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Submission to ARPANSA following an Application by ANSTO for a Site Licence at Lucas Heights for a new Production / Research Reactor

Introduction and ARPANSA as seen so far

The Lucas Heights site where the AAEC from 1958 and ANSTO since 1986 has operated the HIFAR reactor, has never been licensed, either by the Commonwealth, the State or Local Government. That it has operated under an "authorisation" for many years knowing full well that this did not conform to either world's best practice or to the guidelines of the International Atomic Energy Agency makes Australia's much lauded position on the Board of Governors of the IAEA somewhat laughable.

The introduction of a new and better, independent regulatory authority has long been awaited by our local community. The question of regulation was brought up at the Research Reactor Review (RRR) by several environmental groups and by the Nuclear Safety Bureau. To its credit the review committee recommended a new regulator. Why it took six years will remain a matter for conjecture. At the recent hearings of the Parliamentary Standing Committee on Public Works questions were raised as to ARPANSA's ability to take up the challenge and, starting almost from scratch, regulate ANSTO, an organisation which has been virtually self regulating for many years.

That ARPANSA is a Government agency and that ANSTO is the chief source of advice on nuclear matters is cause for alarm. Having spent the past two years dealing with Government Departments, Ministers, Environment Australia and local politicians during what we all refer to as "The Process", we have been left with a deep feeling of cyncism. Each of these groups or individuals has hidden behind terms such as "Under the terms of the Act", "Cabinet-in Confidence" and "under the terms of the legislation there is no obligation.....". It is an essential that the community be convinced that ARPANSA is there to protect it , not the nuclear industry.

That ARPANSA, in its very first test, has fallen short of our expectations fills us with a sense of frustration. Perhaps it is because politicians and bureaucrats have little idea of how ordinary people outside their sphere actually live and think. So why the dissatisfaction?

First the Consultation process as set out in the ARPANSA information letter. Why was this application, which is being treated by the Cabinet as essential to the National Interest, only advertised in one national newspaper? I noticed it by chance in the local Express but missed it in the St. George Leader. Surely ARPANSA knows by now who the main stakeholders are and should have sent notification directly to them - along with a copy of the application.

Which brings up the second point. Access to the multi-page application has been severely restricted. I know of several people who are unable to spend time at the library and who have no Internet access. They have approached ARPANSA for a copy of the application details and have been refused. Others were told to approach ANSTO for a copy. Was this merely a Government cost cutting exercise or an unconscionable attempt to suppress community input. It will have the effect of allowing our local Federal MP to make yet another public statement that the community is not interested in the subject.

The Sutherland Shire Environment Centre has had to spend time and effort in informing people who we know have an interest but were unaware of the application. At the hearings of the Public Works Committee on 5 May the writer had the opportunity to let Dr Loy know his feelings on the subject of lack of access to the application and he was able to have three copies sent. They arrived on 12 May - half way through the public viewing period leaving little time for serious consideration of the issues. (Your 'phone call on 17 May advising an extension of two weeks was welcome but a lot of frantic effort had already taken place!)

Third, have the Health and Safety Committees of ARPANSA, which include community representatives, been set up yet? Do either of these groups have any input to the licence application process? If they have, but do not yet exist, how can the process work?

Fourth, and this has been mentioned previously in correspondence with Dr Loy, there is terminology in the Legislation and the Regulations of ARPANSA which give cause for community concern and anger. This has now appeared in ARPANSA's site licence information sheets. Section (e) referring to radiation doses contains the phrase "having regard to economic and social factors". This is repeated further down the same page. To include this odious expression when referring to the magnitude of radiation doses which may be allowed to an individual and the number of persons exposed will leave you open to criticism for the life of the new reactor. You must realise that the expansion and extension of nuclear activities at Lucas Heights is being imposed on the community. All references to public opinion polls having been ignored in Government decisions.

Fifth, the suggestion that local community groups or individuals provide descriptions of, or references to, international practices which should be taken into consideration by the CEO is another example of lack of understanding. At the outset of this long operation, when it was announced that ANSTO was to receive $6 million towards its EIS and the tendering process, requests were made for funding to assist the community to access independent sources of information. This was quickly denied. We would have been delighted to travel abroad, at Government expense, to gather information from nuclear sites which hold both research reactors and radioisotope production plants close to large communities (if we could find any). As this was not possible our submission will deal with the situation as we see it and primarily from a local viewpoint.

A Digression: Will this submission be sent to ANSTO for its appraisal? This was done by Environment Australia during the EIS process and by the Parliamentary Standing Committee on Public Works, presumably using ANSTO in its role as advisor to Government. ANSTO is really running the whole show, producing, directing and providing the cast.

The Process is Back to Front

From a logical perspective, the first task of ARPANSA is to licence the Lucas Heights site for all those activities which have been carried out, unlicensed, for the past 41 years. The next priority should be to licence - or perhaps shut down some of those activities.

They include:

    . HIFAR.

    . Storage of nuclear fuels.

    . The emissions to the environment - specifying the maximum levels and specifying penalties for their breach.

    . The radioisotope production, packaging and despatch plant with its associated emissions.

    . Production and storage of radioactive wastes. The storage and management of spent fuel (including an investigation of how "rainwater" entered the dry store facility; when it is believed to have happened; who was at fault; how long did it remain undetected; why did not the IAEA inspections uncover the problem. ARPANSA should access all documents, produce a report and make it public.

    . The Hot Cells.

    . The storage of liquid waste from the production of Molybdenum 99 (including an assessment of ANSTO's performance since the 1988/9 report of the Safety Review Committee and subsequent reports, calling for urgent action on what it considered to be a safety problem which could lead to off-site consequences).

    . The Little Forest burial ground should be licensed as a permanent radioactive and toxic waste dump. When the question of medium/long term plans for the site has been asked of ANSTO the response is merely, " We will continue to monitor it". The expected life of the site should be made public.

When I mentioned the apparent reversal of licensing priorities to Mr Macnab ( first the site licence for a new reactor) at the Public Works hearings, he said that it was at ANSTO's request. This raises the point of who pushes the buttons, ANSTO or ARPANSA? It appears that ANSTO can say give us the site licence now so that the tenderers for the new reactor can be sure that they will have somewhere to put it. Perhaps ARPANSA needs someone with the swagger, elbows and boots of a Richard Butler to show who is in control.

To make matters most confusing is a report in the St. George Leader 25 May. page 11, which says " Part of the agency's role is to oversee operations at ANSTO. But before this can happen, ANSTO must apply for licences for all of its operations.............A spokesman for ARPANSA said ANSTO had until August 5 to apply for licences for all the activities undertaken at the site, including the [Little Forest] burial ground. The spokesman said that until then, ARPANSA had no control over the site or what goes on there." (Emphasis added)

So, if this correct reporting, who is responsible for the regulation and overseeing of ANSTO over the next few months. Out of this apparent Black Hole, who would come forward should the impossible accident occur?

The Licence Application

Description of the Facility and its Site (pg. 3)

The description of the new reactor is like a dealer describing the shining new Holden (ANSTO compares HIFAR with a 1950's Austin) as an object with four wheels, six glass windows, five seats, an engine of three litres capacity and brakes. A discriminating buyer would walk away from the yard with such a lack of detail.

The spent fuel storage pond will be suitable for up to nine years storage. What is the fall back position should overseas reprocessing become unavailable? Domestic treatment of spent fuel, conditioning, storage at Lucas Heights, must be factored in as the future of reprocessing is not set in stone. As we all recall, Dounreay closed only three or four days after Professor Garnett expressed her great confidence in the "agreement" with the Dounreay plant and their continuing relationship, to the Senate Committee inquiring into the new reactor project. An agreement is not a contract and details of the contract with COGEMA have been refused to the Public Works Committee as being Commercial-in-Confidence. Such an attitude is not in either the National Interest or the Public Interest.

Will the existing dry storage facility be phased out? This would exacerbate any problems resulting from the overseas option disappearing. Would spent fuel be sent to a national waste dump or storage facility? Would the "low cost industrial building" be suitable for unprocessed spent fuel? Would it be acceptable to South Australia.

Indeed, what is the situation if the national waste dump is delayed? It has taken twenty years for that project to get as far as it has. What actually eventuates or is planned in South Australia has a direct influence on the activities on the Lucas Heights site.

Under Design, the final dot point has that disgraceful reference to " social and economic factors taken into account." Totally unacceptable from a community standpoint.

The Site (pg. 4)

The reference to an alternative site selection process is false as is obvious to all. The Government will not release its "study" due to Cabinet-in-Confidence is because it is ashamed to admit that it did not carry one out. The McKinnon Report said that "If a decision were made to construct a new reactor, it would not necessarily best be placed at Lucas Heights. An appropriate site would best be decided after exhaustive search and taking into account community views. Any siting decision should be based on criteria similar to those developed by the National Resource Information Centre (in its search for a low level waste dump) with an additional range of economic and scientific criteria." (1993 Research Reactor Review 20.1-2.) But is this is outside the sphere of ARPANSA?

ANSTO maintains that "The relocation of infrastructure and personnel to a new site would significantly add to the costs of a new research reactor." (Website) This is no justification for building a reactor at Lucas Heights! There are many issues more important to this community than the cost of the project. It should be noted that neither the EIS nor the Research Reactor Review did not include a cost/benefit analysis which should have been an essential part of the process.

The real reason that Lucas Heights was seen by the Federal Government as being the best site, was that it knew that no other community in Australia would accept it. It also believed that the Local Council would be compliant as would the surrounding population.

Neither does it comply with public opinion . ANSTO's recent public opinion poll - commissioned at a cost of $40,000 of taxpayers' money - found that 83% of Sutherland Shire people surveyed thought that a new reactor should be in a "remote location". That poll was arrived at before there was any announcement of a new reactor. It should be repeated now to gauge any change in attitudes. The results of the ANSTO survey was consistent with this Centre's 1992 poll which found that 81 % people felt that a new reactor should be away from population centres. The Community survey carried out by Sutherland Shire Council in 1998 showed that 77% of respondents were concerned about a new reactor. The Commonwealth has ignored each of these findings.

Will the fact that the granting of a site licence in the face of public opinion will divide the community for the next half century be taken into consideration by ARPANSA?

Facility Management Plans (Page 5)

Here ANSTO continues the approach to the regulator, as it did to Environment Australia; " we can't tell you the specific management plans for the facility as they haven't been developed in detail........Such plans will be provided in more detail in the next application." Etc. etc. etc.

The outline in the list of draft plans is deficient. It fails to include a Synroc plant to deal with, in the future, the long lived liquid wastes from the Molybdenum 99 production plant. This, we are told, is in the process of being solidified following which it will be stored at Lucas Heights until it can be enclosed in a Synroc material. This process and the long term (specify how long) storage should be mentioned in the site licence application. Will the licence mention the long term storage of these intermediate level wastes (described by the Canadian Nuclear Inspectors of ANSTO as High Level, but no matter, we know best)? Will it specify the expected length of time storage would be necessary at Lucas Heights?

It fails to mention spent fuel conditioning or processing. This is referred to in the suggested amendments to the EPIP Act 1974. Whilst ANSTO and the Government will deny that this will take place, once the site is licensed and a new reactor up and running there would be nothing to prevent such operations being added. It would merely need a licence. Any protestations from Council, State Government, local Federal MP's or even the nearby community could be brushed aside. A licence should clearly state whether it will be possible in the future or rule it out specifically.

It is good to see that decommissioning is being looked at. Around the year 2100 whoever is around at the time will be able to take the plans out of a drawer and see who signed them and the licence. They will probably think, how crude they were in those days. Fancy believing that the ground could be returned to a greenfield condition, especially as the original HIFAR was enclosed in concrete in 2080 and its full life is still debatable.

A digression: Schedule for the Replacement Reactor Project. (Page 6). The schedule completion date for the tendering process April and June 00. The last time this date was used was in Cambodia - by Pol Pot- Year Zero.

The Project Management plan (pg. 7)

Does ANSTO have a Chief of Engineering yet? When Minister Minchin attended the opening of the new environmental laboratory on November, this post was vacant. What happened to George Malosh who was in charge of the new reactor project? He disappeared without any fanfare two weeks after giving a talk to residents of Sandy Point about the new reactor project.

The Safety Management Plan (pg. 10)

Management of Change and control of facility modifications, systems to ensure changes are controlled and the unexpected avoided.

The rhetoric describes a perfect situation in an imperfect world. But it raises a pertinent point. During 1990 three of the scientific staff at ANSTO committed suicide, one in May the others in December ( The St. George Leader 20 December 1990) . At that time ANSTO was having severe morale problems due to threats of redundancies. Little has changed according to very recent reports in the local press. Union meetings have taken place following attempts by ANSTO to reduce redundancy payments. Staff are expecting lay-offs. It is likely that ANSTO's Human Resources department is unaware of the Safety Management Plans as described in this licence application.

If staff are so stressed as to kill themselves then their depression could burst out in other ways.

The Security Plan (Page 13)

Which brings us to the subject of sabotage which was brought up graphically by the former head of engineering at ANSTO, Tony Wood in his submission to the EIS. He was describing his worst case scenario which was far worse than ANSTO could imagine. But his comments were trivialised and generally ignored by ANSTO in its response. In this section of the licence application there are more repetitions of the apologies for not having any design details and that ANSTO will get back to you later. Whilst Environment Australia was sloppy enough to let this pass we expect much, much more from ARPANSA.

ANSTO claims that sabotage is not credible. But if the authorities in Oklahoma had been asked the possibility of a large government building being blown apart by a utility full of horticultural products purchased from the local hardware store, they would have laughed. ANSTO has no understanding of world events outside its limited sphere of endeavours or the manner in which terrorist operate, but the results of sabotage could be catastrophic to residents here. We will be meeting with a representative of the Australian Safeguards Office in June and will be sure to ask for an opinion.

It is up to ARPANSA to use the Precautionary Principle effectively ignored by Environment Australia and have a new reactor site moved away from any residential area. That research reactors "are sited in the centre of town in the US and Europe" is of no interest to this community. If other countries have no regard for the safety of their citizens it is their problem.

Incidentally, is ARPANSA able to carry out covert attempts to obtain entry to the ANSTO site? There might be something to learn.

Public Liability

Perhaps the most important issue so far as the community is concerned.

In our submission to the EIS Supplement 3, a challenge was put to Environment Australia . That it send details to one or more Australian insurance companies, of ANSTO's claims in the EIS on its emissions, its health studies, its claims as to the safety of the new reactor and that, even in the most extreme accident, nobody could possibly come to any harm. That it end with the paragraph on page 11-63 of the Supplement as to the suitability of Lucas Heights as a site for nuclear facilities. Ask them, in light of this overwhelming confidence expressed by ANSTO, if they would reconsider insuring local residents.

If they did not agree, their reasons should be asked. If they would not provide insurance cover then Environment Australia should see that ANSTO's arguments cannot meet commercial risk standards and the project should be scrapped.

The Environment Assessment Report on the Proposed Replacement Reactor at Lucas Heights by Environment Australia, February 1999, Section 8.7 sets out the Australian position. It notes that Australia has signed the Convention on Supplementary Compensation for Nuclear Damage but that this requires the contracting party to have legislation in place and that the country ensures the availability of funds for compensation. It confirms that such legislation does not exist and "was not likely until some time in the future, as the convention required ratification by one third of the world's nuclear power generating countries before coming into force".

Environment Australia then passed on to other matters and left this most important subject hanging in the air, unanswered. Our enquiries to commercial insurance companies has confirmed that their standard exclusion clause on nuclear and radiation accidents remains in place.

ANSTO now boasts (Page 33, paragraph 88 of its submission to the Parliamentary Public Works Committee) of a Deed of Indemnity (an insurance?) signed between it and the Commonwealth which protects ANSTO and its staff if it should lose a common law claim following an accident. This does not reassure the local community. Page 34, paragraph 89 implies that individuals would be better off having a fifteen year battle against the Commonwealth in the high court than merely filling out an insurance claim form - that is if the insurance companies here would cover them.

ANSTO's comments, not unexpectedly, miss the point. and are an insult to the local communities. The standard exclusions from Australian insurance policies include only one industrial or scientific area. That "arising from radio-activity or the use, existence or escape of any nuclear fuel, nuclear material, or nuclear waste". We are talking about the ability of the local community to take out personal and property insurance, not having to take the government to court under common law.

The common law option would involve individuals taking ANSTO/the Commonwealth to a high court and proving both cause and negligence. The costs would be enormous and would involve the admission of evidence from experts, who would all demand high fees for their services. In turn, the Commonwealth, which has boundless funds, would contest the case. If it lost then it would appeal. We have seen the system in action before. The Voyager, Agent Orange, the Stolen Generation. Some have dragged out for many years.

ANSTO's response to public submissions to the Parliamentary Standing Committee on Public Works contained even more extravagant and unsubstantiated statements on liability. In section 11, Liability, it states that "...it not a [sic] essential that ANSTO first be taken to court and a judgement be given against ANSTO for the indemnity to apply as such claims may be settled out of court. In this respects, the indemnity works just like commercial insurance. It is clear therefore that residents are fully covered by this indemnity to an extent even greater than they would be under the terms of commercial insurance."

In a letter to ANSTO dated 10 May, a copy of the Deed of Indemnity was requested. It has been promised, but to date has not been received. As part of the site licence application this matter must be an essential part of your assessment. That Environment Australia and the Minister for the Environment saw fit to ignore the liability issue was a great dereliction of duty.

ARPANSA must not follow their example!

The Radioactive Waste Management Plan (pgs 12 & 13)

Whilst the actual Plan is not available for public viewing, the Policy ANSTO/E728, May 1996 is somewhat out of date. References to the "engineered dry storage facility for spent fuel" at Lucas Heights has proved less than satisfactory and references to reprocessing at Dounreay are now history. However it admits that " Australia still requires to develop a geological repository for long lived intermediate level wastes ". In spite of numerous contacts with the relevant Government Department the subject is nowhere near the front of the mind of any bureaucrat.

It also admits that " it will eventually be necessary to establish an independent domestic solution for spent fuel management . And that " it is appropriate to consider potential domestic conditioning options for spent fuel". Neither are being discussed, at least publicly, but when they are Lucas Heights would have both the technical equipment and manpower. And ARPANSA would no doubt give ANSTO a licence.

Emergency Planning

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 to outside agencies from ANSTO personnel. A copy of the DISPLAN is held by the Sutherland Shire Environment Centre.

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.

Emergencies in 1994 and 1997 involving fatal bushfires where evacuation was 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 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 by Keys Young towards the end of the EIS process between ANSTO staff and the community.

Public Information on Nuclear Emergencies. Considering that HIFAR was commissioned 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 thirty eight 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 which organisation had produced it. It was letterboxed shortly before Christmas 1996, at the height of the seasonal junk mail period. Whether this was a deliberate action or merely gross inefficiency is open to debate. The majority will have gone straight into the paper recycling bin. Unseen.

An updated version was distributed towards the end of 1998. It related only to HIFAR and not to a replacement reactor.

Community Interaction. Reference is made to a course for teachers with responsibility for health and safety at local schools. This was held at the Lucas Heights Research Centre 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?

After its release, questions were raised with the Hon. Ian McManus, who was both a local State MP and the Parliamentary Secretary to the Minister for Emergency Services, as to his opinion of the leaflet. His astounding reply included "Should you have any concerns about the emergency procedures I would suggest you advise ANSTO direct. This is a very specialised field and not one that politicians should try to tell the experts what to do" This from a person with responsibilities under State legislation to both the general public and to his own electorate. He did not even understand that ANSTO only has responsibilities within its own perimeter fence. Outside that zone it is up to the State emergency services.

The leaflet deals with the situation in the schools with the dismissive comments "Schools, like other organisations, have a duty of care in respect to persons on their premises should an emergency occur. it is their responsibility to have and implement emergency arrangements if necessary." It also refers to "[Sheltering] could be up to several hours and would not preclude short periods outside, as required." This appears to be code for school children being allowed to to go to the outside toilets. The advice also contradicts the reference to companion animals. "Let pets into the house but do not go looking for them"

Purely on the grounds of its risk to surrounding communities and the inability to provide or even describe adequate emergency plans, the idea of building another reactor at Lucas Heights should be scrapped.

Risk

The 1990's have shown the highest temperatures recorded on the planet in world history. July 1998 being possibly the hottest month. As mentioned previously, the Lucas Heights area had fatal bushfires in 1994 and 1997. But ANSTO persists in its averaged view that severe bushfires can be expected every 8 to 12 years. (Every time a worker gets a sudden blast of radiation the amount is quickly averaged out over a period of months or years to minimise the apparent effect.) The hot temperatures may be the result of human activities which have increased exponentially over the past half century and which show little sign of diminishing.

If a sincere site selection process had been carried out, as was the case during the search for a national waste dump using a wide range of criteria, then Lucas Heights would have been rejected. As indeed was the whole of the Eastern Australian seaboard for the waste dump. Why would a site with poor road access and a bad bushfire record be perfect for a nuclear reactor? To quote Mallory, "Because it is there".

There is little the average mortal can do to lessen the risks from natural events as the recent savage hail storm in Sydney proved. Living at the base of a smoking volcano or in a flood plain is a known risk, the results of which can be devastating. The choices for those people are most often limited by economic reasons. Traditionally the effects of droughts, floods, famines or plagues have been a constant but unpredictable risk to life and livelihood. Since the Industrial Revolution, those natural risks have remained but, whilst bringing economic advantages, there has been added the risks from industrial pollution and accidents. To an extent - choices have still remained as to whether one should work in a coal or asbestos mine and take the risk of an early death or debilitating illness or to move to another region.

Then there is the problem which faces this community today which is that of a situation of risk which is being imposed on it. If the imposition had come from a State or Local Government source you can be assured that it would not go ahead. First the State environmental assessment laws, with far greater strength than those of the Commonwealth, would have come into force. An EIS would have been necessary before a decision was made, not after the event. Also, should the State decide on a project or development the local council and/or objectors have the right to an inquiry into the information - and the risk assessment - contained in the EIS. Such a public inquiry has been asked of the Commonwealth but, as with every other request, it has been rejected.

The imposition of a risk situation on a Sydney suburb by a Commonwealth Minister who lives in Western Australia or South Australia is both unfair and unjust. That the Minister for the Environment has the sole discretion as to the level of environmental, health, safety and risk assessment goes against the interests of this community. The so-called national interest eclipses the local interest and ignores the social and economic investment put into the area by this community.

Professor Anthony Giddens, as part of his recent Reith Lecture series on the BBC describes today's relationship between the scientific community and the general population. He says that "we cannot simply 'accept' the findings which scientists produce, if only because scientists so frequently disagree with one another, particularly in situations of manufactured risk. And everyone now recognises the essentially sceptical character of science." Everyone, it seems except ANSTO and the Commonwealth Government which are totally convinced that the risks presented by a new reactor and increased activities on site, will be negligible.

Giddens also presents a case for professionals to be honest and express their concerns as they see them. "In these circumstances, there is a new moral climate of politics, marked by a push-and-pull between accusations of scaremongering on the one hand, and of cover-ups on the other, If anyone - government official, scientific expert or researcher - takes a given risk seriously, he or she must proclaim it. It must be widely publicised because people must be persuaded that the risk is real - a fuss must be made about it. Yet if a fuss is indeed created and the risk turns out to be minimal, those involved will be accused of scaremongering."

"Suppose, on the other hand, that the authorities initially decide that the risk is not very great, as the British Government did in the case of contaminated beef. In this instance, the government first of all said: we've got the backing of scientists here; there isn't a significant risk, we can continue eating beef without any worries. In such situations, if events turn out otherwise - as in fact they did - the authorities will be accused of a cover up - as indeed they were."

Tony Wood, in his submission to the EIS said that the worst case accident as presented by ANSTO was understated. He also noted the deficiencies in public liability. ( He also said that ANSTO's Draft EIS was full of half truths.) We like to believe that he would have taken the same line had he still be employed as Head of Engineering at ANSTO. That it takes retirement from the service to offer a sincere evaluation of a situation is, whilst understandable, disappointing. On the other hand, ANSTO in its Summary and Conclusions to Appendix C page 23, claims "... the consequences of any credible accident at the proposed replacement reactor at LHSTC will be substantially less than the consequences of the reference accident." Confident, bold and arrogant.

The EIS, Environment Australia, the Minister for the Environment, the Minister for Science have all seen fit to ignore the effects of the risks perceived as real by this community. That ARPANSA is also part of a government department leaves us with the expectation that it will follow a similar path. But we hope for an honest and independent rejection of the site application.

Health

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

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

Current scientific studies in the UK suggest that even radiation exposure less than 1mSv may be harmful and could be poisoning the human gene pool (New Scientist Oct. '97) Yet we are daily subjected to routine emissions of radioactive gasses from the nuclear plant at Lucas Heights!

ARPANSA's brief is to protect workers in the nuclear industry and the population from the effects of harmful radiation. When the draft Legislation was put out for public comment it was noted that the word "harmful" was not defined. That deficiency was, we believe, not corrected. Until it is we will not know what level of harm the regulator will be considering. Are you only concerned with the worst case cancers or will you be examining the more subtle effects of radiation? If so, how will you go about this? Will you have investigative staff or will you rely on the NSW Health Department? This is yet another instance of the local community being left wondering. Will we know when the Health Committee is initiated?

Conclusion

Having spent the past two in close contact with the Government, politics at all three levels and the bureaucratic process, one laments for the democratic system. Whilst there in theory it is singularly absent in practice. We have however taken part in the flawed process, hoping that our voice will be heard and that reason will prevail.

During that time we have listened to Ministers hiding behind "Cabinet-in-Confidence"; watched ANSTO executives tell Senators and Parliamentary Committees that they cannot see important contracts due to "Commercial-in- Confidence"; been evaded by Department staff "due to the terms of the legislation". We have seen local politicians change political course, en mass, at the same time and on the same day. Waited for weeks, sometimes months, for replies to important questions and then received unsatisfactory answers. Our respect for the process has almost reached rock bottom yet we continue to present the case against a new reactor.

It is our considered view that Australia does not need a new reactor as it is swimming against the world trend. That the funds be set aside and put to much better use into research in the field of a sustainable future for Australia. That, if the Government insists on going ahead, Lucas Heights should be rejected as a site.

Prepared by Michael Priceman
Convenor
Nuclear Study Group

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