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Comments on the Draft Paper:
Recommendations for Intervention in Emergency Situations Involving Radiation Exposure

Issued by ARPANSA October 2002

Introductory Remarks ARPANSA's role in disseminating information

The delay in producing these comments has been due to the unavailability of the report outlining the radiological consequences analysis of a sabotage incident in involving one or more reactors at Lucas Heights. This report was originally prepared by ANSTO following the September 11th 2001 attack on the World Trade Centre in New York and was part of the documentation that was considered by ARPANSA in the application for a construction licence for a new reactor.

The report has been hidden by Commonwealth agencies for 'security reasons' but ARPANSA promised a sanitised version that could be used by the NSW State Emergency Services for planning purposes. That version is still unseen leaving the SES, rewriting its plans for an accident with off-site consequences, in the dark. Such a situation reflects badly on ARPANSA which appears to be spending more of its time on providing licences to the nuclear industry than protecting the public from the harmful effects of radiation.

The Sutherland Local Emergency Management Committee will be meeting on Friday 28th February. The closing date for public comment on intervention recommendations is the 24th February. Unless the report is made available to the members within the next day or so it will mean that there will be yet another three months before the committee meets. Really, ARPANSA must try harder or at least provide a date when the report will be available.

Until this matter has been clarified so that the SES can prepare a workable plan then the draft recommendations must not be issued.

An aside, 20th February 2003

I received an interstate 'phone call advising me that ARPANSA was going to release the consequences report on 21st and that I should have a look at the article in the 'Australian'. Having taken that advice I 'phoned ARPANSA for verification. Alas, things were as normal; it would not be released, it was still in the hands of an un-named security organisation and that ARPANSA had its hands tied. Meanwhile the community will continue to be alarmed because of inadequate information that is preventing effective emergency planning.

Why should the public be concerned about its safety?

It is concerned because of the enormous difference between 'experts' as to the possible effects of a sabotage attack. What have we been told so far?

Let's start with ANSTO; after all it is the organisation that advises government on nuclear issues. Its staff of radiation specialists and nuclear engineers advise the CEO who consistently assures us that if all the nuclear plant on site was blown sky-high there would be no adverse effect on persons living beyond the 1.6 Km safety zone. (After all "it is only the size of a household washing machine!")

How this conflicts with the assessment of ANSTO's former chief engineer, Tony Wood, at the ARPANSA public forum on 17th December 2001.

"With respect to the PSAR the bottom line is that we have an open pool reactor which, at any given time, will contain 500,000 Curies of Iodine131. We only have to let one quarter of 1% of this iodine escape to the atmosphere before the exposure dose at the exclusion boundary exceeds the recommended IAEA Generic Intervention Level for Iodine Prophylaxis adopted by ARPANSA. This is a very safe reactor, but it is not harmless as depicted by ANSTO in its hand-out publicity material."

"The PSAR tells us that the most severe of all accidents considered, delivers a smaller dose at the exclusion boundary than an individual living for one month in Sydney would receive from natural background. Moreover it suggests that even this infinitesimally trivial event would not be expected to occur more than once in 300,000 years. At this point in the preparation of the PSAR an important step has been overlooked. It is called the reality check and this check tells me that this result is unreal. It has been achieved by a series of logical steps, but has led to an illogical conclusion, which is not apparent to ANSTO." (Emphasis added)

ARPANSA seems to have variety of opinions depending on who asks and who answers the questions. Dr. Loy at Senate Hearing 20th February 2002 was guarded about the distance radiation might travel but said:

"The energy of the fire would cause the radioactive cloud, if you like, to rise up, to be quite buoyant and then to spread, such that it would be quite dispersed. The doses to any individual would be relatively small, but they would occur at some distance from the facility. We are still playing with that analysis, to be certain that we think it is okay, and we are also looking at its sensitivity to the various assumptions that are made into it. The total collective radiation dose that is figured in that would be comparable to, but a little in excess of, the collective dose that was in the reference accident in the siting licence assessment for the Lucas Height site, but not dramatically so. There would certainly be no instant fatalities; a number of persons would receive a dose which would increase the risk of a fatal cancer in due course. The total expected deaths from that are a little larger than the reference accident we used in the siting, but not much, and the existing kind of emergency plans, the basis for them, including the national antiterrorist plan, would continue to be appropriate as responses to this, should it occur."

A month later the Sutherland Shire Leader quoted an ARPANSA spokesperson as saying that everyone within a 50 Km radius would be exposed to radiation. It has not refuted by ARPANSA.

More recently, at the November 2002 meeting of the LEMC, when the question of the missing consequences analysis was raised, Don Macnab said that there would be limited need for sheltering and no need for evacuation. The latter statement was very pertinent in that the NSW Health Department representative has already advised that it would not be possible to distribute stable iodine tablets to an affected area due to personnel and time constraints and that short term sheltering followed by evacuation to specified area, when tablets could be supplied, could be the best option. This in spite of the community being told for the past 44 years by the NSW SES that stable iodine would be handed out door-to-door - a method that never did make sense.

As part of an earlier study commissioned by Sutherland Shire Council, Daniel Hirsch suggested that there could be a radiation cloud that might spread up to 80 Km. The response to that report from ANSTO and the government was to 'shoot the messenger'; a method frequently used by the nuclear industry.

A final reference that I came upon by chance was from the Australasian Radiation Protection Society's Newsletter No 20 dated September 2000. It was a critique of an article by Dr Rick McLean in the Sydney Morning Herald 4th August 2000. The article was about the potential for a major accident at LHRC. The critique by the newsletter editor, Dr Don Higson, included the following:

"The only way that there could be a dose greater than 50 mSv to a member of the public, outside the LHRL site boundary, would be due to damage caused by some massive external event such as a large commercial airliner crashing directly onto the reactor or a direct hit by a large meteorite. Even without a reactor to attract the missile, this is so unlikely that worrying about it has been described as 'the Henny Penny Syndrome'."

His was remarkably prescient a year before September 11th 2001.

Any member of the community reading these wildly differing estimates might rightly be concerned. If one dismisses ANSTO's claim, worries about Tony Wood's assessment, wonders about ARPANSA's conflicting figures and then examines the largest distance by Daniel Hirsch there can be only one conclusion - that we be alarmed and that ARPANSA be alert. But once again, after four years ARPANSA still gives the perception that it is an instrument of the government and the nuclear industry and that this clouds its reasoning.

Comments on the Draft as it stands

First I commend the placement of line numbers. This makes comment easier to reference.

The draft begins to unravel in the Foreword. Lines 29 - 37 refer to the guidance from the ICRP, IAEA, WHO and other organisations representing the current best practice. Lines 51 - 57 then gives very strange reasons why Australian children should be allowed an intervention level against radioiodine three times that recommended by the WHO. It says that 'the higher value ensures that the size of the planning zone and the number of people affected does not compromise the ability to rapidly implement the protective measure [stable iodine] since the health benefit afforded reduces with increased delay in administration'.

As mentioned earlier the size of the planning zones is still in dispute and awaits APANSA's advice that is still under wraps. The number of people potentially affected depends on this. As does the ability of the SES to supply stable iodine within an hour at the most. It is apparent that this cannot be done. Just because Australian children are the strongest, fittest and best at sport in the universe does not justify their being allowed to ingest radioiodine at a greater level than advised by the WHO.

Draft Introduction


Lines 143 - 145. The 50-year time span when "most of the activities involving ionising radiation have been of considerable benefit to mankind", conveniently omits the nuclear bombs on Japan. One might argue that that activity was not beneficial although considerable. Within your time span does one include the bomb tests carried out in Australia, Algeria, China, India, South Pacific, USSR, USA, etc. etc.? This paragraph should be revised to eliminate the sales propaganda of the nuclear industry. After all, that is not part of ARPANSA's brief.

Lines 152 -154 state that the effectiveness of measures to protect the public depends on the adequacy of emergency plans prepared in advance. This is accurate and pertinent to the current situation where ARPANSA, currently impotent, the broken link in the Government's chain, is unable to provide crucial information to the SES. If this continues to be the case then there is no point in issuing the recommendations.


Lines 176 - 179 referring to psychological problems are valid. As mentioned above, the wide variation of expected consequences of a major accident and Dr Loy's blithe reference to only a few more deaths is sufficient to keep the community's natural paranoia simmering.

Emergency Situations

Types of Emergency

Lines 194 - 198 refer to uncontrolled contaminants from a nuclear research reactor, with dispersion of the contaminants downwind from the reactor. It is good that this has been included. But ANSTO's CEO claims that this is not possible. What are we mere mortals to believe? Is it possible for the two most important nuclear organisations in Australia to stop contradicting each other? You cannot both be correct.

Lines 219 - 221 please add the page number on which Table 1 is listed for ease of access.


Lines 278 - 285 are very interesting but need clarification. The reference to 'Reactor accidents...the recovery stage can extend for many years' is provocative. Are we referring to a research reactor or a power reactor? If the former, do the comments apply? If the latter, why is it included - Australia doesn't have one? Please explain!

The late (or recovery) phase

Lines 313 - 318 suggests that decisions on the withdrawal of protective measures would be made on the basis of environmental and food monitoring information and on-cost-benefit analysis. What about health - supposedly the main purpose of ARPANSA's existence?

Types of protective measures

Line 328, please add the page number that shows Table 2.

Urgent protective actions


Lines 347/8 say that evacuation is not recommended for a period exceeding 7 days. Could this be expanded to say why, as it does not make much sense as it stands?


Lines 371 - 376 refer to lightweight buildings providing less protection. Within a radius of 2.5 Km of Lucas Heights about 50% of houses are made if fibro cement. Are these rated a lightweight under the recommendations? If so then the siting of a nuclear facility should have been denied by ARPANSA. Please clarify the section by describing what is meant by 'light weight'.

Administration of stable iodine

Lines 388 - 394. This paragraph is too bland although correct. If taken within 1 hour of a nuclear accident, stable iodine can be 85% effective but this reduces quickly. In the event of an accident, stable iodine at home is the best protection. Emergency services will not be able to distribute tablets in time during an emergency. This subject will be enlarged later in this submission. Suggest that you add the page number for the detail in Annex A.

Longer-term Protective actions


Lines 427 - 429. Has this been cut and pasted from an international document referring to power reactors? Or is it correct for Australian conditions? Could Engadine residents be expected to be transferred to temporary accommodation for 'a period of several months or more'?

Spatial Aspects

Off-site area

Lines 461 - 463 correctly refer to pre-prepared emergency plans. Give the SES the consequences analysis and perhaps the can prepare such a plan. Until ARPANSA does this we are all whistling in the dark.

Emergency Planning Zones

Precautionary Action Zone (PAZ)

Lines 478 - 494. Again this seems to have been written without any understanding of the reality of the Lucas Heights operation. Aside from the lack of good information from ANSTO and ARPANSA which has been mentioned ad nauseum there is reference to siren systems! Was this included in error as part of another document? From memory the local community has called for a siren system since at least the 1980s. But it has always been rejected by ANSTO as being unworkable.

A siren system, combined with the pre-distribution of stable iodine tablets to an agreed PAZ would be a start in showing that our regulators and those other organisations meant to protect the public are really serious in their intent.

Urgent Protective Action Planning Zone (UPZ)

Same comments as PAZ above.

Long term Protective Action Planning Zone (LPZ)

Lines 539/540 mention that the zones do not stop at Sate or Territory borders. This is an obvious but worthy statement. ANSTO has often given the impression that radiation miraculously stops at its cyclone wire fence.

Generic Intervention Levels and Action Levels

Operational Intervention Levels

Reactor Accidents

If the information contained in these sections refers to research reactors then it would seem that ANSTO's version of 'the facts' surrounding the effects of an accident is grossly understated. Or it is another extract taken from recommendations applying to a power reactor. If the former then it would seem that it is up to ARPANSA to tell the public the truth concerning a worst-case accident. If the latter then the whole section should be re-written so as not to confuse the SES people who will need the recommendations as a realistic guide.

Flow chart showing the decision process for implementation of intermediate and longer-term protective actions. Figure 3, page 25.

The chart has a section marked 'Is release under control'. Its flow optimistically shows 'Yes' but what happens to the chart if the answer is 'No'?

Control of foodstuff

Lines1152 - 1191.

Does ARPANSA foresee any situation where foodstuff could be contaminated due to an accident Lucas Heights or a radiation release from any other source that might affect crops and/or pastures? Possibly this section could relate to a dirty bomb attack. Please explain!

Protection of Emergency Personnel

Line 1240. (ARPANSA 2000) Please include the full title of ARPANSA 2000... and include the page number for easy reference.

Lines 1242 - 1247. The recommendation that emergency personnel may be subjected to dose levels greater than specified in table 9 needs clarification and explanation to the emergency services organisations. What maximum dose levels are recommended or is there in fact no limit? Would it be legal under NSW State Workcover or could the supervisor sending them into such a situation be held legally liable afterwards?

Would emergency workers attending an emergency following a worst-case accident be classed as nuclear industry workers for the purposes of receivable radiation doses or as members of the public?

Lines 1307 -1310. The reference to emergency workers being volunteers is not comforting to the community. To my knowledge the professional combat teams do not operate under such a system.

If ARPANSA can envisage a situation that such a volunteer scenario could occur then it would be essential that the personnel be honestly and fully briefed well before any such a situation occurred. Such a briefing would need to be far more blunt and informative than the usual minimalist advice that is provided by ANSTO. 'Don't worry, there would be hours before any radiation would be released. Don't you wish that all your emergencies gave you so much time to prepare?'

Random thoughts

Lines 1298 - 1341. Are the points raised for the protection of emergency personnel advice to government and emergency organisations or are they instructions? Is ARPANSA aware of the present situation within these areas? Has it checked? Will ARPANSA just dole out the final recommendations and assume that they are being acted on?

Table 1. Page 34. Possible Emergencies, Radiation Exposure Route and Actions

Section 4 relates to uncontrolled releases of radiation from a research reactor. It has never been explained how the SES (HAZMAT) would remove radiation from off-site surfaces. The only method that seems possible would be to flush it down the nearest drain or, if it were soil, remove it to another place. (Where?)

Table 2 Page 35. Administration of stable iodine compounds

The time scale 'early' is not sufficient. Change to 'ideally before any uptake of radioactive iodine and certainly within an hour of any release'.

Permanent resettlement

Again, could this apply to a Lucas Heights accident? If not, what other Australian scenarios could cause permanent resettlement?

Table 3 Page 36. Examples of Initial Safe Distances in Radiological Accidents

The reference to 'a plutonium spill'. Is this serious or yet another import from a larger overseas document? Where is there any plutonium in Australia that can spill?

Table 4 Page 37. Thresholds of Occurrence

The information in the right hand column should be given in simpler terms. We are not all rocket scientists, neither are firemen or police.

Lines 1409 - 1413 sub-note 'f'. The comment that most thyroid cancers are curable is gratuitous. Do your authors know real people who have had their thyroid gland removed and the suffering that it causes? It would be no consolation for those to know that the result of radiation exposure did not kill them, only disabled them.

Table 5 Page 38, Recommended Generic Intervention Levels for Protective Measures for the General Public

We have been through this many times over the past decade but nobody listens. If the maximum level of radiation dose to the public is 1 mSv (Table 9 page 42) then that should be the intervention level. If an accident at Lucas Heights contaminates the public off-site to a level of 1 mSv then sheltering should be initiated immediately.

Sheltering appears to be the obvious first protective measure but in reality, the recent shade temperatures of around 400 C for several weeks in the Engadine area would make the option very questionable. The advice, 'First turn off the air conditioner and close the windows and ventilators', is good in theory but it would lead to enormous discomfort and possible deaths, particularly of older persons. This is always the problem when experts deal with theory rather than reality.

The levels for iodine prophylaxis are far too high. If it was even suspected that radioactive iodine might be released it would be better to advise potential victims to take a stable iodine tablet immediately. Providing, of course that they had them available in their homes.

And here is a way that ARPANSA could be of some practical use to the public. As you work under the Department of Health, why can't you lobby the Minister and the NSW State Premier to alter the laws prohibiting the purchase of the tablets? These people take no notice of the public or the medical profession but ARPANSA must have some clout. Mustn't it?

An even more effective way to overcome this would be for ARPANSA to review its site licence criteria, tell the Minister that you now consider that conditions have changed and that the project for a new reactor be relocated (or, preferably abandoned).

Annex A Page 51 Stable Iodine Prophylaxis

Lines 1902 - 1911. At the LEMC it has been confirmed that the NSW Health cannot deliver stable iodine door to door whilst in a sheltering situation. The 'new' idea is to shelter for a while and then, when it was deemed safe, evacuate to a safe area and then hand out tablets. This seems somewhat defective and does not come up the ARPANSA recommendation d) which calls for 'a detailed plan for the stable iodine to be administered promptly, as the health benefit afforded reduces with increased delay in administration'. The new plan is no plan.

Sub paragraph d) says that 'the pre-distribution can be helpful in specific circumstances although the widespread pre-distribution to individual households is not advised'. It should be explained to the public what specific circumstances these may be and why widespread pre-distribution is not advised.

Planning for Administration of Stable Iodine

Lines 2071 - 2077. This paragraph makes little sense. It refers to 'the detrimental consequences of changing existing emergency plans' - Sir, there aren't any that are workable. What plans there were are being changed at every meeting of the LEMC and are still not settled. In any case emergency planning is always subject to change it is part of the process of improvement.

The final part of the sentence does not make sense and must be explained. How does allowing additional exposure to infants improve the situation of distributing stable iodine? Of course if the SES knew the possible effects of a sabotage attack they might be able to plan accordingly.


The draft is confusing in that large segments appear to have been taken from other, international, documents that may have applied to countries that operate power reactors. As Australia has only a research reactor and no plans for nuclear power plants it would be advisable to redraft all those sections that have no relevance in this country.

All references to Tables, Annexes etc should have an appropriate page numbers noted to make easier reading.

There is a level of repetition that should be adjusted. This would make the document less confusing and easier to comprehend.

Unless and until the Consequences Analysis of a "successful" sabotage attack on one of more reactors at Lucas Heights is released to the public and to the SES the document should be withheld.

The reported comments in the 'Australian' 20th February 2003 that long-term fatalities from radiation exposure after a terrorist attack on Sydney's Lucas Heights reactor would be 'within the limits of tolerability' are outrageous. If the comments are correct then the whole issue of the site licence approval for a new reactor should be re-examined and the Original ARPANSA decision overturned.

Prepared by Michael Priceman
Nuclear Study Group

23rd February 2003

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