level nuclear waste in the State. For a nuclear plant to store and

manage spent nuclear fuel on site this Act will need to be repealed or amended to allow this

safe4 management of spent nuclear fuel. The Act states that it is intended to protect the health

safety and welfare of the people of South Australia. A process whereby a project developer can

demonstrate that a storage technology in use satisfies the objects of the Act and is verified by

the regulator should be allowed by the Act to occur.

4 Spent Nuclear Fuel is presently stored in dry casks after cooling in hardened pools within the nuclear island, providing sufficient barriers to protect the environment and public from harm (Nuclaer Regulatory Commission, 2015)

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

The United Kingdom Office of Nuclear Regulator The licensing and regulation processes for Nuclear Power in the United Kingdom (UK) is

presently undertaken by a joint process between the Office of the Nuclear Regulator (ONR)

and Environment Agency (EA), and the ONR itself respectively. The ONR is a statutory

authority created under the Energy Act 2013 (UK) to establish standards, licence nuclear sites,

and regulates and monitor the nuclear industry in the UK. It also provides advice to Secretaries

(equivalent of Ministers in Australia) on matters relevant to the nuclear industry and the

respective portfolio of the Secretary (Office of the Nuclear Regulator United Kingdom).

The ONR has established a licensing approvals process in conjunction with the EA known as

a Generic Design Assessment (GDA). The GDA was established after recommendations in the

2006 energy review. The main objective of a GDA is to enable the nuclear regulators to become

involved in a licensing process at an early stage of development before a project proponent

makes firm commitments. This enables the regulator and proponent to make any design or

development changes while the project designs are still on paper (Office of the Nuclear

Regulator United Kingdom). This process negates any project delays during construction,

which can negatively affect project finances.

This process is similar to that which is deployed by the Department of State Development where

all approvals and assessments are done at the ‘on paper’ stage and any regulatory or

stakeholder concerns are deliberated and responded to during this phase5. In addition to this

process the lead agency establishes case mangers for individual project applications and then

liaises and delegates to relevant departments on different aspects of the application.

This process requires the project proponent to display an understanding of the hazards and

risks then to show appropriate management systems, while the regulator acts as a central point

of contact and delegates to relevant authorities to ensure an efficient process. This process

results in the ONR and EA to create a Joint Program Office to manage correspondence,

technical issues and contacts. Resulting in the approval of a project with a Design Acceptance

Confirmation (DAC) and the EA to issue a Statement of Design Acceptability (SoDA).

Under this system the AREVA European Pressurised Water Reactor (EPR) was approved and

certified under this system in four years leading to the decision to construct a unit at Hinkley

Point. Currently the ONR and EA are undertaking the GDA process for GE-Hitachi Advanced

Boiling Water Reactor (ABWR) and the Westinghouse AP1000 reactor. All documentation on

these processes is available on the ONR’s webpage6.

The French nuclear scale up In response to the 1973 oil crisis, the French Government embarked upon the world’s most

remarkable scale-up in nuclear power generating infrastructure, building 58 Pressurised Water

5 See Part 9 Sections 57 to 63 of the Mining Act 1971 (SA) for more detail; See Part 9 Section 61 of the

Mining Act 1971 (SA) for more detail 6 http://www.onr.org.uk

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Reactors (PWR) from the early 1970s through to 2000, with a total gross installed capacity of

66GWe. On completion, they produced some 400 TWh per year of electricity, or close to 80%

of France’s energy production (Grubler, 2012). The institutional key to success in France was

the extremely limited number of institutional actors that allowed for centralized decision making

(Grubler, 2010). These senior actors were extraordinarily well coordinated through a small

technocratic elite of engineers, whom worked in tandem with the state owned utility, Électricité

de France (ÉDF), and the state nuclear R&D organization (CEA) (Grubler, The French

Pressurised Water Reactor Program, 2012). Reactor designs were also largely standardized

which made for comparatively shorter construction times to other programs internationally

(Rangel & Leveque, 2012).

The United States Experience

As outlined in the French case study, the standardisation of the design of a nuclear reactor –

in this case the Light Water Reactor – is an essential element in maintaining a viable and safe

program. Commercial reactors in the first few decades of development in the United States

were built with an unusual degree of variability and diversity. For example, by as late as 1981

the tasks of designing, constructing and operating nuclear reactors were handled by diverse

and independent organisations (Princeton University,N.D). In addition, a combination of poorly

conceived assumptions that Light Water Reactors would be no less complex to build than a

coal plant and directives to improve safety features led to substantial cost and time overruns

that would significantly damage the economic case for building nuclear reactors over coal

plants (Perry, et al., 1977).

Several large nuclear power plants were completed in the United States during the early 1970s

at a typical cost of $170 million, whereas plants of the same size completed in 1983 cost an

average of $1.7 billion, a 10-fold increase. Some plants completed in the late 1980s cost as

much as $5 billion, 30 times what they cost 15 years earlier (Cohen, 1990). As mentioned

above, these cost escalations were also met with significantly protracted build times. In addition

to the underestimation of construction complexity and necessary safety improvements, the cost

escalations in the United States can be attributed predominately to rising costs of labour

(particularly professional labour); inflation; regulatory ratcheting largely unscientific in its basis

and in response to public concerns, political pressure and lessons from the Three Mile Island

accident in 1979; and changing regulations, which required costly modifications to plant builds

and exposed decision-making processes to vexatious claims by opponents, which also led to

protracted construction timeframes (Cohen, 1990).

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What place is there in the generation market, if any, for electricity generated from nuclear fuels to play in the medium to long term? Why? What is the basis for that predication, including the relevant demand scenarios? Given the current lack of commercial viability for small modular reactors (SMRs) to be used in

a remote, off-grid setting, a nuclear plant in South Australia would need to assume the role as

a synchronous baseload generator, a role currently performed by combined cycle natural gas

and coal. Given the lack of impetus for any new base load generation within the NEM

(Australian Energy Market Operator, 2014), it is likely that combined cycle gas turbines – and

to a lesser extent, coal generation – will assume the role of base load generators for the medium

term at least, unless a conscious commercial and environmental decision was made to replace

this generating infrastructure prior to its economic life being reached.

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What issues should be considered in a comparative analysis of the advantages and disadvantages of the generation of electricity from nuclear fuels as opposed to other sources? What are the most important issues? Why? How should they be analysed? All currently available and commercially deployable energy technologies should be subject to

multi criteria analysis, which includes factors such as levelised cost of electricity, installed

capacity, capacity factor7, dispatchability, scalability, life cycle greenhouse gas emissions,

capital costs, land use and location. Many comparative analyses of electricity generation

technologies for Australia neglect some of these factors – particularly when comparing

renewable energy technologies with thermal generation sources such as coal and natural gas

– which do themselves a disservice at best or are deliberately misleading at worst. For example,

much of the focus on wind energy development has been on its costs relative to coal-fired

power stations (Parkinson, 2013), neglecting factors such as dispatchability, installed capacity

and capacity factor which makes comparisons between thermal generation sources and

intermittent renewable energy technologies inappropriate as they perform vastly different

functions.

Advantages When discussing energy technology options to service baseload energy requirements to the

NEM, nuclear energy has a distinct advantage over renewable energy technologies such as

wind and solar PV due to its dispatchability, installed capacity and capacity factor. These criteria

are explained throughout this paper. As outlined, nuclear energy enjoys a comparable levelised

cost of electricity to other thermal generation sources that perform a similar function such as

coal and natural gas, though as also discussed earlier in this paper, the internalisation of

environmental externalities through a mechanism such as a carbon price would neutralise any

advantage that coal and natural gas may currently enjoy.

As the French case study attests to, nuclear energy is a proven scalable technology, evidenced

by the remarkable 27-year scale up between 1973 and 2000 in which France went from

sourcing zero nuclear energy to approximately 80% in its electricity grid. Nuclear energy,

contrary to what many believe, is also comparable with wind and solar PV technologies with

regard to lifecycle greenhouse gas emissions. This concept is expanded upon later in this

paper.

Disadvantages High-level nuclear waste, the by-product of electricity generation from all operating nuclear

reactors worldwide, continues to drive emotive debates from opponents of nuclear energy as

well as confound policy makers worldwide. However, the nuclear waste debate is arguably an

example of the folly of long-term planning, which as explained by Brand (2010), creates the

illusion that we currently know the right course of action for the next ten millennia.

Nuclear waste from reactors is reprocessed and stored as liquid in stainless steel canisters

(Australian Nuclear Science and Technology Organisation). Australia already produces low-

level to intermediate waste from medical isotopes and industrial use of radioactive materials

and though no country has yet implemented permanent, underground disposal of high-level

waste, there is broad consensus that waste can be safely stored in deep geological stores

safely (Uranium Mining, Processing and Nuclear Energy Review Taskforce, 2006). It is highly

7 The net capacity factor of a power plant is the ratio of its actual output over a period of time, to its potential output if it were possible for it to operate at full nameplate capacity continuously over the same period of time (https://en.w kipedia.org/wiki/Capacity_factor)

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likely that submissions to this Royal Commission addressing the back end of the nuclear fuel cycle will discuss the geographical suitability of South Australia for such a storage facility . In addition, with the commercialisation of breeder reactor technology (such as PRISM) that can operate from waste generated by current nuclear reactors (Sacks & Meyerson, 2012), and the potential for spent nuclear fuel to be used in some new medical applications (Oregon State University , 2013), the issue of nuclear waste management faces a potential game changer.

Costs associated with the construction of a nuclear reactor and managing the associated waste are the arguments often presented by opponents of nuclear energy. In some cases, particularly in the United States, accident insurance, waste management and assistance to generators has been socialised (Cooper, 2014). In addition, cost overruns associated with the construction of a nuclear plant are often passed onto consumers through electricity bills. Some opponents of nuclear energy claim that between 2002 and 2008, cost estimates for new plant construction rose from between $2 billion and $4 billion per unit to $9 billion per unit (Union of Concerned Scientists). Some also argue that decisions in favour of nuclear power divert money away from genuinely cost effective solutions for our energy and climate change challenge (Goldsmith , 2009). While the front-loaded economics for nuclear power are well known within industry circles, there are generally low life cycle costs, which make developing a framework for comparison not found by short-term cost accounting a key challenge for the sector (Stevens, 2015). In addition, as this paper has explored, decisions around energy generating infrastructure must consider a range of factors including reliability, dispatachability greenhouse gas emissions, load following ability and capacity factor, which extend far beyond crude 'cost' criteria often used as a disingenuous appeal to economics by those opposed to nuclear power likely for emotive or ideological reasons.

As the analysis of comparisons between renewable energy technologies and nuclear energy has illustrated, comparing nuclear technologies with intermittent technologies such as wind and solar PV is inappropriate. However, what such analysis does tell us is that most current nuclear energy technologies are large in scale and are perhaps less suited to servicing dynamic electricity grids with many 'peaks' in demand, such as South Australia's electricity grid. Apart from the CANDU reactor, which as explained earlier in this paper has the ability to load follow (e.g. adjust output promptly in response to changes in electricity demand), current widely deployed nuclear energy technologies have historically been gigawatt scale reactors with very limited ability to load follow . While this paper outlines the potential for new reactor technologies to fit into a South Australian grid scenario, when discussing general disadvantages of nuclear energy, it is in the context of a gigawatt scale reactor that we mention the disadvantage of limited load following ability in a fair assessment of general advantages and disadvantages. The advantages and disadvantages of nuclear energy identified in this paper are summarised in the table below

Table 3.0 ~dvantages and disadvantages of nuclear energy

Advantages LCOE - improved w ith the ex istence of a carbon price

Installed capacity · ability to produce large amounts of energy

Capacity factor - ability to service baseload energy requirements Scalability Low lifecycle greenhouse gas emissions

Dayne Eckermann August 2015

Disadvantages Produces high-level waste, requiring management - though this is being addressed by new technologies Front loaded economics, prone to cost escalations and a high degree of complexity in construction Inflexible generating capacity (inability to load follow) -though this is being addressed by new technologies

18

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

Fukushima Daiichi vs Onagawa Nuclear plant In March 2011, the largest recorded earthquake in Japanese history (magnitude 9.0) hit the

Tohoku prefecture, leaving 20,000 people dead or missing (Ryu & Meshkati, 2014). There were

three nuclear reactors in the region, which all received different fetes: the Fukushima Daichi

plant, operated by Tokyo Electric Power Company (TEPCO) melted down and released

radiation into the biosphere; the Fukushima Daini plant, also operated by TEPCO, was

damaged, though largely controlled by staff; and the Onagawa plant, operated by Tohoku

Electric, which remained largely intact after the tsunami (Ryu & Meshkati, 2014). A 19 strong

mission to the Onagawa plant comprising staff from the International Atomic Energy Agency

found the only major issue with the plant was a flooding of the basement (The Oregon Live,

2012) and a brief fire in the non-nuclear turbine building, while all three boiling water reactors

at Onagawa automatically shut down, as designed (World Nuclear News, 2012). For a time

following the tsunami, the Onagawa plant was also used for housing evacuated persons from

the Fukushima exclusion zone such was the lack of damage to the plant.

Yanosuke Hirai, the former vice president of Tohoku Electric Power whom was involved in the

planning and construction of the plant is said to have left a strong safety culture within the

Tohoku company by defying his colleagues at the time and insisting upon a 49 feet high sea

wall instead of 39 feet high wall. In addition, he called for a unique cooling system that would

provide water in the event of a tsunami that left the plant without access to water (The Oregon

Live, 2012). This is particularly remarkable given the strong Japanese culture of compliance

and the lobbying power of Japan’s electricity utilities (The Oregon Live, 2012). The Onagawa

plant was built on higher ground than Fukushima Daichi (14.7m compared with 10m) as TEPCO

dismantled 35 metres of its natural sea wall in favour of a 10 metre wall to lower costs and

facilitate easier equipment transport (Ryu & Meshkati, 2014). While Tohoku kept revising their

earthquake estimates and acted accordingly by adjusting their defences, TEPCO overlooked

these warnings and resorted to delaying tactics such as casting doubt over the science behind

the warnings (Ryu & Meshkati, 2014). Seismologists and tsunami experts claim that according

to readily available data, an earthquake with a magnitude as low as 7.5 could have created a

tsunami large enough to breach the sea wall at Fukushima Daichi. It has since also been

revealed that for decades, Japanese officialdom and even parts of its engineering

establishment clung to older scientific work that had been superseded by more recent risk

assessments. In addition, structural engineering considerations were at their infancy when

Fukushima Daichi was built in 1967 and thus engineers had minimal basis for the standards

they employed (Onishi & Glanz, 2011).

Tohoku Electric also employed a different approach to their emergency response, which

included: the establishment of an emergency response centre immediately after the

earthquake; the dispatch of supervisors and chief engineers to the main control rooms of

damaged reactors; and the timely information dissemination to the response team. This all

stemmed from a safety culture that simply did not exist at the Fukushima Daichi plant (Ryu &

Meshkati, 2014).

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While South Australia has a comparatively very low earthquake and tsunami risk and given the

age of the Fukushima Daichi plant, it is still worthwhile to note the notions of ‘safety’ and ‘safety

culture’ which arose in the aftermath of the accident at Fukushima Daichi and will need to be

at the forefront of a decision to establish a nuclear power industry in South Australia.

Chernobyl nuclear accident 1986 The world’s worst nuclear accident was a hydrogen explosion resulting in a meltdown of one of

the reactors at the Chernobyl plant in April 1986. While it is beyond the scope of this paper to

speculate on the radiological impacts on human health associated with the disaster, it is

worthwhile mentioning the key findings of the most authoritative radiological and oncological

science from the United Nations World Health Organisation, among other organisations. It is

impossible to assess any latent mortality related to radiation exposure from the accident with

any degree of reliability, 49 persons died as a result of the accident, of which only 28 can be

attributed to acute radiation sickness, with any degree of confidence (The Chernobyl Forum:

2003-2005, 2006). However, it is also possible that the overall cancer and mortality rates within

the geographical areas affected by the accident may increase by as much as a few per cent,

equating to perhaps 4000 latent fatalities in the most highly contaminated areas and an

estimate between 9,000 and 33,000 latent fatalities over a 70 year period, though it is very

difficult to attribute instances of cancer to the accident with any confidence (The Chernobyl

Forum: 2003-2005, 2006). It must however be noted that this commentary in no way intends to

dismiss the severity of this accident, rather communicate the findings of the most authoritative

survey of the accident and prevent mendacious, academically discredited assertions regarding

mortality from the accident (Balanov, 2012) to shape mainstream perceptions of nuclear

energy.

Aside from the dangerous and poorly conceived safety experiment in the absence of

adequately trained engineers that resulted in an uncontrollable chain reaction, hydrogen

explosion and eventual meltdown, the reactor at Chernobyl was inherently unsafe. The reactor

was designed primarily to create plutonium for nuclear weapons, featured a graphite moderator

and had no containment vessel. Consequently, the design of the Chernobyl reactor was used

nowhere outside of the Soviet Union (Sacks & Meyerson, 2012). In addition, similar to the

Fukushima case study, the safety culture at the Chernobyl plant was viewed as sub-standard,

which created the conditions for such a poorly conceived experiment to be carried out in the

first instance (International Nuclear Safety Advisory Group, 1992).

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What regulatory regime needs to be established? What are the best examples and what be can be drawn from them? An adequate regulatory framework to facilitate the development of a nuclear energy generation

sector in South Australia or Australia more broadly currently does not exist and this must be

addressed as a priority if a decision is made to pursue this pathway. The ONR model explained

earlier in this paper provides a reasonable model for consideration. In a lecture given in March

2015, Dr Tim Stone from the ONR in the UK offered the following important points if a decision

was made to pursue a nuclear energy sector in South Australia:

Do everything that needs to be done once, upfront.

Reform the planning system.

Run a strategic siting assessment.

Run a process of formal justification.

Develop a generic design assessment.

Explore ways of enhancing the effectiveness of the regulator regime.

Establish waste management and decommissioning arrangements upfront.

Reform the electricity market.

Establish adequate insurance provisions.

Establish an independent nuclear development forum to ensure accountability

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

Lifecycle greenhouse gas emissions from solar and nuclear fuel cycles in the United States are comparable under actual production conditions and average solar irradiation. However, several factors may significantly change this picture within the next five years such as the development of newer, more efficient uranium enrichment technologies (Fthenakis & Kim, 2007). Contrary to popular belief and the arguments of some opponents of nuclear energy, nuclear energy is widely accepted in technical circles as a low carbon electricity generation technology. The IPCC, in its Fifth Assessment Report, classifies nuclear energy as a 'mitigation technology'. In addition, based on 32 references providing lifecycle greenhouse gas emissions estimates and 125 estimates that passed the panel's literature review screening process (Moonaw, Burg herr, Heath, Lenzen, Nyboer, & Verbruggen, 2011 ), the IPCC declared nuclear power as comparable to renewable energy technologies such as wind and solar PV with regard to lifecycle greenhouse gas emissions (Schlomer, et al., 2014). This information is summarised in the table below. -T .. chnolo Minimum gC02· Median gCOr Maximum gCOr -- gy e/KWh e/KWh e/KWh

Nuclear (Pressurised water and boiling water) Wind (Onshore) Solar PV (Utility

scale) Concentrated solar Coal (with carbon

capture and storage)

Combined cycle gas (with carbon

capture and storage

3.7

7

18

8.8

190

94 T

12

11

48

27

220

170 T

110

56

180

63

250

340

Figure 2 - Lifecycle greenhouse gas emissions assessment for various electricity generation technologies (Schlomer, et al., 2014 )

Conclusion Based on the information cited in this paper, the development of electricity generating infrastructure from nuclear energy technologies is technically and economically feasible while also offering an environmental benefit with regard to greenhouse gas emissions. However, a number of technical, economic, legislative, social and regulatory challenges to the deployment of nuclear energy exist in Australia. If the South Australian and Australian Government's make the decision to pursue nuclear energy in Australia, then serious consideration of these challenges and actions to overcome them must be made as a matter of urgency. From a greenhouse gas and climate change perspective, the promptness of such action is even more

crucial.

Dayne Eckermann August 2015 22

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Annex II: Methodology. In O. Edenhofer, R. Pichs-Madruga, Y. Sokona, K. Seyboth, P. Matschoss, S. Kadner, et al. (Eds.), IPCC Special Report on Renewable Energy Sources and Climate Change Mitigation. Cambridge and New York: Cambridge University Press. Morrison, J. (2014). Government approval not enough, business' need social licence. Yale Global. Nuclear Regulatory Commission. (2015, May 24). Dry Cask Storage. Retrieved July 26, 2015 from United States Nuclear Regulatory Commission: http://www.nrc.gov/waste/spent-fuel-storage/dry-cask-storage.html Office of the Nuclear Regulator United Kingdom. (n.d.). From Summary of lessons learnt during GDA process 2007-2013: http://www.onr.org.uk/new-reactors/reports/onr-gda-sr-13-001.pdf Office of the Nuclear Regulator United Kingdom. (n.d.). A guide to nuclear regulation in the UK. From http://www.onr.org.uk/documents/a-guide-to-nuclear-regulation-in-the-uk.pdf Onishi, N., & Glanz, J. (2011, March 26). Japanese Rules for Nuclear Plants Relied on Old Science. The New York Times . Oregon State University. (2013, April 4). Invention could make spent nuclear fuel useful for irradiation purposes. Retrieved August 2, 2015 from News & Research Communications: http://oregonstate.edu/ua/ncs/archives/2013/apr/invention-could-make-spent-nuclear-fuel-useful-irradiation-purposes Organisation for Economic Co-operation and Development Nuclear Energy Agency. (2011). Carbon Pricing Power Markets and the Competitiveness of Nuclear Power. OECD. Parkinson, G. (2013, February 7). Renewables now cheaper than coal and gas in Australia. Retrieved August 1, 2015 from Reneweconomy: http://reneweconomy.com.au/2013/renewables-now-cheaper-than-coal-and-gas-in-australia-62268 Perry, R., Alexander, A. J., Allen, W., de Leon, P., Gandara, A., Mooz, W. E., et al. (1977). Development and Commercialisation of the Light Water Reactor, 1946-1976. Rand Corporation. Platts. (2015). 2014 top 50 capacity factor. Retrieved July 18, 2015 from Global Nuclear Performance Analysis: http://www.platts.com/news-feature/2015/electricpower/global-nuclear-analysis/2014-top-50-nuclear-capacity-factor Potter, B. (2015, February 18). Surplus capacity confounds industry and policy makers. Australian Financial Review . Price, R., & Blaise, J. R. (2002). Nuclear Fuel Resources: Enough to Last? NEA News , 2 (20). Princeton University. (n.d.). Nuclear Power Plant Standardisation: Light Water Reactors. Retrieved June 28, 2015 from http://www.princeton.edu/~ota/disk3/1981/8118/8118.pdf Rangel, L. E., & Leveque, F. (2012). Revisiting the Nuclear Power Construction Cost Escalation Curse. 31st USAEE/IAEE North American Conference. Austin. Rothwell, G., & Van der Zwann, B. (2002). Is Light Water Reactor Technology Sustainable? Stamford Institute for Economic Policy Research . Ryu, A., & Meshkati, N. (2014, October 30). Onagawa: The Japanese nuclear plant that didn't melt down on 3/11. The Bulletin .

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Appendix A

The following originally appeared on the Decarbonise SA blog on the 12th September 2012 as a description of how the ARPANS Act developed a prohibition for particular Nuclear facilities. The ARPANS Bill entered parliament on the 8th of April 1998 with the intention to amalgamate the Austrlaian Radiation Laboratory (ARL) and the Nuclear Safety Bureau (NSB) into one body, now known as the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA), and to introduce regulatory controls for all radiation and nuclear safety activities. The Bill passed through the House of Representatives on the 12th of November 1998 after a break in sitting occurred due to a Federal election in October. The debate in the House of Representatives mainly focused on the replacement of the Lucas Heights reactor and its perceived implications. The Senate at this time was in the same situation it is presently in where a minority party has the balance of power in issues of partisanship. The Australian Democrats and Greens parties had this balance of power and both shared anti-nuclear policies. It is this balance of power and policy that facilitated the introduction of an amendment by the Greens party to outright prohibit nuclear power. Before amendments were made the Bill was sent to committee to hear from stakeholders and experts with an interest in the Bill. The discussion and questioning of experts in the Senate committee was a short half day hearing with submissions and testimony from stakeholders in the nuclear industry, in the council where Lucas Heights is located, and anti-nuclear advocates. After two days a report was tabled from this committee outlining that amendments be made to the definition of a nuclear Installation and that the report from the minority parties outlined that it also should include a prohibition of nuclear power. The Greens amendment was voted on with no formal division (a record of ayes and noes) and was passed on voice vote alone. In other words, no Senator put their name on record for, or against, the amendment. However, amendments made to Bills in the Senate sent the Bill back to the House of Representatives to be voted on a final time. The Bill was passed in the House of Representatives without division. After a three-and-a-half-hour committee meeting, a several-page report drafted over two days, one hour and 36 minutes of debate post-prohibition recommendation, and six minutes of considering the amendments (see detailed chronology below) it was decided that Australia should not go down the nuclear path. The following is what occurred in chronological order. Dates are hyperlinked. 8th April 1998 The ARPANS Bill was read for a first and second time in the House of Representatives, a fairly procedural matter. An outline of the Bill was given indicating: “This Bill introduces regulatory controls for all Commonwealth radiation and nuclear safety activities for the first time in Australia. It is designed to protect the health and safety of persons and the environment from the harmful effects of radiation practices undertaken under the auspices of the Commonwealth.” – Hon. Trish Worth 14th May 1998 The debate on the Bill continues with main focus residing around the Lucas Heights reactor and its future replacement. Debate is adjourned. 11th November 1998

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After a federal election on the 3rd of October the debate is resumed, where members of parliament make their second reading speeches. 12th November 1998 The ARPANS Bill was read for a third time and passed onto the Senate for further consideration. It is important to note the House of Representatives is comprised of members from federal electorates over Australia, whereas Senators represent their respective States. 23rd November 1998 The Bill is read a first and second time in the Senate, under procedural matters. A brief overview of what the Bill entails was published in Hansard. 26th November 1998 Upon the movement of Sen. Dee Margetts (WA Greens) and affirmed by Sen. Sue Knowles (Liberal Party) the Bill is sent to the Senate Community Affairs Legislation Committee to hear from witnesses with an interest in the Bill on the 30th November 1998. 30th November 1998 The Senate committee comprised of 7 Senators and heard from 12 witnesses: Two Liberal Party, two Labor Party, two Democrats, and one Greens Party Senators; five representatives from ARPANSA (interim body), Nuclear Safety Bureau, Australian Radiation Laboratory and ANSTO; four councillors from the Sutherland Shire council (location of Lucas Heights reactor); and three anti-nuclear advocates, Dr. Jim Green (FoE), Ms. Jean McSorley (Greenpeace), and Mr. Larry O’Loughlin (ACF). The transcripts of their questioning can be read in the Hansard records. Needless to say a detailed and robust discussion of Nuclear Power is clearly absent. 2nd December 1998 The Committee’s final report was tabled in the Senate. In this report it recommends that: Amend the definition of “nuclear installation” to delete the references to nuclear power reactors and to reprocessing facilities, and to add references to the following: a spent fuel conditioning plant a nuclear isotope production facility a nuclear waste storage facility a nuclear waste disposal facility. This recommendation did not clarify for what reason, however paragraphs from the opposition (Labor Party) and minority parties (Democrats and Greens) are the first indication that there will be an amendment to the Bill prohibiting particular facilities, specifically from the Democrats and Greens: “The recommendation to exclude nuclear power reactors from the legislation is an improvement in accountability. The Greens and Australian Democrats, however, are concerned that licenses for `a nuclear fuel fabrication plant’, `an enrichment facility’ `a fuel storage facility’ and `a reprocessing facility’ remain possible under this legislation, albeit with the approval of the CEO. These activities should either be specifically prohibited under this legislation, or at the least, should not be able to take place without full and separate Parliamentary scrutiny.” Thus, Prohibition was decided at the Committee stage after three and a half hours of witness testimony. Regardless, the amendment still has to be voted on in the Senate, and then passed back into the House of Representatives for a final vote before being declared an Act. 9th December 1998 The debate in Senate resumed on the ARPANS Bill, with the main focus being on the controversy surrounding the Pangea Resources leaked promotional video declaring Australia to be the best place in the world to host a high-level nuclear waste site. After this discussion it turned to the amendments, first one considered was Greens (WA) amendment No. 1, the

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prohibition section outlined above. The reasoning for this is outlined in Sen. Dee Margetts 2ndreading speech and comments in committee debate. 10th December 1998 After two sessions discussing the Bill the Greens (WA) amendments were up for vote. The following is how it played out: Sen. Margetts (Greens WA) restated and introduced her amendments where upon Sen. Forshaw (ALP) indicated that the opposition would support Greens amendment No. 1 (prohibition) as “We understand that there is no either medium-term or long-term intention on the part of the government to proceed to construct such facilities” There was a technicality brought up with respect to the Greens and Labor party amendments clashing on the definition of a “nuclear installation”, however this was resolved. At 12.09pm on the 10th of December 1998 the Senate voted on Greens (WA) amendments No.1: The TEMPORARY CHAIRMAN (Senator Watson)—The question before the chair is that the Greens amendment which concerns clause 9A subclauses (1)(a), (b), (c), (d) and (2) be agreed to. Amendment agreed to. That was that. Note that it was referred to clause 9A but was published as section 10 in the Act. The party breakdown of the Senate on that day was; 31 Liberal Party, 29 Labor Party, 7 Democrats, 2 Greens, 5 Nationals, 1 Country Liberal Party, and 1 Independent. The federal election on the 3rd of October that year didn’t affect the Senate at this time as Senators who were retiring do so on the following year; Sen. Dee Margetts was one of those retiring. The Labor Party, Greens and Democrats all have anti-nuclear policies in some form or another, that’s 38 anti-nuclear votes. The Country Liberal Party candidate indicated that he could “…accept the balance of the amendment” proposed by the Greens and ALP, hence 39 votes and at a minimum the amendments passed. Even if it had been decided in the following year the Democrats gained two more Senators, and thus the anti-nuclear majority would have been retained. This vote is also peculiar as votes that are this close tend to go to a division to sort out the ‘ayes’ from the ‘noes’, putting Senators names down in Hansard indicating their vote on the matter. However this didn’t occur. This was a case of the poison chalice perception. After a three-and-a-half hour committee meeting, a several-page report drafted over two days, one hour and 36 minutes of debate post-prohibition recommendation, and six minutes of considering the amendments it was decided that Australia should not go down the nuclear path. As stated previously amended Bills from the Senate move back to the House of Representatives to be voted on again. Unfortunately due to the poison chalice perception, and the waste dump issues energising the anti-nuclear base the following occurred: Dr WOOLDRIDGE (Health and Aged Care) (11:38 PM) —I move: That the amendments be agreed to. And they were, no division.