Comments in Response to a Referral by ANSTO to Environment Australia; Under the Environment Protection and Biodiversity Conservation (EPBC) Act 1999, Regarding a Waste Treatment and Packaging Facility at Lucas Heights
|Referral Number 2001/342 20 July 2001
Preliminary comments on the process relating to public comment
Apparently when such a referral is made to Environment Australia (EA) and that public comment is called for, all that is required under your Act is to post it on your Website. This assumes, incorrectly, that the public as well as local environmental groups will examine your site (and that of all other appropriate government sites) on a daily basis. This assumption is even more out of touch than other departments who believe that the public eagerly reads the public notices in the 'Australian' newspaper every day. That we learnt of the referral a few hours before the deadline and were refused an extension of time emphasises the perception that public comment is really a nuisance to you. The action required of you is the very minimum and is unworthy of a government organisation that professes openness.
Last year ANSTO applied to ARPANSA for licenses to operate the facilities at Lucas Heights that have been self-regulated for the past four decades. A few weeks ago the HIFAR reactor was presented with its first licence but the other facilities, including the waste management stores and associated facilities, remain in limbo. It appears that this referral is connected with the lack of approval for the waste facilities.
The referral is apparently for an opinion by the Minister for the Environment that its new facility is innocuous and not a 'Nuclear Action' and therefore would be approved without proper examination and scrutiny. Our viewpoint is that the processing/conditioning of the wastes described below clearly show that the referral relates to the treatment of the most dangerous radioactive materials on the Lucas Heights site and that it will be a Nuclear Action as described under the ARPANS Act.
We call for a full Environmental Impact Study so that all aspects of the proposal can be brought out for public scrutiny.
Long-Lived Radioactive Wastes resulting from radiopharmaceutical production
The main area that will be dealt with in this submission is that of the liquid waste that is the result of the production of radioisotopes. A subject that is a vexing and ongoing saga dating back to the mid 1980s. At that time ANSTO realised that it had a growing problem and attempted to set up a plant to solidify the liquid. However it proved so difficult (and dangerous) that it was postponed. In the report by the Canadian Atomic Energy team that inspected the Lucas Heights facility in 1990 it described the liquid waste as 'High Level', a term that ANSTO now rejects due to a technicality. However it requires the same kind of handling, shielding and long-term storage as high-level radioactive waste.
In 1988 the Safety Review Committee (SRC), an advisory overseer with no powers other than to recommend, pointed out that the storage tanks that held the highly radioactive liquid were a hazard with a potential for off-site consequences. It recommended that the problem be dealt with as a matter of urgency. Over the subsequent 10 years, each annual report of the SRC called for urgent action and the CEO of ANSTO promised, each year, that it would receive urgent attention.
Finally, in 1999, a solidification process was introduced and, as at 6 December 2000, 2100 litres have been processed and 6500 litres remain to be solidified. At the same time however the radioactive isotopes continue to be produced and new waste is the by-product. One assumed that it would be immediately solidified but apparently not. According to the ANSTO Communications Manager, Ms Keenan ( Email 6.12.2000) 'The liquid waste from current molybdenum production continues to be transferred to stainless steel tanks before it is solidified'. And ANSTO has said that its production of radioisotopes using a new reactor could increase four-fold. A dog chasing its tail?
The amount of radioactivity contained in the waste from isotope production, as described by ANSTO is approx. 400,000 GBq from the HIFAR Reactor and 1.7million GBq from a new reactor during its lifetime. Even when solidified and dramatically reduced in volume the radioactivity is the same and shielding would be required for thousands of years.
It should be noted that the waste solidified so far is stored 'in two high integrity stainless steel vessels with a design life of at least 50 years ' (emphasis added) (ANSTO Annual Report 1999/2000 page 5.) Only 50 years - for waste that lasts for thousands of years? Its long-term goals are to immobilise the waste in something similar to Synroc but this has been promised for the past 20 years or more. The most logical course would be to immobilise the liquid waste in Synroc directly - as this was the original aim of Synroc. But in spite of the $40 million spent already on the development of Synroc it is still a dot on the horizon. Perhaps a mirage?
Section 2.4 of the referral sketchily describes the activities that the new facility would carry out. Point 2 describes 'treatment of various process liquid wastes generated from radiopharmaceutical operations. The treatment process will include chemical additions (if required) and evaporation, followed by solidification into a matrix'.
This can be placed under the umbrella of ' conditioning '. However the process is very close to that of reprocessing with the exception that unused uranium products are not removed and reused. As you are aware, it is government policy that reprocessing is not allowed in Australia. ARPANSA cannot give a licence for reprocessing. That decision, made at the time of the announcement that a new reactor would be built at Lucas Heights, was based on the outrage expressed, correctly, by the Member for Hughes and her political colleagues in the Sutherland Shire. They were aware of the dangers to health and the environment from reprocessing in the UK and France. Whether they now understand the similarity between reprocessing and conditioning of long-lived liquid molybdenum waste is unknown.
Other specific comments on the ANSTO referral
Section 2.4 Page 3
It is noted that the building 'will not be used for additional radioactive storage on site'. Are points 2 and 3 connected? Does 3 refer to radiopharmaceutical waste? If so would it, after being immobilised in cement, be shipped off to a store - somewhere? Again, if so, how, where and when would it be converted into a Synroc matrix? You must get some specific details here.
Section 3.2 Page 5
'The only service that crosses the proposed site is a buried stormwater drain'. !!! Refer to the possible off site effects of the release of the liquid wastes as suggested by the SRC. What could be better than an old stormwater drain?
Further, 'no impacts on groundwater are expected.' Suppose they are unexpected? Such a statement is unacceptable to this community and should be to EA.
Section 4.1 Page 6
What arrogance to answer 'N/A' to this section. Again, refer to the SRC reports.
Section 6 Page 8
'Briefly provide reasons why you believe the action to be controlled or not controlled.' The answers in paragraphs 1, 3, 4, 5 and 6 are contemptuously vague and should be rejected by EA. It is as though ANSTO itself is demanding that its ridiculous claims be tested by an EIS. If so then you must take up the challenge.
Page 9 paragraph 1 claims that '..drainage will be designed ..to ensure that there are no natural or man-made risks to the building such as by way of water ingress into or under the building.' From this may we assume that it will be better than the building that was built over the spent fuel holes originally set into the ground in the open? It was not noticed for 15 years that some of the 'dry' storage tubes had collected rainwater and had corroded the fuel rods. Neither were they inspected during that time.
Paragraph 4 , airborne contaminants. This looks like more 'acceptable' emissions for the community to contend with. Their acceptability approved by ARPANSA. Monitoring of the exhaust system appears to be yet another grey area where ANSTO may or may not decide to monitor. Not good enough!
Paragraph 8 , shielding. This admits to some materials ( radioisotope waste?) requiring significant shielding. And they suggest that it is not a nuclear action?
The referral is a Nuclear Action in all respects but thinly disguised as a simple building.
ANSTO's claim that it is not a Controlled Action should be rejected.
The Minister should be advised to call on ANSTO to carry out a full EIS (to include a public inquiry).
The Member for Hughes should be informed of this attempt to install, via the back door, the preliminary facilities that would certainly lead to spent fuel conditioning - and even reprocessing. Ask for her opinion.
Convenor Nuclear Study Group
Email address firstname.lastname@example.org
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