Introduction

The federal government released a draft EnvironmentalImpact Statement (EIS) on its plan for a national radioactive waste dump near Woomera in South Australia on July 26.

And a fine farce it is, too. The government claims that the approval and licensing process is both "comprehensive and rigorous". However, the government itself will 'review' and then rubber-stamp the EIS. It is nothing more than an expensive bureaucratic whitewash.

Science minister Peter McGauran - dumped from the ministry in 1997-98 for travel allowance irregularities - said in a July 26 statement announcing the EIS release: "The site selection process began in 1992, with the agreement of all States and Territories." However, the dump is opposed by the South Australian government and a large majority of the state's population.

The EIS begins with a disclaimer: "No warranty or guarantee, whether expressed or implied, is made with respect to the information reported or to the findings, observations or conclusions expressed in this EIS." In other words, don't believe a word of it.

Rationale

The EIS skates over the alleged 'need' for a national dump, stating that: "A national repository is required to dispose of Australia's accumulated and expected future low level and short-lived intermediate level radioactive waste. Without a national repository, radioactive waste would continue to be stored in over 100 sites around Australia largely in facilities that were not purpose built. This poses potential public health and safety risks, including possible theft or misuse by terrorists."

That rationale ignores numerous points. Even with a national dump, most of the 100 sites - comprising hospitals, research institutions, and industry and government stores - will continue generating radioactive wastes and will therefore remain as radioactive waste storage sites, if only for interim storage pending transfer to the dump. Sites with inadequate storage facilities ought to be improved whether or not the Woomera dump proceeds. If and when those improvements are made, the case for a centralised dump recedes still further, particularly since the dump will be designed only for short-lived wastes (radionuclides with half lives of 30 years or less).

In some cases, waste is being more-or-less adequately managed and the advantages of moving it to a centralised dump are outweighed by the risks associated with moving it. As a rule of thumb, waste is best managed at the site of production or use because that minimises transport risks and also encourages minimisation of radioactive waste production.

The EIS does not justify the preference for an underground dump as opposed to above-ground storage. There can be advantages in above-ground storage such as facilitating monitoring and remediation of problems.

Safety

The dump proposal could not possibly survive a risk-benefit analysis because the project will provide no benefits whatsoever to Woomera. The risks, whatever their magnitude, must inevitably outweigh the 'benefits'.

The EIS invokes the threat of nuclear terrorism - and specifically mentions the September 11 terrorist attacks in the United States - to justify a centralised dump. However, terrorists would have no interest in the relatively small radioactive inventories stored at over 100 sites around Australia (nor is a dump at Woomera likely to pose a terrorist target).

The EIS fails to address key, unresolved issues. It provides nothing more than an "indicative design" and "preliminary design layout" of the planned dump, along with an "indicative borehole design". (The government plans to dump waste in trenches and boreholes up to 20 metres deep in a 100x100 metre site within the 1.5 x 1.5km site.)

The EIS identifies "operational hazards" associated with the dump but dismisses them with the assertion that: "Appropriate procedures would be developed to address these issues."

The EIS says: "Near-surface disposal has been practised since the 1940s and there are more than 100 near-surface repositories for low level and short-lived intermediate level radioactive waste either operating or being established in over 30 countries around the world." But the EIS says nothing about the manifold problems associated with overseas dumps, on which topic see Kirsten Saunders, May 2002, "Nuclear Waste Dumps: A Review of the United States Experience", PDF file: <www.acfonline.org.au/docs/publications/rpt0021.pdf>.

Woomera residents - and people living along the transport corridors - might take some comfort if, as the government claims, the region was found to be the safest site for a dump on scientific criteria. However, it was not. The government's own siting study found equally suitable geology in the Olary region of western New South Wales. The Olary region also has the advantage of being closer than Woomera to the main waste source - the nuclear reactor plant operated by the Australian Nuclear Science and Technology Organisation (ANSTO) at Lucas Heights. For a discussion on why SA was chosen, see <www.geocities.com/jimgreen3/waste9.html>

Missiles

The preferred site for the dump is in the Woomera Prohibited Area, owned by the federal Defence Department, and is just three kilometres from the Range E target. The EIS states that the risk of missiles inadvertently striking the dump is "Medium" using a US Department of Defense methodology. The EIS says that "larger or higher velocity weapons may strike with sufficient kinetic energy to penetrate the 5 metre soil cover of the waste". The EIS says that the Defence Department "advises that there are on average 60 weapons firings per year that could potentially strike the repository".

These risks were highlighted with a failed rocket test on July 14, 2002, at Woomera.

In October 2001, an experimental supersonic scramjet launched at Woomera veered off course and crashed.

The staging of an Automatic Landing Flight Experiment at Woomera by the Japanese government in 1996 was delayed due to concerns about radioactive waste stored near Woomera.

Members of the Defence Department have privately expressed concern about the potential impact of storing radioactive waste near the rocket range according to South Australian Labor MP Lyn Breuer, whose electorate covers Woomera. In fact those concerns have also been voiced publicly.

Thin edge of the wedge

For some years the government has tried to head off thin-edge-of-the-wedge arguments by asserting that a "total radionuclide inventory" will be established for the dump. However, the EIS does not specify the limit, stating only that it will be established by the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA).

The government has waxed and waned on the issue of co-locating an 'interim' store for long-lived intermediate-level waste, including waste from the reprocessing of spent nuclear reactor fuel from the Lucas Heights reactor plant in southern Sydney, adjacent to the planned Woomera dump. The EIS says that co-location will not occur, but as recently as April 6, 2002, science minister Peter McGauran was quoted in the Adelaide Advertiser saying in relation to co-location that: "We're not ruling out or ruling in anything." (A summary of the co-location controversy is at: <www.geocities.com/jimgreen3/waste10.html#store> See also other articles at <www.geocities.com/jimgreen3/index.html#sawaste>.)

In the mid-1990s, 2,010 cubic metres of low-level radioactive waste - soil from CSIRO research - was moved to Woomera for 'interim' storage. Now, the existence of that 'interim' waste store at Woomera is being used to justify locating the dump at Woomera. The EIS says: "The proposed repository is consistent with the existing land use. The existing use includes the storage of radioactive waste, and presently over half the current inventory of waste (2,010 cubic metres of slightly contaminated soil compared with the total of 3,700 cubic metres requiring disposal) is stored within the WPA."

The point will be obvious: establishing an underground dump at Woomera will allow this or future governments to expand the nuclear activities at the site using the same 'consistent use' argument:
- already, the planned dump will take not only low-level radioactive waste but also short-lived intermediate-level waste, not only short-lived waste but also long-lived waste
- an 'interim' store for long-lived intermediate-level waste (LLILW) may be 'co-located' adjacent to the dump as discussed above
- the 'interim' LLILW store may become a permanent fixture, or a deep underground dump or some other "purpose-built facility" may be established for LLILW disposal at the same site
- ANSTO has said that unprocessed spent nuclear reactor fuel could be sent to the LLILW store for "extended interim storage" if overseas reprocessing plans fall through, and the federal Department of the Environment and Heritage said in 1999 that storage at an unspecified "remote repository" would be the "only prudent and feasible alternative" consistent with government policy if overseas reprocessing plans fall through
- a spent nuclear fuel processing/conditioning plant may be built in Australia in the coming decades, and sites in South Australia would certainly be short-listed (as they were in a 1997 siting study by the federal government)
- there remains a small possibility that above-mentioned developments will pave the way for a deep underground dump for tens of thousands of tonnes of high-level waste from nuclear power plants overseas.

The EIS states: "The estimated initial operational life of the national repository is 50 years, after which time there would be an operational review." In other words, the door is being left wide open for the dump to operate for many more than 50 years.

The EIS states: "The repository would be designed to take about 10,000 cubic metres of low level and short-lived intermediate level waste (although the limit would be set in terms of total activity of various radionuclide groups)." The 10,000 cubic metres figure is almost three times the current stockpile of 3,700 cubic metres generated over the past 40 years.

The thin-edge-of-the-wedge issues are dealt with in detail at: <www.geocities.com/jimgreen3/waste10.html>

Reactor link

The planned dump is, above all, a political exercise designed to remove waste from ANSTO's Lucas Heights reactor plant and thereby reduce opposition to plans for a new reactor.

The government likes to paint a picture of poorly-managed waste in dozens of urban locations, but the EIS reveals that over three quarters of the waste (1,320/1,690 cubic metres) to be trucked to Woomera will come from ANSTO's reactor plant in Sydney. The government also indulges in fear-mongering about radioactive waste stored in the centre of Adelaide. But the EIS reveals that apart from a large volume of low-level radioactive waste already stored at Woomera (the 2,010 cubic metres of CSIRO-origin soil), only 218 cubic metres of waste stored in South Australia is destined for the dump.

In the future, according to the EIS, ANSTO will be responsible for about three quarters of the national production of waste destined for the dump (30/40 cubic metres/year).

Dismantled nuclear reactors destined for the Woomera dump could comprise a waste volume greater than the entire existing national inventory of low-level and short-lived intermediate-level waste. The EIS states that the existing reactor, and the planned new reactor, will each generate 500-2,500 cubic metres of low-level and short-lived intermediate-level waste. The combined figure for the reactors is up to 5,000 cubic metres, compared to the existing national inventory of 3,700 cubic metres. (The two reactors will also produce a great deal of LLILW - a total of over 3,000 irradiated nuclear fuel elements, and ANSTO plans a 12-fold increase in the annual generation of liquid LLILW arising from the processing of targets irradiated in the reactors - liquid LLILW has caused all sorts of problems for ANSTO and continues to do so yet a large increase in the production rate is planned.)

The volume of CSIRO-origin waste now stored near Woomera is about 50% greater than the volume of waste stored at ANSTO destined for Woomera (2,010/1,320 cubic metres). But in total the ANSTO waste destined for Woomera is over 2,400 times more radioactive than the CSIRO waste. (And ANSTO's spent fuel and other LLILW is far more radioactive than both the CSIRO-origin soil and the 1,320 cubic metres at Lucas Heights destined for the dump.)

When ANSTO was directed by the NSW Land and Environment Court not to store the radioactive waste of non-ANSTO origin, and to remove the 2,010 cubic metres of CSIRO-origin soil from Lucas Heights (it originally came from Victoria), the federal ALP government enacted the ANSTO Amendment Act 1992, with Coalition support. This Act made ANSTO immune from NSW public health, land use and environmental protection laws. The major parties have shown themselves willing to over-ride state laws (and local councils) to deal with their radioactive waste problems, so it goes without saying that the promises made in the EIS - which carry no legal weight whatsoever - are scarcely worth the paper they're written on.

The EIS attempts to justify the dump with vague references to the 'national interest' and tenuous, inaccurate attempts to link the dump to the production of medical radioisotopes. The EIS says that ANSTO estimates that "in 2000/01 there were about 525,000 people in Australia who underwent a nuclear medicine procedure for the treatment of medical conditions such as cancer". The real figure is 50-100 times lower. Moreover, the argument that South Australians should accept a national nuclear dump to facilitate the production of medical radioisotopes at Lucas Heights is a nonsense argument - compared to South Australia, seven times more nuclear medicine procedures are carried out in New South Wales, four times more in Victoria and twice as many in Queensland.

Moreover, the argument that a new reactor is needed for medical radioisotopes is specious and has been debunked and disputed by numerous nuclear medicine researchers, nuclear medicine physicians, current and former ANSTO scientists, medical cancer specialists etc. The argument for a reactor for medical radioisotope production was wearing so thin that two government reports in 1999 acknowledged that the primary agenda for the planned new reactor is a convoluted foreign policy ('national interest') agenda.

Radioactive racism

The EIS clutches at straws in an attempt to identify benefits: "The siting phase has involved consultation with Aboriginal groups on heritage, and the engagement of relevant individuals and advisers to report on the heritage values of possible sites. Further opportunities for the involvement of Aboriginal people may be available during the construction stage, including involvement in fencing or other works, or through site visits."

The federal government has attempted a number of manoeuvres to over-ride Aboriginal opposition to the dump. One ploy in the late 1990s was to negotiate with some Aboriginal groups but not others, but widespread opposition nullified that manoeuvre.

Another ploy - this one more successful - was to threaten compulsory acquisition of land short-listed for the dump. Aboriginal groups gave permission for test drilling on short-listed sites in the late 1990s, but only because they were between "a rock and a hard place" according to Stewart Motha from the Aboriginal Legal Rights Movement: "If Aboriginal groups do get involved in clearances [for test drilling] they face the possibility that the Government will point to that involvement as an indication of consent for the project. If they refuse to participate, who will protect Aboriginal heritage, dreaming and sacred sites?"

'Institutional period'

The EIS states that: "After the wastes have been disposed of, and the trenches (or boreholes) capped, the repository area would be monitored and access controlled for a 200-year institutional period. During this period any release of radioactivity from the site would be detected and remediated if required. In future years, when the repository site is no longer under institutional control and the waste form and waste packages have degraded, radioactivity could be released to the environment through a number of pathways."

The EIS further states that: "Overall it has been shown that the risks which might arise in future years, when the site is no longer under institutional control, are acceptably low and are in accordance with the NHMRC 1992 Code." Acceptable to whom? Presumably the government and/or the puppet regulator ARPANSA - but, as we have seen with shallow burial of long-lived wastes at Maralinga, they are far too easily satisfied. Moreover, it is debatable whether the Maralinga clean-up satisfied the NHMRC Code, or whether the Code was even applicable to Maralinga. The EIS notes that its conclusion of an "acceptably low" risk was based on "assessments" and "generic assumptions" about the radioactive inventory - but the inventory could easily exceed the figures used for the risk calculations.

Furthermore, there is an important caveat in the EIS: "The conclusion from these assessments is that the risks are very low, and within the risk target value, for all of the scenarios other than major climate changes and gross erosional events. Where these major changes have been assumed to occur, the risks are only slightly higher than the risk target. However, computer modelling by CSIRO indicates that a transition to a wetter climate in the Woomera area is unlikely to occur in the next 10,000 years."

Of course, climate change is subject to considerable uncertainty and depends on a myriad of variables - e.g. climate change is more likely to occur, and to occur at a more rapid rate, as a result of the unwillingness of the governments of the United States and Australia to ratify the Kyoto Protocol.

Moreover, CSIRO scientists Dr. Jon Olley and Dr. Peter Wallbrink said in 1999 that new scientific evidence indicates that since European invasion/settlement, Australians have had a "far more catastrophic impact on their landscape than previously suspected." European settlement "unleashed an episode of erosion, sediment deposition and change in river systems orders of magnitude greater than we have assumed to date", they said. Dr Wallbrink added: "There's little doubt modern Australians have underestimated the extent of change we have inflicted on our landscape. In some cases the rates are staggering. We're talking about changing the very face of Australia in comparatively few years, so dramatic is the scale of these events." (CSIRO media release, 'Evidence of massive landscape change unearthed', 20/1/99.)

Maralinga weapons tests

One of the many problems with the latest 'clean-up' of the Maralinga nuclear weapons testing site in north-western South Australia was the failure to establish 'waste acceptance criteria' before commencing vitrification of contaminated debris. The EIS justifying the Woomera dump defines waste acceptance criteria as "the set of requirements that must be met before radioactive waste can be accepted for disposal", but it fails to specify the criteria, merely asserting that they "would be developed for the facility before operations begin".

The links between the scandal-plagued Maralinga 'clean-up' and the planned dump have been made by nuclear engineer Alan Parkinson, who was involved in the Maralinga 'clean-up' as a senior government adviser and representative until his criticisms of the project saw him removed from it in December 1997.

"The disposal of radioactive waste in Australia is ill-considered and irresponsible", Parkinson wrote in the August edition of Australasian Science. "Whether it is short-lived waste from Commonwealth facilities, long-lived plutonium waste from an atomic bomb test site on Aboriginal land, or reactor waste from Lucas Heights. The government applies double standards to suit its own agenda; there is no consistency, and little evidence of logic."

On Maralinga, Parkinson writes: "Surprisingly, there was no study to find a proper site for disposal of the Maralinga debris, and no call for a site with suitable geology. The disposal trenches at Maralinga are only 15 metres deep in limestone and dolomite strata exhibiting many cracks and fissures - geology which is totally unsuitable."

Parkinson concludes his Australasian Science article thus: "It is high time that clear and firm guidelines for the disposal of radioactive waste are published, and adherence to these guidelines made mandatory. The government also must accept long-term responsibility for sites that were contaminated with their approval."

Parkinson told ABC radio's Background Briefing program in April 2000: "When you consider that people who are in charge of this project are the same people who are responsible for a national nuclear waste repository ... that they're the people who could easily just say, 'Well, just put a hole in the ground, throw it in.' That's what we've done with the plutonium at Maralinga. And if the politicians have accepted that without any demurring, then why should we bother?"

Likewise, Parkinson argued in a 2001 paper: "The outcome of the Maralinga project is clear evidence that neither the Minister [former science minister Nick Minchin], his department, nor ARPANSA have any credibility in the management of radioactive waste ..." (Comments on DISR / National Store Advisory Committee, July 2001, "Safe Storage of Radioactive Waste, The National Store Project: Methods for choosing the right site".)

Many of the individuals and organisations involved in the botched Maralinga 'clean-up' are also involved in the planned Woomera dump. These include federal government bureaucrats, construction company GHD, the puppet regulator ARPANSA, and sundry 'experts':

Bureaucrats: Parkinson wrote in the February 2002 edition of the journal Medicine and Global Survival: "From its inception, the nuclear industry has had problems with worker and public safety and with environmental degradation. Too often these problems have been caused by ineffective management, cost-cutting measures, or ineffective regulation. The Maralinga project reflects all three of these factors. The public servants responsible for the last years of the [Maralinga] project had no background in radiation or project management, as is illustrated by several statements they made on the public record, asking, for example, what was meant by alpha radiation, or how to convert a milliSievert (a unit of radiation dose) to a picoCurie (a unit of radioactivity), or claiming that soda ash is neutralized by limestone."

GHD: Construction company GHD played a major role in the Maralinga 'clean-up' and has also won a contract with the federal government as private project manager and community consultation manager for the planned Woomera dump. GHD's role as 'community consultation manager' is particularly ironic given that it refused media requests to respond to criticisms of the Maralinga 'clean-up' and has threatened a critic of the 'clean-up' with a defamation suit. For a critique of GHD's role at Maralinga, see <www.geocities.com/jimgreen3/parkinson.html>

ARPANSA: ARPANSA is described as the "Commonwealth's independent regulator" in the EIS, but it is not independent and has not shown itself much inclined to regulate. ARPANSA is too close to government - it is effectively a government agency. It is also too close to ANSTO, with six former ANSTO staff working for ARPANSA, and ANSTO having a direct role in the selection of the chief executive of ARPANSA. ARPANSA's role at Maralinga was inadequate and also deceitful. For example, ARPANSA's chief executive John Loy stated that the 'clean-up' was consistent with the 1992 NH&MRC Code of Practice without noting that the Code did not formally apply to situations such as that at Maralinga. In any case it is debatable whether the 'clean-up' complied with the Code. The government was guilty of the same deception.

Parkinson wrote in Australasian Science: "The government's actions do not lend confidence to how they will dispose of waste from the new reactor. This is the reactor which should not go ahead until the method of handling the spent fuel is "written in blood", to use Dr Loy's words of July 2000. But Loy has licensed its construction while the process for handling spent fuel is not resolved." One of the major gaps in the 'plan' for ANSTO's spent fuel is that there is no LLILW store to receive wastes arising from the overseas reprocessing of spent fuel.

'Experts': Former science minister Nick Minchin said the government "didn't make a move without expert advice" at Maralinga, but the 'experts' were dancing to sensitive, political tunes every bit as much as the politicians and bureaucrats. In 1998, the chair of an 'expert' committee asked a senior government bureaucrat whether the government would "welcome" advice to terminate vitrification of contaminated debris at Maralinga in favour of shallow burial. Of course that advice was welcome since shallow burial was the cheaper option. So-called 'experts' have already made idiots of themselves in relation to the planned dump, with one such 'expert' insisting that the dump would "constitute no risk to the people of Australia" without even knowing whether an underground or above-ground facility was being planned.

PPK: Consultancy company PPK was not involved in the Maralinga 'clean-up' (as far as I know), but it was involved in preparing the EIS for a new reactor at Lucas Heights in conjunction with ANSTO, and it has assisted in the preparation of the Woomera dump EIS. Former ANSTO nuclear engineer Tony Wood said of the reactor EIS: "If it is normal for the proponent (of an EIS) to tell the truth, but not necessarily the whole truth, then ANSTO's presentation is normal. Sometimes the difference between the truth and the whole truth is quite remarkable." The same could be said of the dump EIS.

Submissions

The EIS is on the internet at <www.dest.gov.au/radwaste/DraftEIS>. Hard copies can be purchased for $50 from Australian Government Bookshops and a summary can be purchased for $2.50 (phone 132447).

Public comments on the draft EIS will be accepted until September 20. Submissions will not directly influence the sham EIS whitewash, but it may be worthwhile registering your opinion with a brief submission because data on the number and type of submissions will probably be published.

Submissions can be made by letter/fax/email to:
Radioactive Waste Dump EIS
Department of Education, Science and Training (Location 742)
GPO Box 9880, Canberra City, ACT, 2601.
Fax: (02) 6240 9184
Email: <repository@dest.gov.au>

More information

More information on the dump (please email if you know of other useful information souces):
* Australian Conservation Foundation <www.acfonline.org.au/asp/pages/intro.asp?IdLctn=12>
* Iratiwanti <www.iratiwanti.org>
* Friends of the Earth <www.foe.org.au>
* Nuclear Information Centre (SA) <www.ccsa.asn.au/nic>
* <www.ace.net.au/nnnews/index.html>
* Greenpeace <www.greenpeace.org.au>, esp. <www.greenpeace.org.au/nuclear/whatawaste/pdf/gpap_report.html>
* Sustainable Energy and Anti-Uranium Service <www.sea-us.org.au/wastedump/wastedump.html>
* <www.sanuclearfree.org.au> + waste links: <sanff.zane.net.au/main/links.html>
* more waste articles on this website <www.geocities.com/jimgreen3/index.html#sawaste>
* federal government waste site <www.dest.gov.au/radwaste>