Abstract: Plutonium and uranium fallout from 15 nuclear tests conducted by the British government between 1961 and 1963 contaminated Aboriginal lands. Although the British government declared the Maralinga site safe following a 1967 cleanup, surveys in the 1980s proved otherwise, prompting a new cleanup project. Conflicts of interest, cost-cutting measures, shallow burials of radioactive waste, and other management “compromises” have left hundreds of square kilometers of Aboriginal lands contaminated and unfit for rehabitation. M&GS 2002;7:77-81.

“Claims that the clean-up of Maralinga is not to world's best practice are not well founded.” So said Dr. John Loy, CEO of the Australian nuclear regulatory organization, the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA).(1) This is a bold claim worth comparing with the outcome of the project.

The Cause of the Contamination

Maralinga is a tract of Aboriginal land in the state of South Australia that was commandeered by the Australian government to be used by Britain for the development of atomic bombs. The Australian government had its own aspirations to possess nuclear weapons and perhaps hoped that this would be an avenue for their acquisition.(2, 3)

Seven atomic bombs were exploded at Maralinga; perhaps 25% to 30% of the plutonium in those devices would have been fissioned. The remainder would have been spread around the ground zeroes, or carried into the air to be deposited later as fallout. Many development trials were also conducted at three sites within Maralinga — Taranaki, TM, and Wewak. Those at the two latter sites resulted in plutonium spread over relatively small areas but a series of trials at Taranaki, code named Vixen B, were much more damaging.

There were 15 Vixen B trials, all conducted in the period from 1961 to 1963. In twelve of the tests, both plutonium and uranium were in the radioactive mix; the other three contained only uranium. In each trial, a nuclear device was placed on a large steel structure known as a featherbed, erected on a concrete firing pad. The device was detonated in a manner that prevented a nuclear explosion. The heat of the explosion melted the plutonium and uranium and shot radioactive debris up to 1,000 meters into the air, where it was caught by the wind and spread far and wide. The featherbeds were severely damaged and contaminated and were buried along with the firing pads.

Following these tests, hundreds of tons of contaminated steel, concrete, and other items were reported to have been buried in 21 shallow pits at Taranaki, and hundreds of square kilometers of land were contaminated with plutonium and uranium.

In 1967, the British conducted Operation Brumby — a “final” cleanup of the site. The Australian government accepted that, except for some small fenced “islands,” the site was clean and absolved Britain of any further responsibility. Surveys in the 1980s by the Australian Radiation Laboratory showed that the site was far from clean and safe and their findings led eventually to the latest cleanup project.(4)

The Planned Cleanup

From its inception, the nuclear industry has had problems with worker and public safety and with environmental degradation. Too often these problems have been caused by ineffective management, cost-cutting measures, or ineffective regulation. The Maralinga project reflects all three of these factors. The public servants responsible for the last years of the project had no background in radiation or project management, as is illustrated by several statements they made on the public record, asking, for example, what was meant by alpha radiation, or how to convert a milliSievert (a unit of radiation dose) to a picoCurie (a unit of radioactivity), or claiming that soda ash is neutralized by limestone.(5-7)

Project records also reveal suggestions by ARPANSA (e.g., encasing the debris in concrete) to which the contractor objected on the grounds that they would be difficult to implement. The recommendations were then dropped (5-7) despite the principle that the regulator should stipulate requirements, not make suggestions. Responsibility for the cleanup was vested in the Commonwealth Department of Primary Industries & Energy (later Industry, Science & Resources). ARPANSA was contracted to the Department, so was not independent — another failing.

The plan was generally along the lines of a scheme that had been developed some years earlier (8) and from the beginning was intended to be a partial cleanup, which was a compromise. The more contaminated soil was to be scraped up and buried and some pits were to be exhumed and the contents buried more securely. The pits at Taranaki were to be treated by a process of in situ vitrification (ISV).

ISV uses electricity to turn the soil and pit contents into a hard, glass-like rock, which contains and immobilizes the plutonium for thousands of years. The process has to be tailored for each site, and the Australian government signed a contract with Geosafe, Inc. in the US to match the technology to the Maralinga geology.

Setting Cleanup Standards

The criteria to be met after the contaminated soil was removed were set at a meeting of half of the Maralinga Rehabilitation Technical Advisory Committee (MARTAC), which was established to advise the Minister on the project. Each member of the Committee was contracted to the Department. At Taranaki, the criteria were to remove soil until the surface reading was less than 3kBq (Am-241) per m2. Variations in the ratio of plutonium to americium led to slightly different criteria for the other sites. There were also criteria for the removal of contaminated fragments and particles of plutonium, thereafter referred to by ARPANSA as MARTAC criteria.

MARTAC also prepared some draft criteria for the ISV product, but these were not incorporated into the contract with Geosafe.

Removal and Burial of Contaminated Soil

The removal and burial of soil was a simple civil engineering exercise with an overlay of health physics to protect the workers. Contaminated soil was collected by large scrapers and placed in trenches up to 16 meters deep. The top of the contaminated soil was no higher than three meters below the ground surface and was then covered by at least five meters of clean soil. Dust was a major problem and its suppression at Taranaki was not satisfactory, with the result that thousands of tons of contaminated soil simply blew away. With a change of approach, dust suppression during soil removal at the other two sites was excellent.

Nineteen of the 21 pits at Taranaki were reported to have been covered by concrete caps. As the soil was removed, however, a huge amount of plutonium-contaminated debris was uncovered outside the pits. Much of the debris was covered by only a few centimeters of soil. One cap was about one fifth of the required size and another was several meters away from the pit. The impact of this discovery was that the ISV project would have to be expanded so that all the debris could be treated, at increased cost.

Change of Management Structure

The project management structure was changed in mid 1997. The company that had been awarded the contract to manage the earlier parts of the project was purchased by another company (GHD) that had not made the final six considered for the project management contract. Before the end of 1997, GHD persuaded the Department that it should manage the whole of the project, not just the part that it had purchased. Three meetings were held in secret between GHD and the Department to discuss this takeover. The participants at these meetings were two people from the Department whose only knowledge of ISV was one half-hour visit to see some of the equipment, and two people from GHD who did not have even that meager knowledge. The Commonwealth’s Representative overseeing the whole project was excluded. The most expensive and most complex part of the whole project was decided by four people who were totally ignorant of what was involved. There are no notes of these meetings on record.

The outcome was that GHD was appointed both Project Manager and Project Authority even though the company was not qualified for either position. At the same time, the Commonwealth’s Representative was removed from the project. So the Department had no one in either its own ranks or on the project manager’s team with any knowledge of ISV. This was a recipe for disaster.

Treatment of Contaminated Debris

All of the Taranaki pits were to have been treated by ISV and a contract for this work was placed with Geosafe. Initially the 21 pits would have required 26 “melts” but, with the discovery of the large amount of debris outside the pits, the whole project would require 40 melts. The ISV equipment was built and tested and was transported to site at the beginning of 1998. Treatment of pits started in May of that year.

At that point, the absence of ISV expertise within both the Department and GHD became even more apparent. Into this vacuum stepped the Minister’s advisory committee MARTAC, which met only three or four times a year. This committee had expectations and requirements that were not contractual and were constantly changing. Moreover, the government at this time was seeking ways to reduce the cost of the project and adopted a hybrid scheme in which eight pits would be exhumed and the contents sorted. Some debris would be vitrified in a specially prepared “pod” and the remainder simply buried. The strange thing was that sorting was done by size, not level of radioactivity, so highly radioactive particles would be buried while slightly contaminated debris would be vitrified.

Another peculiar aspect of the ISV part of the project was that ten melts had been completed before agreement was reached on any acceptance criteria, and even then the criteria were rather impractical since some could not be confirmed.

It was quite clear in early 1998 that problems were looming for the project. This was relayed to the then Minister, Senator Parer, but no action was taken.(9) As treatment of Pit 17 (the eleventh melt of the series) was nearing completion, there was an explosion within the melt that severely damaged the equipment and spewed molten glass some 50 meters from the pit. The Department used this incident as an excuse to cancel the ISV contract after having spent 40% of the project budget on the scheme. This decision was taken long before the investigation of the incident was complete. The Department claimed that it could not be sure that the cause of the accident was not due to the process(10), but both the report of the investigation and the audit of that report agreed that the cause was something in the pit, not the process.(11)

Although the government claims that the project was conducted in full consultation with the South Australian Government and the Maralinga Tjarutja, this decision and other key decisions were made without any consultation.(12)

Once vitrification had been abandoned, all debris from the pits that had not been treated was placed in a shallow trench, covered with the solidified vitrified material and then covered with only two meters of soil to grade, with a further three meters of soil above grade. There is no reliable record of what has been buried. Nine firing pads reported by Carter (13) to be contaminated with up to 1 kg of plutonium are not mentioned in the report of burials.(14)

The Department has claimed that burial is a safe disposal method consistent with “the Code.”(15) This was the first time that the Code had been mentioned in relation to the project. When three of the five authors said that it was not applicable (the other two were Commonwealth public servants and would not comment), the Department claimed that it did not have to follow the Code but had chosen to do so. (16) It made this statement despite the fact that not a single requirement of that Code was satisfied.

The government claimed that cost played no part in the decision to opt for burial of the debris. Senator Minchin said: “Can I refute the scurrilous suggestion which I see floating around in the media that suggests that this decision was made on cost grounds.”(16) This is at odds with the statement: “The recent consideration of alternative treatments for ISV for these outer pits has arisen as a result of the revised estimate for ISV being considerably above the project budget.”(17)

The Department also claimed that ISV was abandoned because the amount of plutonium in the pits was less than expected. In fact it was very close to what was assessed at the MARTAC meeting of November 1995 (18), seven months before the contract for ISV was signed.(19,20) This and many other misleading or incorrect statements by the Minister and his Department were exposed.(21)

Since the explosion at Maralinga, the world license for the technology has been purchased by the very large engineering firm Amec, which has been awarded contracts by the US Department of Energy to treat pits containing plutonium debris. There is also keen interest in the technology in several European countries and in Australia.

Cost of the Cleanup

The budget for the cleanup was $Aust 104.4 million (1994 dollars), of which about half was an ex gratia payment by Britain. The British contribution was a mere pittance compared with what it cost to spread the contamination in the first place. If an oil tanker runs aground and its contents are spilled, the owners face huge fines and are required to pay for the cleanup. In the case of the oil tanker, the contamination is accidental. In the case of Maralinga, the contamination was deliberate. Moreover, had the plutonium debris been returned to Britain, the authorities would not have allowed disposal to be undertaken in the same way as was done at Maralinga; the contaminated material would have been placed in a concrete-lined vault.

The Outcome

Dr. Loy was incorrect in saying that the Maralinga cleanup project represented the “world’s best practice.” The project was a compromise from the beginning and was never intended to be a total cleanup. There are still hundreds of square kilometers of land contaminated with plutonium. The government says that all but 120 km2 are now safe, but this is misleading. What they mean is that 120 km2 of land are still contaminated above 3 kBq Am-241/m2. At that level, an Aboriginal living a semi-traditional lifestyle would receive an effective dose of 5 mSv/a (five times that allowed for a member of the public). Within the 120 km2, the effective dose would be up to 13 times greater.

The plutonium-contaminated debris is buried in a bare hole in the ground in limestone and dolomite which exhibits many cracks and fissures, with only two meters of cover to grade. Even burial at a greater depth would be an improvement. At least one member of MARTAC and the regulator at ARPANSA have admitted that encasement in concrete would be an improvement. And every member of MARTAC has agreed that vitrification is a far superior solution.(22)

What has been done at Maralinga in the burial of long-lived, plutonium-contaminated debris can be compared with the government’s plans for the disposal of other radioactive waste. After several years searching for a site with suitable geology, the government recently selected one for the disposal of short-lived, low-level waste and the storage of short-lived, medium-level waste. The low-level waste is to be packaged in drums and placed in a disposal facility with a solid base and then covered by several impervious layers. If such precautions are necessary for short-lived wastes, the disposal of long-lived wastes in a bare hole in the ground in totally unsuitable geology at Maralinga cannot possibly be “world’s best practice.”

In July 2001, the Department issued a discussion paper (23) addressing the safe storage of radioactive waste. In two places in that paper, the Department states that long-lived low- and intermediate-level waste is not suitable for near-surface disposal, and yet that is exactly what they have done at Maralinga.

Concluding Comment

The Aboriginals wish to return to the land, provided it is safe to do so. They have been advised that some of the land is not suitable for permanent occupation and 450 km2 is encircled by boundary markers to remind them that this is so. The boundary markers might have a life of 50 years, but half of the plutonium will still be there in 24,000 years.

Whoever accepts responsibility for the site should recognize that they will have to rely for several thousand years on assurances from a government that has not kept to agreements made only ten years ago.

References

1. Loy J. Maralinga cleaned up to acceptable standards (media release). Australian Radiation Protection and Nuclear Safety Agency (ARPANSA). April 17, 2000.
2. Reynolds W. Australia’s bid for the atomic bomb. Melbourne: Melbourne University Press. 2001.
3. Cawte A. Atomic Australia. Sydney: University of New South Wales Press. 1992.
4. Lokan KH (ed). Residual radioactive contamination at Maralinga and Emu, 1985. Australian Radiation Laboratory, ARL/TR070. April 1985.
5. Hearings before the (Australian) Senate Community Affairs Legislation Committee. May 2, 2000.
6. Hearings before the (Australian) Senate Economics Legislation Committee. May 3, 2000.
7. Parkinson A. Submission to the Senate inquiry into the contract for a new reactor at Lucas Heights. September 2000.
8. Department of Primary Industries & Energy. Rehabilitation of former nuclear test sites in Australia. Report by the Technical Assessment Group. Canberra. 1990.
9. Letter to Senator Parer, Minister for Primary Industries and Energy (personal communication). May 31, 1998.
10. Minchin N. Minister confirms Maralinga is safe (media release). April 17, 2000.
11. Geosafe Australia. Investigation into the explosion during treatment of pit 17 at Maralinga. GSC-030101. Adelaide. June 2001.
12. Minutes of the Consultative Group Meeting. June 23, 1999.
13. Carter RF. Residual plutonium contamination at the former Maralinga range in South Australia, a preliminary note. AWRE, Aldermaston. June 1985.
14. Maralinga project pit exhumations, plutonium inventory in the burial trenches. Project Report by CH2M Hill. August 1, 1999.
15. Code of practice for the near-surface disposal of radioactive waste in Australia. Radiation Health Series No 35. Australian Government Publishing Service. 1992.
16. Minchin N. Response to certain issues raised by Radio National’s background briefing (media release). May 1, 2000.
17. Maralinga Rehabilitation Technical Advisory Committee. Cost comparison for treatment of outer pits (paper prepared for the 12th meeting of MARTAC). October 1998.
18. Maralinga Rehabilitation Technical Advisory Committee. Minutes of MARTAC meeting. November 1995.
19. Parkinson A. Maralinga: clean-up or cover-up? Australasian Science 2000;21:16.
20. Parkinson A. Maralinga rehabilitation project. Presentation at national conference, Medical Association for Prevention of War. Canberra. August 6, 2000.
21. Parkinson A. Maralinga rehabilitation project, dissection of statements made by the Minister or his department. September 2001. (Unpublished; available from author).
22. Notes of the Consultative Group Meeting, 8 May 1999.
23. Department of Industry, Science & Resources. Safe Storage of Radioactive Waste. The National Store Project: Methods for Choosing the Right Site. A Public Discussion Paper, July 2001.

Robyn Williams: This will be a sorry tale, one of arrogance and neglect. That’s the opinion of Alan Parkinson who has over 40 years’ experience as a nuclear engineer in three continents; he was employed by the Atomic Energy bodies in Britain, Canada and Australia. His concern first appeared in Australasian Science magazine in [August] and they’ve since been argued about with the Federal Government in the pages of The Australian Financial Review. Alan Parkinson says that the clean-up at Maralinga was inadequate. He also has some thoughts about the proposals for Lucas Heights where our new reactor is to be set up. See what you think.

Alan Parkinson: What’s the connection between Professor Ernest Titterton, Senator Nick Minchin and Dr John Loy? Don’ know? Then let me ask what’s the connection between Lucas Heights, Evetts Field West and Maralinga? The answer to both question is the last named place, Maralinga, the old atomic bomb test site in South Australia.

After exploding seven atomic bombs at Maralinga, the British returned to the site known as Taranaki in 1961 to carry out 15 trials code-named Vixen B. In these, an atomic bomb was placed on a heavy steel structure erected on a concrete firing pad. The bomb was exploded in a manner which prevented a nuclear explosion, but the heat of the chemical explosion melted the plutonium core, and the force was sufficient to hurl molten plutonium and uranium up to 1,000 metres into the air. The wind then carried the molten cocktail many kilometres downwind, and contaminated hundreds of square kilometres of land in three plumes generally to the north of Taranaki.

The explosion damaged and contaminated the steel structures so much that none could be re-used, so they were buried in shallow pits, together with all of the other plutonium contaminated debris, including the concrete firing pads, and covered by thick concrete caps.

At that time Ernest Titterton was a member of the Atomic Weapons Tests Safety Committee, set up to advise the Australian government of the day on the safety of the British trials. The English-born Titterton had earlier been a member of the British group who worked on the Manhattan Project, which was announced to the world in an horrific way at Hiroshima. Because of his background, some have suggested that Titterton did more to represent Britain in safety committee matters than he did Australia.

In 1967, the British Army conducted their final clean-up of Maralinga in Operation Brumby. When that clean-up was finished, Titterton and others from the committee visited Maralinga to see what had been done. He and his colleagues were said to be ‘extremely satisfied’ with what they were shown. Jolly good show chaps, job well done. On the word of this committee, the Australian government absolved Britain of any responsibility for the site, and everybody was happy, except the Aboriginals whose land it was.

I have always marvelled at the ability of that committee to be able to say job well done, when they had no knowledge of where the contamination lay, nor how the debris was buried.

In the mid-1980s, scientists from the Australian Radiation Laboratory scoured the site and found that it was far from satisfactory. Their findings, coupled with the conclusions of the McClelland Royal Commission in 1984, led to the latest clean-up.

Basically what was done in this latest effort was to scrape up the most contaminated soil and bury it at least three metres below ground. But as the soil was scraped away from Taranaki, huge amounts of plutonium contaminated debris were uncovered. The debris pits were in fact very much larger than the British reports indicated. The concrete caps supposedly covering the pits were far too small and two were several metres away from the pits they were supposed to cover.

Had the Titterton committee been more involved, as they should have been, they could not have said ‘jolly good show chaps’. And because they accepted something on which they had no knowledge, they left Australia with a legacy for future clean-ups. Although Britain did contribute about half of the cost of the latest clean-up, when the disgraceful state of the pits was discovered, Australia had no lever to seek a further contribution from Britain.

In the latest clean-up, the Taranaki pits were to have been treated by a process of in situ vitrification, or ISV for short, which uses electricity to convert the pit contents to a hard glassy rock to immobilise the plutonium for perhaps a million years. The discovery that the pits were much larger than reported meant that the ISV treatment was going to cost more than had been estimated. Senator Minchin’s department then sought ways to reduce the cost, and they embarked on a hybrid scheme by which eight larger outer pits were exhumed and their contents buried in a shallow grave, while vitrification of the inner pits proceeded. After completing 12 of the planned 40 melts, fate came to the government’s rescue. As the 13th melt was nearing completion, something in the pit exploded. The equipment was badly damaged and molten glass was thrown some 50 metres from the pit. The government used this as an excuse to cancel the ISV project and then exhumed all of the pits, including those that had been vitrified, and simply buried the debris. This option was approved by Dr Loy, the chief of the nuclear regulator, ARPANSA. So a process which was agreed by all concerned to be a far superior option was abandoned for one that would not be allowed in Britain, the birthplace of the plutonium.

By now you are probably wondering where Lucas Heights and Evetts Field West fit into this story. As is well known, there is to be a new nuclear research reactor built at Lucas Heights, and Dr Loy said he will not grant a licence for the reactor until there is a method to dispose of the nuclear waste.

For several years, the government has been seeking a site for a nuclear waste repository and the preferred site is Evetts Field West in South Australia. A particular consideration in this selection process is the geology of the site. A visitor to the government’s website can see a cross-section of the proposed repository. Short-lived wastes will be packed in drums and placed on a compacted foundation up to 20 metres below ground. The drums will then be covered by several impervious layers before a covering of soil to ground level. While this is an acceptable design for short-lived wastes, I must ask why is it necessary?

On 17th April, 2000, the day after the Maralinga clean-up was the subject of an ABC Radio National broadcast in the Background Briefing series, Dr Loy issued a public statement. He said: ‘Claims that the clean-up of Maralinga is not to world’s best practice are not well founded.’ So the disposal of long-lived plutonium-contaminated debris less than three metres below ground in a bare hole in totally unsuitable geology is world’s best practice? If that is world’s best practice for long-lived waste, then it must be so for short-lived waste. And if that’s the case, why is the government going to so much trouble to find a suitable site and then package the waste and cover it with impervious materials in a purpose-built facility? Why not simply dig a hole in the ground, anywhere will do, drop it in, and cover it? Dr Loy has said that is world’s best practice, and he is the chief regulator. The current Science Minister, Mr McGauran, went one step further in a recent broadcast. He said they had exceeded world’s best practice!

I should add that Dr Loy was not the only person to make strange comments about Maralinga. For example, in Senate Committee hearings we heard public servants declare that soda ash is neutralised by limestone, and that the limestone is rich in sodium and carbonate; no mention of calcium. We also heard that some plastic sheeting covering the plutonium debris will have a life of a few thousand years. Another strange pronouncement was that an estimated radiation dose of 1 milliSievert per annum includes the background radiation of 2.3 milliSieverts per annum. Even more astonishing is that the dose of 5 milliSieverts per annum which could be contracted on land contaminated with 3 kiloBequerels of Americium per square metre, and on which the project was based, suddenly dropped to 1 milliSievert per annum, even though no work was done where that level of contamination exists.

Dr Loy’s view is also at odds with Senator Minchin’s advisory committee who all agreed with me when I was a member of that committee, that ISV is a far superior method of disposal. But the real cruncher to his view is provided by the department itself.

Over the years, the government has been searching for a site for the repository and a store for intermediate level waste, and has issued several documents for public comment. The latest publication was prepared by the National Store Advisory Committee whose membership includes a representative from ARPANSA. Twice in that document we are told that long-lived waste, whether low level or intermediate level, is not suitable for near-surface disposal, but that is exactly what has been done at Maralinga which the regulator describes as world’s best practice. The paper asserts that in time, such debris should be disposed of in a deep geological facility.

Add to this the fact that ARPANSA did not have a representative on site when the Taranaki pits were exhumed and the plutonium debris buried, so they have no idea what has been buried, nor how much radioactivity is contained. For this, they relied on the word of the contractor. That was what Ernest Titterton did many years ago and his credibility was shattered when the contaminated soil was removed and the plutonium debris found only a few centimetres below the surface.

While I am not opposed to the construction of a new reactor at Lucas Heights, there are many who are. When they hear the regulator’s view of what constitutes world’s best practice, they must question whether he holds similar views about the new reactor and everything associated with it. And when they consider the technical competence of those within the department who are responsible for the repository, it’s not hard to understand their opposition. That opposition will surely continue until the government and the regulator set their houses in order and show some consistency and competence in dealing with nuclear matters.

Robyn Williams: Alan Parkinson, who has worked with the Australian Atomic Energy Commission and its sister bodies in Britain and Canada in a nuclear career spanning 40 years. Sir Ernest Titterton is the voice you hear on countdowns for the first ever test explosion during the Manhattan Project.

Guests:
Alan Parkinson
PO Box 415, Hawker ACT 2614
<[email protected]>

The engineering consultancy firm of Gutteridge, Haskins and Davey (GHD) has received two awards for their ‘management’ of the Maralinga project. They received the inaugural award for project management from the Australian Institute of Project Management and a Gold Merit Award for Project Management from the Association of Consulting Engineers Australia. These two awards carry some prestige and are treasured by engineering companies as marketing tools.

The question is: "Did they deserve these awards?" Anyone who visits the GHD web site can read the write-up by Bob Rosenbauer which supposedly describes what GHD did on the Maralinga project. It is a reasonable assumption that something similar was contained in the submissions for the awards. However, several statements in the GHD write-up are at best questionable, and some are simply not true. There are several other matters that are not in the write-up, and which were almost certainly not contained in the submissions since they would detract from GHD’s case for the awards.

The most obvious incorrect statement is that GHD was appointed by the commonwealth government in April 1994. GHD was not awarded the contract; that privilege went to Australian Construction Services (ACS). The ACEA at least should have known this fact since they objected to the appointment through their then chief executive Geoff Crittenden. GHD were not even invited to tender; in fact they did not make the final six for consideration. GHD came to be involved in the project by way of their purchase of ACS under the government’s privatisation scheme in August 1997, when the ACS contract was coming to a close, apart from provision of some ongoing support services. So the first half of the project, which was reasonably successful, was managed by ACS and GHD had no involvement in any way. Therefore that part of the project should not have been considered by ACEA or AIPM.

There are many examples of work which could be described as less than satisfactory which would not have been included in the submission. For example ACS mis-read the coordinates of the soil removal boundary with the result that one piece of land which should have been scraped was not touched and has not been cleaned. There would have been two pieces, but the Australian Radiation Laboratory (ARL) spotted ACS’s second mistake in time to correct it.

There were several examples of ACS lacking in supervision of their sub-contractors. It was a constant complaint that there was inadequate dust suppression when soil removal was in progress at the Taranaki site. This is shown on the official video record of the project. There were many occasions when work had to stop because the dust was so thick that it would have been dangerous to move the heavy scrapers, bulldozer and water carts. On at least one occasion, the health physicists evacuated the forward area facilities (change rooms, offices, laboratory, workshop, etc) because the dust was so thick that they considered it a radiological hazard to the workers, and yet the work area was almost two kilometres away. Even though the department agreed to pay for an additional water cart ($100,000) ACS never pushed their subcontractor to supply it. The soil removal contractor, Thiess, received the 1998 Case Earth Award for their work at Maralinga. Yes they cleared contaminated soil from the Taranaki site, but tens (perhaps hundreds) of thousands of tonnes of contaminated soil simply blew away. By way of illustration as to how much soil blew away, there was a contaminated fragment lying on the surface about 3 metres beyond the soil removal boundary, but when the health physicists went to remove the fragment after soil removal was complete, they found it was covered by about 600 mm of soil. To compound the matter, Thiess then put in a claim because the amount of soil collected was outside the limits on which they had based their estimates. ACS accepted the claim and paid Thiess thousands of dollars in compensation for not collecting the soil they had already paid them to collect.

Collecting the final bits of contamination to meet the clearance criteria was always going to be difficult and ACS sat by while Thiess tried to remove the final contamination using a grader followed by a scraper. This was never going to work - it was like trying to pick up flakes of talcum powder from rocky ground using the blade of a grader. In the end ACS had to be instructed to instruct Thiess to take a road sweeper to site and use the vacuum cleaner to remove the contaminated dust.

In fairness to Thiess, with a revised method of working, their work at the other two sites (TM and Wewak) was excellent and worthy of the Case award.

As the project moved into the soil removal phase, Thiess persuaded ACS to operate under a system of partnering. A Partnering Charter was established as stated in the GHD write-up, but whether that was instrumental in maintaining morale is another question. Because of the way that GHD engineered their take-over of the ISV part of the project (see below) morale was at a low ebb for the final two years of the project.

The web site tells us that GHD did not favour use of respirators due to the risk of reduced visibility and heat stress, but they insisted on using them at every opportunity. In fact, there was a complaint by the Department’s Representative about the over-use of respirators; for example, the health physicists wore them whenever they went outside to check incoming heavy equipment, and yet only a matter of a few metres away, non-designated workers walked around without any protection.

The web site also says that adequate records were kept of radiation doses for all radiation workers, but the records might not be complete. In at least one case, a person was asked to supply some information again after he had left the project. It also took them eighteen months to realise that person had not attended final lung monitoring and medical, something that should have been done immediately on leaving the project.

It is doubtful if GHD mentioned the case of the contaminated worker who travelled from Maralinga to Melbourne wearing a shirt contaminated with plutonium. While that was discovered, there was no checking of that person’s home, washing machine and the like, and there was no attempt to check if there had been other similar instances. It was simply claimed that the worker did not follow procedures. There was certainly a break-down in procedures because there should have been a detailed inquiry by GHD and its health physics subcontractor.

It is also probable that GHD did not mention the proposals for upgrading the road to Taranaki for an estimated cost of $1.7 million. This was rejected by the client’s representative. A solution was then provided which cost only $700,000.

And they certainly would not have mentioned the re-surfacing of the tennis courts. When the contractor was eager to finish before the Christmas break, ACS allowed him to adopt a technique that was not in accordance with the contract. The surface would break up merely by walking across the courts. This was raised with higher management and after being told to go back to the specification and redo the courts, and not to depart from the specification without discussing it with the client, the parties met at site. ACS then said they wanted to use another method altogether.

Quite separately from the contract with ACS, in 1995 the commonwealth awarded a contract to Geosafe Australia to treat 21 pits which contained plutonium contaminated debris, by a process of in situ vitrification (ISV). By some mysterious means, at the end of 1997, GHD managed to persuade the commonwealth department that they should manage the application of ISV, even though they were not qualified for such an appointment.

From first being appointed, ACS had expressed their view on several occasions that they should be appointed project manager over the whole project. This was mostly aimed at the final phase of the project, the in situ vitrification of those 21 pits. There were many reasons why they should not be appointed and their suggestion was always rejected. By the time GHD bought their way onto the project, the project management team had already demonstrated that they would not be suitable to manage the ISV part of the project. They even expressed the view in writing that they should manage the Department’s contract with the ARL. Imagine that - a contractor managing the regulator!!! Not only did ACS have no knowledge of the complex ISV technology and equipment, they had never even seen the equipment, nor had they been involved in any way in the three year development project to match the technology to the Maralinga geology. Add that some of their performance in earlier parts of the project could be described as less than satisfactory, and there was every reason to reject their overtures. Towards the end of 1997, yet again but under the new hat of GHD, they suggested that they should take over the whole project. This take-over was accomplished in at least three meetings held in secret between two people from the department and two from GHD. The Department’s Representative overseeing the whole project was excluded. The decision to extend GHD’s contract in the most unusual circumstances was made by two people from the department whose only knowledge of ISV was a half-hour visit to see some of the equipment during fabrication, and two from GHD who did not have even that meagre knowledge. Further, those from the department had absolutely no experience in project management, no experience in dealing with contractors, and virtually no knowledge of radiation. The proposal by GHD to take over management of the project was a flimsy, four-page submission which highlighted that they did not know anything about what they would have to do.

Alan Parkinson, the Department’s Representative overseeing the whole project, was asked to comment on the flimsy proposal. He advised that the GHD submission was no basis for extending their contract. According to the department, he was opposed to GHD’s appointment but instead of asking him why, they simply removed him from the project. This left the department with nobody with either project management experience or any knowledge of ISV. This was a recipe for disaster and so it turned out. Even though the meetings between the department and GHD were held in secret and no records were kept, one thing that is certain is that GHD was given a copy of the commonwealth’s contract with Geosafe Australia (a confidential document), the company which was to carry out the ISV work. This was done without Geosafe’s permission to release the contract and without telling Geosafe that such moves were afoot. Such underhand dealings should be deplored, especially as both ACS/GHD and the department had agreed to the Partnering Charter which, among other things, required all parties to deal honestly and openly.

Since there is no record of the meetings, it remains a mystery as to how GHD managed to persuade the department to award them a contract for which they were totally unqualified. But even with their record on the project and the fact that they knew absolutely nothing about ISV, persuade them they did.

When it was announced that GHD would be appointed, even before they had been asked to submit a proposal for the work, there was outcry from Geosafe. In their correspondence Geosafe several times pointed out that GHD had no knowledge at all of the complex technology, and were therefore not suited to the task. There is no explanation of why the department ignored this objection.

In the event, GHD were not only appointed Project Manager, they were also appointed Project Authority. So they were then in a position to give technical direction to Geosafe. The world’s experts in the technology were under the direction of a company with no knowledge or experience. It must be unheard of in the engineering profession for a company to be appointed Project Manager of a project of which they had no knowledge or experience, but to have been appointed Project Authority as well is simply astonishing. If GHD was assessing tenders for work on a project, would they award the contract to some-one with no knowledge or experience?

The department used the device of extending the GHD contract to avoid open tendering and, as admitted in Senate Committee hearings, they did not even negotiate the extension.

GHD said in their submission that the cost of their services for this new appointment would be "of the order of $0.25 million". By the end of October 1997, when their initial contract was drawing to a close, GHD had received $2,833,982 for their services for Phase 2 (the actual clean-up). At the end of May 1999, when there was still over a year to go, they had received $5,070,000. So, far from receiving $250,000 as quoted, they had been paid $2,236,018 - ten times what they quoted. At the same time their budget for project management services rose by over $6 million.

Partly because of the way that GHD took over the project, and partly because they knew absolutely nothing about the work, project relations were severely damaged, and never recovered.

When GHD made their flimsy offer, they said they would undertake a review to identify areas of risk to the commonwealth, but they avoided mentioning that the greatest risk was the appointment of GHD in the first place. When making this review, they either failed to notice, or made no attempt to rectify, the fact that there were no acceptance criteria in the contract with Geosafe - a basic requirement in any contract. Eventually, after ten melts had been completed, there were some agreed criteria.

Shortly afterwards, as treatment was near completion at one of the pits, there was an explosion within the melt. The department used this as an excuse to cancel the ISV project, claiming that they could not identify the cause of the explosion, even though two investigations came to basically the same conclusion. They then claimed that it might not be safe to continue with the technology and cancelled the contract with Geosafe, after having spent about a third of the project budget of $108 million on the scheme. They were advised in this by GHD, for example at a meeting with the department on 15 April 1999, GHD "advised that if work has to be discontinued then this should be able to be achieved contractually without a formal termination as Geosafe had received more than their initially estimated income and fee from the project." Such extraordinary advice from a company claiming to be proficient in project management. The contract was to treat 21 pits, not to earn a specified sum of money. It was towards the end of 2001 before agreement was reached with Geosafe for the cancellation of the $35 million contract - two and a half years.

Whatever the department claims about the safety of the ISV process, it is a fact that project records show that the contract was cancelled as a cost cutting exercise. The process which everybody agreed was the best technology available for immobilising the plutonium was abandoned in favour of a system which the department’s own documents say is not acceptable, as illustrated below.

It seems that no opportunity was missed to denigrate Geosafe and the ISV process. In the aftermath, considerable play was made of some un-melted steel in one of the ISV blocks. There should not have been any criticism, since there was never any requirement, contractual or otherwise, to melt all of the steel. That particular case had added interest because of the instruction received by Geosafe from GHD. The instruction was sent by fax and stated: "This fax provides written confirmation of the advice to terminate melt 8, Pit 15 today. This decision is based on careful consideration of the data provided ..." In other words, GHD instructed Geosafe to stop treatment of that pit and then allowed criticism of the un-melted steel.

A few days after the explosion, and while there was an investigation in progress to attempt to identify the cause, the GHD sub-contractor, Thiess, exhumed a sealed drum from one of the pits. It was immediately buried again. When asked about this, neither the Department, ARPANSA, nor MARTAC knew that a drum had been uncovered. The people who were supposed to be overseeing the project knew nothing about it and yet it could have provided valuable input to the investigation and could have given a lead in identifying the cause. But GHD simply buried it again and one must ask what they were hiding. This episode also demonstrated the lack of supervision by the department and the regulator ARPANSA.

It could be noted that when the explosion occurred, Geosafe was in the middle of a demonstration melt for the US Department of Energy. Unlike the situation at Maralinga, the client had some understanding of the ISV technology and were impressed with the technique. The USDOE then awarded Geosafe a contract to treat a plutonium contaminated pit in the USA.

It could also be added that the Geosafe subcontractor, Amec, was also so impressed that they have purchased the world licence for the technology and are now actively seeking work to treat all kinds of hazardous substances.

When the ISV contract was cancelled, GHD undertook a scheme that they had wanted all along. This was to exhume the debris pits and place the debris in a deeper hole. They could understand digging holes in the ground and filling them up again. The GHD web site tells us that the debris was removed "for deep burial" but this is quite wrong. The code of practice behind which the commonwealth department has tried to hide regards anything within 30 metres of grade as being NEAR SURFACE disposal. See Code of Practice for the Near-surface Disposal of Radioactive Waste in Australia (1992). For the record, the plutonium contaminated debris buried by GHD is only 2 metres below grade.

It should be noted that three of the five authors of the code say that it was not written for a Maralinga type situation; the other two were commonwealth public servants and were obviously constrained. In any case not a single requirement of the code was satisfied.

A recent publication by the department says that shallow burial is not a suitable route for disposal of long-lived radioactive waste. See Safe Storage of Radioactive Waste. The National Store Project: Methods for choosing the right site. A Public Discussion Paper, July 2001. In two places in that document, the department states that low level and intermediate level long-lived waste is not suitable for near surface disposal. And yet that is exactly what GHD has done at Maralinga. Whether the plutonium contaminated debris is classed as low level or intermediate level does not matter, with a half-life of 24,000 years, it is certainly long-lived.

It is interesting to note that had the debris been returned to Britain, the source of the plutonium, it would not be allowed to be disposed of in the manner that GHD adopted.

It is possible that GHD nominated some referees with their submission. If they were people from the Department of Industry, Science and Resources, then their view would have been worthless. Nobody in that organisation connected with the project had any experience of project work let alone project management. As an example, the Department’s Representative was advised by a departmental officer that when dealing with contractors he should "always seek compromises" as though the contract and scope of work meant nothing. That same person also asked the Department’s Representative how to convert a milliSievert into a picoCurie!!!

The lacking in project management and in other technical matters is amply illustrated by answers to Senate Estimates Committees on 2nd and 3rd of May 2000. For example, when Senator Allison asked how the department managed the project, she was told: "We had month by month meetings." The department also said that increases in costs and payments to GHD were approved but could not explain how such approvals were granted.

In summary, GHD had no involvement in the first half of the project. Somehow they managed to persuade departmental officers that they should manage the second half even though they were not qualified for the appointment. The second half of the project cannot be claimed a success since the objective was to treat the 21 pits by ISV; this was not done and a far inferior solution was adopted, one that even the department says is not suitable. As project records show, the cancellation of the ISV project was a cost cutting exercise, and that in itself should reflect on GHD because when they took over the ISV project there were sufficient funds available for even the extended ISV contract.

This is but a short explanation of why, with some inside knowledge of the project, there are many questions that should be asked about why GHD received these awards. There has been criticism of the Maralinga project from several quarters and the awarding committees should have known of this. If these organisations expect their awards to continue to have the prestige in which they are held, then they must be more searching in their project assessments. These awards are held in some esteem and are used by companies in their marketing documents. What would be the anger of other entrants if they were to know that the award was given to a company which had no involvement in the first half of the project and the half in which they were involved failed to meet its objectives.

The sheer scale of the task and the ever-present danger of radiation poisoning combined to make the Maralinga nuclear test site cleanup a unique project management challenge.

The remote South Australian site has been cleaned up, to the extent that potential radiological hazards have been substantially reduced, allowing greater access to the area and reducing or eliminating the requirement for surveillance.

At this year's inaugural National Project Management Achievement Awards in Cairns, the cleanup won the title of 'Best National Project' and an 'achievement of excellence' award was presented to GHD.

GHD was appointed by the Commonwealth Government as project manager and engineering design consultant for the Maralinga Rehabilitation project in April 1994, 31 years after the British concluded nuclear weapons testing there.

The project originated from the Commonwealth Government response to the Royal Commission into British Nuclear Tests in Australia which recommended, inter alia, that the test sites be cleaned up so that they were suitable for unrestricted occupation by Aboriginal landowners following a semi-traditional lifestyle.

British military engineers had attempted cleanups, but extensive radioactive contamination by radionuclides (particularly plutonium-239 with a half-life of 24,110 years) remained from the tests. These cleanups left the plutonium contamination in a readily accessible condition, both in the surface soil and in shallow burial pits.

* The Tasks
* Scope of Work
* The Challenges
* Special Management Methods

The Tasks

The project had to address the following key tasks:
GEOTECHNICAL investigations to evaluate ground water sources and to identify suitable locations for the construction of soil burial trenches.
REFURBISHMENT of Maralinga village and associated infrastructure.
REMOVAL and burial of radioactive contaminated material.
IMPLEMENTATION of a comprehensive health physics regime to prevent worker contamination.
PRODUCTION of a detailed record of the project including all burial locations and site end state conditions as well as worker health records.

Refurbishment of the village meant providing sleeping accommodation for up to 60 people, together with recreation, entertainment and first aid facilities, and offices; upgrading of electricity and water supplies, telecommunications, and sewerage services; and repair of roads.

It also included provision of worker amenities, health physics (radiation safety) and plant decontamination facilities, workshops, and infrastructure services at the work sites.

The cleanup required the construction of five trenches with a total volume of 646 000 cubic metres to bury contaminated soil collected and transported from a 226-hectare area.

At Taranaki, contaminated debris pits were treated by a process known as in-situ vitrification (ISV), undertaken by Geosafe Corporation. ISV uses electricity to melt contaminated material into a glass-like substance, effectively locking the contamination away.

In other instances, contaminated debris pits were exhumed and radioactive or hazardous materials removed for deep burial.

Burial trenches were closed with mounds of clean soil and there was a general collection of debris, and re-contouring and revegetation of disturbed areas. Some 88 kilometres of boundary markers were erected to identify areas not suitable for permanent occupation by Aboriginal landowners living a semi-traditional lifestyle.

Scope of Work

GHD was required to :
* prepare an overall scope of work and plan of action with networks and schedules addressing the total project to show the sequence, timing and duration of all activities in the project;
* develop a project cost plan to enable monitoring and control of project costs;
* manage and prepare detailed work and health physics procedures to be applied to all aspects of the rehabilitation work;
* manage the design and implementation of the physical works.

The company managed multiple contracts covering the development of site infrastructure, the collection and burial of contaminated soil and specialised treatment of contaminated debris pits.

A health physics framework was developed and detailed operational procedures prepared that reflected the site’s radioactivity parameters and the nature of work undertaken.

The Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) had the task of defining areas where soil needed to be removed, verifying that soil release criteria had been met and developing equipment to detect intake of plutonium or other radioactive substances into workers' lungs.

The Challenges

Unique nature and scale of work

No previous cleanup of a nuclear test facility on a commercial basis had been undertaken in Australia. Furthermore only a small number of nuclear test sites had been remediated worldwide and these had primarily been undertaken by military engineers associated with test programs.

As a result the Maralinga cleanup relied on the application of available knowledge to develop appropriate systems and processes.

Limited contamination characterisation

GHD needed to design flexibility into work methods to cope with:
* uncertainty in the sub-surface profile of the contamination (only surface characterisation was available due to high risks associated with measuring sub-surface distribution of the debris and plutonium in the absence of a full health physics regime);
* uncertainty in amount of effort required to achieve release criteria.

Commercial contracting arrangements

The cleanup was to be undertaken on a commercial basis. Previous cleanups of such sites had been undertaken on a cost plus arrangement, resulting in poor control over project out-turn cost. GHD aimed to design and document the main works so that it could be competitively tendered (predominantly on a lump sum basis) and managed within a nominated budget.

Potential health risk to workers

Plutonium contamination on the site posed a significant health risk to workers. No established methods or standards for dealing with such a hazard were available within the Australian construction industry. No worker was to receive a radiation dose in excess of internationally accepted standards.

Workers wore protective suits and respirators where necessary, but their use was not favoured due to reduced visibility and the risk of heat stress.

The services of an experienced nuclear technology firm were employed to produce engineered solutions for worker protection, which included major modifications to the cabins of plant to prevent the intake of contaminated dust.

Worker dose exposure

Adequate records needed to be kept for all project workers to register specific roles and exposure to contamination while at site. GHD implemented and managed a comprehensive dosimetry regime and environmental monitoring system to provide full records of dose levels experienced by radiation workers.

Civil and health physics disciplines

A challenge was bringing together and merging civil and health physics disciplines into a seamless project methodology: the project management and engineering disciplines had little knowledge of nuclear issues, the nuclear technology advisers had little knowledge of large-scale earthmoving operations.

This was achieved by the development of a strong team approach with frequent meetings through design and implementation phases.

Remote site operations

The Maralinga site is remote and existing facilities were not adequate to support required construction activity. Accordingly, a new camp was constructed.

Remoteness also required the adoption of a continuous work cycle as there were no amenities to support time off on weekends.

Limited site access

Careful planning of supply of equipment and materials to the site was necessary due to limited access (passenger rail service available only twice a week, road access a low-standard dirt road). The main entry to the site for workers and light supplies was by charter aircraft, made possible by an existing 2.5 kilometre runway constructed for the tests.

Remote medical support

The small size of the workforce meant that medical support was supplied by first aid officers and the Flying Doctor Service.

Acceptance testing by regulator

ARPANSA, which undertook detailed monitoring of the cleared areas, was not under the project manager’s control. Extensive liaison was needed to prevent monitoring from causing operational delays.

Multiple contractor site

During the project there were often two or more contractors working on site at the same general location necessitating close attention to coordination of site operations (particularly with respect to worker safety). Use of a common industrial agreement removed an area of potential conflict among employees of different contractors.

Special Management Methods

As there were no previous benchmarks against which performance and progress on the project could be assessed, project management processes needed to be rigorously applied to ensure that objectives, scope of work and outcomes were closely aligned.

Higher-level project management techniques were adopted.

The scope of work was sub-divided through a work breakdown structure (WBS) designed to cover investigation, design and documentation activities as well as site construction works.

The WBS was developed from detailed analysis of requirements and the client’s brief and updated for subsequent scope changes. With WBS as a project control tool, GHD adopted an earned-value approach to monitoring and controlling time, performance and resource use.

As an integral part of risk management, and because of the size, complexity and long duration of the project, every element needed to be fully documented. Documentation covered work methods, the required end-state and an extensive suite of project management and operating procedures.

Effective communications were also essential for the project's safe and efficient operation as up to eight separate organisations were working on site at any one time, not all of whom were under the project manager's authority.

Communications included meetings held for both management and worker levels, use of extensive work procedures, reports and regular worker training.

Partnering charters were drawn up for the two construction phases of the project. The partnering approach involved the major organisations plus the support organisations on site who also played a significant role in achieving the project objectives and maintaining morale.

A wider management perspective on contract performance was developed between the client, GHD as project manager and contract superintendent, and the contractors. A project control group was established for both the major soil removal and the ISV contracts, comprising senior management representatives not normally involved in the day-to-day running of the contract.

The CEO of ARPANSA John Loy said: "Australia was faced with a challenging legacy of the Cold War at Maralinga. The remediation has been overall a success story."

To: GHD

From: Jim Green

May 27, 2002.

Dear GHD,

My legal advice is that the article from which GHD’s lawyer quotes would not give rise to any liability.

I took the initiative to contact you personally on two occasions asking for a rebuttal of the website article with a view to publishing your rebuttal and/or correcting any inaccuracies in the article. As my website has noted for some months, there is an open-ended offer to publish a rebuttal in full on my website.

I remain willing to publish a rebuttal in full, or to correct any inaccuracies, on my website relating to GHD’s role at Maralinga. I welcome public debate on the latest Maralinga clean-up, hence my earlier requests to you for information. I do not believe a proper assessment of the clean-up can be made without such debate.

So, not for the first time, I’m asking for a list of factual inaccuracies in the article, and/or a rebuttal which I will post in full on my website. The legalese evident in parts of your lawyer’s letter, and your lawyer’s imaginative and scientifically-illiterate "imputations", only confuse the matter. I reject your lawyer’s claim that a few questionable "samples" suffice to "demonstrate the inaccuracy of the article overall".

Since you ignored my requests for information and also my offer to publish a rebuttal, I took the trouble to find some information about the Maralinga clean-up on your website and I posted that information in full on my website in February or March. (I also made a number of suggestions to GHD so that information about Maralinga can be more easily found on your website, and received a thank-you note from GHD in response. Some of my suggestions may appear on your new-look website later this year.)

I have clearly and demonstrably made every conceivable effort to ensure accurate, fair coverage of the dispute over GHD’s role at Maralinga. To respond to those efforts with legal threats is an outrage. If the aim is to silence and intimidate, GHD will not succeed. If the aim is to defend GHD’s reputation, why not publicly respond to contentious issues raised in the media, in Senate hearings and elsewhere?

I have clearly and demonstrably approached the broader debates over the latest Maralinga clean-up in a spirit of open, informed inquiry. In addition to the above-mentioned efforts to ensure fair and responsible coverage of the dispute over GHD’s role, I have:
* compiled an extensive bibliography of literature about Maralinga and posted that on my website.
* posted a great deal of information about the weapons tests and their aftermath on my website - over 30 articles at last count.
* liaised with federal politicians with an interest in the matter in order to advance our understanding (and the public’s understanding) of the complex and hotly-contested issues surrounding the Maralinga clean-up.
* responded to inquiries from journalists for information about the clean-up. Inter alia, I have explained to journalists how to find relevant information buried in the GHD website.

In the same spirit of open, informed inquiry, I spend a great deal of time fact-checking. To give just one example, I investigated your website claim regarding ‘deep’ burial and found that the regulator describes what you have done as "near-surface" disposal and the 1992 NH&MRC Code defines anything within 30 metres of grade as being "near surface" disposal. You use the same term yourself (5.3 of your lawyer’s letter), as has DISR (e.g., 3/5/00 Senate hearing). So whatever it was, the burial was not ‘deep’, however loose the definition.

Your lawyer’s letter is most interesting for its omissions. For example, your claim that "GHD was appointed ... in April 1994" remains uncorrected. It seems only reasonable to ask: is that the information ACEA and AIPM received? It strikes the outside observer as a highly significant piece of information in relation to the awards.

To mention just one more omission, you say nothing about the pit 14 drum that was exhumed and reburied. Is it true that DISR, ARL/ARPANSA and MARTAC were not informed about the drum until after it was reburied and were not subsequently informed until questions were raised at the 12/5/99 joint meeting? How does anyone know what was in the drum, however light it was, if it was not opened as Senator Minchin stated in a 17/4/00 media release? How does anyone know whether the contents were dangerous or whether they could have helped determine the cause of the later explosion in another pit? If the drum was not opened because, in Senator Minchin’s words, "there was no work procedure to cover such an activity", why not simply develop a work procedure as was done on other occasions? Why use the drum for a "training" exercise without knowing what was in it and when other objects would have served that purpose just as well and without the attendant uncertainties and risks? Was there a work procedure for burying drums with unknown contents? On whose authority did the sub-contractor bury the drum and was this in line with proper procedures? Were there other incidents similar to this?

GHD’s answers to questions such as those ought to be on the public record.  Clearly the clean-up is a matter of major public interest.

Many more questions are raised by the pit explosion, by the process by which ISV was terminated in favour of shallow burial, and by numerous other issues and incidents. Again, GHD’s answers to those questions ought to be on the public record.

To respond to various points using GHD’s lawyer’s numbering system:

1. It was over 15 months after the person concerned left the project before you contacted him regarding final medical and lung monitoring (and a further three months before the monitoring took place). If you want the relevant facts and dates to be spelt out in full on my website, please advise.

If you found that person’s radiation exposure history, your records might be complete. If not, the records are incomplete. The article does not assert that the records are incomplete, it merely raises the question.

Whether or not the radiation exposure history in question was found, why did it go missing in the first place, and was the regulator informed of missing medical record/s?

Even if the radiation exposure history in question was found, your claim to have compiled "a comprehensive record of the project involvement and dose history of the radiation workers" is debatable in light of the the delay referred to above and the incident referred to immediately below.

2. Were ACEA or AIPM made aware of the the case of the contaminated worker? Either way, the article on my website does not assert otherwise.

Can the GHD-related submissions to ACEA and AIPM, by GHD and others, be made public?

I have contacted ARPANSA to get a copy of the GHD/AEA Technology report.

3. DISR was persuaded to appoint GHD as project manager and GHD did some or all of the persuading, e.g. in your four-page written proposal. That is no more than a statement of fact. There are differing views over the adequacy of the process leading up to this appointment, e.g. the exclusion of the Department’s representative from relevant DISR/GHD meetings. You ought to put your opinion on the public record rather than attempting to silence dissenting opinions.

Another bone of contention is whether GHD had the requisite qualifications, and clearly there are differing views on that issue. You ought to put your views on the public record - the GHD website and my website are two immediate options.

You do not dispute that GHD had no experience with, and little or no knowledge of, ISV. If you do not believe that it was important for the Project Manager and/or the Project Authority to have experience with or knowledge of ISV, you are entitled to that opinion and others are entitled to differ.

You do not dispute that GHD saw the Commonwealth’s contract with Geosafe Australia or that this was done without Geosafe’s permission. If you believe that was appropriate and in keeping with the Partnering Charter, you are entitled to that opinion and others are entitled to differ. You declined the opportunity to have your opinions aired on ABC Radio National’s ‘Background Briefing’ program (16/4/00), and you have so far declined my invitation to put your opinions on my website.

GHD says: "The partnering charter certainly does not require all parties to involve each other in internal management matters." The Geosafe contract certainly was not an "internal management matter" as the company’s representatives will themselves attest.

GHD’s statement that "All other contracts had been arranged with GHD as the project manager and Mr Parkinson as client representative ..." is demonstrably false.

GHD acknowledges that it saw the ISV contract in June 1996, prior to its signing, yet the contract progressed in the absence of acceptance criteria. Why?

GHD says: "In no way did GHD exert pressure ... to have Mr Parkinson removed from the project." The article does not state or imply that you did (or did not).

4. GHD asserts that "allegation" 4 regarding costs is "incorrect" but does not adequately justify that assertion. Please supply supporting evidence, e.g. relevant estimated and actual costs.

It would also assist if you could advise if Mr. Farrow’s confidence that estimates were exceeded was well placed (Senate Estimates, 3/5/00):
Senator Allison—But you have an estimate of $250,000. Surely you are able to make a judgment as to whether that estimate was exceeded or not. If so, by how much?
Mr Farrow—I think we can confidently say that the estimate would have been exceeded ...

It would also assist if you could advise whether the following wording, from the 16/4/00 ABC Background Briefing program (reporter Gregg Borschmann), is accurate: "On the 21st November, 1997, the company responded to an invitation by the Department to put a proposal for management of the ISV contract. Background Briefing has a copy of this letter. In it, GHD estimated their additional services would cost in ‘the order of a quarter-of-a-million-dollars.’ Background Briefing also has copies of GHD monthly reports to the Department. These provide details of project expenditure. Not all of the money that GHD has earned since is related to ISV. But the monthly reports indicate that over the past two years or so, the company has been paid, in staff costs alone, more than $2.5 million. This is ten times the cost of the original estimate."

If you dispute the above summary from the ABC, have you made any effort to publicly correct it in the past two years? I am not aware of any such effort despite spending countless hours researching the Maralinga clean-up issue and contacting you personally on two occasions. Why did you decline the invitation to participate in the Background Briefing program in the first place?

5. I am not aware of any claims that GHD breached "relevant guidelines for disposal of waste". The relevance of the 1992 NH&MRC Code of Practice is in dispute. Is GHD aware that the government itself has always made clear that the 1992 Code did not formally apply to the Maralinga clean-up? Minister for Industry, Science and Resources, Nick Minchin, said so himself in a 17/4/00 media release: "The Government has always made clear that the Code of Practice for the near-surface disposal of radioactive waste in Australia (1992) does not formally apply to this clean up." Why no such acknowledgement from GHD? You would also be aware of the views of the authors of the 1992 Code.

Nothing changes the fact that long-lived radionuclides were involved - an indisputable point with significant ramifications. If you think the 1992 Code is relevant on that point, you are entitled to your opinion and others are entitled to differ. The Government is of the view that the Code "does not formally apply to this clean up". The Government is also of the view that near-surface burial is inappropriate for long-lived radioactive waste (‘Safe Storage of Radioactive Waste. The National Store Project: Methods for choosing the right site. A Public Discussion Paper’, July, 2001).

Why does GHD’s website paper state that: "In other instances, contaminated debris pits were exhumed and radioactive or hazardous materials removed for deep burial"? Deep burial did not take place according to the 1992 Code of Practice; or according to regulator John Loy at Senate Estimates, 3/5/00 ("I would describe it as near-surface disposal ..."); or according to DISR’s Harris and Farrow, who both describe it as near-surface burial (3/5/00 Senate hearing). DISR’s Malcolm Farrow appears to regard burial below five metres from grade as ‘deep’ near-surface burial, but the burial pits at Maralinga would not even qualify for that mongrel categorisation.

On the depth of burial, please refer to:
* minutes of the 13/4/99 Consultative Group meeting: "Dr Williams confirmed that if all material was buried under at least 5 metres of cover to grade, and engineered to reduce ingress of water, it would be consistent with the NHMRC Code of Practice ..."
* ARPANSA’s 29/4/99 letter to DISR: "The option to exhume and bury would place the material at least 5 metres, and up to 10 metres, from the surface. ... In particular, it would be considered prudent for contaminated waste in the new burial trench to be covered by 5 metres of clean fill below grade, whether or not any additional capping above ground was included to assist run-off."
* comments from Farrow and Harris at the 3/5/00 Senate hearing
* further relevant excerpts from various documents available on request.

Whether all the material was buried at least two or three metres below grade, it certainly was not all at least five metres and it certainly was not ‘deep’. I have been unable to find evidence of burial of all material at least three metres below grade. If you have same, I would be grateful for the reference. The longest discussion of the matter that I have seen does not clearly specify the depth and seems open to differing interpretations. Another document suggests that the appropriate wording might be ‘at least 2.7 metres’.

You mention an agreement with the regulator regarding the depth of burial, but did the regulator maintain an on-site presence to verify compliance with the agreement?

GHD says: "In their report GHD presented their findings but did not express a preference for a particular approach." The article does not state that you expressed a preference in your report. GHD’s preference to drop ISV in favour of burial is clearly expressed in the minutes of the 13/4/99 Consultative Group meeting (and possibly elsewhere) and would be well known to you in any case.

GHD says that options were reviewed "when the ISV had not produced the results expected by ISR and MARTAC ..." The changing expectations of MARTAC were of less importance than contractual requirements. As you were privy to the contract, you would know that contractual requirements were met by Geosafe.

Jim Green

Letter published in Australian Financial Review, August 2, 2002.
The short item in the AFR of Friday 19 July, page 71, Search for Nuclear Waste Searchers, Tender Watch by Christopher Jay again illustrates the inconsistencies (or double standards) displayed by the government in dealing with nuclear waste. Tenders are to be called for a company to find a site for nuclear waste, including uranium residues and americium. (Then industry, science and resources minister) Minchin told us on 11 August 2000, that the waste will be stored in a concrete building awaiting deep geological disposal. In one of his publications Radioactive Waste, the Seven Biggest Myths, the Senator said that concrete is highly effective in preventing the release of radioactivity. However, in evidence to a Senate committee hearing on 3 May 2000, he said that concrete is not an effective barrier.
I must ask why do we need such a store. We already have the precedent for the disposal of thousands of tonnes of debris contaminated with uranium and americium (and its parent, plutonium which has a half-life of 24,000 years). This burial is at the old atomic bomb site Maralinga in South Australia, and the debris is in a bare hole in the ground in totally unsuitable geology only two to three metres below ground. Although the nuclear regulator did suggest that the debris should be encased in concrete, this suggestion was ignored. In a statement issued on 17 April 2000, the Chief nuclear regulator said that what had been done at Maralinga was world's best practice. So why not adopt this world's best practice and save money on the search for a "suitable" site?
Anywhere will do.
Alan Parkinson
Weetangera, ACT
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Letter published in The Advertiser, August 7, 2002.
Incredible claim
"I enjoyed Simon Benson's article "Maralinga still unsafe, warns whistleblower" (The Advertiser, Saturday 3 August, page 23) and the accompanying photograph showing a cloud of radioactive dust. A similar cloud was created every ten or fifteen minutes or so over the working day.
But that cloud was small compared with the dust arising as soil was collected as shown on the government's own video record of the project. So it is incredible that the government should claim, as they did just below the photograph, that "the [Maralinga] project was conducted to standards that exceeded anywhere else in the world." There must be some awful
practices overseas."
Alan Parkinson
Weetangera ACT
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Letter published in The Australian, 6/2/02
Past drill weakens SA grounds
K.H. LOKAN (Letters, 4/2) notes that the Code of Practice for near-surface disposal of nuclear waste permits disposal of long-lived alpha wastes such as lightly contaminated soil. He says intermediate level wastes are acceptable (to the repository) provided they are relatively short-lived. But the precedent has been set to dispose of debris heavily contaminated with long-lived radioactive substances in a shallow burial in totally unsuitable geology.
This was apparently agreed to by Dr Lokan and is said by the nuclear regulator to be world's best practice. With that precedent, South Australians can rightly claim that the repository can be placed anywhere, so why site it in their state?
Alan Parkinson
Weetangera, ACT