TABLE OF CONTENTS - 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 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 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

"Estimates of public dose are based on the quantities of radioisotopes released (which are measured at the point of release) and atmospheric and dosimetric modelling. The magnitude of the estimated dose depends on the model used and the choice of parameters input into that model. There is a significant uncertainty in doses calculated in this manner, and it is possible that doses may be higher than predicted."
-- Supervising Scientists Group, Environment Australia, 1998, Submission on ANSTO's EIS

The Draft EIS (p.xv) says "ANSTO would ensure that the maximum off-site dose to a member of the public would remain below one percent of the public dose limit adopted by the NH&MRC of one millisievert per year." On page xvii we are given the same "commitment".

Given ANSTO's history of dishonesty and broken promises, legislation in the federal parliament should enshrine a maximum limit of 0.01 mSv annually.

"ANSTO's policy is that for operations associated with the replacement reactor, the dose to any member of the public shall remain below one percent of the public dose limit adopted by the (NH&MRC)." The following questions should be directly answered by ANSTO in the Final EIS:
o does this include emissions arising from isotope processing?
o presumably workers' exposure will rise with increased isotope production. ANSTO should provide specific estimates on worker exposure for given production levels.

The Draft EIS (p.1-2) quotes former science minister Peter McGauran saying the new reactor "will meet the strictest international nuclear safety standards". However other countries do in fact have more stringent regulations than are to be adopted in Australia under the ARPANSA legislation - e.g. Germany, UK, USA. The Final EIS must do one of two things:
o announce that the proposal will indeed meet the strictest international safety standards, with a legislative basis to this commitment.
o acknowledge that the new reactor will not meet the strictest international safety standards.

The Draft EIS (p.x) acknowledges that the new reactor will be able to produce four times as much molybdenum-99 as is currently produced. It also says (p.xv) that "... any increase in the production of radioisotopes could result in a proportional increase in the production of radioactive gaseous emissions, reductions would be achieved by introducing new technologies to treat gaseous emissions. ANSTO would ensure that the maximum off-site dose to a member of the public would remain below one percent of the public dose limit adopted by the NH&MRC of one millisievert per year."

The new reactor could produce four times as much Mo-99 as HIFAR. "Nevertheless, releases from the production facilities would not increase pro-rata as additional means to clean the air extract system would be introduced following a review of the current method of Mo-99 production." Work on cryogenic trap technology has been initiated. ANSTO will be testing iodine absorption filters in 1998. (p.10-42)

These comments raise further questions:
o there appears to be an implicit acknowledgment that emissions will increase (even if they remain below 1% of the NH&MRC limit). What levels are expected?
o what is the experience with the experience, at ANSTO and internationally, with cryogenic trap technology and iodine absorption filters. Are the iodine filters made of charcoal - what risk does this pose in relation to fire - are the filters flammable?

The following comments from CH2M Hill, in relation to Mo-99 production/processing in Building 54, need to be thoroughly addressed in the Final EIS:

 " ... filtration systems for the removal of radioactive particles, vapors and gases are discussed (in the EIS). Therein, the phrase "specially impregnated charcoal" is used to describe media for the removal of iodine and the noble gases xenon and krypton. It is suggested that this phrase be expanded upon, as experience has shown that plain activated charcoal is a poor absorber of noble gases and becomes quickly saturated with iodine. A well informed concerned individual could make a reasonable case that such filtering would be ineffective, leading to increased public exposures from reactor gaseous effluents." (CH2M Hill, 1998, Replacement Reactor Draft EIS Technical Review: Final Report, p.14.)

The Final EIS should quote the following comments:

"Some caution needs to be applied when making comparisons with natural background to avoid the impression that one can conclude that the potential exposure is acceptable because it is less than natural background. All exposures will be in addition to natural background, are imposed not voluntary, and unlike natural background could be avoided if the proposal does not go ahead." (Parkman Safety Management, 1998, ANSTO Replacement Nuclear Research Reactor EIS: Peer Review of Hazards and Risks Analysis, p.13.)

According to CH2M Hill, US guidelines state the following: "... Do not assert that the average annual effective dose equivalent caused by a project translates to an insignificant increase in risk simply because it constitutes only a small increase above background. Present information in relation to standards and allow readers to make their own judgements." (CH2M Hill, 1998, Replacement Reactor Draft EIS Technical Review: Final Report, p.7.)

According to CH2M Hill, care must be taken when comparing emission limits with USA standards because US limits may involve conditional or additional limits lower than the basic limit - the range appears to be 0.25-1 mSv per year for members of the general public. CH2M Hill says, "As a consequence, an unqualified use of the US basic limit is considered to be inappropriate by the reviewers." (CH2M Hill, 1998, Replacement Reactor Draft EIS Technical Review: Final Report.)

The CH2M report also raised the following issue which must be thoroughly addressed in the Final EIS:

"The (CH2M Hill) reviewers felt that in several areas certain subjects lack complete discussion and evaluation. As an example, several radioactive materials/waste storage units are constructed below ground. Despite the fact that two different aquifers have been located within 20 metres of the surface, there is no discussion in Chapter 10, 11 or Appendix F or G (of the Draft EIS) on the potential for contamination of groundwater. Moreover, evaluation of potential uptake and exposure pathways does not include groundwater." (CH2M Hill, 1998, Replacement Reactor Draft EIS Technical Review: Final Report, p.7.)

The Supervising Scientists Group (1998 EIS submission) says activation products formed in air spaces in the HIFAR reactor are the major contributor to public radiation exposure. Is this correct? How do these exposures compare with those from isotope processing?

Given that isotope production and processing is expected to be increased, perhaps by a very large amount, there must surely be a risk that staff working in these areas will receive even higher doses than at present. What "commitments" have ANSTO made in relation to staff radiation exposure? Which independent body - if any - will ensure that radiation exposures are not increased? Will there be a legislative basis to ANSTO's otherwise vacuous commitments?

Why does the SSG note the ICRP/NH&MRC recommendation of 100 mSv / five years without providing comparisons with actual limits applied in countries such as the USA, Germany, UK etc. Such comparisons should be supplied in the Final EIS.

The Draft EIS says (p.xxiii) "The site of the proposed replacement reactor is situated in a zone of low fire hazard, due to its sparse vegetation cover and flat topography." It also says: "The incidence of bush fire close to the site of the replacement reactor would pose no threat to its safe operation. Radiant heat from a major fire may, however, damage cooling towers and cause of precautionary shutdown of the reactor, as part of standard safety procedures."

However in a report delivered to the Sutherland Shire Council on 23 February, ANSTO has acknowledged a host of problems: risks in and around buildings where flammable materials have been allowed to accumulate; failure to monitor information that was available from the Sutherland Fire Control Centre, despite having an ANSTO liaison person there; failure to monitor information on the local radio station; the hazard reduction/clearance program was inadequate around buildings B72 and B75; "most" ANSTO staff followed instructions but "difficulties were experienced with some tenants on site"; a fire was discovered inside building 77, caused by spontaneous combustion of rubbish due to the rise in air temperature; public address announcements were misinterpreted by the announcer because they were not written down; staff did not have adequate information on road closures; lack of co-ordination of volunteer fire-fighters; and poor visibility of some fire hydrants. ANSTO's Safety Division admitted that it needs external advice to deal with some of the problems identified during the crisis.

The most alarming part of the ANSTO report is the euphemism that "Only a few small spot fires at effluent tank in Waste Management Area were reported." ANSTO's waste stockpile includes liquid molybdenum waste arising from radioisotope production. As far back as 1989, this "moly" waste was identified as having the potential for off-site consequences in the event of an accident such as a seismic event or a major fire. It is unclear how close the fires came to the moly waste - ANSTO refused to answer questions when contacted. The federal government's Safety Review Committee (SRC) has repeatedly criticised ANSTO for delays in the project to solidify the liquid moly waste. Even when it is solidified, there is nowhere to dispose of this Category S waste until a national waste repository is established.

I understand that ANSTO has acknowledged that the fires came within 200 metres of the so-called moly waste. This should be confirmed or denied by ANSTO in the Final EIS. If it is denied then how close did the fires come to the moly waste?

More recently we have had some revisionist history from ANSTO: the new story is that the bushfire crisis was well handled by ANSTO!

The Draft EIS says "The main hazards in dismantling activated and contaminated structures are direct radiation exposure and generation of airborne contamination from decommissioning activities." Monitoring of tritium and other radioactive contaminants in the air would be required throughout the decommissioning process."

We are promised a Decommissioning Plan (p.xxvi). Why is this not included as part of the Draft EIS? For HIFAR it appears the "Plan" is to leave the reactor as is for 30 years, and worry about it then. Options would include entombing HIFAR in concrete, complete dismantling, or further procrastination. (p.xxvi)

If the proposal for HIFAR is vague enough, there is still less information on the eventual decommissioning of the proposed new reactor: "The replacement of the reactor would have requirements for the design to include features which would assist decommissioning at the end of its life." More details are required.

It is acknowledged that Lucas Heights is a potential target for nuclear terrorism, as during the 1991 Gulf War when security was increased. The Georgia Institute of Technology closed its research reactor in late 1995, because of concerns that the weapons-useable highly-enriched uranium fuel could be a target for terrorists during the 1996 Olympics. Will the Lucas Heights HIFAR reactor be closed during the Sydney 2000 Olympics?

I understand that HIFAR is scheduled for an extended shut-down during 1999. No doubt there will be a great deal of bleeding-heart rhetoric about the non-availability of medical isotopes during this period. Therefore I hereby offer my services to ensure the adequate supply of medical radioisotopes during this period. I have a detailed knowledge of the international radiopharmaceutical industry and extensive contacts in the industry. I ask ANSTO to accept or reject this offer prior to the Final EIS or in the Final EIS per se.

The ARPANSA bill ought to resolve a number of long-standing problems in the nuclear industry: excessive self-regulation; fragmentation of regulatory bodies; inconsistencies between the states/territories; excessive staff cross-over between promotional and regulatory bodies; the lack of real powers for regulatory bodies; and the lack of transparency and genuine public accountability.

However ARPANSA will not significantly improve the current situation. Perhaps the only thing to applaud without qualification is that the legislation will bring a number of previously unregulated institutions, such as the CSIRO, within the regulatory sphere.

Trish Worth, Parliamentary Secretary to Minister for Health, said in parliament that "The whole framework for this legislation relies on a lot of detail in regulation ..." Yet the regulations - said to run to 100 pages - have not been publicly released. In fact changes are still being made to the regulations and a government spokesperson tells me there is no guarantee that they will be available before the government attempts to push the bill through the Senate.

The regulatory body should be a statutory authority, completely independent of government. Instead we have a half-baked arrangement. The Chief Executive Officer of ARPANSA will be a statutory office-holder, but ARPANSA staff will be public servants employed by the Commonwealth Department of Health and Family Services. Hiring and firing of ARPANSA staff will ultimately be the responsibility of the Minister for Health.

According to legal advice presented to the Sutherland Shire Council, government control of ARPANSA staffing "is a sure giveaway of the Government's intention to create a regulator subservient to the bureaucracy." Even within the tame framework of Australia's environmental regulation, there are examples of regulatory agencies which control their own staff appointments.

The proposed legislation will do little or nothing to fix the problem of revolving-door staffing, with staff transferring between the regulatory body, the federal bureaucracy, and nuclear companies and agencies (in particular ANSTO).

The ARPANSA bill permits wide-ranging exemptions for anything to do with national security or defence purposes. These exemptions are of particular concern to the people fighting the plan to build a new nuclear reactor at Lucas Heights, because one of the justifications for the new reactor concerns a set of convoluted national interest/security arguments.

According to the legal advice provided to the Sutherland Council, "... ANSTO can simply refuse to obey any directive of (ARPANSA) and any condition of a facility licence because it holds to the belief that to obey may be prejudicial to national security and defence."

The Bill does nothing to redress the situation of ANSTO being immune from state environmental, health and safety laws.

The overall objective of the Bill is said to be the protection of people and the environment from the harmful effects of radiation. This is a red herring since there is no safe dose for radiation exposure; even the nuclear industry acknowledges this.

There is growing evidence linking radiation to genetic defects, and research suggesting the somatic effects have been grossly underestimated (e.g. the 1997 US Santa Susana study). None of this research is reflected in the ARPANSA legislation. Nor is there anything in the proposed legislation to suggest that there will be ongoing monitoring of the health impacts of radiation in and around nuclear facilities.

The bill will give a legislative basis to Australia's inadequate radiation exposure limits.

A number of countries - including Germany, the UK and the USA - have erred on the side of caution by setting lower limits than those recommended by the ICRP. In contrast, Australia will not only adopt the maximum limits recommended by the ICRP, but also allow increased doses in "exceptional" circumstances.

The ARPANSA bill will abolish the Safety Review Committee.

The Supervising Scientists Group (1998, EIS submission) seems remarkably relaxed about the reactor proposal. For example, it is ridiculous for the SSG to put its faith in ARPANSA when ARPANSA has not yet been created, when the ~100 pages of ARPANSA regulations have yet to be released, and when the ARPANSA legislation will do nothing to resolve protracted problems such as revolving-door staffing between ANSTO and regulatory bodies.

The Draft EIS (p.4-8) claims that (my emphasis) "ANSTO actively supports the development of a regional safety culture through its own research programs within ANSTO's Safety Division; and running a regional project under the Regional Nuclear Cooperation in Asia. These interests were addressed comprehensively by the Department of Foreign Affairs and Trade and the Australian Safeguards Office in their submission to the Senate Economics References Committee Inquiry into a reactor at Lucas Heights." In fact, the paper from the Department of Foreign Affairs and Trade and the Australian Safeguards Office was just seven pages long and unreferenced. The section on nuclear safety is half a page long!

To the best of my knowledge, the Draft EIS does not mention fatal research reactor accidents. According to the Australian Academy of Science and the International Atomic Energy Agency, there have been five fatal research reactor accidents around the world. (Australian Academy of Science, written submission to the Senate Inquiry.)

Can ANSTO guarantee that the sixth will not be at Lucas Heights? Of course not. Just as alarming is the standard ANSTO response when questioned about these fatal accidents: that (expendable?) reactor operators were killed, not members of the "community".

One of ANSTO's games is to claim that the fatal accidents did not involve research reactors but rather prototype reactors, test reactors etc. Yet ANSTO has defined research reactors as encompassing these facilities in the past and does so again in the Draft EIS (p.3-2) by defining research reactors as encompassing zero power critical assemblies, prototype reactors, training reactors and multipurpose reactors.

The Sutherland Shire Council (Senate Inquiry submission makes the following points:
o safety considerations should take account not only of potential fatalities but also severe social and community disruption.
o the Council commissioned a report by MHB on this issue in 1995. MHB concluded that existing accident likelihood and source term studies prepared for HIFAR were technically inadequate and/or badly dated and no longer state of the art in risk assessment. MHB said that HIFAR, or any similar or larger reactor, "is potentially subject to severe accidents involving fuel melting which have the potential to release sizeable quantities of radioactive material into the environment." Insights have been gained from accidents similar to that which could happen at LHSTC: "These caused significant social disruption by way of restrictions on food consumption, decontamination costs, health monitoring and treatment, litigation costs, overall economic output, and evacuation costs. Even relatively small radiological accident releases have resulted overseas in large societal costs within the "evacuation shadow"."

The comments in Tony Wood's EIS submission on legal liability, the potential for sabotage/terrorism, and the possibility of pool failure, need to be thoroughly addressed in the Final EIS.

In addition, the remarkable history of poor management/staff relations needs to be considered. In 1993 at least one submission to the RRR from a former AAEC/ANSTO employee raised the possibility of sabotage underpinned by hostility towards ANSTO management (I can send this RRR submission on request). ANSTO staff members tell me that there is still a widespread, deep hostility towards ANSTO management from staff members.

Is it true that there has never been an IAEA safety inspection of Lucas Heights (as opposed to routine safeguards inspections) despite there being provision for IAEA safety assessments?

The Supervising Scientists Group appears to be unaware of the various concerns raised about the reference accident raised in other submissions to the EIS, e.g. the possibility that an isotope processing accidents could be more serious, e.g. Tony Wood's comments, e.g. the studies commissioned by the Sutherland Shire Council.

The argument was put to the RRR that accidents are more common in multipurpose research reactors than in power reactors because there are more frequent start-ups, shut-downs, fuel and rig movements, and more opportunities for human error. These arguments were drawn from industry literature and so could not easily be refuted. On the other hand there is no dispute that, in general, accidents involving power reactors pose a far greater risk to the general public because of the far greater volumes of fissile material used to fuel power reactors. (RRR, 1993, p.228.)

The Canadian National Research X-perimental (NRX) reactor was built in 1947. It was essentially a pilot factory for the production of plutonium, which was supplied to the US until 1963. NRX was involved in an accident in 1952. A power excursion destroyed the core of the reactor, causing some fuel melting. The core of the reactor was buried as waste. Hundreds of US and Canadian servicemen were ordered to participate in the clean-up. (Edwards, n.d.) According to ANSTO (1993B, pp.3.16-3.17), the accident led to a significant release of radioactivity, but there were no reported injuries. Given the acknowledgment that there was a significant release of radioactivity, ANSTO's claims that there were "no reported injuries" and that "no off-site consequences were identified" should by no means be taken as meaning that there were no injuries or off-site consequences. Has ANSTO had a change of mind about the NRX accident since 1993? Is it not true that NRX is multipurpose? Is this not an example of a multipurpose accident leading to a significant release of radioactivity?

The Canadian National Research Universal (NRU) reactor first went critical in late 1957. In 1958 there was a fire in the reactor which badly contaminated the inside of the reactor building with some release of radioactivity outside the building. (ANSTO, 1993B, pp.3.16-3.17.) Several fuel rods overheated and ruptured, one catching fire. The ventilation system was jammed in the open position, thus allowing the spread of radioactivity down-wind from the reactor site. The burning fuel rod was extinguished by a relay team of scientists and technicians running past the maintenance pit and dumping buckets of wet sand on it. Over 600 men were involved in the clean-up. Atomic Energy of Canada Ltd. (AECL) claims that very few men were exposed to radiation doses exceeding the then permissible levels. It also claims that no adverse health effects were caused by the exposures received. The methodology for this second conclusion appears to have been the ostrich technique: no follow-up studies were carried out, the men involved in the clean-up were told to observe strict secrecy about the operation, claims that adverse health effects were linked to the clean-up were vigorously denied, and AECL has refused to supply information that would assist in the location of men involved in the clean-up and thus facilitate follow-up studies. (Edwards, n.d.)

ANSTO, 1993, Submission to the Research Reactor Review, Attachment A, Working Paper 3, p.3-2.

ANSTO, 1993B, Submission to the Research Reactor Review, Attachment A: "Research Reactors: Local and International Experience", Working Paper 3: "International Experience with Research Reactors".

Edwards, Gordon, (Canadian Coalition for Nuclear Responsibility), n.d., Reactor Accidents at Chalk River: The Human Fallout, <http://www.ccnr.org/paulson_legacy.html>

SAFETY OF MOLYBDENUM PRODUCTION AND PROCESSING

Murray Scott's submission on the 1998 Lucas Heights EIS raises important issues and questions as summarised below:
o Scott: "The most publicly appealing rationale for a replacement reactor is the provision of medical radioisotopes, particularly Mo-99 for Tc-99m radiopharmaceuticals. But of all the programs associated with the replacement reactor this operation also carries the greatest risk, the greatest potential for massive contamination release and the most significant future weapons proliferation potential."
o Peter McGauran, Hansard, House of Representatives, May 15, 1997, p.3757: "The statement that reprocessing the spent fuel rods would involve significantly lower levels of radioactivity than those already associated with ANSTO's current radio-pharmaceutical production is based on calculations by ANSTO that radiopharmaceutical production on site involves processing 30 kg of irradiated uranium containing 1e17 Becquerels of radioactivity per year, while reprocessing 100 spent fuel rods a year would involve only some 14 kg of irradiated uranium and about fifty times less radioactivity."
o Scott: "The reality is that there was (is) already a substantial irradiated uranium processing operation at Lucas Heights with all the hazards that implies, including the storage of intermediate level liquid radioactive waste in ammonium nitrate solution which carries the risk of chemical explosion."
o ANSTO's Radioactive Waste Management Policy (ref given) states that: "The presence in the intermediate level waste of varying concentrations of ammonium nitrate in combination with nitric acid and other potential sensitising agents (such as metal nitrates) has led to concerns of an explosion hazard during the boiling/solidification processes. An external review of the proposed process by ICI Engineering confirmed the potential safety hazard and outlined various strategies required to overcome the problem."
o Scott: "It should be understood that a chemical explosion involving this material would release dangerous quantities of airborne fission products. On the "other side" of the cold-war panic of the 1950s such an explosion at Chelyabinsk devastated several towns, lakes, streams and a vast swathe of land near the Ural mountains."
o Scott: "I understand that the solidification process now being implemented includes deammoniation of the liquid waste, and it is intended that the Mo-99 production process will in future be modified to separate the ammonia-rich condensate. Nevertheless I believe that the irradiated uranium processing operation constitutes a major part of the hazard associated with operations at Lucas Heights, arguably greater than the reactor itself. It differs from reprocessing only in respect of the chemistry for separating particular elements from the dissolved uranium. Despite the relocation of charcoal filters from B54, a fire in these filters would remain a significant airborne contamination hazard."
o Scott: The neglect of isotope processing in the Draft EIS, in comparison with the Reference Accident for the reactor is a "gross distortion of the actual balance of hazards".
o Scott: "If these irradiated uranium processing facilities were ever to be adapted for weapons plutonium extraction as canvassed above, the significant differences (apart from haste, secrecy and an overriding of safety considerations) would include a generally higher burden of medium half-life fission products and higher specific activity of the solutions. This would introduce the truly horrific prospect of self-boiling solutions requiring active cooling, failure of which would lead to dry-out and almost certain chemical explosion with consequences already referred to."
o Scott: "I would feel much more relaxed about the prosect of a replacement reactor if it did not involve irradiated uranium solution processing."
o Scott: Molywaste solidification hotcell is in Building 41. The solidified waste could be incorporated into Synroc, but ANSTO says that if this occurs with the new reactor would be more likely to use the liquid waste directly to incorporate into Synroc.
o Scott: "The accumulation of "cooled" waste arising from isotope production exceeds that of spent fuel, so the scale of a Synroc plant designed for the existing molywaste liquid could also accommodate proposed spent fuel solutions with little additional cost or hazard."
o Scott: "The production of Mo-99 for radiopharmaceuticals represents one of the most hazardous aspects of operating HIFAR or its replacement. Apart from the risk of radioactive contamination by molywaste liquid spillage, minimised by catch tanks and monitoring, there are chemical hazards arising from the strong oxidising potential of ammonium nitrate in the solution. If allowed to dry and mix with reducing agents such as oils or organic solvents, this solution could potentially form explosive compounds, detonation of which would release significant radioactive contamination to the atmosphere. The de-ammoniation and salt solidification process is designed to minimise this hazard."

The Draft EIS (p.4-8) quotes DFAT/ANSTO saying that "If alternative technologies do not enable national interest requirements to be met at all or to the same degree, then they cannot be regarded as genuine or full alternatives." Is this an acknowledgment that the national interest considerations take precedence over science and medicine? If so this should be spelt out.

The Draft EIS (p.4-22) says "A decision not to build the replacement reactor would be interpreted by other countries as meaning that Australia places nuclear science and technology at a low priority. It would be difficult to maintain Australia's designated position as the country in the region most advanced in atomic energy. Australia's designated seat on the IAEA Board of Governors would be threatened, and as a consequence Australia would have a greatly reduced influence at the highest level in, say, the ongoing development of safeguards policy. ... The maintenance of a strong safeguards regime under the (NPT) has implications for uranium export policy and for Australia's strong support for the (CTBT) and its verification. An effective program of technical assistance in the peaceful uses of nuclear science and technology to developing countries also represents a commitment by Australia under Article IV of the (NPT)."

The Draft EIS (p.4-7) says the national interest includes national security and non-proliferation, nuclear safety, economic development and access to technology.

Another aspect (p.4-7) is ensuring effective arrangements for visits of nuclear-powered warships "consistent with our alliance obligations and public safety." Do any other aspects of the US military alliance impact on the debate over the replacement of HIFAR?

The Draft EIS (p.3-21) refers to the ASO in making the claim that active Australian involvement in the IAEA and the OECD NEA "is essential to encourage early adoption of the protocols by other nations." This refers to new IAEA protocols regarding extended access for inspectors, greater use of environmental sampling, etc. No-one involved in this debate is so naive as to believe that claim and ANSTO should therefore be directed to drop it.

The Draft EIS (p.3-22) says the DFAT and ASO do not believe that a new reactor will enhance Australia's nuclear capabilities and increase Australia's vulnerability or potential for involvement in non-peaceful uses of nuclear materials. This is rubbish. The Final EIS should address the following questions in detail:
o approximately how much plutonium could be produced by the new reactor if Pu production was maximised?
o the Final EIS must acknowledge that even if the new reactor itself is unsuitable for producing fissile plutonium, it could be used for weapons-related research, and that the expertise derived from the operation of a reactor could be diverted for a weapons program.

The Draft EIS (p.3-22) says "The development of a replacement research reactor would not increase the risk of nuclear weapons proliferation in Australia or elsewhere." This completely contradicts many comments made by ANSTO and the government to the effect that Australia must maintain a (civil) nuclear capability given the expansion of nuclear programs in the region. This expansion must inevitably increase the risk of proliferation given the dual-use nature of so many nuclear technologies.

The Draft EIS (p.4-22) says "A decision by Australia not to proceed with the replacement reactor would not influence the decisions of other countries in this region to embrace nuclear power and other aspects of nuclear technology. These are and would be driven by their desires to enhance the standard of living of their people in a greenhouse conscious world and by their concepts of the development of nationhood." The first sentence is rubbish and should be deleted - it is openly acknowledged by ANSTO et al that the (alleged) growth of nuclear programs in the Asia Pacific makes it all the more "necessary" for Australia to have a reactor - why should it not be the same for other countries? The second sentence is idiotic and should be deleted - does ANSTO really interpret the build up of nuclear technologies on the Korean peninsula, for example, as being driven by greenhouse concerns?

The Draft EIS (p.4-22) says "In the absence of a replacement reactor, Australia could, in principle, continue to participate in regional nuclear technical cooperation programs. However, this would very much be in a minor way and the opportunities for playing a lead role would be lost to another country." Under Article IV of the (NPT), Australia would not be seen as an advanced country, able to co-operate in contributing to the "further development of the applications of nuclear energy for peaceful purposes ..." (Article IV)." This is deliberate deceit. It is common knowledge that a cyclotron would fulfil Australia's obligations under Article IV of the NPT. (Then foreign minister Gareth Evans said in Parliament that a cyclotron would suffice "if there were RCA projects designed around its use.") There is no doubt that a spallation source would also allow for the fulfilment of these obligations. ANSTO/PPK should be directed to acknowledge these facts in the Final EIS.

ANSTO should be asked to provide a comprehensive commentary on the paper by Jean McSorley, 1998, "The New Reactor: National Interest & Nuclear Intrigues", which has been sent to Environment Australia by Ms. McSorley.

The relevant sections of Murray Scott's 1998 EIS submission are summarised here and require comment in the Final EIS:

o Scott: "If future international tensions should ever bring about a decision to build nuclear weapons in Australia, I would not be prepared to live near Lucas Heights, mainly through fear of irradiated uranium reprocessing operations. Apart from the obvious threat of hostile attack, e.g. Israel's strike destroying an Iraqi research reactor, the environmental and safety record of military nuclear programs worldwide is appalling. Disasters at e.g. Chelyabinsk, Windscale and Hanford and the environmental contempt of weapons test programs come as no surprise when national imperatives, urgency and military secrecy override any pretence of community consultation or consideration. Who knows what horrors will eventually emerge from the Chinese, Indian and Pakistani weapons programs. The historical entanglement of military and civil nuclear operations in all the weapons states is well recognised as compromising safety accountability ..."
o Scott: "Over the years there has been an accumulation of programs and facilities at Lucas Heights which could be seen internationally to have ambiguous potential for weapons development. These have been publicly ... declared and in most cases shut down. The facilities were exposed (perhaps only after related programs were terminated) to numerous visiting scientists ..."
o Scott: "On the enrichment path (JG - to producing bomb-grade fissile material) there were at Lucas Heights, ostensibly for commercial purposes, a fluorine plant, a UF6 synthesis plant, a laser enrichment project, and the centrifuge cascade development. ... On the alternative plutonium path, which appears more easily accessible at Lucas Heights, there are fuel irradiation facilities in HIFAR and hotcells in B54 in current use for chemical extraction of components from the irradiated uranium. These facilities have been developed for production of Mo-99 medical radioisotopes but differ from a "reprocessing" plant only in respect of the types of chemicals and column materials used to extract specific elements from the dissolved irradiated uranium. The resulting intermediate level radioactive liquid waste is clearly the most dangerous material stored at Lucas Heights and is now belatedly being solidified. The scale of this operation is currently larger than that for reprocessing of HIFAR's spent fuel ... and with the replacement reactor could grow four fold."
o Scott: "Whichever path were taken to produce fissile material, the design of an explosive device or a reactor core is highly specific to the purity of the fissile and structural material available. Despite extensive theory, data and computer calculation "codes" maintained worldwide including at Lucas Heights, it would be necessary in achieving military reliability to test particular configurations for "reactivity" without risking an actual nuclear explosion of criticality incident. In 1972 Prime Minister William MacMahon opened at Lucas Heights a Split Table Critical Facility explicitly intended for this purpose. It was ostensibly built for a proposed fast power reactor development program that was never funded."
o The concrete containment building for the split table was later used as beamline hall for ANTARES. Scott: "Far from disqualifying this building from housing a refurbished critical facility, the proximity of the tandem accelerator would offer a convenient pulsed neutron source, as commonly used for reactivity measurements. Contrary to the statement in the Draft EIS that "cyclotrons are not a source of neutrons", any accelerator of more than ~0.4 MeV beam energy can produce neutrons using a variety of e.g. (d,n) and (p,n) reactions, though not at the flux level available from a reactor. During the brief experimental program actually conducted on the critical facility, a small "neutron generator" accelerator was thus employed. The potential conjunction of the much more powerful tandem accelerator and critical facility in B53 is eerily reminiscent of the setup ~20 years previously in B22 where a beamline from the 3 MeV Van der Graaf accelerator was extended into the reflector of the MOATA reactor, and into a number of special BeO moderated and thorium metal reactor core mockups for similar reactivity or "neutron die away" measurements. One might almost think the tandem accelerator installation was designed with this in mind."
o Scott: "These ambiguous programs were published and, with the exception of the Mo-99 production, shut down and the equipment mothballed. As with any once-hi-tech equipment, the practicability of refurbishing these facilities is uncertain and perhaps the potential timescale for thus producing even one weapon (is?) impractically long. I hope so, but to my understanding these relics remain in storage and now, in considering a 30-40 year extension of reactor operation at the site, I believe we are entitled to know why. It could be suspected that in ANSTO's interpretation of the "national interest", the existence of these things at Lucas Heights is one reason that no other site was considered for HIFAR's replacement."

Scott asks for estimates of the capacity of each of the enrichment related facilities and of the replacement reactor together with the B54 irradiated uranium processing facility if adapted for Pu-239 production, in terms of the time it would take to process sufficient material for a nuclear explosive device.

Scott finishes with the very reasonable request for a schedule for complete disposal of the above and any other relic facilities of potential weapons proliferation significance.

Acknowledging the likelihood that if a nuclear weapons were ever pursued, it would most likely involve ANSTO and the reactor (e.g. for research and/or Pu production), what then is the thought process regarding siting? Are the luminaries in foreign affairs attracted to the idea of having a sensitive facility in suburban Sydney?

None of Scott's comments, or those made in Tony Wood's submission, are as far fetched as they might seem, as some simple facts indicate: the history of high-level interest in a domestic weapons capability; the bombing of Iraq's research reactors four times from 1979 to 1991; the use of research reactors for weapons production (i.e. Pu) in Israel and India and indirect involvement of ostensibly civil research reactors in covert weapons programs in several other countries.

Further to Scott's comments on the nexus between medicine and bombs, I offer the following comments (drawn from an article in Current Affairs Bulletin) and ask for a considered commentary in the Final EIS:

INNOCENCE BY ASSOCIATION: NUCLEAR MEDICINE AND NUCLEAR WEAPONS:

Now to consider the overlap between reactor radioisotope production and covert weapons programs. One link is plutonium extraction using hot cells - lead-shielded radiochemical laboratories with remote handling equipment for examining and processing radioactive materials. Hot cells can, if adequately equipped, be used to extract plutonium from spent fuel. The simpler and cheaper the facilities, the lower the volume and the lower the purity (and thus the weapons-useability) of the plutonium. Hot cells are "dual-use" facilities: they can be used for radioisotope processing, and numerous other non-military purposes, as well as for plutonium separation.

Hot cells have been used in Iraq for plutonium separation. They were supplied by Italy. Iraqi and Italian officials claimed that the hot cells were for medical and industrial purposes. Another illustrative example is North Korea. There has been an international dispute as to whether one of the facilities at the North Korean Yongbyon nuclear site is a civil radiochemical laboratory or a plutonium separation facility or both. In Argentina, hot cells operated from 1969-1972 and may have been used to separate plutonium in support of the covert weapons program. A small volume of plutonium was separated from hot cells in Romania. (Spector et al. 1995, Cronin 1985, Snyder 1985.)

Another link between reactor radioisotope production and weapons development involves radioisotope targets. These targets are placed in irradiation rigs in the reactor, and bombarded with neutrons emitted from the uranium fission reaction. Some targets, such as those used to produce molybdenum-99, are made of HEU, and this raises the question of possible diversion for weapons development. A single target uses only a tiny amount of HEU, but over the course of a year a large radioisotope producer, such as the Canadian company Nordion, can use 20-25 kg of HEU targets. This is sufficient for at least one nuclear weapon or for several cruder devices. (Rojas-Burke, 1993D.)

Another set of links between radioisotope production and covert weapons programs involves enrichment facilities. In Iraq, it was discovered in 1991 that large calutrons - electromagnetic isotope enrichment devices, also known as high-current mass spectrometers - were being used for uranium enrichment (Spector et al. 1995). Calutrons are also used to enrich stable isotopes, which are used, among other purposes, as feedstock for the production of some medical radioisotopes. There have been concerns that a small, Chinese-supplied calutron might have been (and might yet be) used for uranium enrichment in Iran (Spector et al. 1995). As with electromagnetic enrichment facilities such as calutrons, other enrichment technologies, including lasers and gas centrifuges, can be used both for uranium enrichment and for the separation of isotopes for radioisotope production (Hardy, 1996).

Beyond the more-or-less direct connections between radioisotope production and covert weapons programs, there are more general connections. Medical radioisotope production is routinely promoted as one of the most beneficial uses of research reactors. This gives impetus and legitimacy to research reactor programs, despite the potential for covert weapons development. One notable example is Iraq, where the nuclear program began with a small research reactor and a radioisotope laboratory, both supplied by the Soviet Union.

Clearly there is considerable overlap between research reactors, reactor radioisotope production, and covert weapons programs. This may come as a surprise for two reasons. Firstly, these interconnections are not widely advertised by the nuclear industry, for obvious reasons. In the case of medical radioisotope production, its overlap with covert weapons programs is doubly surprising because these two applications are at the opposite end of a spectrum - the best and the worst the nuclear industry has to offer. This ambiguous relationship comes through in the following comments from Ganatra and Nofal (1986), IAEA employees:

"Although radionuclides were used in medicine before World War II, a variety of them only became widely available for medical purposes later, when newly built reactors started producing radionuclides in adequate quantities. In a way, it can be said that the medical profession was introduced to the monstrosity of atomic energy first and then only gradually realized the mitigating medical benefits of the monster. The primal driving force in nuclear medicine development was not its impact on health care, but a desire to look for more and more that could be done with atomic energy - for as many tales of good deeds as possible, as if looking for that elusive other side of the coin."

ANSTO Submission to the Research Reactor Review 1993

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

Richard P. Cronin "India and Pakistan", in Jed. Snyder and Samuel F. Wells Jr. (eds.) Limiting Nuclear Proliferation, Cambridge, Mass., Ballinger, 1985, pp.59-88.

Department of Foreign Affairs (Australia) Submission to the Research Reactor Review 1993.

Ramanik Ganatra and Mohamed Nofal "Promoting nuclear medicine in developing countries" IAEA Bulletin 28(2), 1986, pp.5-11.

Mitchell Reiss Without the Bomb: The Politics of Nuclear Nonproliferation New York, Columbia University Press, 1988.

Research Reactor Review Future Reaction: Report of the Research Reactor Review Sydney, Wentworth Press, 1993.

Roger Richter "Testimony from a former safeguards inspector" Bulletin of the Atomic Scientists October 1981 pp.29-32.

J. Rojas-Burke "Ban on Enriched Uranium Exports Intended Against Bomb Builders also Affects Radiopharmaceutical Makers" The Journal of Nuclear Medicine Vol.34(3), 1993, pp.19N-40N.

Jed C. Snyder, "Iraq", in Jed. C. Snyder, and Samuel F. Wells Jr. (eds.) Limiting Nuclear Proliferation Cambridge, Mass., Ballinger, 1985, pp.3-42.

Leonard S. Spector, Mark G. McDonough and Evan S. Medeiros Tracking Nuclear Proliferation Washington, Brookings Institution, 1995.

F. Takats, A. Grigoriev and I.G. Ritchie "Management of spent fuel from power and research reactors: International status and trends" IAEA Bulletin No.3, 1993, pp.18-22.

Jo Vallentine Let the Facts Speak: An Indictment of the Nuclear Industry, Perth, Office of Jo Vallentine, Senator for the Greens (WA), 1992.

The Draft EIS (p.3-7) says the functions of the old Australian Atomic Energy Commission was to develop nuclear expertise. The Final EIS should note the following:
o a major objective was the introduction of nuclear power
o the Chair of the AAEC, Philip Baxter, was deeply embroiled in a covert push towards a nuclear weapons capability. This comment should include a reference to:
i) Cawte, Alice, 1992, Atomic Australia: 1944-1990, Sydney: New South Wales University  Press.
ii) Walsh, Jim, 1997, "Surprise Down Under: The Secret History of Australia's Nuclear  Ambitions", The Nonproliferation Review, Fall, pp.1-20.
o the AAEC was actively involved in developing plans to use nuclear bombs for civil engineering projects. In fact the AAEC convened a "Ploughshares Committee" to this end.
o the AAEC was actively involved in the uranium industry at various stages of its existence. This included storage of uranium at the AAEC's Lucas Heights facility.
o in the mid 1980s, Bill Hayden, in his capacity as Foreign Minister, argued that Australia should develop a "pre-nuclear weapons capability", by which he probably meant further development of technologies such as uranium enrichment and possibly a reprocessing plant.

The Draft EIS (p.3-14) says the 1986 Committee of Review of the AAEC "recommended that ANSTO commence with clearly defined objectives. Since inception ANSTO has been guided by a strategic planning process ..." In fact the 1986 Committee of Review (a.k.a. the Collins Review) argued that the AAEC had no clear objectives, too large an administrative effort, too many committees, that more effort was needed in commercial activities, and that another review was needed. This should be noted in the Final EIS.

As for ANSTO's strategic planning, this is a disingenuous glossing over of the fact that since the abandonment of the Jervis Bay nuclear power project, ANSTO has been an organisation in search of a mission. That ANSTO has found numerous niche applications across a range of areas does not alter this fact. That ANSTO continues to struggle to find a strategic niche for itself helps explain some of its more absurd activities - for example in 1997 an ANSTO press release announced the dating of the egg of a prehistoric Madagascan elephant bird. ANSTO's failure to find a strategic objective also explains its reliance on "national interest/security" arguments to convince the government of the need for a reactor despite the fact that none of the safeguards work at Lucas Heights (or anywhere else in Australia) is dependent on the operation of a reactor.

In 1994 the Bain report said "ANSTO's mission has become increasingly complex, and activities have proliferated with no clear sense of focus or priority." Thus the problem was not resolved in the 1980s.

As Murray Scott, former ANSTO employee notes, the ambiguous dual-use civil/military programs at Lucas Heights, which may have been pursued in part because of the interest of Baxter and others in weapons, have been air-brushed out of the Draft EIS. The key point is that some programs, e.g. enrichment, were weapons-relevant (and might have appeared as such to other countries) regardless of intentions. For example the enrichment R&D may have been pursued for any or all of the following reasons: i) adding value to uranium exports; ii) ensuring an ongoing supply of enriched uranium fuel for HIFAR; iii) developing a capability to produce enriched uranium fuel to power a nuclear power reactors/reactors in Australia is such were built; iv) developing a capacity to produce weapons-grade enriched uranium for defence/military purposes.

That "dual-use" programs are sensitive even if the intentions are benign is amply illustrated by the first 1-2 years of the enrichment R&D in the mid 1960s, when the existence of this program was kept secret by the AAEC.

For a more complete picture of ANSTO's history than is provided in the Draft EIS, the following are useful: the Cawte and Walsh references listed above; and a chapter of my PhD thesis which can be found on the internet at <http://www.uow.edu/arts/sts/pgrad/phdthesis>

The Draft EIS (p.4-16) refers to the Industry Commission and to the ANSTO-commissioned Access Economics study to assert that there will be economic benefits associated with the new reactor. The Draft EIS (p.4-3) fails to note that the Access Economics study was commissioned by ANSTO. This oversight must be redressed.

The EIS (p.6-19) says "ANSTO does not have access to information on using services for Australian industry." Some independent research should therefore be commissioned by Environment Australia.

Prof. John Stocker, Chief Scientist and Chair of the government's advisory body ASTEC, said in 1993 that: "For the foreseeable future the direct commercial returns appear unlikely to justify the investment in a new reactor and alternative means of supplying research and commercial needs may be more cost-effective." (RRR submission, p.1.)

Prof. Wilson (1993, RRR Appendix 1) said that many of ANSTO's projects have not produced any significant income as yet, in part because of the long lead times involved, and he said that not all such projects will turn out to be financial winners due to technological failure or, more often, due to difficulties in ultimate commercialisation.

The Research Reactor Review (chs. 10-11) undertook a detailed financial evaluation of the proposal for a new reactor. The Review concluded that a new reactor is certain to be a substantial economic burden, even allowing for off-setting revenue, and that there did not appear to be any prospect of commercial or industrial equity capital for a new reactor. The Review (1993, p.26, 119) said:

"Review members found that links between neutron sources and industry were not yet as pervasive and deep as the evidence of scientific usefulness suggested they ought to be. This is not just the case in Australia but world-wide."

"At most other facilities overseas, in order to demonstrate to industry that technology can assist in its operations, industry has been given free access initially and only charged for subsequent use, and then usually at a subsidised price."

The Research Reactor Review (pp.79-80) pressed a number of mining companies to place a value on having a domestic reactor. They said services such as neutron activation analysis and gauges were important but not critical to their operations - in the absence of a domestic reactor they would import products and services at extra expense, or use other techniques. Some companies are heavily dependent on HIFAR, but the income to ANSTO from these activities is relatively insignificant. BHP said that some HIFAR-based services were expensive, inconvenient and there was a slow turn-around.

Former ANSTO employee Murray Scott (RRR submission) said that the uptake by industry of ANSTO's research has not been good, with industry preferring cheaper, more accessible alternatives.

Prof. Ken McKinnon (Chair of the 1993 Research Reactor Review) said on ABC Radio (Background Briefing, 29 March): "There is no way that a research reactor, a new one, built in Australia, would ever make a return on the investment for scientific, commercial and medical uses, which would even get towards a fraction of what it would cost for a cost-benefit analysis on the normal industry basis."

Dr. Gammon (1997), Executive Officer of AINSE, says that "industrial appreciation of neutron scattering's role in material science is lacking." (Gammon, Dr. R.B., Executive Officer, AINSE, 1997, The Contribution of HIFAR to University Research", Proceedings of the Second International Conference on Isotopes, 12-16 October 1997, Sutherland, NSW: Australian Nuclear Association.)

ANSTO finds itself in a catch-22. It has historically provided commercial services and products at subsidised prices. If it raises prices to cover costs, customers may look elsewhere or turn to non-nuclear techniques. Either way, the proposed new reactor is likely to be an economic burden.

The future profitability of radioisotope production is uncertain. ANSTO faces competition from a number of large, vertically-integrated, multinational radiopharmaceutical companies. It is unlikely that ANSTO could compete on the world market against the multinationals to any significant degree. Even ANSTO's plan to become a significant regional supplier may be over-ambitious.

Future income from silicon doping is also uncertain. Amersham (RRR submission), one of the largest multinational radiopharmaceutical companies, said in 1993 that:

"...... silicon doping could not be considered a key activity for the (Australian) national economy since sufficient facilities already exist to meet market demand in other countries and information indicates that additional silicon irradiation world capacity will become available in the immediate and long term future at other new reactor locations."

The Research Reactor Review (p.115) said that

"There are 28 research reactors known, or planning, to have facilities for NTD silicon production, so the supply capacity is growing. ...... ANSTO itself admitted problems in forecasting the future market for NTD silicon. There is both the possibility of at least one non-reactor alternative process as well as the possibility of excess capacity by 2000."

Evidently ANSTO has commissioned a study by Access Economics which claims that ANSTO's programs provide economic benefits of $140-230 million each year. Those figures make no allowance for waste management costs, decommissioning costs, or even ANSTO's annual operating budget of about $91 million. (Peter Fries, Australian Financial Review, September 24, 1997.) Professor Max Brennan, former Chair of the ANSTO Board, said the Access Economics study was probably underpinned by the same sort of "shonky" economics that usually underpin such studies! (ABC TV, Lateline, July 1997.)

The Sutherland Shire Council notes that customised neutron generating instruments for use by mining companies and other industries have been licensed by Daimler-Benz Aerospace which is developing a commercial product, reportedly available in 1998 for less than $100 000. (New Scientist, 13 December, 1997, pp.32-37.)

As it stands, the Draft EIS comments on industrial applications are completely one-sided. They should be balanced by inclusion of all of the above material in the Final EIS.

The Draft EIS (p.4-20) defines opportunity costs as "benefits foregone by choosing to build and operate a replacement reactor compared to using the resources needed to do this for other projects." The Draft EIS identifies several opportunity costs: the land within the buffer zone; scientific research that is foregone on other research projects within Australia. It says: "There is, however, no guarantee that funding for the proposal would necessarily go to other projects if the proposal were not to proceed as the funds are not coming from any earmarked scientific budget."

The Final EIS should acknowledge i) that the funds earmarked for the reactor certainly could be spent on other areas of medicine and science and ii) that there is some dispute as to where the money has come from. The Final EIS should note the following comments from the Shadow Science Minister Martyn Evans (Current House Hansard, pp.3459-66, 14 May, 1998):

"The ARC funding - which is a very important source of funding for grants to our young people, to universities, for researchers to undertake further important studies in science - is declining in the forward estimates. .... In the absence of any other evidence it is reasonable for scientists and certainly for the Opposition to examine the point of view that the government is funding the reactor by a declining grant to ARC. If that is the case, it will severely impede Australian science in the years ahead and severely disadvantage our young researchers, who already have very little chance of getting an ARC grant. Only about 19% of applications for ARC grants are successful, and that means some 80% are not. Under the declining allocations listed in the forward estimates, even fewer people will be successful in obtaining those grants. That is a tragedy for our scientists. It is certainly a tragedy for our young scientists, who will increasingly be forced to go offshore. .... (C)ertainly one can understand that the government might well take a decision to reduce one source of funding within a portfolio so that it could increase another. We understand that often ministers are told 'This is a zero sum game. If you want new expenditure, you must come up with savings.' That is a line the government frequently uses."