Response to the Tentative Findings of the SA Nuclear Fuel Cycle Royal Commission

this is a draft. editing ongoing.

Response to the Tentative Findings of the Nuclear Fuel Cycle Royal Commission

A Submission by Paul Langley

Response to Tentative Finding 74


There is international experience that demonstrates geological disposal is expensive, not without risk, including political and social cohesion risks. Environmental and radiological risks exist. Financial and economic risks exist. The risks include the transport of High Level Nuclear Waste. We shall see that technical reports predict climate change poses a risk to underground High Level Nuclear Waste dumps.That of all the possible risks, the risks posed by hydrology greatly predominate. Reports further find that simplistic assessments that ignore the political, sociological and anthropological sciences produce decades of conflict at many levels.

There is no evidence that nuclear enthusiasts, even where they are nuclear scientists, are sufficiently qualified to attempt to impose what they see as technical solutions to their problems upon civil societies. This is of particular importance where a population’s nuclear history reveals a sound basis for lack of trust in nuclear authorities.

Globally, there is no evidence that the imposition of nuclear industry risk upon populations has ever been justly settled when harms become individually manifest.At present former government employees remain locked in legal battle with British authorities in the highest and most expensive courts in Great Britain. Revelations continue to surface, as they have done for the decades consumed by the cases that these people were lied to, suffered loss of medical records and even denials that their relevant employment ever took place. As it is in Britain, so it was in Australia, the United States, France, Russia and elsewhere.

Calculated risk of so many per 100,000 ,in the apparent eye of the law, is never acknowledged as producing certified individual harms. I referenced the US Department Justice nuclear victims compensation scheme in my first submission to this Royal Commission. Many in the towns of Nevada consider that their streets were literally decimated by the impacts of nuclear activity. Such experiences remain to this day. (Source: Gallagher, C.) In Australia there is testimony of many, including Yami Lester, Lallie Lennon, the Bear-Wingfields, the Elder Women of Coober Pedy and dozens more. These things are not the matter of belief. They are matters of experience. The aboriginal experience many years ago included nuclear realities and facts which were related to nuclear secrets at the time. No non-specialist could know them. Yet we have on record precisely accurate descriptions of fission fallout fractionalisation being described in common language in a manner only a first hand eye witness or a trained expert could know.   There is no doubt that Lester and Lennon were untrained in the art of nuclear observation. (Sources: “Maralinga dust”, Lennon, Lallie Kantjuringa. “The Black Mist and It’s Aftermath”, Lennon, Madigan and Langley. Report to the State government, Federal Government and IAEA.) (no response from the IAEA, of course.) Such considerations are discounted as totally irrelevant by proclaimed nuclear “experts” present in Adelaide today. So much for the “Stepped Process toward Community Consensus”. If only the views of the nuclear extreme are relevant, the social fabric will be torn.

Nuclear adventurism invariably claims to be acting in order to “save the world” from one thing or another.

In my final statement I shall remind the Royal Commission of alternatives to the current proposal. A nuclear dump on Eyre Peninsular or anywhere else will not save this planet from anything, and will impose risk upon populations.


 The Royal Commission tentatively finds that the Gawler Craton is stable. The Royal Commission says nothing about the stability of the climate that impacts it and which will impact it in the near future. I choose not to compare SA with lands of snow and glaciers, such as Sweden and Finland. I choose a much more relevant place:

“….even in extremely arid climates such as the Yucca Mountain site, hydrologic interaction is the most prevalent [risk]. It is the primary mechanism of which contamination can occur, and is the most prevalent consequence to other risks discussed…..” “Because of the extremely arid climate, most of this water is returned to the atmosphere through evaporation before it can infiltrate deep enough into the rock to reach the level of the repository, and eventually the water table…..[Stuckless and O’Leary, 2007] However, it is worth considering that future climatic uncertainties (primarily those concerned with extreme climates, such as the Yucca Mountain site) may cause this pattern to drastically change [Fabbro, 2010].” “The decision seems to have already been made after decades of political and scientific debate, the Yucca Mountain Project was formally halted in 2010, when the Obama Administration stated that the Energy Department would stop seeking Nuclear Regulatory Commission licenses for the project [Johnson, 2013]. Therefore, the site was never constructed or utilized as a waste repository. This makes the applicability of Yucca Mountain as a case study even more powerful-not only does it exemplify the geologic constraints of long-term HLW repository research; it encompasses the much more complex environment that exists when policy and science meet.”

Source: Geological Constraints on High Level Nuclear Waste Disposal and their Relationship to Possible Long Term Storage Solutions A Case Study of the Yucca Mountain Project”, Teresa Dunn, 2013, University of Indiana, pp 11, 13.

I shall show that the US concern regarding sudden climate change – including extreme rain events – and the impact of this upon arid area HLNW Repositories is much more relevant to Australian scenario than the Swedish and Finnish concerns. New glaciations are of more apparent concern in one Scandinavian risk assessment, as we shall see.

The risks posed by sudden climate change and increasing extreme weather events include possible flood events on Eyre Peninsular. This is a section of the Gawler Craton that contains no rivers (Source: SA Water Corp). Like Yucca Mountain, Eyre Peninsular appears to be internally drained.

Finland and Sweden both prohibit the storage of international nuclear waste within their territories. There are rare exemptions for small amounts of waste: “An application to import nuclear substances or nuclear waste from a foreign nuclear installation will contain information on how long the material will stay in Sweden. The application will be granted only if it is clear that the material will either be conveyed out of Sweden within a certain time, or that a licence for terminal storage within Sweden has been granted.” Source: Nuclear Legislation in OECD and NEA Countries – Sweden. Regulatory and Institutional Framework for Nuclear Activities” OCED, NEA, 2008 at pp8.   And:

“Finland’s nuclear waste management is governed by the Nuclear Energy Act and the Nuclear Energy Decree, which define, among other things, the obligations of a producer of nuclear energy, the relevant licensing procedures and the control rights. In 1994, the Nuclear Energy Act was amended so that it now requires all nuclear waste generated in Finland to undergo final disposal in Finland. The Nuclear Energy Act also prohibits nuclear waste’s importation into Finland. The overall supervision of nuclear waste management is the responsibility of the Ministry of Employment and the Economy. It decides the principles and draws up the schedules that power companies must abide by.” Source: STUK, Finnish Nuclear Safety Regulator, Nuclear Waste in Finland” 2016, at

Contrary to the implications of the written material made available by the Royal Commission, the Swedish and Finnish models do not provide South Australians with a moral precedent or imperative for accepting the nuclear waste generated by the rest of the world.   Rather, both nations conform to the principle of clearing up one’s own mess as best one can. Importing the mess of other nations would, it seems to me, be an anathema to both nations. On one hand the Royal Commission implores us to copy Sweden and Finland. On the other hand, both those nations say no in law to what the Royal Commission is proposing and recommending.

However, no doubt, both nations would happily sell their means and methods to South Australians. The cost of this sale has not been made available by the Royal Commission as far as I am aware. No doubt royalties due to Swedish and Finnish patent licenses would apply.

In the USA the cost of the abandoned quest to commence the geologic Yucca Mountain High Level Waste Repository amounts to billions of dollars. It has entailed a long-term dispute between the US Government and the Government of Nevada. In the end, effectively, the State government of Nevada won the extended conflict. Sources: Dunn, as cited above: “Yucca Mountain: A Post-Mortem” and Adam J. White, The New Atlantis, Fall 2012, at, see also “Why Does the State Oppose Yucca Mountain?”, AGENCY FOR NUCLEAR PROJECTS/NUCLEAR WASTE PROJECT OFFICE, State Government of Nevada, at

The Royal Commission in this tentative finding notes that political and scientific processes of the nations of Finland and Sweden, pursuant to High Level Nuclear Waste Dumps gained “social consent”. This description ignores the origins of the demand for a solution to the High Level Nuclear Waste problem in those two countries.   Swedish history shows that:

The people of Sweden demanded a solution to the problem – or crisis as many voters saw it – of HLNW from at least 1976. The election campaign of that year resulted in a new government, one mandated to solve the problem. As a result a Stipulation Act passed the Swedish Parliament in April 1977. This Act mandated that prior to the construction of new nuclear power plants in the nation, the operators must solve the HLNW problem the plant would other wise cause. Various solutions were permitted, including “emplacement of encapsulated waste in a final repository approximately 500 metres in suitable crystalline bedrock formations in Sweden, beginning no earlier than 2020 and backfilling of the storage holes and repository tunnels with a quartz sand and bentonite clay filler material…..” Source: “What to do with Nuclear Waste”, Thomas B. Johannson and Peter Steen, The Bulletin of the Atomic Scientists, November, 1979. One can see in this 1977 law key components of the allegedly brand new Swedish method of geologic storage. The method is in fact not new. It was imposed as solution upon nuclear industry by the will of the Swedish people via their parliament. The record shows that the people of Sweden were led themselves to the certainty that the problem of HLNW in their nation had to be solved.

Nuclear industry did not solve the problem and then seek to lead the Swedish people. The historic record shows in fact that the opposite was true. The nuclear industry had to be hit with laws which compelled it to solve the problem it had caused in Sweden. The implication of the Royal Commission’s tentative finding in this regard is incorrect.   That being the case, the example of Sweden denies the basis for a socio-political role by nuclear industry in South Australia in this matter. The Swedish example mandates 1. That there be a High Level Nuclear Waste problem in South Australia. 2. That the public recognize this problem. 3. That the public demand a solution to the South Australian HLNW problem. As there is no HLNW problem is SA, there is no demand by the SA public for a geologic HLNW dump. That is the true example of Sweden. The Royal Commission has mis-stated the situation completely when it urges us to follow Sweden and Finland.

If Sweden had, at that time, no crisis of HLNW, that is, if Sweden had had no nuclear power reactors in 1976, the people of Sweden would not have had to act as they did in 1976 and 1977 .

Nuclear industry produces both gaseous and solid nuclear exhaust. Exhaust which poses a threat for periods of time which can be described as “inter-civilisational”.

It is now 2016.   The world is aware that every nuclear powered nation has a HLNW problem. If the problem has been solved at any time since 1954, why, in 2016, are South Australians being asked to consent to becoming the High Level Nuclear Waste Repository for the entire Planet? If the problem is solved, why are places at all points north of Adelaide considering, with utter relief at the political and industry level, sending us their HLNW? Some South Australians no doubt are happy that this state may end up as the sociological solution to nuclear industry’s intractable technical problem. Any further away from the nuclear heavy northern hemisphere than here and the nuclear consortiums would be negotiating penguins. If anything goes wrong, the North will be perfectly safe. It will totally be our baby.

The Swedish nuclear authorities were given from 1977 until 2020 to consider the mandatory HLNW geologic waste dump by the people of Sweden. That’s Forty Three years.

How is it that the people of South Australia have been given only from 2016 to 2020 to consider the same issue? A mere Four years? The people of Sweden were time generous to the nuclear industry. That same industry now attempts to railroad us into a “fast buck for them” solution.

Obvious differences exist between the nuclear histories of Finland and Sweden compared to Australia. A brief history of Finland and Sweden includes the following facts:

Finland shared a border with the former USSR from 1918 until the Soviet collapse. Sweden, not much further away from the USSR, shared the same need as Finland to guard against threats and events regarded as normal in the world from 1948 until about 1962. The idea that nuclear fallout was good for you was accepted by authorities in Sweden and Finland. The idea was intensively used in Australia, Britain and the United States. Marshall Brucer introduced the concept of Hormesis to the public via his AEC position from very early on. This, as an aid to the bomb tests and activities of Hanford and Oak Ridge. (“A chronology of nuclear medicine, 1600-1989”, Marshall Brucer, St. Louis, MO, : Heritage Publications, 1990. )

Three events gave significant cause for public trust in Finnish and Swedish nuclear authorities.

The Cold War saw Scandinavia as a whole monitor its environment for nuclear fallout in the environment and food chain. These were publically reported. I refer for example to the online publication “Environmental Radiation – Deposition” authored by STUK, the Finnish Radiation Protection Agency at

There are numerous examples of open public discourse between STUK and the people of Finland.

The Chernobyl Nuclear Accident in the USSR. STUK in Finland was in the forefront of disclosure of events to the Finnish people in an open manner. For example, I refer to R. Pollanen, author of the STUK report “Nuclear Fuel Particles in the environment – Characteristics, atmospheric transport, and skin doses. R. Pollanen, STUK, Radiation and Nuclear Safety Authority, University of Helsinki, Department of Physics. Page 4 and pages 53 and 54 are of immediate interest in any technical debate and in any discourse that informs and receives public interest and knowledge in these matters. It is a very good publication.   It is available currently at I believe it is also available at non IAEA online repositories.

The Windscale reactor fire, England, 1957. Source documents to this event, which occurred out of the blue in the Scandinavian context, is a most interesting one compared to the Australian one. The fire very strongly influenced Britain’s ability to continue its nuclear bombardment in South Australia at that time. I refer the Commission to the publication “Advection of Radioactive Dust over Norway After the Windscale Accident in England October 1957” by Per B Storebo. The report is published by the Norwegian Defence Research Establishment PO Box 1084 Oslo, Norway, 1957. It contains fallout cloud mapping which is unique.

The people of Scandinavia were informed of the 1957 events far faster than were the people of the United Kingdom. Certain facts suppressed for decades by Anglophile nuclear authorities were public record throughout Scandinavia from the time of the events.   The impacts of these facts determine to this day the attitude of those societies toward nuclear safety and nuclear disclosure.   The Scandinavian lands have a historic basis for trust in their nuclear authorities which is in actual fact completely lacking, as a historic basis for trust, from British and Australian societies as a whole.

There must be a significant minority of people in both Sweden and Finland who have grounds for disagreement in the matters currently at hand. Both countries are democratic. Of course there will be diverse views held. The same holds true in South Australia. The absolutism of the nuclear elite is totally at odds within a democratic society.


The Royal Commission tentative finding 74 also states that, briefly, Finland and Sweden, have successfully developed long-term technical and engineering solutions to the technical challenges.

The solutions have been licensed for safe long term storage, but that the most advanced geologic facility (Finnish) will not receive spent fuel until the next decade. Has the development of the final product actually been achieved? Have they stopped learning lessons already? The dumps are not yet in commercial use.

In other words: 1. No Swedish geologic HLNW geologic nuclear facility is currently in routine operation. 2. Sweden, the originator, is lagging behind Finland in implementation 3. Despite this, and despite testing of the solution being ongoing, both nations’ nuclear regulators have licensed the supposedly new solution for use in those two nations.

The relevant proposal regarding HLNW asks South Australians  to consider involves the Swedish solution named KBS-3. Earlier design solutions are: KSB-1 and KSB2. There are variants of KBS-3. KBS-3 H (Horizontal) and KS-3V (Vertical). (Source: Wikipedia. )

The Swedish solution, having been forced on the nuclear industry by Swedish legislation of 1977, has not been, as one would expect and hope, developed without lessons learned.   As yet, the high point in the solution is KBS-3. The solution is not operational anywhere in the world, it is under test in both Sweden and Finland, and presumably, being an optimist, I hope lessons are still being learned. And specifications changed. This learning and specification change period may well extend beyond 2020.

In this country, nuclear authorities have always – always – labeled any nuclear event reported to Australians as being “perfectly safe.” At least initially.   The KBS-3 solution is in a phase of testing, and the reputation of the solution in Finland and Sweden in the public mind is totally dependent upon two things: How much information is being shared by authorities with the public and how much basis there is in reality for the Swedish and Finnish public trust in their nuclear authorities.

The Australian history within the space of one human lifespan is, I submit, very different in these regards. Very different indeed to the history of trust formation in Finland and Sweden. Have authorities left any matter out, omitted anything from public disclosure in Sweden or Finland?   Of course, the questions an older Australian might ask in these matters may be very different from the questions a Swede or a Finn might feel obligated to ask. This is Australia, not Sweden.

KSB-1 and KSB-2 had problems. KSB-3 is perfectly fine. They say. Its good enough to sell to South Australia right now, even though it is still under testing in Sweden and Finland. I refer to the following document:

Safety Assessment for a KBS-3H Spent Nuclear Fuel Repository at Olkiluoto, Complementary Evaluations of Safety Report”, Neall, POSIVA 2007-10, Dec 2007, POSIVA OY Olkiluoto FI-27160 EURAJOKI, FINLAND

In particular I refer to the following figure C-1, Risk summation, expressed as annual individual risk for the Laxemar and Forsmark sites in Sweden, as reproduced below:

I find the information to be of great value. I regret that similarly clear and straight forward graphs or visual aids giving combined risk from background and the proposed High Level Nuclear Waste Sites is absent from the report. Actual risk is the combined risk. Comparisons, while valuable, do not give a fast visual appreciation of total risk. Historic use of the term “less than background”, used as an assurance to the South Australian public since 1952, is not accepted by sections of the population here for obvious reasons.

I refer also to the following from Neall et. al:

“”The long-term durability of native copper in relevant conditions is illustrative evidence for the long-term stability of copper canisters. Several examples of natural copper ores and one archaeological analogue have corroborated the evidence that the sub-surface conditions in Finland will also preserve copper.

“Natural systems also have an important role to play with respect to the long timescales involved in radioactive waste disposal. The Finnish regulatory dose criteria (STUK 2001) acknowledge that, due to increasing uncertainties about the surface environment in the future, the calculation of dose to a human population becomes less meaningful in the long term, especially after the onset of a future glaciation. Other calculated performance and safety indicators can, however, be used to complement calculated doses. Such indicators can show, for example, how the potential toxicity of spent fuel due to ionising radiation compares with that of naturally occurring radioactive materials, such as uranium ore bodies, and how calculated radionuclide releases from the repository compare with naturally occurring radionuclide fluxes. Natural analogues allow us to examine the results of processes that have been occurring in natural systems for periods of time comparable to, or longer than, those used to assess the safety of the repository. In some cases, it is not possible to extract all the detailed information we would like to have but the messages these analogues can convey should not be underestimated: that the Cigar Lake uranium deposit has no surface geochemical anomaly to indicate its presence after 1.3 billion years of existence is evidence of the most direct kind that a system with a suitable hydro geological and geochemical environment can provide safety over the timescales required. ” Source: Neall et. al, paragraph: 7.1.2, “Support from Natural Systems”, pp 164 -165.

Within the context of Finland, the matters raised seem very coherent. However, the very same factors mentioned above may well not hold true for a KSB-3 repository in Australia.

The variables listened in the above quoted paragraph include :

“The long-term durability of native copper in relevant conditions.”

“..the sub-surface conditions in Finland will also preserve copper.”

“The Finnish regulatory dose criteria (STUK 2001) acknowledge that, due to increasing uncertainties about the surface environment in the future, the calculation of dose to a human population becomes less meaningful in the long term, especially after the onset of a future glaciation”.   Apparently STUK has an expectation of a southern migration from Finland due to the emergence of much colder conditions. No people, no need for human dose calculations for that future time. This concern is pretty unique when compared to the concerns raised about Yucca Mountain.

Personally, I think rapidly changing rainfall patterns on the Eyre Peninsular are more relevant a change here than the sudden arrival of a new glacier somewhere to the south of Coober Pedy.

The Royal Commission has not disclosed whether the HLNW geologic repository/dump will be hot or cold. Will it be flooded with ground water as the Swedes intend for theirs?

I refer to the publication “Copper Canisters for Nuclear High Level Waste Disposal. Corrosion Aspects” lars Werne Patrik Sellin Nils Kjellbert Swedish Nuclear Fuel and Waste Management Co Stockholm Sweden October 1992. This publication states:

“…..This is also the time period during which the heat generation of the waste is most important. After some thousand years, the temperature of the repository is approaching that of the undisturbed rock.”pp 4

“Due to its stability in pure water, copper was presented as reference canister material for the Swedish programme already in 1978 III and was further elaborated in the Swedish KBS-3 study in 1983.” pp4.

“In the KBS-3 concept, the canisters are emplaced in bore holes at the bottom of a driftand surrounded by compacted bentonite clay. After canister emplacement, the drift issealed with a bentonite/clay mixture as is indicated in Figure 2. After water saturationof the repository the external pressure will reach a value ….resulting from hydrostatic pressure of 5 MPa and a bentonite swelling pressure of a maximum of10 MPa……“The dimensions and waste load of each canister have been chosen such that the temperature on the outer surface of the canister never exceeds 100° C. The canister wall thickness is dictated by corrosion allowance and radiation shielding; the radiation level at the canister surface should be low enough for radiolysis effects to be negligible.” Pp5

“These sulphides may be supplied by the buffer mass in the deposition holes and thetunnel filling materials. The supply of sulphides from these sources is limited, but there may be a continuous supply from the groundwater, which may contain sulphides at the levelof about O.S mg-dm. A corrosion evaluation has been presented by the Swedish Corrosion Institute for the KBS-3 study.” Pp6.

No matter how reassuring such Northern studies and assessments are to the people of Finland and Sweden, I have to ask, what aspects of the KBS-3 design will be accepted by the South Australian Parliament without sufficient consideration of local environmental and chemical specifics ?   Is the chemistry of South Australian ground water the same as Sweden’s? What else varies? Is the maximum intended temperature of the cooper canisters (not more than 100 deg C) actually the best temperature to choose? Other reports (one quoted below) state otherwise.

How does copper react when subject to irradiation? Many metals respond with embrittlement. I refer to “Low-temperature radiation embrittlement of copper alloys” S.A. Fabritsiev, et. al., Journal of Nuclear Materials, Vol 233-237, Part 1, 1 October 1996 pp 513-518. This paper reports that copper embrittlement is managed by ensuring that the temperature is never permitted to fall below 150 deg. C.  Yet the specifications for the Swedish design call for a maximum temperature of the copper canisters of 100 degrees C. See above.

If the storage is wet storage, what are the likely chemicals to first migrate through the damaged copper? Where will they go?

The fate of neptunium under repository settings is unknown.” Source: “Existing Evidence for the Fate of Neptunium in the Yucca Mountain Repository”, J. I. Friese, E. C. Buck, B. K. McNamara, B. D. Hanson, S. C. Marschman, PNNL-14307, June 2003 Prepared for the U.S. Department of Energy under Contract DE-AC06-76RL01830, Pacific Northwest National Laboratory Richland, Washington 99352.

Where is the groundwater coming from if in SA the repository is to be flooded as proposed by the Swedish text quoted above? Where will the ground water subsequently move to from the repository? Is there in fact any basis for an unthinking acceptance of the Swedish solution in South Australia? How wheat and mutton is produced above the deep, geologic Scandinavian nuclear sewers?   Do they wish they did not have the problem at all? Yes, but sadly they do have the problem. They may have solved their problem. Is their solution to become our problem? Given we do not share much with them, either in environmental type, chemistry or need.

There is only one institution with a similar need. World nuclear industry. Go solve it somewhere else. Maybe convince Sweden and Finland to save the world.   They will say no. That’s quite a lesson for us. Like, they have already have the holes dug.

Tentative Finding 78

parts a – c state: “For the management of used fuel and intermediate level wastes, South Australia has a unique combination of attributes which offer a safe, long-term capability for the disposal of used fuel. They include: the underlying Archaean geological structure, the Gawler Craton, at an appropriate depth for disposal. low levels of seismic activity overall and, in some parts, very low levels relative to elsewhere in the world. an arid environment in many parts of the state.”

The Gawler Craton

The Royal Commission does not provide a map that defines the area covered by the Gawler Craton. The following map is sourced from the web page “Gawler Craton” published by the Department of State Development, Government of South Australia at . The map graphic is located at the link on this webpage. There are many maps showing the Gawler Craton and most of them vary radically from one another. I hope this one is reasonably accurate.

The Gawler Craton. (Area in grey)

The Royal Commission cannot consider the actual location of the HLNW geologic repository, other than to inform that it will be located within the Gawler Craton. While advocating for the repository, the Royal Commission cannot apparently consider Southern groundwater chemistry as compared to Swedish or Finnish groundwater chemistry or any other technical factor. The only technical data it cites in its tentative findings are promotional statements.

The Gawler Craton appears to be very big. I am familiar with some geologic events of the recent past that indicate not all places located over the Craton are “stable” in the common sense.

I refer to the Bight Basin and in particular to the Ceduna Sub Basin of the Bight Basin.

The location of the Ceduna Sub-basin of the Bight Basin:

Source: “OFFSHORE PETROLEUM EXPLORATION ACREAGE RELEASE AUSTRALIA 2014 Regional Geology of the Bight Basin”, Department of Primary Industry GeoScience Australia,

“The thick sedimentary succession in the Bight Basin and its evolution from local half-graben depocentres during the Jurassic, to an extensive sag basin in the Early Cretaceous and passive margin during the Late Cretaceous to Holocene, implies that there is significant potential for the presence of multiple petroleum systems…” ibid.

From comparing the two maps shown above, I conclude that the sedimentary rock which comprises the Ceduna Sub Basin of the Bight Basin overlays portions of the Gawler Craton.

There is evidence of instability within the Ceduna Sub Basin as follows:

“Evidence for hydrocarbon generation in the Ceduna Sub-basin is also provided by the presence of active hydrocarbon seepage. The majority of seepage slicks, interpreted from Synthetic Aperture Radar data, occurs along the margins of the major depocentre, the Ceduna Sub-basin, in areas where significant Late Tertiary to Recent faulting extends to the seafloor or at onlap points of potential reservoir/carrier beds or seals. Hydrocarbon seepage correlates with regional drainage foci and patterns of late stage reactivation faults, which have focused laterally migrating hydrocarbons to produce active, probably episodic seepage at specific locations in the basin. Where these features are absent, seepage may be passive and/or be governed by long distance migration to points of seal failure.” Source: “Bight Basin”, GeoScience Australia, Australian Government, at

I have been unable to find a qualified understanding of the cause for the “episodic” nature of the seepage related to “seal failure”.   One question which arises from my mind in this matter is this: If the sedimentary rock which appears to overlay portions of the Gawler Craton is unstable in one manner or factor or other, to what extent, if any, does the interaction between the Gawler Craton and the sedimentary rock of the Ceduna Sub basin of the Bight Basin lead to this “episodic” “seal failure”?

What are the hydrologic and other dynamics of the Gawler Craton? How well is it understood by modern Geology?

“Owing to sparse outcrop, the geology of the Gawler Craton is relatively poorly understood, and its boundaries are entirely subsurface, being interpreted from total magnetic intensity and gravity data combined with outcrop and drillhole information (Schwarz et al., 2006)”. Source: “Geodynamic Synthesis of the Gawler Craton and Curnamona Province” Edited by N.Kositcin, GEOSCIENCE AUSTRALIA record 2010/27, Australian Government, at

The fate of neptunium under repository settings is unknown.” Source: “Existing Evidence for the Fate of Neptunium in the Yucca Mountain Repository”, J. I. Friese, E. C. Buck, B. K. McNamara, B. D. Hanson, S. C. Marschman, PNNL-14307, June 2003 Prepared for the U.S. Department of Energy under Contract DE-AC06-76RL01830, Pacific Northwest National Laboratory Richland, Washington 99352.

“Known knowns, known unknowns, Unknown unknowns.” Paraphrasing Rumsfield, Circa 2003.  Let’s march right in then. No problems.

Human and other Resources on the Eyre Peninsular Section of the Gawler Craton

The State government Eyre Peninsular Land Use Support Program facilities multiple uses of land resources: “Eyre Peninsula Land Use Support (EPLUS) Program has been created to assist landholders to interact effectively and confidently with the exploration and mining industry.

The Program will provide access to information, education and support and links to services that will assist landholders and explorers and miners manage the impacts on farmland, farm businesses and farming families arising from exploration and mining developments…..” Source: SA Government at

The existence of diverse uses of the relevant area allows mining, smelting and other industry, farming, and other land use. The communities of the Eyre Peninsular are therefore diverse in the activities populations may engage in.   At the moment there may exist concerns about the impact of one type of activity upon other activities on the relevant land. The Eyre Peninsular is an important rural area for South Australia and I consider it a food bowl for the state and the world.

Clean air, clean water and clean soil are prime requirements for successful agriculture. The image of clean South Australian produce is an important one for local and international marketing.

The health of the people and indeed of the entire ecology of the relevant section of the Eyre Peninsular is obviously most important. In a resource poor world, the existence of what appears to be under used land may be seen as a luxury.   However, all resources are finite even in areas in which low population densities are found. A critical resource on the Eyre Peninsular is water.

The proposed HLNW geologic repository may be (or may not be) flooded with ground water after completion – as part of the design criteria. I have to ask how such a repository might impact occupants of the Peninsular.

“Agriculture, aquaculture, tourism and mining industries, all reliant on sustainable natural resources, contribute over $2.5 billion to the economy in an average year.  Despite low rainfall and low soil fertility, around 45% of SA’s wheat and 20% of SA’s barley harvest come from the Eyre Peninsula. In addition, the region contributes 45% of the state’s seafood harvest.  Some 95% of farms are broad acre, of which 85% depend on grain growing alone, or a mix of grain and livestock farming. Given all this, the Eyre Peninsula is extremely vulnerable to a hotter, dryer future.” Source: “Effective Adaptation Policy Making: A case study from the Eyre Peninsula” National Climate Change Adaption Research Facility, at

Most of the water on the Eyre Peninsula comes from underground basins. Most of this water is already drinkable and requires almost no treatment. We have 54 bores to draw the water. Population and industry continue to grow in this area. This means that, despite the quality of local water, its availability is likely to become an increasing issue. This is why we commissioned a pipeline in June 2007 to deliver River Murray water to customers between Kimba and Lock in the north of the peninsula.

We plan to set up an additional water source, most likely desalinated seawater. Because of more rain and recharged groundwater, this has been delayed until 2023/24.” Source: “Eyre Peninsular”, SA Water, at

It may be, on the face of the evidence provided by SA Water monitoring quoted above, that certain areas of the Gawler Craton on Eyre Peninsular are becoming wetter. It may not take hundreds of years for climate change to impact the area. Perhaps it is already changing from the arid place the Royal Commission describes it as. The stability of climate experienced by the Gawler Craton is totally omitted as a consideration in the published Royal Commission edict that “The Gawler Craton is stable”. No it isn’t.

Any threat to the ground water, from any activity, is unacceptable to me personally as an owner of land located on Eyre Peninsular.  I dare say though that I will find the facilities afford me by the Eyre Peninsula Land Use Support (EPLUS) Program will prove to be not worth the doodle pad paper the program was first conceived upon.

Transport of HLNW from around the world to a SA HLNW geologic repository

The Royal Commission apparently assumes that the movements of many hundreds of thousands of tonnes of spent nuclear fuel from many countries around the world to the Gawler Craton will be low risk, no problems and perfectly safe. As contradictory as those stances are. I do not accept that position of default safety. Further I do not accept that the unloading of the HLNW will be perfectly safe. I do not accept that road transport from port to repository site will be perfectly safe, even on a dedicated purpose built road.   I would recommend that Super Freighters laden with the contents of countless reactor cores not sail down the Somali coast nor in the waters to the south of Thailand for fear of pirates. They should avoid man made Islands in the South China Sea. I suppose the ships will be guarded by 6 English policemen each with two revolvers between them. Rather than half the Pacific Fleet they would actually warrant. If they ever get to leave their home ports.  What is the Somali coast going to be like in 40 years? Peaceful or short of rad weapons?

Not every population can be subdued by imposed ‘stepped processes of community consensus’ as apparently we are going to be.

 Gaining Public Trust.

Relevant Safety Assurances made by nuclear “experts” in my life time.  

In the 1980s, the government of South Australia returned ownership of the Maralinga Lands:

“In 1984, the South Australian Government returned the freehold title for the Maralinga Tjarutja Lands to its Traditional Owners. Concerns over radiological hazards prevented the handback of Section 400.” Source: “Maralinga Tjarutja Lands: handback of Section 400” , The Anangu Lands Paper Tracker, at

As I recall at that time the then Premier, the Late John Bannon, visited the Maralinga Lands, along with Peter Burns and other ARPANSA scientists. Peter wrote a detailed description of the problem at Maralinga in a Saturday Advertiser centre page spread at that time. Mr. Bannon was appalled and surprised at the state of some areas of the lands and though the land was handed back, it was too dangerous to permit the owners to return on a permanent basis.

Full handback was not possible until the 21st century.

Why was the then Premier of SA, the late John Bannon, “Surprised” at the extent of the contamination in places at Maralinga? Why was Peter Burns, a significant leader in radiological safety at the global and national levels, and one man who could communicate openly and with trust on these issues, also, apparently surprised at the contamination at Maralinga?

For decades the relevant nuclear experts – especially those under Professor Titterton – had assured Australia and Australians that Maralinga was “perfectly safe”.  From the 1950s until 1984. Many individuals who contested the opinion of these experts were threatened with jail for breaching the official secrets act. (Source: Mr Kevin Wakefield, Ex RAN, Monte Bello Island, Mr Terry Toon, Ex Maralinga, Mr Alan Batchelor, Ex Maralinga. Mr John Hutton, Ex Maralinga.)   While some ordinary people knew the truth, they were not allowed to tell it. And when they did speak out, they received threats and disbelief. It is reasonable to think, given that the RAN surveyed the Monte Bello Islands until 1975, the same would be true of the Army and Maralinga. Everyone is a Sergeant Schulz on that one.

Well it was not perfectly safe. Was it? This is one of South Australia’s formative experiences with nuclear authorities. Professor Titterton remained entrenched at the Federal level as a nuclear safety “leader” until the era of the Whitlam government. This is not ancient history. It is for some people like yesterday. The 1984 McClelland Royal Commission records an exchange between Titterton and the Royal Commissioner. In this exchange Titterton admits he could not disclose all he knew about safety to the Safety Committee due to the fact that he was constrained by the secrecy provisions of both the United States and Great Britain. Will history repeat in this regard? What will Jay not be able to say the people of South Australia? Will silence due to “American and British secrecy provisions” reign again?   The Royal Commissioner McClelland found that some Australians in authority were akin to Fifth columnists acting more in the interests of foreign lands than they were towards Australia and its people.

This earlier Royal Commission also found that nuclear experts had stated to the effect that the critical interests of “a handful of natives” were not going to “stand in the way of the British Commonwealth of Nations.”   (Royal Commission, Conclusions, 8.4.38 – 39). Saving the world required some local sacrifice. As far away from the North as possible.   The ones closest in are the ones most affected.  Shall we do it again Jay W.?

Nuclear history is the art of waiting for historic promises to be exposed for what they are at some future point. It is kind of like a Mandelbrot Set. From where ever one stands, one has a good chance of predicting what comes next. It is like an ever repeating shoreline from which sailors may navigate the future with confidence. 1. More assurances of “It’s Perfectly Safe.” 2. Fine, let the majority rule from faith and trust. 3. Their children learn very clearly what is true and what is not, and who to trust. 4. The grandchildren say “never ever again. You sucked my Grandad and Grandma in.” It’s a process which buys 60 years for those who gain the immediate spoils.

The proposed repository is a sociological experiment. It will take decades for it to provide the history lesson. A very costly higher education.

“Perfectly Safe”, in the History of South Australia, has been a nuclear science fiction, and anyone can prove it. It has never actually true, and contaminated land remains from the time when the owners were forcibly trucked off it in the 1950s. To be concentrated in camps near the Ceduna sub basin of the Bight Basin, which overlays, in part, the Gawler Craton. Such history lies beneath the apparently solid rock statement made by today’s youngster biologists who claim expertise as nuclear people.

The experience of South Australia is more like that of Nevada than it is of anywhere else in terms of nuclear history. Place Oslo in this context and it would melt from irrelevance.

“On 18 December 2009, Section 400 was formally handed back to its Traditional Owners during a ceremony held at Maralinga Village. In an accompanying statement, the Federal Government noted that while most of this parcel of land “is now suitable for unrestricted access,” around 400 kilometres is “safe for casual access such as hunting” but not permanent occupation. The Government stated that it would “continue to monitor the site to assess the ongoing effectiveness of the rehabilitation work and, if necessary, take remedial action.”” Source: “Maralinga Tjarutja Lands: handback of Section 400” , The Anangu Lands Paper Tracker, at

And so it was that the Diaspora of the afflicted people ended after nearly 60 years.   A Diaspora enforced by nuclear experts who claimed that every thing was perfectly safe. Many of the affected never saw their homelands again. In 1984, 2009 was a rest year too far away. Because the truth was with held from entire levels of government. By the experts in charge. If the government is not in charge, who is? Shall we let them do it again? Politicians have proven their ignorance in these matters, no matter whether the ignorance is imposed on them or not.

Will a surprise revisit another Premier at another time, in relation to the proposed dump repeat the surprise of Bannon and Rann? Sometime within the first 60 years of the proposed repository, history will repeat. Of this I am certain. It is as coherent and as congruent as the sky is blue.

SA, the Yucca Mountain of the South. Quite a bumper sticker. Scandinavians are not all knowing, nor are all Americans completely stupid. If you pick the best of each you end up with something other than a nuclear dump amid the farms of Eyre Peninsular.

The Law and the Profits.

Nuclear nations all have their own laws regarding nuclear matters. For instance the United States has many laws, including the Atomic Energy Act, as currently amended, associated laws and regulations. It has long been an issue that the US Act prevents full disclosure regarding “special nuclear material” – that is plutonium and uranium as used and produced in a reactor. This matter has long been a concern in the US democratic setting. For instance, see CARDOZO LAW REVIEW, VOL 26, NO 4, MARCH 2005, PP. 1401-8.

The HLNW repository is promoted by the Royal Commission as being South Australian, owned by the government and benefitting the people of SA. To what extent then, in the course of contract negotiations, will the government and people of SA become beholden to the provisions of foreign laws regarding disclosure and other matters in regard a client nation’s HLNW? Will the contracts be commercial in confidence ? Will provisions alien to SA law be invoked in order to comply with contracted obligations? Will such provisions restrict our right to know and our freedom to speak? Will the full nature of the stockpile resident in the HLNW repository be secret in any way? Will the people be able to study each contract? What is an unclassified restricted document, and what happens if an ordinary person figures out it’s contents?

In sixty years time, are South Australians going to be as surprised as John Bannon was in 1984 at the discovery of danger in a place described for the previous 3 decades as “perfectly safe” by nuclear experts? No doubt, when that day occurs, as it surely will, on the basis of history, the response will be to the effect that the individual risk would be deemed very low. And therefore any demand for justice would fall upon the deaf ears and the blind eyes of a legally immune industry.

An Alternative

 We are told Secure Base load Electrical Power is a certainty upon which our civilization rests. Not withstanding the constantly falling price of off grid generation and storage of domestic and industrial power.

As each day passes, alternatives grow in attractiveness. As usual old industries, such as nuclear industry, bemoan the competing technology as inadequate. The odds are by the time today’s five year child is twenty five they will generate, store and use their own off grid power simply, easily and at a cost that would make TEPCO and Westinghouse executives go green. At the moment though the nuclear industry remains a dedicated future-phobe. Those who call for a nuclear revival merely confirm, in the shrillness of their demands, the proven failures of the industry over time, all over the globe.

A large solar power plant, used for both day time power generation and day time sea water electrolysis, could provide 24 hour base load power. An onsite hydrogen fuelled generator station, generating at night or as required, fuelled by solar produced Hydrogen, could transform the SA economy.   The benefits would not have to be weighted against risks spread population wide. This is 2016. Hydrogen is in daily use around the world. In SA there are potential energy sources as yet resolutely untapped.

A hybrid solar hydrogen power plant could be constructed with current knowledge and hardware.   But of course, it would be an inappropriate icon in a state dominated by the nuclear promise.

A far thinking Parliament would not be bound to digging holes in the ground for a living. It might actually originate and facilitate something that actually could save the planet. Sadly it won’t. It does not have the creative will to do so. Such things would already be done if it had.

Such ideas are deemed crazy ones in the halls of nuclear power, in that place where thinking differently seems to be a sin against the prayer book of a compulsory religion.

No thanks, I do not wish to buy this product. It sucks very badly. Have you got anything else? Preferably something sensible and compatible with the future. Not some rust belt thing that the children of all tomorrows curse us for giving them.

Lest We Repeat these Crimes, Let Us Never Forget.

Paul Langley

15 March 2016