Australian news, and some related international items

Australian Conservation Foundation: need for nuclear waste dump in Flinders Ranges not proven, alternative options not explored.

The siting of a National Radioactive Waste Management Facility, is an issue of huge national importance. So is it fair that our small community is being asked to make such a serious decision based on limited and, we believe, misleading information?

The Australian Conservation Foundation Submission [no 70] to the Senate Economics References Committee on the selection process for a national radioactive waste management facility in South Australia, Dave Sweeney | Nuclear Free Campaigner |

The Australian Conservation Foundation is Australia’s national environment organisation. We stand up, speak out and act for a world where reefs, rivers, forests and wildlife thrive

ACF welcomes this opportunity to comment on this important national issue and anyopportunity to talk to this submission before the Committee. The continuing and contested federal move to site a national radioactive waste management facility in regional South Australia has wide ranging and lasting impacts and requires the highest level of scrutiny, rigour and consideration.

ACF concerns over the federal radioactive waste plan and process include:

the federal government has never proven the need for the project or adequately  explored alternative management options.

In its current configuration the federal plan has failed to realise the justification threshold required for nuclear  actions or establish a compelling and robust case for the planned facility

 conflicts with the current federal plan and best international and industry practice. In particular, the proposed approach to intermediate level waste management is clearly not consistent with international best practice

 the proposed facility is unlawful in South Australia and the conflict between the federal plan and existing state law undermines commitments to the principle of a volunteered site and non-imposition

 the profound trust deficit and broad ranging community suspicion and mistrust that exists towards the facility, the process and the proponent

 given that the federal government and federal agencies are both the project proponent and project assessor the federal role is not disinterested or neutral

 federal moves to ‘harmonise’ approvals and licensing processes are viewed by many in the community as a fast-tracking exercise

the persistent failure of the project proponent to provide timely, detailed and transparent information or to respond to public information requests

 the persistent failure of the proponent to proactively challenge misinformation around the project, especially in relation to economic benefit, nuclear medicine and the nature of waste to be managed at any future facility

 the high level of community stress and tension related to the planned facility and  the divisive nature of the process

 the challenge to meaningfully engage affected Aboriginal peoples, transport corridor and wider communities and emergency services/first responders

 the need to ensure national stakeholders are recognised in the process

These issues are of critical importance to radioactive waste management and the current federal approach and highlight the need for the highest levels of scrutiny, evidence and procedural rigour. This has been lacking in the federal approach to date.

ACF notes that the Committee has resolved that it will only accept submissions that strictly address the inquiry’s terms of reference, with a particular focus on the appropriateness and thoroughness of the site selection process for a national radioactive waste storage facility.

ACF has specific concerns and comments as well as broader observations that are directly related to the national radioactive waste plan and process and to term of reference (f). We request the Committee adopt a broad construction and consider the wider context to this important national interest issue.

Should the Committee maintain that such issues are beyond its remit ACF would urge the Committee to explicitly identify these issues and this constraint and recommend that they be subject to future separate and dedicated scrutiny.

These broader concerns are key to resolving the current policy impasse and realising the goal of advancing responsible national radioactive waste management.

ACF maintains that there has been no compelling public health, radiological or national interest case made for the planned facility and that extended interim storage at existing federal facilities is possible, prudent and – coupled with a public options analysis – far more likely to realise a lasting solution to our radioactive waste management challenge.

In this context ACF offers the following comments for the Committee’s consideration.

The Committee’s inquiry is happening because the federal approach to radioactive waste management for over two decades has comprehensively failed. This history is important and needs to be recognised, not replicated.

1990/91 – around 2000 cubic metres of low level contaminated soil moved from CSIRO in Fishermans Bend (Vic) to the Australian Nuclear Science and Technology Organisation’s (ANSTO) Lucas Heights nuclear facility in southern Sydney

1992 – NSW Land and Environment Court upholds Sutherland Shire Council application and orders removal of non ANSTO origin waste from Lucas Heights

1992 – Primary Industry and Energy Minister Simon Crean announces national radioactive waste repository site selection study

1998 – National repository study identifies the Billa Kalina region of north-central South Australia as the area for detailed site-specific investigation

1998 – ANSTO seek approval for construction of the current OPAL reactor and commits to progressively move Lucas Heights waste off site

2003 – Federal government acquires land for a site in northern SA. This is later quashed following a Federal Court objection and the government abandons SA site plans in 2004.

2005 – Despite an earlier commitment to the contrary the Federal government identifies three Defence land parcels in the Northern Territory as possible waste sites

2007 – Muckaty Station north of Tennant Creek is added to the NT site list and becomes the primary federal focus

2012 – Resource Minister Martin Ferguson announces radioactive waste returning after reprocessing in Europe will be stored at Lucas Heights due to delays with Muckaty plan.

2014 – Muckaty site nomination withdrawn during Federal Court action and Minister Ian Macfarlane announces “I’ll throw it open to anyone in Australia who can provide me with a block of land free of dispute and challenge that is environmentally suitable”

2015 – National Radioactive Waste Management Project opens for nominations – six sites are short listed in November.

2015 – Waste returned from Europe moved into dedicated on site storage at ANSTO

2016 – Barndioota site chosen for detailed federal site assessment

2017 – Two Kimba sites added for federal consideration

This abbreviated timeline highlights several important factors in the current radioactive waste management discourse: a fixation on the pursuit of one management model, a pattern of community impact and pressure, a lack of transparency and trust sustained and successful community resistance and a potential way forward.

The search for a site and the lack of a proven rationale:

A more than two-decade federal government search for a national radioactive waste facility site has failed multiple times in South Australia and the NT due to sustained community, especially Aboriginal community, opposition; widespread political and community contest and protest; a deep lack of trust and confidence in government processes and successful Federal Court legal challenges.

After all this time, effort, headlines and heartache there is still no social license and no national facility, and the search and story continue today in the Flinders Ranges and at Kimba.

Radioactive waste management is a complex policy arena. It involves long lived wastes that pose a significant intergenerational legacy and burden. The material is hazardous with important safety, security and risk considerations and related technical, financial, regulatory and political complexities and costs. The difficulty of the issue is heightened by the long-term nature of the material and the fact that any decision may sterilise other future management or development options.

However, while radioactive waste management is complex it need not be intractable. A new and different approach to addressing this national policy challenge is now needed.

The search for a site has developed such institutional momentum that advancing this has become an end in itself. This has seen the search for a postcode to host a national facility prioritised over any evidence-based assessment of whether a national facility is needed or if the proposed federal model is the best management option.

The principle of ‘justification’ is a key part of any radiation safety approach. This requires that any decision that alters a radiation exposure situation should do more good than harm. ACF maintains that this foundation principle has not been realised in relation to the current federal plan.

The planned national facility will not remove waste from hospitals or medical clinics, is not advancing the long-term disposal of intermediate waste and the claimed project benefits have not been adequately tested or proven.

Along with justification the principle of net benefit is useful to frame the discussion. The National Health and Medical Research Council (NHMRC) 1992 Code of Practice for the Near-Surface Disposal of Radioactive Waste in Australia requires that “No practice involving exposures to radiation should be adopted unless it produces sufficient benefit to the exposed individuals or to society to offset the radiological detriment it causes”.

Similarly, section 41 of the ARPANSA Regulations (1999) lists matters the CEO of the Australian Radiation Protection and Nuclear Safety Agency must consider in relation to a licence application, including: “Whether the applicant has shown that there is a net benefit from carrying out the conduct relating to the controlled facility.” That requirement is also specified in subsection 32(3) of the ARPANS Act.2

Despite this successive federal governments have made no efforts to demonstrate net benefit during multiple failed radioactive waste management proposals.

There has been scant attention or assessment given to alternative radioactive waste management options and the absence of this fundamental pathway analysis is inconsistent with the evidence base required to demonstrate justification. The current federal approach fails to address or satisfy this pivotal test.

a) the financial compensation offered to applicants for the acquisition of land under the Nominations of Land Guidelines;

The proposed amount of offering three to four times the market price for any selected area of land is not unreasonable given that the price of the land – as opposed to the value of the country – under consideration is itself not high. What is unreasonable is that a single landholder can make a site nomination without any wider consultation or consent and this is promoted as a voluntary process.

For 100 hectares of land in regional or remote Australia, this does not equate to a large incentive for the landowner and the financial benefit is likely to be modest. However, it should be noted that ‘the Commonwealth reserves its right to determine, at its sole discretion, any offer it makes for the acquisition of property’.

South Australia has state legislation in place prohibiting the storage or disposal of nonstate nuclear waste on their land. The National Radioactive Waste Management Act 2012 (section 19) provides the federal government with the power to override this law.

Such a scenario undermines the stated commitment to ‘volunteerism’, as the democratic rights of the affected electorate would be actively ignored and over-ridden. A nominee only holds the right-to-withdrawal up to the point the nominated site has been approved. International experience shows that a continuous right-to-withdrawal (up to the time the Minister declares a site for the facility under section 14 of the National Radioactive Waste Management Act 2012) would be more consistent with international best practise.

The actual declaration of a nominated site as the chosen one for a facility gives the Minister the right to acquire adjacent or related land required to access the declared site and may therefore affect the rights of other community members. What protections will  apply to ensure any other affected parties also have the right of consent to the selection of the site?

b) how the need for ‘broad community support’ has played and will continue to play a part in the process, including:

i) the definition of ‘broad community support’, and

ii) how ‘broad community support’ has been or will be determined for each process advancement stage;

Community benefit and consent: importance, definition and extent.

Not only the community in near proximity of the site would be affected but also wider regional communities and those communities along the transport routes between the facilities producing or currently storing nuclear waste and any new facility. This issue affects a far broader cohort than simply the local community at the possible site and in the current process these wider voices are disenfranchised and under-represented.

There is an extensive body of academic and technical reports and policy papers that note the importance of social license and community consent and the need to recognise, respect and respond to opposition on its merits rather than reflexively view criticism as vexatious, misinformed or ‘emotional’.

Disturbingly stakeholders, especially community and civil society critics of the federal plan, appear to be viewed more as impediments than assets by the project proponent. This is particularly the case in relation to calls for evidence and independent review around the projects fundamental rationale, drivers and need.

The recent South Australian Royal Commission into the nuclear industry noted that radioactive waste management requires both social consent for the activity and advanced technical engineering to contain and isolate the waste. Of the two, social consent warrants in planning and development much greater attention than the technical issues.

The earlier UK Committee on Radioactive Waste Management (CORWM) found that community involvement in any proposals for the siting of long term radioactive waste facilities should be based on the principle of volunteerism i.e. an expressed willingness to participate and identified the failure of earlier ‘top down’ mechanisms (often referred to as Decide-Announce-Defend).

CORWM stated that it is generally considered that a voluntary process is essential to ensure equity, efficiency and the likelihood of successfully completing the process and that there is a growing recognition that it is not ethically acceptable for a society to impose a radioactive waste facility on an unwilling community. It further found that communities should have the right to withdraw from siting processes up to a predefined point.

There is a growing recognition that it is not ethically acceptable for a society to impose a radioactive waste facility on an unwilling community

UK Committee on Radioactive Waste Management, 2006

Experience has shown that without this consent, the project will sooner or later be cancelled, stopped or indefinitely delayed − one way or the other EU Nuclear Decommissioning Best Practice guidelines

ACF welcomes the focus on community issues in the Committee’s deliberations. Defining ‘community’ is clearly a pivotal issue and point of tension in relation to the current federal project, especially given that the enabling legislation the National Radioactive Waste Management Act (2012) lacks guidance or definition. Reaching any definition involves significant policy challenges and political choices and these both  shape and reflect the level of wider community confidence in any siting process.

The lead author of this submission participated in the federal departments Independent Advisory Panel (IAP) for the National Radioactive Waste Management Project and is personally aware of both the genuine intent with which this work was approached, and the complexities involved.

This experience demonstrated that it is far easier to find neat metrics to measure and assess natural and technical features and properties than it is to do so with human values, attitudes and responses.

A further issue is that the current proposal is a move by the federal government to start a national facility. It is a unique and significant nuclear action and an issue of legitimate and keen national interest. It cannot solely or primarily be approached as a regional or local government administrative area decision.

There are clear communities of interest that are not geographically defined but who need to be actively recognised and meaningfully engaged. This was recognised in the SA Nuclear Fuel Cycle Royal Commission finding that both ‘broad social consent and specific community consent must be obtained for any new nuclear activity to commence in South Australia’.

Community groups in both Kimba and the Flinders Ranges have publicly commented on the need for broader community engagement in the siting process. The Flinders Local Action Group (FLAG) in a September 2016 survey letter to regional residents made this point strongly, stating:

The siting of a National Radioactive Waste Management Facility, is an issue of huge national importance. So is it fair that our small community is being asked to make such a serious decision based on limited and, we believe, misleading information?

ACF notes the findings of the FLAG December 2016 community survey report and the concerns raised over the conduct and serious methodological bias of the initial Orima phone survey in relation to the Flinders Ranges site. Clearly a landline based phone survey, particularly in regional Australia, will lead to skewed results, and ACF draws these matters to the Committee’s attention as specific examples of community concern that deserve further interrogation.

ACF also notes the clear opposition of most Adnyamathanha people to the Flinders Ranges proposal. This was also noted by the Department in the phase one summary report of the siting process which acknowledged “opposition from Indigenous groups including the Adnyamathanha people due to the Indigenous heritage in and around the  nominated land”.

The Adnyamathanha Traditional Lands Association (ATLA) 2017 annual report identified that the federal plan “continues to be an issue and ATLA remains totally opposed to the waste dump at Wallerberdina. ATLA has been treated very poorly in this whole process and it has been a real struggle to ensure our voice is heard.”

This position was made clear again in March 2018 when the ATLA Board reaffirmed its concerns stating:

The Adnyamathanha Traditional Lands Association remains totally opposed to the nuclear waste dump at Wallerberdina This is our land, our culture and we must have veto over this toxic waste being dumped in our country. Udnyus come and go but we will be here forever. We say NO to the waste dump, for our grandchildren and their grandchildren and many generations to come”.

ACF draws the Committee’s attention to the profound and unresolved discrepancy between this situation and Australia’s international obligations.

States shall take effective measures to ensure that no storage or disposal of hazardous materials shall take place in the lands or territories of indigenous peoples without their free, prior and informed consent”

UN Declaration on the Rights of Indigenous Peoples (Article 29)

This conflict alone should be reason enough not to further any consideration of this site. In relation to the proposed Kimba sites ACF notes that Kimba was initially excluded from the shortlist after phase one of the process with the proponent observing strong levels of community opposition and concerns about community cohesion and noting that ‘given the level of strongly held opposition, it remains an open question as to how much additional support could be garnered through further engagement’.

Kimba was later re-added in a non-transparent move that has exacerbated community pressures and discord and signalled to many in the community that for the federal government No does not get heard as No – rather it is perceived as ‘not yet’.

This approach, coupled with the federal siting process continuing on the basis of an AEC conducted vote that had a return (56%) that was well lower than other figures previously floated by portfolio Ministers and Department representatives as indicative of broad community support (65%) has further eroded confidence.

There is a view among many in the community that the consultation dice has been loaded in Kimba so that radioactive waste haul trucks can be loaded in Sydney.

The current federal process increasingly resembles a disconnected vehicle speeding towards a pre-determined destination. History – both here and overseas – strongly suggests that any nuclear project that lacks community confidence and credibility is heading towards failure. This is not a desirable outcome either in relation to the stress and pressure experienced by affected communities or for advancing a responsible and effective national approach to radioactive waste management.

Trust and Transparency:

ACF notes that from the early days of the federal search for a national radioactive waste site there have been deep concerns and criticisms raised over the culture and approach of the relevant federal Department.

It is interesting to note that in his preamble to the 1996 No Time to Waste report of the Senate Inquiry he then chaired Senator Grant Chapman (now the nominator of the Wallerberdina site) was explicitly critical of the uncooperative role of the Department of Industry, Science and Technology, stating:

‘…this approach is not conducive to developing a professional relationship in which to undertake community consultations for the siting of future national facilities. The resentment expressed by the State Government, local councils, the Aboriginal community and the public of South Australia will make it more difficult for other Commonwealth departments to conduct similar exercises in that State in the future’.

This adversarial federal pattern continued through the Billa Kalina and Northern Territory iterations of the site search. The failure of the long push to locate a facility at the Muckaty site offered a very real opportunity to re-visit and re-calibrate the federal approach.

Describing the Muckaty process as a ‘disaster’ on ABC Radio in August 2014 Minister Macfarlane later announced a revised approachAfter decades of top down decision making based on the Decide-Announce-Defend model, the new process at least contained some degree of transparency, a stated commitment to volunteerism and, as recognised in the Committee’s terms of reference, a federal statement that it will not impose such a facility on an unwilling community (note: this commitment remains to be tested as it is not consistent with federal threats to override existing SA legislation that makes the planned facility unlawful)

These modest and welcome improvements have unfortunately not been matched with an elevated level of transparency as the site selection process has been operationalized.

The Department has refused repeated community and stakeholder requests to either initiate or participate in public forums, QnA’s and debates preferring instead to host more managed and curated events where the pro-facility message is not challenged.

Information requests, including through Parliamentary mechanisms like Senate Estimates, are evaded, partially answered or responded to in a cursory fashion after long delays. Repeated attempts by civil society stakeholders to develop agreed statements of fact in relation to such vexed and potentially divisive areas as the degree of connection between the national facility plan and access to nuclear medicine and the properties of the material to be managed in any future national facility have not been acted upon.

A further cause of widespread frustration that has seen the erosion of trust and confidence in the Department’s approach has been its reluctance to clarify clear factual errors and misleading information in relation to the federal radioactive waste plan.

Despite repeat requests from multiple stakeholders for clarification and correction the Department has allowed inaccuracies to become accepted. This inaction is unjustified, unprofessional and unhelpful to measured debate and consideration.

This can particularly be seen in relation to exaggerated economic and employment claims, the extent to which any national facility is linked to continuing access to nuclear medicine and the nature and properties of waste to be managed at any future facility.

There are multiple examples of this in the two regions under federal consideration in SA. This pattern was also evident in the earlier short-listed sites and is apparent again now in pre-nomination regions including Leonora (WA) and Brewarrina (NSW).The Department is speedy in response to critics but sedated when it comes to correcting misinformation that might be seen to add to support to the case for a national facility. In short, there is a deep and deepening trust deficit and for many community and civil society actors the Department lacks credibility and is not regarded as an honest broker.

International best practice: current assertions, future options

Despite never having subjected the remote or regional facility model adopted by successive federal governments for two decades to independent analysis or any option review, the project is repeatedly promoted as being both consistent with international best practice and required to meet international obligations.

Neither of these assertions is correct.

The plan is to dispose of low level waste (LLW) at the national facility. This would be containerized, emplaced and covered with no intention to recover. Low level waste needs to be kept isolated from people and the wider environment for several hundred years. This approach to managing the least challenging material to be handled at any national facility is consistent with current international industry practice.

In relation to the management of long-lived intermediate level waste (ILW) the federal plan is to move this a long distance from above ground interim storage where the vast bulk is produced and currently stored at ANSTO to above ground interim storage at a less secure, monitored and resourced facility in regional South Australia. There is no pathway, process or timeframe to identify a final disposal method or site for the ILW.

The plan has no cogent radiological or public safety rationale and is not consistently with international best practice or required to comply with international obligations.

The fundamental question that needs to be answered: what is the most responsible way to manage Australia’s ILW in the absence of a proven disposal pathway? has never even been asked. Instead there has been the conflation of two distinct waste management options, one (LLW) which is consistent with best practice, and one (ILW) which is not.

Please find the attached briefing paper [on original] Advancing responsible radioactive waste management in Australia.  on the case for extended interim storage of ILW at ANSTO to provide the time and certainty to ensure a proper deliberative and evidence-based decision on future management options.

This approach is prudent, possible and far more logical in relation to radiological protection, informed and integrated decision making, and minimizing cost, unnecessary duplication and double-handling.

ACF and a range of civil society groups see this approach as the clear circuit breaker in the policy and discourse impasse surrounding radioactive waste management and commend this approach to the Committee’s attention. If this issue is seen as outside the Committee’s scope we urge you explicitly reference this option for further independent consideration as it is of fundamental importance to how and whether responsible radioactive waste management in Australia is realized.

It is important not to downplay or trivialize the issues surrounding the management of LLW, but it is clear the most serious and complex challenges are found with ILW. The current federal plan is, at best, a diversion of financial, political and human resources and capacity from meeting this long-term challenge, and it shirks the hard question.

A key federal driver for the national radioactive waste facility was the timeline of spent nuclear fuel waste returning from reprocessing in Europe. There was a clear political imperative to ‘sort’ the national facility siting issue to avoid this waste returning to ANSTO.

The failure of the Muckaty plan meant that this was not realized and that waste returns from France were returned to ANSTO in December 2015. This development is a gamechanger and should be recognized as such and used as a turning point in the national radioactive waste discourse.

A purpose built dedicated storage facility was constructed at ANSTO which now securely houses a TN81 transportation and storage container or flask. A further flask is expected to return from the UK in 2021 and could be housed in the same facility with no further returns until at least 2035.

The TN81 has a conservative design life of forty years which means that it can house the ILW until 2055, subject to favorable outcomes of periodic reviews by the federal nuclear regulator the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA).

Importantly, the ARPANSA operating license for this facility is “not time limited” and the facility is capable of storing ILW “until the availability of a final disposal option”. In early 2018 ARPANSA stated it holds “a high degree of confidence in the safety of this facility”.

Effectively this provides for secure extended interim storage at the site where the majority of the ILW currently is, that is home to the highest monitoring and emergency response capacity and is a secured, tenured and actively managed site that is fully expected to remain the centre of Australian nuclear expertise over this period.

ACF again draws the Committee’s attention to the attached [on original] briefing paper Advancing Responsible Radioactive Waste Management which further details this option.

Interestingly a variation on this approach was identified by a 2004 NSW Parliamentary Inquiry which recommended that Lucas Heights should continue to act as an interim waste facility, subject to a review of operating conditions to ensure world’s best  practice. Unfortunately, this sensible suggestion was not explored by the federal government.

Such an approach would allow the real decision about radioactive waste management in Australia – i.e. what to do with Australia’s ILW in the long term – a far greater chance of being addressed in a measured, transparent and rigorous way. The current federal approach avoids this key question and as a result is not fit for purpose.

Project Uncertainty:

The current federal approach contains much that is opaque or uncertain and that would benefit from interrogation by the Committee, including:

 the rationale for the suspension of federal Aboriginal heritage and environmental protections during the siting process – an expedient approach that is not consistent with best project assessment practice

 the rationale for continuing to advance the Kimba site nominations in an important grain producing region despite the NHMRC 1992 Code of practice for the near-surface disposal of radioactive waste in Australia listing the following criterion (inter alia) for near-surface disposal of radioactive waste: “the site for the facility should be located in a region which has no known significant natural resources, including potentially valuable mineral deposits, and which has little or no potential for agriculture or outdoor recreational use” (our emphasis)

 the basis for advancing the Wallerberdina Station nomination as the land in question is a pastoral lease and there is uncertainty over how and whether it is possible that such land can be ‘volunteered’ for the purpose sought by the federal government. In March 2017 the SA Department of Treasury and Finance found there appears to be untested uncertainty about how the respective legislation, commonwealth or state, applies, when it applies and in what way”. This is hardly the basis for confidence in a foundation strategy for the management of an extremely long lived and problematic industrial waste.

 the conflict between the proposed national facility and the existing South Australian state legislation. South Australia is the only jurisdiction currently being considered as a potential host for a national radioactive waste facility and it has long-standing legislation banning the import, transport, storage and disposal of nuclear wastes, the Nuclear Waste Storage (Prohibition) Act 2000. This seeks

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”.

 There are clear indications that the federal intention is to override the state legislation – including this response to a Question on Notice in March 2017

Question (Senator Ludlam): Is the Department considering overriding the South Australian Nuclear Waste Storage (Prohibition) Act 2000, which prohibits the import, transport, storage and disposal of irradiated nuclear fuel wastes and other wastes intended for the NRWM Facility?

Response (Senator Canavan): The department is yet to consider its position with respect to the South Australian Nuclear Waste Storage (Prohibition) Act 2000. However, the department notes that the National Radioactive Waste Management Act 2012 (NRWM Act) already provides that State and Territory laws have no effect to the extent that they “regulate, hinder or prevent” activities authorised under the NRWM Act.

The federal government has often spoken of the voluntary nature of the current national radioactive waste management project. Any failure to respect existing state legislation would deeply undermine this claim and open the process to challenge. Such an approach would also be inconsistent with international industry practice and standards that clearly highlight the importance of inclusion and the consent of state and local jurisdictions. Any such federal action would  also have significant implications for the regulator ARPANSA which is required to be mindful of and reflect best practice in its licensing decisions. Despite repeated request for clarification the Department has failed to provide clarity on this issueor detail on any contingency planning in this eventuality.

 Uncertainty over the what the lack of a pathway, process and timeline for a decision on long-term ILW management means for communities affected by the current federal plan. There is a disconnect between assertions made by the department that this waste will be moved in a matter of decades (which begs the question to where) and repeated references by ARPANSA that any national facility will have provision for ILW above ground storage for approximately 100 years. The lack of clarity on what a community is signing up for, or being rolled over by, is deeply disrespectful and not acceptable.

 Confidence and trust is enhanced with continuity and the constant turnover of both portfolio Ministers and project personnel has not been favorable to this. ACF is aware of many times when community members in the regions under active federal consideration to host a national radioactive waste facility have raised this concern. There is a damaging hemorrhaging of both institutional memory and community confidence because of this rapid transition, including at the most senior political levels.

Concluding remarks:

The clear majority of Australia’s radioactive waste is currently stored at two secured federal facilities with the bulk of ILW at ANSTO and much of the LLW at Woomera (SA). ANSTO has the capacity to continue storage of this material for many years and this allows an opportunity to re-calibrate the national approach to this issue with the extended interim storage of Australia’s highest-level wastes at ANSTO and a genuine assessment of longer term management options. The current federal proposal is one of considerable pain for scant gain and merely kicks the can further down the road.

A measured, transparent and evidence-based approach to radioactive waste management provides our best chance to achieve a credible and lasting result for us and all future Australians.

References and resources accessed in preparing this submission included:

No Time to Waste – Report of the Senate Select Committee on the Dangers of Radioactive Waste, April 1996

National Radioactive Waste Management Bill 2010 (Provisions), Senate Legal and Constitutional Affairs Legislation Committee report, 2010

Inquiry into the Transportation and Storage of Nuclear Waste, NSW Parliament Joint Select Committee on the Transportation and Storage of Nuclear Waste, 2004

Socio-economic and other non-radiological impacts of the near surface disposal of radioactive waste – IAEA technical document, September 2002

Low and intermediate level waste repositories: Socio-economic aspects and public involvement – IAEA technical document, June 2007

Radioactive waste and spent fuel management in the European Union – European Commission report, 2011

July 13, 2018 - Posted by | Uncategorized

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