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Submission to the Senate References Committee on the Matter of Whether a New Reactor Should be Built to Replace the HIFAR Reactor at Lucas Heights or on Some Other Site in Australia

Site selection process for a nuclear reactor

The Decision

It is important to deal with the question of siting first because Sutherland Shire is facing a situation in which the Federal government has made a decision, announced 3 September 1997, that a new nuclear reactor will be built to replace the ageing HIFAR and it will be sited at Lucas Heights. The announcement was accompanied with the reassurance that an Environmental Impact Study (EIS) would be carried out "on the suitability of the Lucas Heights site". There has been no consultation with the local community on this matter.

The Players in the EIS

The EIS is being rushed through at this moment and will be well on the way to completion by the time this Committee hands down its report. It is being carried out by the proponent, the Australian Nuclear Science and Technology Organisation (ANSTO) with the assistance of an Australian consultant, PPK Environmental and Infrastructure P/L, a UK consultant NNC - said to stand for National Nuclear Construction and hardly an independent assessor - with the help of $6 million from public funds.

The fact that the proponent is also the chief advisor to the government on nuclear matters as well as being responsible for its own EIS on its existing site is beyond reason. But it is within the terms and legal parameters of the Act, drawn up 24 years ago and most certainly out of date. Indeed Andrew Sorenson of the NSW Environmental Defender's office describes " an unfortunate trend has become apparent in the EIA process at the Commonwealth level. Approve first - Assess later" is the Commonwealth EIA an empty ritual?"

Take this one step further and we find that the person responsible for the final acceptance or rejection of the EIS is the Minister for the Environment Senator Robert Hill. He is a member of that same Cabinet which made the decision, in advance, that a new reactor will be built at Lucas Heights. All this is gives the locals little confidence that there will be anything but a positive outcome for ANSTO and a negative for the community.

The Consultant

PPK is well known to the surrounding population as it was the consultant for the EIS into the suitability of either Holsworthy or Badgerys Creek as a site for a second Sydney airport. In spite of the fact that it came down against the Holsworthy option - a decision which was so obvious that it could have been made by a year 11 science class and saved millions of dollars - PPK's efforts at community consultation were so poor that the Auditor overseeing the EIS reported that " it had failed to build confidence in the EIS process".

When ANSTO announced the appointment of its local consultant, Professor Garnett proclaimed that "the EIS would be finished around the middle of 1998 following widespread community consultation to ensure that all concerns about the replacement reactor are fully explored" . Our first contact with PPK was not encouraging and only confirmed our worst suspicions. When asked whether public meetings were planned we were told " No ".

The Auditor

The Auditor, SMEC, made many other serious criticisms of the airport EIS and these are described in the article by Murray Hogarth in the attached cutting from the Sydney Morning Herald.31/9/98.

Even before the Auditor's report had been published we had requested, nay, demanded that an Auditor be appointed to the reactor site EIS. Our request was denied by Minister Hill who said that the appointment of an Auditor for the airport was a "special case" which could not be repeated. After the release of the Auditor's report we repeated our request but we expect another refusal. Why should the Minister wish to make the EIS appear fair? After all, the decision has been made.

Recommendation : An Auditor is essential if only to balance slightly the outrageously partial nature of this shameful exercise. We ask that this Committee immediately call upon the Minister to make the appointment.

Site selection and the Research Reactor Review

Probably anticipating a decision to build a new reactor, the RRR in its 1993 report said that:

"If a decision in favour of a new reactor is made then the question of siting will become a major problem for the government. When the search for a national waste repository for low and intermediate level radioactive waste was started following the Research Reactor Review (RRR), the process was initiated by the National Resources Information Centre (NRIC)."

"Following the code of practice laid down by the NH & MRC for the Near Surface Disposal of Radioactive Waste in Australia its criteria included natural and physical characteristics such as low rainfall - freedom from flooding - stable hydrology - freedom from cyclones, tectinic, seismic or volcanic activity, as well as socio-economic, ecological and land factors."

The McKinnon report said that "If a decision were made to construct a new reactor, it would not necessarily best be placed at Lucas Heights. An appropriate site would best be decided after exhaustive search and taking into account community views." "Any siting decision should be based on criteria similar to those developed by the NRIC with an additional range of economic and scientific criteria." (emphasis added)

We are of the opinion that the NRIC has carried out its task of locating a site for a national radioactive waste dump - for low level rad.waste - in a thorough and professional manner. At the second Conference on Nuclear Science and Engineering in Australia, October 1997, Dr S M Veitch of the NRIC explained that to overcome the (not unexpected) NIMBY complex, he had considered everyone's backyard and had examined the whole of the Australian land mass. We were not surprised that, in its second phase, when eight broad regions which met the criteria were identified, none was within a thousand kilometres of Lucas Heights. In fact the entire eastern seaboard was seen to be unsuitable. Unsuitable that is, for a low level waste dump but perfect, it has been decided, for a nuclear reactor!

Government reaction to the RRR report on siting a new reactor

In a response to a question from Senator Lees, the Minister for Science and Technology, through Senator Parer, fell back on the old feeble defence of saying that the report from the RRR was only used for guidance and the government did not have to follow its advice. He claimed that the Minister for Science had examined alternative sites and that they had all been found to be unsuitable. However he would not announce details of the supposed study. How many alternative sites were examined? Which were they? What were the criteria used? How long did the study take? (The present search for a suitable waste dump site, through the NRIC, has taken four years and will take another year at least for final selection.). What did the study cost? Which department carried it out?

To nobody's surprise the Minister says that the "ideal" site is Lucas Heights. One of the main reasons given was the cost of moving to another location. This presents an obvious contradiction. If it makes economic, safety and logistical sense (to the government) to move 40 years build-up of radioactive wastes from Lucas Heights to, perhaps Western Australia, then the same logic should apply to move its nuclear reactor operation away from a growing area of population. Cost is apparently of little significance where waste is concerned - although we cannot get even the slightest indication of the cost of the waste dump.

If, however, cost is so important then surely it would be more economical to leave the waste on site at Lucas Heights? All it would need would be a few thousand more empty barrels for the low level stuff, drill more holes into the rock for the spent fuel rods and find a location for the very nasty liquids which result from the manufacture of radioisotopes. Of course the politics would be bad. The community and the local Council would explode in rage as would our docile Federal representatives. But the government's economic argument would be consistent. Wouldn't it?

On the other hand, if the question of siting waste dumps and nuclear reactor is decided purely on objective scientific criteria - as we trust the EIS will be - then where is the sense in having a dump a couple of thousand kilometres away from the producer? We hope that you will get to the bottom of this.

Recommendation: That the Committee obtain a fully detailed and costed report of the alleged study to find a site for a replacement nuclear reactor. That this report, if it exists, be made public.

Recommendation: That the Committee obtain from the Department of Primary Industry and Energy an estimate of the cost for a national waste repository and that the figure be made public.

Why then was Lucas Heights selected as the preferred and only site for the new reactor?

There are only three possible reasons.
  1. Because the staff like living in our beautiful Shire.

  2. Because it exists.

  3. Because no other community would accept it.
No other reasons spring easily to mind.

Why will the community not accept the decision?

There are many valid and compelling reasons. They include:

It's not remote

Lucas Heights was selected in 1955, as a site for Australia's nuclear industry for the very reason that it was remote from population. Now, 40 years later, it is surrounded by houses, on the edge of Australia's largest city. This is no longer in a good site for a nuclear reactor!

It does not comply with public opinion

ANSTO's public opinion poll - commissioned in 1996 at a cost of $40,000 of taxpayers' money - found that 83% of Sutherland Shire people surveyed thought that a new reactor should be in a "remote location". This is consistent with this Centre's 1992 poll which found that 81% of people felt that a new reactor should be away from population centres. The Commonwealth has ignored this finding.

Representatives from the Centre were invited to take part in the process leading to the public attitudes survey which was carried out at the end of 1966. When we insisted that the question be put as to a preferred option for a site should the government decide to build a new reactor we were told by the ANSTO representative that "We don't to go into such detail at this stage" Mrs. SusanYoung, the Director of the polling company Keys Young backed this up with the comment " You can't ask that question - because we know the answer!"

This made us all the more determined - and suspicious - so with the support of another community representative and the representative from Council we were able to ensure that the siting question was raised. The rejection of a new reactor was emphatic. 83% of the people polled in the Sutherland district and 88% of the people from the Liverpool / Bankstown area rejected the Lucas Heights option.

It must also be understood that, when the survey was taken, in December 1996, there had been no public mention by the government of a new reactor. However, less than three months after the survey results were made public, Minister McGauran raised the prospect of both a reactor and a reprocessing plant at Lucas Heights.

Recommendation: That the Committee arrange for the public attitudes survey to be carried out again to determine what changes to attitudes, if any, have taken place during the past 12 months. The cost would be far less than the $40,000 for the original poll and should be taken from the $6 million ANSTO has been given for the EIS.

It is a health risk to the local population

According to ANSTO " The annual dose of radiation received by any member of the public living near ANSTO as a result of authorised emissions from the site is currently less than one-100th of the amount permitted by the National Health and Medical Research Council and by NSW Government regulations. A modern research reactor would not produce more than those levels ..."

Regulations or not, there is no proof that this (or any) level of radiation is safe. There are neither medical records nor diagnostic tests to assess the effects of radiation on the local population. Apart from obvious cancers and leukaemia - which can take decades to develop - more subtle health or genetic problems could be caused such as impaired scholastic performance, visual impairment or reproductive problems. The NSW Health Authorities have avoided their responsibilities and declined to carry out health studies. They say that one " would not be warranted".

There are many stories in the local community concerning health problems. Some were raised during the RRR but there were time constraints and the NSW government was not asked (and was unlikely to agree) to carry out a check on their hospital records over a period of many years. The local doctors showed little interest during the Review. Over 100 were contacted in an attempt to ask for their opinions on local health. Only 4 replied.

In my own street, which lies less than 2.5 Km from the reactor, within 50 metres on each side of my house I can record:
  • 1 case of leukaemia. A very fit male, died aged 41

  • 3 cases breast cancer, 1 fatal. All in their 30s

  • 1 female, died of cancer of the pancreas, aged 60

  • 1 female, died of liver cancer, aged about 50

  • 1 female, died of stomach cancer, in her 40s

  • 1 female, ovarian cancer, in her early 20s, still being treated

A local doctor described a short street in Menai as " a place where I would not wish to live ". Two members of one family have died of cancer and there is one case of child leukaemia. It is close to the Little Forest Burial Ground.

On 6 July 1984 2.12 kilograms of unenriched uranium hexafluoride were released into the atmosphere. State Emergency Services were not notified; State Pollution Control Commission and staff were notified well after the event. A committee of enquiry was appointed to establish the cause of the release. In the period following this unplanned release there was a spate of miscarriages in the Lucas Heights suburb. These were never investigated or explained.

These cases may all be perfectly average for the rest of Sydney but we have no way of knowing. They are certainly not "suburban myths".

Current scientific studies in the UK suggest that even radiation exposure less than 1mSv may be harmful and could be poisoning the human gene pool Yet we are subjected daily to routine emissions of radioactive gasses from the nuclear plant at Lucas Heights!

Recommendation : That the Committee persuade the NSW government to carry out a thorough health study of the communities around the reactor site, using, amongst other tools, hospital records. It should attempt to check death records of all people who have lived in the area since the reactor was commissioned in 1958. The Commonwealth government should fund this.

It is impossible to obtain insurance cover against a nuclear accident

Commercial insurance companies will not insure against radiation or nuclear accidents because they " would not have enough funds to cover claims " . In the event of such an accident individuals would have to make civil claims against the Commonwealth Government. The NSW Government and the local Council may also be liable for damages and their position with regard to Workcover is uncertain.

Following the report of the RRR in 1993, we contacted the NRMA Insurance once again, advising it that the reactor and its operation was considered quite safe. Would it be willing to reassess its position and offer us insurance? The answer was exactly the same. No.

During the Senate Select Committee on the Dangers of Radioactive Waste in Australia, we raised the matter of lack of insurance. Some of the Senators, in their wisdom, compared this standard exclusion from all insurance policies as being merely one of a list of such exclusions. However we disagree in that it refers to one particular industry. No other industries are treated in this way. There must be something about the nuclear industry that over-rides normal commercial considerations. However, it must be said that the insurance companies are not willing to take risks with their own money - it spite of "expert" opinions.

Recommendation : That the Commonwealth government provide insurance cover for personal injury and property loss (including loss of property values and social disruption) in the event of an accident at the reactor site which has off-site consequences. This would eliminate the need for individuals to take the government to court in civil proceedings. Remember the "Voyager" and "Agent Orange" cases.

Safety at and around the site

ANSTO maintains that "the existing reactor has operated safely for almost 40 years since it was commissioned in 1958." It also states that "safety inspections of the reactor are carried out on a regular basis and have shown it to be in excellent condition.".

On the contrary there have been many examples of safety lapses recorded over the years. Some of these are set out on attachment B. Most involve human error as would be expected in any industrial operation. The overseeing body relating to safety is the Safety Review Committee which reports annually to the Minister. However it has no teeth, only the power to recommend. This may improve with the impending regulatory body, already more than four years in the making but there is no public indication of its content at this stage.

Lucas Heights a potential disaster area

In 1994 and 1997 disastrous bushfires struck the area. In the most recent calamity Barden Ridge, the suburb closest to ANSTO, was evacuated at the height of the fire. Eleven houses in the next suburb of Menai were destroyed. At the same time the ANSTO staff were locked in, unable to telephone their families. The official reason was that staff were held back on police advice. For several days the only road connecting the site was blocked to through traffic.

The road system which connects the ANSTO site to Menai, Bankstown and Sutherland at one end and to Liverpool and Engadine at the other is renowned for it traffic jams in normal traffic situations. In the event of an emergency evacuation of the local area, it would be impassable.

When the incongruity of having Australia's only nuclear reactor in a disaster area was pointed out to the Minister for Science, he replied that having the " facilities of ANSTO nearby was an asset!". Such insensitivity could only come from a member whose electorate is 1100 Km from this area and is a response that is rejected by the local community.

Emergency planning and local awareness

The emergency plans for the site relate to events which occur within the perimeter fence. ANSTO has responsibility for this area. If the consequences of an accident extend outside the fence then it becomes the responsibility of the NSW Emergency Services organisation. ANSTO's role in this would be to offer advice. Following years of public demands for information on what to do in the event of an emergency a simple brochure was provided to several thousand nearby homes. The timing of its release and the method showed incredibly bad planning.

It was placed in 20,000 letterboxes two weeks before Christmas 1995, the height of the junk mail drops! Was it meant to go directly into the recycling bin? A copy of it is attached, along with our response. The emergency leaflet took the combined brainpower of the chiefs of the NSW State Emergency Services and ANSTO at least 18 months to put together. In conversations with the ANSTO Communications Manager, Mr John Mulcair, we have been informed that an updated and improved version will be released "soon". Considering that it took 37 years for the first, pitiable, version to appear we are not tremendously enthusiastic about a second.

Our main concerns are:
  • The lack of pre-event training as prescribed by the NH & MRC in 1990. This is the responsibility of the NSW Health Department but is non-existent.

  • The lack of knowledge and training in local schools where, rather than evacuation, containment indoors for an unknown period of time would be the first phase of an emergency.

  • The enormously high level of radiation which would be allowed (NH & MRC advice) before evacuation "would be considered". In fact it is evident that the senior emergency planners at ANSTO totally discount evacuation ever being necessary.

Two years after the leaflet we are no nearer to having satisfactory answers to these questions.

The reactor as a potential target for terrorists

In 1990, at the time of the Gulf War, several sites around the country were designated by government as being potential target for retaliation by terrorists. Amongst those named were the national airports and ANSTO.

Because of this, security was said to have been upgraded where necessary. This was raised at the Senate Select Committee on the Dangers of Radioactive Waste in Australia. Fortunately the worst fears were not realised.

At the moment history is in the process of being repeated and, once again, Australia has offered its support to a US planned strike on Iraq. As soon as the Prime Minister's announcement of Australian assistance, residents began to 'phone the Centre for advice. There was little that we could offer except that we hoped sense and negotiations would prevail on all sides. The question which this Committee must address is whether a nuclear reactor, seen as a prime target for terrorist attack, should be sited close to a large and growing population.

In today's world of high explosives made from common fertilisers and the ready availability of launching weapons, the very visible white containment shell would make a perfect target, impossible to miss. But the security services provided by the Commonwealth Police on site would be enough you might say. Is it? I can provide an example of its deficiency to the Committee but it would have to be given in camera.

The Precautionary Principle

Its use, alas, has never been a prominent feature of the nuclear industry anywhere in the world. One might say that, in 1958, the site of HIFAR was chosen specifically because it was in a remote area well away from Sydney's small population. There is no excuse for ignoring it in 1998.

Alternative Technologies to Generate Neutrons for Medical, Scientific, Mining, Industrial and Other Uses

As I write, I am looking at the front page of the local newspaper "The St George and Sutherland Shire Leader" - affectionately shortened to "the Leader", dated 12 February 1998. Its headline is,

Well done again, St George
New Cancer Breakthrough

There is a photo of Dr Barry Allen peering through a row of laboratory glasswear followed by the story of his team's production of an artificial radioisotope particle which can be sent into the body to track and kill cancer cells.

The particles are alpha-emitting radioisotopes which, as Professor Allen explains, cannot be obtained from a nuclear reactor, such as the one at Lucas Heights. He should know because he was a chief research scientist with ANSTO for many years. To get them, his team, working "on limited grants", collaborated with the University of Geneva and had it made on a high energy accelerator there. It should be noted that these radioisotopes are designed to save lives rather than as the majority of those produced by HIFAR which are for diagnostic use.

Professor Allen has questioned the decision to build a replacement for HIFAR, describing it as being a step into the past and that a new reactor may well be the last of its kind ever built. As Director of the St George Hospital's Centre for Experimental Radiation Oncology, also said that the $300 million reactor will have little impact on cancer prognosis, the major killer of Australians today and that anticipated developments on functional magnetic resonance imaging may well reduce the future application of reactor based nuclear medicine.

He also asked whether the Australian Science, Technology and Engineering Council (ASTEC) had reviewed the arguments presented to the Minister for Science by ANSTO which led subsequently to the decision by Cabinet. His opinion was that a major factor in the decision, was that pushed by the Department of Foreign Affairs and Trade, that our seat on the board of the International Atomic Energy Agency depended on us operating a nuclear reactor. If this is correct, then it will be one of the most expensive seats in history!

Recommendation : That the Committee contact Professor Allen and get his informed opinion on the matter.

Alternative Technologies - are they available?

Much has been written on this subject since the report of the RRR. Following that report and the visit to Australia by Dr Manuel Lagunas-Solar it was expected that the Commonwealth government would have directed an independent study into alternative technologies. However it did not happen and, once more, all advice was provided by ANSTO which did not wish to sink its chances of having a new machine, whatever the cost to the nation.

A detailed study has been completed very recently By Dr J. Green of Wollongong University, who we believe will be making a submission to this Committee. Whilst this Centre does not have the expertise to present the full case for the alternative technologies we are able to offer some references to experts in the field

An Investigation into the technical feasibility of Cyclotron production of Technetium 99m

By Gary Egan, Cyclotron & PET Centre, Austin Hospital, Melbourne
Chris Jamieson, National Medical Cyclotron, ANSTO, Sydney
Manuel Lagunas-Solar, Crocker Nuclear Laboratory, University of California, Davis, USA

Here are some interesting extracts

" The fission production technique has been employed by ANSTO for over 20 years, resulting in the accumulation of long lived High Level radioactive waste estimated to exceed 370 Tbq. This is a substantial quantity of High level radioactive waste and necessitates the identification and establishment of a high level waste repository, as recommended by the Reactor Review Committee.

Production of the equivalent quantity of Mo 99 via the neutron activation technique would have produced significantly less (<5%) high level waste."

"Expansion of Australia's accelerator infrastructure and expertise will provide many new scientific and commercial opportunities. These opportunities will not be available if Australia makes a much greater investment in nuclear reactor technology. If Australia had chosen nuclear energy for domestic and industrial electricity needs it would have been essential to maintain a research reactor capability in the country. However, the decision not to implement nuclear energy requires that Australia and Australian scientists pursue new scientific and industrial technologies. Accelerator technologies and, in particular cyclotrons for medical radioisotope production, provide an immediate new direction."

The authors of this paper acknowledged the valuable advice given by their colleagues who included: Dr Henri Tochon-Danguy of the Austin Hospital and Cyclotron Centre, Melbourne; B. Barnes and N. Woods from the National Medical Cyclotron, Sydney and Drs C.M. Castaneda and Zianzhou Zeng from the Crocker Nuclear Laboratory, University of California, Davis, USA. All these people are at the cutting edge of cyclotron technology.

Development of Cyclotron Technologies for Medical Radioisotope Production

In the paper prepared by Dr Gary Egan for the conference "Nuclear Science and Engineering in Australia 1995" the following extracts are worthy of your attention.

Referring to the production of medical radioisotopes " However, many other radioactive waste products are produced from the fission (Reactor) production technique with typically 20 times more high level waste produced than the desired radioisotope Mo 99 . This is directly in contradiction to ANSTO's professed aim of waste reduction.

In his conclusions on the feasibility of cyclotrons as an alternative to reactor production of medical radioisotopes - particularly Technetium 99m which is currently used in 80-90% of all nuclear medicine diagnostic processes - Dr Egan estimates that:

"If the current estimated yields of proton induced, neutron spallation produced 99 Mo are accurate , a single domestic production facility has the potential to satisfy demand for Technetium 99m throughout Australia. One High Energy cyclotron located in Australia would also have the capacity to supply the major cities of south east Asia"

"In Australia it is timely and important to consider the future of medical radioisotope production methods. Application of these new developments in cyclotron technologies may provide a new and practical method of reliably producing 99 Mo- 99m Tc generators."

Accelerator Reactor Hybrid Systems

At the same conference, Dr J W Boldeman, a senior scientist at ANSTO made some interesting comments on the comparison of reactor technology with that of accelerators. Amongst them were:

"Spallation neutron sources have been competitive with research reactor systems for neutron beam research for the last 15 years. The possibility of using spallation sources for many other applications has been discussed for at least 30 years but implementation has not followed, partly because of limitations in the performance of accelerators and partly because of the capital and/or running costs. This no longer applies and there are a number of serious proposals to construct new varieties of spallation facilities which have a much higher probability of coming to fruition.”

Later, in comparing spallation sources with reactors when used for condensed matter studies he describes a spallation unit as being "fractionally superior in performance to that of a 10 MW reactor. In fact it is not unlike a 15 MW reactor, which is not surprising as it is used in a similar way. The only exception is for applications involving cold neutrons where the dc spallation source significantly outperforms both a 15 MW reactor and AUSTRON............ It is relevant to note that the accelerator driving the dc spallation source is much simpler and less expensive in design."

Why then does ANSTO concentrate its priorities on a replacement reactor? The answer may lie in the final two sentences of Dr Boldeman's paper. " Some studies of such facilities were started in the 1960's although they did not proceed very far . It would be interesting to evaluate the prospects for radioisotope production in a modest spallation source."

Even if we take into consideration the enthusiasm of experts working in the field of cyclotrons and spallation, their arguments in favour of this technology are compelling. ANSTO's push for a replacement reactor is based on dubious arguments, many of which were dismissed by the RRR. However, as the chief advisor to the government, ANSTO always has the ear of its Minister and his advisors. Would those scientists who are employed by ANSTO - which owns and operates the Sydney cyclotron - be willing or able to present an alternative case to your Committee?

Recommendation: That the Committee urgently contact the authors of these papers as well as the persons mentioned in the acknowledgement to obtain their first hand views.

The Safety, Cost, Viability and Effectiveness of Alternative Technologies such as Cyclotrons, Spallation Sources Compared with the Long-term Commissioning, Operation and Decommissioning of a New Reactor

We will deal with these matters briefly but may be able to point the Committee in the right direction so that it can use the vast resources of the Parliamentary Library plus the efforts of it many research staff. Please take into consideration that much of this work was carried out by the Research Reactor Review in 1992/3. For some 8 months it gathered together facts, opinions and ideas. Its members travelled the nuclear establishments of the world seeking wisdom and the result was the report "Future Reactions".

The terms of reference of the Review included:
    1. Whether, on review of the benefits and costs for scientific, commercial, industrial and national interest reasons, Australia has a need for a new nuclear research reactor, and

    2. A review of the present reactor, HIFAR, to include an assessment of the national and commercial benefits and costs of HIFAR operations, its likely remaining useful life and its eventual closure and decommissioning.
    This review was the only one in the history of the Australian nuclear industry in which almost all of the evidence was available to the public and is still openly available for research purposes. Noticeably, since 1993, all discussions relating to a new reactor have taken place well away from public view. The public have no information regarding revised regulatory legislation, alternative site selection processes, what the national radioactive waste repository will be designed to hold or the results of the Probability Safety Assessment of HIFAR.

    Costs surrounding the existing reactor and its replacement

    The economics of ANSTO's operation as the figures were presented to the RRR brought forth a remark from Dr Tor Hundloe, the committee member most qualified to understand them, " that is, if we ever get to the bottom of them!" Section 11.6 of the report attempts to present the conclusions. On page 142, 11.7 the difficulties become apparent.

    11.7 Even with appropriate refinements of the figures in the cost-benefit submissions made by ANSTO, but adding in the costs of decommissioning and waste disposal, an economic analysis of the balance of benefits over costs is not positive, unless high values are arbitrarily assigned to the science and national interest components for either HIFAR or a new reactor.

    So what can we establish from the crumbs of information which the government is willing to pass to us?

    ANSTO states that a new nuclear reactor "is expected to cost in the vicinity of $300 million". In probability it will cost far more . Actual reactor costs have often shown to greatly exceed estimates. For example, the estimated $130million for Indonesia's RSG-GAS reactor blew out to $580million.

    Costs for decommissioning all three Australian reactors need to be factored into the analysis. The cost of decommissioning HIFAR is estimated to be around $70million and cost of decommissioning a new reactor would probably be comparable. ANSTO has no funds allocated for decommissioning. This additional funding would be provided from the public purse by the government.

    Costs for waste "management" include $90million which has been put aside by the federal Government for reprocessing ANSTO's existing spent fuel rods overseas.

    Reprocessing fuel rods from a new reactor would be an on-going expense and ANSTO is proposing to continue overseas reprocessing as its main option. Alternatively, building a small radioactive waste reprocessing plant in Australia would cost around $90million based on ANSTO's own estimates.

    Then there is the cost of a nuclear waste dump which must be considered. The 1993 McKinnon Report recommended that a dump for High Level waste be built. Although there has been no estimate of costs for a dump in Australia - and the government denies that one is needed - one US estimate suggests $17 billion for a single deep underground repository. This included $11 billion for studies and research into the suitability of the site. In the UK $750 million was spent for research into a deep underground radioactive waste dump at Sellafield, before the proposal was finally shelved!

    For the past 17 years and more seriously for the last four years, a search has been going on for a national dump to take Low Level and short lived Intermediate Level waste. The Department of Primary Industry and Energy has refused to give even an estimate of the cost until a site has actually been verified. Based on European studies it could cost up to $200million.

    Our nuclear experts say that there is no reason to hasten any decisions. Leave them for another generation of scientists and politicians to sort out. This passing on of the responsibility should not be acceptable to this Committee.

    Social and environmental costs of a new reactor must include consideration of the environmental and health costs to the community, as concluded by the Research Reactor Review . This includes the cost of sickness, death, genetic abnormalities, loss of property values in the event of an accident, contamination of the atmosphere and waterways and the impact of long-lived radioactive waste on the environment. Sadly none of these issues have ever been studied by the government departments which have a duty of care to the community.

    No insurance is available to the public against a nuclear accident.

    A third reactor is unlikely to bring economic advantages

    The existing reactors have been unprofitable, costing taxpayers in the order of $65m each year in subsidies. Overseas research reactors have not proved cost-effective. For example, two DIDO (HIFAR-type) reactors at Harwell were closed in 1990 purely on economic grounds.

    ANSTO uses the isotope market of south-east Asia to argue that a new reactor will bring economic benefits. However, "The developing markets for radiopharmaceuticals in Asia are likely to be captured by the large, aggressive and integrated American and European radiopharmaceuticals companies. ANSTO is starting from a very low base, and does not appear well-positioned to enter foreign markets. If anything, it may find itself fighting to defend the domestic market."

    The current financial crisis in the south east Asian area would appear to have dashed even the most optimistic of ANSTO's forecasts.

    In any case, overseas isotope suppliers are developing dedicated production reactors which will enable to them to produce isotopes more cheaply and efficiently than Australia could. Canada, the world's largest supplier of medical radioisotopes is building two dedicated reactors - for a total cost of $140 million! Add to this the fact that there is a world glut of technetium 99M, the most commonly used isotope for diagnosis.

    ANSTO states that its staff bring economic benefits to the local community. This would not change if ANSTO was developed into a non-reactor based science and technology park. It could research the science of ultimate disposal of radioactive waste which is an international problem of the highest order. Synroc could be brought into the practical rather than the theoretical field with an increase in staff working on it full time rather than on a casual basis.

    ANSTO estimates that " 800 jobs will be created during the construction phase of the project, with more than half the expenditure on the new reactor to occur in Australia. " . At a recent Senate Estimates Committee meeting, ANSTO's Executive Director was unable to justify this figure saying that " the job estimates had been arrived at by parties other than ourselves".

    ANSTO suggests that half of the $300 million for the new reactor would be spent in Australia which is another way of saying that upwards of $150 million will be spent overseas. Investing $1 billion in alternative and sustainable energy, research and the health industry would create many more jobs and be more cost-effective than investing in a new nuclear reactor. ANSTO itself has stated that a new reactor would employ fewer people than the existing reactor!

    According to Professor John Stocker, former head of the CSIRO and now Australia's chief scientist "Any decision (for a new reactor) should be on rational economic and national benefit grounds" and "For the foreseeable future the direct commercial returns appear unlikely to justify the investment in a new reactor and alternative means of supplying research and commercial needs may be more cost-effective."

    More recently during a discussion group on ABC Radio National's Science Show, Robyn Williams asked Professor Stocker how he saw the scientific emphasis in Australia in the year 2020. His reply was that the environment would most certainly be at the centre of all science at that time.

    In a climate of stringent economic control and financial cut-backs to many social services, the enormous cost of a new nuclear reactor cannot be justified. A wiser course would be to fund a broader range of scientific and technological projects.

    Recommendation : Now that an area for the national waste dump has been selected from the eight suggested by the NRIC - the Woomera option - an estimate of its cost be obtained from the Minister and that it be made public. It is beyond belief that such an undertaking be started without some idea of its cost.

    Recommendation : That the Committee investigate the question of the "co-location" at this site, of the long lived Intermediate Waste which will return from Dounreay. Will it be yet another "interim measure"? If so, how long is it envisaged to stay at the site? How would it be stored? Above ground and retrievable or below ground? What are the estimated half lives of the contents of the concreted wastes? Note: some of these decay naturally but then transform into elements with extremely long lives. Has deep underground permanent disposal been considered" If not why not?

    Recommendation : That the Committee investigates the cuts in government funding to scientific, medical and industrial research and development over the past two budgets and compares these with the costs which are being and will continue to be incurred to run HIFAR and any replacement. That it makes an estimate of any job losses which have taken place due to funding costs.

    Recommendation : That Professor Stocker be consulted and his opinion be asked about the cost/benefits of this proposal. (It could be the first time he has been asked.)

    Has the Government satisfactorily addressed the issues raised anconditions imposed by the 1993 Research Reactor Review in the context of the decision to proceed with a new reactor at Lucas Heights?

    The Report

    In August 1993 the report of the RRR, Future Reactions , was released. In its overview were some very blunt findings. These included :
    • "Unless a reactor, whether the current HIFAR reactor, or any prospective new one, is considered sufficiently important for scientific purposes and in the national interest, to justify continuing government financing for its capital and a majority of its running costs, it would not be viable."

    • "There does not appear to be any prospect of commercial and industry equity capital."

    • "A complete cost-benefit analysis of the case for a new reactor cannot be done because of the inescapable arbitrariness of the financial values put on the national interest and benefits from science aspects. Economic evaluation is not possible if major benefits or costs cannot be measured in any meaningful way."

    • " The scientific effort based on the current reactor cannot alone carry the case for a new reactor. At present, even allowing a reasonable value for the scientific effort and adding in commercial revenue possibilities, the case for a new reactor is left crucially dependent on the value attributed to the national interest."

    • The Government ........... has taken a strong view on the importance of the national interest. Consequently it might want to make a positive decision........ for the same reasons and in the same way as it does for defence and other national interest issues........"
    Some of these matters have been discussed earlier in this submission . We believe that the government, on the advice of ANSTO, has not carried out a thorough and independent investigation of alternatives to reactor based research or production of radioisotopes. Neither has it made any effort to put in place a long term policy for the reduction of radioactive wastes, their long term management or, more importantly their ultimate disposal.

    One recommendation made by the Review, was that ANSTO take the lead in developing nuclear waste disposal techniques and offering its expertise to assist other countries. We concur with this and suggest that it would provide worthy employment for much of ANSTO's scientific staff for at least the next 50 years.

    It could be carried out without the need to produce the waste which it has not been able to come to terms with over the past 40 years and for which it has no coherent plan for the next similar period.

    The Conditions

    In Future Reaction the Review set down what it described as a number of onerous conditions which needed to be met before a positive decision on a new reactor could be made. It said that " if any of these onerous requirements is not met, either a negative decision or a decision to delay further would be indicated ". The present Federal Government has ignored some of these conditions totally, using the usual excuse that the report was only a guide to the government in its decision making process. A summary of the conditions is set out below.

    Condition 1: That a high level waste site has been firmly identified and work carried out on proving its suitability.

    The first attack by ANSTO in its campaign that "the RRR got it wrong" was to declare that Australia does not produce any high level waste and that it is only produced from power reactors. This is an example of the nuclear industry's way of reclassifying waste - always to a lesser level. However Professor McKinnon and his team correctly identified ANSTO's spent fuel rods as high level waste.

    When the radioactive residue which will result from the reprocessing of Australian fuel rods is returned, it is of such a nature that it is clearly identified by the US Department of Energy as high level waste . Our experts have persuaded the government that it is merely long lived intermediate level, which makes it sound more innocuous. However its management and, if we ever reach that stage, ultimate disposal, is the same as for high level waste.

    ANSTO also holds an ever-increasing stock of liquid waste which arises from the production of radioisotopes. This was described by the Canadian Atomic Energy inspection team which surveyed ANSTO's operation in 1990, as high level waste.

    Because our Federal Government has conveniently ignored this recommendation - and that of the report of the Senate Committee on the Dangers of Radioactive Wastes in Australia - and has only continued with its search for a waste dump for low and short lived intermediate level wastes it faces the inevitable "interim" or "temporary" storage situation. In our submission to that Senate Committee we asked if the these terms could be quantified. Ten years, fifty, one hundred, five hundred, a thousand? We were unsuccessful in our request.

    So, not only has this first onerous condition been ignored, the government has decided to go ahead with a new reactor in the knowledge that there is no long term policy to deal with our high level or long lived intermediate level waste.

    Conditions 2 and 3 related to: whether there was evidence that spallation technology can offer as much as or more than a new reactor. And, There has been no practical initiation of a cyclotron anywhere world-wide to produce technetium 99 m.

    This has been dealt with earlier in this submission but we wish to add that the RRR recommended that advances in accelerator technology be investigated during the five year delay. Dr Gary Egan of the Austin Hospital in Melbourne applied for a grant to carry out such a study in collaboration with Dr Manuel Lagunas-Solar of the University of California, an expert in the field of cyclotrons. The government rejected the request.

    At the Senate Select Committee on the Dangers of Radioactive Waste, Dr Egan said that $500,000 over three years would be sufficient to research the matter so that an informed decision can be made. The committee agreed, saying that it was a modest sum. At that stage of the inquiry they were looking at ways to reduce the build up of radioactive waste in Australia. Needless to say, this suggestion was also denied by the government and we strongly believe that it was because of the influence of the government's scientific advisors from ANSTO.

    Condition 4: That there is good evidence of strong and diverse applications of neutron scattering capability in Australian science, including many young scientists and a complex of industrial uses.

    This condition was brought about by findings from section 6 of the RRR report titled Science at HIFAR. Some of the blunt conclusions are worth bringing to your attention.

    "It is easy to acknowledge real ANSTO accomplishments but still have to ask the crucial question required by the Review's terms of reference. That question is whether the science at ANSTO is of sufficient distinction and importance to Australia to warrant the large investment for a new reactor. The Review is not convinced that is the case - at least not yet.

    A picture of a vibrant field of science, energised by young people excited by the challenges and opportunities, did not emerge. HIFAR is not at present and has not for many years been the focus of scientific effort equivalent to that evident in several other scientific fields.

    The Review was not even convinced that (reactor based) science has been a major focus of ANSTO activity. The flowering of recent vigour might not be evident yet in publications, but at present the case for a new reactor on scientific grounds cannot be sustained, however compelling the need for such science."

    Has there been any improvement since the McKinnon Report? Our Centre is not in a position to pass comment here. However, in the April 18 1996 issue of Lucas Heights News , ANSTO's in-house magazine, union delegates were reported as having met with the ANSTO Board on Wednesday March 20, 1996 and raised their concerns about the depletion of nuclear expertise at ANSTO and the need for a training and recruitment program.

    Such reports do not fill local residents with feelings of assurance when they think of a the next forty years, at least of living near another nuclear reactor. One which will produce more waste than medical radioisotopes - will extend the period of time during which a major accident might occur - could contribute to health problems (including those due to added stress) - and all the reasons given in the first section of this submission.

    Condition 5: That the National Interest remains a high priority.

    To paraphrase Dr Samuel Johnson " Patriotism (National Interest) is the last refuge of a scoundrel". And it was here, in 1993, that the RRR had its major problem. What is exactly meant by National Interest? The Commonwealth Government, particularly the Department of Foreign Affairs, took a strong position on the importance of this nebulous term. It claimed that, without access to its own nuclear reactor Australia would not be able to sit at the tables of world power. The Review could see no evidence that permanent membership of the International Atomic Energy Authority (IAEA) was crucial to Australia's National Interest.

    It suggested that national nuclear expertise depends, in part, on the availability of people with operational, scientific and safety skills based on reactor operations and that ANSTO scientists are used by international atomic bodies which enables them to "influence the debate". In the end the Review concluded that the Government could put whatever meaning it liked on the term and that if it wanted to, could decide to build a new reactor for no other reason than National Interest.

    Your Committee will have the same problem to overcome and I do not envy your task. Whenever the reasons for a new reactor are argued they boil down to only three subjects. "Life saving" medical radioisotopes (ignoring the alternatives) - scientific research (of dubious value according to the RRR) and National Interest. As the case for the first two begins to fail then the protagonists, the scoundrels, fall back to their bunker position exclaiming National Interest.

    Recommendation : That your Committee consult Professor McKinnon and the other members of his team from the RRR and ask his opinion as to whether the conditions set out in his report have been met.

    Other recommendations by the research Reactor Review

    A Probabilistic Risk Assessment (PRA) be conducted to assess the remaining life expectancy of HIFAR

    The assessment will be carried out on the reactor core only and will not include the containment chamber or the question of off-site danger. Dr Garry Smith of Sutherland Shire Council is still on the planning committee but will have no part of the actual assessment. It is intended that The International Atomic Energy Agency (IAEA) will oversee the process but this is a dubious choice as this body cannot be regarded as impartial. Its main occupation is selling the "advantages" of nuclear power to under developed countries but omitting to mention the huge cost and unsolvable waste problem. At the same time, it is the body which sets down the world regulatory standards for the nuclear industry.

    Regulation of ANSTO

    The RRR pointed out - after urging from environment groups - that ANSTO operates in a manner inconsistent with the IAEA's international principles and requirements. ANSTO operates under an Authorisation issued by the ANSTO Board . The Review noted that current regulation was unduly fragmented and unclear and it recommended that a new body be formed which would have unambiguous and effective sanctions to apply to ANSTO to ensure that any conditions it imposed were met.

    The task of bringing Australian nuclear regulation up to international standards - after 38 years of operation - was given to the Minister for Health, at that time Dr Carmen Lawrence. The new regulatory body was to be known as the Australian Institute for Radiation Protection (AIRP). It would incorporate the Australian Radiation Laboratory, based in Melbourne and the Nuclear Safety Bureau but exclude the Safety Review Committee. Dr Garry Smith is a member of the latter body. The Shire Council has asked for a council representative on the new body because the reactor is situated within its boundaries. These requests have been ignored.

    Dr Lawrence's department undertook the task in total secrecy and, at the time of the change of government, there was no information available to the public. Details of the progress of the new regulator have been asked of the new Minister, Dr Wooldridge.

    In a letter received from the office of the new Minister for Health dated 5 July 1996 we were informed that "the government is yet to determine the nature of future regulatory arrangements" and that "the Government has not decided whether to proceed with the former Government's AIRP proposals"

    There seems to be some kind of a curse on the preparation of what should be a fairly simple set of regulations. Firstly, Dr Lawrence had problems in her portfolio, unrelated to her Ministerial duties. Later, Dr Wooldridge gave the legislation to his under-secretary, Senator Bob Woods, who later resigned his seat in parliament. Still, the regulations should have been put in place by the bureaucrats who, we understand, do all the work.

    Summary

    We believe that no logical case has been made by either ANSTO or the Federal Government for spending this huge amount of money on a project of dubious need for Australia's medical, scientific or national interest needs.

    That neither the onerous conditions nor many of the recommendations of the RRR have been met.

    That the costs of a new reactor far outweigh the fanciful and impossible to substantiate benefits which ANSTO and the former Minister for Science claimed to exist. Indeed, the Former Chairman of the AAEC Professor Max. Brennan, in a discussion on ABC Lateline last year, when asked about the $100 million which would flow to Australia via the operation of a new reactor, said that the figures probably came from "the same shonky areas of economics which usually invent such figures".

    That nuclear (reactor) science was seen to be cutting edge technology decades ago but that this is no longer the case. A new reactor would be a step into the past.

    That there are numerous areas of research, education and science which are much more worthy of government support than that of nuclear research. That the only worthwhile areas of nuclear research which the government should support are those of safe and final disposal of wastes from this irresponsible industry and those alternatives which do not use nuclear fission as an energy source.

    That the scientific expertise presently employed at Lucas Heights be harnessed to these tasks as well as that of renewable, non polluting, energy. A field which must have the highest importance in the next century.

    That the problems of wastes produced by the present and any new reactor will stick with us for centuries, some at a remote site and the rest permanently at Lucas Heights. The latter includes the two or three decommissioned reactors which will possibly be concreted in situ. Waste processing of spent fuel, rejected as a concept for political reasons is still a strong possibility in the near future. If so, where better to have the plant than Lucas Heights? There is nothing to prevent this. It could become Australia's Sellafield or Dounreay or Cape de la Hague. A place of pollution and bad health where staff may be told that, if they had concerns, they might choose not to have children.

    The Little Forest Burial Ground, across the road from ANSTO and permanently contaminated with radioactive and toxic materials, will not go away. Local people get sick but a health study is not warranted! And not carried out.

    The people have spoken, in the form of the ANSTO public attitudes survey, saying that they do not want an extension of the nuclear industry at Lucas Heights.

    That the decision to proceed with the building of a new reactor at Lucas Heights was made before the Probability Safety Assessment report on the HIFAR reactor has been made public. Indeed the Minister has suggested that the full report might be kept away from the public (and Local Council) and only the Executive Summary released - some time. Can your committee have this essential report made public? If not, a public statement as to why it is so secret should be made.

    Australia does not need a nuclear reactor at all. But if the government insists on going ahead then Lucas Heights is not the right place for it.

    Michael Priceman
    Convenor
    Nuclear Study Group
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