Antinuclear

Australian news, and some related international items

Submissions on Radioactive Waste Code 2018

5 March – 2 more submissions published – by Colin Mitchell and Cameron Scott

There have been 24 submissions published by ARPANSA , by March 2 2018

Only one submission, (by Denise Carpenter) is happy with the draft Code. It is possible that there are other submissions, praising the Code, that have not been published.

(This latest one not yet published: by David Noonan – Submission on Required Protection of Cultural Heritage from impact by Disposal Facility Site selection AND on the Principle of Non-Imposition of Disposal Facilities .)

Already posted on this website :  Amy Cosh, Brett Stokes, Anonymous (3) Justine Major , Denise Carpenter (the only pro nuclear post) .   Also: James and Cindy Sheperdson, Janet Tiller, Tiffany Congdon, Graham Tiller (3).  Also: Noel Wauchope.

More recent submissions:

Joan Boylan  Why do South Australians have to carry this burden? We pride ourselves with a clean green reputation and will fight this divisive process and dangerous illegal poison coming across oceans, through our ports or across our sacred country.
South Australians have already made it clear that we do not want nuclear waste here. We spent $!0 million of our taxes to run a citizens jury and the vote was overwhelmingly NO.
Leave the waste at Lucas Heights where it is secure.

Michele Madigan  Submission to ARPANSA  re Code for Disposal of Solid Radioactive WasteThanks to ARPANSA for inviting submissions on this vital issue – vital for Australia and particularly, currently, for South Australia.

ARPANSA has an important role to play during the whole current process of the Federal Government’s ongoing plans for the Disposal of Solid Radioactive Waste. Unfortunately the Department has not engaged in any of the proposed sites – in Flinders Ranges or Kimba in a genuine way. The Department has acted only as an eager proponent – and one with funds to seek to entice those who are anxious for short-term profits.

I have witnessed myself, public servants constantly defending the Departmental position with unscientific arguments for the safety of the facility (#329); with claims of unrealistic short timeframes for radiation danger – with no admission as does ARPANSA that the duration is for 10,000 years (# 1553); with assurances of the greater percentage of local community support than actually exists.

2.1 The Department/Federal Government proponents continually stress that the present planned facility is essential for the survival of nuclear medicine within Australia. However in reality the planned national facility will not remove waste from hospitals or medical clinics. Nor is it advancing the long-term disposal of intermediate waste (only the re-located interim storage.)

(cf #413) The Lucas Heights long -lived intermediate level waste will be stored above ground – in direct opposition to world’s best practice of the requirement for underground storage.

# 401 is particularly endorsed, recognising as it does the ‘essential ‘ nature of local Aboriginal engagement in the siting process. Aboriginal citizens in SA have been opposition leaders to both Federal campaign in SA. The Kupa Piti Kungka Tjuta for the Billa Kalina /later Woomera area 1998-2004 and many of the members of the Adnymathanha  (present proposed Flinders Ranges site.)

3 SUBMISSION TO ARPANSA

Obviously, Aboriginal peoples’ intimate knowledge of country, groundwaters and heritage is a resource for the genuine consultation which ARPANSA as the regulating body desires. It is of grave concern that this proposed Flinders radioactive dumpsite is next to the Adnyamathanha Indigenous Protected Area (IPA). Many Traditional Owners have made enormous efforts to stand up for country and heritage at great cost to their general wellbeing, emotional and physical health. As well as revealing Aboriginal heritage matters, their previous and ongoing commissioned research reveals frequent seismic and flooding activity.

# 246 The process of nomination by individuals (and acceptance by the Department) in both Flinders Ranges and Kimba sites has led to very serious community and family disruption and genuine angst in the general communities of Kimba and districts, Hawker, Quorn and districts.

373-379 – In contrast to the Federal plan, the ARPANSA document recognised the vital importance of genuine, clear community consent/ social license. In extension, what affects these two local areas cannot be considered as isolated from the entire state of SA – eg regarding safety and reputation in the international markets of tourism and grain trade. As well, the travel route from Sydney has not been revealed.

Leon Ashton   I am writing this submission in regard to the ARPANSA upgrade and changes to the Code for disposal of solid radioactive waste.  This is not a submission to the Federal Government senate inquiry.

  The old Code RHS-35 is only applicable to near surface disposal of LLW in an arid environment, whilst the new Code SSR-5 is applicable to all solid radioactive waste in all locations thoughout Australia.

My concerns are:

1 Will there be any procedures put in the upgraded Code to positively ensure a LLW site already chosen/built will not have a permanent ILW facility built under it at some time in the future?

2 We know there will be a significant increase in ILW from Lucas Heights, which has already started.  We also know there is ILW returned from France plus unknown quantities currently stored at Woomera.  How does this affect the licensing for a LLW site, if it is found that more ILW will be “temporarily” stored at the LLW facility, for much longer than the LLW licence covers it for?  Are we not basically repeating the same issues that have arisen from the old Code? For example a permanent ILW site must be chosen before the ILW can be moved from its present place where the licence allows it to be temporarily stored.

3 The fact that ARPANSA are upgrading the Code of Practice for disposal of solid radioactive waste to tie in with international nuclear standards and best practice, where does the new Code now sit with France returning what they classify as HLW to us?

4 Community Engagement.  It is my personal opinion that a lot more emphasis needs to be places on the honest and factual information given to both local and broader communities up front.  I do strongly believe that if a community votes for or against a proposal, that the voting numbers must be significantly higher (say 75-80%) than the present 65%, for a facility to move forward. 65% of our community does not allow in any way, a clear concise (the community wants this) vote.  This is such an important issue that I believe it requires a lot more consideration in this area.

Anonymous:   Particle accelerators are providing a cleaner (no highly radioactive, long lived waste) alternative to nuclear reactors for producing medical isotopes. – Just as we strive to minimise people’s UV and Asbestos exposure, ARPANSA’s goal should be to minimise people’s exposure to radiation and radioactive particles. The best way of doing that is by minimising the production of long-lived radioactive waste. Where is most long-lived radioactivity produced in Australia? ANSTO. Workers have to handle radioactive waste, there is the risk of extra Gamma radiation exposure and the risk of inhaling or ingesting radioactive particles. Often a dental X-ray is equated with inhaling or ingesting radioactive particles. This is extremely misleading and dishonest. Inhaled or ingested particles could remain in a person for many years, creating a much higher long-term risk, especially to the young. There is also the risk of radioactive waste contamination if an accident occurred during transportation. New techniques have been developed to create medical isotopes that do not involve creating nuclear reactor waste. For example, Canada’s research work using Cyclotrons to produce Technetium 99, North America‘s move to linear accelerators. The Netherlands is doing promising work with electron accelerators. ANSTO has the high security and space for storing the nuclear waste it has created. Creating a new repository will only encourage them to produce more waste at taxpayer’s expense. If a new repository had to be created, it needs to be away from rail and port facilities, otherwise nuclear proponents will be lobbying hard to evolve the repository into an international nuclear waste repository. The bottom of Radium Hill mine would have plenty of space for ANSTO’s nuclear waste, as long ANSTO was actively transitioning to cleaner particle accelerators for doing its work.  Source https://www.arpansa.gov.au/code-disposal-solid-radioactive-waste-rps-c-3Marty & Rachel Yates   ARPANSA needs to make the mental health and wellbeing of community a priority in the code and not just consider the potential exposure to radiation as a health risk.
The code defines ‘community’ and discusses ‘consultation’ but there is no mention of ‘broad community support’ anywhere. A set figure to clearly define how much support is needed should also be included.
NO type of radioactive waste should be stored on agricultural land.Margie & Butch Eckermann  We are totally opposed to a radioactive waste facility being built near Kimba, or at Wallerberdina in the Flinders Ranges. Radioactive waste is not “guaranteed” safe. The process for storing radioactive waste in our communities continues to cause stress and division. Please consider the mental health of our community members opposing this project. We were told this facility would not be forced on an unwilling community, and we say NO. Broad community support needs to be clearly defined.

Mnemosyne Giles

I Object. ARPANSA is untrustworthy changing type of dump after 2 years of cruel & immoral (using bribery) consultation. Of course they know what they are doing. Changing the dump to include ALL types of disposal opens the way for deep disposal and an international dump as has always been on the agenda (as recommended eg. by Richard Yeeles) There is no permanent solution to IL & HL Waste (active over 10,000 years). Nuke Ind denies health effects. Moratorium on mining & production not a dump!!!!!! page 3 source https://www.arpansa.gov.au/code-disposal-solid-radioactive-waste-rps-c-3
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