1. Unnecessary
2. Unwanted
3. Dumping on Democracy
4. Radioactive Racism
5. Public Health & Environmental Risks
6. No Independent Regulator
7. Blank Cheque
8. Dumping on SA
9. Thin Edge of the Wedge
10. The Real Agenda
11. False Consultation
12. Secrecy
13. Maralinga
14. Tourism & Exports
15. Commercial Imperatives

1. Unnecessary

Radioactive waste is best managed at the site of production in properly secured and monitored above-ground facilities:
i) thus avoiding the risks associated with transportation
ii) encouraging waste producers to minimise waste production (as opposed to out-of-sight-out-of-mind options); and
iii) because the dump would only take waste every 2-5 years so waste producers would need proper on-site facilities even if the dump went ahead. Once they all have adequate facilities, the rationale for a dump is negated.

The government’s answer to point iii) is to talk about the waste backlog “problem”. According to the government (Final EIS, Appendix C), just 20 cubic metres of low- and short-lived intermediate-level waste destined for the dump have been generated in South Australia. Elsewhere the government says this material is stored at 130 sites. So on average, institutions have a backlog of just one-sixth to one-seventh of a cubic metre - about a suitcase full - no real problem at all.

In some cases - e.g. disused buildings for which alternative uses are proposed - storage at the site of production is inappropriate. Alternatives can be found to deal with the minuscule amount of waste that falls into that category.

The government argues that it is problematic to have many different institutions managing radioactive waste, and so it is, but many different institutions will be managing waste whether or not the dump goes ahead because they continue to produce it. If they can’t manage the waste they shouldn’t be dealing with radioactive materials in the first place - especially since radioactive decay ensures that the waste is less hazardous than the radioactive materials which give rise to it.

The government has grudgingly acknowledged the obvious point that many waste stores will still be waste stores even if the dump goes ahead, because of ongoing production, which begs the question: what is the federal government doing to ensure proper licensing, regulation, monitoring etc. of state/territory waste stores? The answer is: nothing, absolutely nothing. Lots of scare-mongering about “unsafe” or “temporary” stores but no action whatsoever to remedy unsatisfactory stores. Thus the government’s claim to be acting on public health and environmental grounds must be rejected. Moreover, the management of Commonwealth storage sites has left much to be desired, e.g. several spent nuclear fuel accidents (and cover-ups) at Lucas Heights in recent years.

2. Unwanted
* an overwhelming majority of South Australians oppose the dump (68-95% according to various polls).
* the South Australian Parliament legislated in March 2003 to ban the dump.
* the United Trades and Labor Council of SA has established a ban on union labour building, or supplying services to, the dump.
* seventeen local councils oppose the transportation of radioactive waste through their jurisdictions between Lucas Heights in Sydney and the planned dump site near Woomera.

3. Dumping on Democracy
* the government intends using the Lands Acquisition Act 1989 to compulsorily acquire a site for the dump.
* the government is also threatening to over-ride state legislation banning the dump using either the ARPANS Act or the ANSTO Act.

4. Radioactive Racism
* Opposition from Aboriginal groups such as the Kupa Piti Kungka Tjuta women’s group has been ignored.
* the government plans to annul Native Title rights at the dump site. A crude divide-and-rule tactic by the federal government to buy off Aboriginal opposition to the dump was rejected. "Our heritage is not for sale", said Kokatha Land Council representative Andrew Starkey. (The Australian, 27/2/03.)

5. Public Health & Environmental Risks
* the government underestimated the possibility of missile or rocket strikes on the dump site according to the Defence Department, defence minister Robert Hill,  and civil aerospace organisations. Only when the plan to build the dump next to a missile/rocket testing range was subjected to independent scrutiny was it abandoned. Why no independent assessment of other aspects of the dump proposal?
* since the “preferred” dump site next to the missile testing range was rejected by environment minister David Kemp, science minister Peter McGauran has been pretending that the two non-preferred sites east of Woomera are of “equal suitability” to the rejected site (media release, 15/4/03). Yet the Final Environmental Impact Statement prepared by Mr McGauran’s own department said that those two sites are inferior in terms of “access, security, biology and hydrology”.
* the government has identified numerous "operational hazards" but has no plans to address them.
* any benefits to SA associated with the dump are negligible and must be outweighed by the costs/risks.
* risk assessments have not accounted for social risks, e.g. the mismanagement of the Maralinga ‘clean-up’, e.g. lack of an independent regulator.
* risk assessments have also ignored the risk of a low-level and short-lived intermediate-level waste dump paving the way for higher-level wastes.
* no option of insurance against nuclear accidents, and little chance of winning common law claims against the Commonwealth.
* the government estimates a 23% chance of one truck accident while moving the current national waste inventory to SA (with many more movements and thus additional risks in subsequent years and decades).
* emergency services such as the SA Firefighters Union have expressed concerns about and opposition to the dump and the lack of consultation.
* scientific uncertainties regarding radiation/health debates, e.g. European Committee on Radiation Risk recent recommendation for a 10-fold reduction in the total maximum permissible dose to members of the public arising from anthropogenic sources (from 1.0 milliSieverts to 0.1mSv annually)
* various other scientific uncertainties, e.g. studies from Los Alamos and Nevada have revealed much faster radionuclide migration than previously believed.

6. No Independent Regulator
* no prospect of diligent oversight from an independent regutor because there IS no independent regutor.
* the head of the Lucas Heights nuclear agency (ANSTO) was directly involved in the selection of the head of the regulatory agency (ARPANSA).
* six ex-ANSTO staff work for ARPANSA, i.e. revolving door.
* ARPANSA’s performance during the Maralinga clean-up left much to be desired according to nuclear engineer Alan Parkinson
* ARPANSA has already abrogated its responsibilities and commitments in relation to long-lived intermediate-level waste (LLILW): ARPANSA CEO John Loy stated that reactor construction at Lucas Heights would not be authorised until “progress” was made towards the establishment of a LLILW store, but he still approved reactor construction even though the “progress” with the store was all backwards.

7. Blank Cheque
* we have nothing more than a “preliminary, indicative” design of the dump.
* the dump would take waste for “at least 50 years” according to the government, i.e. indefinitely.
* information on the waste inventory is scanty, e.g. the governments estimate of total radioactivity increased by 37% between July and December 2002.
* waste acceptance criteria have not been established.
* the ‘low-level’ dump would take low-level, short-lived intermediate-level and “very small quantities” of long-lived intermediate-level waste.
* overall, South Australians are being asked to sign a ‘blank cheque’.

8. Dumping on SA
* the claim that SA is the "best and safest" site for the dump is false and is flatly contradicted by the government's own documentation. The relevant scientific report - the 1997 Phase 3 Discussion Paper from the Bureau of Resource Sciences - notes that four states have areas of “high suitability”. (<www.geocities.com/jimgreen3/waste9.html>).
* a clear double-standard has been applied comparing SA and NSW sites: partial overlap of water basins is given as the reason for exclusion of NSW site, but the selected SA region partially overlaps the Great Artesian Basin.
* the claim that two-thirds of the national inventory is already in SA is misleading: measure by radioactivity (instead of volume) and count only SA-produced waste (not Commonwealth waste), and the figure is 2/6367 Gigabecquerels or 0.03%. (The CSIRO soil at Woomera accounts for 54% of the national waste volume but just 0.3/6367 GBq = 0.005% of the radioactivity.)

9. Thin Edge of the Wedge
* the 'low-level' waste dump could be followed by a store for long-lived intermediate-level wastes (LLILW) including wastes arising from reprocessing spent nuclear fuel rods from reactors at Lucas Heights. This ‘co-location’ was the government’s ‘first siting option’ until 2001. Twice in 2002 the science minister refused to rule out co-location.
* the ‘interim’ LLILW store may become a permanent fixture, or a deep underground dump or some other "purpose-built facility" may be established for LLILW disposal.
* a nuclear reprocessing/conditioning plant may be on the agenda in the years to come. Several sites in SA were considered for a reprocessing plant by the federal government in 1997 - Mt. Lofty Ranges, Woomera, and Roxby Downs (Department of Industry, Science and Tourism, "Siting Cabinet Submission", July 1997).

10. The Real Agenda
* the government’s agenda is to shift waste from ANSTO’s nuclear plant at Lucas Heights in Sydney to reduce public opposition to a new reactor; 81-90% of the waste sent to Woomera would come from Lucas Heights. So the government’s agenda is not to safely manage existing waste, but to facilitate the production of far more waste - and to dump that in SA as well.
* reactor approvals (past and future) are contingent on getting the waste off-site.
* using the upper estimates (2x2500=5000 m3), dismantled nuclear reactor components (which the government plans to dump in SA) will comprise a greater volume than the entire current national inventory (3700 m3).
* the government’s claim that most of the waste is a by-product of nuclear medicine is false. In any event, if nuclear medicine was the criterion for siting the dump (which it isn’t) and if there was a need for a national dump (which there isn’t) then the dump would go in NSW, which has seven times more nuclear medicine procedures than SA, or Victoria (x4) or Queensland (x2). Beware the federal government’s scare-mongering and guilt-tripping - Australia doesn’t even need a reactor for isotope supply let alone a dump let alone a dump in SA.

11. False Consultation
* the Environmental Impact Statement is a sham - written, 'reviewed' and rubber-stamped by the federal government.
* instead of a genuine consultation process, and an independent public inquiry, we are being subjected to a $300,000 PR campaign including a $220,000 contract awarded to multinational firm Hill & Knowlton (which has previously worked for tobacco companies, asbestos companies, Enron etc.)
* the government plans to recruit “willing scientists” as part of its PR campaign.

12. Secrecy
* all 667 public submissions on the EIS have been kept secret.
* the Defence Department’s risk assessment has been kept secret.
* the Final EIS was kept secret for a month.
* the Environment Department’s analysis of the EIS is being kept secret.
* the Australian Democrats have initiated three Senate orders for all documents relating to the siting of the dump to be made public, but all three orders have been refused by the government. (Senator Lyn Allison, media release, 11/4/03.)

13. Maralinga
* the government breached national and international standards during the latest 'clean-up' of the Maralinga nuclear test-site and there's no reason to believe the dump project would be handled more responsibly.
* the government falsely claims that cost-cutting did not motivate its decision to dump plutonium-contaminated debris in shallow pits despite several documentary records to the contrary. Who’s to say safety won’t be compromised to cut costs at Woomera. In fact it already is, e.g. minimal security, e.g. unlined disposal trenches.
* the ‘clean-up’ has been strongly attacked by scientists such as nuclear engineer Alan Parkinson and US-based geochemist Dale M. Timmons, and a key decision (shallow burial of plutonium-contaminated debris) was strongly opposed by Dr. Mike Costello from the government’s own advisory committee. A senior ARPANSA officer, Dr. Geoff Williams, complained about a “host of indiscretions, short-cuts and cover-ups” during the ‘clean-up’.
* the government should cancel the dump and clean up Maralinga instead.
* numerous articles on the Maralinga scandals including several by scientific whistle-blowers Alan Parkinson and Dale Timmons at: <www.geocities.com/jimgreen3>.

14. Tourism & Exports
* according to SA Premier Mike Rann: "We proudly market ourselves as a clean, green state in the export of our wine and foodstuffs, and in attracting tourists to our pristine outback. What impact would a national radioactive waste dump have on our tourism and export industry?" (Letter to SA parliamentarians, quoted in The Australian, 17/3/03.)
* according to SA environment minister John Hill: “[This proposed national dump] will harm our clean green image, which is important for food and wine exporters and the tourism industry. (Media release, 6/3/03.)

15. Commercial Imperatives
* John Pattison, lecturer in the School of Physics and Electronic Systems Engineering at the University of South Australia, expressed concern in his EIS submission that a private contractor would pressure the government of the day to up-grade the dump from low-level waste and short-lived intermediate-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.