ANSTO’s dodgy classification of nuclear wastes.
When the re-processed material is returned to Australia invariably the processing country refers to that material as high-level waste but ANSTO reclassifies it as intermediate level on the very weak argument of the classifications in Europe being different to Australia…… it seems ludicrous that it should assume its own manner of classification and against the treaty adopted classifications of IAEA and adhered to by other countries.
a known area of seismic volatility with several notable earthquakes recorded in the past fifty years…. the area is prone to flooding with expectations of increased magnitude of floods.
Peter Remta – submission to Senate Committee on National Radioactive Waste Management Amendment (Site Specification, Community Fund and Other Measures) Bill 2020 [Provisions] Submission 65
Excerpt
“………MANAGEMENT OF FACILITY
The intended management by the government of the disposal and storage of the different classes of nuclear wastes at the Kimba facility is technically flawed and inappropriate based most recent scientific research and nuclear cycle experiences throughout the world.
The proposal by the government is to dispose of the low-level waste in containers above ground while the intermediate level waste would be temporarily stored for an unspecified period again in containers held above the ground.
Based on the prescriptions and requirements of the International Atomic Energy Agency (IAEA) age of the different classes of nuclear waste at the Kimba facility is technically flawed and inappropriate based on ths outlined in its Safety Code11 :
(a) the low level waste should be disposed of by shallow burial; and
(b) the intermediate level waste should even when stored on a temporary basis be geologically buried at appropriate depths.
(b) the intermediate level waste should even when stored on a temporary basis be geologically buried at appropriate depths.
This is essential in the case of the intermediate level waste due to its highly dangerous and harmful status and the serious health consequences of human exposure.
In addition recent experience overseas has shown that many of the containers used for the above ground disposal and storage of nuclear waste are prone to corrosion and other integrity problems which can only be readily overcome by geological burial until better and longer lasting containers can be developed.
As a result most international experts are now advocating and even demanding underground burial of nuclear waste of all levels for disposal or even temporary storage and are quite surprised at the course being followed by Australia having regard to its prowess in the resources industry.
INTERNATIONAL OBLIGATIONS
The prescriptive codes of IAEA have been fully adopted by ARPANSA12 as its standards for the classification and treatment and management of nuclear waste in Australia.
The prescriptive codes of IAEA have been fully adopted by ARPANSA12 as its standards for the classification and treatment and management of nuclear waste in Australia.
However and with seemingly little local criticism the government and its plans for the now chosen Kimba facility have ignored these prescriptions and requirements which may well lead to ARPANSA not licensing the various stages of the construction and operations of the facility at Kimba.
The government has been unable to assure the members of the Kimba community that ARPANSA will in all probability licence the various stages of the establishment and operations of the government’s facility.
Even more importantly the execution of the proposals of the government in establishing the facility and its subsequent operations are in breach of its international treaty obligations which would among other things give any aggrieved community group the right to complain to the United Nations.
CONVENTION OBLIGATIONS
It is interesting that a new subsection 3(2) of the Bill gives effect to Australia’s obligations as a party to the Joint Convention for the safe and secure management of what is defined as decontrolled material and in particular Australia’s obligations under Chapters 3 and 4 of the Joint Convention.
It is interesting that a new subsection 3(2) of the Bill gives effect to Australia’s obligations as a party to the Joint Convention for the safe and secure management of what is defined as decontrolled material and in particular Australia’s obligations under Chapters 3 and 4 of the Joint Convention.
Despite this legislative provision the subsequent passing of the Bill cannot excuse or justify any preceding breaches by the government of its obligations in that regard.
However it suggests that the government has doubts about the validity and integrity of its proposals under international law relating to its convention obligations.
In any event the Joint Convention was in 1997 while the prescriptive safety codes of IAEA and ARPANSA referred to in notations 10 and12 requiring underground burial of nuclear waste were issued in 2009 and 2010 respectively and I suggest intentionally excluded from the explanatory memorandum and the Bill.
NATURE OF WASTE
The government has always stated that the facility at Kimba would only be used for the permanent disposal of low-level waste and indefinite storage of intermediate level waste with that storage period being up to 100 years.
The government has always stated that the facility at Kimba would only be used for the permanent disposal of low-level waste and indefinite storage of intermediate level waste with that storage period being up to 100 years.
As already stated in both instances the waste would be held above the ground which is against the prescriptions and requirements of the international regulatory bodies including in particular the International Atomic Energy Agency (IAEA).
The waste generated at Lucas Heights by its reactor is of high level when it is sent overseas for re-processing but the government does not give it a classification or even describes it as waste before its departure.
When the re-processed material is returned to Australia invariably the processing country refers to that material as high-level waste but ANSTO reclassifies it as intermediate level on the very weak argument of the classifications in Europe being different to Australia.
Considering that Australia does not have a nuclear industry nor a highly regarded regime of controlling a relatively small amount of nuclear waste it seems ludicrous that it should assume its own manner of classification and against the treaty adopted classifications of IAEA and adhered to by other countries.
Nuclear waste generated at Lucas Heights and then sent by Australia to Scotland for re-processing will now under a substitution agreement between Scotland and England (to which Australia is not a direct party) be returned to Australia as high level waste which was generated in England and reprocessed at Sellafield which until recently was one of the largest multi-function nuclear industry cycle hubs in the world.
This has never been properly explained by the government to the Kimba community or in fact to the public in general even though its actions and conduct have been questioned by overseas experts within the nuclear industry.
Moreover and despite the substitution arrangements the so-called reprocessed waste being returned to Australia by England is completely contrary to the requirement of the facility at Kimba to deal only with locally generated waste.
In addition the government refuses to disclose the levels of radionuclides in the waste to be sent to Kimba which is a most important factor in the management and disposal of nuclear waste.
CENTRAL FACILITY
The government has described the facility at Kimba as being a central one for Australia with the implication that it would dispose of or store as required all the present legend or stockpiled waste in Australia and all waste generated locally in the future.
The government has described the facility at Kimba as being a central one for Australia with the implication that it would dispose of or store as required all the present legend or stockpiled waste in Australia and all waste generated locally in the future.
However the government has failed to explain how it or any future operator of the facility will gain or acquire the waste currently held in numerous locations (stated tobe over 100) throughout Australia since except for the waste from Lucas Heightswhich is run by ANSTO and some other federal government installations it has has no rights or control over the other waste.
At the very least it would require some constitutional changes by whatever means possible to gain legislative power over that waste which would undoubtably be a difficult exercise and to a large extent would completely defeat the notion of a central national facility.
TECHNICAL ASSESSMENT
After accepting Napandee as a nominated site the government engaged AECOM to carry out what is described as a characterisation study of the site at Napandee which concluded with a technical report dated 23 July 2018.
After accepting Napandee as a nominated site the government engaged AECOM to carry out what is described as a characterisation study of the site at Napandee which concluded with a technical report dated 23 July 2018.
This study was preceded in February 2018 by a preliminary outline by AECOM of what work would be carried out at Kimba on both of the nominated sites under the characterisation study.
The Department itself had claimed what is designated as a phase 1 assessment under the nomination guidelines giving effect to the existing legislation and issued a summary report which while undated was probably made public in July or August of 2017.
That summary added little to the technical nature of both Kimba sites and dealt principally with community consultations and the results of a recent ballotWhile all three reports were colourful presentations with elaborate artwork and photographs in reality by technical standards they contained little proper information to support and satisfy the selection of Napandee as the site for the waste management facility.
The reason is that most of the concluding opinions in the reports by AECOM were inconclusive and suggested additional work to meet the required or desired status to be acceptable for the facility at Napandee.
The Department has recently issued what it calls a fact sheet on Napandee which is dated February 2020 and which again is a high standard presentation in its artwork and photography.
However the conclusion in the fact sheet under the heading of Site Characterisation
After completion of the technical assessments at Napandee, the Department ofIndustry, Science, Energy and Resources has been advised that with further assessment, any supporting infrastructure constraints and risks posed by
environmental hazards such as seismic and flooding events, can be mitigated via design solutions.
environmental hazards such as seismic and flooding events, can be mitigated via design solutions.
This conclusion again shows that the Napandee selection was both premature as to its choice by the government due to the lack of a full assessment and investigation of the site and completely unsuitable for the facility.
Again drawing on the experience of the mining industry the technical assessment of Napandee would be regarded as an uncommercial exercise well short of a scoping and feasibility study to determine its suitability for the waste facility.
It also gives proof to the adage that governments should not be involved in businesses as they invariably end up as commercial disasters.:
However irrespective of the government’s technical assessments and proposed engineering designing the Napandee site will remain highly unsuitable for the waste facility due to its sandy sedimentary setting from surface to a vertical depth of approximately 30 metres in a known area of seismic volatility with several notable earthquakes recorded in the past fifty years.
The area has a relatively shallow water table (being only some 10 metres down) which will undoubtedly lead to various problems of hydrology including contamination of underground water flows from the escape of any nuclear waste material to be brought to Napandee.
While no hydrology studies have been done AECOM recommended modelling to estimate the risks of floods as the area is prone to flooding with expectations of increased magnitude of floods.
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1.This month.
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