TABLE OF CONTENTS - PART 3 : ALTERNATIVES TO A NEW REACTOR:
--> GENERAL COMMENTS
--> SCIENTIFIC RESEARCH
--> SUITCASE SCIENCE
--> SPALLATION SOURCES
--> CYCLOTRONS

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

ANSTO/PPK (p.6-3) list criteria relating to the proposal's objectives:

Objective:   "Maintain and Enhance Health Care Benefits to the Community"
Criteria:  Ability to produce diagnostic and therapeutic radiopharmaceuticals to meet    existing demand; to meet projected future demand; to meet user expectations    for reliability; and in a cost effective manner.

The criteria assume the need for domestic production, a biased assumption which obviously needs to be removed.

The criteria also need to consider the opportunity costs and to do this thoroughly and objectively. ANSTO cannot do this given its record of secrecy and dishonesty. PPK cannot do this because it has no nuclear expertise and because the Draft EIS demonstrates that PPK is quite prepared to parrot ANSTO's misinformation. Therefore Environment Australia will need to commission independent research. In short this research will need to evaluate the health gains (and risks) associated with a reactor and to compare with alternatives such as preventive medicine and public health programs. The analysis should also address the opportunity costs in relation to alternative diagnostic imaging modalities. This will require a sophisticated knowledge of the range of modalities used in diagnostic imaging and the interaction between the various modalities.

The Objective "Maintain Strategic National Interest" includes the Criterion "Ability to maintain and enhance Australia's nuclear expertise and knowledge in order to provide ongoing advice to the Commonwealth Government on nuclear issues." (p.6-3) Again, this criterion is so blatantly biased that it must be removed or drastically changed. It assumes an answer to the crucial question as to whether national interest objectives (e.g. non-proliferation) can best be met by technical means (e.g. a new reactor and whatever technical expertise will be derived from its operation) or through other initiatives (e.g. greater emphasis on and funding for diplomatic initiatives).

The Objectives "Provide a Neutron Beam Research Facility" and "Provide a Neutron Beam Training Facility" assume that Australia has a need for a neutron facility (either a reactor or a spallation source). Again, this criterion is so blatantly biased that it must be removed or drastically changed. It is absurd to assume the "need" for a neutron beam research facility. The funding set aside for the reactor should be opened up for competitive allocation as a major national science facility.

The Objectives and Criteria are so hopelessly biased that Environment Australia will need to draw up a new set of objectives and criteria. I am willing to assist.

ANSTO/PPK (p.x): "None of the strategic alternatives meet all of the multi-purpose objectives of the proposal." This is misleading obfuscation. In the absence of a reactor a range of strategies will need to be pursued: importing some isotopes, greater use of cyclotrons, suitcase science etc. It does not matter that any specific alternative (e.g. cyclotrons) cannot fully replace a reactor. In fact cyclotrons and spallation sources are multi-purpose facilities, and can be used for much the same range of purposes as a reactor: isotope production, scientific research, industrial applications, etc. Nor does the planned new reactor meet some important objectives, e.g. production of PET radioisotopes, the isotopic fingerprinting work which is a crucial national security project and uses the ANTARES accelerator, etc.

A comprehensive evaluation of the cases for and against a new reactor requires a detailed, fully-costed alternative strategy for medicine, science, industry, and national security objectives. This would enable meaningful comparison with the reactor proposal. The Draft EIS not only fails to provide this alternative strategy, it conveniently ignores and side-steps the need for such a strategy to be developed and costed.

Generally, the three studies commissioned by Environment Australia overlook the fundamental question: does Australia need a nuclear research reactor? The only exception is a cursory, half-page treatment of this fundamental question in the CH2M Hill study.

ANSTO/PPK (p.4-8) refer to the Beam Facilities Consultative Group which comprises people from most areas of neutron use. What role does ANSTO have in this Group, apart from publishing the Group's report? This Group is held up as an authority on the range of scientific benefits associated with a new reactor. It needs to be noted in the Final EIS that a group of neutron users is, to say the least, unlikely to be able to objectively evaluate the arguments for and against a new reactor. They obviously have career and/or financial interests in a new reactor.

ANSTO/PPK (p.4-3) discuss potential scientific and industrial benefits without even a passing mention of the opportunity costs. ANSTO/PPK must be required to submit a detailed justification of the planned new reactor in the context of Australia's science and technology sector.

ANSTO/DIST (Senate Inquiry submission, pp.497-498) imagine that the 1993 RRR "identified the necessity for a replacement research reactor." To justify this lie, ANSTO/DIST give a highly selective reading of the RRR's comments on neutron science. To counter this I offer the following fair and accurate summary of the RRR's comments (pp.24-25). An accurate summary should appear in the Final EIS.

"Neutron scattering is a powerful tool for application in a wide range of scientific fields: physics, chemistry, biological sciences, materials technology, and nuclear medicine, at basic and applied levels. ...... Leaving aside for the moment cost considerations, the Review concluded that there are strong arguments for Australia to maintain a neutron source. Without this tool, Australia would lock itself out of several rapidly advancing areas of science."

But when cost considerations are factored into the equation:

"A new neutron source would only be justifiable ultimately if the money required for its construction were to be additional and not at the expense of the current Science budget." (RRR, p.xx.)

The Review considers that funding a new research reactor or a major upgrade of HIFAR should not be at the expense of existing science expenditure." (RRR, p.120.)

And there are other issues as well ......

"The Review considers that, for scientific use at least, there is a strong case for a research reactor, that is, a neutron source, to be available nationally. It is essential to ask, however, whether Australia has the scientists and the intensity of effort in this field to make such a purchase a good scientific investment, whether there are alternatives and whether our industry would be able to exploit its potential if Australia were to buy a new one." (RRR, 1993, p.28.)

Having examined these questions, the RRR was sceptical. In relation to the "crucial" question posed by the Terms of Reference, whether the science at ANSTO is of sufficient distinction and importance to Australia to warrant a new reactor, the RRR (pp.65-66) said:

"The Review is not convinced that that is the case - at least not yet. ANSTO scientists are held in esteem by other scientists here and overseas. Peer reviews of recent scientific output were more mixed. Nobody advanced the view that Australian scientists working at HIFAR are at the cutting edge of science. The Australian Research Council Review pointed to a facility not fully exploited. The evaluations of publications were also mixed. A picture of a vibrant field of science, energised by young people excited by the challenges and opportunities, did not emerge. HIFAR is not at present and has not for many years been the focus of scientific effort equivalent to that evident in several other scientific fields."

"The Review was not even convinced that (reactor-based) science has been a major focus of ANSTO activity. The full flowering of recent vigour might not be evident yet in publications, but at present the case for a new reactor on science grounds cannot be sustained, however compelling the need for such science."

"The number of scientists and the range of scientific activities undertaken using HIFAR, even taking into account its limitations, are more limited than would alone carry the case for a new research reactor."

The Draft EIS (p.4-12) claims that ANSTO's research is "world class" and (p.6-19) that the new reactor would be a "world-class facility - probably in the top ten facilities in the world." However:
o 1994 International Atomic Energy Agency data reveals that there are 20-25 research reactors around the world with a neutron flux equivalent to, or greater than, the neutron flux of the planned new nuclear reactor in Australia (3 x 1014 neutrons/cm2/sec). It is simply not possible to carry out "world class" research when so many reactors will outperform the planned new reactor in Australia. ANSTO/PPK should be asked to go through the most recent table of research reactors from the IAEA and to rate the planned new reactor in terms of neutron flux. This should note how many reactors have a flux greater than AND equal to that planned for the new reactor.
o the Australian Academy of Science (Senate Submission, p.404) says that "In order to compete with the comparable medium-flux facilities overseas, the new Australian reactor should have characteristics such as: a power of about 30 MW, producing a flux of about 8 x 1018 neutrons / square metre / second" However the proposed new Australian reactor will be 14-20 MW, and the neutron flux will be about three times that of HIFAR, not eight times that of HIFAR as recommended by the AAS Working Group. Thus the AAS implicitly acknowledges that the proposed new reactor will NOT be able to compete with comparable facilities overseas. This should be noted in the Final EIS.

The Draft EIS (p.4-13) says "It is recognised that early next century there will be a period when there is expected to be a lack of neutron sources." The Australian Academy of Science mentions a number of projects to overcome the so-called "neutron drought", but only a minority of these projects involve research reactors (Senate Reactor Inquiry submission, p.392):

"To meet this 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."

ANSTO and the government claim that funding for the new reactor is not coming at the expense of other science projects. However funding set aside for the reactor closely matches funding cuts to the Australian Research Council. Martyn Evans, Shadow Science Minister, makes the following points (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."

If ANSTO/PPK persist with their assertion that the money is not coming from the science budget, then they should be directed to explain exactly where the money is coming from. If this means obtaining the relevant information from the government, so be it.

Also, is it true that part of the funding is coming from the health-care budget?

The Sutherland Shire Council (Senate Reactor Inquiry submission) says: "With respect to application of neutron scattering in Australian science, the research output of ANSTO since the RRR requires close attention. Council's preliminary analysis suggests that there is increasing research paper output, but decreased evidence of scientific citation."

The following points should be noted in the Final EIS:
o Dr. John Stocker, who holds the government position of Chief Scientist, and is also Chair of the government's advisory body the Australian Science, Technology and Engineering Council (ASTEC), says that neither the Office of the Chief Scientist nor ASTEC were consulted by the government before announcing the decision to replace HIFAR (Pockley, 1997C)
o In 1993, the head of the CSIRO said that it could not support a new reactor if funding was not addition to usual science funding, and that "CSIRO is of the general opinion that more productive research could be funded for the cost of a reactor." The current head of the CSIRO has declined to comment on the proposal to build a new reactor, and said that he was not consulted about the proposal to replace HIFAR before the decision was made.
o the proposed new reactor has not been thoroughly evaluated against other areas of science and technology. Federal ALP shadow science minister, Mr. Martyn Evans, says: "The money should have been competitively offered and judged against other needs for science." (Quoted in Pockley, 1997C.)

The Draft EIS's uncritical perspective on the scientific benefits of a reactor for scientific research should be balanced by inclusion of the following perspectives:

Prof. Barry Allen, former Chief Research Scientist at ANSTO, Fellow in the Department of Pharmacy at the University of Sydney, Head of Biomedical Physics Research at the St. George Cancer Care Centre; and author of over 220 publications, made the following comments in Search, the official publication of the Australian and New Zealand Association for the Advancement of Science (October, 1997)

"(The new) reactor will be a step into the past .... (It) will comprise mostly imported technology and it may well be the last of its kind ever built. More importantly, anticipated developments in functional magnetic resonance imaging may well reduce the future application of reactor-based nuclear medicine. Certainly the $300 million reactor will have little impact on cancer prognosis, the major killer of Australians today. In fact, the cost of replacing the reactor is comparable to the whole wish list that arguably could be written for research facilities by the Australian Science, Technology and Engineering Council (ASTEC). .... Apart from the neutron-scattering element of the reactor, there will be little research and development yet it will make a large dent in the budget for Australian research, which at this point is so badly needed in order to take us into the next century. .... The decision to proceed with a new reactor is not wrong, but it is a far cry from the optimal expenditure of funds that Australia badly needs in science and technology."

There is also the view that too much of the research at ANSTO merely duplicates overseas research. Former AAEC/ANSTO/CSIRO employee Murray Scott made the following comments in his submission to the RRR:
o ANSTO's research is facility-driven, i.e. it is driven by a perceived need to make use of ANSTO's facilities, in particular expensive instruments such as HIFAR, rather than being driven by practical problems. This results in expensive facilities such as HIFAR functioning as "technologies in search of a mission". A better model would be "small science", more flexible, problem-based rather than facility-based.
o much of ANSTO's research is redundant, adding little if anything to overseas knowledge - dotting the i's and crossing the t's. "This tunnel vision tends to be perpetuated as the students in turn become supervisors and promote their own little corner of whatever field they were herded into."
o Scott says: "Though HIFAR has become indispensable to the people involved, e.g. in neutron diffraction and activation analysis, it has commanded resources which would have supported considerably more effort in closely related fields such as X-ray diffraction and mass spectrometer or atomic absorption analysis. .... (The proposed new reactor) would continue to drain students, research effort and money away from more productive fields for many decades."
o generally the uptake by industry of ANSTO's research has not been good, with industry preferring cheaper, more accessible alternatives.

Prof. Ian Lowe, from Griffith University, analysed the reactor/science debates during the RRR and concluded thus:

"In summary, science policy considerations suggest strongly that a new research reactor should not be a high priority for Australia's small public sector research budget."

"Although the construction of HIFAR and other facilities at Lucas Heights have resulted in about 3% of Australia's public science expenditure going into the ANSTO operation, the returns have been comparatively modest. The output of scientific papers is modest, whether measured per researcher or per unit of expenditure, and it is not possible to show the impact of this work as being unusual. The rate of invention and patenting makes little contribution to the nation as a whole."

Prof. Lowe also commented on the importance of neutron sources:

"A key argument presented to the (RRR) was that neutron diffraction is now such an important analytical tool that no self-respecting industrial nation can afford to be without a state-of-the-art source of neutrons. I have discussed this argument with several physicists who do not have direct vested interests. All agree that neutron diffraction is a useful tool but by no means the most important investigative technique. They agree that useful science could be done if we were to have a state-of-the-art reactor, but do not see it as the highest priority for research in the physical sciences."

"If it were really true that a research reactor is a necessary tool for an advanced industrial society, it would not be possible for those nations which lack a reactor to be successful in modern technology. But Ireland, listed by ANSTO as one of the nations not having either nuclear power reactors or a research reactor, manages to produce four times the value of Australia's high technology exports, despite only having a population about a quarter of ours. Thus the argument that a research reactor is essential for advanced manufacturing industry is clearly invalid. It may be useful and beneficial, but it is not essential."

It is likely that in the Final EIS, ANSTO will mention the support for a new reactor by medical and scientific bodies such as the Australian Academy of Science, Australian Nuclear Association, Australian and New Zealand Society of Nuclear Medicine, Australian and New Zealand Association of Physicians in Nuclear Medicine, and the Australian Academy of Technological Sciences and Engineering.

Allen, Prof. Barry, 1997, "Benefits of Nuclear Reactor Still Unclear", Search, Vol.28(9), p.259.

Pockley, Peter, 1997C, "Senate Inquiry into Research Reactor", Search, Vol.28(10), p.296.

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

The Draft EIS (p.4-12) says "... there has been a trebling in the use of overseas neutron facilities by Australia's top research scientists, but even they have been unable to obtain the instrument time they have sought."

This is an important issue and far more information is required on the access of Australian scientists to overseas facilities. ANSTO's habit appears to be to present one or two worst case examples and to leave the matter at that. ANSTO should be directed to provide comprehensive data. AINSE may be able to assist.

The Draft EIS (p.6-19) claims that access to overseas facilities is usually restricted to scientists who have made significant contributions to research at their national research reactor facility, and that even if it was "strategically possible" to meet the expectations of Australian neutron scientists it would be "prohibitively expensive". This sits very uncomfortable with comments made by ANSTO employee John Boldeman at the 1997 Australian Nuclear Association conference. Boldeman discussed the following four programs which allow Australian scientists to access overseas facilities:
o the ANBF synchrotron facility in Japan
o the APS synchrotron facility in the USA
o Australian collaboration with the ISIS spallation facility in the UK
o the Access to Major Research Facilities Program

Boldeman says "All (four) programs have been outstandingly successful and have provided comprehensive research opportunities for Australian scientists at very small cost." The number of funded proposals is expected to double in the next few years, from the 1996-97 level of about 75 projects. One hundred and thirteen senior scientists plus 41 postgraduate students were supported in 1996-97.

Boldeman's comments should be included in the Final EIS. They highlight the need for more detailed information on cost and access.

One issue is that it may be easier to access overseas facilities if something can be offered in return - such as access to an Australian reactor. Perhaps higher sums of money can be offered as an alternative. If the RRR's figures ($2 million per year for 20-30 scientists) are more-or-less accurate, then the government should be able to provide ample funding for suitcase science at a fraction of the cost of a new reactor. Australian scientists have access to overseas synchrotron and spallation facilities, although there is no domestic synchrotron or spallation source. Countries which operate reactor(s) may be prepared to exchange access to their reactors in return for access to non-reactor facilities in Australia. For example ANTARES could be used as a bargaining chip, keeping in mind ANSTO's comment that "The high quality work at the tandem accelerator is attracting more and more work from Australian and international researchers in a wide variety of fields." Other bargaining chips might include the ANSTO supercomputer, or synchrotron or spallation sources if such are built in Australia.

The Korea Atomic Energy Research Institute (KAERI) is worth specific mention. KAERI operates the HANARO reactor, which first went critical in early 1995. It has a high power level (30 MW) and high neutron flux (maximum core thermal flux of 4.5 x 1014 n/cm2/sec). The functions of the reactor are fuels and materials testing in support of the nuclear power program (30%), neutron physics experiments (28%), radioisotope production (22%), neutron activation analysis (16%), and silicon doping and neutron radiography (4%). KAERI hopes to use HANARO as the basis of an international research centre.

The "Access to Major Research Facilities Program" was initiated in 1990 by the Department of Industry, Science and Tourism. Initial funding was $150 000 p.a., rising to $330 000 for the fiscal year 1996-97. The term major research facilities refers to large facilities not available in Australia such as synchrotron radiation sources, high flux neutron beam sources, high energy physics facilities and astronomical facilities. The proposed facility must be a major facility with a capital cost greater than $100 million. Maximum funding is $12 000 dollars, funding is limited to 14 days, and the maximum number of researchers is three per proposal. Access to such facilities is competitive and subject to heavy worldwide demand.

In sum, it is certain that an expansion of suitcase science programs could partially fill the gap left by the closure and non-replacement of HIFAR. However the extent of future access to overseas facilities is an open question.

The Draft EIS merely repeats a number of dubious and largely unsubstantiated assertions that ANSTO has been making about spallation sources for some years. ANSTO's pessimism is utterly at odds with the views expressed by a senior ANSTO scientist, Prof. John Boldeman, in a 1995 article. (Boldeman, J.W., 1995, "Accelerator Reactor Hybrid Systems", Proceedings of the 1995 Conference on "Nuclear Science and Engineering in Australia, 1995", Lucas Heights, 30-31 October.)

To give some examples of the low level of debate, consider the following comments in the Draft EIS (p.xi): "Spallation sources are very expensive, have not been proven as a reliable source for the routine production of medical or industrial radioisotopes, operate in a pulsed mode and have extensive periods of shutdown for maintenance."
o "very expensive"? In 1995, ANSTO mentioned existing spallation sources (ISIS, SINQ) and planned spallation sources (ASTRON/Austria) and said "The cost of each of these facilities is around $200 million." In response to a Parliamentary Question on Notice, ANSTO later denied making that comment! Whatever the current costs, it is likely that costs will decrease as spallation technology is further developed and commercialised. SCK-CEN says that for Myrrha/Adonis, the base investment cost is expected to be less than half that of a typical 15 MW reactor cost, with annual operating costs of about $2 million. Certainly Australia would not be looking to build a GeV spallation source which might cost in the vicinity of $1 billion; according to Prof. Barry Allen, an instrument of something like a quarter of that power would suffice for Australia's needs.
o "have not been proven as a reliable source for the routine production of medical or industrial radioisotopes"? Rubbish. See below.
o "operate in a pulsed mode"? Not all spallation sources operate in a pulsed mode.
o "extensive periods of shutdown for maintenance"? This is a dubious claim which needs to be substantiated - not just with the one worst-case example of ISIS. SCK-CEN says that the modular, flexible nature of Myrrha/Adonis would result in less down-time when compared with multipurpose research reactors.

The Draft EIS (p.6-4) says this of ADONIS: "It is unique, being the only "hybrid" proposal where the conceptual design has considered the replacement of research reactors for the production of particular isotopes." In fact, there is a great deal of R&D into hybrid systems. This literature can easily be accessed through the SCK-CEN web-site: <http://hades.sckcen.be/>

It would be the height of absurdity to imagine that ANSTO and/or PPK could objectively and adequately evaluate the option of replacing HIFAR with a spallation source, or the prospects for spallation technology more generally. Therefore Environment Australia has no option other than to commission independent research. Prof. John Boldeman should be consulted, as should the former ANSTO Chief Research Scientist Prof. Barry Allen, who now works at the St. George Cancer Care Centre.

SPALLATION PRODUCTION OF MEDICAL RADIOISOTOPES.

The Draft EIS (pp.6-6--6-7) glosses over the long history of spallation production of medical radioisotopes. For example it says (p.6-6) "A spallation source could theoretically be used to produce new isotopes in low quantities for medical research." In fact, spallation sources have been used since the 1970s to produce a wide range of radioisotopes. For example the US Department of Energy initiated a program in 1974 and has produced about 75 radioisotopes using spallation targets. The radioisotopes recovered are distributed for worldwide use in nuclear medicine, environmental research, physics research and industry.

The discussion on ADONIS (p.6-6) is inaccurate and dishonest. The comments on operating regimes, cost, number of staff required etc. are in contradiction with the views expressed by SCK-CEN.

ANSTO/PPK note that SCK-CEN envisage the use of HEU secondary targets - a good point, but one which conveniently ignores the fact that LEU targets can be used. ANSTO/PPK should be directed to note the following: The use of LEU targets has been discussed in the literature, e.g. Egan, Gary F., 1995, "Development of Cyclotron Technologies for Medical Radioisotope Production", Proceedings of the Conference on "Nuclear Science and Engineering in Australia, 1995", Lucas Heights, 30-31 October.

The Draft EIS (p.6-4) says of the existing spallation sources: "None of these operate at a power range that would enable isotope production performance comparable to the proposed replacement reactor or even to HIFAR." This needs clarification - in particular the important parameter of neutron flux is not discussed.

The Draft EIS (p.6-5) says "A letter from SCK-CEN in Belgium (Dhont, 1998, pers. comm., 6 June), has confirmed, however, that "it seemed very unprobable to find financing by isotope-producers in a technology which was not yet proven", and that their research was now on the Myrrha system. This (Myrrha) concept has been proposed for the transmutation of wastes and other nuclear physics activities. A prototype Myrrha facility would take four years to construct." However the SCK-CEN web-site says "The initial Adonis project, especially focused on radioisotope production, remains a current project within the envelope of the Myrrha project." Thus there may be ongoing work into the Myrrha system - clarification required in the Final EIS. As for funding, the lack of private-sector investment is not a decisive limitation in an industry which has historically been heavily subsidised. The implicit assumption from ANSTO/PPK is that the radiopharmaceutical industry should be operated solely on a commercial basis. This flies in the face of ANSTO's own operations which involve the provision of heavily-subsidised isotopes by a public-sector agency.

The following comments are drawn from Allen Zeyher, 1997, "Belgian Companies Propose New Solution for Isotope Production", The Journal of Nuclear Medicine, Vol.38(3), p. 16N:
o "ADONIS is not new technology in its components. Cyclotrons are well established in scientific research. Moreover, similar irradiation targets are used all the time. However, SCK-CEN believes combining the two technologies can reduce cost and reliably help meet the demand for Mo-99, the most widely used medical radioisotope."
o "A variety of irradiation targets can be installed and removed individually, allowing the user to shape the neutron multiplication while remaining far enough from criticality. The flux around the irradiation targets is optimized for Mo-99 production ... but can be increased. The targets can be loaded and unloaded with the facility on line, and production can be matched to market needs. SCK-CEN calls the system inherently safe, with a simple, fail-safe construction. Continuous operation is possible with a minimum of human intervention, thus reducing personnel costs. The price SCK-CEN quotes for initial construction of ADONIS is less than $50 million, with annual operating costs of $2 million, a feasible investment for a radiopharmaceutical company or group of companies, according to SCK-CEN. One ADONIS installation would have a maximum capacity of 50% of the world's demand for Mo-99. Capacity could be increased by adding cyclotrons and/or subcritical assemblies."
o After consulting with authorities in Europe and the USA, SCK-CEN estimates that the time for licensing and building ADONIS would be only four years. Nordion (the Canadian radiopharmaceutical company) agrees that licensing ADONIS could be as easy as licensing a cyclotron, but says it is not certain until it is actually tested with a regulatory body."
o Other possible applications for ADONIS include neutron beam research, neutron activation analysis, transmutation/partitioning studies, and proton beam research.

The Canadian TRIUMF facility operates four accelerators. According to an article in The Journal of Nuclear Medicine, "Once a high-intensity spallation facility connected to a new separator is brought online in 1999, ... TRIUMF would be able to produce large quantities of neutron-rich therapeutic radionuclides with very high specific activities." (Linda Ketchum, Mark Green, Silvia Jurisson, 1998, "Research Radionuclide Availability in North America", The Journal of Nuclear Medicine, Vol.38(7) and Vol.38(8).) This sentence undermines no less than five of the myths propagated by ANSTO - large quantities, high specific activity, neutron-rich radioisotopes, therapeutic radioisotopes, clinically-useful radioisotopes c.f. research only. ANSTO/PPK should be directed to start afresh and provide an honest account of spallation production of radionuclides in the Final EIS.

A federal Parliamentary Research Report, released the week after the decision on a new reactor, concludes that: "It is clear that, in coming to a decision in principle to have a new reactor constructed in Australia, the Government has not made a thorough, balanced comparison of the merits of spallation sources versus the reactor method for technetium production." (Panter, Rod, 1997, "Cyclotrons: Can they be used to make technetium-99m?" Parliamentary Research Report, Department of the Parliamentary Library.)

ANSTO (1995) notes that for Mo-99 production, downstream processing is identical and that the principal source of radioactive waste at Lucas Heights arises from radioisotope production and processing. ANSTO goes on to say that "Thus the replacement of HIFAR by a spallation neutron source would not have a marked impact on the radioactive wastes generated by ANSTO." However the spallation technique offers a major advantage: it would eliminate the need to irradiate fuel rods and to store and dispose of spent fuel rods.

ANSTO (1995) says "It would appear that substantial research and long-term evaluation would be required to substantiate the viability of .... commercial production (of Mo-99 using spallation sources)." ANSTO is exaggerating the time frame. SCK-CEN (the Belgian nuclear research centre) expects a pilot system to be in operation within four years and it expects to REPLACE the BR-2 reactor with a spallation source in 10-15 years. If a multipurpose spallation source is not a viable option by the time HIFAR is closed, this is no problem. Interim strategies, such as importing radioisotopes, can be pursued while spallation technology is more fully developed. Certainly a spallation source for scientific research is a viable option now, since such facilities are already in operation overseas.

ANSTO (1997) says that "The RRR acknowledged in 1993 that, even if Australia acquired a spallation source, a reactor would still be needed for radioisotope production." This is nonsense and no such comment should appear in the Final EIS. With supply from the two Australian cyclotrons (and plans for others in train), plus imported isotopes, and perhaps also a domestic spallation source used to produce radioisotopes among other purposes, there would be no need whatsoever for a reactor (small or large).

SPALLATION SOURCES AND THE "STRATEGIC NATIONAL INTEREST" (pp.6-6--6-7)

It is accepted 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.

The Draft EIS (p.6-6) says that building a spallation source as an alternative to a reactor (my emphasis) "... would flow on to the loss of Australia's seat on the International Atomic Energy Agency Board of Governors." However it is not certain that the IAEA BoG seat would be lost without a reactor, and it is not certain that it will be retained with a new reactor. ANSTO/PPK should be directed to state these facts unequivocally.

ANSTO/PPK (p.6-7) grossly overstate the "need" for a new reactor to maintain nuclear fuel cycle expertise and thus provide advice to government. Nuclear expertise can be gained through access to overseas facilities. A great deal of national interest work is not dependent on a reactor - e.g. ANTARES plus radiochemical laboratories for environmental sampling, e.g. the ASO's work in video surveillance research, e.g. diplomatic/political initiatives. Moreover it appears that the importance of a domestic reactor in relation to monitoring and influencing nuclear programs overseas is overstated. For example the North Korean saga is held up as an example of Australian initiative in the international arena, but it is beyond belief that this saga would have unfolded any differently without Australian involvement, and in any case the link between operation of a research reactor and Australian involvement in this affair is tenuous.

SPALLATION SOURCES AND NEUTRON RESEARCH

The Draft EIS (pp.6-7) says "There are some applications where the figures of merit of both types of facility overlap, so that neutron beam research using the single crystal diffraction technique could be carried out equally well on a suitably designed and equipped spallation source or a research reactor."

Thus we finally have an acknowledgment from ANSTO that there is a degree of overlap between spallation sources and research reactors. Yet the Draft EIS contradicts itself by saying that spallation sources, very high flux reactors, and high/medium flux reactors with sophisticated instrumentation have "well-defined and complementary roles". The comment that the roles are well-defined overlooks the rapid advances in spallation technology and the growing range of actual and potential applications. This lie should be deleted from the Final EIS.

The Draft EIS (p.6-7) refers to the Beam User Consultative Group's user requirements for the new reactor. The Draft EIS then goes on to say that a spallation source would not be able to satisfy all the performance criteria. This is absurd. If the Consultative Group was asked to provide requirements for a spallation source, then a reactor would not suffice for the criteria! The comment should be deleted.

The Draft EIS (p.6-7) refers to a Kohn article written in 1993. Reference to a five-year old article on a technology which is advancing so rapidly should not be allowed. Why is there no reference to the 1995 article by ANSTO employee John Boldeman or the work of Gary Egan or the SCK-CEN literature or the literature on hybrid systems R&D? Answer: ANSTO has an a priori position that it wants a new reactor and thus has no interest whatsoever in an objective evaluation of alternative technologies.

The Draft EIS (p.6-8) refers to the need to meet all of the objectives "simultaneously". The assumption is that one particular instrument must meet all of the objectives. Thus options such as greater reliance on overseas services and products, and greater reliance on non-technical methods to achieve national interest objectives, are downplayed or ignored. ANSTO/PPK should be required to remove all such assumptions throughout the Draft EIS. ANSTO/PPK should also be directed to state unequivocally that a new research reactor will not meet important objectives in the relevant areas of science and medicine, e.g. production of PET radioisotopes.

SPALLATION SOURCES AND INDUSTRIAL APPLICATIONS

The EIS (p.6-8) says "the use of a pulsed spallation source for industrial radioisotope production would be at the expense of scientific research." This conveniently ignores the modular design proposed for Myrrha/Adonis.

The following summary of Jamriski et al. contradict ANSTO/PPK's comments about industrial applications. It should be included in the Final EIS:

The US Department of Energy (DOE) has been at the forefront of radioisotope production using spallation reactions since it initiated a program in 1974. High-current accelerators have been used to produce about 75 neutron-deficient radioisotopes using spallation targets. The accelerators are located at the Los Alamos National Laboratory and the Brookhaven National Laboratory. Research isotopes are also recovered from targets irradiated at the TRIUMF facility in British Columbia, Canada. The radioisotopes recovered are distributed for worldwide use in nuclear medicine, environmental research, physics research and industry. Products include Sr-82, Cu-67 (from ZnO targets), Ge-68, and some unique isotopes in quantities not available from other sources such as Be-10, Al-26, Mg-28, Si-32, Ti-44, Fe-52, Gd-148, and Hg-194. [Jamriski, D.J., Peterson, E.J., and Carty, J., 1997, "Spallation Production of Neutron Deficient Radioisotopes in North America", Proceedings of the Second International Conference on Isotopes, 12-16 October 1997, Sutherland, NSW: Australian Nuclear Association.]

The Draft EIS notes that ISIS (UK) is used for industrial purposes and that industrial applications are planned for SINQ and ADONIS.

SPALLATION SOURCES AND RADIOACTIVE WASTE

The Draft EIS (p.6-8) notes that "In general, compared to a reactor, a spallation source produces significantly less radioactive waste."

The Draft EIS (p.6-8) then says "However, because of the inventory of fissile material in the sub-critical assembly, a hybrid system such as the ADONIS concept would produce significantly more radioactive waste than a spallation source." So what? What is of interest is the comparison with research reactors. ANSTO/PPK should be directed to note that there would be advantages in relation to waste given that spallation sources and hybrid systems do not use uranium fuel rods whereas research reactors do.

ANSTO, 1995, "The use of cyclotrons and accelerators for the commercial production of radioisotopes", Submission (#32C) to Senate Select Committee on the Dangers of Radioactive Waste.

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

Boldeman, J.W., 1995, "Accelerator Reactor Hybrid Systems", Proceedings of the 1995 Conference on "Nuclear Science and Engineering in Australia, 1995", Lucas Heights, 30-31 October.

Egan, Gary F., 1995, "Development of Cyclotron Technologies for Medical Radioisotope Production", Proceedings of the Conference on "Nuclear Science and Engineering in Australia, 1995", Lucas Heights, 30-31 October.

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

Yongen, Yves, 1995, "A Proton-Driven, Intense, Subcritical Fission Neutron Source for Radioisotope Production", Proceedings of the International Conference on Accelerator-Driven Transmutation Technologies, Vol. 346(1), pp.852-857.

PRODUCTION OF MEDICAL ISOTOPES (Draft EIS, p.6-9--6-13)

The Draft EIS (p.6-9) asserts that "Both reactors and cyclotrons are needed to make the full range of radioisotopes that are required for medicine, because of the different types of isotopes they are capable of producing." This assertion should be deleted because it ignores the rapid advances with cyclotrons, accelerator-driven spallation sources and hybrid systems. It also assumes the "need" for nuclear medicine despite the fact that nuclear medicine is dwarfed by alternative imaging modalities.

The Draft EIS (p.6-8) says that "Most medical radioisotopes can be produced in either a nuclear reactor or by a cyclotron." The Draft EIS (p.6-9) also asserts that the "medical community" argues that cyclotrons and reactors have different but complementary roles. Yet the Australian and New Zealand Association of Physicians in Nuclear Medicine, in its written submission to the Senate Reactor Inquiry, said: "... many of the reactor-produced isotopes have been made in cyclotrons". ANSTO/PPK should be directed to include this quote in the Final EIS.

ANSTO/PPK should be directed to note that nuclear medicine practitioners have vested career and/or financial interests in a new reactor, and that there are those in the "medical community" who oppose the reactor plan.

As an example of the duplicity of the medical community, a nuclear medicine specialist is quoted in a recent edition of The Weekend Australian saying that a new reactor is vital for medical isotope production, yet the same doctor has written to me making the following points:
o his clinic imports Mo/Tc generators from both the UK (Amersham) and ANSTO. The Amersham product is superior in quality to ANSTO's product, and cost and reliability are comparable.
o my arguments on the (good) prospects for greater reliance on imports are "quite compelling".

The Draft EIS (p.6-9) quotes an OECD study which says that inadequate supply of reactor isotopes such as Mo-99 and Ir-192 would have detrimental impacts in medical and industrial sectors.

As for iridium-192:
o it has a half life of 72 days (ample for importation)
o Amersham (RRR Submission) claims to be the largest consumer of bulk Ir-192 in the world and says that is could supply high-quality Ir-192 sufficient to meet Australian demand
o there several bulk producers, e.g. in Russia, Sweden, the US (Isotec).

A recent article illustrates the versatility of cyclotrons. It describes the University of Wisconsin 11 MeV cyclotron which has produced 100 radionuclides using over 100 proton-induced reactions. (Linda Ketchum, Mark Green, Silvia Jurisson, 1998, "Research Radionuclide Availability in North America", The Journal of Nuclear Medicine, Vol.38(7) and Vol.38(8).)

REPLACING REACTOR ISOTOPES WITH CYCLOTRON ISOTOPES

ANSTO/PPK should be directed to address this topic with a shred of honesty rather than with the typical misleading assertions along the lines that both reactors and cyclotrons are and always will be necessary.

Prof. Henry Wagner has recently reiterated a claim he first made in 1996: that cyclotron-produced F-18 fluorodeoxyglucose (FDG) is the "molecule of the century". Wagner goes on to report that at the annual conferences of the US Society of Nuclear Medicine, the number of presentations on FDG has increased, reflecting its increasing role in clinical practice. By contrast, the number of presentations on Tc-99m has been flat over the past six years and actually fell from 430 in 1997 to 332 in 1998 - a decline of almost 25% in one year. Wagner describes research showing FDG to be 97% accurate in detecting metastatic bone lesions compared to just 81% for a Tc-99m-based compound. FDG has a particularly strong role in oncology - cancers studied by FDG include those of the lung, colon, head and neck, thyroid, brain, breast, melanoma, plus 41 others. (Henry N. Wagner, 1998, "Nuclear Medicine: The Road to Smart Medicine and Surgery", The Journal of Nuclear Medicine, Vol.39(8).)

"FDG-PET imaging has been demonstrated to be useful clinically in evaluating neurological diseases such as brain tumours, complex partial seizure disorders and dementia, myocardial viability and malignant tumours throughout the body. Several factors are responsible for this increased utilization of FDG-PET imaging, but its use in the evaluation of malignant tumours has had the greatest effect on its growth." (R. Edward Coleman MD and Ruth D. Tesar, 1997, "Clinical PET: Are We Ready?", The Journal of Nuclear Medicine, Vol.38(12), pp.16N-24N.)

A limiting factor is the availability of FDG. The majority of PET centres have a cyclotron and produce the FDG they use. Several centres have arrangements with industry to provide FDG for local and regional use. As at December 1997, there were 12 regional FDG distribution centres in the USA.

A new pharmacy network opened in mid 1996 to supply FDG to hospitals which do not have cyclotrons on site. This is PETNet Pharmaceutical Services, a joint venture between Syncor and CTI. It already had 100 customers as at January 1997 according to PETNet. At this time PETNet had 10 sources of FDG, using hospitals and universities. PETNet planned to have 25 sources within three years. (Deborah Kotz, 1997, "The Reinvention of PET", The Journal of Nuclear Medicine, Vol.38(1), pp.13N-26N.)

In 1996 in the USA, three camera companies introduced coincidence detection systems that can be added on to SPECT enabling FDG positron imaging (i.e. without the need for a dedicated PET camera). (Deborah Kotz, 1997, "The Reinvention of PET", The Journal of Nuclear Medicine, Vol.38(1), pp.13N-26N.)

According to Dr. Ernest Garcia, President of the Institute of Clinical PET, "Over the next year, the number of PET centers throughout the US could double ..." (Deborah Kotz, 1997, "The Reinvention of PET", The Journal of Nuclear Medicine, Vol.38(1), pp.13N-26N.)

CYCLOTRON PRODUCTION OF TECHNETIUM-99m

The Draft EIS (p.6-9) claims that in his 1995 paper, Lagunas-Solar concluded that cyclotrons cannot compete with reactors in the production of Mo-99 because yields are too low. The US DOE is quoted making a similar point. It does indeed appear that cyclotron Mo-99 production is not a short-term practicality, which leaves the option of direct Tc-99m production - the focus of the scientific research in recent years.

The Draft EIS (p.6-10) asserts that "In the last five years, since the Research Reactor Review, there have been no real advances towards the commercial production of Tc-99m using cyclotron technology and there has been little in the way of peer reviewed publications in this area." This is wrong on both counts. To give a concrete example of ANSTO's pathetic, juvenile, dishonest behaviour on this issue, Lagunas-Solar's experiments have demonstrated a purity of over 99.999% and on the basis of these results the Australian and New Zealand Association of Physicians in Nuclear Medicine has acknowledged that the presence of unwanted isotopes of Tc (the only impurity of any consequence) is "negligibly small". Despite this, ANSTO still insists that purity is a concern (with consequences for image quality and patient radiation dose), apparently on the basis that Lagunas-Solar's 1997 research results have not yet been published in a peer-reviewed journal. Needless to say ANSTO is quite happy to draw from sources other than peer reviewed journals when it suits. On what basis does ANSTO still claim that purity is still a concern?

Dr. Lagunas-Solar updated his internet site earlier this year. After analysing the experimental results, he concludes thus (http://crocker.ucdavis.edu/CNL/RESEARCH/chemistry.htm):

"Therefore, all the current results .... indicate that accelerator produced Tc-99m can be effectively produced with <25 MeV proton accelerators and used in labeling a wide array of known Tc-99m radiopharmaceuticals. Based upon existing radionuclidic composition data, the expected quality and resolution images performed with accelerator produced Tc-99m is expected to be no different from imaging conducted with generator-produced Tc-99m from reactor-produced Mo-99. Finally, several sources of enriched Mo-100 are available."

The Draft EIS (p.6-10) raises the familiar issues: specific activity, purity, and distribution logistics.

Purity.

The Draft EIS (p.6-10) notes that impurities have flow-on effects for patient dose and image resolution. As mentioned, concerns about purity have been put to rest by the 1997 research results.

Logistics of supply

The Draft EIS (p.6-10) quotes a 1997 Lagunas-Solar paper to the effect that cyclotron Tc-99m production "appears to be an alternative for local and regional production". Here we have another example of one of ANSTO's specialties - selective and misleading quotation. The spurious conclusion drawn from the above quotation is that a large number of cyclotrons would therefore be required. In response to such claims by Senator Ellison in the Senate in September, 1997, Dr. Lagunas-Solar (pers. comm.) says:

"With regards to Senator Ellison's comment that Australia would need to install a "large" number of accelerators, I have not made such a statement in my letter to the Honourable Prime Minister. It seems that this statement was his own conclusion from the previous statement regarding local/regional supply. I did not indicate what the local/regional supply would be as this question needs to be answered with input parameters I do not presently have for the logistics of transportation, population densities, medical center infrastructure, etc. Furthermore, in the Australian case, I am not aware of any serious effort to study the logistics and economics of such a system (combining commercially supplied Mo/Tc generators with accelerator-made Tc-99m) to serve the needs of Tc-99m across the nation. It seems clear that such a study should be made if serious consideration of these options is to be made."

Environment Australia must insist that the above quote from Lagunas-Solar is included in the Final EIS. So must the following quote drawn from a letter from Dr. Lagunas-Solar to Prime Minister Howard in September 1997:

"It is my understanding that my work has been reviewed by ANSTO, without the benefit of my direct participation, and clearly using outdated and/or incomplete information. ANSTO also provided statements to Parliament based on information (also out of date) available through our internet site. Based upon a general analysis of ANSTO's review, I strongly feel that it does not provide an objective and balanced review of the actual status and/or the conclusions of our work."

The Draft EIS (p.6-10) asserts that supply to rural and regional areas of instant Tc-99m would be problematic. The logistics of supplying Tc-99m is unlikely to be an insurmountable problem. Moreover it depends on parameters about which more information is required, in particular production yields and the necessary number and distribution of cyclotrons around Australia.

If ANSTO intends to make mention of its infamous "review" of the potential of cyclotron production of Tc-99m, then it should be noted that ANSTO (1997, pers. comm.) has told me that the so-called working group only met a couple of times, it went no further than a cursory literature review, no report was produced, and the working group has since been disbanded.

Does ANSTO stands by its own data (RRR submission) that 85% of nuclear medicine procedures are in the eastern seaboard state plus ACT? If so, this fact alone severely undermines their propaganda in relation to logistics of supply.

Yield

The Draft EIS (p.6-10) asserts that in excess of 10 cyclotrons would be required to meet Australian demand, with more required as demand grows, and this would not be the most "cost effective" way to supply this radioisotope. It is claimed that the unit cost could be as much as ten times as high.

The assertion that in excess of 10 cyclotrons would be required is dubious. Environment Australia will need to contact Dr. Lagunas-Solar to allow him to scrutinise this claim. ANSTO will need to provide the basis for its assertion.

Targets

The Draft EIS (p.6-11) asserts that there are two known suppliers of enriched Mo-100 targets, the USA and the CIS, "but neither is on a commercially proven scale".

The Draft EIS (p.6-11) then comments on the risks of relying on the CIS given the financial and organisational problems in that country and how reliance on the CIS would place the health care of the Australian public at risk. ANSTO/PPK (p.6-11) leap to the conclusion that a reactor is needed in Australia. There are several problems with these emotive comments:
o it overlooks the potential for alternative suppliers to be found
o it ignores questions such as these (which should be answered in the Final EIS): for what purpose(s) other than Lagunas-Solar's research is Mo-100 produced; could enrichment plants be encouraged to generate a supply of enriched Mo-100 if there is a steady demand; how many enrichment facilities exist around the world with the capacity to produce enriched Mo-100 targets, etc. etc.
o it ignores methods still under investigation which do not require the use of Mo-100 targets
o in leaping from the premise to the conclusion that an Australian reactor is necessary, it ignores the potential to import Mo-99 or to use spallation sources (including hybrid systems)
o a number of assertions are made without evidence or even reference.

Independent assessment

An independent assessment of the prospects for cyclotron and spallation/hybrid production of Mo-99/Tc-99 is required. Environment Australia should commission Dr. Gary Egan to conduct this investigation. Dr. Egan should be asked to do the following:
o assess the current status of overseas research projects into accelerator and spallation production of Mo-99/Tc-99m and other radioisotopes.
o relate this research to the Australian situation, taking into account issues such as logistics of supply, economics, etc.
o consider possible Australian contributions to the further development/commercialisation of cyclotron/spallation production of Mo-99/Tc-99m
o assessment of the prospects for importing Mo-99 as an interim measure, if HIFAR is shut down before full-scale commercial production of Mo-99/Tc-99m using cyclotrons or spallation sources is feasible
o evaluate the current and potential uses of cyclotrons and spallation sources for scientific research and industrial applications.

There is no dispute that Dr. Egan is very well qualified for the task. He has previously conducted research, and published several articles, on these topics. He has considerable expertise in cyclotron technology and was previously employed as the Chief Scientist at the Austin Hospital, Melbourne (which operates a cyclotron and PET centre). Currently, Dr. Egan runs a medical imaging consulting and software development company called Expert Imaging Systems.

No less importantly, Dr. Egan would be acceptable to all parties in this debate. Dr. Clarence Hardy from the Australian Nuclear Association said in his verbal submission to the Senate Inquiry: "I do not have any objections to Dr. Gary Egan; he has presented papers at our conferences, and he is a respected person." In response to Senator Forshaw's comment that it might be worthwhile to commission an independent consultant to study the prospects for spallation technology, cyclotrons, etc., Dr. Hardy said: "You could do that, and you could pay someone to do it. It should not take very long and it should not cost too much."

Most importantly, the technical details from the University of California (Dr. Lagunas-Solar's research team) need to be related to the Australian situation (Tc-99m demand, growth in demand, existing infrastructure, cost, etc). Dr. Egan carried out such an analysis in 1993 - it is included in Volume I of the Senate Inquiry's submissions, pp.137-148 (Inquiry's page numbering). A very similar analysis is required, using updated information.

Dr. Egan should also be asked to carry out an assessment of the Belgian spallation research, the prospects for importation of Mo-99 (as an interim or long-term measure), and current and future potential of accelerators and spallation sources for science and industry.

Dr. Egan is prepared to carry out this research.

CYCLOTRONS AND THE NATIONAL STRATEGIC INTEREST.

See the earlier comments on spallation sources and the strategic national interest.

Note that the Draft EIS completely ignores the possibility that a concrete non-proliferation initiative for Australia would be to take the lead in the development and export of non-reactor alternative technologies including cyclotrons.

CYCLOTRONS AND ENVIRONMENTAL HEALTH AND SAFETY STANDARDS.

ANSTO/PPK (p.6-15) say that "Cyclotrons are perceived by the public to be inherently safer than reactors because they are incapable of sustaining a nuclear chain reaction and because of their smaller radioactive inventory." Do ANSTO/PPK dispute these public perceptions? Do they dispute information supplied by the Australian Academy of Science (Senate Inquiry written submission) that there have been five fatal research reactor accidents around the world? Do they know of any fatal cyclotron accidents?