Hans-Peter Schnelbögl, Diplom Ingenieur (Techn. Univ. Munich)    Ph: (02) 6622 0243
PO Box 1223 Lismore NSW Australia 2480   www.nor.com.au/community/future   July 2000


Long-term Consequences of Uranium Mining

Example: Olympic Dam mine at Roxby Downs, Australia


The radiation from the uranium tailings (mining waste) is many million times more dangerous to humans than the radiation from the ore in its original state.

These tailings are being produced in vast quantities in Australia – 14,000 tonnes each day.

They will cost human lives for millions of years.

By law, the tailings are required to be safely contained for 1000 years. Erosion may start within a 100 years. Even after 1000 years, the tailings retain 99% of their radioactivity – a scientific fact





1 Why is the Radiation from the Tailings so Hazardous?

1.1 Health effects of tailings radiation

1.2 The millionfold increase of the radiation hazard from the tailings

1.2.1 Alpha radiation and fine milling

1.2.2 Fine milling as it affects tailings erosion, dispersion and accumulation in the biosphere

1.2.3 Emanation of the radioactive gas radon

1.2.4 Fine milling and future human interference with the tailings

1.2.5 Fine milling and oxidation

1.3 The very long-term hazard of the tailings

1.4 Lost knowledge

1.5 Tailings versus toxic chemical waste

2 Tailings Storage

2.1 The quantities

2.2 Tailings storage in tailings dams

2.3 Leakage into groundwater

2.4 Structural life expectancy

2.5 Comparison of storage options

3 Estimates of Radiation Exposures and Death Toll

3.1 The combined dose limit

3.2 The ‘critical group’

3.3 The Contribution of the Various Aspects and Pathways of Radiation

3.3.1 Alpha Radiation - Inhalation of Tailings Particles

3.3.2 Alpha Radiation - Ingestion of Tailings Particles

3.3.3 Inhalation of Radon Gas

3.3.4 External Radiation - Gamma Radiation

3.4 The Combined Radiation Exposure

3.5 Estimates of the future death toll

3.6 Other studies and estimates

3.7 Pathway distribution model

4 Economic Aspects

4.1 Cost of tailings storage

4.2 Rehabilitation, reclamation, compensation and mine closure

5 Regulatory, Political and Ethical Aspects

5.1 The international regulatory body (ICRP)

5.2 The Australian regulations

5.3 Supervision

5.4 Nuclear industry and society

5.5 The ethical background

6 The inadequate EIS process

6.1 Environmental Impact Statements omit the essential information

6.2 The submissions to the EIS

6.3 The role of the consultancy firm (Kinhill)

6.4 The Supplement to the EIS can ignore the main concerns in submissions

6.5 The role of the assessing and supervising authorities (OSS and Environment Australia

6.6 The political decision

6.7 Concepts for a revised EIS process




The uranium tailings issue presents an unprecedented challenge to our ethical framework paralleled only by the potential for a large scale nuclear war.

However, while such a war is a potential, the future tragedy from our uranium tailings is a certainty. While a nuclear war would result from an accident or from an act of despair or insanity, the uranium tailings are being created out of business calculation. While a nuclear war affects both our generation and, via genetic effects, future generations, the uranium tailings will affect, nearly exclusively, innocent members of our future generations.

The effects of the uranium tailings will be particularly insidious. According to our estimates (Olympic Dam tailings), during the worst period some 150,000 years from now, the death toll for humans will be about 500 per year. These deaths will be spread out over thousands of kilometres, although they will be more concentrated in the region of the mine site. These large scales of time and space perfectly hide the dramatic death toll of many millions to billions of future humans from each of our uranium mines. This makes it impossible for the future victims to perceive the source of their problem and to escape their predicament.

The situation requires us to develop an abstract understanding and appreciation of ethical values. This is a big challenge for a society, which is largely indifferent to the drastic TV footage of starvation in distant Africa.

The international (ICRP) and various national regulatory bodies, as well as our scientists, have failed miserably in this challenge: generally the consideration of the future death toll (‘future detriment’) is ignored (‘truncated’) beyond a thousand years.

According to our estimates, over the first thousand years - the regulatory time frame for safe storage of tailings - the death toll from the Roxby Downs mine will be about 10 per year resulting in a total of 10000 deaths. These 10000 deaths as a consequence of the operation of a uranium mine are totally unacceptable, but then there will be another 130 million deaths after the ’truncation’ -- seemingly not worth considering or even mentioning in any official study.

There is another Australian uranium mine with similar deadly consequences, and many more mines are being prepared. If we collectively do not want to be the biggest killers in the planet’s history, we must stop uranium mining.

Our modern science and industry certainly gave a lot of abilities and powers to the modern human. Unfortunately, our ethical development is not yet adequate to deal with such powers. Power corrupts, and this makes it now even more difficult to catch up with the development of adequate values, where we already are used to those powers. We are faced with the decision whether we as individuals, and as a society, wish to value short-term economic gain higher than the most fundamental ethical values. Rarely are we aware that human happiness is directly related to our ethics and good-heartedness.

The tailings issue invites us to rethink our ethical position and open our hearts for those future people to be affected. If we accept this challenge, then not only can we save millions of future lives, but we ourselves will benefit greatly: the development of more responsible ethics will eventually help us to resolve our contemporary problems as well (unemployment, street violence, pollution etc.).





Uranium mining is in no way a sustainable development. It has no constructive balance between economy, environment and the welfare of the people. In the long term, it will destroy all three.

  1. After uranium mining, about 80% of the radioactivity of the original ore remain in the ‘tailings’. These tailings are the mining waste, which is usually dumped near the mine site.
  2. The main type of radiation of the uranium ore is alpha radiation. Alpha radiation is about 20 times more dangerous than beta and gamma radiation.
  3. The alpha radiation of the natural ore has little effect on humans because an alpha-radiating substance needs to be inside the human body to be biologically effective. However, to extract the uranium, the ore is being finely milled -- to particle sizes, which easily can get inside the body via inhalation and ingestion. Also, the fine milling facilitates erosion and dispersion of the tailings. Fine milling increases the detrimental effect of the tailings radiation many million times.
  4. The inhalation of only 1½ grams of Roxby tailings dust or 0.4 gram of Ranger tailings dust per year exceeds the legal dose limit. However, when mining at Roxby Downs and Ranger is finished there will be enough radioactive tailings left (620 million tonnes) to theoretically cover the whole of Victoria 1.7mm high.
  5. The most dangerous isotope in the tailings is the gaseous radon-222. It is continually being produced in the tailings as a decay product and can carry four of the six alpha decays of the tailings to distant locations. The fine milling, combined with erosion and dispersion of the tailings, will facilitate its escape. The gaseous radon spreads the contamination over thousands of kilometres.
  6. 50 years of Australian uranium mining will bring death for millions of years. For each year we delay the closure of Ranger and Roxby Downs, an estimated 3.5 million future Australians will die -- equivalent to the population of Sydney.
  7. Radioactivity can not be perceived with the senses. Over the long time spans involved the knowledge and understanding of the dangers will be lost as well. Many people will be living and working in areas contaminated with tailings isotopes. They will grow their food on contaminated soil and drink contaminated water. The tragic consequences (mainly cancers and genetic damage) appear only years after the exposure, thereby further obscuring the reasons for suffering and death
  8. The radioactive hazard from the tailings at Ranger and Roxby is such that the tailings would have to be safeguarded for billions of years. Australian regulations require a life expectancy for a tailings repository of 1,000 years. However, after 1,000 years the tailings retain 99% of their radioactivity (this is not an estimate but a scientific fact). After only five years the tailings dams at Roxby Downs and Ranger have had major leaks and seepage.
  9. The cost of low-level surveillance, monitoring, maintenance of the tailings repositories, of related training and preservation of information (very conservatively estimated at $300,000 per year for Roxby and $140,000 per year for Ranger) adds up to $4.4 trillion over the next 10 million years (a minute fraction of the required time span). However, the regulations provide for the government to resume responsibility and bear costs shortly after mine closure.
  10. The main waste from in-situ leach uranium mining, is unrecovered uranium leachate. It will contaminate groundwater (springs, bores and seepage) for literally billions of years.
  11. Recently, nuclear energy and uranium mining have been promoted as Greenhouse-friendly. It is neither ethical nor possible to combat our Greenhouse problems with a ‘nuclear solution’ which will be borne by our future generations with disease, genetic damage and billionfold death from radiation cancer. Greenhouse emissions have to be reduced and uranium mining has to end. Wind energy is Greenhouse-friendly and considerably cheaper than nuclear energy (in many cases even cheaper than coal) as several European countries prove

This paper further provides comparisons of various tailings storage options and estimates of the future death toll based on a study by the US Environmental Protection Agency. Also attention is given to the regulatory, political and ethical aspects, including concepts for a revised EIS process.



1. Why is the Radiation from the Tailings so Hazardous?

1.1. Health effects of tailings radiation

The most commonly known health effect due to tailings radiation is lung cancer. It is triggered by the inhalation of airborne tailings isotopes, one of them gaseous, the others in fine particles. This is initially the main pathway of the radiation hazard.

Later, when the radioactive contamination has spread from the tailings deposit into the water and soil of the region, ingestion of tailings material becomes an additional pathway of contamination. At this stage, the health effects will include birth defects, still births, leukemia, gastro-intestinal cancers (and many other cancers), Downs Syndrome, premature aging and heightened susceptibility to diseases.

Where the mining operations are very messy, such adverse health effects can already appear during mining, even though on a smaller scale.


1.2. The millionfold increase of the radiation hazard from the tailings

The mining waste (the tailings) is in composition and quantity hardly any different from the original ore. Usually, the extracted uranium makes up less than 1% of the original ore, leaving more than 99% of the ore's bulk in the tailings. Also, the radiation removed from the ore as a consequence of the extraction of the uranium is less than 20%. This leaves more than 80% of the ore’s original radiation in the tailings. A relatively small quantity of process chemicals has been added. How does it come then that the radiation hazard from the tailings is many million times larger than that from the original ore? A decrease of the radiation by 20% seems to contradict a millionfold increase in the radiation hazard from the tailings.

The only major difference between ore and tailings is the very fine consistency of the tailings, which is a result of the fine milling of the ore to allow the uranium extraction. This indeed is the main reason for the vastly increased radiation hazard. The fine milling of the ore

The following sections will give a more detailed description of the effects of the fine milling:


1.2.1. Alpha radiation and fine milling

The main radiation hazard from the tailings comes from the powerful alpha radiation. Unlike beta and gamma radiation, it cannot penetrate the skin due to the large size of the emitted particle (the ‘ray’). It is only when the alpha radiating material is inhaled or ingested that it becomes dangerously bio-effective, many times more than beta or gamma radiation.

Therefore, when alpha radiating rocks are milled into small particles that can become airborne and inhaled or can be assimilated by plants and enter the food chain, a completely new situation arises: the alpha radiation from the finely milled ore becomes many million times more detrimental to human health than the alpha radiation from the original uranium ore sitting in the ground. The inhalation of only 1½ grams of Roxby Downs tailings dust or 0.4 grams of Ranger tailings dust per year exceeds the allowable dose limit (see calculations in App. A1 and A2).


1.2.2. Fine milling as it affects tailings erosion, dispersion and accumulation in the biosphere

The second most important consequence of the fine milling is the susceptibility of the tailings to erosion and dispersion. Erosion and dispersion are the main mechanisms bringing the tailings into the biosphere -- the very location where they should never be.

To demonstrate the effects, the Olympic Dam tailings dams may serve as example. This tailings deposit will be some 12 square kilometres in size and some 30 metres high (the height of a 10-storey building). To prevent tailings erosion the tailings deposit will eventually be covered with 1½ metres of clay and rocks. This is supposed to fulfil the regulatory requirement of a life expectancy of 1000 years for tailings repositories. However, when a few years after mine closure the active management of the tailings dams ceases, this cover will be breached within less than a hundred years. (see chapter 2 for more details) A single breach in the cover is enough to get the tailings erosion started, which in turn will lead to the collapse of the remaining cover and to full scale tailings erosion.

OECD(1984, p.41) assumes a tailings erosion by water of 10 mm per year from the tailings surface. Obviously this depends on the precipitation rate and pattern, which is impossible to predict for the future. The pending Greenhouse Effect may well bring increased rainfalls. Using an erosion rate of only 1mm per year, the huge Olympic Dam tailings piles would be eroded within 3000 years.

In OECD(1984, p.40) the wind erosion is assumed to remove initially 0.5 mm and later on 0.25mm to 0.1 mm per year from the tailings surface.

Taking again the Olympic Dam tailings dams at Roxby Downs as an example, the tailings would be more or less completely eroded within 120,000 to 200,000 years -- by wind erosion alone. Each year some 8,000 to 40,000 cubic metres of tailings will be blown off the Olympic Dam deposit. Each cubic metre of tailings contains some 1.75 million grams of tailings particles. Theoretically, if these tailings were all to be inhaled equally, between 10 and 50 billion adults could be lifted above the inhalation dose limit -- from the tailings blown off the dam in a single year. This erosion continues year after year. These figures would only slowly decrease as the radioactivity diminishes: after 80,000 years to 50%, after 200,000 years to 35%.

While the water erosion spreads the tailings material over the area surrounding the tailings dams and onto flood plains, the dispersion by wind will contaminate the whole of Australia. The sizes of the tailings particles range between those of fine sand and talcum powder. Such fine particles easily become airborne: according to NUREG-0706 (1980) "particles smaller than 100 micrometres may have a velocity of fall lower than the upward velocity of the turbulent wind. Such particles are carried through the atmosphere for long periods and to great distances from their original location."

The particle sizes of the tailings material fit very well into this category: according to the WIN-112(1960) "80% of the radioactivity of acid-leach tailings is associated with particles less than 38 micrometres in size". Consequently, the radioactive tailings particles are nearly all of a size suitable for dispersion over great distances. This may be illustrated by the well-known fact that the wind can carry the red Sahara sand in considerable quantities over a distance of more than 2000 km to central European cities.

These tailings will not just disappear once they have been blown off the tailings surface. A large proportion will accumulate in the biosphere. They can be picked up by the wind many times. And each time a tailings particle is moved around by the wind, it is subject to potential inhalation by a human or any other breathing being. Consider the proximity of major population centres (Sydney 1300 km, Melbourne 1100 km and Adelaide 500 km). When these tailings particles eventually finish their air journey and find a resting place either somewhere in the topsoil or in the sea, their new destructive work place will be the food chain (see section 3.3.2). The small size of the tailings particles greatly facilitates the leaching of various tailings isotopes, in particular uranium-238, uranium-234, thorium-230 and radium-226. The leached isotopes are then taken up by plants thereby entering the food chain.

Once the soil cover on the Olympic Dam deposit is eroded (sometime within the next 1000 years, but more likely within a hundred years), all Australians are bound to carry some Olympic Dam tailings particles in their bodies. Additionally, every Australian will then carry Olympic Dam radioisotopes due to the emanation of gaseous radon from the tailings (see section 1.2.3). Even though statistically quite a few particles are needed to trigger cancer, a single particle can achieve this.

Coming back to the wind erosion of the Olympic Dam, the speed of this erosion will actually be greatly increased by the combined effect of wind and water erosion. Floods will spread the tailings over large areas depositing them in successive thin layers on everything inundated. These very fine layers on the ground, on the grass, on the bark and leaves of trees, on sealed and dirt roads, on crops etc. can easily become airborne or enter the food chain. The Roxby Downs area does occasionally experience such heavy downpours (1 in 200 year storm: 210 mm) and floods (several over the last 20 years). The very long time spans involved will certainly bring a variety of climatic conditions with dramatic consequences.

Considering all these aspects, we estimate that the tailings dam will be more or less completely eroded within 1,000 to 30,000 years.


1.2.3. Emanation of the radioactive gas radon

The third consequence of the fine milling is a vastly increased release of the radioactive gas radon. This gas is continually being produced in the tailings. A short explanation of the uranium decay chain will clarify this:

As uranium-238 decays it forms a daughter isotope, thorium-234, which in turn decays into another radioactive isotope etc. There are 14 decay stages and consequently there are 14 radioactive isotopes in the uranium ore. While four of these decay stages are to some extent removed with the uranium extraction, ten of those decay stages occur in the tailings. Six of those ten transformations in the tailings are alpha decays.

The most dangerous of these radioactive decay products is the gaseous radon-222. It is continually produced as the decay product of radium-226. When radon-222 itself decays (half life: 3.8 days), its own decay product (polonium-218) will usually decay within minutes and so will the following three isotopes. This effectively means that somebody inhaling a decaying radon atom will not only receive the radiation from its decay but probably also the radiation from its decay products. Radon is responsible for most of the cancer deaths attributable to the tailings.

The release of radon gas into the atmosphere is greatly hindered by any material or water covering the uranium ore or the tailings. The radon release from all the uranium deposits currently being mined or proposed to be mined in Australia is minute – as long it stays in its natural location deep in the ground. The covering sands, rocks and clays reduce the release rate many trillion times. Just the mining of the ore will increase the radon release into the atmosphere many billions of times. The fine milling will further increase the radon release rate, especially when considering the consequent erosion and dispersion of the tailings over a large area.

After the mining and milling, even the back filling of the tailings into the ore’s original location can not remedy the new situation: the finely milled particles have lost the geological stability of the original uranium ore. They are subject to erosion, subsidence, suspension in groundwater, oxidisation, leaching and even human interference (see next section).

The claim of the mining industry that they reduce the radioactive hazard in the mining area because they remove the uranium is absurd. In fact, they increase the radiation hazard many million times.


1.2.4. Fine milling and future human interference with the tailings

In the past, uranium tailings have been abused on a large scale: in the US the tailings have been used for landfill and concrete admix, even for garden beds. Thousands of houses have been contaminated. This happened at a time and in a country where all the knowledge, the scientists and the technicians with their instruments were at hand.

In the distant future the tailings hazard will be a little understood legend -- or completely forgotten. Tailings will again be an attractive material for the above-mentioned purposes or for completely different ones we can not even imagine like the sale of cobalt-60 for its magic properties (in 1983 an ignorant Mexican scrap dealer sold cobalt-60 to a thousand even more ignorant customers for its magic properties).

The tailings will be an easily available and homogenous source of very fine rock particles. Their use for building materials brings the radiation hazard, and in particular the radon emanation directly into the places where people live and work. The probability of such events may seem very low (maybe a couple of percentage points over a hundred-year period), however, because of the long time spans involved, this very low probability turns into a near-certainty.


1.2.5. Fine milling and oxidation

The finely milled tailings provide a many thousand times larger surface area than the original ore. This facilitates oxidation and substantial leaching of radioisotopes, which are then easily assimilated by plants and animals. The wetland filtration proposals of the mining industry (ERA, 1995 and Jones, 1996) have vividly demonstrated this: most of the uranium in water is being taken up by the flora of the wetland.

Especially under acidic conditions, the oxidation causes severe water contamination. The uranium tailings are usually disposed of in a highly acidic form due to the process chemicals. Also, many of the tailings are derived from acid-forming ores, which further aggravates the problems. Any buffering with lime is usually insufficient or only temporarily successful.

After the erosion of the tailings the negative effects of the oxidation are even more prominent due to the increased exposure of the material to the atmosphere.


1.3. The very long-term hazard of the tailings

The main problem with the tailings is their very long-term radioactivity (see Fig.3). This problem is further aggravated by the residual uranium in the tailings. Usually, 95% to 99% of the uranium is being extracted leaving 1% to 5% of the uranium in the tailings. Without residual uranium, the tai-lings radiation would be a severe health hazard for some 500,000 to 1 million years depending on the ore grade. Due to the residual uranium this tailings hazard will persist for some 20 billion years. For Ranger, the residual uranium in the tailings is not 1% to 5% of the original uranium content of the ore, but rather an excessive 10%, and for Olympic Dam an extreme 23%.

The radioactivity of the Olympic Dam tailings is:

After 1,000 years 99% (99%) of the original tailings activity*

after 10,000 years 93% (91.4%)

after 100,000 years 57% (40%)

after 1 million years 28% (0.01%)

after 1 billion years 22% (0%)

after 10 billion years 6% (0%)

'original tailings activity' refers to the tailings' radioactivity 6 months after the uranium extraction.

The values in brackets exclude the effect of the residual uranium content in the Olympic Dam tailings.

Over 500,000 years, some 60% of the tailings radiation is being caused by the effects of the residual uranium content of the tailings (see Fig.3), over 10 million years this contribution is 95%. For Ranger tailings, the residual uranium content would directly and indirectly contribute over 500,000 years about a third of the total radioactivity (over 10 million years some 85%).

Despite the decreasing radioactivity of the tailings (Fig.3), their detrimental effect (Fig.1) actually increases during the first 150,000 years as the tailings spread out and become more and more accessible to the biosphere:

The average death toll per year due to the ‘Olympic Dam’ tailings (Fig.1) could be somewhere around

30 deaths per year during the mine’s operation (design includes partly dry tailings beaches)

5 deaths per year after rehabilitation until tailings erosion starts (perhaps from year 2040 - 2300)

100 deaths per year while erosion of the tailings deposit is the main aspect (perhaps till year 50,000)

450 deaths per year while dispersion of the tailings is the main aspect (perhaps till year 220,000)

220 deaths per year while the residual uranium content becomes the main aspect (till year 500,000)

100 deaths per year while the residual uranium content is the main aspect (till year 1 billion)

10 deaths per year while the radioactivity gradually diminishes (till year 20 billion)

These annual figures add up to about 130 million deaths over the next 500,000 years (see section 3.5). Obviously these figures are rough estimates. However, they give some idea of how the various stages are proportioned to each other. The graph on the cover sheet illustrates this further. It becomes obvious that the quality of the mine’s operational management, the stability of the tailings dam and the rehabilitation are of little significance for the long-term effects and for the total death toll, even though they are so important for the short and medium-term effects. The vertical dashed line in Fig.1 (front-page) shows how far our willingness to accept responsibility reaches.

There is no safe containment for such time spans, not even if buried a few hundred metres under the ground (see section 2.5).

Also, the extremely long time spans involved will bring a variety of climatic conditions to the mining area. This can change the remoteness of the area considerably, especially with the Greenhouse Effect. Arid land can turn into agricultural land, the remote mine site can turn into a residential area.


1.4. Lost knowledge

The knowledge and understanding of the situation will certainly be lost within a few thousand years if not much earlier. Then it can be expected that humans not only work, grow food and live near the tailings deposits, but also do all these right on top of the tailings.

Already today, the information is not passed on, not even to those most affected, but rather encrypted into some scientific reports. Consequently, children have been playing and swimming in tailings dams at Port Pirie in South Australia for years. The government had to be forced by repeated public pressure to erect fences and to cover the tailings. There is still no ongoing health observation for those exposed.

As mentioned before, in the US tailings have been used for land fill, concrete admix and even in garden beds.

In an example from Bulgaria, the tailings radioactivity got into the food chain: A farmer grew wheat on contaminated soil near a uranium mill. Regular consumption would have lifted the dose 74 times above the legal limit (see section 3.3.2 for details).

This future loss of understanding of the situation will be inevitably combined with a lack of perception for the dangers. Alpha radiating dust either inhaled with fresh air or ingested via the food chain will have no immediate effects. The most common consequence, cancer, becomes apparent only after some 20 years. Other effects like genetic damage and slightly increased aging are even more subtle.


1.5. Tailings versus toxic chemical waste

Without wanting to defend the currently irresponsible production and disposal of toxic chemical wastes, there are big differences between radioactive tailings and toxic chemicals:

The volume: the enormous quantities of tailings from our uranium mines, Roxby and Ranger, could well exceed all the toxic chemical waste from the two industrial centres Sydney and Melbourne.

Most of the toxic chemicals are toxic due to their strong need to react with other substances and to recombine to form other compounds, which are less toxic, if at all. A responsible waste management would actually trigger those processes before disposal, where avoiding or recycling are not possible. Over a comparatively short time span most of the toxic chemicals will recombine to more stable and less toxic substances.

In contrast, the radioactivity of an isotope will not be affected by a change of its chemical nature – nor will the incineration of radioactive waste reduce the radioactivity. Even reprocessing of nuclear waste will actually leave considerable more radioactive waste than there was in the first place. Only the extremely slow decay – determined by the half-life of the parent isotope - will reduce the radioactivity. For the first 200,000 to 800,000 years thorium-230 (half life: 77,000 years) is the main parent isotope. Because of the residual uranium in tailings, uranium-238 will eventually become the parent isotope. The half-life of uranium-238 is 4.5 billion years.


1.6. Tailings versus in-situ leach mining

In-situ leach mining is often proposed as an alternative uranium mining method without tailings and their long-term consequences. During in-situ leach mining the uranium is being leached out of the ore in its natural location in the ground. At Beverley, S.A., millions of litres of acid are to be pumped underground via a row of bores while several surrounding bores are meant to recover the acid together with the dissolved uranium. The main contaminant is now un-recovered uranium leachate.

There are several problems with this method:

Aquifers become the dump sites for radioactive waste.

Uranium-238 becomes the main parent isotope and main contaminant of the waste right from the start of the operation. The half life of uranium-238 is some 60,000 times longer than that of thorium-230, the main parent isotope in tailings. This dissolved uranium will escape retrieval in large quantities, and contaminate ground water and the ground for infinity (billions of years). Dissolved uranium is even more dangerous than finely milled uranium.

The contamination of the ground water is usually justified with the ground water being too salty for human consumption. The high salt content of the ground water is a direct consequence of the low rainfalls in those areas. However, rainfall patterns do change – and have changed in the past. Over the extremely long time spans involved many and extreme climatic variations are certain. During times of high rainfall the ground water comes to the surface via springs and seepage, allowing the uranium to enter the biosphere.

At times of increased rainfall localised aquifers often link up to large aquifer systems like the Great Artesian Basin. This will contaminate the ground water of huge areas forever.

Even during today’s ‘low rainfall / high salt ground water’ period, the contaminated water may be brought up to the surface. The water is with or without prior salt reduction useable for many purposes. Once the uranium has come to the surface it will contaminate the biosphere with its radioactivity, its very high chemical toxicity, and with its radioactive decay products. From the contaminated areas large quantities of the radioactive gas radon will emanate spreading the contamination over thousands of kilometres.

It is not possible to exactly state whether in-situ leach mining will have worse consequences than the traditional uranium mining with tailings, especially in those cases where the residual uranium content of the tailings is less than 1%. However, this comes down to the consideration whether it is more acceptable to have somebody die in the future for 50 cents or for a dollar of profit to be made today.


1.7. Greenhouse Emissions Versus Nuclear Energy

Frequently, nuclear energy production is praised as being free of Greenhouse emissions. Summit Resources, Paladin Resources, Southern Cross Resources and Uranium Australia all claim zero Greenhouse gas emissions for nuclear energy. Nuclear energy is therefore claimed to be environment friendly. Nothing is further from the truth for the following reasons:

  1. As outlined in this paper, radioactive uranium tailings are being produced in enormous amounts without a solution for their long-term storage. It is not ethical – apart from not being possible – to combat our environmental problems from Greenhouse emissions with a nuclear ‘solution’ which will be borne by our future generations with disease, genetic damage and billionfold death from radiation cancer.
  2. In an article by Nigel Mortimer ‘Global warming and the nuclear power debate’ it is further described that there are not enough viable uranium deposits to make a switch to nuclear power, far from sustaining such a switch. As the uranium resources become more marginal, more energy is needed for the uranium extraction, reaching a cut-off point within a few years.
  3. The economic cut-off point, making nuclear energy unviable, is obviously reached much earlier. The cost of nuclear energy would be already today much higher than the cost of renewable energy if the long-term costs of radioactive waste storage were considered.
  4. There are considerable Greenhouse emissions from the nuclear fuel cycle during it’s stages of:

The Greenhouse emissions from the nuclear fuel cycle have been recognised many years ago, before Chernobyl, and before the tailings problem was fully recognised. As long the Greenhouse emissions due to the ongoing task of tailings stabilisation were not factored in, the emissions from the nuclear fuel cycle appeared to be rather low. This approach is no longer acceptable.

  1. A study by Bill Keepin and Gregory Kats (1988) – without considering the Greenhouse emissions due to the ongoing task of tailings stabilisation and due to emergency measures and ongoing clean-up after Chernobyl-type accidents – came to the conclusion
  1. Before, the Greenhouse emissions as a indirect consequence of Chernobyl-type accidents were mentioned. The human cost of such accidents is an even more severe consequence. As we know from the Hiroshima statistics, the radiation cancer fatalities in areas with low-level contamination will not be known for some twenty to forty years due to the slow progression of this disease. Most of the Chernobyl victims are of this category. The more credible estimates of the Chernobyl death toll range from 250,000 to 1,000,000. Many of the Chernobyl fatalities will never be known because of the way the clean up operation was conducted, for example the near total lack of information about the identity of the more than 200,000 emergency workers from all over the USSR who received the highest doses. Can we resolve our environmental problems at the expense of the lives of others? There have been several near-meltdowns at other reactors.
  2. Nuclear reactors were originally designed to produce the material for nuclear weapons. While this motive has largely vanished from the public perception, the eager attempt by third world countries -- including some dictatorships – to acquire nuclear power plants, can only be seen in this light. Nuclear power includes the risk of nuclear war.

The very reason for the Greenhouse convention is the protection of human life and health. How could a technology involving the death of billions of human lives be praised as a solution?



2. Tailings Storage

2.1. The quantities

Currently there are some 50 million tonnes of uranium tailings stored in Australia. Another 620 million tonnes are foreshadowed from currently approved operations (Ranger, Olympic Dam and Jabiluka). This is a total of 670 million tonnes equivalent to some 390 million cubic metres. Theoretically, these tailings could cover some 390 square kilometres one metre high or the whole of Victoria 1.7 mm high.

The danger from these tailings is proportional to the uranium content of the original ore. Also, the quality of the tailings storage and the residual uranium content of the tailings need to be considered.

In section 1.3 it was concluded that there is no safe storage for the tailings due to the enormous time spans involved. Similarly, there is no safe storage for such vast quantities, not even for much shorter time spans. However, the combination of the enormous time spans and the vast quantities makes it obvious that there is no safe storage for the tailings.

Accordingly, I could not find a scientific study of storage options for tailings reaching beyond 10,000 years.

Conveniently, our radiation research bodies ignore the distant future and describe such modelling as unscientific (OSS, 1997) or as "not technically supportable" (OECD,1984, p.90). However, the remaining tailings radiation after 10,000 years is 91.4 % -- a scientific fact!


2.2. Tailings storage in tailings dams

Tailings dams are the most common means of tailings storage. In Australia, the Olympic Dam tailings are to be stored in several tailings dams covering an area of some 12 square kilometres. These dams will eventually be 30 m high, which gives them a net capacity of some 310 million cubic metres plus space for cover and freeboard. These tailings dams may well be of Olympic dimensions regarding their size, their bad design and the consequences for the lives of potentially billions of future humans.

According to O.D.ExpEIS (p. 8-18) the retaining embankment will be initially constructed to a height of 4 - 5 m. Thereafter, the embankment will be raised in several increments to a total height of up to 30 m. This mode of construction can be seen in Fig. 8.5 (O.D.ExpEIS). This means that 20% of each tailings wall increment will sit on the previous wall increment while some 80% will sit on top of the tailings themselves. These tailings are like fine sand and powder and lack inherent strength. Over time, the tailings wall increments will simply sink into the tailings material. The same will happen to the 1½ m cover of swale material, sand and rock on top of the tailings deposit. A single breach in the tailings wall would lead to large-scale erosion of the very fine tailings material within a very short time. This could mean the end for the Olympic Dam tailings dam within a hundred years of its completion!

If the described deterioration and collapse of the dam’s wall and cover does not happen fast enough, then erosion will achieve all this on its own: the outer faces of the 20 kilometres of tailings walls will have a slope of 20 (a 90 m down-slope). They are covered with a 1m clay liner and "would be sheeted with 500 mm of rock armouring to provide erosion protection". Unfortunately, stormwater does not jump from rock to rock as it runs down the 90-metre wall faces. This would require something like roof tiles.

The 1m clay liner to be installed underneath the rocks would be cracked and broken in many places due to

Again, a single breach in the many kilometres of dam wall will get the large-scale erosion started. While the O.D.ExpEIS (chapter 8.7.1) presents hardly any rainfall data, an average annual rainfall of some 200 mm and a maximum rainfall event of some 250 mm (12 hour and 72 hour -- 500 year average return) are specified. These figures are certainly sufficient for the dam’s erosion. The previous O.D.EIS includes more detailed rain data and in particular a 582mm annual rainfall in 1974 and a PMP (probable maximum precipitation) of 800 mm for a 72 hour storm. Locals are telling me that there were several floods in recent years. Some 2 years ago, Lake Torrens has been filled from local rain, for the first time in white Australian history.

In the case of such higher rainfalls a third mode of disintegration of the dam walls might be the fastest performer: now the tailings dam acts at times like a lake. The walls however are not constructed to retain water within the dam. The water pressure will force the water through the tailings wall until it is stopped by the outer layer of clay. From there on it will run down to the wall base and escape from the dam wall at the transition between the outer clay liner and the ground. Obviously, this will lead to erosion of the dam wall underneath the clay liner and to erosion at the base of the clay liner. As a consequence weak spots of the clay liner will collapse and start the erosion of the dam wall.

There are further problems due to the different behaviour of rocks and clay in changing wet and dry conditions: Contrary to the rocks, the clay expands and contracts and even cracks. This will have the rocks gradually sink into the clay, defeating their purpose.

The alternative tailings storage system using the 'Central Thickened Discharge' method as outlined in chapter 8.6 of the O.D.ExpEIS would not improve the environmental performance, rather it would speed up the eventual erosion of the tailings. Essentially, both systems propose to dispose of the tailings in a pile and to cover the pile with a layer of clay and rocks.

The Senate Committee on Uranium Mining and Milling (SSCUMM) sets its hopes on past and future improvements in tailings management. Let’s have a look: 20 years ago the tailings had to be covered all the time with at least 2 metres of water to reduce the escape of the radioactive radon gas from the tailings dam and the wind erosion of tailings particles. When that proved a nuisance for Ranger it was decided that the moist tailings retain the radon several times better than properly soaked tailings and therefore a water cover was not any longer required. This completely ignored that the moist tailings consistency reduces the radon escape perhaps 10 times while a 2-metre water cover reduces radon escape about 2500 times! Too, the tailings dam surface will largely dehydrate at times thereby allowing the release of very large amounts of radon and tailings dust.

Currently, we reach a new stage in those ‘improvements’ hailed by SSCUMM -- on our way to a Third World country: the tailings can now be worked and messed around with in a large scale:

There appears to be only one reason for all this: do it cheaper -- make more money! It seems the principles of ‘Best Practice Technology’ (BPT) and ‘As Low As Reasonably Achievable’ (ALARA) have been abandoned long time ago, perhaps out of the recognition that safe uranium mining is impossible anyway.


2.3. Leakage into groundwater

Tailings are soaked with a highly acidic liquor enriched with radioisotopes, considerable quantities of highly toxic process chemicals and leached heavy metals. At Olympic Dam, this liquor has been leaking in enormous quantities into the ground water. This happened despite the 'scientifically tested' claims about the carbonates reacting with any leaking tailings liquor to form gypsum which would then "create a seal limiting further advance of the wetting front" (s.O.D.-EIS, p.18).

The ‘wetting’ is obviously a ‘pouring’ as the South Australian Health Commission notes: "Based on these results, the amount lost might be of the order of 1 Gigalitre" (RDWL, 1996, p.89). This tailings liquor has a concentration of 1550 Bq/l for uranium 238, and 4833 Bq/l for thorium 230 (RDWL, 1996, p.98), a potent radioactive mix.

Despite remedial action there appear to be two ongoing leaks in the tailings storage facility, one of them actually increasing (see Fig. 4.21, O.D.ExpEIS).

The finely milled uranium-238, thorium-230 and radium-226 are all water soluble in the acidic tailings environment. These contaminants will be leached out of the tailings and enter the ground water and eventually the surface water via springs and seepage. Due to the currently dry climate the groundwater might not have enough pressure to move around and form springs. However, the very long time spans involved will certainly bring a variety of climatic conditions (eg. the Greenhouse Effect) which can be expected to change this dramatically. This climatic change might already be on its way: recently nearby Lake Torrens was filled up by local rain, first time in white Australian history.


2.4. Structural life expectancy

The most optimistic estimate for the structural life expectancy of a tailings dam I have ever heard of, was 10,000 years. However, even then the tailings retain 91.4% of their radioactivity.

The Australian regulations require a design life for a tailings dam of 200 years and a structural performance for 1000 years. After 1000 years the remaining tailings activity is 99%.

The Olympic tailings dam, due to its incremental wall structure (see section 2.2) will have difficulty to survive a hundred years.

Not surprisingly, the Olympic Dam draft EIS (1983) and the Olympic Dam Expansion Project EIS (1997) do not even mention the extremely long time spans involved nor discuss the performance of the dam for this duration.

Considering the enormous quantities and time spans there is no safe storage for uranium tailings.


2.5. Comparison of storage options

The radioactivity of the tailings is directly proportional to the quantity of yellowcake produced. The residual uranium content contributes an additional radioactivity component which steadily increases over the first 500,000 years and then remains nearly constant for billions of years. To which extent the tailings radiation becomes harmful to future humans depends mainly on the capability of the storage facility to prevent the escape of the tailings material into the biosphere. However, there is no storage option, which could achieve this sufficiently for the time spans required.

The storage options are:

Dumping the waste material next to the mine: this is the historic and, more recently, the Third World approach. Here the tailings material is exposed to erosion by water and wind right from day one. Phase 3 of the graph in Fig.1 starts from the beginning of the mine operation, the dashed line of refusal to accept responsibility moves right to the beginning of the time scale. The environmental and health effects become already measurable during the mine’s operation.

Storage in a tailings dam: this option is seemingly much cleaner and better controlled than the simple dumping of the waste. The first two phases in the graph are being added. They bring an improvement of the environmental and health situation for the first few hundred years. After this the death toll rises steeply – for hundreds of thousands of years. If this improvement would not actually save perhaps a thousand human lives, one could be forgiven to say that it is purely cosmetic and totally insignificant in the face of the long-term death toll. The tailings dams at Olympic Dam have been repeatedly detailed in the previous chapters. While it is possible to design much better tailings dams than this structure, the improvements will have only a very temporary effect. Compared with the previous option (the plain dumping of the tailings), the storage in a tailings dam might reduce the death toll by about 0.01 to 0.5%.

Storage in open mine pit: this storage option prevents a large proportion of the tailings from entering the biosphere and therefore significantly reduces the long-term death toll from the tailings. There are many parameters making a big difference in the performance of this option:

The death toll with this storage option could be very significantly reduced, maybe by 65 - 95 %. Nevertheless, for mines like Ranger the estimated death toll with this storage option would be still many millions. This can be illustrated by presenting some of the specific problems associated with the Ranger mine pits which are being used for tailings storage:

Not surprisingly, ERA has not provided any details on how to deal with those obvious issues. Despite many public concerns about the lack of consideration of the long-term aspects of the tailings storage - and even a government request (see JabDraftEIS-Suppl. B-23 ‘Tailings at Ranger’) - the final Jabiluka EIS has not addressed the issues nor named the time-spans of concern. Obviously, there are no solutions.

Storage in old or specifically built mine shafts: this is the safest storage option. Compared with the open mine pit it provides greater depth and better ways of sealing the deposit off. The death toll would be reduced by perhaps 90 - 99%. The only remaining transport mechanism for the transfer of tailings particles into the biosphere are the aqueous transport and human interference. This storage option still involves the death of many thousands if not millions of future humans and is therefore not a suitable storage proposal for any further mining. However, it seems to be the best option available for dealing with the tailings that already exist at various dumps, in tailings dams and in mine pits.

Synroc and similar technologies: Synroc is very well known and therefore often thought to be a good storage refinement for underground storage of tailings. However, Synroc is only adequate for small quantities (kilos rather than millions of tons). The only related storage technology for low-level high volume waste is the addition of cement to the tailings and the mixing of the tailings into concrete. However the required long-term success for hundreds of thousands of years is a thousandfold beyond the reach of concrete.



3. Estimates of Radiation Exposures and Death Toll

This chapter investigates the radiation exposure and the consequent future death toll on the example of the Olympic Dam mine at Roxby Downs.

If you don’t like numbers and details you may want to skip this chapter and continue with chapter 4


3.1. The combined dose limit

The dose limit for a member of the public continually exposed to radiation is 1mSv (milliSievert) per year.

[The radioactive dose received by a person is measured in milliSievert. This unit considers the bio-effectiveness of the radiation received.]

Where the person is exposed to different types and pathways of radiation, this dose limit applies to the sum of all components of ‘man-made’ radiation. The radiation from uranium tailings has at least five such components which are listed in the following sections. In a first step the permissible and/or likely exposure from each component will be estimated, as if the other four components were non-existent (section 3.3). Then the combined exposure from all pathways / aspects is calculated (section 3.4).


3.2. The ‘critical group’

The following investigation of the various components will in particular investigate their dose contribution for the ‘critical group’. The ‘critical group’ is the group of people most exposed to the radiation (see ICRP 42, p. 16). The members of the ‘critical group’ have a risk factor or exposure aspect in common.

In the case of uranium tailings the members of the critical group are those living right on top of the spread out tailings deposit. They comprise future rural settlements of people who live from the produce they grow and drink the local ground water.

The radiation exposure of the ‘critical group’ determines the necessary limitations to a project to make it comply with the standard or whether it can go ahead at all.

By definition the size of the ‘critical group’ will be "up to a few tens of persons". If only a couple of people were to be the most exposed then they would not be considered a ‘critical group’ and therefore not necessarily require an end or modification to a project. A larger group of people with a common risk factor would have to be selected.

In contrast, if a group of a hundred people were to be the most exposed, this would not constitute a ‘critical group’ and a smaller subgroup with higher exposures has to be selected.

In our case we selected the group of people living right on top of the tailings which by then have been spread out by erosion. Their lifestyle and activities, according to the definitions of the ‘critical group’, inflict a high dose on them. They are assumed to work directly with the tailings such as digging them for land fill, building material or whatever other use may be found in the future, and to live and sleep in a building which tends to accumulate the radon emanating from the ground, which consists mainly of exposed or eroded tailings.


3.3. The Contribution of the Various Aspects and Pathways of Radiation

3.3.1. Alpha Radiation - Inhalation of Tailings Particles

The maximum permissible quantity of inhaled tailings from Olympic Dam has been specified as 1.4 grams per year (see Appendix 2). This is just from one source, as if the other pathways would not contribute any further radiation. Therefore the permissible dose is in fact considerably lower (see section 3.6 for distribution models).

In section 1.2.2 the capability of the tailings to become airborne for long times has been shown, as well as the actual mechanics and quantities of the wind erosion. We conclude that the inhalation of tailings dust by the ‘critical group’ will be between 30 and 150 grams per year (average 60 grams). For the concentration of the Olympic Dam tailings this results in an annual dose contribution of about 40 mSv.


3.3.2. Alpha Radiation - Ingestion of Tailings Particles

After a few hundred years, it can be expected that humans not only work, grow food and live near the tailings deposits, but also do all these right on top of the tailings. Consequently, the ingestion of contaminated food will be a huge problem. Some examples may illustrate this:

At the uranium mill of Bukhovo in Bulgaria the fences around a contaminated area deteriorated and the area was in part reused for agriculture just 30 years after the mining (Dimtchev 1991, p.66-74) and (Vapirev 1991). Radium concentrations of up to 1077 Bq/kg were found in cereals grown in these areas.

[The number of radioactive decays per second for a given material is measured in Becquerels (Bq).]

Regular consumption (1kg per week) of such a cereal would result in an annual dose of 74mSv, while the admissible dose is 1mSv. Were these cereals grown there some 250,000 years later, the annual dose to the consumer would be still some 8 times too high.

In an example from Australia (Ranger mine) the radium-226 contamination of mussels from four different locations downstream from the mine has been investigated (McKay, 1984): On average 260 Bq/kg have been measured for radium resulting in 0.08 mSv/kg if ingested. The annual ingestion of 4 kg mussel flesh, considered to be typical, would already constitute 32% of the permissible annual dose for the public.

However, the average person in the tropical area consumes probably annually some 1000 L of water and some 500kg of food, much of which may be contaminated as well.

This indicates that in some areas near the mine and especially for those people living mainly on bush tucker, the legal dose limit for the public is already now being transgressed, while both the tailings erosion and the radon release are still under control.

After a few thousand years, when the tailings deposits have been spread over a large areas, the contamination will be many times increased. For the ‘critical group’ (Olympic Dam) we estimate an annual dose from ingestion of 25 mSv per year.


3.3.3. Inhalation of Radon Gas

The most dangerous isotope in the tailings is radon-222, dangerous because it is gaseous and carries four of the six alpha decays of the tailings.

Because of its rather short half-life, hardly any radon escapes from the uranium ore in its natural location before mining. Most likely, the rock was originally buried deep in the ground. Even the open pit mines at Ranger get the uranium ore on average some 100 m deep out of the ground. The Olympic Dam mine is an underground mine with the ore body being more than 300 m below surface. Even if this ore is only covered by sandy soil, at this depth the radon escape is reduced many trillion times (BI 1992, p.117).

In contrast, the escape of radon from the tailings will eventually be comparatively unobstructed: while initially the tailings are saturated with water and later covered with soil to reduce the radon escape, eventually they will dehydrate and become exposed by erosion. For somebody living right on top of the eventually spread out tailings, a dose of 300 mSv appears likely (see calculations in Appendix 4).

Over the very long time spans involved, the deposit in the tailings dam will certainly be spread around the Andamooka and Lake Torrens flood plains by the water and carried around by the wind to great distances. These spread out tailings offer very little resistance to the radon escape.

Uranium 238, thorium 230 and radium 226 are all water soluble, especially under the acidic conditions of the Olympic Dam tailings. They can enter the ground water and the surface water from the tailings dam as well as from any accumulations of eroded tailings. Radon, a decay product of radium and, indirectly, of thorium and uranium, continually arises from any uranium, thorium and radium contamination. Therefore, not only the tailings, but with them the emanation of radon gas is spread with contaminated water.


3.3.4. External Radiation - Gamma Radiation

The gamma dose for somebody living, working and sleeping on tailings material is about 4 mSv per year for the Olympic Dam tailings (for the calculations see appendix 1 and 3):

The source definition used in our calculation for the gamma radiating material would apply to any accumulation of tailings material of 10 mm thickness. Therefore, after a few thousand years when erosion has done its job, not just 6 square kilometres, but hundreds of square kilometres will be affected, with many people living there.

For tailings deposits of 15 centimetre thickness, as applicable to the ‘critical group’, the resulting yearly dose would be 19mSv.


3.3.5. Residual Uranium Content

When uranium is extracted from the ore, a certain percentage will always escape extraction and remain in the tailings (usually 1% - 5%). This residual uranium and its radioactive decay products will contaminate the tailings for billions of years (U-238 half-life: 4.5 billion years).

For Ranger this residual uranium amounts to close to an excessive 10% of the ore’s uranium content; for Olympic Dam the residual uranium is specified as an extreme 30% (see O.D.ExpSuppl, p.10-17), probably to be reduced to 23% with pulsed column extraction. This residual uranium will increase the alpha radiation of the tailings right from the moment of deposition by 2.2% for Ranger and by 5% for Roxby due to the two uranium isotopes U-238 and U-234, and within some 500,000 years by another 10%, and 23% respectively, of the peak value of the tailings radiation due to the quasi-permanent maintenance of the complete uranium decay chain from this pool of residual uranium (see Fig.2). The resulting additional radioactivity of 12.2% (Ranger) and 28% (Roxby) will be near permanent (after 1 billion years 10% and 24% respectively).

Like the rest of the tailings, the uranium is finely milled. Consequently, this alpha radiation is several million times more detrimental than it was in the original uranium ore (see section 1.2).

In the very long term, the residual uranium and its decay products will be the major cause of the future death toll from uranium tailings, due to the extremely long activity times involved.


3.4. The Combined Radiation Exposure

The total of all those dose contributions for the ‘critical group’ would peak at 400 mSv (384 mSv excluding the residual uranium content). Allowing for the effect of the slowly diminishing radiation combined with the accelerating erosion and dispersion (see section 1.2.2) the exposure profile for the ‘critical group’ could be some


times above the legal dose limit in

1000 years



20000 years



60000 years



100000 years



1 million years



1 billion years


equal to dose limit in about

20 billion years

While the dose to the individual future human in the ‘critical group’ reaches its peak in about 20,000 years, the actual yearly death toll (see Fig.1) reaches its peak in about 150,000 years (100,000 years) as the spreading contamination reaches more and more people.

The estimated radiation dose from the tailings requires safe storage for the tailings for billions of years.


3.5. Estimates of the future death toll

While it is not possible to calculate the future casualties from the radioactive tailings, it is possible to make estimates for various scenarios.

The US Environmental Protection Agency (US EPA) made estimates for US tailings as they were in 1983. Using those together with various future scenarios in Australia we conclude that there may be some 130 million future cancer deaths from the eventually 569 million tonnes of Olympic Dam tailings (see App. 5 for more details). This estimate applies to a time span of 500,000 years into the future, similar to the past time span of human life on our planet. Assuming human habitation of our planet for 1 billion years, the Olympic Dam tailings could cost some 100 billion lives.

Obviously these estimates come with substantial uncertainties which could increase or decrease the estimates considerably. However, we do not have the right to give the credit of the doubt to the mining companies. This is not a trial where the crime has already happened, where we have to give the credit of the doubt to the accused. This is rather an ongoing activity inflicting death and disease. The credit of the doubt has to be reserved for those potentially affected. A responsible mining company or government would therefore have to use the higher estimate of 1.4 billion future radiation cancer deaths from Roxby Downs’s tailings (see App.5 for details).


3.6. Other studies and estimates

So far the estimates have been based mainly on data of the US Environmental Protection Agency. There have been several other studies on the long-term effects of uranium mining:

The estimates of the collective dose commitment (equivalent to death toll) are similarly biased towards the industry and appear several thousand times too low. In Table 3.8 of the OECD report a collective dose commitment between 780 and 3000 man-Sievert has been claimed for the 10,000 year period, which is equivalent to a death toll of 40 to 150.

The study does not always provide sufficient detail to show where it went wrong in its estimates. However, there are a few examples where the mistake can be shown: in section 3.4.1. (paragraph 98) the radon exhalation rate from the uncovered tailings dam is assumed to be 0.4 Bq/(m2xsec). Considering the seasonal variation of the radon release this figure appears at least 40 times too low and should be at least 16 Bq/(m2xsec). Using the dose distribution shown in Figure 3.2 of the OECD report, this mistake alone would increase the collective dose by a factor of 10, i.e. 800 to 3000 deaths.

The study assumes that by the end of the 10,000 year period hardly any tailings have been eroded yet. Therefore the death toll estimate for the second 10,000 year period (Estimate(2)) has to be increased, perhaps by a factor of 10.

The tailings particles eroded in a particular 10,000 year period will not all have left the biosphere by the end of that period. Consequently there is an accumulation of radioactive tailings particles in the biosphere. This requires the estimates for the following 10,000 year periods to be further increased, perhaps according to the formula Estimate(n) = Estimate(2) x 1.2 n, until the deposit is eroded (after some 200,000 years according to the study).

These tentative changes to the report’s assumptions would result in a death toll of 2 million to 5 million people over a 200,000-year period. Considering the high content of residual uranium in the Ranger tailings the integration would have to be continued for some 20 billion years (with a different formula though) resulting in a total death toll of several billions.

Understandably, the report by the mining friendly committee is limited to 10,000 years. On page 90 of the report it is stated that "such integration [‘to and beyond 100 million years’] is not technically supportable". However, the remaining tailings radiation after the report's time limit of 10,000 years is 91.4 % -- a scientific fact!

Paragraph 61 of the 1988 report states that "over 1 million years, assuming a world population of 10 billion persons, the collective dose from the long-lived radionuclides was estimated at about 3,400 manSv/Gigawatt-year." 95% of this dose is due to uranium tailings (derived from listing in the same paragraph of the report). The production of one Gigawatt-year requires about 230 tonnes of natural uranium (see 1993 report, Annex B, Table 16). The proved and probable uranium ore reserves at Olympic Dam are estimated (30 June 1996) at 569 million tonnes with an ore grade of 0.06% (see O.D.ExpEIS, Table 3.1). This results in 314,000 tonnes of uranium oxide -- enough to produce 1480 Gigawatt-years. For the above assumptions, the collective dose from the Olympic Dam uranium tailings is therefore 4.78 million manSv (.95 x 3400 x 1480), which is equivalent to a future death toll of 239,000.

Paragraph 32 of Annex B, 1988 report, details that the radon release "as a function of time is assumed to be constant, and given the very long duration of the source, the normalized collective effective dose equivalent commitment is proportional to the duration considered reasonable for assuming the release." This statement shows that various factors increasing the radiation hazard from the tailings in the long-term (see this paper Appendix 5e) have not or not adequately been considered. Using the four correction factors outlined in App.5e, the above death toll estimate increases to 179 million. Considering the very slowly diminishing radioactivity of the tailings and the different integration periods for the estimates, the result confirms my estimates within much less than an order of magnitude.


3.7. Pathway distribution model

As described above, there are several types and pathways of radiation. The dose limit is set for the sum of those individual components. To derive a dose limit for a particular component, its share in the total dose needs to be estimated first.

The proportions of the different components vary for different exposure situations. For example, those most exposed to the tailings, the ‘critical group’, will have a high dose component from external radiation, while those living in Melbourne will be exclusively exposed to radon and the inhalation and ingestion of particles.

The estimate for the averaged distribution model is 80% radon, 12% inhaled tailings, 8% ingested tailings and 0.2% external radiation.

For the ‘critical group’ the estimate is 77% radon, 11% inhalation of tailings dust, 7% ingestion and 5% external radiation.

An example may best illustrate which effect the above dose distribution models have on the individual dose limits: In App.2 we calculated that 1.44 grams is the permissible quantity of tailings dust that can be inhaled per year. The averaged distribution model attributes 12% to inhaled tailings dust. This means the average permissible quantity to be inhaled is only 0.12 x 1.44 grams = 0.17 grams per year. This compares with the theoretically permissible quantity of 1,44 grams per year when inhalation was considered in isolation.

The additional dose due to the residual uranium and it’s radioactive decay products has to be factored in separately because of their different time correlation.



4. Economic Aspects

4.1. Cost of tailings storage

Using again Olympic Dam as an example, the cost of safeguarding the tailings deposits for 500,000 years would amount to 300 billion dollars (for future generations to bear). No consideration has been given to this in the O.D.ExpEIS.

Assuming some $80,000 per year for low-level surveillance and monitoring

+ $500,000 per year for corrective measures like earthworks and repair of fences

+ $20,000 per year for preservation of information and related training

= $600,000 x 500,000 years = 300 billion dollars

The regulations (Code of Practice on the Management of Radioactive Wastes from the Mining and Milling of Radioactive Ores, 1982) provide for the South Australian government to resume responsibility and bear costs shortly after mine closure.

For the Ranger mine these costs are estimated at 140 billion dollars.

Obviously this amount could be much higher in the case of severe flooding, earthquakes etc. However costly those future efforts, their result is bound to be limited.

Also, the effect of the residual uranium has not yet been included in those costings. When the residual uranium and it’s associated time spans are considered the cost of safeguarding the tailings will be several thousand trillion dollars in today’s values.

Yeelirrie, a WMC trial uranium mine from the 70’s, might give some illustration: during years of neglect of the site security, some uranium ore had been used to repair nearby roads and people have been swimming in a contaminated dam. We are assured that nobody drank the water. Now, WMC tries to remedy the problem with fencing and warning signs (The Age, 10 July 1997). Who will be able to read those signs in 1000 years? How long will those fences last? Obviously it is not possible to provide safe storage for hundreds of thousands of years, and even less for the required billions of years. However, the costs of safeguarding those tailings are prohibitive for much shorter time spans. Faced with the wastes from this tiny trial mine, the mining giant WMC ($6.9 billion equity), opts for signs and fences which provide very limited protection for very limited times.


4.2. Rehabilitation, reclamation, compensation and mine closure

Uranium mining may not be viable much longer: overseas, many millions of dollars are being paid out to uranium mine workers to compensate them for the health effects, mainly cancers just like our government pays currently many millions of dollars to those affected by the mining and use of asbestos.

Another indicator of the hazards involved is that insurance policies generally exclude damages due to radiation. Nor are governments very willing to accept the responsibility for their actions: Britain’s Prime Minister, Tony Blair, is refusing to award compensation to veterans of nuclear test explosions for the illness they have suffered, despite Labour’s support for their cause while in opposition.

A new study, ’Chromosomal aberrations with Namibian Uranium Mine Workers’ (Zaire, 1995), indicates the extent of the genetic damage caused by radiation exposure (the highest dose of those workers was only 5 mSv which compares with 20 mSv and 50 mSv permitted in Australia) far beyond the known increase in birth defects and still births. Much of this genetic damage will be passed on from generation to generation to leave a permanent mark on humanity. However, the study may indicate some new avenues to prove health damages from radiation exposure. This might be an incentive for the government and the uranium industry to adequately care for those to be exposed to radiation from the tailings, including those to be exposed after the mine’s operation.

The decommissioning and clean-up costs for uranium producing projects in Australia is currently estimated to be some 70 cents per pound of uranium produced. However, a different approach is shaping up with Sweden spending some $AUS 50 per pound of uranium (Diehl, 1996, p.2).

The increasing public awareness of the tragic long-term consequences of uranium mining may at any moment lead to the closure of Olympic Dam and Ranger. The enormous costs of expanding the facilities appear to be an outrageous gamble with shareholder’s money. Those shareholders would largely not be aware of the problems. The responsibility lies foremost with board and management of the company. It can’t be expected that the public will again accept arrangements similar to those for the asbestos mining companies. As Peter Jelinek-Fink, scientific secretary of this year’s conference of the International Atomic Energy Agency said: "We are only one accident away from being dead." Do not misunderstand, he is not concerned about human life or his life but the nuclear industry’s life.



5. Regulatory, Political and Ethical Aspects

5.1. The international regulatory body (ICRP)

The ‘International Commission on Radiological Protection’(ICRP) is widely accepted as the authoritative body to analyse the available data on the health effects of radiation and then to issue non-binding regulations. These regulations are then expected to become incorporated into the laws and regulations of the various nations.

Originally, the ICRP was actually attached to a medical congress, and the members of the commission were mainly radiologists and medical scientists. For these reasons and probably because of its innocent name, the ICRP is still today credited with a great deal of trust into their motives.

During the Second World War the ICRP meetings ceased. After the war, a certain Lauritzen Taylor, former member of the Manhattan Project (development of the first nuclear bomb) initiated the ICRP anew according to his liking: the ICRP members were to be chosen by its own members who were originally largely chosen by him. Accordingly ICRP members are usually close to the mining industry or other factions of the nuclear establishment. The ICRP is undemocratic, unrepresentative and has no legitimacy whatsoever. The professions represented in the ICRP are rather related to industry than to human health which they are supposed protect. The relevant fields of epidemiology, genetics and pathology are under-represented. The biologist R. Blackith from Dublin points out that scientists criticising the ICRP activities are outcast from the ranks of serious scientists. To differ from the majority opinion is seen as proof of scientific incompetence.

The Report from the Session of the Permanent People’s Tribunal on Chernobyl writes about ICRP, IAEA (International Atomic Energy Commission) and UN-SCEAR (United Nations Scientific Committee on the Effects of Atomic Radiation): "This system of agencies is very tightly knitted, with many overlapping memberships. It has been effectively isolated from normal channels of occupational and public health … this small group of scientists has full control of policy making, and of recognition given to "outside" research, which may challenge its findings and decisions. All who disagree with the recommendations and policies, are labeled either ignorant, emotional or non-scientific. There is no international forum in which disputes can be resolved, either for scientific questions or for policy decisions." (PPT 1996, pages 216 and 217).

The ICRP recommendations provide the best indication of their motives: when it comes to the consideration of the rights and the suffering of the human beings of the distant future the most tragic atrocity of the ICRP comes to light. In ICRP46, Chapter 7.3 ‘Time-scales’ on page 13/14 the ethical aspects of ‘man-made’ radiation are discussed as vaguely as possible. In a roundabout way the ICRP offers two options to the governments on how to disregard those future humans:

The whole chapter 7.3 (ICRP46) is bathed in vagueness and nice phrases (eg. ‘For careful judgement by national authorities’ or ‘is an issue of an ethical and political nature to which there is no simple answer’). [Obviously, the simple answer is: "You shall not kill."]. However, looking at the regulations of the various governments involved with the nuclear industry they have understood the message: nearly all decided to ‘truncate’ somewhere between 1000 and 10,000 years without ever spelling out the consequences of their decisions. To discuss such a decision and the implications publicly would make the decision an obviously deliberate one – possibly an act of mass murder even though legalized for the time being.

In Australia the structural life expectancy of a tailings dam has to be 1000 years at least. The graph on the front page shows how such regulations receive their deadly implementations: during those thousand years the radiation dose is reduced to a low (comparatively only) value, and afterwards the contamination rises steeply to result in the deaths of many millions, if not billions.

Coming back to the ICRP: historically the ICRP dragged its feet in regard to dose reductions needed in response to any new data and statistics on radiation effects. Usually, the dose limits were reduced only after considerable delay. At the moment there is already a ten-year delay between the new statistical evidence requiring a lowered worker’s dose limit and the ICRP amendment.

Even worse, since the last lowering of the dose limit (frowned at by the mining industry but forced onto the ICRP by statistical evidence and critical scientists) several of the individual dose conversion factors for the uranium decay chain have been changed, thereby mitigating some of the effects of the dose reduction for the mining industry. In Appendix 2 it can be seen how the critical values for worker’s protection – permissible inhalation of ore dust and product dust – have gone up by a factor of about 2 to 10 despite the reduction of the general dose limit. The limits in App.2-1 are based on the ICRP recommendations of 1978 whereas the limits in App.2-2 are based on the ICRP recommendations of 1990 to 1995.

After nearly half a century, the ICRP has developed an extremely complex dose assessment system which inhibits public scrutiny. Even the national radiation research bodies are currently not able to make exact determinations. This will eventually lead to the so-called computer modelling by consultancy firms, which removes the last bit of transparency and is wide open to fraud. Obviously, Third World countries will be completely at the mercy of the multinational mining giants.

In the published proceedings on ‘Chernobyl – Environmental, Health and Human Rights Implications’, the ‘Permanent Peoples Tribunal’ states: "The Tribunal condemns … the International Commission for Radiation Protection (ICRP), whose policy is clearly inspired by the promotion of the nuclear industry, instead of being aimed at the protection of the potential victims" (PPT, 1996, p.229).


5.2. The Australian regulations

Some 8 years ago a nuclear consultant with international experience told me that Australia has good regulations (obviously by ICRP standards) for radiological protection, but supervision was on a Third World standard. Good regulations without adequate supervision are useless except if some concerned citizens go to court.

However this last loophole for humanity is to be closed as well: now the Australian standards do not even match the ICRP recommendations. The Australian recommendations for the implementation of the new (1990) outdated ICRP dose limits have watered down those limits even further: ICRP60 recommends for workers a 5 year cumulative dose limit of up to 100 mSv. The Australian recommendations provide for exceptions up to 250 mSv. Australia is one of the first, if not the first, country to provide a Third World template for ‘no worries’ regulations. Despite this, at a recent Senate Select Committee Hearing I heard representatives from ARL and from ANSTO declare that Australian regulations were top in the world.


5.3. Supervision

The current environmental supervision of uranium mining and milling in Australia is totally inadequate. Naturally there is a limitation in the case of uranium mining and milling: ‘adequate’ supervision of something ‘that should never happen’ is mutually exclusive, just like adequate supervision of genocide. Here it is futurecide.

But beyond this limitation, the most basic requirement of an independent supervisor is not being met: the supervisor, the South Australian Health Commission, is not requested to conduct the environmental tests and measurements at the mine and mill, but rather to rely mainly on the operators information.


5.4. Nuclear industry and society

The nuclear industry is often seen as antagonistic to democracy and human rights. A free society is a big threat to this industry which is so dependent on cover-up and disinformation. This is because of

The ever-expanding scale of potential destruction is so far-reaching that the signature of the ICRP on the ‘truncation’ rules (see section 5.1) might cost many times more future lives than there are currently on our planet.

Our society has a criminal law to deter and punish those which cause the death of a human. This is a generally accepted means of protecting human lives. However, a short reflection on history makes it clear that most killings have not been caused by individuals but by governments.

Governments can commit crimes by legislative processes. Laws that permit uranium mining are laws that commit crimes against present and future generations. Therefore we need to work for the national and international protection for the dignity of human life.

On the national level such a protection within the constitution could override acts and laws by government and parliament. The deterrent function of criminal law has to be extended to those scientists, politicians and bureaucrats who facilitate such crimes by bending the truth, by manipulating or just by being silent in the face of such pending crimes.

To deal with the multinational uranium mining companies and their international regulator, an international trial on the uranium-mining holocaust similar to the Nuremberg Trials may be needed.


5.5. The ethical background

This most important issue has been addressed in the foreword of this paper. I would like to add some considerations.

During my research I came across many instances where essential information has not been brought out to the public. The ‘Indenture Agreement’ between the South Australian Government and the operators of the Roxby Downs mine is the most obvious example: this contract includes a clause (clause 35), which prohibits the government from making public certain information, including the results of the environmental monitoring of the project. The government now needs the agreement of the mining company to release such information.

The hiding of information about the tailings reminds me of the general dishonesty in government and industry. Dishonesty is a near total blanket over our society, and nearly everybody is aware of this. Dishonesty is required where responsibility is discarded. In contrast, for a responsible society, speaking out the truth becomes a major responsibility for everybody.

Confronted with a technology which expands into ever more risky dimensions, the only society capable of handling such challenge would have to be based on truth and a caring attitude.



6. The inadequate EIS process

Currently the EIS process consists of 6 stages:

  1. The Environment Department provides the ‘Guidelines’ for the EIS after public consultation
  2. The proponent prepares a ‘Draft Environmental Impact Statement’ which explains the environmental problems of the project and details the proponent’s concepts of how to deal with the problems.
  3. The public writes submissions to the draft EIS
  4. The proponent prepares a Supplement to the EIS, which considers the concerns raised in the submissions
  5. The Department of the Environment prepares an ‘Environment Assessment Report" for the project based on the information provided in the EIS and the concerns raised by the public.
  6. The Minister for the Environment gives consent to the project under certain conditions or rejects the project.

In the case of the Jabiluka proposal and of the Olympic Dam Expansion the EIS process failed in all stages. This chapter will mainly consider the stages 2, 3, 4, 5 and 6 of this process.


6.1. Environmental Impact Statements omit the essential information

An Environmental Impact Statement is meant to explain the environmental problems of a project, and then to detail the proponents concepts of how to deal with the problems.

The Environmental Impact Statement is to show that the project is ecologically sustainable, that there is a balance between economy, environment and the welfare of the people.

In the case of uranium mining, some of the environmental impacts are so severe and unavoidable that their explanation and discussion would make uranium mining outright unacceptable. How did the proponents of the Jabiluka mine and of the Olympic Dam Expansion Project deal with this dilemma? They simply omitted the consideration of those impacts, in particular they did not even mention

to become widely dispersed into the environment via wind and water

to become airborne and inhaled

to enter the food chain

Not only the discussion of those principal environmental problems has been omitted from the EIS but also many details required for an independent assessment. These include important measurements available to the company. Even such essential details as the particle size distribution of the tailings and their respective radioactivity or the residual uranium content of the tailings have not correctly been specified if at all.

Where it matters most, the very purpose of an EIS has been ignored.


6.2. The submissions to the EIS

The submissions to the draft EIS are meant to provide the public and any other interested parties (competitors, government departments etc) with an opportunity to raise concerns about the proposal. There are severe limitations to this stage where the environmental impacts of the proposal are not obvious or not easy to assess. This is particularly true for uranium mining: the long-term environmental impacts are not easily understood by lay persons; they will not be obvious in the immediate future and are therefore not obvious at existing mines, and their extent is difficult to assess even for scientists, especially when the required information is not provided.

The Environmental Impact Statements for the Jabiluka mine and for the Olympic Dam Expansion Project have both not provided this information. This is even more tragic as the issues raised in this paper cover only the minute ‘visible’ fraction of the details which can be researched just with commonsense – without the data, without the information, and in particular without all the instruments and dozens of scientists and technicians to check those millions of measurements.

Even access to the mines is denied. The EIS could claim just about anything. In the light of these considerations, the omission of those extremely tragic aspects of the projects leads to daunting suspicions about the credibility of all the other data and statements in the EIS which can not be checked independently. Hardly any details are given on radiation measurements, past or proposed (measurement principles, techniques, instrumentation, independent (?) consultants / engineers employed, baseline studies). In the Olympic Dam EIS Supplement, Kinhill justifies this with a lack of space in the EIS. A webpage or a couple of CD’s could certainly resolve this. Kinhill was able to issue the Jabiluka EIS on CD (even though without the required details).


6.3. The role of the consultancy firm (Kinhill)

The EIS’s for Jabiluka and for the Olympic Dam Expansion have both been prepared by the consultancy / engineering firm Kinhill. In both Kinhill has completely ignored the basic facts.

After 1000 years, the tailings retain 99% of their current radioactivity – this is a scientific fact. If they need to be kept meticulously out of the biosphere for now, then obviously they need to be kept out of the biosphere in 1000 years and then also for millions of years thereafter. One might ask what else are they prepared to ignore? The ICRP (ICRP 46) employs similar disregard for the lives of future humans. However, a crime cannot be justified because a similar crime is being committed by somebody else.

In chapter 10.1.2 (O.D.ExpEIS) we read explanations of the statistical aspects of death which diminish the tragedy of death inflicted on others for a company’s profit: Death is being reduced to ‘number of years of life lost’. Again, the ICRP supplied the mould (see ICRP 60).

These concerns about Kinhill have to be seen in context of the regulatory framework of the EIS process: the consultants for the preparation of the environmental impact statement are chosen and paid for by the company. Considering the effect of competition from other consultants wanting to get the job, who could expect the consultant to be simply concerned with the potential environmental impact?

The EIS consultancies undergo a negative selection process with potentially dire consequences for all humankind. The EIS process needs to be overhauled.


6.4. The Supplement to the EIS can ignore the main concerns in submissions

The EIS Supplement is the last opportunity for the proponent to address environmental concerns, in particular those raised in submissions.

In the case of the Jabiluka proposal as well as in the case of the Olympic Dam Expansion Project, the supplements did not address the severe concerns about the long-term effects of the uranium tailings raised in several submissions. Even the prospect of millions of projected deaths did not motivate the companies to discuss the issues. There are no solutions for those problems. Consequently, the discussion of those problems would lead to a stop of uranium mining. In particular the Olympic Dam Supplement addressed many of the less important, misunderstood and mistaken details raised in public submissions without facing up to the main concerns. This can only be seen as an admission of those environmental impacts. The list of items not addressed in the Supplements is essentially identical to the list in section 6.1 (above).


6.5. The role of the assessing and supervising authorities (OSS and Environment Australia)

As detailed before, the Environmental Impact Statements are compromised by the interests of the proponents / consultants; the public is limited by its lack of information, its inability to check up on measurements and claims. This leaves the supervising and assessing government authorities as the last hope for an assessment of the environmental impact. Their contribution to the EIS process comes as the ‘Environmental Assessment Report’ which is supposed to investigate the environmental impact on the basis of the draft EIS, the public submissions, the Supplement to the EIS, and their own research.

In the case of the Jabiluka proposal, the Commonwealth Department of the Environment wrote a 141-page ‘Environment Assessment Report’ (1997) with exactly one paragraph (7 sentences) devoted to the assessment of the long-term tailings hazard. Considering that many millions of future lives are endangered, this issue should have taken up at least half of the report. While those few sentences provide some acknowledgment of the impacts, each and every one of those sentences contains gross distortions and / or diminishment of the facts. The very approach in writing those sentences shows the bias of the authors for the mining company and against the lives of the future humans. It is impossible to know where this bias comes from. Certainly, a lot of independent character is required (see chapter ‘A Law unto Themselves’ in Quentin Dempster’s book "Whistleblowers").

The ‘Assessment Report’ (1997) for the Olympic Dam EIS avoids the investigation of the long-term tailings issue altogether.


6.6. The political decision

The last stage of the EIS process is the decision by the politicians, here mainly the Minister for the Environment, Robert Hill, and the Minister for Resources and Energy, Warwick Parer.

After the derailment of the EIS process up to this stage, a tremendous responsibility rested with those ministers. The public still had the informal opportunity of writing letters to those ministers, and this has certainly been done.

Unfortunately, the ministers appear to have reached their decision a long time ago. Even worse, they appear to be at the source of the derailment of the previous stages of the EIS. As several ministerial advisors and government scientists indicated, the political will to address the issues was not there.


6.7. Concepts for a revised EIS process

The long-term consequences of the uranium mining will cost many millions (if not billions) of future lives. How is it possible that the EIS process failed those humans so miserably?

When we talk about the death of many millions, even billions of future humans from cancer, about birth defects and ongoing genetic damage, we are facing one of the biggest crimes in human history, however legal it may be today. An EIS process permitting such crimes urgently needs review.

For proposals with high environmental risks like nuclear and chemical plants, mines and heavy industries, a different approach is required: the EIS has to be compiled by independent consultants. The disclosure of the environmental impacts and risks in the EIS has to be a legal requirement backed by criminal law. Non-disclosure or misleading description of severe impacts or risks have to be penalised like the corresponding crimes, for example as ‘accessory to murder’, and have to automatically trigger the dismissal of the proposal. In the current EIS process the consultant has not much choice but to become an accomplice to the crime, if he wants to get the job.

Similarly, those assessing the EIS and submissions, as well as the decision-bearing politicians, have to be exposed to the deterrent function of criminal law. Murder and manslaughter are not acceptable, not for greed, not for job security, not in exchange for party donations etc.

Also, the companies and their managers have to be made liable for the long-term consequences of their activities.

A society largely based on the pursuit of self-interest cannot deal with the excesses of modern technology without the use of the criminal law to protect the fundamental rights to life, health and environment. This protection has to include future generations. Obviously, it would be preferable to have a common appreciation of these values as the base of our society’s functioning, making the threat by criminal law a secondary recourse. However, as our economy, politics and media are now structured and as we humans have developed our ethical framework so far, the deterrent function of criminal law has a very important role, which we urgently have to utilise.




‘No practice involving exposures to radiation should be adopted unless it produces sufficient benefit to the exposed individuals or to society to offset the radiation detriment it causes’ (ICRP - Principle). The most important detriment from the Roxby Downs mine (the radioactive contamination by tailings for billions of years) has not even been mentioned in the Olympic Dam Expansion Project EIS.

In the past, the tailings issue has been addressed in single sentence remarks:

In the Ranger inquiry / Fox Report, II, p.141: "The time taken for radon output to dwindle to insignificant levels could be 100,000 years or more (perhaps up to a million years)."

Annual Report of the Supervising Scientist 1988/89: "Almost all of the radioactivity will be con-tained in the tailings and … a potential health hazard remains for several hundred thousand years"

There are several government radiation research bodies in Australia. One would assume that their foremost task is to investigate these issues of public interest. However, they obviously prefer to keep the issues quiet so the industry remains viable.

The recent Senate Report (SSCUMM) chooses to state: "The Committee, whilst not necessarily sharing the more pessimistic forebodings about management of tailings, nonetheless views tailings management as among the most serious challenges…" Obviously, the committee could not tell the reasons why it does not share those ‘pessimistic forebodings’ nor did it take up this ‘most serious challenge’. All it recommended was reliance on future research. How would you feel if you and your family were to be deep-frozen, with the hope that one day the iceblocks could be revived – just because it suits the business interests of some company? While there may be a hope that you could be revived one day, there is no justified hope that the tailings could be made safe, and they will affect billions of future humans.

Uranium mining is a crime against humanity. Those choosing to abuse their responsible position by ignoring or down-playing the issues, have to be seen under this light.

The tremendously destructive potential of our technology (and the tailings issue in particular) challenge us to rethink our ethical and legal framework. This should be addressed in a future revision of the constitution. By now, ‘Crimes against Humanity’ and the ‘Dignity of the Human Life’ are well-established legal terms in other countries and in international courts (constitutions of various countries, Nuremberg Trials, Bosnian War Crimes Tribunal) however limited their current application

If we had suitable legal protection, our scientists, bureaucrats and politicians would have learnt their lessons after the asbestos affair when disinformation, academic silence and manipulation caused a 30-year delay to the mine closures. Instead, we are facing the same difficulties again – now with uranium mining. The stakes have increased a thousandfold – or perhaps a millionfold.

While research for this study has been conducted with inadequate funds and personnel, it certainly provides sufficient information

for the immediate closure of all uranium mines and the outright rejection of any new mine proposals

to conduct a thorough research project by nuclear and environmental scientists into the issues raised with the participation of environmental groups.

to halt all asset transfers of companies previously or currently involved with uranium mining to secure some of the costs

to investigate why ANSTO, ASTEC, OSS, ARL, Environment Australia and other related scientific and environmental research and control bodies have not provided clear information to date, and to then press criminal charges against those responsible to prevent future repetition.

To contact all current and past workers at uranium mines for a thorough dose assessment and health examination, to inform them about their medical and legal situation.



App. 1: Activity calculations:

The specific activity of U238 is 1.233 x 104 Bq/g and the U238 content of U3O8 (yellowcake) is 84.8%.

Therefore the specific activity of U238 in yellowcake is 1.045 x 104 Bq/g (alpha only). Considering the two other uranium isotopes in yellowcake, U234 and U235, as well the total activity of uranium in yellowcake is 2.1 x 104 Bq/g (alpha only).

With an Olympic Dam ore grade of 0.065% the specific activity of U238 in the original ore is 6.79Bq/g, which represents the current chain activity both in the uranium ore and in the tailings. The total uranium activity in the original ore would be 13.6 Bq/g (alpha only).

The tailings contain 6 alpha decays, each having the same activity, therefore the total specific activity (alpha only) for the tailings is 6 x 6.79 = 40.8 Bq/g, and for uranium ore 10 x 6.79 = 67.9Bq/g


App. 2: Dose limits for inhalation of tailings particles:

1. According to the Code of Practice on Radiation Protection in the Mining and Milling of Radioactive Ores’, 1987, Commonwealth of Australia:

For designated radiation workers an annual dose limit of 50 mSv applies. For members of the public a dose limit of 1mSv per year applies (with a subsidiary dose limit of 5mSv per year, as long the average annual dose over a lifetime does not exceed 1 mSv). The conversion factors for ore dust, product dust and tailings dust are 0.021, 0.034 and 0.017 [mSv/alpha disintegration per sec.] respectively.

The maximum quantity of dust [grams] to be inhaled per year is therefore:


Ore dust

product dust

tailings dust

For workers




For members of the public, ongoing exposure




For members of the public, single accident




2. According to ICRP’s 60, 68 and 72

For designated radiation workers an annual dose limit of 20 mSv applies with a subsidiary dose limit of 50 mSv per year as long the average annual dose over 5 years does not exceed 20 mSv. For members of the public a dose limit of 1 mSv applies with a subsidiary dose limit of 5 mSv per year as long the average annual dose over 5 years does not exceed 1 mSv. The conversion factors are detailed for each isotope separately requiring lengthy calculations and uncertain assessments. Considering for each dust category only the two isotopes with the largest conversion factors we arrive at the following maximum quantities of dust [grams] to be inhaled per year:


Ore dust Th-230,Ra-226

product dust U-238,U-234

tailings dust Th-230,Ra-226

For workers, ongoing exposure




For workers, single accident in any 5 years




For members of public, ongoing exposure




For member of public single accident in any 5years




The maximum quantity of Olympic Dam tailings dust to be inhaled per year by a member of the public is 1.44 g. With a spec. gravity of 1.75, this would be equivalent to a half teaspoon.

All the above inhalation limits would have to be set much lower as other sources of man-made radiation apply as well, both for workers and the public. In a practical situation, perhaps some 2 – 100 times less dust is allowable to be inhaled.


App. 3: External radiation, gamma dose:

The two main gamma-radiating isotopes in the tailings are Bi-214 and Pb-214 with a dose factor of 2.81E-04 resp. 4.69E-05 [Sv/a per Bq/cm3]. With a spec. activity of 6.79Bq/g (see App.1) and a tailings density of 1.9 we arrive at an activity/vol of 12..9 Bq/cm3.

This results in an annual dose of (2.81 + 0.469) x 10-4 x 12.9 = 4.23mSv for a thickness of the tailings deposit of 1 centimetre. For a 15 centimetre thick deposit the annual dose would be 19.7mSv.


App. 4: Radon emanation and annual dose:

In the O.D.EIS (1982, p.9-26) the radon emanation rate for the tailings during mine operation is specified as 0.6 and 3.2 Bq / (m2 x s). While this might be correct for the partly saturated tailings during mine operation, the long-term emanation rate after erosion of the cover and dehydration of the top strata of the tailings would rather be 7.3 Bq/ (m2 x s). This assumes a radium 226 content of 7.3 Bq/g (O.D.EIS, 982, p.9-26, adapted to the higher ore grade) and an emanation constant of 1Bq/ (m2 x s) per Bq/g of radium 226 (ARL TR 43).

For the members of the ‘critical group’ we assume that they live in buildings which tend to accumulate the radon gas emanating from the ground. If a person lives in a 10-squaremetre / 20 cubic metre hut, tent or similar structure erected on the ground without much cover of the ground, and keeps doors and windows closed during the night (8 hours), then the radon accumulation (in a night) is 7.3Bq/(m2xs) x 8h x 3600s x 10m2 = 2,102,400 Bq and the average radon concentration during the night is then 52,560 Bq/m3. The exposure time is 365 x 8 = 2920 hours. This results in a dose of 300 mSv.

While this calculation considers a rather theoretical situation (no radon losses from the building and unobstructed radon emanation), this is more than compensated by not considering the daytime exposure to radon in the calculation.

I assume a radon dose of 300 mSv per year for members of the ‘critical group’.

The radon released from a tailings deposit stems mainly from the top layer of the deposit. Most of the radon from the deeper layers can not escape from the deposit. This explains why the radon emanation rate (see above) is proportional to square metre and not to cubic metre or ton. As the tailings are being eroded and spread out over vast areas, the total radon release increases considerably. After some 20,000 years of erosion an average radon dose of 1 mSv could well apply to the residents of an area of 200,000 square kilometres.


App. 5: Estimates of future radiation cancer deaths from current Australian uranium tailings:

It has been estimated by the US EPA that, without control, the radon emissions from all tailings in existence at licensed US sites in 1983 would cause about 500 lung cancer deaths per century (EPA 1983a), and that, without remedial action, the radon emissions from all tailings at inactive US mine sites would cause 170 - 240 deaths (EPA 1983b).

For our estimates we use the figures from the inactive mine sites as they more closely reflect the condition of the Olympic Dam tailings deposit over the future millennia, when the tailings will be exposed and spread around (the US study does not include the long-term aspects of the tailings).

Considering the very slowly diminishing radioactivity of the tailings the 170-240 death per century (205 deaths used for calculations) would result in about 228,000 future lung cancer deaths from radon emissions alone.

We assume the average dose distribution model for uranium tailings to be 80% radon, 12% inhaled tailings dust, 8% ingested tailings and 0.2% external radiation (see chapter 3.6). This would result in 284,000 future cancer deaths from the combined pathways.

The US EPA estimates have been made for the situation in the US in 1983. How do they compare with the future situation in Australia?

a) Population density of Australia: Our estimates are made for today’s Australian population density which is 10.67% of the US reference population density. This figure is based on the current estimate of the Australian population (18.2 million). Correction factor(C/f): 0.1067

b) Population density in the region of mine site: Olympic Dam is located in a remote area, even more than the US reference mines. This is somewhat mitigated by the fact that a variety of climatic conditions can be expected over the long time spans involved – as happened in the past. Higher rainfall would make the prevalent soils much more fertile. This would increase the average future population density of the area as well as the contaminated food supply from the area. C/f: 0.5

c) Tailings quantities: In 1983 there were some 26 million short tons (equivalent to 23.6 million tonnes) of tailings at inactive mine sites in the US. The Olympic Dam tailings will eventually amount to 569 million tonnes. C/f: 24

d) The ore grade directly determines the radioactivity of the tailings. Unfortunately there are very contradictory statements about the Roxby Downs ore grade. In the original EIS an ore grade of 0.05% was stated and since widely used. A recent report to the Senate (Leigh, 1997) states an ore grade of 0.15% -- 3 times higher!! An investigation of this discrepancy might be of interest. The new O.D.ExpEIS, gives in Table 3.2 values between 0.069% and 0.087% for the years from 1996 to 2010 and in Table 3.1 a value of 0.06% for the total deposit. We assume an ore grade of 0.06%. The average ore grade of the reference US tailings is 0.227%, resulting in a reduction of the detriment. C/f: 0.26

e) The effects of those American tailings were only considered for a time span of 100 years into the future. After 1000 or 10,000 years the situation will be substantially different -- tailings will be an intrinsic part of the human biosphere. Then, the detriment will be much higher than during the ‘foreseeable’ next hundred years considered in the US study. For the long-term situation, four main differences have been identified:

The tailings deposits will increasingly deteriorate causing higher erosion rates than assumed in the reference US-study. C/f: 2

The loss of knowledge and understanding of the dangers will result in people living, working and farming right on top of deposited and eroded tailings. C/f: 5

The ongoing erosion of tailings will result in a substantial accumulation of tailings particles in the biosphere. While a considerable proportion of the eroded and dispersed tailings will leave the biosphere in various ways (buried under sediment on land or in the ocean), substantial quantities will remain in the topsoil from where they can release radon and enter the human food-chain again and again. Some of the tailings covered by sediment will again become exposed by erosion. Even those tailings covered by sediment will largely stay connected to the biosphere for 2 reasons: Firstly, several of the radioactive isotopes in the tailings are water-soluble (OECD, 1984, p.38 ff.). The fine particle size of the powdery tailings permits the leaching of those isotopes. Secondly, radon gas continues to escape: A cover of half a meter of sand will reduce the radon emanation from the tailings into the biosphere by 29% only, a cover of three metres by 88% (EPA 1986). The tailings leaving the biosphere each century may be 10% of all tailings in the biosphere, the tailings re-entering the biosphere may be 0.5% of all tailings which had left the biosphere earlier. These rates would be higher in the earlier centuries, and rather lower in the later centuries, eventually moving close to zero. The above given rates would result in more tailings entering the biosphere than leaving it during the first thousand years, then they would largely stay in balance for some 4000 years. From then onwards the tailings in the biosphere would slowly increase again, for some 30,000 years. Afterwards the tailings will ever more slowly leave the biosphere, over billions of years. C/f: 15

Also, the loss of knowledge and understanding of the dangers will see the people of the future mining the tailings for land fill, concrete admix or for their garden beds as it happened some 30 years ago in the US when we had all reason to know better. C/f: 2 .. 5 .. 10

f) Since the first recommendation of a radiation dose limit in 1902, the dose limits had to be reduced again and again as the evidence of the hazard mounted. The last major push for such a dose reduction occurred in the eighties when new statistical data from Hiroshima further revealed the long-term consequences of uranium mining. Each reduction in the dose limit increases the costs of uranium mining considerably, and reduces the viability of the whole nuclear industry. As usual, the International Commission on Radiological Protection (ICRP) resisted the required changes for a long time and eventually introduced a half-hearted dose reduction with a 10-year delay. This reduction granted a 2.5 times lower dose limit for workers and a 5 times lower dose limit for members of the public. Since, the ICRP modified the individual conversion factors for the most critical isotopes in the uranium ore and tailings effectively increasing the maximum exposures for the most common situations some 2 to 6 times. This effectively inverted the dose limit reduction (see App.2 and chapter 5.1). Considering that the dose limit reduction was in the first place not adequate to the statistical evidence from Hiroshima and that not even the basic principle of a linear ‘dose – effect relationship’ has been applied to the calculation even though accepted in principle, the maximum exposures limits may be another 2 to 10 too high. For most practical situations, the combined effect of these flaws might result in a radiation exposure limit some 4 to 60 times too high. For various reasons these distortions of the exposure limits had only a limited influence onto the US study (eg. radon research is not based on Hiroshima data). C/f: 1.5 .. 10

These assumptions would suggest 106 million future cancer deaths from the proposed Olympic Dam uranium tailings (284,000 x 0.1067 x 0.5 x 24 x 0.26 x 2 x 5 x 15 x 5 x 1.5 = 106 million) for the scenario considered most likely (underlined correction factors). With the above assumptions the death toll could range between 42 million and 1.41 billion! These estimates do not yet include the effect of the residual uranium content, which increases the death toll over the next 500,000 years by about 20% (please note that in the very long term this aspect will increase the death toll perhaps several hundred times, which is not yet considered here). The estimate of the death toll from the Olympic Dam tailings over the next 500,000 years is therefore 127 million, ranging from 53 million to 1.4 billion.

Obviously these estimates come with big uncertainties which could increase or decrease the estimates considerably. However, we do not have the right to give the credit of the doubt to the mining companies. This is not a trial where the crime has already happened, where we have to give the credit of the doubt to the accused. This is rather a proposal for the future to indirectly inflict death and disease. The credit of the doubt has to be given to those potentially affected.

Please note: For the calculations of the future death toll in App.5 very small doses (minute fractions of a mSv) have been included into the statistical cause of cancers. The consideration of annual doses below 1mSv (the maximum dose for members of the public) is often rejected as insignificant. However, there is a natural background dose of about 2 mSv providing already a high base level. Therefore these minute additional levels have to be included.

The other argument made is that these smaller man-made doses are insignificant compared to the natural background. While it is true that a dose of 0.1 mSv adds only 5% to the average background radiation, it is as well true that the natural background radiation costs many lives (some 1800 deaths per year in Australia). The fact that nature causes deaths does not give us the right to add to this. Over the very long time spans involved vast numbers of people (perhaps 50% of the above estimates) will die due to those ‘insignificant additions’ to the natural background radiation. The sanctity of human life can not be abolished because nature causes deaths. Nature provides for the eventual death of each of us. This does not give mining companies the right to request a share in killing rights.




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Roxby Downs is claimed to be the mine with the world’s biggest uranium ore reserves.

The proposed expansion will result in about 569 million tonnes of tailings. The ore grade (vastly differing figures) is assumed to be 0.06%, a low-grade ore. The tailings disposal in a dam is discussed in this submission. Supervision of the mine is poor (mainly by the S.A. Health Commission).

Ranger is one of the world’s biggest uranium mines. The mine will eventually produce some 42 million tonnes of tailings. Due to the high ore grade (0.29%) the radiation hazard from the tailings is particularly serious. The tailings are being dumped into the two mine pits. These mine pits are unsuitable for tailings disposal (high rainfalls, many aquifers, proximity to Magela creek, proximity to floodplain, etc.). In a recent EIS the operator proposed to use the surplus space in the mine pits for Jabiluka tailings. This would even further aggravate the situation because of the acid-forming nature of some of the Jabiluka tailings.

The residual uranium content of the tailings, originally claimed to be 1% is now admittedly rather 10%. While this increases the death toll for the next 500,000 years ‘only’ by some 10%, for the very distant future this alone may increase the death toll by several orders of magnitude.

Jabiluka is a proposed new uranium mine adjoining the Ranger mine. The very high ore grade of 0.46% and the acid forming nature of some of the resulting tailings (20 million tonnes of tailings at a first stage) would make this proposal very problematic. A residual uranium content of 10% has been used.

The tailings storage for Jabiluka is not yet resolved, with several options being persued.

Using our estimates of the future death toll (appendix 5) and our comparison of different storage options (section 2.5) and correcting for the respective ore grades, tailings quantities and residual uranium content we may have to expect a death toll for the next 500,000 years

These estimates are very sketchy, and a detailed study would produce higher death toll estimates.

The estimated 500,000-year death toll for the two linked mines Ranger and Jabiluka, if approved, could be between 16 and 23 million humans, depending on the tailings storage options chosen. Taking into account the full time span of the hazard from the residual uranium content, the tailings from these two mines would cost billions of human lives.

Uranium mining has to be stopped as a matter of urgency.