Comments in Response to a Referral by Notes for the ARPANSA Public Forum held in Sydney on the 14th and 17th December 2001 and Stage 2 submission
Thank you for the opportunity to speak at this forum. For the benefit of the overseas members of the panel I am here to represent the Sutherland Shire Environment Centre and People Against a Nuclear Reactor, both community based organisations that are self funding and have the safety and welfare of the Shire and its residents at heart.
We are not nuclear scientists. This gives us an advantage in some ways, in that we don't carry the baggage of the technical and bureaucratic jargon that accompanies their communications. Briefly I will cover some of the issues that concern the community.
First the ARPANSA process itself and this forum. The public has already made its stage1 submissions and has been asked to make its second stage. But based on what? We have not had a single response on our first round comments. Not even the anticipated bulk rejection of every genuine The ARPANSA- ANSTO Q & A makes many references to 'Amendments in the next revision of the PSAR'. Other replies say that 'it will be confirmed/clarified in the Final SAR (FSAR). When I raised this with the Experts from the IAEA I was told that the FSAR would be prepared after the reactor was built and that 'this is the way it is done'.
Question: On the bottom left hand of each Q &A page there is a note 'Checked/Agreed:' does this mean that ARPANSA has agreed to every brief answer? And that there have been no follow-up questions?
Question: If this is the way FSARs are produced, is it the World's Best Practice as is supposed to be the ARPANSA way or is it merely the practice that is acceptable to the nuclear industry?
ARPANSA has a number of working parties operating from its Nuclear Safety Committee that I believe are researching the contentious subjects of waste storage and disposal, spent fuel and that Damned Elusive Seismic study.
Questions: Have the working parties finished their research? Will their findings be released to the public? If so when can we expect to see them? If not, why not?
What version of the seismic report are we considering at present? The contentious peak ground acceleration was updated from its original 2.3.g to 4.1g, then subsequently reduced by 10% to 3.7g. All not surprising when one considers the lack of historical data but the questions put in my first submission still remain unanswered.
Questions: What is the usual seismic engineering safety factor that is built into a nuclear reactor that is situated near a growing urban population?
What was the original safety factor built into HIFAR including any subsequent upgrades?
Liquid Waste from the Production of Molybdenum 99
This is another subject that hangs on and on and one that the seismic reports will have a bearing on. The reason for raising this issue which is not strictly connected to the application for a construction licence is to throw some light on the way ARPANSA deals with safety problems, apparently giving ANSTO free reign.
Stored in stainless steel tanks it was pointed out by the defunct Safety Review Committee in 1988 that there was a risk of the tanks being damaged by an earthquake (2.3g?) and that the result could have potential for off-site consequences. Every year for the next decade the SRC brought up the subject to ANSTO and every year the same response was made, that the matter was receiving ANSTO's urgent attention.
After about ten years a scheme was installed to solidify the waste over a period of time. Earlier this year I asked how the project was going and what was happening with the ongoing waste production. It seems that, whilst the solidification was proceeding to plan, new waste was being added to the tanks and that this will continue for the life of the HIFAR reactor. Meanwhile ARPANSA either has or is in the process of, issuing a licence for this storage plant.
Questions: Will ARPANSA advise whether it has licensed the stainless steel storage tanks? If so, has it taken into consideration the continuous reports from the SRC? If not, why not? Again, if it has, what safety engineering safety factors to withstand an earthquake were originally built into the tanks?
Whilst you might say what has the state of Argentina's economy got to do with ARPANSA's decision to grant a construction licence to INVAP it is worthy of mention. I am sure that somewhere in the depths of the Department of Finance the daily figures are being studied with some concern. Today Argentina has to repay over a billion dollars as debt interest. From a grass roots view its relevance to INVAPs ability to construct a safe reactor is extremely important. As is its staying power to deal with follow up problems. INVAP was created under a Federal law that such companies must be fully owned by the government, whether at federal, provincial or county level. (Senate Select Committee, Hansard 26 th October 2000 page LH 207) It is fully owned by the Province of Rio Negro and if the Federal government goes under where will this leave INVAP?
Question: If INVAP, the provincial or the federal government has to initiate large cost cutting measures who, from Australia, will oversee INVAP's capacity to undertake the safe construction of a new reactor?
INVAP - its ability and construction record
ANSTO has confirmed that any technical or design defects or problems are the direct responsibility of INVAP. Anything goes wrong INVAP has to fix it. It is all in the contract we are assured. But if INVAP goes belly up, as we all know happens without notice these days, who would bail out ANSTO? Would we (could we) call in one of the failed tenderers to see if they could fix any problems?
Which brings me to the Egyptian reactor built by INVAP. Articles in the Australian magazine the Bulletin suggested that all was not well with the new reactor, that it had rarely operated and that there were technical problems that might have safety implications. These reports were raised in the Senate inquiry at the October 2000 hearing. INVAP said that it was working at full power when they handed it over in March 1998 and that the amount of use was up to the operator. No problems!
When ARPANSA was questioned on the issue it said that one of its senior mechanical engineers had visited the Egyptian reactor a year earlier and was able to talk to the INVAP engineers, the operator and the Egyptian regulator about its design, construction and operation. The impression that he gained was that it was a well-constructed, well-designed reactor and that the limitation in its operation was due to the demand put on it by the operator rather than a limitation in its design and construction.
A year later ARPANSA had second thoughts and Dr Loy and Don Macnab had a two day visit to Egypt. The public outcome was a single page PR release which contained mere hints of the problems that seem to confirm the Bulletin article. In true Public Relationspeak it was confirmed that ' there are a small number of important technical issues that still need resolution if Egypt is able to operate the reactor at full power. Of particular interest in the Australian context is the method of calculating the power peaking factor in the reactor core and the formation of bubbles in the reactor pool. That such issues arise in the commissioning of a new reactor design is not surprising or unprecedented. Technical issues have arisen in the commissioning of new reactor designs before now. Canada has not yet been able to fully operate its new Maple reactors and the Hanaro reactor in South Korea had to operate at less than maximum power for some time after commissioning.'
When I asked for a copy of a more detailed report on the visit Dr Loy replied that there was not exactly a report and that any other details were in the heads of himself and Mr Macnab. Whilst levity is often a good tool for getting a message across, this response made me wonder - again - why I bother to spend my valuable but unpaid time on this organisation.
Questions: Is it correct that advice was requested from another manufacturer to get the problems fixed? If so which manufacturer was it?
Four years after the hand-over by INVAP is the Egyptian reactor working as regularly as the operator would like?
Is the ' formation of bubbles in the reactor pool ' a safety issue?
What did the Minister for Health say when you told him that the report of the visit was in your head?
If a new reactor is built by INVAP and it is not working satisfactorily after four years, (described in your press release as being neither unprecedented nor surprising) does ANSTO have enough competent staff to operate HIFAR and a recalcitrant one? How long would you extend the licence for HIFAR without an upgrade to bring it up to 20 th century standards?
Security and sabotage
I may have mentioned earlier that the expectations of any of our concerns being recognised by ARPANSA are minimal. We assume that we are assumed to be on a lower level of understanding and have to have things spelled out to us slowly. Sabotage for instance. In 1999 this was raised in several submissions relating to the preparation of a site for a proposed new reactor. In addition to the unwashed and ignorant, a former chief engineer and operator of HIFAR eloquently and descriptively raised the subject. The response from Dr Loy was terse and dismissive 'Of course it is possible to posit all sorts of simultaneous disasters and suggest superhuman powers to saboteurs or enemies; but that does not help the careful evaluation of a real-life proposal.'
To my knowledge, no-one had suggested that saboteurs had superhuman powers except Dr Loy. We had described how sabotage was a possibility and for that reason Lucas Heights, close to a large and growing population was an unsuitable site. The real life situation that the CEO was in was that the Cabinet had made a decision to build a new reactor at Lucas Heights and that he was obliged to approve the site licence.
It would be good to hear a retraction of that 1999 statement in the light of the events in New York. It should be acknowledged that the world's awareness of terrorism has changed - even though it has been widely used in Spain, the UK and Northern Ireland, Sri Lanka and Russia for many years. The perpetrators are far from superhuman, merely people willing to sacrifice their lives for reasons outside the range of western understanding.
Question: Will ARPANSA review its licence approval for the Lucas Heights site in view of new information on what sabotage is in the 21 st Century? Even if this placed the organisation in an untenable position with its Minister.
One of the strangest comments that senior Government Ministers repeated relating to the possibility of sabotage in Australia was that, 'there was no specific threat.' Ministers, there never is (except in Ireland where coded telephone warnings are sometimes given to the police). It just happens.
Recently ARPANSA asked ANSTO to reassess its security measures for the site. Not a bad idea but an independent assessment would have been better. I heard this on the early morning ABC Radio National News. It was followed by a quote from the CEO of ANSTO to the effect that a direct hit from a large aircraft was unlikely - that the reactor is so small and mainly underground that it was unlikely that it would be hit. It seemed that the reassessment had been done before breakfast.
Question: Did Dr Loy take the ANSTO CEO to task for her pre-emptive comments?
It should be noted that the reference to a direct hit by an aircraft was an accidental event as were all the descriptions of such an event in the ARPANSA/ANSTO Q & A that were mainly drawn up in July.
An Aircraft Attack
It has been pointed out to me that a key factor in the ability of a new reactor to withstand a deliberate attack from an aircraft is the protective grillage. Q & A on chapter 4, Buildings and Structures, page 15 has the comment from ARPANSA that 'It is not clear why the aircraft grillage governs the design since this is a much less frequent event than the OBE and SSE seismic events.'
The ANSTO reply mentions ' Aircraft impact loads govern the roof design due to their magnitude despite their low frequency of occurrence.'' Further details will be available once the detail Engineering is completed.'
I have been advised to obtain a copy of a report that details the way the grill is designed to ensure that it is practical and not merely decoration. Q & A page 12 question 4.25 refers to a small jet aircraft and the unique grill designed to absorb the impact without damage to the reactor and the pool. It also refers to a resultant fire that lasts 20 minutes. ARPANSA asks for the rationale for reliance on the grill at the expense of a stronger containment building. A goods question.
ANSTO's replies may have been valid before 11 September but are they so today? They also refer to the grillage as serving as an architectural feature - which is a worry.
Question: Is ARPANSA following up on this feature or has it accepted ANSTO's reply?
Since July I have been trying to get a copy of a report titled Part C Replacement Research Reactor, Design and Methodology that deals with the grill. First it was said to be commercial in confidence and more recently under a security embargo. I received a reply from John Carlson of ASNO yesterday confirming this.
The odd part is that I was told by an ARPANSA officer recently that the document had actually been on display in the public ARPANSA library in Miranda for some time but was now withdrawn. I fail to see how a document can be set aside as a security document after having spent time on public display.
Question : Could ARPANSA say how long the document was on display - dates please? Have they kept records of who examined it?
Will ARPANSA re-examine the grill design to see if it would withstand the force of a large passenger plane deliberately flown into the building?
I will end now but would like to point out that there are many issues mentioned in stage 1 of public submissions. Rather that you asking me questions for the next 40 minutes it would be more stimulating if you were to respond to the points that I have raised today and the other issues - waste disposal, temporary or permanent - insurance against a radiation accident - reprocessing, processing and conditioning - emergency planning, that remain unanswered.
Nuclear Study Group
Sutherland Shire Environment Centre
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