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Comments on the Application for a Construction Licence
Following the Public Forum

First I will mention that the forum proved better than was expected in that views, opinions and even some facts were aired in public and were questioned. There was certainly enough to make it obvious that there is much to be done before ARPANSA approves a construction licence. Should a licence be granted in February, as was forecast by Dr Loy in his original timetable, then the forum would have been a mere talk-fest and a waste of everyone's time.

As briefly as I can, here are some of the areas that must be examined in great detail by ARPANSA and others referred to government before a decision is made.

Why a reassessment of the Site Licence must be carried out.

Sabotage was ignored as fantasy during the original licence application. Fantasy became reality on 11.9.01 to the extent that US 'experts' visited Hollywood afterwards to hear from scriptwriters what they should be on the lookout for. It seems that US bureaucrats have little imagination.

The ease with which Greenpeace activists entered the LH site on 17 th December displayed the total lack of security that applies to the site. The claims by ANSTO and ASNO at the forum were invalid and made little sense. Real terrorists would have had them for breakfast. Even the IAEA admits that it is impossible to prevent such acts.

ARPANSA has not had the opportunity to examine green-field site alternatives. Government had made the decision that Lucas Heights was suitable - that there was no risk to the public in any circumstances so the closeness to residential dwellings was of no consequence. All that was needed was the stamp of approval from the new regulator. ARPANSA should call on government to allow it to compare Lucas Heights with a number of alternative green field sites.

There is now total uncertainty as to a worst-case 'accident' following 9/11/01

The suggestions go back and forth and each example is waived away by ANSTO as being of no matter. ARPANSA must dig deep and decide what would the effects of a worst- case accident - and of course sabotage - and how it could affect the health of the closest residents. By this I am not referring specifically to deaths but to other non-terminal radiation such as thyroid cancers that may not necessarily be terminal.

Regarding the latter I refer to the comments made in the appendix to Dr Williams' report on the forum. I would appreciate a response from ARPANSA as to the accuracy of his figures that are scary. Also the remarks by Dr Higson on pages 30/31 of the hearings of 17 th December do not fill me with the confidence displayed by ANSTO. " I can envisage circumstances in which there could be...a real possibility of doses which might - local to the reactor - which might cause cancer but I could not see that these have been widespread. This would be, strictly speaking a local effect." If he alludes to local meaning local residents then this should be made clear to the public that there are real risks and that if the reactor goes ahead it will have been approved by ARPANSA with this clearly in mind.

Lack of a valid emergency plan

When I read the transcript of Mr Tony Wood's address on this subject (pages 5/6) I confess to almost shedding tears of frustration. He described in his usual clear uncompromising style what I have been saying over the past ten years in submission after submission. Surely at some stage someone will begin to take notice now that someone with experience and credentials is saying the same. The agencies that have the responsibility of dealing with an emergency have been lulled into the idea that a worst case accident (on HIFAR) would take several hours to take effect and that any effect would be negligible. A new reactor ' would be even safer' .

Mr Wood also raised the issue of Iodine 131 that could be released in his worst-case postulated accident/incident. He suggested that the test for a good emergency plan would be if it could demonstrate that procedures are in place to ensure that the most exposed members of the public would receive notification of the accident and advice to stay in doors within half an hour and that they would all have potassium iodide pills within 1 - 2 hours.

At present the plans are being re-written to make them 'more reader-friendly'. I doubt that his suggestion will be mentioned in the new plans.

I ask that APRANSA takes up this issue with the NSW Department of Health and get its assurance that it is capable of distributing of the pills in the required time. Failing this then it should examine the issue of the pills to each household in the immediate area of the site. If you are then not satisfied that this can be done then you should not grant a construction licence.

Alienation of the land may be perhaps for a short time only after an emergency we are told. Is the local population aware of this? Why does no government department take this issue into consideration? If there is 'only short term' alienation may we presume that neither ANSTO or the Federal Government would take responsibility for loss of value or the possibility of psychological effects of knowing that 'low doses' of radiation had affected the area. Not good enough!

Lack of sufficient design detail as was expected and intimated in the site licence approval. Each stage has put off vital decisions. The EIS and the site licence approval said wait for the PSAR. The PSAR now says wait for the SAR that will be done after the reactor is built. All the rules of the game constantly alter to suit ANSTO. Even ANSTO agrees. ' Yes. What we have here is essentially the bare bones of a PSAR .' (Andy Willers page 85) Not good enough!

Economic situation in Argentina

The bad economic situation at the time of the forum is now far worse. Several Presidents later and the rioting continues in the streets. The middle class has been hit by its loss of savings and, in government employ, being unpaid. The designers and potential builders would come in the middle class category. Would they put their heart and soul into producing a safe and efficient reactor?

Are the appropriate Commonwealth Ministers fully briefed on the consequences of:
  • the inability of INVAP to complete the project;

  • the safety of a completed reactor;

  • the availability follow-up action by INVAP should it not function correctly;

  • the real story on the Egyptian reactor. Does the Minister for Science now know the full story following the visit by Dr Loy and Mr Macnab to Egypt?

  • the 'guarantees' given by the President of Argentina referred to by Professor Garnett. To which President was she referring? Which commercial banks guaranteed the contract? Are they still solvent? Is the ' Icing on the cake ' just that?

What does the contract stipulate regarding cancellation before or after a construction licence is approved? Should INVAP find itself unable to continue when into the construction stage (and receiving some down-payment from ANSTO) how would we get a reimbursement if the cupboard was bare?

Does ARPANSA stand aloof (blindfold) from all these important issues? Do you see it as none of your business and leave it to other government departments? Will you raise these issues with your Minister or merely look at papers and assess promises and agree to a licence?

Waste management

'We will be reviewing the situation' was the song that DITR repeated at the forum. Dr Budnitz took them to task and asked for a quantification of the length of life of the LLILW store. Even Dr Loy hinted that the design basis of 50 years ' was a bit short' .

Eventual disposal was even more difficult. DITR would review the situation in 2004/5, including disposal techniques and facilities overseas. (Always the optimists that another country would take our waste off our hands.) The best that DITR could come up with was that ' the strategy at the moment is the safe storage and for eventual disposal '. No real plans, except for ' a sort of conceptual cartoon' (Budnitz, page 46.)

Conclusion

Even a cursory look at the material that emerged from the forum and the subsequent reports lead to the conclusion that it is far too early to grant a construction licence. You must go back to square one and look at the (un)suitability of the Lucas Heights site. Choose another site if the project is really as worthwhile as was seen in 1997 and then continue the licensing process.

Michael Priceman
Convenor
Nuclear Study Group
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