ARPANSA Reports Slam Nuclear Dump

Two reports released by the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) have raised a range of concerns and criticisms regarding the federal government's plan to build a national radioactive waste dump in SA. The reports were written by Prof. Ian Lowe and George Jack, who, along with ARPANSA CEO John Loy, chaired a two-day forum held in Adelaide in February. ARPANSA is assessing the federal government's application to build the dump.

The most objectionable aspect of the ARPANSA licensing process - and the dump debate more generally - has been the federal government's willingness to repeatedly misrepresent Indigenous groups:

* the government has never acknowledged that clearance for test drilling was granted by Indigenous groups under duress - those groups participated in surveys of short-listed sites only because of the explicit threat from the federal government that test drilling would proceed with or without those surveys;

* it is misleading for the government to claim, as it repeatedly does, that clearance was granted for test drilling without also noting that those clearances in no way amounted to consent to the dump and that the government has compulsorily acquired the dump site and transport corridor, annulling Native Title rights and interests in the process; and

* it is plainly false for the federal Department of Education, Science and Training (DEST) to claim that: "The preferred sites and two alternatives have been identified by Aboriginal groups as not containing areas of significance for Aboriginal cultural heritage ..."

ARPANSA must be satisfied that the government has established a net benefit with its dump proposal. In fact the federal government has not even attempted to substantiate its claim that the proposed dump will result in net benefits with respect to radiological hazards - let alone that the alleged benefits justify the additional social and democratic costs associated with the dump. Asked whether the government has carried out risk analyses justifying its net-benefit claims, a federal government representative at the ARPANSA forum acknowledged that no such studies had been carried out and that the government was relying on a "general feeling" that a dump would minimise overall radiological hazards.

Prof. Lowe noted in his written report: "There are some difficult issues to be resolved if the applicant is to show that the proposal would provide a net benefit to the community, most obviously including a risk assessment to determine whether the increased risk of collecting and transporting waste is outweighed by the reduced risk of storage at a properly engineered repository; this study should take into account the continuing need for local storage of waste between the proposed disposal campaigns. A professional risk assessment cannot be conducted until a firm waste acceptance plan and transport code are developed."

Another issue which was prominent at the ARPANSA forum, and in the reports from Prof. Lowe and Mr. Jack, concerned whether the federal government department reponsible for the dump - the Department of Education, Science and Training (DEST) - has the technical expertise to manage the project.

ARPANSA received submissions from nuclear scientists with first-hand experience of DEST's capabilities during the latest clean-up of the Maralinga nuclear test site. Professor Peter Johnston stated in his submission that: "The applicant has inadequate technical competence to manage its contractors. DEST was an ineffective manager of the Maralinga cleanup in a number of key ways. ... At times the project was not fully in DEST's control."

Likewise, Alan Parkinson, a nuclear engineer with extensive first-hand knowledge of the Maralinga clean-up, noted in his submission: "It has to be noted that the same group responsible for the debacle of the Maralinga project have responsibility for the radioactive waste repository. On the Maralinga project they showed without any doubt that they had no experience or knowledge of radioactivity and no expertise at all in project management. They have publicly shown their complete lack of understanding in project management methods, radiation and other technical issues. Thus they are not equipped either to approve the design of the facility or see it through the construction period."

Those criticims were echoed in the reports by Prof. Lowe and Mr. Jack. Prof. Lowe wrote: "In this case, where the facility if approved will be operated on behalf of the community to reduce the risk from low-level radioactive waste, political accountability should demand that the Department responsible show its capacity to manage the repository. If that capacity does exist, it was not demonstrated at the public forum, confirming Prof. Johnston's criticism.

Mr. Jack also expressed concern: "The relationship between DEST and its contractors, and the capability of the former to manage the latter, is bothersome and bears further examination."

IAEA Report

A review team from the International Atomic Energy Agency (IAEA) has presented its final report to ARPANSA. The report is generally sympathetic to federal government dump plans - the IAEA's primary function is to promote the nuclear industry - but it contains some important criticisms.

In particular, IAEA recommends that licensing should be step-by-step instead of DEST's three-in-one application for licences to prepare the site, build and operate the dump. The IAEA states: "The application for siting, design, construction and operation of the facility in a single step overlooks the step by step approach that is now considered to be international best practice. A single step approach precludes the iteration considered to be necessary to achieve, demonstrate and develop confidence in the safety of the facility. It is recommended that alternatives be explored to take the licensing process forward in a more step by step manner."

The IAEA also echoes the concerns expressed by Prof. Peter Johnston, Alan Parkinson and others. The IAEA report states: "The responsibility for development and operation of the repository rests clearly with the Applicant who, with a limited number of dedicated staff, appears to rely heavily on contractors. This makes it difficult to deliver an integrated programme (given the wide range of scientific and technical disciplines involved) and to provide the continuity needed later when the facility will be operated on a campaign basis. The [IAEA International Review Team] suggests that the Applicant should consider retaining more of the functional responsibilities for development and operation of the repository within DEST."

The IAEA report also states that:

* site-based experiments should be conducted "to demonstrate the feasibility of creating the necessary structures and repository barriers and to build confidence in their performance."

* DEST's licence application is "difficult to navigate and, when the appropriate section is found, many of the procedures are present as drafts or missing entirely."

* DEST should carry out further study of the faults and fractures on the site to evaluate their potential influence on groundwater movement and allow, if necessary, their effect to be incorporated into safety assessments.

* DEST should conduct a more extensive study of the geomorphology of the site.

* DEST should prepare a plan to identify the actions that would be taken if the monitoring programme were to produce an unexpected observation." (At the ARPANSA forum in Adelaide in February, DEST said the dump would be back-filled with cement AND that the waste would be retrievable!)

The IAEA report, and the reports from Ian Lowe and George jack, are on the ARPANSA website: www.arpansa.gov.au/reposit/nrwr.htm. Second-round submissions to ARPANSA by the Australian Conservation and Friends of the Earth are on the CAND website: www.oocities.org/nonucleardump

By Jim Green
Friends of the Earth / Campaign Against Nuclear Dumping

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