TABLE OF CONTENTS - PART 1
--> COMMENTS ON THE EIS PROCESS
--> COMMUNITY CONSULTATION
--> JOBS, ECONOMICS & A NON-REACTOR FUTURE FOR LUCAS HEIGHTS
--> PREVIOUS STUDIES
--> RADIOACTIVE WASTE
--> SITING
--> NUMBER OF REACTORS IN THE WORLD

> PART 2 :
RADIOACTIVE EMISSIONS
BUSH FIRE HAZARD
DECOMMISSIONING
HIFAR SHUT DOWNS
ARPANSA
NUCLEAR SAFETY
THE NATIONAL INTEREST/SECURITY DEBATES
HISTORY OF NUCLEAR ACTIVITIES IN AUSTRALIA
INDUSTRIAL AND AGRICULTURAL APPLICATIONS
OPPORTUNITY COSTS

> PART 3 :
ALTERNATIVES TO A NEW REACTOR:
GENERAL COMMENTS
SCIENTIFIC RESEARCH
SPALLATION SOURCES
CYCLOTRONS

> PART 4 :
ALTERNATIVES TO A NEW REACTOR:
NUCLEAR MEDICINE
RADIOPHARMACEUTICAL R&D
TARGET TECHNOLOGY
RADIOISOTOPE PROCESSING FACILITIES

"If it is normal for the proponent to tell the truth, but not necessarily the whole truth, then ANSTO's presentation is normal. Sometimes the difference between the truth and the whole truth is quite remarkable." --- Tony Wood, former Head, Engineering and Reactors, ANSTO, 1998, EIS submission.

The Environmental Impact Statement (EIS) appears to be an expensive bureaucratic whitewash.

John Howard is quoted in the St George & Sutherland Shire Leader (11 August, 1998) saying that the Government has been "open and honest" in its handling of the reactor issue. Rubbish. We have no reason to trust a government whose strategy was explained thus by a "senior government source" on Radio National's "Background Briefing" program (March 29): "The government decided to starve the opponents of oxygen, so that they could dictate the manner of the debate that would follow the announcement. Because they couldn't win it on rational grounds ... they decided, right, we'll play the game and in the lead up to the announcement catch them totally unawares, catch them completely off-guard and starve them of oxygen until then."

It was also made clear on the ABC radio program that the government deliberately overstated the medical "benefits" of having a new nuclear reactor in suburban Sydney, and that the government deliberately delayed the announcement on the new reactor so that it would coincide with the decision on Holsworthy. To the best of my knowledge, these claims have not been denied.

Given its record of secrecy, manipulation, and dishonesty, and the fact that the government has already made an in-principle decision to build a reactor, there is every reason to question the value of the EIS process.

We can only hope that employees within Environment Australia have the integrity and the courage to take a stand. In the first instance the task for Environment Australia is to ensure that the Final EIS is a vast improvement on the Draft EIS. This is no small task since the central premise of the Draft EIS - that a new reactor is justified on medical, scientific, national interest and industrial grounds - is fallacious.

ANSTO's track record on the new reactor plan is one of secrecy, manipulation and dishonesty. It is my experience, shared by many others, that the government and ANSTO are excessively secretive about the reactor plan and about ANSTO's operations more generally. It is commonplace for letters and questions not to be answered at all let alone adequately. I have sent dozens of letters to ANSTO which have not been answered. When I asked Helen Garnett, ANSTO's Executive Director, about this during a radio debate (August, 1998), her response was, predictably, evasive and quite possibly a blatant lie. She claimed that she is aware of a "few" letters asking questions relating to commercial-in-confidence issues. Rubbish.

ANSTO set the tone early in the EIS process, as discussed by the Sutherland Shire Council: "Council (takes) issue with (ANSTO's) Notice of Intent for the proposed reactor that the conditions of the (1993 Research Reactor Review) had been satisfied or otherwise addressed during the government analysis of the need for the proposed reactor. Indeed, Council found the Notice of Intent to be quite different from other Notices of Intent for Commonwealth projects, amounting to an advocacy document rather than an objective identification of the issues likely to arise in the Environmental Impact Assessment. Council is concerned that such an advocacy document may have the tendency to bias the results of the investigation. For example, an examination of specific sites as proven and feasible alternatives to the proposal, particularly in the context of future nuclear waste management, has been excluded. The presence in the Notice of Intent of conclusions concerning the outcome of the environmental assessment process, suggests that the process is not intended to be objective but possibly to arrive at a pre-judged conclusion."

The fact that ANSTO is responsible for preparing the EIS is completely unacceptable given its vested interest in a new reactor and ANSTO's track record of secrecy, manipulation and dishonesty.

In a letter to me (12 August, 1996) the (former) science minister Peter McGauran said: "Although the Research Reactor Review recommended that a decision on a new reactor be made 'in about five years time', it did not recommend that a new inquiry be undertaken." This is false. The 1993 Research Reactor Review (p.4) specifically said that "if, at some later stage, a new reactor is envisaged, it should be assessed by a new panel possibly operating within the Environmental Protection Act 1974". The RRR clearly had in mind a public inquiry, conducted by a panel such as that which conducted the RRR, not this sham Environmental Impact Assessment.

There are many other problems with the EIS:
o the lack of detail on just about every issue is high farce. It was nice, however, to learn on p.7-19 that "... most people value the friendliness of their neighbours, and the opportunities to be of help and meet with other people afforded by their place of residence."
o the fact that there is no opportunity for public comments to be made on the Final EIS is completely unacceptable and inexplicable. Given the flawed legislation, and the realpolitik of government/ANSTO collusion on the reactor plan, the Final EIS is certain to be almost as disgraceful as the Draft EIS. There is always the opportunity to write to the Environment Minister or the Science Minister (again), but my letters to government ministers are rarely answered and never answered satisfactorily.
o ANSTO has had millions of dollars of tax-payers' money to prepare the EIS whereas opponents have had no funding whatsoever. The Final EIS should note this fact.
o ANSTO hired PPK Environment and Infrastructure to help prepare the EIS. PPK was severely criticised by an independent auditor during the Holsworthy airport EIS. The PPK project team has no expertise in nuclear sciences. PPK's "information stalls" are high farce: PPK distributes information on the EIA/EIS process but hardly any information on the reactor proposal per se.
o PPK refused to organise a public meeting at which both proponents and opponents would speak.
o PPK refused to publicly release research documents being produced by ANSTO and NNC (the sub-contractor) during the preparation of the Draft EIS.
o I asked ANSTO to send answers to a list of questions reasonably quickly so that I could incorporate the answers into this submission. I still have no answers after several months. In fact I have been asking some of the questions on that list for over a year and ANSTO continues to stonewall with a string of weak excuses: commercial-in-confidence, under-resourced and over-worked, answers will be supplied in the EIS (which they have not), etc. The reality is that ANSTO manipulates its corporate image with the selective release of information and misinformation. Only the federal government has the power to immediately redress this situation yet the government itself has been secretive and dishonest.
o I asked PPK to send answers to a list of questions reasonably quickly so that I could incorporate the answers into this submission. I still have no answers after approximately two months.
o Dr. Furzer (Sydney University) submission on the Draft EIS notes that he twice asked ANSTO to supply four papers listed in the Draft EIS. The papers were not supplied and thus Dr. Furzer says his submission was "limited in scope".
o another submission to the Draft EIS noted that a request for a tape of the radio debate between myself and Garnett was not met in time for it to be of use in making an EIS submission. ANSTO was in possession of the relevant tape for some time but, according to 2SSR, ANSTO was unable to make copies. ANSTO can operate a nuclear reactor but cannot copy a tape?

It is reasonable to suspect that ANSTO has been sitting on the tape of the radio debate because it does not want to have to justify comments made by Helen Garnett during the debate. In particular, Garnett's comments on safety, emergency planning etc. were, from my recollection, distinctly different to ANSTO's usual rhetoric. Environment Australia should acquire a copy of the tape from ANSTO or 2SSR and follow this matter up.

ANSTO's standard response to criticisms of the EIS is that the procedure has been followed to the letter of the law. This counts for little when the legislation is grossly inadequate.

The Sutherland Shire Council (Senate Inquiry submission) called upon the Federal Government to put in place an environmental auditor to oversee the reactor EIS process. That call went unanswered.

Earlier this year I compiled a catalogue of misinformation on the new reactor. ANSTO is the major culprit, though it is common enough to see bureaucrats and politicians parroting misinformation which appears to have originated from ANSTO. Neither ANSTO nor the government has prepared a response to this catalogue of misinformation. I have written to Garnett asking if she will prepare a response to the criticisms made of ANSTO in this catalogue of misinformation and send it to me. She refuses to do so.

Others have commented on ANSTO's slanted approach to the reactor debate:
o "Of course, (ANSTO does) have a vested interest in pursuing a new reactor. That obviously is their raison d'etre - the whole reason for the existence of ANSTO - and they would therefore be expected to pursue that argument as strongly as they could in the public arena." (Martyn Evans, Shadow Science Minister, Current House Hansard, pp.3459-66, 14 May, 1998.)
o "(It is an) unfortunate state of affairs that dear old ANSTO, which lives off taxpayer's money, is feeding us all this propaganda and very little objective information. I thought governmental agencies are there to serve the public - not just to perpetuate themselves." (Nuclear engineer employed at ANSTO for a quarter of a century.)
o 6-8 current or former ANSTO staffers have told me that have no faith/trust whatsoever in ANSTO management and that hostility towards ANSTO management is generalised within the Organisation.

It is common for ANSTO to ignore information which undermines the case for a new reactor - the Draft EIS is a clear example of this. I have listed questions and suggestions throughout this submission and I expect ANSTO/PPK to address each and every suggestion/question in the Final EIS. Most suggestions and questions are highlighted to facilitate this process.

The Draft EIS (p.18-16) says "ANSTO is in the process of developing a customer service charter which, among other things, will address provision of information. All members of the community would have access to a complaints handling and resolution procedure developed by ANSTO to ensure complaints are recorded and addressed. ... ANSTO, most likely involving a third party, would report publicly on issues relating to the number of complaints received, how these complaints were resolved and if they impacted on the project."

Why a customer service charter - why not a public service charter? Do the Draft EIS comments refer only to the new reactor "project" or is an ongoing mechanism envisaged?

It is imperative that the customer service charter and the complaints resolution procedure are implemented forthwith. I understand that ANSTO has stone-walled this project for a long period of time. Environment Australia should insist that the process is implemented forthwith as one condition of acceptance of a Final EIS.

The Draft EIS (p.18-17) says "ANSTO has made presentations to community groups on aspects of waste management, such as discharges to the sewer, and will continue to do so on request." It is notable that ANSTO refuses to participate in a public debate on the reactor plan. I have made numerous requests to ANSTO staff for a public debate and all requests have been refused. One excuse given is that hecklers would disrupt the debate. This is ironical given that the vast majority of heckling at public meetings has been from ANSTO employees and contractors. A more likely reason for ANSTO's shyness is that ANSTO does not want to be held to account for the plethora of misinformation it has released on the new reactor plan. The Final EIS should also note that the following participants in the debate have refused my request for a public debate at a public meeting:
o Helen Garnett, Executive Director of ANSTO
o Mike Watson, ANSTO PR hack. (He was scheduled to debate me at Como in June but pulled out with less than 24 hours notice, claiming that I would bring along protesters who would heckle him and that I would bring along the media!)
o John Mulcair, ANSTO PR hack
o Stewart Carr, ANSTO's radioisotopes director
o PPK
o science minister John Moore
o Danna Vale, Member for Hughes, opponent-turned-supporter of the reactor plan, denies that political expediency motivated the change.
o "Honest" John Howard
o former science minister Peter McGauran

Helen Garnett agreed to a radio debate, held on 14 October on 2SSR radio. This was no substitute for a genuine public debate at which community members would have ample time to ask questions. ANSTO planned to use this debate as evidence of its "commitment" to community consultation, and therefore advertised the debate in the local paper(s). I am told the advertisement was ridiculously small and buried in an obscure part of the paper. A copy of this advertisement should appear in the Final EIS.

The entire community consultation "strategy" has been high farce. PPK's role is particularly pathetic - "information" stalls with no information, failing to reply to letters, etc. The Twyford report was also far from adequate.

"I would be surprised if the fraction of ANSTO's work which actually depended on the output of the reactor facility ... exceeded ~1/3. Overstatement of ANSTO's reactor-dependence persists in the Draft EIS." --- Murray Scott, Submission on 1998 Draft EIS

The Draft EIS makes the following assertions:
o "Most of ANSTO's science and technology activities depend either directly or indirectly on the operation of a reactor." (p.4-4)
o "... there would be adverse local employment impacts as a result of not having a replacement reactor." (p.4-23)
o "In the absence of a reactor, on the Lucas Heights site, the range and extent of activities at the Lucas Heights Science and Technology Centre would be significantly reduced. There would be little use for much of the nuclear related infrastructure that has been built up over the decades and there would be a concomitant loss in staff." (p.4-23--4-24)
o "If the government decided to use the site for some other use it is likely that much of the infrastructure would not be able to be used efficiently or effectively. There would need to be substantial investment and changes to the site to enable it to be used for another purpose. Even under the most optimistic scenario, it is thus likely that there would be a significant loss of employment and economic activity at the Lucas Heights Science and Technology Centre with flow on effects to the community." (p.4-24)

This string of assertions should be thoroughly justified or removed.

As for the proportion of reactor-dependent work at LHS&TC:
o Prof. Geoffrey Wilson (RRR Appendix, pp.31-32, 41-43) analysed ANSTO's program expenditure. His findings were that in 1991-92, reactor-dependent research cost $8.35 million (31%), reactor-independent research (including the Japanese Photon Factory) cost $18.45 million (69%). Radioisotope research was considered to be reactor-independent. Prof. Wilson concluded that just 31% of ANSTO's research is reactor dependent - less than one third.
o drawing on ANSTO's 1992-93 Program of Research, former AAEC/ANSTO/CSIRO employee Murray Scott (RRR submission) concluded that HIFAR and MOATA were used in 8 of 17 projects. In person-years this amounted to 45/215 or 21%. The figure fell to 14% when the adjacent CSIRO facilities were included. Presumably the reactor-dependent figure would be lower given the closure of the MOATA reactor.
o two current ANSTO employees estimate that only 30-40% of ANSTO's work is reactor dependent.

The Final EIS should note that according to the only independent reviews (Wilson, Scott), only 21-31% of ANSTO's work could be considered to be reactor dependent.

There may be a case for further investment in non-reactor technologies at LHSTC, which would further reduce concerns about job losses.

Overall, it appears that LHSTC can be maintained as a viable and useful institution without a reactor. A non-reactor future offers the following advantages:
o few if any job losses (and perhaps more jobs) depending on investment in non-reactor technologies (accelerators, spallation sources, etc.)
o reduction in the generation of radioactive waste
o health and safety advantages
o increased community support

Environmental Economics Group (Environment Priorities and Coordination Group) - Environment Australia, 1998, EIS submission. This submission raises numerous questions about ANSTO's legendary capacity for creative accounting. (A number of submissions to the 1993 Research Reactor also took up this issue.) It deals with claims made in the Draft EIS in relation to employment, opportunity costs, etc. I understand that one of the studies commissioned by the Sutherland Shire Council and presented in the Council's submission to the EIS addresses economic matters including jobs and opportunity costs. In addition, the Environmental Economics Group (Environment Priorities and Coordination Group) should be asked to study the matter in some depth rather than simply asking questions of ANSTO. A related issue which requires thorough investigation is to develop and cost a non-reactor future scenario for the ANSTO Lucas Heights site.

JOB ESTIMATES

The EIS (p.5-35) says "It is envisaged that preliminary groundworks phase work crews would comprise approximately 40 to 50 people. The average number of people working on the site would be in the order of 100 with a peak of up to 150. These figures exclude off-site workers and sub-contactors who may be involved directly in the construction."

What is the overall estimate for employment arising from reactor construction?

In a press release (September 3, 1997), former science minister Mr. Peter McGauran said "The reactor .... will create up to 800 new jobs during the building phase." Ms. Danna Vale says "The decommissioning of the old reactor and the construction of the replacement will create over 800 new jobs in the Shire." Prof. Garnett said her understanding is that the figure of 800 jobs was arrived at by working out the amount of money that will be spent in Australia (just over 50% of the capital costs) and then using "normal" calculations used in the construction industry. According to Senator Lundy, ANSTO said in its submission to the 1993 RRR that a new reactor would create just 175 jobs.

Prof. Garnett said ANSTO was not involved in arriving at the estimate of 800 estimates. ANSTO has however said that 3600 person-years of employment will be generated during construction of the reactor, and that the construction time will be three years. This equates to 1200 full-time jobs over three years. How does ANSTO justify this claim? Is it true that in 1993, ANSTO projected no more than 175 jobs? How can the 1993 information from ANSTO be squared with the 1997 information?

By way of comparison, AECL (Canada) is building two reactors plus an isotope processing facility and expects this will create 500 person-years of employment. Even allowing for the fact that ANSTO plans a multipurpose reactor, as opposed to the dedicated isotope-production reactors in Canada, ANSTO's projection of 3600 person-years of employment appears to be well beyond the realms of possibility, as do the claims of Mr. McGauran and Ms. Vale.

No figures have been provided as to potential employment arising from pursuing alternatives to a new reactor at Lucas Heights, such as cyclotrons, linear accelerators, spallation sources, synchrotron radiation sources, and so on. It is imperative that this information is provided in the Final EIS.

Former ANSTO employee Jim Fredsall (1998, EIS submission) claims that only 3% of ANSTO staff are engaged in R&D (including medical applications) that depends on having an on-site reactor. He says, "All other ANSTO R&D applications which depend on reactor isotopes can use isotopes imported from overseas." The basis of Mr. Fredsall's claims should be ascertained and commented on in the Final EIS.

AECL, leaflet attached to Mr. J.R. Fredsall's submission to the Senate Nuclear Reactor Inquiry.

ANSTO, 1997, "A Replacement Research Reactor for Australia: Background Information", <http://www.ansto.gov.au/qanda.html>

Garnett, Prof. Helen, 1997, Senate Estimates Committee Hearing, 12 November, Estimates Committee Hansard, pp.387-397.

Senator Lundy, 1997, Senate Estimates Committee Hearing, 12 November, Estimates Committee Hansard, pp.387-397.

COSTS

The Sutherland Shire Council (submission to Senate Inquiry) makes the following points:
o basing costs on preliminary design will significantly underestimate the likely replacement reactor costs
o there is a need to budget for capital additions (a large and growing cost in US commercial reactors)
o "underestimating of decommissioning costs occurred in the ANSTO Submission to the RRR because of the use of high discount rates ...."
o waste costs must be factored in
o overall, cost-benefit analysis needs to incorporate: quotations on a reasonably specific design; the history of cost increases in major projects (particularly nuclear reactors); a sensitivity analysis of revenue estimates based on the impacts of lower levels of growth and/or market penetration; and the need to be specific about scientific benefits.
o "It is vital that decommissioning costs and waste management (including establishment of waste repository) costs be included in any estimate for a replacement reactor so that world's best practice waste minimisation and waste disposal may be achieved in Australia."
o "Fundamentally, no thorough cost-benefit analysis for the replacement reactor process has occurred, nor is likely to occur in the absence of such a requirement in the Final Guidelines for the EIS."

The Sutherland Shire Council based those claims on a number of expert commissioned studies (Attachments B, G, H, I to the Council's submission to the Senate Inquiry), which Environment Australia should obtain.

In his 1998 EIS submission, Tony Wood (ex-ANSTO) questions ANSTO's claims about the cost of relocating a reactor. His claims need to be independently tested. I suspect that Environment Australia has the in-house expertise to at least partially pursue this matter.

The Draft EIS (p.3-14) refers to the 1992 ASTEC report on major national research facilities in support of the reactor proposal. DIST and Danna Vale have done likewise. However the 1992 ASTEC Review was a preliminary sifting of almost a hundred proposals for science funding; it was anything but a searching analysis of the cases for and against a new reactor. Then Prof. Anne Henderson-Sellers, an ASTEC member, one of three members of the RRR panel, and now an ANSTO employee, expressed serious doubts about the medical, scientific and commercial reasons for a reactor (in the RRR report). During the 1993 RRR, ASTEC said a decision on a new reactor ".... must not be based solely on the needs of scientific research and industrial production. It must also take account of a number of social, political and cost factors. .... The detailed, rigorous evaluation advocated by ASTEC has yet to be made - ASTEC sees this as the responsibility of the RRR." If ANSTO/PPK insist on justifying the reactor with reference to the 1992 ASTEC study, the above quote from ASTEC should be included.

The Draft EIS (p.3-16) also attempts to justify the reactor proposal with reference to the 1994 Bain-Battelle report. The Draft EIS fails to note that this report was commissioned by ANSTO and thus its independence is open to debate. Moreover the report's treatment of substantive issues such as waste management and the health effects of radiation is cursory - the report falls far short of being a systematic, balanced analysis of the cases for and against a reactor. The reference to the 1994 Bain-Battelle report should be deleted in the Final EIS.

ANSTO/DIST (Senate Inquiry submission, pp.497-498) also imagine that the 1993 RRR "identified the necessity for a replacement research reactor." Rubbish. This is further discussed later in this submission (Alternatives - Scientific Research - General Comments).

ANSTO/PPK (p.10-2) say "There are many precedents for the proposal as about 50 other research reactors of the same power level as that proposed are operating worldwide and systems for the management of radioactive wastes exist at all these facilities." However according to an article in the IAEA Bulletin, many operators of research reactors find themselves in a "crisis situation" because of waste management problems. (Takats, F., Grigoriev, A., and Ritchie, I.G., 1993, "Management of spent fuel from power and research reactors: International status and trends", IAEA Bulletin, No.3, pp.18-22.)

The Draft EIS (p.5-27) says "With completion of the (Waste Management) Action Plan, well ahead of the commissioning of the proposed reactor, ANSTO would have state-of-the-art facilities to ensure that ANSTO's wastes are managed in accordance with best international practice." The 1993 RRR stressed that the waste management problems should be resolved before a decision on a new reactor. It is doubtful that ANSTO will be able to dump the current stockpile of waste before the commissioning the new reactor, let alone have firm and credible plans for the management of the waste arising from the new reactor. The plans merely involve dumping the waste overseas and in South Australia - i.e. shifting the problem not resolving it.

"The waste from the Lucas Heights Science and Technology Centre forms only part of the total waste arising in the country." (p.6-38) ANSTO should be directed to estimate how much of Australia's radwaste - in volume and radioactivity - does in fact arise from ANSTO's operations at Lucas Heights.

"ANSTO's intention is that all the intermediate level liquid wastes that are produced while the replacement reactor is operating would be solidified in Synroc and stored in-situ until the national long lived intermediate level waste storage facility is operational." (p.10-45) Precisely what steps are involved in immobilising the wastes in Synroc? Why is this not addressed in detail in the Draft EIS and can this be remedied in the Final EIS? Will this take place at ANSTO's Lucas Heights facility?

The EIS (p.xv) says "There would be no long term storage of any radioactive waste at the Lucas Heights Science and Technology Centre." What is the definition of "long term": 5, 10, 20 years?

Does ANSTO believe there are technical or safety reasons not to use Lucas Heights as a permanent or semi-permanent waste dump?

The Sutherland Shire Council has asked the Senate to recommend:
(a) That a final decision to commission a new reactor not be taken until there is an established repository for storage or disposal of spent fuel rods or their residues away from urban sites or population centres, including Lucas Heights."
(b) no processing/reprocessing of spent fuel at Lucas Heights or any other urban area or adjacent to any population centre.

The Sutherland Shire Council (Senate Inquiry submission) says: "It (the federal Environmental Protection Act 1974) has led to poorly regulated federal developments which impact heavily on local communities. These inadequacies will persist even with current proposed changes to the Act. One of the best examples of such shortcomings in the Act .... is the decision of Federal Cabinet to consider locating a replacement nuclear reactor at only one site (Lucas Heights) in the absence of an established management approach for future waste streams from the reactor."

CH2M Hill raises concerns about transportation of radioactive materials which should be addressed in the Final EIS:

"As a general comment, cross-border shipments of radioactive materials is of major concern in North America, as well as in most Western European countries. In the United States, the US Department of Energy made more than 14,000 hazardous materials shipments in 1996. Of this number, 242 (approximately 1.7%) resulted in equipment, personnel and/or environmental radioactive materials contamination. During the period from 1971 through 1996, there were 2,379 shipping accidents involving Type A packages, with 219 of these resulting in release of package contents. Within the same period, there were 91 accidents involving Type B, one of which released its contents. This incident rate is sufficiently high to warrant examination of such accidents. Radiation exposures should be hypothesised based on a maximum credible shipping accident, and the increased incidence of fatality extrapolated and included in the Final EIS." (CH2M Hill, 1998, Replacement Reactor Draft EIS Technical Review: Final Report, p.11.)

The Department of Primary Industries and Energy is up to its old tricks in its submission on the Draft EIS, asserting that DOPIE has a "national strategy" for radwaste management. Indeed it has. It was announced by a Senior Government Source on ABC Radio National (March 29, 1998): "I understand that Cabinet considered reprocessing, but decided it was an issue for another generation. ... Someone else can worry about it. And reprocessing is a possibility then ... but that's 20 years away. So the government thought, we're not going to make decisions about reprocessing 20 years before we have to. ... The big ticket item was the new reactor and it was felt that politically you just couldn't win the reprocessing argument and the new reactor."

"Instead of construction of an appropriate repository for highly radioactive waste deriving from spent fuel or residues arising from treatment from overseas, ANSTO and the Federal Government have chosen to manipulate definitions of nuclear waste. Notwithstanding whether high level or intermediate level nuclear waste is derived from the fuel in question, both require disposal in a geological repository, according to international best practice. Such a repository is not even under investigation. Council is also very concerned that the proposal to co-locate the spent fuel or its residues with the proposed low level shallow burial repository (in South Australia) may cause a repeat of the failed attempt of the Federal Government to establish a low level repository in the 1980s." --- Sutherland Shire Council. 1998, Submission to Senate Inquiry

"A crucial issue is final disposal of high-level wastes, which depends upon identification of a site and investigation of its characteristics. A solution to this problem is essential and necessary well prior to any future decision about a new reactor. ...... It would be utterly wrong to decide on a new reactor before progress is made on identification of a high level waste repository site."

"The spent fuel rods at Lucas Heights can only sensibly be treated as high level waste. World opinion is moving in the direction of favouring the conditioning and direct disposal of spent fuel rods in preference to reprocessing. In any case, maintenance of the view that reprocessing is the best option inevitably involves return to Australia of by-product high level liquid wastes, making a national high level waste repository an inescapable concomitant of having any kind of nuclear reactor." --- 1993 Research Reactor Review

Murray Scott (1998, EIS submission) says, "Contrary to my previous impression, the corrosion of old spent fuel HIFAR rods is a real concern. A few rods are already deemed unacceptable for reprocessing in the U.S., although the reasons for this are obscure and may change." The Final EIS should provide details on the above.

The Draft EIS (p.10-15) says about half of the current spent fuel stockpile is of USA origin, the other half from the UK. The UK origin spent fuel rods will be sent to "another overseas reprocessor" given the closure of Dounreay. Currently there are 1425 spent fuel rods on site.

The Draft EIS says
o "It is possible that the replacement reactor fuel would be clad in aluminium as for the HIFAR fuel and would require a form of processing and/or conditioning to place it in a more leach resistant form for long term storage in a repository. The established process for achieving this is reprocessing. The spent fuel is dissolved in acid, the uranium separated out for recycling and the remaining waste products, containing all the fission products, some activation products and some associated non-radioactive components, are conditioned into a highly leach resistant waste form such as borosilicate glass or Synroc." (p.5-28--5-29)
o "Fuel would be reprocessed overseas, the waste would be conditioned into a long-lived intermediate level waste form and would eventually be returned to Australia for storage at a remote location." (p.x)
o "The Commonwealth Government has stated that no waste arising from reprocessed/conditioned spent fuel would be returned to Lucas Heights." (p.xvi)

It is envisaged that there will be a shipment of spent fuel every five year. (p.10-20)

"Compared to HIFAR, the fission products would be proportional to the utilisation of uranium-235. As the fuel utilisation could be twice that of HIFAR, the quantity of fission products in the spent fuel could be double that of HIFAR." (p.10-19)

The Draft EIS (p.10-18) says "Currently no facility is routinely reprocessing low enriched uranium research reactor fuels. These fuels require modifications to be made to the traditional reprocessing chemistry and, as the recovered low enriched uranium has less value than the high enriched uranium recovered previously, there has until recently been little demand for the reprocessing facilities to invest in the modifications that are required to undertake the reprocessing of low enriched uranium fuels." However, both the United States and the United Kingdom have announced that they have successfully reprocessed low enriched uranium on a pilot scale. The United States has described the technology to reprocess these fuels, and Cogema in France for example has indicated that it is prepared to undertake reprocessing of low-enriched uranium fuels on a commercial basis. It (Cogema) has already signed contracts to reprocess fuel, on a lifetime basis, from the research reactor BR2 at Mol, Belgium, and the RHF, Institut Laue-Langevin, Grenoble, France. It can therefore be concluded the service will be commercially available for the proposed replacement reactor fuel."

The Draft EIS (p.10-19) discusses the volumes of wastes arising from reprocessing and say "this would be essentially the same for all possible replacement reactor and fuel types". About 9-12 cubic metres of long-lived intermediate level wastes will be generated from reprocessing if a process similar to the Dounreay cement type waste is used. Other waste conditioning technologies such as borosilicate glass or Synroc can reduce the volumes of waste by a factor of over 200 while still meeting the heat loading criteria for intermediate-level waste. This would result in less than 0.1 cubic metres per year. ... It is ANSTO's intention to take full advantage of such volume reduction technologies for the disposition of the waste from replacement reactor spent fuel." (p.10-19)

The Draft EIS (e.g. p.10-17, 10-20) discusses obligations which will be placed on the successful reactor vendor: "ANSTO is including in the tender specifications a requirement that bidders must demonstrate that a solution, compatible with Australia's waste management strategy, exists for the ultimate disposition of their spent fuel arisings. It would be ANSTO's intention to enter into long-term contracts for spent fuel shipments and reprocessing/conditioning ..." Surely the vendor is not expected to become embroiled in matters such as:
o the politics surrounding the effort to dump radioactive waste in the Billa Kalina region in South Australia despite the massive opposition of native title claimants such as the Arrabunna
o covert transport of spent fuel through Sydney
o finding and choosing between reprocessors

Precisely what is expected of the reactor vendor should be spelt out.

The Draft EIS (p.10-17) says "The greatest part of all the highly-enriched uranium research reactor spent fuel that has ever been produced has been reprocessed." The evidence for this assertion should be provided.

The Draft EIS (p.10-22, Table 10.3) acknowledges that the disposal option for long-lived intermediate level waste is a "geological disposal facility." However on occasions ANSTO says geological disposal is not necessary for wastes such as those arising from reprocessing. This needs clarification. Is the intention to continue to put this waste in a shed in South Australia ad infinitum, or is there a longer-term intention to build a geological repository?

ALTERNATIVES

The Draft EIS (p.5-29) says "The alternative to reprocessing is to condition the fuel using a chemical or physical process so that it retains the fission products for long periods of time after it is placed in the repository. However, no "direct disposal" technology for research reactor fuel has yet been developed or proven and the international criteria for both safety and nuclear materials safeguards to apply to direct disposal of research reactor spent fuel do not exist. Thus, although direct disposal is an option, it is currently less proven than reprocessing and is only being developed for co-disposal with high level waste from power reactor spent fuel. It is not a viable option for countries without a commercial nuclear power industry."

Another option (Draft EIS, p.6-38) is to condition the fuel and dispose of it without reprocessing in a deep repository. A number of such conditioning processes are being developed by the US DOE "but they have not been proven and would not be feasible in Australia ..."

The alternative to reprocessing is chemical or physical processing. Most technologies also involve isotopic dilution to reduce the residual uranium enrichment level because even LEU research reactor fuels can undergo selective leaching and reconcentration thus leading to criticality concerns. (Draft EIS, p.10-18)

The Draft EIS (p.10-18) says the US DOE requested a review on spent fuel treatment options by the US National Research Council. These options include direct co-disposal, and melt and dilute. The NRC is reported to have said that the conventional reprocessing option should have been given more careful consideration by the DOE because the costs and risks are well known, the necessary facilities are currently in operation at Savannah River, and the waste form (borosilicate glass) will likely be acceptable for disposal at the repository.

The options for spent fuel are listed as follows (p.6-36ff):
o long-term storage at Lucas Heights - not government policy - "fuel cladding ... provide containment for tens of years but not for the long timescales that are required for long-term storage or permanent disposal. As a result, it is necessary to condition the fuel."
o reprocessing overseas with waste remaining overseas - not feasible - "All commercial reprocessors require that wastes be returned to the country of origin."
o reprocessing and waste disposal in Australia - not government policy
o reprocessing, prompt disposal in repository - not government policy - small quantity of Category S waste cannot justify cost of a geological disposal facility
o reprocessing overseas with waste returned to Australia

The Draft EIS (p.5-29) says "a service would be commercially available for the proposed replacement reactor fuel." However only one possible reprocessor is identified, Cogema in France. ANSTO must be required to list any other potential reprocessors. Given that ANSTO expected to be able to send its spent fuel to Dounreay for years (or decades), and this option fell through at the last minute, total reliance on Cogema will not suffice, especially since it appears there is no contract with Cogema for existing or future spent fuel.

No "direct disposal" technology for research reactor fuels has been developed or proven. (Draft EIS, p.10-18)

"In the unlikely event that the overseas options should become unavailable, it would be possible at short notice to take advantage of off-the-shelf dry-storage casks for extended interim storage at the national storage facility, pending renewed arrangements being negotiated for reprocessing/conditioning of the fuel. Such dry storage cask systems are being adopted in Germany for interim storage of research reactor spent fuel, and are available commercially from a number of companies ..." (Draft EIS)

QUESTIONS

The following questions should be answered be ANSTO:
o does ANSTO support the development of a pilot reprocessing plant at Lucas Heights to trial Synroc to treat spent fuel
o does ANSTO support the development of a pilot reprocessing plant anywhere in Australia to trial Synroc to treat spent fuel
o what process is used at Cogema and what waste volumes will arise from that process?
o what processes are used at any other reprocessing plant which might accept spent fuel from the planned new reactor and what waste volumes will arise from those process?
o the Draft EIS (p.10-19) says it has been in contact with "existing reprocessors" - they should be named.
o will ANSTO, in keeping with the spirit of the RERTR program, refuse to deal with reprocessors who are prepared to return HEU to their customers?
o is it true, as claimed in the CORE submission, that the new German government has a policy of banning reprocessing? What will be done with spent fuel from Germany's research reactors?

REPROCESSING AT LUCAS HEIGHTS?

A "senior government source" said on ABC Radio National (March 29, 1998): "I understand that Cabinet considered reprocessing, but decided it was an issue for another generation. They knew that they could dispose of the current spent fuel rods in the US and the UK and then not have a storage problem until the year 2015. You see the new reactor comes on stream 2005, the spent fuel rods have to cool down for seven years and then be stored for another five, so 2015 they've got to worry about their spent fuel rods. Someone else can worry about it. And reprocessing is a possibility then ... but that's 20 years away. So the government thought, we're not going to make decisions about reprocessing 20 years before we have to."

The senior government source also said: "The big ticket item was the new reactor and it was felt that politically you just couldn't win the reprocessing argument and the new reactor."

Prof. Helen Garnett, ANSTO's Executive Director, justifying Lucas Heights as a site for a reprocessing plant (12 November 1997, Estimates Committee Hansard, pp.387-397): "When you are dealing in things radioactive, you have things like active drains and a large number of infrastructure systems available - ventilation, for example - and, by linking what was there, we suggested that it could be put there. It was consistent with the activities we have. It is consistent with dealing with radioactivity, and therefore we said that it was a reasonable place to put a small pilot processing plant."

Former AAEC/ANSTO/CSIRO employee Mr. Murray Scott objects to the debate over reprocessing/conditioning of spent fuel at Lucas Heights on the grounds that it already occurs, i.e. processing uranium targets to extract radioisotopes.

ANSTO/PPK (p.10-4) acknowledge that increased production of radiopharmaceuticals would increase the amount of radioactivity in the waste. "However, the extent to which this results in an increase in emissions or the volume of waste depends on the extent to which new technologies are employed."

The Draft EIS (p.10-8) suggests that LEU targets will be used for Mo-99 production. However this commitment needs to be made explicitly and unequivocally.

ANSTO should be directed to comment on the following comments drawn from Rojas-Burke, J., 1993, "Ban on Enriched Uranium Exports Intended Against Bomb Builders also Affects Radiopharmaceutical Makers", The Journal of Nuclear Medicine, Vol.34(3), pp.19-40:
o LEU targets require a greater volume of uranium to make up for decreased enrichment levels.
o Processing more uranium means handling more radioactive by-products - three to six times the volume of dissolver solution, about six times more dissolver salts, six times more fission-product salts, and up to 30% more waste at the end of all processing steps.

Clarification is required as to projected growth in Mo-99 production. In the Draft EIS we are given the following information:
o growth in Mo-99 generator production by 23% over 5 years (p.10-42)
o growth ranging from 1.64 to 3.3 (Table 10.5)
o anticipated growth in Mo-99 production is given as 4 times the current rate (p.10-45)

Section 3.8.2 fails to give a breakdown of how much of the waste dumped in South Australia will be of ANSTO origin. ANSTO or the relevant government departments/agencies should be required to submit such an estimate both in terms of volume and radioactivity.

The Draft EIS (section 3.8.2) says that co-location of a store for long-lived intermediate-level waste will be "considered" once a site for a low level waste dump has been selected. Yet elsewhere the co-location plan is presented as a sure thing: the Draft EIS (p.5-28) says that reprocessing wastes "would eventually be returned to Australia for storage at the storage facility which will be co-located with the national radioactive waste repository."

There is an assumption running through the Draft EIS that the national dump in South Australia is a fait accompli. This is misleading. A specific site has yet to be identified within the vast Billa Kalina region in South Australia (although we are told a site will be identified in early 1999). There is opposition to the project from the ALP (SA branch), the Democrats and other minor parties, and there is a campaign against the mine involving people in Adelaide and others living in and around the Billa Kalina region. Last but not least, there is opposition from Aboriginal groups with native title claims on the land pending. A campaign group has been established called Coober Pedy Against Waste Repository. The groups voicing objections to the dump include: Kupa Piti Kungka Tjuta Aboriginal Corporation, Arid Lands Environment Centre, Friends of the Earth, Conservation Council of South Australia, and Antikirinya Land Management Corporation.

There is also the assumption that co-location of long-lived intermediate-level waste at the Billa Kalina dump is a fait accompli. Again, this is misleading. The Billa Kalina dump is being sold as a low-level waste dump. There is no guarantee that even a low-level dump will be accepted by (or forced on) South Australians, let alone a store for co-location of long-lived intermediate-level waste.

The Final EIS should not assume that the SA waste dump is certain to proceed, nor that co-location will occur if the dump is established in the first place.

It is claimed that Billa Kalina, the region in South Australia where it plans to build a radioactive waste dump, is a pastoral lease, not Aboriginal land. Kevin Buzzacott, from the Arabunna, responds: "Our land was taken by massacre and displacement. No treaties were even signed. We have never ceded out sovereignty. Our sovereignty cannot be extinguished. Under international law we still own the land and will always oppose the radioactive waste dump."

The government hopes to begin construction of the dump in the year 2000. This is highly ambitious and flies in the face of the protracted history of the project, which dates from 1980. A "community consultative phase" is underway, which is likely to throw up political obstacles.

There is the promise of an assessment under the federal Environmental Protection (Impact of Proposals) Act 1974; most likely this will involve a sham Environmental Impact Assessment.

No figures are available on the financial cost of the project. The federal government says that the cost will be recovered through a user-pays system, which will encourage radwaste producers to adopt waste minimisation strategies. But the government also says that charges will not be so high as to encourage illicit disposal or abandonment of radwaste. What costs has ANSTO budgeted for?

Through the 1980s, all state governments supported the idea of a national radwaste dump - but not in their state. In the early 1990s, the federal ALP government was openly threatening to seize land for a dump if the stalemate prevailed.

To head off the thin-edge-of-the-wedge argument, the federal government's Bureau of Resource Scientists says that "a limit on total radionuclide activity for the proposed disposal facility will be established." What does ANSTO plan to do with its radioactive waste once the limit for the SA dump has been reached?

One of the site-selection criteria for the Australian dump is that it should not be located in an area where land ownership rights or control could jeopardise long-term control. However this criterion has not yet been considered. The government offers the curious reason that "negotiations with land-owners will be necessary whatever the site".

There are a number of Aboriginal groups living in the Billa Kalina region - the Kuyani, Barngarla, Kokatha, Arabunna and the Nukunu. Most of these groups are represented on the Port Augusta Native Title Working Party, which has already met with the federal Department of Primary Industries and Energy several times to discuss the proposed dump. Andrew Starkey, a member of the Working Party and spokesperson for the Kokatha People's Committee, says that a number of native title claims are pending on land in the Billa Kalina region. Starkey is well aware that the current proposal may be the thin edge of the wedge.

How can the existence of a number of native title claims be squared with the site-selection criterion concerning long-term control? "A very good question," I was told by the Department of Primary Industries and Energy. Could native title claims could be jeopardised by the dump.

The government's propaganda fails to mention the main reason for establishing a national dump. The planned dump amounts to little more than a clearing exercise for ANSTO to quell opposition to the new reactor. ANSTO has played a significant role in the whole exercise, both as Australia's biggest producer of radwaste (excluding uranium mines) and as a technical adviser to the government on radwaste strategies. Needless to say, there is a glaring conflict of interest in ANSTO's dual roles as radwaste producer and policy adviser.

Such is ANSTO's clout that when it was directed by the NSW Land and Environment Court not to store radwaste of non-ANSTO origin, and to remove 2000 cubic metres of CSIRO-origin radwaste, the federal ALP government enacted the ANSTO Amendment Act 1992. This Act made ANSTO immune from NSW laws on land use, environment protection, and sundry other matters. The Liberal Party supported this legislation - so much for "states' rights".

The 1993 Research Reactor Review noted that it would be no gift to future generations to leave Australia's radioactive problems untackled. The dump will not solve the problems. It merely shifts the problems of radwaste generators, most of all ANSTO, to South Australia. The first step forwards is to minimise the production of radwaste. For this reason, among others, it is an outrage that the federal government is pushing through the construction of another nuclear reactor (which will be the largest producer of Category S waste).

Questions: Have the various Aboriginal groups with native title claims over the Billa Kalina region been informed that one of the fall-back options for spent fuel is to dump it directly on their land without reprocessing? If they have not been informed, will ANSTO/PPK do so immediately? Has the South Australian government been informed of this fall-back plan and if so, what was the response of the SA government?

The CH2M Hill study commissioned by the Commonwealth Department of the Environment makes the following points in relation to the proposed Billa Kalina dump, all of which need direct comment in the Final EIS:

"The assumption is made ... that the repository will be actively accepting waste prior to the commissioning of the replacement reactor. Waste acceptance criteria for this repository will not be established until some time into the future. In addition to availability, waste acceptance criteria may have significant impacts on (ANSTO's) operations, including the replacement reactor. Obvious areas of potential concern include contaminated liquids, radioactive wastes combined with non-radioactive hazardous wastes, radiation exposure limits on disposal packages, and potential limitations on specific nuclides (typically fissile and transuranic), or perhaps even on total activity. In addition to limitations which might preclude a waste type or form, such criteria often places stringent requirements on the characterisation of waste materials. Assuming such criteria are as yet unavailable, the final EIS could address that which is anticipated in the context of the proposed reactor." (CH2M Hill, 1998, Replacement Reactor Draft EIS Technical Review: Final Report.)

One final point: it would be useful if, after consultation with the government, ANSTO unequivocally states in the Final EIS that the SA dump, if ever established, will "never, ever" accept waste from overseas.

ANSTO/PPK should be directed to note that neither ANSTO nor the government has heeded the RRR recommendations:
o "If a decision were made to construct a new reactor, it would not necessarily best be placed at Lucas Heights. An appropriate site would best be decided after exhaustive search and taking into account community views."
o "Nonetheless, if a positive decision on a new reactor is to be made, full consideration should be given, not only to the cost disadvantages of a new site, but also to the views of the Sutherland Shire Community."

The Draft EIS notes that greenfield sites which fulfil accessibility, health and safety, environment protection, and availability of resources criteria, are available with proximity to Canberra, Sydney, Melbourne, Brisbane, Adelaide, Perth and some regional centres.

The Draft EIS says that a site selection process "was conducted prior to the preparation of this Draft EIS and has not been reviewed as part of the scope of this Draft EIS." ANSTO/PPK should be directed to justify this extraordinary omission.

The Sutherland Shire Council (Submission to the Senate Nuclear Reactor Inquiry) has requested that the federal government's site location study be made public and subjected to appropriate public comment during the EIS. The Council says that since the RRR, the Nuclear Safety Bureau has reassessed issues relevant to the siting of HIFAR and that this assessment is presumably relevant to the siting of a new reactor. Council sent this NSB assessment to Steven Sholly (whose report appears as Attachment F to the Council's submission to the Senate Inquiry). Sholly found several inadequacies in the NSB assessment:
o a non-mechanistic approach to accident progression and scale flowing from assumptions and single-point modelling which did not account for uncertainties
o the lack of verification of dose consequence modelling
o arbitrary limitation of doses and distance estimates.

The Draft EIS (p.3.27-3.29) says there are
o 27 zero power critical assemblies
o 1 prototype reactor
o 42 training reactors
o 195 neutron source / high flux reactors (178 research, 17 test)

giving a total of 265 reactors in 59 countries with a further 12 under construction.

54 of the 265 are identified by the Draft EIS (p.3-29) as being multipurpose. I think ANSTO said the number was 85/265 earlier this year. Which is it?

37 countries have multipurpose reactor.

Nine countries have constructed multi-purpose research reactors in the past ten years. Does this mean all nine reactors are operating, or does it include reactors still under construction? What is the trajectory of multi-purpose research reactors? How many were in operation 5-10-15-20-25 years ago?

As at 1992, 85% of multipurpose reactors were over 20 years of age and nearly two thirds were over thirty years of age (ANSTO, RRR submission). DIST/ANSTO (Senate Inquiry submission) say "Multipurpose research reactor infrastructure is not declining." ANSTO should be asked to justify this assertion, providing data on numbers of multipurpose reactors ever built, number still in operation, age spread. Almost certainly there have been more closures than start-ups in the past decade, and there will be many more closures in the next 10-20 years.

Two thirds of all research reactors in the world are over 25 years old and "are likely to be closed early in the next century."

Research reactors in planning include:
o Canada - 2 Maples
o France - plans for a 100 MW reactor mainly for materials testing, also isotope production.
o Germany - FRM-II
o Thailand - ordered 10 MW Triga.
o China reported to be planning an upgrade of the 15 MW HWRR-II reactor to 60 MW.
o Taiwan envisages refurbishing its 40 MW TRR reactor
o JAPAN - JAERI design study for new fuel irradiation test reactor.
o Egypt - 22 MW research reactor under construction
o Argentina - project for a 20 MW research reactor.

Numbers of research reactors in the world (IAEA data):
December 1994  297
March 1996  288
December 1996  273
May  1998  265

Permanent shut-downs from December 1994 to May 1998: 32 in 3.4 years - approximately 10 annually.

Multipurpose reactors have shown greater longevity than most other reactor types: the reason is simply that they are more flexible and thus less prone to program-related closure. A consequence of this is that a significant number of multipurpose reactors are ageing and will be closed in the next 10-20 years. All of this is discussed in my first submission to the Inquiry, and still more information is available at http://www.uow.edu.au/arts/sts/pgrad/phdthesis>

Some multipurpose reactors are being replaced, others are not. According to the AAS submission, it appears that more than a few multipurpose research reactors are being replaced - but not by multipurpose research reactors:

"To meet this (neutron) demand there are major design studies in progress for an advanced spallation neutron source in Europe as well as a new research reactor of the highest performance in Munich and continuous spallation source in Switzerland. At Oak Ridge in the United States an approximately $US 0.5 billion project has been started and in Japan the "Neutron Arena" of the Japanese Hadron Project as well as a spallation source for the Japanese Atomic Energy Research Institute (JAERI) are under development. The Japanese have also refurbished their reactor at the Japanese Nuclear Centre and a few years ago a very powerful reactor, DHRUVA, was commissioned in India."