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Submission to the Inquiry into the Management of Nuclear Waste in the United Kingdom

Preamble

You may be wondering why an Australian environment group, 20,000 kilometres, away should be making a submission on what is most certainly a matter - and a dilemma - for the UK Government. The first reason is that our Sutherland Shire is the host to Australia's only nuclear facility which has been operating for the past 40 years. As such we have had the opportunity of watching, with increasing dismay, the way our nuclear "experts" have dealt with its small but ever increasing quantity of nuclear waste.

The second reason is our unfortunate connection with your reprocessing plant at Dounreay in Scotland. The name of our Shire would be familiar with the folks of the north of Scotland even if we were not sending our spent fuel to them.

Historically the HIFAR reactor was presented to us in the late 1950s, probably as a "gift" for allowing British nuclear bomb tests to take place on Australian territory. The outcome of those tests is on record. Maralinga is a wasteland which, after many years, is now being partially cleaned up - at a great, but not full, cost to the UK Government. It will never be fully habitable. Also the timely report from the University of Dundee has shown that there is a high rate of birth defects in the grandchildren of British servicemen who were present at the Maralinga tests.

Australian servicemen who were also at the tests will be watching the response to the report from the British Government. Their representatives have already asked the Australian Government to carry out a similar survey. The immediate reply from our Minister was that such a survey "would be premature". After 42 Years!

This submission will not enlighten your Committee as to how to manage the wastes that your large civil and military nuclear industry has created and continues to create. I wish that it could. It might however give you an indication of how the effects of the waste from one small reactor can cause an enormous problem for which this technologically advanced country will not or cannot take responsibility.

Definitions and Time Scales

Whenever nuclear waste management is mentioned the terms "interim", "short-term" "temporary", "not permanent" and, more honestly, "timing uncertain" are used. These are expressions used throughout the industry and most certainly here in Australia. In 1992, at the Research Reactor Review (RRR), referring to the waste presently held at the Lucas Heights, Sydney, nuclear site, Professor Parsons of the Australian Ionising Advisory Council said , "Whilst the existing storage of waste might go on for 40 or 50 years we have got to come up with some solution for the permanent management and disposal of High Level waste.......something that does not need supervising for 100,000 years". Apart from this plea he was unable to give any substantive advice.

As our waste has been accumulating since 1958, Professor Parsons is admitting that "short term" means about 80-100 years, at which time the industry may have come up with a solution acceptable to government, the wider scientific community and to the Australian people. No other industry would be allowed to create such a situation in a responsible society.

Sustainable, long term management

The use of the word management implies that permanent, safe and final disposal methods are not expected in our lifetime. Much time and massive amounts of money have gone into researching the permanent deep geological burial of High Level radioactive wastes. The tunnel system at Yucca Mountain in the USA was almost ready to be the world's first permanent disposal site when it was down-graded to an "interim" storage site. A similar situation occurred at Sellafield except that it was called off before construction took place. It is obvious that even the most dedicated supporters of the nuclear industry are not intrepid enough to sign their names to a "permanent" solution.

If long-term management, as opposed to permanent disposal, is your aim then the only suitable and sensible method is above-ground, dry, retrievable storage. In fact this would mean that the waste would be accessible if and when a technical method of safe disposal is ever found. It is my lay opinion that this may never happen.

Is there adequate knowledge to support my proposal? Probably, but the next question which would have to be asked is, what is meant by long-term? For further technical opinion may I suggest that you contact:

Dr Kristin Shrader-Frechette
Distinguished Research Professor
Department of Philosophy
University of South Florida
4202 East Fowler Avenue, CPR 107
Tampa Florida, 33620-5550 USA

Professor Shrader-Frechette is a member of a Blue Ribbon Panel, the US equivalent of a Royal Commission, evaluating sites for the possible storage of Intermediate level radioactive waste in the US. I attach a copy of the brief submission which she made to an Australian Senate Select Committee on the Dangers of Radioactive Waste in Australia.

Site Selection Process

Australia has been vaguely interested in setting up a repository for Low and short-lived Intermediate rad. waste since 1980. The lack of urgency may be due to the advice from the former Australian Atomic Energy Commission (AAEC) and the Australian Nuclear Science and Technology Organisation (ANSTO), which superseded it in 1987. These are the government instrumentalities which have operated our reactor since its commissioning and which have overseen the accumulation of waste at the reactor site. Their advice was that there was no hurry to take action and that everything was under control. This tardiness became public in 1992 during the Research Reactor Review when it was realised that Australia had a High Level waste problem which had to be fixed.

In 1992 the Commonwaealth Government issued a discussion paper A Radioactive Repository for Australia: Methods for Choosing the Right Site. Public comment was sought and by 1994 a second paper was released, Site Selection Study - Phase 2. I had intended to send you extracts from this report but I now realise that it is copyright. However I will ask the relevant authorities to send you a copy. The project is being carried out by the National Resource Information Centre which is a branch of the Commonwealth Department of Primary Industries and Energy, PO Box 858, Canberra ACT 2601.

At a recent seminar in Sydney on nuclear matters, an officer of the Department said that to overcome the inevitable and understandable NIMBY effect, the survey had looked into every backyard in Australia. The Phase 2 document shows the methods and the criteria used to produce the eight regions deemed to be suitable for a site. The criteria included geological and hydrogeological stability; stable climatic conditions; seismic, tectonic and volcanic activity; low population with little chance of population increase; groundwater; a geology which would not allow migration of radioactivity off site; no known mineral resources or potential for agricultural development; reasonable access for transport; the location to have no cultural or historical significance or to be subject to ownership claims.

The next stage is to choose the 'best" out of the eight regions and then select the actual site for the repository. This process was to be announced by the end of 1997 but so far there has been no public announcement. When it does occur, the Department will first need the approval of the State or Territory Government. It is interesting to note that none of the State Governments has volunteered a site although the New South Wales Government has stated that it "will not co-operate with the Commonwealth if NSW is selected". If and when the Commonwealth gets the necessary State approval it will then have to sell its plan to whichever local community is closest. If that community rejects the plan then the government will have to decide whether to impose it or not, against the wishes of the people.

The whole subject is confounded by the issue of what to do with spent fuel from our reactor. After doing nothing for 36 years and suddenly realising that its storage space was almost full, a decision was made to send a batch to the UK (Dounreay) for reprocessing. This option had been available for many years but because of the high cost and the fact that the residual wastes after reprocessing would be returned to Australia it had been ignored. At first the news was that the wastes would not be returned for 25 years. Then it became 20 and soon it may well be "as soon as possible" if the Scottish EPA gets its act together. Such returns will be a major problem for Australia because it has nowhere to store it - and nothing is being planned!

As mentioned, the repository which is taking so long to establish is a near surface facility designed for Low and Short-lived Intermediate waste. The materials to be returned from Dounreay are classified by both the UK and, understandably, by Australia as Long-lived Intermediate. The USA prefers it to be classified as High Level due to the transuranics which it contains. Whatever the terms used, the management is the same. So what is being suggested? To "co-locate" it at the Low Level site for the next 50 years or so - until something turns up!

Acceptable Risk and Intergenerational Equity

The term "acceptable risk" should be examined and the question asked, acceptable to whom? If the risk is acceptable to the scientific community, with its own turf to defend, then it should be treated with scepticism. If acceptable to members of the House of Commons (or our own Parliament) then their time scale is measured only in political terms i.e. "A day is a long time in the world of politics". If the risks are seen to be acceptable to communities close to nuclear waste repositories because of economic reasons such as trade and jobs then one must ask whether they are considering their own descendants?

The assessment of risk will be carried out by scientists within and without the nuclear industry. Their assessments will be over-optimistic and will support their mathematics which are based on today's knowledge. Their reports will be tidied up by the word-smiths and handed on to Government which will have responsibility for the final decisions. It will be those parliamentary decision makers who will be judged by future generations.

I suggest that those who make the decisions, somehow, be made to accept material responsibility should their predicted risk assessments be found to have been underestimated.

The short history of the nuclear industry is replete with evidence of ignoring or denial of any possible effects on future generations - most particularly in the field of its relationship with its waste. This in spite of high incidence of leukaemias close to waste reprocessing plants (Dounreay Sellafield, La Hague) or the example of the advice to male workers at Sellafield that "if they had any doubts, they might decide not to have children".

In Australia's nuclear industry there is little concept of intergenerational equity. The best that it can suggest is to store its High/Intermediate Level waste for the next 50 years or so and see whether the next generation of scientists can solve the problems which this generation has bequeathed. And this in spite of SYNROC!

SYNROC - Australia's answer to the World's nuclear waste!

SYNROC was created in the 1970s by Professor Ted Ringwood of the Australian National University. It is a synthetic rock or ceramic which is formed by melting together some common rock forming minerals. It was touted as being the answer to all the world's nuclear waste problems, especially High Level liquid waste. The development of SYNROC was taken up by the AAEC and ANSTO but, after two decades, there is no plant anywhere using the process.

ANSTO boasts of "continuing trials and co-operation in" a variety of countries and has set up a model plant at its reactor site. With typical Australian modesty it describes SYNROC as being "at least 1000 times better at holding radioactive elements than presently used disposal forms and can be buried immediately..." In spite of this the Australian Government does not possess the necessary confidence to fund a production plant within Australia but would prefer to see one built overseas. The obvious but unstated reason is that there is not enough waste here to justify a production plant here so it would need imported nuclear waste for it to operate economically. Such an action would not be politically acceptable to the Australian population.

An International Solution?

Many nuclear States have looked with envy at Australia's wide uninhabited spaces and dreamed of it as the world's nuclear garbage bin. That governments here, of all political persuasions, have rejected this as being unacceptable is understandable. That the same governments are quite prepared to send spent fuel to the USA - for permanent storage - or to the UK for reprocessing, displays an ambiguous and unethical attitude. It also ignores the United Nations Special Session on Sustainable Development, section 59, which deals with radioactive wastes. This states, in part, " In general, radioactive wastes should be disposed of in the territory of the State in which they are generated as far as is compatible with the safety of the management of such material".

ANSTO also ignores this in relation to the waste that it expects to generate from a replacement reactor. In a Notice of Intention it states that "the arisings of spent fuel from a replacement reactor .......will be essentially the same as those developed for the present reactor". This relates to storage on site for a period and then sending the fuel rods overseas for reprocessing, presumably to Dounreay if it is still open. Australia still will not take responsibility for its own waste but should be made to do so. The only practical way to do this would be for the international nuclear nations to refuse to accept waste from developed countries. They should also discourage under-developed countries from getting involved in an industry which produces intractable wastes.

Australia has often referred to a "regional arrangement" for nuclear waste disposal but has never offered its own land. I am sure that if one of our neighbours, with a high population and low standard of living, were to accept the lure of a long term steady income to store foreign waste then Australia would quickly agree. It could then tell the public that it had "finally solved its waste problem".

Summary
  1. Each country which has become involved in the nuclear industry, at whatever level, is now aware of the insurmountable problem of radioactive waste disposal. The US Department of Energy has agonised as to whether it should accept spent research reactor fuel rods from 16 developed countries including Australia, Germany and Japan. Another 24 countries, ranging from Bangladesh to Zaire, were also considered. The total number of fuel element was 22,700. The International Atomic Energy Authority must discourage entry into the nuclear club of any country which is unwilling or unable to deal with its own waste.

  2. Honest, quantified, descriptions of time scales must be used so that the public is aware of the size of the problem.

  3. Nuclear weapons countries - which have produced the greatest waste problem - must continue, for as long as it takes, to investigate a solution for the safe and permanent disposal of long-lived wastes. Any results should be shared with the rest of the world as a service to future generations. This should not preclude any non-weapons countries from also carrying out this research.

  4. Safe long-term management of existing waste should be seen as a priority but not as an end in itself. To merely rely on management and ignore a permanent disposal solution can only pass the problem into the far future. The half-life of Plutonium is 24,000 years. How many generations is that?

  5. There can be no "good" site for a nuclear waste dump so far as the general community is concerned. The UK is well aware of this following the protests in rural southern England in the 1980s. The recent selection of Sellafield, which was rejected, and, more recently, Dounreay, as a potential permanent dump site is an insult to those local populations. These sites were only seen to be satisfactory because of the environmental damage already done by the existing reprocessing plants.

  6. Risk assessment studies can only be carried out with the open contribution of local communities. Such communities must be provided with funding so that they may obtain expert advice from whatever source. Any assessment carried out behind closed doors by "experts" is worthless.

  7. The public will certainly opt for "as safe as possible, regardless of cost" if it is ever asked. Why should it settle for less? The implications are, that if the government cannot bear the cost, it must seriously assess whether the nuclear industry is cost effective - including decommissioning and the long-term management and final disposal of waste - and, if not, should it be allowed to disappear.

  8. Joint international research into nuclear waste is urgent and necessary. Joint international waste dumps should be outlawed.
Michael Priceman
Convenor,
Nuclear Study Group
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