This submission is in addition to that dated 14 July in view of new information and, in part, following the recent public meeting arranged by ARPANSA.
I have had discussions with several members of the community on the question of submission to ARPANSA regarding licence applications. Most have said "Why bother, they will dismiss anything that we say, just like last time", referring to the granting of the site licence for a new reactor. Having felt the same way I said that it might still be worth the effort. We live in hope. If however, all the comments are "considered" by the CEO as required by the Act and then summarily dismissed, it will alienate the public altogether from the process. I am sure that this is not the effect that ARPANSA wants, although it would give you some relief.
Whilst part of ARPANSA's brief is to review licence applications and approve (or refuse?) them. It also has a more urgent duty, that of setting up Australian standards for radiation protection. For what may be perceived as political reasons the latter is taking second place to the granting of licences. In fact it is starting the book at the last page and working backwards.
This leads to the premise that the licences granted or about to be granted are interim or, if permanent, then whenever the new standards are put in place they will have been appropriately adjusted to meet the terms of the licence. Not a good start.
In the case of the existing facilities at Lucas Heights this presents ARPANSA with a huge dilemma. If HIFAR were proposed today as a new reactor (the site already being licensed) it would be refused due to design deficiencies. The Nuclear Safety Bureau said that it could not be "authorised" past 2002 without a major upgrade. The same could be said for the radioisotope plant and packing area, long recognised as the dirtiest parts of the Lucas Heights operation and the liquid waste storage tanks.
Question: How can ARPANSA licence a condemned nuclear reactor without its standards for safety, design and emissions firmly in place? If it does so, how can it claim that it is working to International Best Practice as is demanded in the Act? What form of words will be used to justify it?
Question: Will there be any room for public comment on new standards? If so when is it expected to take place?
Waste Management and Storage
In 1988, Safety Review Committee (with no power to regulate, only to advise) described the storage of liquid waste from the production of Technetium as an accident, with potential off-site consequences, waiting to happen. For the next decade, in each of it annual reports the SRC was told by ANSTO that the matter was receiving its urgent attention. Around 1999 a method of solidifying was found and ANSTO advised that it would take about three years to finalise the job.
Oddly, for an organisation that boasts of its Synroc as being 1000 times better than any similar encapsulation material for long-lived liquid waste, (does that poster still exist?) ANSTO did not consider using it directly for this troublesome waste. Synroc was designed for exactly that purpose. Instead the plan was to solidify first, keep it on site - no plans to move it to a hypothetical store - and "later", unqualified as usual, perhaps use Synroc.
Question: The liquid is still stored in a potentially risky condition. If it were a new plant you would not licence its storage in that manner. How then can you licence it now? Surely to do so would breach the terms of the Act. It certainly is not International Best Practice.
Question: Why allow ANSTO to carry out two lengthy processes when one, according to its theoretical world, would be possible?
Question: The SRC suggested that an earthquake could be the cause of an accident with off-site consequences. Do the engineering plans for the tanks holding the liquid allow for an earthquake? If so what horizontal ground acceleration was allowed for and what safety margins were built in?
Question: Is the liquid waste that continues to be produced at the radioisotope plant being moved directly to the same storage tanks or is it being solidified immediately without interim storage?
Spent fuel storage
During the period from around 1985 and 1998 there was no inspection of the moisture/liquid content of the spent fuel at the Lucas Heights "dry storage" area. This resulted in the handling errors and accidents that are referred to in ARPANSA's quarterly reports. An ANSTO union official at the first Senate Inquiry admitted this lapse and said that the person who should have done the job had been moved to another job. He did not mention the supervision of that person or the higher management that had ultimate responsibility for the lapse in procedures.
It was believed also that IAEA inspections checked the condition of the spent fuel but it seems that they merely counted the number of seals on the in-ground storage tubes. Such trust in ANSTO procedures!
ARPANSA called for an "analysis of the root causes of the accidents/incidents of 1998/9". This was followed by cursory mentions in belated ARPANSA quarterly reports. The analysis report does not seem to have been made public.
Questions: Can it be assumed that Ministers Wooldridge, Minchin and Hill are blissfully unaware of any problems in Australia's most advanced, cutting edge scientific organisation? Where can a copy of the analysis report be obtained?
At last week's public meeting the matter of emergency planning was raised during question time. The reply was that, "yes there is a plan and that it is available in the local library". Whilst strictly correct the DISPLAN is merely a management plan that tells the public nothing about how to react to an emergency at ANSTO. Is it correct to say that ARPANSA has the role of observer at meetings of the local emergency management group?
Since our submission of 14 July there have been meetings with Mr Brian Carr who carried out an examination of the current DISPLANs for the NSW State Emergency Service. Whilst Mr Carr was given a copy of the NH & MRC document, "Intervention in Emergency Situations Involving Radiation Exposure - 1990" he made no mention of it in his report. This was surprising as it is the only document that actually makes recommendations on radiation emergency procedures and describes typical situations.
It also stresses pre-event preparation of those people who live in near-field situations. What is even more surprising and disturbing is that, at a recent meeting of the Local Emergency Management Committee, the new chairperson asked the members if they had read the NH & MRC paper. None were aware of its existence! It is understood that this will be rectified but it underlines the fact that the very people that ARPANSA believes will act on behalf of the public are kept as much in the dark as the blissfully unaware public.
One of the main problems with the emergency planners has been its close proximity to ANSTO advisors, who repeat the mantra,
The worst event, just cannot happen
But if it did you would have several hours to react
In any case no members of the public would come to any harm
Don't you wish that all your emergencies allowed you so much time?
With advice like this why bother to read the NH & MRC guidelines?
Question: According to Daniel Hirsch, attitudes like this are more likely to cause an accident than not. Do you agree?
Question: How can you licence an operation with this standard of emergency preparedness?
Questions: Is ARPANSA represented at the Emergency Management Committees? Should it be? Are you willing to rely on your faith and trust in this important area, hand out the licences and leave the emergency planning to the New South Wales State?
Question: Are the NH & MRC intervention guidelines still in place? Has ARPANSA any influence on them?
Part of Australian mythology is that the umpire's decision is final. Cop it sweet and get on with the game. All this went out of the window following the revised estimates of horizontal ground movement that were made in the New Zealand report. The bar was raised from 2.3g to 4.1g and ANSTO cried foul! Being the powerful entity that ANSTO is, yet another panel of "experts" was formed to review the higher figure. The amazing reason given was that the new figure was "too conservative". Naively, the public believes that design, planning for safety and conservatism go hand in hand.
Questions: Is a different figure going to be negotiated? Will ARPANSA be involved?
Whatever the final figure the effect of a defined earthquake must be applied to each facility at the Lucas Heights site including HIFAR, the radioisotope plant, waste storage areas and especially the liquid Molybdenum waste containers.
Questions: Will the design and construction of each of the facilities be carefully examined and tested against the upgraded seismic figure? Are there existing technical drawings specifying the safety factors built into the existing facilities? If not, how will their safety be assessed and who will carry out this assessment? Will the finally agreed (negotiated) seismic figure be built into the site licence requirements?
Whilst this is outside the terms of your Act, it is not worthy of the ARPANSA CEO to tell the community "Take it up with the insurance companies". This has already been done. The response is that whilst the industry has no opinions as to the claims of safety made by ANSTO it is not prepared to cover radiation or nuclear accidents. So we can only turn to the Commonwealth Government to do the right thing. But it also refuses to accept ultimate responsibility. Once again the perception that even the government lacks confidence in the claimed low level of public risk made by ANSTO and accepted by ARPANSA.
Let us take a hypothetical situation. ARPANSA, on trust, gives the licences. The "non-credible" accident occurs - SLOCA - the Emergency Services people have still not read the NH & MRC guide on intervention in the case of a radiation accident; the community, even if radiation does not have a dramatic effect, loses both socially and financially. Could a class action be mounted against the Commonwealth, ANSTO, ARPANSA, the NSW State Government and even former Sutherland Shire Councillors? Something to mull over.
Former Chief Engineer at ANSTO, Tony Wood, in his submission to the new Senate Committee of Inquiry sets out the case very clearly. Please get hold of a copy. He describes "the people living in the vicinity as being blissfully unaware that they are disadvantaged with respect to their financial security compared with their equivalents living in Europe, North America and Japan". These are countries with huge nuclear facilities and they are treated better than the community living next to our tiny, boutique research reactor using a quantity of fuel "that you can get into a teacup".
In his more recent submission to the Senate Committee's Inquiry into the contract Mr Wood comments on the Commonwealth Government's refusal to offer the community absolute liability. "This would cost the Government nothing, would enhance its standing in the community and bring it in line with international best practice. The EIS claims that the worst reactor accident would have trivial consequences and would have a return period of 1,000,000 years. If this claim is true the Government's reluctance to offer absolute liability represents probably the most extreme example of conservatism I have ever seen."
It is worth mentioning that Mr Wood's criticisms are never refuted, merely ignored.
This point was raised at the public meeting but quickly turned to "zero risk". Can you point to a new research reactor anywhere in the world where zero emission controls are in place? If you can ARPANSA should be insisting on it, whatever the cost to the Government. Anything less would be an admission that cost factors out-weigh public health. Don't forget that there has never been a health study carried out on the local population in spite of claims to the contrary by ANSTO. In the EIS they trotted out the opinion of a noted UK expert who duly accepted the source information provided by ANSTO.
Final Brief Comments
ARPANSA is obliged to follow International Best Practice when approving licences. The International Atomic Energy Agency offers guidelines but they are minimum standards. Where has ARPANSA actually visited to see International Best Practice in operation? Or is it merely using computer modelling and nuclear industry journals to set its standards?
Is it ARPANSA's aim to lead the world in nuclear regulations or be a follower of overseas practice?
Reports on the condition of the Little Forest Burial Ground say that, so far, it is safe as long as it is not disturbed. Environment Australia however, has in its EIS report, suggested that the waste be removed. This sounds like Sophie's Choice for the local community. Would ARPANSA licence its removal? Will ARPANSA licence its present status?
Why isn't the Little Forest waste site included in the current set of licence applications?
What would the effect of a sudden loss of coolant have on the HIFAR containment building? Do you accept the ANSTO's optimistic figure of 3% radiation release as being correct? Why do you dismiss Mr Wood's comments on the real worst-case scenario?
Please do not trivialise health effects of radiation and risk when discussing the operation of a nuclear reactor. Your staff's references of "similar to that of a plane trip from Sydney to Melbourne" and "sitting on the perimeter fence for a full year" and " we all live in a sea of radiation" are facile as well as being out of the Hans ANSTOson Handbook of Clichés. How much Iodine 131, Argon and Krypton do we get in that plane trip?
When is a study planned into the long term collective doses of radiation that may be absorbed by members of the public living in the area? It appears that most of ANSTO's assessments of dose are based on single doses that are then averaged out. What about the sudden accidental or unexplained peaks in radiation releases? How is the public to learn about them?
Page two of your information sheets on this licence application, dated 18 October 2000 mentioned that "your submission may become a public document'. Under what circumstances can this take place? I asked for details by telephone earlier this week but have had no reply.
ARPANSA operates and suffers, under the Terms of its Act. The CEO mentioned at the public meeting that perhaps the US system of open judicial meetings, to discuss and test the information that accompanies licence applications, should take place in Australia. Perhaps what is described as International Best Practice is not as good as it sounds. If so the CEO should take his views to his Minister and tell him that the Act should be improved by amendment. Legislation with shortcomings -such as FOI - has a habit of remaining on the books forever if it suits the system. The leadership will not come from Parliament.
ARPANSA should take time out, start at page one, re-set its goals and priorities and first get all its standards, including design and emissions firmly in place. Meanwhile shelve these licence applications as it would be unrealistic to grant licences for these old facilities without getting the basics right first.
Nuclear Study Group