Antinuclear

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Flinders Local Action Group’s detailed submission: Nuclear Waste Dump decision is a National matter – not just a local one

CONCLUSION: The current model to establish a NRWMF is wrong. This initiative has not come from any community. This is a National problem and it needs a National solution.

What is really wrong about this process is that radioactive waste, including the legacy material, is the Nation’s inheritance from an industry which, for its entire lifetime, has not included waste disposal as part of its production process. Filling and stacking drums was never going to be a solution. This is a National issue and a National problem. Small, remote communities, whether at Kimba, the Flinders Ranges or anywhere else, should never be expected to make the decision alone to accept the toxic by-products of one industry’s lifetime production.

The Flinders Ranges are promoted throughout the world as one of the last untouched landscapes that can be easily accessed. Tens of thousands visit the Flinders Ranges each year from all over the world. 

A major point has been made of the need to clear our hospitals of low level waste comprised of used gloves, gowns, syringes and other items. This was contradicted, in October 2017, by a DIIS sponsored spokesman in Hawker who “advised that nuclear waste from nuclear medicine procedures in hospitals is virtually zero……the use of nuclear medicine will not contribute to radioactive waste in hospitals……this short lived product is stored for 10 half-lives……and disposed of as hospital waste.

 

Flinders Local Action Group , Greg Bannon, Roybn Wood, Leon Ashton, Bob Tulloch Submission toTo The Senate Economics References Committee. Inquiry into the process surrounding the Federal Government’s National Radioactive Waste Management Project (NRWMP).(Submission No. 73)

INTRODUCTION   The Flinders Local Action Group is a regional group of volunteers based in the Flinders Ranges that have strong concerns about the project proceeding in our community.

The three sites currently under consideration for the facility are all in South Australia – one at Barndioota in the Flinders Ranges and two in Kimba on the Eyre Peninsula. Some of this nuclear waste is a hazard for hundreds of years and some for thousands of years.

The Flinders Local Action Group (FLAG) was formed to challenge the waste facility being built in our area and is made up of indigenous and non-indigenous members of the community. The site at Barndioota is of high cultural and archaeological significance to the Adnyamathanha Traditional Owners, is located in a flood zone, is subject to seismic activity and is located in the iconic Flinders Ranges. We do not believe this site is appropriate for the federal radioactive waste facility. The process of site selection is fundamentally flawed and has caused deep division and stress in our community.

Addressing the Terms of Reference

a) Financial compensation offered to applicants for the acquisition of land under the guidelines

 Compensation is a minor part of the issues involved with site selection. The whole process has been problematic since March 2015 when the Federal Government, (citing the use of “international best practice”), invited landholders across Australia to nominate land for a National Radioactive Waste Management Facility. Twenty five eligible sites were nominated and, of these, six were shortlisted for public comment.

 There was no requirement for the nominees to seek consent or even consult with their neighbours or communities.

Storing radioactive waste on agricultural or pastoral land is a major departure from accepted land use. Under principles of “best practice” such a serious departure should demand consent from a number of sources including neighbours , community, local authorities and right up to the relevant State bodies

.  Nominations closed on 5th May and the short list was announced on 13th November, 2015. This announcement, nearly nine months after the process commenced, was the first that the community, including the Flinders Ranges Council, had heard of the nomination of Barndioota as a potential site to accept nuclear waste. Community knowledge and awareness of the project was minimal.

The name “Barndioota” was not widely known or used. The nominated property is well known locally as Wallerberdina. The area nominated is classified “Out of Districts”, outside local government boundaries and under the jurisdiction of the Outback Communities Authority. The nominator does not live there.

 The nominator, a partner in the relatively recently acquired Wallerberdina lease, is fully informed of the history and scope of this project. A former South Australian Federal Senator, he served on three Senate Select Committees related to this industry – Dangers of Radioactive Waste, 23/03/95 to 24/04/96 (Chair from 30/03/95); Uranium Mining and Milling, 08/05/96 to 15/05/97 (Chair from 23/05/96); and Lucas Heights Reactor, 17/08/00 to 24/05/01.

b) How the need for “broad community support” has played and will continue to play a part in the process, including:

DIIS contracted Orima Research to assess community support and produce a report. It is a large document, of over 200 pages, containing all the charts, bar-graphs, tables, questionnaires, responses, summaries etc. from each of the six shortlisted sites. There is a lot of repeated information and it is confusing for a layman to decipher. ( The document is: DIIS, National Radioactive Waste Management Facility, Community Sentiment Survey, Wave 2 Report of Findings, April 2016)

The document has been reviewed by an independent researcher who has offered a critique. His opening paragraph is quoted below. “I have read through the report referred to above and have made a number of observations in summary format below. These comments are made without access to either the raw survey data or any detailed report on the survey findings e.g. tabular data. In reality this report should be titled only a summary report – it is too sketchy and contains too many errors to be considered a formal interpretive report”.

  1. Definition of “broad community support”

A “general population survey” was conducted by telephone using a process called “computer assisted telephone interviewing” (CATI). Phone numbers were sourced from “SamplePages” and were primarily composed of landline numbers. Many local people with only a mobile service would not have had an opportunity to take part in the survey. This was a flaw in the random sampling process.

 Orima Research determined that 65% of the respondents to the Barndioota survey did not oppose the process moving into the second phase of consultation. This response has been publicly misrepresented many times to give the impression that the community has agreed to support the facility. The community has never been formally asked whether it wants it or not. (Note: The 65% figure above comes from only 11% of the population – i.e. 146/1331)

There were two locally generated surveys that attempted to gauge the level of support.

 A petition against the proposal was conducted by Hawker GP Dr Susi Andersson and presented to Minister Matt Canavan in November 2016. 852 signatures were collected and, after scrutiny, the results showed 91 “No’s” from Hawker (54% of the voting population) and 251 from Quorn (42%). There were another 30 from the Flinders region,

but not in the voting area. The additional 480 votes came from people outside the region who were concerned with the proposal and wished to record their signatures. This does not indicate broad based support.  The Flinders Local Action Group conducted its own survey in September 2016, which asked the question “Do you want a National Radioactive Waste Management Facility established at Wallerberdina Station/Barndioota – Yes, Undecided or No?”, returned a convincing “No” vote. The results of this survey are listed in the following table;

Results of the Flinders Local Action Group Survey Surveys Response Yes Undecided No Area posted Rate % Vote Vote Vote

Hawker / Cradock 174 22% 31% 5% 64%

Quorn 383 24% 11% 3% 86%

Area result 557 23% 17% 4% 79%

The survey attempted to distribute voting forms to the community through Australia Post’s Unaddressed Mail Service. Those distributed through Quorn Post Office were only delivered to boxes that accepted “junk mail”. By contrast, all DIIS material and newsletters are delivered without restriction to every mail bag and letterbox in the district.

ii) How “broad community support” has been or will be determined for each stage of the process.

 A senior Department official wrote, “…the Federal Government is not pushing for a state-ofthe-art National Radioactive Waste Management Facility in SA”, (Adelaide Advertiser, 6/09/2017). For more than two years there has been a relentless focus on our region in order to secure community acceptance for the project.

 The DIIS presence is promoted as “providing information”, which is true, but the information has had little balance. The emphasis has been on accentuating the benefits to the community and alleviating concerns.

 At the initial public meetings the community was coming to terms with the proposal, trying to absorb a lot of technical information, mixed with assurances of high safety standards and rigorous protocols. The level of questioning from the floor was relatively simplistic and unsophisticated and the community was on a steep learning curve.

 A radioactive waste dump has serious, long term implications. If it didn’t, it would not be necessary to expend so many resources over such a long period to sell the proposal to a community. From those first town meetings in Quorn and Hawker to explain the proposal, early in 2016, deep division in the community opened rapidly. Supporters of the project seem uncritical and accepting. Expectations of new, unforseen opportunities have been raised and the possibilities, real or imagined, seem to outweigh all other concerns.

 Much public consultation has been conducted privately via “drop in” days, one-on-one, for individuals or small groups to ask questions or voice concerns. The flow of information is filtered through the Department officials

There is a long list of actions and activities that have been brought to this community over the last two years or more, all aimed at “community engagement”. It has long been recognised that to “sell” a new concept, where there is a degree of opposition or scepticism, it is useful to encourage the community to become involved and “take ownership” of the proposal. Contracting as many community members as possible to serve on committees and working groups is a good start. The positions carry annual contracted payment, presumably paid per diem (for meeting attendance). It is not unreasonable to compensate for time and travel, but the roles are advisory only. It is made clear that all decisions rest with the Department and, ultimately, the Minister responsible.  Some of these actions are listed below.

  1. Barndioota Consultative Committee: There are around 19 members, including the Convenor who comes from outside the district. It is not really clear what role it performs other than an advisory one, perhaps, a rubber stamp for Department decisions. There are restrictions on what Committee Members are allowed to disclose from meetings.The committee has been involved in the Community Benefit Package grant allocations but does not assess the applications. It is presented with summaries of each and asked to rank them.The committee does not produce minutes, only notes. They can be accessed on-line but are often delayed. Notes from the December meeting were still not posted on 22/03/18.

    The community is encouraged to interact with the committee, supposedly as a conduit for community “engagement” but on two occasions, orderly community members wanting to attend a meeting as observers have been ejected. As at April 2018, two years into the process, no guidelines or protocols have been set to allow members of the community to observe meetings.

  1. Appointment of a Community Liaison Officer (1 person), an Economic Working Group (7 people) and a Heritage Working Group (10 people).
  2. 3) DIIS, ANSTO and AusIndustry staff have manned displays, with hand-outs for children, at two successive Quorn Shows and the inaugural Hawker Community Fest.
  3. 4) A representative of AusIndustry re-located his family to Hawker for a period of time in 2017 to assist with issues related to the Community Benefit Package grants.
  4. 5) Engaged a consultant from Queensland University with expertise in community engagement to speak to the BCC and working groups, with follow up visits scheduled.
  5. 6) Introduced a number of different speakers including a delegation of four from Champagne in France. The delegation was here to praise the benefits a waste facility had brought to their region and to allay concerns of any negative impacts to agriculture and tourism if the facility goes ahead.
  6. 7) Escorted a number of different individuals and groups, including school students, to visit Lucas Heights and demonstrate the safety of the material to be stored here. This offer has been open to many in the community. The visit has been reassuring to those who support the proposal. For those with reservations, who have not taken up the offer, it seems like a pointless and expensive exercise, knowing that nothing will be presented that is not clean, efficient and well run. ANSTO’s expertise and procedures have not been questioned.

c) How any need for indigenous support has played and will continue to play a part in the process. How will support be determined for each stage?

 Support from the Traditional Owners is vital for the project to proceed. Indigenous people were surveyed separately, outlined in the Orima Research document (pp104-105). Of 77 people surveyed only 4 lived in the specified area, the remainder living outside, but the majority of those expressed attachment to the land as owners or traditional owners.

 Members of this community have been offered a trip to France to view the operations of the ANDRA CSA facility in the Champagne region.  Members of the Viliwarinha Yura, traditional owners of the area proposed, and one of the core bodies making up the Adnyamathanha Traditional Landowners Association (ATLA), were speaking up very strongly against this proposal before most of the community in general were aware of it. ATLA is opposed.

  1. Whether and/or how the Community Benefit Packages affect broad community and indigenous community sentiment.

 There is more to it than just the Community Benefit Packages (CBP). It is inevitable that the introduction of money into an issue like this will affect community sentiment. This is particularly so in small communities like ours where opportunities are limited. Expectations have now been raised in those who support the project. Community sentiment has been affected and there needs to be no distinction between the white and black communities.

 The Department states on its web site: “A Capital Contribution Fund of at least $10 million to support local projects will be made available to the final host community”. However, as detailed in the National Radioactive Waste Management Act 2012, Part 6A, Section 34E: “A committee chaired by the State Premier and comprising 3 other persons resident in that State with expertise in education, infrastructure and health will advise the Minister when administering the fund”. There is a very good chance that the $10,000,000 could just simply disappear into state revenue.

 DIIS is well-resourced and a lot of money has been spent with seemingly little public accounting. Some figures are accessible, for example, contracts for Committees and Working Groups, Community Benefit Package grants and so on, but there are many expenses that do not seem to be open for scrutiny. These relate to staff presence in the district and associated expenses, vehicle hire, escorted visits to Lucas Heights by numbers of different groups and individuals, expenses related to bringing speakers to public information sessions or to attend Consultative Committee meetings, printing and postage of promotional material, attendance of staff at local Shows and associated hand-out material, discretionary spending on credit cards and so on.

 Community co-operation is the glue that holds small towns and districts together. The introduction of money has been like pouring solvent on the glue. It may be a long time before the split can be stuck together again.

 Defining “community” has been a subject of discussion. In the Department’s “Phase 1 Summary Report, April 2016 – Section 3.6, pp. 8,9)” the six short listed sites are all defined differently. In our region the definition was given as the area within a 50 km radius of the site, plus the rest of the area outside in the jurisdiction of the Flinders Ranges Council. This takes in the township of Quorn, which is over 70 kms from the site. It was thought that including Quorn, being a larger town that Hawker, may increase the capacity for local businesses to tender for work on the facility.

 The Department has said that this facility will not be forced onto an unwilling community. It has also said that no individual or group will have the right of veto. It is not clear what this statement really means. It is assumed to mean that no individual or group has the casting vote, either for or against. How a vote will be decided and who will be eligible to vote is still under discussion. It is not “open and transparent” and is a source of concern and stress.

 It has been signalled that discussion may take place to exclude Quorn and contract to the area of the former Hawker District Council, prior to amalgamation with Quorn, plus the rest of the 50 km circle. There has been no explanation and the assumption is that this may be considered to offer the best chance of a “Yes” vote at the end of Phase 2. When Phase 2 will end is unclear.

 On the other hand, for those who do not want the facility here, an added stress is the thought that if the vote is opened to a wider electorate (Eyre Peninsula or State-wide), people with no connection to this area may vote to keep it here so it is not sited closer to them. In 2017 a Citizen’s Jury voted by two-thirds majority not to accept international high level radioactive waste in SA. Community members are not confident that vote will translate to this current proposal.

What is really wrong about this process is that radioactive waste, including the legacy material, is the Nation’s inheritance from an industry which, for its entire lifetime, has not included waste disposal as part of its production process. Filling and stacking drums was never going to be a solution. This is a National issue and a National problem. Small, remote communities, whether at Kimba, the Flinders Ranges or anywhere else, should never be expected to make the decision alone to accept the toxic by-products of one industry’s lifetime production.

f) Any other related matters

 This process has and continues to cause great distress. It has set community members and even families against each other. It is also setting project supporters in different communities against each other because DIIS says they have no preferred site and are proceeding with “community engagement” in two, or possibly even four, communities consecutively. When the question was asked, “How will the communities that miss out be reconciled?” the reply was that they will have had their Community Benefit Packages as compensation.

 One small example of this community division, if not considered petty, occurred at a public meeting in Hawker in on 10th October, 2017. A group of three speakers were addressing a public evening information session on the subject of Nuclear Medicine and Radiation. A resident from Quorn attempted to ask a question and was asked by the Chairperson to leave the meeting on the grounds that it was for Hawker residents, causing him much embarrassment. In reply to a written protest about the incident, the DIIS spokesman said he could not intervene because it was not a DIIS meeting. The speakers had been brought to Hawker by the Department and were not scheduled to speak in Quorn.

 The Flinders Ranges are promoted throughout the world as one of the last untouched landscapes that can be easily accessed. Tens of thousands visit the Flinders Ranges each year from all over the world. In 2016, the Flinders Ranges was cited as the tenth best place in the world to visit. According to figures quoted from the Tourism S.A. web site, something like $300 million is generated annually from tourism in the Flinders and outback areas. The number of tourists visiting the French facility in the Champagne region and Lucas Heights are quoted to support the facility. There are no guarantees, however, that such a facility in the Flinders will attract visitors or turn some away. Neighbouring pastoral properties, that also run tourist ventures, are very concerned about this project and are opposed to it.

 The Flinders Ranges have an international reputation as a location for film productions going back over seventy years or more. Many famous movies and series have been filmed in and near the Flinders Ranges. “Robbery Under Arms” was shot in the 1950’s up to one of the most recent, the latest in the “Wolf Creek” series, filmed last year

Mason Curtis is production and location manager with more than 25 years’ experience in the industry. He was most recently here to work on “Wolf Creek”. In September last year he wrote to the Hawker “Town Crier”. Part of his letter reads, “Too often now I am challenged by very senior film makers that have indicated they will not visit or return to the Flinders Ranges if it becomes a nuclear waste dump. I’ve defined that the area is near Hawker but it means little to interstate and international film makers…..I believe the short term economic benefits of such a facility will severely impact on film making in the area and the long term cost to us will be loss of trade, tourism, effectively free tourism promotion through film, and ultimately cause irreparable damage to our film culture”.

 It is illegal to establish a radioactive waste facility in South Australia, under State Legislation. The Nuclear Waste Storage Facility (Prohibition) Act was passed in 2000. The objects of this Act are “to protect the health, safety and welfare of the people of South Australia and to protect the environment in which they live by prohibiting the establishment of certain nuclear waste storage facilities in this state.” Apart from overriding it, it is not clear how this legislation is to be accommodated. To override it and force the facility on South Australia would not be in line with “international best practice”

Nuclear Medicine: It has been impressed on the community that a primary reason for the NRWMF is the need to dispose of Australia’s radioactive medical waste. DIIS is the only official source of information, some of which implies that procedures such as CAT scans, X-Rays, and cancer treatments require the use of radioactive isotopes. Plain scans, X-Rays and a vast majority of cancer treatments do not use such isotopes.

These statements are simplistic and misleading but readily grasped and repeated by those who are uncritical, accepting and not prepared to do their homework. It is frustrating and disappointing to hear this same information being publicly stated to the Brewarrina community two years after it was called into question in our district.

A major point has been made of the need to clear our hospitals of low level waste comprised of used gloves, gowns, syringes and other items. This was contradicted, in October 2017, by a DIIS sponsored spokesman in Hawker who “advised that nuclear waste from nuclear medicine procedures in hospitals is virtually zero……the use of nuclear medicine will not contribute to radioactive waste in hospitals……this short lived product is stored for 10 half-lives……and disposed of as hospital waste. As an example, if you receive nuclear medicine via an injection the syringe gets put in a lead lined bin and then capped, dated and sent for incineration after 10 half-lives of the longest lived radionuclide”.

Independent information, primarily from the Medical Association for the Prevention of War (MAPW), paints a different picture and offers alternatives. This information and the authors have been publicly discredited, however their message is even more relevant now than two years ago. Medical science has made considerable advances in that time. (See attachment #1: MAPW open letter to the Minister)

 On three counts alone, the Barndioota site should never have made the short list:

  1. It is situated on the Hookina floodplain. A simple scroll over the area on Google Earth reveals the image of alluvial fans, the signature of massive historic floods and mud flows. Only a basic grasp of topography is needed to observe the “steps” in the plateaux between ranges indicating traumatic shifts of topsoil turning it into flowing mud. (See attachments: #2, #3 & #4 – Professor CC Vonderborch documents)
  2. ii) The Flinders Ranges are one of the most seismically active areas in the country. The seismic record speaks for itself.

(See attachment #1: MAPW open letter to the Minister)

 As mentioned earlier, housing radioactive waste on pastoral land is a major departure from the accepted land use. Once established, the facility will be actively accepting low level radioactive waste (LLRW) for 100 years and will require oversight and management for a further 300. Colocated on the same site will be an unspecified amount* of intermediate level radioactive waste (ILRW), to be temporarily stored for an unspecified time*. (*unspecified amount – ANSTO is planning increased production of radioactive isotopes for medical use to potentially supply an international market. Increased production must increase waste. *unspecified time – “Temporary” has been defined as 30 to 40 years or possibly more.)

 ILRW can only be stored at this site on a temporary basis. DIIS has stated that for permanent disposal it requires deep burial in geologically stable conditions – no such site exists in Australia today and there is currently no plan to develop one.

 In the relatively short life of this industry being developed for peaceful means, the world is littered with examples of incidents, accidents, design failures and human error. The problem of waste storage has still not been solved. In this current search for a site for NRWMF it has not been publicly acknowledged that accidents can and do happen.

CONCLUSION:

The current model to establish a NRWMF is wrong. This initiative has not come from any community. This is a National problem and it needs a National solution. A completely new discussion needs to take place, involving all States and Territories and all other interested bodies. A uniform, national policy, formulated at COAG level, is needed. Strong leadership – bi-partisan, inclusive and empathetic – and genuine spirit of cooperation is needed.

Attachments:

  1. letter to Minister Canavan
  2. Geological and environmental Implications of a nuclear waste disposal site in the Barndioota area
  3. Diagram Barndioota alluvial flows
  4. Explanation of diagram – implications for groundwater
  5. Map showing earthquake hazard zone
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June 11, 2018 - Posted by | AUSTRALIA - NATIONAL, Federal nuclear waste dump

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