Appendix 5
PROPOSAL BY THE AUSTRALIAN NUCLEAR SCIENCE AND TECHNOLOGY ORGANISATION
TO CONSTRUCT AND OPERATE A REPLACEMENT NUCLEAR RESEARCH REACTOR AT THE
LUCAS HEIGHTS SCIENCE AND TECHNOLOGY CENTRE
ADVICE AND RECOMMENDATIONS
UNDER PARAGRAPH 9.3.1 OF THE ADMINISTRATIVE PROCEDURES UNDER THE ENVIRONMENT
PROTECTION (IMPACT OF PROPOSALS ACT) 1974
It is recommended that the above proposal be implemented in accordance
with the following conditions.
ANSTO commitments and undertakings
1. The construction and operation of the proposed reactor at the Lucas
Heights Science and Technology Centre (LHSTC) must be in accordance with
the undertakings and commitments provided by the Australian Nuclear Science
and Technology Organisation (ANSTO) in the Final Environmental Impact
Statement (Replacement Nuclear Research Reactor, 1997/98, Volumes
1, 2 and 3), and as summarised in Chapter 18 of Volume 3. If there is
conflict between the ANSTO undertakings and the recommendations below,
the recommendations will take precedence.
Construction environmental management plan
2. ANSTO must prepare a construction environmental management plan (EMP),
to the satisfaction of the Minister for the Environment and Heritage,
prior to construction commencing. The EMP will address all commitments
and undertakings made by the proponent for environmental management during
construction, and as summarised in Chapter 18 (Volume 3) of the Final
Environmental Impact Statement. The following associated recommendations
must also be addressed:
- an Erosion and Sedimentation Control Plan must be prepared as part
of the EMP. Measures proposed to be implemented must be referred to
the NSW Environment Protection Authority (EPA) and the NSW Department
of Land and Water Conservation for comment prior to their adoption in
the EMP. The Plan shall conform with the principles and objectives of
the following NSW EPA handbooks:
- Managing Urban Stormwater: Treatment Techniques 1997;
- Managing Urban Stormwater: Soils and Construction 1998; and
- Managing Urban Stormwater: Source Control (draft release 1998);
- a Remedial Action Plan must be developed, as part of the EMP, in accordance
with NSW EPA guidelines for the treatment of hydrocarbon-impacted soil.
Any requirements for off-site disposal of contaminated soils must be
to the satisfaction of the NSW EPA;
- an Air Quality Management Plan must be prepared, as part of the EMP,
in consultation with the NSW EPA and the NSW Department of Land and
Water Conservation. A primary objective of the Plan will be to ensure
that particulate levels at the nearest residence are below 50 g m-3
(PM10) during construction works;
- appropriate works must be installed to protect the identified Aboriginal
shelter site (PAD 1) from construction water run-off and sediment. Provision
will be made in the EMP for liaison between the proposed ANSTO EMP Environmental
Officer and the NSW National Parks and Wildlife Service concerning environmental
management in the vicinity of the site, if required;
- a Noise Management Control Plan must be prepared, as part of the EMP,
with the objective of ensuring that noise impacts to the public are
minimised. The Plan must be prepared to meet NSW EPA requirements;
- the EMP must include a comprehensive monitoring program to ensure
that run-off and discharges from the construction site meet nutrient,
sediment and other surface water quality criteria for protection of
the environment. At least 12 months baseline data must be collected
prior to construction works commencing. The program will include measures
to be implemented should acceptability criteria be exceeded; and
- a program of groundwater monitoring must commence at least twelve
months prior to construction commencing. This program will be detailed
in the EMP. Prior to construction commencing, an independent report
reviewing the results of the program and requirements for further monitoring
during construction and operation of the reactor must be prepared (see
also Recommendation 11 below). This report must be submitted to the
Australian Radiation Protection and Nuclear Safety Agency (ARPANSA)
and the Department of the Environment and Heritage for agreement.
Other construction issues
3. ANSTO must consult with the NSW Roads and Traffic Authority to determine
if upgrading of the intersection between New Illawarra Road and the LHSTC
entrance is needed, in particular extension of the southbound deceleration
lane. Any works required will be completed prior to construction commencing
and at ANSTO's expense.
Operational impacts (non-radiological)
4. Monitoring of water quality must continue into the operational phase
until sufficient data has been collected to indicate that the site, and
stormwater run-off, has stabilised.
5. A Stormwater Control Plan must be developed during the design stage
to ensure that the site system is constructed to current best practice
and in accordance with NSW EPA guidelines. The plan will also consider
options for containment of one-off larger volume spills, such as fire
fighting foams. The plan must be prepared to the satisfaction of the Department
of the Environment and Heritage.
6. ANSTO must review the Lucas Heights Buffer Zone Plan of Management
(1986), in consultation with relevant stakeholders, to ensure measures
required for the protection of the environment during the construction
and operation of the proposed replacement reactor are implemented, and
to ensure that the biological and conservation values of the buffer zone
are maintained. The revised plan must be prepared to the satisfaction
of the Department of the Environment and Heritage.
Site emissions and monitoring
7. Radioactive gaseous emissions discharged via stacks from buildings
associated with radiopharmaceutical production (primarily Buildings 23
and 54) must not increase above existing levels regardless of any future
production increases. This requirement should be recognised by ARPANSA
as part of its licensing of emissions from radiopharmaceutical facilities
at the LHSTC. The objective of this approach is to ensure implementation
of existing and emergent technologies to further contain or reduce such
emissions.
8. ANSTO, in consultation with ARPANSA, should re-examine the issue of
coordination and timing of processes which give rise to gaseous emissions
from stacks with a view to minimising the impacts of radioactive gaseous
discharges, to the extent practicable.
9. A review of the method of molybdenum-99 production process must be
undertaken by ANSTO, in consultation with ARPANSA, to investigate means
whereby the isotope can be produced and isolated with decreased releases
of subsidiary radioactive waste products. This should be completed to
the satisfaction of ARPANSA.
10. A high priority must be given to the review and licensing of radioactive
waste discharges to sewer by ANSTO. As part of this, ANSTO should be required
to undertake further assessment and analysis to ensure that all possible
exposure pathways and future events at the Cronulla Sewage Treatment Plant
are taken into account. Monitoring and assessment of individual discharges
within the LHSTC is also desirable, to enable understanding of the various
sources and their relative contributions. This assessment must be prepared
to the satisfaction of ARPANSA and prior to reactor operations commencing.
11. As part of the groundwater monitoring program (see Recommendation
2 above), ANSTO must establish bores at appropriate locations in the LHSTC
and the buffer zone to ensure coverage of contaminants from the site overall
and aquifer flows downstream of the proposed reactor. The locations and
monitoring regimes must be agreed with ARPANSA.
12. ANSTO must consult with ARPANSA with a view to establishing a radiological
site characterisation, or 'footprint' for the reactor site and LHSTC/buffer
zone in general. The objective of this characterisation is to provide
a fundamental basis for ongoing radiological monitoring programs and the
detection of radiological trends over time. The current radiological monitoring
should be reviewed on the basis of the site characterisation. The characterisation
and monitoring review must be completed prior to commissioning of the
proposed reactor.
Hazards and risks
13. The Preliminary Safety Analysis Report (PSAR), to be prepared at
the detailed design stage, must be subject to independent peer review
to the satisfaction of ARPANSA.
14. The assumptions used in deriving the Reference Accident effectively
constitute design parameters for the proposed reactor and must be incorporated
in the final design to the satisfaction of ARPANSA. In the event of changes,
such that the Reference Accident examined may no longer be valid, agreement
to any major design changes must be sought from the Minister for the Environment
and Heritage prior to design finalisation.
15. The PSAR must demonstrate that the design of reactor components (eg
reactor pool, beam tube penetrations) effectively excludes the failure
of these components for earthquakes of lower frequency than the design
basis earthquake, to rule out a fast loss of coolant accident as a credible
incident. This will need to be demonstrated to the satisfaction of ARPANSA.
16. The consequences resulting from loss of off-site electricity for
water supply and fire fighting purposes must be examined as part of the
PSAR. If risks are significant, on-site power provisions for water pumps
should be provided to the satisfaction of ARPANSA.
17. The safety implications of an inter-linked store for spent fuel elements
must be assessed in detail in the PSAR, to the satisfaction of ARPANSA.
18. The final design of the reactor should include a fixed and possibly
automatic fire suppression system within the containment building, to
the satisfaction of ARPANSA. The PSAR should also examine the need for
a drencher system for the cooling towers.
19. The risk of a common mode failure involving both HIFAR and the replacement
reactor during the commissioning period, and resourcing requirements to
ensure adequate infrastructure and staffing safety, must be addressed
as part of the PSAR to the satisfaction of ARPANSA. The results of the
PSAR analysis should also be reflected in emergency plans.
20. In the event of dual operation occurring for a longer period than
six months, ANSTO must obtain separate approval and authorisation from
ARPANSA. This authorisation should specify safety, infrastructure and
occupational requirements to ensure that doses are minimised during any
extended commissioning period.
21. The Safety Analysis Report for the reactor must include provision
for ongoing monitoring and audit of the frequency and severity of external
events to ensure that assessed risks to the replacement reactor remain
valid and acceptable, taking into account new developments in the vicinity
of the reactor over time.
Emergency management plan
22. Existing emergency plans and arrangements must be updated and subject
to independent review at the detailed design stage and prior to the proposed
reactor becoming operational. This must be completed to the satisfaction
of ARPANSA. The independent review of the plans should include opportunities
for input by relevant State emergency agencies and the general public.
23. The emergency management plan must also include a specific plan aimed
at facilitating community understanding of credible hazards and risks
from the reactor, mitigation measures, emergency arrangements and implications
for the community. The plan should consider the best combination of media
to achieve the above objectives. The plan must be prepared to the satisfaction
of the Minister for the Environment and Heritage, in consultation with
the Minister for Industry, Science and Resources and the Minister for
Health, prior to the reactor being commissioned.
Community consultation
24. ANSTO must develop a specific program for ongoing community consultation
and dissemination of information during the design, construction and commissioning
phases of the reactor, to the satisfaction of the Minister for the Environment
and Heritage.
25. A high priority must be given by ANSTO to finalising a 'Community
Right to Know Charter' between ANSTO and the community. This charter,
as a minimum, must establish principles for information exchange, the
obligations of parties in providing and using information, timely mechanisms
for dispute resolution, and a process for periodic review and update.
The use of a recognised mediator to facilitate completion of the charter
should be considered. If a charter has not been agreed within 12 months
of the date of these recommendations, the outstanding issues of dispute
should be referred to the Minister for the Environment and Heritage for
resolution, in consultation with the Minister for Industry, Science and
Resources and the Minister for Health.
Nuclear wastes
26. Reactor construction should not be authorised until arrangements
for the management of spent fuel rods from the replacement reactor have
been demonstrated to the satisfaction of ARPANSA and the Minister for
the Environment and Heritage.
27. The Minister for Industry, Science and Resources and the Minister
for Health should give timely consideration to strategies for the long
term management and eventual permanent disposal of Australia's long-term
intermediate-level nuclear wastes, and associated issues.
ANSTO environmental management system
28. ANSTO must continue, as a high priority, to review and upgrade its
environmental management systems (EMS) to achieve ISO 14000 standards.
The EMS should be certified by a suitably accredited independent body
and be in place prior to the replacement reactor being commissioned.
Compliance with commitments and recommendations
29. ANSTO must report to the Minister for the Environment and Heritage
on measures taken, or to be taken, to implement the above recommendations,
including the undertakings and commitments referred to at Recommendation
1. This is to be done by way of an initial written report to the Minister
prior to construction commencing and thereafter at six monthly intervals
until all recommendations have been addressed to the satisfaction of the
Minister for the Environment and Heritage. These reports must be made
publicly available by ANSTO, following their acceptance by the Minister.