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Submission to ARPANSA following an Application by ANSTO for a Facility Licence at Lucas Heights for existing nuclear plant and the HIFAR Reactor

Introduction

A nuclear reactor in suburbia?

The case for placing the HIFAR reactor and its acceptance by the Sutherland Shire Council in the 1950's was based on seriously misleading statements by the then chief of the Australian Atomic Energy Commission (AAEC) at meetings with the Council. Phillip Baxter, later to be knighted, assured the councilors that there would be no radioactive emissions from the plant. As he was the country's nuclear expert his confident advice convinced them that everything was safe. After all it was the time of "atoms for peace" - even though the plant was to be run under the Australian Defence Act.

In hindsight, Sir Phillip was incorrect, for whatever reason. Radioactive wastes have been pushed into the air and to the local river system (now to the sewer) and the community continues to be given assurances that everything has been and will be all right. The local population has mushroomed especially in recent years when it was expected that HIFAR would be pensioned off and the site cleaned up. If HIFAR were to be replaced, then common sense would dictate that it would be sited well away from suburbia.

However, government works not only slowly but also in ways far less than wondrous. The decision to continue the operation of a reactor for the next half-century - and to expel radioactive gases to the atmosphere, was made with the arrogance that one expects from a government with an adequate majority. And with complete disregard to the wishes of the community. However that is not your problem and the matter in hand is whether the Lucas Heights site should be licensed, after 42 years, to operate HIFAR and the radioisotope production plant.

Historically, since the Industrial Revolution began, people have lived close to their place of work and often in dangerous situations. Usually the workers had no option and certainly there was little scientific knowledge of the unseen hazards. At the beginning of the 20th century the knowledge base increased but protection of workers or local residents was not uppermost in the minds of plant owners. The asbestos industry is a case in point where its product was known, almost a century ago, to be a carcinogen but the information was deliberately held back and even today it fights claims of negligence.

More recently in the developed world, when litigation has become the way of claiming compensation, companies are becoming more careful in their ways of operating. The spate of TV advertisements by the NSW State Government about safety and the Worksafe system is an example of this concern. The question of where the nuclear industry stands - like an obsolete lighthouse - regarding public liability will be mentioned later.

Reasons Why The Lucas Heights Site Should Not Be Licensed for Nuclear Activities

Recent Events Involving Accidents and Regulation

The accident (should we describe it as in incident?) at the fireworks factory in the Netherlands should have sent ARPANSA some kind of message. Two days after the explosion I heard an interview on the ABC Parliamentary and News Network, PNN, with a local official. He said that "The factory was licensed, the storage facility inspected, the licence has recently been updated and, to help the process, the army bomb unit had been called in to endorse its safety. It was safe.........(pause)........But the accident happened."

It has not been established whether arson/sabotage was involved but the fact that a factory with the capability of causing such damage was even considered in such an area, not to say licensed, beggars the imagination. Whilst I would not expect a worst-case accident with HIFAR to result in such an obvious catastrophe as that in Holland the results could be far worse than the industry or the licenser works out from computer modeling.

A day or so after the Dutch explosion came the fatal Queensland school fireworks accident. The evening TV report had a heavily uniformed Chief of Police saying that the fireworks operator was licensed, all the equipment seemed to be in order and that there was nothing obviously wrong with the methods employed. But, once again, it happened.

I have no information about the other fireworks explosions in Europe and Mexico that happened within the same seven days. I would doubt that the South American operation was subject to the rigorous licensing procedure as that in Holland but regardless, a fatal accident occurred.

The point that it is intended to emphasise is that, regardless of the misinformation on radioactive emissions which led to HIFAR being built at Lucas Heights in the 1950's, there is no excuse to continue the pretence in the year 2000 that it is a suitable site for a nuclear reactor of any size.

Stop Press: Last week's incident at Kingsford Smith airport in which the radar system went down as did back up system no.1 and back up system no.2 shows that even "defence in depth" safety plans, often mentioned by ANSTO and parroted by ARPANSA are sometimes ineffective when most needed. The scientific community, even more than the rest of us, should know that Murphy's Law is the most consistent law in our tiny part of the universe, but it can't be factored into the computer model.

The Licence Application

In the statement by the CEO of ARPANSA that accompanied the issue of the licence for ANSTO to prepare a site for a new reactor, comments were made about the process. In particular the issue and status of documents that were necessary to make a decision. It mentioned that in future applications ANSTO would need to unambiguously establish which documents were to be relied on and that the significant documents be clearly referenced so that there can be no ambiguity. A clear indication that ANSTO would have to do better next time.

The way that ANSTO presented its information for this current series of applications for the entire site showed that they had either not read the comments of the CEO or had not understood them. Its pages were not numbered consecutively and it was not indexed. Was it good enough for the ARPANSA team? Apparently not. But it took a series of serious whinges before the public was given a time extension, a promise that additional detail would be forthcoming and that the application would be split into sections over time.

Whilst the Sutherland Shire Environment Centre was quickly provided with the ANSTO bundle, other members of the local community were denied this "privilege". They were told that they could access it either at the local library or on the Internet. No hard copies would be made available. Neither were they available in the Southern States where peak environmental groups have a vital interest because Lucas Heights waste will eventually finish up there.

The suggestion that the Internet is the answer shows the lack of understanding of the real world by bureaucrats who are surrounded by top of the range computers and printers to match. All provided by public funds. The average home printer would not be able to cope with the amount of material put out by ANSTO and the cost would be out of the question. I note that the copy provided to the Centre by ARPANSA was downloaded and printed for us. For this we are grateful but we should not be an exception.

The cost of providing similar documentation, as requested by the public, should be allowed for by ARPANSA and charged up to the applicant as part of the licence fee. In reality this would only be money laundering as the public funds every organisation connected with this process. We still recall the $6 million allowed by the Government to ANSTO for its EIS and vendor selection procedure. And, as part of the level playing field, the rejection by the Government when we asked for funding to enable independent research to be carried out.

Out of all this the community perception is that any public input is to "satisfy the terms of the ARPANS Act". Which raises the question once again how much unpaid time and energy should be given to making a submission? If the first licence approved for ANSTO last September is the benchmark then the answer is, very little. The public comments were read, noted and dismissed. In fact a situation similar to that of the EIS process and that carried out by the Joint Parliamentary Public Works Committee.

International Best Practice

Has ARPANSA studied developed world sites similar to that at Lucas Heights which contain a 10Mw reactor used for production and research purposes? One which also has a radioisotope production plant and storage and handling of spent fuel over a 40 year period? And which is situated close to a large and growing suburban area? Suburbs where the prevailing winds, containing low levels of radioactive gas, sigh daily over their rooftops?

If so, it would be good to have examples of their monitoring methods - details of their off-site emergency plans - whether they have regulated maximum allowable radiation release limits. Such information should be shown in the licence approval (can we expect any other result?)
  • Does ANSTO claim to use international best practice in its waste spent fuel handling? If so how does its record conform when it allowed "rain water" to enter its in-ground spent fuel "dry storage" tubes and remain unnoticed for 10 to 15 years? Why did not the IAEA inspectors check the dryness of the containers or did they merely count the seals at the top of each tube?

  • Is ANSTO's monitoring of abnormal gas releases international best practice when last year's release could not be quantified and it did not actually know which day it had occurred?

  • Was international best practice in place when the uranium hexofluoride was released into the atmosphere in the 1980's?

  • Or when there was a half million dollar fire which burnt out a laboratory about 1993?

  • Or when the three spent fuel handling incidents took place in 1998/9? (It must be noted here that in the quarterly report of the ARPANSA CEO for the period 1.10.99 to 31.12.99 these incidents were "noted" in four brief lines. It refers to an ANSTO report on the root cause analysis of the incident but there was no detail at all. If this is to be the standard of the reporting then the long period of anticipation has not been worthwhile. Please have a look at the quarterly reports of the former Safety Review Committee. These should be the minimum standard for such reports.)

  • Or when, in March 1999 an ANSTO staffer received 550 mSv to his fingers due to inadequate management. International best practice? (Again, this accident was noted in the ARPANSA quarterly report for 1.4.99 to 30.6.99 and it was mentioned that a report on the investigation would be made in subsequent reports. A year later and there has been nothing.
It is also important to point out that the CEO's report also said "Initial investigations by staff of both ANSTO and ARPANSA reveal that similar incidents (with lower doses) had occurred previously. Inadequate follow-up and management procedures had failed to prevent a recurrence."

However, to confuse me even more, the statement by the ARPANSA CEO which came with the licence approval to prepare the site for a new reactor, 22 September 1999 page 5 section f) Whether the applicant has shown a capacity for complying with these regulations and the licence conditions that would be imposed under section 35 of the Act (regulation 41(3)(e)), contained the following show of confidence in ANSTO:

"Paradoxically, an organisation with a strong safety culture will discover more 'incidents' than one with a poor regard for safety practices. The important thing is that events are examined and the lesson learned."

It should be pointed out to the CEO that it was only in 1990, long before ARPANSA was a gleam in the government's eye, that the Canadian Atomic Energy Authority carried out a check of the ANSTO plant and found that its safety culture was, in fact, something less than perfect. It left behind a list of recommendations to improve matters. I am sure that a copy would still be available on request.

Waste Management and Storage

There is a conflict of requirement by ARPANSA to licence the Lucas heights site for the HIFAR reactor, in that the site has been deemed suitable for a new reactor but with a caveat that:

'contingency plans describing alternative strategies for disposal of radioactive waste and spent nuclear fuel will also be required with the application for licence to construct the new reactor. A licence to operate the [new] reactor would not be issued by ARPANSA without there being a clear and definite means available for the ultimate disposal of radioactive waste and spent fuel'.

A similar condition was placed by Minister Hill in his EIS approval of the site. The question must be asked, if the new reactor has to have such plans, why not HIFAR? It would also be helpful for us in the future if ARPANSA would define exactly what it means by "disposal" and "ultimate disposal". Whilst both seem to have clear meanings, Government Departments are prone to use different interpretations, especially when relating to an Act of Parliament.

Whilst The CEO believes that the Government has made clear progress on the low level waste dump it is in fact some two years behind schedule. And this merely for the site! He also uses the standard wording of the Government regarding the "commitment to examine co-locating a store for long-lived intermediate waste in association with the repository". The commitment may still be there but the recent political flack in South Australia puts the matter of where the long-lived waste will finish up, in considerable doubt.

Because of the public altercation between the Premier of South Australia and the Minister about the long-lived waste, the Minister has fallen back on one of the clichés of the nuclear industry in that "whilst the matter is of high importance it is not urgently upon us". That attitude leaves us in the position of continuing to produce waste with nothing more than a commitment by a minister who will be long retired by the time the wastes returning from the UK or France hit the proverbial fan.

This leaves ARPANSA with nothing but a "framework to tackle the waste issues", on which to base its decisions to licence the existing plant and the proposed future expansion of the site. A form of words that it will doubtless find acceptable but with little substance and one that will not inspire the community with confidence in the licensing system.

Emergency Planning

It is difficult to write on this subject to the regulator because, as we all know, any off-site emergency is the responsibility of the NSW State Emergency Services. However I refer you to the NH & MRC 49 page paper "Intervention in Emergency Situations Involving Radiation Exposure (1990)". Page 2 gives an example as suggested by international recommendations of a typical emergency situation as "uncontrolled releases of radioactive contaminants from a nuclear research reactor, with the dispersion of the contaminants over a region downwind from the reactor". That is to say the kind of event that we all hope will not happen.

It adds that the controls applied to activities involving radiation sources in Australia, the possibility of any of these scenarios arising from activities in Australia is extremely low. However, as we are aware, accidents occur in the most unlikely situations around the world. For example, the Dutch fireworks factory - licensed, checked by the army experts and which destroyed the local town. And everyone asks how and why did it happen.

Note: It also includes an accidental explosion of a nuclear weapon in a ship or aeroplane. Such an "incident" does not appear to be considered in the ARPANSA (or NSB) annual reports. Whilst you take up the possibility of a leakage of radiation from a visiting ship's reactor, the major accident remains under the sand. Will you be looking at this possibility in the near future? If not, why not?

The NH & MRC dose ranges for primary intervention levels for the public are between 5 and 50 mSv whole body dose. This would involve sheltering. Between 50 and 500 mSv evacuation would be considered. Huge doses indeed but we are told that such doses cannot occur from HIFAR or even from a new Argentinean reactor. Why then should they be included in the guidelines? If they are not possible then surely ARPANSA will be pushing to have realistic dose levels substituted. Please clarify this in your anticipated licence approval.

The final page of the NH & MRC paper says that the success of all countermeasures depends on a clear understanding of their purpose. And, more importantly, that public authorities should develop programmes to educate and prepare communities living in a potential near-field situation. The stress being on pre-event preparation. This has never been attempted and representations to the relevant authority have proved fruitless. In fact the only information ever supplied to the general public in the area was a poorly worded leaflet put out in 1996 and then re-issued two years later. Both laid stress on the unlikelihood of any accident and ANSTO's safety record - which negated the usefulness of the rest of the information.

After representations to the NSW Minister for Emergency Services a study of the existing plans relating to the ANSTO site is underway. The community has had some involvement and we eagerly await its findings. One of the specifics we have asked for is that the person conducting the review, Mr. Brian Carr, looks at international best practice emergency plans where a reactor and an isotope production plant co-exist close to a residential area. It has been suggested that this be the starting point of his inquiry.


But neither ANSTO nor ARPANSA has powers or influence in this area of government. Both are safely ensconced behind the safety of either their perimeter fence or the Terms of the ARPANS Act.

Seismology

When ANSTO applied for its first site licence last year its optimistic estimate for horizontal ground accelerations associated with the 10.000-year return period was 0.17g with an uncertainty of 0.6g. ARPANSA accepted 0.23 as a conservative figure for the proposed new reactor but mentioned that another study, commissioned by the Department of Industry, Science and Resources, was being carried out. Doubtless you will be studying the results which now, optimistically, have chosen a figure of 0.41g.

The question of how the structure of HIFAR would stand up to such a hypothetical earthquake will need careful consideration. When was HIFAR last upgraded to withstand an earthquake? What g force was used for that upgrade and what was the safety factor allowed for an event above 0.23g? Details should be included in your report.

In an article in the St George Leader 15 May 2000, Dr Ron Cameron of ANSTO, is reported as saying that the study was commissioned only to produce "seismic parameters which would be used in the study of the impact of highly unlikely but potentially severe seismic loads on HIFAR" and not to make recommendations about its safety. If it was not about the safety of HIFAR then why go to all that expense of the study?

The effects of such an earthquake, at ground accelerations around 0.23 could have serious effects on the above ground water reservoir at the site. This was pointed out to ANSTO in the Horoschun report in 1985 and it was recommended that the tower be reinforced. and the quality of its foundations examined. The alarming fact that, fifteen years later, this has not been done, displays an over optimistic attitude by ANSTO to possible events which could lead to accidents.

This is the result of having no real regulator until 1999. What power of persuasion has ARPANSA shown in this regard ? Condition g) on page 31 of the 1999 SER calls for the upgrading of the water tower be completed "as soon as is reasonably practicable". This is even weaker language than that used by the Safety Review Committee in 1988 regarding the potentially unsafe condition of the liquid waste from the molybdenum processing plant. It was a decade before ANSTO took that problem in hand.

Radiation Protection

It was good to see that ARPANSA is reviewing the emissions from the Lucas Heights site with a view to authorising (licensing) them. The CEO, in his statement admits that the radiation protection - the reason for the existence of ARPANSA - assumes that any level of radiation exposure carries some risk, however small, of health effects. He also suggests that society has accepted the siting of potentially hazardous industries in populated areas. Of course the majority of such industries were set up in the dark days before EIS processes (however weak these may be) and that the local people were never consulted. If the CEO is correct about public acceptance then perhaps he will give examples in his anticipated licence approval.

Neither were the potential risks advertised. An example of this was the placement of the HIFAR reactor at Lucas Heights in the 1950's. "There will be no radioactive emissions," the experts told the Councilors. And, because it was to be used only for peaceful purposes, the Government used the Defence Act to control the site!

Now local communities are far less likely to accept a hazardous industry in their district without a fight. They are better educated, have become much more informed about the hazards and are able make decisions in the face of public relations hyperbole. In this local situation, when the community has been asked, it was prepared to last out HIFAR because they knew it would have to close down soon. This is not the same as acceptance of a permanent nuclear industry.

ALARA ( As Low As Reasonably Achievable)

HIFAR is one of the oldest reactors in the world and the radioisotope plant is also old and inefficient. They probably pump out more emissions than is necessary because ANSTO is allowed to apply the ALARA system which qualifies and compromises its meaning by the addition of the odious phrase "having regard to social and economic factors" . I recall that Greenpeace, in its submission to the Research Reactor Review, referred to correspondence with ANSTO which confirmed that its procedures used to produce radioisotopes were below international best practice and that they were not being upgraded because of economic factors.

Almost ten years later I am unaware that any improvements have been made and that this is probably the reason that so much radioactivity is emitted from the stacks. How are you able to pressure, request or cajole ANSTO to perform better if it merely throws the economic factor of ALARA at you? Get rid of it from the definition and tell the people you regulate that only the best is acceptable. If they cannot afford the best then they should get out of the game.

This aspect of regulation also has serious effects should a new reactor be imposed at Lucas Heights. Are the existing hot cells etc. to be replaced or at least upgraded? Or will they battle along, inefficiently, as they have done in the past? (If they are to be replaced what would the cost be?)

Regulation of emissions from the site

Whilst the maximum allowable suggested dose to the public is 1 mSv there is considerable latitude being played around it. It has long been suggested that the lower constraints as applied in the US and UK be applied. ANSTO responds by a voluntary commitment to keep below 0.3mSv and asserts that in fact its emissions are far lower than this. Why then is the 1 mSv retained?

There is also the dubious way of averaging, over a five-year period, doses received by either the public or by workers. If for instance there was a release to the public of 4.5 mSv then ANSTO and ARPANSA could refer to the previous five years and assert everything is all right. An event causing a 4.5 mSv exposure, according to ANSTO's assurances that any accident could not have any effect on the nearby population, would surely be severe? Perhaps severe enough to close the plant down?

What I am getting at is, based on ANSTO's assurances and its reported emissions, why will ARPANSA not regulate to a 0.3 mSv level and take action if it is exceeded? Is it because there are emissions to the nearby area around or above 1 mSv, which are averaged out for the public records?

Zero Emissions

Many industries are being forced by strong legislators to install plant with zero emissions. It is understandable that with a forty two year old reactor this would be too costly but the constraints should be applied to any new reactor - wherever (or if) it is installed. ANSTO does not appear to have considered this at all. In fact it has warned that the emissions from the new reactor and isotope production plant will increase over and above existing HIFAR levels. Is this one of the "steps into the past" as described by Dr Barry Allen?

Has ARPANSA any say in zero emission technology for the new reactor? Or is it comfortable in merely carrying out the terms of the Act?

"We all live in a sea of radiation!"

Whenever an ANSTO executive is asked a question about radiation this cliché is trotted out. Like many of ANSTO's statements this is true but does not tell the whole story. Another former ANSTO engineer has mentioned that its EIS contained many half- truths. I was saddened to hear the ARPANSA CEO start off a radio interview recently with the same phrase. Too many visits to the Lucas Heights site?

Parkman picked out such clichés in its review of the EIS. It noted that:

"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 exposures 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."

In spite of this advice nothing has changed, it seems that the spin doctors are still in charge.

Is there a safe level of man-made imposed radiation exposure?

The nuclear industry claims that what they release does no harm but other scientists disagree. Even back in 1985 the United Nations, in its publication Radiation - "Doses, Effects and Risks" said that:

"Radiation doses have to reach a certain level to produce acute injury - but not to cause cancer or genetic damage. In theory at least, just the smallest dose can be sufficient. So no level of exposure to radiation can be described as safe."

For many years the industry has taken as a bench-mark the nuclear bombs dropped on Japan in 1945. It assumed that working backwards from the worst case would give an indication of the effects of low doses. However more recent research has shown that low doses can be harmful and should not be trivialized. In an article in the Medical Journal of Australia 17 June 1996 Dr Derek Roebuck, Radiologist, writes that:

"Seemingly 'non-invasive' tests involve the use of ionizing radiation and carry the risk of causing malignant tumours. This risk is widely underestimated in medical practice in Australia..." Replying to the Hiroshima and Nagasaki studies he said that "there are reasons to assume there is a linear relationship between dose and risk with no threshold, implying that no radiation exposure is completely safe. (It must be recognized that there are those who dispute this.)"

New Scientist, October 1997, has an article on DNA damage caused by radiation. It too discusses the epidemiological studies of Hiroshima survivors It notes that the internationally accepted figure of radiation to a member of the public is 1 mSv but, in spite of these safeguards, there is persistent mistrust of radiation and of the nuclear industry. Dr Eric Wright head of the experimental haematology department at the Medical Research Council at Harwell, U.K. has pointed out that radiation can inflict damage on cells that, at the moment, can only be detected after they have divided several times. He calls this radiation induced genomic instability.

The eventual effects of this can include misshapen chromosomes and mutated genes and early cell death. Dr Wright says that "There is no doubt that genomic instability is a real consequence of radiation exposure."

So, as the community closest to HIFAR and possibly a new reactor for the next half century, we are faced with decisions made predominantly by members of the nuclear industry who ignore all evidence from sources other than their own.

To this point, there is nothing to show that ARPANSA has any opinions that fall outside the nuclear industry standards.

Risk

Off-site emergency planning falls outside your responsibility although ARPANSA should certainly look at the effects of an accident with off-site consequences. Once again we are faced with ANSTO being the advisor to Commonwealth and State governments. With any luck, completely honest and scientific with any advice it gives but at the same time with huge vested interests to maintain. When it claims that the most serious accident imaginable would have no radiation effects outside the perimeter fence and that the emergency services would have several hours after the event to take action, one can understand that State authority slips into a state of calm.

What happens when ANSTO's risk figures are presented to commercial insurance companies? "With a frequency of occurrence of the reference accident at one in a million per year, the maximum risk from this accident of an individual developing a fatal cancer is calculated to be less than one in six thousand million (1 in 6,000,000,000) per year and the maximum risk of any harmful health effect is less than one in four thousand million (1 in 4,000,000,000) per year." ( EIS volume 3, supplement, page 11-3)

Their reply is that, whilst they do not doubt ANSTO's figures they will not provide insurance. When this was mentioned at the Senate Inquiry a Senator suggested that nuclear accidents were "standard" exclusions. In fact it is the only industry against which insurance cannot be obtained. I can buy a house next to Caltex at Kurnell or near the Melbourne Chemical complex that went up in smoke a few years ago or even next to a fireworks factory and get insurance. But not next to a tiny, washing machine sized, peaceful nuclear research reactor. Something smells.

This is an area in which ARPANSA is not involved - under the Act. On the other hand, from a safety point of view, can you seriously ignore the stand of the Australian insurance industry?

ANSTO's Web page claims, with conviction, that the Commonwealth Government's Deed of Indemnity provides residents with insurance cover. Check this out. It is far from the truth. Your Act demands that you look after the health and safety of the public. Have talks with the Insurance Council of Australia, check ANSTO's claims, compare the two and then let your conscience make the correct decision and deny a site licence.

Little Forest Burial Ground

This may not come under the terms of this licence application but at some stage it must. The wastes buried there are monitored to see if any radioactivity has migrated off-site. None has been found so far although increased radioactivity in samples of soil and vegetation has been recorded. ( ARL report, undated ). Whilst all the reports have suggested that, providing the site is not disturbed, it should be safe, we have noted that Environment Australia prefers that the waste be removed from the site. Presumably if and when a suitable waste dump is built.

This presents yet another Catch 22 situation for the local residents. A street in Menai, not far from the LFBG is said to have several cases of severe illness. If there is a connection between this and the old waste dump, should the waste be left there or should it be removed elsewhere? After the controversial Maralinga clean-up could we be sure that the situation could not get worse? The local community such not have to find itself in such a position.

Neither should it have to face uncertainty for the next fifty years of reactor operation and radioisotope production. Do the right thing and present the government with the truth that Lucas Heights is unsuitable for such a project and that HIFAR be shut down as soon as possible.

Stop Press: The contract for the new reactor was signed at ANSTO's Lucas Heights site yesterday. A demonstration by local residents was planned, arriving at 10.30 am. Due to an accident on the Heathcote Road involving a concrete truck and an accident at a roundabout on the Menai Road delayed access to the Lucas Heights site for an hour. As we have repeated ad nauseum , such events occur regularly in this area. Murphy's Law dictates that it would happen if a serious accident happened at ANSTO. When will you understand this?

Michael Priceman
Convenor
Nuclear Study Group
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