1. OPENING COMMENT

An interesting feature of the MARTAC Report is that although I was a member of the committee for more than half its life and attended 10 of its 17 meetings, plus several splinter group meetings, I am not mentioned in the report.  However, I do appear in one of the photographs and that photograph is interesting for other reasons - see later.

When I was removed from the project and MARTAC, I received messages of support from just about every organisation connected with the project.  I received several messages from remaining members of MARTAC in which a recurring theme was the difficulty they would face writing their report without my input.  The report shows their concern was well founded.

2. TABLING THE REPORT

In presenting the report to the House of Representatives, the Minister for Science said: “The MARTAC Report describes in detail the $108 million clean-up of the former British nuclear test sites in South Australia.  The project achieved its goals and a world’s best practice result.”  In his closing comments, the Minister said: “Other plutonium contaminated sites elsewhere in the world will be cleaned up.  I and MARTAC hope that Australia’s conduct of a successful, large-scale rehabilitation program will be an experience of benefit to others.”

The Minister’s comments immediately prompt three questions.  Does the report describe the project in detail?  Will the report be of benefit to others?  Was the outcome world’s best practice?  The short answer to all three questions is No.

How can a partial clean-up be described as world’s best practice?  Even though it was agreed that only the most contaminated soil would be collected and buried, much more soil could have been removed so that the Maralinga Tjarutja would have unrestricted access to the site, as recommended by the McClelland Royal Commission.  That would have been an improvement, so what has been done cannot possibly be world’s best practice.

Every member of the MARTAC agreed that ISV was a far superior option for treating the debris pits.  So even the Minister’s own advisory committee disagrees with his claim that shallow burial of plutonium contaminated debris is world’s best practice.  Several things could have been done to improve the disposal of this debris.  Burial at greater than 30 metres below ground would be an improvement and one that would probably attract universal acceptance.  Encasement in concrete, as recommended by ARPANSA, would be another improvement.

Another of the Minister’s advisory committees, the National Store Advisory Committee, say that long-lived radioactive waste is not suitable for near-surface burial.  So they would surely not agree that shallow burial of plutonium waste is world’s best practice.

The report was prepared by a group of scientists who met on three or four occasions a year and did not have any day-to-day contact with the project.  For the second half of the project, the department did not provide any engineering oversight even though it was an engineering project.  Consequently the committee (and the department) had to rely on what was reported to them by the project manager whose primary loyalty must be to his own company.

This lack of detailed knowledge by the committee has resulted in many mistakes in the report.  It contains many misleading statements or incomplete descriptions, and in some places it is so wrong that one must be suspicious of the committee’s (or the department’s) motives.

The report does not provide a complete description of how the work was done.  It does not describe what problems were encountered and what was done to overcome them.  In some cases, the authors obviously did not know what was done on site and so used general terms to cover their ignorance.  Examples are provided below.

Anyone seeking guidance from this report for the clean-up of other sites will be disappointed.  A better guide to what was done in the first half of the project can be gained from the official video record of the project.

There was a great deal of controversy about the second part of the project - the in situ vitrification of 21 debris pits.  The cause can be traced to inadequate definition of requirements; appointment of a company with no knowledge or experience as both project authority and project manager over that part of the project; non-contractual and changing requirements by MARTAC; and very poor project relations, which extended to some members of MARTAC.  Consequently, the report seems to be somewhat skewed.  It is interesting that the US Department of Energy ignored the experience of Maralinga and after making independent assessments, has adopted vitrification technology for at least four projects since the explosion at Maralinga.

There are many examples of the inadequacy of the report.  Many times the authors show their ignorance of the details of the project.  Sometimes the descriptions are totally wrong, and this can  be shown by reference to attachments, appendices, or project documents.

3. THE SEQUENCE OF WORK

Pages 94 and 95 show a Project Activity Summary listing work done together with start and finish dates.  The table is confusing.

The table shows a heading Pit Exhumation and Restoration, but it does not say which pits it refers to.  That section shows exhumation of debris pits at Taranaki taking place in the period 27 July to 20 September 1997, but no pits were exhumed at Taranaki until the ISV project was cancelled in 1999.

The table shows pit exhumation at the TM site in the period 21 to 23 October 1997, but exhumation of pits at the TM sites took much longer than three days.  Exhumation of Pit 2U was the first remediation work at the TM site and took 9 days (see page 294).  There was a delay of two days during exhumation of Pit 22 while a new windscreen was made in Adelaide and flown to site.  The most puzzling thing is that the pits at the TM site were exhumed and their contents placed in the burial trench before soil removal commenced but soil removal is shown as taking place before pit exhumation.  The same happened at the Wewak site and the table confuses that also.  All very puzzling.

The table does not show when pits in the Airfield Cemetery were exhumed, nor does it show when the un-numbered (informal) pits were treated, both of which were major tasks.

4. ESTABLISHING THE SOIL REMOVAL BOUNDARY

The area within which contaminated soil was to be removed for burial was delineated by technicians from the Australian Radiation Laboratory (ARL).  It is not clear how they decided where the soil removal boundary should be.  A reader could gain the impression that this was a haphazard operation since some areas were added after soil removal at Taranaki was complete, suggesting that there was insufficient monitoring before setting the boundary.

Page 189 describes how ARL set the boundary and says: “the final soil removal boundary was set at least 30 m outside the last detected visible fragment or particle exceeding MARTAC criteria.”   But there were fragments just beyond the boundary, and this fact does not appear in the report.  One fragment was a contaminated lead brick about four metres outside the boundary, between the Taranaki north-east and north plumes.  When a health physicist went to remove this brick after soil removal was complete, he had to dig down about 600 mm to retrieve it.  Apart from placing a question over how the soil removal boundary was set, this also indicates how much contaminated soil simply blew away.

An example of a vague description occurs on page 205 where it says that after soil removal was complete: “... additional scanning was carried out to a substantial distance beyond the outermost particle or fragment located.”  What is a ‘substantial’ distance?  And who decided when it was sufficiently ‘substantial’?

The GHD report (Attachment 4.4 page 82) relates that Lots 41 and 42 were added for soil removal in March and June 1999 and they were identified when ARPANSA conducted surveys to confirm that no contamination above criteria remained at site.  These lots adjoined the soil removal boundary - so why were they not included in the bulk soil removal?

5. BURIAL TRENCH

In his speech on 25 March, Mr McGauran said: “ARPANSA also certified that the burial trenches were constructed consistent with the national Code of Practice for the near-surface disposal of radioactive waste.”  Senator Chapman made the same statement in his speech on the same day.

I received a letter from The Hon Trish Worth, dated 20 June 2002 which said: “In a letter dated 29 February 2000, the Chief Executive Officer of ARPANSA wrote to the then Minister for Industry, Science and Resources certifying that the burial trenches at Taranaki, TM 100/101 and Wewak were constructed consistent with the Code of Practice for the Near-surface Disposal of Radioactive Waste in Australia (1992) for the disposal of the radioactive waste resulting from the Maralinga clean-up.”  Since nobody from ARL/ARPANSA was involved in any way in the positioning, design, excavation, filling, or covering of the trenches, I question how Dr Loy could honestly make such a claim, so I asked for a copy of the report on which the claim was based.  I then received a letter from Dr Loy which merely said: “The second point you raise relates to the requirements of the near surface code for site selection for a near surface facility.  The code sets out site requirements and criteria for waste management, some of which are prospective to be applied prior to choosing a site.”  This was no answer to my query and I have still not seen a copy of the report - I doubt if there is such a document on which Dr Loy could have based his statement.

6. SOIL REMOVAL

The process of bulk soil removal is covered in two paragraphs on page 193 which give a brief description of how soil was removed by scrapers with assistance from a bulldozer, and then by a road-sweeper to brush and vacuum away the soil.  But it does not tell that the final bits of contaminated soil were removed by a man with a pick and a vacuum hose.  This is clearly shown in the official video record of the project, and is related at page 74 of the GHD report.

Nowhere does the report mention that GHD gave wrong coordinates to the contractor with the result that one strip of land at Taranaki that should have been cleared was missed, and has not been cleaned because the regulator later said it would be acceptable as it was.  A strip at the TM site would also have been omitted but ARL spotted the mistake in time for it to be rectified.  That strip is shown as Lot 12A on Figure 4.12 on page 210.

When the report authors had no knowledge of how soil was removed, they used indeterminate words and descriptions to hide their ignorance.  For example, on page 205  the report tells of removal of soil from two very small lots, Lot 42 (1.5 hectares) and Lot 41 (0.1 hectares).  The report does not say how the soil was removed from Lot 42 but says that soil from Lot 41 was ‘removed in the usual way’, and the reader has to go to page 247 to find where the soil was buried.  By the time this remedial work was done, the scrapers (used for the bulk soil removal) had left site and would not have been taken back for such a small area - so the lots were not treated ‘in the usual way’, and the report does not tell how.  Fortunately, the GHD report (Attachment 4.4, page 82) describes how this soil was removed using a front end loader and excavator to load the soil into a truck which then dumped the soil in the ISV burial trench - hardly ‘the usual way’.

The MARTAC Report itself is confusing when telling where this soil was buried.  On page 205, when describing the removal of soil from Lot 42, it says: “Given the proximity to the disposal trench being constructed for the pit debris, it was considered worthwhile to remove this soil.”  The implication is that the soil was buried in the pit debris trench.  But page 247 lists what was buried in a different trench, the ISV burial trench, and second on the list is: “Contaminated soil from lots 41 and 42” also reported by GHD (page 138 of Attachment 4.4).

Senator Allison asked in Senate Estimates hearings of 3 May 2000: “What is the estimate of how much soil was due to be scraped up compared with how much actually was.”  In his reply, Senator Minchin said: “The volume of contaminated soil (including debris) collected by Thiess was 380,267 cubic metres (266,828; 68,365 and 45,074 cubic metres in the Taranaki, TMs and Wewak trenches respectively).  The pre-construction estimated volume of contaminated soil and debris was 383,000 cubic metres, very close to the actual amount of soil collected.”  Apart from the amount for Taranaki, it is the same as given in the report.  But the question was about soil, not soil and debris.

The MARTAC Report says at page 196: “The total volume estimated for the Taranaki soil burial trench was 285,000 m3.  In fact the final volume turned out to be 262,840 m3.”  Page 198 states: “Approximately 250,000 m3 of contaminated soil was collected and buried at Taranaki.”  The report says at page 209: “Approximately 65,500 m3 of contaminated soil was collected and buried at TMs ....” and at page 210 it says: “Approximately 44,500 m3 of contaminated soil was collected and buried at Wewak ....”  The GHD report (page 43 of Attachment 4.4) shows the design capacity of the three soil burial trenches as 285,000 m3 for Taranaki, 90,000 m3 for TM and 55,000 m3 for the Wewak trench.

The importance of this is that if the amount of soil collected was not within 30 per cent of the estimated volume, the soil removal contractor could claim some compensation.  In about September 1997, the contractor submitted such a claim and GHD accepted it, paying them $80,000 (or $90,000) in settlement.  The amount of soil collected, which was the subject of Senator Allison’s question is about 84% of what was expected to be collected, so why did GHD accept the claim?  [Note: These numbers need to be checked with DEST - the percentage and the settlement amount.]

7. DUST SUPPRESSION

The report describes (pages 193 and 194) the need to suppress dust during soil removal.  It says: “This requirement to suppress dust was mainly for operator perception and for visibility and plant movement safety reasons.”  While these were some of the reasons, we were more concerned about contaminated soil blowing onto lots which had been checked by ARL and given clearance certificates.  It was a constant complaint that dust suppression was not effective and that soil was blowing across the soil removal boundary.  The report does not mention the thousands of tonnes of contaminated soil that simply blew away ? across the soil removal boundary.  At the bottom of page 324 is a convoluted and meaningless statement: “Considerable effort was therefore devoted to the control of dust during soil removal, mainly through its suppression during soil removal …”  It does not say how this was achieved and ignores the very poor dust suppression at Taranaki.

While the report discusses measures that were adopted to suppress dust (see page 193), it does not give all the details and fails to mention that the successful measures were not adopted until the work moved from Taranaki to the TM site.

A photograph at page 335 has the caption: “Scene at Taranaki, September 1996.  Work suspended during dust storm arising from south-westerly winds in excess of 40 km/hr.”  The photograph shows work still in progress.  It does not give a true picture of a dust storm; a better idea would have been to have captured a still from the official video of the project, or from the problems faced by troops in Iraq.  It is also misleading because the winds could be from any direction not only south-westerly.

Page 194 relates how work had to be stopped on about 15 occasions because of the heavy dust.  Since Thiess were paid when dust caused a cessation of work, GHD should have records of exactly how many times this occurred, but their report presented at Attachment 4.4 says at page 81: “It is estimated that for the complete soil removal operations at Taranaki, there were approximately 15 occasions on which work was suspended due to excessive dust levels ...”

The report fails to mention that on at least one occasion, the health physicists evacuated the forward area facilities (offices, laboratory, change rooms, maintenance facilities and the like) which were more than a kilometre from the work site because of the huge amount of dust in the air.  On that occasion, the wind must have been from the north or north-west since the facilities were to the south of the work area.  The GHD report (page 81 of Attachment 4.4) records this event.  Some of the workers in those facilities were non-designated workers; that is they were not under the umbrella of the health physics regime.

It was a common sight to see health physics personnel wearing respirators whenever they walked out of doors onto the walkway, but only a few metres away were non-designated workers with no protection.  I remember being instructed by a health physicist to go indoors during one such storm, but only a few metres away were non-designated workers in the open air.

In fairness to the contractor, before work moved from Taranaki to the TM site, we held a ‘lessons learned’ meeting (see Attachment 4.14).  Thiess took note and revised their procedures; dust suppression from then on was excellent.  This was achieved by employing two water trucks through the day and watering the scraped surface at the end of the day’s work.  Dust suppression in the trench was achieved by two water cannon placed above the trench.  But the report does not mention this.

8. MONITORING OF CLEARED AREAS

Page 190 describes how ARPANSA monitored the site after soil removal by first driving over it with ‘the Nissan’.  This was a vehicle with four radiation detectors fitted to a bar across the front, shown on page 190.  What the report does not say is how ARPANSA monitored the ground that was too rough for the Nissan.  Some parts of central Taranaki were scraped right down to rock and the resulting surface was so rugged that the Nissan could not traverse it without damaging the detection equipment.  The official video record shows how this part of the site was monitored by health physics technicians on foot using hand-held instruments.

Several times, (eg page 200) the report says that all lots met the clean-up criteria satisfactorily.  The report states at page 191: “On completion of the above measurements, a ‘lot clearance certificate’ was issued by the Environmental Monitor.  These certificates indicated that the lots met all criteria and were to be classed as cleared. ......  A sample lot clearance certificate is provided at Attachment 4.2.”  If all clearance certificates had been attached, they would have shown that sometimes a lot did not meet the clearance criteria and ARL granted concessions because the effort to get down to the criteria would be excessive compared with the benefit.  I have no problem with the granting of concessions, but there is no reason why the report could not acknowledge their existence.  Appendix 6.1 presents summaries of lot clearance which show that the average for each lot satisfied the overall criterion, but some individual hectares within a lot did not - that was when a concessional clearance certificate was granted.

The report does not mention that two lots at Taranaki were granted clearance certificates, but were later found to have contaminated debris buried - the pit caps were displaced by several metres, so ARPANSA had granted clearance certificates for two lots which still had contaminated debris buried only a few centimetres below the surface.  This shows how difficult it is to guarantee that all contamination has been removed.

9. APPROVAL PROCESS - HEALTH PHYSICS PROCEDURES

The report is totally wrong in its statements of how work procedures and health physics procedures were developed and approved.  The report totally ignores the part played by the department in this process, at least until January 1998.  This is so blatant, it must be deliberate.

The report states at page 63: “The Regulator formally approved all health physics procedures and had the opportunity to review all radiological work permits and method of work statements that subsequently followed.”  At page 314, the report states: “A listing of health physics procedures, all of which were approved by the Regulator is presented in Attachment 5.3.”

Both of these statements are wrong; ARPANSA could not be the approving authority since they had no interest in cost.  Until January 1998, all health physics procedures were approved by the department, that is by the Engineering Adviser and Commonwealth Representative acting on behalf of the department.  A couple of extracts from MARTAC minutes, which the report authors must have known about, show this to be the case.

• Minutes of the sixth meeting of MARTAC: “It was agreed that DPIE as the agency which ultimately carries responsibility for nuclear liability claims should have the right to delete procedures regarded as excessive provided that the modified procedures satisfy the requirement specified by the regulator (ARL).”
• Minutes of the eighth meeting of MARTAC: “Dr Lokan advised members that, as a matter of course, all HP [health physics] procedures are passed to Peter Burns of ARL for review.  Mr Burns had indicated that some of the current procedures appeared unnecessarily strict but he will not recommend relaxing them.  As HP regulator, his task is to ensure that HP procedures satisfy the HP policy.  Mr Burns believes that as the radiation risks are owned by the principal, then ARL, as the regulator, has no right to question standards that are too high.”

This latter quotation in particular shows that cost was no concern for ARPANSA; their only interest was to ensure that the procedures satisfied the Health Physics Policy.  The latter example is related at page 333, showing that the report authors knew that ARPANSA was not the approving authority, which questions why they said otherwise.

The first report by the Health Physics Review team, presented as Attachment 5.5 states: “The chain of command for the project accords with the structure shown in Figure 1 of the DPIE Health Physics Management document.”  It continues: “One item of note is that DPIE takes a strongly ‘hands-on’ approach to project management, with continuous interaction between DPIE’s Engineering Adviser and the various contractors’ managers.”  And then: “The DPIE Engineering Adviser has the responsibility, delegated by the DPIE Project Director, to ensure that site activities conform to DPIE requirements.  He reports direct to the Project Director in Canberra.  He uses both formal and informal approaches for advice on health physics matters from MARTAC, the Health Physics Auditor (HPA) and the Health Physics Manager (HPM).” [The Health Physics Review Team was a three-man team: Bruce Church, a member of MARTAC; Peter Burns, the Health Physics Auditor from ARPANSA; and Mark Sonter, an independent health physicist.]

[Note: MARTAC considered the DPIE Health Physics Management document to be very important, so it should have been appended to the MARTAC Report, but I doubt if the department could produce a copy.  I wrote the document and I had it at my own office for a minor amendment when I was removed from the project, so it was included with many other documents which I returned to the department (as instructed).  I suspect that the documents I returned were simply destroyed, since everything except that document was already in the department’s files.  In all probability the overall description of the health physics regime no longer exists in the department.  That is a pity because the document stated: “Works Australia [name change from Australian Construction Services] and AEA Technology were jointly responsible for the development of a library of health physics procedures, the details of which were written by the Australian Nuclear Science and Technology Organisation (ANSTO).  These procedures were reviewed by ARL and approved by DPIE.”]

In describing my work as it pertained to health physics, the Health Physics Review Team report continues: “DPIE’s Engineering Adviser regularly visits Maralinga to oversee the project.  He is in the HP ‘chain of command’ as the DPIE Representative and has considerable input to the production of the WA [Works Australia, purchased by GHD] HP Procedures.  He is the approving authority for these procedures on behalf of DPIE.  He applies a common sense engineering approach and cost-conscious viewpoint, which is nevertheless valuable, and seeks advice on health physics matters as necessary.  He also reviews all RWPs [Radiological Work Permits] before they are finalised and approved.”

And then for further explanation, the Health Physics Review Team report adds: “He regarded ARL as the prime authority on any HP matters.  But this role does not extend to his (sic) approving them.  ARL’s role is restricted to reviewing them to ensure that they meet the requirements of the ARL Health Physics Policy.”

MARTAC must have known of the content of the Health Physics Review Team report, especially as one of their members was a joint author, and knowing that they should have stated that all procedures were approved by the department, not the regulator.  The committee’s motives in presenting a totally different, and incorrect, version must be questioned.

It is likely that the department played no part in the approval process after January 1998 since they had no suitably qualified staff, which then raises the question of who did approve procedures taking cost into account - it could not have been either GHD or ARPANSA.  Allowing GHD to approve them would have left an avenue for them to over-specify the requirements, assign more people, and earn more money.  So it is likely that the department simply resigned that responsibility and left a big hole in the process.  Other evidence shows that in the latter years of the project, the health physicists dictated their own terms - they were out of control, see below.

Other extracts from minutes of MARTAC meetings could be reproduced to show that the approval of health physics procedures was discussed on several occasions, so all of MARTAC must have known that ARPANSA reviewed them but were not the approving authority.  With such a wealth of statements from MARTAC’s own documents, I have to question why the report claims that ARPANSA approved health physics procedures.

10. APPROVAL PROCESS - WORK PROCEDURES

Again MARTAC has ignored the part played by the department in the approval of work procedures.  And again the reasons why they have done so must be questioned.  Is it just ignorance or is there another motive?  All work procedures were subject to approval by the department, as required by Attachment G of the contract with ACS/GHD.  That part of the contract required: “all plans, scheduling documents, qualification procedures, work instructions, and other data describing the contractor’s intended approach to the rehabilitation work” to be submitted to the department for formal approval.  This was done until January 1998.  It is likely that this process was not followed after that date since the department then had no-one suitably qualified to review and approve any procedures.  The question then is who protected the Commonwealth’s interests - it could not have been GHD since their first priority is to their own company.

Although it was not written into the contract with Geosafe, I agreed a similar process with Leo Thompson (Managing Director of Geosafe Australia) for the approval of ISV procedures.

The quote from page 63 of the report mentioned above: “The Regulator formally approved all health physics procedures and had the opportunity to review all radiological work permits and method of work statements that subsequently followed.” confuses health physics procedures and work procedures.  Radiological Work Permits (RWP) followed from health physics procedures, but Method of Work Statements (MOWS) did not.  The latter were part of the engineering design process, prepared by Thiess and submitted through ACS/GHD to the department for approval.  The GHD report (Attachment 4.4 page 202) states: “When the documents [MOWS] had been prepared to the Project Manager’s satisfaction, they were submitted to ISR for approval.”

The report says (page 185) that workers were required to sign the Job Safety Analysis (JSA) form.  This is wrong.  The Job Safety Analyses were internal Thiess documents and were part of the engineering design process; they were not part of the health physics regime.  Radiation workers were required to sign the Radiological Work Permit after receiving suitable training.  Again, this is explained in the official video record of the project.

There was an exchange in the Senate Committee hearings of 3 May 2000 (page E57 of the Hansard) which shows how little those in the department knew of work processes and their approval, viz:

Senator ALLISON - Who typically approved work procedures on the site?
Mr Harris - ARPANSA.
Senator ALLISON - ARPANSA and not GHD.
Mr Harris - No.  All the procedures for radiation monitoring and for all radiation work were approved by ARPANSA.
Mr Farrow - There were provisions in the GHD arrangements that they would approve and develop things like quality assurance systems, work safety systems and work procedures.  That is part of the contractual arrangements.
Senator ALLISON - Is it possible to get some sort of indication of which kinds of procedures GHD were responsible for and which were the responsibility of the department and/or ARPANSA?
Mr Farrow - Sure.  They were developed by GHD as part of their contract for the arrangements.  The whole process for how that was carried out was under the approval processes.
Senator ALLISON - Mr Harris just said ARPANSA was responsible for approving the work procedures.  Were there different sets of procedures?
Mr Harris - Again it needs to be emphasised that all procedures that involved any risk to workers from radiation were approved by ARPANSA.

That exchange demonstrates that those in the department did not know the difference between work procedures and health physics procedures, nor did they know that all procedures should have been approved by the department - and were until January 1998.  If they really did adopt the process described in that exchange, they gave GHD a blank cheque.

11. IN SITU VITRIFICATION (ISV)

It is in addressing the ISV part of the project that the report really fails.

Even though all members of MARTAC considered ISV to be far superior to any other option, the report has gone to great lengths in its attempts to discredit the technology.  The fact that there was a deal of antagonism developed between at least some members of MARTAC and Geosafe did not help.

The problem really started with the failure of the department to specify the acceptance criteria in the contract with Geosafe, signed by R Rawson of DPIE (DEST) without seeking any advice  from his Engineering Adviser.  The MARTAC Report includes some criteria which had been drafted by MARTAC, but fails to add that they were not transferred to the contract.  A basic requirement in any contract, a statement of what has to be achieved, was not included in the contract.  Page 137 lists the draft criteria:

• There should be a high degree of confidence that contaminated soils and debris within the pits are completely vitrified and all materials either melted or encased in the vitrified product;
• Temperatures of the melt at the base of the pit would reach a specified level, to be advised following the Report of Phase II trials at Intermediate Scale; and
• Most of the plutonium should be distributed within the vitreous/ceramic component of the ISV product.

These criteria were quite impractical.  There was no way to verify the first and third without breaking up the blocks, and that would diminish the value of ISV.  At page 254 of the report is the statement: “MARTAC remained concerned that the only secure method of verification might still be exhumation of the completed blocks.”  This we always knew and that was why we had to have a very cooperative working relationship with the ISV contractor.  Such a relationship could not be attained following the appointment of GHD as project authority and project manager.

The report presents a different interpretation of the criteria at page 241, with almost the same wording at page 124 of the GHD report.  It says:
“In intent [the objectives of ISV] were:

• That the contents of the pit were fully incorporated in the melt
• That the melt temperature was sufficient to melt steel; and
• That the plutonium was uniformly distributed within the calc-silicate melt phase.

A particular point to note is the change in the third criterion which previously stipulated ‘most of the plutonium’.  See further comment later.

Again these are impractical, especially the first and third.  And again, the report does not acknowledge that they were not contractual.

At page 260 is a statement referring to the blocks of Pits 3 and 19A: “Since neither of these blocks lived up to MARTAC’s expectations …”  Expectations are generally not contractual unless they are defined and included in the contract.  A very strange comment recorded in the minutes of a meeting of the Consultative Group on 8 May 1999 was: “Mr Davy stated that the problems he personally had in relation to the performance of ISV were not definable in a contract sense.”  This shows an impractical approach to project work - requirements have to be specified, otherwise they cannot be achieved.

It is noticeable that in neither set of criteria is there a requirement to melt the steel.  The second criterion only says that the melt has to achieve a temperature at which steel would melt, and that is not good enough.  First, it is not sufficient to reach a specified temperature; it has to be held long enough for it to take effect.  Secondly, the plutonium contamination could only be on the surface of the steel, and as long as the plutonium is scavenged from the steel surface into the melt, the rest doesn’t matter.  But the report makes constant reference to unmelted steel in the blocks.  The first criterion, in either form, is quite clear that pit debris should be encapsulated (incorporated), not necessarily melted.

Step 1 of the chart on page 223 of the report is an attempt to portray these criteria as contractual.  Step 4 of that chart claims that ARPANSA (which at the time was ARL) reviewed the findings of a report prepared by Ansto about ISV.  It says they did this without knowledge of the criteria.  But at that time, Keith Lokan was a member of MARTAC and the Director of ARL, so they did have access to the draft criteria.

The problem was compounded when the department appointed GHD as both Project Authority and Project Manager for the ISV phase of the project.  Nobody from GHD had been involved in the three-year development program to match the technology to the Maralinga geology, and nobody from GHD had even seen the full-scale equipment which was then undergoing final trials before being shipped to site.  The point that GHD were totally unqualified for the appointments was made several times in writing to the department but for some unknown reason they persisted with the appointment.  Is it world’s best practice to appoint an unqualified company to manage a project?  The way that the appointment was made in secret with no involvement by either Geosafe or myself, coupled with GHD’s lack of knowledge, caused strained relations for the remainder of the project.

The problem was further compounded by the fact that after the appointment the department had no-one involved in the project who had any knowledge of ISV or project management.  So Geosafe, the world’s experts in ISV, found themselves reporting to, and taking technical direction from, a company with no knowledge or experience who in turn reported to a client who was similarly ignorant.  [This was after I was removed from the project.]  None of this appears in the report.

12. MARTAC UNDERSTANDING OF ISV

It is quite clear that the members of MARTAC had limited understanding of the ISV technology.  This is demonstrated later when discussing the discovery of lead beneath the ISV blocks.  At page 253 there is a tacit admission of the committee’s lack of knowledge, viz: “Factors considered by MARTAC included:

• the limited understanding of the vitrification process ...”

Pages 224 and 225 relate the use of a graph of the relationship of ISV melt temperature to melt viscosity with differing major oxides ratios.  MARTAC claim that this relationship was used to control melt temperature and melt viscosity.  Dale Timmons, a geochemical expert who designed the geochemistry for the Taranaki pits, comments: “Reference to Ca+Mg/Si+Al ratios being used to determine viscosity is incorrect.  Use of the graph in Figure 4.15 was presented and identified in my Geochemical Design as a convenient preliminary evaluation tool only and was identified as such.  This graph has nothing to do with how viscosities were calculated nor did it ever present any expectations.  It was simply an interesting observation that was made and presented.  MARTAC was informed of this on several occasions and this issue was addressed in my comments on the Final Draft Report.  This fundamental mistake made by MARTAC affects their conclusions regarding the viability of ISV throughout their report.  It is amazing that this glaring error has been repeatedly overlooked despite repeated advice to correct it.  Although my final report presenting all of the geochemical conclusions was presented to MARTAC, it is not referenced so I can only surmise that it is not attached as it should be.”

Page 226 starts with: “The expectation by all parties (the Department, MARTAC, the ISV Contractor) that by varying the composition of the material being treated, the melt temperature and melt outcomes could be determined in a predictable way was fundamental to planning for the application of ISV to the Taranaki waste disposal pits (Geosafe Corporation 1996a).  In practice, MARTAC held the view that these expectations were not met.  MARTAC reached this conclusion because at Taranaki melt temperature versus the acidic oxide : basic oxide ratio did not follow the trend of Figure 4.15.  The greatest outlier from the trend was for Pit 17 (temperature 1619EC, ratio 0.22).”  Dale Timmons says: “MARTAC reached their conclusion stated in this paragraph based on the wrong trend and the wrong ratios presented in Figure 4.15.  Thus their conclusions are in error. ......  MARTAC has overlooked, forgotten or misplaced this carefully documented evaluation.  MARTAC states that its ‘expectations’ were not met.  You must ask the question: What were MARTAC’s ‘expectations’ and are they consistent with Geosafe’s contractual obligations?  This is not stated.”

13. DEPTH OF MELT

There was always the question of how we could know that melting had reached the bottom of the pit, but it was generally agreed that since any uncontained debris would be under a 500 tonne rock, it was not a serious issue.  Even so, Geosafe was instructed to continue treatment 600 mm beyond the reported depth of each pit, of course with an increase in cost, to give some assurance that the bottom of the pit had been reached.

Page 244 relates some assessment of Pit 3: “It was found that the melt had not reached pit bottom and had been terminated prematurely.”  It is not clear who instructed Geosafe to stop the melt but a fax from GHD to Geosafe dated 23 June 1998 states that DPIE wished to “be involved in deciding when to stop the melt”.  A fax from Geosafe to GHD on 25 June 1998 says that the matter was discussed with Dr Perkins of DPIE prior to stopping the melt.  So who did decide the melt was complete?  And why criticise Geosafe if the decision was taken by the department?  These facsimiles are contained in Assessment of the MARTAC Criteria for the Treatment by In Situ Vitrification of Radioactive Pits in Maralinga, Geosafe Australia Pty Ltd, August 1999.  Unfortunately this document is not attached to the MARTAC Report.

14. UN-MELTED STEEL

Some lumps of plates could, perhaps should, have been expected because we received a report from Britain which said: “The heavy steelwork remaining on the firing pad was dismantled ......  One mass of steel plates welded together as a result of the explosion, and weighing approximately 10 tons ...”  See Oldbury in AWRE Report T4/61, Vixen B1, Operation Vixen B1 - it doesn’t say where the mass of plates was buried.

Great play has been made of unmelted steel especially in the block of Pit 15 (see for example pages 265, 271 and 277).  Again, the report does not tell of the instruction from GHD to Geosafe by facsimile of 17 October 1998: “This fax provides written confirmation of the advice to terminate melt 8 pit 15 today.”  This facsimile is contained in the Geosafe report just mentioned.

This unmelted steel was used by Senator Minchin in an attempt to explain why ISV was cancelled.  In a letter dated 6 August 1999 to the Maralinga Tjarutja, Senator Minchin said “Also, doubts have been raised as to the quality of the vitrified product with unmelted steel which is still contaminated being found in the bottom of at least two of the melts only some two metres below the surface.”  But there never was any requirement to melt the steel.  The strange logic is that unmelted steel covered by 2 metres of hard rock was not acceptable, but that same steel under friable soil is acceptable.

15. DEBRIS AND PLUTONIUM UNDER AN ISV BLOCK

The report describes the discovery of plutonium under the ISV blocks, for example at page 260, and uses this for further criticism of ISV.  Again this appears to be contrived criticism aimed at discrediting ISV.

Long before the ISV treatment of pits started, it was generally accepted that some uncontained plutonium beneath the ISV block would be acceptable.  This view continued after the treatment got under way.  In a paper, MARTAC Recommendations to ISR - Remediation of Pits, dated 29 April 1999, Keith Lokan, a member of MARTAC, and previously Director of the Australian Radiation Laboratory, said: “I still consider that, in view of the engineering trials and the outcomes so far, that the product is ‘good’, in that it incorporates/encapsulates the plutonium in a very stable waste form.  I am not swayed much by arguments about intrusion, deliberate or inadvertent.  I do not think that a tiny remainder below or at the edge of a buried 400 tonne block presents a significant intrusion risk (recall Peter Burns view at the last MARTAC that up to 10 grams [of plutonium] would be acceptable).”  Another statement at a meeting of the Consultative Group held on 13 April 1999 confirms that containment of all plutonium was not a requirement.  The minutes show: “Dr Williams noted that unincorporated plutonium at the bottom of a pit was not a major concern to ARPANSA ....”

Also, the third of those draft criteria did not require all of the plutonium to be incorporated in the melt; it stated most, viz:  Most of the plutonium should be distributed within the vitreous/ceramic component of the ISV product.

Even after the hybrid option had been adopted and some debris was to be vitrified ex situ, the regulator did not require or expect all of the plutonium to be encapsulated.  In a letter to Jeff Harris of DPIE dated 4 August 1999, Dr John Loy, the CEO of ARPANSA said:“For the ex situ vitrification to proceed there would also need to be a clear demonstration that ISV could incorporate the majority of plutonium contamination into a melt.  Without such a demonstration it cannot be accepted that ISV encapsulates the contaminated material in the melt matrix.  ARPANSA would require these issues to be resolved before it could approve the use of ISV in this option.”  The looseness in distinguishing between in situ and ex situ vitrification is apparent.

But the statement in the report (page 271) is different.  It says “The Regulator (Loy, 1999) pointed out at this stage (30 July 1999) that the inability of ISV to incorporate all debris brought into question the ISV process, particularly when large quantities of contaminated steel were involved.  It stated that it would require a clear demonstration that ISV satisfactorily encapsulated the contaminated material in the melt matrix before it could approve the use of ISV in the hybrid option.”  MARTAC omits the sentence: “For the ex situ vitrification to proceed there would also need to be a clear demonstration that ISV could incorporate the majority of plutonium contamination into a melt.”

So any comments in the report about plutonium under any ISV block should be discounted.  For example, the strange and somewhat meaningless statement on page 265: “The presence of this pedestal, meant that unincorporated and transferable plutonium contamination lay at a distance below the ground surface which was not acceptable to the regulator.”  It doesn’t say how much plutonium, where it could be transferred, nor how deep below ground surface, and there is no reference to any statement from the regulator saying this was unacceptable.

At pages 271 to 277, MARTAC presents very brief information on the exhumation of the ISV blocks.  In nearly every case, they note that there was no contamination found beneath the blocks demonstrating without doubt that vitrification was encapsulating all of the contamination.  The list does however note for Pit 4: “reasonably high contamination levels were found on the underside” and for Pit 13: “elevated readings were recorded” and Pit 15: “high gamma levels were found on the steel ..... and ....with high gamma levels” and Pit 19A: “found to be slightly contaminated”.  None of these statements are worth much, they need to be quantified.  It is not good enough to use meaningless terms such as these in a report by scientists.  This is particularly so if the levels of contamination can be accepted.  In any case, the whole block was radioactive since it encapsulated radioactive material, so it is not clear how they were able to separate single readings from the remainder of the block.

16. CRACKING OF ISV BLOCKS

After the first pit had been treated, MARTAC decided it should check to see how the resultant block compared with their draft criteria.  John Morris, a member of MARTAC, took on the task of comparing the blocks with the criteria, presumably at the request of the department.  It was not in MARTAC’s terms of reference to be so involved in the project.  One must ask why MARTAC should undertake such work since it casts doubt on their impartiality, and a Quality Assurance program should have been the responsibility of Geosafe or GHD.  Note that John Morris also undertook work on the Maralinga project under contract to the project manager while a member of MARTAC - surveying the geology of the soil burial trench and sinking a water bore at Taranaki.

The involvement by an advisory committee which had no position in the contract structure seems to have exacerbated the strained relations which existed between Geosafe and GHD.  The relationship between John Morris and Leo Thompson of Geosafe and others became very strained to say the least - others witnessed some very tense exchanges.

From then on MARTAC were much more involved than would be expected of an advisory committee.  Page 260, states: MARTAC’s QA program had two main components:

• Verification that all the waste components were incorporated or encased into the ISV ceramic phase.
• Verification that the plutonium was uniformly mixed within the ceramic phase of the melt.

Step 7 of the chart on page 223 shows that MARTAC “reviewed melts against original criteria” but they were not contractual.  There is no mention of the Project Manager and Project Authority doing such work, even though it was their responsibility.

Instead of allowing blocks to cool naturally, the soil was removed and, I understand, the blocks were drenched with cold water.  Dale Timmons says: “I personally advised MARTAC, Carolyn (sic) Perkins & Jeff Harris not to uncover, force cool and break open the monoliths.”

At page 263, MARTAC states: “The Taranaki blocks were not monoliths as they had fractured during cooling.”  And in a footnote to that page they add: “Monoliths could have been advantageous at Taranaki, had they been produced, as they would have contained no open pathways to the atmosphere through which air and water could have penetrated to attack the steel masses.  This matter would not have attained any significance, however, if the ISV treatment had incorporated all of the pit contents and if it had melted all of the steel contents, to ensure the transfer of all plutonium to the oxide phase of the melts.”  Why should MARTAC criticise the cracked ISV blocks when it is quite clear that the blocks were cracked because of the accelerated cooling.  Dale Timmons says: “I strongly advised Carolyn (sic) Perkins, Jeff Harris and MARTAC against uncovering and cooling the monoliths because cracking would result thus compromising the integrity of the monolith.  Much to my shock and surprise, this advice was ignored.  In essence, this major error on the part of MARTAC is being used to discredit the technology.”

Page 246 relates: “The Regulator noted in the same exchange that the process of excavating around and below completed melt blocks was undesirable ...”

17. WHAT HAPPENED TO THE LEAD?

I sat through a joint meeting of MARTAC and the Consultative Group on 12 May 1999, and heard members of MARTAC ask “What happened to the lead?”  Neither they nor GHD, nor ARPANSA could understand why there was very little lead showing up in the analysis of ISV blocks.  The minutes of that meeting show: “Mr Davy pointed out that .... MARTAC had reason to believe that significant plutonium contamination is expected to be found on the lead bricks used at the featherbeds.  Mr Davy added that large quantities of lead bricks had yet to be found in the exhumed pits or in the ISV product.  Mr Church added that, until more information is available, it is premature to say what the implications might be of less than expected amounts of lead being found.  In response to a question by Prof Johnson as to the possibility that the UK had recovered such things as lead bricks, Mr Davy stated that there is no mention in the historic records of recycling being carried out.  Dr Lokan added that Oldbury’s handwritten notes on what was in the pits specifically mention lead as being in the pits.”

It is when the report relates the finding of lead beneath the ISV blocks that MARTAC really demonstrates a lack of understanding of ISV and basic heat transfer.  Pages 280 and 281 go into great detail about the discovery of lead beneath the blocks, and the report indicates surprise at this discovery.  The report says: “It appears that the lead from within the pit debris had become molten during the ISV process and had settled to the base of the melt and then flowed into fissures and cracks in the underlying heat affected soil and rock.”  And then: “The lead had therefore migrated from the pits into in situ geological materials below the pit floors.”  Similar comments appear at page 155 of the GHD report.  Had they understood how the molten pool of soil and pit debris advances down into the pit, they should have realised that the lead was going to melt ahead of the pool and trickle down to the bottom of the pit and into the fissures in the rock.

At page 263 MARTAC says: “Lead metal in the pit debris was not generally processed by the ISV treatment and a substantial proportion of the total lead inventory escaped from the pits during the processing.”  That should have been expected.

But, according to page 281, they then removed some of this lead trapped in rock, 5 metres below ground, and placed it under friable soil less than five metres down.  Where is the logic?

18. EXPLOSION IN PIT 17

The explosion as treatment of Pit 17 was nearing completion has been debated on several occasions.  There can not be any definitive finding as to the cause of the explosion.  Geosafe arranged for an investigation into the cause and the conclusion was that the explosion was caused by some explosive material in the pit.  GHD employed another company to conduct an audit of that investigation.  The audit concluded that the explosion was caused by something in the pit but considered it more likely to have been a drum of volatile material.

Page 251 says: “The ISV Contractor also engaged SHE Pacific to further investigate the incident [the explosion of Pit 17].  SHE Pacific concluded that the most likely cause of the event was an explosion involving 2 - 3 kg of ANFO (ammonium nitrate fuel oil).”  The auditor’s statement in Attachment 4.5.7: “The final reports of Geosafe and its consultant contain factual errors and misunderstandings regarding ANFO.” seems to be misplaced since the Geosafe team included Orica, a major manufacturer of ANFO.

Page 252 shows MARTAC setting themselves up to be experts in everything.  The report says: “MARTAC concluded that the cause of the pit 17 explosion was probably something other than active explosive material being present in the pit.”  Both the SHE Pacific report and the audit of that report concluded that the explosion was caused by something in the pit and rejected notions advanced such as the explosion of gaseous carbon from exposed electrodes.  In Senate committee hearings on 3 May 2000, Malcolm Farrow said: “Even if we had looked at each piece [of debris] we would not have known whether it was the contents of the pit that had caused the explosion or a build-up of gas from limestone or what had caused the explosion.  We could not tell.  The experts could not tell.”  At the same hearings, Senator Minchin said: “.... if it were the process itself then it was not safe to continue.”  MARTAC and the department, with no expertise in explosives, rejected two reports by experts in explosives in favour of one that suited their own agenda (or the department’s agenda).  Both reports were paid for by the department.

MARTAC says at page 253: “The continuing uncertainty surrounding the pit 17 explosion and the concern it may have been intrinsic to the vitrification process itself ....”  The audit report says: “Geosafe is well justified in not reaching for speculative or far-fetched explanations in the absence of hard data and rigorous scientific arguments to support them.”  Dale Timmons comment on this item was: “The only hypothesis forwarded by MARTAC that blames the Pit 17 explosion on an intrinsic deficiency of the ISV process (exploding graphite electrodes) was determined to be silly.”

19. COMPARISON OF ISV WITH EXHUME AND BURY OPTION

A demonstration of how illogical everything became where ISV blocks were concerned appears at page 246.  The report relates how the regulator “proposed that the finished blocks be capped with concrete and that the whole of inner Taranaki be covered with a 1m layer of clean soil.”  How does this compare with the fact that the buried debris, no longer encapsulated in rock, does not have a concrete cap?

Another statement is on page 271: “The confirmation that the steel in Pit 15 had not melted, followed by the discovery of relatively large quantities of plutonium contamination on the base of the steel, contributed to the regulator raising concerns as to whether the remaining completed melts could be left in their present state within 2 to 3m of the surface.”  So the blocks were broken up and placed in the debris burial trench only 2.7 metres below the surface as shown in the report at page 267.  Where is the logic?  Also, what is meant by “relatively large quantities of plutonium” remembering that 1 milligram (one twenty-thousandth of a cubic centimetre) is sufficient to kill a person if breathed into the lung.  And how does this compare with Peter Burns’ view, related above, that 10 grams would be acceptable (about half of a cubic centimetre)?

To demonstrate the illogical stance by MARTAC and ARPANSA we have only to compare even partially encased debris trapped in a vitrified 500 tonne block of hard rock, with no encasement at all under 2 - 3 metres of friable soil.

20. AMOUNT OF PLUTONIUM ON PIT DEBRIS

Several reasons have been advanced in an attempt to justify moving away from ISV to the hybrid option.  One of them is that there was less plutonium than first expected.  The fact that these moves were underway long before there was any ISV or exhumation of pits shows this is already a spurious reason.  Throughout, MARTAC attempts to minimise the amount of plutonium to be expected in the Taranaki pits.  While making this attempt, they do not include anywhere the committee’s own estimate of 2.2 to 4.4 kg, made at the meeting on 29 - 30 November 1995 - seven months before the contract was signed to proceed with ISV.

The report states at pages 30 and 31 that there could be between 2 and 20 kg of plutonium in the pits (total), but tries to give the impression that there is “up to 20 kg”.  For example, on page 31 the first item in Table 1.6 claims the amount in the Taranaki pits “as estimated by TAG” to be “up to 20 kg”.  Yes the TAG Report does say that at page 39, but at page 29 it says “2 to 20 kg”.

Table 3.9 on page 130 gives the historic estimates of the amount of plutonium in the Taranaki pits.  The table shows various estimates made over the years - the most important being an estimate of 20 kg by Pearce (1964 and 1968).  This was never taken as a serious estimate from the start of the project, but MARTAC clings to that fictitious amount.

The table also says: “Cornish (1987) - Advice from the UK that the pits were unlikely to contain more than a few kilograms of plutonium”  In fact, Cornish says at page 48 “The conclusion is that the best estimate of total plutonium in all Taranaki pits is about 2.2 kg.”  MARTAC constantly ignores the estimate provided by Cornish, perhaps because it does not support their claim about the amount of plutonium in the pits being less than expected, but this was the guiding document for the preliminary engineering studies of the TAG.

The final item in the table reports an estimate of 2.2 kg contained in a letter from UK Ministry of Defence.  In fact that estimate totalled 3.1 kg, surely this cannot be an error in adding a column of numbers.

The report then states at page 132, that: “the amount of plutonium consigned to the pit exhumation trench from contaminated soil and steel in the outer pits, and from the ISV blocks which were ultimately disposed of in these trenches (sic) ... was 650 g”  This paragraph shows that GHD did not measure plutonium on everything exhumed from the pits.  In particular, they did not measure the plutonium on nine concrete firing pads exhumed from Pits 5 and 11.  Since these pads were ignored, MARTAC and the department have tried to deny their existence.  Dr Perkins gave an assurance in Senate Committee hearings on 3 May 2000 (Hansard page E38) that no firing pads have been missed, but their existence has not been recorded in the project reports.

The importance is that according to British reports, these pads could have been contaminated with up to 1.5 kg of plutonium.  Had those pads been monitored, it is possible that the actual amount could have been very close to our estimate.  Instead of admitting the mistake, MARTAC now tries to reject the British report.

In fact neither the MARTAC Report nor the GHD report mentions the firing pads, but MARTAC does note at page 260 that exhumed debris included “concrete fragments”.  I asked in a meeting of the Consultative Group that when exhuming the pits, they made sure not to break up the firing pads, otherwise the concrete fragments would be buried instead of vitrified.  It seems my request was ignored and the firing pads were broken up.

The minutes of a Consultative Group meeting on 31 March 1999 show: “Mr Davy acknowledged that estimating the level of plutonium in a disposal pit has a high level of uncertainty associated with it.”  So it is amazing that MARTAC can present a precise amount of 650 grams with no mention of the difficulty of making that measurement.  Attachment 4.10, Plutonium Inventory in the Burial Trench, by CH2M Hill, states at page 1: “The geometry of the twisted structural steel component is most problematic.  Repetitive measurements varied by a factor of ten.  Further there has been no consideration for self-absorption or in a few cases, attenuation by soils adhering to surfaces measured.”  That report then comments on the method of measuring the plutonium: “The methodology is not close to ideal.  Clearly, errors by a magnitude of 10 are possible for this component of the steel.”  Why were these cautions not included in the main report? [Note that the original title of that report was Estimate of Pu239 Inventory on Test Support Structures and Blast Walls.  This suggests that concrete firing pads were never intended to be monitored.]

The truth is that there can be no firm figure assigned to plutonium buried in the debris pits.

21. INTRODUCTION OF THE HYBRID SCHEME

When the contaminated soil was removed from central Taranaki, it became obvious that the debris pits were much larger than the British reports indicated.    This meant that ISV would cost more than had been quoted.  The department then said that some way must be found to cut the cost of treating the Taranaki pits.  The first time I heard of the department’s desire to cut the costs was in the silliest conversation I have ever had to endure during which I was told that “we have to find a way of reducing the cost.”  That was towards the end of 1997, at least eight months before ISV started at site, and when there were sufficient funds still available to cover the anticipated increased cost.

Even before ISV started at site in May 1998, GHD had put forward a proposal to exhume the outer pits and simply bury the debris (see pages 138 and 245).  It is not clear who asked them to prepare such a case.  At that time, I was asked by some-one in the Minister’s office for my thoughts on the matter and I replied by telephone and e-mail on 13 May 1998.

Page 245 says that the hybrid option, in which some pits would be vitrified and some exhumed, the contents sorted, some vitrified and some buried, developed from a MARTAC proposal in mid-1998.  But GHD put forward a proposal to the June 1998 meeting of MARTAC together with some cost estimates, which must have been prepared in May 1998 at the latest.

The report states at page 271: “[the ISV blocks] make up a distinctive marker layer on top of the more highly contaminated debris from the outer pits.”    This raises the question of why the hybrid proposal was to vitrify the less contaminated pits and exhume and bury the more contaminated pits - if they really did have to adopt the hybrid option, it should have been the other way round; vitrify the more highly contaminated pits

22. COSTS

Several times the report draws attention to the low estimated cost for ISV produced in the TAG Report; see pages xliv, 82, 83.  But the TAG Report states several times that there was considerable uncertainty about the costs presented.  Instead of referring to the TAG Report, MARTAC should acknowledge the estimates prepared before funds were sought from the Commonwealth government.  Two estimates were prepared.  One was $26.3 million and the other was $26.7 million and these were very close to the contracted price for ISV against the original scope - that price was $26 million.  All of MARTAC knew this so why do they introduce the TAG estimate which we knew was not reliable and was overtaken by a much more reliable estimate?

The two main reasons for the increase in cost for ISV were the very much larger size of pits than had been assumed when the price was prepared, and the drop in the Australian dollar compared with the US dollar.  A third reason which entered later was the requirement by GHD for additional vehicles, additional attachments for the excavator, and additional thermocouples and work required by MARTAC.

In Senate Estimates hearings on 3 May 2000, page E33 of the Hansard, Senator Minchin said: “Can I refute the scurrilous suggestion which I see floating around in the media that suggests that this decision [to cancel ISV] was made on cost grounds.”  But in every discussion of the move away from ISV towards exhumation of some pits, and in every paper, there is mention of the potential cost savings.  In some discussions the question of cost seemed paramount.  A paper prepared by GHD, dated 21 August 1998 that is not appended or attached to the MARTAC Report says: “The recent consideration of alternative treatments for these outer pits has arisen as a result of the revised estimate for ISV being considerably above the project budget.”  At a meeting between the Maralinga Tjarutja and DPIE and the Convenor of MARTAC on 28 October 1998, Mr Harris said: “If we went to burial we would save a lot [of money].  However, we are not pressing on costs.  If we save money out of it we have a better chance of putting it to uses on the project like monitoring.”

Page 140 reports discussions of the hybrid scheme.  Foremost in these discussions is that the option saves money.  In its discussions leading up to the cancellation of ISV altogether, the report mentions at page 253: “the costs associated with the delays [while investigations were completed and modifications made], .....  and the high cost of continuing with vitrification.”  And that exhumation and burial offered “a valid low cost alternative.”

These comments coupled with many more in discussion papers make it quite clear that cost played a major part in first of all curtailing ISV and then abandoning it all together.  But there were sufficient funds remaining in the budget for even the most expensive vitrification option, assuming competent management.  Dale Timmons commented: “These make the conclusions quite clear.  ISV was terminated due to cost in my opinion.  I believe that the vast majority of the alleged deficiencies outlined by MARTAC were made to justify going with a cheaper option.”  Leo Thompson echoed this view: “It was always about money.”

Page 256 says: “The exhume and bury option was now reconsidered, .....  There was sufficient experience on-site to establish that exhumation of untreated waste pits could be done safely and its costs could be reliably estimated to be lower than the ISV costs; and in particular, lower than the indicated costs of the hybrid option.”  This shows quite clearly that the final solution was determined on cost grounds.

There was an interesting statement in Appendix 3.3 of the report: “Dr Lokan pointed out that ARL will not countenance the digging up of all the pits.”  This comment was made during a discussion of characterisation of the Taranaki pits.  Within a couple of months, ARPANSA had been formed and the new regulator considered exhumation of all pits to be acceptable.

23. OCCUPATIONAL HEALTH AND SAFETY

In discussing injuries and accidents, the report says at page 321: “The one serious accident that could have caused major injuries or fatalities was the explosion of the ISV melt at pit 17.”

While acknowledging that nobody was in the vicinity of the explosion and nobody was injured, the report neglects other accidents which did involve workers and could have caused ‘major injuries or fatalities’.  There were at least three vehicle accidents; in two of which the four-wheel drive vehicles overturned and the other which could have been even more serious in which a truck stopped just short of plunging down an embankment.  Nobody was hurt in those accidents either, but all three could have had serious consequences and nobody dreamed of banning vehicles from site.

The report also fails to mention the occasion when the windscreen of an excavator was broken during exhumation of a debris pit at the TM site.  This broke the sealed environment for the operator.  Work was suspended for two days until a replacement screen could be made and flown in from Adelaide.  This event is reported in the video of the project and in the GHD report on page 103.

24. SAFETY OF THE SITE AFTER THE CLEAN-UP

On page 317, the report tells of the worker who arrived at the ARPANSA facility for his final lung monitoring and was found to be wearing a shirt contaminated with plutonium.  The report tells how he had “made occasional forays into the red area” [in his own clothes].  There was no investigation to check the person’s home and no knowledge of how many times he was contaminated.  There is no statement that he was the only one to breach the procedures.  The department has no way of knowing if others also breached procedures.

The report tells (page 317) of occurrences of non-designated employees working in red areas.  There was no explanation of how this could occur since to enter a red area the worker should have passed a health physics check point.

[Note workers in red areas were ‘designated’ employees, subject to medicals and health physics control.  Non-designated employees were not under that regime.]

Page 317 also mentions several further minor occurrences of low level skin contamination towards the end of the project.  What the report does not say is that by then health physics was out of control and they were monitoring workers outside red areas, even in white areas and recording contamination.  I have copies of health physics reports which show this.  [A white area was one in which there was no radiation and no health physics control.]  These occurrences raise some questions about the safety of the site post clean-up.

On my last visit to site we were made to wear overshoes and cotton gloves when we entered central Taranaki even though that area had satisfied the criteria and had been covered with clean soil.  Less than a hundred metres away, the land is thirteen times more contaminated and the Tjarutja have been told it will be safe for them to traverse that land with no health physics support.

I have twice asked ARPANSA to tell me what account they took of the thousands of tonnes of soil which blew across the soil removal boundary when they estimated radiation doses post clean-up.  I have never received a reply.  The ARPANSA Inhalation Dose Assessment presented at Attachment 6.2 notes that measurements of americium have fallen in the period 1994 - 2000.  The level of americium should have increased, not fallen (as americium-241 grows in from the radioactive decay of plutonium-241).

It is interesting to note Figure 4.10 on page 207.  Several high spots are shown along the centrelines of the north and north-west plumes.  The interesting point about the north-west plume is that the high spots are beyond lower contamination.  Whether this came about because of the soil carry-over is not known.

Attachment 6.2 provides the final dose assessment for the site.  It was prepared by ARPANSA and records lower dose assessments than those on which the project was planned.  When the project was planned it was estimated that the dose to an Aboriginal living a semi-traditional lifestyle on land contaminated with 3 kBq Am-241/m2 would be 5 milliSieverts per annum.  The final estimated dose at that level of contamination has fallen by a factor of five.  This appears to have been achieved by changing the assumptions on which the calculation was based, and by using a different model.  The five-fold decrease in estimated dose is mentioned on page 366.

It is interesting that the Minister said in his speech to the House of Representatives on 25 March 2003 that installation of boundary markers “proved to be a conservative approach.”  In his speech to the Senate on the same date, Senator Chapman echoed the Minister’s statement and added: “.... a restricted land use zone is not strictly required.  Even though it has been kept in place as a conservative measure, ARPANSA has concluded that restriction on permanent occupancy within the restricted land use boundary is purely a precautionary measure.”  But at page 366, MARTAC says: “Land-use restriction is still necessary however, to eliminate the ingestion pathway for infants.”

25. ABORIGINAL ACCEPTANCE OF THE CLEAN-UP

It is of course entirely up to the Maralinga Tjarutja to accept or reject the return of their lands after the clean-up.

Page xlii says: “None of the contamination of concern arose from the so-called major trials - the testing of nuclear weapons by evoking a nuclear detonation.”  This assumes that there was 100 per cent fission of the bomb materials, compared with the 30 per cent efficiency that was usual.  It also ignores the statement by ARL to the Public Works Committee and included in the TAG Report that the area of contamination around the Tadje ground zero will be of concern well into the future; it is something like 300 times more radioactive than the clean-up criterion.

The report records the end-state in terms of Becquerels of Americium per square metre.  Americium is not the important element - plutonium is far more important.  The report should have given the ratio of plutonium to americium for the three clean-up sites, but this might have highlighted an apparent anomaly.  The following table shows the Pu/Am ratio for the site contaminated with plutonium and the relevant clean-up criterion.  Examination of the values shown suggest that the criterion for TM101 should have been lower than that for Taranaki rather than higher.  The reason why this is not so is not explained in the report.
 

Site	Pu/Am Ratio (1988 value)	Criterion kBq Am-241/m2
Taranaki	7.2	3
TM100	21.6	1.8
TM101	7.7	4.0
Wewak	19.9	1.8

Neither does the report explain why the criterion for removal of fragments did not change from Taranaki to the other sites, even though the Pu/Am ratios differed.  It was after I asked for an explanation of this seeming anomaly (at the last MARTAC meeting I attended) that ARL decided that all fragments above 30 kBq Am-241/m2 should be removed from the TM site, rather than those above 100 kBq Am-241/m2, as explained on page 208.

The Tjarutja should take note of the slight contamination of workers moving into and out of the cleaned areas as mentioned above.

They should also take note of the statement on page 214 that the loader had difficulty lifting some contaminated debris at the Kuli site and that the health physicists stopped work because of the “rising levels of contamination”.  This debris was then left where it was and will be removed “next time suitable plant is on site.”  But the road leading to this debris has been ripped up.  Will it ever be removed?  When is there likely to be suitable equipment on site?

Page 46 of the report tells that the Maralinga Tjarutja accepted the clean-up described in Option 6 (c) of the TAG report, subject to payment of $45 million financial settlement for restriction of access to the fenced area of the Vixen B plumes.  Page 48 tells that the settlement to the Tjarutja was $13.5 million plus ‘significant’ non-cash items.  It seems to me that they did not get much for their non-cash items, only a bit of paid employment on the project.

The Tjarutja also have to realise that they will be relying on the government for assurances for thousands of years and the government did not honour agreements made only ten years ago.  For example, part of the agreement in the settlement of claims and agreement to Option 6 (c) was that there would be no changes without discussing the proposed changes with the Aborigines.  The decision to move to the hybrid scheme was made without adequate discussion with the Tjarutja and the decision to abandon ISV altogether was simply announced with no discussion.

26. PROJECT RELATIONSHIPS

I was asked by DPIE to comment on the proposal by GHD to take over the whole project without competitive tendering, rather than the part ACS won in open competition.  In my letter to Mr Rawson (DPIE) on 23 November 1997, I said: “Feedback from the site is that GHD are already behaving as though the change in management has come about and this is causing a lot of ill-feeling.  I believe that the project (and therefore DPIE) has been severely damaged in terms of cost, progress and relationships and the longer this continues the greater that damage will be.”  I did not receive any response and the appointment of GHD went ahead a month later.  The way that the GHD appointment was handled ensured ill feeling from the outset.

The report makes a spurious claim twice on page 80 that: “As well as the use of informal channels of communication, a more formal system of meetings and reports was instigated aimed at achieving an informed, efficient, cooperative and harmonious Project environment.”  They failed in this respect.  After I had left the project but was still an adviser to the Maralinga Tjarutja, I heard about meetings in which there was open hostility.  A senior person refused to attend a joint meeting of MARTAC and the Consultative Group (which I attended) because of the hostility.  Note this was raised in Senate Committee hearings on 3 May 2000 at page E60 of the Hansard.

There was also ill-feeling between the Maralinga Tjarutja and the department, especially over the cancellation of ISV.  This ill-feeling resulted in the Tjarutja writing to the then Minister, Senator Minchin asking for Mr Harris to be removed as Chairman of the Consultative Group.  It was in that same letter that the Tjarutja dissociated themselves from the decision to cancel ISV.

27. PHOTOGRAPHS

The report contains several photographs which are presumably meant to assist in understanding the project.  The choice of photographs is interesting and a couple of them show that the report authors did not understand what they were showing, or they deliberately chose them to show that rules and work practices were sometimes disregarded.

Figure 5.13 on page 336 shows people on the walkway which provided access to the earth moving equipment (this is the photograph in which I appear).  Why this photograph was chosen is a mystery since it shows us in our own clothes inside the red area.  This suggests we were breaking the rules, but in fact the photo was taken before soil removal started so that walkway had not been declared ‘red’.

The cover photograph for Chapter 5, page 303, is another mystery.  This one shows a scraper depositing its load of contaminated soil in the burial trench.  In our attempts to minimise dust raising, the work process was for the scrapers to deposit soil on the wetted part of the trench.  This photo shows the scraper depositing its load on the dry part of the trench.  Quite clearly the rule was broken.

Photographs on pages 183 and 327 show two different approaches to the same task.  Both photographs show an excavator in use to exhume debris pits.  The photo on page 327 is entitled Dust suppression during pit exhumation and it shows water being sprayed onto the debris during the exhumation.  The photo on page 183 does not show any dust suppression.

It is not clear why the cover photograph for Chapter 3, page 97, is included, except that it is a good photograph and makes a nice cover.  Another photograph of the same site is presented on page 352.  The strange thing is that the Tufi site was not part of the clean-up project.  As an aside, it was to have been the site of the next nuclear bomb explosion, but was never used.

Many photographs were taken of the plutonium contaminated debris found when soil was removed from central Taranaki.  Strangely none have been reproduced in the report.  Why?  Could it be that they show the extent of debris beyond the pit boundaries and would show why ISV was going to cost more than had been estimated and quoted?  Some of those photographs clearly show the pit cap and the debris beyond the cap.

28. INPUT BY ALAN PARKINSON

Following my removal from MARTAC, I received messages from the remaining members of MARTAC in which a recurring theme was the difficulty of writing the report without my input.  Examples are: “It will be a horrible mess doing the final report without you.  I hope some-one comes to their senses.”  “We (EVERYONE) hoped that the Dept would recant.  Everyone had a grizzle to Caroline [Perkins].”  “MARTAC has commenced the final report [19 July 1998] and as you would know the rough draft chapters are just that.  We are missing your input, and no doubt will continue to do so.” “I will miss your dry humour and valuable insights, and clearly we will not have a report as good as it would otherwise have been.  Many of us have pleaded with DPIE to at least let you serve as an adviser to MARTAC for the writing and editing of the report.”  “It will be a horrible mess doing the final report without you.”

And there were e-mails between remaining members of MARTAC, such as:“I was stunned and believe DPIE have cut off their noses to spite their face.  I really hope they will loosen a bit in letting Alan help us with the final report.”

Members of the committee also wrote to the department about this problem, for example to Dr Perkins: “I was stunned to receive news that Alan was no longer acceptable to DPIE.  This is a terrible blow to our ability to complete the MARTAC Report.  Is it possible for him to be hired as an advisor to MARTAC to assist in the preparations of the final report?  I strongly suggest some consideration be given for some kind of liaison/advising role be made so we do not have to be without the DPIE management corporate memory of the project.”  “I find it hard to think of anyone who has the same encyclopaedic knowledge of the rehabilitation project.  It may be too late, but would it not be possible for Alan to be contracted to edit the Departmental (or MARTAC) Report at the conclusion of the project.”

Des Davy sent an e-mail to members of MARTAC on 11 March 1998 saying that he had met with people at DPIE and: “Alan will not be re-engaged in any role - author, editor, reviewer, member - by DPIE.”  That e-mail was the one that told other members: “Jeff [Harris] has been put on notice that there will be a formal criticism of the decision/method of removal of Alan from MARTAC.”

All of this fell on deaf ears and the report has suffered.

29. REPORT EDITING

The report shows some really sloppy editing.  It is jumbled with the same subject sometimes addressed in two or more sections.  In some instances, the information differs when it is presented more than once.  For example, the area surrounded by the boundary markers is said to be 412 km2 on pages xliv and 120, but is 475 km2 on page 111.

There are some peculiar errors, such as in the Index on page xix which has strange ‘219' in the middle of the title for section 4.6.6.2.  And why is ‘Marcoo’ shown in italics on page 10?

The report is very vague in many places, using indeterminate terms like: burial at depth, nominal fence, satisfactory outcome, heavily contaminated, generally highly active, significant debris, relatively shallow depth, appropriate depth, buried at depth, deep trench and many more.

30. EXAMPLES OF MINOR MISTAKES AND SOME THAT ARE NOT SO MINOR

Pages xxxv and 397 - ALI means Annual Limit on Intake - not of Intake

Page 9 shows the Forward Gate in its original position.  Before the site work started, the gate was moved to just south of the road to Kuli.  This put all of the contaminated work sites, except the Airfield Cemetery, in the Forward Area.

Page 14 shows a photograph of Tietkens Well Number 1, and says it is near Taranaki - it is at Roadside.

Page 62 says: “Since 1998, when ARL was subsumed into ARPANSA ...”  ARPANSA came into being on 5 February 1999.

Page 63 says in the footnote that Method of Work Statements were part of the health physics regime.  They were part of the engineering design - not health physics.

Page 64 says: “When its [GHD] contract was varied in 1998 to project manage the ISV contractor’s work ...”  The contract variation to enact this change (and also to appoint GHD as Project Authority) was signed on 24 December 1997.

Page 69 says that the contract with Geosafe required them to: “evaluate the OAT [Operational Acceptance Test] and determine whether Phase 3 had been satisfactorily completed.”  This was not Geosafe’s responsibility.  This test was to demonstrate to DPIE that the equipment performed as per design, and if it did, then DPIE was to accept ownership on behalf of the Commonwealth.

Page 72 provides a list of persons or organisations appearing before the Public Works Committee which includes Mr RH Ashby.  He made a submission but did not appear at the hearing.

Page 78 says: “...the Department developed an Environmental Management Plan.  Copies of the plan were subsequently made available to all employees and contractors entering the site.”  I never saw any EMP, but the department did develop a Notice of Intent and employed ACS to prepare a Conservation Management Plan.  These were prepared to comply with legal requirements and were not available to the workforce.

Page 80, Table 2.2 lists the types and functions of meetings during the project.  The list is incomplete missing, for example, the weekly design meeting (one of the most important meetings), the monthly partnering meeting at site, the project review group meeting and the executive review group meeting.

Page 81 tells that the Convenor of MARTAC attended a Conference of Experts in July 1997.  It is not clear why this should be highlighted, but since it is, it should note that I also attended.

Page 82 says: “The major contractors and subcontractors to the Project (eg the Project Manager, the Health Physics Provider, the primary Earthworks Contractor and the ISV Contractor) provided monthly progress reports on their activities to the Department.”  This is wrong.  Only ACS/GHD and Geosafe did this.  I don’t know if Geosafe continued to provide reports directly to the department after January 1998 - even though they were contracted to the Commonwealth and therefore could be expected to provide monthly reports, they might have been required to provide them to GHD (the Project Authority and Project Manager) after that date.

Page 84 says that workers returned to Adelaide for rest and recreation.  While a few workers resided in Adelaide, more returned to homes in Melbourne, Sydney, Darwin, Ceduna, or Canberra.

Page 88 says that Hydrogen Services Pty Ltd maintained the pool of vehicles used to transport workers, staff, and visitors to and from the job site and the airfield.  This is incorrect.  Hydrogen Services, Steve Sheppard and Micheal Apostolides, were DPIE Site Representatives and their main function was to keep the DPIE Engineering Adviser informed of day-to-day events on site until January 1998.  As for maintenance of vehicles, they maintained DPIE and APS vehicles only, and assisted ARPANSA in maintenance of their vehicles using facilities in the village.  The other vehicles were maintained by Thiess using facilities in the forward area

Pages 89 and 306 say that movements of visitors to site were supervised by project management staff.  This is wrong.  Depending on who the visitors were, they might have been accompanied by project management staff, but most times they were not.  For example, when Thiess managers visited site, they were accompanied by Thiess staff when they went into the forward area and into red areas.  Usually visitors, as distinct from persons working on the project, were accompanied by department staff or representatives.

Page 102 says: “Table 3.3 summarises the radioactive contamination thought to be in the pits at the start of the Project (Pearce 1968) ...”  The Pearce Report was not the guide.  The Cornish Report was used.

Page 103 - The first item in Table 3.3 says that MARTAC’s assessment of the amount of plutonium in the Taranaki pits was 1 to 4 kg.  Actually we thought there would be between 10 and 20 per cent of the total plutonium used in the Vixen B trials.  That is 2.2 to 4.4 kg.

Page 110.  In the first paragraph of section 3.3.3.4 (approximately 280 kBq/m3 Pu239) should be kBq/m2.

On page 120 we are told: “The Regulator’s recommendations for the boundary line were endorsed by MARTAC and the MCG [Maralinga Consultative Group] in early 1999.”  A bit late for their endorsement; that work was complete by late 1997.  Also a typo APANSA, re ARPANSA

Page 130, Table 3.9 gives historic estimates of the amount of plutonium in the Taranaki pits.  It says: “Cornish (1987) - Advice from the UK that the pits were unlikely to contain more than a few kilograms of plutonium”  In fact, Cornish says at page 48 “The conclusion is that the best estimate of total plutonium in all Taranaki pits is about 2.2 kg.”  A few lines further down in the table is: “UKMOD (1999) - 2.2 kg with an estimate of its distribution across the 21 pits.”  In fact the amount shown in that reference added up to 3.1 kg.

Page 131 is an example of something throughout the report when discussing the amount of plutonium expected in the Taranaki pits.  Every time this topic is addressed the authors quote the Pearce Report and the TAG Report.  Every time they quote only “up to 20 kg” from the TAG Report.  They neglect the other estimate in the TAG Report which says 2 - 20 kg.  In any case, the TAG Report was not used as a guide.

Page 139 says: “...the extra overburden placed over the pit was leading to melts that ended up proud of ground surface ...”  This would have been of no great moment, but in any case the statement is misleading.  MARTAC should have added this happened only at two pits with the second and third melts.  All others that were reported to be below the surface - see GHD report page 126.

Page 140 says that an advantage of the hybrid option was: “It combines the best possible waste form for specific wastes, with an ability to bury contaminated soil in trenches consistent with previous practice.”  But then says: “Among the disadvantages listed was a discussion of the hybrid option requiring a continued major reliance on ISV ...”  Those statements seem to conflict.

Page 142 says that Geosafe said that it was no longer prepared to undertake ISV treatment of any pit at Taranaki.  Dave Osborne of Amec (the company operating the ISV equipment at Taranaki) told me that they had said they would continue with the ISV treatment of the two remaining pits (16 and 19B), but suggested they be taken into the hybrid option and the contents treated ex situ.  Leo Thompson of Geosafe confirmed this view.

Page 143 says that MARTAC concluded that burial of debris was consistent with the NHMRC Code.  I was at that meeting and Mike Costello (a member of MARTAC) said he did not believe the code was applicable, and I agreed with him.  Later, three of the authors of the code said it was not applicable - the other two would not comment, one was employed by ARPANSA and the other by ANSTO.

Page 144 again refers to 20 kg of plutonium in the Taranaki pits - we never assumed that, even if the TAG team did.

Page 145 should have mentioned that debris from pits at the TM and Wewak sites was placed at the bottom of the burial trenches (16 metres and 13 metres deep).  This is an important distinction from the burial of debris at Taranaki.

Page 145 says that the pits at the TM site contained no heavy items.  This is incorrect.  Some very heavy steel boxes were found in the TM pits which were very difficult to lift and transport to the burial trench.

Page 157 says: “With cost estimates available to TAG, the cost of treatment of burial pits decreased as excavation, grouting and ISV were in turn considered.  Reality was the reverse of this.”  This shows they were more concerned with cost than effectiveness of treatment.  They are comparing an old Holden Ute with a quality new car.

Page 163 describes treatment of informal pits.  It is incorrect, any exposed debris was not removed, unless it was contaminated and ear-marked for removal.  The debris was simply covered again, sometimes with compaction.

Page 164 shows a map of informal pits and the treatment they received.  The information is incomplete since it shows only those pits treated under GHD management.  Some pits were treated by DPIE Site Representatives on my instruction.

Page 169 says that the inventory of material deposited in the Marcoo crater “is not known but would be expected to include fences, gates, warning signs and target response waste, as well as small quantities of contaminated soil.”  Later on that page: “It seems reasonable to assume that at least the more bulky of the target response debris were placed in the Marcoo crater and, in particular, up to three caravans, five swift aircraft, eight aircraft wing sections and up to six 100-ft towers.”  No need to assume; had MARTAC looked at AWRE Report No O 19/69, Decontamination Aspects of Operation Brumby by BW Arliss and CR Thomas they would have seen a photograph of the aircraft and trailers in the Marcoo crater.  The report also confirms that contaminated soil from the Wewak site is buried in that crater.  And it lists other items of equipment such as two caterpillar tractors, one wheeled tractor one grader, one ten ton truck, five Land Rovers, all of which are still buried somewhere on the range.  There is another interesting and damning photograph in that report - it shows servicemen digging up cobalt-60 pellets at the Tadje site.  The men had no respiratory protection even though the Tadje site was heavily contaminated with plutonium (and still is).

Page 180 refers to: “The blue (uncontaminated) area ....”  While most of the blue area was uncontaminated, some parts were not.  The rest of the paragraph is misleading since the first trial was in an uncontaminated area and the second was in a slightly contaminated area.  The areas were not chosen: “to see if the proposed methods could handle the different ground conditions.”  They were chosen so that we could move up in surface contamination and still be on the ground to witness the trials.

Page 184 - vehicles were not modified to reduce dust generation.

Page 184 states: “Experience quickly dictated the need to operate high pressure surface cleaning jets at the lowest effective pressure in order to minimise the dispersion of possibly contaminated grease and to minimise reliance on rear entry suits ...”  I doubt if there were any rear entry suits on site; workers dressed in Tyvek suits, taped down the front and wore respirators when hosing down heavy plant.  Also, and more importantly, they used high pressure hoses, which explains why globs of grease could be seen high on the walls of the vehicle decontamination unit.  It might have been those globs of grease that made it impossible to decontaminate the walls of that building, a building designed for easy decontamination.  The walls were stripped off at the end of the project and buried.  The GHD report says at page 253: “The most effective technique for cleaning soils from plant and equipment was by using the hot high-pressure hose after application of degreaser or detergent. .....  This approach was used for the majority of the decontamination work.”  A low pressure hose was only used at the outdoor facility at the TM site, and possibly the Wewak site.

Page 185 relates how Method of Work Statements were submitted to the Project Manager for review, and how the Project Manager might prepare a Radiological Work Permit.  It does not say who approved these documents.  The same paragraph is wrong in saying that workers were required to sign the Job Safety Analysis.

Page 186 - Dust Suppression was a procedure not a design element.

Page 187 says: “Fractures in the filter brackets ..... were corrected before the filter failed ....”  It was not the filter that failed, it was the bracket attaching the filter to the vehicle

Page 190 relates monitoring by ARPANSA but does not say how they monitored where the ground was too rough for their vehicle-mounted equipment.

Page 191 says: “These [clearance] certificates indicated that the lots met all criteria and were classed as cleared.”  This is not strictly true.  Concessions were granted for some lots so that they could meet concessional criteria.

Page 197 reports how the surface of the soil burial trench was surveyed to measure the amount of plutonium.  This was done only when the soil from central Taranaki was being placed in the trench.

Page 200 says: “While all lots had met the clearance criterion of 3 kBq/m2, further soil was re-introduced to provide some soil cover in that part of the central region ... which to achieve the required criterion had been completely denuded to the underlying bedrock.”  This should note 3 kBq Am-241 per m2 but more importantly, three lots did not meet that criterion.  It would have been useful to add that the soil was introduced to protect heavy electrical cables that would lie on the surface during the ISV work.

Page 216 says that tight fitting lids were used when transporting pit debris to the burial trench.  It was not a tight fitting lid, and it was dispensed with altogether after exhumation of Pit 2U - the first to be exhumed.  It also says the exhumation proceeded without incident - that ignores a potentially serious incident when the windscreen of the excavator was broken.

Page 217 says that there was more stringent sealing of the transport bins when the debris from the Airfield Cemetery was transported to Taranaki.  The bin was not sealed for this transportation.  The bin was lined with plastic, the debris placed in and then the plastic sheeting was sealed at the top.

Page 221 says ISV was developed by the US Department of Energy.  It was developed by Battelle Pacific Northwest Laboratories.

Page 226 relates estimated costs for ISV to be $US6.2 million plus $US9.8 million for treating the 21 pits at Taranaki.  It does not quote the source of these estimates.  If we assume $A1.00 is equal to $US0.6, then the estimates become $A10.3 million for the equipment and $A16.3 million for treatment of the pits.  In fact the Geosafe price for the work was the other way round - $A17 million for the equipment and $A9 million for treating the pits.

Page 236 says: “Investigations around each pit before and after removal of the concrete caps on pits 1 to 19A (20 pits) ...”  When I did my radio talk on the Perspective series on 22 April 2003, I mentioned this mistake, pointing out that Pit 19A had no cap.  Des Davy, the Convenor of MARTAC has been telling people not to believe me because I am wrong.  This is one of the things he quotes and says he is on strong ground in saying I am wrong, but there it is in his own report.  Only 19 of the Taranaki pits were capped.  Des is equally wrong in other criticisms of my broadcast.

Page 240 says that because of the larger than expected size of the Taranaki pits, the number of melts required rose from 26 to 41, “with a corresponding increase in estimated costs”  The report should have noted that this was not a pro rata increase in costs - far from it.

Page 244 says that experience in exhuming pits at the TM site showed that pits could be exhumed safely.  This was never in question, so the statement is superfluous.

Page 245 says that “The concept of a hybrid option developed gradually from a MARTAC proposal in mid-1998, when MARTAC first considered the possibility of exhumation and reburial of the outer pits as a safe cost-effective alternative to ISV.”  This statement shows that cost was a driving factor in the move to curtail ISV.  While this might have been the first time that MARTAC considered the change, the concept started long before that in about September 1997.  GHD prepared the paper discussed by MARTAC in May 1998 and the question is who asked them to prepare the paper.

The first paragraph on page 245 says: “The remaining, smaller, debris would also be vitrified in ‘general debris’ pods, ....”  But then in the same paragraph it says: “The contaminated soil that was excavated from the outer pits along with the (<10 cm) debris was to be buried ...”

Page 245 talks about actions to be taken depending on the level of contamination beneath an ISV block but it does not explain how anyone could get under the 500 tonne block to make the measurements.  The paragraph is also clumsy in the way it expresses the radioactivity - instead of saying 10 kBq/g of Pu239, it should say 10 kBq of Pu239 per gram (of what?).

Page 247 says: “The explosion at pit 17, .... also led to a requirement to dispose of damaged equipment including the ISV hood.”  It was always intended to dispose of the hoods - that was taken into account when the ISV Burial trench was designed - didn’t MARTAC know that?

Page 248 tells that the lids of the filter units were removed so that voids could be filled with soda ash prior to disposal (in order to dispose of the unused soda ash also).  But removing the lid would have allowed access to only half of the units.  They should have removed one of the ends to gain complete access.

Page 260 is headed MARTAC’s Quality Assurance (QA) Program - Why would an advisory committee have a QA program?

Page 261 says: “... unmelted steel can sink to the bottom of the melt.”  This is what MARTAC was told to expect since steel is heavier than the silicate melt.

Page 261 relates how in retrospect, there was insufficient characterisation of the Taranaki pits.  This was because MARTAC decided against it.

Page 262 lists work that MARTAC describes as disruptive but most of the items listed were known before ISV started.

Page 263 again refers to melt temperatures and viscosity and says there was inadequate predictability in the melt temperature.  Dale Timmons says: “The incorrect assumption and thus incorrect conclusions are again presented regarding melt chemistry, temperature and viscosity.  Again, the predictions were far more accurate than anybody anticipated.  This statement and conclusion are completely false.”

Page 263 - MARTAC claims that the melt temperatures deviated from those predicted.  Dale Timmons says that the paragraph is “completely false, that predicted melt temperatures and viscosities were proven to be highly accurate, and such proof was provided to MARTAC.”

The headings of the table on page 273 are very confusing with headings such as: “Base of steel on steel; Melt above steel at steel; and Comments referring to steel steel”.

Page 289 says: “... the magnetic survey equipment was identifying a significant number of locations where subsequent excavations showed there was no metallic object.”  This repeated the experience of years earlier in which the survey indicated steel plates outside Pit 10.  The indication was solid rock and no steel.

Page 294 relates a survey of Pit 23U and says that the survey found a few pieces of metallic debris, which were removed, but no other.  Pit 23U was a very large pit filled with a great deal of metallic debris.

Page 295 states that: “The actinium was exhumed and buried in the Wewak burial trench.”  There were five locations of actinium and the whole lot was removed when the soil was scraped away for burial - it was not a separate exercise.

Page 295 relates finding a contaminated steel girder after soil had been removed from Taranaki; this could have been the girder found by Keith Lokan the day before the visit by the Public Works Committee.  The girder was removed to the soil burial trench.  The report doesn’t say exactly where the girder was found nor whether this was after the lot had been given a clearance certificate.  If this was after granting a certificate, then the episode demonstrates again the difficulty of guaranteeing a lot clear of contamination.  If this is not the case, then there was no reason to include this statement in the report, there were many pieces of contaminated steel found.

Page 306 relates that workers were issued with either a red or blue site pass.  It doesn’t mention those workers who remained in the Maralinga village and were issued with a white pass.  The report says that the passes were scanned as workers moved into or out of red or blue areas.  This is wrong.  Only red area passes were scanned as workers moved into or out of red areas.  However, a record was kept of workers entering or leaving the forward area - a daily log was completed and forwarded to DPIE to show who entered the forward area each day.