SSEC logo Sutherland Shire Environment Centre  
shop

Submission to Environment Australia on the Replacement Nuclear Reactor Environment Impact Study

Introduction

This Draft EIS is most assuredly a proponent's document as was expected and as is allowed under the Commonwealth legislation which covers the EIS process. Legislation which the Minister agrees is twenty years out of date and which he will amend, for better or worse, as soon as possible after the ANSTO site problem is safely settled.

Its credibility is also destroyed for two reasons. First, because the decision to build a new reactor at Lucas Heights has already been made by Cabinet. We are not dealing with a proposal here but a decision. The Environmental Defenders' Office has deplored an increasing incidence of a government making a decision and then tailoring an EIS to justify it. This EIS is particularly brutal example.

Second, ANSTO is a government instrumentality and it is the government which has the advantage of making the law, acting as defendant, the prosecutor, the defence counsel, the jury and the judge. The local community, which has shown in separate opinion polls (83% oppose it) that it does not agree with the decision to impose another nuclear reactor here, is relegated to the gallery. They may watch but not say anything.

Yet in spite of this we have taken part in this flawed process. We have asked for an independent auditor, for funding to obtain outside opinion, for extension of time to deal with the mass of complex material placed before us. We have asked for public debates and for access to the scientific information being supplied to the proponent. Anything that would give a semblance to the Australian quality of fair play. All were rejected.

The community now relies on the integrity, insight and expertise of Environment Australia to cut through the dishonesty, omissions and half truths contained in the Draft EIS document.

Comment: In general the Draft is, due to constant repetition, difficult to follow. Subjects are not dealt with in a single section which would have made it for easier to understand Perhaps this was not by accident. Our submission has followed the order of the Draft and, for that reason, it may contain some repetition. For this we apologise.

Comments on various Chapters of the EIS document

Background to the proposal - Chapter 3

Overview of Nuclear Activities (Section 3.2.1 of EIS)

The Table 3.3 on pages 3-8 and 3-9 purports to provide an overview of the history of nuclear research activities in Australia but there are some glaring omissions. What was the AAEC doing during the period 1969 to1976? According to official publications around that time (Atomic Energy in Australia, vol. 15 number 3, July 1772 and vol., 15 number 4, October 1972 AAEC Annual Report 1975/6) the AAEC had both equipment and programmes in place for the enrichment of uranium for the extraction of plutonium from reprocessed spent reactor fuel and for criticality testing. These programmes, depending on government policy at the time, could be used either for commercial purposes or for the production of fissile materials for use in nuclear weapons. i.e. dual purpose.

During that time Sir Phillip Baxter openly advocated an Australian nuclear weapons programme, which, thankfully Commonwealth governments refused to take up. However the plant commissioned during that time is still. I believe, on the Lucas Heights site, albeit dismantled and kept free from corrosion. Doubtless, given a government go-ahead in time of regional disturbance they could be reassembled and the programmes restarted.

This may be a significant reason why the government does not want to examine alternative sites in Australia. However, should there be even the slightest possibility that weapons research is revived at Lucas Heights, then siting in a suburban area of Australia's largest city would be out of the question. There would be a return to the dark days of secrecy, the results of which are still evident amongst some ANSTO staff.

There would be a possibility of either terrorist or attack on the site from other sources. There would the inevitable damage to the environment and to the health of local communities which such operations have caused at such sites as Sellafield, Hanford. and Aldermaston.

The EIS should detail the equipment which it has on site which, on government instruction, could be used for weapons research and/or development. State whether it has been listed for examination by the IAEA. An opinion should be obtained by Environment Australia from the Nuclear Non-Proliferation Safeguards Office as to whether the retention of such equipment is detrimental to our position with the NNP Treaty. A timetable should be given for its scrapping. This would send a positive message to our neighbours on non-proliferation.

Bain/Battelle review (3.5.2)

The 1994 Bain International / Battelle Review of ANSTO's operations and its purpose in the scheme of Australian scientific life, was commissioned by ANSTO. It was neither public nor independent, being paid for by ANSTO. . However it did point out that since about 1984 "the central purpose of the organisation has not been clear. Activities have proliferated with no clear sense of focus or priority".

This was confirmed by the retiring Chairman of the ANSTO Board, Mr Ward-Ambler in the 1995-6 Annual Report (Page 9). He said that for twenty five years the government had made no long-term plans or decisions on the role the Australia should play in nuclear technology, either nationally or internationally. He also scared many people in high places by suggesting that Australia might carry out domestic conditioning of spent fuel, hinting an involvement in the ways to deal with wastes from Asian reactors (page 10 of the Annual Report)

That the Bain/Battelle review recommended a replacement reactor - contrary to the findings of the very public Research Reactor Review - was hardly surprising. After all it was paid for by ANSTO. The major objectives described in the Draft are simplistic in the extreme and certainly do not add up to the spending of $300 million to bolster up one small portion of Australia's scientific effort.

Senate Economics Reference Committee Inquiry. (3.5.3)

"The contents of key submissions made to the Committee were considered." This is a vague statement.

Which submissions were considered as "key" and to what extent were they considered? Those considered should be listed.

Commonwealth Regulatory Authorities. (3.6.4)

Nuclear Safety Bureau.

Congratulations! For the first time ANSTO admitted that it operates under an "authorisation", not a licence. And that the Authorisation does not carry the legal force of a licence nor was it up the standards of the IAEA. Why has this not been admitted either by ANSTO, the NSB or by their relevant Ministers over the past many years? At a conference in Sydney in September 1997, organised by the Australian Nuclear Association this was raised this but the criticism was strongly refuted by the representative of the NSB.

The Safety Review Committee.

This group is, at present, the only link between the oversight of ANSTO's operations and the public, in that it has, as a member, the Chief Environmental Scientist of Sutherland Shire Council. If the anticipated ARPANSA legislation passes through parliament without amendments, the SRC will be disbanded and replaced by the Radiation Health and Safety Advisory Council (RHSAC). It will not be required to present an annual report to a minister as does the SRC. That Council will merely provide advice to the CEO of ARPANSA which is a downgrading of the position held by the SRC.

Nuclear Research Reactors Overseas. (3.7.5)

Whilst some research has been carried out using HIFAR, its value was not seen by the RRR as being significant enough to justify its replacement. In fact HIFAR and any replacement would be more accurately described as a medium sized industrial production unit, used for the manufacture of radioisotopes, some silicone irradiation and some minor research. There is a dishonesty in the constant repetition that the majority of research reactors overseas are in urban or semi-urban environments. The majority of those said to be housed on university campuses are far smaller than either HIFAR or a replacement and none, to our knowledge, are industrial production units.

ANSTO should give details of reactors designated as "Research" which produce radioisotopes on a commercial basis, their proximity to residential housing and the size of that population.

Lucas Heights as a suitable site (3.8.1)

It acknowledges that neither the IAEA nor the NSB have a specified criteria for the siting of a reactor. To solve the problem, the details in Table 3.5 show the alleged site selection criteria for locating a reactor at LH. To get this, the government/proponent has merely listed a description of the LH site and found it to be suitable.

Amongst the problems with the list are:

Seismic conditions: there is no mention of the Newcastle earthquake which caused tall buildings in the Sydney CBD to sway. That event could not possibly have happened - until it did. Newcastle is only 160 Km from Sydney.

Under Health and Safety there is no mention of the severe bushfires which have struck the area three times in four years. Would regular, severe - and fatal - bushfire occurrences be included as part of a preferred site selection criteria?

Under Receptor Pathways, Geology, Sandstone substrata is seen as having a suitable underlying stability. Surely it is both soft and porous and therefore unsuitable.

Population Issues. No mention of public knowledge of Emergency Plans. For 38 years it was considered counter productive to alert the local population of any emergency plans. This will be dealt with further under section 11.7.4

Land availability mentions the buffer zone of 1.6 Km but does not mention the 4.8 Km zone in which growth and manufacture of food products, or "institutions" is excluded. Although, strangely, West Engadine school lies only 2Km from HIFAR.

ANSTO will claim that the 4.8 exclusion zone no longer applies but Sutherland Shire Council still maintains its exclusivity.

Several public opinion surveys were ignored in the section on public issues. Page 3-33 quotes twice from the McKinnon report which stresses that the views of the surrounding community be taken into account. This clearly has not taken place either by the government in making its original decision or by the proponent in the Draft. This omission will be dealt with later.

Emergency services availability issues were skirted here and this will also be mentioned later.

Costs for the project must surely be taken with some scepticism allowing that they are merely 1997 estimates based on 1992 estimates. Currently there have been no tenderers chosen and actual figures are not expected until the middle of next year. Half the estimated $286 million will be imports and the Australian dollar has depreciated sharply in recent times.

What is the current estimated cost?

Reference to the "alternative site selection process" said to have been carried out by the Department of Industry, Science and Tourism - with input from ANSTO - can only be seen as an artifice unless its content and selection criteria are made public. The Cabinet makes its decision, vital information is withheld from the public and is expected to accept it without a murmur. Trust us, we are your leaders and we know what is best for you. To say that it is Cabinet in Confidence is unacceptable. What can it contain to make it so secret? Perhaps it contains nothing at all!

It is interesting to learn from ANSTO (page 3-33) that $700 million has been invested in the Lucas Heights site over the past 40 years. Add the $300 for a replacement reactor plus the large but unquantified future costs for decommissioning three reactors, for a waste dump, for dealing with the spent fuel and well over a billion dollars is involved.

What has the AAEC and ANSTO achieved scientifically to justify this expense?

How has it added to national value?

Alternatives to the Proposal - Chapter 6

Consideration of Alternative Sites Away from Lucas Heights (6.8.1)

As mentioned in 3.8.1 above, the government has not provided any details of its alleged alternative site selection process. This section is merely a description of the Lucas Heights site and cannot be said to be a comparison of any alternative. However it does raise some interesting points, particularly in section F of table 6.6 on page 6-31.

At Menai Market Place information stalls were held by PPK and People Against a Nuclear Reactor (PANR) on 14 March. I attended and had a lively and very civil discussion with a young (thirtyish, holding a baby) scientist from ANSTO who defended his role at the LHRL. After a time he asked "Why would you want to move a new reactor to another site ( I had not suggested this) when Lucas Heights is already contaminated for the next 40,000 years. Would you want to duplicate this?" This took me aback. Even I would not have put forward such a statement in my objections to a new reactor. I accepted that his knowledge in the area of site contamination was superior to mine. He did not leave his name.

In section F, column three, A Remote Greenfield Site, it is claimed that "The hazards and risks associated with all aspects of the current operation of the Lucas Heights Science and Technology Centre would be transferred to the new site."

But we have read the Draft EIS and there are no hazards and risks. ANSTO says so for page after page after page.

Later on page 6.31 comes the admission that should another site be chosen then "In addition, many of the issues raised by some members of the community in relation to the storage, disposal and transport of waste and the perceptions of public risks of the new reactor would be transferred to the new site."

And that, as we have pointed out for some considerable time, is the reason that Lucas Heights is seen by the government as "the perfect site". Because it is there and no-one, even Premier Kennett wishes to have the doubtful honour of taking it away from New South Wales.

The references on page 6-32 that environmental investigations into other possible sites would take a minimum of 12 months and therefore delay the commissioning of a replacement, enforce our opinion that this EIS is being rushed through at an immoderate pace and, whatever its findings, the government will not alter the decision made on 3 September 1997. Because of this we can have no confidence in the EIS process.

Alternative Spent Fuel and Waste Management Strategies (6.9)

Spent Fuel (6.9.1)

There is no mention of the alternative of long term dry storage of the fuel from HIFAR, possibly at a national repository. This would avoid reprocessing either here or overseas, reduce the costs and hazards of transportation and have the spent fuel accessible so that, if and when the nuclear industry does discover a means to safely and permanently dispose of it, it will be available. Due to the life span of the radioactivity held in the spent fuel, the word "permanently" means in a geological time scale, many times longer than humans have inhabited the earth. A difficult task but until the situation is faced by both the government and the industry they will both carry on the pretence of "interim" storage and "management".

An alternative mentioned in Figure 6.2, page 6.37 is reprocessing and waste disposal in Australia. This is described as Not Government Policy. Surely this should read Not Current Government Policy. Is it core policy or non core? Governments and Ministers come and go and their decisions are just as ephemeral.

Long Term Storage at Lucas Heights Science and Technology Centre

This section raises some interesting points. The main reason that this is not seen to be either prudent or feasible is that it is not acceptable, politically, to the community at large or to the politicians and councillors in the area. The technicalities mentioned in the draft are merely to make the draft look better.

The second paragraph says that processing, reprocessing, conditioning of the spent fuel - all similar procedures - at a foreign plant is the most cost effective. But is it the safest? And can it be seen as disposal when the resultant waste, far greater in volume than the original elements but containing the same amount of radiation, will be returned to Australia for further "interim" storage?

The question of the HIFAR reactor, on site during its period of decommissioning, is not mentioned here in the Draft but certainly should be. From the time it is switched off to the time it is fully decommissioned, whatever the option used, it will be, most certainly, radioactive waste. Whatever plan is put into place after the initial cooling down time of 30 years the local community will be faced with several generations of waste storage on site. The option of encapsulating the core in concrete and leaving it permanently on site would completely reverse the government (and ANSTO) claim that Lucas Heights would not be used for long term storage of nuclear waste.

The reference on page 6-38 to community opposition to the permanent storage of spent fuel at LH is a misrepresentation. The opposition is to the long term/permanent storage of nuclear waste at LH.

Reprocess Spent Fuel Overseas

The final paragraph says that "another variation of this alternative is to reprocess the fuel in Australia, but, as mentioned above, this option is not consistent with Government policy."

This should be altered to "not consistent with current government policy".

Permanent Repository. The concept of the co-location storage facility for long lived intermediate level wastes (described as high level waste according to the US Dept. of Energy) resulting result from either local or overseas reprocessing, has never been fully explained.

How much radiation would be contained in the waste?

What would the radioactive materials be and what half lives would each have? (Remember that certain isotopes decay into others which have considerably longer half lives than their parent. Please give full details.)

How much long lived waste would be sent to the store which was produced by the HIFAR reactor, by volume and radioactivity? This includes all wastes returned to Australia following reprocessing.

Similarly, how much, per year, would be sent to the store produced from a new reactor?

When Senator Collins was in charge of the Department of Primary Industry and Energy, he boasted that the materials to be held in the low level waste dump "would decay to nothing in about 300 years". At that time long lived intermediate wastes had not been on the agenda.

How long would the long lived waste need to be stored there before it was deemed to be below detectable levels?

In addition, previous references to the co-location store were that it was to be for "interim" use. Repeated requests as to how long "interim" meant have been ignored. Now we read (page 6-38) that such a store, together with the waste repository, would "provide a comprehensive strategy for Australia's small inventory of radioactive waste". If the storage of long lived intermediate waste is only "interim" then how can it be seen as being a comprehensive strategy?

How long is it envisaged that long lived intermediate waste will be stored at the co-location store?

Page 6-39 contains another ANSTO understatement. It implies that Lucas Heights is only partly responsible for the production of radioactive wastes in Australia. Based on 1985 figures, 70% of such waste was produced at that time at Lucas Heights. It is likely that the percentage will have increased since then. When the wastes from overseas reprocessing are returned, that percentage will rise even higher, not merely in volume but in its radioactive inventory.

Physical, Biological and Social Context of the Proposal - Chapter 7

Biodiversity (7.2.2)

Under this heading it is interesting to note the references to the two most recent major bushfires in 1994 and 1997. Even allowing that there was no serious damage to the LHSTC it still is an incredibly strange area to site a nuclear reactor. The question must be asked, would Lucas Heights be seen as a perfect site if it was an area of natural bushland today? Most certainly the answer would be no.

Community Interest and Involvement (7.4)

Community Involvement in General (7.4.1)

The summary of community involvement has omitted the only group at which substantive discussion took place. At the urging of the then Minister for Science, Senator Chris Schacht, an ANSTO/Council Forum was set up and its first meeting was held on 12 December 1994. Those present were, for ANSTO, Mr Ward Ambler, Chairman of the Board, Professor Garnett, then Acting Executive Director, Mr Cameron, Director of Health and Safety and Mr Matthews, Union Representative.

For the Sutherland Shire Council were, Mayor Rankin, Councillor McDonell, Dr Gary Smith, Council Principal Environmental Scientist. The representative of the community was Mrs Rice from the Sutherland Shire Environment Centre.

The meeting was chaired by an independent facilitator and excellent minutes were taken by staff from the Department of Science Industry and Technology.

These meetings took place in this form until 2 May 1995. The meeting planned for 15 August was postponed and the next took place on 30 May 1996. During the time between the meetings there had been changes both in the Federal Parliament and in the structure of the Council and the first and most obvious alteration was the removal of the community representative from the process. Next, the minutes fell below the previous high standard. Finally the formal process became private chats.

ANSTO's Existing Community Consultation Programme

The community has been consigned to the local liaison group in which the ANSTO representative is the Communications Manager who handles public relations. This group has attempted to put together a Public Right To Know Charter for the past three years. Earlier this year the group thought that it had a simple ( 1 1/2 pages) but workable charter but at that stage ANSTO brought in its legal advisors, who I believe were attached to the Attorney General's Department. This action has brought the process to a standstill, to the great consternation and frustration of all the community participants and the facilitators, Negotiated Solutions.

The existence of such a charter several months ago would have greatly assisted the EIS process but ANSTO chose to delay its initiation. Whilst ANSTO is able to place top level legal obstacles to the charter, the community members have neither the expertise nor the funds to challenge the delays.

Community Attitude Surveys

This section mentions the two very limited surveys carried out during the Research Reactor Review by Roy Morgan and Reark. Both were based on focus groups and the participants were "led" rather than left to discuss the subject. Reark in particular appeared to overstep the boundaries of its task by making suggestions in its report such as ANSTO might benefit by altering the name of its establishment and remove the reference to "nuclear". Neither of these surveys carry much weight.

Bain International/Batelle Memorial Institute was commissioned by ANSTO to review its future operation. To include this in the Draft EIS as part of a Community Attitude Survey is yet another insult to the local community which was not consulted at all. Of 130 interviews, said in the Bain report to include environmental and community groups, one was with Friends of the Earth and another with two representatives of Greenpeace. Both well informed groups but which can not be seen as representing the people of Sutherland Shire.

The Keys Young Survey of 1997 was more representative in that it was quantitative in nature. But more of that later. Why was there no mention of the Neighbourhood Interaction and Participation Survey mentioned commissioned by Sutherland Shire Council in 1997 and carried out by BBC Consulting Planners? Page 15 of this report deals with concerns about the impact on quality of life.

Concerns about the HIFAR reactor ranged from 13% extremely concerned - 14% very concerned - 19% quite concerned - 24% a little concerned. Total 70%.

Concerns about a new reactor and reprocessing plant were 32% extremely concerned - 16% very concerned - 14% quite concerned - 15% a little concerned. Total 77%.

The existence of this survey was mentioned to PPK during its "information" day at Menai Market Place. Why was it ignored in the EIS Draft?

During the Research Reactor Review, requests were made to the Chairman for a public opinion survey to be carried out. As there was no response and we were unaware of the Morgan and Reark projects, the Sutherland Shire Environment Centre decided to do its own survey. In street polls we spoke to 414 local residents. The districts canvassed were Woronora, Oyster Bay, Sutherland, Engadine, Gymea and Bangor.

The survey was brief and, as with the Keys Young poll, showed some conflicting results. Awareness of ANSTO was high, 82% were quite/moderately aware. 49% said that medical research/medical isotopes were primary activities. 63% were of the opinion that Australia should be involved in activities involving the operation of a nuclear reactor.

However 55% were quite/moderately worried with the idea that a new reactor be built at Lucas Heights. The question "If there is to be a new nuclear reactor, where should it be located?" brought up the following result. 5% close to a major city - 4% a regional centre - 3% don't care. 25% said some distance from towns and 56% remote from development. A total of 81% opposing siting in a residential area. Another 7% wrote in Lucas Heights.

Details of our poll were also provided to PPK but again ignored. Which raises the question, what exactly was the PPK strategy ? Was it to provide a balanced, unbiased EIS document ? Or was it to get a positive result for its employer, ANSTO?

The Keys Young survey was conducted at a cost of $40,000 during the second half of 1996. Approximately 9 months before the announcement of the new reactor at Lucas Heights. As participants in its development we, and Keys Young, were told that the purpose of the poll was to assist ANSTO in its communications policy. Its timing led to its questions being asked in a climate of ignorance about the looming spectre of a new reactor at the site. In fact there was resistance by ANSTO when we demanded that questions relating to the siting of a new reactor be asked.

However, it was asked at question 16, although a close look would show some bias in the kind of answers respondents could make. Three of these related to "support" of a particular site, only one to "not support" and two "not sure" and "would not care". There was overwhelming support for locating the reactor at a remote location, very, fairly and somewhat. Sutherland respondents 83% - Liverpool/Bankstown 88% - other Sydney suburbs 78% and even Melbourne 75%. Results very similar to those obtained by the Centre four years earlier.

Strangely, the majority of Sutherland Shire respondents to question 20 said that drawbacks outweighed benefits for the Shire as a consequence of ANSTO's activities. The main benefit being employment 55%. Other perceived benefits were medical/curing cancer 9% - valuable research 8% - national benefit/importance 1%.

Conclusion: Based on the three polls which have actually spoken with a large number of Shire residents, it is apparent that Lucas Heights is not a preferred site for a new reactor. That it has been glossed over and the work of the surveys ignored, says little for the integrity of the Draft EIS

PPK Performance in the area of Community Consultation in this EIS Process

Perhaps it should be noted that PPK is not a stranger to Sutherland Shire. It had hardly left here as consultant to the EIS for Second Sydney Airport - Holsworthy - when it was given the job of handling the ANSTO case. Because of its previous poor handling of community issues there were demands on the Minister for the addition of an independent auditor to oversee the ANSTO process, by individuals, local groups and Sutherland Shire Council. All were denied but, at the time that the Draft must have been in its final stages, ANSTO employed Twyford Consulting to assess PPK's work.

The interim report from Twyford Consulting was not publicly available before the Draft EIS was released. In fact it arrived three weeks after the event. This was typical of the delay in obtaining copies of the Draft itself due to "unexpected demand". A reprint was necessary. It made the already short time to appraise it, even shorter.

The Twyford report raised issues which gave us an excellent insight of the so-called community consultation process. We learnt that "Community consultation programmes are normally designed to suit the level of community input or public participation that is required by the overall project......Some projects seek a high level of participative decision-making from the community.........Other projects seek merely to increase the community's awareness of a project and allow them the opportunity for comment."

Then, to our dismay, we are told that" Community consultation programmes within administrative approvals processes such as Environmental Impact Assessments typically fall towards the lower end of the consultation continuum." Well, that really put the process into perspective. In even more graphic form the report shows Arnstein's Eight Rungs on the Ladder of Citizen Participation. Our assessment is that we, the community, are at the second rung - from the bottom - in which the powerholders educate (or cure) citizens and that our degree of power sharing is that of non-participation. It is described as "Therapy".

Then there is the matter of transparency. Twyfords report, in setting out the standards for community consultation, states that transparency implies that stakeholders clearly understand the project, the consultation process and the decision making process. We do understand these matters. But the report continues to say that stakeholders are to be informed as to why they are being asked to participate and the level of participation or influence they can expect in any of the decisions relating to the project. After several meetings with PPK, including a full day sharing a tent with them at the ANSTO Open Day, such information was never mentioned.

The outcome of the Twyford report was the hiring by ANSTO of Keys Young to act as facilitators in a series of small group meetings and to arrange a debate on the local radio station 2SSR. The debate took place between Professor Garnett and Dr Jim Green and was good to listen to. However the question must be asked, how many people actually listen to that station? If it had been held on one of the commercial radio stations which have known numbers of listeners, it would have had some effect on the public debate. This would have been expensive of course but ANSTO was provided with $6 million to carry out the EIS and to arrange for the tendering process.

However it will allow ANSTO to boast that it took heed of Twyford's recommendation and participated in a "public" debate. Environment Australia should view this sceptically.

Three group meetings took place also, in a small meeting room of Sutherland library.

The largest hosting 15 and the smallest 11. Nothing new came from them, merely a rehash of opposing positions. The meeting dealing with emergency arrangements satisfied none of the concerns of local teachers who were present.

Comment: These meetings in no way compensated for open and public discussions at which both sides could state their position, an audience ask questions and clearly hear the answers. The Centre and People Against a Nuclear Reactor held three such meetings and invited ANSTO management, our local Federal Member, and the Minister for Science to attend and give their views. All invitations were declined. We can only conclude that they were all unsure enough of their position to debate it in public.

PPK - General Performance

These comments relate to Appendix C of the Draft.

Consultation Objectives

In identifying key stakeholders it is interesting to note that the Sutherland Shire Environment Centre was not seen in that light. However, after attending their presentation at the ANSTO - Community forum on 18.2.98 and later at PANR a week later, there would have been little to add.

That PPK saw as an objective " to comply, as a minimum, with the statutory requirements for public review of the draft" is nothing to boast about.

Mobile Displays

Page C-8 states that, in declining an invitation to attend public meetings, an alternative suggestion was made that representatives of community groups distribute their information and express their point of view at information days and at mobile displays organised by PPK. This is incorrect. That was the idea of the community groups; there was no discussion with PPK on the issue and they should not take credit for it.

Of the approximately 120 people who went to their stand at Menai Market Place on 14.3.98, a majority came across to our stand some thirty metres away and complained that those on PPK's stand could not or would not answer questions on the reactor proposal. We were pleased to assist.

The Information Day at Legends Youth Centre, Menai 27.3.98 went ahead in spite of PPK having been advised by a local that they would not be seen by passers by. This proved true and their stand was moved fifty metres to a position outside the library. Of the approx. 100 people who came across, 77 signed our petition opposing the new reactor. (77% is slightly less than opinion polls have shown, but in line with that of the BBC poll carried out for Sutherland Council.)

A mere 100 people attended the EIS Information Day held in conjunction with the ANSTO Open Day on 23.5.98. PPK shared a tent with members of the Department of Primary Industry and Energy (who had preliminary information about the proposed national waste dump), and People Against a Nuclear Reactor. Whether by design or ineptitude, the tent was pitched halfway between the main gate and HIFAR where most of the action was taking place. The visitors were being shuttled to and from that area by bus. So, out of a few thousand visitors, we picked up 100 strays.

Workshops

That the planned workshops did not go ahead is no great surprise. State government and local councils do not see that they have any say into whatever goes on within ANSTO since the Commonwealth 1992 ANSTO Amendment Act took away all their rights with respect to the environment and planning. However they still have obligations to the NSW public in areas of emergency planning action, duty of care to schoolchildren and the shadowy area of compensation to both workers and the public in the event of an accident.

Environment and community groups had already become disillusioned by the earlier meetings and had no indication of what was meant by a "structured" workshop. They wanted public meetings at the start of the EIS process so that the community could be better prepared and take part more effectively during the process. This was denied from the outset and should be deplored.

Precinct Committee Meetings

Out of nine area, only Woodlands could be considered close to the reactor. Was this the best selection that could be made?

Quality of Information

The paragraph on page C-9 is yet one more insult to the community. ANSTO, PPK and the other consultants have had a battalion of highly paid "experts" to advise them over many months and with millions of public dollars to play with. At the end of that time the public is presented with this Draft document, confusing in its style and requiring every word to be read and analysed. This is being carried out by ordinary residents of this area, unpaid, lacking in any funding to obtain outside advice or legal opinion. And now we are told that there is ample time to review it and to assess the merits of information received by ANSTO during its preparation.

There is most certainly insufficient time. And where is the additional information for us to review? It was not made public when the Draft was released.

Comment: The community consultation carried out during the EIS process has, from the start, been inferior. It has been long on "the process" and short on informing the public. The Minister should have heeded our requests for a Commonwealth Auditor and not relied on ANSTO, the proponent, to engage its own overseers. As employees they are paid to get a good outcome for their employer.

Regarding Emergency information, this will be dealt with in detail under section 11.7.4. However it must be said that the 20,000 brochures titled "What if there is an emergency at Lucas Heights Research Laboratories?", were somewhat less than mediocre and raised more questions than they answered.

Which precinct committees were given briefings on emergency procedures?

Community Involvement During Preparation of this Draft EIS. (7.4.2)

Consultation for this Draft EIS

Consultation Strategy

It is said that "others has a misunderstanding that HIFAR was in fact closing down permanently" Surely this was an understanding? Whether or not a new reactor is built HIFAR would not be authorised by the NSB after 2005 without major overhaul and updating. That it will be shut down is correct.

Several of the dot points in this section refer to "a number of submissions" and "some members of the community". The actual numbers should be included.

Concerns raised by the people who made submissions have been mentioned but where is the rebuttals of these concerns? It is not sufficient to merely state that "A common concern.that there is no known safe disposal for nuclear waste products". If ANSTO considers that the statement is incorrect then it must give its reasons in detail. That it has not done this gives the impression that it agrees with the comment.

"Key submissions to the (Senate Economics Reference) Committee were taken into account in preparing this Draft EIS". Which submissions were considered "Key"?

Management of Reactor Products, Spent Fuel and Wastes - Chapter 10

The introductory section to this chapter, page 10-1/2 does not mention the Little Forest Burial Ground. Whilst this lies outside the ANSTO site it belongs to the complex; it was contaminated by the AAEC; it is constantly monitored (we hope) by ANSTO to ensure that contaminants to not migrate off site. It should be ANSTO's duty in this EIS to give a commitment as to if, when and how it will attempt to clear it up. If such a commitment is not made, then ANSTO should state how it sees the medium/long term future of the area.

Methodology (10.1)

Background. (10.1.1)

In mentioning the 265 research reactors scattered throughout the world and "systems for the management of radioactive wastes exist at all these facilities" it fails to note that the majority had severe problems with waste disposal, particularly of spent fuel. The list of forty countries was divided into developed, including Australia, Germany and Japan and developing, ranging from Bangladesh to Zaire.

This situation was bad enough to cause the US Department of Energy to carry out an EIS on a Proposed Nuclear Weapons Non-Proliferation Policy Concerning Foreign Research Reactor Spent Nuclear Fuel. It reached a decision to accept the return of 22,700 elements.

This background description gives the misleading impression that, whilst the problems may be "managed in accordance with best practice", that is the end of the matter. Not so! Australia has been part of the international nuclear community for forty years, at the end of which it has had to appeal to other countries to help its constipation of waste by sending its spent fuel to them for either storage or disposal (USA) or reprocessing (UK). Strangely, the UK deal means that we will have reprocessed waste returned to Australia, vastly increased in volume and containing almost the same amount of radioactivity as was contained in the spent fuel elements.

This is the result of the attitude which has permeated the industry since its inception. That of "waste is no problem - we will work it out in due course". This attitude heavily spices the whole section on waste. As does the vagueness, lack of detail and qualification of statements.

Scope of Assessments. (10.1.2)

This section is full of undetailed statements.

"Although the details of the proposed reactor have not been determined....."

"As far as possible, the magnitude of the emissions to the environment and the waste production rate associated with the proposal have been estimated. However the emissions associated with the proposed reactor depend on details of the design."

"The proposed reactor would increase ANSTO's capacity to produce radioisotopes relative to the current situation. This increased production rate would increase the amount of radioactivity in the waste. However, the extent to which this results in an increase in emissions or the volume of waste depends on the extent to which new technologies are employed."

Surely the producers of the EIS are not to be allowed to escape with such fluff?

Principles of Waste Management at ANSTO. (10.1.3)

Page 10-5, paragraph Concentrate and contain. This gives the impression that this method is currently part of ANSTO's normal process for dealing with its liquid wastes. Not so! The long lived intermediate liquid waste (seen by both the US and Canadian authorities as high level waste) resulting from the manufacture of the medical isotope Technetium 99m was seen by the Safety Review Committee as far back as 1988 as waste presenting an off site hazard. It insisted that the matter be dealt with quickly. Ten years later the liquid is still in the same place but, we are informed, the plant is almost ready to carry out the solidification process. Such a situation cannot be described as being "commonly converted". Certainly not at ANSTO.

Neither can it be seen, even if it is actually carried out, as being a cradle to the grave process. It is merely transformed into a more manageable form - but still as radioactive - for further long term storage,. Somewhere.

Regarding gaseous emissions, there is a reference to " being below agreed working levels". Agreed to by whom? What is the process when, as has happened with the Argon-41, excess releases occur? Should there not be a release limit above which the operator is either taken to task by the regulator (when ARPANSA is set up perhaps) or fined, or the plant shut down? Such a system should also apply to the isotope production plant. I am not aware that ARI is taken into consideration in this EIS although it is a major producer of radioactive wastes. The EIS should deal with all emissions from the Lucas Heights site, not merely the reactor.

Radiopharmaceutical Production This paragraph correctly describes the method of producing Technetium 99m (half life 6.02 hours) from a generator Molybdenum 99 (half life 6 hours). It should be noted that, in its propaganda issued locally, ANSTO has claimed that Technetium 99m cannot be imported because of its short half life. But it has omitted to say that Molybdenum 99 generators are regularly transported around the world. Australia is one of the recipients of this service so that it can cover those times when it falls behind in production or during the regular maintenance close down periods of HIFAR.

Gaseous and liquid Waste Treatment (10.2.5)

Mention is made of filters fitted to all buildings where radioactive or contaminated components are processed or stored. The filters stay in place "for a year or more" before being replaced. As the filters are the last line of defence preventing excess gas releases to the atmosphere, how are they checked for efficiency? Are they examined manually or are they monitored in some other way. How often. This should be explained in detail.

Environmental Commitments on Reactor Products (10.3.3)

Surely these commitments are implicit in the operation of a government organisation which works under a regulatory regime. What is not clear here is, what would the penalty be should it fail to observe the international standards and regulations? Will such penalties be plain to see in the impending ARPANSA regulations?

Page 10-15 of the Draft has just started to come away from the binding. Has it started to self destruct whilst I am only half way through? Built-in obsolescence already?

Existing Management of Spent Fuel (10.4.2)

The first paragraph mentions the removal of fuel elements from the pond to the Engineered Dry Storage Facility. It does not mention the embarrassing situation last year when it was discovered that some of the elements were standing in as much as 90 litres of "rainwater". That situation, said by ANSTO to be checked regularly by ANSTO inspectors and by members of the IAEA, had not been noticed for possibly 13 years (when the building was erected over the storage area which was formerly in the open). Full information may be obtained from the Safety Review Committee's quarterly reports and from ANSTO's site Union Representative Mr Howard Matthews.

Such shoddy monitoring must rule out the continuation of the operation nuclear plant and the storage of radioactive materials at Lucas Heights.

The paragraph containing reference to "returning spent fuel elements to an overseas reprocessor, originally considered to be Dounreay in Scotland", should contain the reason that Dounreay was closed because of a spate of accidents, bad management, a polluted site and surrounding area, and that reprocessing was no longer viable.

Dounreay was closed quickly and without notice, taking potential customers like ANSTO by surprise. Dounreay management did however say that existing contracts would be honoured but that Australia did not have one! References to "other overseas/European reprocessors" began to appear in ANSTO's publications.

Management of Spent Fuel from the Proposed Reactor (10.4.3)

The US Department of Energy has stated that it would not take back spent fuel from a new reactor either for storage or for reprocessing. Sellafield, the UK's other major reprocessor is under attack from several western European countries which claim that effluent pumped in huge quantities into the Irish sea is polluting their coasts. And in general the UK has major waste management problems of its own, its plan for a deep underground dump at Sellafield having been scrapped after spending millions of pounds on primary research.

Government Policy

This paragraph is almost meaningless as it is simply a continuation of its HIFAR policy of which half disappeared when Dounreay closed. This is another case of ANSTO looking into the past rather than spelling out its plans for the future. ANSTO must be much more specific as where (overseas) and which reprocessing company will undertake to reprocess elements containing a grade of fuel not currently being reprocessed anywhere. We do not even know the specification of either the reactor or the type of element or how it is clad or its enrichment level.

The wastes resulting from this phantom reprocessor will be long lived intermediate level we are told.

What radionucleides will they contain?

What will their half lives be?

Will their return for storage be an interim measure - if so, how long is interim? Fifty years, a hundred, five hundred, five thousand?

How many future generations will be left to either guard, or dispose of this waste?

All this should have been detailed in the Draft EIS.

What happens to the policy should ANSTO fail to arrange a contract with Cogema in France?

If reprocessing is found to be not viable?

Will the ten year storage space allowed for spent fuel be enough?

Page 10-17, paragraphs 3 and 4 are contradictory so far as firm plans are concerned. In paragraph 3 it mentions a commitment to commence "such arrangements" (for shipping spent fuel) whenever storage inventory reaches five years arisings. It then talks of long-term contracts for reprocessing rather than for individual shipments. The next paragraph mentions contracts covering the lifetime quantity of spent fuel elements. The "commitment" seems to be the minimum position. This should be clarified.

Paragraph 5 is of great importance. "Bidders (for the reactor) must demonstrate that a solution, compatible with Australia's waste management strategy, exists for the ultimate disposition of their spent fuel arisings". Surely manufacturers of nuclear plant are different and separate from producers of nuclear fuels and reprocessors of spent fuel.

How can the tenderer for a reactor demonstrate this pathway?

Does ANSTO see its placement in a repository, i.e. a store, as being ultimate?

Should this not read interim?

If interim, the questions raised under Government Policy must be answered

Disposal of Spent Fuel

Paragraph 3 states that "..........the remaining waste products.......are conditioned into a highly resistant waste form such as borosilicate glass or Synroc." This gives the wrong impression that Synroc is being used for that purpose. This impression must be corrected. At this stage there is no Synroc plant operation anywhere for this purpose except on an experimental basis.

The same paragraph also refers to the greatest part of all the high enriched uranium research reactor spent fuel has been reprocessed. Whilst this is correct, the new reactor would be using low enriched uranium for which commercial reprocessing is not at present in place anywhere.

Reliance on one reprocessor, Cogema, would be a precarious situation (as was Dounreay). Should Cogema not eventuate, or close at short notice, the other options are:

Interim dry storage without conditioning.

Conditioning and direct "disposal". That word again! At the National dump with unknown facilities.

Interim dry storage in casks.

Or, not to be forgotten, domestic conditioning / processing.

Costs of alternatives to Reprocessing

Nowhere have costings been made of any of the methods of dealing with spent fuel either from HIFAR now that the Dounreay option has gone, or from a new reactor. Whilst $88 million has been allocated for shuffling the HIFAR elements backwards and forwards, that figure was based on Dounreay.

Will Cogema, or whoever else may be interested, do the job for the same price? If not, what will the cost to the taxpayer be?

What will they charge for low enriched uranium reprocessing?

What will be the cost of a long term dry store at the National dump? The feasibility and cost benefits of dry storage, without reprocessing, must be included as an alternative.

These are all important considerations for the government and should be subject to public scrutiny.

Impacts of Spent Fuel (10.4.4)

Again, what is meant by "extended storage" at the, still being discussed, national long lived intermediate level storage facility.....? How long is "extended" etc. etc. etc. (See Government Policy above).

Paragraph 2 is hopelessly vague. Volumes unknown, fuel type unknown, appropriate processing technologies unknown.

Paragraph 3 raises interesting points about volume reduction of the wastes from reprocessing. The Dounreay method greatly increased the volume of the spent fuel sent from Australia by its method of using a cement form of packaging. Assuming that Cogema does come up with a method of reprocessing low enriched uranium spent fuel, then its preferred method of packaging has been borosilicate glass.

The likelihood of the French setting up a Synroc plant is remote, but, if it did, would Australia have to pay for it?

Has ANSTO ever costed a Synroc production plant ? If so could it give an example?

ANSTO gives examples of the volume from the Dounreay cement system (9-12 cubic metres / year) and for the hypothetical Synroc (0.1 cubic metres / year). It does not mention the volume if enclosed in glass.

Whatever packaging method used, how long would it be able to be stored at a national waste dump? After that storage period, what would the next step be?

Paragraph 5 restates the "promotion of Synroc technology" and "seeking opportunities for joint development and application of Synroc" - as it has for the past two decades and with minimal success. As the two main countries in which reprocessing is carried out commercially, UK and France, are committed technically and financially to other methods, what are the actual chances of having them switch to Synroc? The EIS is supposed to be a factual description of what is proposed, not a wish list.

Environmental Commitments on Spent Fuel (10.4.5)

Bullets 3 and 4 should be considered together with Table10.3 on page 10-22. That table, 2.2 describes the single option for the disposal of long lived waste as described by the IAEA. A geological disposal facility.

This was raised at a meeting with senior ANSTO staff on 26 October, facilitated by Keys Young. It was pointed out that Australia did not have such a facility, was not even considering one, and that the official government line was that there would not be sufficient quantities of LLILW to merit one being built. ( the last point contradicts the 500 cubic metres mentioned on page 10-19, paragraph 3). So the next question was, once more, how long was it to be "co-located" at a national waste dump? 50 years, 100, 500 or more? The answer, preceded by a stunned look, was, "a long as necessary". No one was willing to suggest a time line.

Is this the government/ANSTO's understanding of intergenerational equity; of not leaving problems to future generations?

The final paragraph of this section sets out the qualifications which might prevent the five commitments from taking place as well as the expectations which are part of the plan. An EIS based on faith!

Management of Existing Radioactive Wastes (10.5)

Types of waste (10.5.1)

It should be pointed out that ANSTO has wanted, for some time, to send some of its low level waste to NSW council tips. Successive NSW governments have refused this, even though ANSTO claims it to be exempt waste.

Does ANSTO produce high level waste? Inspectors from the Canadian Atomic Energy in 1990 described the liquid waste from the production of Molybdenum 99 as HLW. Whilst that material has not moved from its position since that time it has been reclassified to LLILW. One could say that "all characters in this story are real. Only the names have been changed to protect......ANSTO". It is acknowledged that the IAEA did its reclassification four years after the Canadian visit but the material was clearly seen by ANSTO staff as being too dangerous to interfere with, in spite of the warnings from the Safety Review Committee as to it being a safety hazard.

On the other hand, waste materials following reprocessing are persistently and clearly referred to as High Level Waste by the US Department of Energy in its 1996 Final EIS Statement on a Proposed Nuclear Weapons Non-Proliferation Policy Concerning Foreign Research Reactor Spent Nuclear Fuel. ANSTO is prepared to follow the UK classification but not that of the US DOE. Is this science or merely selective referencing?

Referring again to Table 10.3, is there an error here? 2.1 Mentions short lived waste with characteristics of long lived radionuclide concentrations?

Waste Management Policy (10.5.4)

Legislation and Regulatory Control


It is interesting that this section boasts of conforming to the NSW radiation protection statutes. Of 1957 - 1959 - 1972 and 1993. Only 50 years behind the rest of the world. When might we see statutes brought up to date? Is the IAEA impressed with these standards or was it not informed?

The final paragraph of this section, page 10-33 claims that the nuclear fuel at the LHSTC is regularly inspected by staff from the IAEA itself. This is misleading and implies that the inspectors actually inspect the spent fuel elements. In fact they count the holes which contain the elements. If they had inspected their condition, those standing, corroding, in 90 litres of water would have been discovered some time between 1985 and 1997.

Dose Limits

The dose limit of 1 mSv to the public over above natural background level, as suggested by the NH & MRC and the ICRP, is accepted by ANSTO. However the NSB has a requirement constraining it to a lower level. ANSTO says that it has adapted a constraint of 0.3 mSv for all its operations. It claims that the actual dose to the public is 0.01 mSv.

Why then cannot ANSTO volunteer (or better still, be legislated) to adopt as its limit the 0.3 mSv constraint as is the case in the UK?

In the long paragraph on page 10.34 on other international standards, there is a pointed reference to the US EPA's regulation which says that "facilities emitting radionuclides in an amount that would cause less than 10% of the dose standard.......are exempt from the reporting requirements. It is to be hoped that this is not a flag waving exercise towards getting a licence which would not require it to report. I sincerely hope that all reporting requirements are set out clearly in the ARPANSA legislation - and in the regulations, which are not yet in the public arena.

The ANSTO Waste Management Policy

Dot point 1. Surely complying with legislative and regulatory requirements and ensuring that discharges are within authorised limits is not a commitment. It is a requirement which, if not achieved would (or certainly should) initiate its closure.

Dot point 2. The ALARA principle is qualified by the phrase "economic and social factor taken into account". Either it uses ALARA or it doesn't.

Dot point 3. Again a qualification. "When appropriate disposal routes are available". If they are not available then the project does not go ahead.

The IAEA Safety Fundamentals document referred to next is also vague in the following areas:

Dot points 4 and 5. "An acceptable level of protection" of human health and of the environment. Acceptable to whom? The NH&MRC? the NSB and ANSTO? This should be a commitment of a total level of protection of human health backed up by specific health monitoring over the full operating life of the nuclear plant on site. These checks to be carried out by the NSW Department of Health, regular public reports issued and fully funded by the Commonwealth government.

Dot point 6. Does not take into consideration the detrimental effects on the health and environment at the overseas reprocessing plant. The Dounreay plant, to which we were prepared to send our spent fuel, has certainly polluted its own site and the area outside its boundaries. There have been health reports showing excess levels of child leukemia amongst the local community. The Australian government's response to this has been, "that is the responsibility of the UK regulators".

Dot point 7. This gives the clear impression that there will be few improvements in management of nuclear waste in the near future. "......that predicted impacts on the health of future generations will not be greater than relevant levels of impact that are acceptable today." Considering that dose limits to both industry workers and the public have tightened enormously over the past forty years as knowledge has increased, surely the aim would be to reduce any impacts below currently accepted limits.

Dot point 8. Another qualified commitment. "......rad. waste shall be managed in such a way that will not impose undue burdens on future generations. If this was a serious commitment then it would read "will not impose any burdens on future generations."

Dot point 9. We have waited, impatiently, for forty years for a national legal framework which would effectively and independently control nuclear activities in Australia. The ARPANSA legislation which was seen only recently and which has taken five years to draft, falls short in several areas and should be subjected to amendment. The actual regulations are not yet available for public scrutiny. At the last request we were informed that they are not yet completed. In spite of this the House of Representatives passed the legislation without debate.

Dot point 10. Yet another qualification. "- generation of rad.waste shall be kept to the minimum practicable." There should be an aim, however difficult, for zero emissions and zero waste production. Such an aim would be the way forward to seriously consider alternative methods of carrying out the science in which ANSTO is interested - without a reactor.

ANSTO's Waste Management Action Plan

Whilst we have received copies of ANSTO's Rad, Waste Management Policy - Preliminary Environmental Review (ANSTO/E728) we are not privy to its actual management plan. The brief review in the EIS Draft mentions legacy issues but ignores the Little Forest Burial Ground. The RRR report(17.4 page 210) said that "the question was rather whether management and control of the area is adequate and whether the risk to public health and safety is low enough to allay concern. That ANSTO has monitored the area on a regular basis since the disposal operations. Both the SRC and Coffey Partners in a report for the NSW government found that there was very small health risks to people not living on the site and recommended continuing monitoring."

It is only recently that we learnt that the monitoring equipment was damaged by vandals and that (due to cost?) was not replaced for 12 months. During this period the "regular" monitoring was not carried out.

Dot point 1. This refers to the solidification of the liquid waste from the production of Molybdenum 99, seen to be a hazard with potential for off-site consequences by the Safety Review Committee in 1988. It mentions the longer term possibility of Synroc being used to immobilise the solid material. Could this be explained in more detail because it is our understanding that Synroc was originally designed to encapsulate liquid high level waste. Is it not capable of carrying this out by directly converting the existing liquid into a Synroc material? Double handling seems to be inefficient - and dangerous to workers.

Is the solidification merely a stop-gap solution to overcome the hazardous situation because the Synroc process is still, after 20 years, in its infancy and untested? Surely it would be an ideal opportunity of showing the world just how good it is. Or perhaps that is the real problem.

Australian Government Policy for Solid Waste

So much relies on the national waste dump which has been on the agenda for twenty years. A repository for low and short lived intermediate level waste plus an interim co-location store for the long lived waste can hardly be described as providing a comprehensive strategy for Australia's rad.waste.

Until there is a specific long-term plan for the long lived material then it is merely putting off the day of reckoning and handing on the problem to future generations. At the meeting on 26 October it was pointed out that of the four ANSTO staff present plus the representative from the Australian Nuclear Association, all except one would be dead by the time a decision was necessary on the long lived waste. The odd person out would be in his late eighties and might not remember the subject.

Management of Future Radioactive Wastes (10.6)

Introduction (10.6.1)

Again we are faced with the vague "because we don't know the design of the new reactor we can only guess that some of the emissions and waste production will decrease and others will increase".

Table 10.4 mentions the number of irradiation cans increasing in proportion to the rate of Mo99 production, but no figures are given. Later, there is reference to the increase in Mo99 with the generation of liquid and solid wastes. In the former, "fission levels would increase but the volume would not increase in the same way due to improvements in the process". The estimated levels should be listed. Is the improvement in the production process specific or is it another area where things might happen but no details or timetables are available?

What are the estimated increases in the low level solid waste from Mo99 production?

Characteristics of Gaseous Emissions (10.6.2)

"Normal" Emissions


We have purposely placed quotation marks around the word normal to remind you of the statement (claim, commitment, assurance, promise) by Professor Baxter to Sutherland Council when he was selling the idea of setting up HIFAR in the 1950's, that there would be no gaseous or liquid emissions from the operation of the reactor. An eminent person, a distinguished scientist and one who could make pronouncements which were proved to be incorrect and misleading.

Whilst such emissions have become common, usual, routine in this district they will never be normal. This point was taken up eloquently by Parkman in its peer review of the Draft EIS.

"Some caution needs to be applied when making comparisons with natural background (radiation) to avoid the impression that one can conclude that the potential exposure is acceptable because it is less than natural background. All exposure will be in addition to natural background, are imposed, not voluntary and, unlike natural background, could be avoided if the proposal does not go ahead."

Molybdenum 99 Production

Growth in the use of this product is estimated to be about 10 to 15% per year to about 2002. Is HIFAR capable of meeting this estimated demand? If not will there be an increase in imports? It is our understanding that even today there are situations when ARI cannot keep up with their orders and have to rely on imports.

There are claims from ANSTO that "thirty percent of imports arrive late or are unusable". This was claimed in hearings of the Senate Estimates Reference Committee but they were not substantiated on the peculiar grounds of customer confidentiality. We understand that the chief supplier of imported radioisotopes counterclaims that 98% of its product arrive on time.

This is an important discrepancy and should be examined and reported on in detail.

Table 10.5 Shows increase estimates in Cobalt-60 and Samarium-153. but page 10-42 states that only Mo99 production will give rise to increases in emissions and waste. Is this correct? Some figures are needed for verification.

Abnormal Emissions

As mentioned earlier, all emissions to the atmosphere in this area are abnormal. The release of uranium hexafluoride in 1984 has raised some concern. Whilst the accident was investigated by ANSTO itself (would this be allowable under ARPANSA?) there are several claims of miscarriages in the Lucas Heights/Menai area following the accident.

Did the NSW Health Department investigate these claims?

Did carry out any surveys?

Or did it accept the findings of the ANSTO inquiry and its estimated dose figures?

The comment in the Draft that none of these incidents involved the reactor is irrelevant. All radioactive emissions from the Lucas Heights site, "normal" or "abnormal", involve the reactor directly or indirectly.

Characteristics of Liquid Emissions (10.6.3)

Page 10-44 bullet 4, mentions the incident of 5 March 1997 involving the "drops of contaminated liquid which had been picked up from a storage area during the transfer of some spent fuel". We urge you to read the minutes of the Safety Review Committee on this matter. This was the movement of spent fuel elements which had been found to be corroding after spending a decade in 90 litres of "rainwater" in the euphemistically described dry storage area. ANSTO still has a problem of describing honestly the cause of this total failure of its monitoring programme.

Characteristics of Intermediate Level Liquid Wastes (10.6.4)

To claim that the solidification of the liquid wastes fro Mo99 production "has been identified by ANSTO as a priority" without mentioning the demands from the Safety Review Committee since 1988, is breath taking in its use of words which cloud the facts.

When Synroc is developed and industrial production is possible (final paragraph), will the intermediate solidification process be eliminated and the liquid contained in Synroc in a direct operation? How much will the Synroc plant cost?

What would be the cost of the concrete storage vessels be?

How long would the storage be, whether at Lucas Heights or at a national store? Would it be seen as "ultimate disposal" or would it be expected to have a subsequent phase? If so, what is envisaged?

Characteristics of Other Low Level Solid Wastes (10.6.6)

High Efficiency Particulate Air Filters: They will contain radioisotopes "mainly short lived". Does this imply that some are long lived? If so please give details by type, volume, radioactivity levels and half lives.

Characteristics of Intermediate Level Solid Wastes. (10.6.7)

Once more, "...........contain very few long lived radioisotopes". How many and how long lived are they? What are their radioactivity levels?

Environmental Commitments on Emissions and Radioactive Wastes (10.6.12)

These contain similar qualifiers as in 10.4.5

Risks of Leakage and Leaching of Radioactivity from Storage Facilities (10.9.3)

Paragraph 4. It is good to hear that the tubes are now regularly inspected for moisture and corrosion since the 1997 debacle.

Hazards and Risks - Chapter 11

Methodology (11.1)

Background (11.1.1)

Yes, every human activity has a risk, but there are voluntary risks and imposed risks. Until very recently community knowledge on hazards was slight, but, with the enormous expansion of information flow the situation has changed. People have a lower acceptance of having hazardous situations imposed on them, And they not prepared to accept platitudes.

The table 11.1 shows a number of everyday risks and how they might affect the population - on average. Certainly the insurance companies of Australia will have a similar list from which they will have worked out the premiums needed for them to be able to pay for claims and make a profit. Of course they have standard exclusions but the only commercial exclusion is that of the Nuclear Industry. Forget the "research" emphasis of the Lucas Heights proposal, ANSTO's operation is a medium sized commercial one.

For your information, here are the standard exclusions.

Caused by depreciation, wear, tear, rust or corrosion.

Caused by vermin, insects or birds.

Caused by flood.

Caused by the sea or high water.

Arising from any war, invasion, acts of foreign enemy, civil war, rebellion, revolution, insurrection, or military or usurped power.

Arising from the lawful seizure, confiscation, nationalisation or requisition.

Intentionally caused by you or your family or a person acting with the consent of you or your family.

Arising from radioactivity or the use, existence, or escape of any nuclear fuel, nuclear material or nuclear waste.

Recommendation. This EIS process is an ideal opportunity for Environment Australia to send copies of the relevant sections to the major insurance companies which explain how benign the new reactor will be. And to ask them if the evidence, promises and commitments of ANSTO will result in an alteration of policy with regard to nuclear hazards.

If they are unwilling, then the use of the Lucas Heights site should be abandoned.

The world of insurance (and that of gambling) is probably the one which uses statistical probability most of all. That our insurance industry will not cover accidents which involve nuclear plant or radiation carries more weight than protestations from the industry.

The Reactor Building (11.2.2)

It is noted that the spent fuel from a new reactor would be stored in the same building as the reactor itself. That its maximum capacity is ten years arisings, say a total of up to 400. Even if this figure is halved, assuming that ANSTO succeeds in managing to get someone to reprocess them, then surely storing them next to the reactor itself is not sensible. If Murphy's Law takes over and the in-credible reactor accident occurs, having the highly radioactive spent fuel along side could become a double hazard.

Regulations and Criteria (11.3.2)

International Atomic Energy Agency

May we refer to the Peer Review carried out by representatives of the IAEA? Firstly, in that report, page 24, "List of persons met during the visit" there is an error. The meeting on 24 August at Sutherland Shire Council refers to a Mr White of Sutherland Shire Environment Centre. In fact the representatives of that group were Bob Walshe, Chairman and Michael Priceman (the author of this submission). Mr White is in fact a councillor but he was not present at that meeting as I am sure he will have pointed out to you.

During the meeting Dr Gurpinar was asked whether the IAEA had ever rejected a site for a nuclear reactor. "Certainly" was the reply. On what grounds? The example he quoted was a site on a promontory, at the end of which was a residential community. In the event of an accident at the reactor site, residents would have had to go towards the scene of the accident if evacuation was necessary. So the site was rejected.

We pointed out the location of the new suburb of Woronora Heights which would be in a similar position. It has only one road and that points towards ANSTO. "In that case", said Dr Gurnipar, "they have a problem".

Unfortunately there was no mention of this in his report and, to say the least, we are disappointed. However we expect Environment Australia to assess this problem.

Hazards, Risks to Public from Normal Operation of Proposed Reactor. (11.4.3)

Public Health


The reference here of the "best indication" of the effects of the normal operation on the health of the general public are the studies of the existing operation of HIFAR. This is nonsense as the authors of the Draft well know. The "studies" carried out during the Research Reactor Review were far too limited in scope to justify any conclusions. It can safely be said that the effects on the health of local residents - and on ANSTO's former employees - are unknown.

The RRR had no requirement in its terms of reference to consider public health. As an afterthought, and as a result of objections raised by residents, certain cursory statistical comparisons were made between Sutherland Shire and Warringah Shire. But none could be considered as being specifically dedicated studies. More recently, to add insult to residents, inquiries to the office of our local Federal Member on this subject brought the suggestion that residents supply proof and the matter would be considered.

Earlier, in 1995, during a discussion with the new Mayor of Sutherland Shire, the subject of health and ANSTO was raised. The mayor said that she had connections with knowledgeable people in the health industry, would speak with them and would get back to us. Subsequently we received a report based on studies carried out in the UK claiming that there were no problems. In tiny print in the appendix was a thank you to British Nuclear Fuels Limited (BNFL) for funding the study. Doubtless the report had been passed to the mayor from ANSTO.

Recently, we learnt from the NSW Department of Health that a study into the prevalence of thyroid problems in the area would cost a mere $15,000 but the Department was not willing to proceed. Is this unwillingness caused by a fear of adverse findings perhaps bringing about litigation for failing to carry out its responsibilities and duty of care to its constituents?

Page 11-28 states that an investigation of anecdotal claims expressed by residents by the Australian Institute of Health and Welfare National Perinatal Statistics Unit of the University of Sydney was carried out. This is incorrect. The request for an investigation was made by the RRR but the first stage was a request by the Professor in charge that residents approach the families who had been affected asking for their permission for the study to go ahead. This request was denied on the grounds that it was both unprofessional and an invasion of privacy. To our knowledge that section of the study did not take place.

Comment: Is not up to the local community to prove that there is a health hazard attached to living close to a nuclear plant. But it is, in the EIS process, the responsibility of the proponent to prove that there is no risk.

Our critique of the RRR's report on health is attached.

Hazards and Risks to the Public from Reactor Accidents (11.4.5)

Land Contamination and Intervention Levels


What would the social and economic effect be following an announcement that such an incident/accident had occurred? Even if it was said that there had been no adverse effect on the nearby land? Who would take responsibility on subsequent falling land values?

Public Liability (11.4.7)

International Aspects and Australia's Position


These paragraphs are another insult to the local community. First we read of international junkets in Paris and Vienna where conventions were drawn up over thirty years ago and protocols extended six years ago. Their aim, to provide adequate financial protection against damage caused by the nuclear industry. Sounds good so far. Then we learn that Australia is neither a party to either convention, nor does it consider doing so! As usual, rather than taking a lead in this matter, Australia prefers to follow the procrastinations of the rest of the nuclear world and leave its residents in limbo.

Then it gets worse. Australia does not have specific national legislation covering nuclear liability. Any problems, just sue the Commonwealth Government. Most of us are old enough to remember the Voyager incident and the Agent Orange cases in which the Commonwealth delayed justice and responsibility for many, many years.

Emergency Planning (11.6)

So far as the general community is concerned there is little information available from any of the emergency service agencies with respect to an emergency at Lucas Heights involving radiation. The public DISPLANS are little but management layers. They give the titles of the people with responsibilities but there is no detail. As an example, the ANSTO DISPLAN, which is said to cover off-site emergencies following an accident at Lucas Heights, shown the limits of the area being the site fence! Then it offers technical assistance from ANSTO personnel.

Inquiries to the agencies as to specific details brought the reply from the police department that details were confidential. The fire service had a similar policy. The health and ambulance services - sent details of its emergency procedures but the only references to radiation related to an accident involving a vehicle carrying a medical radioisotope. Nothing about the nuclear operation at ANSTO.

Recent emergencies involving bushfires where evacuation has been necessary showed up the expected and quite understandable chaos. The announcement of an emergency at ANSTO would doubtless cause a similar situation involving blocked roads and overloaded telephone systems. It is well known that the roads around ANSTO are often jammed due to the most minor accidents. Indeed the recent telephone debate on local radio station 2SSR between Professor Garnett and Dr Green was delayed for that very reason. As was the start of a meeting organised last week by Keys Young between ANSTO staff and the community.

Public Information on Nuclear Emergencies

Considering that HIFAR was set up in 1958 it is disgraceful that the first widely circulated public brochure on what to do in the event of an emergency at Lucas Heights emerged almost forty years later. It was so slight in content as to have little value; it raised more questions than it answered - and it did not even mention what organisation had produced it. It was letterboxed shortly before Christmas 1996, at the height of the seasonal junk mail period. The majority will have gone straight into the paper recycling bin. Unseen.

We are told, that an updated version is in the pipe-line. The EIS says that it will be distributed during 1998. There has been nothing so far. Are we to suppose that it will repeat its 1996 debacle? Will it relate to HIFAR or to a replacement reactor? As ANSTO claims that HIFAR presents a minimal risk and that a replacement no risk at all why refer to the urgency of sheltering or of not going out looking for pets?

Page 11-61 mentions a regular newsletter every two months sent to 40,000 households. Will Environment Australia ask ANSTO for copies of the last six and the dates they were circulated?

Community Interaction

Reference on page 11-60 to a course for teachers with responsibility for health and safety at local schools. This was held in November 1997. Conversations with some of the teachers who attended it said that it was little more than a public relations exercise and that they learned little from members of the emergency services agencies.

Questions as to the suitability of demountable classrooms for sheltering have been asked without suitable reply.

Are they able to be sealed off for sheltering purposes?

How will communication with the outside world take place as there are no 'phones. What does the teacher do if parents call and demand to pick up their children as they did during the recent bushfires? Open the doors and put the others at risk or simply tell them to go home and read the pamphlet?

How long would sheltering be?

Where are the toilets?

What about children with special dietary or medication requirements?

Recommendation: That, on the grounds of its risk to surrounding communities and the inability to provide adequate emergency services, the idea of building another reactor at Lucas Heights should be scrapped.

Environmental Management and Monitoring - Chapter 18

Role of ARPANSA and other Regulatory Authorities (18.2.2)

Australian Radiation Protection and Nuclear Safety Bill 1998 (ARPANSA)
  1. 1. The push for proper legislation for and regulation of the nuclear industry in Australia has been going on for many years. The aim was to bring this area at least up to the highest standards which apply overseas (in some countries). This push came, not from the industry or from government but from the environment movement. Finally, when the report of the Research Reactor Review (RRR) was released in 1993, the lack of proper regulation was made public and given the stamp of officialdom. At last we had been taken notice of through our submissions to the review.

  2. Why had the regulatory regime been allowed to remain at 1950s level? One reason is that whenever the subject of the industry - and within this term we include AAEC/ANSTO - was raised in federal parliament it was treated as a non-controversial matter and passed without examination or rational debate. Nothing altered in that regard when this 1998 bill was presented. Somehow the industry has such sway that our members forget their differences and the confrontational way they usually carry out their daily business.

  3. An outstanding example of this was the federal ANST0 Amendment Bill of 1992 which removed State and local government's jurisdiction relating to areas of environment or planning. That bill was a disgrace but it was supported by the major parties in Canberra.

  4. When it was announced that the regulations were to be improved and brought into the 20th century we were delighted. But for three years from 1993-96 the silence was deafening. From 1996 there was some movement but little response to our enquiries. Now we are presented with a bill without having any idea as to what regulations will be put in place. Why? Because the details are not yet complete. It would be far better to comment on the regulations rather than the bill but it seems the Canberra club will close ranks once more and deal with the bill as non-controversial without access to the detailed regulations.

Comments on the Bill
  1. "The Object of the Act, Section 3, is to protect the health and safety of people.from the harmful effects of radiation." Who will define the word harmful particularly with respect to human health? Attached are copies of articles on the dangers of low levels of radiation exposure. If harmful refers only to fatal cancers then it will be a deficient definition. There are daily emission of radioactive gases from both the reactor and the radioisotope production plant at Lucas Heights. As there has never been any health examination of the local population it cannot be said that there has been no genetic or non-genetic damage to cells. Will the new body carry long term tests, probably over the next fifty years? It will be very difficult and costly but surely it cannot be ignored as it has since 1958.

  2. The Act binds the Crown (2) "Nothing in this Act renders the Crown liable to be prosecuted for an offence". What does this mean and who is it protecting?

  3. Operation of the Act (9) with regard to the Nuclear Non-Proliferation (Safeguards) Act 1987. has the Safeguards Office examined the Bill carefully and if so is it fully satisfied that it will not conflict with its Non Proliferation Treaty safeguards?

  4. Definitions, section 11, Nuclear installation. Do critical and sub-critical assemblies include Hot Cells?

    There is no mention of waste dumps or repositories. Or storage places for spent fuel, waiting to be moved somewhere. Are these excluded from the Act. If so under what regime would they be licensed? Or would they be licensed at all? If not included then this is a glaring example of why the regulations must be seen and examined before the Bill is passed.

    Reprocessing plants are included in the list of nuclear installations. Reprocessing is still on the table (or at least in the middle drawer). Assurances from any Minister are all subject to use-by dates and the average tenure of Ministers for Science over the past ten years is 18 months.

  5. The Chief Executive Officer, CEO, of ARPANSA. Sections 12 and 33. How it this person chosen? Appointed by the Minister / Governor General or following international advertising of the position? Would present or former employees of ANSTO be eligible for the post? Should they be?

    A more worrying detail is that ARPANSA and its CEO will be "part of the Department of State administered by the Minister". Surely this is contrary to the concept of independence of the agency. Whilst it may be said that it will not be within the Department of Science, as is ANSTO, the Department of Health is not without close connections with the influential nuclear medicine industry. Let's face it, ANSTO is the chief advisor to all government departments and even the Minister for the Environment, which might have been a better choice if in fact a government department was shown to be essential, is a member of the Cabinet which made the decision on a new reactor at Lucas Heights. The agency should not be part of a Department.

  6. Functions of the CEO Section 13 (2). "The CEO must take all reasonable steps to avoid any conflict of interest between the CEO's regulatory functions and the CEO's other functions." What is implied here? Does the Bill anticipate conflicts of interest?

  7. The Radiation Health and Safety Advisory Council. Section 17. Is this the body on which we are assured that a community representative will take part? Will the Council be less than the Safety Review Committee which would be abolished under the new scheme? How will the Minister choose the members? The Council is there to "advise the CEO" so presumably it will not publish an annual report, directed to a Minister, as did the SRC. A report which was available to the public.

    How will the public get to know what is going on in the Council? You may recall that it was only because of the availability of a SRC report that we discovered that rain water had entered the "dry storage" tubes containing spent fuel and that it had not been discovered for about 15 years.

  8. Prohibitions relating to construction of nuclear installations, possession of controlled materials etc. Sections 18 and 19. There are several references to "Maximum Penalty of 2000 penalty units" for breaches of conditions. This sounds like the reverse of Fly-Buy units. What on earth does it mean?

  9. Licence Conditions. Section 23, (3), (a) (4) (a) Entry and inspections of a site "at reasonable times".......... Does this preclude spot checks without notice?

  10. Review of licence decisions. Section (4) "The Minister is taken to have confirmed the licence decision if the Minister does not give a written notice of the Minister's decision within 60 days of the request." What if the Minister or his staff have overlooked the request? This can happen.

    This state of affairs is repeated under Enforcement. Section 30 (4)

  11. Review of decisions to give directions. Section 30. Reading sections 29 and 30 the scenario could be that the CEO gives directions to a controlled person covering a situation involving the health, safety of people or danger to the environment. The controlled person, within 90 days, requests a review by the Minister and the Minister then has 60 days to make a decision. Could it actually take 5 months to go through the system in such circumstances?

  12. Notional Payments by the Commonwealth. Section 43. My Collins dictionary describes "notional" as ideal; fanciful; fussy or, in the USA, whimsical. What does it mean when enshrined in Commonwealth legislation?

    The sections dealing with money (44) (45) are difficult to understand and should be examined by an accountant.

  13. Staff assisting the CEO. Section 46. Surely the CEO should be able to hire and fire his own staff. The idea of them being supplied by the Department Secretary brings to mind several episodes of "Yes Minister".

  14. Powers of inspection. Section 51 (2) (a). An inspector is not authorised to enter premises under sub-section (1) "unless the occupier of the premises has consented to the entry..." Surely this is a misprint! Add this to the licence conditions at section 23 which refer to entry and inspection of sites "at reasonable times" and it adds up to a very polite but useless set of powers. But it might rule out the kind of raid carried out by the NSW Minister for the Environment, Tim Moore, on ANSTO in 1992

  15. Powers available to inspectors. Sections 53 (1) (b) and (3) These refer to the use of powers necessary for avoiding an imminent risk of death, serious injury, serious damage to the environment. (emphasis added). Who decides or defines what is meant by "serious"? The CEO? The yet to be seen regulations? The inspector? Will the word be qualified by another one - "acceptable".

  16. Offences relating to warrants. Section 68. Here is the only understandable severe penalty which is spelled out. Maximum 2 years imprisonment for making a false or misleading statement when applying for a warrant. Presumably this would be for the inspector involved. He gets prison but the "occupiers" who break their terms get penalty points!

  17. Operation of State and Territory laws. Does this mean that such State and Territory laws are over-ruled by this legislation as did the ANSTO Amendment Act of 1992?

  18. Where is there reference to uranium mining and particularly the wastes it produces? Will this be outside the scope of ARPANSA? If so, why?
There are enough areas which should have merited a debate and certainly raise cause for amendments to the legislation. There must be many more for more practised eyes to pick out. That the total weight of the members of all sides of parliament with legal backgrounds who are unwilling to even to consider the shortcomings of the Bill and to treat it as non-contentious, should be cause for alarm. Meanwhile five years have passed and it looks as if this or a similar Bill will get through and it will take another forty years to get it fixed up.

New legislation and regulations should be put in place urgently but we must be sure that they are comprehensive and that they will protect the population and the environment, not the industry. This Bill must not be passed without full examination and much clarification by our elected representatives.

Cumulative Impacts and Ecologically Sustainable Development - Chapter 20

Identification of Potential Cumulative Impacts (20.1.2)

Table 20.1

The Lucas Heights Waste Management Centre is described as having no significant cumulative impact on the local environment. But science is, or should be, always examining and re-examining its own research. The August 7 1998 edition of the UK journal, The Lancet, stated that "residence within 3 Km of a landfill site was associated with a significantly raised risk of congenital anomaly" and that " systematic environmental health surveillance is needed for municipal landfill sites and other pollution sources".

This report has led to yet another call for government (UK) to reduce the amount of toxic waste produced by industry.

This EIS has not considered the possibility of synergistic effects which might occur between the airborne materials from the Lucas Heights landfill and the radioactive gases emitted from the ANSTO site. Many times during the year when there are temperature inversion conditions, the tip can be smelt within a wide radius. Certainly as far as Sandy Point to the west. Is it enough to say that, because the radiation from ANSTO is below acceptable levels, in conjunction with the tip and adverse weather health problems are impossible? This should be thoroughly examined in conjunction with the NSW Health Department.

The Little Forest Burial Ground has been largely ignored in the Draft. But it will not go away. The manner in which it was developed would not be allowed today. So what will become of it? Does ANSTO have a plan to reclaim the land? Is such a project possible? Would it be safer to just leave it and merely monitor it? And leave it to future generations? Is it intergenerational equity to leave a message and say that it won't do you any harm?

Precautionary Principle

Dot point one claims that "no adverse health effects have been found". It would be more truthful to add that neither have they been looked for.

Paragraph two on page 20-11 refers to the nature of the health benefits to the nation by the production of radioisotopes. This gives the impression that the reactor method is the one and only way. However there has been no substantive effort on the part of those in the nuclear science community to examine alternative methods of producing them. This is perhaps one of the most dishonest arguments for a new reactor.

Intergenerational Equity

This section begins with fine sentiments. Social equity, justice, fairness, basic needs. of society, fairer distribution of costs and benefits. All reminiscent of a Marxist manifesto. Next we get the legacy to future generation of health, diversity and welfare - not to mention the long lived rad. waste. So it was not mentioned.

Then we get a restatement of ANSTO's case for a new reactor ! Not very subtle but a reminder of what the EIS is all about in case we have lost the plot and become bored in the final pages.

Whist a new reactor would not be the only source of long lived waste, it and that from HIFAR, will be, by far, the greatest quantity both in volume and radioactivity. Further on, and we agree, the current generation should not pass on the legacy of their decisions to future generations. There is the importance of handling the waste and disposing of it in accordance with internationally accepted practices thereby avoiding the imposition of undue burdens and risks to future generations and ensuring that they are no greater than those permitted for the current generation. From this it appears that things are not going to improve, merely stay the same. Is this cutting edge science as we understand the expression? Or is there an element of the truth and ANSTO cannot foresee the disposal of waste getting any better?

Regarding the national waste dump there is obvious concern in the EIS that either a decision will be further delayed; or co-location will not occur; or that an alternative site for a spent fuel waste store may be needed; or that a deep geological disposal facility is decided on (as is the internationally accepted practice is said to be - although it has not yet really started).

No worries! The EIS says that a waste dump is needed whether or not this proposal goes ahead, so it doesn't really matter if there is no decision. Just pass Lucas Heights as a suitable site for a new reactor, let us get the contracts in place and the waste dump/store/repository will fall into place - at some time in the future. This is the story of the nuclear industry world wide and Australia is no different. Such decisions have led the Russians to dump its serious waste into the ocean near Japan, for the US government to be sued by 21 States as they have nowhere to put the fuel waste from nuclear power plants and for the UK to have a House of Lords Inquiry into its own problems of waste since the Sellafield Deep Hole project was abandoned.

Aren't we fortunate that our government has ANSTO to "provide sound advice" on matters of waste? Current advice is that the timing of the decision on the waste dump "need not be chronological". That is, let us build the new reactor, start producing waste and, perhaps in fifty years time, the question of what to do with the build up of waste will be closer to a conclusion.

And in any case, "until the design and fuel type of the replacement reactor are known, it is premature to finalise arrangements for spent fuel management". What insolence! This is exactly the time, not in the future!

Which brings us back to intergenerational equity.
Back to Submissions Index