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Comments on the Draft New Reactor EIS

The Secretary
Replacement Research Reactor
EIS Environment Assessment Office
Environment Australia
GPO Box 787
Canberra ACT 2601

Dear Sir,
  1. It fails to address the most basic question, "Does Australia need a new reactor?" It merely examines the suitability of the Lucas Heights site. ANSTO's case for a new reactor is a re-hash of its 1992 case which was rejected by the Research Reactor Review (1993).

  2. The Draft is tainted by its one-sidedness. As expected, being the proponent, ANSTO has not included a single comment which might harm its case. It cannot claim to be objective.

  3. Many of the references favouring the project are from ANSTO's own literature or from members of its staff or from the Nuclear Safety Bureau, whose staff are mostly former employees of ANSTO.

  4. The EIS admits that there is no detailed specification for the proposed new reactor, therefore all of its references to emissions, safety features, reference accidents, types of fuel, waste quantities etc. are hypothetical and, accordingly, impossible to assess.

  5. There is no mention of the degree to which the Lucas Heights site is already contaminated following forty years of waste production and on-site storage. Neither has the Little Forest Burial ground been assessed. This site is totally contaminated and is unlikely ever to be restored for any useful purpose.

  6. A cost/benefit analysis has not been included.

  7. An updated costing of the proposal in the light of the devalued Australian dollar should be included. (Although this also would be hypothetical until specifications and tenders have been received.)

  8. The question of alternative sites away from growing residential housing is a secret, tightly held by Cabinet. That it will not release details of its alleged study is an insult to this community.

  9. Attention is given to the removal of waste from the Lucas Heights site. But some radioactive spent fuel will remain on site throughout the expected 40 year life of a new reactor, though partial removals are promised at intervals of several years. And the superceded (radioactive) reactor would remain on site for 30-100 years, or even permanently, depending on the method of decommissioning it.

  10. The off-site emergency plans are still vague and consist publicly of a management regime with no details specific to an accident involving radiation. The EIS consultants have refused to contact local schools to assess their preparedness to handle such an event.

  11. Reference is made to new legislation proposed for the Australian Nuclear Industry. Again this is premature as it has not yet passed through parliament. Whilst it is an improvement on the existing hotch potch it is still not up to international standards and needs many amendments. Its actual regulations are still not available to the public for examination.

  12. The health of local residents from the operation of the HIFAR reactor and the radioisotope production plant has once more been ignored. There has never been a health study carried out in spite of the many medical papers which have detailed the possible effects of low level radiation.

These are some of the more obvious problems with the Draft. Doubtless more will emerge as it is further dissected.

Yours Sincerely

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