On the day Mrs Eileen Brown is awarded the Nobel Prize equivalent for environmental efforts, the “Goldman Award”, the Australian Conservation Foundation releases the proposed decision of Federal Environment Minister Kemp on the national nuclear waste dump showing key questions remain unanswered.

“The flawed environmental impact statement process has seen the preferred dump site formally ruled out and key questions of groundwater impacts and dump operations left unanswered” said David Noonan, ACF Campaign Officer.

“Allowing the proponent of this nuclear dump plan the Science Minister McGauran to now decide the site of the waste dump is like leaving the fox to safeguard the chickens.”

“It is the clear intention of the Commonwealth to use secret processes from here on in to address the siting, operations and the real impacts of this nuclear dump plan. With the study of groundwater impacts from the proposed hazardous burial of reactor wastes to be undertaken after the dump approval is given by Minister Kemp. “

“All of these key environment issues should have been subject to proper public consultation.”

Minister McGauran is to now to make the final siting decision between two alternate dump sites near Woomera in north SA and the “facility design and operational measures to safeguard the environment” have yet to be determined by his Department of Science.

Minister Kemp’s proposed decision is contained in correspondence obtained by the ACF to other Federal Ministers asking for their comment on his proposed nuclear dump decision.

“ACF congratulates Mrs Eileen Brown and the Kungka Tjuta on winning the Goldman Award for their fight to prevent this imposition of a nuclear waste dump onto their traditional lands” said Dave Sweeney, ACF Nuclear Issues Coordinator. “There are now growing national and international efforts to protect the human and cultural rights of the Kungka Tjuta the senior Aboriginal women of north South Australia.”

THE federal Government will not  release an environmental report on the controversial  construction of a radioactive waste dump beside a military  bombing range in the South Australian desert.

It is the  second time in as many days the Government has withheld   documents relating to concerns over locating a low-level radioactive waste repository in the Woomera Prohibited  Area, about 500km north of Adelaide.

On Monday, Environment Australia is legally required to deliver Environment Minister David Kemp its assessment on the repository, which could be operational by next year.

The federal Opposition, Australian Democrats, the South Australian Government and the Australian Conservation Foundation yesterday called for the public release of the EA report.

They say too much secrecy has been involved in the project so far and the public has a right to know the impacts of building a repository 3km from a defence target area before a binding decision is made.

A spokeswoman for Dr Kemp told The Weekend Australian the EA report would remain confidential until after Dr Kemp consulted with relevant ministers and delivered his final decision in late March.

She said those calling for the report's release knew "perfectly well that (releasing the document) would be completely unprecedented".
"It's a report to the minister for his consideration."

Defence Minister Robert Hill made a similar argument to the Senate on Thursday, rebutting Democrat calls for the release of a defence briefing raising serious concerns over the chances of a bomb or missile striking the repository.

A MOVE to build a low-level nuclear waste dump in South Australia has been overwhelmingly rejected. Most of the 667 public submissions the Government received over the proposed radioactive waste repository in SA's Outback are critical of the plan.

Many suggest the dump is being forced on SA.

"I oppose the Federal Government's plan to establish, or rather impose, a radioactive waste dump in SA," one submission says.

"Please don't risk turning our Outback or any part of this country into a wasteland but look to the longer term to keep Australia as safe as possible," says another.

Other submissions identify risks for transporting radioactive waste across Australia to the proposed site near Woomera, point to health and environmental implications of the planned repository, and question why the dump has to be in SA.

Submissions also reveal fears the Federal Government is planning to locate in SA a second dump for higher level waste. The submissions were made in response to the Federal Government environmental impact statement on the proposed dump.

Federal Science Minister Peter McGauran will issue a supplementary document to the EIS today which details the submissions and Government responses.

Federal Environment Minister David Kemp will make a final decision on the dump in March.

THE federal Government looks set to steamroll the South Australian Government and community over its decision to support construction of a radioactive waste dump 45km north of Woomera next year.

Federal Science Minister Peter McGauran yesterday released a report in response to 667 submissions on the proposed repository, which would have an operational life of 50 years and act as a central store for the nation's low-level industrial and medical waste.

Federal Environment Minister David Kemp will analyse the supplement to the draft environmental impact statement for final approval, and a decision is likely in March.

Mr McGauran's recommendation remained unchanged from the draft EIS released last year, despite only a "handful" of the 667 submissions received supporting the repository.

"The EIS is not a poll of people's opinions," Mr McGauran said.

He argued 532 of the submissions were petition-like letters drafted by the Australian Conservation Foundation: "It is a fact that the majority of the submissions were opposed to the siting but a lot of them were on erroneous grounds."

Mr McGauran blamed "disinformation", largely from the South Australian Government and environmentalists, for the backlash.

The repository will operate possibly beyond 2054, opening its doors every two to five years to the nation's radioactive waste, expected to total 4000 litres a year.

Known as 52A, the proposed site was one of three shortlisted sites. It is on a state pastoral lease. Should it be approved, the federal Government will compulsorily acquire the land.

South Australian Premier Mike Rann said Mr McGauran had been "duplicitous" in suggesting the state Government's opposition to the dump was based on political expediency.

He said the state should not compromise its "clean, green image" and was worried South Australia was being "softened up" for a higher-level waste dump than proposed.

"The issue of transportation (of waste) worries me greatly," Mr Rann said. "I don't see why we should be known as the nuclear waste state."

Opposition environment spokesman Kelvin Thomson said the federal Government was "soldiering on, full steam ahead", yet again ignoring public opinion on issues of national significance.

"The South Australian community does not support it and so to try and cast aspersions on the submissions misses the point completely," he said.

Greens senator Kerry Nettle described the report as "another of Howard's out-of-sight, out-of-mind solutions".

Independent senator for South Australia Meg Lees called on Dr Kemp to reject the recommendations.

SCIENCE Minister Peter McGauran arrived in Adelaide yesterday - to belatedly tell South Australians why a national nuclear waste dump should be built here.

His visit came more than 12 months after he assumed the portfolio and took on responsibility for the low-level waste repository - and more than three months after the chance for South Australians to comment on the plan lapsed.

Senator McGauran also took the opportunity to make a scathing attack on the State Government's opposition to the plan, accusing Premier Mike Rann and environment groups of "spreading disinformation" about the dump.

He was in Adelaide to release the final documents of the environmental impact statement for the dump.

Within the next two months, federal Environment Minister David Kemp will decide on whether to approve the dump, which is planned for one of three sites near Woomera.

By 2004 the shallow-burial dump will be built, most likely at the Government's preferred site known as Area 52A, on pastoral land northwest of Woomera.

While an Advertiser poll last year showed 76 per cent of South Australians opposed the shallow-burial dump, Senator McGauran claimed there was growing support for the plan.

"When South Australians realise that the large amount of waste haphazardly stored at the moment is untenable, is unsafe, then they will support a repository and they will also, I believe, realise that it has to be done on the basis of scientific judgment and that's why Woomera is the preferred site," he said.

Senator McGauran said Mr Rann had used "baseless emotion" in arguing against the dump. "He's talking down SA and it will become a self-fulfilling prophecy if he's not careful," he warned.

"He talks about SA's clean, green image being clouded by all of these supposed events but, in actual fact, having 130 unguarded sites for low-level waste would harm the state's image more than anything else."

Senator McGauran reinforced the Federal Government's threat to build a dump in SA despite the overwhelming opposition.
"The Commonwealth would not wish to resort to its constitutional powers to override the South Australian Government, but if it came to that we have to make a decision," he said.

Mr Rann angrily rejected Senator McGauran's claims.

"I just thought his statements were quite duplicitous," he said.

"My guess is that the Federal Liberal Government has decided not only to locate a low-level dump in SA but once they have used their powers to impose that on us against our will we will then be softened up for an intermediate-level waste dump.
"I don't see why we should be known nationally and internationally as the nuclear waste dump state."

Australian Conservation Foundation nuclear campaigner David Noonan said the democratic rights of South Australians had been undermined.

"SA people should have the right to decide on their own future," he said.

The dump will take about 3700 cubic metres of low-level and short-lived intermediate level waste from sites across Australia.

Meanwhile, within months, Senator McGauran is likely to receive a shortlist of possible sites for the planned intermediate-level waste store.

"What we've said is that we won't co-locate, we won't locate an intermediate-level radioactive waste store, an above-ground facility, next to or close to the repository," Senator McGauran said.

FEDERAL Science Minister Peter McGauran visited Adelaide yesterday claiming there is growing support in South Australia for the siting of a national nuclear waste repository in this state.

You could have fooled South Australians.

In any case, what the people of our state think doesn't matter. Mr McGauran's other message is that the consultation process is over and all that remains is the Federal Government's final decision.

Everyone knows that decision was made years ago and that it has always been this Federal Government's intention to foist the dump on SA.

This shameful process has been nothing but an unequivocal kick in the teeth for us all and a heart-breaking defeat for democracy.

A decision on the site of the nation's first low-level nuclear waste dump is just weeks away after the federal Government quietly signed off on the final environmental impact statement on Christmas Eve - a move it has yet to make public.

The Weekend Australian has confirmed that Environment Minister David Kemp officially accepted the final submission on the proposed dump on the last sitting day of parliament, triggering a 60-working-day countdown until he must deliver his decision.

Environment Australia has until February 7 to hand down a final assessment of the project, which if it goes ahead will store low-level radioactive waste from hospitals, industry and Sydney's Lucas Heights nuclear reactor.

Dr Kemp then has until March 24 to decide whether the dump will go ahead and where.

But four weeks after the final EIS document was approved, the Government has yet to make it publicly available, despite strenuous opposition to the dump from the South Australian Government, community, environment and Aboriginal groups.

A spokeswoman for Dr Kemp denied the Government had attempted to keep the decision secret, and said the EIS would be made publicly available next week.

"Due process has been followed . . . the consultation period is now over," the spokeswoman said. "We're not in the habit of putting out a press release every time we put out an EIS."

The federal Government is considering three sites in northern South Australia, all on state land and under native title claim.

While the South Australian Government strongly opposes the plan, the federal Government has warned it will compulsorily acquire land if necessary and excise it from South Australia for its purposes.

South Australian Environment Minister John Hill yesterday accused the federal Government of being "very secretive about the entire EIS process" and called for the immediate release of the documents to give the public a chance to scrutinise them.

"They have a duty to make sure the EIS is publicly circulated before they make the decision and they have been very quiet about that," Mr Hill said.

Australian Conservation Foundation nuclear campaigner David Noonan condemned Dr Kemp for failing to make his decision public, and warned that the project would be a key test of environmental democracy.

"Dr Kemp should have let people know he had already started the clock ticking," Mr Noonan said.

"This will be a substantial document and by the time the public has access to it the federal Government will be well advanced in preparing their assessment report."

The Howard Government, through Science Minister Peter McGauran, has treated South Australians and their views about the proposed location of Australia's low-level nuclear waste dump with contempt, by releasing its response on the day when Australia farewells the Iraq-bound troops.

This is the second attempt by the Government to bury their intentions regarding the low-level waste dump through the dubious timing of a press release.

Environment Minister David Kemp started the clock ticking for this release by formally "accepting" this Supplement to the EIS on Christmas Eve last year - another ploy to hide from the media and the public.

And South Australians were victims of the Government spin on Christmas Eve 1998, when then Environment Minister Robert Hill gave the go-ahead to the Beverly Uranium Mine.

The Government has also used taxpayers' money to fund a $300,000 propaganda campaign, aimed at the people of South Australia, to persuade them that the waste repository should be in their State. Despite this cynical and wasteful exercise, 667 submissions expressing strong reservations and deep concerns, were received by the Government.

Yet today's report states that it is beyond the scope of its response to the public to comment on: "debate about the health effects of radiation"; the adequacy of the Commonwealth's environmental legislation or its EIS process"; or  "comments that are assertions or opinions".

In fact, the process of public consultation, held in regional centres close to proposed dump sites, was cursory and one-sided. The public was not listened to, but instead exposed to Government propaganda.

The people of South Australia, in particular, have every right to feel angry that they have been victims of the Howard Government's contempt in this process.

A ‘Campaign Against Nuclear Dumping’ was launched in Adelaide on January 31 in opposition to the federal government's plan for a national radioactive waste dump near Woomera in the centre-north of South Australia.

The campaign was initiated by anti-nuclear campaigners and environmentalists and is attracting growing support and involvement. It will involve a range of protest activities as well as awareness-raising and a public debate. The campaign was initiated in response to revelations late last year in a leaked government document that the federal government is planning a $300,000 propaganda campaign to convince South Australians to turn their state into the nation's nuclear dump.

The objections to the planned nuclear dump are many:
* radioactive waste is best managed at the point of production (thus avoiding risks of transportation, and encouraging prudent minimisation of waste production);
* an overwhelming majority of South Australians oppose the dump (68-95% according to various polls), as does the state Labor government;
* the dump poses numerous risks, such as the possibility of missile or rocket strikes on the dump, and (according to the government) a 23% chance of a truck accident while moving the current national waste inventory to SA;
* the government's claim that SA is the "best and safest" site for the dump is not true and is flatly contradicted by the government's own literature; and
* the 'low-level' waste dump may clear the way for long-lived intermediate-level wastes, including wastes arising from reprocessing of spent nuclear fuel rods from the nuclear research reactor at Lucas Heights in Sydney.

A supplement to last year's environmental impact statement was publicly released on January 23 by science minister Peter McGauran - having been completed a month earlier but kept secret from the public. The draft EIS and the supplement were written by the proponent of the project - the federal government's department of education, science and training - and both give glowing endorsements of the project. Environment minister David Kemp will rubber-stamp the EIS, probably in late March. McGauran and Kemp have been challenged by the Campaign Against Nuclear Dumping to front for a public debate on the dump proposal in Adelaide on April 6.

The sham EIS process, and the federal government's manoeuvrings more generally, were described in a January 24 editorial in the Adelaide Advertiser as a "shameful process" and "an unequivocal kick in the teeth for us all and a heart-breaking defeat for democracy".

All but two or three of the 667 public submissions received in response to the draft EIS were opposed to the dump - an outcome McGauran blamed on "disinformation" from the South Australian Labor government and environmentalists. McGauran also claimed growing support for the dump, to which the Advertiser editorial responded: "You could have fooled South Australians."

The supplement to the EIS adds no detail on a myriad of issues left unresolved in the draft EIS. Numerous "operational hazards" have been identified by the federal government but are dismissed with the assertion in the draft EIS that: "Appropriate procedures would be developed to address these issues." The draft EIS gave nothing more than an "indicative design" of the planned dump, and the supplement adds no detail whatsoever.

Nor have full details on the nature of the waste destined for the dump been released. The government describes the project as a 'low-level' waste dump, but its definition of 'low-level' waste includes short-lived intermediate-level waste. Moreover, the government plans to use the dump for a "very small" but unspecified amount of long-lived intermediate-level waste. The government says that long-lived intermediate-level waste would only be accepted if it meets waste acceptance criteria - but those criteria have not yet been defined or publicly released.

There are other surprises in the supplement to the EIS. Then science minister Nick Minchin said in a January 24, 2001 media release that the dump would have "a 50 year working life". In the supplement to the EIS, this has been upgraded to "at least 50 years", with no explanation of the bracket creep.

Even supporters of a dump have voiced strong opposition to aspects of the proposal. For example, John Pattison, a lecturer in the School of Physics and Electronic Systems Engineering at the University of South Australia, voiced concern in his submission on the EIS about private sector operation of the dump. He expressed concern that a private contractor would pressure the government of the day to up-grade the dump from low-level waste to long-lived intermediate-level waste, to accept waste not just from Australia but also from overseas, and that a private contractor may not provide the necessary level of security.

The government has short-listed three sites near Woomera for the dump. Mining giant WMC Limited (formerly Western Mining) has no objection to a site within the Woomera Prohibited Area being used, but it objects to the other short-listed sites because of possible disruption to its activities by protesters. Location of the dump at one of the sites outside the WPA would also make it more likely that protesters would continue to target the Roxby Downs uranium mine, WMC claims. WMC also wants a commitment from the government to fund programs to address negative perceptions caused by the location of the dump in the region.

If the government accommodates WMC by locating the dump within the WPA, it will be treading on the toes of powerful commercial and military interests involved in the commercial aerospace industry and weapons testing. The Australian Space Research Institute, BAE Systems and the Northern Regional Development Board oppose the use of the short-listed site within the WPA. In submissions on the draft EIS, ASRI and BAE Systems contested the government's risk assessment on several counts, such as the probability of a missile or rocket strike on dump, the capability of the dump to withstand a strike, and the consequences for future activities if a strike were to occur.

Honoured then ignored

On January 26, Eileen Kampakuta Brown was awarded an Order of Australia for services to the community through the preservation, revival and teaching of traditional Anangu (Aboriginal) culture and as an advocate for Indigenous communities in Central Australia. Mrs Brown was recognised as a woman of extensive traditional cultural knowledge - the very cultural knowledge that has informed her ten-year struggle against the federal government's proposal to dump radioactive waste in the South Australian desert.

Mrs Brown is a member of the Kupa Piti Kungka Tjuta women's group from Coober Pedy, a council comprising senior women from Kokatha, Antikarinya and Yankunytjatjara countries. The Kungka Tjuta women have fought the dump plan through their campaign called Irati Wanti - 'the poison, leave it'.

A January 28 statement from Irati Wanti said: "To the Kungka Tjuta the desert is not a 'remote' waste-land suitable for the storage of Australia's radioactive refuse. It is their home — intimately known, densely named and overlaid with stories, meanings, and histories. Furthermore, the desert is life-sustaining, supporting diverse plant and animal life through vast underground water sources."

To find out more about the dump or the Campaign Against Nuclear Dumping, contact Jim Green: phone (08) 8211 7604 or email <[email protected]>.

Draft EIS + Supplement to the EIS = Final EIS.
S-EIS = Supplement to the EIS
DEST = Department of Education, Science and Training
All quotes from S-EIS unless otherwise indicated.
Appendix B to S-EIS summarises all submissions.

GENERAL

The Supplement ignores a range of issues claimed to go beyond the scope of the guidelines including: alternative energy (? energy ?) aspects of the Lucas Heights reactor; the clean-up of the British nuclear testing sites at Maralinga; the health effects of radiation; the adequacy of the Commonwealth’s environmental legislation or the EIS process; comments about companies or organisations.

p.5: “The Supplement is submitted to Environment Australia and released to the public.” But the Supplement was passed from DEST to environment minister Kemp on December 24, 2002 yet it was only made public on January 23, 2003.

“Under the EPBC Act, Environment Australia is required to provide a detailed independent assessment report about the EIS to the Minister for the Environment and Heritage who will consider the report together with input from other sources, before considering whether to approve the proposal and, if so, what conditions to apply. There is no conflict of interest in this process.”
- DEST writes and reviews the EIS, that is a conflict of interest
- review by Environment Australia and approval by the Environment Minister means nothing given the government’s commitment to the project, e.g. July 2002 Cabinet decision to implement a communications strategy including a media campaign to ‘sell’ the dump to South Australians.

“The policy of successive Australian governments is that countries should expect to make their own arrangements to safely dispose of their radioactive waste.”
- except for Australia, e.g. one-way shipments of spent fuel to USA (and use of reprocessing plants in France and (previously) Dounreay/Scotland, and contingency plan for spent fuel conditioning in Argentina).

“In many cases, materials are stored in cardboard boxes, hidden in cupboards, in lift wells and under stairs. These clearly represent unsafe working environments for employees.”
- many cases? Where’s the detail?

COMPENSATION

“Compensation for damage or costs as a result of actions by protestors against the repository would be given consideration by the Commonwealth. Compensation could alternatively be obtained by legal action through the courts.”

WMC Submission: “It is possible that the proposed location of the repository and any access road may affect current pastoral operations, including fence lines and watering points. The Commonwealth must commit to full compensation of costs incurred by a pastoralist to prevent disruption to existing operations as a result of the location of the repository.”
S-EIS: “Compensation will be addressed during the acquisition by the Commonwealth of the repository site. The compensation would take into account the effect the operation of the repository would have on the pastoral lease.”

ARPANSA

“ARPANSA is independent of ANSTO.”
- except for Helen Garnett’s role in John Loy’s selection, and the employment of about six ex-ANSTO staff by ARPANSA

PUBLIC OPPOSITION

“‘Overwhelming community opposition’ presumably refers to an opinion poll taken by The Advertiser newspaper, published on 31 July 2000, which concluded that 80% of the people of South Australia oppose the repository. The survey was taken without informing respondents about the options and reasons for having a national repository, the current arrangements for storing waste, and the reasons why the central-north region of South Australia was chosen. It may not have yielded informed views.”

UNRESOLVED ISSUES

“As the proponent, DEST is required to provide full details about the proposal including matters that may have the potential to significantly affect the environment in an EIS.”

But the Draft EIS and S-EIS fail to provide full details on many issues, deferring them for later resolution and approval by ARPANSA.

The Draft EIS identified numerous "operational hazards" associated with the dump but dismissed them with the assertion that: "Appropriate procedures would be developed to address these issues." The S-EIS adds no detail whatsoever.

The Draft EIS gave nothing more than an "indicative design" and "preliminary design layout" of the planned dump, along with an "indicative borehole design". The S-EIS adds no detail whatsoever.

S-EIS: “The Draft EIS presents a preliminary design of sufficient detail to assess the environmental and other impacts of the project under consideration. This is standard practice in EIS processes. Detailed design work follows approval of the EIS and is then submitted to the relevant regulatory authorities for approval.”

“An outline of the likely design and operational plans for the repository is given in Chapter 6 of the Draft EIS. Greater details of design and operations will be presented in the application to ARPANSA for a licence to operate the facility, expected to be in 2003 subject to the satisfactory completion of the environmental assessment process.”

“The licence application to ARPANSA will indicate the nature of the waste to be disposed of in the national repository.”

“Waste acceptance criteria will be finalised during the detailed design stage, as part of the ARPANSA licensing process (see Section 3.3 of the Draft EIS). Considerable information on the proposed content of the criteria is provided in Section 4.3 of the Draft EIS.”

“The total activity limits for radionuclides will be established for the repository from the safety assessment. This will include very small quantities of long-lived intermediate level waste to be disposed of in the facility. Such materials will have to meet the acceptance criteria such as the conditioning of the waste and their activity concentration limits derived from a detailed safety assessment of the final repository.”

SA government submission: “The schedule of groundwater monitoring lacks an adequate groundwater monitoring network and does not adequately define what constitutes a contamination event of uncontaminated groundwater, or an excursion of contaminated groundwater. It also does not adequately develop risk management strategies to ensure zero/minimal impacts on groundwater or contingency plans to be implemented in the event of a contamination event or excursion, nor does it explore expected effectiveness.”
S-EIS: “These matters would be addressed during the detail design stage, as part of the ARPANSA licensing process (see Section 3.3 of the Draft EIS). An EMMP would be prepared before the construction and operation of the repository, as required under the NHMRC 1992 Code.”

STORE FOR LONG-LIVED INTERMEDIATE-LEVEL WASTE

The S-EIS cites a submission noting that in 2002 McGauran twice refused to rule out co-location, but the S-EIS doesn’t respond to that point. The S-EIS states that co-location will not occur.

OVERSEAS DUMPS

“Facilities established in the past were not always established under strict environmental guidelines and licensing. This has resulted in some facilities, for example three repositories in the US, being closed because of a lack of environmental control.”

EMERGENCY SERVICES

Submission: The Secretary of the United Firefighters Union of SA has publicly expressed his strong disapproval to establish a nuclear waste dump in SA and is calling on other emergency services to opposed the project. He also believes that although the EIS asserts that communities have been consulted on transport issues and states, there has been no meaningful consultation.

ACF submission: The Firefighters Union recommends a ban on attending accidents involving radioactive waste because of obvious concerns about the health and safety of its members and believe that there is no protocol to deal with this type of accident. Firefighters, MFS, SAS and Police are concerned that they have not been consulted regarding the repository proposal.

Broken Hill City Council submission: Previously the council requested that an analysis of the capability of emergency services within the region be undertaken. The statement that fire services are equipped for dealing with radioactive incidents is considered to be unsatisfactory. While the fire brigade may be trained, it has been forgotten that most of the towns along the transport route have volunteer brigades and as such are generally less able to meet the same standards as town brigades. Also the distances between towns can result in long response times in the event of an emergency.

Hay Shire Council submission: We question the ability of the regional emergency services to provide an adequate response should there be an accident. Little consolation can be gained from the advice in the EIS that HAZMAT stations in Sydney, Newcastle and Wollongong are staffed by 90 specially trained fire-fighters.

S-EIS responses:

“Emergency response to incidents involving hazardous materials, including radioactive waste, is a matter for the relevant state or territory emergency services, and is comprehensively covered by existing emergency planning arrangements. Section 7.6.4 of the Draft EIS describes response procedures for each relevant state and territory. In summary, each state and territory has comprehensive disaster response plans in place designed to: respond to incidents involving accidents involving trucks carrying hazardous materials, contain any spillages of materials, clean up any spillage.”

“Emergency services organisations around Australia were consulted, and provided the extensive information on emergency services programs, organisation and equipment described in Section 7.6.4 of the Draft EIS. The organisations consulted are listed in Appendix G2.7 of the Draft EIS. In South Australia the SA Metropolitan Fire Services (MFS) and the SA Country Fire Services (CFS) were consulted.”

“As noted in Section 7.6.4 of the Draft EIS, the SA Government has emergency procedures in place in the event of a hazardous material spillage. The MFS and CFS have equipment and are trained in handling spillage clean-ups, and advice may be obtained from the Environment Protection Agency on spills involving radioactive material. The Commonwealth could also be called on for assistance if required.”

“The response to a spill into water would be up to the MFS and CFS to determine; however, the approach would be expected to be similar to the arrangements that the South Australian Government and WMC Limited have in place for the transport of uranium oxide concentrate from Olympic Dam to Adelaide (Kinhill Engineers 1997a).”

“The NSW Fire Brigade (NSWFB) is also responsible for land-based incidents and spillages on inland waterways including creeks, lakes, drains and others (Section 7.6.4 of the Draft EIS). To assist in combating incidents on water, the HAZMAT unit (part of the NSWFB) mains a rigid hulled inflatable boat at its depot at Greenacre, in Sydney, which responds to combat waterway spills, deploy booms, take readings or samples, and carry out other spillage response  duties.”

OVER-RIDE OF STATE LEGISLATION

DEST seems to think the ARPANS Act will do the trick ...

“Existing Commonwealth legislation (the Australian Radiation Protection and Nuclear Safety Act 1998 (ARPANS Act)) would have precedence over any state legislation, to the extent that they are inconsistent.”

“The Australian democratic process is based on the Australian Constitution, which is an agreement involving all states and territories. In the Constitution certain powers are handed from the states to the Commonwealth. Section 109 of the Constitution, provides that, if a valid Commonwealth law is inconsistent with a law of a state parliament, the Commonwealth law operates and the state law is invalid to the extent of the inconsistency. In the management of radioactive waste, the Commonwealth has the ARPANS Act in place, which provides for the establishment and regulation of national radioactive waste management facilities. It is not a question of the Commonwealth overriding state legislation as the Commonwealth already has the relevant legislation in place. Rather, the proposed State legislation is inconsistent with already existing Commonwealth legislation.”

LAND ACQUISITION

“As noted in the Draft EIS, the Commonwealth acquisition would be undertaken under the Lands Acquisition Act 1989, and would formally commence once the Minister for the Environment and Heritage has reached a decision on the repository proposal. The Lands Acquisition Act 1989 allows land acquisition by agreement, or by compulsory process, following a well-defined series of steps. It is a standard process used for government projects.”

WASTE MINIMISATION (NOT)

“The Commonwealth Government agrees that alternatives to the creation of radioactive waste should be encouraged where feasible and that there should be incentives for the minimisation of radioactive waste production. There will be fees for the disposal of waste in the national repository to encourage waste minimisation (Section 6.11 of the Draft EIS).”

SAFETY

“Overall it was shown that risks that might arise in future years, when the site is no longer under institutional control, are acceptably low and in accordance with the NHMRC 1992 Code.”

But the Draft EIS gave a caveat which is not mentioned in the S-EIS: "The conclusion from these assessments is that the risks are very low, and within the risk target value, for all of the scenarios other than major climate changes and gross erosional events. Where these major changes have been assumed to occur, the risks are only slightly higher than the risk target. However, computer modelling by CSIRO indicates that a transition to a wetter climate in the Woomera area is unlikely to occur in the next 10,000 years."

DEST says the cover for the dump would “extend beyond the walls” of the dump so that “lining of the walls is unnecessary”. But the S-EIS pointedly fails to commit to preventing infiltration of water, saying only that the cover would “limit infiltration”.

EXISTING STORAGE SITES

PND submission (paraphrased by DEST): The Draft EIS states that ‘storing such waste in many locations in non-purpose built facilities potentially poses greater risk to the environment and people than disposing of the material in a national purpose-built repository where the material can be safely managed and monitored’. No evidence has been provided for this assertion. Current storage locations be further updated and regulated to provide purpose built facilities, this would avoid problems of transportation, safety and environmental risks.

S-EIS quotes:
- “The Draft EIS states the long term disadvantages of storing radioactive waste at the site of waste generation (in Section 1.6.1). Radioactive materials and sources are used for medical, industrial or research purposes at a large number of locations around the country. To adopt the approach suggested would require storage facilities to be maintained for relatively small amounts of waste at each site. Individual sites would need to meet defined design and security criteria at significant cost, and implement an approved EMMP. They would also require access to technical expertise in the storage of radioactive waste, which would pose difficulties for some industrial and commercial operations.”
- “A licensing system with a regular inspectorial, monitoring and audit process would need to be established at each individual site to ensure the proper long-term management and custodianship of the wastes held.”
- “Maintaining such a large number of approved storage facilities over a long period of time would be very costly, with reduced guarantee for the occupational and public safety and security of the materials than in the national repository proposal.”
- “There is no strategy in place to improve the existing 100+ storage locations across Australia in buildings that were neither designed or located for the long-term storage of radioactive material. Under the proposal, these facilities shall continue to be required as temporary storage areas even when the national repository is established.”
- “Radioactive waste stored in hospitals, industry and smaller research institutions poses the greatest potential difficulties for management in the long-term. This is because the waste is largely stored in non-purpose built facilities and administrative arrangements are not in place for monitoring and security in the long-term.”

Still no evidence (i.e. quantitative risk assessments) justifying the government’s position.

Many of the existing stores will continue producing and storing waste indefinitely (with removal of stockpiles every 2-5 years if the dump goes ahead) so by the government’s logic they all ought to have: defined design and security criteria at significant cost; an approved EMMP; access to technical expertise in the storage of radioactive waste; and a licensing system with a regular inspectorial, monitoring and audit process.

As there is “no strategy in place to improve the existing 100+ storage locations across Australia”, then why does the government claim to have a “comprehensive” plan for radwaste management?

ALTERNATIVES TO DUMPS

“It is not accepted that ‘assured isolation facilities’ are international best practice. These facilities have been proposed as an alternative to near-surface disposal in the United States where commercial operators are involved. They have not been introduced elsewhere as a suitable option for long-term management of radioactive waste.”

TRANSPORTATION

The Draft EIS said the annual risk of an accident trucking the existing inventory too Woomera is 23%, a nonsense statement since that is a one-off not an annual event. The S-EIS clarifies:
- “The risk of an accident occurring during transport of waste to the repository has been discussed in Section 7.6 of the Draft EIS. There has some misunderstanding related to the risk of transport accidents and the risk of environmental contamination as a result of any potential road accident.”
- “The Draft EIS stated that there was approximately a 23% chance that one of 171 trucks taking waste to the repository in the first disposal campaign could have an accident. This would include minor accidents causing no disruption to the waste cargo. This is equivalent to the probability of an accident occurring during an ‘average’ truck trip to the repository of 0.14%, a very low likelihood. The risk of an incident involving waste shipments is significantly lower than the potential for an accident involving other hazardous materials.”

Transport risks were mentioned in a number of regional submissions, e.g. P0573 Brown Lockwood South Public School.

SITE SELECTION

“This process has identified the central-north region of SA as the best area to site the facility.”

“The central-north region of South Australia was selected over the Olary region for siting studies as it had the largest area of suitability against the selection criteria, as described in Section 5.2 of the Draft EIS. In addition, the Olary region in part overlaps both the Murray-Darling and the Great Artesian Basins, which are important water resources.”

Digging a hole for themselves:
- SA was no better than Olary on the 13 criteria
- central-north SA in part overlaps the Great Artesian Basin so there is a clear double-standard vis a vis NSW/Olary.

LIFESPAN

The lifespan for dump is creeping up:
- then science minister Nick Minchin said in a 24/1/01 media release that the dump would have “a 50 year working life” (‘Preferred site for national low level radioactive waste repository to undergo environmental assessment’).
- the Draft EIS says: "The estimated initial operational life of the national repository is 50 years, after which time there would be an operational review."
- the S-EIS says: “The operational life of the proposed national repository is expected to be at least 50 years during which time there will be occasional disposal operations.”

INSURANCE

“In the extremely unlikely event of a transport accident, redress would be sought under the relevant domestic laws dealing with pollution and liability for harm to the environment.”

The same applies to accidents at the dump, or during preparation and ‘consolidation’ of waste to be sent to the dump ... no insurance option, just common law.

PRIVATE OPERATION

Submission from John Pattison (University of South Australia, School of Physics and Electronic Systems Engineering)
- I support the concept of a National Radioactive Waste Repository and the selection of site 52a. I am concerned that the repository will be operated by a private contractor.
- I have considerable reservation as to whether a private contractor would resist the commercial temptations to put pressure on the government of the day, possibly by-passing ARPANSA, to increase the level of radioactive waste to long-lived intermediate level waste. I object to increasing the level of waste.
- I have considerable reservation as to whether a private contractor would resist the commercial temptations to put pressure on the government of the day, possibly by-passing ARPANSA , to take radioactive waste from overseas. I object to us storing international waste.
- I doubt that a private contractor would provide the necessary level of security.
- Security fencing will not stop a terrorist or dedicated naïve demonstrator (e.g. security debacle at Woomera Detention Centre). Being located in the Woomera Prohibited Area is essential, but not sufficient. I will not give my binding support unless the above concerns are addressed.

INDIGENOUS AUSTRALIANS

ACF submission: “The Commonwealth would have to use the Lands Acquisition Act to acquire and use any of the proposed sites as stated in the EIS. The use of the Land Acquisition Act would annul Native Title rights in the area with subsequent cultural, socio-economic and disempowerment impacts on Native Title claimants and traditional owners. These issues have not been properly addressed in the EIS.”

PND submission: The Australian Council of Trade Unions Indigenous Conference passed a motion supporting the Kupa Piti Kunga Tjuta in their campaign to stop the repository proposed for their country and called the ACTU to mount a coordinated campaign with all their affiliates to oppose the development.

Submission from Aboriginal Planning Committee of Sisters of St Joseph:
- We wish to express our concern about the proposed repository for the storage of nuclear waste.
- The committee is concerned that Aboriginal cultural clearances are presented as Aboriginal approval of the repository, however nothing could be farther from the truth.
- The senior members of the Aboriginal groups involved in ‘cultural clearances’ are known to several members of our committee. The knowledgeable elders only participated in such clearances to preserve important cultural sites for which they have responsibility.
- The carrying out of this serious cultural duty (cultural clearance) did not condone such use of traditional land for which the Tjukur (Tjukurrpa), knowledge of the law, is held. Most senior members have been at the forefront of a national campaign to oppose the use of this land as a nuclear waste dump.

S-EIS:
“There has been extensive consultation with Aboriginal groups with heritage interests in the Woomera area and with native title claims covering the three possible sites (see Chapter 11 of the Draft EIS). Opinions were sought both in meetings and via written submissions from Aboriginal groups.”
“As in the broader community, attitudes towards the project varied between and within Aboriginal groups. Opinions ranged from opposition to the proposal to guarded neutrality conditional on cultural heritage issues being assessed appropriately, and landscapes and places of spiritual and cultural significance being properly protected.”
“The preferred sites and the two alternative sites and the access routes to them have been cleared for all works associated with the construction and operation of the repository (see Section 11.1 of the Draft EIS).”
“Aboriginal groups with native title claims covering the three sites continue to be consulted to address land tenure issues in the context of intended acquisition of the final site by the Commonwealth.”

S-EIS: “The Aboriginal heritage clearance process is described in Section 11.1.3 of the Draft EIS. Nowhere in that section or elsewhere in Chapter 11 is it stated or implied that involvement by Aboriginal groups in the cultural heritage clearance surveys represented Aboriginal approval of the repository.”

But at the ARPANSA Public Forum on 17/12/01, DEST’s Jeff Harris said (transcript of proceedings on ARPANSA website): “ ... those aboriginal groups that have heritage interests in those lands we have consulted extensively, with them, and each of the three sites that are going through environmental impact assessment has been inspected by these aboriginal groups and have cleared for the construction and operation of the repository.  That is not to say that they might not wish to have the repository on their land but it does say that we have got a good degree of credibility with the aboriginal groups that we taking their interests into account.”

SPACE INDUSTRY + MISSILE TESTS

Woomera Instrumented Range (WIR) / Woomera Prohibited Area (WPA)

The Australian Space Research Institute (ASRI), BAE Systems and the Northern Regional Development Board all oppose the use of site 52A within the WIR/WPA but do not object to sites 40a or 45a.

ASRI and BAE Systems contest the government’s risk assessment on several counts (e.g. probability of a strike on dump, capability of the repository to withstand a strike, consequences for future WIR/WPA activities if a strike occurs).

Concern that future operations (and potential expansion of activities) will be jeopardised by the dump, e.g. ASRI plans to trial larger rockets in the WIR.

ASRI claims that the Draft EIS overstates the security advantages of siting the dump within the WPA, especially since activities will be jeopardised by dump.

Concern from ASRI that insurance would be unaffordable or unobtainable if the dump is located in the WIR/WPA.

ASRI wants to waste stored at two sites relatively close to Site 52a to be moved and BAE Systems says the sites have had a detrimental effect on the use of the WIR area.

ASRI conclusion: ASRI believes that the proposal to site a radioactive waste repository near the launch and target areas of a rocket range is illogical and dangerous. ASRI considers the WIR/WPA vital to the advancement of Australian space science and technology. ASRI is convinced that a national radioactive waste repository at Site 52a will adversely affect the useability of the WIR/WPA and, consequently the future development of Australian space science and technology. ASRI urges the selection of sites more distant from the test range.

BAE Systems submission
- BAE Systems has a corporate commitment to the marketing and increased commercial use of the WPA for a range of aerospace programs
- dump incompatible with ongoing and expanding weapons testing and commercial trials (in the past year, WIR used for missile firings, drone launches, sounding rocket launches and Japanese National Experimental Supersonic Transportlaunches (NEXST-1).
- particularly concerned that site 52a is located well within the designated hazardous areas for most weapons trials including those in Range E and the adjacent Range E target area and notes that the NEXST-1 launch resulted in the explosive impact of the burning rocket booster 15 minutes after launch.
- Draft EIS risk assessment on likelihood of an accidental missile/bomb impact is seriously flawed
- dump at site 52a will have a profound effect on future trials proposed in the WIR and WPA and hence future business for the Defence department.
- it would increase liability concerns and ead to increased insurance premiums for clients, rejection of trials and the forcing of non-optimum flight paths, which will seriously affect the competitive advantages offered by the WPA.
- ‘perceived risk’ of radiation exposure has prevented use of specific areas in the WPA by the German Space Agency, the Japanese National Space Development Agency and NASA.
- site 52a has unique characteristics ideally suited to safe landing for test vehicles, so dump would preclude future deliberate landings of test vehicles in the optimum recovery region
- government preference for site 52a based on perceived better security of the site, but the single continuously manned security checkpoint for the entire WPA/WIR is located 45 km away and personnel can readily gain access to the WIR via station tracks from the Stuart Highway and Roxby Downs Road.
- all three sites require additional independent security provisions to prevent entry by determined groups such as protestors or terrorists.

Northern Regional Development Board submission:
- supports concerns raised by BAE systems, the Department of Defence, and others about site 52a.
- the NRDB has identified Defence and Aerospace as an important opportunity to attract additional investment into northern SA, dump would substantially diminish the efforts of BAE systems and others to achieve that investment.

Comments by DEST in S-EIS on above submissions:
- Site 52a is superior to Sites 40a and 45a in terms of access, security, biology and hydrology, however both 40a and 45a are acceptable alternative sites. While the main disadvantage of Site 52a compared to the other two sites is its potential impact on the activities within the WPA, the environmental impact and risk assessment indicates that there is a low risk of any such impacts, and the risks can be managed by good practice.
- The risk assessment described in Section 10.7.5 of the Draft EIS uses the Department of Defence endorsed methodology to assess the risk of the repository being struck by a projectile with sufficient energy to result in a release of radioactive material. This assessment indicates that the risk is low and within acceptable operational parameters. On this basis, the presence of the repository at Site 52a is not considered an ‘adverse encumbrance’ on commercial use of the WPA.
- New business in the WPA has continued despite the radioactive waste currently stored at two sites in the WPA.
- It is not possible to predict with accuracy the likely nature of weapons trials and space launch activities over an extended period. However, the past 50 years have seen substantial improvements in weapon and space vehicle design, as well as the development of sophisticated computer-based design and simulation tools. These tools have meant that the behaviour of weapons and space vehicles has become far more reliable over time.
- For radioactivity to be released into the biosphere, a breach of at least 5 m of cap material and consolidated fill, plus the containment structure of the waste would be needed.
- In regard to safe landing of test vehicles: the NEXST-1 landing area (which is assumed to include an appropriate safety template) does not overlap either Site 52a or the Range E Target Area.
- The [BAE Systems] submission gives examples of a number of recent range activities: ASRAAM is the AIM-132 Air-to-Air Missile. In studies for the Draft EIS this weapon was identified as not being a weapon that has the potential to penetrate the repository. Kalkara is not a missile but an unmanned aerial vehicle. It flies like an aircraft under guidance and is then landed by parachute. HyShot is the University of Queensland scramjet trial. The trial vehicle is designed to fly some 130 km down-range and does not impact in the vicinity of Site 52a.
- The German Space Agency considered the possible placement of a temporary radar tracking station at Maralinga, not Woomera, in the 1990s. The full reasons for the German Space Agency decision to not proceed are not known; however it is not reasonable to extrapolate that the same decision would have been made in the case of the repository, as the issues are very different.
- It is not known what factors were relevant to the elimination of Evatts Field as an acceptable site for the Japanese National Space Development Agency ALFLEX spaceplane landing trials, in the 1990s. In any case, the situation at Evatts Field at the time related to waste being temporarily stored above-ground in a non-purpose built building (a hangar) located relatively close to the runway centreline. The national repository would be an engineered, monitored, below-ground low level waste repository located some distance from the Range E target area. NASA is not proceeding with the X-38 proposal for reasons unrelated to the national repository.
- The risk of the repository being hit by a missile has been calculated using US Department of Defense methodology (see Section 10.7 of the Draft EIS). The mishap probability is ‘remote’, the mishap severity is ‘marginal’, and the risk category is ‘medium’ which is the second lowest risk category presented by the relevant standard. Risk mitigation measures would statistically reduce the risk to a risk category of ‘low’.
- A very conservative risk assessment was presented in Section 10.7 of the Draft EIS. The Australian Department of Defence advised that there were on average 60 weapons firings per year that could potentially strike the repository. Defence advise that of the 60 weapon releases, 42 have the potential to penetrate to a depth of 5 m.
- The repository cover would not be loose bulldozed earth. Soil fill over the repository contents would be compacted and covered with a compacted clay and other layers. Some further soil consolidation may be expected to occur. In addition any radioactive sources determined to be of higher activity would be contained in the repository within a conditioned concrete matrix.
- No information was sighted during the preparation of the Draft EIS to indicate that Site 52a lies within the safety templates of proposed space launches or that the probability of impact per launch exceeds 10-7. The risk assessment described in Section 10.7.5 of the Draft EIS indicates that the risks associated with Defence weapons trials (which are much more common in the WPA than space launches) lie within acceptable risk parameters, based on military risk standards.
- Investigations undertaken for the Draft EIS, including extensive consultation with the Department of Defence, were unable to identify any case where trials or activities did not go ahead because of the presence of radioactive waste. The WIR has continued to function with two radioactive waste stores located on it.
- The failure and crash of the NEXST-1 launch vehicle occurred within 500 m of the launch point and not within the landing area template shown in the attachment to the [BAE Systems] submission. This was some 8 km from Site 52a. It is also understood that, although visually spectacular, the impact of the launch vehicle resulted in little if any cratering and would not have been sufficient to breach 5 m of cover. While the launch vehicle was destroyed, the trial vehicle was recovered largely intact.
- The [ASRI] submission appears to have misunderstood the nature of the risk calculations discussed in Section 10.7.5. The method of calculating the probability of a weapon impacting on the repository is based on the safety template areas and uses Defence’s own advice regarding the varying probability of impact within the safety template. The safety templates used by Defence are based on the probability of impact from an individual weapon release of 1 x 10-6 at the template boundary, increasing to approach unity at the target point. The information provided by Defence indicates that the repository lies towards the template boundary i.e. in an area where the risk is 1 x 10-6. The methodology using the total area of the WPA is an alternative method used to demonstrate that other methods of calculating probability of impact produce a less conservative probability of impact than the use of the template probabilities.
- An annual impact probability of 4.2 x 10-5 means that an impact can be expected to occur once every 23,809 years, a period 95 times the lifetime of the repository. This can reasonably be considered a Remote possibility. Multiplying the annual impact probability by 250 means that there is a probability of impact of 1.05 x 10-2 per 250 year period, which still equates to an expected occurrence of once every 23,809 years.
- The Draft EIS does not base its estimate of probability on the relative areas of the repository and the WPA. It presents this methodology in Section 10.7 only as an alternative demonstration. The methodology used in the Draft EIS to calculate probability of impact uses the fundamental principal inherent in the concept of safety templates. The weapons being trialled on the WPA are intended to deliver a payload accurately and consistently at a defined target point. However, to account for weapon fault or error during trials, a safety template is applied. The size and shape of the safety template is based on the criterion that the probability of the weapon falling outside the template is to be no greater that 1 x 10-6. The probability of the weapon striking a chosen point within the template is therefore not uniform across the template. The probability of impact is close to 1 at the target (i.e. the template centre) and decreases with distance from the target, approaching 1 x 10-6 at the template boundary.

WMC LIMITED SUBMISSION

Whereas the Australian Space Research Institute (ASRI), BAE Systems and the Northern Regional Development Board oppose the use of preferred site 52a, WMC wants site 52a to be used and opposes site 45a.

Summary WMC submission:
- WMC believes that for jurisdictional reasons, the repository should be established at the preferred site (52a) because the Commonwealth has jurisdiction over the Woomera Prohibited Area within which the preferred site is located. Site 45a is not within the Prohibited Area, but on a SA pastoral lease.
- It is possible that during the construction and operation of the repository, there will be actions by demonstrators.
- WMC has previously spent $2.4 million enhancing security around its pump stations due to protestors and it has not been able to fully safeguard WMC property against the actions of protestors or to secure prompt action through the courts to deal with a situation of continuing trespass and vandalism. WMC is concerned that it could be faced with a similar situation if site 45a were to be selected whereas some of these difficulties are avoided by Commonwealth jurisdiction over the preferred site 52a.
- If the preferred site is not ultimately selected for the repository, WMC believes that more security and surveillance must be provided than is proposed in the Draft EIS. Based on its experience, WMC does not believe that the proposed security arrangements are adequate if the repository is located on property not controlled by the Commonwealth.
- While the Commonwealth is proposing to acquire land on which the repository is to be established, site 45a would remain surrounded by pastoral lease operations on which assets would be at risk when protestors seek access to the repository.
- WMC believes that there must be a permanent presence of security personnel at the repository to both safeguard the repository and to detect any possibility of vandalism of property in the vicinity. Additional arrangements would be necessary if site 45a were used for the repository. WMC believes that any property holder who incurs damage or costs as a result of actions by protestors against the repository, should be compensated by the Commonwealth.
- WMC also believes that the repository should be established on the preferred site, 52a, to reduce the possibility of any dislocation to existing business at Olympic Dam by protestor action. Location of the repository at 45a would make it more likely that protestors would continue to target Olympic Dam.
- It is possible that the proposed location of the repository and any access road may affect current pastoral operations, including fencelines and watering points. WMC believes the Commonwealth must commit to full compensation of costs incurred by a pastoralist to prevent disruption to existing operations as a result of the location of the repository.
- WMC also believes that the Commonwealth must cover all reasonable costs associated with the need to secure property or assets against damage by protestors.
- WMC believes the Commonwealth should commit to ongoing dialogue with pastoralists in the region to monitor any adverse impact on their ability to sell stock or the price of their stock as a result of the location of the repository, and, if necessary, agree to fund programs to address negative perceptions of the region caused by location of the repository.

S-EIS: “The control the Commonwealth has over the WPA has been taken into account in the siting studies. Apart from the geology and groundwater characteristics, which are superior at Site 52a when compared to the other two sites, the security provided by the WPA provides an advantage at Site 52a.”

S-EIS: “Part of the licence application to ARPANSA will involve a threat assessment for the relevant site to be undertaken by the Australian Security Intelligence Organisation (ASIO), together with an outline of the proposed security system for the various stages of the facility operation. This is expected to involve a combination of physical security, surveillance and an on-site presence as appropriate. ARPANSA would need to be assured that the proposed arrangements provided adequate security for the radioactive waste at the repository site. If Site 52a were chosen, the siting on the WPA would provide additional protection to site security.”

COUNCILS

Submissions expressing concern about dump and esp. transportation from Broken Hill City Council, Central Darling Shire Council, Hay Shire Council, Narrandera Shire Council.

Sutherland Shire Council
- The Lucas Heights Science and Technology Centre should not be used as a de facto repository for the radioactive waste of Australia. Commonwealth policy agrees with this position.
- The EIS is inadequate with respect to its statutory obligations under the EPBC Act notably in its failure to adequately describe the design and life-cycle considerations of the proposal. This includes aspects relevant to environmental impact, costs and benefits, security and potential impacts on indigenous and non-indigenous Australians.

OTHER

Sutherland Shire Council submission: Table E7 of the EIS indicates that long-lived intermediate level waste (including uranium and plutonium) will be placed in the repository. The EIS is misleading the public by indicating that it is a short-lived intermediate level repository.

S-EIS: “However, the use of vertical boreholes of up to 20 m in depth is one possible option for the disposal of small volume sealed sources and is under consideration for the proposed national facility (see Section 6.2.3 of the Draft EIS).”

Appendix C in the S-EIS contains an updated national inventory tabulated by volume and by a handful of radionuclides.

John Hill — Government of SA submission:
- On principle, each State should take responsibility for the storage of their respective radioactive waste material produced.
- ... the Commonwealth has failed to adequately prescribe the design of a facility which could result in detrimental environmental outcomes.
- The design philosophy adopted by the proponent creates the potential for environmental harm to occur as a result of leachate migration to the watertable as defined by the SA Environment Protection Act 1993. The facility is ‘designed to leach’ rather than each storage cell being totally sealed.
- There is no assessment of the impacts on site hydrology which may occur as a result of accelerated climate change resulting from global warming and the associated implications for site design criteria.
- No details are provided to ensure that the repository management plan addresses ‘operational details, ongoing control, maintenance, monitoring and reporting, and post closure management of the site’.
- The assumptions made on the nature and characteristics of the geological units (including soils), are questionable. The site is more likely to be characterised as a fractured rock or double porosity medium, rather than a porous medium as assumed in the EIS. There are implications on the fate of any potential leachate at the site due to the complex nature and different behaviours of fractured rock aquifers.
-The schedule of groundwater monitoring lacks an adequate groundwater monitoring network and does not adequately define what constitutes a contamination event of uncontaminated groundwater, or an excursion of contaminated groundwater. It also does not adequately develop risk management strategies to ensure zero/minimal impacts on groundwater, and contingency plans to be implemented in the event of a contamination event or excursion, nor explore expected effectiveness.
- Insufficient detail has been provided on the collection and consolidation part of the logistics chain within the metropolitan area. There is a concern regarding the numerous locations where storage takes place and how and where vehicles will be ‘consolidating’ their loads of low-level waste.