Stephen Tansing Mr Scarce Nuclear Fuel Cycle Royal Commission...

Stephen Tansing Mr Scarce Nuclear Fuel Cycle Royal Commission

GPO Box 11043 Adelaide SA 5001

Friday, 3151 July 2015

Dear Mr Scarce,

Please find enclosed my submission to the Nuclear Fuel Cycle Royal Commission covering all four topics that form the terms of references for this royal commission.

I wish to emphasise that the outlook for further processing of minerals and manufacture of materials containing radioactive and nuclear substances is at best risky from a commercial point of view. I also wish to note that the outlook for nuclear fuel leasing is wnclear, because it is a departure from current world practices and processes. Small modular reactors, particularly using the emerging molten salt based technologies, offer great opportunities for the circumstances in Australia, including the incineration of high level nuclear waste. Waste incineration in many ways is a superior choice to a deep geological repository, although it is not wjthout difficulties.

It remains unclear where/how nuclear based electricity generation sits in Australia's future, but it seems obvious that there exists synergies between Solar Thermal energy with high temperature fluoride molten salt storage and Small Modular [nuclear] Reactors using molten salt technology. The fluoride-salt-based conversion (without enrichment) of uran.ium seems to be the most likely fjrst step, if market forecasts through 2030 prove favourable.

In the mean time, renewable energy looks like a sure thing, with potential synergies whilst a nascent nuclear industry forms. And whether by hook or by crook, in tl1e end, nothing and no one will stop the 21st century energy transformation.

Stephen Tansing, Nuclear Fuel Cycle Royal Commission 1

Exploration, Extraction and Milling I make no detailed submission to the royal commission regarding the exploration, extraction and

milling of radioactive substances.

Thorium - a fertile nuclear fuel- is usually found in combination with other lanthanides such as

Neodymium, Samarium, Yttrium and Erbium. The economic case for exploration, extraction and

milling of thorium as part of a nuclear fuel cycle will be influenced by and interact with the

economic case for exploration, extraction and milling of lanthanides. Rare Earth magnets, catalysts,

fibre dopants in optical and optoelectronics are potential industries that may demand lanthanides co

produced with thorium as nuclear fuel. Lynas Corporation[1], as an example, has faced problems

with their processing facility in Malaysia based on resource at Mt Weld, Western Australia,

significantly because thorium currently doesn't have a major global market. Instead Lynas must

navigate the problems of handling thorium not as fuel but as a nuclear waste. A global market for

thorium would need to appear to induce increased extraction of lanthanide deposits that contain

high proportions of thorium.

[1] Bradsher, Keith. "Malaysia Gambles on Processing Rare Earths." The New York Times, March 8, 2011. http://www.nytimes.com/2011/03/09/business/energy-environrnent/09rare.html.

Further Processing of Minerals and Manufacture of Materials Containing Radioactive and Nuclear Substances

There is currently an oversupply in the Uranium market. Projections from the World Nuclear

Association through 2030 express uncertainty whether increasing demand will materialise. An

important factor in play is that emergent nuclear reactor technologies promise to bring higher

nuclear fuel efficiency.

1. Could the activities of conversion, enrichment, fabrication or reprocessing feasibly be

undertaken in South Australia?

2. Would it be feasible for South Australia to assume a greater role in manufacturing materials containing radioactive and nuclear substances?

3. What are the projections for future supply and demand for conversion, enrichment, fuel fabrication or reprocessing activities?

4. Could South Australia viably increase its participation in manufacturing materials

containing radioactive and nuclear substances?

The Nuclear Fuel Cycle Issues Paper 2, Figure 1 shows that any new manufacturing industry

would be a risky venture, although it may potentially pay off. Does it make sense to

engage in a financially r isky business venture involving nudear materials? And if the

lower case identified by the World Nuclear Association evenhlates, who will pay off any

emergent bad debt whilst not stripping off operational safety costs from the nascent


manufacturing industry?

Predicting energy consumption in the future is notoriously fraught, as can be observed with

the changing (decreasing) energy intensity of Australia's growing economy that few analyst

predicted. For example, the US Energy Information Administration predicts an annual

growth rate in nuclear electricity production of only 0.2% compared with 1.9% to

2.7% for renewables against against a GOP increase of 2.4% per annum. What is the

opportunity cost of investment in nuclear materials manufacturing over renewable energy?

Looking at China, a Lawrence Berkeley National Labs study suggests that China will add

between 6GW and 12GW nuclear power per annum through 2050, compared with 12GW

and 14GW renewables. Therefore the risk of a nuclear manufacturing industry is heavily predicated on selling to growing markets like China.

The International Energy Agency projects a virtual decarbonisation of global electricity

production by 2050. lEA predict that the largest share of global electricity will be from

renew abies at some 65% of total global electricity production. lEA says "The high share

of variable renewables, which in some countries reaches well over 40%, significantly

changes the operating environment of nuclear." And this means nuclear power operating

under flexible peaking rather than inflexible baseload regime, whid1 in tum means reduced

fuel requirements.

In the 2006 Uranium Mining, Processing and Nuclear Energy Review, BHP Billiton

submitted that " there is neither a commercial nor a non-proliferation case for it to

become involved in front-end processing or the development of fuel leasing services in

Australia" BHP noted that it's "strategy is not to enter the front -end processing market

nor indeed does it have the depth of technological skills and precision engineering manufacturing experience to do so."

Since the UMPNER review, the short term outlook provides no new commercial incentive

for BHP and indeed the future outlook appears to be commercially risky. Any proposed

nuclear fuel manufacturing industry must carefully assess the investment value given these

business risks, compared with opportunity cost.

The production and manufacturing of other radioactive substances, especially for export, is

already being conducted in the Lucas Heights complex in Sydney. The OPAL reactor is

capable of being expanded with a second neutron guide hall on the south side of the reactor

building. Why would investment in a second research reactor for Adelaide be viable if

OPAL can be expanded at reduced cost instead? The management, governance and financial

sustainability concerns in recent years around the Australian Synchrotron make the

installation of additional cyclotrons and synchrotrons in Adelaide for commercial purposes

questionable.

In US 2011, the US NRC issued a license to Areva Enrichment Services to construct and

operate the Eagle Rock Gas Centrifuge uranium enrichment plant in Bonneville County,


near Idaho Falls. This project is on hold, but should market conclitions change would likely

fill any potential space described in the Nuclear Fuel Cycle Issues Paper 2, Figure 1 before

Australia.

If uranium enrichment is contemplated, then it is assumed that South Australia - or more

broadly Australia- has developed the knowledge to enrich uranium. It is clear that

knowledge of uranium enrichment is intimately tied to weapons proliferation. There is no

reason to believe that any other nation that is a signature to the Nuclear Non-Proliferation

Treaty will share the knowledge. However Australians in Australia have developed a method

of Separation of Isotopes by Laser EXcitation. The economics of this method remain

unclear. Work between SILEX Systems and imerested parties under the GE-Hitachi Global

Laser Enrichment company in the United States stopped on 24th July 2014. On face value

the reason appears to be that investment in novel enrichment methods have been abandoned

due to market conditions, perhaps a kind of "fallout" from the Fukushima Daichi incidents.

Silex CEO and Managing Director, Dr Michael Goldsworthy[!] said : " the global nuclear

industry is still suffering the impacts of the Fukushima event and the shutdown of the

entire Japanese nuclear power plant fleet in 2011. Demand for uranium has been slow-er

to recover than expected and emichment services are in significant oversupply." Anothez::.

reason may be that the SILEX process for enrichment is in fact inferior in physic~] aJidlor

economic terms to the existing sunk investment in the Gas Diffusion process used 1n the · United States of America.

.. . · .• -··

Reading of the Nuclear Fuel Cycle Issues Paper 2, Figure 1 sourced from.the·World N~clear

Associations also shows a deception on the part of the authors of the Issues Paper · ·.~ Number Two of this Royal Commission. The Converdyn Metropolis Works Plant is not a

uranium enrichment plant and that Converdyn does not engage in commercial uranium

enrichment. lnstead Converdyn is -hinted by its very name - a uranium conversion plant

from uranium oxide from a mine into Uranium Hexafluoride (UF6) used as input into

uranium enrichment. Nuclear Fuel Cycle Issues Paper, Figure 1 "Projected world uranium

enrichment supply-demand balance" shows no such thing. Instead it shows Projected

world uranium conversion supply-demand balance.

It is folly to attempt a commercial uranium enrichment industry in Australia.

According to the World Nuclear Association, the following conversion plant utilisations

exist:

Company Nameplate Capacity ' Utilisation 2013 (t U as UFG)

Cameco, Port Hope, Canada 12,500 70%

Gameee, St:Jr:i:ftgfieles, HK &;GOO 83%

JSC Enrichment & Conversion 25,000 55% Irkutsk & Seversk, Russia Operating capacity 15,000

Comurbex (Areva) 15,000 ,70%


,-

Company NamepJate Capacity Utilisation 2013 (t U as UF6)

Malvesi (UF4) & Tricastin (UFG), France

Honeywell Converdyn, 15,000 70%

I Metropolis, USA

CNNC, Lanzhou, China 3650? unknown

IPEN, Brazil 40 70% -

Wor ld Total circa 71,000 nameplate -·

In August 2014 the Springfields, Lancashire, UK uranium conversion plant operated by

Cameco was placed in standby. "With the current weak market for UF6 conversion we can

meet our customer requirements from our Port Hope conversion facility and benefit from

better utilization of existing assets," said Tim Gitzel, Cameco's president and CEO.

Jf the market picks up, will Carneco's Springfields plant be rejuvenated in front of any

potential Australian plant?

The potential for any Australian uranium conversion plant will only likely emerge as one of

a diverse set of suppliers to China.

5. What legislative and regulatory arrangements would need to be in place to facilitate further processing and further manufacturing activities, including the transport of the products which they generate?

I would advise a thorough review of international regulatory frameworks. For example Part

71 for the US NRC Regulation 10 for the Packaging and Transportation of Radioactive

Material and Part 73 of the US NRC Regulation 10 for the Physical protection of plants and

materials[2][3].

This means that before any shipment can occur, the shipper is required to review the

package certificate of compliance to determine if any testing or maintenance is required. The

shipper may be required to check or change package seals and other components or perform

leak testing. In addition, the shipper must take radiation measurements at specific locations

on and around the package to make sure that the levels are below the required limits.

The shipper must also meet the transportation requirements for shipment of the nuclear

material including route selection, vehicle condition and placarding, driver training, package

marking, labeling, and other shipping documentation.

The shipper must make sure that spent fuel is protected against radiological sabotage.

Shippers who transport or deliver spent fuel to a carrier for transport are required to meet

specific requirements that include:

(a) notify the Federal regulator, such as ARPANSA, of the shipment, who would in turn \

notify the relevant parties - as required - of the Australian National Security Community.

Stephen Tansing, Nucleal' Fuel Cycle Royal Commission 5

(b) having suitable procedures for addressing emergencies

(c) having a communications centre, having a written log of shipment events

(d) making arrangements with local law enforcement for shipments while en route

(e) using armed escorts in heavily populated areas

I choose not to comment about additional risks, processes, best practice models, health, safety and

environmental risks or security and safeguards implications of further processing of minerals, and

manufacture of materials containing radioactive and nuclear substances. However, T do emphasise

the need to form credible assessments and procedures that can be expected to be effective in tl1e real

human organisations would implement them. If anything comes from past significant incidents in the nuclear industry is the critical role of the human factor.

[1] Parkinson, Giles. "Silex Tumbles after Solar-Nuclear Switch Hits Market Roadblock." Renew

Economy, July 28, 2014. http://reneweconomy.corn.au/2014/silex-tumbles-after-solar-nuclear

switch-hits-market-roadblock-51041.

[2] US NRC. "NRC Regulations Title 10, Code of Federal Regulations." US NRC, July 23, 2015.

http://www.nrc.gov/reading-rm/doc-collections/cfr/cfr-title-lO.zip.

[3] US NRC. "Safety of Spent Fuel Transporation." US NRC, March 2003.

http://pbadupws.nrc.gov/docs/ML0311/ML031140098.pdf.

Electricity Generation from Nuclear Fuels 1. Are there suitable areas in South Australia for the establishment of a nuclear reactor for

generating electricity? What is the basis for that assessment?

2. If a facility to generate electricity from nuclear fuels was established in South Australia,

what regulatory regime to address safety would need to be established?

3. What are the best examples of those regimes? What can be drawn from them?

A number of criteria must be developed, using knowledge from other nuclear regulatory

bodies from around the world. For example, the US Nuclear Regulatory Commission has

developed a [!]General Site Suitability Criteria for Nuclear Power Stations.

Some criteria are as follows[2], from the NRC Regulation Title 10, Part 100:

o Characteristics of reactor design and proposed operation:

• Proposed maximum power level

• Nature of contained inventory of radioactive materials

• Extem to which generally accepted engineering standards apply to reactor design

• Extent to which reactor incorporates unique or unusual features that have a

significant bearing on the probability or consequence of accidental release of


radioactive materials

• The presence or absence of sa fety features that are engineered into the facility,

and the likelihood rhat those barriers will be breached as a result of an accident

before a release of radioactive materials into the environment can occur.

o Population density and use characteristics of the site environs, including the

exclusion area, the population distribution, and site-related characteristics must be

evaluated to determine whether individual as well as societal risk of potential plam accidents is low, and that physical characteristics unique to the proposed site that

could pose a significant impediment to the development of emergency plans are

identified.

o The nature and proximity of man-related hazards (e.g., airports, dams, transportation

routes, military and chemical facilities) must be evaluated to establish site

characteristics for use in determining whether a plant design can accommodate

commonly occurring hazards, and whether the risk of other hazards is very low.

o Physical characteristics of the site, including seismology, meteorology, geology. and

hydrology.

• A Safe Shutdown Earthquake Ground Motion design basis for the site

• Maximum probable wind speed

• Maxjmum probable precipitation

• Soil, sediment and rock characteristics, adsorption and retention coefficients,

ground water velocity, and distances to the nearest surface body of water

• The maximum probable flood

o Determination of t11e seismic, meteorologic, hydrologic, and geologic characteristics

of the proposed site should consider the most severe of the natural phenomena that

have been historically reported for the site and surrounding area and include

sufficient margin for the limited accuracy, quantity, and period of time in which the

historical data have been accumulated.

o Sites located near geologic structures for which an adequate database to determine

"capability" is developed.

4. Are there commercial reactor technologies (or emerging technologies which may be commercially available in the next two decades) chat can be installed and connected to the

NEM?

S. 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?


6. What factors affect the assessment of viability for installing any facility to generate

electricity in the NEM?

7. What are the conditions that would be necessary for new nuclear genera cion 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?

B. What place is there in the generation market, if any, for electricity generated from nuclear

fuels to play in the medium or long term?

9. What are the lessons to be learned from accidents, such as that at 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?

10. What impact might the establishment of a facility to generate electricity from nuclear fuels

have on the electricity market and existing generation sources? What is the evidence from

other existing markets internationally in which nuclear energy is generated? Would it

complement other sources and in what circumstances? What sources might it be a substitute

for, and in what circumstances?

Based on a study by Electranet[3], the existing SA transmissjon network can support a

single loss of generation event of up to 450MW without experiencing steady state, dynamic

voltage and transient stability issues. This in turn limits South Australia's electricity grid to

no more than 450MWe per unit. A single nuclear energy generation unit within the grid

must be allowed to SCRAM without causing transmission problems. Indeed throughout

Australia the largest coal power plants have a unit size of no more than 720MWe (Eraring

Power Station NSW after uprating, built in a set of 4 units).


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Figure 1: Full range of Tmport/Export limits versus Generation/Load loss from maximum 10 minimum South-East of South Australia (SESA) wind generation[3]

Very few nudear power stations are in operation globally with a unit size no more than

450MWe, and indeed the Levelised Cost of Electricity is lower for much large nuclear

lGWe ir bigger nuclear reactors. Why? The safety and regulatory burden for a nuclear

power reactor does not increase linearly with the size of the reactor. Instead, the additional

regulatory burden is smaller for incrementally bigger reactors. These constraints make use

of traditional large-scale Water-cooled reactors as unsuitable for South Australia. It also

casts a long doubt over the economic case for a smaller Water-cooled reactor of a traditional design.

The most likely form of Nuclear Electricity Generating Station is some kind of SmaD

Modular Reactor. Each module can then be independently SCRAMed without negatively

affecting South Australia's electricity reliability. In order to reduce the safety burden per

unit energy produced to a minimum, a vastly improved design would be required that uses

less parts, common parts and requires far less engineered safety systems to achieve the same

level of safety protection.

I recommend taking the closest look at the High Temperature Molten Salt class of small

modular nuclear reactors. I specifically identify this class because it features the basic

characteristic of low pressure to provide increased safety, and high temperature to provide

increased energy efficiency.

Low Temperature (250-500°C) High Temperature (600-800°C)


Low Pres.<mre (Up to 2 atm)

High Pres.1111re (I 00 arm or more)

Low Thermodynamic E[fic·iency Higlr Thermodynamic.: Effidency

• • •• . -. . Light Water Reactor (LWR) Heavy Water Reactor (CANDU)

Molten Salt Reactor Advanced High Temperature Reactor (MS)

Gas Cooled High Temperature Reactor Advanced High Temperah1re Reactor (GC)

Figure 1: Transatomic Power (TAP) Molten Salt Reactor[6]

Molten salt nuclear reactors feature the fuel as a fluoride salt mixed with a coolant and/or

moderator also a fluoride salt. Several molten salt designs feature very wide thermal safety margins. In particular, coolant-moderators based on Sodium-Rubidium Fluoride eliminate the production of tritium and more broadly the presence of Hydrogen. This is a profound

outcome, because it significantly reduces the potential corrosive nature of the salt (regulated to be pH=7, or slightly above), the usual concern with such reactors, whilst eliminating the production of a biologically hazardous product (tritium) of most nuclear reactors. It also

means tl1at Sodium-Rubidium Fluoride Molten salt cooled-moderated nuclear reactors all but eliminate runaway exothermic Hydrogen generation as a potential driving force that

could lead to explosive conditions at a nuclear reactor as seen at Fukushima. According to research by the University of Tennessee[ 4], a combination of 46% Sodium fluoride, 33% Rubidium Fluoride and 21% Uranium Tetra-fluoride has a eutectic melting point of 470°C

and requires uranium enrichment of less than 2% (slightly enriched uranium) to operate as an electricity generator. This means it can burn spent nuclear fuel from traditional Light

Water Reactors as part of waste management. It must be noted that Rubidium Fluoride nuclear fuels have several significant activation products: 86mRb, 88Rb and 86Rb with half lives of lrnin, 18 min and 18 days respectively with high-energy (>0.3 MeV) gamma

radiation[S]. Activated fuel would need management, and suggests a role for robotics in maintenance but also facilitates constant surveillance of the reactor vessel walls.

Molten salt reactors support a freeze valve concept whereby excessive heat causes the fuel,coolant and moderator mixture to drain out of the reactor into a subcritical


configuration. That is, excessive heat turns off the reactor automatically without human

intervention. The peak fuel temperature is something like soooc BELOW the boiling point

of the coolant whereas the peak fuel temperature in a water-cooled nuclear reactor is

something like 1900°C ABOVE the boiling point of the coolant. Tllis means that a molten

salt reactor is highly resistant to a Boiling Liquid Expanding Vapour Explosion, whereas a

Water-cooled reactor IS AT RISK BY DESIGN.

Molten salt reactors operate at or near atmospheric pressure, whereas Water-cooled reactors

operate at something like 150 times atmospheric pressure. Therefore Molten Salt reactors also eliminate a Pressure-release Driving Force from the reactor.

Molten salt reactors operate at up to 700°C, which is much higher than the 300°C found in

typical water-cooled nuclear reactors. This translates into significantly higher

thermodynamic performance and the ability to use the reactor for industrial processes other

than electricity.

Molten salt reactors using Zirconium Hydride moderation rods in nickel-alloy cladding

operate in the thermal and fast spectrum simultaneously, ensuring high fuel utilisation even

from slightly enriched or even spent fuels .

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Figure 2: Neutron spectrum in Molten Salt Reactors with different moderation[6]

Molten salt reactors produce far less Noble Gases like Xenon and Krypton. The noble gases

interfere in the fiss ion process and reduce operator control over the reactor. Xenon

production at low power levels in RMBK type nuclear reactors was an important factor in the Chemobyl incident, and remains an operations problem in all water-cooled nuclear

reactors. Low noble gas production enables a molten salt reactor to be used in a loadfollowing or peak-load r ole in off-grid settings, without introducing additional safety

risks. Also, a Helium-sparging mechanism allows the little noble gases and in relevant

designs tritium gases that are produced to be extracted continuously online.

Finally high temperature molten salts are an excellent storage and heat transfer medium for


Solar Thermal Energy. South Australia, like other areas of Australia, is blessed with large

quantities of Solar Thennal insolation throughout the year. Just not overnight. However

molten salts, including the Fluoride Salts such as Sodium-Rubidium Fluoride, can be used to

store high temperature solar thermal energy captured during the day for dispatch overnight.

Unlike the lower temperature Nitrate Salts currently being fielded in Spain and the United

States, high temperature molten salts allow hot gas turbines to be driven from the salt. Hot

gas turbines, when combined with Stearn Turbines in a combined cycle formation are much

more energy efficient than Steam Turbines alone. This in tum increases the energy

efficiency of a Solar or Nuclear Thermal Power Plant, reducing its costs, and rendering it

more thermodynamically efficient than a Coal fired power plant.

11. How might a comparison of the emission of greenhouse gases from generating electricity in South Australia from nuclear fuels as opposed to other sources be quantified, assessed or

modelled? What information, including that drawn from relevant operacional experience

should be used in that comparative assessment? What general considerations are relevant in conducting those assessments or developing these models?

Different electricity generating technologies introduce greenhouse gas burdens at different

stages of their lifecycle. For example fossil and nuclear fuelled electricity generat.ion

stations require ongoing refuelling and maintenance whereas solar photovoltaics may attract

rare, minimal maintenance. Comparisons of the greenhouse gas burden of different

electricity generating technologies must:

(a) Account for the total greenhouse gas burden over the lifecyde of the development,

construction, operation, decommissioning and material recycling of the asset, including

embodied emissions in construction material and fuel mining and production. Estimates

should also be made of fugitive emissions from construction material and fuel mining and

production.

(b) Be formulated in terms of energy produced over the lifetime of the asset.

(c) Differentiate those technology configurations in which more than about 60% of the total

unit capacity can be considered dispatchable, given 24 hours notice of availability, but less

than 1 hour notice of request for supply. Dispatchable electricity generators can tum on and

equally turn off, based on market demand. The 60% indicator is driven by the NEM's

annual operating envelope between peak supply/demand and trough supply/demand;

different energy mixes and the presence of demand management may change the indicator

level. A viable electricity system will usually be based upon a mix of complemenlary

electricity generating technologies, and comparisons between technologies in different

complementary roles within the same mix is unhelpful.

12. What are the wastes (other than greenhouse gases) produced in generating electricity from

nuclear and other fuels and technologies? What is the evidence of the impacts of those

wastes on the community and the environment? Is there any accepted means by which those impacts can be compared? Have such assessments making those comparisons been


undertaken, and if so, what are the results? Can those results be adapted so as to be

relevant to an analysis of the generation of electricity in South Australia?

13. How might a comparison of the unit costs in generating electricity in South Australia from nuclear fuels as opposed to other sources be quantified, assessed or modelled? What

information, including that drawn from relevant operational experience, should be used in that comparative assessment? What general considerations should be borne in mind in conducting those assessments or models?

The usual method to compare the waste streams produced by electricity generating

technologies is by using Life Cycle Analysis (LCA). The literature focussed heavily on

Greenhouse Gases (GHG) when conducting LCA. Difficulties arise when comparing other

metrlcs.

For example, the World Energy Council's lifecycle assessment[7] makes the following

comments:

"Evaluation of emissions from energy production and transportation life cycles has heen the

principal target of studies because of the direct and jndirect impacts on health and

environment and the international conventions for emission control. For energy production

life cycles, other effects related to rational use of energy, natural resources and land have

also been considered. This kind of analysis has been used to compare fossil and renewable

energy cycles with each other. Since the renewable energies (particularly solar and wind) are

'dilute', more materials and larger land areas are required than for the fossil ones.

There are comparative studies on the land requirements of different electricity generation

options. The problem with such comparisons is that the calculated areas are not fully

comparable. The area may have other simultaneous uses not related to electricity generation.

For example, a hydropower reservoir may also be used for flood control or irrigation and

sometimes for fishing and recreation. A tree plantation area may also be used for recreation.

Solar photovoltaic modules are usually installed on roofs that have no alternative use.

One way to compare different electricity generation options is to calculate the so-called life

cycle energy payback time. This concept is defined as the time required for the electricity

generation equipment to produce the amount of energy equal to the energy used to build,

maintain and fuel this equipment, converted to the corresponding amount of electrical

energy. Another way to present the result of such an analysis is to calculate the so-called life

cycle energy payback ratio. This is the ratio of the net electrical energy produced over a

plant's lifetime to the energy required to build, maintain and fuel the plant over its lifetime."

Application of risk-consequence assessments driven by failure modes, effects and criticality

analysis as well as design basis wastes from energy production and transportation

technologies, and project with capital and operations expenditure to foflll;ulate a life cycle

energy payback time is a relevant comparison basis.

The most thorough risk-consequence and design basis wastes review ever conducted is the

ExternE project by the European Union. The ExternE project themselves recognise that


such an analysis is a very difficult and complex activity, involving a wide range of different

types of expertise, and remains a work in progress.

It would be tempting to take the European Union's ExternE findings directly without further

assessment, but that would likely be erroneous. Instead, Australia should seek to utilise the

methodology developed by the EU and mix with the relevant efforts already made by

CSIRO, GA, BITRE, BREE and others to make an equivalent assessment for Australia.

BREE has already developed an Australian Energy Technology Assessment, but explicitly

ignores decommissioning and waste management of any technology in their assessments.

Of course, this skews favourably technologies like Nuclear Power with high decommissioning and waste management costs, and unfavourably technologies like Wind

Power with high recyclability of valuable materials.

[1] US NRC. "Regulatory Guide 4. 7, Revision 3, General Site Suitability Criteria for Nuclear

Power Stations," March 2014. http://pbadupws.nrc.gov/docs!ML1218/ML12188A053.pdf.

[2] US NRC. t'NRC Regulations Title 10, Code of Federal Regulations." US NRC, July 23, 2015.

http:/ /www.nrc. gov/reading -rm/doc-collections/cfr/cfr-title-1 0. zip.

[3] Electranet. "South Australian Transm1ssion Annual Planning Report." Electranet, June 2013.

http://www.electranet.eom.au/assets/Reports-and-PapersffAPR2013-Final-28June2013final.pdf.

[ 4] Chvala, Ondfej. "MSR Lattice Optimization for Economic Salts with LEU Fuel." In

Proceedings of ICAPP, 2014. http://web .utk.edu/~ochvala/MSRJICAPP2014/14187-final.pdf.

[5] Williams, D.F., L.M. Toth, and K.T Clarno. "Assessment of Candidate Molten Salt Coolants for

the Advanced High-Temperature Reactor (AHTR)," March 2006.

http://web.ornl.gov/"'Webworks/cppr/y2006/rpt/124584.pdf.

[6] Transatomic. "Transatornic -Technical White Paper." Massachusetts Institute of Technology,

March 2014. http://www. transatomicpower.com/wp-content/uploads/20 15/04/transatomic-white

paper.pdf.

[7] World Energy Council. "Comparison of Energy Systems Using Life Cycle Assessment." World

Energy Council, July 2004. http://www.worldenergy.org/wp-content/uploads/2012/1 0/PUB _Comparison_ of_Energy _Systens_using_lifecycle_2004_ WEC.pdf.

Management, Storage and Disposal of Nuclear and Radioactive Waste

1. Are the physical conditions in South Australia, including its geology, suitable for the

establishment and operation of facilities to store or dispose of intermediate or high level

waste either temporarily or permanently? What are the relevant conditions? What is the

evidence that suggests those conditions are suitable or not? What requires further

investigation now and in the future?

The proposed National Radioactive Waste Management Facility is to cater for low level and


intennediate level nuclear waste. High level nuclear waste typically takes one of two forms:

(a) Spent nuclear fuel rods, or

(b) Waste materials remaining after spent fuel is reprocessed.

lsotopic analysis of spent nuclear fuel has shown that long-lived high level nuclear waste comprise the actinides, which can be transmuted into shorter lived isotopes under neutron

bombardment.

Pyroprocessing can be used to extract all the actindes at once in a form suitable for a waste incinerating nuclear reactor.

The Molten Salt nuclear reactor mentioned earlier, but also the Liquid Sodium Fast Reactor, are capable of transmuting mixtures of act.lnides into intennecliate and low level nuclear

waste, and even into stable (non-radioactive) useful materials.

I strongly urge the commission to not recommend the establishment of a high level nuclear waste repository, and instead focus on reprocessing systems that require only an intermediate level nuclear waste repository with much shorter expected containment

lifetimes (300 years ralher than 10,000 years). This would be consistent with the arrangements being made be the Federal Government.

Stephen Tansing, Nuclear Fuel Cycle Royal Conunission 15

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