Supplementary Remarks

Supplementary Remarks

Senator Stott Despoja

Australian Democrats

The Australian Democrats support the Majority Report, but wish to add the following Supplementary Remarks.

The Australian Democrats do not support the construction of a new nuclear reactor. In particular, we are not satisfied by the justifications which have been provided by ANSTO and the Government for the construction of a new reactor. It is our view that a new reactor can only be justified if the national interest argument is upheld. We are not satisfied by the national interest arguments before the Committee. The Australian Democrats oppose any further Australian involvement in the nuclear fuel cycle.

1. Executive Summary and Recommendations

1.1 The Australian Democrats oppose the construction of a new nuclear reactor in Australia. It is clear that a new nuclear reactor cannot be justified on economic, scientific, national interest grounds.

1.2 In the event that further and appropriate justifications are provided by the Government, it must be noted that insurmountable problems remain in relation to waste disposal.

1.3 Radioisotope production for medical purposes constitutes only a small component of reactor operation. The radioisotope production function of ANSTO must not be used as a public relations tool in an attempt to justify the construction of a new reactor. (2.4, 2.5)

1.4 Where radioisotopes are required, they can be purchased in commercial transactions from international suppliers. Arguments against the importation of radioisotopes based on reliability, ethics and price have not been substantiated. (2.7, 2.8)

1.5 The Australian Democrats agree that it remains 'inconceivable that the environmental benefits of a new reactor would outweigh the environmental costs (emissions, waste etc)'. (2.10)

1.6 There are significant opportunity costs in spending on a new reactor at a time when the possibilities of alternative nuclear technologies have not been fully explored. (2.12)

1.7 There are significant opportunity costs in committing to major expenditure on a new nuclear reactor while many other parts of the Australian scientific are languishing for want of resources. (2.12)

1.8 The Australian Democrats believe that the funds proposed to be spent on the new nuclear reactor ($286 million in 1997 dollars plus recurrent funding and waste disposal costs) should be diverted to other research priorities (including, but not limited to, alternative nuclear science projects). (2.15).

1.9 The continued reliance on the national interest argument as the primary justification for a new reactor is both misguided and inappropriate. (2.16)

1.10 Australia continues to play a significant role in the promotion of nuclear technologies through the export of uranium and through our cooperation with the United States timetable on non-proliferation. (2.18)

1.11 The Australian Democrats believe closing the existing HIFAR reactor (and not constructing a new reactor) would be the greatest contribution Australia could make to both the Australian national interest and the broader interests of non-proliferation. (2.20)

1.12 An argument was advanced that Australia's export trade in uranium might benefit from the technical expertise and credibility flowing from a new nuclear reactor. This is neither appropriate nor desirable. The Australian Democrats oppose the export of uranium outright. It should be noted that this argument runs directly counter to the professed national interest in non-proliferation. (2.19, 2.23)

1.13 Neither the existing HIFAR reactor nor the proposed new reactor can be justified in economic terms. Studies investigating economic impact have failed to include the full costs of operation and have incorporated and perpetuated unreasonable assumptions about non-economic benefits which might be gained from the reactor. (2.21, 2.22)

1.14 Alternative technologies have apparently only been examined in a cursory manner. While neither spallation sources nor cyclotrons can provide a complete replacement for a nuclear reactor, there are significant waste and environmental benefits in the use of non-reactor alternatives in the field of nuclear science. (3.1)

1.15 The Australian Democrats oppose the maintenance in service of the HIFAR reactor. This would result in the continued production of nuclear waste, and a continuation of Australia's broader involvement in the nuclear fuel cycle. (3.11)

1.16 The Government has proceeded with the proposal to build a new nuclear reactor contrary to the recommendations of the 1993 Research Reactor Review. In particular, the Government has proceeded despite a failure to resolve the long-term high-level waste disposal problem. (4.1)

1.17 The Proposed National Radioactive Waste Dump does not appear to be a viable solution to the radioactive waste problem in Australia (given broad community opposition). However the Australian Democrats remain concerned about the use of the existing Lucas Heights facilities as Australia's defacto high-level radioactive waste storage facility. (4.13, 4.14)

2. Do we need a (new) reactor?

2.1 The Australian Academy of Science has noted three areas in which the reactor is currently used. These are:

2.2 It has been maintained by Department of Foreign Affairs and Trade, [2] ANSTO and the Department of Industry, Science and Resources that the reactor contributes to local knowledge and research which supports Australia's interest and involvement in nuclear non-proliferation negotiations. This claim is examined further below.

2.3 The Australian Democrats do not endorse the creation of a problem for future generations of Australians. The problems of nuclear waste and site contamination will not magically disappear. They must be contained and we must act to prevent the further expansion of Australia's involvement in the nuclear fuel cycle. The construction of a new nuclear reactor is an unacceptable contribution to the ongoing nuclear problems which the world is facing.

Radioisotope production and nuclear medicine

2.4 One of the strongest themes in the evidence presented before the Committee was the need to provide access to reactor facilities for the creation of radioisotopes for use in nuclear medicine. One of the most vigorous advocates of this view was ANSTO.

2.5 More than one witness questioned whether this justification was being used as the 'acceptable face of nuclear science'. Other witnesses suggested that the importance of nuclear medicine was naturally diminishing as alternatives, such as ultrasound, were further developed.

2.6 Witnesses also questioned the value of money spent on nuclear medicine in utilitarian terms. Dr Jim Green suggested that equivalent sums spent in other medical areas would bring about significantly greater benefits. [3] Dr Green made specific reference to ultrasound, but his arguments apply equally to a range of other diagnostic and treatment technologies. Another witness pointed directly to alternative nuclear and non-nuclear facilities and suggested that money spent on a reactor might have a bigger impact if spent in other ways. [4]

2.7 Evidence was provided that, during annual scheduled shutdowns of the existing HIFAR reactor, radioisotopes are already imported from Belgian, Canadian or South African suppliers. [5] It was suggested by ANSTO witnesses that there were problems with the supply chain for these radioisotopes, but it is clear that availability is adequate for current needs. It is also evident that the supply chain has been dramatically improved since the examination of this issue in the 1993 Research Reactor Review. It is understood that both the United States and the United Kingdom import their Molybdenum from a reactor in Canada which produces 'most of the Molybdenum in the world'. [6]

2.8 There are three types of argument which are often advanced in relation to the use of imported radioisotopes. These include arguments about reliability, ethics and price.

Reliability

2.8.1 Concerns have been raised about the reliability of non-ANSTO supplies of radioisotopes. These arguments are often advanced without reference to the annual shutdown of the existing HIFAR reactor. Presently, the HIFAR reactor is shut down for around 3 months each year. During this time, radioisotopes are imported from foreign suppliers. At least one witness indicated that the international distribution system for radioisotopes is now 'established and efficient'. [7] According to another witness (Dr Jim Green, Submission No.1, p15), the risks of transportation delays have been significantly overstated. Evidence provided by Dr Jim Green shows that delays affect less than 0.5% of shipments from the South African Atomic Energy Corporation.

Ethics

2.8.2 The primary `ethical' concern with the importation of radioisotopes is known colloquially as the NIMBY issue. This concern suggests that we should not import isotopes if we are not prepared to produce them ourselves, or at least share in the negative aspects of isotope production. [8] This argument clearly points to a number of significant and valid concerns with the construction of a new reactor. While this `ethical' point has been argued by a range of witnesses, it is our view that relying on the commercial output of other countries is appropriate at this stage.

Price

2.8.3 Although little evidence was provided to the Committee on the pricing of imported radioisotopes, it is apparent from the limited evidence that the economic situation favours the imported materials. As mentioned above, the Commonwealth provides very significant subsidies by hiding the bulk of the capital and recurrent costs of the existing and proposed facilities behind the veil of the `national interest' argument.

Industrial and Environmental Applications

2.9 Reactor outputs, processed materials and neutron based technologies are also used in a range of other industrial and environmental applications. Indeed, ANSTO has made claims about an estimated $90 million annual gross economic benefit which flows to the minerals industry. [9] Unfortunately, all economic arguments involving the reactor begin with an unrealistic set of assumptions about the unquantifiable national interest or strategic value of the reactor.

2.10 In the environmental arena, the Australian Democrats agree that it remains 'inconceivable that the environmental benefits of a new reactor would outweigh the environmental costs (emissions, waste etc)'. [10]

Nuclear Physics Research

2.11 Another of the justifications provided by the Government (and ANSTO) for a new nuclear reactor is the importance of the reactor to research and higher education in Australia. While we acknowledge the benefits that might be gained from the availability of reactor research facilities in Australia, we remain concerned about the opportunity costs involved in the construction of a new nuclear reactor at this time.

2.12 A number of submissions referred to the opportunity costs arising from a failure to upgrade Australia's nuclear reactor based research facilities. This raises two important and countervailing arguments:

2.13 Researchers have suggested that our existing research adds to our 'standing and credibility as a voice in international radiation technology and safety, and non-proliferation forums'. [11] This point is discussed further below.

2.14 A number of witnesses discussed the possibility of a shift of fundamental nuclear research away from nuclear reactor based research to other neutron sources. Other witnesses referred to the possibility, likelihood and desirability of `suitcase science'. While it is apparent that these alternatives can not completely substitute for the local availability of a nuclear reactor, they are a safe and cost-effective option.

2.15 The Australian Democrats believe that the funds proposed to be spent on the new nuclear reactor ($300 million plus recurrent funding and waste disposal costs) should be diverted to other research priorities (including, but not limited to, alternative nuclear science projects).

National Interest and National Security

2.16 The national interest justification appears to be one of the primary motivations behind the push for a new nuclear reactor for Australia. The national interest argument is heavily influenced by the Government's desire to maintain Australia's designated regional seat on the Board of Governors of the International Atomic Energy Agency (IAEA). It must be remembered that that seat was gained in the 1950s, at a time when Australia was providing raw materials for the nuclear weapons programmes of both the United States of America and the United Kingdom.

2.17 Australia's involvement in the IAEA points to a fundamental conflict in the role of that organisation. While the Government (and DFAT) have repeatedly pointed to the importance of the IAEA's role in `safeguarding' against nuclear proliferation , it is clear that the IAEA is simultaneously a promoter of nuclear technologies through dual-use projects such as reactors. This IAEA conflict of interest deserves further public examination, especially in a context where arguments are being advanced which are intended to justify the construction of costly reactor facilities on the strength of our current tainted position on the IAEA.

2.18 Australia continues to promote nuclear technologies through the export of uranium and through our cooperation with the United States on non-proliferation treaties and timetables. Clearly, the question that must be asked in relation to the national interest justification is: 'Is the new reactor and the work it supports part of the solution, or part of the problem?' [12]

2.19 DFAT has rejected alternative technologies on the basis that they would not provide Australia with expertise in managing the nuclear fuel cycle. This is a self-serving argument which clearly provides no escape from Australia's involvement in the nuclear fuel cycle.

2.20 The Australian Democrats believe that closing the existing HIFAR reactor and not constructing a new reactor) would be the greatest contribution Australia could make to both the Australian national interest and the broader interests of non-proliferation.

Economic impact and jobs

2.21 The 1993 Research Reactor Review addressed the issue of a cost-benefit analysis and determined that: 'If HIFAR, or any replacement reactor, were required to balance income and expenditure solely through commercial activities, it would not be viable.' [13] The 1993 Research Reactor Review found further that the balance could be made if science and national interest arguments were assigned high economic values. [14]

2.22 A subsequent report commissioned by ANSTO found substantial gross economic benefits from an indigenous neutron source (Access Economics, Assessing the Benefits of an Indigenous Neutron Source, Canberra, February 1997). This study was based on the operation of the HIFAR reactor, and projected the benefits, without apparent reference to the capital and recurrent costs of a possible new reactor. In addition, it is not clear that this study appropriately investigated the substantial environmental and management costs associated with waste disposal.

2.23 An argument was advanced by some witnesses [15] that Australia's export trade in uranium might benefit from the technical expertise and credibility flowing from a new nuclear reactor. The Australian Democrats oppose the export of uranium outright and are not satisfied by this argument. It should be noted that this argument runs directly counter to the professed national interest in non-proliferation.

3. Alternative technologies

3.1 The availability and viability of alternative technologies for neutron generation is one of the central issues to which the Committee was directed in its terms of reference. As the inquiry has progressed over a lengthy period, it has become clear that Government has little interest in pursuing these non-reactor technologies.

Spallation sources

3.2 Spallation sources are the only technology other than nuclear reactors capable of producing neutrons. In summary, spallation sources produce neutrons by directing a beam of high energy protons at a heavy metal target. This induces a reaction which releases an intense neutron flux.

3.3 It is broadly argued [16] that spallation sources are complementary to, rather than a replacement for, a nuclear research reactor. Spallation sources are not currently in use for either bulk radioisotope production or for commercial irradiation.

3.4 There are significant costs involved in the construction and operation of a spallation source. While there are significant waste and environmental benefits when comparing spallation sources with a nuclear reactor, the costs are comparable to a research reactor, and a spallation source is not currently able to meet the radioisotope production requirements.

Cyclotrons

3.5 Cyclotrons operate by using a strong electrical field to accelerate sub-atomic particles to high-speed while they are constrained to a circular path. On release they are directed on to the material being irradiated. Irradiation of particular targets results in the formation of isotopes which are then separated using chemical techniques before use.

3.6 Two cyclotrons (one at the National Medical Cyclotron at Royal Prince Alfred Hospital in Sydney and another at the Centre for Positron Emission Tomography at the Austin and Repatriation Medical Centre in Melbourne) are already operated by ANSTO for the production of radioisotopes, primarily for medical use.

3.7 As cyclotrons are not a source of neutrons, they can not be used as a replacement for a neutron source such as a reactor. It is understood that there are currently no viable cyclotron based techniques for the production of Technetium-99m, which is regarded as a key component of nuclear medicine. Research in this field continues, with witnesses referring to the work of Dr Lagunas-Solar of the University of California. [17]

3.8 There are significant advantages to the use of cyclotrons. In operation they produce very little radioactive waste, and capital, operating and decommissioning costs are significantly lower than for nuclear reactors.

Maintenance of HIFAR

3.9 Another option, previously canvassed in the 1993 Research Reactor Review, would be the maintenance of the existing HIFAR reactor. This is a very limited option, with significant upgrading required around 2003 if operation were to continue.

3.10 This is an expensive option, but may provide an important breathing space in which to further consider the role of alternative technologies. Evidence before the Committee about the work of researchers including Dr Lagunas-Solar and the Belgian Myrrha/ADONIS program suggests that there will shortly be viable techniques based on alternative (ie non-reactor) technologies .

3.11 The Australian Democrats oppose the maintenance in service of the HIFAR reactor. This would result in the continued production of nuclear waste, and Australia's broader involvement in the nuclear fuel cycle.

Viability of alternatives

3.12 We have discussed the possible use of cyclotron and spallation source based technologies as an alternative to the construction of a new reactor. Broadly, the funding of alternatives would accomplish two important outcomes:

Australia would no longer be dependent on reactor based technologies and the requirement for nuclear waste storage and treatment.

Australia could be established as a leading scientific community in the development and application of alternative neutron and isotope production technologies.

3.13 At this stage, it is apparent that cyclotrons, spallation sources, or a combination of the two, would not be able to produce the full range of radioisotopes currently in medical use in Australia. However, it is also clear from evidence provided to the Committee that medical isotope production constitutes only a small component of the existing reactor output, and medical use alone should not constrain the available alternative options.

3.14 The Australian Democrats remain concerned that ANSTO and the Government have failed to seriously examine the suitability of spallation source, cyclotron and other technologies as replacements for the bulk of the existing reactor research and production.

4. What about the waste?

4.1 The 1993 Research Reactor Review made a number of important recommendations. One particular recommendation concluded that:

A crucial issue is final disposal of high-level wastes, which depends upon identification of a site with radioactive waste disposal. That recommendation said that a solution to the high-level waste disposal problem was essential and necessary well prior to any future decision about a new reactor. (Research Reactor Review, Recommendation 17.2)

4.2 There is not yet a solution for the high-level waste disposal problem. It has become clear that the Government believes a solution has been found in the proposal for a national radioactive waste dump in either South Australia or Western Australia. In general, the Government continues to regard the issue of waste disposal as an afterthought.

4.3 The following remarks are not intended as a full exposition of the waste storage, reprocessing and disposal issues, but are instead a short exposition of the issues which affect the future waste capacity, and necessarily the possible future operation of a new nuclear reactor.

Storage

4.4 A large quantity of nuclear waste remains in storage at Lucas Heights. As at mid-1997 this included a range of materials, including 1630 spent fuel elements. There were also 6500 litres of intermediate liquid waste, 200 cubic metres of intermediate solid waste and 5000 200 litre drums of low level solid waste. [18]

4.5 Evidence before the Committee indicates that there are a number of problems with the storage of this waste. [19] Late in 1998, an accident during the transfer of a spent fuel rod resulted in the rod dropping from the base of a storage flask. It is significant to note that the rod was being relocated due to water entering the storage flask. This rod was in supposedly dry storage. The Committee was reminded that 'Lucas Heights is a high level radioactive waste dump'. [20] The Australian Democrats realise that this is both inappropriate and unsustainable.

4.6 The concerns of local residents have been heightened by the secretive way in which ANSTO and ARPANSA have managed various recent safety incidents. The fuel rod incident mentioned above only became public knowledge after details were leaked to the local media by an ANSTO staff member. The Sutherland Shire Council was not informed of the incident until five weeks after it had occurred. This is not appropriate.

Waste reprocessing

4.7 Overseas reprocessing contracts will not actually solve Australia's nuclear waste/spent nuclear fuel problem. Even if overseas reprocessing does take place, massive amounts of radioactivity will be contained in the waste from the overseas reprocessing of Australian spent nuclear fuel. This waste will contain the same amount of radioactivity as that contained in the spent nuclear fuel sent for reprocessing. These wastes will present a major problem in terms of handling, storage and protection. Currently, there is no total budget, and no firm plans, for the construction of a store to take the long-lived intermediate levels wastes from overseas reprocessing. There is no plan and no budget for the establishment of the deep geological repository `necessary' for disposal of these wastes.

4.8 The Australian Nuclear Science and Technology Organisation (ANSTO) was allowed to negotiate the contract for the reprocessing contract without any independent Parliamentary oversight. The contract may contain `cost-plus' clauses through which the overseas reprocessor can automatically increase costs for additional environmental, technical or health and safety requirements that they or the regulatory agencies, may request. There is no information available on what early termination arrangements might have been included in the contracts – or whether there is a `iron-clad' guarantee that France will accept all of the spent fuel from the proposed new reactor.

Conditioning

4.9 Serious questions remain over whether or not all the spent fuel from the proposed new reactor will go for reprocessing overseas. There remains a possibility that some of it, if not all, will stay in Australia and will be `conditioned' here. This matter has already been raised by ANSTO, which has itself previously raised the possibility that the reprocessing plants currently operating might not remain open to receive spent fuel over the life of the proposed reactor. If the spent fuel remains in Australia for conditioning it will have major costs implications for the new reactor.

4.10 Conditioning is the partial reprocessing of spent fuel where the fuel rods are dissolved, the mixture changed in some way and then resolidified. In reprocessing uranium and/or plutonium are separated from the fission product waste. Conditioning is not banned in Australia. The Committee which previously examined the ARPANSA legislation recommended that conditioning be specifically banned, but the final legislation was mute on the subject.

Contingency plans

4.11 ANSTO appears not to have a contingency plan in the event that current waste disposal proposals do not proceed. It is not clear whether ANSTO might resort to conditioning spent nuclear fuel in Australia if reprocessing contracts fail.

4.12 There is no guarantee that the La Hague reprocessing facility will remain open over the coming 50 years to receive spent fuel for reprocessing. ANSTO had previously contracted with BNFL for reprocessing of waste at the Dounreay facility, but this contract was subsequently cancelled after that plant ceased accepting foreign waste.

Proposed National Radioactive Waste Dump

4.13 Questions should be asked over the planned national nuclear waste dump for the disposal of low-level waste (LLW) and short-lived intermediate level waste (SLILW) in the Billa Kalina region in South Australia. This plan is opposed by the Aboriginal people of the region. There is also increasing opposition from State political parties and national and regional environment groups to this proposal.

4.14 It should not be assumed that the Government's plans for nuclear waste and spent fuel disposal will proceed unchallenged. Experience in other countries show that there are significant environmental, technical, financial, social and political hurdles to overcome in establishing nuclear waste disposal sites. There are many cost implications if the current proposals do not eventuate.

Senator N Stott Despoja

Footnotes

[1] Submission No.21, Attachement A, Submission by the Australian Academy of Science to the Research Reactor Review (Revised for the Senate inquiry), February 1998, p3.

[2] Evidence, p.E149.

[3] Evidence, p.E318.

[4] Professor Barry Allen, Evidence, p.E103.

[5] Submission No.6, p3.

[6] Evidence p.E178.

[7] Submission No.6, p3.

[8] Michael Priceman, Evidence, p.E57.

[9] Submission No.29, Attachment A, p31.

[10] Submission 1B, p5.

[11] Submission No.3.

[12] Submission 7C, Attachment: The New Reactor: National Interest & Nuclear Intrigues, p4.

[13] Research Reactor Review, para 11.6.

[14] Research Reactor Review, Recommendation 11.7.

[15] Submission No.27, p5.

[16] ANSTO, Submission No.29, p26.

[17] Submission No.8, p8.

[18] ANSTO booklet, Managing Radioactive Wastes and Spent Reactor Fuel, p5.

[19] Former Senator Karin Sowada (Australian Democrats, NSW) asked a number of questions and was involved in a number of Senate debates on this issue during the passage of an ANSTO legislation amendment in 1992.

[20] Caldicott, Evidence p.E164.