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A New Reactor at Lucas Heights
Contents

Chapter 3

Siting and Environmental Impact of the New Reactor

3.1 The arguments advanced by the Government and ANSTO in favour of building the new reactor at the Lucas Heights site are essentially that:

• the present site meets all the siting and safety criteria for a research reactor;
• the proposal makes use of existing physical infrastructure and experienced personnel at Lucas Heights;
• existing distribution arrangements for radiopharmaceuticals will not be disrupted; and
• building a new reactor at a greenfields site would involve a very large additional cost. [1]

3.2 However, this site is opposed by a number of local residents and community groups concerned with the environmental impact of continued nuclear activity in their neighbourhood and perceived shortcomings in the management of nuclear waste.

3.3 Representatives of both ANSTO and the Commonwealth Department of Industry, Science and Resources (DISR) [2] advised the Committee that various sites across Australia had been considered and evaluated against specific criteria. Based on international guidelines, and endorsed by the 1993 RRR, the criteria encompass:

• Accessibility: within one hour's road travel of a major international airport; same day travel from major centres of research; proximity for staff to residential and research centres;
• Health and safety: area of low seismic activity and stable geology; low cyclonic activity and low flood potential; favourable airborne dispersion characteristics and low potential for waterborne pathways; not affected by other hazardous or incompatible land use; feasible emergency response capability;
• Environmental protection: not in unique ecological or conservation areas; without potential for significant adverse impact on the physical or cultural environment;
• Availability of resources: adequate and reliable power and water supplies; proximity to reliable service providers and contractors;
• Cost factors: cost of site-related construction, infrastructure and land acquisition (including a suitable buffer zone); operating costs. [3]

3.4 In accordance with these criteria, possible sites were identified in the vicinity of Canberra, Sydney, Melbourne, Brisbane, Adelaide, Perth and some regional centres. However, primarily on the grounds of cost and confidence in the lack of health and safety risks associated with reactor operations, the Government has chosen to maintain the Lucas Heights Science and Technology Centre as the site of Australia's nuclear research activities.

Siting options

3.5 Originally in 1955, Lucas Heights was chosen as the site for establishment of HIFAR, Australia's first and current research reactor. Situated in the local government area of Sutherland Shire, approximately 30 kilometres south-west of Sydney's central business district, the Lucas Heights Science and Technology Centre is largely surrounded by the Heathcote National Park, the Holsworthy Military Reserve, the Waste Management Centre, Lucas Heights and bushland. Initially a 4.8 kilometre buffer zone encompassed the centre, but based on overseas experience, the buffer was reduced to 1.6 kilometres [4].

3.6 In the 1950s, the combination of sparse regional population and development, together with proximity to Sydney, were key factors in the choice of Lucas Heights as the site for Australia's research reactor. Since that time, however, significant population growth and urban expansion has transformed the region into what this Senate inquiry's terms of reference describe as`… a densely populated suburban area of Sydney'. Indeed, in 1993 the RRR described the Sutherland Shire as among the fastest growing local government areas in New South Wales, with many more people moving in than out. [5]

3.7 Population growth in the Sutherland Shire therefore raises two major questions in respect of the siting of the new reactor at Lucas Heights. First, given the ongoing debate concerning the possible health and safety risks associated with a nuclear research reactor, it would seem expedient and good public policy to distance such a facility from highly urbanised areas. Many local residents would support the view of the Liverpool City Council, which neighbours the Sutherland Shire, that:

… it is completely unacceptable for a potentially dangerous facility such as this to be built in the midst of a rapidly growing residential suburb, within Sydney's most populous suburb. [6]

3.8 Given the population now in the Sutherland Shire, it is inconceivable that Lucas Heights would be chosen now as a greenfields site for a new reactor. One could anticipate huge community reaction similar to the proposed (since abandoned) Holsworthy airport proposal.

3.9 On the other hand, population growth in the Sutherland Shire has increased dramatically, despite the presence of HIFAR, indicating that it is not a significant deterrent in the eyes of new Shire residents. In support of this, the RRR noted that the Sutherland Shire Council has a requirement that prospective land purchasers be informed of the reactor's presence in the district, therefore ensuring an informed decision to live in proximity to a nuclear facility. [7]

3.10 Taken together with the RRR's endorsement of HIFAR safety standards and the siting criteria identified, this would suggest the validity of Lucas Heights as a possible site for the new reactor. However, despite indicating qualified support for a new reactor per se, it is important to note the RRR did not commit itself to recommending Lucas Heights as the appropriate site. Rather, the Review advises:

If a decision were to be made to construct a new reactor, it would not necessarily best be placed at Lucas Heights. An appropriate site would best be decided after exhaustive search, taking into account community views. [8]

3.11 The Sutherland Shire Environment Centre argued that the decision to site the new reactor at Lucas Heights is not in accordance with community views. The Centre told the Committee that community views canvassed in a 1996 public opinion poll, show that 83 per cent of Sutherland Shire residents thought that a new reactor should be in a `remote location'. [9]

3.12 It must be acknowledged that this survey was subject to markedly different interpretations by different groups. ANSTO, for example, told the Committee that when asked whether they would be supportive of a new reactor being built at the existing Lucas Heights site, 57 per cent of Sutherland Shire residents responded positively. [10]

3.13 The Committee considers that it would have been preferable if a more detailed, extensive survey of community views had been conducted.

3.14 In light of the RRR's observation and concerns from within the Sutherland Shire community, DISR undertook an investigation of various alternative sites for the new reactor. The study has not been released for public examination on the grounds that it is a cabinet-in-confidence submission. Government officers did inform the Committee that suitable sites had been identified in the vicinity of Canberra, Sydney, Melbourne, Brisbane, Adelaide, Perth and some regional centres. However, specific details of each location, together with the site selection criteria used to evaluate these sites, have not been disclosed.

3.15 The Committee believes that such information should have been made available to the Committee particularly having regard to the recommendations of the Research Reactor Review.

3.16 While acknowledging that various suitable sites for the new reactor do exist, the significant costs associated with developing a greenfields site is the Government's key argument in favour of the Lucas Heights option. Remaining at Lucas Heights avoids the expense of duplicating nuclear infrastructure elsewhere. As highlighted in the joint ANSTO/DISR submission to the Committee, the location also:

… meets all siting and safety criteria, makes use of the existing physical infrastructure and experienced personnel at Lucas Heights, and will not disrupt the existing, very effective distribution arrangements for radiopharmaceuticals. [11]

3.17 Furthermore, without revealing the detail of the Government's site study, Dr Paul Wellings, Head of DISR's Science and Technology Division, defended the study's methodology and conclusions in the following terms:

The methodology was evaluated by the Department of Finance as a robust method for arriving at the costing procedures that would have been incurred had we moved the reactor to a greenfield location. At the end of the day those criteria, which include health and safety issues, showed that the minimum additional cost of moving to a greenfield site would have more than doubled the cost of the project. There was also the issue that this would have had us maintaining two nuclear sites in Australia. Lucas Heights … would still have been used to handle material from the cyclotron and would have been an active site because it would have been going through a cooling down phase with a view to decommissioning in 30 years time. [12]

3.18 Although opposed to a new reactor on the grounds of science and technology funding priorities, Professor Barry Allen, a nuclear scientist of 35 years experience, clearly endorsed Lucas Heights as the appropriate site due to its pre-existing infrastructure.

If you are going to have a new reactor, it should be where all the support facilities are and where all the staff are located basically, and I think Lucas Heights is that place. If you are going to move it, then you have to put a dollar price on controversy. How many tens of millions of dollars extra is controversy worth?….I have no doubt the reactor sited at Lucas Heights would be eminently safe and managed in the way that Lucas Heights has managed things in the past, at a very high level of expertise. [13]

3.19 While acknowledging the strong financial arguments in favour of Lucas Heights over a greenfield site, the Committee appreciates community concerns regarding the non-disclosure of the site selection study. Health, safety and nuclear waste issues are of vital concern to local residents. These concerns are only exacerbated when information appears to be withheld. Both the Sutherland Shire Council and the Sutherland Shire Environment Centre questioned the adequacy of the criteria used in site evaluations, and in particular:

… whether [the locational study] took into account issues related to nuclear waste generation and disposal, and took account of important local information with respect to the Lucas Heights area and any other areas in Australia relevant to the reactor siting issues. [14]

3.20 Although, in announcing Lucas Heights as the site for the new reactor, the Government instigated an environmental impact assessment of the proposal, this has failed to allay the concerns of many local residents. In the first instance, opponents of the proposal saw flaws in the alternative sites study from which Lucas Heights was selected, and thereafter with the design and execution of the environmental impact study of this siting option. Further, the internal departmental consideration of alternative sites appears to have been a modelling exercise against generic criteria rather than a detailed consideration of specific sites. The Committee notes with concern that this internal study was conducted prior to the preparation of the draft environmental impact study (EIS) and was not reviewed in the EIS:

ANSTO has advised the Senate Economics References Committee that a process involving consideration of alternative sites, subsequent to the Research Reactor Review, was conducted by officers within the [then] Department of Industry, Science and Tourism, with input from ANSTO. The site selection criteria indicated that greenfield sites, which fulfil accessibility, health and safety, environmental protection and availability of resources criteria, are available with proximity to Canberra, Sydney, Melbourne, Brisbane, Adelaide, Perth and some regional centres. In addition, the costing methods comparing locating a replacement reactor at Lucas Heights and alternative sites were reviewed by the [then] Commonwealth Department of Finance. This process was conducted prior to the preparation of this Draft EIS and has not been reviewed as part of the scope of this Draft EIS. [15]

Consideration of alternative sites to the Lucas Heights Science and Technology Centre was undertaken for several locations but without reference to a specific site. [16]

3.21 These factors can only lead to the conclusion that alternative sites have not been properly considered as recommended by the 1993 RRR. Certainly there has not been an `exhaustive search' for alternative sites and the only site subject to the EIS is Lucas Heights.

3.22 If Australia is to have a new reactor then alternative sites to Lucas Heights must be properly considered. Such analysis should include the potential economic benefits of locating the reactor in a less populated regional area.

Environmental Impact Assessment process

3.23 Following the Government's announcement that a new reactor would be built at Lucas Heights, the Minister for the Environment directed ANSTO to prepare an environmental impact statement (EIS) pursuant to the Environment Protection (Impact of Proposals) Act 1974 (EPIP Act). The Committee notes that the aim of the environmental assessment process is to ensure that all environmental matters are examined with respect to a given project and that community groups with particular interests have the opportunity to raise relevant issues. The EIS is not designed to make a final decision on the merits of a proposal. Rather, it is intended to canvass and evaluate all likely impacts of the proposal. In accordance with these parameters, the Committee sees the authority of the EIS as hinging on three main issues:

• the breadth of its guidelines;
• the extent of its community consultation; and
• the independence of its analysis.

Preliminary stages

3.24 The environmental assessment process involved a number of stages, which took over a year to finalise. Key developments during this phase included the appointment of ANSTO as the `proponent' for the new reactor proposal. A Commonwealth agency, Environment Australia, was responsible for preparing the EIS guidelines. These were prepared following a month-long public review of a set of draft guidelines. ANSTO appointed a company called PPK Environment & Infrastructure Pty Ltd to prepare a draft EIS report. PPK in turn contracted the services of another environmental assessment and control company, NNC Ltd which has expertise in the nuclear industry.

3.25 Despite having appointed an independent agency to conduct the EIS, ANSTO remained the main proponent of the EIS process and continued to provide technical input, specifically regarding the description of the new reactor proposal, the need for the proposal and the alternatives that have been considered.

3.26 The EIS study team comprised a steering committee and task leaders drawn from ANSTO officers, together with PPK Environment & Infrastructure staff and several specialist subconsultants. At least 42 highly qualified professionals formed the PPK EIS team, representing a range of physical and social sciences including: environmental planning; transport engineering and economics; geotechnical and civil engineering; nuclear safety; health physics, archaeology and community consultation.

3.27 The EIS guidelines developed by Environment Australia demanded a very detailed study of the likely physical, biological and social impacts of a new reactor located at the Lucas Heights Science and Technology Centre. Reflecting these requirements, the EIS describes in great detail:

• the new reactor proposal itself, together with the perceived need for it;
• alternative reactor types and technologies;
• the existing environment including community and socio-economic issues and future trends over the anticipated operating life of the facility;
• environmental impacts from construction, emissions, transport and storage of fuel elements;
• hazards and risks;
• decommissioning of both the existing and new reactor;
• the regulatory regime surrounding Australian research reactor operations; and
• proposed environmental safeguards and monitoring programs. [17]

3.28 The key findings of the EIS in each of these areas are discussed below, together with relevant evidence received by the Committee. Before proceeding to this, however, two further aspects of the EIS process warrant consideration: the extent of community consultation; and perceived independence of the study.

The extent of community consultation in the EIS process

3.29 A preliminary stage in the EIS process involved the preparation of guidelines to direct the study. While the EPIP Act does not require consultation prior to the preparation of a draft EIS, in the case of the new reactor ANSTO sought public review of the guidelines in an attempt to encourage maximum community involvement throughout the EIS process. The draft guidelines were released for comment between 8 November and 6 December 1997, and attracted 118 submissions. [18]Once revised, the guidelines were provided to ANSTO as the proponent of the EIS and to all parties who had commented on the draft version. The guidelines also were published on the internet for the information of any other interested parties.

3.30 Community consultation was emphasised throughout the EIS evidence gathering process, with the aim of recognising key stakeholders and understanding their interests in the project. Some of the key consultation activities undertaken included:

• distributing newsletters outlining the new reactor proposal, EIS process and issues raised during the process to households in the Sutherland Local Government Area;
• establishing an EIS website and telephone information line;
• participating in meetings with Sutherland Shire Council and a range of community interest groups; and
• organising mobile staffed displays at local shopping centres. [19]

3.31 A similar range of community consultation activities continued following release of the draft EIS for public comment. The release itself was widely advertised in national, and where applicable, metropolitan and local press. Interested individuals or groups were invited to comment on the draft EIS, after which ANSTO prepared a supplement to the draft, responding to all issues raised. To assist with any inquiries during the public exhibition phase of the draft EIS, PPK undertook for selected exhibition locations to be staffed by members of the EIS study team for most Saturdays during the exhibition period. [20]

3.32 Notwithstanding the various consultative efforts outlined above, the Committee notes a degree of dissatisfaction expressed by some opponents of the new reactor proposal. In particular, the community group People Against a Nuclear Reactor claimed that consultation throughout the EIS process was inadequate and that citizens were treated with contempt. People Against a Nuclear Reactor stated their case against PPK in particularly strong terms:

… (PPK) have made it abundantly clear that they will prepare their statement without any consideration of the cumulative wisdom or wishes of local residents, or the technical expertise of the Australian non-nuclear scientific community. The company has also refused our repeated requests to conduct a public meeting on the proposal. So intense has been the uproar about PPK's lack of any attempt to engage in meaningful consultation with residents, that another company, Twyford Consultants [sic], has been engaged to evaluate the public participation component of the EIA process. [21]

3.33 While appreciating community groups' concerns about the 1new reactor proposal, the Committee notes that, in addition to the broad consultative mechanisms already discussed, PPK specifically identified People Against a Nuclear Reactor as a key local stakeholder group, and met with them on at least one occasion to discuss the new reactor proposal [22]. In response to People Against a Nuclear Reactor's complaint that PPK failed to conduct a public meeting on the proposal, PPK argued that participation in such a forum would be contrary to its role. PPK explained its position in the following terms:

… PPK's role is to assess the environmental impacts of the (replacement reactor) proposal and not to advocate the proposal (therefore) participating in such a public debate would not be appropriate. PPK declined the (public meeting) invitation and, as an alternative, proposed that representatives of these community groups distribute their information materials expressing their point of view at Information Days and Mobile Displays organised by PPK throughout the EIS consultation process. [23]

3.34 In relation to Twyford Consulting's appointment to conduct an evaluation of the community consultation process, the Committee notes that PPK undertook this measure in response to concerns raised by Sutherland Shire Council. Specifically, Twyford Consulting were engaged to:

Evaluate the effectiveness and appropriateness of the community consultation strategy, including the objectives, processes and outcomes (both outcomes during and at the conclusion of the process); and

Evaluate the implementation of the strategy, specifically how the process was handled; how responsive it was to the needs of the community; and what outcomes were actually achieved. [24]

3.35 Twyford Consulting evaluated PPK's consultation strategy in respect of the preliminary stage of the EIS, that is prior to release of the draft statement, and recommended certain measures to assist with community involvement in the public exhibition phase of the EIS. Twyford Consulting's general conclusion regarding consultation in the preliminary stage of the EIS process was that it was undertaken to an `acceptable' level, however with some shortcomings. In the area of managing potential conflict, the consultants found that PPK's early attempts at dialogue with the group People Against a Nuclear Reactor were adequate, but subsequently deteriorated through a lack of flexibility and transparency, hampering ongoing, meaningful dialogue and producing suspicion on both sides. According to Twford Consulting:

Effective dialogue and open responses to questions and requests in Stage 2 (the public exhibition phase of the EIS process) will be critical in managing community expectations, minimising conflict and meeting the (managing potential conflict) standard. [25]

3.36 Transparency was an additional aspect of the preliminary consultation process in which Twyford Consulting identified problems. According to Twyford Consulting, transparency refers to the stakeholders' understanding of the EIS process, in particular the consultation and decision making occurring within it. Twyford Consulting found that generally this standard had not been met, with many of their sample interviewees failing to understand the consultation and EIS process. True community consultation therefore was not achieved. Instead, a lack of trust tarnished the process, resulting in the perception that the EIS was being undertaken to support a pre-determined decision, rather than the decision to proceed with a new reactor being based on the outcome of the EIS process. [26]

3.37 In the Supplement to the Draft EIS, PPK noted that Twyford Consulting made recommendations about the consultation process and that `as a result of the recommendations … additional community consultation activities were conducted during the exhibition period'. [27] These activities included an information letter mailed to several hundred local businesses, a radio debate and public discussion groups. [28]

3.38 However, Cr Genevive Rankin of the Sutherland Shire Council told the Committee that:

The radio debate was held … on what must be one of the lowest rating radio stations in the country. It is our local radio station. It was an extremely controlled environment to make sure the minimum number of people heard. If we has had a debate on the ABC or on broad radio that people listened to, then you might be able to say this was public consultation. [29]

3.39 While Cr Rankin noted that the detail of the public consultation process outlined in the Draft EIS `sounds very impressive when you write that down' [30] she stated that in relation to public meetings in the community:

… an ad was taken out in the paper - it was buried and it did not mention where or when the meeting would take place. In order to get to that meeting you had to ring Environment Australia and PPK and satisfy their criteria. They had the meeting in a tiny little room in the library … which holds 12 people. [31]

3.40 The Supplement to the Draft EIS acknowledged that a number of submissions expressed concerns about the process and consultation process. ANSTO, on the other hand, claimed that `the assessment process has been in compliance with the Environment Protection (Impact of Proposals) Act 1974 and associated Administrative Procedures'. [32] However, Cr Rankin told the Committee that:

Even if by some technical stretch of the imagination we can say that the legislation written in 1974 has been complied with, it is world's worst practice in terms of community consultation, I can assure you. [33]

3.41 The Committee believes that while PPK and ANSTO may have undertaken an adequate process of consultation (within the limited requirements of the EPIP Act), this should have been more extensive and intensive given the significance of the issue. The Committee feels that public meetings conducted along similar lines to those relating to the Holsworthy Airport proposal should have occurred on the new reactor proposal. Such meetings, well advertised and providing for broader community involvement, would have assisted in overcoming the strongly held perception that ANSTO controlled the process to its own best advantage.

Concerns regarding the adequacy and independence of the EIS process

3.42 Having been drafted 24 years ago, the legislation underpinning the EIS process was criticised by some inquiry participants as being out of date and inadequate. That the Government's Environment Protection and Biodiversity Conservation Bill 1998 (now passed) was designed to supersede the EPIP Act, to a large extent acknowledges weaknesses within the legislation.

3.43 Despite deficiencies in the standards demanded by the EPIP Act, the Committee notes that specific measures were adopted during the new reactor EIS process to address criticisms about the quality and independence of the evaluation. In terms of framing the EIS guidelines, the level of consultation throughout the study and the subsequent peer review of the draft EIS, Environment Australia exceeded the minimum requirements of the EPIP Act.

3.44 A number of inquiry participants, including the Sutherland Shire Council, criticised the EPIP Act as being inconsistent with the principles of ecologically sustainable development, as defined in the Inter-Governmental Agreement on the Environment of 1992. [34] While this was an issue requiring attention in the overhaul of Commonwealth environmental legislation, the Committee notes that it has not meant that the question of ecologically sustainable development has been ignored in the new reactor EIS. On the contrary, the following principles of ecologically sustainable development as set out in the NSW Environment Planning and Assessment Regulation 1994 are considered throughout the EIS study:

• the precautionary principle. If there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation;
• inter-generational equity. The present generation should ensure that the health, diversity and productivity of the environment is maintained or enhanced for the benefit of future generations;
• conservation of biological diversity and ecological integrity; and
• improved valuation and pricing of environmental resources. [35]

3.45 PPK acknowleded that the parameters for measuring ecological sustainability remain widely debated, but defended the above tests, concluding that:

Achieving a sustainable development will necessarily involve negotiating a balance between each of the principles in order for the decision maker, in this case the Commonwealth Government, to arrive at a decision on whether or not to proceed with the proposal. [36]

3.46 The scope for a possible conflict of interest was a further weakness of the EPIP Act noted by a number of inquiry participants. In particular, the fact that the legislation allowed the initiators of a project (ie, ANSTO) to act also as the proponent of the environmental impact study was widely condemned. Among others, the Sutherland Shire Environmental Centre was particularly critical of ANSTO's appointment as proponent of the new reactor EIS, on the grounds that it would impede impartial analysis:

The fact that the proponent is also the chief adviser to the government on nuclear matters as well as being responsible for its own EIS on its existing site is beyond reason. [37]

3.47 Similarly, the Sutherland Shire Environment Centre saw a conflict of interest in the Minister for the Environment and Heritage being responsible for making recommendations on the findings of the EIS:

…the person responsible for the final acceptance or rejection of the EIS is the Minister for the Environment, Senator Robert Hill. He is a member of the same Cabinet which made the decision, in advance, that a new reactor will be built at Lucas Heights. All this gives the locals little confidence that there will be anything but a positive outcome for ANSTO and a negative for the community. [38]

3.48 The extent of concern regarding both the adequacy and independence of the EIS process prompted the Sutherland Shire Council and other community representatives to call for an environmental auditor to oversee the EIS process. Whilst the Minister for the Environment instigated three peer reviews of the EIS process, this approach of using an environmental auditor was adopted in respect of the Holsworthy and Badgery's Creek airport proposals and serves as a good model for ensuring appropriate scrutiny of the EIS process. The findings of the EIS peer reviews are considered at paragraphs 3.99 - 3.108 following discussion of the major environmental impacts of the new reactor identified in both the EIS and evidence to the Committee.

3.49 There was some concern expressed that the EIS process had gone forward in the absence of both design features for the new reactor and a waste plan. [39] The Committee was told that Daniel Hirsch, a US consultant for Sutherland Shire Council on the EIS, noted in a submission to the Council that:

In the United States, environmental review and safety assessment practice requires that the reactor must have a design before the EIS is prepared. [40]

3.50 However, Mr Watt, an engineer at ANSTO, confirmed that:

There are no detailed plans. ANSTO is not designing the reactor; ANSTO is simply specifying performance criteria and a number of general parameters within which the reactor must operate. It is up to the suppliers, the prospective vendors, to come up with designs which meet those requirements. [41]

3.51 The Supplement to the Draft EIS responded to concerns about lack of reactor design, stating:

The Draft EIS uses what is known as a set of `bounding conditions' rather than a detailed design in analysing the environmental impacts of the replacement reactor. These bounding conditions represent parameters within which all acceptable designs must lie. This approach allows the designer, when selected through a competitive tender process that can only proceed following a favourable outcome from the EIS process, to utilise the best possible design and technology whilst still ensuring that all environmental constraints are met.

… the proponent must still obtain regulatory approval to construct, to commission and to commence routine operation. [42]

3.52 In the Committee's view, the independence of the EIS process was satisfied within the limitations of the EPIP Act. That said, the process would have been strengthened if an independent environmental auditor had been appointed in an oversight role similar to the approach adopted for the Holsworthy and Badgerys Creek airport proposals. This would have given far greater assurance to the public, and in particular the local community, that the EIS process was not only independent but also transparent and accountable.

Health and environmental impacts of the new reactor

3.53 The new reactor will impact on its physical and social environment, both in the construction phase and operationally over the longer-term. The extent of its impact will vary across a range of issues. According to the draft EIS, even in the most extreme cases, these impacts can be mitigated through specific environmental management initiatives. This view is shared by the Australian Radiation Laboratory, the agency currently responsible for independent verification of radioactive discharges measured by ANSTO:

… we have no doubt that with a proper waste management policy and environmental controls in place, a new reactor can be operated at the site without causing any significant environmental harm or undue risk … [43]

3.54 In the sections that follow, the Committee examines the evidence relating to the possible impact of HIFAR and a new reactor on community health and the environment. The Committee also addresses the potential accidents and risks that HIFAR and a new reactor pose and the measures in place to address these issues.

Possible health impacts

3.55 The Committee heard widely conflicting evidence concerning the possible health impacts of radiation doses to the public arising from HIFAR's routine liquid and airborne discharges. The health implications of HIFAR and the proposed new reactor represent a major concern for many Sutherland Shire residents. This concern has been exacerbated by the uncertainty surrounding the actual magnitude of reactor emissions and nature of health risks they pose. As a local resident, Ms Maria Psaltis noted:

How do the emissions affect our air, plant and animal life, waterways, our backyard vegetables and humankind in general? [44]

3.56 In an effort to allay such concerns, reactor proponents pointed to the extent of radioactivity occurring naturally in our food and environment. As well, a number of inquiry participants cited studies that have that found reactor operations do not pose a health risk to Sutherland Shire residents.

3.57 The National Health and Medical Research Council (NH&MRC) recommends a general radiation dose limit for the public of one millisievert [45] annually. According to the Nuclear Safety Bureau (NSB), this represents approximately half the average background radiation received by Australians. In respect of HIFAR emissions, ANSTO advised that the maximum possible annual dose of radiation is less than 0.01 millisieverts, which is equivalent to the dose received by an airline passenger on a return flight from Sydney to Melbourne. [46]

3.58 The NSB endorsed the safety of emission levels from HIFAR, confirming that dose limits are well below the recommended level of the NH&MRC. Together with the Australian Radiation Laboratory, the NSB is responsible for independent monitoring of both airborne and liquid radioactive discharges from the Lucas Heights Science and Technology Centre. The NSB advised that, in respect of HIFAR, the most significant radioactive airborne discharge is argon-41, a short-lived radioactive gas produced by the neutron activation of air inside the reactor irradiation facilities. [47]These emissions still fall within recommended levels, as observed by the NSB:

Although the assessed maximum doses to the most highly exposed member of the public approach ANSTO's ALARA [48] objective of 20 Sv per year, below which it is not necessary to demonstrate that the doses are as low as reasonably achievable, work is continuing at HIFAR to identify the sources of and to reduce the amount of airborne discharges from the reactor. [49]

3.59 Furthermore, the NSB argued that the likely radiation doses arising from the new reactor would be even smaller than is currently the case. Different processes employed by the new reactor would minimise discharges, specifically of argon-41 and liquid discharges of tritium.

As the replacement reactor would not incorporate air-cooled irradiation facilities, and will use light water cooling, very little, if any, of these discharges would be released. The major discharges from a pool reactor would be very short-lived nitrogen-16 gas, and trace amounts of solid contamination in the pool water. It is expected that the radiation impact of these discharges would be less than the current discharges from HIFAR. [50]

3.60 Despite the assurances of ANSTO and the NSB, key inquiry witnesses indicated dissatisfaction with discharge levels from the ANSTO site. The Sutherland Shire Council submitted that the United States Environmental Protection Agency currently sets an effective dose limit for public exposure to radioactivity three times more stringent than ANSTO. [51]The Council also cited recent research indicating that the health impacts of airborne and other radioactivity may be worse than previously estimated by the international nuclear fraternity. [52]

3.61 Echoing such concerns, paediatrician Dr Helen Caldicott gave a graphic account of the possible impact of ionising radiation on living tissue. Describing in turn the destructive effects of strontium on bones, plutonium on testes, and iodine on children's thyroids, Dr Caldicott warned of the longer term consequences of radioactive emissions:

... as we accumulate nuclear waste into the environment, so the incidence of these diseases will increase over time, but we will not live to see it. It takes 20 generations for recessive genes to express themselves….So what we are doing is playing around with evolution. By producing radioactive waste we are producing random, compulsory genetic engineering for the rest of time. [53]

3.62 ANSTO and DISR claimed that Dr Caldicott provided a misleading account of radiation biology, omitting information essential for an understanding of the comparative risk arising from reactor emissions. In particular, they claimed that Dr Caldicott failed to acknowledge the background radiation to which we are all exposed, and the fact that this far exceeds even the worst hypothetical levels of exposure arising from HIFAR emissions. ANSTO and DISR representatives argued:

A given dose of radiation from a naturally occurring source has the same biological effect as the same dose from a man-made source. The risk from ionising radiation depends on both the intensity of the source and the length and nature of exposure. It should be noted that international and Australian standards have been developed as providing acceptable limits on the risk arising from exposure to ionising radiation. Provided these standards are adhered to, the risks associated with the use of radioactive materials are very low. [54]

3.63 Furthermore, ANSTO and DISR claimed that no detrimental health effect arising from background radiation has been demonstrated. This is the case even when the natural radiation reaches levels of 5-10 millisieverts annually, as occurs in parts of Europe such as Sweden, Switzerland, Austria, Spain and Finland. [55]

3.64 The Committee also notes the findings of both the 1993 RRR and PPK environmental impact statement regarding the new reactor proposal. These findings corroborate ANSTO and DISR's position on the safety of HIFAR emissions. After consideration of various internationally respected consultants' reports, the RRR concluded that the health of residents in the Sutherland Shire is not affected by HIFAR emissions; indeed, it is normal when compared with another equivalent shire and New South Wales overall. [56]

Possible impact on the natural environment

Geology, soils and water

3.65 Although geology, soils and water within the Lucas Heights Science and Technology Centre will be disturbed during the construction phase of the project, specific management measures proposed by the draft EIS appear adequate to mitigate any longer term environmental damage. The draft EIS noted that an erosion and sedimentation control plan would be prepared prior to commencement of the reactor's construction. [57] Thereafter, once the reactor had commenced operation, key environmental management strategies would encompass close monitoring of stormwater flows, including construction of barriers for any emergency containment of contaminated liquids. The draft EIS summarised the major potential water-related impacts of the new reactor as encompassing:

• short term impacts on local drainage lines arising from potential sediment release during construction, particularly for Melinga Molong Gully on the southern side of the proposed new reactor site;
• potential short term reductions in water quality in local streams following rain from increased stormwater discharge;
• long-term minor impact of increased hard surface area, which may increase runoff velocities and consequently erosion and sedimentation of local streams; and
• minor impacts on groundwater flow and groundwater quality. [58]

Air quality

3.66 With the major exception of atmospheric release of radionuclides which is discussed in chapter 4, the draft EIS indicated that the likely impact of the new reactor on air quality is minimal. Air pollution generated during the construction phase of the new reactor was predicted to be on a par with that of any similar sized building project, and unlikely to contribute to a sustained or significant deterioration in local air quality. As a possible management strategy, however, the draft EIS noted that air quality safeguards could include controlling the amount and effect of dust generated from earthworks and emissions from construction plant and equipment. [59]

3.67 In respect of greenhouse gases, the draft EIS found that although heat is a by-product of the fission process and is discharged to the atmosphere via a series of heat exchangers, the impact on air humidity would be localised and have a negligible greenhouse effect. No greenhouse gases such as carbon dioxide would be released through the operation of the new reactor. [60]

Flora and fauna

3.68 After a detailed study of the flora and fauna present within the Lucas Heights Science and Technology Centre, the EIS judged the likely impact of the new reactor on flora and fauna to be minimal.:

Taking into consideration the low conservation significance of the site of the proposed replacement reactor, the low scale of impacts likely to result from construction activities and the abundance of bushland adjoining the site, the overall impact of the proposal on flora and fauna is considered to be low. [61]

3.69 The most significant impacts will be the loss of approximately 1.5 hectares of Red Bloodwood/Scribbly Gum Woodland vegetation and approximately one hectare of open heath vegetation, triggering an associated loss of habitat for native fauna. As with other areas of environmental impact, however, a range of environmental management measures can be used to mitigate the impact on local flora and fauna, both within the construction phase and operation of the new reactor. The draft EIS claimed that with careful management of the buffer zone for the protection and long-term maintenance of biodiversity and natural ecosystem processes, the research reactor's presence would assist long-term conservation of the flora and fauna within the buffer zone. [62]

Accident potential and risk management

Safety regulation and management

3.70 Various safety aspects of ANSTO's operations have been overseen by three bodies:

• the Nuclear Safety Bureau (NSB);
• the Safety Review Committee; and
• the Australian Radiation Laboratory (ARL).

3.71 Both the NSB and the Safety Review Committee were established by the Australian Nuclear Science and Technology Organisation Act 1987. The NSB was until recently responsible for monitoring and reviewing the safety of ANSTO's nuclear plant, and for setting limits on radioactive materials discharged from HIFAR. Radioactive discharges measured by ANSTO were independently verified by the ARL. The Safety Review Committee had a more general, overarching charter to review and assess the effectiveness of standards and procedures adopted by ANSTO, to ensure the safety of its operations.

3.72 Despite the existence of these three regulatory bodies, the 1996 Senate Select Committee on the Dangers of Radioactive Waste identified a gap in the regulation of Commonwealth radiation sources and practices outside of HIFAR and associated plant. The Australian Radiation Protection and Nuclear Safety Act 1998 [63] addresses this problem through the creation of a new regulatory body, the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA). Under the Act, which came into effect on 5 February 1999, ARPANSA combines the resources of the ARL and the NSB. The Act also introduces regulatory controls in respect of all Commonwealth radiation and nuclear activities by prohibiting Commonwealth agencies from dealing with radioactive materials or apparatus, or any aspect of a nuclear facility, unless licensed to do so by the Chief Executive Officer of ARPANSA. [64]

3.73 ARPANSA has taken over from the NSB as ANSTO's key safety regulator overseeing all aspects of nuclear activity, including the design, construction, commissioning, operation and decommissioning of nuclear facilities. The NSB (now ARPANSA) conducted its safety compliance monitoring through a variety of channels ranging from formal submissions provided by ANSTO, to safety assessments, audits and inspections conducted by NSB experts. NSB advised that, on average, it conducted some form of inspection at ANSTO each week, and that its procedures complied with recommendations of the International Atomic Energy Agency for independent regulation and are comparable to regulatory processes in other OECD countries. [65] Furthermore, to ensure the transparency of NSB processes, its findings were reported to the Minister for Family and Community Services [66] on a quarterly and annual basis; all such reports were tabled in both houses of the Federal Parliament. [67]

3.74 The NSB required that radiation doses arising from reactor operations wereless than the limits set by the Australian National Health and Medical Research Council and conformed to the principle of As Low As Reasonably Achievable. However, both the accuracy of radioactivity monitoring and extent of information disclosed for public scrutiny were questioned by opponents of the new reactor.

3.75 In the view of a number of opponents of the new reactor proposal, public information concerning ANSTO operations is seriously deficient. For example, Mrs Suzanne Ireland, a long term resident of the Sutherland Shire, recounted for the Committee her difficulties in obtaining information about operational incidents:

I have lived at Engadine, Heathcote and Woronora Heights in the surrounding areas over the last 20 years. Perhaps all of us out there are naive. We did not realise that anything got past the site. We never knew that in 1992 the EPA made a raid on ANSTO and found leaking waste. We never knew that two kilograms of hexafluorene went up the stack accidentally in 1984 and there was an internal inquiry which decided that there was insignificant damage done to the population. [68]

3.76 Dr Helen Caldicott made comments in a similar vein about the availability of public information concerning ANSTO operations:

The deficit of data is quite amazing about the releases in terms of the number of curies released by the reactor, and of radioactive iodine, noble gases, caesium 137, frontium 90, alphamitters and tritium. For someone to assess what is going on at this reactor, one needs the data, and it is surprisingly deficient. [69]

3.77 ANSTO vigorously disputed this claim, pointing to a range of public documents produced regularly by ANSTO and independent assessors such as the NSB and Safety Review Committee. ANSTO noted that it had always published the full results of extensive environmental monitoring in an annual Environmental Survey Report. As well, its submission to the 1993 RRR was a public document that contained an extensive account of the historical waste produced at Lucas Heights, including all the emissions and environmental monitoring data for much of the history of the site's operations. [70]

Emergency Planning Procedures

3.78 In addition to the monitoring of radioactive emissions, a vital element of safety management at the Lucas Heights Science and Technology Centre is the emergency planning procedure. The NSB has been the independent assessor of ANSTO's emergency planning arrangements. Together with other Commonwealth and State agencies, the NSB periodically observed practice exercises to assess the viability of these arrangements. Over the past three years, the findings from these exercises have been incorporated in a complete redraft and updating of ANSTO's emergency arrangements for the Centre. [71] Standing Operating Procedures detailing the response of each of ANSTO's operational units also have been developed. The NSB indicated that ANSTO's emergency arrangements are `suitable and resources are in a satisfactory state of preparedness'. [72]

3.79 A different conclusion was reached by some local residents and other critics, however, who warned of inadequacies in ANSTO's emergency planning arrangements. Ms Maria Psaltis, a long-term resident of Barden Ridge (formerly known as Lucas Heights) which neighbours the Lucas Heights Science and Technology Centre argued that ANSTO has never properly prepared the community for an incident. [73] Furthermore, Dr Helen Caldicott claimed that, in the event of major catastrophe, HIFAR could meltdown in eight minutes, leaving little time for proper evacuation and emergency strategies to be implemented. In discussing ANSTO's official Emergency Planning Arrangements document , Dr Caldicott argued:

All (the document) contained was who was responsible: this one, this one, and that one. But there was nothing in it about what people should do with their children, how they get out their potassium iodine tablets, or how Sydney would evacuate and where to. [74]

3.80 ANSTO, with the support of independent analysis, disputed the possibility of a meltdown at the Lucas Heights Science and Technology Centre, let alone one that could occur within eight minutes. ANSTO's position was supported by representatives of the Australian Manufacturing Workers Union employed at the Lucas Heights Science and Technology Centre. Mr John Edwards observed:

….in general terms, the training of staff and the expectation of what to do if such an emergency should arise is, I believe, perfectly adequate. Where exercises have been carried out – and in many cases, these have been combined exercises involving the Sutherland Shire and the local emergency services – they have been done in the form of tabletop exercises, with independent review and auditors and referees. There have also been more realistic exercises carried out. While it is not my area of work, it is my understanding that – and it is not as though they have been without problems; no exercise ever would be – no significant problem has been identified. [75]

3.81 The Committee does not consider that Dr Caldicott's doomsday scenarios are realistic. However, the Committee believes that ANSTO should do more to advise and educate the community about its emergency management procedures.

Accident and emergency risks

3.82 The risk of a nuclear related accident occurring at the Lucas Heights Science and Technology Centre is of great concern to many local residents. Together with the issue of pollution, it represents one of the major reasons for opposition to the proposed new reactor. However, evidence to the Committee indicated that both the risk and potential impact of accidents or other emergencies occurring at the site are significantly less than generally feared. Indeed, in keeping with the assessment of the NSB, the PPK environmental impact assessment of the new reactor proposal found that:

... the hazards and risks of the proposed replacement reactor are within nationally and internationally accepted standards and criteria and are As Low As Reasonably Achievable. [76]

3.83 Although the proposed new reactor will have a higher neutron flux than HIFAR, and will be submerged in a deep pool of water rather than a closed tank, PPK claimed that this will not have a detrimental effect on safety. The NSB endorsed the PPK view that use of a pool will in fact enhance safety by providing a shield around the reactor and spent fuel, acting as a cooling agent and offering the potential to retain the majority of any fission products released in the event of an accident. [77]

3.84 PPK's conclusion regarding the safety of the proposed new reactor reinforced the findings of the 1993 RRR. Despite the natural concerns surrounding nuclear activity, the RRR found that the weight of evidence to its inquiry supported the view that HIFAR operates safely by an adequate margin and well within international safety standards. The RRR went so far as to claim:

The risks to people living in the Sutherland Shire are very much less than the risks of traffic accidents, lightning strikes, bushfires, and several other forms of natural hazards. [78]

3.85 Nonetheless, many local residents and nuclear opponents remained unconvinced. The Sutherland Shire Council cited expert evidence disputing the safety standards of ANSTO operations. In 1995 the Council commissioned an independent study by MHB Technical Associates, California, to analyse the possible impact upon the district of a severe research reactor accident. An alarming finding of the study was that accident likelihood and source team studies prepared for HIFAR were:

... technically inadequate and/or badly dated and no longer in keeping with the state of art in risk assessment. [79]

3.86 In response, ANSTO argued that the MHB report was confused about nuclear operations at Lucas Heights. According to ANSTO, the MHB report not only misunderstood the Australian standard and system for radiation protection of the public but also applied the wrong US standard in assessing the operation of HIFAR. ANSTO stated that the radioactive emissions from HIFAR satisfy the standards of the US Environment Protection Authority. [80]

3.87 ANSTO also provided evidence to the Committee indicating that scenarios based on a reactor `meltdown' – such as Dr Caldicott's assertion of an `eight minute meltdown' – are unrealistic. A meltdown refers to major damage to the fuel elements in the reactor core that would release a significant quantity of radioactive fission. [81] ANSTO disputed that such a catastrophe could occur at the Lucas Height Science and Technology Centre given the design and proven safety record of both HIFAR and similar reactors operating overseas. According to ANSTO, internationally there is a more than 50 year history of operation of several hundred research reactors without any core meltdown accidents affecting the public. [82] International Atomic Energy Agency reports indicate that between 1945 and 1961 there were four research reactor accidents leading to six worker fatalities. Since that time, however, no lives have been lost as a result of reactor accidents. The IAEA also reported that no members of the general public have been affected by reactor accidents. [83]

3.88 The `eight minute meltdown' claim appears to be based on a scenario fabricated as part of a 1986 hypothetical accident. Conducted by a HIFAR Safety Analysis Working Party, the study postulated that a core meltdown might occur in eight minutes following the simultaneous occurrence of multiple random and severe events, including the total failure of the HIFAR Emergency Core Cooling System. If such a crisis were to occur, ANSTO argued that the radiological consequences at the edge of the buffer zone would be below the NH&MRC's lower intervention levels for any emergency countermeasures. [84] Professor Garnett, Executive Director of ANSTO stated:

The NSB has also, along with international authorities and using international assessments, identified that there is no accident that could occur at Lucas Heights that would even require any evacuation of anybody in the community. The worst possible hypothetical case – and I stress that – is where there may need to be some sheltering for a very brief period of time. The maximum distance that would occur from ANSTO is up to 2.5 kilometres. [85]

3.89 Aside from accidents or emergencies occurring as a result of technical malfunction, natural disasters, specifically bushfires, pose a realistic threat to the Lucas Heights Science and Technology site. A detailed bushfire strategy is included in ANSTO emergency guidelines. It was called upon in December 1997 when major fires ravaged the area. According to the Sutherland Shire Environment Centre, these fires proved Lucas Heights to be a potential `disaster area', as evidenced by the forced evacuation of Barden Ridge, the suburb closest to the Science and Technology centre, and the destruction of eleven houses in the next suburb of Menai. [86] However, both ANSTO and the NSB appear satisfied that the necessary precautions are in place to protect HIFAR from serious threat.

3.90 At the height of the December 1997 fires, ANSTO took the precaution of ceasing reactor operations for a 24 hour period. HIFAR itself was not evacuated with reactor operators maintaining their posts throughout the emergency. [87] In ANSTO's view, a shutdown of HIFAR is the worst possible impact bushfires might have on nuclear operations at the site. Given the extent of firebreaks, warning systems and non-combustible building materials surrounding HIFAR, ANSTO was confident that there is no credible way in which a bushfire could lead to a reactor accident. This conclusion was endorsed by the Acting Director of the NSB, who informed the Committee that:

We are satisfied with the ability of HIFAR to withstand bushfires. Indeed I think that the bushfire that occurred sort of vindicated that conclusion. [88]

3.91 Nonetheless, the Committee notes that access to the reactor site is limited to one road and that during the bushfires this road was closed at times. The Committee considers that it is unsatisfactory to have a situation where access to the reactor site cannot be guaranteed at all times.

3.92 Regardless of reassurances regarding accident and emergency risks, the Sutherland Shire Council believes that, in the worst case scenario that an incident does affect local residents or their property, current public liability arrangements are inadequate. Legal advice commissioned by the Council indicates that, by relying on the common law, nuclear liability in Australia is primitive by international standards. [89] Although Australia has signed the 1997 Convention on Supplementary Compensation for Nuclear Damage, [90] ratification of the convention is a long way off. Therefore, in the meantime compensation for any damage would have to be claimed under common law. Whether the Commonwealth or ANSTO would be liable for any losses or damage would depend on the details of the particular case. The Commonwealth has indicated that it would ensure ANSTO has the capacity to meet any damage claims which might conceivably be awarded. [91] It is noted in the Supplement to the Draft EIS that a deed of indemnity was signed between the Commonwealth and ANSTO on 27 August 1998. [92]

Transportation risks

3.93 Transportation of nuclear waste and radioisotopes from the Lucas Heights Science and Technology Centre is a further area of significant accident potential. It is of particular concern to local residents and neighbouring councils in areas through which radioactive materials are moved. Both the NSB and the ARL have been responsible for monitoring all transportation arrangements for radioactive materials.

3.94 Stringent regulations adopted by the International Atomic Energy Agency underpin the NSB and ARL's monitoring of radioactive materials' transportation. These regulations demand safety assessments at a number of levels. In respect of each type of radioactive material, the regulations specify design criteria for the transportation container and recommend appropriate handling and stowage procedures. A key aspect of the NSB's work, therefore, has been to:

… assess the (radioactive waste) transport casks and packages against those regulations. We witness the tests of those packages and we are completely satisfied as to the fitness for purpose of the transport packages. Additionally we have reviewed the transport plan for the movement of those wastes outside of the site. [93]

3.95 The NSB concluded that there is no undue risk to the health and safety of the public arising from the transportation of nuclear waste. [94] This was also confirmed in evidence from the Commonwealth Department of Transport to the 1996 Senate Select Committee on the Dangers of Radioactive Waste, which indicated that there have been no significant incidents in the transportation of radioactive materials in Australia during the last 30 years. [95]

Conclusions of the Draft EIS

3.96 Based on its broad analysis of the likely environmental impact of a new reactor located at Lucas Heights, PPK Environment & Infrastructure reached the following general conclusion:

The cumulative impacts arising from the construction and subsequent operation of the proposed replacement reactor for a period of not less than 40 years are expected to be small, particularly if the management measures outlined in the Draft EIS are implemented.

The site for the proposed replacement reactor has been well characterised and the impacts of HIFAR monitored over the past 40 years. Provided the mitigating measures are taken, and given the commitment that radioactive waste would be removed from Lucas Heights, the analyses in the draft EIS have indicated that there are no significant issues raised under the principles of ecologically sustainable development. [96]

3.97 The principles of ecologically sustainable development as defined in the New South Wales Environmental Planning and Assessment Regulation 1994 underpinned PPK's analysis. Intergenerational equity is one of the four key principles of ecologically sustainable development. It concerns the legacy passed from one generation to the next in respect of health, diversity and productivity of the environment. According to the draft EIS, some of the benefits of the proposed new reactor in relation to the principle of intergenerational equity would be:

• economic benefits to the local, regional and national communities of interest through generated employment, income and economic input;
• increases in the standard of health care through the availability of a reliable supply of radiopharmaceuticals and access to increased numbers of radiopharmaceuticals;
• enhanced opportunities for neutron beam research to Australia's scientists and engineers;
• better analytical services to improve Australian industry competitiveness; and
• maintenance of technical expertise to provide sound advice to Government in international affairs. [97]

3.98 In ANSTO's view, further studies relating to issues raised in the public submission process, confirm `the findings of the Draft EIS and hence the findings of the Final EIS are unchanged from the Draft EIS'. [98]

Key findings of independent peer reviews of the new reactor EIS

3.99 Three independent reviews of some of the key nuclear issues considered in the EIS were commissioned by Environment Australia. The reviews were conducted by the International Atomic Energy Agency, Parkman Safety Management, and Ch1M HILL respectively. All three reviews had the goals of:

• ensuring rigorous independent expert scrutiny of the draft EIS;
• assisting stakeholders in understanding the EIS technical issues, and in preparing their submissions on the draft EIS; and
• assisting Environment Australia in its assessment of the proposal.

The International Atomic Energy Agency Review

3.100 The International Atomic Energy Agency (IAEA) review was largely concerned with the radiological risks associated with both normal operations of the proposed new reactor and possible accidents. In particular, the review was requested to evaluate the EIS in terms of the appropriateness and adequacy of data and methodologies used; the appropriateness of any standards used and basis for their use; and the correctness or reasonableness of any assumptions, comparisons or conclusions made, particularly in relation to siting. [99]

3.101 Based on an assessment of available information, discussions with key parties and a site visit, the IAEA concluded that Lucas Heights would be an acceptable location for the proposed new reactor. In the opinion of the IAEA, the proposed site:

… has no negative characteristics which would make it unacceptable from a nuclear or radiological safety point of view. Any deficiencies of the site can be compensated by engineering design. [100]

3.102 This finding by the IAEA is not surprising given that Lucas Heights has been the site of the HIFAR reactor for forty years.

3.103 However, in reaching its conclusion, the IAEA noted shortcomings in the so-called `Reference Accident' [101] evaluated in the EIS. The IAEA judged the Reference Accident to lack detail and noted that a full justification for the choice of accident was not included in the EIS. Accordingly, the IAEA recommended that the Final EIS include substantiation for the Reference Accident, citing all other accident scenarios considered (including those with external initiators) and a justification for why they were screened out. [102]

The Parkman Safety Management Review

3.104 The second EIS peer review was conducted by the UK based Parkman Safety Management (PSM), and focused on the preliminary hazard and risk assessment contained within the new reactor EIS. As with the IAEA review, PSM identified scope for improvement in the analysis of the EIS's Reference Accident. In particular, PSM noted that the same Reference Accident was evaluated by ANSTO in its Siting Safety Assessment submitted to the NSB in April 1998. However, ANSTO used different modelling assumptions concerning dispersion parameters and receptor behaviours in its assessment. Consequently, PSM recommended that these differences be explained in terms of their sensitivity to key aspects of the hypothetical accident including:

• the height of fission product release;
• weather conditions;
• lifestyle assumed for the most exposed person; and
• collective dose cut-offs.

3.105 This recommendation was addressed by ANSTO and PPK in the Final EIS. The differences in the modelling assumptions used by ANSTO and PPK were stated in the report. [103] The Final EIS claimed that the effect of these differences did not alter the conclusions in the draft EIS regarding the Reference Accident. According to ANSTO and PPK:

It should be recognised that the Siting Safety Assessment is part of a regulatory submission intended to obtain Site Authorisation for the replacement nuclear research reactor … and hence serves a different, yet complementary, purpose to the EIS.

The differences in modelling assumptions result from the independence of the NNC calculations from those of ANSTO and also provide an indication of the effect of a range of realistic assumptions on the results of the Reference Accident assessment. It should be noted that the assumptions made in the Draft EIS and the Siting Safety Assessment Reference Accident are pessimistically bounding in that it is not credible to make more conservative assumptions. For example, the timing of the release from the reactor building is assumed to coincide with F/D cycling of weather which provides the maximum credible dose. Both the Siting Safety Assessment and Draft EIS results for the doses from the reference Accident are within the relevant criteria put forward by the Nuclear Safety Bureau. [104]

3.106 Aside from this one area of weakness, PSM judged the Reference Accident to be appropriate for bounding any fault that could occur on a well designed reactor system. In addition, PSM commented that the risks and hazards assessment of the EIS had been undertaken in accordance with currently accepted methodologies and internationally verified computer codes. Although some shortfalls in information requirements were identified, PSM generally supported the conclusion that the effects of up-rating can be accommodated without increased off-site doses. [105]

The Ch1M Hill Review

3.107 Ch1M HILL was the third group to conduct a peer review of aspects of the new reactor EIS. Specifically, Ch1M HILL considered the nuclear-related aspects of the EIS, focussing on the:

• appropriateness and adequacy of information presented;
• appropriateness of any standards used and the basis for their use;
• correctness and reasonableness of any assumptions, comparisons or conclusions made;
• overall adequacy of materials presented in the EIS in addressing relevant nuclear matters;
• comments on any commitments by ANSTO for future studies; and
• recommendations or suggestions for additional work. [106]

3.108 Ch1M HILL concluded that the draft EIS had adequately identified the risks associated with the new reactor proposal, and that the possible related impacts were appropriately described as minimal. Ch1M HILL noted a need for further detail within the EIS, particularly with respect to the shipment of spent nuclear fuel and wastes; disposal of radioactive wastes; and regulations and operational criteria.despite these minor shortcomings, the company was unable to identify any conditions precluding the construction and operation of the new reactor. [107]

Committee's conclusions regarding siting

3.109 The Committee concludes that adequate public consultation within the limits of the EPIP Act took place over the new reactor proposal but that the process could have been significantly improved. Conducting public meetings, similar to those relating to the Holsworthy Airport proposal, would have allowed for more open channels of communication between both sides of the new reactor debate and may have helped allay some of the concerns of local parties.

3.110 In the Committee's view, the process surrounding the environmental impact study (EIS) was independent. But it too could have been enhanced by appointing an independent environmental auditor in an oversight role similar to the approach taken with the Holsworthy and Badgery Creek airport proposals. This would have improved the transparency and accountability of the EIS process.

3.111 While the EIS process was independent, it was incomplete and inadequate insofar as it did not consider alternative sites to Lucas Heights for the new reactor. The 1993 RRR stated explicitly that an `exhaustive search' for alternative sites was essential before a decision could be made on a new reactor. Neither the internal departmental study on alternative sites, nor the methodology and criteria informing that study, has been released by the Government to the Committee. The Committee has been kept in the dark on a fundamental stage in the decision making process for the new reactor.

3.112 The Committee concludes that the decision to build a new reactor was made without proper consideration of the recommendations of the RRR in regard to exhaustive analysis of alternative sites. The Committee recommends that alternative sites be properly and fully investigated by an independent public inquiry.

Footnotes

[1] Submission No.29, p. 3.

[2] Formerly the Department of Industry, Science and Tourism, until 22 October 1998; Commonwealth of Australia Gazette – Special; Administrative Arrangements Order, 22 October 1998.

[3] Submission No.29, p.11.

[4] K R McKinnon, Future Reaction, Report of the Research Reactor Review, Commonwealth of Australia, August 1993, p.162.

[5] K R McKinnon, Future Reaction, Report of the Research Reactor Review, Commonwealth of Australia, August 1993, p.164.

[6] Submission No.33, p.1.

[7] K R McKinnon, Future Reaction, Report of the Research Reactor Review, Commonwealth of Australia, August 1993, p.164.

[8] K R McKinnon, Future Reaction, Report of the Research Reactor Review, Commonwealth of Australia, August 1993, Recommendation 20.1, p. xxiv.

[9] Submission No.7, p. 4.

[10] Evidence, p. 380.

[11] Submission No.29, p.3.

[12] Evidence, p. E14.

[13] Evidence, pp.E102-103.

[14] Submission No.25, p.18.

[15] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p.3.33.

[16] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p.6.29.

[17] Submission No.20, p.2.

[18] Submission No.20, p.1.

[19] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, pp.2-4–2-5.

[20] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p.2-5.

[21] Submission No.33, p.1.

[22] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, , Volume 2/Appendices, p.C-4.

[23] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, , Volume 2/Appendices, p.C-8.

[24] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p.7-17.

[25] Twyford Consulting, Evaluation of an EIS Community Consultation Process for ANSTO and Sutherland Shire Council. August 1998, p.8.

[26] Twyford Consulting, Evaluation of an EIS Community Consultation Process for ANSTO and Sutherland Shire Council. August 1998, p.11.

[27] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 3/Supplement, p.2-14.

[28] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 3/Supplement, p.2-11.

[29] Evidence, p.E302.

[30] Evidence, p.E306.

[31] Evidence, p.E294.

[32] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 3/Supplement, p.2-14.

[33] Evidence, p.E295.

[34] Submission No.25, p.10.

[35] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p.2-7.

[36] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p.20-6.

[37] Submission No.7, p.1.

[38] Submission No.7, p.1.

[39] Evidence, p.E295.

[40] Evidence, p.E298.

[41] Evidence, p.E273.

[42] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 3/Supplement, pp.5-7—5-8.

[43] Submission No.22, p.2-3.

[44] Submission No.19, p.2.

[45] The sievert is the unit measure of the effects of ionising radiation on living cells, and one thousandth of a sievert is known as a millisievert (1000 Sv). PPK Environment & Infrastructure, Draft EIS, Glossary, p.G-17.

[46] Submission No.29B, p.1.

[47] Submission No.28, p.7.

[48] The ALARA objective refers to doses being `as low as reasonably achievable'.

[49] Submission No.28, p.7.

[50] Submission No.28, p.12.

[51] Submission No.25, p.15.

[52] Santa Susana Field Laboratory Epidemiological Study: Report of the Oversight Panel, September 1997, referred to in Submission No.25, p.15.

[53] Evidence, p.E169.

[54] Submission 29B, p.2.

[55] Submission 29B, p.2.

[56] K R McKinnon, Future Reaction, Report of the Research Reactor Review, Commonwealth of Australia, August 1993, p.205.

[57] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p. 8-14

[58] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p.8-16.

[59] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p. 9-8.

[60] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p.9-7.

[61] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p.12-17.

[62] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p.12-17.

[63] Assented to 24 December 1998, commenced 5 February 1999.

[64] Evidence, p E 410.

[65] Submission No.28, p.3.

[66] Formerly the Minister for Health and Family Services until 22 October 1998.

[67] Evidence, p.E78.

[68] Evidence, p. 308.

[69] Evidence, p.E164.

[70] Submission No.29B, p.5.

[71] Copies of the Lucas Heights Site Emergency Plan and the ANSTO Emergency Plan (DISPLAN) are available for inspection at the reception centre at ANSTO, at Sutherland Shire Council libraries and at the Sutherland Shire Environment Centre. The Sutherland Shire Local Disaster Plan (DISPLAN) and the Georges River District Disaster Plan (DISPLAN) are also available at libraries.

[72] Submission No.28, p.11.

[73] Submission No.19, p.2.

[74] Evidence, p.E181.

[75] Evidence, p.E68.

[76] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p.20-11.

[77] Submission No.28, p.12 and PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p.11-22.

[78] K R McKinnon, Future Reaction, Report of the Research Reactor Review, Commonwealth of Australia, August 1993, p.166.

[79] Submission No.25, p.16.

[80] Submission No.29B, Attachment - Comments on MHB Report etc., p.2.

[81] Submission No.29B, Attachment - Research Reactors and Meltdowns, p.1.

[82] Submission No.29B, Attachment - Research Reactors and Meltdowns, p.1.

[83] Submission No.21, p.8.

[84] Submission No.29B, Attachment - Research Reactors and Meltdowns, p.2.

[85] Evidence, p.E240.

[86] Submission No.7, p.7.

[87] ANSTO Safety Division, Report on Bushfires of December 1997, February 1998, p.12.

[88] Evidence, p.E92.

[89] Submission No.25, p.17.

[90] The Convention on Supplementary Compensation for Nuclear Damage requires ratification by one third of the world's nuclear power generating countries before it comes into force. Thereafter, Australian legislation will need to be established to meet the obligations of the Convention. PPK Draft EIS, Main Report, p.11-48.

[91] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p.11-48.

[92] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Supplement to Draft Environmental Impact Statement, Volume 3/Supplement, p ES-19.

[93] Evidence, p.E83.

[94] Evidence, p.E83.

[95] Senate Select Committee on the Dangers of Radioactive Waste, No Time to Waste, April 1996, p.84.

[96] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p.xxvii

[97] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p.20-12.

[98] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Supplement to Draft Environmental Impact Statement, Volume 3/Supplement, p. ES-20.

[99] International Atomic Energy Agency, Review of the Draft Environmental Impact Statement for the Replacement Nuclear Research Reactor, September 1998, p.1.

[100] International Atomic Energy Agency, Review of the Draft Environmental Impact Statement for the Replacement Nuclear Research Reactor, September 1998, p.17.

[101] A hypothetical accident scenario used to assess nuclear facility siting, accident management and emergency planning. See PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Draft Environmental Impact Statement, Volume 1/Main Report, p.G-16.

[102] International Atomic Energy Agency, Review of the Draft Environmental Impact Statement for the Replacement Nuclear Research Reactor, September 1998, p.17.

[103] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Supplement to Draft Environmental Impact Statement, Volume 3/Supplement,Table 11.5, page 11.38.

[104] PPK Environment & Infrastructure, Replacement Nuclear Research Reactor, Supplement to Draft Environmental Impact Statement, Volume 3/Supplement, p.11-37.

[105] Parkman Safety Management, ANSTO Replacement Nuclear Research Reactor EIS: Peer Review of Hazards and Risks Analysis, September 1998, p.1.

[106] Ch1M HILL, Report to Environment Australia: Replacement Reactor Draft EIS Technical Review, September 1998, p.2.

[107] Ch1M HILL, Report to Environment Australia: Replacement Reactor Draft EIS Technical Review, September 1998, p.1.

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