Despite ANSTO's attempts to trivialise the safety risks of the proposed new reactor at Lucas Heights in southern Sydney, there's no doubt that it would contain sufficient radioactivity to cause major off-site contamination in the event of a major accident and the failure of containment systems. Nuclear engineer Tony Wood, former head of ANSTO's Division of Engineering and Reactors, told the 2000-2001 Senate inquiry into the reactor plan that the proposed new reactor “when operating at full power will contain sufficient fission products to cause great damage off site if a large fraction were to escape.”

Likewise, a 1995 report from MHB Technical Associates, commissioned by the Sutherland Shire Council, said that HIFAR, or any similar or larger reactor, “is potentially subject to severe accidents involving fuel melting which have the potential to release sizable quantities of radioactive material into the environment.”

The safety debates involve issues such as what type of accident would constitute a worst-case accident (or “reference accident”), the likelihood of such an accident, what proportion of the reactor’s radioactivity might escape to the environment, and what consequences a serious accident would have.

The Senate inquiry heard from Daniel Hirsch, the former director of a nuclear policy research program at the University of California and currently co-chair of the Santa Susana Field Laboratory Advisory Panel, an independent oversight body for the US Department of Energy. Hirsch is visiting Australia at the invitation of the Sutherland Shire Council.

Hirsch disputes ANSTO’s dismissal of an accident in which coolant (or water) would be lost thus exposing fuel rods. Hirsch says that at least half a dozen loss-of-coolant accidents have occurred around the world.

ANSTO’s assertion that a loss-of-coolant accident can be dismissed as being too unlikely to  contemplate is premature, since a detailed design for the proposed reactor has yet to be produced. ANSTO uses the conditional clause, as in the Final EIS: “The pool structure and beam tube penetrations would be designed to be so robust that a large loss of coolant accident is not considered credible.”

Hirsch said he was astonished to find that the environmental impact statement for the proposed new reactor took place in the absence of a reactor design.

An October 31 media release from ANSTO says, “three independent peer reviews of the Draft Environmental Impact Statement for the replacement research reactor ... confirmed that the “reference accident” assumptions and outcomes, were appropriate.” This assertion is partly misleading, partly false:
* the review by the International Atomic Energy Agency (IAEA) said “full justification for the selected Reference Accident is not included in the EIS”.
* the Review by Parkman Safety Management said, “As no specific design has yet been chosen, it is not possible for a full and detailed safety assessment to be undertaken at this stage.”
* and the Review by CH2M Hill said “The probability of occurrence and potential consequences of a given accident sequence are highly dependent on the specific design and operational features of a reactor facility. Because these details have not yet been finalised for the proposal, it is not possible to develop a detailed quantitative assessment of accident hazards and risks at this stage.”

Sabotage

The Sutherland Shire Council is concerned that ANSTO all but ignores sabotage as a risk, particularly in light of previous attempts at sabotage such as the 1983 discovery of significant quantities of gelignite and ammonium nitrate, and three detonators, inside ANSTO’s boundary fence.

Tony Wood says a sabotage event “has the potential to have much worse consequences [than ANSTO’s selected reference accident] and the EIS admits there is no way of assessing its likelihood.”

At the October 25 hearing of the Senate inquiry, Wood expressed concern about the pool-type reactor proposed by ANSTO: “Pool reactors have a free water surface and this very feature, which is desirable for flexible access to the core, also makes it vulnerable. The EIS claims credit for the massive reinforced concrete block of the pool but this is the very thing which would direct the force of an explosion into the reactor core and expel fuel and water.”

Wood urged the Senate committee to urge the federal government and ANSTO to conduct an assessment of the potential consequences of sabotage:  “When it comes to the confidential assumptions about types and quantities of explosives which could realistically be used I would like to see input from SAS or other military experts because I believe, in the light of what has been said on this topic in the EIS, a degree of realism is missing at ANSTO.”

A related issue is the poor status of staff/management relations at ANSTO. ANSTO staff members, self-described as ANSTO “Staff Representing Truth in Science” said in a March 3 letter to a Sutherland Shire Councillor that, “The last 4 years have seen unprecedented industrial actions resulting in lost-time for ANSTO. The staff morale is exceptionally low ... because of unprecendented ineptitude at senior management level.” This raises the spectre of sabotage, and it could lead to an exacerbation of an already critical problem: the lack of nuclear and engineering expertise at ANSTO.

Earthquake

ANSTO’s dismissal of earthquakes as a potential initiator of a serious accident has also been called into question. The federal government commissioned the New Zealand Institute of Geological and Nuclear Sciences and other experts to assess the likelihood and potential impacts of an earthquake on the Lucas Heights nuclear plant.

The chair of the technical review committee concluded that: “The TRC considers the assessment provided by IGNS Ltd. does represent the most comprehensive review of potential earthquake motion in the Lucas Heights region that has been undertaken to date, and the general methodology employed conforms to recognised international standards.”

The IGNS report found that the impact of an earthquake could be almost twice that previously predicted. Subsequently, the government refused to release the report for some months, and the IGNS report is currently being “reviewed” by government agencies behind closed doors.

Dr. Garry Smith, from the Sutherland Shire Council, told the October 25 Senate hearing, “The report of that independent consultant was to the effect that the estimation for earthquake came up with an earthquake size, a peak ground acceleration, approximately twice the size of that previously assessed by ANSTO and others. Our concern is that that measure of twice the earthquake has not entered into the specification process for the design of the reactor. From what we have seen - we are addressing this with ANSTO and ARPANSA - it was to some degree the earlier earthquake specifications that were initially used for the tendering process and so on. And we do not know what the current earthquake specification for the design is: whether that New Zealand study, which is agreed to be the most comprehensive study to date, has been taken on board, or whether there is some earthquake number in between, or whether it is the low number. ... What is of particular concern is that the process of assessing this issue is occurring post-EIS, it is occurring in a non-public process between ANSTO and ARPANSA, and the public has no access to how that government information is being used. It is a real concern to us.”

Smith said, “If there is any uncertainty with respect to the size of an earthquake which can potentially affect radioactivity release, surely the public can expect that the government will err on the side of caution and safety. You do not ignore a report just because you are not sure or the estimates have some level of uncertainty. You build in an inherent level of safety to overcome the uncertainty. I am not confident, having been part of those committee processes and now part of ARPANSA, that under the current process those levels of uncertainty are being adequately addressed. ... I have real concerns about the level of safety that will be achieved by the reactor with respect to things like earthquake specification. It costs money to build in safety features.”

Consequences

ANSTO claims the most “credible serious accident” would release one millionth of the radioactivity of the core of the reactor. Based on previous reactor accidents, Daniel Hirsch says that a more appropriate figure would be several-hundredths of the core radioactivity. ANSTO arrived at its optimistic conclusion in part by ignoring many of the radionuclides that would be released in the event of a serious reactor accident.

A serious reactor accident at Lucas Heights would have health effects (e.g. fatal cancers, non-fatal cancers, genetic effects) and many other effects: decontamination costs, evacuation costs, restrictions on food consumption, litigation costs, and overall impacts on economic output. As MHB Technical Associates notes, “Even relatively small radiological accident releases have resulted overseas in large societal costs within the ‘evacuation shadow’.”

Dr. Greg Storr, an ANSTO scientist giving evidence to the Senate inquiry on October 25, described a fatal research reactor accident at the SL-1 reactor in the USA in 1961:  “Three operators died. It was a research sized reactor. It was caused by what was called a reactivity excursion. It was caused by one of the operators deliberately withdrawing one of the control rods - that is one of the pieces of material which controls the neutron reaction -  and that action sent the reactor to what they call superprompt critical. When it went superprompt critical, there was a large increase in the temperature in the reactor core, the water boiled and it caused a water hammer effect which accelerated the slug of water above the core up in to the pressure vessel. The pressure vessel broke and it accelerated up and hit the roof, pinning one of the operators to the roof. The two other operators died later from radiation exposure. That is the SL-1 accident.”

Several other fatal research reactor accidents have been recorded, most recently in the USA in 1998 during maintenance operations at a research reactor.

Health effects of radiation

Another safety-related debate concerns the health effects of low-level radiation.  Despite being Australia’s largest nuclear agency, ANSTO cannot make up its mind on this topic. On October 30 (as reported in the October 31 Sydney Morning Herald), ANSTO said that in the “improbable event of an accident, community impacts would be negligible”. The following day, ANSTO announced that a reactor accident would have “no health impacts on the community” (emphasis added).

This confusion was also evident in an internal Department of Industry, Science and Resources (DISR) 1998 briefing document, obtained by the Sutherland Shire Council under freedom of information legislation. The document ponders the best euphemism to describe the health risks from radioactive emissions from the planned new reactor. “Don’t say no extra risk - acceptable risk?? ... There are risks associated with everything.”

“Be careful in terms of health impacts - don't really want a detailed study done of the health of Sutherland residents”, the DISR document said. (Alan Parkinson noted in his Senate submission that a senior DISR bureaucrat did not one of the most basic facts in the field of radiation studies - the difference between alpha and gamma radiation. An adviser to Senator Minchin is revealed by Parkinson not to know the difference between an acid and a base.)

Further safety concerns derive from the lack of nuclear expertise at Lucas Heights. Tony Wood said in his submission, “It is a fact ... that ANSTO now only has a small team of dedicated reactor professionals most of whom are operating HIFAR and they are fully extended. ... I suggest that the [Senate] Committee seek assurance from the Government that experienced reactor engineers be hired by ANSTO to pursue the proposal from now on. So far they have been conspicuous by their absence in the team.”

ANSTO staff members - self-described as “Staff Representing Truth in Science” - wrote to a Sutherland Councillor on March 3, saying, “Because of inept executive management there is no succession planning within the organisation. Although it will be strongly denied by ANSTO, it is well known by those in the field that the new reactor project is having difficulty finding sufficient nuclear literate staff to address the tender process. It is understood that the current full-time staff on the program had their origins in the AAEC and are up for retirement. Inept management, no succession planning? Who is going to safely operate a new reactor in Sutherland Shire.”

Another issue which impinges on safety is the significant likelihood of a cost blow-out associated with the new reactor project, which could lead to cost-cutting in areas affecting safety (e.g. design parameters for the proposed new reactor, e.g. staff retrenchments). Jim Fredsall, former president of the Australian Nuclear Association and a former ANSTO nuclear engineer, said in his submission to the Senate Inquiry that the new reactor would be a constant drain on the taxpayers of this country for the next half century.

ANSTO “Staff Representing Truth in Science” wrote in their March 3 letter, “it is known that the reactor replacement costs are projected to blow out considerably more than the amounts told to the Federal Government, but once the project is started it will have to be completed irrespective of costs. A number of staff believe there should be an independent external review of financial management at ANSTO and the real costs of a new reactor.”

ANSTO claims that even for the “hypothetical maximum credible accident”, no countermeasures beyond the 1.6km buffer zone would be required. Emergency planning is inadequate and will remain so because of the head-in-the-sand approach taken by ANSTO and by federal and state governments.

Daniel Hirsch makes the important point that the trivialisation of the safety risks associated with the Lucas Heights nuclear plant actually increases the risks: “... a blind belief that no serious harm can occur, no matter what goes wrong with the reactor, no matter how serious the operator error; produces a markedly increased risk, as any review of past nuclear accidents will demonstrate.”

Insurance

In the event of a serious reactor accident at Lucas Heights, Sydney residents would find it extremely difficult or impossible to pursue compensation claims.

According to Michael Priceman from the Sutherland Shire Environment Centre, “The [ANSTO EIS] report on the suitability of Lucas Heights as the site for a new reactor ... found that it was perfect, based on what ANSTO described as its pessimistic assumptions that the frequency of a worst case accident was one in a million per year and therefore the maximum risk to an individual developing a fatal cancer was one in 6 billion per year. Armed with those sporting odds the Insurance Council of Australia still refuses to insure the public.”

With respect to government indemnity, Tony Wood said in his written submission to the Senate inquiry that both ANSTO and the government have “misled” the public and that ANSTO’s EIS was “genuinely confused, or ... had set out deliberately to confuse.”

Wood notes that, unlike many countries in Europe, North America, and elsewhere, Sydney residents are not protected by absolute liability, which frees the claimant from having to prove anything other than damage as a result of a reactor accident. Instead, Sydney residents effected by a nuclear accident would only have recourse to common law, which requires that the aggrieved party prove both damage and negligence.

The government knows that it has misled the public, Wood says, “yet not only has it chosen to do nothing about it, but it has misinformed the community that a Deed of Indemnity it has produced for a different purpose does provide equivalent financial security, when clearly it does not.”

Wood says the Deed of Indemnity was designed to attract bidders for the reactor project: “In the absence of absolute liability of the operator in Australia the Government faced a dilemma because no overseas reactor vendor would consider bidding because if he (sic) were successful he (sic) could be held liable in the event of an accident. Although the Government has chosen not to indemnify its own citizens, it must indemnify the reactor vendor if it wants a new reactor. Hence the Deed of Indemnity was produced last year, which does in fact indemnify the vendor.”

Wood says it is a “mystery” to him why the Government has not accepted absolute liability: “It looks as if the Commonwealth lacks confidence in the low level of public risk claimed for the new reactor in the EIS. If it is so low what is to be lost by offering the guarantee.”

Wood quoted the US Presidential Commission on Catastrophic Accidents, which said in 1988 that applying common law principles to nuclear accidents would result in an outright denial of recovery or a difficult and protracted process.

A former engineering director at Australia's only nuclear reactor said today that safety measures at the existing facility were inadequate and did not cover public safety.

Speaking at the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) public forum on the building of a new reactor at Sydney's Lucas Heights, Tony Woods said the facility "didn't have adequate protection for anything".
"Our (safety) procedures are so cumbersome, and they'd take so long to implement, they'd be ineffective," he said.

Mr Woods, who retired in 1991 after 30 years service at Lucas Heights, said the "safety culture" at the facility had to be greatly improved.

He said the current Australian Nuclear Science and Technology Organisation (ANSTO) safety plan only considered plant employees and did not include any measures for the public.

Mr Woods said the Sutherland Shire Council's contingency plan anticipated many emergencies, including earthquakes, but did not consider a nuclear accident.

"If you look at the plan regarding the public, there's no mention of the reactor. It's like it isn't there," he said.
He cited the example of a reactor employee who was refused admission to Sutherland Hospital, one of the nearest medical facilities to Lucas Heights, because of a wound that was contaminated.

Mr Woods urged planning for a worst-case scenario of complete core meltdown plus major containment failure, including evacuation procedures and prior distribution of medicines.

He also said a smaller research reactor like the one planned would be more vulnerable to an act of sabotage or terrorism because it isn't as well fortified.

"The main reason a terrorist would attack this (facility) is not to kill a lot of people but to terrify them," he said.
"If we've got a good plan we can protect people ... that's more effective than fortifying the reactor."

But there was one very significant positive in Mr Woods' presentation - nuclear accidents were not as catastrophic as people imagined.

He said research showed that many of the illnesses anticipated after the accidents at Chernobyl and Three Mile Island, including leukaemia, did not manifest themselves among the population as expected.

Thyroid cancer was the only illness that boomed after Chernobyl, which Mr Woods said could be nipped at the bud by using iodine tablets.

He said the biggest health hazard in the event of a reactor accident was the psychological effect of the incident, and better communication was needed.

"People don't have the correct perspective as far as radiation is concerned," he said.

"You'd go in an get an X-ray and you wouldn't ask what the dosage is.

"I think ANSTO has a problem in so much as it likes to sugar-coat its information.

"They feel the public can't take information that could cause them concern.

"I think (consulting and informing external bodies) is better for the project and better for everyone."

--AAP