NICK MINCHIN, the federal Minister for Industry, Science and Resources, asserts that the "national interest" is driving his search for a national radioactive-waste dump site.

However, the search is being driven not by the national interest, but by nuclear interests - in particular the need for the Australian Nuclear Science and Technology Organisation to get rid of its waste stockpile in order to minimise public opposition to the plan for a new reactor in the Sydney suburb of Lucas Heights.

The Federal Government understates ANSTO's contribution to the national waste stockpile, and plays with words and fiddles with figures to achieve that end. Yet Des Levins, director of ANSTO's radioactive-waste management division, has publicly acknowledged that there is "no doubt" that "the major fraction" of the waste sent to a national dump would arise from ANSTO's operations at Lucas Heights.

There are two proposals on the table: one to dump low-level waste in unlined trenches; the other for an above-ground store for long-lived intermediate-level wastes.

The Federal Government will conduct its own "assessment" of the plan for a low-level dump in South Australia over the next 12-18 months. The SA Government has given support in principle to the dump, but surveys show that 86-95 per cent of South Australians are opposed to it. The fiercest opposition comes from traditional owners.

Still more contentious is the Federal Government's plan for an above-ground store for intermediate-level wastes, including those arising from the reprocessing of ANSTO's spent fuel rods.

ANSTO has signed contracts with the French reprocessing company Cogema. Overseas reprocessing is "safe and responsible" according to Minchin, but "contrary to sound non-proliferation principles" according to the Department of Foreign Affairs, "morally dubious" according to the 1993 Research Reactor Review, and dirty and dangerous according to the many Europeans who are fighting to end reprocessing at Cogema's plant and at British Nuclear Fuel's notorious Sellafield plant.

What if the Cogema contract falls though - just as an earlier plan to use the Dounreay reprocessing plant in Scotland did? A different answer is given to this question whenever it is asked.

Minchin says there is no contingency plan because the Cogema contract is firm. ANSTO says the contingency plan is "extended interim storage" of spent fuel at the proposed above-ground intermediate-level waste store while an alternative overseas reprocessing option is negotiated. Minchin's Department of Industry, Science and Resources insists that the above-ground store will not be used to store spent fuel rods.

The Cogema contract is a "curie-for-curie" deal - as much radioactivity as is reprocessed will be returned to Australia. The Federal Government and ANSTO planned to co-locate an above-ground store with the low-level dump in SA. Yet that proposal has ignited such hostility in SA that the state Parliament will soon pass legislation prohibiting the construction of a store for intermediate-level waste.

Nick Minchin and the Prime Minister, John Howard, have responded by threatening to override this legislation - an interesting twist, given that Minchin represents SA in the Senate and given Liberal rhetoric about "states' rights". Minchin and Howard's response has of course hardened opposition in SA not only to the proposed store for intermediate-level waste, but to the proposed low-level dump.

The Federal Government may have the legal clout to override SA legislation, but it is highly unlikely that it will attempt to do so, given the extent of public opposition in SA.

Another option is to build a plant to treat spent fuel in Australia, followed by long-term storage at the proposed above-ground store and eventual disposal in a (non-existent) deep geological repository. ANSTO's executive director, Helen Garnett, told a Senate estimates hearing that Lucas Heights would be a "reasonable" location for a "pilot" reprocessing plant to treat spent fuel.

In March 1998 an unnamed senior government bureaucrat told ABC radio's Background Briefing that "Cabinet considered reprocessing, but decided it was an issue for another generation. Someone else can worry about it. And reprocessing is a possibility then . . . but that's 20 years away."

With so many waste-management issues unresolved, it is irresponsible for the Government and ANSTO to proceed with their plan for a new reactor which will generate another 1600 spent fuel rods and which will, according to ANSTO documents, result in a 12-fold increase in the annual production of intermediate-level liquid wastes and a four-fold increase in the annual production of all other waste categories.

According to Garnett, ANSTO is working to a "wouldn't-it-be-nice" timetable in relation to waste management. However, deadlines are fast approaching. Both the Australian Radiation Protection and Nuclear Safety Agency and the Environment Minister have to agree that "satisfactory arrangements" exist for spent-fuel management before construction of a new reactor can begin in 2002.

A May 16 article in the Bulletin said Minchin would need a selling technique "hotter than radioactive waste" to persuade ARPANSA and the Environment Minister to allow reactor construction to begin in 2002, by which time a site for an intermediate-level waste store may (or may not) have been identified, but the store not yet assessed, approved or built.

However, the Bulletin may be overestimating the independent regulator's independence and the Environment Minister's interest in the environment. The legislation which gives ARPANSA its existence is the same legislation the Federal Government proposes to use to override SA legislation.

Garnett sat on the selection panel of three that interviewed applicants for the position of chief executive officer of ARPANSA. Not surprisingly, the successful applicant appears not to be troubled by ANSTO's role in selecting its own regulator.

The waste issue is just one of the problems with the plan for a new reactor at Lucas Heights. The argument that a new reactor is required for medical-isotope production has become so implausible that the Government now concedes that the debate over isotope-supply options "has not been resolved satisfactorily".

No cost-benefit analysis has been conducted of the reactor proposal, nor is one planned - a source of considerable consternation within Treasury. National security has been identified by government departments as the "cornerstone" of the alleged need for a reactor, yet the most detailed public document on this topic is a seven-page, unreferenced document from the Department of Foreign Affairs and the Australian Safeguards Office.

The aforementioned Canberra bureaucrat told Background Briefing that the strategy to deal with opponents of the planned new reactor in Sydney was "to starve the opponents of oxygen . . . just keep them in the dark completely." ANSTO is no better - even the president of the Australian Nuclear Association has recently complained about the "culture of secrecy" at ANSTO.

Small wonder there is a growing campaign, initiated by the Sutherland Shire Council and the Australian Local Government Association, for a Royal commission to hold the Government and ANSTO accountable for their furtive, undemocratic and dishonest handling of both the reactor and waste issues.

1. SUMMARY
2. SPENT FUEL
- Cogema
- Argentina
- other overseas reprocessing options
- domestic management of spent fuel
- 'extended interim storage' of spent fuel
3. PROPOSED NATIONAL STORE FOR LONG-LIVED INTERMEDIATE-LEVEL WASTE (LLILW)
4. FINAL DISPOSAL OF LLILW
5. LOW-LEVEL REPOSITORY

1. SUMMARY

ARPANSA cannot justify issuing a licence to construct a new reactor because of the failure of ANSTO and the federal government to put in place satisfactory waste management strategies:
- it cannot be assumed that overseas reprocessing options will be available over the lifetime of the proposed reactor.
- domestic spent fuel storage and treatment options are severely constrained. For example, the ARPANS Act prohibits domestic reprocessing; the ANSTO Amendment Act prohibits long-term storage at Lucas Heights; DISR has unequivocally stated that the proposed national long-lived intermediate-level waste (LLILW) store cannot be used for interim storage of spent fuel; etc.
- ARPANSA CEO John Loy says that progress on the LLILW store would be required before issuing a reactor construction licence yet the only 'progress' on the store has been backwards.
- no progress whatsoever has been made with respect to ultimate disposal of LLILW.
- some progress has been made with respect to a low-level repository but that project is by no means a fait accompli.

2. SPENT FUEL

Condition #26 attached to Senator Minchin's approval of the new reactor EIS: "Reactor construction should not be authorised until arrangements for the management of spent fuel rods from the replacement reactor have been demonstrated to the satisfaction of ARPANSA and the Minister for the Environment and Heritage."

Reprocessing is prohibited in Australia (under the Australian Radiation Protection and Nuclear Safety Act). Senator Minchin says that "each nation should look after its own waste". The 1993 Research Reactor Review (p.212) said that "exporting an Australian problem is morally dubious." So why then is it acceptable for spent fuel from Lucas Heights to be reprocessed/conditioned in Europe, Argentina or elsewhere? "Repatriating" spent fuel to the USA under the provisions of a non-proliferation program is equally problematic and contradictory. ANSTO's recent interest in sending spent fuel to Russia (possibly on a no-return basis) is still more problematic.

COGEMA

The availability of the Cogema option over the lifetime of the proposed new reactor cannot be guaranteed or assumed. There is considerable pressure from numerous member states of the OSPAR Commission (which regulates marine pollution in the North East Atlantic) for the cessation of reprocessing at both La Hague and Sellafield. In all likelihood this pressure will continue to increase. Incidents such as the delay with the unloading of ANSTO's last shipment of spent fuel at a French port may become increasingly common and such disputes increasingly protracted.

The German government and nuclear utilities have agreed that shipments of spent fuel from Germany to overseas reprocessing plants (France, UK) will cease from 1/7/2005. This further jeopardises Cogema's future. A report in the 26/5/00 World Information Service on Energy News Communique noted, "Without the German orders both reprocessing plants [Cogema and BNFL] could hardly survive. ... Germany is La Hague's biggest customer." <www.antenna.nl/wise>

Licensing and authorisations are not in place for ANSTO's current spent fuel stockpile at La Hague let alone for fuel from the planned new reactor.

ARGENTINA

ANSTO's comments on INVAP's capabilities have been deceitful. ANSTO told Jean McSorley on 6/10/01 that: "INVAP has satisfied ANSTO they already have the basic facilities and technology that would be required should processing by INVAP be needed." Yet INVAP told McSorley: "CNEA has developed a novel method to eventually process its own research reactors fuel elements, which can be also useful for ANSTO project. The present demonstration program has a duration of four years, starting 2001."

Argentina's constitution prohibits the importation of radioactive waste. The pretence that spent fuel does not constitute radioactive waste is increasingly untenable - in Argentina, France, Australia and elsewhere. In 1993 the Research Reactor Review (p.xxiii) insisted that "The pretence that spent fuel rods constitute an asset must stop." Yet a Department of Industry, Science and Tourism (DIST) briefing paper, dated April 1998, obtained by Sutherland Shire Council under Freedom of Information legislation, asserts that spent fuel is not "waste" but is instead a "resource". And ANSTO and the government rely on this semantic nonsense with respect to Argentina.

OTHER OVERSEAS REPROCESSING OPTIONS

ANSTO's Draft EIS (p.10-18) states that "It can ... be concluded the service [reprocessing LEU uranium research reactor fuel] will be commercially available for the proposed replacement reactor fuel." This conclusion is based on pilot reprocessing of LEU research reactor fuel in the UK and the USA, and indications from Cogema that it was prepared to reprocess LEU uranium fuels on a commercial basis. In a submission to the Senate Select Committee, ANSTO lists a number of organisations capable of reprocessing or conditioning research reactor spent fuel (other than Cogema): US DoE, UK AEA, BNFL, CNEA (Argentina), and Minatom (Russia).

However, ANSTO acknowledged in its Draft reactor EIS (p.10-18): "Currently no facility is routinely reprocessing low enriched uranium research reactor fuels."

BNFL / UKAEA

Widespread European opposition to reprocessing, as demonstrated by last year's OSPAR decision, casts a cloud over both BNFL and UKAEA.

ANSTO's plan to send more spent fuel to Dounreay came to grief in 1998. In March 1999, ANSTO's communications manager described Dounreay as a "dirty, broken-down old plant" ... yet ANSTO was keen to send as much spent fuel as possible to Dounreay.

BNFL has been subject to an endless string of scandals in recent years and it would be unconscionable to send spent fuel there even if the option was available. The option may not even be available - for example a 14/5/01 UK Independent article began, "British Nuclear Fuels will try this week to head off a revolt by its biggest overseas customers, which threatens 2,000 jobs and the future of the Sellafield reprocessing plant in Cumbria. Senior BNFL managers are scheduled to meet customers from power companies in Germany, Japan, Switzerland, Holland and Italy who have warned they may withdraw £6bn of business from Sellafield."

Detailed coverage of BNFL's problems can be found in The Independent <www.independent.co.uk>, the Guardian/Observer <www.guardian.co.uk/nuclear>, and on the World Information Service on Energy website <www.antenna.nl/wise>.

According to Alan Martin, in a report commissioned by Sutherland Shire Council, "The other major commercial reprocessor, BNFL, has not offered reprocessing services for research reactor fuel, probably because it was considered that the Dounreay facilities of the UIC were more suitable for the purpose. Even though the situation with Dounreay has changed, it is unlikely that BNFL would wish to take any steps in the near future that could jeopardise, commercially or politically, its mainstream reprocessing activities." (Alan Martin, Replacement Nuclear Research Reactor at LHSTC, October 1998, p.6.)

USA

ANSTO's Final EIS (p.10-10) states that the US Department of Energy has decided to pursue a melt-and-dilute approach for aluminium clad spent research reactor fuel, which in ANSTO's view "is not an option available to Australia."

ANSTO appears to be misrepresenting the DOE's plans. ANSTO said in a February 2001 supplementary submission to the Senate Select Committee that "direct disposal of silicide fuel is not a practicable course of action, and indeed has been specifically rejected by the United States Department of Energy." In fact the DOE says: "During the development of the Melt and Dilute technology, DOE may determine that, for technical, regulator or cost reasons, the Melt and Dilute option is no longer available. As a back up to Melt and Dilute, DOE will continue to pursue the Direct Co-Disposal option of the New Packaging Technology and would attempt to implement this option if Melt and Dilute were no longer feasible or preferable. Direct Co-Disposal has the potential to be the least complicated of the new technology options. However, there is uncertainty that aluminium-based SNF, packaged according to the Direct Co-Disposal option, would be acceptable in a geologic repository." (DOE, Spent Nuclear Fuel Management, Final EIS, DOE Savannah River Operations Office, March 2000, p.2-12).

Have fuel types which would not require reprocessing/conditioning been explored independently of ANSTO?

DOMESTIC MANAGEMENT OF SPENT FUEL

Domestic options for spent fuel management appear to be severely constrained by a range of factors.

Reprocessing is prohibited in Australia (ARPANS Act 1999).

According to Senator Minchin's adviser David Wawn (personal communication, 23/12/99), "the ANSTO Act specifically precludes the Lucas Heights Science and Technology Centre becoming a national radioactive waste repository."

An April 1998 Department of Industry, Science and Tourism (DIST) briefing paper, obtained by Sutherland Shire Council under Freedom of Information legislation, reveals that the government does not want to close off the option of building a domestic reprocessing plant. It says: "We may look at new technologies to deal with spent fuel at a later date. ... Do not mention a reprocessing plant." So domestic reprocessing/conditioning is on the agenda ... but the public is to be kept in the dark about this.

Any plan (or contingency plan) for spent fuel reprocessing/conditioning in Australia is likely to face insurmountable political opposition. A "senior government source" (understood to be a senior DFAT bureaucrat involved in the reactor push) said, "The big ticket item was the new reactor and it was felt that politically you just couldn't win the reprocessing argument and the new reactor." The bureaucrat also said that reprocessing is "an issue for another generation" and "someone else can worry about it". (ABC Radio National, Background Briefing, 29/3/98, <www.abc.net.au/rn/talks/bbing/bb980329.htm>).

ARPANSA Council/Committee members are encouraged to read the ABC Background Briefing transcript to appreciate the depth of the government's deceit and secrecy in relation to the reactor plan. Many hoped that the creation of ARPANSA would help to ameliorate the situation. Sadly, Garnett's direct involvement in the selection of Loy as ARPANSA CEO - and Loy's refusal to criticise this process - appears to have set the pattern. ARPANSA's role in the Maralinga 'clean-up' was highly problematic, as detailed by ex-DISR whistle-blower Alan Parkinson. Again, ARPANSA Council/Committee members are encouraged to familiarise themselves with the role of both DISR and ARPANSA in the Maralinga scandals. I can provide information on request (<[email protected]>).

'EXTENDED INTERIM STORAGE' OF SPENT FUEL

ANSTO said in its Draft reactor EIS (p.10-18): "In the unlikely event that the overseas options should become unavailable, it would be possible at short notice to take advantage of off-the-shelf dry-storage casks for extended interim storage at the national storage facility, pending renewed arrangements being negotiated for reprocessing/conditioning of the fuel."

However, DISR has unequivocally stated that spent fuel will not be stored at the planned LLILW store.

ANSTO appears to be reluctant to acknowledge that "extended interim storage" of spent fuel at a LLILW store (should such a store be established) is not an option. (See ANSTO, submission to Senate Select Committee, titled "Questions received 11 October 2000 from Senate Select Committee on the contract for a new reactor at Lucas Heights, answer to questions 50 and 51.)

Long-term storage at Lucas Heights is illegal under the ANSTO Amendment Act.

This issue must be addressed by ARPANSA. If it is not possible to send spent fuel overseas, it appears the only 'interim' strategy is to leave the spent fuel at Lucas Heights ... which is illegal under the ANSTO Amendment Act. How can ARPANSA possibly justify issuing a reactor construction licence under these circumstances?

It appears that Dr. Loy plans to dodge this issue by obfuscating on the need for contingency plans.

ARPANSA's Regulatory Branch said in its Safety Evaluation Report on ANSTO's application to prepare a site for a new reactor: "Contingency plans describing alternative strategies for disposal of radioactive waste and spent nuclear fuel will also be required with the application for licence to construct the replacement reactor."

Will the Regulatory Branch reaffirm the need for contingency plans in its report on the reactor construction application? Or will the Regulatory Branch accommodate to the scheming of Loy/ANSTO/DISR?

ANSTO's contingency plan for "extended interim storage" also raises safety issues. The reactor Draft EIS (p.10-18) states, "even low-enriched uranium research reactor fuels are sufficiently enriched for selective leaching and reconcentration effects to have the potential to lead to criticality concerns at long times after disposal."

3. PROPOSED NATIONAL STORE FOR LLILW

According to Loy, (personal communication, 1/6/2000), "at the time of a decision on a licence to construct the replacement reactor, arrangements for the reprocessing of the specific fuel proposed for use in the reactor would need to be demonstrated to be available when the reactor would be in operation and there would need to be progress on the strategy to establish a store for ILW, including for the waste arising from the reprocessing of spent fuel."

ARPANSA cannot justify issuing a reactor construction licence in the absence of demonstrable progress on the establishment of a LLILW store. Yet the 'progress' on the proposed store has all been backwards.

Numerous statements have been made in recent years, by the government and ANSTO, to the effect that co-location of a LLILW store with the proposed repository will occur or is likely to occur:
- when asked during a parliamentary inquiry in 1999 whether spent fuel wastes would be dumped in SA after reprocessing in Europe, Garnett said: "Yes".
- in 1997, the Commonwealth/State Consultative Committee on the Management of Radioactive Waste said that co-location of a store with the planned underground repository "should be considered as a first siting option".
- the proposal to co-locate LLILW with the repository is stated as a firm intention by the Department of the Environment and Heritage in its Environment Assessment Report on ANSTO's EIS (e.g. E.A.R. Executive Summary, chapter 2.4.3, chapter 7.8.3.5, chapter 13.2).
- the Department of the Environment and Heritage (1999 Environmental Assessment Report) also said that "The current timing is for the store to be in operation by the time the replacement reactor is commissioned in 2005. Clearly, any long-term planning depends on the establishment of such a facility."

These statements influenced Loy's decision to grant a licence for the preparation of a site for the proposed new reactor. Loy said: "It is true that the waste repository proposal is still in the development stage, that the long-lived intermediate level waste storage facility is yet to be definitely planned and no decisions have been taken on final disposal of long-lived intermediate level waste. There are significant environmental, social and political issues that will need to be dealt with for these plans to come to fruition. The question for me in this application is whether, at least in principle, I could see that there was sufficient commitment to the current plan and the general availability of alternative approaches so as to be confident that a way through would be found in a reasonable timescale. I took into account that there is clear progress on the siting of a low level waste repository and a Government commitment to examine co-locating a store for long-lived intermediate level waste in association with the repository." (CEO/ARPANSA, 22/9/99, Issue of a Licence to ANSTO to Prepare a Site for Replacement Research Reactor Facility.)

As for the government's 'progress' on the LLILW store:
- the government made a decision to lie to South Australians through 1998/99 by saying nothing about the co-location plan (e.g. see press releases from Warwick Parer and Nick Minchin) and repeatedly deriding statements to the contrary as disinformation from anti-nuclear 'extremists' (to use a favoured phrase of Senator Minchin). A typical tactic was semantic obfuscation, with the government insisting that the planned repository would not take LLILW ... true, but only half the truth.
- when South Australians found out about the government's deceit, overwhelming public opposition led to legislation passing through the parliament last year banning the establishment of such a facility. All political parties represented in the SA parliament supported the legislation (the vote was 46-1 in the lower house).
- the federal government has since abandoned its plan to co-locate LLILW with the planned repository.
- an 'expert committee' has been established to advise on LLILW storage ... but not until after the next federal election.

Clearly, all the progress has been backwards. ARPANSA cannot issue a reactor construction licence in these circumstances.

In the event that the government's efforts to establish a national LLILW store fail, one possible contingency is long-term (or permanent) management of spent fuel residues by Cogema. However, DISR/ANSTO state that "The Australian Government has undertaken to accept the return of residues to Australia and to take all reasonable steps to facilitate their return. It is not considered that any circumstances could arise which would delay such return of residues." (DISR/ANSTO, 1999-2000 Additional Estimates hearing - Questions on Notice, Senate Economics Legislation Committee, question #7 from Senator Allison.)

Then Western Australian Premier Richard Court said on August 14, 2000 that WA would fight any proposal to host a national LLILW store in that state. "We've got a simple message - we don't want it. We're quite prepared to look after our own waste that's generated here, and let every state take the same position", Court said.

I understand that the NSW government claims to have legislation in place which would prohibit the establishment of a LLILW store in NSW.

The government hopes to minimise the political obstacles by establishing a LLILW store on Commonwealth land, but the political obstacles are still considerable and quite possibly insurmountable.

Loy refuses to rule out issuing a reactor construction licence even if a LLILW store site has not been identified, and, incredibly, refuses to rule out issuing a reactor operating licence in 2005/2006 even if a LLILW store site has still not been identified. Loy has been repeatedly asked to publicly lay down some clear bench-marks with respect to waste management but he refuses to do so. He has however come to an unspecified arrangement with ANSTO regarding his requirements (or lack thereof).

The 1993 Research Reactor Review said that a new reactor should not be contemplated until "a high level waste repository site has been firmly identified and work started on proving its suitability" (p.xv) and that "A crucial issue is final disposal of high-level wastes, which depends upon identification of a site and investigation of its characteristics. A solution to this problem is essential and necessary well prior to any future decision about a new reactor. ... It would be utterly wrong to decide on a new reactor before progress is made on identification of a high level waste repository site." (p.xiv)

If it was "utterly wrong" for the government and ANSTO to push ahead with a new reactor in the absence of a site for LLILW, what are we to make of Loy's willingness to issue reactor construction and operating licences in the absence of a site for a store?

Even if a store site had been identified, that would be small comfort. There are many examples internationally of sites for waste stores/repositories being identified but the project not reaching completion. In Australia, examples include the plan to build a national repository in the Northern Territory, and the recent abandonment of the plan for co-location of a LLILW store with the planned repository.

4. FINAL DISPOSAL OF LLILW

A submission from the Nuclear Safety Bureau on ANSTO's Draft EIS stated that an acceptable strategy for the ultimate disposition of the replacement reactor fuel would be required before ARPANSA would authorise reactor construction.

The federal Department of the Environment and Heritage (1999 Environment Assessment Report) said, "It should be noted that the National Storage Facility would only provide for above-ground storage of some wastes. It would not constitute a final solution for disposal of long-lived intermediate-level wastes. Currently, the only such facility in the world for permanent disposal is the experimental deep geologic Waste Isolation Pilot Plant in New Mexico, USA."

The Department of the Environment and Heritage also stated, "The Department is of the view that it is now timely to consider strategies for the long-term storage and eventual permanent disposal of Australia's long-lived intermediate-level nuclear wastes, and associated issues. This would assist in facilitating public understanding and input into a 'solution' (if one exists), and in ensuring that a timely response is developed."

Subsequently, Condition #27 attached to the approval of the new reactor EIS is that "The Minister for Industry, Science and Resources and the Minister for Health should give timely consideration to strategies for the long term management and eventual permanent disposal of Australia's long-term intermediate-level nuclear wastes, and associated issues."

When asked about the above condition in a Senate hearing on May 3, a senior DISR officer construed the question as relating to the national LLILW store not permanent disposal. (Senate Economics Legislation Committee, Consideration of Supplementary Estimates, Canberra, Proof Committee Hansard.)

Likewise, ANSTO appears to be of the opinion that the proposed national store for LLILW is equivalent to final disposal (e.g. Draft EIS, p.10-6, diagram).

Likewise, David Wawn, an adviser to Senator Minchin, said "Long-lived intermediate level waste is not suitable for near-surface disposal. Therefore, if and when disposal is contemplated in Australia for this type of waste, underground disposal of typically several hundred metres in depth is likely to be used. However, storage of long-lived intermediate level radioactive waste in an above-ground, purpose built structure as proposed by Australia is an internationally accepted method for the long-term management of this type of radioactive waste." (Personal communication, 23/12/99.)

The Safety Evaluation Report attached to ARPANSA's issue of a licence to prepare a site for a new reactor states, "A licence to operate the reactor would not be issued by ARPANSA without there being clear and definite means available for the ultimate disposal of radioactive waste and spent nuclear fuel."

ARPANSA cannot issue a reactor construction licence given that no progress whatsoever has been made with respect to ultimate disposal.

Clearly Loy thinks differently, and thus it is essential that ARPANSA's Regulatory Branch states the contrary view unequivocally. ARPANSA Council/Committee members also ought to issue public statements distancing themselves from Loy's willingness to issue reactor construction/operating licences despite the totally unacceptable situation with respect to ultimate disposal and waste management more generally.

5. LOW-LEVEL REPOSITORY

Progress with the repository in SA continues to fall behind schedule. For example, when the Billa Kalina site in SA was selected in 1998, the government stated that construction of the repository was expected to commence in the year 2000. Yet the EIS has still not been released - and it appears to have been delayed on account of the upcoming federal election.

It should also be remembered that efforts to establish a national low-level waste repository stretch back 20 years. The plan for a repository in SA is far from being a fait accompli.

A poll conducted by Channel 7 in July 1999 found that 93% of South Australians are opposed to hosting a national repository. A 1999 survey commissioned by Greenpeace, and conducted by Insight Research Australia, found that 86% of South Australians (and a majority of all Australians) oppose the federal government's planned repository. A poll conducted by the Advertiser, SA's only mass circulation newspaper, in July 2000 found that 87% of South Australians are opposed to a repository in the north of the state.

The fact that Loy seems prepared to issue a construction licence before the repository EIS has been completed - perhaps even before it has begun - is further evidence that the emperor has no clothes. ARPANSA Council/Committee members and ARPANSA staff ought to call for his dismissal.